Albian Sands Energy Inc. Muskeg River Mine Expansion Project Supplemental Information Request
EUB Application No. 1398411
Alberta Environment EPEA Application No. 004-20809 Water Act File No. 60330
October 24, 2005
1 TABLE OF CONTENTS
CONSULTATION...... 4 GENERAL...... 4 SOCIO-ECONOMIC...... 5 PROJECT INTEGRATION...... 6 RESOURCE BASE ...... 10 MINING...... 11 ORE PROCESSING ...... 18 Ore Prep ...... 18 Solvent ...... 19 Extraction...... 21 WATER MANAGEMENT ...... 29 TAILINGS MANAGEMENT ...... 29 UTILITIES...... 40 AIR...... 41 Emissions ...... 41 Ambient Air Concentrations...... 44 Modelling...... 46 Emissions Management ...... 50 Ecological Effects ...... 51 Regional Management ...... 53 AQUATICS ...... 54 Water Intake and Infrastructure ...... 54 Fish and Fish Habitat ...... 56 Water Quality and Pit Lakes...... 60 Hydrology ...... 64 Hydrogeology ...... 68 Dam Safety...... 76 Navigable Waters...... 77 TERRESTRIAL...... 77 Gravel Resources ...... 77 Historical and Archeological Resources...... 79 Project Description, Layout, and Footprint...... 80 Terrain and Soils...... 82 Closure, Conservation and Reclamation Plan...... 85 Vegetation and Wetlands ...... 93 Wildlife and Biodiversity...... 99 HEALTH...... 106 General...... 106 Human Health ...... 107 Wildlife Health...... 110 Hydrogeology ...... 110 Surface Water...... 111 Traditional Land Use and Resource Use ...... 111 Socioeconomics ...... 112
2 ERRATA...... 113 APPENDIX A...... 116
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CONSULTATION
1. Describe what public consultation has been undertaken since the applications were filed, including the issues that have been identified, how these issues have been resolved, outstanding unresolved issues, and how Albian Sands plans to resolve these remaining issues.
2. Volume 1, Section 1.3, Page 1-19. Albian Sands states, “Shell and Albian Sands support, and are committed to working with regulatory agencies and regional stakeholders to facilitate responsible development, focused on resource conservation, environmental protection and the enhancement of regional socio-economic opportunities. a. What are Albian Sands’s intentions with respect to the identification and preservation of aboriginal heritage sites on the Muskeg River Mine Lease areas?
3. Volume 1, Section 1.3, Page 1-19. Explain in detail the efforts that Albian Sands has undertaken to develop “agreements with neighbouring lease holders to minimize resource sterilization and to facilitate economic recovery of bitumen along lease boundaries”.
4. Volume 1, Section 16.10, Page 16-45. Albian Sands states, “Albian Sands also consults with Aboriginal representatives at the Reclamation Working Group (RWG) on reclamation and at the Sustainable Ecosystem Working Group (SEWG) on terrestrial management systems.” a. How does Albian Sands perceive Aboriginal groups receive this consultation? b. Do the Aboriginal groups have a preferred venue for consultation?
GENERAL
5. Having regard for the application to renew the 10 year (Environmental Protection and Enhancement Act) EPEA and Water Act Approvals, review the current approvals for the Albian Sands Muskeg River Mine (MRM) and provide Albian Sands's view on the continued applicability of the clauses, indicating whether there are clauses that Albian Sands feels should be removed, modified, or should remain as is. Provide Albian Sands's basis for any recommendations.
6. Volume 1, Section 2.4, Page 2-12. Albian Sands states, “About 8,500 m3/h is being recycled from the tailings settling pond to the process. The objective is to maximize the use of reclaim water to reduce the volume of makeup water intake from the Athabasca River. The raw water system has met or exceeded design expectations.” Discuss the opportunities to increase the volume of recycled water used in this expansion.
4 7. Volume 1, Section 2.4, Page 2-12. Albian Sands states, “The on-site, Class III industrial landfill continues to be used for solid waste disposal.” In the paragraph following this, Albian Sands references a Class II landfill. a. Does Albian Sands have both a Class II and a Class III landfill? b. If so, what is the life expectancy of the Class II landfill? c. What is the life expectancy of the Class III landfill?
8. Volume 1, Section 4.1, Page 4-3. Albian Sands states, “water requirements for the drilling program are estimated at an average of 8m3 per hole. The drilling mud is water-soluble and an environmentally acceptable tar mud type. Bentonite and barite drilling muds are used if adverse hole conditions arise that require well control. All drill cuttings and fluid collected from the drilling mud pit are transported by vacuum truck to the Albian Sands mine site’s external tailings disposal area. Volumes of drilling waste are recorded and submitted weekly to the Albian Sands environment department.” a. Does Albian Sands have approval to dispose drilling muds in its tailings disposal area? b. If not, is Albian Sands requesting approval to dispose drillings muds in its tailings disposal area?
SOCIO-ECONOMIC
9. Volume 1, Section 17.3, Page 17-9. Albian Sands indicates “that the urban population by 2015 is expected to reach 76,100 people for the base case; 79,100 for the application case; and, 98,000 people for the planned development case.” Albian Sands further indicates that the urban population will reach 99,400 in 2011 under the planned development case. Volume 1, Section 7.2.5.4, Page 7-18. Albian Sands indicates that “demand on municipal infrastructure and services will increase, generally in advance of the growth in the assessment base.” Volume 4, Section 7.7.15.3, Page 7-287 also states “the RMWB is facing a shortfall between its needs in terms of infrastructure and what it can finance from its own means and through support from senior levels of government.” a. Provide additional comment on the capacity of municipal infrastructure to accommodate the expected population growth, particularly with respect to water, sewer and land that is ready for residential development. Given the expected shortfall in revenues, clarify what the municipality has indicated was its ability to respond to these growth pressures.
10. Volume 1, Section 17.3, p. 17-10. Albian Sands states that “the level of activity for the planned development case will increase the camp population to 10,000 workers in 2007 and as high as 17,000 workers in 2010.” a. Provide additional information on how a camp population of 17,000 workers will impact health services, especially hospital emergency room services. In particular, outline any steps that have been taken either by the Northern Lights Regional Health Authority (NLRHA) or Government following the previous
5 construction peak to address/reduce the pressure points experienced in health services (when workers in construction camps peaked at about 8,560). b. Provide additional detail about what the NLRHA and with the Fort McMurray Medical Staff Association have indicated was their ability to respond to the expected peak in construction workforce and, in turn, the expected increased demands on health services.
11. Volume 1, Section 17.3, p. 17-12. Albian Sands suggests, “if the population growth in the urban area is in line with the forecast in the planned development case, the number of new dwellings required could reach 13,200 in the 2005 to 2015 period.” Albian Sands also indicates “the Wood Buffalo Housing Development Corporation expects the need for about 2,000 additional units for rental and ownership in the 2005-2009 period.” a. Comment on whether there is sufficient serviced land being made available in a timely manner to meet existing and a sustained level of future housing demand?
12. Volume 4, Section 7.7.6, p. 7-240-7-241. Albian Sands states that “changes in the population levels in Fort McKay and the other rural communities in the Wood Buffalo region are related to community related demographic pressures, including ... people leaving the community is search of employment and returning to it, in part to avoid high housing prices in the urban center.” a. Comment on the extent to which housing supply in the Reserve communities is able to accommodate increased demand. Discuss any barriers that may exist that would restrict a supply response to the increased level of demand.
13. Volume 4, Section 7.7.10.3, p. 7-260. The application states that “The three-year capital budgets of the school boards indicate there are a number of facilities in need of renovation and/or expansion. Alberta Infrastructure and Transportation has allocated funds for one new separate school in Timberlea. This leaves a substantial gap in infrastructure requirements as defined by the school boards.” a. Given the timeline required to renovate or construct new schools, comment on whether new school capacity can be added to correspond with the expected increases in enrollment.
PROJECT INTEGRATION
14. Volume 1, Section P.1, Page P-i. Albian Sands states that the Muskeg River Mine Expansion (MRME) “will be integrated with the Athabasca Oil Sands Project.” Volume 1, Section P.1, Page P-ii, Albian Sands also indicates that the Shell Scotford Upgrader located in Fort Saskatchewan is part of the Athabasca Oil Sands Project (AOSP). Further, in Volume 1, Section 1.3, Page 1-19 Albian Sands states, “Shell and Alb1ian Sands support, and are committed to working with regulatory agencies and regional stakeholders to facilitate responsible development, focused on resource conservation, environmental protection and the enhancement of regional socio-economic opportunities.” It is our understanding that Albian Sands is the applicant for this project.
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a. Please clarify the relationship between Albian Sands and Shell with respect to this project. b. Provide a description and diagram that illustrates the legal chain of command and associated responsibilities for the MRME and the AOSP. c. How does the Shell Jackpine Mine fit into the AOSP ownership structure? d. In the Shell Jackpine application, the design work indicated the mining activities would be stand-alone. Is Shell now applying for an amendment to its Jackpine Mine Approval No. 9756? e. If an amendment application will be filed, when will this occur? f. Does Shell intend to be the Operator of Jackpine Mine or will Albian Sands be the Operator?
15. Volume 1, Section P.1, Executive Summary, Page P-ii. Albian Sands indicates in the project schedule that construction of the new facilities will be completed by Q3 of 2009, with the start-up of the new third train planned for the beginning of Q4 of 2009. Albian Sands also indicates, as one of their process options, (Volume 1, Section 12.1, Page 12-2) that “the MRM expansion’s new froth treatment facility” will be used “as an initial outlet for the Jackpine Mine froth.” a. Provide an integrated schedule of both projects. b. Provide all process configurations and their options being considered as part of this application. c. When will the final decision be made on the process configuration?
16. Volume 1, Section P.1, Executive Summary, Page P-ii. Albian Sands states “clean bitumen will continue to be sent to the Scotford Upgrader”. a. Does the Shell Scotford Upgrader currently have the capacity to process the bitumen production from MRM debottleneck project (of 180,000 barrels per calendar day (bbls/cd)) plus Jackpine Mine 1st stage development (of 100,000 bbls/cd)? b. If not when will there be sufficient capacity? c. When will the Shell Scotford Upgrader have the capacity to process the additional bitumen production from MRM (including 90,000 bbls/cd from 3rd train) and Jackpine Mine (which includes 100,000 bbls/cd from 2nd stage development) for a total approximately 480,000 bbls/cd? d. What markets exist for bitumen sales outside of the Shell Scotford Upgrader? e. Provide a gant chart for the Muskeg River Mine Expansion development, Jackpine Mine Phase 1 and Phase 2 and Shell Scotford Upgrader Expansions, showing the timelines demonstrating the expected plant additions and modifications as well as production levels and their increases.
17. Volume 1 – Section P.P1 - Page-iii. Albian Sands states, “Market opportunities for crude oil products from the upgrader include: • Feedstock supply for Shell’s Scotford and Sarnia refineries • Refineries in the US Midwest • emerging markets in the US west coast and offshore, including the Far East”.
7 a. Discuss Albian Sands’s plans to maximize the value of the refined product in Canada?
18. Volume 1, Section 1.2, Page 1-8. Albian Sands states, “The lease 90 area also includes part of what is currently Lease 30. This area between Lease 13 and Lease 90, is required by the expansion project for mining, overburden and tailings disposal, and other infrastructure. The bituminous lease rights for this area are held by Syncrude Canada Limited (Syncrude). Shell has an agreement with Syncrude to acquire the portion of Lease 30 applicable to the Syncrude Lease 30 swap area.” Further, our records show Lease 13 is held by Albian Sands Energy Inc., Lease 90 is held by Shell Canada Limited, and Lease 30 is held by Syncrude Canada Limited. a. Clarify whether Albian Sands has the rights to mine all of the oil sands included in the mine plan. b. Explain how these rights have been granted.
19. Volume 1, Section 1.2, Figure 1.5, Page 1-11. The project schedule presented by Albian Sands indicates that site preparation including: clearing, dewatering, and other activities will begin in 2005 prior to the expected regulatory decision. a. Provide a detailed description of the scope of work and areas being impacted by this activity. b. What approvals does Albian Sands have to conduct this site preparation? c. What additional approvals will be required before this work begins?
20. Volume 1, Section 1.4, Page 1-22. Albian Sands states that it is applying for amendments to Approval No. 8512 under the oil sands conservation act. Specifically, Albian Sands is applying for “a modified utility corridor, that includes a bitumen froth pipeline as well as tailings and water pipelines, connecting Muskeg River Mine with Jackpine Mine”. Albian Sands has not applied to the Alberta Energy and Utilities Board (EUB) for pipeline licences to link MRM with Jackpine, as required under EUB Guide 56. Any pipeline connecting leases held by different operators, and located outside of the applicant’s lease boundary requires an approval. a. Will Shell or Albian Sands be applying for the required pipeline approvals? b. When will these applications be filed? c. In Albian Sands’s view how will these changes impact the Shell Jackpine Mine approval? d. What is the impact expected from these changes on the Shell Jackpine project? e. What is the capacity of the bitumen froth pipeline, tailings and water pipelines connecting the two facilities? f. What impact does transferring tailings between the MRM and Jackpine Mine have on the tailings plan (volume, type of tailings placement and timing) for both mine sites end-pit lake designs (size, volume, type of tailings placement and timing), recycle water quality and quantity, containment capacity, and timing of (progressive) reclamation? g. Provide the rationale for the water and tailings transfer pipelines between MRM and Jackpine Mine projects?
8 h. If tailings are transferred between the Shell Jackpine and Muskeg River Mine projects who will be responsible for the tailings and reclamation liability?
21. Volume 1, Section 8.6, Page 8-20, 8-21. Albian Sands states, “Unconverted residue from the Scotford Upgrader will be processed in a solvent deasphalting unit to produce an asphaltene product. If a market for this product is not fully established by the start of the upgrader’s third train operations, the solid asphaltene product, in the form of small pellets (pastilles), will be transported to the Muskeg River Mine for temporary storage while market development occurs.” a. Discuss alternatives to the production of asphaltene at Scotford? b. What is the status of asphaltene market negotiations? c. Discuss the alternatives to shipping asphaltene to MRME? d. What are the proposed alternative asphaltene storage locations other than the MRM? e. Discuss the Life Cycle Valuation Assessment (LCVA) of shipping the asphaltene product to the MRME area for storage while a market for the product is developed? f. Discuss the effect shipping the asphaltene to MRME would have on the economics of marketing the asphaltene? g. How many truckloads per week, for what period of time would be required to transfer the asphaltene to the MRME? h. What effect would the trucking have on the highway traffic between Scotford Upgrader and the MRM? i. Comment on the capacity of the transportation network from Fort Saskatchewan to Fort McMurray to accommodate the increase in truck traffic. j. Has the expected truck traffic been included in Albian Sands’s traffic management studies? k. Have Alberta Transportation and any potentially impacted counties been advised of the potential increase in truck traffic? l. If asphaltene was permitted to be shipped back to the MRME what contingencies would be in place in case the highway is closed between Shell Scotford and the MRME (due to fires, weather, etc.)? m. What are the proposed alternative asphaltene storage locations on the MRM site? n. What methods of containment and mitigation are planned for the proposed asphaltene storage area? o. What options is Albian Sands assessing with respect to seepage? p. Do dust control measures, such as water sprays, change during winter operations? q. Provide a cross section showing the conceptual design of this stockpile. r. What facilities are available at the Muskeg River mine to accommodate the storage and subsequent reclamation of the asphaltene? s. What is the expected recovery of the stored asphaltene? t. Is Albian Sands assuming the liability for the asphaltenes including storage and rehandling associated with recovering bitumen or other resources located below any storage location? u. If an economical market does not develop for asphaltenes, what is Albian Sands’s contingency plan for managing the stored asphaltenes?
9 v. Has Albian Sands considered gasifying this product? w. If not, why not? If it has, what is the status of implementation? x. What is the energy value of the asphaltene and what are the alternatives, pro’s and con’s to the use of asphaltene as an energy source? y. Why is Albian Sands proposing to act as a by-product handling and storage facility? z. Does Albian Sands have waste generator and waste receiver numbers? aa. With the current paraffinic froth treatment process some asphaltene is precipitated out and rejected to the tailings ponds. If Albian Sands is proposing to store solid asphaltenes from the Shell Scotford Upgrader on the MRM site: i. What would the impact be of constructing a deasphalting unit on the MRM site? ii. What are the pro’s and con’s associated with this option?
RESOURCE BASE
22. Albian Sands has indicated that additional drillholes were drilled in the winter of 2004/05 in some areas. Provide updated maps showing the most up-to-date geological interpretation that includes the new drilling. The updated maps should include: • Devonian surface (fig 3-3) • Total Volume to Bitumen in Place (TV/BIP) map (fig 4-3) • Ore thickness isopach (fig 4-5) • Average ore grade (fig 4-6) • Overburden thickness (fig 4-7) • Interburden thickness (fig 4-8) • Pit and Island evaluation (fig 5-1) • Incremental pit limit analysis (fig 5-2) • Final pit limits (fig 5-3)
23. Based on the drill hole data provided in the area of the proposed Jackpine Mine Utility Corridor, between the northeast pit wall of the Sharkbite Pit and Jackpine Creek (approximately 472,700 Universal Transverse Mercator East (UTM E) and 6,346,000 Universal Transverse Mercator North (UTM N)), does Albian Sands believe that the interpretation of the presented data to be conclusive with respect to resource definition?
24. Volume 1, Section 3.2, Figures 3.3 to 3.7, Pages 3-10 to 3-14. Figures 3.3 to 3.7 are missing geological information for the southwestern portion of the External Tailings Disposal Area (ETDA) and extension portion. Provide updated revised figures that include geological information for these areas.
25. Volume 1, Section 3.2, Figure 3.8, Page 3-15. Figure 3.8 shows no overburden survey data locations for Lease 30 Swap area. Provide an update on plans to conduct drilling to investigate this area, especially the ETDA extension portion.
10 26. Volume 1, Section 4.1, TV/BIP, Page 4-8. a. Does Albian Sands believe that the 12 to 1 TV/BIP ratio is still valid at the current market price or the future projected market price of oil? b. Is Albian Sands investigating recovering bitumen outside this 12:1 ratio? c. What is Albian Sands’s position on the major limitations to recovering ore outside the 12:1 TV/ BIP ratio? d. The map is unclear, provide a TV/BIP plan so that the color differences between full numbers are more distinct? e. Has Albian Sands explored the possibility of allowing third party companies to mine the higher TV/BIP areas that Albian Sands does not consider economically viable? f. If so, would Albian Sands consider receiving ore and or bitumen from these third parties?
27. Volume 1, Section 4.1, Figure 4.3, Page 4-9. Figure 4.3 shows pit crest limit in Lease 90 South excludes a significant portion of low TV/BIP along the western side of the lease. Discuss the reasons for this and whether further exploratory drilling is required in this area.
28. Volume 1, Section 4.1, Page 4-13. Albian Sands indicates that three Vulcan block models were used to calculate the bitumen resource for the total application areas and that the resource base maps provided in the application are a blend of the output from the three models. a. Provide a map showing the areas covered by each of 3 geological models. b. How were fringe areas for the maps treated to ensure no loss of accuracy where models were joined?
MINING
29. Volume 1, Section 5.1, Page 5-2. Albian Sands indicates that “A limit to Muskeg River single-pit operation was identified at 245,000 bbl/cd. Therefore, Alternative 3 entails planning for a second small mine in the Lease 90 area, with a capacity of 25,000 bbl/cd.” a. Explain in detail the work that was done to determine the indicated limit for single-pit operation. b. Could additional ore be supplied from the Jackpine Mine to the dry ore crushers at the existing plant instead of from Lease 90 to make up the desired production? c. Typically, the operation of a single pit at a faster rate would be seen as a more efficient way to increase production versus operating separate pits from a total footprint viewpoint. If Lease 90 development were delayed significantly in favor of increased production at the existing or Jackpine Mine pits how would that affect total land disturbance and the total time that land is taken out of productive ecological function? d. Describe the expected additional operational complexity and cost associated with operating mine equipment fleets in separate pits as proposed versus more intensive development in a single pit.
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30. Volume 1, Section 5.2, Evaluating Marginal Areas, Page 5-6. Albian Sands states, “The final pit limit was determined using the following criteria: (a) • A TV/BIP of 12 (b) • 3-D incremental analysis of mining ratios (c) • Geological confidence of drilling data (d) • Effects on streams and rivers (e) • Potential environmental impacts The TV/BIP ratio of less than 12:1 in Interim Directive 2001-7 incorporates the bitumen grade, and accounts for all volumes of material that need to be mined to obtain bitumen. It is applied vertically, to establish the mine floor, and horizontally, to define the mine crest limits.” Illustrate graphically the calculation of how the TV to BIP is applied to define the pit walls?
31. Volume 1, Section 5.2, Tables 5-2 and 5-3, Pages 5-6 and 5-8. Albian Sands states, “Because of the geological complexity, the area between the original Muskeg River Mine’s east and west pits were analyzed in detail (see Figure 5-2). This area is defined by more than 20 drill holes, 9 of which were completed during the 2003–2004 winter drilling program. The pit floor in this area is at the same elevation as the ore bodies to the east and west. However, the mineable ore thins to 20 to 30 m in thickness. Three-dimensional analysis of the north and south edges of the pushback pits’ connection, using mining push backs, and a 3-D evaluation of islands 3 and 4 were completed. Results of this evaluation, listed in Table 5-2, were used to define the final pit limit in this area.” It is acknowledged that a portion of the unit cost for mining is in the development of the pit, roads and infrastructure. a. Given present economics and forecasts, provide an evaluation on a unit cost per barrel to mine these islands out. b. Based on this evaluation, is it economically feasible to mine out these islands? c. Do these islands possess a TV/BIP less than 12? d. Provide the same analysis for the islands in the Sharkbite Mine area.
32. Volume 1, Section 5.2, Figure 5-1, Page 5-7. Figure 5-1 shows an area of TV/BIP less than 12.0 that is larger than pushback 2 and sterilized by the location of Overburden Disposal Area (OBDA) 5. a. Provide the evaluation and analysis as required under EUB Interim Directive (ID) 2001-7 using current costs, future revenue and inflation on an annual basis and summarized into each discount range, for all areas of TV/BIP less than 12.0, that is impacted by the location of OBDA 5. b. Include an evaluation of alternative discard areas including the area adjacent to the south pit wall of the Lease 90 North Pit, in an east-west direction. c. It appears that some of the OBDA 5 waste could be located in this area to free up access to OBDA 5 sterilized reserves. The Canterra Road would have to be routed south to avoid this new OBDA.
33. Volume 1, Section 5.2, Page 5-11. Albian Sands identifies Segments 5 to 8 of the mine pit as being adjacent to Syncrude's Aurora North tailings pond, mine and plant
12 site. a. Provide an adequately scaled plan showing the location of Syncrude's tailings pond, plant site, and mine relative to Albian Sands’s proposed final pit wall position. b. Provide three cross sections showing Syncrude's tailings pond, mine and plant site relative to Albian Sands’s proposed final pit wall, and all major subsurface soil units. The cross section of the mine should include the approximate location and dimensions of the insitu boundary dyke pillar. c. Has Albian Sands conducted any preliminary stability analyses to confirm that an adequate factor of safety exists for all potential failure modes? Provide these analyses and discuss the uncertainties in the analyses assumptions. d. Discuss the potential for additional ore sterilization due to the locations of the pond and plant site areas. Discuss Albian Sands’s confidence that the proposed final pit wall location will not change. e. Does Albian Sands intend to conduct further detailed investigation to assess geotechnical conditions along this boundary? f. Provide the conceptual layout of geotechnical instrumentation that Albian Sands will implement to monitor stability and groundwater conditions along this boundary. g. Has Albian Sands discussed the concept of mining in this area with Syncrude? h. If so, what are the results of these discussions?
34. Volume 1, Section 5.2, Segment 8 to 9, Page 5-12. Albian Sands states; “This expansion application assumes that an in situ oil sands barrier dyke similar to that in Segment 6 to 7, will be left.” The Syncrude-Shell Boundary Study, dated October 30, 1998, Exhibit 11, submitted as part of the Muskeg River Mine Application No. 970588, states “that a single common dyke be established as the long term planning basis for the Aurora Centre/Muskeg River boundary.” Page 2 of this report states, “In the centre Pit area the value of the sterilized ore will always be greater than the incremental cost of building a common dyke, assuming the revenue from this ore will be realized on or about 2025.” Page 20 of this report states, “Case 2 (Common dyke) offers a clear economic advantage over the other 3 cases.” On page 164, line 19 of the Muskeg River Mine Hearing transcripts, Board staff ask a line of questioning to Shell regarding, what would impact the recommendations of building a common centre pit dyke as recommended in the Syncrude-Shell Boundary Study. Page 165, line 20 states, “If everything else is equal, the same cost, same revenues, you have the same displacement between your revenues and your costs, you will get the same answer even if you are one year away from building a dike or 10 years before building a dyke.” EUB Interim Directive 2001-7, Section 3.1, outlines a procedure for evaluating oil sands sterilization as part of a EUB application for a new mine or mine extension. The August 28, 2000 letter to industry identified as foot note 6, in Section 3.1 of this directive states, “Further, once project life is established we don’t think it appropriate to extend the time span by addition of off-project reserves. This is not to imply that a project may not be extended but rather, should an extension be applied for, we would want to ensure the extension would not result in resource sterilization.”
13 a. Explain why Albian Sands has not made reference to the Syncrude-Shell Boundary Study recommendations, provided an update to the study, or provided new information and analysis as required under EUB ID 2001-7, when an entirely different course of action has been applied for. b. Why did Albian Sands base its mine plan for this application on the assumption that an insitu barrier similar to that in Segment 6 and 7 will be left when the approved case is for recovery of all ore at the lease boundary? c. Should the EUB conclude that if this application is not approved all of the ore at the referenced lease boundary segment will be recovered as part of the existing approved operation, whereas approval of this application will result in significant resource sterilization at this lease boundary? d. If all of the ore at the referenced lease boundary must be recovered it is expected that significant changes to dyke construction, overburden/interburden disposal operations, and tailings disposal operations would result. Provide a preliminary design for a common dyke that could be constructed to contain tailings at this lease boundary. What volume of material would be required for construction of this dyke? e. How would the construction of the dyke referenced in part d) affect mine operations and the overall construction schedule? Would Albian Sands have adequate construction material available to construct this dyke in the time when it is needed? f. How would the recovery of the ore at this lease boundary and construction of the common dyke affect tailings operations? Would additional out-of-pit tailings storage be needed in this case? g. Provide an annual material balance showing how this case would be managed. The material balance should show the placement locations for all overburden, interburden, and tailings material. h. Describe all other changes in the proposed operation that would be required to allow recovery of all the ore at this lease boundary. i. Provide the evaluation and analysis as required under EUB ID 2001-7 and Clause 10 (b) of Approval No. 8512, using current costs, future revenues and inflation. The analysis should include an excel spreadsheet showing all activities, costs and future revenue on an annual basis and summarized into each discount range.
35. Volume 1, Section 5.2, Page 5-13 and Section 5.3, Page 5-22. Albian Sands indicates that Segments 14-15 and 17-18 of the mine pit are offset 200 m from Albian Sands’s External Tailings Disposal Area (ETDA). a. Provide a representative cross section through the ETDA and mine showing all above ground structures, the proposed final pit wall limit and all major subsurface soil units. b. Discuss how this offset was established and provide the supporting analyses. c. Discuss Albian Sands’s plans to conduct more detailed geotechnical investigations at this and other critical locations (e.g. area between Syncrude Aurora North Mine and Albian Sands). d. Discuss Albian Sands’s geotechnical monitoring plans for this and other critical locations around the EDTA. Provide the conceptual layout of the geotechnical
14 instrumentation. e. Describe the contingency options that are available if accelerated dyke movements resulting from mining are observed?
36. Volume 1, Section 5-2, Figure 5-4, Table 5-4, Page 5-12 and 5-22. In Figure 5-4 the difference in elevation between the two halves of the dyke is 5.0 metres. OBDA 1 has received EUB approval. While the application for OBDA 2 is currently under review by the EUB, the design is not yet approved. a. Why could Syncrude and Albian Sands not reach an agreement on an identical height? b. Explain whether such agreement be beneficial in terms of final reclamation, reduction in dyke construction requirements, or increase in resource recovery?
37. Volume 1, Section 5.2, Segment 2 to 3 states, Page 5-14. Albian Sands states “A 100 metre setback from Jackpine Creek and a 150 metre utility corridor define this segment.” a. Submit a typical cross section of the setback area similar to Figure 5-6 on page 5- 16 of the Muskeg River Mine Expansion Project Application.
38. Volume 1, Section 5, Figure 5-6, Page 5-16. Elaborate on the viability, risks, pros, and cons of the design illustrated in section B-B of Figure 5-6. This Figure may be visually misleading as presented with the toe of the dyke sitting on a 30 m wide bench in the pit. Provide additional details regarding the design of this dyke?
39. Volume 1, Section 5.2, Segment 9 to 1, Page 5-18. Albian Sands states, “The 12:1 TV/BIP limit defines this segment.” Volume 1, Section 5.2, Page 5-8, Table 5-2, shows Pushback 1 having a 3-D TV/BIP value of 8.5. Which statement is correct?
40. Volume 1, Section 5.3, Page 5-22. Provide an update to Table 5-4 providing proposed resource sterilization estimates based on the newest model. a. Discuss how resource sterilization by construction of overburden disposal areas 3, 4, 5, 6, and 7 could be reduced or eliminated. Include consideration of: • placement of more overburden in-pit, • increasing the final elevation of in-pit cells; • greater integration with Jackpine mine overburden and tailings management plans, • potential off-lease dump sites, • rehandle of OBDAs at a future date to allow recover of underlying resource. b. What would the TV/BIP ratio be for the resource underlying each of the OBDAs after they are constructed to design capacity?
41. Volume 1, Section 5.3, Page 5-21 and Figure 5-23 Page 5-23. Albian Sands states that an expansion to the existing tank farm is required to support the expansion project. However Figure 5-9 shows a new Tank Farm location.
15 a. Provide a map showing details of the existing plant site, areas of plant expansion, existing tank farm, new tank farm, utility corridor, Jackpine Creek, Muskeg River and a colour fill of areas of TV/BIP 12.0 or less. This map is intended to zoom into the area from the existing plant site to segment 2 to 3 as shown in Volume 1, Section 5.2, Page 5-10, Figure 5-3. b. Provide justification for the new tank farm including why the existing plant site or an expansion of the existing tank farm cannot accommodate storage needs. Include in the justification, the evaluation for Sharkbite pushback 1, the as required under EUB ID 2001-7 using current costs, future revenue and inflation on an annual basis and summarized into each discount range.
42. Volume 1, Section 5.3, Figure 5-9, Page 5-23. Figure 5.9 shows facility locations and resource sterilization areas. a. Why is the south extension of the ETDA not included as an area of resource sterilization? b. Provide an estimate of resource sterilization that would be sterilized by the extension.
43. Volume 1, Section 5.4, Page 5-26. Albian Sands indicates in Table 5-6 that a swell factor for overburden and oil sands of 10-20per cent has been used as mining criteria. Provide the swell factor that was used for each overburden/interburden disposal location.
44. Volume 1, Section 5.4, Table 5-7, Page 5-26. Albian Sands shows the design criteria for overburden disposal areas as having a maximum height of 60 m and overall slope of 4:1. Also, Section 5.6, Page 5-54 indicates that 10 m lifts would be used during construction (depending on the fill strength and subsurface drainage). a. Discuss why Albian Sands believes these criteria will achieve a stable structure and how foundation conditions and pit wall interaction have been considered? b. Provide preliminary stability analyses to support comments (in a. above). c. Discuss how these criteria will provide for stable structures for future end-land use. d. Is it possible that determining storage capacity based on these criteria could be somewhat optimistic if poor foundation conditions exist, and could result in reduced storage capacity, increased in-pit dumping (lost in-pit pond storage capacity)? e. If so, explain the significance of any potential impacts on storage capacity due to these conditions. f. Provide a discussion on Albian Sands’s experience at MRM at OBDA 1 and 2 relative to this criteria and the known fill properties, foundation drainage and strength characteristics and observed dump performance. g. Will Albian Sands conduct detailed geotechnical designs for each of the disposal sites prior to construction?
45. Volume 1, Section 5.4, Table 5-8, Page 5-27. Albian Sands provides the typical thicknesses for the various subsurface soil units in the development area.
16 a. Based on Albian Sands’s experience at MRM, which of these units present the most geotechnical challenges? b. Given that these units have significant impact on pit wall, overburden dump and dyke designs, will Albian Sands be conducting detailed geotechnical investigations to define the extents and assess the properties of these deposits. c. Discuss Albian Sands’s confidence in characterizing the strength and pore pressure response of these units and in being able to predict their behavior under various loading/unloading conditions.
46. Volume 1, Section 5.5, Page 5-30. Table 5-9 provide overall production schedule for the project. Provide the same information broken down into the four different mining areas (Muskeg River Mine, Sharkbite, Lease 90 South, and Lease 90 North).
47. Volume 1, Section 5.5, Table 5-9 - Mine Production Schedule, Page - 5-30. The provided production table does not provide enough information to perform any definitive checks of the tailings plans provided. In addition to the information contained within Table 5-9, provide the following by year.
CONNATE MINERAL FINES COARSE WATER TV to BIP
% wt of mineral % wt of mineral Mt Mt
48. Volume 1, Section 5.5, Table 5-10, Page 5-33. Table 5-10 shows OBDA 5 becomes active beginning in year 2012. Volume 1, Section 3.3, Page 3-21, Figure 3-10, shows that granular resources lie beneath OBDA 5. a. What is the schedule for removal of this resource in terms of years? b. Provide an updated assessment of the bitumen resource in this area after the granular material is removed?
49. Volume 1, Section 5 - Period from 2010 to 2012, Page 5-38. Albian Sands states, “Lease 90 mining will be completed to the south limit and the active mining face will progress northward. Ore will be hauled to the existing crusher stations near the Muskeg River Mine plant site.” The chosen mining direction of Lease 90 appears it will result in greater haul distances earlier in the project. Elaborate on the pro’s and con’s of the chosen mining direction (i.e., does this allow for progressive reclamation?).
50. Volume, Section 5.5 - Road Surfacing, Page 5-54. Albian Sands states “road surfacing gravel will be obtained from the Susan Lake and Muskeg River granular deposits. The gravel will be screened and crushed, then hauled to suitable stockpile sites at Muskeg River Mine. Wherever practical, gravel will be reclaimed from temporary mine roads as mining progresses. Trucks are presently the major method of transporting ore and for the foreseeable future play a major role in the oil sands industry.
17 a. With available gravel supplies being scarce and the hazards associated with wet icy haul roads what road construction and gravel alternatives research is Albian Sands conducting or planning to conduct to improve productivity and safety? b. Further, it is becoming increasingly more evident that heavy hauler tire availability might be a major concern to the mining industry worldwide. What effort is Albian Sands involved in that may address this issue? c. The shale layer that is often found in the upper McMurray may be of use as a road construction material. Please outline what efforts the applicant has made to salvage this resource and if no effort has been made what steps is Albian Sands going to take to salvage and incorporate this material in their road building practices.
ORE PROCESSING
Ore Prep 51. Volume 1, Section 2.2, Crushing and Conveying, Page 2-5. Albian Sands states, “although the crushers have met and exceeded design capacity during summer conditions, work is ongoing to full realize design capacity during severe winter conditions.” a. What work is ongoing to fully realize the design capacity of the crushers during severe winter conditions? b. What impact, does increasing the capacity of crushers have on rejects losses?
52. Volume 1, Section 2.2, Sizing and Conditioning, Page 2-5. Albian Sands states, “Material flow characteristics in the silo and reclaim conveyors have resulted in either reduced material flow rates or blockages from compacted material. Air and heat have been added to improve flow characteristics over a wider operating range. Generally, the system has functioned within acceptable design parameters.” a. What was the reasoning behind the decision to use a silo and what are your plans to improve this flow through the silo? b. How does the current silo design throughput compare to design expectations? c. What additional improvements if any will be required and when will they be implemented? d. Is the decision to use surge silos/bins versus surge piles related to the overall heat balance of your process? Explain.
53. Volume 1, Section 5.5, Figure 5-13: Crusher Conveyor Locations and Timing - Page 5-32. Major Crusher moves have not been proven as yet in the Oil sand industry. a. Elaborate on how Albian Sands intends to relocate the crusher (i.e. plan, schedule, timing and potential risk factors) as it affects the viability of the MRME plan as a whole. b. Illustrate the hydro transport layouts for location 4 and 3 back to the plant site and the crossing of the Muskeg River. c. What is Albian Sands’s fallback position if relocating the crusher proves to be unfeasible and how will this impact the MRME plan?
18
54. Volume 1, Section 6.2, Ore Processing, Page 6-6. The peak capacity of the expanded ore preparation facilities will be 36,000 t/h of mined oil sands and yet in Table 5-5: Project Planning Criteria, the peak mine production of 28,000 t/h. Clarify the reason for the difference.
55. Volume 1, Section 6.2, High-Capacity Ore Feed, Page 6-5. Albian Sands states, “A second high-capacity ore feed and size reduction system that matches a large scale, truck-and-shovel operation will provide feed to the expanded plant. The new ore feed system will consist of two relocatable, double-roll crushing plants, each rated at 14,000 t/h. The crushing plants will be used to reduce the ore to less than 400 mm for transportation by conveyor to a 10,000-t, steel surge bin.” Provide a diagram that illustrates the production capability of the ore preparation facilities up to and including the breakers before and after the expansion additions. This diagram should include the t/h capability of each piece of equipment within the preparation process.
Solvent
56. Volume 1, Section P.1, Executive Summary, Page P-i. Albian Sands indicates that “the process configuration of the new facilities is the same as that used at the existing Muskeg River Mine” with bitumen extraction in Primary Separation Cells (PSCs), primary and secondary flotation, froth clean-up using the paraffinic solvent counter- current decantation (CCD) froth treatment process and solvent recovered from froth treatment tailings using a tailings solvent recovery unit (TSRU) similar to the existing plant at Muskeg River Mine. a. Provide a description of the performance at bitumen extraction, froth clean-up and TSRU since start-up on a monthly basis to present and compare to the design case. b. Explain any deviations from design and any improvements planned/required for bitumen losses and solvent recovery from tailings.
57. Volume 1, Section 6.2, TSRU System - Debottlenecking, Page 6-15. Albian Sands indicates the debottlenecked TSRU system will operate with two first-stage columns and a common second stage column that operates under a partial vacuum. In Volume 1, Section 6.2, Page 6-17 Albian Sands states, “Solvent recovery from the new TSRU will be in excess of 99%. The residual solvent loss will meet or exceed the target of four units of solvent per 1,000 units of dry bitumen.” a. What is the current percentage of solvent recovery from the froth treatment tailings in the TSRU on a monthly average (start-up to current)? b. What is the current percentage of solvent recovery from the froth treatment tailings in the TSRU on an annual average basis (for 2004, and to date for 2005)? c. What are the volumes of solvent losses to the tailings pond per 1,000 volumes of dry (whole) bitumen on a monthly basis from start-up to present? d. What are the volumes of solvent losses to the tailings ponds, on an annual average basis: for 2004, and to date for 2005, per 1,000 units of dry (whole) bitumen?
19 e. What volumes of untreated froth treatment tailings have been directed to the tailings pond? f. What testing has Albian Sands done with modifying the preheating and pumping systems and using the above configuration that confirms an overall solvent recovery in excess of 99 per cent with solvent losses to tailings of less than 4 volumes /1000 volumes of dry (whole) bitumen can be achieved? g. What are the contingencies if losses are higher? h. Why are two second-stage columns not being proposed? i. In consideration of your answers to the above questions, does Albian Sands remain convinced its technology selection is appropriate?
58. Volume 1, Section 2.2, Froth Treatment, Page 2-7. Albian Sands states, “the solvent concentration in third-stage underflow has been above design targets. Process options are being studied to reduce the solvent content in the third-stage underflow from the settlers. Through modifications and improvements to the design of the TSRU, solvent recovery is expected to achieve design rates by the end of 2006. The plan to incorporate these modifications has been reviewed with the EUB.” a. What are the current solvent concentrations in the third-stage underflow and how does it compare to design? b. What is the current throughput in the third-stage underflow and how does that compare to design? c. What challenges/problems have been encountered with the counter-current decantation circuit (settlers) operation that Albian Sands is not currently achieving design rates? d. How are these challenges being addressed by Albian Sands, to assure the regulators that the company can achieve the performance indicated in this application? e. What is the impact of the current solvent losses to the tailings pond as a result of the above design limits? f. What process options are being studied and what is the implementation schedule to reduce the solvent content in the third-stage underflow from the settlers? g. Provides the reasons why solvent recovery is expected to take till the end of 2006 to achieve design recovery and rates?
59. Volume 1, Section 6.2, Solvent Recovery; TSRU, Figure 6-9, Pages 6-15/6-17. In Figure 6-9 Albian Sands indicates steam injection upstream of the TSRU column in the feed pipe is similar to the existing operation. a. What has been the past performance of heating froth treatment tailings using this method? b. Has it met the design performance? c. What improvements are planned to improve this performance? d. Has Albian Sands considered a change in design of the TSRU feed stream heating system and/or direct heating inside the column? e. If not, why not?
20 60. Volume 1, Section 6.2, TSRU System – New Train, Page 6-17. Describe the impact if the new train were delayed until the modifications to the existing TSRU confirms that losses of 4 vol / 1000 vol on whole bitumen are achieved?
Extraction
61. Volume 1, Section 2.2, Extraction Plant, Page 2-6. Albian Sands states, “the extraction plant has effectively met production requirements, product quality and recovery capacity. However, the plant requires further modifications to sustain performance at design rates over a broad range of ore grades.” a. What is meant by the statement “…has effectively met … recovery capacity”? b. Is this recovery capacity referring to a recovery efficiency or volume? c. What modifications are required to sustain performance at design rates? d. Albian Sands also indicates, “bitumen recovery has exceeded regulatory guidelines at higher grades”. Provide a comparison of bitumen recovery with the higher grades of oil sands processed with respect to ID-2001-7. e. In 2004 what was the overall bitumen recovery at the MRM plant site with and without asphaltene rejection? f. What was the average grade of oil sands processed? g. What is Albian Sands’s 2003 and 2004 operating performance with respect to overall bitumen recovery as per with EUB Interim Directive (ID) 2001-7 h. Provide the action plan and schedule to meet these requirements? i. What modifications are planned to improve the recovery “over a broad range of ore grades” j. What are the recovery initiatives being investigated for low-quality ores?
62. Volume 1, Section 2.2, Facility Performance; Froth Treatment, Page 2-6. Albian Sands indicates production “rates in excess of 31,800 m3/cd (200,000 bbls/cd) of dry bitumen product have been attained…”. a. What percentage of the time in 2004 and 2005 to date have these rates been achieved? b. What impact has pushing the existing plant throughput to as high as 200,000 bbls/cd (approximately 30 per cent higher throughput than design) had on bitumen recovery performance and solvent loss performance? c. Provide performance data at these throughputs (i.e. grade, tonnage of oil sands processed, bitumen recovery and solvent losses to tailings).
63. Volume 1, Section 2.2, Page 2-6. Albian Sands states, “Tests on various process additives are ongoing.” It is our understanding that the MRM is a non-caustic process and the possibility exists to test process additives that may improve overall bitumen recovery. a. What testing is Albian Sands conducting on process additives to enhance bitumen recovery for low grade, high-clay fines or poor processing ores? b. When are the results of this testing expected? c. What are the current test results of process additives with respect to their ability to enhance bitumen recovery?
21 d. What impacts do these process additives have on dispersing clays in the tailings ponds, tailings management, reclamation, overall water management and water chemistry?
64. Volume 1, Section 2.3, Recovering Bitumen from Thickeners, Section 2.3, Page 2-9. Albian Sands states, “One unexpected result of fines thickening and warm-water recovery has been the release of bitumen in the thickeners. Even though the release of bitumen forms a bitumen layer on the water surface in the thickeners, which provides beneficial heat retention during winter months, the option of recovering this bitumen is being explored.” a. What is the estimated additional bitumen recovery that can be achieved by capturing and cleaning the bitumen released in the thickeners? b. What are the options being explored with respect to recovering the bitumen layer from the water surface of the thickeners, the feasibility of each option and the schedule for implementation of these options? c. What is the potential impact on bitumen froth quality, froth treatment performance and solvent losses if this bitumen is recovered?
65. Volume 1, Section 2.4, Optimizing Utilities; Heat Recovery, Page 2-11. Albian Sands indicates that initial heat integration and heat recovery expectations have not been met due to a number of process issues. a. What impact has this had on bitumen recovery? b. What percentage of the bitumen in the oil sand feed, on an annual basis, is lost to coarse tailings, thickened tailings, rejects and TSRU tailings as a result of insufficient process heat integration? c. How much was the process temperature lowered within primary extraction and froth treatment due to insufficient heat integration? d. What was the increase in process temperature within primary extraction and froth treatment due with the use of temporary boilers? e. How does Albian Sands propose to optimize the process heating system?
66. Volume 1, Section 5.4, Project Criteria, Table 5-5, Page 5-25. Albian Sands states “the new extraction train design was based on an average feed grade of 10.9 wt% bitumen” and yet the mine life average is 10.5 wt per cent and ranges between 9.8 wt per cent and 11.4 wt per cent. a. Provide the rationale for the extraction plant design at a higher feed grade than the mine life average. b. What impact would lower grade oil sands have on a train designed at a higher feed grade being that oil sands tonnage is increased to maintain a constant final product rate? c. What design considerations have Albian Sands given to processing lower grade higher fines ore? d. What contingencies does Albian Sands have in place to ensure bitumen recovery requirements are met with such a variation in oil sands feed quality and quantity?
22 67. Volume 1, Section 6.2 Rejects Handling, Page 6-8. Albian Sands states, “a new rejects handling system will be installed with the mine expansion”. Since the oversize material rejected from the rotary breakers represents a source of bitumen loss: a. Does Albian Sands intend to crush and recycle rejects to improve bitumen recovery? b. If not explain why. c. How much bitumen in the oil sand feed is lost to rejects for the existing facility? d. How do current bitumen losses to oversize rejects compare to the original, debottleneck operation and expansion designs? e. If the bitumen losses to rejects is greater than design what changes are being proposed (i.e. crushing, recycling)? f. What method does Albian Sands use to measure reject bitumen losses? g. What is Albian Sands’s expectation of accuracy with respect to reject loss measurement and how has this been verified?
68. Volume 1, Section 6.2, Primary Extraction Process, Page 6-9, 6-10. Albian Sands indicates that the two existing primary extraction trains were originally designed to produce 75,000 bbls/cd. Albian Sands also indicates that as part of its debottlenecking project a 24.5-m diameter PSC which would contribute to a production increase to 180,000 bbls/cd will be constructed. Further, as part of the expansion a 30-m diameter PSC will be constructed as part of a new train to increase production to 270,000 bbls/cd. a. Once the existing primary extraction trains have been debottlenecked, what is the throughput in each of the two debottlenecked extraction trains once they achieve design performance? b. What modifications to the existing primary extraction trains are required before the design throughput and performance can be achieved? c. What is the design throughput increase attributed to the 24.5-m diameter PSC, and the 30-m diameter PSC respectively and how do they compare to the design throughputs of the PSCs in the two existing trains? d. It seems that the capacity of the two new PSCs contain a considerable amount of spare capacity over the production of 270,000 bbls/cd. Provide the rational for the need for this capacity increase.
69. Volume 1, Section 6.2, New Train, Page 6-10. Albian Sands indicates it will be adding modifications to the middlings withdrawal and injection points on all vessels to improve performance. a. What are the modifications to the middlings withdrawal and injection points on all the vessels? b. How will the addition of the middlings withdrawal impact bitumen recovery? c. What test work has Albian Sands done to confirm the improved performance? d. What are the contingencies if the expected performance is not achieved?
70. Volume 1, Section 6.2, Froth Composition and Treatment, Pages 6-10/6-11. Albian Sands is projecting an average froth quality of 51per cent bitumen, 38per cent
23 water and 11 per cent solids by mass for material balance purposes yet expects the composition of the froth to average 55 to 60 per cent bitumen: a. How do the projected and expected froth quality compositions compare with the existing Muskeg River Mine average froth quality? b. What impact does lowering the projected average froth quality have on: i. Froth treatment capacity? ii. Heat and energy balances? iii. Flow and composition in the TSRU? c. What is the impact of improving this froth quality (i.e. targeting to produce a froth of 60 per cent bitumen, 30 per cent water and 10 per cent solids w/w) have on the bitumen recovery in the froth treatment plant and on solvent loss?
71. Volume 1, Section 6.2, Primary Extraction Process Debottlenecking, Page 6-10. Albian Sands indicates that in order to improve extraction plant performance it intends to install froth underwash on all primary separation cells (PSCs). a. What is Albian Sands’s expected improvement in bitumen recovery, froth quality and solvent losses to tailings associated with adding froth underwash? b. Provide the rationale for this improvement? c. What is the increase in froth temperature from current froth temperatures with the addition of froth underwash? d. What is the impact of increased froth temperature in the froth treatment plant, (i.e. will more solvent chilling capacity be required in the CCD circuit)?
72. Volume 1, Section 6.2, Middlings Stream, Page 6-11. Albian Sands indicates that part of the flotation tails stream will be recycled to primary separation cells (PSC’s): a. What is the purpose of recycling this stream? b. What testing has been done to confirm this purpose? c. Will this stream be used to enhance bitumen recovery and if so how?
73. Volume 1, Section 6.2, Tailings Treatment and Processing, Page 6-11. Accurate and precise measurement and sampling are critical aspects of determining bitumen losses and recovery. a. Describe the present methodology that Albian Sands uses to measure bitumen losses to primary tailings and thickened tailings streams. b. What work has Albian Sands done to independently verify the accuracy of all measurement associated with these streams? c. Provide a comparison of measured to calculated bitumen losses for both the primary and thickened tailings streams?
74. Volume 1, Section 6.2, Page 6-11. Albian Sands indicates that “deaerated froth will be processed to remove trash and solid organic material… by pumping the froth through a battery of linear screens…”. Albian Sands also indicates that in debottlenecking the existing tailings treatment circuit, modifications are to be done on the existing screens, flotation cells and cyclones.
24 a. What are the expected benefits and recovery improvements by pumping froth through the linear screens? b. What percentage of the bitumen in the oil sand feed is lost to the froth screens? c. What modifications will be done to the existing screens, flotation cells and cyclones?
75. Volume 1, Section 6.2, Debottlenecking, Page 6-14. Albian Sands notes, “Circuit performance indicates that the existing process vessels have enough capacity to support the production for the debottlenecked plant.” a. What testing or performance evaluations did Albian Sands use to assess the CCDs circuit performance as adequate to meet the debottleneck rates? b. What were the results of the circuit performance analysis? c. For debottlenecking, what are the modifications to the existing froth treatment circuit equipment? d. What is the present performance and the expected performance after modifications?
76. Volume 1, Section 6.2, Page 6-14. Albian Sands states, “the overall deasphalted bitumen recovery in froth treatment will be over 99%.” a. Is this statement correct? Is this recovery on a whole bitumen basis? b. Provide the current deasphalted bitumen recovery in froth treatment and compare it to design? c. Explain any deviations between the actual and design deasphalted bitumen recovery? d. Provide the current operating asphaltene rejection rate as a percentage of bitumen in the oil sands feed (on a whole bitumen basis) and compare it to design? Explain any deviations from design. e. What is the statistical analysis of asphaltene content found in Muskeg River Mine bitumen? i. Explain any deviations from the original MRM Application. f. In Table 6-1, Bitumen Recovery from Average- Grade Oil Sands, a recovery of 98.5 per cent is shown yet 99 per cent is stated above. Explain the difference.
77. Volume 1, Section 6.2, Tailings Treatment and Processing, Page 6-11. With the possibility of storing asphaltenes from the Shell Scotford Upgrader on the MRM site, rejecting asphaltenes into the tailings ponds may no longer be the best option from a resource recovery perspective. a. What is the status of asphaltene recovery from tailings in light of today’s oil and gas prices? b. What additional research has Albian Sands done on the feasibility of recovery of asphaltenes from tailings? c. Provide the costs to recover this material.
78. Volume 1, Section 6.3, Bitumen Recovery and Product Quality, Table 6-1: Bitumen Recovery from Average-Grade Oil Sands, Page 6-23. It appears that Table 6-1 is based on a grade of 10.5 wt per cent but the text in a couple paragraphs
25 before indicates Table 6-1 is the expected average process recovery at an average feed grade of 10.9 wt per cent bitumen. Please clarify.
79. Volume 1, Bitumen Recovery and Product Quality, Figure 6-11: Bitumen Recovery Versus Plant Feed Grade, Page 6-24. a. Albian Sands indicates in Figure 6-11 that its design bitumen recovery will be 89.7 per cent for a grade of 10.9 per cent while EUB ID 2001-7 requires a minimum recovery of 89.97 per cent. The Muskeg River Mine Expansion Project Extraction design bitumen recovery indicates a significant drop as compared to the EUB Extraction bitumen recovery at the above grade. b. Clarify Albian Sands’s commitment to meet the overall bitumen recovery requirements set out in EUB Interim Directive 2001-7. c. What design changes does Albian Sands need to make to the proposed project to achieve the bitumen recovery requirement in ID 2001-7? d. Why should the EUB approve this expansion if Albian Sands is proposing to not meet the requirements of ID 2001-7 in their application? e. How will Albian Sands demonstrate that they can meet the intent of ID 2001-7?
80. Volume 1, Section 6.2, Page 6-16. Albian Sands indicates that the debottlenecked configuration for the existing TSRU will consist of two first stage columns and one second stage column. a. What is the design service factor for the multistage slurry preheating system? b. What are the critical design criteria for the TSRU? c. What is the design maximum feed rate to the debottlenecked and expanded TSRU facilities? d. Clarify the methods used to arrive at the TSRU efficiency.
81. Volume 1, Section 6.2, Page 6-19. Albian Sands indicates that they will be constructing a new vapour recovery system to capture a majority of the solvent vapours. a. What is the current performance of the vapour recovery system, as compared to design? b. What improvements is Albian Sands proposing for the new vapour recovery system design? c. Will the new vapour recovery system have sufficient capacity to handle any high solvent losses or chiller problems?
82. Volume 1, Section 6.2, Paraffinic Froth Treatment – New train, Page 6-15, 6-25. Albian Sands notes that there may “be the potential to further enhance the process by applying the newly developed, high-temperature froth treatment process in which “a high-temperature froth treatment (HTFT) pilot plant was constructed at CANMET in 2004…” a. What testing has been done on this process? b. Provide a brief description of the test program, testing completed and to be completed, as well as preliminary findings/results. c. What is the next step of HTFT development?
26 d. How soon could the HTFT process be ready for commercial application? e. Will the high-temperature froth treatment process be developed in time for the new froth treatment train? f. Discuss the disadvantages related to using HTFT. g. Discuss the risks associated with these disadvantages.
83. Volume 1, Section 6.4, Froth Treatment Pilot Plant, Page 6-25, 6-26. Albian Sands states that “depending on the final technology evaluation, the froth treatment new train might be changed from the current low-temperature process to the high- temperature process”. Albian Sands indicates that an advantage of the HTFT process is improved energy efficiency “as a result of eliminating the need for solvent chilling.” a. What work has Albian Sands done that would indicate that the HTFT process is less energy intensive than the existing low-temperature process? b. What is the difference in energy intensity between the processes? c. Does Albian Sands currently cool the recycle diluted bitumen stream from the second stage CCD circuit to prevent the solvent flashing over to the vapour recovery unit and to prevent losses to flare/cogeneration? d. If so, why does the high temperature froth treatment process being tested by Albian Sands not require solvent chilling?
84. Volume 1, Section 8.2, Recycle Water, Page 8-4. Albian Sands indicates a cooling tower will be installed to cool recycle water to prevent the recycle pond water temperature exceeding 23˚C. What risks does Albian Sands face if this water temperature exceeds 23˚C?
85. Volume 1, Section 9.1, Material Balances, Page 9-1. Provide a measurement plan for the expanded and new facilities showing the streams to be measured to enable process control and fulfill the requirements for S-23 reporting. Provide a simplified process flow diagram showing these measurement points.
86. Volume 1, Section 9.1, Material Balances, Figures 9-1 and 9-2 Pages 9-3 and 9-4. The balances for both a calendar-day basis and a stream day basis do not balance for the bitumen and solvent components, particularly around the Solvent Recovery Unit (SRU) and the Make-Up Solvent loop. a. Provide corrected material balances both on a calendar-day and stream-day basis for the existing operation, the debottlenecked operation, the expanded operation and the integrated operation with Jack Pine. b. Include the balance for asphaltenes and maltenes in (a) above. c. Provide the asphaltene content in bitumen in these balances. d. Provide the bitumen, solvent and asphaltene densities used.
87. Volume 1, Section 9.1 Material Balances Figures 9-1 and 9-2, Pages 9-3 and 9-4. Based on the oil sand feed rates in these figures it would appear Albian Sands is designing for an overall plant availability of approximately 75 per cent (20,153 tonnes per calendar day (t/cd) / 27,125 tonnes per stream day (t/sd)).
27 a. What is the basis for the selection of the low availability of 75 per cent when industry norms are typically 85 per cent? b. What impact does this have on equipment selection and sizing and therefore project cost and peak production capability? c. If stream day rates are as high as indicated and actual availability closer to 85 per cent will Albian Sands run higher production rates? d. If so what will these new rates be?
88. Volume 1, Section 9.6, Thermal Energy Requirements, Table 9-2: Comparison of Thermal Energy Requirements, Page 9-6. a. Explain the assumptions/ basis of the thermal energy requirements in Table 9-2 and are they the same as in the original Muskeg River Mine Application? b. Explain any deviations from the original design. c. What was the feed grade, bitumen recovery and process temperature used for Table 9-2?
89. Volume 1, Section 9.2, Energy and Heat Balances, Page 9-7. Provide Heat and Energy Balances for the existing operation, the debottlenecked operation, the expanded operation and finally the integrated operation with Jackpine. What assumptions were used?
90. Volume 1, Section 10.4 Water Balance, Table 10-2 Page10-19 and Section 10.5 Water Management, Page 10-21. Table 10-2 indicates total run off from the closed circuit area is 0 million cubic metres (Mm3) (column I3) yet on page 10-21 it indicates that the maximum closed circuit surface diversion is required to increase from 3.83 to 13.1 Mm3/annum (a). a. Why does the maximum closed circuit diversion have to increase when the expected inflow or run off from the closed circuit is zero? b. Could the actual closed circuit run off be captured to reduce river water removal volumes? c. If so by how much? d. Identify the source of the recycle water. e. If the source of the recycle water is consolidated tailings (CT)/non-segregating tailings (NST) provide the consolidation curves and research data used to create the curves.
91. Volume 1, Section 11.1, Waste Management Table 11-1, Page 11-3. Table 11-1 indicates major substances used at the MRM are Methyl Isobutyl Carbinol (MIBC) and Kerosene. a. Is MIBC and Kerosene still used in the current MRM process? b. Will MIBC and Kerosene be used in the expanded MRM production cases of debottlenecked rates and or expansion rates? c. What impact does MIBC and Kerosene have now on bitumen recovery? d. How much MIBC and Kerosene is used in the process now? e. What impact does MIBC and Kerosene have on fine tailings dispersion in the tailings ponds?
28
92. Volume 1, Section 12.1, Muskeg River Mine Integration, Page 12-2. Albian Sands states, “a staged development of the third processing train at Muskeg River Mine will provide the opportunity to further advance new froth treatment processes for inclusion into the Jackpine Mine development.” What new froth treatment processes are being evaluated and what is the present status of each?
WATER MANAGEMENT
93. Volume 1, Section 10.3, Water Management / Use, Page 10-13. The application states that “The maximum annual make-up water requirements for the expanded Muskeg River Mine will not exceed the current Albian Sands Water Act licence allocation of 55.1Mm3/a”. a. What have been the water requirements for the past 2 years? b. Explain how the bitumen production is expected to increase by 1.75 times with oil sands processed nearly doubling and yet no additional water above the license allocation is required?
94. Volume 1, Section 10.3, Athabasca River Withdrawal, Page 10-15. Albian Sands states, “If water diversion quantities from the Athabasca River are constrained for short periods of time during exceptional low-flow periods, process water requirements will be maintained from water inventory in the external in-pit tailings ponds”. a. What is the minimum withdrawal rate required from the river even if constrained? b. How long could Albian Sands operate at design throughputs before the process water inventory would be depleted? c. What are the options Albian Sands has considered and the status of each option for implementation if Athabasca River water is constrained for longer periods of time?
TAILINGS MANAGEMENT
95. Volume 1, Section 1.2, Page 1-14. Albian Sands states, "The design basis for the expansion currently includes adding gypsum to combined tailings. Work is being done at a demonstration plant to evaluate the capability of achieving a reclaimable landscape using a tailings mixture in which the coarse fraction provides geotechnical competence and sufficient void space to contain the fines, without adding gypsum." a. What are the implications of the work being done at the demonstration plant (the pilot where gypsum is not being added)? b. If the project is successful, will Albian Sands be changing their design (to not include gypsum additions)? c. When does Albian Sands expect to have results from the demonstration plant?
96. Volume 1 - Section 2.3- External Tailings Disposal Design, Page 2-9. Albian Sands indicates, “the external tailings disposal area was constructed according to design, with only minor adjustments required to allow for geotechnical monitoring. A
29 comprehensive tailings management survey conducted in the fall of 2004, indicated that, with the exception of larger than planned volumes of free water, every tailings settling, compaction and stability parameter has improved from the initial design assumptions.” a. What was Albian Sands’s initial expectation of free water inventory at this point? b. What is Albian Sands’s current actual free water inventory? c. What mechanism and evidence does Albian Sands have to explain the increase in free water inventory? d. What specifically were the initial tailings assumptions for the original Muskeg River Mine Application? e. How do the initial assumptions compare to current actual tailings performance? f. How do these initial tailings assumptions compare to the current planning assumptions? g. Albian Sands’s plan to construct a sand storage area and to return the Thin Fine Tailings (TFT) to the existing external tailings pond will result in increased fines loading on the existing external tailings pond. What impact will this have on the free water quality, turbidity and the resulting recycle water quality to the plant? h. Has the additional free water inventory reduced Albian Sands’s original river water import expectations? i. Explain why Albian Sands opted to build the proposed sand containment structure returning TFT to the existing pond versus accelerating the construction of the original external MRM tailings pond and plan? j. How has this increased water volume impacted above water beach development in the ETDA? k. Has this increased water volume resulted in any negative impacts on the construction and operation of the dykes, and seepage and geotechnical stability? Provide data/analysis to support comments. l. Elaborate on what the “parameters” being referenced are and why and by how much they have improved. Provide a table that compares the initial design parameters with the improved parameters.
97. Volume 1, Section 5.5, Post-Mining and Closure, Page 5-40. Albian Sands states, “For the post-mining status (2032 to 2044), see Figure 5-22. For the final closure and drainage plan, see Figure 5-23. The arrangement of in-pit tailings cells, their final elevations and their filling sequence have been designed to meet the objectives of the final closure drainage plan. Placing variable depths of overburden capping material onto in-pit cells in conjunction with sand capping specific in-pit cells provide the required closure landscape. Final contouring of the capped tailings cells allows sustainable drainage patterns to develop, which eventually collect into the pit lakes.” a. Capping of CT/NST filled ponds has not been done at a commercial level yet. What research is Albian Sands doing to prepare for this and what is the fallback if for example the bearing strength required of the CT/NST deposit cannot be achieved?
30 98. Volume 1, Section 5.5, Page 40, Bullet 5. Albian Sands states that they will be “transferring mature fine tailings and thin fine tailings from Muskeg River Mine and Shark bite tailings cells to the final pit lakes located in the Jackpine Mine development area.” In Volume 4, C, C&R Plan, Section 2.2.7.1, Page 41 Albian Sands states that they will “limit introduction of residual tailings material (fluid, NST, thickened tailings[TT], mature fine tailings [MFT] and consolidated tailings [CT] to pit lakes to the extent possible.” Attachment A, Figure 14 shows three pit lakes in the reclaimed MRME landscape that will receive tailings from MRME. a. What is the proposed timing of the fluid transfer from tailings cells of the MRME to Jackpine Mine pit lakes? b. What is the sand volume and pit space available from the Jackpine Mine development area? c. Why are the tailings proposed to be deposited to the final pit lakes instead of transferring them to a single pit lake or treating them to become NST? d. What are the potential impacts to water quality if there are tailings deposits beneath the pit lakes? e. Confirm the area of each of the different types of water capped tailings proposed for the closure landscape at the proposed MRME and Jackpine mine developments. f. Confirm the volume of tailings materials to be deposited and the capacity of tailings materials each pit lake could contain.
99. Volume 1, Section 7.1, Tailings Management, Page 7-1. Albian Sands notes that tailings will continue to be deposited in the external tailings disposal area until 2009 then in-pit with a transition period of two to three years planned during which decreasing amounts of tailings will be deposited in the external tailings disposal area and finally 100 per cent consolidated tailings in-pit operation by the end of 2011. a. For the increase in tailings capacity required (from 342Mm3 to 520Mm3), how much is attributed to increased throughput and how much due to a delay of consolidated tailings in-pit? b. If mining were accelerated in the Muskeg River Mine Pit instead of the mining the Lease 90 are when proposed, would the tailings management issues for the project be reduced? c. Explain why or why not. d. If all of the ore at the lease boundary between the MRM pit and the Aurora North Center pit must be recovered as already approved, describe the potential implications for the external tailings pond.
100. Volume 1, Section 7.1, Page 7-1. Albian Sands states that an additional 10 m vertical lift is being proposed for the ETDA in this application, from the current design elevation of 330 metres above sea level (masl) to 340 masl. According to Albian Sands this dyke raise (along with the south sand toe berm extension) represents an increase in storage capacity of 178 Mm3. a. Provide a detailed update on the geotechnical performance of the ETDA to-date. b. Describe any geotechnical challenges in the ETDA that could cause potential problems as a result of the proposed dyke raise?
31 c. Is Albian Sands confident that the proposed dyke raise to elevation 340 masl can be achieved safely? d. Provide preliminary geotechnical stability analyses and discussion to support Albian Sands’s position. Some of the analyses should consider the future mining along the north side of the ETDA. e. Provide a detailed discussion on why this amount of additional storage capacity is required. f. Compare the amount of storage needed (until in-pit storage is available) with the additional capacity being sought. g. What other alternatives have been considered to provide this required capacity (e.g. use of the Shell Jackpine ETDA)?
101. Volume 1, Section 7.1, Page 7-2. Albian Sands states, "In the new south extension area, the dyke will be beached to the interior and filled with sand, and the TFT will be immediately pumped to the main tailings area. This will result in a sand berm area with no containment of fluids." Albian Sands has also indicated that the first mine pit area will be available to receive tailings in Q3 2009, by which time the third production train comes on line and the EDTA extension is nearing completion. a. It appears that the south extension to the ETDA is required prior to the third process train comes on line. What percentage of the additional tailings storage requirement related to debottlenecking? b. What percentage of the additional tailings storage requirement is related to underestimation of tailings production? c. Discuss Albian Sands’s confidence that all the fine tailings will be removed from the extension, and sufficient storage capacity will be available in the main pond until in-pit storage is available. d. Provide a graph showing predicted versus produced cumulative fine tailings volumes since startup to support Albian Sands’s position. e. In the event that fine tailings storage requirements exceed the predicted volumes, and in-pit storage is not available, or the geotechnical conditions in the ETDA (e.g. Concerns related to liquefaction stability of beach below water (BBW) deposits) preclude raising of the dykes to the proposed 340 masl elevation, what contingency options are available for storing fine tailings elsewhere? i. Is their a possibility that Albian Sands could maintain fine tailings in the south toe berm extension? ii. Is their a possibility that Albian Sands could request temporary storage of fine tailings at an alternative location (i.e. Shell Jackpine ETDA or other alternatives) until in-pit storage becomes available? f. Discuss the sequence in which the extension will be constructed. i. Will the extension be infilled with sand after reaching full height or will the infilling with sand occur at several elevations? ii. Provide diagrams whenever possible to aid the discussion. g. Discuss whether or not the present geotechnical conditions in the ETDA (e.g. Concerns related to liquefaction stability of BBW deposits) might in fact preclude raising of the dykes to the proposed 340 masl elevation. i. What are the available geotechnical mitigation options that would allow this
32 raise to occur safely? ii. Discuss plans to further investigate the liquefaction characteristics of the beach deposits.
102. Volume 1, Section 7.1, Consolidated Tailings In-pit and Section 7.6 Purpose of NST Testing, Page 7-2 & 7-37. In Section 7.1, Albian Sands indicates they will produce a gypsum amended CT (consolidated tailings) to assist with pond reclamation. Later in Section 7.6 Albian Sands indicates they will try to avoid the use of gypsum to prevent Ca ions contaminating the recycle water and downgrading bitumen recovery. Albian Sands also indicates the target solids concentration for NST (non-segregating tailings) is 67 per cent and earlier indicates it is 1.62 specific gravity (SG) or 61 per cent solids. a. Does Albian Sands intend to produce a gypsum, or other chemical, amended CT/NST? b. If Albian Sands’s decision is to produce a non chemical amended CT/NST: i. What will be Albian Sands’s target NST stream density and sand to fines ratio (SFR) or alternatively provide the segregation boundary curve Albian Sands intends to use for a non-segregating tailings stream without chemical amendment? ii. How will Albian Sands maintain the high tailings densities required for non chemical amended CT/NST mixes given the usual mine feed rate fluctuations? iii. In section 7.6 Albian Sands indicates that the clay to water ratio (CWR) may be insufficient to make NST. For non-chemically amended NST mixes what does the CWR have to do with the ability of the tailings mix to remain non- segregating? Explain. c. If Albian Sands’s decision is to produce a chemically amended CT: i. What chemical will be used? Provide the segregation boundary curve for the specific chemical. ii. If the clay, mineral, water ratio is insufficient to make gypsum or other chemically amended CT/NST, what is Albian Sands’s fallback position for NST make? What impact will this have on tailings management? iii. Is the propensity to downgrade bitumen recovery more, in a non-caustic based process such as at MRM, or less with calcium based chemically amended NST mixes? Explain? iv. At what combined concentration of Calcium (Ca) and Magnesium (Mg) in the NST release process water does Albian Sands believe bitumen recovery will be affected given a non-caustic based process? v. How does Albian Sands propose to control excursions in release water Ca and Mg concentrations from impacting bitumen recovery should they occur? vi. If Albian Sands intends to produce a gypsum amended NST: 1. What minimum release water Ca ion concentration would indicate clay saturation for on-spec NST make? 2. How does this concentration in 1 above compare to the maximum Ca ion concentration allowable in the recycle water to prevent hot water scale deposits in the hot process water piping system?
33 3. If the expected release water Ca ion concentration exceeds the concentration allowable to prevent hot water scale formation what is Albian Sands’s plan to reduce the Ca ion concentration and prevent scale formation from severely restricting production?
103. Volume 1, Section 7.1, Final Tailings Deposition, Page 7-4. Albian Sands indicates at the end of mine life there will be 141 Mm3 of MFT to transfer to a pit lake. a. Could Albian Sands thicken the MFT to reduce the required stored volume? b. What reduced volume of MFT could be achieved by thickening? c. What impact would installation and operation of thickeners have on project cost and return on investment (ROI)? d. What impact would this have on the size of the end pit lake(s)? e. What is the forecasted volume of MFT to be transferred to the end pit lake at the end of mine life from the Muskeg River Mine Lease area and the Jackpine Mine Lease area? f. What is the total volume of MFT expected at the end of mine life? g. How much MFT is currently in place? h. What methodologies are used to measure the current MFT volumes in place? i. Does Albian Sands believe the quantity of MFT or other tailings contained in an in-pit lake will make any difference in the performance of the lake? i. Explain, in terms of the potential effects of tailings material on the ecological components in the lake and in terms of proposed function of the lake.
104. Volume 1, Section 7.6, Page 7-37. Albian Sands states that the objective of achieving a reclaimable landscape is by creating a tailings mixture that is geotechnically competent. Provide a discussion on Albian Sands’s definition of a geotechnically competent deposit as it relates to bearing capacity and the basis of this definition.
105. Volume 1, Section 5.5, Post-Mining and Closure, Page 5-40. Albian Sands indicates that as part of the their final closure drainage plan they will be “transferring mature fine tailings and thin fine tailings from Muskeg River Mine and Shark bite tailings cells to the final pit lakes located in the Jackpine Mine development area”. Capping of tailings in End pit lakes is currently an unproven reclamation strategy. a. What research is Albian Sands conducting with respect to end pit lakes that will increase confidence in this strategy? b. Provide Albian Sands’s fallback plan if end pit lakes are not demonstrated to be successful. c. What research is Albian Sands conducting on alternative tailings technology that would preclude the need to store tailings in end pit lakes?
106. Volume 1, Section 7.1, Final Tailings Deposition, Page 7-4. Albian Sands states “Near the end of the plant life, 141 Mm3 of MFT will need to be transferred from in- pit cells 7, 12A and 16 to allow construction of the pit lakes and to integrate the requirements for closure between Muskeg River and Jackpine mine areas. The main
34 tailings area of the external tailings disposal area will also be dredged of 71 Mm3 MFT, refilled with coarse tailings and reclaimed. This will require integration of the requirements for the closure plans for the mine areas. Drainage will be directed into a number of pit lakes after mining operations end.” While Thin Fine tails are tabulated in Table 7.3 and we acknowledge that they turn into mature fine tailings, the accumulation of Mature Fine tails is not shown anywhere. Provide the values and the location of the Mature Fine tailings as well as the consolidation curves used to develop the plan.
107. Volume 1, Section 7.1, Figure 7-3: Site Layout and In-Pit Cell Locations, Page 7.5. For clarity each structure whether it is a pond or a dyke should have a distinct and unique name. It is noted in Figure 7-3 that a number of dykes are labeled Dyke 1, yet the cell naming convention used in Figure 7-3 does not repeat. Explain the naming convention for the dykes.
108. Volume 1, Section 7-2, Tailings Management Plan, Page 7-7 to 7-24. a. Provide the Tailings Assumptions and criteria used in building the tailings management plan. Include: • All model inputs for the tailings models including but not limited to the following example: The separate masses in tonnes of sand, fines, and water for one cubic metre of sand dyke. • Specific gravities of all tailings and material streams • Tailings consolidation curves (for all tailings types) • Dyke design and construction criteria • Tailings deposition angles b. Provide the tailings material placement schedule on a mass basis by tailings component this should include the following: • Establish the starting baseline for all structures. This should include, the volumetric “peels” of each structure and the present level of each tailings material type within each structure. • Provide the consolidation curves applied to all tailings deposits to clearly show how the volume changes and fluid is released. • Illustrate clearly that your structure construction schedule can meet the mining and tailings waste production schedule. c. Provide a summary of key tailings milestones that will provide a quick reference for all stakeholders. Include milestones such as but not limited to: • Date of first foot print disturbance • Date of first Tailings in by structure/pond • Date of the last Tailings in by structure/pond • Date of Sand cap being completed • Reclaimed (need to elaborate) • Mass and Volume of MFT in storage at startup of the MRME • Mass and Volume of MFT in storage at the end of mine life
109. Volume 1, Section 7.2, Tailings Stream Properties, Table 7-1, Page 7-8. Albian Sands indicates a deposited dry density as being a density achieved after 2
35 years of dewatering the deposit. All the streams depicted are deposited below water. How can the deposited dry density be less than water (i.e. <1.0 t/m3) for deposits below water such as TSRU, TT, TFT and course tails as shown in table 7-1? Explain.
110. Volume 1, Section 7.2, Page 7-8. Albian Sands states, "The south extension will also provide a toe berm for stability because weak foundation soils underlie the southern portion of the existing dyke."
a. Provide a cross section through the south toe berm extension that shows the proposed structure along with the underlying soil layers. i. Comment on which of the underlying soil layers present the most geotechnical concern in the design. b. Provide the supporting preliminary stability analyses that have been conducted, which support the above statement. Besides assessing the stability benefits the toe berm extension will have on the ETDA, the analyses should also assess the stability of the toe berm extension itself, and whether or not a toe berm will be required to stabilize the south toe berm extension. c. Provide the strength and pore pressure parameters used in the analyses. d. Comment on the impact that the proposed toe berm extension will have on the pore pressure dissipation ability of underlying weak soil layers and whether saturation of the underlying soils by the toe berm will hinder this dissipation.
111. Volume 1 - Section 7.2, Table 7-1: Tailings Deposition Properties, Page 7.8. For Table 7-1, provide the deposited specific gravity (SG) with water as well as the consolidation curves or relationships that you have used for your plans and the rationale associated with these curves.
112. Volume 1, Section 7.2, Consolidated Tailings Operations, Page 7-9. Albian Sands states the “consolidated tailings management plan recognizes that NST will not be produced as a non-segregating product all the time” and therefore “the overall NST stream factor is 85%.” a. What percentage is attributed to the NST plant reliability and what percentage can be attributed to mixes being segregating? b. With production of NST scheduled to start in 2009, and continue for the remaining project life, how much of the sand in oil sands processed from 2009 to the end of project life will be used for NST production? c. Provide the total tonnes of sand used in NST production and the percent of total sand in oil sand that is allocated for NST production. d. What are the contingencies to ensure that the expected sand is being used for NST production?
113. Volume 1, Section 7.2, Figure 7-4: Schematic for Production of NST, Page 7- 10. Albian Sands’s NST production plan calls for the consolidation of TSRU tailings to the point where they can be beached on top of, and then covered with a 1.7 SG overburden material prior to final reclamation. a. Provide the research and available test data supporting these concepts.
36 b. What further work is Albian Sands planning to support its conceptual plan?
114. Volume 1, Section 7.2, Tailings Material Balance, Table 7-3: Tailings Material Balance, Page 7-20. How do the volumes in Table 7-3 match up with the volumes indicated under the “Volume of Tailings” subsection on page 7-4? Explain any differences.
115. Volume 1, Section 7.2, Tailings Management Plan, Tables 7-3 to Table 7-7, Pages 7-20 to 7-22. We acknowledge that tailings management plans are complex and conceptual in nature. However, the EUB recognizes the importance of reclamation goals and the need to demonstrate how the tailings management plan will achieve these reclamation goals. Our understanding is that as part of the AOSP it is the intention of Albian Sands to integrate MRM, MRME and the Jackpine mine resources and possibly containment structures for an approximate bitumen production of 500,000 bbls per day. Of high importance to a surface oil sands operation is a comprehensive materials balance that includes all materials transferred versus time from the mining face through to the tailings containment structures. The above referenced tables outline only the expected volumes of different tailings streams both in pit and into external ponds. a. Provide a summary of the above-integrated plan that shows the MRM, MRME, Jackpine 1 and Jackpine 2 material movements versus time annually for the projected mine life. i. Using the mine plan production targets for oil sand feed and the mine geological model for oil sand feed quality characteristics for assays of fines and coarse sand fractions, on a year by year basis, describe in table format the complete dispensation of all materials. This will include: • All planned mined tonnes from all mines • Transfers, destinations and inventories of waste within and between all mines such as Overburden, Interburden and rejects. • Transferred waters and products as well as inventories between all mines and the Shell Scotford Upgrader. • All coarse sand and fines into final tailings products, the desired quality specifications of each product such as sand to fines ratio (SFR), stream density, clay mineral water ratio (CMWR) and the final pond or pit discharge location of each of these streams. • The plan should use the same structure names that have been identified in the general arrangement drawing and used in the tailings plan. • Swell and consolidation factors should be identified. b. Additionally to better illustrate the transfers of streams within and between mines include Process Flow Diagrams for the key integration points of the different process configurations (i.e. when new mine pits, process units or tailings structures are incorporated into the plan the transfer of streams may change). c. Additionally provide the energy balances of the reported transfers. All key streams must be provided both on a volume and mass basis. Use the attached tables (in Appendix A) to aid in responding to this question.
37 116. Volume 1, Section 7.2, Tailings Pumping and Pipelines, Page 7-22. During capping, the three NST pipelines will be used for coarse sand and the spare line will be used for thickened tailings with a pipeline solids content of 46 wt per cent. a. How does the expected solids concentration compare with Albian Sands’s current thickener underflow solids concentration operation? b. What information does Albian Sands have that confirms that 46 per cent solids are achievable in the pipelined thickened tailings stream? c. What is the clay content required to make on-spec NST in the TT stream and how does this clay content compare with the clay content in the existing thickener underflow or TT stream? d. What is the impact on capping if the 46 per cent is not achieved?
117. Volume 1, Section 7.2, Tailings Pumping and Pipelines, Page 7-22. Albian Sands notes “TRSU tailings will be pumped in two dedicated pipelines to the operating in-pit cells and discharged under a 3-m water cap.” a. What has been the past performance of managing TSRU tailings in this manner? b. What is the operating time in this mode during summer months and winter months? c. What is required to ensure that TSRU tailings can be managed in this manner year round?
118. Volume 1, Section 7.3, Page 7-25. Albian Sands states, "Results of stability analyses indicate that it is feasible to increase the elevation of the external tailings disposal area by 10 m to 340 masl." Albian Sands provides Figures 7-13 to 7-15 showing the new design configurations at representative cross sections. a. Revise Figures 7-13 to 7-15 to also show the underlying soil layers. b. Submit the stability analyses that were conducted to evaluate the factor of safety for the new design configurations for all the possible failure modes, including upstream failures. i. Figure 7-13 in particular shows the centerline constructed dyke being changed to more or less an upstream configuration (with a steep 0.75:1 slope and stepping onto softer TSRU tailings). Confirm if this is in fact being done, and whether this is possible. ii. Provide upstream stability analyses for this case. iii. Provide all strength and pore pressure parameters used in the analysis. iv. Discuss other possible options to raise the centerline portion of the dyke. c. Provide the target factors of safety used in the designs as well as the soil strength and pore pressure parameters for both the design and contingency cases. d. Discuss the basis of the strength and pore pressure parameters used. e. Discuss Albian Sands’s plans to conduct further geotechnical investigations in the ETDA area, including the extension.
119. Volume 1, Section 7.3, Page 7-26. Albian Sands states, "Long above water beaches will be maintained in the main pond to mitigate potential problems with liquefaction beach-below-water (BBW) tailings." a. Has Albian Sands determined the required length of the above water beaches in
38 order to mitigate the potential liquefaction issues? b. Discuss the challenges in maintaining long beach lengths in light of the higher than expected water inventory in addition to the proposed storage of fine tailings from the south toe berm construction. How will these be overcome? c. Will Albian Sands conduct detailed geotechnical investigations of the beaches to assess and evaluate the liquefaction potential prior to slope flattening and dyke raising? d. Discuss Albian Sands’s plans to conduct a breach and inundation study for the ETDA for the 340 masl elevation and the toe berm extension at 335 masl elevation. Provide details.
120. Volume 1, Section 7.4, Table 7.9, Page 7-31. In Table 7.9 Albian Sands summarizes the in-pit dyke disposal design criteria and indicates that the NST disposal plan will accommodate NST beaches between NST pond and dyke. a. What will the minimum length of these beaches be to protect against piping or other failure and how will Albian Sands ensure development of these beaches? b. Will these in-pit dykes require licensing under the Water Act?
121. Volume 1, Section 7.3, Figure 7-13: Design Cross-Section Number, 3, Page 7 – 28. The proposed increase in elevation of the dyke as illustrated in Figure 7-13, shows that the upstream slope will be changed from 2:1 to 0.75 to 1. Discuss the present performance of the external pond in this area, and specifically the present dyke slopes that are being achieved and provide support for this design.
122. Volume 1, Section 7.4, Typical In-Pit Tailings dykes, Page 7-32. Building in-pit dykes out of just overburden as illustrated in Figure 7-16, has historically been a challenge in the oil sand industry. What is Albian Sands’s fallback position and how does the materials balance work if a significant volume of sand is used in dyke construction to meet tailings fluid rise schedules?
123. Volume 1, Section 7.6, Non-segregating Tailings Testing, Page 7-37. Albian Sands states, “to date, the Muskeg River Mine has demonstrated the ability to produce coarse and fine streams and thickened fine tailings” but needs to confirm commercial assumptions for NST, before implementing this technology, through a $9 Million demonstration plant program. Albian Sands also indicates “the ratio of sand to fines can be met using existing tailings streams, but the clay-to-water ratio might be unacceptable” and therefore is proposing a field test to reduce moisture content in coarse tailings before adding to thickened tailings. a. What is the test program and schedule for the demonstration plant? b. How long will it take to confirm the feasibility of NST? c. What are the contingencies if the field testing does not produce the required results? d. What alternatives are being studied in parallel?
124. Volume 3, Section 3.2.1.1, Table 2, Page 17. Table 2 indicates that Pit Cell 2 will have a final elevation of 403 masl. Verify this final elevation.
39
125. Volume 4, Appendix 4-4, C, C&R Plan, Section 1.6, Page 14. Albian Sands states, “Several uncertainties exist in the closure planning process including long- term performance of landforms, feasibility of developing trafficable tailings landforms (non-segregating tailings), long-term performance of vegetation communities and capability to return landscape biodiversity.” a. Discuss the strategies used in the development of Thickened Tailings and NST. b. What methodologies may be used to control the density of Thickened Tailings and NST? c. Discuss the availability of alternative materials and processes used to adjust the water content of the Thickened tails and NST proposed for use by Albian Sands. d. Discuss alternatives that are, and alternatively are not available to make Thickened Tailings and NST for the creation of dry, adaptable and robust reclaimed landscapes. Provide justification for each alternatives acceptance and rejection. e. Discuss the effect that the volume and rate of bitumen production, and any other plant process has on the rate of NST and T.T. development, how it affects the percent solids and suitability for the creation of reclaimed dry landscapes.
UTILITIES
126. Volume 1, Section 2.4, Page 2-11. Albian Sands states, “Initial heat integration and recovery expectations have not been met because of a number of process issues. Consequently, temporary boilers have been installed to increase steam capacity by about 100 t/h during winter operations while the overall process heating system is optimized.” a. Explain the process issues that Albian Sands has encountered requiring the use of temporary boilers for steam generation. b. Explain how Albian Sands intend to modify this situation? c. Has Albian Sands used these boilers during periods other than winter? d. How long will these boilers be required before the overall heat integration is optimized? e. Are the temporary boilers a permanent solution?
127. Volume 1, Section 8.5 Auxiliary Utilities; Steam Boilers, Page 8-12. Albian Sands indicates six new boilers will be required to provide the low-pressure steam requirements for the expansion project. a. Will the six new boilers have sufficient steam capacity to replace the temporary boilers? b. If not, what is Albian Sands’s plan to meet the low-pressure steam requirements?
128. Volume 1, Section 5.2, Section 2-3, Page 5-16 (Also discussed in Section 5.7, Page 5-58, Mine Access and Utilities and Page 6-13 and 5-16 Segments 12 to 13). Within these sections Albian Sands discusses the concept of designing a utility corridor to accommodate existing utilities with Syncrude. Provide the list of resolved and unresolved utility and access corridor requirement issues that Albian Sands has discussed with other stakeholders that may be affected by the proposed Albian Sands
40 MRME.
129. In EUB Decision 2004-009, Shell was directed to provide, “an access road and utility corridor update in its 2006 annual report. The report shall include a resource assessment of the oil sands located in the Sharkbite area and under the modified infrastructure corridor. It shall also include a comparison of alternative access road and utility corridor alignments with respect to resource recovery and other relevant criteria.” In light of the realignment now proposed by Albian Sands, this information is required as part of this application.
130. Volume 1, Section 8.3, Electrical Power, Page 8-7. Albian Sands indicates plant site power could come from the Alberta Interconnected System (grid) or it could come partially from the ATCO Power facility at the MRM. How much of the total additional power needs could be met by the existing cogeneration station?
131. Volume 1, Section 8.4, Natural Gas, Page 8-9. Albian Sands indicates natural gas consumption will rise from 740 gigajoules per hour (GJ/hr) to 3,390 GJ/hr, an increase of greater than 3.5 times. In contrast, bitumen production is increasing by only 75 per cent (155,000 bbls/day to 270,000 bbls/day). a. Why is natural gas consumption increasing disproportionately to production? b. What options, if any, has Albian Sands considered to reduce the increase in natural gas requirements, (e.g. gasification of stored asphaltenes from the Shell Scotford Upgrader)?
AIR
132. Provide total areas in Hectares for all Study areas (Local Study Area (LSA), Terrestrial Study Area (TSA), Regional Study Area (RSA), etc.) used in the EIA, as well as size of the developed area.
Emissions
133. Volume 1, Section 1.2, Page 1-14. Under the section Technology Development, Albian Sands states that for non-segregated tailings, “A demonstration plot has been constructed at Muskeg River Mine and testing is expected to continue for several years.” a. Has the testing indicated any increases or decreases in air emissions of greenhouse gases or volatile organic compounds? b. Discuss any technology development, or pilot, that Albian Sands has conducted to reduce air emissions from mobile, stack, or fugitive sources.
134. Volume 1, Section 6.2, Page 6-17. Albian Sands states, “The residual solvent loss will meet or exceed the target of 4 units of solvent per 1000 units of dry bitumen. The new TSRU system will be operated so that no untreated tailings are sent to the tailings pond.” a. How have Albian Sands’s current operating procedures achieved this objective?
41 b. How well have current operations achieved Albian Sands’s current target for solvent losses of 4 units of solvent per 1000 units of dry bitumen? c. What are the annual 2004 and monthly 2005 solvent losses to date? d. Has Albian Sands used the actual solvent loss ratio for modeling predictions? If not, why not? e. Provide the pond fugitive modeling results if the 2004 annual average solvent loss ratio and the 2005 average to date solvent was used? f. Discuss the effect on ambient air quality concentrations of Volatile Organic Compounds (VOCs) near the tailings pond, if losses of solvent exceed 4 units of solvent per 1000 units of dry bitumen. g. Discuss Albian Sands’s plans to improve, or change operating procedures, to further reduce the risk of untreated tailings reaching the tailings pond, and achieve a target of solvent losses of less than 4 units of solvent per 1000 units of dry bitumen. h. What are the implications for present and predicted health risks assessments if the actual solvent losses were used?
135. Volume 2, Appendix 2-8, Section 1.2, Page 5-37. This section describes the current air monitoring that is being performed in the region. a. Has Albian Sands performed any additional air monitoring that is outside of the normal Wood Buffalo Environmental Association (WBEA) program? b. What are the findings and interpretations from these additional monitoring events, if any? c. Discuss, if applicable, how the results supplement fugitive emissions data from the plant site, mines, and the ponds and its relative significance.
136. Volume 2, Appendix 2-9, Section 5.2, Page 70. Albian Sands states, “A Vapour Recovery Unit (VRU) with 60% of the capacity of the existing VRU will be added.” Elaborate on the meaning of this sentence. Is the 60% capacity based on ‘per existing unit’ or ‘per existing facility’?
137. Volume 2, Appendix 2-9, Section 5.2, Page 73 and Appendix 2-9, Section 5.3, Page 75. Albian Sands states, “The NOX emissions were calculated assuming the fleet will meet the Tier 1, Tier 2, Tier 3 and Tier 4 emission standards set by the U.S. EPA,” and “The majority of the mine fleet emissions considered in the air quality assessment are based on Tier 2 emissions standards.” Clarify the discrepancy associated with the above two statements.
138. Volume 2, Appendix 2-9, Section 5.2, Page 74. Albian Sands states: “The mine face fugitives were scaled back from data provided for the Muskeg River Mine (Syncrude 1998; Shell 2002) on the basis of bitumen production,” and “The pond fugitives were scaled from tailings ponds at Muskeg River Mine (Syncrude 1998; Shell 2002) on the basis of bitumen production. The pond emission rates are based on solvent loss to the tailings pond at a rate of 4 barrels of solvent per 1,000 barrels of production.” a. Provide detailed calculations of the mine face fugitives and pond fugitives.
42 b. Provide calculations used to formulate the 11.3 t/d of VOCs (in Table 22). c. Provide a discussion on estimation of acrolein.
139. Volume 2, Appendix 2-9, Section 5.2, Page 74. Albian Sands states, “The processing facility at the project is not expected to be a significant source of fugitive emissions and, as such, these emissions were not quantified”. In light of other oil sands plants having fugitive emissions, provide plant fugitive emission rates for the Muskeg River Mine Expansion project.
140. Volume 2, Appendix 2-9, Section 3.4.4.2, Page 3-107. Albian Sands states, “Acid forming compounds were calculated as the sum of the SO2 and 70% of the NOX emissions. This accounts for the slightly lower acid forming potential of NOX emissions.” Provide the rationale for using 70% of the NOx emissions.
141. Volume 2, Appendix 2-9, Section 7, Table 29, Page 113. It is shown that co- generation emissions are listed in the Application Case. It is our understanding there are no additional co-generation units being proposed. a. Are the co-generation emissions caused by incremental amount a result of the Muskeg River Mine Expansion Project? b. What was the method used to determine the co-generation emissions? c. Has Albian Sands considered the Clean Air Strategic Alliance (CASA) document: “An Emissions Management Framework for the Alberta Electricity Sector Report to Stakeholders"?
142. Volume 2, Section 3.3.2 and Section 3.4.2.1, Table 3.3-1, Table 3.4-2 and Table 3.4-3, Page 3-48, Page 3-56, and Page 3-57. It appears that the Muskeg River Mine Expansion is increasing output from 150,000 bbl/cd to 270,000 bbl/cd (an 80% increase) while emissions of NOx are increasing 83% (up 4% per barrel), VOCs are increasing 94% (up 18% per barrel). a. Why are the emissions of NOx and VOCs increasing per barrel as compared to the original Muskeg River Mine? b. Discuss the options Albian Sands might take to reduce the emissions of VOCs and NOx to the same levels per barrel as achieved by the original Muskeg River Mine.
143. Volume 2, Section 3.3.2, Table 3.3-3, Page 3-49. This table indicates calendar day SO2 emission estimates for Syncrude, Suncor and Canadian Natural Resources Limited (CNRL) that are higher than stream day values. a. Discuss the basis for calculating estimated calendar day emissions. b. How many upset events have occurred at these upgraders and what magnitude of events was estimated? c. Clarify if the flaring emissions from upset events at these upgraders were modeled through averaging flared emissions over the year or as discrete events.
144. Volume 2, Section 3.4.2.1, Table 3.4-3 and 3.5-2, Page 3-56 and 3-130. Provide project-specific benzene emissions estimates separate from VOCs emission estimates.
43
145. Volume 2, Section 3.4.5.2, Page 3-113. Albian Sands states, “… the Project would contribute a 3% increase in the emissions of ozone precursor chemicals in the region. Therefore, any effect on the peak ozone in the region should be very small.” a. Quantify “very small.” b. Provide further discussion on estimates of ground-level ozone as a result of increased pre-cursor emissions from the project.
146. Volume 2, Section 3.4.8.2, Tables 3.4-34 and 3.4-35, Page 3-124 and 3-125. Albian Sands provides greenhouse gas (GHG) emissions estimates associated with both the construction phase and the operations phase of the Project. Provide detailed calculations for these GHG emissions estimates.
147. Volume 2, Section 3.4.8.2, Table 3.4-36, Page 3-124 and 3-125. Albian Sands states, “Table 3.4-36 provides a summary of provincial and national GHG emissions as reported in Canada. The GHG emission contribution from the Project in 2015 will amount to 0.5% of the projected Alberta emissions and 0.15% of the emissions projected for Canada.” a. Explain why there are no projected National and Provincial GHG emissions between 2002 and 2015 included in the table. b. If there are GHG projections available from 2003 to 2014, provide them.
148. Volume 2, Section 3.4.8.4, Page 3-126. Albian Sands states, “The existing Muskeg River Mine uses an integrated co-generation facility whereas the commercial team for utilizing incremented co-generated electricity are under exploration for the project.” a. Does Albian Sands plan to use co-generated power in the future as part of the MRME? b. If co-generated power is used in the future, does Albian Sands plan to use the existing co-generation system or build an expanded co-generator? c. If co-generation is part of the supply of electricity and steam/heat for the MRME, what are the expected incremental increases in air emissions related with additional co-generation?
149. Volume 2, Section 3.5.3.2, Page 3-131. Albian Sands states, “When the Base and PDC emissions are compared, there is a projected increase of 22% for SO2, 40% for NOX, 48% for VOCs and 27% for TRS.” Provide the projected increase for benzene emissions separate from the VOCs.
Ambient Air Concentrations
150. Volume 2, Section 3.3.3, Page 3-50. Albian Sands states, “The maximum base case predictions of 1-hour, 24-hour and annual ground-level SO2 concentrations in the RSA (outside of developed areas) were predicted to be 275, 177 and 11.0 μg/m3 respectively. The maximum 1-hour, 24-hour and annual ground-level SO2
44 concentrations in the LSA (outside of developed areas) were predicted to be 275, 177 3 and 11.0 μg/m respectively.” Confirm that the maximum Base Case SO2 predictions for the LSA and the RSA are of the same value.
151. Volume 2, Section 3.4.3.2, Page 3-86. Albian Sands states, “All of the predicted PAH and metal concentrations are within applicable AAAQO and other criteria.” Provide the “other criteria” referred to in relation to Polycyclic Aromatic Hydrocarbons (PAHs) and metal concentrations.
152. Volume 2, Section 3, Table 3.5-3, Page 3-131. Provide the emissions data for Carbon monoxide (CO) and PM2.5 similar to Table 3.4-5.
153. Volume 2, Section 3.5.3.2, Table 3.5-5, Page 3-134 and Section 3.5.3.2, Table 3.5-7, Page 3-136. It appears that equivalent or larger emission estimates were used in the planned development scenario as compared to the application scenario; however the predicted maximum 24-hour NO2 concentration and number of predicted NO2 exceedances of Alberta Ambient Air Quality Objectives (AAAQO) drop in the planned development scenario. The predicted concentration of NO2 in regional communities appears to be increasing in the planned development scenario as well (Volume 2, Section 3.5.3.2, Table 3.5-7, Page 3-136). a. Clarify why predicted maximum 24-hour NO2 predictions are lower in the Planned Development Case (PDC) than in the Base and Application Cases, for both the LSA and the RSA. b. Explain why there is only 1 occurrence predicted above the 1-hour AAAQO in the PDC for both the LSA and the RSA, when there are 4 occurrences predicted in the Application Case and 3 in the Base Case. c. Explain why there are no exceedances of the annual average NO2 predicted in the PDC, when there are exceedances in both the Base and Application Cases. Note: NOx emissions are expected to increase by 40% in the PDC.
154. Volume 2, Section 3, Table 3.3-2, Page 3-48. The table shows that there is no flaring and that there are no plant fugitive emissions for the Muskeg River Mine. a. Explain why emissions due to flaring are zero. b. Provide emissions details if flaring is occurring periodically and emissions are different substances than listed in Table 3.3-2. c. What portion of the flaring would be considered routine flaring? d. What is the composition of the flaring vapour and what are the sources? e. How many hours/days per year has Albian Sands been under upset conditions since start up and what are the volumes of associated flaring on an annual basis? f. What measures are being taken to minimize flaring? g. Justify no plant fugitive emissions for the Muskeg River Mine and the expansion project.
155. Volume 2, Appendix 2-9, Section 8.1, Page 133. Albian Sands states, “Emergency flaring will not result in any increases in ambient SO2 or H2S concentrations since there are no sulphur compounds in the flared gas.”
45 a. Provide information on what emissions will be from released from flaring besides SO2 and H2S. b. Provide a health risk assessment including these emissions. Please respond to this portion of the question in the Health section.
156. Volume 2, Appendix 2-9 , Section 8.3, Table 34, Page 135. In Table 34, Albian Sands provides estimates of Annual PM10 and PM2.5 emissions from slash burning. However, it is unclear whether these emission estimates were included in the Application Case PM2.5 and PM10 emissions estimates. a. Please clarify. b. If these emissions estimates were not included, discuss the significance of not using this data.
157. Volume 2, Appendix 2-10, Section 1.3, Table 4, Page 6 and Table 5, Page 11, Appendix 2-11, Section 1.3, Table 5, Page 6 and Table 6, Page 12, and Appendix 2-12, Section 1.3, Table 3, Page 6 and Table 4, Page 11. In Footnote (g), Albian Sands states, “These areas were calculated by subtracting the LSA areas from the RSA areas; therefore, some areas may occur over the AAAQO although there are no predicted occurrences in excess of the AAAQO.” Clarify the above statement.
Modelling
158. Volume 2, Section 3.4.3.2, Page 3-57. Albian Sands states, “When the Base and Application Case emissions within the modelling domain are compared, the Project results in an increase of 2.5% in the combined regional emissions. The respective increases in the regional emissions as a result of the Project are projected to be 0.2% for SO2, 3.7% for NOX, 2.8% for CO, 2.0% for PM2.5, 2.6% for Volatile Organic Compounds (VOCs) and 0.9% for Total Reduced Sulphur compounds (TRS).” Provide the calculations used to determine that the Project results in an increase of 2.5% in the combined regional emissions. (When individual emissions are added, the total equals 12.2%).
159. Volume 2, Section 3.4.3, Tables 3.4-14, Page 3-77. Albian Sands indicates that the predicted decrease in benzene at some community receptors is due to the change in location of the mine fleet. However, there are no decreases reported in Table 3.4- 14. Are benzene predictions expected to decrease at any of the community receptors?
160. Volume 2, Section 3.4.3.2, Page 3-86. Albian Sands states, “Table 3.4-17 provides a comparison of the predicted daily PM2.5 concentrations in the regional communities. The table lists the 98th percentile of the modeled predictions, since that is the basis of the Canada-Wide Standard. While the Project emissions result in an increase in predicted PM2.5 at most communities, the Application Case 98th percentile 24-hour PM2.5 concentrations at all community receptors are below the Canada-Wide Standard.” Provide a figure of isopleths illustrating the comparison of th Base and Application Case 98 percentile 24-hour PM2.5 concentrations.
46 161. Volume 2, Section 3.4.3.5, Page 3-106. Albian Sands states, “To limit the uncertainty of emission rates, especially from fugitive and mine fleet sources, actual monitoring data and operating conditions were incorporated into the emission estimates where available.” a. Specify which facilities provided maximum approved values and which provided emissions based on normal operating conditions. b. For those facilities whose emissions are based on normal operating conditions, how would applying maximum approved values impact the predicted concentrations for the Base Case and the Application Case?
162. Volume 2, Section 3.4.7.2, Page 3-120 and Table 3.4-33 (footnote b), Page 1- 121. Albian Sands states, “The ability to detect odours is usually related to the high “peak” concentrations during each hour. To address these fluctuations, a “peak” concentration was determined by applying a multiplication factor to the CALPUFF model estimates. A factor of 10 is most suitable near to point sources and a factor of 2 is most suitable when receptors are distances of 2 to 5 km away from the emission sources,” and “Values are based on a peaking factor of 2, which is appropriate beyond 5 km from the source”. Clarify whether the peaking factor is appropriate when receptors are 2 to 5 km away from the emission source or when receptors are beyond 5 km from the emission source.
163. Volume 2, Appendix 2-10, Table 13 and Volume 2, Appendix 2-11 Table 14. Tables 13 and 14 indicate predicted ambient levels of H2S and reduced sulphur in regional communities for the base and application cases respectively. While Hydrogen sulphide (H2S) and Carbon disulphide (CS2) levels are well within Alberta Ambient Air Quality Objectives, predicted peak 1-hour total reduced sulphur (TRS) are greater than 14 μg/m3 at Ft. McKay with greater than half of that concentration from thiophenes. It is noted that predicted peak 24-hour TRS concentrations are 3 expected to be 3.764 μ/m in Ft. McKay. Components of TRS including H2S and thiophenes are very odourous, likely in the predicted concentration ranges. a. It would appear that the proposed project is not predicted to increase TRS levels in Ft. McKay. Explain the sources of TRS responsible for predicted concentrations in Ft. McKay. b. Given the contribution of odourous reduced sulphur compounds to TRS levels, discuss potential odour impacts on communities in terms of frequency and duration of sulphur related odours. c. Given the sources involved, what measures would be required to reduce TRS emissions in a way that would further mitigate the frequency and duration of odour events in Ft. McKay?
164. Volume 2, Appendix 2-6, Section 1.21, Table 71, Page 36. Provide details on how the Municipalities air emissions were estimated.
47 165. Volume 2, Appendix 2-9, Section 3.1, CALMET 3-D Meteorology. Provide a map showing locations of WBEA stations, surface stations, upper air stations, and precipitation stations.
166. Volume 2, Appendix 2-9, Section 3.1.5.2, Page 24. Albian Sands states, “The river valley is surrounded by Birch Mountain to the northwest, Muskeg Mountain to the east and Stoney Mountain to the south. Terrain elevations were derived from the United States Geologic Service (USGS) Digital Elevation Model with 250 m resolution. This data was then gridded to 5 km resolution and the elevation at the centre of each grid cell is used to define the elevation of that grid cell.” Explain how the 5 km terrain grid resolution is adequate for this project.
167. Volume 2, Appendix 2-9, Section 4.1, Page 28 and Volume 2, Section 3.4.4.2, Page 3-107. Albian Sands states, “The modelling assumes that all of the nitrogen that gets deposited is available to contribute to PAI (i.e., no vegetation or soil uptake),” and “Acid forming compounds were calculated as the sum of the SO2 and 70% of the NOX emissions. This accounts for the slightly lower acid forming potential of NOX emissions.” a. Explain the first statement, considering that in Section 3 (footnote b of Table 3.4- 25) it was stated that only 70% of NOx emissions were considered. b. Provide the rationale for using 70% of the NOx emissions.
168. Volume 2, Appendix 2-9, Section 4.4, Page 36. A background value of 23.4 parts per billion (ppb) is given for Ozone (O3). Provide the basis for the calculation of this background value.
169. Volume 2, Appendix 2-9, Section 4.7, Page 52. a. Substantiate the method used to calculate Community Background Concentrations (i.e. published literature, studies). b. Explain why more recent emissions data were not used.
170. Volume 2, Appendix 2-9, Section 6.3.3, Figure 28, Page 99 and Page 101. Albian Sands states, “The fractional bias plot indicates that the CALPUFF modeling performed satisfactorily for the NO2 predictions at most stations, and resulted in conservative predictions at the Millenium and Albian Sands Stations”. Albian Sands indicates in Figure 28 that for concentrations over 10 micrograms per cubic meter the model consistently over predicts NO2 concentrations at the Millennium and Albian Sands site. a. What has been the trend in monitored ambient NO2 concentration levels derived from WBEA monitoring data over the period of record as compared to change of emissions of NOx in the airshed? b. What are the frequency, location and magnitude of any monitored exceedances of Alberta Ambient Air quality Objectives for NO2 in the WBEA monitoring data over the period of record?
171. Volume 2, Appendix 2-8, Table 2, 3, and 6, Pages 6, 12 and 14.
48 a. Provide Tables similar to 2, 3, and 6, including the actual number of exceedances for the study period instead of the annualized data. i. The Tables should show the number of exceedances for each Station from 1988 to 2003. b. Since the WBEA treats TRS the same as H2S and reports them to Alberta Environment as exceedances, include TRS (14 and 4 ug/m3) exceedances in the tables.
172. Volume 2, Appendix 2-9, Section 6.3.6, Figure 33 and Figure 34, Page 110 and Page 111. Albian Sands states, “The percentile graph indicates that the CALPUFF modelling provided conservative estimates of VOC concentrations at the Millennium Station”. a. Has Albian Sands conducted any monitoring to characterize the effect of fugitive emissions of VOCs from their tailings pond on air quality concentrations of VOCs? b. Discuss what the results of this monitoring indicates about the effect of fugitive VOC emissions from the Albian Sands’s tailings pond on ambient concentrations of VOCs at receptors near Albian Sands and the hamlet of Fort McKay. c. What is the trend in monitored ambient VOC concentration levels derived from WBEA monitoring data over the period of record?
173. Volume 2, Appendix 2-9, Section 8.1, Page 133. This section discusses additional modeling that was performed which include the VRU upset, Basal Aquifer depressurization and slash burning. a. Were other upset conditions considered? b. Were they modeled and if so what were the results?
174. Volume 2, Appendix 2-9, Section 8.5, Page 136. Albian Sands states “an alternate PDC assessment of NO2 and PAI was completed”. Provide the results.
175. Volume 2, Section 2.2, Pages 2-6 to 2-18. Albian Sands describes air quality and potential acid deposition in pages 2-6 and 2-18. In particular, the acid deposition predictions are compared with the Provincial/CASA framework criteria. It is important to note that the NOx-SO2 Management Working Group has yet to complete work to enable Stage 2 of the framework to be implemented where modeled results would be used for acid deposition management decisions. a. Do the emissions and PAI predictions for the Muskeg River mine expansion planned development case differ significantly from predictions used in the development of the NOx-SO2 Management Working Group Acid Deposition Management Framework? b. If so, explain in terms of changes to areas that are predicted to exceed the NOx- SO2 Management Working Group “modeled” management objectives within the next 30 years.
49 Emissions Management
176. Volume 2, Section 3.4.3.4, Page 3-101. Albian Sands states, “Albian has committed to mitigation measures that will minimize acrolein concentrations resulting from the Project, including minimizing mine fleet fuel consumption and the use of mine fleet vehicles that meet applicable standards at the time of purchase.” a. Explain how Albian Sands plans to minimize fuel consumption by mine fleet vehicles.
177. Volume 2, Section 3.4.3.4, Page 3-110. Albian Sands states, “… the predicted annual nitrogen levels are conservative when compared to TEEM site monitoring conducted by WBEA. This on-going research should confirm whether the acid deposition levels predicted in Table 3.4-27 are realistic or conservative. If these predictions are realistic, it is likely that management activities will occur that will prevent acid deposition from reaching the Base Case levels presented in Table 3.4- 27.” Provide a description of management activities that would occur if this were the case.
178. Volume 2, Section 3.4.8.4, Page 3-126. Albian Sands states, “The GHG intensity for the operations phase of the expanded Muskeg River Mine is 28.8 kg CO2E/bbl based on a production rate of 270,000 bpcd. This value is slightly higher than the existing Muskeg River Mine designed basis of 22.5 kg CO2E/bbl. The increase is due to increased haul distance for the mine fleet and new fugitive estimation methodologies which indicate potentially higher emission rates.” Albian Sands also states, “The GHG intensity for indirect emissions from electricity consumption during the operations phase of the expanded Muskeg River Mine is 14.2 kg CO2E/bbl, which is based on a production rate of 270,000 bpcd. This value is slightly higher than the existing Muskeg River Mine designed basis of 3.5 kg CO2E/bbl because of greater electrical demand due to increased volume of ore processed and incremental electrical requirements being supplied from the provincial grid. The existing Muskeg River Mine uses an integrated co-generation facility whereas commercial terms for utilizing incremental co-generated electricity are under exploration for the Project.” a. What proportion of the increase from 22.5 kg CO2E/bbl to 28.8 kg CO2E/bbl is primarily due to new fugitive emissions estimates and what is due to increased haul distances? b. Discuss the new fugitive emission estimation methodologies and provide detailed calculations. c. Discuss what Albian Sands can do to achieve a target of 22.5 kg CO2E/bbl for the MRME. d. The GHG intensity for indirect emissions of 14.2 kg CO2E/bbl is substantially higher than the designed basis of 3.5 kg CO2E/bbl. Please explain how Albian Sands is planning on bringing the expanded mine in line with the designed basis. e. What GHG contribution is attributed to trucking asphaltenes from the Shell Scotford Upgrader to MRM?
50 179. Volume 2, Section 3, pages 3-123 to 126. During the 1999 Muskeg River Mine application hearing Shell committed to preparing a Greenhouse Gas Management Plan. According to the Alberta Energy and Utilities Board Decision 99-2 “The Board is prepared to accept Shell’s commitment to prepare a Greenhouse Gas Management Plan that includes emissions reduction targets for its Muskeg River Mine”. a. Provide the GHG Management Plan that was committed to in 1999. b. What are the specific emissions reduction targets for the Muskeg River Mine and the expanded Muskeg River Mine project that is being applied for? c. Provide any analysis results in support of the GHG Management Plan and comment on draft or intermediate specific emissions reductions targets that are being examined for the Muskeg River Mine and its expansion project.
Ecological Effects
180. Volume 2, Section 3.5.4.1, Page 3-168. Albian Sands states, “Since the residual impacts for Application Case PAI levels presented in the Air Emissions Effects on Ecological Receptors resulted in a negligible environmental consequence (Section 4.5), the linkages presented in Figure 3.2-3 were considered not valid and an assessment was not completed.” Considering that emissions estimates for SO2 and NOx are expected to increase by 22% and 40% respectively in the PDC, provide a discussion and information (tables and isopleth figure) for the PDC PAI predictions, similar to that of the Base and Application cases.
181. Volume 2, Section 3.5. Provide a PDC assessment for odour for the local study area.
182. Volume 2, Section 4.2.5, Page 4-11. Albian Sands states, “No PDC assessment was completed for effects of air emissions on aquatic resources, soils, vegetation, or wetlands because the effects under the Application Case were negligible.” Provide the rationale for concluding that air emission effects on aquatic resources, soils, vegetation, and wetlands are negligible.
183. Volume 2, Appendix 2-15, Section 2, Page 24. In regards to the potential effects of air emissions from the MRME and other regional developments on vegetation and wetlands Albian Sands states “As the Application Case assessment of air emission effects on terrestrial vegetation and wetlands resulted in negligible environmental consequences for all parameters, a classification of PDC impacts was not completed. The parameters have been assessed for information purposed only”. Albian Sands also states “The 24-hour criteria would be exceeded over 165 ha, reducing in area by 630 ha (<1% of the vegetated portions of the TSA) from the Base Case. This reduction in area is due to the redeployment of the mine fleets of several Oil Sands developers into a more concentrated area”. a. Justify not performing a PDC assessment despite the addition of 12 oil sands projects and an increase in four non oil sands emission sources from the application case. (Increased production is in the order of 1.5 million bbl/d).
51 b. Provide details of this redeployment to justify the decreased area that sees the lower 24-hour SO2 emissions. c. Clarify what is meant by “The parameters have been assessed for information purpose only”.
184. Volume 2, Section 4.5.2.5, Page 4-86. Provide a close-up view of the RSA and clearly differentiate between the moderate and high sensitive dots (symbols) by using two different colours.
185. Volume 2, Section 4.5.3.1, Table 4.5-1 (footnote d), Page 4-92. Albian Sands states, “Acid deposition rate from SO2 deposition, except where total N deposition is greater than 9 kg/ha/yr.” a. Provide acid deposition estimates for the regional lakes if total N deposition both below and above 9 kg/ha/yr were to be included. b. Does this affect the number of lakes exceeding the critical load?
186. Volume 2, Appendix 2-15, Page 1-30. Appendix 2-15 contains a discussion of how nitrogen deposition was handled with respect to acidification. Not all of the nitrogen was accounted for as acidifying and as a result only deposition above 9 kg/ha-yr was counted. It is important to understand that the exclusion of first 9 kg/ha- yr from acid deposition calculations has not yet been accepted by the Cumulative Environmental Management Association (CEMA) NOx-SO2 Management Working Group. a. Please provide a revised assessment of acid deposition that does not exclude the first 9 kg/ha-yr of predicted nitrogen deposition.
187. Volume 2, Section 4.5.3.1, Page 4-92. With regards to critical loads of acidity, Albian Sands states, “These results suggest that a small number of lakes in the Oil Sands Region may be at risk of acidification under the Base Case, and in some cases under background conditions. However, the assessment is believed to be conservative because it was based on simultaneous emissions from all existing and approved developments at their fully approved capacities.” Explain how the use of critical loads in this assessment can be considered conservative when N is not accounted for?
188. Volume 2, Section 4.5.3.3, Table 4.5-3, Table 4.5-5, Table 4.5-13, Table 4.5- 16, Page 4-96, Page 4-100, Page 4-106, Page 4-114. In Footnote (a), Albian Sands states, “The predictions reported for vegetated areas are based on interpolated values derived from actual CALPUFF model results (Section 3.3). As such, theses predictions may not completely agree with predictions presented in the air quality assessment.” Provide details of the calculations of the Base case and Application case SO2 and NO2 predictions for vegetated areas.
189. Volume 2, Section 4.5.3.3, Table 4.5-6, Page 4-101. With regards to nitrogen deposition, Albian Sands states, “A total of 132 ha (<1%) of vegetated areas are
52 within the 0.25 keq/ha/yr level.” However, Table 4.5-6 states that the <1% of poor fen bog in the TSA is in the >2.0 keq/ha/yr. Clarify this discrepancy.
190. Volume 2, Section 4.5.4.1, Page 4-103. Albian Sands states, “There is a very small increase in the areas of vegetation and wetlands potentially affected from direct SO2 effects between the Base and the Application cases. These small increases may be a result of modeling error and may not represent actual Project effects.” Provide Albian Sands’s rationale for this statement.
191. Volume 2, Section 4.5.4.1, Page 4-105 and 4-107. With regards to episodic stream acidification, Albian Sands states “…most of the additional area predicted to receive total N deposition above 9 kg/ha/yr, which is the estimated threshold for significant NO3 leaching, is within the mine footprint,” and “Uncertainty in predictions related to episodic acidification is the result a lack of detailed understanding regarding the future role of N in surface water acidification in the Oil Sands Region.” a. Specify what is meant by “most”. b. Would an analysis of areas receiving total N deposition both below and above 9 kg/ha/yr change the estimated frequency and severity of episodic stream acidification?
192. Volume 2, Section 4.5-4, Page 4-107. With regards to Air Emission Effects on Ecological Receptors - Certainty and Prediction Confidence, Albian Sands states, “The analysis of air emission effects is conservative in the protective sense because of the conservative approach used to model acid deposition (i.e. simultaneous emissions at the fully approved rates from all developments; use of conservative NOx emission estimates). Therefore, exceedances of the critical loads do not necessarily indicate a future effect, but rather highlight the potential for effects.” Explain how calculating acid forming compounds as the sum of the SO2 and 70% of the NOx emissions, using 9kg/ha/yr as the estimated threshold for significant NO3 leaching, and basing acid deposition on SO2 alone results in a conservative prediction of air emission effects on ecological receptors.
Regional Management
193. Volume 2, Appendix 2-5, Section 2.2.1, Page 5 and Volume 2, Section 4.3.4.1, Table 4.3-7, Page 4-34. Albian Sands states, “Albian believes the existing WBEA program and system are adequate to monitor ambient air quality following commissioning of the Expansion project.” On Page 4-34, Table 4.3-7, Section 4.3.4.1 of Volume 2, Albian Sands notes that there is a lack of air quality monitoring for acrolein to validate the conservatism of the modeling. Clarify how increased ambient monitoring for acrolein will be captured through the existing WBEA program.
194. Volume 2, Appendix 2-14, Table 95, Page 158. Table 95 indicates exposure ratios for acrolein are predicted to be greater than one. In Volume 2, Section 4.2,
53 page 4-8 Albian Sands states “Therefore, Albian proposes to work with the WBEA to investigate methods for measuring acrolein in ambient air in the Oil Sands Region within the regional air quality monitoring program”. a. What specific steps will Albian Sands take to carry out acrolein monitoring in the region? b. Over what timeframe would such monitoring take place and when could first results and conclusions be expected?
AQUATICS
Water Intake and Infrastructure
195. Volume 1, Section 10, Page 2, and Volume 3, Appendix 3-6, Page 6. In 2012 Albian Sands plans to build a sedimentation pond to maintain and regulate flows to the downstream reaches of Mills Creek and subsequently to Isadore’s Lake. Water from the Athabasca River will be pumped into the pond to attenuate the flow. The total suspended solids (TSS) levels in Mills Creek (Table G-6, Volume “Aquatics”, Appendix G) are significantly lower throughout the year than in the Athabasca River. TSS levels in the Athabasca River are known to be high with a significant portion of the suspended solids in the form of very small particles which have a very long settling time. a. Provide the calculations and/or modeling used to establish the retention time required for the water in the pond to reach acceptable TSS values. b. Were these results used in calculating the required pond size?
196. Volume 1, Section 10.2, Page 10-6. Albian Sands states, “Both diversion channels will be designed to convey the 100-year flood event with 0.6 m of freeboard.” a. Explain how the 0.6 m value was obtained. b. Explain whether planning for a 100-year flood event is still adequate.
197. Volume 1, Section 5.2, Segment 18 to 19, Page 5-14. Albian Sands has identified a new access road and utility corridor located 100 to 200 metres east of the existing plant access road. Volume 1, Section 5.2, Page 5-16, Figure 5-6, shows a typical cross-section of the corridor area. Clarify the measures proposed to ensure that a 100 year Muskeg River flood event does not erode the corridor fill material supporting the proposed infrastructure.
198. Volume 1, Section 8.6, Muskeg River Bridges, Pages 8-16, 8-18. This section describes the bridge design and construction criteria: a. Describe the proposed concept for leak detection and spill containment for the tailings bridge crossing including sizing of any abutment ponds required. b. How will the leak detection/spill containment requirements differ for the other two bridges?
54 199. Volume 1, Section 10.2, Page 10-6, Page 10-8. Albian Sands states, “During operations, runoff from these sources will be collected within a closed circuit system and used in the process. Runoff from the plant site will be collected with the treated plant wastewater and sent to the process water recycling pond. Ditches designed and built to avoid ponding will collect the onsite road drainage within the plant and ore preparation areas. Culverts will be provided at road crossings. The water will be treated in sedimentation ponds to remove oil before being mixed with the closed- circuit industrial water system for recycling.” a. Explain how the sedimentation ponds are sized (e.g., with respect to storm events). b. On Page 18-21, Albian Sands states, “The recycle water pond collects waters from: • water reclaimed from the external tailings disposal area • surface runoff from developed areas • mine wall seepage • boiler blowdown • backwash from water treatment system • treated sewage” c. Clarify whether water from all of the above sources can be effectively treated for release.
200. Volume 3, Section 5.5.5.2, Page 5-242. Albian Sands states, “If thermal effects in the streams are observed or anticipated, the residence time in the polishing (sedimentation) ponds will be increased by enlarging and deepening the ponds.” In Volume 3, 5-244, Albian Sands states, “Also, dissolved oxygen concentrations can be improved by modifying the pond design to increase or promote atmospheric re- aeration.” How economic would it be to make modifications to the sedimentation ponds such as emptying, enlarging and deepening them?
201. Volume 1, Section 16, Page 25. Albian Sands states, the “…expansion project will not increase water withdrawal from the Athabasca River beyond Albian Sands current licensed limit.” Compare the average daily, monthly and yearly rates of water withdrawal from Albian Sands’s existing water intake before and after the proposed Muskeg River Mine Expansion Project, throughout the life of the project.
202. Volume 3, Section 1.4.6, Page 1-25. Albian Sands states, “The process of evaluating potential effects of the Project on receptors may result in the identification of opportunities for Project re-design to eliminate or minimize a potential effect. This iterative process is an integral component of the Project design engineering team working with those completing environmental and social impact assessments. Through this process, many potential effects of the Project were eliminated during the process of completing the design premise of the Project.” a. Provide a list of potential effects of the Project that were eliminated during the process of completing the design premise of the Project. b. Explain why and how each effect was eliminated.
55 Fish and Fish Habitat
203. Volume 1, Section 10.2, Page 10-4. Albian Sands states, “Clean water will be discharged to natural receiving streams to maintain aquatic ecosystems. Sources of clean water will be: • drainage from undisturbed areas • muskeg drainage and overburden dewatering • runoff from: o off-site roads o reclamation material stockpile areas o overburden disposal areas (OBDAs) • mine surface runoff, where water quality objectives can be achieved before water is discharged to receiving watercourses”. Explain what modeling, monitoring and mitigation will take place to indicate that enough clean water is being discharged to maintain ecosystems.
204. Volume 1, Section 16.7, Page 16-32. Albian Sands states, “The temperature of outflows and downstream receiving waters will be monitored continuously for two years to ensure that thermal effects on receiving streams, if any, are small. If detrimental changes to the thermal regimes of receiving streams are observed or anticipated, outflows from the pit lakes will be directed to shallow ponds or wetlands…” a. Provide evidence that two years of monitoring is adequate. b. Explain whether the operation of the ponds will be altered following the two year period of monitoring. c. Are there any other parameters being monitored? The statement suggests that only temperature will be monitored. i. Discuss whether biological receptors of temperature changes (such as benthic invertebrates, aquatic flora, ice conditions, and ultimately fish), will be monitored for indications of impacts as a result of temperature changes.
205. Volume 3, Section 5.1.2.2, Page 5-6. Albian Sands states, “The selection of the RSA included the LSA and likely spatial extent of potential effects that could measurably affect aquatic resources. The RSA includes the Athabasca River from Fort McMurray to Embarras as this includes the zoogeographical distribution and movements of several of the Muskeg River watershed fish species.” a. Explain how the “likely” spatial extent of potential effects was determined. b. Explain how confident Albian Sands is that potential effects will not extend beyond the proposed regional and local study areas for this project.
206. Volume 3, Section 5.1.3, Page 5-7. Albian Sands states, “Some of the assessment nodes described above were unique for certain aquatic resources components. For example, Node S24 was assessed for only the hydrology and fish habitat changes, while the remaining assessment nodes on the Athabasca River (Nodes A1, A2 and A3) were assessed for the water quality, fish and fish habitat changes.” Clarify why Node S24 was not assessed for water quality changes.
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207. Volume 3, Section 5.2.3, Page 5-24. Albian Sands states that the Project will result in a maximum reduction of total open-water within the LSA during operations in 2020 by up to 0.2 km2 from pre-development conditions. Volume 3, Conceptual Compensation Plan, Table 6 states that the estimated habitat losses in the Project area will reach 688,667 m2 from the physical elimination of fish habitat. Clarify Albian Sands’s reference to “open water” and indicate at which part of the year the “open water” calculations were performed. Discuss the apparent discrepancy.
208. Volume 3, Section 5.6.3, Page 5-282 and Table 5.6-1, Page 5-268. Table 5.6-1 lists Key Indicator Resources selected for the Muskeg River Mine Expansion Project. Northern pike is the only species of fish recorded in Isadore’s Lake and as such is the only Key Indicator Resource selected. When describing Isadore’s Lake environmental setting on page 5-282 the report mentions “…evidence of a summerkill event observed during the July 2004 survey when large numbers of dead brook stickleback and fathead minnows were observed ….” Explain the discrepancy. Discuss why brook stickleback has not been included in the list of Key Indicator Resources selected for Isadore’s Lake.
209. Volume 3, Section 5.6.3, Page 5-285 and Table 5.6-3, Page 5-285. The table indicates that there is no data for Unnamed Watercourse 5. It is assumed that the creek is non-fish bearing, being of small size and having steep gradient (Appendix 3- 6, Page 12). a. Clarify whether the non-fish bearing status was derived only from orthophotography, and if the non-fish bearing status includes the mouth of the creek. b. Discuss whether the majority of water in the creek originates from a muskeg area on the top of the Athabasca River escarpment. c. Discuss the effect that the removal of the upstream top portion of the creek (175 m2 of the stream) will have on the flow in the Unnamed Watercourse 5, giving special consideration to the lowermost part of the creek. d. Explain why an average gradient of 3.3% and a maximum gradient of 6.4% were considered a major factor in declaring the Unnamed Watercourse 5 as a non-fish bearing creek.
210. Volume 3, Section 5, Table 5.5-5, Page 5-202, and Table 5.5-12, Page 5-231. Numerous chemical parameters are projected to exceed Water Quality Guidelines, especially in the Far Future scenario. For example, molybdenum is predicted to have a 10-fold increase over chronic levels, and selenium concentrations will double over pre-development concentrations. Selenium is known to affect reproduction and fry survival in fish. a. Describe any additional research Albian Sands plans to conduct to determine if there are any negative effects/responses due to an increase in these chemicals in the ecosystem. b. This section reports significant increases in selenium concentrations. In the predevelopment case these substances were on the borderline of having chronic
57 effects. The base case combined with the application case indicates significant increases in selenium concentrations over chronic effects. Selenium is also elevated in Isadore’s Lake in the Far Future scenario. Discuss how Albian Sands determined that elevated levels of molybdenum and selenium would not impact current and future fisheries in the watersheds affected by this development. c. Indicate whether there will be any increases in molybdenum and selenium in the Muskeg River and Jackpine Creek associated with the mine.
211. Volume 3, Section 5.6.5.2, Page 5-300/306. Fish are considered to be the most sensitive aquatic organisms to selenium (Coyle et al. 1993; Hamilton and Buhl 1990; Hermanutz et al. 1996). Peak selenium concentrations in fish tissue in Isadore’s Lake are predicted to exceed the benchmark of 2.13 μg/g wet weight in 2054 when the West Pit Lake initially outflows. The predicted peak concentrations of 2.4 μg/g wet weight represents a potential increase of 13% over the toxicological benchmark. The magnitude of the potential effects is, therefore, rated as low. Frequency and duration are rated as high and long-term, since the source of the selenium is continuous and the predicted increase occurs after operations cease. This high selenium concentration will also occur in pit lakes as indicated on Page 5-331. a. Selenium is known to affect reproduction and fry survival in fish. Exceedances of this benchmark could impact the long-term suitability of Isadore’s Lake and the pit lakes for fish. b. Discuss any mitigation options that can be taken to reverse this effect. c. Describe the likelihood that Isadore’s Lake and the pit lakes will not be able to support self-sustaining fisheries in the future.
212. Volume 3, Section 5.6.2.4, Page 5-306. Albian Sands states, “Peak selenium concentrations in fish tissue in Isadore’s Lake are predicted to exceed the benchmark of 2.13 µg/g wet weight in 2054 when the West Pit Lake initially outflows. The predicted peak concentration of 2.4 µg/g wet weight represents a potential increase of 13% over the toxicological benchmark. The magnitude of the potential effects is, therefore, rated as low. Frequency and duration are rated as high and long-term, since the source of the selenium is continuous and the predicted increase occurs after operations cease.” Chronic exposure to relatively low doses of selenium can lead to detrimental developmental effects in bird and fish embryos (Environ. Toxicology & Chemistry, 24 (9), 2373-2381). Discuss how confident Albian Sands is that a 13% increase above the toxicological benchmark of selenium concentrations in Isadore’s Lake with a high frequency and long term duration, will have only a low magnitude for causing potential effects.
213. Volume 3, Section 5.6.5.2, Page 5-312. There are a number of uncertainties regarding the effects of water quality on fish. Many chemical parameters already exceed chronic toxic effects. The Project as described may further compound these exceedances. Describe how Albian Sands plans to confirm that the predictions made regarding the effects of water quality on fish are accurate.
58 214. Volume 3, Section 5.6.2.4, Page 5-320 to 321. Three options are listed for proposed fish habitat compensation. a. Clarify whether Albian Sands will implement all three options. b. If not, provide the decision criteria for selecting among the options.
215. Volume 3, Section 5.6.2.4, Page 5-326. Albian Sands states, “The findings of the fish habitat and fish abundance assessment (Section 5.6.5.2) determined that predicted changes in habitat area and habitat conditions would have no residual negative impacts on fish habitat or fish abundance.” Explain the predicted changes in species assemblage in the local and regional study areas as a result of project-related habitat changes.
216. Volume 3, Section 5, Pages 5-297 to 5-299. Fish are known to exhibit a strong avoidance reaction to sulfide. a. Indicate whether the elevated sulfide concentrations in Muskeg River and Jackpine Creek will affect the migration of fish up these systems. b. Indicate at what times of the year elevated sulfate conditions occur in these systems. c. Indicate whether the elevated levels will coincide with the historic movement of fish as they migrate from the Athabasca River.
217. Volume 3, Appendix 3-6, Pages 22-31. Albian Sands proposes three options for the development of compensation habitat. According to Table 6, which presents a summary of estimated habitat losses and gains for the Muskeg River Mine Expansion, the habitat lost is much greater (688,667 m2) than the habitat gained (389,451 m2). The majority of the habitat gained is achieved by using compensation credits from the Shell Jackpine Mine Phase 1 No Net Loss Plan. The Compensation Plan for Jackpine Mine Phase 1 has not been approved by the EUB, and there is a great uncertainty regarding the success of the plan. Considering the above and the length of time required for the compensation to demonstrate viability: a. Discuss the time frame for Khahago Lake to be a viable fish habitat. b. Khahago Lake is expected to replace stream habitats cut off by the Jackpine mine to minimize fish habitat loss. It will be isolated from the Muskeg River drainage for many years. Khahago Lake habitat may only support forage fish species. Clarify whether Albian Sands is proposing isolated Khahago Lake forage fish habitat as a replacement of losses to sport fish habitat currently connected to the Muskeg River. i. If so, provide rationale for this choice. c. If Khahago Lake is determined to be an unacceptable option for compensation or if Khahago Lake fish habitat takes a longer time than anticipated to achieve full potential, provide and discuss other alternatives for fish habitat compensation.
218. Volume 3, Appendix 3-2, Section 5.3, Page 24. Table 6 provides a summary of estimated habitat area losses and gains for the Muskeg River Mine Expansion. According to Albian Sands, 688,667m2 of aquatic habitat will be lost and 389,451m2 of potential compensation is identified. The 2:1 compensation ratio is based on
59 productive capacity not habitat area, so the 389,451 m2 of compensation may be adequate. Provide evidence and discuss how confident Albian Sands is that 389,451m2 will satisfy the 2:1 habitat compensation ratio.
219. Aquatic Environmental Setting Report, Section 3.2.8, Page 3-23. Albian Sands states, “Sampling was conducted using drift traps designed after Burton and Flannagan (1976), with trap opening dimensions of 15 x 15 cm, and a mesh size of 500 µm.” Small animals, early instars of larval insects, and especially midge larvae are severely undersampled by mesh sizes of 500um or larger. A mesh size of 250µm is generally thought to be the best compromise (Taylor, B.R. January 1997). Explain why a smaller mesh size was not used in the invertebrate drift surveys.
220. Aquatic Environmental Setting Report, Section 6.2.1.8, Page 6-15, Table 6-2. In Table 6-2, what fish inventory methods are being referred to by the acronyms SN and SL?
Water Quality and Pit Lakes
221. Volume 1, Section 7.1, Page 7-4. Albian Sands states, “Eighteen in-pit cells will be created when the area is mined and used for tailings disposal, comprising…three in-pit clarification cells (cells 7, 12A and 16) to store the TFT fluids generated from the NST deposition. At closure, these three cells will be converted to pit lakes and the TFT fluids remaining in the cells will be water capped.” Explain how cells 7, 16 and 12a were chosen for the pit lake locations and what alternative locations were considered.
222. Volume 3, Section 5.4.5.3, Page 5-143. Albian Sands states, “Albian will continue its active participation and support to CEMA as well as its task groups including the End Pit Lakes task group.” Explain what pit lake research, management and monitoring Albian Sands has completed, or plans on completing, in addition to the CEMA End Pit Lake task group.
223. Volume 3, Section 5.4.5.3, Page 5-146. Albian Sands states, “The pit lakes at closure include the East, East Central, West Central and West pit lakes. The West Pit Lake will discharge to Isadore’s Lake and the other pit lakes will discharge to the Muskeg River.” At mine closure, maintaining the integrity of the two pit lakes constructed along the border of the Muskeg River will be important to the sustainability of the reclaimed flow regime of the Muskeg River. a. Explain what specific opportunities currently exist aside from the CEMA End Pit Lakes Subgroup and Watershed Integrity Task Group, to cooperate with other projects in the Muskeg River watershed. b. Additionally, what actions are being taken by Albian Sands to improve pit lake utilization and understanding in order to aid in the maintenance future reclaimed watersheds.
60 224. Volume 3, Appendix 3-2, Page 37. Albian Sands states, “The dykes have sufficient elevation of 282.5 masl to prevent dyke overtopping even in the event of a probably maximum flood in the Muskeg River.” How confident is Albian Sands that during a flood event, there is sufficient storage in these two pit lakes to prevent overtopping of the dykes along the Muskeg River?
225. Volume 3, Section 5.5.4.6, Page 5-215. Albian Sands states, “PAHs are hydrophobic and strongly adsorb to soil particles, therefore they will not travel with seepages to receiving waterbodies and watercourses. Consequently, PAH concentrations in sediment of the Athabasca and Muskeg rivers will not be affected by seepages into these rivers.” Polycyclic aromatic hydrocarbons (PAHs) can enter water through discharges and certain PAHs move through soil. (Agency for Toxic Substances and Disease Registry (ATSDR). 1995.). Please justify and explain the conclusion that PAHs will not travel with seepages to receiving waterbodies and watercourses and that the Athabasca and Muskeg rivers will not be affected.
226. Volume 3, Section 5.5.5.2, Page 5-227. Albian Sands states, “A change of less than 10% (in concentration of key substances or constituents) was considered to result in negligible effect on water quality.” a. How confident is Albian Sands that a change of less than 10% of any substance listed in Table 5.5-10 will result in only a negligible effect on water quality? Provide a peer-reviewed scientific rationale to further support this conclusion. b. Does the above conclusion remain the same when the effect of a moving baseline is considered?
227. Volume 3, Section 5.5.5.2, Page 5-233, Figure 5.5-11. Figure 5.5-11 illustrates the cumulative distribution curves for total dissolved solids (TDS) at Muskeg River Mouth. Explain why there is a reduction in TDS concentrations from the Base Case to the Application Case.
228. Volume 3, Section 5.5.5.2, Page 5-238. Albian Sands states, “Water quality in the Athabasca and Muskeg rivers, Jackpine Creek and Isadore’s Lake are, and will continue to be, monitored on a regular basis.” Clarify how often water quality monitoring will occur in these receiving streams.
229. Volume 3, Section 5.5.5.2, Page 5-238, 5-239. Albian Sands states, “The RAMP currently monitors receiving stream quality at several sites, while CEMA has several initiatives to study water quality effects in receiving streams. Albian will continue to participate in these studies to determine performance of mitigation measures.” a. As the water quality task group of CEMA has not received funding for several years, clarify what CEMA initiatives Albian Sands has or will participate in related to water quality effects in receiving streams. b. Since both CEMA and Regional Aquatics Monitoring Program (RAMP) are regional programs not designed to measure changes or effects from a specific development, explain what receiving stream quality monitoring Albian Sands has planned in addition to CEMA and RAMP.
61
230. Volume 3, Section 5, Table 5.5-17, Page 5-251. Table 5.5-17 indicates that a large number of water quality parameters within the pit lakes will not meet aquatic life guidelines and will be above normal background levels for this area. a. Indicate how the Alberta Water Quality Guidelines will be achieved prior to discharge. b. Provide the maximum retention time provided by pit lakes.
231. Volume 3, Section 5.5.2.4, Table 5.5-1, Page 5-184. Suspended solids were not included in the water quality assessment. This parameter is one of the most important indicators of change in flows. Provide the analysis for Albian Sands’s suspended solids.
232. Volume 3, Section 5.5.2.6, Page 5-187. Modeling incorporates the release of operational and reclamation waters. The timing and magnitude of releases can be important factors in water quality impact assessment. a. Clarify the expected timing and magnitude of releases (i.e., will releases occur continuously or in large flush events?). i. Also indicate how this is addressed in the models.
233. Volume 3, Section 5.5.2.6, Page 5-187. The pit lake model assumes complete mixing of the lakes. Albian Sands indicates that the pit lakes will be fairly deep, suggesting the possibility of thermal stratification (Appendix 3, Page 86). a. Discuss the implications of thermal stratification (or halocline due to salinity) on the impact assessment. b. Provide maximum release and loading rates from bottom sediments if the pit lake contained a highly reduced hypolimnion.
234. Volume 3, Section 5.5.3.6, Page 5-192. Predicted water quality for pre- development case was compared to base, application and planned development. This case is based on water quality data up to 2003. It remains unclear from the presentation how well predicted pre-development water quality compares to observed data. Discuss the similarities (or differences) and demonstrate that the assumed log- normal distributions used for modeling are appropriate for the observed data.
235. Volume 3, Section 5.5.4.3, Table 5.5-3, Page 5-197. Median and peak concentrations are modeled. However, there is no indication as to how often peak concentrations are reached, compared to pre-development. a. Clarify the distribution of peaks and lows. b. Discuss the rationale for the reported ranges in peaks.
236. Volume 3, Section 5.5.5.2, Page 5-218. Albian Sands assumes that Mills Creek will have concentrations similar to Isadore’s Lake. Stream chemistry is very different than that of a lake because it is much more responsive to changes in a watershed that affect flows. Clarify Albian Sands’s position in this matter and explain why Isadore’s
62 Lake was used as an indicator of environmental impact, while Mills Creek appears to be a much stronger candidate.
237. Volume 3, Section 5.5.5.2, Page 5-219. On Page 5-242, biological oxygen demand (BOD) effects on the Muskeg River and Isadore’s Lake are considered a valid linkage. However, on Page 5-212, the mitigative ability of polishing ponds is noted as being generally low, indicating no BOD impact. This depends on retention times of the polishing ponds. a. Clarify all assumptions made in the water quality impact assessment concerning polishing pond efficiency and retention time. b. Discuss the impacts if polishing ponds operated at the lower limit of predicted efficiency due to upsets, excessive water, etc.
238. Volume 3, Section 5.5.5.2, Page 230. Albian Sands did not compare the Application Case to Observed Natural Variation. In some cases, the upper range of peak application case is much higher than peak observed natural conditions (e.g., sulphate is over 4 times higher). Elaborate on the significance of these findings.
239. Volume 3, Section 5.5.5.2, Page 230. The impact of climatic patterns on lakes is particularly relevant, because contaminants can accumulate and be re-introduced into the water column. a. Describe how Albian Sands accounted for any climatic patterns that can create natural cumulative impacts from one year to the next (e.g., a small increase in TDS, Total Phosphorous, etc. this year may accumulate in the system and increase next year). b. Discuss the long-term trends that these climatic patterns may produce.
240. Volume 3, Appendix 3, Page 67. LC50 units for water quality parameters are usually noted as concentrations, not percentages as provided in the EIA. Clarify Albian Sands rationale for providing the data as percentage values.
241. Volume 3, Appendix 3, Page 69. The water quality model appears to be calibrated with the same data that was used to create distributions to populate the model. If this is true, validate the model using a different data set than that used for calibration. If no additional site data are available, consider validation to a reference system.
242. Volume 3, Appendix 3, Page 70. Mine-related water releases were added to the model as continuous flows. Clarify Albian Sands’s rationale for doing so. Discuss potential impacts assuming 25% of the polishing pond capacity is pumped to the receiving stream at the maximum pumping rate of the designed infrastructure. An assessment based on the percentage of pumped storage in current operating procedures (e.g. the Alsands Drain, Aurora – Stanley Creek) would also be appropriate.
63 243. Volume 3, Appendix 3, Page 77. The water quality models used by Albian Sands utilized observed data from source water rather than surface runoff quality from reclaimed areas. Source water and reclaimed runoff water can be quite different in quality. a. Discuss the impacts if actual water quality data from reclaimed landscapes (e.g. Syncrude and Suncor) were used and indicate why these were not incorporated into the EIA. b. Assume surface runoff from reclaimed landscapes is similar to current overburden water quality. Recalculate the worst-case scenarios substituting overburden dewatering quality as the potential loading from surface runoff from reclaimed land if data from reclaimed soils is not available.
244. Volume 3, Appendix 3, Page 80. Lake water quality can be highly influenced by internal processes (internal loading, settling, decomposition, etc.). Calibration and validation of this model was not performed (a similarly deep lake in northern Alberta would have been appropriate). Therefore it is unclear whether the assumptions in the model make its predictions worst case. a. Describe how internal processes could affect the water quality of the pit lakes. b. Discuss the effect of excluding these processes from the model.
245. Volume 3, Appendix 3, Page 135. This section provides a general overview of climate change predictions. Provide a more thorough description of these predictions.
Hydrology
246. Volume 1, Section 16.5, Page 16-21. Albian Sands states, “A groundwater monitoring program is in place and a response plan is being developed to ensure any groundwater impacts from spills or leaks are identified promptly along with the appropriate remedial responses to be implemented.” a. Clarify when the response plan will be ready and provide the details of the response plan. b. Provide a plan of the entire project area that shows the conceptual design of the groundwater monitoring. i. Clearly identify proposed locations of dewatering wells, monitoring wells and when they would be installed.
247. Volume 1, Section 16.5, Page 16-22. Albian Sands states, “Groundwater seepage from the reclaimed landscape could reach surface waterbodies, including the Muskeg River, Jackpine Creek and pit lakes. If higher than predicted seepage is detected, measures such as subsurface drains to intercept the seepage or additional low permeability barriers to reduce the seepage could be used. In addition, alterations to the reclaimed surface to influence shallow groundwater flow directions could be considered during the expansion project’s life.” What mitigation will Albian Sands implement to reduce seepage?
64 248. Volume 1, Section 16.5, Page 16-22. Albian Sands states, “…should unexpected effects on surface water result from basal aquifer depressurization, possible mitigation alternatives include: • changing the location and pumping rate of individual depressurization wells • releasing overburden dewatering water or diverting surface water to the affected area” a. Discuss Albian Sands’s experience with Basal Aquifer depressurization at Muskeg River Mine and its impact on surface waterbodies. b. Identify mining areas that may require more vigilant monitoring to ensure that unanticipated impacts are identified immediately. For example, would Lease 90 South Pit be one such area due its proximity to the Muskeg River and relatively thin McMurray formation?
249. Volume 1, Section 16.6, Page 16-25. Albian Sands states, “The expansion project will not increase water withdrawal from the Athabasca River beyond the Albian Sands current licensed limit. Therefore, the expansion project has no effect on flows in the Athabasca River.” a. Clarify whether the current licensed limit discussed above includes withdrawals resulting from Jackpine Mine. b. Although Albian Sands will not be withdrawing past current licensed limits, the withdrawal that is occurring could still have some affect on flows in the Athabasca River. Explain whether Albian Sands examined the effect their current licensed withdrawal is having on the Athabasca River. c. Given that Albian Sands will still be within their current licensed amount, what will be the predicted change in actual water withdrawals resulting from the proposed expansion?
250. Volume 1, Section 10.3, Page 10-14, Figure 10-3. Albian Sands proposes to withdraw up to the licensed limit in years 2015, 2017, 2023, 2027, 2029, 2031, 2032. Explain what contingency plan is in place if restrictions are placed on withdrawals in some of those years or if Albian Sands requires more water than anticipated due to emergency withdrawals, for example.
251. Volume 3, Appendix 3, Page 135. Climate change effects may be felt seasonally in timing and peak flows (e.g., more storms, shorter ice-cover period, etc.). a. Discuss the potential for more intense summer storms, less snow, earlier melt etc. that could occur with climate change. Discuss the implications of these events on existing and planned projects. b. Explain why accidental discharges were not factored into the models.
252. Volume 3, Section 1.4.3, Page 1-9. CEMA’s Instream Flow Needs Working Group has recently recommended a threshold value for the Athabasca River. This means that if the river flow reaches this level, withdrawal by industry may not be allowed. Discuss any contingency plans Albian Sands has to fulfill their water demand in such a situation.
65 253. Volume 3, Section 5.2.2.1, Page 5-15. Albian Sands states, “The drawdown of groundwater levels in the Basal Aquifer will be long-term; however, groundwater levels will recover to near premining elevations several decades following completion of depressurization operations.” a. Provide a timeline for how long it is estimated for groundwater levels to recover. b. Explain the difference between premining groundwater elevations and what the predicted groundwater levels will be several decades following completion of depressurization operations.
254. Volume 3, Section 5.2.2.3, Page 5-17. Albian Sands states, “Basal Aquifer depressurization is estimated to change groundwater seepage to the Athabasca River, Muskeg River and Jackpine Creek of 15,360, 1,450 and 400 m3 /d, respectively in 2020.” Volume 3, Section 5.3.5.6, Page 5-83. Tables 5.3-6 & 5.3-7 extend only to the year 2020. a. Clarify why results for the year 2020 are presented. b. Confirm that modeling of basal aquifer depressurization past 2020 will occur.
255. Volume 3, Section 5.3.2.1, Page 5-40. Albian Sands states, “It is not expected that drawdown exceeding 1 to 2 m would be observed at a distance exceeding 30 km.” a. Discuss how this was determined and how confident Albian Sands is that greater drawdown will not extend beyond 30 km. b. How have regional (Planned Development Case) hydrogeological considerations been incorporated into this estimate? c. Discuss efforts by Albian Sands and others to develop a regional hydrogeological model that can answer these and other related questions?
256. Volume 3, Section 5.3.5.4, Page 5-65. Albian Sands states, “The maximum incremental decrease in groundwater discharge to the Muskeg River as a result of the Project would therefore be approximately 1,100 m3/d.” Table 5.3-4 on page 5-70 provides the reduction in groundwater discharge to receiving streams due to overburden dewatering application case. The values in that table for the Muskeg River are higher than 1,100m3/d. a. Clarify which values are accurate and provide the maximum reduction in discharge to the Muskeg River that is expected as a result of the Project. b. Explain the significance and potential impacts (in terms of percentage reduction in baseflow) to the Muskeg River due to this decrease in groundwater discharge.
257. Volume 3, Section 5.3.5.9, Page 5-95. Albian Sands states, “The groundwater quality in the reclaimed lands is generally expected to be poorer than groundwater quality in the surrounding Quaternary deposits and the Basal Aquifer, due to the presence of salts, hydrocarbons and naphthenic acids in the reclaimed tailings backfill materials.” a. Explain which substance is the most problematic contaminant in reclaimed tailings materials.
66 b. Provide the toxicity, mobility, and persistence of the most problematic contaminant in reclaimed tailings materials.
258. Volume 3, Section 5.4.3.3, Page 5-121. Albian Sands states, “The lake level has been monitored by RAMP since February 2000.” A record of actual monitored data from 2000-2003 is not long enough to understand the long term water pattern in Isadore’s Lake. a. Clarify whether Albian Sands consulted air photo data to further understand the lake’s long term water pattern (if so, provide the record of data used) and confirm that continued monitoring of Mill’s Creek and Isadore’s Lake will continue until significant disturbance of flows begin (~2012 with the commencement of construction activities in Mills Creek watershed). b. Confirm whether Albian Sands has or will be conducting point monitoring of Isadore’s Lake outflows over a wide range of lake levels.
259. Volume 3, Section 5.4.5.3, Page 5-146. Albian Sands states, “Starting in 2012, water from the Athabasca River will be pumped to a sedimentation pond that will be located upstream of the lake. Water will be released from the sedimentation pond, which will be located upstream of the lake, to the lower end of Mills Creek to maintain the mean monthly flows the creek and the water balance in Isadore’s Lake.” a. The success of this plan will depend on there being enough reserve water in the proposed sedimentation pond to compensate for any uncertainty in the water balance for Isadore’s Lake. Explain whether Albian Sands considered any alternative water supply plans for Isadore’s Lake. b. Provide details of the final design and operational plan for the proposed sedimentation pond. c. Will use of the proposed sedimentation pond continue in perpetuity?
260. Volume 3, Section 5.4.3.4, Page 5-124. Albian Sands states, “…the mean annual flow of the Athabasca River at Station S24 will be reduced by about 2%.” Explain the potential impacts on the aquatic ecosystem of the Athabasca River from a 2% decrease in flows.
261. Volume 3, Section 5.4.5.3, Page 5-141. Albian Sands states, “The local streams and lakes in the PDA include an unnamed creek…” Explain what baseline studies were conducted on Unnamed Creek.
262. Volume 3, Section 5.4.5.4, Page 5-167. Albian Sands states, “Only Cell 7 (location of West Central Pit Lake) and Cell 16 (location of East Central Pit Lake) will be located within the 100-year flood risk limits.” What is the potential significance of these cells being located within the 100-year flood risk limits?
263. Volume 3, Section 5.4.5.4, Page 5-169, 5-171. Albian Sands makes reference to studies on detailed design criteria for final design of the reclamation systems and on the erodibility of sand and overburden materials from which reclamation drainage
67 channels will be built. Clarify what studies have been done, and the status of any studies currently underway or planned.
264. Volume 3, Section 5.6.5.2 Key Question AR- 4, Page 5-315. Albian Sands has proposed three new bridges with clear spans of 30 m. The bridges are designed to handle a 100-year flood. a. Indicate how Albian Sands calculated the 100-year flood level. b. Describe what data was used in the calculations.
265. Volume 1, Section 8.5, Page 8-11 – 8-12. Albian Sands states, “Part of the existing utility corridor and plant access road will be relocated to the east along the mineral surface lease (MSL) boundary… The detailed design will be based on ensuring that all utility corridors will: • Minimize the impact on resource recovery • not pass through active areas in the mine plan • be offset from waterways to avoid environmental impacts” a. Explain what alternatives to this joint utility corridor were considered for linking the Jackpine Mine and Muskeg River Mine. b. Explain what alternative locations for the utility corridor were considered.
266. Volume 1, Section 8.6, Figure 8-1, Page 8-17. Figure only identifies two bridge locations. Provide the location of the third bridge crossing and identify/label the three bridges (conveyor, tailings and heavy hauler).
267. Volume 1, Section 12.2, Page 12-4. Albian Sands states, “Connecting pipelines will cross Muskeg River and Jackpine Creek. Water crossings will be above ground on pipeline utility bridges, and will incorporate leak detection systems and secondary containment.” a. Explain what mitigation strategy would be implemented in the event of a leak. b. Explain what maintenance plans are in place for the proposed connecting pipelines. c. Explain the design plans for the secondary containment associated with the water crossings. d. Explain how the bridge locations were chosen. e. Provide the alternative bridge locations considered.
Hydrogeology
268. Volume 1, Page 1-18 and Volume 3, Section 1.4.5, Page 1-17. Albian Sands provided lists of key environmental and oil sands assessment issues. Groundwater quality and flow are excluded from both lists. Explain why impacts on groundwater quality and flows are not considered key issues.
269. Volume 1, Section 3.3 and Volume 3, Section 5.3. Hydrogeological information provided in Volumes 1 and 3 confirm the presence of a tributary to the Pleistocene Channel, called the Sharkbite Channel. Based on the information provided in the EIA,
68 it cannot be determined whether the Sharkbite Channel represents a significant groundwater resource. a. Provide aquifer test data (transmissivity, long-term yield) to determine if the Sharkbite Channel can be considered an "exceptional aquifer" and/or a "domestic use aquifer" as defined by Alberta Environment, and whether or not there is a hydraulic connection to the Pleistocene Channel Aquifer. b. Discuss Albian Sands’s plans and schedule for clarifying the significance of the Sharkbite Channel and the potential impact of the project on that resource. c. Clarify why Albian Sands is of the opinion that this project should proceed despite the potential impact on the Sharkbite Channel. d. Figure 3-10 on Page 3-21 of Volume 1, Section 3.3 does not indicate the presence of the Sharkbite Channel. Provide an updated version of Figure 3-10 including the Sharkbite Channel. e. Describe the geomorphology of the Sharkbite Channel and its relation to the Pleistocene Channel and provide a comparison of the geological composition of the Sharkbite and Pleistocene channels (grain size analysis, mineralogy).
270. Volume 3, Section 5.3.5.9, Page 5-93. Albian Sands states, “The Muskeg River Granular Deposit, although limited in lateral extent represents an aquifer suitable for water supply. Thick sand and gravel deposits located in the southeastern portion of the Sharkbite (Sharkbite Channel) also represent an aquifer. These two deposits likely represent the only groundwater aquifer resource that is removed as part of the Project. During the closure management phase the reclaimed landscape is not expected to result in the creation of substantial groundwater resource because of the low permeability of some of the capping material and the quality of the water.” Characterize the loss (in terms of quantity and quality) in groundwater resources represented by the loss of the Sharkbite and Muskeg River Granular Deposit and the impact of this loss on future water supply in the area.
271. ESR for Hydrogeology, Pages 29 & 30. Information provided in the environmental setting report (ESR) does not differentiate between the Pleistocene Channel Aquifer and the Sharkbite Channel. In fact, based on the information provided, it is considered one or the same. The ESR states “The Pleistocene Channel Aquifer appears to extend across Jackpine Creek into the Sharkbite from Jackpine Mine – Phase 1. Groundwater quality in granular deposits in the Sharkbite is similar to groundwater quality in the fresher portions of the Pleistocene Channel Aquifer east of Jackpine Mine.” The ESR proceeds to state “Therefore, the degree of hydraulic connection between the granular deposits on the east and west sides of Jackpine Creek cannot be quantified with the available information.” a. Indicate why the ESR does not differentiate the Sharkbite Channel as suggested in Volumes 1 & 3 of the EIA. b. Discuss the investigations that Albian Sands will undertake to gather additional information to quantify the hydraulic connection between the granular deposits on the east and west sides of Jackpine Creek.
69 272. Hydrogeology Environmental Setting Report, Figure 4A shows the surficial geology for the regional study area. It appears that a relatively large sand dune deposit intersects the south toe berm extension. a. Will Albian Sands be conducting field investigations to identify these and other surficial granular deposits in the toe berm area? b. Describe the measures Albian Sands will take to ensure that these deposits do not provide a conduit for seepage of process-affected water into the environment. c. In the event of detected seepage, what mitigation will Albian Sands undertake?
273. Volume 1, Section 10.2, Table 10-1, Pages 10-3 & 10-8. Mining of oil sands in the southeastern portion of the Sharkbite Lease area will result (beginning Year 2022) in the loss of a potential groundwater resource, the Sharkbite Channel, due to dewatering and mining. a. Indicate to what extent the Sharkbite Channel will be mined out. b. Describe what portion of the Pleistocene Channel will be mined through, if any. c. Indicate whether the mining activities in the Sharkbite Channel would block a pathway for groundwater contaminants to travel from the in-pit tailings to the Pleistocene Channel.
274. Volume 1, Section 16.5, Page 16-22. In EUB Decision Report 2004-009 (Shell Jackpine Mine Project) the EUB recommended “…that AENV incorporate conditions in its approval requiring Shell, in conjunction with other developers, to define and carry out a regional groundwater study of the PCA in order to evaluate the regional nature of this groundwater resource.” Consequently, AENV incorporated this condition within Shell’s EPEA Approval. a. Provide an update on the status of the regional study that Shell was to undertake for the Pleistocene Channel Aquifer (PCA). b. Is the Sharkbite Channel included as part of this study?
275. Volume 2, Section 2, Pages 2-29, 2-34. In this section Albian Sands discusses the potential changes in groundwater flow patterns and groundwater quality due to the External Tailings Disposal Area (ETDA) and mine backfilling and reclamation activities. In several instances Albian Sands states, “These changes will be long- term, and irreversible.” Provide context (nature and extent) of the changes expected to groundwater quality in the Quaternary and Basal Aquifers resulting from the ETDA and mine backfilling and reclamation activities.
276. Volume 3, Section 5.3.5.4, Page 5-70. Albian Sands states, “This increased gradient would occur between the Sharkbite and the western edge of the Jackpine Mine – Phase 1 Tailings Pond for a period of approximately 5 years (from 2026 to 2031).” a. Explain the significance of this increased gradient between Jackpine Creek and Sharkbite area and the impacts this could have on mining of the Sharkbite area and operation of the Jackpine Mine Tailings Pond. b. Discuss possible option to mitigate negative impacts.
70 c. Volume 3, Section 5.3.5.4., Page 5-73. Albian Sands states, “Additional hydrogeological investigations in the southeastern part of the Sharkbite Mine will be considered as part of annual plans.” Clarify why hydrogeological information on the southeast portion of the Sharkbite Mine was not collected as part of this EIA and discuss Albian Sands’s plans to conduct future hydrogeological investigations in this area.
277. Volume 3, Section 5.3.5.6, Pages 5-85 to 5-92. Provide tables indicating base case groundwater quality conditions and predicted groundwater quality concentrations similar in format to what was provided for surface water quality predictions. In particular, discuss the expected groundwater concentrations at closure (2054) and Far Future a. (100 year) stages. As well, compare these concentrations with water quality guidelines (drinking water and aquatic life).
278. Volume 2, Section 2, Page 2-35, and Volume 3, Section 5.2, Page 5-21 and Section 5.3, Page 5-88. a. Explain why seepage to the Basal Aquifer, from backfilled Non-Segregating Tailings (NST) pits, is estimated to increase substantially, to 1924 m3/day from the base case of 255 m3/day. b. Additionally, explain what chemical constituents are expected to increase in groundwater over time, including expected loading characteristics.
279. Volume 2, Section 2, Page 2-37 and Volume 3, Section 5.2 Page 5-24. Under the Aquatic Resources Summary and Aquatic Conclusions component of the EIA, the potential effects of the Project for surface water hydrology and surface water quality are assessed and evaluated under Base Case, Application Case and Planned Development Case. Hydrogeology has not been assessed and evaluated under the Planned Development Case under Aquatic Resources Summary/Aquatic Conclusions. Provide a Planned Development Case Assessment for Hydrogeology.
280. Volume 2, Appendix 2-5, Section 3.4, Page 15/16. Monitoring well 04-2412A identified on Page 15 is not shown on Figure 3. Basal aquifer monitoring wells ASE00-310 and ASE96-801 identified on Page 16 are not shown on Figure 1. Locate these wells on the appropriate figures.
281. Volume 3, Section 5.2.2.1, Page 5-16. Albian Sands states, “At Closure and Far Future, seepage from the eastern side of reclaimed PDA north of the Muskeg River will migrate towards the Muskeg River. The Project is not expected to result in an incremental increase in seepage flux from backfilled pits to the Muskeg River. This seepage is expected to take 50 to 100 years to reach the Muskeg River. Seepage from the western-most side of the Project is expected to migrate west through the Quaternary deposits and discharge along the Athabasca River escarpment.” a. Discuss the assumptions used and the calculations involved in obtaining these estimates. b. How confident is Albian Sands with the 50 to 100 year estimate?
71 c. Discuss additional seepage mitigation options Albian Sands could implement to protect the Muskeg River and add confidence to this estimate. d. Describe the monitoring plan to be used to detect seepage from these pits.
282. Volume 3, Section 5.2.2.4, Page 5-20. Albian Sands states, “Seepage from the ETDA is not expected to reach the Muskeg River although, as noted above, seepage through the foundation of the ETDA expansion into the Basal Aquifer is expected to occur. Prior to reaching the Basal Aquifer, downward seepage will migrate through the bitumen saturated McMurray Formation. Once this seepage enters the Basal Aquifer, it will migrate in a westerly direction as part of the regional flow direction eventually discharging to the Athabasca River .During operations and Closure, groundwater levels and flow directions will be altered by the ETDA expansion.” a. Are there any predicted changes in chemistry of the seepage prior to discharge? b. Explain the potential impacts of this discharge on the Athabasca River. c. Discuss any seepage mitigation options Albian Sands could implement to protect the Athabasca River from seepage. d. Volume 3, Section 5.2.2.1, Page 5-16. Albian Sands states “Seepage from the existing ETDA is expected to affect groundwater flow patterns and groundwater quality in the Quaternary deposits and the Basal Aquifer beneath the tailings area. Hence the southern expansion of the ETDA will add small increments to these changes.” Albian Sands states that the regional flow pattern direction is into the Athabasca River, however if groundwater levels and flow directions will be altered by the external tailings disposal area (ETDA) expansion, confirm that the regional flow will continue to be to the Athabasca River in the future. e. Provide an update on the groundwater flow patterns based on the current groundwater monitoring around the ETDA. Provide plans showing contours of hydraulic heads in the Quaternary and Basal Aquifer before (present conditions) and after (predicted at closure) on the same figures. f. Provide plans as above which show the southern extension of the ETDA with predicted heads. Discuss the modeling that was used to calculate these heads and all parameters and assumptions used. Does Albian Sands plan on testing these assumptions?
283. Volume 3, Section 5.2.2.4, Page 5-20 – 5-21. Albian Sands states, “Seepage of pore water from tailings backfilled pits will be of lower quality (e.g., Total Dissolved Solids [TDS]) compared to natural groundwater in Quaternary deposits. Groundwater quality in Quaternary deposits will be influenced between Cells 1, 2, and 3 and the Muskeg River and along the west side of Cells 10 and the Athabasca River escarpment. However, the seepage to the Muskeg River from the Project is not expected to increase when compared to the existing Muskeg River Mine. Groundwater quality in the Basal Aquifer beneath the footprint of the mines and down gradient of the reclaimed mine area will likely be affected. These changes will be long-term and irreversible.” a. Clarify what is being compared, i.e., predicted seepage or actual seepage from the existing Muskeg River Mine?
72 b. Albian Sands states that seepage to the Muskeg River from the Project is not expected to increase, but the seepage that does occur will be of lower quality. Explain the significance of this. c. Provide how far down-gradient from the reclaimed mine area impacts are expected. d. Is any offset being considered for the long-term irreversible affects to the groundwater quality in the Basal Aquifer beneath the footprint of the mines and down-gradient of the reclaimed mine area?
284. Volume 3, Section 5.2.2.4, Page 5-21. Albian Sands states, “This seepage is expected to migrate from the northwest corner of Cell 10 (Cell 10 perimeter dyke). This seepage is expected to migrate west through the Quaternary deposits and discharge along the Athabasca River escarpment. Seepage is also expected to migrate laterally through Cell 15 perimeter dyke at a rate of approximately 70 m3/d. This seepage will be intercepted by the perimeter ditch and routed to wetlands located at south end of Cell 15.” Explain why the seepage expected to migrate west from Cell 10 through the Quaternary deposits and discharge along the Athabasca River is not being intercepted by perimeter ditches and routed to wetlands like the seepage expected to migrate laterally through Cell 15.
285. Volume 3, Section 5.2.2.5, Page 5-22. Albian Sands states, “The ETDA south expansion includes an extension to the perimeter ditch system that is designed to intercept seepage that would otherwise flow from the tailings pond into Quaternary deposits. Sand capping placed directly over NST will be isolated from in-situ Quaternary sand and gravel deposits by the placement of low permeability overburden.” a. Describe the monitoring program that will be implemented to detect potential seepage bypassing the collection ditch. b. Discuss Albian Sands’s experience at the Muskeg River Mine with cutoff ditching to mitigate seepage and provide evidence of how successful perimeter ditches have been at the Muskeg River Mine in cutting off known and potential seepage pathways.
286. Volume 3, Section 5.3.4.2 and 5.3.5.5, Table 5.3-2, Pages 5-58/59 and 5-72. The Fort Hills EPEA approval included a clause to limit the effects of drawdown on the McClelland Lake Wetland Complex to protect rare plant species. a. Describe any effects that Basal Aquifer dewatering (Albian Sands Expansion plus existing and approved operations) will have on wetlands in the vicinity of Kearl and McClelland Lakes. b. Indicate how Albian Sands will adjust their dewatering activities in the event of a prolonged period of drought to ensure that surface water bodies will not be adversely affected. c. Clarify if Albian Sands has had discussions with other operators in the area regarding the protection of the McClelland Lake Wetland Complex.
73 287. Volume 3, Section 5.3.5.4, Table 5.5.3, Pages 5-63/65. EIA snapshots (Figures 5.3-11 to 5.3-13) of overburden dewatering were provided to year 2020. According to Table 5.3-3, overburden dewatering will occur to year 2031 and the highest dewatering rates will occur after year 2021. Provide overburden dewatering snapshots (Figures) at 5-year intervals to year 2031 and provide an updated Table 5.3- 4 indicating the reduction in groundwater discharge to receiving streams for these intervals.
288. Volume 3, Section 5.3.5.4, Page 5-63. This section indicates there is a 4.0 m layer of sand between the Pleistocene Channel Aquifer and the Sharkbite Channel Aquifer. As well the Komex Environmental Setting Report (Page ii) states, “The Pleistocene Channel Aquifer appears to be connected to granular deposits west of Jackpine Creek”. Discuss the likelihood of inducing higher seepage rates (and containing that seepage within the Jackpine lease area) from the Jackpine Mine Tailings Pond when dewatering the Muskeg gravel deposit and Sharkbite Channel Aquifer.
289. Volume 3, Section 5.3.5.5, Figures 5.3-15 to 5.3-22, Page 5-72 to75. Albian Sands states “Figures 5.3-15 through 5.3-22 illustrates the groundwater elevations, flow directions and drawdown in the Basal Aquifer for the Application Case. These figures illustrate that the Project results in a limited increase in incremental drawdown…” Provide the rationale for using “incremental effects” to describe changes due to anthropogenic activities on groundwater flow systems and chemistry instead of “cumulative effects”.
290. Volume 3, Section 5.3.5.6, Page 5-82. Albian Sands states, “Due to elevated groundwater levels in the ETDA and depressurization of the Basal Aquifer, there will be relatively strong downward vertical gradients beneath the facility during operations such that a portion of the seepage will migrate downwards towards the Basal Aquifer. However, due to the low hydraulic conductivity of the McMurray Formation deposits, this seepage is not expected to reach the Basal Aquifer during operations.” a. Provide cross sections confirming that the low permeability McMurray Formation layer is continuous throughout the facility area. b. What is the hydraulic conductivity of the McMurray Formation deposits? c. Volume 3, Section 5.5.5.6, Page 5-85. Albian Sands states, “The advective transport of seepage from the ETDA to the Basal Aquifer is expected to be greater than 100 years.” How confident is Albian Sands that seepage from the external tailings disposal area (ETDA) will take longer than 100 years to reach the Basal Aquifer and ultimately the Athabasca River? d. Explain what monitoring will occur to validate that seepage is not reaching the Basal Aquifer and Athabasca River in less time.
291. Volume 3, Section 5.3.5.7, Page 5-87. Albian Sands states, “This seepage will migrate towards (and potentially be captured by) the depressurization wells.”
74 a. Describe the expected efficiency for seepage to be captured by the depressurization wells. b. Explain the mitigation that will occur if the seepage is not captured by the depressurization wells. c. Explain what monitoring (amount, timing, and spacing) will take place to indicate whether seepage is being captured or not. d. What monitoring is planned for after Albian Sands ceases depressurization of the basal aquifer?
292. Volume 3, Section 5.3.5.7, Page 5-91. Albian Sands states, “This seepage is not expected to reach Isadore’s lake to the south.” a. Explain how confident Albian Sands is that this seepage will not reach Isadore’s Lake. b. Explain how Albian Sands will confirm that seepage is not reaching Isadore’s Lake.
293. Volume 3, Section 5.3.5.10, Pages 5-96/97. Confirm that at closure (2054) and Far Future (100 years), additional mitigative measures will be incorporated should unexpected seepage rates and/or groundwater quality changes be observed in the vicinity of the external tailings disposal area and mine backfilling and reclamation areas. Discuss what these additional measures might be.
294. Volume 3, Section 5.3.6.2, Pages 5-99 to 5-102. With respect to predictive confidence, the uncertainty related to prediction of basal aquifer depressurization rates, infiltration rates and seepage rates from the external tailings facility is given as plus or minus 30%. a. Provide the uncertainty, in terms of percentage, related to predictions associated with overburden dewatering and seepage from in-pit tailings. b. Explain how and on what basis the plus or minus 30% uncertainly was arrived at.
295. ESR for Hydrogeology, Appendix I. Provide missing Table I(B)-2.
296. ESR for Hydrogeology, Section 7.2.2, Page 33. Albian Sands states “the potential exists for baseflow contributions to Jackpine Creek from Quaternary deposits and the Pleistocene Channel Aquifer.” a. Provide the estimated groundwater baseflow contribution to Jackpine Creek from the Quaternary deposits. b. Indicate what percentage of the mean annual discharge is the baseflow contribution to Jackpine Creek.
297. Volume 3, Section 5.3.5.9, Page 5-93. Albian Sands states, "These two deposits likely represent the only groundwater aquifer resource that is removed as part of the project." This statement suggests that very little or no exploration was carried out to identify any other potential groundwater aquifer resources. Please provide Albian Sands’s plans to identify other groundwater resource aquifers that may be removed as part of this project.
75 298. ESR for Hydrogeology, Figure 8. Figure 8 shows the NW tributary of the Pleistocene Channel Aquifer (east of Jackpine Creek and within the LSA) terminating before reaching the Muskeg River. Figure 8 also shows a lack of borehole data for this portion of the Pleistocene Channel Aquifer. Indicate what further field work is planned to map the extent of this tributary to confirm whether it is or is not connected to the Muskeg River.
299. Volume 3, Section 5.3.2.2, Page 5-43. Albian Sands states, “Changes in the groundwater levels and flow directions in the Pleistocene Channel Aquifer as a result of dewatering activities at Jackpine Mine – Phase 1 were estimated to not extend beyond the Jackpine Mine – Phase 1 external tailings pond. The tailings pond was predicted to form a groundwater divide. Changes to groundwater resources as a result of the Jackpine Mine – Phase 1 are therefore assumed to be restricted to areas east of the Jackpine Creek and do not have the potential to overlap with shallow groundwater resources and geographic area affected by the Project.” a. Hydrogeology Environmental Setting Report, Figure 8 shows the general location of the Pleistocene Channel (Kearl Channel). Discuss Albian Sands’s plans to investigate the extent of this channel and it’s interaction with the southeast portion of the Sharkbite Pit and hydraulic connections with other nearby granular deposits. b. Explain how it will be verified that dewatering of the Pleistocene Channel Aquifer will not affect groundwater levels and flow direction associated with the same aquifer found in the Sharkbite area of the expansion project. c. Explain what the significance would be if the prediction that groundwater flow and levels in the project area (i.e. Sharkbite area) will not be affected by the Jackpine Mine – Phase 1 dewatering of the Pleistocene Channel turns out to be false.
Dam Safety
300. Volume 1, Section 7.3, Figures 7-13 to 7-15, Pages 7-28 to 7-30. Figures 7-13 to 7-15 depict design cross-sections through the dykes for the External Tailings Disposal Area. Indicate whether there will be stripping of material beneath the proposed Design Toe Berms, Contingency Dykes, or Starter Dyke of the South Expansion.
301. Volume 1, Section 7.3, Table 7-8, Page 7-25. Table 7-8 outlines the dyke design parameters for both the design case and the contingency case. In the contingency case the dykes are considerable larger. Describe potential impacts on the seepage collection system, wildlife corridors or other boundaries if the “Contingency Case” for the berm were required for stability.
302. Volume 1, Section 16.5, Page 16-19. Albian Sands states “Seepage from the existing external tailings disposal area is expected to affect groundwater flow patterns and groundwater quality in Quaternary deposits and in the basal aquifer beneath the tailings area… These changes will be long-term, and irreversible.”
76 Discuss contingencies proposed to mitigate impacts if the incremental environmental impacts of the southern expansion of the External Tailings Disposal Area are greater than assumed.
303. Volume 3, Appendix 3.2, Page 37/38. On Page 37 Albian Sands states, "West Central and East Central pit lakes is secured from... Muskeg River... by... dykes..." and on Page 38 "These lakes are not... contained by manmade dams." Clarify which portions of the proposed dykes are manmade.
304. Volume 4, Appendix 4-4, Figure 22, Page X. The map indicates a perimeter dyke will be built on the east side of Cell 1. a. In the event of a complete failure of this dyke in 2044 how would the material confined by the dyke be expected to behave (as a liquid, solid, etc.)? b. What differences would there be if the failure occurred in 2015 or 2020 instead?
Navigable Waters
305. Volume 1, Section 8.2, Page 8-3. Albian Sands states, “The modifications required for the river water system for the expansion project include installing one additional river water vertical-turbine pump.” Provide the proposed location of the additional river water vertical-turbine pump and describe the potential temporary and permanent impacts on navigation from the additional pump.
306. Volume 2, Section 1.2, Page 1-3. Albian Sands states that “The integrated application will fulfill requirements of the following Acts: … Federal Navigable Waters Act….” Navigable Waters Protection Act issues have not been addressed in detail in the EIA and a detailed assessment of the project’s potential impacts on navigation has not been carried out. Describe the potential temporary and permanent impacts on navigation resulting from the Project (including associated in-stream fish habitat compensation measures) on the Muskeg River.
TERRESTRIAL
Gravel Resources
307. Volume 1, Section 5.5, Page 5-38/39, Section 5.6, Page 5-54 and Section 10.2, Page 10-6. Albian Sands indicates that gravel from the Muskeg River Gravel Deposit will be removed during the periods of 2007-10, 2010-12 and 2013-2016 and stockpiled within the mine. a. The stockpile location for this gravel does not appear to be on any mine plans. Provide this information. b. If the gravel is being removed over three different periods, indicate what volume, if any, will be used during each period for road or other construction purposes. If the gravel will be used during these periods, clarify the need to stockpile.
77
308. Volume 1, Section 18.2, Figure 18-1, Page 18-5. This figure depicts the lands required for the amended Mineral Surface Lease (MSL) boundary, using a blue dashed line. However, there appears to be no connection between the Lease 90 Pit and the bottom of the Lease 90 North Pit. a. Describe the connection between the two pits and indicate how Albian Sands proposes to access one from the other? This should be included in the MSL and not in a separate Licence of Occupation (LOC). b. Clarify that the lands shown meet the 2016 operating limits and that this would be the extent of the EPEA 10 year approval area.
309. Volume 4, Section 5.4.3, Page 5-28 and ESR for Historical Resource, Traditional Land Use, Resource Use, Section 3.4.2, Table 3-3, Page 3-10. Albian Sands indicates that it obtained its information on gravel volume (14 MM m3 within the Muskeg River Gravel Deposit) from a 1979 Thurber Consultants report and identifies the resource as being within Sections 2,3,10,11–Twp 95–Rge 10–W4M. a. What was the basis for the testing within the identified lands at that time? Was exploration for gravel resources completed for the entire footprint of the then proposed Alsands Project? b. Is the footprint of the Albian Sands Muskeg River Mine the same as that of the former Alsands and, if not, does Albian Sands propose to test other areas? c. What process did Albian Sands use to verify the accuracy of the information in the Thurber Consultants report, and has that process been accompanied by any further test drilling on the lands?
310. Volume 4, Section 7.2.2, Page 7-9/10, Section 7.4.2.1, Page 7-76, Section 7.4.4.3, Page 7-87, Section 7.4.4.3, Table 7.4-6, Page7-90 and Table 7.4-9, Page 7- 96. Albian Sands indicates that 20.5 MM m3 of gravel is needed for the project, and that 14 MM m3 is available within the Muskeg River Gravel Deposit. Albian Sands further indicates that the remaining balance would be obtained from the Susan Lake Pit, and that any other material found during mining activities would be reported. a. Clarify whether the entire footprint of the project area, or lands to eventually be disturbed under MSL for mine development, has been tested for gravel. b. Indicate whether Albian Sands is planning to use all available aggregate resources within the project footprint prior to going to outside sources. c. Sustainable Resource Development (SRD) will require Albian Sands to prepare an Aggregate Management Plan as part of the MSL approval. The volume to be removed from the Muskeg River Gravel Deposit is estimated at 14 MM m3 based on a buffer of 50 meters from the Muskeg River. What is the effect on the volume of available aggregate material if SRD sets a minimum buffer of 100 m (standard practice) from the river?
311. Volume 4, Section 7.4.5.2, Page 7-102. Clarify the discrepancy of presenting the aggregate environmental consequence as moderate in this section and as low on Page 7-97.
78 Historical and Archeological Resources
312. Volume 1, Section 16.13, Page 16-53. Albian Sands states: “Two sites within the project development area have been recommended for additional study and provincial designation as a significant provincial historical resource. The HRIA conducted by Lifeways for the Birch Mountain Resources Muskeg Valley Quarry Project identified sites HhOv 305 and HhOv 319 that fall within the expansion project. Albian Sands is working with ACD to review the boundaries of a reservation notation that is being recommended west of the currently proposed Birch Mount Resources’ limestone quarry within the northern area of Lease 90. The notation will define an area of restricted access to protect areas that support high densities of artifacts, some of which represent Beaver River fine-grained sandstone. If this reservation notation affects the expansion project, changes to the expansion project will be presented in supplemental information.”
Quarry of the Ancestors On March 24, 2005, Alberta Community Development submitted an application for a Protective Notation (“PNT” 050083) to Alberta Sustainable Resource Development to register an interest on lands containing a very important archaeological site complex in northeastern Alberta, informally known as “Quarry of the Ancestors”. The PNT encompasses approximately 229.66 hectares (567.5 acres) in Sections 27, 28, 33 and 34-94-10-W4M and Section 3-95-10-W4M and includes sites HhOv 305 and HhOv 319.
Several components associated with the development of the MRME would affect the lands that are covered by the reservation/notation application, most notably “Overburden Disposal Area 5 West” (“OBDA 5W”) and “Canterra Road Relocation”. The northeastern portion of OBDA 5W will cover the northern portion of “Quarry of the Ancestors” while the proposed Canterra Road Relocation will involve lands that are also included within the reservation/notation for “Quarry of the Ancestors”. a. Identify, explain and illustrate what changes and/or redesign of the OBDA 5W would be necessary to avoid “Quarry of the Ancestors”. b. Identify, discuss and illustrate other alignments for the “Canterra Road Relocation” that would avoid the “Quarry of the Ancestors”. c. Compare the alternatives in terms of cost, technical consideration, and potential environmental impact, including impacts on this archaeological resource.
313. Volume 4, Section 7.6. Albian Sands plans to address Historical Resources Act requirements for the MRME in four phases: • Phase 1 – Historical Resources Impact Assessment of first ten year footprint • Phase 2 – Historical resources sensitivity modeling of post-ten year footprint • Phase 3 – Post-ten year footprint preliminary historical resources studies • Phase 4 – Historical Resources Impact Assessment of post-ten year footprint Albian Sands is required to submit the report(s) discussing the results of the Phase 1, 2 and 3 studies prior to, or at the same time as, the submission of the Environmental Impact Assessment. Although the initial Historical Resources Impact Assessment has
79 been submitted and Albian Sands is completing the Phase 2, 3 and 4 studies, including supplemental studies associated with “Quarry of the Ancestors”, the reports have not been submitted. Discuss Albian Sands’s plans for submission of the required supplemental reports. Historical Resources Act clearance for project approval and EIA completeness will not be considered until after the required reports have been submitted and Alberta Community Development has had the opportunity to review and comment.
314. Volume 1 and Volume 4, “Quarry of the Ancestors” Protective Notation and Biodiversity Conservation. The Protective Notation that Alberta Community Development has recommended for “Quarry of the Ancestors” (lands within the proposed development area for Lease 90) includes a mix of wetland and upland habitat types. a. Assuming the application for protective notation is approved, and the requested lands are left undisturbed, provide an analysis/discussion of the benefits and opportunities for reduced impacts to terrestrial and wetland resources in the Muskeg River Mine Expansion Project area. b. Provide detail to the analysis by examining reduced impacts and conservation of sensitive wildlife species (Canadian toad, yellow rail, short-eared owl, etc.), rare plants, uncommon ecosites and biodiversity in the LSA.
Project Description, Layout, and Footprint
315. Volume 4, Section 6.1.6.5, Page 6-10. Albian Sands states, “The new clearing associated with the Project will be 8,091 ha in size during operations (ie., the Project Development Area or PDA). Effectively, for the period of operations there will be a complete loss of soil and terrain, terrestrial vegetation, wetlands and forest resources, wildlife and biodiversity for this area. Therefore, during operations the environmental consequence to all components is considered to be high. However, during closure and reclamation this high environmental consequence is reduced with successful reclamation.” Discuss opportunities to decrease this high environmental consequence during operations.
316. Volume 1, Section 5.2, Mine Layout, Figure 5-1, Page 5-7. This figure shows marginal resource areas where the TV/BIP ratio is 12 or less and where ore is <15m thick. a. From the perspective of vegetation species retention provide maps that identify the footprint of areas not specifically required for mining or overburden disposal. b. Identify the areas Albian Sands could use as a bio-insitu revegetation sources for the reclaimed landscape. c. Alternatively identify the reasons why the areas could not remain as a bio-insitu resource for the reclaimed landscape.
317. Volume 1, Section 8.3, Page 8-7. Albian Sands proposes to construct new electrical power distribution lines in the project area.
80 a. Describe the proposed distribution system, including length of new lines, height of poles, etc. Provide illustrations or a map. b. Discuss options for mitigating possible effects of powerlines on birds, with reference to any relevant guidance documents.
318. Volume 1, Section 5.2, Page 5-13. Albian Sands proposes to relocate a portion of Highway 63 closer to the Athabasca River, by 700 m, which could potentially impact the Athabasca River Valley. a. Provide an analysis of the impacts to bitumen recovery if Highway 63 was not relocated, and mining of the Muskeg River Pit was restricted by the current highway location. b. What is the basis for choosing a buffer of 150 m between the Athabasca River and the proposed Highway 63 Right of Way? c. After the proposed realignment, will there be a problem maintaining the utility corridor along Highway 63 as per the Fort McMurray-Athabasca Oil Sands Subregional IRP? Will there be a viable utility corridor for future projects north of the MRME Project?
319. Volume 1, Section 8.6, Figure 8-1, Page 8-17. This figure shows a relocation of the Canterra Road, south of Lease 13 and into the habitat setback along Jackpine Creek. a. Confirm who is responsible for relocating Canterra Road. b. Who will take ownership of Canterra Road? c. Would the relocation be complete prior to decommissioning of the existing Canterra Road alignment? d. Does Albian Sands intend to maintain public access on this road for the life of the mine? e. Is it anticipated that there would be constraints to users of Canterra Road? f. Provide more information on the schedule for the relocation of Highway 63. Albian Sands should also contact Alberta Infrastructure and Transportation to discuss the schedule, and to ensure continuity of Highway 63 is maintained, and that the relocation meets all applicable design standards. g. Confirm that discussions will be arranged with Alberta Infrastructure and Transportation to set up an agreement stating Albian Sands will be responsible for all costs associated with the relocation of Highway 63.
320. Volume 4, Section 7.7.14, Pages 7-279 to 285. This section discusses current issues and planned developments along Highway 63. a. Provide an assessment of the increased traffic that will be accessing the Canterra Road from Highway 63 as a result of the proposed project. Include the types of vehicles, predicted volumes, and the effect on traffic flow at that intersection. b. Provide an assessment of the impact that the increased traffic flow will have on safety at the intersection of Highway 63 and Canterra Road. c. Provide mitigation options to address the impact that the increased traffic flow will have at this intersection.
81 321. Volume 1, Section 5.5, Figure 5-12, Page 5-31. Figure 5-12 is representative of the mine development plan. There is no discussion or evidence of intermine coordination with Syncrude’s Aurora North mine or the Birch Mountain Muskeg Valley Quarry or the proposed Hammerstone project. a. Discuss the landform and tailings design and timing considerations necessary for the intermine coordination required to optimize development for the MRME project and the adjacent developments. b. Discuss opportunities for coordinated intermine closure landforms, pit lakes, watershed development and end land use.
322. Volume 1, Section 7.1, External Tailings Disposal Area, Page 7-1. Albian Sands states, “The existing external tailings disposal area covers 1,060 ha and has a capacity of 342 Mm3 of tailings. An additional 10-m vertical lift is being proposed in this application, from the current design of a 330-masl final dyke height. It is also proposed to incorporate a south extension of the sand toe berm. This will increase tailings storage to 520 Mm3 and the area’s overall footprint to 1,316 ha.” Define the total footprint disturbance both numerically and graphically that show clearly the gradual buildup of disturbance and then the gradual reclamation so that one can see the net disturbance when all mining has been completed and how the mine site will transition to a fully reclaimed landscape. Include all footprint disturbances such as overburden waste disposal areas and plant locations.
323. What impact does transferring tailings between the MRM and Jackpine Mine have on the tailings plan (volume, type of tailings placement and timing) for both mine sites end-pit lake designs (size, volume, type of tailings placement and timing), recycle water quality and quantity, containment capacity, and timing of (progressive) reclamation?
324. Volume 4, Section 3.5.1, Table 24, Page 100. Albian Sands indicates that 10 NST cells will be capped with overburden, while four NST cells will be capped with sand. a. Discuss the rationale for choosing the two capping techniques, and indicate how the capping technique was selected for each NST cell. b. Discuss any implications for reclamation using overburden vs. sand capped cells. c. Address any uncertainties associated with oil sands mine reclamation success.
Terrain and Soils
325. Volume 1, Section 16.2, Page 16-7. Albian Sands states, “…expansion project NOx and SO2 emissions will result in an increase in the areas of PAI above 0.17, 0.25, 0.50 and 1.0 keq/ha/a, within the RSA and LSA.” And, “…emissions from the expansion project did not result in any additional grid cells being predicted to exceed the monitoring, target or critical loads adopted by CASA.” At the same time, the Terrestrial Environmental Setting Report (Page 5-33) indicated that sensitive and moderately sensitive soils make up a significant portion of the RSA (21.5 and 19.7%,
82 respectively). Explain why the increase in PAI did not increase the total area being predicted to exceed the monitoring, target or critical loads.
326. Volume 1, Section 16.2, Page 16-7. Albian Sands discusses acid deposition from emissions. Describe the potential effects of acid deposition on reconstructed soils that include high components of coarse-textured mineral material. Indicate whether critical loads have been determined for reconstructed soils.
327. Volume 4, Section 6.1.6.2, Page 6-7. Albian Sands states, “…the impact assessment will focus on areas of permanent soil loss and on forest capability as an indicator of overall soil quality.” Forest capability is not measured, but predicted from attributes of the reconstructed soils; therefore, it cannot be used as an objective and independent indicator of soil quality. Elaborate on whether there are other indicators of soil quality that may be more appropriate for use in this case.
328. ESR for Terrestrial, Section 2.2.2, Page 2-3. Albian Sands states, “Site index data, including tree species, age, breast height and tree height, were collected at various soil inspection sites throughout the local study area. The purpose was to relate forest productivity, measured by site index, to land capability class.” a. Is there a strong correlation between site index and land capability class? b. Are there uncertainties about this correlation? c. If so, is Albian Sands conducting work to further define the relationship between site index and land capability class? d. Discuss whether there are other indicators of soil quality that may be more appropriate for use in this case. e. Is Albian Sands collecting any other baseline information?
329. ESR for Terrestrial, Section 5.2.2, Table 5-12, Page 5-17. Albian Sands presents measurements of site index and Land Capability Class ratings for selected soil map units in Table 5-12. Discuss whether the data indicate a strong predictive relationship between Land Capability Class and site index.
330. ESR for Terrestrial, Table 5-19, Page 5-27. Albian Sands lists mineral soil salvage depths of 15 cm for a variety of soil types in the proposed development area. a. What are the range and average soil and upper subsoil depths each of the predisturbance soil types? b. Why has 15 cm been proposed as the soil salvage depth?
331. ESR for Terrestrial, Section 5.3.1, Page 5-18. Albian Sands presents data for various chemical constituents of soils within the LSA. Based on the median values of total organic Carbon and total Nitrogen content, indicate the potential for mineralization of Nitrogen from the LFH layer, the A-horizon and peat.
332. Volume 4, Appendix 4-4, Section 2.4, Page 52. Albian Sands states, “In general, organic soil mixed with fine-textured till, clay or silts (fines), is the preferred
83 coversoil for use on tailings sand areas to increase the moisture holding capacity of the reclamation soil.” a. Explain how Albian Sands will provide for preferential salvage of the soil material containing fine textured material? b. What areas will be reclaimed using the organic matter with fine-textured till, clay or silts? c. Overburden dumps 5 & 6 are proposed for areas that supported a high proportion of good timber productivity areas in the predisturbance landscape (Figure 6-9, Terrestrial ESR). Explain why Albian Sands recommends that such preferred material not be salvaged? d. What will the fines content be for the coversoil, upper subsoil and lower subsoil for reclamation prescriptions as shown in Figure 10?
333. Volume 4, Appendix 4-4, Closure, Conservation and Reclamation (C, C&R) Plan, Section 2.4, Figure 10, Page 53. Figure 10 provides a schematic of basic soil reconstruction practices that will be followed for the Project. It suggests that in some cases 20 to 50 cm of cover soil will be placed on tailings sand. a. Substantiate why Albian Sands considers this reclamation practice to be sufficient for the establishment of productive forests, and healthy, sustainable ecosystems (including old-growth forest bird communities). b. Provide empirical data from existing reclaimed locations at the Albian Sands Muskeg River Mine, or at other mines with similar soils to support the claim. c. Will the proposed soil profiles return predisturbance nutrient and moisture regimes to the reclaimed lands? d. Will the proposed soil profiles provide a foundation upon which ecosystems containing vegetation species of value for traditional use can establish? e. Is Albian Sands aware of any studies that support, or otherwise, the concept that the proposed standardized soil profiles have been able to establish sustainable areas of vegetation species listed as important for traditional land use? f. If so, provide a list of these studies. g. Clarify what traditional land use species have been established to date using the soil profiles listed in Figure 10? h. What area of each traditional vegetation species will be established on Albian Sands’s mine development areas? i. What is the significance to the potential establishment of traditional use vegetation and traditional use if the targeted species are not supported by the soil profiles of Figure 10? j. Provide alternative mitigation strategies for the establishment of soil profiles for the establishment of forest ecosystems that support vegetation species important to traditional use?
334. Volume 4, Appendix 4-4, C, C&R Plan, Section 2.5.2, Page 58. Albian Sands states, “Direct placement of suitable material to reclamation areas enhances site revegetation as dormant, in-situ, native seed and viable root fragments are transferred with the soil amendment. Spreading the material on a reclamation area in early spring has usually resulted in the emergence of a variety of native forbs,
84 wildflowers, grasses and woody-stemmed species. Direct placement will be implemented wherever practical.” a. What area of the predisturbance landscape has upland mineral soil and LFH soil materials suitable for direct placement? b. Describe the percentage of reclamation where the use of each - direct placement and LFH soil materials will occur? c. Describe in detail limitations to the use of direct placement and LFH soil materials?
335. Volume 4, Appendix 4-4, Section 3.3.2, Table 16, Page 87-88. Table 16 is apparently a generic prescription that does not take into account the availability of material at the mine-site. The reclamation plan predicts an increase of 1,395 ha in Land Capability Class 3 (Table 6, Page 49). Table 16 indicates Silty Loam, Clay, and Heavy Clay (i.e., fine-textured material) besides Sandy Loam in the Upper Subsoil and Lower Subsoil. Indicate where, and from what soil series, this fine-textured mineral material will be obtained.
336. Volume 4, Appendix 4-4, Section 3.3.2, Page 87. Albian Sands states, “Due to the abundance of coarse-textured material in the Project area, reclaimed soil profiles will be modified from the usual profiles to ensure that equivalent capability is replaced at closure.” a. This statement apparently addresses the shortage of fine-textured material, but what does it mean? b. Describe how the reclaimed soil profiles will be modified.
Closure, Conservation and Reclamation Plan
337. Volume 1 and Volume 4, Appendix 4-4. Tailings Management: The tailings management plan is confusing at times, with various tailings streams diverted to an end pit lake depending on operating conditions and how well the tailings plan works. Closure: The alternate tailings technology selected by Albian Sands has several unknown characteristics. This increases the uncertainty around reclamation of the tailings ponds, the amount of dry landscape/terrestrial habitats at closure, and may increase the risk that Albian Sands will require additional tailings storage space in the future. a. Explain and compare the total area of terrestrial ecosites in the pre-disturbance scenario, application case at closure, best-case scenario at closure, and worst-case scenario at closure. b. Compare the total area required for tailings ponds and tailings deposits to be reclaimed in the best-case scenario at closure, and the worst-case scenario at closure. c. Provide an explanation of the operating conditions that would result in the best and worst cases.
338. Volume 3, Section 5.1, Page 22. Albian Sands proposes three compensation options.
85 a. Please clarify if Albian Sands intends to pursue all three options. b. Option 1 indicates that habitat units will be gained for the MRME through the construction of a Compensation Lake, Khahago Lake and Muskeg Creek Channel at the Jackpine Mine – Phase 1. Discuss the current status of these proposed forms of compensation and the issues/concerns associated with them. c. Option 3 indicates a compensation plan near the south end of Muskeg River. Provide more detailed information on this option (land ownership, consultation, investigations, etc…). d. Table 6 on Page 24 provides two options as “Option 3”. Please clarify this. e. What options outside the surface mineable area has Albian Sands explored for fisheries habitat compensation?
339. Volume 4, Appendix 4-4, Table 1, Page 3. Albian Sands indicates that there are 634 ha of existing disturbances in the Project expansion area. a. Provide a summary of these disturbances by activity, and clarify whether any of these disturbances were created by Albian Sands. b. Will any of this predisturbance, if under other surface dispositions, affect Albian Sands’s application for amendment to their existing MSL?
340. Volume 4, Appendix 4-4, C, C&R Plan, Section 1.2, Page 4. Albian Sands states, “The reclaimed landforms will be designed using the Reclamation Working Group (RWG) Landscape Design Checklist (RWG 2004), where applicable.” Will Albian Sands agree to use the Landscape Design Checklist, 18 March 2005 approved by the Alberta Government?
341. Volume 4, Appendix 4-4, C, C&R Plan, Section 1.6, Page 15. Albian Sands states, “End land use options available will be constrained by the type of landforms to be constructed (e.g., pit lakes are not available for dry land uses).” Describe the end land use restrictions envisioned for all reclaimed landform types?
342. Volume 1 and 4 include information about the years of clearing, reclamation material application, vegetation treatment and closure for various landforms. Provide a table similar to the one below, showing the corresponding dates of the various stages of the mine progression for each landform structure listed below.
Area Date of Date Date of Closure Clearing Reclamation Vegetation Dates Material Treatment Applied ETDA OBDA 1 OBDA 1a OBDA 1b OBDA 2 OBDA 3 OBDA 4
86 OBDA 5 OBDA 5e OBDA 5w OBDA 6 OBDA 7 W Pit Esc O. burden Cell 1 Cell 2 Cell 3 Cell 4 Cell 5 Cell 6 Cell 7 Cell 8 Cell 9 Cell 10 Cell 11 Cell 12 Cell 12a Ob Cell 13 E part Ob Cell 14 Cell 15 Cell 16 Cell 17 W part Ob Pit 90 Ob Plantsite
343. Volume 4, Appendix 4-4, C, C&R Plan, Section 1.2, Page 5. Albian Sands states, “reclamation certification will be achieved to allow transfer of the lands back to the crown”. a. Provide a chart and map that demonstrates when each component of the mine is scheduled to be ready for a reclamation certification request? b. Discuss the issues associated with this schedule. c. Provide a table and graph that shows cumulatively, for each year, the land area disturbed, the land area reclaimed and the land area that remains un-reclaimed.
344. Volume 4, Section 6.5.1.2, Table 6.5-4, Page 6-45. Table 6.5-4 shows 775 ha of disturbance at closure. a. What does Albian Sands mean by “closure”? b. Describe the “disturbance” that will remain at closure. c. Is the timeframe associated with closure the same as the timeframe for lands to be certified reclaimed and returned to the province?
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345. Volume 4, Section 6.5.1.3, Page 6-51. Albian Sands states, “The soil impact classification relies heavily on the ability of the planned reclamation program (Volume 4, Appendix 4-4, C, C&R Plan) to return an equivalent capability. Research to date suggests that reclaimed landscapes can achieve equivalent capability for forestry. Organic soils are an integral component of the reclaimed soil used for reclamation and the integration of the organic soil in the reclamation mix provides nutrients and seed propagules for the reclaimed landscape.” Further, in Volume 4, Appendix 4-4, C, C&R Plan, Section 2.4, Page 52 Albian Sands states, “Muskeg River Mine approval is based on returning equivalent land capability (Leskiw 1998) using coversoil consisting of a mixture of 20 to 40% mineral material and 60 to 80% organic material.” a. Does Albian Sands on its own, or through participation in multi-stakeholder groups, conduct work looking at the ability of reclaimed sites to achieve equivalent land capability? b. If so, describe the results to date. c. Does Albian Sands on its own, or through participation in multi-stakeholder groups, conduct work looking at the use of fertilizer on reclaimed lands and its effect on tree growth? d. If so, describe the results to date. e. What is Albian Sands’s position with respect to the use of fertilizer on reclaimed lands to achieve equivalent capability? f. Is it Albian Sands’s position that lands under ongoing fertilization could meet equivalent land capability, or does the fertilizer mask the true capability of the reclaimed land? g. Does Albian Sands on its own, or through participation in multi-stakeholder groups, conduct work looking at the Land Capability Classification for Forest Ecosystems in the Oil Sands System (LCCS) and the feasibility of current reclamation coversoil, as discussed above, to achieve sustainable boreal forest ecosystems and equivalent land capability? h. If so, describe the results and uncertainties. i. What is Albian Sands’s view with respect to the LCCS and reclamation soil requirements? j. If a change were made to the reclamation requirements, would Albian Sands adopt the modifications outright? k. Would Albian Sands wait until conditions to operating approvals were changed before modifying reclamation practices? l. Does Albian Sands on its own, or through participation in multi-stakeholder groups, conduct modeling of the sustainable productivity and sustainability of tree growth on the coversoil mixture discussed above? m. If so, describe the results to date. n. Does Albian Sands on its own, or through participation in multi-stakeholder groups, conduct calibration studies on reclaimed lands against the LCCS? o. Is Albian Sands aware of any reports discussing calibration of the LCCS against reclaimed lands?
88 p. Describe the results and uncertainties related to this calibration work and the measurement of forest productivity on reclaimed lands versus natural forest stands. q. Does Albian Sands on its own, or through participation in multi-stakeholder groups, conduct modeling of the effect different depths of the coversoil has on potential productivity. Example: Difference in potential productivity of the site when coversoil is 20 cm deep, versus 50 cm deep on reclamation sites? r. Discuss the results and uncertainties and their significance. s. How do these reclaimed sites compare to baseline? t. Does Albian Sands on its own, or through participation in multi-stakeholder groups, conduct work to look at the security of the organic ion in organic reclamation soils where it exceeds the soils capability to regenerate the same volume prior to a significant event that may remove it from the root zone due to combustion by groundfire or natural oxidation processes? u. If so, describe the results and uncertainties. v. Discuss any recommendations Albian Sands would like incorporated into the LCCS, Albian Sands reclamation practices and soil salvage procedures for reclamation of the Albian Sands mines to address the technical issues discussed above.
346. Volume 1, Section 16.1, Table 16-3, Page 16-47. Within table 16-3 input from Fort McKay representatives expressed that “Dykes and overburden dumps at the mines do not look natural.” Albian Sands’s response within the table is, “As long as safety of the dykes is addressed, trials will be conducted to deposit material for surface variation. Some sections of the overburden dumps can have more convolutions than the original footprint.” Albian Sands’s statement above conflicts with later statements in Volume 4, Appendix 4-4, Section 3.5.4.2, Page 105 where selected contradictory statements are; • “slopes are terraced and range from 4:1 to 10:1 (note that terraces may be reduced for closure.)” • “Surface area is very large, shape tends to be regular with some relatively straight sides” The Fort McMurray Athabasca Oil Sands Subregional Integrated Resource Plan (IRP) recommends (on page 110, 3rd bullet) promoting “…aesthetic qualities of the landscape”. Albian Sands’s statement above seems to conflict with this recommendation. Describe the modifications incorporated into landform designs, and/or post mining modifications to dykes and overburden dumps, necessary to produce landforms that will have the natural appearance requested by Fort McKay and recommended by the IRP.
347. Volume 4, Section 7.5.5.4, Page 7 – 159. Albian Sands states, “The magnitude of the impact on the visual aesthetics of Landscape Unit AE12 is considered negligible both before and after Closure, as the landscape integrity does not change during or after the operation of the Project. The geographic extent of this effect is considered local because noticeable effects will occur only on viewpoints within 5 km; the duration is long-term, as reclamation will not return the PDA to a fully forested state
89 until after closure. The frequency of the effect is moderate, because observers will see the area on an intermittent basis from the Athabasca River. The visual impacts are reversible with reclamation. The environmental consequence for Landscape Unit AE12 will be negligible (Tables 7.5-7 and 7.5-8).” a. Would the people of Fort McKay and other stakeholders in the region who will frequent the reclaimed landscape find the appearance to be natural if they visit reclaimed landforms? b. Is the natural landform appearance incumbent on the establishment and advanced maturity of forest growth?
348. Volume 4, Appendix 4-4, Page 6. Albian Sands has included the option for agricultural uses to be considered in the end land use goals. Indicate the driver behind this opportunity and indicate any specific agricultural activities being considered.
349. Volume 4, Appendix 4-4, C, C&R Plan, Section 1.2, Page 6. Albian Sands states that one of the basic end land use goals is to “provide for traditional land uses (e.g., hunting and trapping) as preferred by key stakeholders”. In Volume 4, Appendix 4-4, C, C&R Plan, Section 1.2, Figure 2, Page 7, Albian Sands lists Traditional Land Use as a reclamation target. a. What is the baseline predisturbance area of vegetation species important for culturally significant plants listed in Volume 4, Section 7.3.4.3, Table 7.3-3, Page 7-43, Culturally Significant Plants Identified on Registered Fur Management Area #2172? b. What are the areas of reclamation that will support the specific traditional use species important to traditional land use. c. What are the species of importance to First Nations that will be replaced in reclamation? d. Are there uncertainties about the species of importance identified above? e. What area of each species will be established, and is the establishment dependant on an associated ecosystem? f. If establishment of an ecosystem with key vegetation species is important for Traditional Use vegetation then what soil types and nutrient regime are required to facilitate ecosystem development? g. What are the uncertainties? h. What research has been done, and what is planned for the development of the technology necessary to establish vegetation species of importance to traditional use.
350. Volume 4, Appendix 4-4, C, C&R Plan, Figure 11, Page 56. Comparing Figure 11, the Closure Land Capability in the Local Study Area, Table 10, the Summary of Predicted Forestry Capability Class Changes following Reclamation in the Local Study Area and Figure 6-9 of the Terrestrial ESR, Timber Productivity within the Local Study Area; different conclusions can be drawn from the figures. Table 10 shows the combination of LCCS Class 2 and 3 to be 2910 ha in the pre-development situation and 4356 ha in the closure case. Figure 11 shows the majority of the closure
90 landscape to be class 4; however the predisturbance baseline map, Figure 6-9, shows a large proportion of the predisturbance area to be medium or good Timber Productivity Rating (TPR). Explain the discrepancies between the LCCS Ratings and the TPR class ratings, and the significance of the differences.
351. Volume 4, Appendix 4-4, C, C&R Plan, Figures 17 to 19, Pages 73 to 75. Clarify the scheduled time differences between the different mine operational, reclamation and closure steps for 5 year time periods from 2015 to 2044 for each part of the mine as shown in project progression maps in this section as compared to Volume 1, Section 5.5, Figures 5-14 to 5-22, Pages 5-42 to 5-50.
352. Volume 4, Appendix 4-4, C, C&R Plan, Figures 17 to 29 inclusive. In the context of overall mine planning, Albian Sands notes that an objective of the mine plan is progressive reclamation. a. Provide the schedule for each of the development components for overburden dumps, in pit tailings cells, out of pit tailings (water, sand, NST) and plant site including the steps of infill, settling, dewatering, capping, watershed development, and revegetation and certification? b. Explain why so much area must remain disturbed at one time? c. What alternatives exist to develop more of the mine in a progressive manner that would create the opportunity to develop individual tailings and overburden structures from clearing to reclamation in a more expedient manner? d. What options exist to reduce the period of time required to develop and reclaim Oil Sands Lease 90?
353. Volume 4, Appendix 4-4, Section 3.2, Figures 23 – 28. a. Why does the out of pit tailings structure receive its sand cap in 2011, and then sit inactive for 33 years until approximately 2044? b. What can be done to speed up the process of removing the water component of the ETDA?
354. Volume 4, Appendix 4-4, Section 3.5.1.2, Page 99. Why does it take from 2009 to 2031 for the NST cell 1 to be reclaimed?
355. Volume 4, Appendix 4-4, Section 2.3.2, Page 49. Albian Sands states that peatlands will decrease 25% from 3,073 ha (25% of the PDA) at Pre-Development to 0 ha (0%) at closure. This calculation is not correct. A decrease from 3,073 ha to 0 ha is a 100% decrease, not 25% as stated by Albian Sands. Clarify.
356. Volume 4, Appendix 4-4, Section 3.3.1, Page 86. Albian Sands states, “Due to the coarse texture of soils in the Project area and the lack of fine-textured soils, soils with sandy loam to loamy sand texture will be salvaged. These coarse textured soils will [be] mixed with organic material or replaced such that a textureal [sic] change occurs in the rooting zone to improve moisture holding capacity.” Clarify the meaning of the second sentence and indicate how this reclamation treatment will result in sustainable soils.
91
357. Volume 4, Appendix 4-4, Section 3.3.2, Page 89. Albian Sands lists several concerns about reclamation success, due to the coarse-textured mineral material that will be used. These concerns include low water-holding capacity and lack of nutrients. a. Discuss the level of uncertainty associated with those stated concerns, and the potential impacts to reclamation success. b. Document Albian Sands’s experience (successes and failures) in reclamation of disturbed areas with a soils mix consisting of primarily coarse-textured materials. Provide empirical data where available.
358. Volume 3, Section 2.3, Table 1, Page 12. Table 1 indicates one design criteria will be “sand ridges on out-of-pit Non-Segregating Tailings (NST) storage areas with overburden cap”. a. Confirm whether this is a typographical error, since the application does not indicate any out-of-pit NST storage areas. b. If this is correct, where is this out-of-pit NST storage area located?
359. Volume 3, Section 2.3, Page 13. Albian Sands states “Channels in overburden soils are to be built out of select overburden materials with dominant gravel material mixed with sand, silt and clay.” Albian Sands goes on to say “Otherwise, placement of selected overburden materials will be provided to ensure stable channel slopes over the geological time frames.” a. Provide a typical gradation (range) of the select overburden materials proposed for channel construction and typical thickness. b. How will Albian Sands ensure that placement of select overburden at proposed channel locations takes place, for example, at overburden dumps where potentially large variability in material gradation could exist during construction of these structures? c. How does this Closure Drainage Plan propose to monitor for material placement during construction of these overburden dump structures in order to identify areas lacking the appropriate material gradation. d. How does this Closure Drainage Plan, in general, ensure that changes in the mine plan are continually being monitored in order to update the Closure Drainage Plan?
360. Volume 1, Section 5.5, Page 5-40. Albian Sands advises that “The arrangement of in-pit tailings cells, their final elevations and their filling sequence have been designed to meet the objectives of the final closure drainage plan. Placing variable depths of overburden capping material onto in-pit cells in conjunction with sand capping specific in-pit cells provide the required closure landscape. Final contouring of the capped tailings cells allows sustainable drainage patterns to develop, which eventually collect into the pit lakes.” The Closure Drainage Plan in Volume 4, Appendix 4-4, C, C&R Plan, Section 2.2, Figure 4, Page 17 states, “The layout of the proposed closure drainage systems, including main channels, secondary channels, shallow wetlands, and pit lakes are shown in Figure 4. Only a small
92 fraction of the channel lengths are cut through the natural ground. Most channels are built in overburden soil with selected gravel contents to resemble the natural analogues. Detailed information on closure drainage systems is provided in Volume 3, Appendix 3-2.” a. Clarify the apparent contradiction between these two statements. b. Will Albian Sands develop landform designs for watercourse requirements progressively as the landforms develop to achieve the strategy discussed in the C, C&R Plan and Volume 3? c. Figure 4 of the C, C&R Plan shows no watercourse development within an area that exceeds 1 km in length. What means will be used to manage water runoff from such large areas without significant erosion during major non-typical rainfall events?
Vegetation and Wetlands
361. Volume 3, Section 5, Figure 5.3-21, Page 5-80. This figure shows large drawdowns of the basal aquifer extending to the north and east and does not show any drawdown from the existing Syncrude and Suncor mines on the west side of the river. There are notable drawdowns at the CNRL Horizon Project, however. a. Explain if, and where, the extent of drawdown from the other west bank mines is impacting the basal aquifer. b. Will the cumulative drawdown of the basal aquifer have a negative impact on the salt water springs flowing into Saline Lake and La Saline Natural Area? Provide sufficient detail to justify the answer.
362. Volume 4, Section 1, Table 1.8-1, Page 1-45. In this section, Albian Sands discusses plans to salvage medicinal plants encountered in the proposed project footprint area. a. Discuss the potential to work with First Nations communities for harvest of these medicinal plants. b. Does the opportunity exist to transplant any of the more important species to areas that will not be disturbed by oil sands mine development?
363. Volume 4, Section 6.2.2, Page 6-16. This section indicates that the Project will result in a moderate negative environmental consequence to areas with high rare plant potential. This is due mainly to the inability to reclaim peatlands which have a high rare plant potential. At the Base Case, areas with high rare plant potential occupy 28% of the LSA, and at Closure, high plant potential areas will occupy 20% of the LSA. Albian Sands states that this is a decrease of 9% (Page 6-67: high rare plant potential will decrease 9% from 5,155 ha (28%) at the Base Case to 3,571 ha (20%) at Closure). a. Explain how this decrease was calculated. The above figures suggest that areas with high rare plant potential will decrease from 5,155 ha to 3,571 ha which means that the high rare plant potential area will be reduced by 29%.
93 b. Describe in detail all mitigation measures that Albian Sands will undertake to minimize impact on the area with high rare plant potential, and on the rare plant populations (transplantations, avoidance, etc.)
364. Volume 4, Section 6.2.2, Biodiversity, Page 6-19. Albian Sands states, “Terrestrial vegetation mean patch size (MPS) will increase 630% from 11 ha at the Base Case to 79 ha at Closure; the increase in MPS will have a positive effect on plant species of interior patch habitats including predominantly native plants.” a. What means would be used to introduce the vegetation species to the reclaimed lands? b. What species have been shown to establish on upland areas of reclaimed oil sand mines? c. What is the effect of the large polygon sizes to the suitability of wildlife habitat for the various Key Indicator Resource (KIR) guilds considered for the closure situation? d. Describe the strategies Albian Sands intends to use to encourage vegetative biodiversity and ecosystem development within the reclamation areas? e. What means will be used to introduce the range of upland species present prior to disturbance to reclaimed upland sites? f. What means will be used to introduce the range of wetland species present in an undisturbed site to reclaimed wetland sites?
365. Volume 4, Section 6.2.3, Page 6-20 and 6-21. Albian Sands mentions “mitigation measures designed to minimize the effects of the Project during operations”. These strategies include, “reclaiming and revegetating overburden dumps progressively to provide habitat”. a. Discuss Albian Sands’s strategy to reclaim and revegetate the non-overburden landscape progressively to an equivalent capability for end land use alternatives? b. What types of forest communities, and associated vegetation species, will make up the wildlife habitat for each KIR? c. What level of confidence (research or documented) exists to support the concept for each KIR?
366. Volume 4, Section 6.2.3, Page 6-21 and 6-22. In the first bullet, Albian Sands states, “reclaiming the landscape to an equivalent capability, optimizing the value of watershed, timber, wildlife habitat, fish habitat, recreation or other resources and taking into account stakeholder preference.” a. Describe the strategies Albian Sands would use to enhance the emergence of biodiversity, ecosystem, habitat and watershed values in the reclaimed lands. b. Would direct placement of the LFH soil layer and shallow mineral soils from upland forest situations be used to reclaim other upland forests? c. Would Albian Sands place an emphasis on the salvage and use of “fines” based soils, or higher fines content, over the use of the standard organic based reclamation coversoil as a means to enhance upland forest biodiversity potential when it is available?
94 367. Volume 4, Section 6.2.3, Page 6-21. Albian Sands makes a statement about “expanding the existing weed control system for the project area”. a. Describe the existing weed control system and provide details of the proposed changes. b. Clarify Albian Sands’s compliance with the Weed Control Act.
368. Volume 4, Section 6.3.2, Page 6-28 and Section 6.5.2.2, Page 6-58. Riparian communities within the LSA represent 1,219 ha (7% of LSA). Albian Sands identifies riparian communities as occurring within 100 m of watercourses. According to Albian Sands, riparian community area will increase from 1,219 ha (7% of the LSA) at the Base Case to 1,576 ha (9%) at Closure. Given the above definition of riparian communities, explain in detail the techniques, procedures and processes that will result in the proposed increase of riparian communities along the rivers and creeks at closure within the LSA.
369. Volume 4, Table 6.5-11, Page 6-53. Albian Sands plans to add 170 ha of “riparian shrubland #1” and 1416 ha of “riparian shrubland #2”, included as types of wetlands to be present in the closure landscape. These two vegetation types are not recognized by the Field Guide to Ecosites of Northern Alberta (Beckingham and Archibald 1996), nor by the Alberta Wetland Inventory. a. Described these two habitat types, including reference to established and accepted wetland categories. b. Explain why Albian Sands is proposing to develop such a large area of a habitat type in the reclaimed landscape that does not exist in the region naturally. c. Discuss options to provide an equivalent area of reclaimed wetlands that are consistent with established wetland categories.
370. Volume 4, Section 6.5.2.2, Table 6.5-20, Page 6-61. Albian Sands shows a net increase of 3975 ha of good to moderate TPR area. a. Provide peer supported data to support the concept that reclamation soils proposed for reclamation have the capability of sustainably producing TPR classes equivalent to predisturbance, without the use fertilizer or soil amendments. b. If the LCCS is found to have flaws then what is the implication for productivity of the reclaimed lands for wildlife, Traditional Use, or fiber?
371. Volume 4, Section 6, Table 6.5-26, Page 6-66. Sections 33 and 34 of TWP94 R10 W4 are reported to have limestone outcrops and wetlands on limestone. a. These areas have the potential for unique vegetation patterns and species. Were there any rare plants identified in this area? b. Confirm that sufficient surveys were done to find unique habitat types in this area.
372. Volume 4, Section 6.5.2, Page 6-69. Albian Sands states that it is “…conducting a wetlands monitoring program to verify the predictions of dewatering in the vicinity of the existing Muskeg River Mine.” Provide a summary of data and results from this program to date, including a map of the groundwater observation network.
95 373. Volume 4, Section 6.5.2, Tables 6.5-11, 6.5-13 to 6.5-15, 6.5-17, 6.5-18, 6.5-20, 6.5-21, 6.5- 24, 6.5-25, 6.5-27, 6.5-29, 6.5-30 to 6.5-32. Changes in areas of vegetation are given as absolute percent of LSA or RSA. In the final TOR for the MRME project, Clause 5.7.3 (f) (vi) directed changes to be reported as relative percent change in the indicator. a. Provide the relative percentage change and recalculate all affected tables accordingly. b. Recalculate Table 6.5-33.
374. Volume 4, Appendix 4-8, Page 9, and Volume 4, Table 1.4-1, Page 1-21. The expansion of the West Pit will require approximately 5 km of Highway 63 to be realigned closer to the Athabasca River. The disturbance footprint including the highway will be ~150 m from the river at its closest point. Albian Sands points out that due to the realignment of Highway 63 the adjacent riparian area may not be suitable for wide-ranging wary wildlife until about 20 years after reclamation, around year 2041. Albian Sands also notes that riparian communities are highly productive areas with high rare plant potential and form important wildlife habitat and corridor areas, and the highest number of potential terrestrial vertebrate species (132) occurred in the riparian areas (Appendix 4.3, Page 18). a. What mitigative measures are Albian Sands planning to undertake to minimize the effects of the Highway 63 realignment on riparian habitats, specifically with regard to maintaining high rare plant potential along the Athabasca River and maintaining effective wildlife movement corridors in the river valley? b. Discuss the potential for reducing impacts on rare plant habitat, wildlife movements and habitat connectivity within the LSA. c. Discuss alternative locations for realigning Highway 63 (e.g., the previously mined areas to the east), and provide details on the practicality of these alternative locations.
375. ESR for Terrestrial, Section 3.4, Page 3-6. Albian Sands indicates that invasive species were found within the LSA. a. Describe measures that Albian Sands is planning to undertake to reduce the encroachment of invasive species in the LSA. b. Discuss Albian Sands’s plan to monitor invasive plant species in the LSA during the life of the project.
376. ESR for Terrestrial, Page 3-8. Vegetation resources in the RSA were quantified from satellite imagery under a supervised classification. Provide an accuracy assessment for the resulting classification based on field data that were not used in the training of the classification. This should include an overall accuracy of the image as well as class-by-class errors.
377. ESR for Terrestrial, Page ii, and Volume 4, Section 6.5.2.2, Page 6-65. This report indicates that twenty-three rare vascular and thirty-two bryophyte species were found on the LSA - two of these species are new to Alberta. Plants found within the Project footprint but not elsewhere within the LSA include the following vascular
96 plants: western meadow aster (Aster campestris), willow herb (Epilobium halleanum), mountain club-moss (Huperzia selago), white adder's-mouth (Malaxis monophylla), Leiberg's (white) waterlily (Nymphaea tetragona) and bur-reed (Sparganium fluctuans); and non-vascular plants: Amblyodon dealbatus, Callicladium haldanianum, Campylium polygamum, Polytrichum longisetum and Thiudium philbertiis. One species (Callicladium haldanianum) is new to Alberta, and was found within the project footprint. a. Identify which species are listed under the General Status of Alberta Wild Species (ASRD 2000) and the Federal Species at Risk Act. b. Describe all mitigation measures that Albian Sands will undertake to minimize impacts on the unique species that will be affected by the project and occur on the project footprint only. c. Describe any special mitigation plans for Callicladium haldanianu, a rare species new to Alberta, and found within the project footprint.
378. ESR for Terrestrial, Section 6.1, Page 6-1 and Volume 4, Section 6.2.2, Page 6-15. This report states that wetlands dominate the LSA, covering 59% (6,659 ha). Albian Sands indicates that wetlands will decrease in area by 2,239 ha, which is a decrease of 33.6%. a. Discuss alternative reclamation technologies that Albian Sands could take to diminish this significant loss of wetlands in the local area and result in more wetlands present in the project area after reclamation. b. Describe potential adjustments (possible restoration of fens) in the proposed reclamation plan that would increase the area of wetlands in the LSA after reclamation.
379. ESR for Terrestrial, Section 6.2.2, Table 6.2. This table lists all species of rare plants found within the LSA. Provide a table listing all species of rare plants found within the LSA and on the project footprint and indicate the exact locations where the rare plants were observed. Confirm that the rare plant documentation has been provided to the Alberta Natural Heritage Information Centre (ANHIC).
380. Volume 4, Appendix 4-4, C, C&R Plan, Section 1.6, Page 15. Albian Sands identifies a number of assumptions that may affect their ability to reclaim disturbed lands, including the statement that “species identified in the Oil Sands Vegetation Reclamation guidelines will be available for use (OSVRC 1998)”. a. Are all vegetation species recommended by the guideline available for reclamation at the MRM? b. If not, which species are unavailable? c. Identify the work, and funding expended by Albian Sands to determine the means to produce and develop seedlings of these unavailable species for use in reclamation of their mine development since development of the Muskeg River Mine? d. What developmental steps, funding and schedule does Albian Sands have in place to develop vegetation species sources for these currently unavailable species?
97 381. Volume 4, Appendix 4-4, Figure 4, Page 18. This section addresses wetlands and watercourses in the closure landscape. However, the conceptual map does not show integration across lease boundaries between reclaimed (closure) watercourses and adjacent natural watercourses. a. Discuss and clarify how closure wetlands and watercourses will be integrated across lease boundaries with adjacent natural wetlands and watercourses. b. Provide conceptual maps and plans illustrating this integration.
382. Volume 4, Section 6.2.2, Page 6-19. Albian Sands states, “The plant and wildlife species of treed fens and bogs, shrubby fens and graminoid fens of deep organic soils constituting a portion of the biodiversity of peatland wetlands types, are expected to be negatively affected in the LSA. The environmental consequence to ecosystems with high biodiversity potential, including wooded and shrubby fens, is moderate in a negative direction due to a moderate magnitude of disturbance and irreversibility. Marshes and wetlands with high biodiversity potential will be used to reclaim former peatlands where possible. This will reduce the environmental consequence due to the loss of high biodiversity potential peatlands.” a. What is the potential biodiversity of reclaimed marshes and wetlands as contrasted with wetlands of the predisturbance situation? b. What is the Albian Sands plan for incorporation of vegetation species important to First Nations into the revegetation plan for wetlands? i. Clarify the species, the area of each species type and strategies for their establishment? c. What are the types of wetlands envisioned for the reclaimed areas? d. Discuss any pilot programs planned to demonstrate the return of wetlands and their biodiversity through the use of direct placement of wetland vegetation?
383. Volume 1, Section 16.7, Page 16-31. Water Quality Mitigation, Monitoring and Management. Within this section there is no discussion of riparian area development. Riparian areas associated with watercourses have been evaluated as having a diverse range of rare plant species. a. Provide baseline information showing the various types of watercourses in the area and the range of riparian vegetation species associated with each? b. Discuss the reclamation strategy for watercourse development for ecosystem establishment? c. Provide a schedule for the development of baseline species determination and, species selection and recruitment for reclaiming riparian areas of the proposed development area.
384. Volume 4, C, C&R Plan, Section 2.2.6.1, Page 37. Albian Sands states, “Planting of riparian and instream vegetation will sometimes be required in the development of reclaimed streams and lakes to ensure rapid development of aquatic communities.” a. What are the species Albian Sands is proposing be planted? b. What is the source of these species? c. When would such species be available for operational use?
98 385. Volume 4, C, C&R Plan, Section 2.2.6.1, Page 37. Albian Sands states, “Additional approaches to enhancing colonization by plants, algae and invertebrates include seeding of periphyton and invertebrate communities in streams by using cobble from nearby natural streams, and seeding of plankton communities in lakes and ponds by water from nearby natural lakes and ponds.” a. What are the locations of the source riparian and watercourse areas? b. If these source areas are not within the proposed development area then what added impact to the area would occur?
386. Volume 4, Section 6.5.2.2, Page 6-57. Albian Sands states, “Riparian community area will increase from 1,219 ha (7% of the LSA) at the Base Case to 1,576 ha (9%) at Closure (Table 6.5-17); the increase in riparian community area will have a positive effect on vegetation with increased habitat for plant species adapted to interior habitats, many of which are native species.” a. What types of riparian habitat existed prior to disturbance as compared to the proposed closure situation? b. Explain what species are being referred to, what is their source and means of dispersion within the interior habitat? c. If the species are not native, then what non native riparian species are envisioned?
Wildlife and Biodiversity
387. Volume 1, Section 1.1, Page 1-6. Albian Sands indicates that three new bridges will be constructed over the Muskeg River for the haul road, conveyor and pipelines. A haul bridge between the existing Canterra Road bridge and the Albian Sands utility bridge will be constructed. The conveyor belt and process pipelines in the utility corridor between the Sharkbite area and the plant site will require construction of two additional bridges across the Muskeg River (Appendix 4-8, Section 3.2, Page 7, and Volume 1, Figure 6-10, Page 6-21). In previous project applications, Shell (Albian Sands) committed to maintaining an undisturbed buffer (400 m wide) along the Muskeg River valley, as mitigation for impacts to wildlife use and habitat connectivity. a. How would the form (length and width) and function (use and effectiveness) of this buffer be impacted by the proposed project? b. Discuss alternative options Albian Sands might consider to minimize the number of bridges on the Muskeg River, reducing the project footprint and maintaining Albian Sands’s commitment to undisturbed buffers and wildlife habitat connectivity. i. Compare the options in terms or technical suitability, economics, and environmental impact. c. Provide detailed information on the widths of the bridges under alternative scenarios and include the openness ratio for the wildlife crossings under the bridges.
99 388. Volume 1, Section 8.6, Page 8-16. Albian Sands indicates that although the conveyor bridge will not be required until 2020, it will be built in 2007 to provide additional motor vehicle crossing for construction purposes. Discuss the alternative of using the haul bridge or other existing bridges for motor vehicles and delaying construction of the conveyor bridge until 2020 to reduce the impact on wildlife movements and habitat connectivity.
389. Volume 1, Section 8.6, Figure 8-1, Page 8-17. This figure depicts a relocation of the Canterra Road. Discuss the potential effects on wildlife movements and wildlife habitat connectivity within the LSA as a result of the relocation of Canterra Road. Explain in relation to other developments within the LSA.
390. Volume 2, Appendix 2-5, Section 4.2, Page 24. This section describes wildlife monitoring programs planned by Albian Sands in relation to project operations and those required by existing EPEA approvals. Discuss Albian Sands’s plans to monitor wildlife (amphibians, birds, small mammals, ungulates, carnivores, etc.) on the areas reclaimed in this project.
391. Volume 3, Section 5.2.4.5, Page 5-35. Albian Sands states, “…outflows will be directed to treatment wetlands to receive further treatment and produce satisfactory water quality before being released to receiving waterbodies.” Volume 3, Section 5.5.4.6, Page 5-215, Albian Sands states, “Eroded material transported in surface flow will be trapped in polishing ponds, wetlands and pit lakes; therefore, sediment and associated adsorbed substances eroded from natural, disturbed and reclaimed land areas will have negligible effect on sediment quality of PAHs and metals in receiving waterbodies and watercourses.” a. Explain what the potential impacts are to waterfowl, amphibians etc. of process- affected water and eroded material in sedimentation ponds or wetlands. b. Explain what mitigation Albian Sands is considering for protecting or preventing wildlife from using the sedimentation ponds or treatment wetlands that contain process-affected water and eroded material. c. Discuss how effective prevention of wildlife use of tailings ponds etc., have been at the existing Muskeg River Mine.
392. Volume 4, Section 1.6, Table 1.8-1, Page 1-44. This table indicates that Albian Sands will support the Alberta Biodiversity Monitoring Program. Explain how this support will be realized. Describe any plans for Albian Sands to participate in programs to monitor the cumulative effects on biodiversity in the region using the Alberta Biodiversity Monitoring Program protocols where feasible.
393. Volume 4, Section 6, Pages 6-17, 6-86, 6-95, and Table 6.5-35, Page 6-82. This section indicates that 59% of Canadian toad habitat will be lost due to the project development and that Canadian toad habitat is not expected to reach pre-development levels at closure. Canadian toad is listed provincially as “May be At Risk” species in the General Status of Alberta Wild Species (ASRD 2000), and the Muskeg River-
100 Kearl Lake area can be described as a localized concentration of the species in the Regional Study Area. a. Describe Albian Sands’s mitigation measures designed specifically for Canadian toad. b. Provide Albian Sands’s perspective: Is the Muskeg River Mine Expansion Project, combined with other developments in the Muskeg River valley and near Kearl Lake, likely to eliminate one of the most significant populations of Canadian toad in the region? c. Examine Canadian toad habitat availability and suitability in the LSA, and compare with habitat suitability, distribution and abundance in the RSDS study area (see CEMA Sustainable Ecosystem Working Group study – Regional Habitat Suitability Modeling for Canadian Toad). This information would be required prior to further disturbance at the Project site.
394. Volume 4, Section 6.2.3, Page 6-20. This section describes environmental mitigation options that Albian Sands will undertake during project life. Discuss other mitigation options for species of special concern (e.g. Canadian toad) and migratory birds.
395. Volume 4, Section 6.3.3, Page 6-33. This section indicates that wolverine and the northern long-eared bat were recorded within the LSA. Both these species are designated as ‘May Be At Risk’ in the General Status of Alberta Wild Species (ASRD 2000). Describe any mitigation measures Albian Sands is planning to undertake that are designed specifically for these two species.
396. Volume 4, Section 6.5.3.2, Page 6-76, and Section 1.6, Table 1.8-1, Page 1-44. Albian Sands indicates that potential nuisance wildlife (especially black bears) will be removed from the project areas. Albian Sands also points out that bear relocation tends to be very expensive and requires considerable effort. In Table 1.8-1 (Page 1- 44) Albian Sands states it will continue to implement the Nuisance Wildlife Species Control Program. Describe all measures that Albian Sands will employ to prevent black bears from entering the project sites (camps, mines, pipeline and utility corridors, other infrastructure, etc.) and adjacent areas.
397. Volume 4, Appendix 4-1, Table 6, Page 53. This section indicates a total loss (100%) of habitat for the old growth forest bird community, including pileated woodpecker, black-backed woodpecker, Cape May warbler and barred owl. All of these species are listed as sensitive species in the General Status of Alberta Wild Species (ASRD 2000). a. Discuss the effect this habitat loss may have on the viability of the local populations of old growth forest birds (especially species designated as sensitive) and the potential to reach pre-disturbance levels after reclamation. b. Discuss alternative mitigation, reclamation and revegetation techniques Albian Sands might consider to minimize loss of habitat for old growth forest bird communities in the project area post-closure.
101 398. Volume 4, Appendix 4-1, Section 2. This report describes Habitat Suitability Index (HSI) Models developed for moose, lynx, black bear, fisher, beaver, muskrat, ducks and geese, boreal owl, and Canadian toad. Based on these models, maps of the distribution of different quality habitats for the above species at the base case were provided (Figures 9 – 29). Model validation was provided for the Canadian toad HSI model only. The project terms of reference (5.7.4.e.) indicate model predictions should be compared with wildlife data from the Study Areas. a. Discuss the confidence that the models developed for species other than Canadian toad can be confirmed by field observations. b. Discuss the process and data used to validate/calibrate the HSI models for moose, lynx, black bear, fisher, beaver, muskrat, ducks and geese, and boreal owl. c. Explain how the values of all parameters and multipliers used in the HSI models were estimated. Provide rationale for using specific values of the parameters in the HSI models (i.e., using 0.8 as FOOD multiplier in moose HSI, using a reference for the values of the ‘mean tree diameter at breast height’ variable depicted in Figure 3 in the HSI model for black bear, and using a reference for the values of "mean canopy tree height" (variable SI(1)) in the moose model). d. Provide figures illustrating the distributions of high, moderate and low quality habitats for all modeled species in the closure landscape.
399. Volume 4, Appendix 4-1, Section 4. This section discusses Population Viability Analysis for moose and black bears. Throughout this section, units of animal densities and population sizes are used very inconsistently. a. Standardize the units to express the densities as number of animals per square km. b. Provide units for all variables listed in Tables 13 and 14 on Page 64.
400. Volume 4, Appendix 4-1, Section 4. This section deals with potential changes to moose and black bear populations over the period of the next 30 years. The estimated carrying capacity is given for the RSA. At the same time Albian Sands states that black bear habitat within the LSA will be reduced by 64% (Volume 4, Section 6.2.2, Page 6-17). a. Provide the predicted carrying capacity expressed as animal/km2 for black bears and moose in the LSA. b. Explain whether the carrying capacity (for black bears and moose) in the LSA after closure will be higher or lower (or remain the same) than the carrying capacity in the LSA before project development. c. The Population Viability Analyses (PVAs) completed for moose and black bear do not account for potential effects of increased hunting pressure resulting from increased access. Other potentially important factors not included in these PVAs are vehicle collision mortality and potential changes in predation pressure. Explain the effect these factors would have on the outputs of the PVAs, had they been included in the analyses.
401. Volume 4, Appendix 4-1, Section 4.3.1.2, Page 65. This report indicates that in the population viability analysis completed for moose, the Base Case carrying capacity was estimated to be 0.72 moose/km2.
102 a. Is this a reasonable estimate? Explain in detail (by giving specific equations) how this moose carrying capacity was calculated. (Previous work completed in northeastern Alberta demonstrated that moose density is usually less than 0.25 moose/km2 (Schneider and Wasel 2000)). b. Provide specific references that report moose densities in the RSA higher than those reported by Schneider and Wasel (2000) [Schneider, R.R. and S. Wasel. 2000. The effect of human settlement on the density of moose in northern Alberta. Journal of Wildlife Management 64(2): 513-520.].
402. Volume 4, Appendix 4-1, Section 4.3.2.2, Page 69. This section indicates a 50% decrease in carrying capacity (from 0.18 bear/km2 to 0.09 bears/km2) for black bears in the RSA over 30 years, but Figure 32 implies that there will be no significant change in black bear population size over the next 30 years. Explain what factors are responsible for the almost constant size of the black bear population despite a very significant (50%) decline in the carrying capacity for this species.
403. Volume 4, Appendix 4-8, Section 3.2, Page 7. Albian Sands indicates that the utility corridor connecting the Sharkbite area and the plant site will contain a conveyor belt, ten process pipelines and the existing facility access road and bridge (Appendix 4-8, Section 3.2, Page 7, and Volume 1, Figure 6-10, Page 6-21). Two new bridges will be constructed beside the existing utility bridge, one for conveyors and another for pipelines. a. What would be the total width of this utility corridor connecting the Sharkbite area and the plant site? b. Discuss alternatives that would result in a narrower total width of this utility corridor crossing of the Muskeg River.
404. Volume 4, Appendix 4-8, Section 3.2, Page 7. According to Albian Sands the wildlife crossing area under the conveyor belts along the west side of the corridor will be 82 m from the edge of the access road to the point where the conveyors reach ground level. Describe what kind of wildlife crossing structure Albian Sands proposes along the east side of the wildlife corridor.
405. Volume 4, Appendix 4-8, Section 3.2, Page 6. Albian Sands indicates that a 10 m wide, 4 m high, 34.5 m long wildlife underpass will be constructed approximately 250 m southeast of the bridge over the Muskeg River to provide additional wildlife passage. a. Clarify what kind of a wildlife crossing structure Albian Sands proposes to construct. Provide the design specifications of the proposed crossing structure and illustrate with figures. b. Discuss predicted effectiveness of the proposed crossing structure, using existing data where available. c. Discuss potential impacts on the existing wildlife buffer.
406. Volume 4, Appendix 4-8, Section 3, Page 6-8. This section discusses the existing and future bridges over the Muskeg River and wildlife crossings along the
103 river. However, it is not clear what width of setback distances Albian Sands is proposing to maintain that would allow for wildlife movement along the Muskeg River. Discuss the widths and effectiveness of setbacks that Albian Sands will maintain along the Muskeg River.
407. Volume 4, Appendix 4-8, Section 3.2, Page 8. Albian Sands states that the Muskeg River near the haul road bridge (depicted in Figure 7.5-23) and the existing Project bridge is about 10 m wide for most of the year. The width of the bridges will provide a 9 m shoreline to maintain wildlife movement during most periods of the year. Albian Sands also indicates that there will be no dry ground on either side of the river under the bridge during a 1:100 year flood. a. Confirm whether this 9 m of shoreline is the combined width of the shorelines on both sides of the river. b. Indicate how much dry ground there will be under 1:20 and 1:50 year floods.
408. Volume 4, Appendix 4-8, Page 9. Albian Sands indicates that the realignment of Highway 63 will create a corridor of variable width (from 150 to 800 m) for about 8 km on the east side of the Athabasca River Valley. Albian Sands also provides evidence from other studies documenting wildlife use of corridors 6 km long and 350 – 1500 m wide. Albian Sands states that the remaining undisturbed valley will be as narrow as 150 m and suggests that the adjacent Daphne Island may be used by some species of wildlife seasonally, effectively increasing the width of the remnant corridor for them. a. Provide evidence to support the conclusion that Daphne Island might be used as a movement corridor for wildlife, on an annual or seasonal basis. b. Using existing evidence, substantiate the effectiveness of wildlife movement corridors 8 km long and 150 – 800 m wide, and indicate how this information and data could be applied to wildlife in the study area. c. Has Albian Sands considered establishing setbacks along the Athabasca River wider than 150 m at the narrowest point, similar to commitments made by other industrial operators in the oil sands area? d. Has Albian Sands considered the 400 m setback currently recognized along the west side of the Athabasca River Valley at the CNRL Horizon Project, and why that setback was established?
409. ESR for Terrestrial, Section 4.1.3, Page 4-2. Albian Sands states, “A nocturnal owl survey was undertaken in the study area to determine “presence” versus “no detection” for the six species that occur in the region and that are also known to respond to broadcast calls: saw-whet owl, boreal owl, long-eared owl, barred owl, great gray owl, and great horned owl (Takats and Holroyd 1997). Two other species that occur in the Oil Sands Region as well, the northern hawk owl and short-eared owl (Semenchuk 1993), do not respond to broadcast calls.” a. Considering that two owl species are recognized as not responding to broadcast calls, explain what alternatives to broadcast surveying were considered (for example, key squares surveys, diurnal point count surveys) and why they were not chosen.
104 b. How were the northern hawk owl and short-eared owl accounted for?
410. ESR for Terrestrial, Figures 4-4, 4-5, 4-6, 4-7, 4-8, and 4-9, Pages 4-10 to 4- 15, 4-19 to 4-22, and 4-25. Figure 4-9 indicates that numerous bat capture and echolocation site locations in the southern part of the LSA were used in bat baseline data surveys. Similarly, Figure 4-4 indicates stations for nocturnal owl surveys located in the southern part of the LSA. However, Figures 4-5, 4-6, 4-7, and 4-8 show that the southern part of the LSA was not included in the surveys conducted for pellet transects, raptor broadcast/sightings, and amphibians respectively. Explain why the southern part of the LSA was not included in these baseline field surveys.
411. ESR for Terrestrial, Table 4-3, Page 4-18 and Figure 4-8, Page 4-21. The Breeding Bird Survey that was conducted for this project did not provide complete coverage of the LSA. Of 25 ecosite phases present in the LSA, 14 were sampled at two or fewer locations. No surveys were conducted in the south Lease 90 area. Albian Sands states on Page 4-18 that “…difficulties in accessing some areas of the Leases did not allow complete representation…”, and yet bat surveys were conducted in the Lease 90 area in July when access should have been similarly difficult. a. Support Albian Sands’s conclusion that the breeding bird survey is adequate to characterize the bird communities within the LSA at baseline, and to provide a foundation for post-reclamation monitoring. b. Would Albian Sands consider conducting supplemental breeding bird surveys to obtain baseline information in the Lease 90 portion of the project area?
412. ESR for Terrestrial, Section 7.2.2, Page 7-11. The baseline information provided in this section on woodland caribou in the RSA and LSA seems to be incomplete. After the introduction, the next subsection (7.2.2.1, Page 7-12) describes baseline information on deer populations instead of caribou. Woodland caribou are listed as “At Risk” in Alberta. Provide the missing baseline information and discussion on woodland caribou in the RSA and LSA.
413. ESR for Terrestrial, Section 7.2.1.3, Page 7-11. Albian Sands states, “Traditional ecological knowledge gathered during consultations with Elders of the Athabasca Chipewyan First Nation indicates that moose use the West Pit area of the LSA year-round (ACFN 2004; Figure 7-1).” a. Explain whether traditional ecological knowledge (TEK) was gathered on other species in addition to moose and provide Albian Sands’s findings if so. b. Clarify whether TEK from Fort McKay First Nations regarding wildlife habitat use was gathered. If not, explain why not.
414. ESR for Terrestrial, Section 7.3.2.1, Page 7-16. Albian Sands states, “Neither fisher nor fisher sign were systematically recorded during baseline tracking or pellet surveys in the LSA.” Explain why fishers were not systemically recorded during baseline tracking and pellet surveys.
105 415. ESR for Terrestrial, Section 7.8.3.4, Page 7-38, Table 7-19. This report notes the presence of short-eared owl within the LSA. Short-eared owl relies on maintenance of edges of large wetlands, but wetlands will be significantly reduced due to the project development. Short-eared owls are designated as “May Be at Risk” in the General Status of Alberta Wild Species (ASRD 2000). a. How will this habitat loss affect the viability of the local population of short-eared owl and its potential to reach pre-disturbance levels after reclamation? b. Discuss alternative reclamation and revegetation techniques that might reduce habitat loss for the short-eared owl.
416. ESR for Terrestrial, Section 7.9.3, Pages 7-59 – 7-64. Of the six species of management concern categories (ungulates, fur bearers, ursids, bats, amphibians, and birds) described for regional habitat availability on pages 7-59 to 7-64, 4 of the categories were described as finding more usable habitat in the local study area relative to what is available in the regional study area. Discuss the significance of this finding in terms of the effect of significant disturbance in the local study area on habitat availability.
417. ESR for Terrestrial, Section 7.9.4, Page 7-64. Albian Sands makes no reference in this section to the Yellow Rail, a “sensitive” species under the federal Species At Risk Act. However, in Terrestrial Appendices, Appendix O, Table O- 6, Page O-12 it is reported that five Yellow Rails were observed incidentally on four different occasions, at four locations. This frequency of occurrence is one of the highest recorded on any oilsands region bird survey to date. a. Provide a map of the observation locations, including an overlay of habitat polygons. b. Describe in detail the habitat at each of the observation locations, including specific reference to the areas of FONG (graminoid fen) that have been identified in the LSA. c. Explain why once these birds had been recorded, an appropriate nocturnal survey was not conducted? d. Discuss the potential extent of Yellow Rail habitat in the LSA, and the number of birds that might be expected in the LSA. Discuss expected impacts to this species at its preferred habitat. e. Provide a detailed discussion of options for mitigation of impacts to Yellow Rail.
HEALTH
General
418. Volume 1, Section 2.2, Page 2-4. Albian Sands states, “Additional equipment, including hydraulic excavators, 300-t and 90-t trucks, is provided by earth moving general contractors.” Provide an accurate prediction of the additional numbers of equipment and indicate how these were accounted for in the air effects predictions in the EIA.
106 419. Volume 1, Section 5.1, Page 5-2. Albian Sands states, “Alternative 3 was selected because it was determined to be environmentally and socio-economically neutral, yet economically superior to the other alternatives considered.” a. Provide evidence illustrating how Alternative 3 is neutral, both environmentally and socio-economically, compared to the other alternatives. b. Identify how the alternative was determined to be neutral in these respects.
420. Volume 1, Section 5.3, Page 5-24. With respect to asphaltene pastille storage, Albian Sands states “Leading tests showed that the pastilles are inert.” Provide references to support this conclusion, and confirm that no Chemicals of Potential Concern (COPCs) (including any heavy metals) are entering water that comes in to contact with this product.
421. Volume 1, Section 5.6, Page 5-53. Albian Sands states, “The balance of the slash will be chipped, where practical, or piled and burned.” a. Provide an estimate of how much slash will be burned. b. In addition, indicate whether emissions associated with slash burning have been included in the air assessment. If not, provide the updated assessment.
422. Volume 1, Section 10.2, Page 10-5 to 10-6. With respect to muskeg and overburden dewatering, indicate whether there will be any metals or hydrocarbons released to surface waters during the dewatering process.
423. Volume 1, Section 10.2, Page 10-9. Albian Sands states that it will divert Athabasca River water through existing Albian Sands raw water pipelines to a sedimentation pond, and discharge it to the lower section of Mills Creek. Indicate whether this alteration in water source will affect the surface water bodies in any way (e.g. water quality, fish abundance and diversity, etc.).
424. Volume 2, Appendix 2-14, Section 2.2.2.4, Page 36. Albian Sands states, “If substances were detected in plant samples but not in soil, the BAF was calculated using half the detection limit for soil and vice versa.” Provide the rationale for using half the detection limit rather than using a more conservative approach, such as using the full detection limit.
Human Health
425. Volume 2, Section 3.4.2.1, Page 3-55. Albian Sands states, “Some of the Project emissions were increased proportionally based on the increased production rate; however this scaling could not be completed for all scenarios based on the following:…” a. For the cases where scaling was not carried out, clarify how predictions were generated for the modeling. b. Discuss why scaling could not be completed for some scenarios.
107 426. Volume 2, Section 3.4.3.2, Table 3.4-17, Page 3-87. The PM2.5 predictions for regional communities in Base and Application Case seem to be much lower than predictions made in previous EIAs (e.g. Shell Jackpine Mine). Explain why this is the case.
427. Volume 2, Section 3.4.7.2, Table 3.4-17, Page 3-116. For the VOC and other compounds assessment it was assumed that the mine fleet and tailings pond “…were conducted in the western portion of the development area.” Albian Sands suggests that this is unrealistic yet more conservative. Albian Sands then states, “For the odor assessment, a more realistic mine fleet and tailings pond configuration was assumed.” a. Explain why Albian Sands did not choose to use the more conservative scenario for the odor assessment as well. b. Provide the odor assessment using the more conservative assumptions used for the rest of the assessment.
428. Volume 2, Section 4.2.2.1, Page 4-5. Albian Sands states “The PTI camp and the Oil Sands Lodge were only evaluated for the base case because these camps will be moved to a new location as a result of the project.” Provide justification for not including an evaluation of the new camp locations for the application and planned development case.
429. Volume 2, Section 4.3.2.3, Page 4-16. Albian Sands states, “The multi-media risk assessment does not include volatile organic chemicals and acid gases since deposition of these substances from air and incorporation into other media would be negligible.” Provide evidence to support this conclusion.
430. Volume 2, Section 4.3.2.3, Page 4-19. Albian Sands states, “Although historically exposures have been evaluated over a full lifespan for carcinogenic chemicals, “the variability between adult exposure and lifelong exposure is much smaller than the uncertainty inherent in the derivation of cancer slope factors (Health Canada 2003a); thus, evaluation of the adult phase is considered acceptable.” This comment is excerpted from a guidance document for screening at contaminated sites, and should not necessarily reflect practices for a full human health risk assessment. It is not adequate evidence to justify evaluating only the adult life phase. Provide an assessment of risk associated with carcinogenic chemicals using an entire lifetime (i.e. 70 years).
431. Volume 2, Section 4.3.4.1, Page 4-32. The acrolein and sum (nasal lesions) Exposure Ratios (ERs) exceed 1.0 at many residential receptors. Comment on the health effects that may be experienced by the receptors at these locations.
432. Volume 2, Section 4.3.4.1, Table 4.3-5, Page 4-32. Table 4.3-5 presents predictions only for cabins A-F and J. Explain why the labelling process of cabins omits G, H, I.
108 433. Volume 2, Section 4.3.4.1, Page 4-40. In the chronic effects assessment, it is estimated “…wild plants/garden produce constitute 100% of a person’s summer vegetable consumption.” a. What was the duration of a summer in this assessment? b. Furthermore, how will this assumption take into consideration individuals who preserve wild plants and garden produce and eat them year long?
434. Volume 2, Section 4.3.4.2, Table 4.3-13, Page 4-45. The maximum 24-hr acrolein concentration is absent from Table 4.3-13. Indicate why no maximum 24 hour concentration of acrolein is presented.
435. Volume 2, Section 4.3.4.2, Table 4.3-14, Page 4-45. Albian Sands states, “Application Case acrolein concentrations are higher than Base Case concentrations at the 95th percentile, but there is very little difference between Base Case and Application Case concentrations at the 75th percentile. Thus, 75% of the time, exposures at these locations will be equivalent to Base Case exposures.” And, “Thus, slightly less than 75% of the time, daily acrolein concentrations at these locations will be less than the acute limit.” a. Explain the small increases between the Base and Application Cases for Fort McKay and Cabin E for the 1-hour acrolein peak and maximum concentrations. b. Specify at what percentile 24-hr acrolein concentrations are less than the acute limit. c. Comment on the potential health implications associated with exposures above guidelines over 25% of the time.
436. Volume 2, Section 4.3.4.3, Page 4-48 and Appendix 2-14, Page 111. The PM2.5 acute impacts do not identify what air concentrations (e.g. average, maximum, or 98th percentile) were used in the PM2.5 assessment. Provide the air concentrations used.
437. Volume 2, Appendix 2-9, Section 4.8.1, Page 59. Albian Sands states, “Predicted concentrations for PM2.5 and VOCs are very similar between options at all receptors, indicating that any of the four options would be acceptable.” Following this result, explain why the model retained is considered more conservative than the others for predictions of acrolein concentrations.
438. Volume 2, Appendix 2-14, Page 53. Albian Sands states, “Annual average ambient air concentrations for the Application Case were compared to risk-based concentrations (RBCs) for the protection of human health.” Using annual averages in the screening process does not account for health effects associated with acute exposures. Provide an updated, more conservative screening assessment that uses 1- hr and 24-hr maximums to identify potential Chemicals of Potential Concern (COPCs) to be evaluated in the assessment.
439. Volume 2, Appendix 2-14, Section 4.1.2, Table 68, Page 105. The highest 24- hr peak acrolein concentration is 1.9 µg/m3. a. Identify at what location this prediction was made.
109 b. Explain why this location was not included in Table 4.3-13.
440. Volume 2, Appendix 2-14, Section 7.1, Table 96, Page 159. In Table 96, Incremental Lifetime Cancer Risk (ILCR) at Cabins E and F for nasal tumours are equal to the upper bounding acceptable risk of 1x10-5. Discuss the Sum ILCR (Nasal Tumours) for Cabins E and F.
Wildlife Health
441. Volume 2, Section 4.4. Indicate whether Albian Sands took into account impacts on wildlife health due to removal or disruption of habitat.
Hydrogeology
442. Volume 3, Section 5.3.4.1, Page 5-51. Albian Sands states, “Effects on groundwater quality attributable to Basal Aquifer depressurization, potable supply wells, EDTA and extraction plant facilities have not been observed (Komex 2004).” Clarify whether this statement suggests that the effects have been investigated and not observed, or that the association between the activities and groundwater quality has not been investigated.
443. Volume 3, Section 5.3.5.5, Figures 5.3-16, 5.3-18, 5.3-21, Pages 5-75 to 81. Based on the zones of drawdown, clarify whether Albian Sands has identified any residential groundwater users that may be negatively impacted as a result of this drawdown.
444. Volume 3, Section 5.3.5.6, Page 5-85. Albian Sands states, “During operations the water from these facilities will be pumped and returned to the tailings facility…After mine operations are completed, seepage intercepted by the perimeter ditches will be routed through wetlands prior to being released to the environment.” a. Discuss the predicted impacts associated with the seepage entering the wetlands. b. Discuss Albian Sands’s plan to contain ETDA water until it is of acceptable quality to be released to the environment.
445. Volume 3, Section 5.3.5.9, Page 5-95. Albian Sands states, “Seepage from the ETDA will alter groundwater quality, although this effect will be limited to the Quaternary sediments and Basal Aquifer beneath the footprint of the TDA, due to the presence of perimeter ditches which intercept lateral seepage from the facility.” a. What is the level of confidence associated with the effectiveness of this mitigation measure? b. Should this measure fail, discuss additional mitigation measures available to prevent groundwater impacts.
446. Volume 3, Section 5.3.5.9, Page 5-96. Albian Sands states, “Downward seepage of water from tailings-backfilled mine pits into the Basal Aquifer may result
110 in a deterioration of groundwater quality in this aquifer.” Indicate whether there are any receptors in the region with drinking water wells that may be impacted.
Surface Water
447. Volume 3, Section 5.5.2.4, Page 5-185. Albian Sands suggests that methyl- isobutyl-carbinol (MIBC), kerosene, and/or diesel may be used on site at a later date. Provide a health risk assessment associated with the use of these compounds.
448. Appendix 2-14, Section 2.4, Page 45. Albian Sands states “Site-specific bioconcentration factors (BCFs) from water to fish were calculated from recently measured fish tissue concentrations in the Athabasca River from the RAMP program (Golder 2003a; RAMP 2004) and modeled background water quality for Athabasca River.” a. Explain why background water quality was modeled instead of measured. b. Indicate whether there are RAMP fish tissue concentrations available for other waterbodies including Muskeg River and Isadore’s Lake. If so, please include this data in the risk assessment.
449. Appendix 2-14, Section 2.4, Table 38, Page 47. In the case of antimony, cadmium and vanadium, explain how base case water concentrations are greater than the application and the planned development case water concentrations.
450. Volume 2, Appendix 2-14, Section 3.2.1.1, Tables 50-52, Pages 72, 74 and 75. Tables 50, 51 and 52 compare median chemical concentrations to water quality guidelines or risk-based concentrations. a. Clarify why only predicted median concentrations were used to compare to water quality guidelines or risk-based concentrations. b. Clarify why predicted peak concentrations (99th percentile) were not used.
451. Volume 2, Appendix 2-14, Section 3.2.1.3, Table 61, Page 83. In Table 61, Albian Sands indicates that ingestion of surface water was “evaluated for hunter/trapper receptor only.” Identify precisely which water sources were evaluated to support this statement.
452. Volume 3, Section 5.5, Page 5-225. Albian Sands states, “These measures will reduce the concentration of substances of concern and minimize the changes from the Project discharges on surface water quality of receiving waters.” Indicate if plans exist to upgrade regional municipal drinking water treatment plants if for some reason the mitigation measures for the existing and proposed Muskeg River Mine Project are not effective and drinking water quality (municipal water) is adversely affected.
Traditional Land Use and Resource Use
453. Volume 4, Section 7.3.6.2, Page 7-53. Albian Sands states “This Project will result in the removal of three small lakes within the Sharkbite area…The three lakes
111 area is an important fishing and hunting area for the trappers and one of the few good fishing areas left within the RFMAs…Recreating habitat outside the boundaries of an RFMA does not restore that traditional use area for the RFMA holder and family.” Given this information, discuss the initiatives are Albian Sands proposes to ensure that traditional lifestyles will not be lost as a result of Project activities.
454. Volume 4, Section 7.4.1.2, Page 7-75. Albian Sands states, “Impacts to berry picking areas will be mitigated through reclamation. Berry picking habitat is expected to improve following reclamation, resulting in a positive long-term change.” a. What is the confidence associated with this prediction that the habitat will improve? b. Describe the potential impacts on current residents who pick berries in the area, given the fact that this opportunity will be lost for a long time frame.
Socioeconomics
455. Volume 4, Section 7.7.4.3, Page 7-232. Albian Sands states: “The pendulum of active provincial government involvement may have swung too far…it may be appropriate to create within the provincial government a specific focus on the Wood Buffalo region, with a coordinated and funded strategy to support the sustainable socio-economic development in the region.” a. Describe the responsibility that industry has for the impacts within the region. b. What activities are being considered to address the socio-economic stresses within the region?
456. Volume 4, Section 7.7.4.3, Page 7-233. Albian Sands indicates their definition of “outside the normal sphere of operations contributions” to include “providing help to affected local agencies, through a charitable donation policy and such initiatives as “days of caring” and facilitating volunteer commitments in staff.” Provide specific examples of the extent of Albian Sands’s involvement in these noted efforts.
457. Volume 4, Section 7.7.9.3, Page 7-253. Albian Sands states, “A secondary reason lies in the housing allowances that some oil sands developers provide to help some workers to find accommodations in town. These allowances have made a subsection of demand for rental accommodations relatively insensitive to prices and provided more upward pressure on rents.” Indicate whether Albian Sands has identified or proposed any alternative recruitment strategies that will not have such potential negative effects on housing prices in the region.
458. Volume 4, Section 7.7.9.3, Page 7-254. Albian Sands states “There is some discussion around a preliminary plan of Fort McKay to develop a residential subdivision on reserve lands. This community would provide housing choice to oil sands workers and substantially reduced commute times to a number of existing and planned projects.” Predicted noise levels are below Permissible Sound Levels (PSLs), however, noise levels exceed the EUB recommended design guideline limit of 40
112 dBA at 1.5 km from a facility. If it is reasonably foreseeable that there will be residents within the 1.5 km boundary, the impact should be assessed.
ERRATA
459. Volume 1, Cover letter. Albian Sands indicates it is applying to mine Leases 13, 90, and 30. The reference within this section identifies Bituminous Lease 90 as “7280880T90”. Our records show this should be 7288080T90.
460. Volume 1, Section 7.3, Figure 7-15, Page 7-27. Figure 7-15 appears to contain an error. Figures 7-1 and 7-12 show the top of the toe berm extension will be constructed to elevation 335 masl, whereas Figure 7-15 shows this elevation to be 320 masl. Confirm whether Figure 7-15 contains an error.
461. Volume 1, Section 10.2, Figure 10-2, Page 10-11. Provide the significance of the different colours in Figure 10-2.
462. Volume 2, Section 4.3.2.3, Page 4-19. Albian Sands states, “For further details…and for multi-media risk assessments refer to Sections 3.1.1.2 and 3.2.1.2.” These sections were not found in the EIA. Provide the noted sections, or reference where they may be identified.
463. Volume 2, Section 4.5.4.1, Page 4-122. Albian Sands states, “The PDC air quality predictions of regional SO2, NO2 and PAI are presented in Section 3.5.3.” There appears to be no PDC air quality prediction of PAI in section 3.5.3. Provide the PDC predictions of PAI.
464. Volume 2, Appendix 2-1, Table 1, Page 32, 37, 47. There is a reference to Volume 1 – Section 3.4. This section does not appear to be included in the application. If this reference is not in error, please provide the correct section.
465. Volume 2, Appendix 2-5, Section 3.4, Page 9, last sentence. Note that according to the reference provided on page 27, the last sentence on page 9 should state “Details on the existing groundwater monitoring program for the Muskeg River Mine can be found in the 2003 Groundwater Monitoring Program for the Muskeg River Oil Sands Project (Komex 2004).” Information provided indicates “…Expansion Project…”
466. Volume 2, Appendix 2-5, Section 3.4, Page 21. Indicate how the reference provided, Canadian Council of Ministers of the Environment (CCME) (1993 a, b), is related to quality assurance/quality control for a groundwater monitoring program. According to the reference list, this reference is related to measuring volatile organic compounds from fugitive emissions.
467. Volume 2, Appendix 2-5, Section 3.4, Page 15 & 16. Page 15 identifies monitoring well 04-2412A that is not identified on Figure 3. Page 16 identifies basal
113 aquifer monitoring wells ASE00-310 and ASE96-801 that are not identified on Figure 1. Please provide updated Figures.
468. Volume 2, Appendix 2-15, Section 2, Table 5, Page 18. In Table 5 the information labeled as Application predictions but it appears to be predictions for the Planned Development Case. Please confirm.
469. Volume 3, Section 5.5.4.3, Page 5-196. Albian Sands states, “The assessment nodes are described in Section 5.5.2.8 and shown in Figure 5.3-5.” Figure 5.3-5 shows Basal Aquifer Groundwater Elevation and Flow Directions. Figure 5.1-4 shows the location of the assessment nodes. Confirm that Figure 5.1-4 is the figure being referenced on page 5-196.
470. Volume 3, Section 5.5.4.3, Page 5-197, Table 5.5-3. In this table, bolded concentration values exceed the corresponding aquatic life guideline. Both cadmium and sulphide have values in the table that exceed the aquatic life guideline. Explain why the cadmium and sulphide values are not bolded.
471. Volume 3, Section 5.5.5.2, Page 5-230. Albian Sands states, “Figure 5.5-11 compares predicted sulphate concentrations during the Far Future snapshot under pre-development, Base Case and Application Case conditions”. Figure 5.5-11 illustrates cumulative distribution curves for total dissolved solids at Muskeg River Mouth, not sulphate concentrations. There does not appear to be a figure illustrating sulphate concentrations. Provide the correct location of the figure illustrating the cadmium concentrations.
472. Volume 3, Section 5.6.2.4, Page 5-326. The hard copy states, “Predictions for fish and fish habitat diversity are based on the predictions presented for the fish health assessment (Section 5.6.4.3) and fish habitat and fish abundance assessment (Section 5.6.5.1).” The CD copy states, “Predictions for fish and fish habitat diversity are based on the predictions presented for the fish health assessment (Section 5.6.5.2) and fish habitat and fish abundance assessment (Section 5.6.5.2).” Confirm which section references are the correct ones.
473. Aquatics Environmental Setting Report, Section 4.6, Table 4-8, Page 4-7. Table 4-8 shows daily solar radiation rates by month. The maximum annual value of 0.29 is incorrect if the mean annual value is 3.01. The value should be closer to 3.35. Correct the annual maximum daily solar radiation rate.
474. Volume 4, Section 7.4, Table 7.4-6, Page 7-91. This table discusses Integrated Resource Plan guidelines and measures to meet guidelines. Explain the rationale for contacting Economic Development and Tourism when Sustainable Resource Development is the recreation specialist on vacant crown land. Is this statement simply an error?
114 475. Terrestrial ESR, Section 9, References, Page 9-2. “Leskiw, L.A. 2004. Land Capability Classification for the Forest Ecosystems in the Oil Sands.” is referenced. Please confirm Leskiw, L.A. (Alberta Environmental Protection) 1998, Land Capability Classification for Forest Ecosystems in the Oil Sands Region is the actual document that was used.
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APPENDIX A
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