Pierre River Mine Project
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Application for Approval of the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong><br />
Supplemental Information Round 2<br />
Volume 1: <strong>Project</strong> Update and ERCB SIRs<br />
Submitted by:<br />
Shell Canada Limited<br />
Submitted to:<br />
Alberta Energy Resources Conservation Board and<br />
to Alberta Environment<br />
May 2009
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong><br />
Supplemental Information<br />
Round 2<br />
April 2010
PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
ROUND 2<br />
Letter of Transmittal<br />
CONTENTS<br />
TABLE OF CONTENTS<br />
Contents<br />
Table of Contents.............................................................................................................................. i<br />
List of Illustrations..........................................................................................................................iii<br />
Part 1: Overview<br />
1. Introduction<br />
1. Overview..............................................................................................................................1-1<br />
2. Navigable Waters.................................................................................................................1-5<br />
3. Communication with the Applicant...................................................................................1-11<br />
2. Errata<br />
1. <strong>Project</strong> Description Errata....................................................................................................2-1<br />
2. EIA, EIA Update and ESR Errata........................................................................................2-3<br />
3. Supplemental Information Errata.........................................................................................2-9<br />
Part 2: ERCB SIRs<br />
3. General<br />
SIRs 1 – 2............................................................................................................................3-1<br />
4. Mining and Processing<br />
Geotechnical SIRs 3 – 4......................................................................................................4-1<br />
Mining SIRs 5 – 11 .............................................................................................................4-4<br />
Processing SIRs 12 – 28......................................................................................................4-9<br />
Tailings Management SIRs 29 – 38 ..................................................................................4-28<br />
5. Noise<br />
SIR 39 .................................................................................................................................5-1<br />
6. Air<br />
SIRs 40 – 45........................................................................................................................6-1<br />
7. Water<br />
Water Management SIRs 46 – 49 .......................................................................................7-1<br />
Hydrogeology SIRs 50 – 79................................................................................................7-4<br />
8. Terrestrial<br />
Conservation and Reclamation SIR 80 ...............................................................................8-1<br />
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CONTENTS TABLE OF CONTENTS<br />
9. Errata<br />
SIR 81 .................................................................................................................................9-1<br />
Part 3: AENV SIRS<br />
10. General<br />
SIR 1 .................................................................................................................................10-1<br />
Public Engagement and Aboriginal Consultation SIR 2...................................................10-2<br />
Waste Management SIRs 3 – 5 .........................................................................................10-2<br />
11. Air<br />
Dispersion Modelling SIRs 6 – 13 ....................................................................................11-1<br />
Air Quality Assessment SIR 14 ......................................................................................11-13<br />
12. Water<br />
Water Management SIRs 15 – 16 .....................................................................................12-1<br />
Hydrogeology SIRs 17 – 19..............................................................................................12-5<br />
Hydrology SIRs 20 – 40..................................................................................................12-22<br />
Surface Water Quality SIR 41.........................................................................................12-61<br />
Aquatics SIRs 42 – 43.....................................................................................................12-63<br />
13. Terrestrial<br />
SIR 44 ...............................................................................................................................13-1<br />
Conservation and Reclamation SIR 45 .............................................................................13-2<br />
Terrain and Soils SIRs 46 – 47 .........................................................................................13-3<br />
Wildlife SIRs 48 – 59........................................................................................................13-5<br />
Biodiversity and Fragmentation SIRs 60 – 78 ................................................................13-35<br />
14. Health<br />
SIRs 79 – 89......................................................................................................................14-1<br />
15. EPEA Approvals<br />
SIRs 90 – 96......................................................................................................................15-1<br />
16. Errata<br />
SIRs 97 – 98......................................................................................................................16-1<br />
Glossary<br />
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SUPPLEMENTAL INFORMATION<br />
ROUND 2<br />
CONTENTS<br />
LIST OF FIGURES<br />
LIST OF ILLUSTRATIONS<br />
Figure ERCB 25-1 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Material Balance – One Train (Calendar Day)..........................2-13<br />
Figure ERCB 25-2 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Material Balance – One Train (Calendar Day)..........................2-14<br />
Figure ERCB 3-1 Potential Sterilization Area .......................................................................................4-2<br />
Figure ERCB 12-1 Jackpine <strong>Mine</strong> Development...................................................................................4-10<br />
Figure ERCB 12-2 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Development..............................................................................4-11<br />
Figure ERCB 19-1 Average Monthly Bitumen Recovery and Improvement Required.........................4-18<br />
Figure ERCB 25-1 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Material Balance – One Train (Calendar Day)..........................4-24<br />
Figure ERCB 25-2 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Material Balance – One Train (Calendar Day)..........................4-25<br />
Figure ERCB 34-1 Conceptual ETDA Construction Material Requirement .........................................4-35<br />
Figure ERCB 42-1 Base Case Maximum 1-Hour Benzene Predictions.................................................6-17<br />
Figure ERCB 42-2 Application Case Maximum 1-Hour Benzene Predictions......................................6-18<br />
Figure ERCB 42-3 Base Case Likelihood of 1-Hour Benzene Predictions Exceeding 30 µg/m 3 ..........6-19<br />
Figure ERCB 42-4 Application Case Likelihood of 1-Hour Benzene Predictions Exceeding<br />
30 µg/m 3 ..................................................................................................................6-20<br />
Figure ERCB 60-1 <strong>Pierre</strong> <strong>River</strong> Mining Area – Hydrogeologic Cross-Section Locations and<br />
Monitoring Wells in the Local Study Area .............................................................7-16<br />
Figure ERCB 60-2 <strong>Pierre</strong> <strong>River</strong> Mining Area – Hydrogeologic Cross-Section E–E′............................7-17<br />
Figure ERCB 75-1 Geological Cross-Sections A-A′ and B-B′ ..............................................................7-30<br />
Figure ERCB 75-2 Hydrogeological Cross-Sections C-C′, D-D′ and E-E′............................................7-31<br />
Figure ERCB 75-3 Regional and Local Study Areas, Cross-Section Locations, Regional<br />
Topography and Drainage.......................................................................................7-32<br />
Figure ERCB 75-4 Piezometer Locations – McMurray Formation – Basal Aquifer .............................7-33<br />
Figure AENV 3-1 Revised Class II Landfill Site..................................................................................10-3<br />
Figure AENV 10-1 Comparison of Temperature, Wind Speed and Wind Direction Vertical<br />
Profiles ..................................................................................................................11-10<br />
Figure AENV 19-1 Aerobic and Anaerobic PAH Decay Rates............................................................12-19<br />
Figure AENV 24-1 Application Case Oil Sands Developments in the <strong>Pierre</strong> <strong>River</strong> Mining Area<br />
Local Study Area in the Far-Future.......................................................................12-31<br />
Figure AENV 27-1 Reclamation Ecosite Phase/Wetlands Types Planting Prescriptions.....................12-39<br />
Figure AENV 38-1 Wet and Dry Surface Landscape at Closure for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ................12-57<br />
Figure AENV 70-1 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Area Local Study Area Athabasca <strong>River</strong> Corridor ..................13-63<br />
LIST OF TABLES<br />
Table 1-1 Guide to the SIRs ......................................................................................................1-3<br />
Table ERCB 8-1 Lease 9 Resource Summary (2007 Data) ..................................................................2-1<br />
Table 2-1 Environmental Errata ................................................................................................2-3<br />
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CONTENTS LIST OF ILLUSTRATIONS<br />
Table 5.5-12 Winter Habitat Conditions at Waterbody Sampling Sites in the<br />
Eymundson Creek Watershed (Updated) ..................................................................2-6<br />
Table 18-1 Calibrated Hydraulic Conductivity and Recharge Values in Regional Model<br />
(Revised) ...................................................................................................................2-6<br />
Table ERCB 8-2 Lease 9 Resource Summary (2009 Data) ..................................................................2-9<br />
Table ERCB 4-1 Internal Drain Flow Estimate ..................................................................................2-10<br />
Table ERCB 27-1 Comparison of Thermal Energy Requirements.......................................................2-11<br />
Table ERCB 3-1 Potential for UTS/Teck Resource Sterilization .........................................................4-3<br />
Table ERCB 4-1 Internal Drain Flow Estimate ....................................................................................4-4<br />
Table ERCB 4-2 Comparison of <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Estimated Seepage Flux and Measured<br />
Seepage Flux at the Muskeg <strong>River</strong> <strong>Mine</strong> External Tailings Disposal Area ..............4-4<br />
Table ERCB 8-1 Lease 9 Resource Summary (2007 Data) ..................................................................4-6<br />
Table ERCB 8-2 Lease 9 Resource Summary (2009 Data) ..................................................................4-6<br />
Table ERCB 23-1 Bitumen Recovery Comparison ..............................................................................4-21<br />
Table ERCB 26-1 Solvent Loss for Material Balances with Asphaltene Recovery Unit .....................4-23<br />
Table ERCB 26-2 Solvent Loss for Material Balances Without Asphaltene Recovery Unit ...............4-26<br />
Table ERCB 26-3 Solvent Loss for Material Balances with Asphaltene Recovery Unit<br />
(Volumetric) ............................................................................................................4-26<br />
Table ERCB 26-4 Solvent Loss for Material Balances Without Asphaltene Recovery Unit<br />
(Volumetric) ............................................................................................................4-26<br />
Table ERCB 27-1 Comparison of Thermal Energy Requirements.......................................................4-27<br />
Table ERCB 27-2 Comparison of Thermal Energy Requirements.......................................................4-28<br />
Table ERCB 33-1 Fines Capture in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA TT Deposit....................................4-33<br />
Table ERCB 41-1 <strong>Project</strong> Emissions Summary including Additional Auxiliary Boilers.......................6-3<br />
Table ERCB 41-2 Comparison of Regional SO2 Predictions .................................................................6-4<br />
Table ERCB 41-3 Comparison of Regional NO2 Predictions.................................................................6-5<br />
Table ERCB 41-4 Comparison of SO2 Predictions In Regional Communities.......................................6-7<br />
Table ERCB 41-5 Comparison of NO2 Predictions In Regional Communities......................................6-8<br />
Table ERCB 41-6 Comparison of CO Predictions In Regional Communities .......................................6-9<br />
Table ERCB 41-7 Comparison of Benzene Predictions In Regional Communities .............................6-10<br />
Table ERCB 41-8 Comparison of Select VOC Predictions In Regional Communities........................6-11<br />
Table ERCB 41-9 Comparison of PM2.5 Predictions In Regional Communities..................................6-13<br />
Table ERCB 42-1 Regional 1-Hour Benzene Predictions ....................................................................6-15<br />
Table ERCB 52-1 Predicted Tailings Sediment Porosity .......................................................................7-6<br />
Table AENV 5-1 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Waste Categories and Disposal Methods ..................................10-6<br />
Table AENV 8-1 Example Hourly OLM and ARM NO2 Concentrations...........................................11-6<br />
Table AENV 9-1 Steady-State Emissions Factors for Nonroad Diesel Engines.................................11-7<br />
Table AENV 9-2 Transient Adjustment and Deterioration Factors for Nonroad Diesel Engines.......11-8<br />
Table AENV 9-3 Load Factors for Nonroad Diesel Engines ..............................................................11-8<br />
Table AENV 17-1 Comparison of ETDA Seepage Management Alternatives.....................................12-6<br />
Table AENV 18-1 Calibrated Hydraulic Conductivity and Recharge Values in Regional Model<br />
(Revised) ...............................................................................................................12-13<br />
Table AENV 23-1 Summary of Data Sets Used for Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> <strong>Project</strong> ..........................................................................................................12-28<br />
Table AENV 59-1 Potential and Observed Federally Listed Species and Associated Habitat to<br />
be Cleared and Reclaimed in the Local Study Area..............................................13-31<br />
Table AENV 60-1 Predicted Key Indicator Resource Habitat Fragmentation Effects for the Base<br />
Case, Application Case and Planned Development Case in the Regional<br />
Study Area.............................................................................................................13-39<br />
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CONTENTS LIST OF ILLUSTRATIONS<br />
Table AENV 70-1 Wildlife Habitat Change Within the Corridor Between the <strong>Pierre</strong> <strong>River</strong><br />
Mining Areas Local Study Areas: Application Case ............................................13-64<br />
Table AENV 82-1 Factors Affecting Sense of Smell............................................................................14-4<br />
Table AENV 82-2 Odour Characteristics and Thresholds ....................................................................14-7<br />
Table AENV 82-3 Comparison of Predicted Peak Air Concentrations with Odour Thresholds –<br />
Cabin Residents.....................................................................................................14-12<br />
Table AENV 82-4 Comparison of Predicted Peak Air Concentrations with Odour Thresholds –<br />
Aboriginal Residents .............................................................................................14-14<br />
Table AENV 82-5 Comparison of Predicted Peak Air Concentrations with Odour Thresholds –<br />
Community Residents ...........................................................................................14-16<br />
Table AENV 85-1 Comparison of Construction and Operations Phase Greenhouse Gas<br />
Emissions ..............................................................................................................14-23<br />
Table AENV 86-1 Consumption Rates for the Cabin and Aboriginal Residents................................14-25<br />
Table AENV 86-2 Chronic Risk Quotients from Multiple Pathways of Exposure – Cabin<br />
Residents ...............................................................................................................14-26<br />
Table AENV 86-3 Chronic Risk Quotients from Multiple Pathways of Exposure – Aboriginal<br />
Residents ...............................................................................................................14-27<br />
Table AENV 86-4 Chronic Lifetime and Incremental Lifetime Cancer Risks per 100,000 from<br />
Multiple Pathways of Exposure – Cabin Residents ..............................................14-28<br />
Table AENV 86-5 Chronic Lifetime and Incremental Lifetime Cancer Risks per 100,000 from<br />
Multiple Pathways of Exposure – Aboriginal Residents.......................................14-29<br />
Table AENV 86-6 Contribution of Individual Exposure Pathways to Potential Risk Quotients<br />
for Manganese .......................................................................................................14-30<br />
Table AENV 89-1 Chronic Risk Quotients from Multiple Pathways of Exposure .............................14-37<br />
Table AENV 93-1 Changes in Predicted Forestry Capability Class Changes Following<br />
Reclamation in the <strong>Pierre</strong> <strong>River</strong> Mining Area - Revised.........................................15-3<br />
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CONTENTS LIST OF ILLUSTRATIONS<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 1: OVERVIEW<br />
PURPOSE<br />
INTRODUCTION<br />
OVERVIEW<br />
Section 1.1<br />
This document provides responses to Supplemental Information Requests (SIRs)<br />
Round 2 for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. In addition to this document, Shell<br />
has also submitted:<br />
• an EIA Update, dated May 2008, that included updates for the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> and Jackpine <strong>Mine</strong> Expansion projects<br />
• a Supplemental Information document , dated May 2009, containing project<br />
update information and responses to the Alberta Energy Resources<br />
Conservation Board (ERCB) and Alberta Environment (AENV) information<br />
requests<br />
STRUCTURE OF THE SUPPLEMENTAL INFORMATION<br />
Part 1 – Overview<br />
This Supplemental Information has been divided into three parts:<br />
• Part 1: Overview<br />
• Part 2: ERCB SIRs<br />
• Part 3: AENV SIRs<br />
A glossary has also been provided at the end of the document.<br />
The Overview contains the following information:<br />
• corrections to errors and omissions identified in:<br />
• the application<br />
• the EIA, the May 2008 EIA Update, and the environmental setting<br />
reports (ESRs)<br />
• previously filed May 2009 supplementary documents<br />
• a letter from Transport Canada confirming the results of a navigability<br />
assessment for the waterways in and around the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and<br />
Jackpine <strong>Mine</strong> Expansion project areas<br />
• regulatory contact information<br />
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INTRODUCTION OVERVIEW<br />
Parts 2 and 3 – Supplemental Information Responses<br />
Section 1.1<br />
As requested by the ERCB and AENV, the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> SIR responses to<br />
each regulator’s set of information requests are provided separately. Part 2<br />
contains the ERCB information requests and responses. Part 3 contains the<br />
AENV information requests and responses.<br />
Table 1-1 lists the numbers of the SIRs, the categories assigned by the regulators,<br />
and their location in this supplemental filing.<br />
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INTRODUCTION OVERVIEW<br />
Table 1-1: Guide to the SIRs<br />
ERCB SIRs (Part 2) AENV SIRs (Part 3)<br />
Section Name SIR No.<br />
Section<br />
No. Section Name SIR No.<br />
Section 1.1<br />
Section<br />
No.<br />
General 1 – 2 3 General 10<br />
Mining and Processing<br />
• Geotechnical<br />
• Mining<br />
3 – 4<br />
5 – 11<br />
4 • General<br />
• Public Engagement and<br />
Aboriginal Consultation<br />
• Processing 12 – 28 • Waste Management 3 – 5<br />
• Tailings Management 29 – 38 Air 11<br />
Noise 39 5 • Dispersion Modelling 6 – 13<br />
Air 40 – 45 6 • Air Quality Assessment 14<br />
Water 46 – 79 7 Water 12<br />
• Water Management 46 – 49 • Water Management 15 – 16<br />
• Hydrogeology 50 – 79 • Hydrogeology 17 – 19<br />
Terrestrial 80 8 • Hydrology 20 – 40<br />
Errata 81 9 • Surface Water Quality 41<br />
• Aquatics 42 – 43<br />
Terrestrial 13<br />
• General 44<br />
• Conservation and<br />
Reclamation<br />
45<br />
• Terrain and Soils 46 – 47<br />
• Wildlife 48 – 59<br />
• Biodiversity and<br />
Fragmentation<br />
60 – 78<br />
Health 79 – 89 14<br />
EPEA Approvals 90 – 96 15<br />
Errata 97 – 98 16<br />
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1<br />
2
INTRODUCTION OVERVIEW<br />
Section 1.1<br />
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SUPPLEMENTAL INFORMATION<br />
PART 1: OVERVIEW<br />
ASSESSMENT<br />
INTRODUCTION<br />
NAVIGABLE WATERS<br />
Section 1.2<br />
In a letter dated February 23, 2010, Transport Canada informed Shell that an<br />
assessment of the navigability of waterways in and around the proposed <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> and Jackpine <strong>Mine</strong> Expansion projects had been conducted. The<br />
assessment identified two waterways, the Athabasca and Muskeg rivers, that<br />
were navigable and applicable to the Navigable Waters Protection Act (NWPA).<br />
Transport Canada has requested Shell to provide additional information about the<br />
proposed works. Once Shell responds to Transport Canada’s request, Transport<br />
Canada s will notify Shell which of the proposed works in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
and Jackpine <strong>Mine</strong> Expansion project areas will require applications to be<br />
submitted under the NWPA.<br />
Transport Canada’s letter is provided in Attachment 1.<br />
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INTRODUCTION NAVIGABLE WATERS<br />
Section 1.2<br />
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INTRODUCTION NAVIGABLE WATERS<br />
Section 1.2<br />
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INTRODUCTION NAVIGABLE WATERS<br />
Section 1.2<br />
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INTRODUCTION NAVIGABLE WATERS<br />
Section 1.2<br />
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INTRODUCTION NAVIGABLE WATERS<br />
Section 1.2<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 1: OVERVIEW<br />
REGULATORY COMMUNICATION CONTACTS<br />
INTRODUCTION<br />
COMMUNICATION WITH THE APPLICANT<br />
Section 1.3<br />
All communication with Shell on this regulatory application should be directed to<br />
both:<br />
Ms. Margwyn Zacaruk<br />
Mr. Shawn Denstedt<br />
Major Approvals Coordinator Osler, Hoskin & Harcourt LLP<br />
Shell Canada Energy Barristers and Solicitors<br />
Heavy Oil, Development Suite 2500, TransCanada Tower<br />
400 – 4 Avenue S.W. 450 – 1st Street S.W.<br />
PO Box 100, Station M Calgary, Alberta T2P 5H1<br />
Calgary, Alberta T2P 2H5 Tel: (403) 260-7088<br />
Tel: (403) 384-5194 Fax: (403) 260-7024<br />
Fax: (403) 691-4255<br />
e-mail: margwyn.zacaruk@shell.com<br />
e-mail: sdenstedt@osler.com<br />
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Section 1.3<br />
INTRODUCTION COMMUNICATION WITH THE APPLICANT<br />
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SUPPLEMENTAL INFORMATION<br />
PART 1: OVERVIEW<br />
Volume 2, Section 4, Resource Base<br />
ERRATA<br />
PROJECT DESCRIPTION ERRATA<br />
Errata Subsection 4.2, Lease Resource Definition, page 4-13, Table 4-2<br />
The information provided in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Application, Volume 2,<br />
Table 4-2 was incorrect.<br />
Section 2.1<br />
Correction The correct information is shown here in Table ERCB 8-1. The information has<br />
been updated according to the block modelled geology data and pit shell design<br />
that were used to compile the <strong>Project</strong> Description. This information is also<br />
provided in the response to ERCB SIR 8a.<br />
Resource<br />
Category<br />
Total in situ<br />
resource<br />
Ore at >7%<br />
bitumen grade<br />
and minimum 3 m<br />
thickness<br />
Ore at<br />
TV/BIP < 12<br />
Table ERCB 8-1: Lease 9 Resource Summary (2007 Data)<br />
Volume<br />
of Ore<br />
(Mm 3 )<br />
Lease 9 Area Lease 9 Pit Area<br />
Grade<br />
(wt%)<br />
Bitumen<br />
(Mm³)<br />
Bitumen<br />
(Mbbl)<br />
Volume<br />
of Ore<br />
(Mm³)<br />
Grade<br />
(wt%)<br />
Bitumen<br />
(Mm³)<br />
Bitumen<br />
(Mbbl)<br />
2,347 7.58 368 2,312 1.423 9.74 286 1,800<br />
1,346 11.03 307 1,930 1,116 11.22 259 1,627<br />
846 11.24 196 1,235 791 11.28 184 1,158<br />
Volume 2, Section 11, Waste Management<br />
Errata Subsection 11.2, Waste Classification and Management, page 11-6,<br />
Table 11-3<br />
The volumes presented in Table 11-3 of the application were incorrect for the<br />
following waste types:<br />
• flue gas desulphurization solids<br />
• bottom ash<br />
• fly ash<br />
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ERRATA PROJECT DESCRIPTION ERRATA<br />
Section 2.1<br />
When the application was prepared, the waste volumes presented did not<br />
correspond to the boiler size and the technology selected. This was an error in<br />
compiling the data for the application.<br />
Correction The correct waste information was presented in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 1, Table 4-1.<br />
Volume 2, Section 19, Alberta Environment Approval Requirements<br />
Errata Subsection 19.2, Application for Renewal, page 19-3 to 19-34<br />
The header Application for Renewal was incorrect.<br />
Correction The header of this subsection should have read Application for Approval. This<br />
information is also provided in the response to AENV SIR 97a.<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 1: OVERVIEW<br />
EIA Volume<br />
Number<br />
PRM EIA<br />
Update:<br />
Supplemental<br />
Information,<br />
Volume 2<br />
ERRATA<br />
EIA, EIA UPDATE AND ESR ERRATA<br />
Section 2.2<br />
Table 2-1 lists the errata from the EIA, environmental setting reports (ESRs) and<br />
the 2008 EIA Update.<br />
Table 2-1: Environmental Errata<br />
Page<br />
Number Error Correction<br />
21-7 PRM SIR 267a was incorrect in the<br />
following statements:<br />
“gravels as a result of mining is 2.1<br />
km (see EIA, Volume 3, Section<br />
6.5.1.3, page 5)”<br />
“the EIA for Shell’s Jackpine <strong>Mine</strong><br />
Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
project (Shell 2007) indicates that a<br />
drawdown of 0.1 m is expected up to<br />
3 km west of, and up to 5 km north<br />
and south of, the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
pit limits”<br />
21-46 PRM SIR 294a was incorrect in the<br />
following statements:<br />
“For the purpose of this hydrological<br />
assessment, a drawdown of more<br />
than 1 m is considered to have the<br />
potential to negatively affect fen<br />
structure and function in a manner<br />
that could reduce flood attenuation<br />
capacity.”<br />
“Groundwater drawdown of more<br />
than 1 m in fens has the potential to<br />
negatively affect 9% (1,099 ha) of<br />
wetlands within the watershed<br />
areas.”<br />
“A water level drawdown of over 1 m<br />
may results in a shift in the structure<br />
and function of fens on landscapes,<br />
resulting in a reduced capacity to<br />
attenuate flows.”<br />
These statements have been<br />
corrected as follows: “gravels as a<br />
result of mining is 2.1 km (see<br />
Suncor [2007], Volume 3, Section<br />
6.5.1.3, page 5).” “the updated<br />
drawdown for Shell’s Jackpine <strong>Mine</strong><br />
Expansion (refer to Update<br />
Appendix, Section 3) indicates that a<br />
drawdown of 0.1 m is expected up to<br />
7.8 km from the Jackpine <strong>Mine</strong><br />
Expansion project footprint in certain<br />
areas (see Figure 3.1-1 in Section 3<br />
of the Update Appendix).<br />
These statements have been<br />
corrected as follows: “For the<br />
purpose of this hydrological<br />
assessment, a drawdown of more<br />
than 0.1 m is considered to have the<br />
potential to negatively affect wetland<br />
structure and function in a manner<br />
that could reduce flood attenuation<br />
capacity.”<br />
“Groundwater drawdown of more<br />
than 0.1 m in fens has the potential<br />
to negatively affect 37% (7,153 ha)<br />
of wetlands within the LSAs.”<br />
“A water level drawdown of over 0.1<br />
m may results in a shift in the<br />
structure and function of fens on<br />
landscapes, resulting in a reduced<br />
capacity to attenuate flows.”<br />
April 2010 Shell Canada Limited 2-3<br />
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Section 2.2<br />
ERRATA EIA, EIA UPDATE AND ESR ERRATA<br />
EIA Volume<br />
Number<br />
PRM EIA<br />
Update:<br />
Supplemental<br />
Information,<br />
Volume 2<br />
(cont’d)<br />
Table 2-1: Environmental Errata (cont’d)<br />
Page<br />
Number Error Correction<br />
23-117 PRM SIR 454c was incorrect in the<br />
following statements:<br />
“Therefore, the total predicted<br />
drawdown area, as defined by the<br />
0.1 m drawdown isopleths in the<br />
LSAs, is 45,957 ha, 14,869 ha at<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and 31,088 ha at<br />
the Jackpine <strong>Mine</strong> Expansion.”<br />
“The areal extent of fens potentially<br />
affected by drawdown (1,833 ha) for<br />
the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and Jackpine<br />
<strong>Mine</strong> Expansion account for 4% of<br />
this total area.”<br />
“The fens potentially affected are<br />
also 4% of the total drawdown area”<br />
“The 1,833 ha of fens potentially<br />
affected by drawdown is
Section 2.2<br />
ERRATA EIA, EIA UPDATE AND ESR ERRATA<br />
EIA Volume<br />
Number<br />
PRM EIA<br />
Update:<br />
Supplemental<br />
Information,<br />
Volume 2<br />
(cont’d)<br />
Volume 4B,<br />
Appendix 4-1<br />
Volume 4B,<br />
Appendix 4-1<br />
Table 2-1: Environmental Errata (cont’d)<br />
Page<br />
Number Error Correction<br />
23-50 In SIR 426a , Table 426-7 replaces<br />
Table 2.4-5 in the ESR. The area of<br />
disturbed land and the area of water<br />
within the Jackpine <strong>Mine</strong> Expansion<br />
LSA have been reversed.<br />
27 Table 1, presented in Appendix 4-1<br />
incorrectly presented recharge<br />
values for the ground moraine or<br />
glaciolacustrine deposits.<br />
95 Under the heading 'Calibration<br />
Results' the sentence reads “The<br />
PRMA local model was calibrated to<br />
17 static groundwater levels in the<br />
surficial aquifers, one static<br />
groundwater level in the McMurray<br />
Formation oil sands and eight static<br />
groundwater levels in the Basal<br />
Aquifer (Table 10).<br />
Aquatics ESR 5-209 Table 5.5-12 has a missing footnote<br />
“(b)” for the cells that were not<br />
measured<br />
Aquatics ESR 5-210 The sentence in line one “Water<br />
temperature and pH…” is incorrect<br />
This reversal is not an accurate<br />
reflection of the pre-disturbance<br />
conditions in the local study area<br />
(LSA). The baseline disturbed areas<br />
in the LSA on Table 426-7 should<br />
read 1,709 ha and the baseline open<br />
water areas in the LSA should read<br />
102 ha. For more information please<br />
see AENV SIR 47a.<br />
A corrected Table AENV 18-1 shows<br />
shaded rows that have been<br />
revised. Please refer to AENV SIR<br />
18dii for more detailed information.<br />
it should read "The PRMA local<br />
model was calibrated to 18 static<br />
groundwater levels in the surficial<br />
aquifers, one static groundwater<br />
level in the McMurray Formation oil<br />
sands and 16 static groundwater<br />
levels in the Basal Aquifer (Table<br />
10)"<br />
Updated Table 5.5-12 is shown<br />
below.<br />
Replace first sentence as “Water<br />
temperature was suitable for use by<br />
all fish species; however, pH was<br />
above the guideline for the<br />
protection of aquatic life (i.e., > 8.5)<br />
(Table 5.5-11)”.<br />
April 2010 Shell Canada Limited 2-5<br />
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Section 2.2<br />
ERRATA EIA, EIA UPDATE AND ESR ERRATA<br />
Updated Table 5.5-12: Winter Habitat Conditions at Waterbody Sampling Sites in the<br />
Eymundson Creek Watershed<br />
Waterbody<br />
Unnamed<br />
Waterbody 5<br />
Unnamed<br />
Waterbody 6<br />
Sampling<br />
Site (a) Station<br />
14<br />
2<br />
Point or<br />
Profile<br />
Ice<br />
Thickness<br />
[m]<br />
Maximum<br />
Water<br />
Depth<br />
[m]<br />
1 profile 0.45 3.65<br />
(a)<br />
See Figure 5.2-2 for sample site locations.<br />
(b)<br />
Data not obtained due to equipment malfunction.<br />
– = Not measured.<br />
Sample<br />
Depth<br />
[m]<br />
Water Quality Field Parameters<br />
Temperature<br />
[°C]<br />
Dissolved<br />
Oxygen<br />
[mg/L]<br />
Conductivity<br />
[µS/cm] pH<br />
0.75 1.4 2.61 – (b) – (b)<br />
1.20 1.9 2.35 – (b) – (b)<br />
1.80 2.2 1.87 – (b) – (b)<br />
2.30 2.3 1.79 – (b) – (b)<br />
2.80 2.4 1.97 – (b) – (b)<br />
3.30 2.6 1.83 – (b) – (b)<br />
3.65 2.8 1.49 – (b) – (b)<br />
2 point 0.45 4.00 0.75 1.4 2.50 – (b) – (b)<br />
3 point 0.45 1.60 0.75 0.5 1.65 – (b) – (b)<br />
4 point 0.45 1.20 0.75 0.5 1.35 – (b) – (b)<br />
1 point 0.50 0.70 – 0.1 1.66 337 6.95<br />
2 point 0.50 1.25 0.80 0.8 3.19 479 6.86<br />
3 point 0.50 1.20 0.80 0.3 3.97 445 6.74<br />
4 point 0.50 1.20 0.80 1.2 4.03 487 6.37<br />
Table 18-1: Calibrated Hydraulic Conductivity and Recharge Values in Regional Model<br />
(Revised)<br />
Horizontal<br />
Hydraulic Vertical<br />
Conductivity Conductivity Recharge<br />
Material<br />
[m/s]<br />
[m/s] [mm/yr]<br />
Glacial and Glaciolacustrine deposits 1 (east of Athabasca) 5E-7 5E-9 16<br />
Glacial and Glaciolacustrine deposits 1 (west of Athabasca) 5E-7 5E-9 25<br />
Glacial and Glaciolacustrine deposits 2 5E-7 5E-9 25<br />
Ice Contact deposits 1 (west of Jackpine <strong>Mine</strong> Expansion) 8E-6 8E-8 104<br />
Ice Contact deposits 2 (east of Jackpine <strong>Mine</strong> Expansion) 2E-5 2E-7 104<br />
Outwash Sand 5E-5 5E-6 104<br />
Aeolian deposits (west of <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>) 6E-5 6E-7 157<br />
Buried channel aquifers 3E-4 3E-6 157<br />
Clearwater and Grand Rapids formations 1 (Muskeg<br />
Mountain)<br />
1E-11 1E-13 –<br />
Clearwater and Grand Rapids formations 2 (elsewhere) 5E-11 5E-13 –<br />
McMurray Formation Oil Sands 1 (Muskeg Mountain) 1E-11 1E-13 –<br />
McMurray Formation Oil Sands 2 (below Clearwater<br />
elsewhere)<br />
1E-9 1E-10 –<br />
McMurray Formation Oil Sands 3 (areas of no Clearwater) 6E-9 6E-10 –<br />
McMurray Formation Oil Sands 4 (Athabasca <strong>River</strong> valley) 2E-7 2E-8 –<br />
McMurray Formation Basal Sands 1 (
Section 2.2<br />
ERRATA EIA, EIA UPDATE AND ESR ERRATA<br />
Table 18-1: Calibrated Hydraulic Conductivity and Recharge Values in Regional Model<br />
(Revised) (cont’d)<br />
Horizontal<br />
Hydraulic Vertical<br />
Conductivity Conductivity Recharge<br />
Material<br />
[m/s]<br />
[m/s] [mm/yr]<br />
McMurray Formation Basal Sands 2 (>4 m thickness) 8E-5 8E-6 –<br />
Waterways Formation 1E-9 1E-11 –<br />
Prairie Evaporite (salt and anhydrite) 1E-10 1E-11 –<br />
Methy 1 (lower portion and below Waterways/Clearwater) 5E-8 5E-13 –<br />
Methy 2 (upper portion in areas of no Waterways/Clearwater) 5E-7 5E-9 –<br />
Methy 3 (upper portion at Athabasca and Firebag <strong>River</strong><br />
valleys)<br />
5E-5 5E-7 –<br />
Sewataken Fault 5E-8 5E-8 –<br />
– = Not defined.<br />
References<br />
Mills, L.S. and F.W. Allendorf 1996. The One-Migrant-per-Generation Rule in<br />
Conservation and Management. Conservation Biology. 10(6): 1509-<br />
1518.<br />
Wang, J. 2004. Application of the One-Migrant-per-Generation Rule to<br />
Conservation and Management. Conservation Biology. 18(2): 332-343.<br />
April 2010 Shell Canada Limited 2-7<br />
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Section 2.2<br />
ERRATA EIA, EIA UPDATE AND ESR ERRATA<br />
2-8 Shell Canada Limited April 2010<br />
CR029
PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 1: OVERVIEW<br />
Volume 1, Section 2, Geology<br />
ERRATA<br />
Errata Section 2.3, page 2-17, Tables 2-2 and 2-3<br />
SUPPLEMENTAL INFORMATION ERRATA<br />
Section 2.3<br />
The information provided in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 1, Tables 2-2 and 2-3 was incorrect.<br />
Correction The correct information is shown here in Table ERCB 8-2. The information has<br />
been updated according to the updated block modelled geological data and<br />
revised pit shell design that were used to compile the <strong>Project</strong> Update. This<br />
information is also provided in the response to ERCB SIR 8a.<br />
Resource<br />
Category<br />
Total in situ<br />
resource<br />
Oil sand at >7%<br />
bitumen grade<br />
and minimum 3 m<br />
thickness<br />
Oil sand at<br />
TV/BIP < 12<br />
Table ERCB 8-2: Lease 9 Resource Summary (2009 Data)<br />
Volume<br />
of Oil<br />
Sand<br />
(Mm 3 )<br />
Lease 9 Area Lease 9 Pit Area<br />
Grade<br />
(wt %)<br />
Bitumen<br />
(Mm³)<br />
Bitumen<br />
(Mbbl)<br />
Volume<br />
of Oil<br />
Sand<br />
(Mm³)<br />
Grade<br />
(wt%)<br />
Bitumen<br />
(Mm³)<br />
Bitumen<br />
(Mbbl)<br />
2,169 7.15 321 2,017 1,334 9.11 253 1,591<br />
1,242 11.32 290 1,827 1,011 11.43 239 1,502<br />
940 11.63 226 1,421 859 11.60 206 1,294<br />
Volume 1, Section 10, Mining and Processing SIRs<br />
Errata Section 10.1, page 10-49, Table 136-2<br />
The flux and total expected flow data presented in the May 2009 <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong>, Supplemental Information, Volume 1, Table 136-2 were incorrect. The<br />
flux and total expected flow rows of data were transposed.<br />
Correction The correct information is shown here in Table ERCB 4-1. This information is<br />
also provided in the response to ERCB SIR 4a.<br />
April 2010 Shell Canada Limited 2-9<br />
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Section 2.3<br />
ERRATA SUPPLEMENTAL INFORMATION ERRATA<br />
Table ERCB 4-1: Internal Drain Flow Estimate<br />
Approximate Length of<br />
Perimeter Cell Dykes<br />
(m)<br />
Flux<br />
(m 3 /s/m)<br />
Total Expected Flow<br />
(m 3 /d)<br />
Thickened tailings 5,750 4.12E-05 20,500<br />
Mature fine tailings 9,000 9.56E-05 74,500<br />
Volume 1, Section 10, Mining and Processing SIRs<br />
Errata Section 10.1, page 10-49, Table 136-2<br />
Total Flow 95,000<br />
The statement “The top of the ore surface was modified to exclude any ore<br />
stringers of 3 m or greater that were separated from the main orebody by a waste<br />
band more than four times as thick” was incorrect.<br />
Correction The statement should have read “Both the top and bottom of ore surfaces were<br />
used unaltered to calculate ore volumes.” This information is also provided in<br />
the response to ERCB SIR 10a.<br />
Volume 1, Section 10, Mining and Processing<br />
Errata Section 10.1, page 10-127 and 10-128, Figures 197-1 and 197-2<br />
The information provided in Figures 197-1 and 197-2 was incorrect.<br />
Correction The corrected material balance for a typical operating calendar day case has been<br />
reproduced here as Figure ERCB 25-1. The corrected material balance for a<br />
typical operating stream day case has been reproduced here as Figure<br />
ERCB 25-2.<br />
Volume 1, Section 10, Mining and Processing SIRs<br />
Errata Section 10.1, page 10-131, Table 199-1<br />
The thermal requirement and natural gas consumed data presented in Table 199-1<br />
was incorrect.<br />
Correction The data should have been identical to that presented in Table 9-2 of the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> <strong>Project</strong> Update. The correct information is shown here in Table<br />
ERCB 27-1. This information is also provided in the response to ERCB SIR 27a.<br />
2-10 Shell Canada Limited April 2010<br />
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Section 2.3<br />
ERRATA SUPPLEMENTAL INFORMATION ERRATA<br />
Table ERCB 27-1: Comparison of Thermal Energy Requirements<br />
Operating Scenario<br />
Thermal<br />
Requirement<br />
(GJ/m 3 )<br />
Natural Gas<br />
Consumed<br />
(GJ/m 3 )<br />
Feed Grade<br />
(wt% Bitumen)<br />
Process<br />
Temperature<br />
(°C)<br />
Winter average-grade ore 2.44 0.86 10.9 40<br />
Winter coarse high-grade ore 2.34 0.97 11.7 40<br />
Summer low-grade ore 2.10 0.00 10.1 40<br />
Summer average-grade ore 1.65 0.05 10.9 40<br />
Summer high-grade ore 1.55 0.13 11.7 40<br />
Volume 1, Section 10, Mining and Processing SIRs<br />
Errata Section 10.1, page 10-154<br />
The statement “Of the 21% mineral solids, about 60% are finer than 44μm.” was<br />
incorrect.<br />
Correction The correct value used for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is about 50% finer than 44 μm<br />
which would result in a sands-to-fines ratio (SFR) of 1:1. This information is also<br />
provided in the response to ERCB SIR 29a.<br />
Volume 2, Section 23, Terrestrial SIRs<br />
Errata Section 23.1, page 23-143<br />
The Albian Sands <strong>Mine</strong> external tailings containment facility was incorrectly<br />
referenced instead of Shell’s proposed external tailings disposal area (ETDA).<br />
Correction The response to May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 2, SIR 461d should have referenced Shell’s <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA.<br />
The corrected response to the original question follows.<br />
In the early stages of ETDA construction and use, mammals, amphibians and<br />
reptiles are unlikely to interact with the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> external tailings<br />
disposal area (ETDA) shoreline from surrounding undisturbed areas. Terrestrial<br />
wildlife will be further discouraged from accessing the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA<br />
because the dyke surrounding the ETDA will be about 7 m high before any<br />
tailings are released.<br />
As discussed in EIA, Volume 5, Section 7.5.3.2, residual impacts from activities<br />
associated with the interaction of wildlife with project infrastructure, such as<br />
mortality associated with the ETDA, after mitigation measures are applied (see<br />
EIA, Volume 5, Section 7.1.3) are predicted to have a low environmental<br />
consequence rating for yellow rail and black-throated green warbler, and a<br />
negligible rating for all other key indicator resources (KIRs), such as Canadian<br />
April 2010 Shell Canada Limited 2-11<br />
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Section 2.3<br />
ERRATA SUPPLEMENTAL INFORMATION ERRATA<br />
toad, barred owl, moose, black bear, Canada lynx, fisher marten and beaver (see<br />
EIA, Volume 5, Section 7.5.3.2, Table 7.5-36). Interactions with infrastructure<br />
are reasonably well understood but lack quantification. Therefore, prediction<br />
confidence was rated as moderate. From 2003 to 2008, the Muskeg <strong>River</strong> <strong>Mine</strong><br />
recorded 70 avian mortalities because of oiling, averaging 11.6 birds per year.<br />
Total avian mortalities at the Muskeg <strong>River</strong> <strong>Mine</strong> from 2003 to 2008 are 119,<br />
averaging 19.8 birds per year. Regional environmental consequences at the<br />
Planned Development Case for interactions with infrastructure are predicted to be<br />
negligible. Shell is continuing to manage its bird deterrent systems to mitigate the<br />
effects of the ETDA on birds.<br />
2-12 Shell Canada Limited April 2010<br />
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Section 2.3<br />
ERRATA SUPPLEMENTAL INFORMATION ERRATA<br />
Figure ERCB 25-1: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Material Balance – One Train (Calendar Day)<br />
April 2010 Shell Canada Limited 2-13<br />
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Section 2.3<br />
ERRATA SUPPLEMENTAL INFORMATION ERRATA<br />
Figure ERCB 25-2: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Material Balance – One Train (Calendar Day)<br />
2-14 Shell Canada Limited April 2010<br />
CR029
PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 2: ERCB SIRS – ROUND 2<br />
Question No. 1<br />
GENERAL<br />
ERCB SIRS 1 – 2<br />
Request 1 Provide any updates that Shell has to the application, EIA or SEIA.<br />
Section 3.1<br />
Response 1 Any additional information pertaining to the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> application and<br />
supporting documents is contained in the responses to the second round of<br />
supplemental information requests (SIRs).<br />
Question No. 2<br />
Request Volume 1, Section 7.1, Page 7-1, Supplemental Information Responses.<br />
Shell states, “The correct proposed boundary is shown in the revised Figure 1-<br />
2.” In Volume 1, Section 10.1, Page 10-66, Supplemental Information Responses<br />
Shell states, “Overburden must be removed beyond lease boundaries to achieve<br />
design wall angles and to expose ore for recovery at the lease boundary.”<br />
2a Provide a revised project boundary for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> that justifies the<br />
size of the boundary based on the needs for the life of the mine. Include the 250<br />
metre setback from the Athabasca <strong>River</strong> with the project boundary revision.<br />
Response 2a As discussed in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, Section 10.1, page 10-66, SIR 147, When an economic bitumen<br />
resource crosses a lease boundary, Shell designs the pit so that the wall<br />
intersects the top of the ore at the boundary, to maximize resource recovery from<br />
the lease. This necessitates removing some overburden from adjacent leases in<br />
order to achieve design wall angles and expose ore for recovery. This practice is<br />
typically facilitated through lease boundary agreements between adjacent lease<br />
holders. Shell is currently in discussion with its adjacent lease holders to ensure<br />
that resource recovery is maximized for both parties, and fully expects lease<br />
boundary agreements to be in place before operations start. If any of the adjacent<br />
lease holdings revert back to the Crown, then Shell would make the appropriate<br />
regulatory applications.<br />
April 2010 Shell Canada Limited 3-1<br />
CR029
GENERAL ERCB SIRS 1 – 2<br />
Request 2b When will Shell apply for a revised lease boundary?<br />
Response 2b Application for a revised project boundary is not required.<br />
Section 3.1<br />
3-2 Shell Canada Limited April 2010<br />
CR029
PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 2: ERCB SIRS – ROUND 2<br />
Question No. 3<br />
MINING AND PROCESSING<br />
ERCB SIRS 3 – 38<br />
Section 4.1<br />
Request Provide a preliminary assessment of the setback distance for the North<br />
Overburden Disposal Area from the Lease boundary with UTS Energy (Lease<br />
14). Use the available geological information and consider the open pit on the<br />
UTS side.<br />
Response 3 The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Plan was developed to maximize ore recovery on Oil<br />
Sands Lease (OSL) 740012009 (Lease 9). Consequently, most (60%) of the north<br />
overburden disposal area is built in-pit after the ore has been mined out.<br />
Additionally, in designing the north overburden disposal area, the available<br />
storage space within the external outline of the dump was balanced with the<br />
mining volume required to advance the mining sufficiently to enable the north<br />
overburden disposal area to be extended in-pit.<br />
Current mine plans show that the north overburden disposal area is offset 100 m<br />
from the UTS/Teck OSL 014 (Lease 14) boundary, with a portion of the north<br />
overburden disposal area initially being built on oil sands that are less than 12<br />
TV:BIP. Based on Shell’s interpretation of the geology, a narrow ore band under<br />
the dump in Lease 9 continues into UTS/Teck Lease 14 (see Figure ERCB 3-1).<br />
As UTS/Teck has not publicly disclosed mine plans for Lease 14, Shell<br />
considered two alternatives to provide a preliminary assessment of the setback<br />
distance from the north overburden disposal area to the UTS/Teck Lease 14<br />
boundary:<br />
1. Maintain the current design of the north overburden disposal area, i.e.,<br />
100 m from UTS/Teck Lease 14 in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Plan<br />
2. Move the toe of the north overburden disposal area south to accommodate<br />
an open-pit mine on the UTS/Teck side of the lease<br />
The first alternative might result in sterilizing the UTS/Teck resource. This is<br />
calculated based on a narrow strip (less than 750 m) of mineable oil sands located<br />
north of the north overburden disposal area (see Figure ERCB 3-1). Here, an<br />
estimated location of the ultimate mine crest from the UTS/Teck lease line has<br />
been calculated and constrained within the resource delineated by the TV:BIP 12<br />
limit. Shell also assumed a typical geotechnical design setback from the external<br />
dump toe to a pit crest would be 150 m.<br />
April 2010 Shell Canada Limited 4-1<br />
CR029
MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Figure ERCB 3-1: Potential Sterilization Area<br />
Section 4.1<br />
4-2 Shell Canada Limited April 2010<br />
CR029
MINING AND PROCESSING ERCB SIRS 3 – 38<br />
TV:BIP<br />
Cut-off<br />
Section 4.1<br />
Therefore, the potential UTS/Teck resource sterilization for TV:BIP 12 has been<br />
calculated between the estimated pit crest required to recover ore to the lease<br />
boundary and the design setback from the north overburden disposal area, and is<br />
summarized in Table ERCB 3-1.<br />
Table ERCB 3-1: Potential for UTS/Teck Resource Sterilization<br />
Ore<br />
(Mt)<br />
Overburden<br />
and<br />
Interburden<br />
(Mbcm)<br />
Diluted Ore<br />
Grade<br />
(wt%)<br />
Bitumen in<br />
Place<br />
(Mm³)<br />
TV/BIP<br />
(bcm/m³)<br />
12 3.97 3.32 12.18 0.49 10.6 1.74<br />
Question No. 4<br />
Strip Ratio<br />
(m³/m³)<br />
The second alternative is the potential for increased offset of the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> north overburden disposal area to accommodate an open pit on the<br />
UTS/Teck side of the lease. This scenario would require an additional 50 m<br />
offset of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> north overburden disposal area from the lease<br />
boundary over a length of about 1,125 m. The additional offset would decrease<br />
the north overburden capacity by 8.44 Mbcm or about 8% of the total design<br />
capacity. However, during the first three years of operation, i.e., before in-pit<br />
space becomes available, the lost dump area would need to be added onto the<br />
south side of the dump by adjusting the opening sequence in the mine. Therefore,<br />
about the same sterilization (0.49 Mm 3 ) incurred on UTS/Teck Lease 14 in this<br />
scenario would be incurred on Shell’s Lease 9.<br />
Shell and UTS/Teck have had preliminary discussions on developing an<br />
agreement on the boundary issues. These discussions are ongoing and Shell fully<br />
expects them to be successfully completed before development begins on either<br />
side of UTS/Teck Lease 14 or Shell’s Lease 9.<br />
Request Volume 1, Section 10.1, Page 10-49, Supplemental Information Responses.<br />
Table 136-2 presents the internal drain flow estimates.<br />
4a Review the information in the “Total Expected Flow” column in Table 136-2<br />
and resubmit the results.<br />
Response 4a The flux and total expected flow data presented in the May 2009 <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong>, Supplemental Information, Volume 1, Table 136-2, was incorrect. The<br />
flux and total expected flow rows of data were transposed. The correct<br />
information is presented in Table ERCB 4-1 and also provided in Section 2.3,<br />
Supplemental Information Errata.<br />
April 2010 Shell Canada Limited 4-3<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Table ERCB 4-1: Internal Drain Flow Estimate<br />
Approximate Length of<br />
Perimeter Cell Dykes<br />
(m)<br />
Flux<br />
(m 3 /s/m)<br />
Section 4.1<br />
Total Expected Flow<br />
(m 3 /d)<br />
Thickened tailings 5,750 4.12E-05 20,500<br />
Mature fine tailings 9,000 9.56E-05 74,500<br />
Total Flow 95,000<br />
Request 4b Discuss the estimated seepage volume in cubic metre/day/metre (m 3 /day/m) by<br />
comparison to the seepage volume (m 3 /day/m) at the External Tailings Facility<br />
(ETF) in the Muskeg <strong>River</strong> <strong>Mine</strong>.<br />
Response 4b A comparison of the estimated seepage flux in cubic metre/day/metre (m 3 /d/m) at<br />
the external tailings disposal area (ETDA) in the Muskeg <strong>River</strong> <strong>Mine</strong> and the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is presented in Table ERCB 4-2.<br />
The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> theoretical flows are higher than those measured at the<br />
Muskeg <strong>River</strong> <strong>Mine</strong>. This is expected, as the EIA predictions are based on<br />
conservative assumptions that frequently over-predict actual values. Differences<br />
in flux below the ETDAs at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and Muskeg <strong>River</strong> <strong>Mine</strong> result<br />
from the following factors:<br />
• the design basis of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> flows assumed the pond to be at full<br />
height, or about 45 m above original ground, whereas the Muskeg <strong>River</strong><br />
<strong>Mine</strong> pond is at a lower average elevation of 25 m above original ground,<br />
over the 2006 to 2009 time frame that seepage flows were collected<br />
• the theoretical flux from the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is based on steady-state<br />
assumptions, whereas the Muskeg <strong>River</strong> <strong>Mine</strong> has likely not reached this<br />
state<br />
Table ERCB 4-2: Comparison of <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Estimated Seepage Flux and Measured<br />
Seepage Flux at the Muskeg <strong>River</strong> <strong>Mine</strong> External Tailings Disposal Area<br />
Question No. 5<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
Theoretical Flux<br />
(m 3 /d/m)<br />
Muskeg <strong>River</strong> <strong>Mine</strong><br />
Measured Flux<br />
(m 3 /d/m)<br />
Thickened tailings 3.6 0.5<br />
Mature fine tailings 8.3 1.2<br />
Request Provide the 3-D DXF electronic files for the top of the McMurray and the top of<br />
the Devonian surfaces for the proposed project area.<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Section 4.1<br />
Response 5 Shell will provide dxf files on CD to the ERCB under separate cover for review.<br />
Surface elevation contours will show the top of the McMurray and Devonian<br />
formations. Each formation will have two files – contours with annotations and<br />
closed contours only.<br />
Question No. 6<br />
Request Provide the entire drilling database (i.e. collar and assay files), in text format,<br />
used to build the resource model in the <strong>Project</strong> Update.<br />
Response 6 The requested information has been provided to the ERCB through the well<br />
licensing process. On February 24, 2010, the ERCB confirmed that the<br />
information is in its data set.<br />
Question No. 7<br />
Request Provide a hard copy of the updated TV/BIP contour map of an appropriate scale<br />
covering the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> project area. Include the Final Pit Limits (toe<br />
and crest), the UWI (or hole ID) and TV/BIP value posted beside each model<br />
drill hole in NAD 1983.<br />
Response 7 Two paper copies of the updated TV/BIP contour map, along with the<br />
corresponding electronic files of these maps, are being provided to the ERCB<br />
under separate cover.<br />
Question No. 8<br />
Request Volume 1, Section 2.2, Pages 2-11, 2-17 to 2-18, Tables 2-1, 2-2 & 2-3,<br />
Supplemental Information Responses; Volume 2, Section 4.2, Page 4-13, Table<br />
4-2.<br />
When comparing Tables 2-2 and 2-3 from the Update to Table 4-2 from the<br />
original application, there has been a significant increase in resource in the<br />
Lease 9 Area and a significant decrease in resource in the Lease 9 Pit Area.<br />
Table 2-1 indicates that no additional drilling was done in the Lease 9 area in<br />
2007-2008 drilling season.<br />
8a Provide the factors that contributed to the change in resource estimation for the<br />
Lease 9 Area and Lease 9 Pit Area.<br />
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Section 4.1<br />
Response 8a In the original application, Volume 2, <strong>Project</strong> Description, Table 4-2, as well as<br />
in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Tables<br />
2-2 and 2-3, incorrect information was provided. This revised data is presented in<br />
Tables ERCB 8-1 and ERCB 8-2 and is also provided in Section 2, Errata.<br />
Resource<br />
Category<br />
Total in situ<br />
resource<br />
Ore at >7%<br />
bitumen grade<br />
and minimum 3 m<br />
thickness<br />
Ore at<br />
TV/BIP < 12<br />
Resource<br />
Category<br />
Total in situ<br />
resource<br />
Oil sand at >7%<br />
bitumen grade<br />
and minimum 3 m<br />
thickness<br />
Oil sand at<br />
TV/BIP < 12<br />
Table 4-2 has been updated according to the block modelled geology data and pit<br />
shell design that were used in the <strong>Project</strong> Description, and is shown here as Table<br />
ERCB 8-1.<br />
Table ERCB 8-1: Lease 9 Resource Summary (2007 Data)<br />
Volume<br />
of Ore<br />
(Mm 3 )<br />
Lease 9 Area Lease 9 Pit Area<br />
Grade<br />
(wt%)<br />
Bitumen<br />
(Mm³)<br />
Bitumen<br />
(Mbbl)<br />
Volume<br />
of Ore<br />
(Mm³)<br />
Grade<br />
(wt%)<br />
Bitumen<br />
(Mm³)<br />
Bitumen<br />
(Mbbl)<br />
2,347 7.58 368 2,312 1.423 9.74 286 1,800<br />
1,346 11.03 307 1,930 1,116 11.22 259 1,627<br />
846 11.24 196 1,235 791 11.28 184 1,158<br />
Tables 2-2 and 2-3 have been updated according to the updated block modelled<br />
geology data and revised pit shell design that were used in the May 2009 <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, and are shown here as Table<br />
ERCB 8-2.<br />
Table ERCB 8-2: Lease 9 Resource Summary (2009 Data)<br />
Volume<br />
of Oil<br />
sand<br />
(Mm 3 )<br />
Lease 9 Area Lease 9 Pit Area<br />
Grade<br />
(wt%)<br />
Bitumen<br />
(Mm³)<br />
Bitumen<br />
(Mbbl)<br />
Volume<br />
of Oil<br />
sand<br />
(Mm³)<br />
Grade<br />
(wt%)<br />
Bitumen<br />
(Mm³)<br />
Bitumen<br />
(Mbbl)<br />
2,169 7.15 321 2,017 1,334 9.11 253 1,591<br />
1,242 11.32 290 1,827 1,011 11.43 239 1,502<br />
940 11.63 226 1,421 859 11.60 206 1,294<br />
Request 8b Based on the new resource information found in Tables 2-2 and 2-3, update the<br />
following original application tables:<br />
• Table 5-4 in Section 5.4<br />
• Table 5-8 in Section 5.5<br />
• Table 5-9 in Section 5.6<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Section 4.1<br />
Response 8b As noted in the response to ERCB SIR 8a, Tables 2.2 and 2.3 have been revised<br />
and the revised information represents overall block model quantities and is not<br />
representative of mineable quantities. The update of mineable quantities is<br />
presented in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, Section 3.1, Table 3-1.<br />
Question No. 9<br />
The mine production schedule was not updated because of the minor changes to<br />
mineable quantities, i.e., less than 5% over the project life, detailed in the May<br />
2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section 3.1,<br />
Table 3-1. As a result, the production details have not been updated for<br />
Volume 2, <strong>Project</strong> Description, Section 5.4, Table 5-4.<br />
The mine production schedule and waste material balance was not updated for<br />
the <strong>Project</strong> Update because of the minor changes in mine quantities described in<br />
the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1,<br />
Section 3. Therefore, there is no new data available to update Volume 2, <strong>Project</strong><br />
Description, Section 5.5, Table 5-8 and Section 5.6, Table 5-9.<br />
Request Volume 1, Section 3.1, Page 3-1, Table 3-1, Supplemental Information<br />
Responses; Volume 1, Section 2.2, Page 2-18, Table 2-3, Supplemental<br />
Information Responses.<br />
Table 3-1 compares the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong> pit attributes and area<br />
between the <strong>Project</strong> Update and the original application.<br />
9a How is the “Final Bitumen Product” in Table 3-1 calculated from Bitumen in<br />
Place?<br />
Response 9a Final bitumen product is calculated by applying the design plant recovery to the<br />
mined ore quantity. For a description of the calculation for recoverable bitumen,<br />
see the response to SIR 150a in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 1, Section 10.1.<br />
Request 9b What is the difference between “Bitumen in Place” in Table 3-1 and the “Total<br />
In Situ Resource” bitumen volume in Table 2-3?<br />
Response 9b The bitumen in place in Table 3-1 refers to the raw bitumen within the design<br />
mine pit that meets the minimum mineable criteria, as outlined in ERCB Interim<br />
Directive 2001-07. The total in situ resource in Table 2-3 refers to all bitumen<br />
that is located within the areal extent of the mine pit, i.e., no minimum mineable<br />
criteria.<br />
April 2010 Shell Canada Limited 4-7<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Question No. 10<br />
Section 4.1<br />
Request Volume 1, Section 10.1, Page 10-66, Supplemental Information Responses;<br />
Volume 1, Section 3.1, Page 3-1, Table 3-1, Supplemental Information<br />
Responses.<br />
Shell states, “The top of the ore surface was modified to exclude any ore<br />
stringers of 3 m or greater that were separated from the main orebody by a waste<br />
band more than four times as thick.”<br />
10a Is the resource in the 3 m or greater ore stringers included in the ore volume<br />
tabulated in Table 3-1?<br />
Response 10a The statement “The top of the ore surface was modified to exclude any ore<br />
stringers of 3 m or greater that were separated from the main ore body by a<br />
waste band more than four times as thick” was incorrect. The statement should<br />
have read “Both the top and bottom of ore surfaces were used unaltered to<br />
calculate ore volumes.” The resources tabulated in Table 3-1 include all<br />
resources within the lease area located below the topographic surface. For<br />
additional information, see Section 2.3, Supplemental Information Errata.<br />
Request 10b What is the quantity and grade of resource in the 3 m or greater ore stringers?<br />
Response 10b This question is no longer applicable. See the response to ERCB SIR 10a.<br />
Request 10c What contingency will Shell use to offset the loss of the resource associated with<br />
not recovering the 3 m or greater ore stringers?<br />
Response 10c This question is no longer applicable. See the response to ERCB SIR 10a.<br />
Question No. 11<br />
Request Volume 1, Section 10.1, Page 10-68, Table 148-1, Supplemental Information<br />
Responses; Volume 1, Section 3.1, Page 3-1, Table 3-1, Supplemental<br />
Information Responses; Volume 1, Section 2.2, Page 2-18, Table 2-3,<br />
Supplemental Information Responses.<br />
11a Discuss the differences between “In Situ Bitumen” for TV/BIP Cut-off equal to<br />
12 in Table 148-1, “Bitumen” volume for “Ore at TV/BIP ≤ 12” in Table 2-3<br />
and “Revised” bitumen volume for “Bitumen in Place” in Table 3-1.<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Section 4.1<br />
Response 11a The quantities in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, Table 3-1 and Table 148-1 are not generated using the same<br />
assumptions or mine pit design. Table 148-1 summarizes the ore quantities from<br />
within mine pits limited by the respective TV/BIP cut-offs, as requested in SIR<br />
148b. Table 3-1 summarizes ore quantities for the <strong>Project</strong> Update mine pit, which<br />
includes all TV/BIP≤12 resource as well as marginal resource areas, as described<br />
in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1,<br />
Section 3.1.<br />
The quantities in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, Table 2-3 were incorrect, and have been updated in the response to<br />
ERCB SIR 8, and are also provided in Section 2.3, Supplemental Information<br />
Errata. In ERCB Table 8-2, the bitumen volume for oil sand ore at >7% bitumen<br />
grade and minimum 3 m thickness in the Lease 9 Pit Area is identical to the<br />
revised bitumen in place in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 1, Table 3-1.<br />
Request 11b Discuss the differences between “Recovered Bitumen” volume for TV/BIP Cutoff<br />
equal to 12 in Table 148-1 and “Revised” bitumen volume for “Final bitumen<br />
product” in Table 3-1.<br />
Response 11b The quantities in Table 3-1 and Table 148-1 are not generated from the same<br />
mine pit design. For a description of the difference between the stated resources,<br />
see the response to ERCB SIR 11a.<br />
Question No. 12<br />
Request Volume 1, Section 1.2, Page 1-8, Supplemental Information Responses;<br />
Volume 1, Section 10.1, Page 10-86, Supplemental Information Responses.<br />
Shell states, “This execution plan relies on a series of successive smaller<br />
investments, consisting of selective equipment additions and modifications in the<br />
following areas:<br />
• Jackpine mining equipment additions<br />
• Jackpine extraction facilities<br />
• Muskeg <strong>River</strong> <strong>Mine</strong> froth treatment and utilities”<br />
12a Provide a summary of the selective equipment additions and modifications for<br />
each area and an updated schedule showing proposed investment stages.<br />
Response 12a The statement cited was intended to point out that although Shell is adjusting to<br />
the current economic environment by making a series of smaller investments, the<br />
overall scope of the application did not change. Therefore, no new equipment or<br />
modifications from that described in the Jackpine <strong>Mine</strong> Expansion Application<br />
April 2010 Shell Canada Limited 4-9<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Jackpine <strong>Mine</strong><br />
Production Production Thousand bbl/cd<br />
350<br />
300<br />
250<br />
200<br />
150<br />
100<br />
50<br />
0<br />
2009<br />
Section 4.1<br />
and <strong>Project</strong> Update are contemplated. The timing of these equipment additions<br />
was originally described in the December 2009 Jackpine <strong>Mine</strong> Expansion,<br />
Supplemental Information, Volume 1, SIR 134 and is reproduced here.<br />
The overall development strategy and plan for Shell’s Jackpine <strong>Mine</strong> and <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> was outlined in the December 2009 Jackpine <strong>Mine</strong> Expansion,<br />
Supplemental Information, Volume 1, Section 1.2, Overview. The following<br />
represents Shell’s current estimated schedule, based on regulatory approval being<br />
granted before 2011.<br />
First oil production from the Jackpine <strong>Mine</strong> – Phase 1 is expected in 2010 and<br />
will increase over time up to 15,900 m 3 /cd (100,000 bbl/cd). Additional bitumen<br />
production capacity from staged development could start as early as 2014,<br />
increasing as additional mining and extraction equipment is added. First oil<br />
production from the third extraction train is not expected until 2017, with full<br />
production expected by 2020 (see Figure ERCB 12-1).<br />
2010<br />
2011<br />
Muskeg <strong>River</strong> <strong>Mine</strong><br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
Jackpine <strong>Mine</strong> – Phase 1<br />
Train 1<br />
Train 2<br />
Design and<br />
Construction<br />
2012<br />
2013<br />
2014<br />
Train 2<br />
Train 3<br />
Design and<br />
Construction<br />
4-10 Shell Canada Limited April 2010<br />
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2015<br />
Year<br />
2016<br />
2017<br />
Jackpine <strong>Mine</strong> Expansion<br />
Train 3<br />
Figure ERCB 12-1: Jackpine <strong>Mine</strong> Development<br />
An investment decision has yet to be taken to expand the mining and extraction<br />
facilities of the Muskeg <strong>River</strong> <strong>Mine</strong> beyond the current capacity of 23,850 m 3 /cd<br />
(150,000 bbl/cd). Further expansion of the Muskeg <strong>River</strong> <strong>Mine</strong> will be dependent<br />
on the investment factors outlined in the Jackpine <strong>Mine</strong> Expansion <strong>Project</strong><br />
Update, Section 1.2, <strong>Project</strong> Development Update, and the future operating<br />
performance of the Jackpine <strong>Mine</strong> and Muskeg <strong>River</strong> <strong>Mine</strong>.<br />
The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is expected to produce first oil in 2018, with full<br />
production from the first train achieved around 2021 (see Figure ERCB 12-2).<br />
The timing of design and construction activities has yet to be determined.<br />
2018<br />
2019<br />
2020<br />
2021
MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Production Thousand bbl/cd<br />
250<br />
200<br />
150<br />
100<br />
50<br />
0<br />
2009<br />
2010<br />
2011<br />
2012<br />
<strong>Pierre</strong> <strong>River</strong><br />
Design and Access Construction<br />
2013<br />
2014<br />
2015<br />
Section 4.1<br />
April 2010 Shell Canada Limited 4-11<br />
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2016<br />
Year<br />
2017<br />
2018<br />
2019<br />
Train 1<br />
Figure ERCB 12-2: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Development<br />
2020<br />
2021<br />
Train 2<br />
Request 12b Clarify if Shell is applying for approval of these additions and modifications as<br />
part of this application.<br />
Response 12b Yes.<br />
Question No. 13<br />
Request Volume 1, Section 4.2, Page 4-5, Table 4-1, Supplemental Information<br />
Responses.<br />
Waste Type<br />
Shell states, “The AER cogeneration unit waste volumes have been updated to<br />
reflect the latest information available.” Below is a comparison of the updated<br />
waste tonnages from Table 4-1 and those identified in the initial application in<br />
Volume 2, Section 11.2, Page 11-6, Table 11-3. Both are based on annual waste<br />
generated at 31,800 m3/cd (200,000 bbl/d) production.<br />
Initial application (Dec 2007)<br />
Unit (Tonnes)<br />
Flue gas desulphurization solids 350,000 495,000<br />
Bottom ash 50,000 70,000<br />
Fly ash 185,000 265,000<br />
2022<br />
2023<br />
Updated application (May 2009) Unit<br />
(Tonnes)<br />
13a Provide an explanation for the increase in waste tonnage from the original<br />
application to the updated application.<br />
Response 13a Several scenarios were run with different combustion processes and fuel<br />
characteristics for the original application. When the application was prepared,
MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Section 4.1<br />
the waste volumes presented did not correspond to the boiler size and the<br />
technology selected. This was an error in compiling the data for the application.<br />
Request 13b Explain any impacts to the EIA based on the higher waste tonnage.<br />
Response 13b The higher waste tonnage does not affect the EIA. The asphaltene energy<br />
recovery (AER) cogeneration waste will be stored in one of two Class II landfills<br />
at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> (see the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 1, Section 4.2, Waste Management), which were sized to<br />
accept the updated waste volumes. The Class II landfills are located within the<br />
boundaries of the proposed <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> development area, which was<br />
assessed in the EIA. The landfill will be located with the project’s closed-circuit<br />
system for process-affected waters and will be constructed and operated based on<br />
best management practices to minimize air and aquatic emissions. Therefore, the<br />
impacts from the landfill are expected to be negligible and do not affect the<br />
findings of the EIA.<br />
Request 13c Update the EIA to reflect the larger waste volumes and emissions.<br />
Response 13c See the response to ERCB SIR 13b.<br />
Request 13d Provide a summary of the environmental measures and controls that will be<br />
included in the design to minimize emissions.<br />
Response 13d The asphaltene-fired cogeneration plant will include the following environmental<br />
control units:<br />
Question No. 14<br />
• selective catalytic reduction<br />
• limestone handling and preparation<br />
• a mercury control system<br />
• a baghouse<br />
• wet flue gas desulphurization (FGD) and wet electrostatic precipitator (ESP)<br />
• solid waste handling systems<br />
For a summary of each of these units, see the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong><br />
Description, Volume 2, Section 8.2, Electrical Power.<br />
Request Volume 1, Section 10.1, Page 10-82, Supplemental Information Responses.<br />
Shell states, “Shell does not plan to have a permanent ore stockpile within the<br />
project area. However, during the commissioning of the mine, an ore stockpile<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Section 4.1<br />
will be required for the ore removed before the plant start-up. Stockpiled ore<br />
will be blended into the extraction plant during early production.”<br />
14a For the temporary ore stockpile, provide a table that includes on an annual<br />
basis:<br />
i tonnes of ore moved to the temporary stockpile,<br />
ii. expected grade of the stockpiled ore, and<br />
iii. tonnes of ore processed from the temporary stockpile.<br />
Response 14a Details of the commissioning plan have not yet been finalized. The requirements<br />
for a temporary ore stockpile will be detailed when the opening mine cut is<br />
designed during commissioning planning and will be provided as part of the<br />
ERCB annual mine plans.<br />
Question No. 15<br />
Request Volume 1, Section 10.1, Page 10-83, Table 159-1, Supplemental Information<br />
Responses.<br />
Shell notes in Table 159-1 that the Solvent Loss based on TSRU only for 2003<br />
was 10.6 Vol solvent /kvol Bitumen. Information provided in the Muskeg <strong>River</strong><br />
<strong>Mine</strong> Expansion supplementary information responses submitted in April, 2006<br />
indicated that the annual average solvent losses for 2003 were greater than 17<br />
volumes of solvent per 1000 volumes of bitumen produced.<br />
15a Clarify and provide the correct volumes of solvent losses per thousand volumes<br />
of bitumen production for 2003.<br />
Response 15a The solvent losses shown in Table 159-1 are correct. The differences referred to<br />
are the result of changes in the calculation method requested by the ERCB during<br />
the Muskeg <strong>River</strong> <strong>Mine</strong> Expansion approval. In 2003, the ERCB’s definition of<br />
solvent loss was based on the tailings solvent recovery unit (TSRU) losses only.<br />
In 2006, the Muskeg <strong>River</strong> <strong>Mine</strong> approval was amended to define solvent losses<br />
to include vapour recovery unit losses. In 2003, there were substantial vapour<br />
losses, primarily to flare, which resulted in greater than 17 vol/kvol solvent loss.<br />
Request 15b Based on the solvent losses summary in Table 159-1, it is acknowledged that<br />
Muskeg <strong>River</strong> <strong>Mine</strong> has experienced difficulties achieving ERCB solvent losses<br />
per bitumen production requirements since start-up. Shell is requesting approval<br />
to construct and operate a similar tailings solvent recovery unit (TSRU) for the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Justify the approval of similar design concepts in the<br />
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Section 4.1<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Application in light of Muskeg <strong>River</strong> <strong>Mine</strong>’s challenges in<br />
meeting existing approval conditions with a similar design.<br />
Response 15b As outlined in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, SIR 159, several improvements have been made to the Muskeg <strong>River</strong><br />
<strong>Mine</strong> process in recent years to significantly improve solvent losses and achieve<br />
regulatory compliance. These improvements will be applied to future designs,<br />
including the Muskeg <strong>River</strong> <strong>Mine</strong> Expansion TRSU process starting up in 2010.<br />
Shell is confident that, as design and operational experience grows, the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> solvent losses will meet the current 4 vol/kvol requirement.<br />
Question No. 16<br />
Request Volume 1, Section 10.1, Page 10-85, Supplemental Information Responses.<br />
Shell describes their development and investment philosophy. In Volume 1,<br />
Section 1.2, Page 1-7, Supplemental Information Responses. Shell states,<br />
“Although the overall scope of Shell’s development plans for the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> and the Jackpine <strong>Mine</strong> Expansion remain unchanged, the timing of the<br />
execution of certain approved Jackpine <strong>Mine</strong> and Muskeg <strong>River</strong> <strong>Mine</strong> facilities<br />
has required some adjustment.”<br />
16a Provide an updated integrated schedule for Jackpine <strong>Mine</strong> (JPM) Phase-1,<br />
Muskeg <strong>River</strong> <strong>Mine</strong> (MRM) debottlenecking, Muskeg <strong>River</strong> <strong>Mine</strong> Expansion<br />
(MRME), Jackpine <strong>Mine</strong> Expansion (JPME), and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> (PRM)<br />
projects that includes production capacity, timelines for construction,<br />
commissioning, and start-up.<br />
Response 16a For the requested information, see the response to ERCB SIR 12.<br />
Request 16b If an integrated schedule is not available, when will Shell commit to providing an<br />
integrated schedule for JPM Phase-1, MRM debottlenecking, MRME, JPME, and<br />
PRM projects that includes production capacity, timelines for construction,<br />
commissioning, and start-up?<br />
Response 16b Shell will provide updates to its plans for the Muskeg <strong>River</strong> <strong>Mine</strong> and Jackpine<br />
<strong>Mine</strong> as part of the annual reporting to the Board, or when changes to the design<br />
or operations scope necessitate the filing for amendments to the existing<br />
approvals.<br />
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Question No. 17<br />
Section 4.1<br />
Request Volume 1, Section 10.1, Page 10-89, Supplemental Information Responses.<br />
Shell states, “Shell is applying for both natural gas and asphaltene fuel<br />
cogeneration to supply steam and power for the mine.” In Volume 1, Section<br />
10.1, Page 10-106, Supplemental Information Responses, Shell states, “The<br />
decision on when to build the asphaltene recovery plant depends on many<br />
factors, including prevailing market conditions, joint venture partners’ financial<br />
approval and regulatory conditions.”<br />
17a Is Shell applying for approval to build both a natural gas and asphaltene<br />
cogeneration system?<br />
Response 17a Yes, Shell is applying to build one asphaltene-fired cogeneration unit and one<br />
natural-gas-fired cogeneration unit. However, asphaltene energy recovery (AER)<br />
technology is still under development and must meet Shell’s investment criteria<br />
(see the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1,<br />
Section 1, Overview, page 1-8) before proceeding to design and construction. If<br />
AER does not meet Shell’s investment criteria, then Shell will seek approval to<br />
build two natural-gas fired cogeneration units. An assessment of the alternative<br />
two natural-gas-fired cogeneration units was included in the EIA.<br />
Request 17b Verify that Shell is committing to building both a natural gas and asphaltene<br />
cogeneration system.<br />
Response 17b See the response to ERCB SIR 17a.<br />
Question No. 18<br />
Request Volume 1, Section 10.1, Page 10-89, Supplemental Information Responses.<br />
Shell states, “Greenhouse gas emissions are expected to be higher with AER<br />
cogeneration than with natural gas as combustion.”<br />
18a Provide a summary of the measures and controls that Shell will implement to<br />
minimize greenhouse gas emissions for both asphaltene energy recovery (AER)<br />
cogeneration and natural gas units.<br />
Response 18a Shell is designing adequate plot space for both the natural-gas-fired cogeneration<br />
unit and the AER cogeneration unit to be retrofitted for carbon capture<br />
technology if this becomes a viable option in the future.<br />
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Section 4.1<br />
In addition, Shell expects that future energy reductions (and subsequent<br />
greenhouse gas reductions) will occur as experience from current and future<br />
operations are incorporated into the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> design.<br />
Request 18b Clarify Shell’s commitment to use the best available technology to minimize<br />
greenhouse gas emissions for both AER cogeneration and natural gas units.<br />
Response 18b Shell will comply with applicable policy and regulations for greenhouse gas<br />
emissions.<br />
Question No. 19<br />
Request Volume 1, Section 10.1, Page 10-91 to 10-92, Tables 166-1 and 166-2,<br />
Supplemental Information Responses.<br />
Table 166-1 provides a summary of monthly bitumen recovery with oil sands<br />
grade greater than 11%. Based on this table, on a monthly basis, Shell has<br />
exceeded 90% target recovery for 13 months out of 46 months. Table 166-2<br />
provides a summary of annual bitumen recovery. Based on this table submitted<br />
for 2003-2008, Shell had not achieved the bitumen recovery as required under<br />
ERCB ID 2001-7 Operating Criteria: Resource Recovery Requirements for Oil<br />
Sands <strong>Mine</strong> and Processing Plant Sites.<br />
19a Past performance shows that Shell has experienced challenges meeting bitumen<br />
recovery requirements. Explain how Shell will meet the required bitumen<br />
recovery to satisfy ERCB ID 2001-7.<br />
Response 19a The response to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, SIR 166f, as well as the response to the December 2009 Jackpine<br />
<strong>Mine</strong> Expansion, Supplemental Information SIR 137h, highlight improvements<br />
to the original Muskeg <strong>River</strong> <strong>Mine</strong> design curve regarding bitumen recovery.<br />
Shell will incorporate improvements currently being made at the Muskeg <strong>River</strong><br />
<strong>Mine</strong>, as well as those included in the new Jackpine <strong>Mine</strong> design to help improve<br />
bitumen recovery performance for all oil sand grades. The knowledge gained<br />
from these two operations will be used to improve the performance of the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> facilities.<br />
As stated in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, SIR 166f:<br />
Shell has taken several initiatives at the Muskeg <strong>River</strong> <strong>Mine</strong> regarding the initial<br />
design, with the objective of improving bitumen recovery, including:<br />
• adding sodium citrate to increase bitumen recovery. Sodium citrate is<br />
currently used at the Muskeg <strong>River</strong> <strong>Mine</strong>. The use of a chemical additive,<br />
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such as sodium citrate, will be considered at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, to<br />
improve recovery performance.<br />
Section 4.1<br />
• adjusting the hydrotransport temperature. The hydrotransport temperature is<br />
a critical variable affecting bitumen recovery. The current understanding<br />
indicates that a hydrotransport slurry temperature of 40 to 45°C is the<br />
optimum range, particularly for lower grade ore.<br />
• implementing bitumen recovery from the thickener. Bitumen recovery has<br />
been implemented on one train and might be implemented in future<br />
expansions. Alternatively, the upstream recovery equipment might be made<br />
more efficient.<br />
Depending on the operating conditions at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, some or all of<br />
these improvements might be implemented, as necessary.<br />
In addition, the response to the December 2009 Jackpine <strong>Mine</strong> Expansion,<br />
Supplemental Information, SIR 137h stated that:<br />
The Jackpine <strong>Mine</strong> Expansion project team will consider current Muskeg <strong>River</strong><br />
<strong>Mine</strong> operations and build on the lessons learned from that development.<br />
In addition to the items listed in SIR 137f and SIR 137g, the Jackpine <strong>Mine</strong><br />
design already includes several improvements over the Muskeg <strong>River</strong> <strong>Mine</strong><br />
design, including:<br />
• a longer conditioning pipeline<br />
• reduced solids loading in the primary separation cell<br />
• primary separation cell design improvements, including improved feed<br />
distribution and froth underwash<br />
• increased flotation capacity<br />
All of these changes are expected to improve bitumen recovery. The effectiveness<br />
of the improvements will be evaluated once the Jackpine <strong>Mine</strong> is operational,<br />
and they will be considered, as needed, for the Jackpine <strong>Mine</strong> Expansion.<br />
Request 19b It is acknowledged that Muskeg <strong>River</strong> <strong>Mine</strong> has experienced difficulties achieving<br />
ERCB bitumen recovery requirements since start-up. Justify the design proposed<br />
in this application in light of Muskeg <strong>River</strong> <strong>Mine</strong>’s shortfalls in meeting existing<br />
bitumen recovery requirements.<br />
Response 19b Shell’s understanding of the technical and operational performance of bitumen<br />
extraction has increased significantly since the original Muskeg <strong>River</strong> <strong>Mine</strong><br />
design. Shell is continuing to improve the Muskeg <strong>River</strong> <strong>Mine</strong> performance as<br />
well as including a number of design improvements in the Jackpine <strong>Mine</strong>.<br />
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Recovery (%)<br />
Section 4.1<br />
Additional operational improvements gathered from these two facilities will be<br />
considered in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> design.<br />
Measuring small changes to the calculated annual bitumen recovery is a slow<br />
process. Recent changes made to the Muskeg <strong>River</strong> <strong>Mine</strong> operation are starting<br />
to show some improvement (see Figure ERCB 19-1) and Shell expects that this<br />
improvement will continue in 2010 as additional bitumen recovery improvement<br />
initiatives are implemented, such as a new PSC feed well and adjusting pH on the<br />
slurry line.<br />
90<br />
85<br />
80<br />
75<br />
70<br />
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec<br />
Month<br />
Required Actual<br />
Figure ERCB 19-1: Average Monthly Bitumen Recovery and Improvement Required<br />
Question No. 20<br />
Request Volume 1, Section 10.1, Page.10-96, Supplemental Information Responses.<br />
Shell states “Generally, the higher grade ores are associated with higher than<br />
average recovery, and produce froth with lower water content. Bitumen recovery<br />
at these higher rates and higher grades were within expectations.” Table 167-2<br />
indicates that an overall recovery of greater than 90% was achieved for 7 out of<br />
16 days based on the data provided.<br />
20a Explain what Shell considers “within expectations” for bitumen recovery as<br />
mentioned above.<br />
Response 20a The statement cited was part of a larger response in reference to the impact of<br />
higher rates on recovery. The data shown in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 1, SIR 167 was used to indicate that, during<br />
that time period, recoveries at high rates were as good or better than average<br />
performance.<br />
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Section 4.1<br />
Request 20b Clarify if Shell’s bitumen recovery expectations are aligned with ERCB ID 2001-<br />
7 requirements.<br />
Response 20b Shell’s expectations for bitumen recovery are that, on an annual basis, the<br />
requirements of ID 2001-7 will be met. This is based on operational<br />
improvements achieved to date at the Muskeg <strong>River</strong> <strong>Mine</strong> and further design<br />
improvements, which have been incorporated into the current Jackpine <strong>Mine</strong>.<br />
Question No. 21<br />
Request Volume 1, Section 10.1, Page 10-113, Supplemental Information Responses.<br />
Shell states, “Asphaltene rejection is about 10 wt% of the bitumen production.”<br />
21a Clarify Shell’s commitment to limiting asphaltene rejection to 10 weight per cent<br />
based on bitumen production.<br />
Response 21a The current design basis for the high-temperature froth treatment process is to<br />
reject less than 10 wt% asphaltene based on bitumen production. The asphaltene<br />
rejection level is a balance between upstream bitumen recovery and final bitumen<br />
quality. Lower asphaltene rejection rates favour higher bitumen recoveries but<br />
lower bitumen quality, whereas increased asphaltene rejection rates favour the<br />
application of technologies for asphaltene energy recovery (AER) and further<br />
upgrading at the AOSP Scotford Upgrader. This balance of adding value to the<br />
bitumen resource can and does shift over time, so that Shell cannot make a firm<br />
commitment on the level of asphaltene rejection.<br />
Question No. 22<br />
Request Volume 1, Section 10.1, Page 10-120, Supplemental Information Responses.<br />
Shell states, “The diluted bitumen and solvent storage tanks are not connected to<br />
the vapour recovery system.”<br />
22a Clarify if the diluted bitumen and solvent storage tanks are fixed roof or floating<br />
roof tanks.<br />
Response 22a The diluted bitumen and solvent storage tanks are internal floating roof tanks.<br />
Request 22b Clarify if the diluted bitumen and solvent storage tanks are connected to any<br />
blanket system.<br />
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Section 4.1<br />
Response 22b The diluted bitumen and solvent storage tanks are not connected to any blanket<br />
system.<br />
Request 22c Clarify the typical and all alternate routings for the vapours from the diluted<br />
bitumen and solvent storage tanks.<br />
Response 22c As stated in the EIA, all above-ground storage tanks are designed to conform to<br />
the Canadian Council of Ministers of the Environment guidelines for Controlling<br />
Emissions of Volatile Organic Compounds from Aboveground Storage Tanks,<br />
1995. The floating roofs of both types of storage tanks are equipped with seals to<br />
minimize fugitive emissions.<br />
Question No. 23<br />
Request Volume 1, Section 10.1, Page 10-123, Figure 193-1, Supplemental Information<br />
Responses; Volume 1, Section 10.1, Page 10-126, Table 197-1, Supplemental<br />
Information Responses.<br />
Figure 193-1 indicates that bitumen recovery requirements will not be met for oil<br />
sand grades less than approximately 10.8% wt bitumen. Table 197-1 indicates<br />
that bitumen recovery requirements will not be met for each balance case.<br />
23a For areas on the curve where the bitumen recovery requirements as set out in<br />
ERCB ID 2001-7 are not met, explain the steps Shell will take to meet the<br />
requirements.<br />
Response 23a All of the initiatives listed in the following will improve bitumen recovery.<br />
However, the effectiveness of each initiative will vary with ore type, and benefits<br />
may overlap, making it difficult to attribute particular portions of recovery<br />
improvement to a particular initiative. As more experience is gained across a<br />
wider range of feed grades, a new design curve is expected to be derived.<br />
As stated in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, SIR 166f:<br />
Shell has taken several initiatives at the Muskeg <strong>River</strong> <strong>Mine</strong> regarding the initial<br />
design, with the objective of improving bitumen recovery, including:<br />
• adding sodium citrate to increase bitumen recovery through increased<br />
bitumen concentration in the primary settling vessel froth. The use of a<br />
chemical additive, such as sodium citrate, will be considered at the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong>, to improve recovery performance.<br />
• adjusting the hydrotransport temperature. The hydrotransport temperature is<br />
a critical variable affecting bitumen recovery. The current operational<br />
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Section 4.1<br />
experience indicates an optimal range of hydrotransport slurry temperature<br />
between 40 to 45°C, particularly for lower grade ore.<br />
• implementing bitumen recovery from the thickener. Bitumen recovery has<br />
been implemented from a thickener on one extraction process train.<br />
Depending on the operating conditions at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, some or all of<br />
these improvements might be implemented, as necessary.<br />
In addition, the response to the December 2009 Jackpine <strong>Mine</strong> Expansion,<br />
Supplemental Information, SIR 137h stated that:<br />
The Jackpine <strong>Mine</strong> Expansion project team will consider current Muskeg <strong>River</strong><br />
<strong>Mine</strong> operations and build on the lessons learned from that development.<br />
In addition to the items listed in SIR 137f and SIR 137g, the Jackpine <strong>Mine</strong><br />
design already includes several improvements over the Muskeg <strong>River</strong> <strong>Mine</strong><br />
design, including:<br />
• a longer conditioning pipeline<br />
• reduced solids loading in the primary separation cell<br />
• primary separation cell design improvements, including improved feed<br />
distribution and froth underwash<br />
• increased flotation capacity<br />
All of these changes are expected to improve bitumen recovery. The effectiveness<br />
of the improvements will be evaluated once the Jackpine <strong>Mine</strong> is operational,<br />
and they will be considered, as needed, for the Jackpine <strong>Mine</strong> Expansion.<br />
Request 23b Clarify Shell’s commitment to meet ERCB ID 2001-7 bitumen recovery<br />
requirements for all grades.<br />
Response 23b As stated in ERCB SIR 25, corrected site-wide material balances have been<br />
calculated for average feed grade on a calendar and stream day basis. Based on<br />
this new information, the comparison of design bitumen recovery to ERCB ID<br />
2001-7 presented in Table 197-1 of the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 1, Section 10.1, has been updated and is<br />
shown here as Table ERCB 23-1.<br />
Table ERCB 23-1: Bitumen Recovery Comparison<br />
Calculated Ore Calculated<br />
Grade<br />
Recovery ERCB ID 2001-7<br />
Basis<br />
(% Bitumen)<br />
(%)<br />
(%)<br />
Calendar day 10.9 90 90<br />
Stream day 10.9 90 90<br />
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Question No. 24<br />
Section 4.1<br />
Shell is confident that the steps outlined in the response to ERCB SIR 23a will<br />
result in continued recovery improvement toward meeting the requirements of<br />
ID-2001-7 on an annual basis.<br />
Request Volume 1, Section 10.2, Page 10-126, Supplemental Information Responses.<br />
Shell states, “The densities used in these material balances are solvent = 650<br />
kg/m3 whole bitumen = 1,000 kg/m3 asphaltene = 1.050 kg/m3.”<br />
24a The densities used in these material balances are not consistent with the densities<br />
used at Muskeg <strong>River</strong> <strong>Mine</strong>. Clarify the difference in densities.<br />
Response 24a The densities used in the application are design values, not actuals. The design<br />
values were selected to support equipment sizing. For design purposes, these<br />
values are not significantly different from the actual values used for reporting<br />
purposes for the Muskeg <strong>River</strong> <strong>Mine</strong> i.e., Muskeg <strong>River</strong> <strong>Mine</strong> whole bitumen =<br />
1,007 kg/m 3 and solvent density = 657 kg/m 3 . Any consequences resulting from<br />
the differences between the actual values and design values are well within<br />
normal design margins.<br />
Request 24b Provide the density for the final bitumen product.<br />
Response 24b The final bitumen density (de-asphaltened bitumen) is 995 kg/m 3 .<br />
Question No. 25<br />
Request Volume 1, Section 7.1, Pages 7-11 and 7-12, Figures 9-1 and 9-2,<br />
Supplemental Information Responses; Volume 1, Section 10.1, Pages 10-127<br />
and 10-128, Figure 197-1 and 197-2, Supplemental Information Responses.<br />
The following clarifications are required in regards to the provided site-wide<br />
material balances:<br />
25a Provide corrected material balances on the calendar day basis for:<br />
i Deaeration and Froth Screening: Solids balance<br />
ii. Froth Treatment: Solids balance, Solvent balance<br />
iii. Tailings Solvent Recovery Unit: Solvent balance<br />
iv. Asphaltene Recovery Unit: Water balance, maltene balance, asphaltene<br />
balance, solids balance<br />
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Section 4.1<br />
Response 25a The corrected material balance for a typical operating calendar day case is shown<br />
in Figure ERCB 25-1 and is also provided in Section 2.3, Supplemental<br />
Information Errata.<br />
Request 25b Provide corrected material balances for the stream day basis for:<br />
i. Asphaltene Recovery Unit: Maltene balance, asphaltene balance, solids<br />
balance, solvent balance<br />
Response 25b The corrected material balance for a typical operating stream day case is shown<br />
in Figure ERCB 25-2. The correct information is also provided in Section 2.3,<br />
Supplemental Information Errata.<br />
Question No. 26<br />
Request Volume 1, Section 10.1, Page 10-129, Supplemental Information Responses.<br />
Table 197-2 and Table 197-3 show the solvent losses from the TSRU unit only.<br />
26a Provide an updated table that includes site-wide solvent losses from all sources<br />
including flared losses, tank losses, etc.<br />
Response 26a Most of the solvent losses are from the TSRU tailings. The design basis for the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is that there will be no solvent flaring. Other losses, such as<br />
tank losses, are relatively minor compared to the solvent loss in the TRSU<br />
tailings. The expected emission rate from the solvent tank is only 2,060 kg/a.<br />
Table 197-2 and 197-3 have been updated to reflect solvent losses from other<br />
sources, and are reproduced here as Table ERCB 26-1 and ERCB 26-2.<br />
Table ERCB 26-1: Solvent Loss for Material Balances with Asphaltene Recovery Unit<br />
Solvent Solvent Recovered<br />
Loss in Asphaltene Tank Losses<br />
Bitumen (TSRU) Recovery Unit Plus Other Solvent Loss per<br />
Basis (t/h) (t/h)<br />
(t/h)<br />
(t/h) 1,000 Volumes<br />
Calendar day 1,362 3.26 0.67 0.03 2.96<br />
Stream day<br />
Note:<br />
1,656 3.96 0.81 0.03 2.95<br />
specific gravity of solvent = 0.65<br />
specific gravity of bitumen = 1.0<br />
solvent loss per 1,000 volumes = (total solvent loss – AER solvent recovery) X 1000<br />
(solvent SAG * bitumen)<br />
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Section 4.1<br />
Figure ERCB 25-1: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Material Balance – One Train (Calendar Day)<br />
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Section 4.1<br />
Figure ERCB 25-2: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Material Balance – One Train (Calendar Day)<br />
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Section 4.1<br />
Table ERCB 26-2: Solvent Loss for Material Balances Without Asphaltene Recovery Unit<br />
Solvent Loss Tank losses plus<br />
Bitumen (TSRU)<br />
other Solvent Loss per<br />
Basis (t/h)<br />
(t/h)<br />
(t/h)<br />
1,000 Volumes<br />
Calendar day 1,362 3.26 0.03 3.72<br />
Stream day 1,656 3.96 0.03 3.71<br />
Note:<br />
specific gravity of solvent =0.65<br />
specific gravity of bitumen = 1.0<br />
solvent loss per 1,000 volumes = (total solvent loss) X 1000<br />
(solvent SAG * bitumen)<br />
Request 26b Update the table to include solvent losses and bitumen production on a<br />
volumetric basis.<br />
Response 26b Table ERCB 26-3 and ERCB 26-4 provide volumetric data for site-wide solvent<br />
loss for each material balance case with and without the asphaltene recovery unit.<br />
Table ERCB 26-3: Solvent Loss for Material Balances with Asphaltene Recovery Unit<br />
(Volumetric)<br />
Basis<br />
Bitumen<br />
m 3 Solvent<br />
Loss<br />
/h<br />
(TSRU)<br />
m 3 Solvent Recovered<br />
in Asphaltene<br />
/h<br />
Recovery Unit<br />
m 3 Tank Losses<br />
/h<br />
Plus Other<br />
m 3 /h<br />
Solvent Loss per<br />
1,000 Volumes<br />
Calendar day 1,362 5.02 1.03 0.047 2.96<br />
Stream day 1,656 6.09 1.25 0.047 2.95<br />
Note:<br />
solvent loss per 1,000 volumes = (total solvent loss – AER solvent recovery) X 1000<br />
(bitumen)<br />
Table ERCB 26-4: Solvent Loss for Material Balances Without Asphaltene Recovery Unit<br />
(Volumetric)<br />
Basis<br />
Bitumen<br />
m 3 Solvent Loss<br />
/h<br />
(TSRU)<br />
m 3 Tank Losses<br />
/h<br />
Plus Other<br />
m 3 /h<br />
Solvent Loss per<br />
1,000 Volumes<br />
Calendar day 1,362 5.02 0.047 3.72<br />
Stream day 1,656 6.09 0.047 3.71<br />
Note:<br />
solvent loss per 1,000 volumes = (total solvent loss) X 1000<br />
(bitumen)<br />
4-26 Shell Canada Limited April 2010<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Question No. 27<br />
Section 4.1<br />
Request Volume 1, Section 10.1, Page 10-131, Table 199-1, Supplemental Information<br />
Responses; Volume 1, Section 10.1, Page 10-130, Figure 198-1, Supplemental<br />
Information Responses.<br />
Table 199-1 and Figure 198-1 show different values for natural gas consumed<br />
for summer low-grade ore, summer average-grade ore, and summer high-grade<br />
ore.<br />
27a Explain the difference between the natural gas requirements identified in Figure<br />
198-1 and Table 199-1.<br />
Response 27a The thermal requirement and natural gas consumed data presented in Table 199-1<br />
was incorrect. The data should have been identical to that presented in Table 9-2<br />
in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1. The<br />
corrected table has been reproduced here as Table ERCB 27-1 and is also<br />
provided in Section 2.3, Supplemental Information Errata.<br />
Table ERCB 27-1: Comparison of Thermal Energy Requirements<br />
Thermal<br />
Operating Scenario<br />
Requirement<br />
(GJ/m 3 Natural Gas<br />
)<br />
Consumed<br />
(GJ/m 3 Process<br />
)<br />
Feed Grade<br />
(wt% Bitumen)<br />
Temperature<br />
(°C)<br />
Winter average-grade ore 2.44 0.86 10.9 40<br />
Winter coarse high-grade ore 2.34 0.97 11.7 40<br />
Summer low-grade ore 2.10 0.00 10.1 40<br />
Summer average-grade ore 1.65 0.05 10.9 40<br />
Summer high-grade ore 1.55 0.13 11.7 40<br />
There is still a difference between Figure 198-1 and Table ERCB 27-1.<br />
Table ERCB 27-1 includes total natural gas consumed, including gas consumed<br />
by the combustion turbine, the duct burner and the auxiliary boilers. Although<br />
Table ERCB 27-1 shows the total thermal energy required to heat process water<br />
and to create process steam, the natural gas consumption is only for the gas<br />
directly fired, i.e, the natural gas routed to the duct burner and the auxiliary<br />
boilers. The natural gas routed to the cogeneration unit is not included.<br />
If the energy recovered from the gas-fired cogeneration plant that is used for<br />
steam generation were associated with its equivalent natural gas consumption,<br />
the thermal energy requirements would appear as shown in Table ERCB 27-2.<br />
April 2010 Shell Canada Limited 4-27<br />
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Table ERCB 27-2: Comparison of Thermal Energy Requirements<br />
Operating Scenario<br />
Thermal<br />
Requirement<br />
(GJ/m 3 )<br />
Natural Gas<br />
Consumed<br />
(GJ/m 3 )<br />
Feed Grade<br />
(wt% Bitumen)<br />
Process<br />
Temperature<br />
(°C)<br />
Winter average-grade ore 2.44 1.37 10.9 40<br />
Winter coarse high-grade ore 2.34 1.42 11.7 40<br />
Summer low-grade ore 2.10 0.37 10.1 40<br />
Summer average-grade ore 1.65 0.46 10.9 40<br />
Summer high-grade ore 1.55 0.50 11.7 40<br />
Question No. 28<br />
Section 4.1<br />
Request Volume 1, Section 10.1, Page 10-132, Supplemental Information Responses.<br />
Shell states, “Details of the commissioning and start-up plan for the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> ore preparation, primary extraction, froth treatment plants, and asphaltene<br />
recovery unit have not yet been developed.”<br />
28a Clarify Shell’s commitment to provide a commissioning and start-up plan to the<br />
ERCB for review and approval one year prior to the start of commissioning.<br />
Response 28a A commissioning and start-up plan for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will be provided to<br />
the ERCB for review and approval one year before commissioning starts.<br />
Question No. 29<br />
Request Volume 1, Section 10.1, Page 10-154 and 10-168, Supplemental Information<br />
Responses.<br />
Shell states, “Of the 21% mineral solids, about 60% are finer than 44μm.” Table<br />
218-5 on Page 10-168 presents the Sand-to-Fines Ratios (SFR) of different<br />
tailings streams. The SFR for the TSRU tailings stream is shown as 1.1:1.<br />
29a Explain the discrepancy in the fines content of the TSRU.<br />
Response 29a The statement “Of the 21% mineral solids, about 60% are finer than 44μm.” in<br />
the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section<br />
10.1, page 10-154, was incorrect (see also Section 2.3, Supplemental Information<br />
Errata). The correct value used for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is about 50% finer than<br />
44 μm, which would result in a sands-to-fines ratio (SFR) of 1:1. The SFR of the<br />
tailings solvent recovery unit (TSRU) stream of 1.1:1 shown in Table 218-5 of<br />
the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section<br />
10.1, is an estimated SFR based on the general geology at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
and is used for tailings planning.<br />
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Question No. 30<br />
Section 4.1<br />
Request Volume 1, Section 3.1, Page 3-1, Table 3-1, Supplemental Information<br />
Responses; Volume 1, Section 10.1, Page 10-166, Table 218-4, Supplemental<br />
Information Responses.<br />
Table 3-1 indicates that revised data of Ore is 2,102 Mt. In Table 218-4, the<br />
sand, fines, bitumen and water from extraction sum to 2,263.8 Mt.<br />
30a Confirm the updated total ore tonnage. Update Table 3-1 or Table 218-4<br />
according to the latest information.<br />
Response 30a The mine quantities stated in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, were updated to reflect the revised pit limits and updated block<br />
model. However, the mine production schedule and integrated tailings plan were<br />
not revised because of the small (5%) change in total mine volumes. Table 3-1<br />
(see the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1)<br />
provided a comparison of the revised ore tonnage to the ore tonnage in the<br />
December 2007 application.<br />
Table 218-4 in the response to SIR 218 provided additional details on the tailings<br />
schedule submitted with the December 2007 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, <strong>Project</strong><br />
Description, Volume 2. Therefore, it cannot be reconciled with the total mine<br />
quantities from the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information. The<br />
extraction ore properties provided in Table 218-4 excludes breaker rejects.<br />
Therefore, the breaker reject tonnage of 86 Mt must be added to the extraction<br />
ore tonnes to reconcile with the 2,349 Mt of total ore reported in the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> <strong>Project</strong> Description.<br />
Request 30b Update the following tables:<br />
i. Table 218-3: Supplemental Information Responses<br />
ii. Table 7-5: Volume 2 of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Application<br />
iii. Table 7-7: Volume 2 of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Application<br />
iv. Table 7-8: Volume 2 of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Application<br />
Response 30b The data was not re-calculated because the mine production schedule and<br />
integrated tailings plan were not updated for the <strong>Project</strong> Update, as stated in the<br />
response to ERCB SIR 30a.<br />
The general mine scheme and sequence of the development will be maintained.<br />
April 2010 Shell Canada Limited 4-29<br />
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Question No. 31<br />
Section 4.1<br />
Request Volume 1, Section 4.1, Page 4-1 to 4-3, Supplemental Information Responses.<br />
Shell states, “This update identifies the methodology and techniques that will be<br />
applied to ensure that the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> development complies with ERCB<br />
Directive 074.”<br />
31a Update Table 7-2: Volume 2 of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Application, according to<br />
the tailings management plan described in Section 4.1.<br />
Response 31a Table 7-2 in Volume 2, Section 7 of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> application, outlines<br />
the tailings activity sequence. The sequence is a general list of activities for<br />
external and in-pit tailings disposal. The operating dates for the external tailings<br />
disposal area (ETDA) will not change in relation to current Directive 074<br />
compliance planning. Consistent with the Jackpine <strong>Mine</strong>, <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will<br />
use an external tailings disposal area with a thickened tailings cell for about 10<br />
years after start-up. When sufficient space is mined in-pit, non-segregating<br />
tailings (NST) deposition will begin.<br />
Question No. 32<br />
As outlined in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, Section 4.1, page 4-1, Shell intends to meet the objectives of ERCB<br />
Directive 074 by enhancing the tailings plan outlined in the application with one,<br />
or a combination of, the following:<br />
• applying the appropriate thickener design<br />
• using coagulants<br />
• potentially recycling thin fine tailings (TFT) to a supplemental thickening<br />
process<br />
The strategy implemented at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will be based on experience<br />
gained from the Jackpine <strong>Mine</strong> and other industry applications at existing mines.<br />
The Jackpine <strong>Mine</strong> ETDA will be commissioned in 2010 in conjunction with a<br />
thickened tailings dedicated disposal area (DDA). Experience gained at the<br />
Jackpine <strong>Mine</strong> in technology development and tailings operations and<br />
management will be considered at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> to meet the objectives of<br />
ERCB Directive 074.<br />
Request Volume 2, Section 3.2, Page 3-11.<br />
Shell states, “In 2006 and 2007, under 100 auger holes were initiated to evaluate<br />
OB.” In Volume 1, Section 10.1, Page 10-165, Supplemental Information<br />
Responses, Shell states, “<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> planning considered 75% of the<br />
overburden and interburden material to be acceptable dyke construction<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Section 4.1<br />
material. Of this 75%, the overall use of available dyke construction material<br />
throughout the life of the mine is 40%.......Pre-stripping of overburden is<br />
advanced in the production schedule in years when there is an insufficient<br />
quantity of construction material available to meet the dyke placement<br />
requirement.”<br />
32a Explain how Shell determined the 75% value for construction quality overburden<br />
and interburden.<br />
Response 32a The approximate construction material availability and capture rates from<br />
existing operations were applied to the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> planning parameters.<br />
Detailed material properties for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> overburden and<br />
interburden have not yet been consolidated.<br />
Request 32b What is Shell’s plan to further evaluate and update the assumptions of the<br />
amount of construction quality overburden and interburden material?<br />
Response 32b Shell will collect similar geotechnical data and conduct similar testing programs<br />
for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> as those employed at the Muskeg <strong>River</strong> <strong>Mine</strong> and the<br />
Jackpine <strong>Mine</strong>. Data collection will focus on material samples collected from<br />
exploration programs, including detailed geotechnical laboratory testing for such<br />
properties as moisture, density, direct shear and triaxial shear.<br />
Request 32c Overburden pre-stripping does not increase construction quality overburden and<br />
interburden availability over the life of the project. If construction quality<br />
overburden and interburden estimates are lower, what is Shell’s contingency<br />
plan for dyke construction?<br />
Response 32c To clarify the availability and usage of overburden and interburden materials at<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>:<br />
• the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> production schedule includes 1,127.8 Mbcm of total<br />
overburden and interburden waste over the mine life<br />
• an estimated 75% (780.1 Mbcm) of the total overburden and interburden<br />
waste is considered suitable in situ construction material<br />
• an estimated 80% (627.9 Mbcm) of the suitable in situ construction material<br />
is considered recoverable by mine operations<br />
• only 49% (310.1 Mbcm) of the recoverable construction material is<br />
scheduled for placement as suitable material in engineered structures.<br />
Therefore, 51% of the identified recoverable construction material remains as<br />
contingency.<br />
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Section 4.1<br />
• prestripping is used to increase construction quality overburden by advancing<br />
the mining of suitable material during specific periods when there is a<br />
construction material shortfall<br />
The design philosophy for all engineered structures is to maximize the use of<br />
available materials from the mine by tailoring construction material<br />
specifications for the structure to match the mine materials available. Therefore,<br />
the primary contingency for a construction material shortfall is to re-design the<br />
engineered structure and the associated material specifications to use as much of<br />
the available materials as possible.<br />
Request 32d Discuss its impact on the tailings management plan, including impact on nonsegregating<br />
tailings (NST) production, fines capture and mature fine tailings<br />
(MFT) inventory.<br />
Response 32d The contingency scenario where dyke structures are re-designed to optimize<br />
material use would result in increased material quantities being placed in the<br />
dykes, resulting in a revision to the integrated mine and tailings plan to<br />
accommodate the adjusted material placement schedule.<br />
Question No. 33<br />
Adjustments to the design of engineered structures and the waste material<br />
movement schedule are not expected to affect NST production, fines capture or<br />
MFT inventory.<br />
Request Volume 1, Section 4.1, Page 4-2, Supplemental Information Responses.<br />
Shell states, “During operation of the ETDA (from 2018 to 2028), the TT will be<br />
contained in a discrete cell within the ETDA, built using coarse tailings sand.<br />
The TT cell within the ETDA will act as a designated disposal area for the<br />
thickened tailings deposit.” In Volume 1, Section 10.1, Page 10-168, Table 219-<br />
1, Supplemental Information Responses; it is indicated that the slurry density was<br />
lower than 1400 kg/m3 (46% solids) more than a third of the time. Also, in<br />
Volume 1, Section 10.1, Page 10-144, Supplemental Information Responses,<br />
Shell states, “The timing required to make the TT deposits trafficable is<br />
uncertain, as no full-scale stand-alone thickened tailings deposit has yet been<br />
created, capped and made ready for reclamation in oil sands industry. However,<br />
Shell understands the Directive’s requirement to have dedicated disposal areas<br />
capped and ready for reclamation within five years after deposition activities<br />
stop. Shell is evaluating, as a high priority, the means to shorten the time<br />
required to make TT deposits ready for reclamation at the Muskeg <strong>River</strong> <strong>Mine</strong><br />
tailings test facility.”<br />
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33a Based on the updated Table 218-4, what is the annual percentage of fines in Ore<br />
Feed captured in thickened tailings (TT) deposit, i.e. excluding the thin fine<br />
tailings (TFT) formed from TT stream, during 2018-2028?<br />
Response 33a The fines captured in the TT deposit in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> tailings plan are<br />
summarized in Table ERCB 33-1. As shown in Table ERCB 33-1, the fines<br />
capture averages 40% between 2018 and 2028.<br />
Period<br />
Table ERCB 33-1: Fines Capture in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA TT Deposit<br />
Total Ore<br />
(t)<br />
Extraction Ore Feed Thickened Tailings Deposit (3)<br />
Course<br />
(t) (1)<br />
Fines<br />
(t) (2)<br />
Fines<br />
wt%<br />
<strong>Mine</strong>ral<br />
Course<br />
(t) (1)<br />
Fines<br />
(t) (2)<br />
Fines<br />
(% of<br />
Extraction<br />
Fines)<br />
2018 5.98 4.16 0.85 16.9 1.95 0.38 44.7<br />
2019 19.02 13.22 2.69 16.9 0.93 1.03 38.5<br />
2020 54.59 37.96 7.73 16.9 2.66 2.97 38.5<br />
2021 66.51 46.44 9.45 16.9 4.43 3.67 38.9<br />
2022 75.97 53.12 10.82 16.9 5.05 4.20 38.9<br />
2023 114.51 79.80 16.24 16.9 10.61 6.41 39.5<br />
2024 117.65 82.18 16.73 16.9 10.64 6.59 39.4<br />
2025 109.68 76.19 15.51 16.9 9.34 6.09 39.3<br />
2026 116.61 81.63 16.62 16.9 9.21 6.50 39.1<br />
2027 116.08 81.03 16.50 16.9 7.67 6.41 38.8<br />
2028 108.91 75.45 15.36 16.9 23.56 6.49 42.3<br />
Total 905.51 631.18 128.49 16.9 86.05 50.76 39.5<br />
Note:<br />
1. Coarse refers to all mineral consisting of particle size greater than 44µm.<br />
2. Fines refers to all mineral consisting of particle size less than 44µm.<br />
3. Thickened tailings deposit includes all thickener underflow captured in the beach (excluding thin fine tailings<br />
runoff), as well as all cyclone underflow “lost” from cell construction on the centreline dyke and captured in the<br />
beach.<br />
Request 33b Is the annual percentage lower or higher than 50%? If lower, what constraints<br />
limit Shell’s ability to capture a minimum of 50% fines in feed in the TT deposit<br />
between 2018 and 2028?<br />
Response 33b The level of fines capture in thickened tailings deposits is currently constrained<br />
by Shell’s understanding of the capabilities of this technology. Shell recognizes<br />
that, at this stage, this level of fines capture, in isolation, will not meet the<br />
requirements of Directive 074. Therefore, in order to meet the 50% capture<br />
required, Shell will use supplementary technologies, such as:<br />
• applying the appropriate thickener design<br />
April 2010 Shell Canada Limited 4-33<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
• using coagulants<br />
• potentially recycling TFT to a supplemental thickening process<br />
Section 4.1<br />
The type and extent of supplementary technology employed at the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> will be based on the experience gained through commercial operations at<br />
the Muskeg <strong>River</strong> and Jackpine mines. Shell expects that these operations will<br />
comply with Directive 074 before the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> starts up. Shell is<br />
confident that, although some of the details of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> plan still<br />
need to be determined, the knowledge gained at its existing operations will allow<br />
the <strong>Pierre</strong> <strong>River</strong> mine to meet the objectives of Directive 074.<br />
Request 33c What is Shell’s plan to meet the requirement of fines capture as specified in<br />
ERCB Directive 074: Tailings Performance Criteria and Requirements for Oil<br />
Sands Schemes, i.e., minimum 50% of fines in feed?<br />
Response 33c See the response to ERCB SIR 33b.<br />
Request 33d Discuss how Shell will measure the fines captured in the TT deposit and the<br />
strength of the deposit.<br />
Response 33d The techniques and procedures for measuring fines capture and deposit strength<br />
will be based on the Jackpine <strong>Mine</strong> Fines Measurement Plan, which is currently<br />
being developed. The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Fines Measurement Plan will be<br />
submitted in conjunction with the Annual Compliance Report by September 30<br />
of the year before tailings deposition starts, as outlined in ERCB Directive 074:<br />
Tailings Performance Criteria and Requirements for Oil Sands Schemes Section<br />
4.4.<br />
Request 33e Clarify Shell’s commitment to meet the requirements of ERCB Directive 074.<br />
Response 33e Shell is committed to meeting the objectives of ERCB Directive 074 and will<br />
continue to work with the ERCB to ensure that the appropriate technology is<br />
successfully implemented to achieve the required targets and timelines.<br />
Question No. 34<br />
Request Volume 1, Section 4.1, Page 4-2, Supplemental Information Responses.<br />
Shell states, “In 2029, the first mined pit area will be available to receive<br />
tailings……Non-segregating tailings will be made by combining a portion of the<br />
TT stream with the cyclone underflow stream and gypsum to produce a slurry<br />
with a sand-to-fines ratio of 5:1. The remaining TT will be disposed of in a<br />
separate in-pit cell (DDA). Thin fine tailings will be removed continually from<br />
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Section 4.1<br />
the active non-segregating tailings designated disposal area by pumping to the<br />
in-pit clarification cell.” In Volume 1, Section 10.1, Page 10-168, Table 218-5,<br />
Supplemental Information Responses, Shell states, “Sand to fines ratio is 6.7:1<br />
for Non-segregating tailings.”<br />
34a What are the constraints that will prevent Shell from starting NST production<br />
before 2029?<br />
Response 34a The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> has been designed to store tailings on start-up in an<br />
external tailings disposal area (ETDA). The ETDA has been designed to provide<br />
sufficient space to store tailings volumes until in-pit storage space is available.<br />
Volume Volume (Mbcm) (Mbcm)<br />
v<br />
V<br />
o<br />
L<br />
u<br />
m<br />
e<br />
M<br />
b<br />
c<br />
m<br />
Initially, the ETDA containment dykes will be constructed exclusively from<br />
overburden and mine waste material. Once operations start, course sand from<br />
extraction, together with mine waste, will be used to construct the ETDA dykes.<br />
Figure ERCB 34-1 is a conceptual example of the approximate requirement for<br />
EDTA construction material versus the amount of construction material available<br />
by year. The figure also illustrates the availability of construction material if NST<br />
production were initiated at the beginning of the project.<br />
If NST production were to start earlier than 2029, the course sand used to<br />
produce NST would not be available for ETDA construction. This material<br />
shortage would impede ETDA dyke construction resulting in insufficient tailings<br />
storage capacity.<br />
v<br />
Years<br />
Years<br />
Cumulative Cumulative Construction Construction Material Material Available Available (mine waste and coarse sand tailings)<br />
NST Cumulative Construction Material Available<br />
Cumulative Cumulative Construction Construction Material Required Available (mine waste only, coarse sand tailings<br />
used for NST)<br />
v<br />
Cumulative Construction Material Required for Tailings Containment<br />
Figure ERCB 34-1: Conceptual ETDA Construction Material Requirement<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Section 4.1<br />
NST produced at start-up, before in-pit storage is available, would require aboveground<br />
containment structures. These structures might result in areas of ore<br />
sterilization. Furthermore, the use of overburden to construct NST storage at<br />
start-up would consume construction material required to build in-pit dykes and<br />
delay construction of in-pit storage.<br />
The plan to start NST production in 2029 is based on this balance between fluid<br />
generation, material balances and the availability of in-pit storage space.<br />
Request 34b What steps does Shell plan to take to diminish these constraints?<br />
Response 34b As new information becomes available and engineering constraints change, Shell<br />
will review its mine plans with the intent of advancing NST production and<br />
accelerating reclamation. Currently, the first opportunity to begin NST<br />
production is 2029.<br />
Request 34c Confirm the sand to fines ratio listed for NST.<br />
Response 34c The May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section<br />
4.1, page 4-2, refers to the NST as produced from the tailings processing facility<br />
(SFR44 = 5:1). This ratio, which represents the limit of current pumping<br />
capability, is different from the sand to fines ratio of the orebody (SFR44 = 6.7:1).<br />
This is because coarse sand is bypassed around the NST process and placed<br />
concurrently within the NST deposit.<br />
The May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section<br />
10.1, Table 218-5, lists the sand to fines ratio of the NST deposit as deposited,<br />
and matches the SFR of the orebody.<br />
Request 34d Discuss how Shell will measure the fines captured in the NST deposit and the<br />
strength of the deposit.<br />
Response 34d Shell will collect samples of the NST in the DDA from multiple locations on an<br />
annual basis. The samples will be analyzed to determine solids content and the<br />
percentage of fine minerals solids that are finer than 44 μm. This information<br />
will be used to determine total NST inventory, including density, total mass of<br />
solids and total mass of mineral solids finer than 44 μm. The strength of the NST<br />
deposit will be determined using cone or ball penetrometer results from annual<br />
DDA surveys.<br />
Request 34e What is Shell’s mitigation strategy if fines captured in NST deposit are lower<br />
than targeted?<br />
4-36 Shell Canada Limited April 2010<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Section 4.1<br />
Response 34e If fines captured in the NST are lower than targeted, a number of options may be<br />
evaluated to address the potentially reduced fines sequestration, including:<br />
Question No. 35<br />
• amending NST production and placement practices to enhance fines capture<br />
• marginal increases in fines content of the NST slurry delivered to the DDA<br />
for deposition to accommodate for fines losses during deposition (i.e.<br />
overshoot fines target)<br />
• supplemental offsets using alternative technologies, such as atmospheric<br />
fines drying of MFT or thickened tailings deposits<br />
Request Volume 1, Section 10.1, Page 10-145, Supplemental Information Responses.<br />
Shell states, “non-segregating tailings deposits will be managed to meet the<br />
requirements of ERCB Directive 074, i.e., NST deposits will be targeted to have a<br />
minimum undrained shear strength of 5 kPa for the material deposited in the<br />
previous year, and they will be ready for reclamation within five years after<br />
active deposition has stopped. The planning basis for final NST deposits will be<br />
to have the strength, stability and structure necessary to establish a trafficable<br />
surface with minimum undrained shear strength of 10 kPa for the surface layer.”<br />
35a Elaborate on Shell’s plan to manage the NST deposit to comply with ERCB<br />
Directive 074.<br />
Response 35a Shell’s plan to manage the NST deposit to comply with ERCB Directive 074 is<br />
based on its current understanding of the technology derived from field-scale<br />
NST performance tests at its Muskeg <strong>River</strong> <strong>Mine</strong> tailings test facility. These tests<br />
also form the basis for the tailings management plans filed in accordance with<br />
Directive 074 for the Muskeg <strong>River</strong> <strong>Mine</strong> and the Jackpine <strong>Mine</strong>. Shell expects<br />
that commercial-scale demonstration of these field-scale predictions will be<br />
available before the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> NST operations start up, and that this<br />
commercial experience will be incorporated into the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> design.<br />
Request 35b What is the contingency plan if non-segregating tailings deposits do not comply<br />
with ERCB Directive 074?<br />
Response 35b Shell is confident that the non-segregating tailings deposits will meet the<br />
objectives of Directive 074, i.e. will meet the strength criteria, reduce fluid fine<br />
tailings production, and produce trafficable deposits. See the response to<br />
ERCB SIR 34e for contingencies if fines capture falls below target. If the NST<br />
deposit has a lower undrained shear strength than predicted, adaptive measures<br />
will be taken to enhance the rate of excess pore-pressure dissipation, such as<br />
April 2010 Shell Canada Limited 4-37<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Question No. 36<br />
Section 4.1<br />
enhanced drainage, i.e., wick drains, and measures to stabilize the upper surface<br />
of the deposit through the placement of capping material.<br />
Request Volume 1, Section 10.1, Page 10-166, Table 218-4, Supplemental Information<br />
Responses, indicates that TT, TSRU and NST occur within in-pit cells. Also, in<br />
Volume 1, Section 10.1, Page 10-156, Supplemental Information Responses,<br />
Shell states “If concurrent deposition of NST and TSRU is not feasible, the TSRU<br />
tailings will be deposited and managed in the fine solids settling areas.”<br />
36a Will TT and/or TSRU be co-disposed with NST in the in-pit cells? If yes, does<br />
Shell consider in-pit cells as dedicated disposal areas (DDAs)? Elaborate on the<br />
rationale. If not, update Table 218-4 to be consistent with the statement.<br />
Response 36a As discussed in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, SIR 216, the tailings deposition plan calls for the concurrent<br />
deposition of non-segregating tailings (NST) and TSRU tailings into the<br />
deposition cells. Deposition will be primarily:<br />
• subaerial for the NST tailings<br />
• subaqueous for the TSRU tailings<br />
The introduction of a small percentage of TSRU tailings into a localized area of<br />
the NST deposit (i.e., runoff collection area) will not compromise the NST<br />
deposit performance and the in-pit cells will serve the function of DDAs.<br />
Request 36b How will co-disposing TSRU tailings impact the NST deposit performance?<br />
Explain.<br />
Response 36b The TSRU tailings will be deposited in the NST runoff collection pool at the toe<br />
of the subaerial NST deposit. Coarse hydrocarbon and mineral solids will settle<br />
out rapidly and be incorporated into the NST deposit, while some fine mineral<br />
solids and water will be released into the water column and transferred with NST<br />
deposit runoff as thin fine tailings (TFT) to clarification cells. Most of the fine<br />
solids will be transferred with runoff from the NST deposit to MFT holding<br />
ponds. Therefore, NST performance is not expected to be affected.<br />
4-38 Shell Canada Limited April 2010<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Question No. 37<br />
Section 4.1<br />
Request Volume 1, Section 10.1, Page 10-156, Supplemental Information Responses.<br />
Shell states, “If asphaltene recovery operations are not initiated, the TSRU<br />
tailings will be incorporated into fluid fine tailings mixes. Some of these fluid<br />
fines tailings will be incorporated into NST and some will be stored in water<br />
capped mature fine tailings (MFT) end-pit lakes.” In Volume 1, Section 10.1,<br />
Page 10-136, Supplemental Information Responses, Shell states, “The TSRU<br />
tailings will be deposited at least 3 m below the water table in the ETDA.”<br />
37a Provide the reasons why asphaltene recovery operation may not be initiated.<br />
Response 37a The decision on whether or not to initiate asphaltene energy recovery (AER) will<br />
be based on the value assessment framework that Shell uses to test the viability<br />
of a development project proposal against changes in the investment climate over<br />
time. As discussed in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 1, Section 1, Overview, page 1-8, this assessment considers<br />
the following factors:<br />
• technical<br />
• economic<br />
• commercial<br />
• operational<br />
• regulatory<br />
This decision will balance the various risks associated with the investment. If any<br />
of these risks are considered unacceptable, then asphaltene energy recovery<br />
would not be initiated.<br />
Request 37b Provide the technical and economic analysis of asphaltene recovery of TSRU<br />
tailings; elaborate on the issues Shell has with asphaltene recovery.<br />
Response 37b As described in the response to ERCB SIR 17, Shell is still in the process of<br />
developing AER technology as part of a full technical and economic evaluation<br />
of the project. This is not done in isolation, but in the context of the overall<br />
project during detailed engineering.<br />
Request 37c Discuss the impact on the asphaltene recoverability if TSRU tailings are mixed<br />
into fluid fine tailings.<br />
Response 37c Once TSRU tailings are mixed into fluid fine tailings, subsequent separation for<br />
asphaltene recoverability would be difficult because of the nature of this finely<br />
dispersed multi-phase mixture.<br />
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MINING AND PROCESSING ERCB SIRS 3 – 38<br />
Request 37d Does Shell plan to deposit TSRU tailings separately? Discuss the option of<br />
depositing TSRU tailings separately.<br />
Section 4.1<br />
Response 37d Shell is not planning to deposit TSRU tailings separately because of the<br />
additional cost and the increased environmental footprint that would result from<br />
segregation.<br />
Question No. 38<br />
Request Volume 1, Section 10.1, Page 10-156, Supplemental Information Responses.<br />
Shell states, “The application case shows a total of 251.1 Mm 3 of MFT, whereas<br />
the no-NST case results in a total of 300.2 Mm 3 of MFT, a net increase of<br />
49.1 Mm 3 of MFT over the final 12 years from 2028 to 2039.”<br />
38a What is the volume of MFT generated per volume of bitumen production?<br />
Response 38a The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will produce 196 Mm 3 of recovered bitumen product (see<br />
the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section<br />
3.1, Table 3-1). The estimated production of mature fine tailings (MFT) is<br />
251.1 Mm 3 . Therefore, the ratio of MFT to recovered bitumen is 1.28 m 3<br />
MFT/recovered bitumen m 3 .<br />
Request 38b What constraints will prevent Shell from minimizing the fluid tailings volume?<br />
Response 38b Shell’s principal constraint in minimizing fluid tailings volume is the availability<br />
of commercially proven technology. Shell believes that the tailings management<br />
plan outlined in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Application presents a balance between<br />
minimizing fluid tailings and the limits of current technology.<br />
Request 38c What is Shell’s plan to decrease the volume of MFT per volume of bitumen<br />
production? What is the target?<br />
Response 38c Shell’s estimate of the volume of MFT generated at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is<br />
based on the original project application and subsequent updates. Although the<br />
MFT to bitumen ratio is expected to improve as experience from the Jackpine<br />
<strong>Mine</strong> operation are incorporated into the detailed design, at this point in the<br />
project development, it is difficult to make informed projections or set targets in<br />
this regard.<br />
4-40 Shell Canada Limited April 2010<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 2: ERCB SIRS – ROUND 2<br />
Question No. 39<br />
NOISE<br />
ERCB SIR 39<br />
Section 5.1<br />
Request Volume 2, Section 12.1, Page 12-1, Supplemental Information Responses.<br />
Shell states, “During detailed design, a noise management plan will be<br />
developed for the project. The plan will follow the requirements under Section<br />
5.1 of ERCB Directive 038. The program will incorporate commitments made in<br />
the EIA, plans for assessment updates or monitoring, as appropriate, and ERCB<br />
requirements for stakeholder involvement in the plan development.” “Shell will<br />
develop the project’s noise management plan, but the ERCB will have an<br />
opportunity to provide input to the plan.” “The plan is expected to be developed<br />
after detailed engineering and the associated noise control design work has been<br />
completed, before the start of construction. This will allow the plan to focus on<br />
sources of potential concern and on receptors that might be potentially affected.”<br />
39a Confirm Shells commitment to provide a revised noise impact assessment (NIA)<br />
to the ERCB based upon the detailed engineering design and associated noise<br />
control design work to verify compliance with ERCB Directive 038: Noise<br />
Control. This revised NIA would be included in the development of a noise<br />
management plan.<br />
Response 39a Shell will complete an update to the Noise Impact Assessment (NIA) at the<br />
completion of the detailed design process in order to verify compliance with<br />
ERCB Directive 038: Noise Control. The revised NIA would become part of the<br />
operations noise management plan for the project.<br />
Request 39b Confirm that the noise management plan will be submitted for ERCB review and<br />
approval as per Section 5.1.1 of ERCB Directive 038.<br />
Response 39b Shell will submit a draft of the plan for ERCB review and comment before this<br />
plan is implemented.<br />
Request 39c Identify the anticipated timeline (e.g. Q1 2010) for providing the revised NIA and<br />
proposed noise management plan to the ERCB.<br />
April 2010 Shell Canada Limited 5-1<br />
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NOISE ERCB SIR 39<br />
Section 5.1<br />
Response 39c The plan is expected to be developed after detailed engineering and the<br />
associated noise control design work has been completed, before the start of<br />
construction. This will allow the plan to focus on sources of potential concern<br />
and on receptors that might be potentially affected. Given current plans, the<br />
anticipated timeline for completion of the updated Noise Impact Assessment and<br />
the draft Noise Management Plan is two years prior to start up of operations.<br />
5-2 Shell Canada Limited April 2010<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 2: ERCB SIRS – ROUND 2<br />
Question No. 40<br />
AIR<br />
ERCB SIRS 40 – 45<br />
Section 6.1<br />
Request Volume 1, Section 11.1, Page 11-30, Supplemental Information Responses.<br />
In relation to redundant SO2 pollution control equipment Shell states,“The<br />
current design has an estimated component availability of above 99%.”<br />
40a Provide the overall annual Wet Flue Gas Desulphurizer (WFGD) unit<br />
availability when all the component availabilities are factored in.<br />
Response 40a Each section of the wet flue gas desulphurizer (WFGD) includes spare major<br />
equipment that is critical to ensuring sustained operation of the unit. Sparing the<br />
critical equipment results in a high on-stream factor for the WFGD. The current<br />
design has an estimated component availability of above 99%. The overall<br />
WFGD on-stream availability is expected to be at least the same.<br />
Request 40b Discuss implications to the air assessment if the availability is less than 99%.<br />
Response 40b EIA, Volume 3, Appendix 3-8, Section 4.3, provides the air quality and health<br />
risk assessment for an upset scenario in which the asphaltene-fired cogeneration<br />
unit pollution control equipment malfunctions. Additional information on this<br />
scenario is also provided in the response to SIR 250 in the May 2009 <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong>, Supplemental Information, Volume 2, Section 20.<br />
In summary, the predicted maximum 1-hour sulphur dioxide (SO2)<br />
concentrations for this upset scenario are greater than the Alberta Ambient Air<br />
Quality Objective (AAAQO) of 450 µg/m³. The likelihood of exceeding the<br />
AAAQO outside developed areas during an event is 3.8%. This does not take<br />
into account the likelihood of the event actually occurring. The maximum<br />
predicted 1-hour SO2 concentrations are above the AAAQO at Cabins H and K<br />
with a likelihood of exceedance of 0.07% and 0.06%, respectively. While these<br />
concentrations are high and could result in adverse health effects, the likelihood<br />
of this upset event occurring is low, as Shell has committed to redundant SO2<br />
pollution control equipment. In addition, the duration of these impacts is<br />
expected to be brief, because if the pollution control equipment were to fail,<br />
operations personnel would react quickly and switch the fuel for the asphaltenefired<br />
cogeneration unit to natural gas within 15 minutes.<br />
April 2010 Shell Canada Limited 6-1<br />
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AIR ERCB SIRS 40 – 45<br />
Question No. 41<br />
Section 6.1<br />
Request Volume 1, Section 11.1, Page 11-28, Supplemental Information Responses.<br />
Shell states, “A cold period is when additional thermal energy is required to<br />
provide heat inputs to oil sands feed and recycle water. Typically, this additional<br />
thermal energy will be provided by the co-generation units. However, during<br />
extreme winter conditions, or if there is capacity constraints as a result of<br />
undefined downtime of the co-generation unit, then one or more of the auxiliary<br />
boilers will be brought into service. Currently, historical data is not available to<br />
determine how frequently this backup heat generation will be required. Some of<br />
the main factors that define the cold period (or winter conditions) are:<br />
• oils sands feed temperatures being below 0°C<br />
• raw water and reclaim water makeup at, or below, 2°C<br />
• recycle pond temperatures below 5°C”<br />
41a Provide a discussion whereby Shell utilizes historical temperature records and<br />
its experience at the Muskeg <strong>River</strong> <strong>Mine</strong> and Jackpine <strong>Mine</strong> Phase-1 operations.<br />
Provide a conservative estimate for how often on an annual basis the main<br />
factors described above would be met.<br />
Response 41a In the EIA and in the May 2008 EIA Update, Shell conducted an air quality<br />
assessment, which reflected the continuous air emissions expected for both the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and the Jackpine <strong>Mine</strong> Expansion projects. Shell premised the<br />
air quality assessment on the intermittent use of auxiliary boilers to supplement<br />
heat during cold periods. This premise has raised concerns that the air quality<br />
assessment for the projects might not be conservative if Shell is required to fire<br />
its auxiliary boilers more than currently expected.<br />
To provide assurance that potential air quality effects resulting from the projects<br />
are not understated, Shell is providing an air quality assessment of an alternative<br />
emissions scenario (see the response to ERCB SIR 41b). This alternative<br />
emissions scenario conservatively assumes that all of the projects’ auxiliary<br />
boilers are in continuous use.<br />
Shell does not capture historical data on all of the main factors which define the<br />
cold period and, consequently, the amount of time that the temporary boilers<br />
would need to be fired. In addition, the need to fire these boilers is influenced by<br />
other factors, some of which are not directly linked to ambient air conditions.<br />
As an alternative emissions scenario was assessed to indicate the potential<br />
impacts of firing auxiliary boilers continuously throughout a full year, a<br />
discussion of the factors that would dictate auxiliary boiler use is unnecessary, as<br />
impacts from this more conservative alternative emissions scenario do not change<br />
the EIA’s air quality impact assessment conclusions, as discussed in the response<br />
to ERCB SIR 41b.<br />
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AIR ERCB SIRS 40 – 45<br />
Request 41b Based on the response above, how would the air assessment change if the<br />
additional thermal energy requirements would be met by additional boilers<br />
running at the same time as the co-generation units?<br />
Section 6.1<br />
Response 41b The conclusions of the air quality impact assessment do not change if the<br />
auxiliary boilers at the Jackpine <strong>Mine</strong> Expansion and the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> are<br />
assumed to be in continuous use.<br />
To assess the effect of the additional auxiliary boilers on the air quality<br />
assessment, the boiler emissions sources were added to the Application Case<br />
emissions and modelled according to the methodology outlined in the EIA (see<br />
EIA, Volume 3, Appendix 3-8, Section 2). The updated project emissions,<br />
including the additional auxiliary boilers, are presented in Table ERCB 41-1.<br />
Table ERCB 41-1: <strong>Project</strong> Emissions Summary including Additional Auxiliary Boilers<br />
Source<br />
Jackpine <strong>Mine</strong> Expansion<br />
Stream-<br />
Day<br />
SO2<br />
(t/sd)<br />
Calendar-<br />
Day SO2<br />
(t/cd)<br />
Emission Rates<br />
Change to Jackpine <strong>Mine</strong> – Phase 1 (a) -0.30 -0.30 -6.71 -1.60 -0.37 -0.78 0.00<br />
Addition of Jackpine <strong>Mine</strong> Expansion (b) 4.08 4.08 6.45 7.75 0.31 8.79 0.07<br />
Subtotal (c) 3.78 3.78 -0.26 6.15 -0.06 8.01 0.07<br />
Addition of Auxiliary Boilers (d) 0.02 0.02 1.25 2.03 0.18 0.13 —<br />
New Total with Auxiliary Boilers (c) 3.80 3.80 0.98 8.17 0.12 8.15 0.07<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
Total (e) 4.10 4.10 12.45 13.31 0.51 17.39 0.14<br />
Addition of Auxiliary Boilers (d) 0.02 0.02 1.25 2.03 0.18 0.13 —<br />
New Total with Auxiliary Boilers (c) 4.11 4.11 13.70 15.34 0.69 17.52 0.14<br />
<strong>Project</strong> Total (c) 7.91 7.91 14.68 23.51 0.81 25.66 0.22<br />
Note:<br />
(a) Emissions from EIA, Volume 3, Appendix 3-8, Table 31 and expressed as tonnes per stream-day [t/sd], tonnes per calendar-day [t/cd]<br />
or tonnes per day [t/d]. The change is calculated in EIA, Volume 3, Appendix 3-8, Table 30 and represents the difference between the<br />
updated Jackpine <strong>Mine</strong> – Phase 1 and the Base Case Jackpine <strong>Mine</strong> – Phase 1.<br />
(b) Emissions from EIA, Volume 3, Appendix 3-8, Table 31.<br />
(c) Some numbers are rounded for presentation purposes. Therefore, it may appear that the totals do not equal the sum of the individual<br />
values.<br />
(d) The emissions displayed assume all three boilers in service. This represents a conservative winter operations scenario.<br />
(e) Emissions from EIA, Volume 3, Appendix 3-8, Table 36.<br />
April 2010 Shell Canada Limited 6-3<br />
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NOx<br />
(t/d)<br />
CO<br />
(t/d)<br />
PM2.5<br />
(t/d)<br />
VOC<br />
(t/d)<br />
Table ERCB 41-2 shows a comparison of regional sulphur dioxide (SO2)<br />
predictions for the Application Case and the Application Plus Boilers Case. A<br />
comparison of the regional nitrogen dioxide (NO2) predictions for the same cases<br />
is shown in Table ERCB 41-3. Note that the results for both cases do not include<br />
the Fort McKay Lease, according to the May 2008 EIA Update. The SO2<br />
TRS<br />
(t/d)
AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
predictions do not increase as a result of adding the auxiliary boiler emissions.<br />
Only the annual NO2 predictions increase minimally.<br />
Table ERCB 41-2: Comparison of Regional SO2 Predictions<br />
EIA Update<br />
(May 2008)<br />
Application<br />
Case<br />
Application<br />
Case Plus<br />
Boilers<br />
Change<br />
Due to<br />
Boilers (a)<br />
Parameter<br />
Local Study Area<br />
maximum 1-hour SO2 (excluding developed areas) (b)(c) (µg/m³) 74.1 74.1 0.0<br />
occurrences above 1-hour AAAQO (d)(e) 0 0 0<br />
area above 1-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
peak 24-hour SO2 (excluding developed areas) (b)(c) (µg/m³) 47.9 47.9 0.0<br />
occurrences above 24-hour AAAQO (d)(e) 0 0 0<br />
area above 24-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
annual average SO2 (excluding developed areas) (b)(c) (µg/m³) 5.6 5.6 0.0<br />
occurrences above annual AAAQO (d)(e) 0 0 0<br />
area above annual AAAQO (excluding developed areas) (c)(d) (ha)<br />
Regional Study Area excluding Local Study Area<br />
0 0 0<br />
maximum 1-hour SO2 (excluding developed areas) (b)(c) (µg/m³) 275.8 275.8 0.0<br />
occurrences above 1-hour AAAQO (d)(e) 0 0 0<br />
area above 1-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
peak 24-hour SO2 (excluding developed areas) (b)(c) (µg/m³) 143.9 143.9 0.0<br />
occurrences above 24-hour AAAQO (d)(e) 0 0 0<br />
area above 24-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
annual average SO2 (excluding developed areas) (b)(c) [µg/m³] 11.6 11.6 0.0<br />
occurrences above annual AAAQO (d)(e) 0 0 0<br />
area above annual AAAQO (excluding developed areas) (c)(d) [ha] 0 0 0<br />
Regional Study Area<br />
maximum 1-hour SO2 (excluding developed areas) (b)(c) (µg/m³) 275.8 275.8 0.0<br />
occurrences above 1-hour AAAQO (d)(e) 0 0 0<br />
area above 1-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
peak 24-hour SO2 (excluding developed areas) (b)(c) (µg/m³) 143.9 143.9 0.0<br />
occurrences above 24-hour AAAQO (d)(e) 0 0 0<br />
area above 24-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
annual average SO2 (excluding developed areas) (b)(c) (µg/m³) 11.6 11.6 0.0<br />
occurrences above annual AAAQO (d)(e) 0 0 0<br />
area above annual AAAQO (excluding developed areas) (c)(d) (ha)<br />
Note:<br />
0 0 0<br />
(a) Although the modelling predictions in the table have been rounded for presentation purposes, the changes were calculated<br />
directly from model outputs. Therefore, it is feasible to show small changes without an apparent change in the listed<br />
concentrations.<br />
(b) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model guidelines<br />
(AENV 2003).<br />
(c) Developed areas include the <strong>Project</strong> Development Area and existing and approved open pit mines and upgrading complexes<br />
within the regional study area (RSA) and local study area (LSA).<br />
(d) The 1-hour, 24-hour and annual Alberta Ambient Air Quality Objectives for SO2 are 450, 150 and 30 µg/m³, respectively.<br />
(e) The number of occurrences is based on the concentrations outside of developed areas.<br />
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AIR ERCB SIRS 40 – 45<br />
Table ERCB 41-3: Comparison of Regional NO2 Predictions<br />
EIA Update<br />
(May 2008)<br />
Application<br />
Case<br />
Application<br />
Case Plus<br />
Boilers<br />
Section 6.1<br />
Change<br />
Due to<br />
Boilers (a)<br />
Parameter<br />
Local Study Area<br />
maximum 1-hour NO2 (excluding developed areas) (b)(c) (µg/m³) 189.9 189.9 0.0<br />
occurrences above 1-hour AAAQO (d)(e) 0 0 0<br />
area above 1-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
peak 24-hour NO2 (excluding developed areas) (b)(c) (µg/m³) 183.3 183.3 0.0<br />
occurrences above 24-hour AAAQO (d)(e) 0 0 0<br />
area above 24-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
annual average NO2 (excluding developed areas) (b)(c) (µg/m³) 46.4 46.5 0.1<br />
occurrences above annual AAAQO (d)(e) 0 0 0<br />
area above annual AAAQO (d) (excluding developed areas) (ha)<br />
Regional Study Area excluding Local Study Area<br />
0 0 0<br />
maximum 1-hour NO2 (excluding developed areas) (b)(c) (µg/m³) 285.4 285.4 0.0<br />
occurrences above 1-hour AAAQO (d)(e) 0 0 0<br />
area above 1-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
peak 24-hour NO2 (excluding developed areas) (b)(c) (µg/m³) 264.9 264.9 0.0<br />
occurrences above 24-hour AAAQO (d)(e) 3 3 0<br />
area above 24-hour AAAQO (excluding developed areas) (c)(d) (ha) 1,800 1,800 0<br />
annual average NO2 (excluding developed areas) (b)(c) (µg/m³) 65.7 65.7 0.0<br />
occurrences above annual AAAQO (d)(e) 1 1 0<br />
area above annual AAAQO (d) (excluding developed areas) (ha) 626 627 1<br />
Regional Study Area<br />
maximum 1-hour NO2 (excluding developed areas) (b)(c) (µg/m³) 285.4 285.4 0.0<br />
occurrences above 1-hour AAAQO (d)(e) 0 0 0<br />
area above 1-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0<br />
peak 24-hour NO2 (excluding developed areas) (b)(c) (µg/m³) 264.9 264.9 0.0<br />
occurrences above 24-hour AAAQO (d)(e) 3 3 0<br />
area above 24-hour AAAQO (excluding developed areas) (c)(d) (ha) 1,800 1,800 0<br />
annual average NO2 (excluding developed areas) (b)(c) (µg/m³) 65.7 65.7 0.0<br />
occurrences above annual AAAQO (d)(e) 1 1 0<br />
area above annual AAAQO (d) (excluding developed areas) (ha)<br />
Note:<br />
626 627 1<br />
(a) Although the modelling predictions in the table have been rounded for presentation purposes, the changes were calculated<br />
directly from model outputs. Therefore, it is feasible to show small changes without an apparent change in the listed<br />
concentrations.<br />
(b) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model guidelines<br />
(AENV 2003).<br />
(c) Developed areas include the <strong>Project</strong> Development Area and existing and approved open pit mines and upgrading complexes<br />
within the regional study area (RSA) and local study area (LSA).<br />
(d) The 1-hour, 24-hour and annual Alberta Ambient Air Quality Objectives for NO2 are 400, 200 and 60 µg/m³, respectively.<br />
(e) The number of occurrences is based on the concentrations outside of developed areas.<br />
April 2010 Shell Canada Limited 6-5<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Tables ERCB 41-4 through ERCB 41-9 show the comparison of SO2, NO2,<br />
carbon monoxide (CO), benzene, other select volatile organic compounds<br />
(VOCs) and PM2.5 predictions at regional communities. Note that the VOC<br />
predictions are based on the revised external tailings disposal area speciation, as<br />
discussed in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, Section 7.2. The results indicate that the boiler emissions do not cause<br />
any material increases in predicted concentrations within regional communities.<br />
The decrease in the 1-hour NO2 maximum concentration at Anzac is due to the<br />
use of different oxides of nitrogen (NOX) to NO2 conversion method. As<br />
discussed in Appendix 3-8, Section 2.3.5 of the EIA, the ambient mine ratio<br />
method was used to calculate NO2 concentrations when the NOX concentration<br />
exceeded 0.03 ppm. The 1-hour maximum NOX concentration at Anzac was<br />
slightly lower than the 0.03 ppm threshold in the Application Case; however,<br />
when the boiler emissions were added, the maximum 1-hour NOX concentration<br />
was consequently above 0.03 ppm and the ambient ratio method was triggered.<br />
This resulted in a lower predicted NO2 concentration at that particular location.<br />
6-6 Shell Canada Limited April 2010<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Community<br />
Table ERCB 41-4: Comparison of SO2 Predictions in Regional Communities<br />
Application<br />
Case (µg/m³)<br />
Maximum 1-Hour SO2 (a)(b) Peak 24-Hour SO2 (a)(b) 2 (a)(b)<br />
Peak Annual SO<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Application<br />
Case (µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Application<br />
Case (µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Section 6.1<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Anzac 46.4 46.4 0.0 22.7 22.7 0.0 3.4 3.4 0.0<br />
Conklin 20.9 20.9 0.0 11.5 11.5 0.0 1.2 1.2 0.0<br />
Fort Chipewyan 15.2 15.2 0.0 9.5 9.5 0.0 0.6 0.6 0.0<br />
Fort McKay 84.5 84.5 0.0 24.3 24.3 0.0 4.2 4.2 0.0<br />
Fort McMurray 48.1 48.1 0.0 17.3 17.3 0.0 3.0 3.0 0.0<br />
Janvier/Chard (IR 194) 28.3 28.3 0.0 14.4 14.4 0.0 1.6 1.6 0.0<br />
Clearwater (IR 175) 31.4 31.4 0.0 12.2 12.2 0.0 1.9 1.9 0.0<br />
Namur <strong>River</strong> (IR 174A) 29.9 29.9 0.0 13.5 13.5 0.0 1.1 1.1 0.0<br />
Poplar Point (IR 201G) 25.3 25.3 0.0 13.3 13.3 0.0 1.3 1.3 0.0<br />
Cabin A 38.6 38.7 0.1 16.4 16.4 0.0 2.1 2.1 0.0<br />
Cabin B 27.0 27.0 0.0 13.1 13.1 0.0 1.7 1.7 0.0<br />
Cabin C 37.4 37.4 0.0 14.2 14.2 0.0 2.1 2.1 0.0<br />
Cabin D 39.5 39.5 0.0 15.2 15.2 0.0 2.2 2.2 0.0<br />
Cabin E 35.4 35.4 0.0 14.3 14.3 0.0 2.3 2.3 0.0<br />
Cabin F 37.7 37.7 0.0 15.4 15.4 0.0 2.4 2.4 0.0<br />
Cabin G 28.6 28.6 0.0 12.4 12.4 0.0 2.4 2.4 0.0<br />
Cabin H 46.0 46.0 0.0 29.1 29.1 0.0 3.1 3.1 0.0<br />
Cabin I 62.6 62.6 0.0 25.4 25.4 0.0 3.8 3.8 0.0<br />
Cabin J 98.2 98.2 0.0 44.2 44.2 0.0 5.9 5.9 0.0<br />
Cabin K 64.9 64.9 0.0 27.8 27.8 0.0 4.2 4.2 0.0<br />
Cabin L 51.3 51.3 0.0 20.3 20.3 0.0 3.2 3.2 0.0<br />
Descharme Lake, SK 15.4 15.4 0.0 6.7 6.7 0.0 1.0 1.0 0.0<br />
La Loche, SK 15.6 15.6 0.0 9.6 9.6 0.0 1.1 1.1 0.0<br />
Oil Sands Lodge 68.3 68.3 0.0 25.7 25.7 0.0 4.6 4.6 0.0<br />
PTI Camp 104.7 104.7 0.0 32.4 32.4 0.0 4.5 4.5 0.0<br />
Note:<br />
(a) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model guidelines (AENV 2003). The eight highest 1-hour predictions were not excluded from<br />
the peak 24-hour and annual values.<br />
(b) The 1-hour, 24-hour and annual AAAQOs for SO2 are 450, 150 and 30 µg/m³, respectively (AENV 2009).<br />
April 2010 Shell Canada Limited 6-7<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Community<br />
Table ERCB 41-5: Comparison of NO2 Predictions in Regional Communities<br />
Application<br />
Case<br />
(µg/m³)<br />
Maximum 1-Hour NO2 (a)(b)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Application<br />
Case<br />
(µg/m³)<br />
Peak 24-Hour NO2 (a)(b) Peak Annual NO2 (a)(b)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Application<br />
Case<br />
(µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Section 6.1<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Anzac 79.0 77.9 -1.1 42.6 42.6 0.0 6.3 6.3 0.0<br />
Conklin 85.0 85.0 0.0 39.3 39.4 0.1 3.8 3.8 0.0<br />
Fort Chipewyan 63.5 63.9 0.3 33.0 33.1 0.1 2.9 3.0 0.0<br />
Fort McKay 116.7 116.7 0.0 88.9 88.9 0.0 28.1 28.1 0.0<br />
Fort McMurray 100.8 100.8 0.0 78.3 78.4 0.1 20.8 20.8 0.0<br />
Janvier/Chard (IR 194) 58.0 58.1 0.0 24.2 24.3 0.1 3.9 3.9 0.0<br />
Clearwater (IR 175) 54.7 54.8 0.2 34.9 34.9 0.0 4.6 4.6 0.0<br />
Namur <strong>River</strong> (IR 174A) 45.2 45.3 0.1 29.8 29.9 0.1 2.2 2.2 0.0<br />
Poplar Point (IR 201G) 55.8 55.7 0.0 46.5 46.7 0.2 6.5 6.5 0.0<br />
Cabin A 81.7 81.7 0.0 64.0 64.1 0.1 14.2 14.3 0.1<br />
Cabin B 72.1 72.1 0.0 57.0 57.1 0.1 10.6 10.6 0.0<br />
Cabin C 82.1 82.1 0.0 65.1 65.2 0.1 13.7 13.8 0.1<br />
Cabin D 88.0 88.0 0.0 68.2 68.3 0.1 15.2 15.3 0.1<br />
Cabin E 81.1 81.1 0.0 65.4 65.4 0.0 14.6 14.6 0.1<br />
Cabin F 83.2 83.2 0.0 67.8 67.8 0.0 15.4 15.5 0.1<br />
Cabin G 101.9 101.9 0.0 75.5 75.6 0.0 14.8 14.8 0.0<br />
Cabin H 102.4 102.4 0.0 72.7 72.7 0.0 17.5 17.6 0.1<br />
Cabin I 122.4 122.4 0.0 95.0 95.0 0.0 28.7 28.7 0.0<br />
Cabin J 165.5 165.5 0.0 127.9 127.9 0.0 34.7 34.8 0.1<br />
Cabin K 151.3 151.3 0.0 112.4 112.4 0.0 32.0 32.1 0.1<br />
Cabin L 108.4 108.4 0.0 83.1 83.1 0.0 23.0 23.2 0.2<br />
Descharme Lake, SK 21.3 21.6 0.3 11.3 11.5 0.2 1.5 1.5 0.0<br />
La Loche, SK 49.8 49.9 0.1 21.9 22.0 0.1 3.4 3.4 0.0<br />
Oil Sands Lodge 133.5 133.6 0.0 93.2 93.2 0.1 30.4 30.4 0.0<br />
PTI Camp 94.5 94.5 0.0 67.8 67.9 0.1 24.0 24.0 0.0<br />
Note:<br />
(a) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model guidelines (AENV 2003). The eight highest 1-hour predictions were not excluded from<br />
the peak 24-hour and annual values.<br />
(b) The 1-hour, 24-hour and annual AAAQOs for NO2 are 400, 200 and 60 µg/m³, respectively (AENV 2009).<br />
April 2010 Shell Canada Limited 6-8<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Community<br />
Table ERCB 41-6: Comparison of CO Predictions in Regional Communities<br />
Application<br />
Case<br />
(µg/m³)<br />
Peak 1-Hour CO (a)(b) Peak 8-Hour CO (a)(b)<br />
Application<br />
Case Plus Boilers<br />
(µg/m³)<br />
Change Due to<br />
Boilers (c)<br />
(µg/m³)<br />
Application<br />
Case<br />
(µg/m³)<br />
Application<br />
Case Plus Boilers<br />
(µg/m³)<br />
Change Due to<br />
Boilers (c)<br />
(µg/m³)<br />
Anzac 989.4 990.9 1.5 586.0 587.6 1.6<br />
Conklin 336.1 336.1 0.0 189.1 189.1 0.0<br />
Fort Chipewyan 379.7 380.1 0.4 230.3 230.6 0.3<br />
Fort McKay 1,079.8 1,079.9 0.1 643.3 643.8 0.4<br />
Fort McMurray 5,052.9 5,052.9 0.0 2,362.6 2,362.6 0.0<br />
Janvier/Chard (IR 194) 423.9 424.6 0.8 258.2 258.9 0.7<br />
Clearwater (IR 175) 204.4 204.4 0.0 158.6 159.1 0.5<br />
Namur <strong>River</strong> (IR 174A) 86.9 87.0 0.1 81.4 81.5 0.1<br />
Poplar Point (IR 201G) 212.5 212.6 0.1 140.2 141.3 1.1<br />
Cabin A 307.3 307.3 0.0 254.2 254.3 0.1<br />
Cabin B 282.4 282.4 0.1 236.9 236.9 0.0<br />
Cabin C 347.1 347.1 0.1 282.9 283.0 0.1<br />
Cabin D 388.0 388.0 0.1 315.1 315.1 0.1<br />
Cabin E 371.4 371.4 0.0 288.5 288.6 0.1<br />
Cabin F 376.0 376.0 0.0 287.5 287.6 0.1<br />
Cabin G 584.4 584.4 0.0 414.5 414.5 0.0<br />
Cabin H 436.0 436.3 0.4 325.1 325.3 0.2<br />
Cabin I 488.6 488.6 0.0 305.4 305.4 0.0<br />
Cabin J 1,016.9 1,016.9 0.0 707.0 707.0 0.0<br />
Cabin K 1,212.1 1,212.1 0.0 714.3 714.3 0.0<br />
Cabin L 550.8 550.8 0.0 395.7 395.8 0.0<br />
Descharme Lake, SK 36.1 36.4 0.3 24.9 25.2 0.3<br />
La Loche, SK 500.2 501.3 1.1 289.4 290.0 0.6<br />
Oil Sands Lodge 914.4 914.4 0.0 610.0 611.6 1.6<br />
PTI Camp 518.5 518.6 0.1 276.4 276.8 0.4<br />
Note:<br />
(a) The peak concentrations include the highest 1-hour predictions from the CALPUFF model.<br />
(b) The 1-hour and 8-hour AAAQOs for CO are 15,000 and 6,000 µg/m³, respectively (AENV 2009). There is no annual AAAQO for CO.<br />
(c) Although the modelling predictions in the above table have been rounded for presentation purposes, the changes were calculated directly from model outputs.<br />
Therefore, it is possible to show small changes without an apparent change in the listed concentrations.<br />
Section 6.1<br />
April 2010 Shell Canada Limited 6-9<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Table ERCB 41-7: Comparison of Benzene Predictions In Regional Communities<br />
Maximum 1-Hour Benzene (a)(b)<br />
Application<br />
Case<br />
Application<br />
Case Plus<br />
Boilers<br />
Change Due<br />
to Boilers<br />
Community<br />
(µg/m³) (µg/m³)<br />
(c)<br />
(µg/m³)<br />
Anzac 1.4 1.4 0.0<br />
Conklin 0.3 0.3 0.0<br />
Fort Chipewyan 1.6 1.6 0.0<br />
Fort McKay 4.9 4.9 0.0<br />
Fort McMurray 28.6 28.6 0.0<br />
Janvier/Chard (IR 194) 0.3 0.3 0.0<br />
Clearwater (IR 175) 1.0 1.0 0.0<br />
Namur <strong>River</strong> (IR 174A) 0.6 0.6 0.0<br />
Poplar Point (IR 201G) 0.7 0.7 0.0<br />
Cabin A 2.4 2.4 0.0<br />
Cabin B 1.1 1.1 0.0<br />
Cabin C 1.6 1.6 0.0<br />
Cabin D 1.9 1.9 0.0<br />
Cabin E 1.5 1.5 0.0<br />
Cabin F 1.5 1.5 0.0<br />
Cabin G 2.4 2.4 0.0<br />
Cabin H 2.4 2.4 0.0<br />
Cabin I 2.9 2.9 0.0<br />
Cabin J 6.5 6.5 0.0<br />
Cabin K 6.0 6.0 0.0<br />
Cabin L 2.6 2.6 0.0<br />
Descharme Lake, SK 0.2 0.2 0.0<br />
La Loche, SK 1.4 1.4 0.0<br />
Oil Sands Lodge 4.1 4.1 0.0<br />
PTI Camp 8.8 8.8 0.0<br />
Note:<br />
(a) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta<br />
model guidelines (AENV 2003).<br />
(b) The 1-hour AAAQO for benzene is 30 µg/m³ (AENV 2009). There are no 24-hour or annual<br />
AAAQOs for benzene.<br />
(c) Although the modelling predictions in the table have been rounded for presentation purposes, the<br />
changes between Base Case and Application Case predictions were calculated directly from<br />
model outputs. Therefore, it is possible to show small changes without an apparent change in the<br />
listed concentrations.<br />
6-10 Shell Canada Limited April 2010<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Table ERCB 41-8: Comparison of Select VOC Predictions In Regional Communities<br />
Parameter *<br />
Application<br />
Case<br />
(µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Application<br />
Case<br />
(µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Anzac Conklin<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Maximum 1-hour acrolein 0.1416 0.1416 0.0000 0.1825 0.1825 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0122 0.0122 0.0000 0.0080 0.0080 0.0000<br />
1.3705 1.3705 0.0000 0.3145 0.3145 0.0000<br />
Peak 1-hour cyclohexane 2.7583 2.7583 0.0000 0.5123 0.5123 0.0000<br />
Peak annual cyclohexane<br />
0.0505 0.0505 0.0000 0.0114 0.0114 0.0000<br />
Peak 1-hour ethylbenzene 1.1342 1.1342 0.0000 0.2224 0.2224 0.0000<br />
Peak 1-hour xylenes<br />
7.2387 7.2387 0.0000 1.3596 1.3596 0.0000<br />
Fort Chipewyan Fort McKay<br />
Maximum 1-hour acrolein 0.1081 0.1081 0.0000 1.2509 1.2509 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0134 0.0134 0.0000 0.0943 0.0943 0.0000<br />
1.6217 1.6217 0.0000 4.9343 4.9343 0.0000<br />
Peak 1-hour cyclohexane 0.9516 0.9516 0.0000 23.4510 23.4510 0.0000<br />
Peak annual cyclohexane<br />
0.0213 0.0213 0.0000 1.1659 1.1659 0.0000<br />
Peak 1-hour ethylbenzene 0.4201 0.4201 0.0000 8.1807 8.1807 0.0000<br />
Peak 1-hour xylenes<br />
2.6227 2.6227 0.0000 58.3880 58.3880 0.0000<br />
Fort McMurray Janvier/Chard (IR 194)<br />
Maximum 1-hour acrolein 0.8831 0.8831 0.0000 0.0624 0.0624 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0668 0.0668 0.0000 0.0042 0.0042 0.0000<br />
28.6070 28.6070 0.0000 0.3330 0.3330 0.0000<br />
Peak 1-hour cyclohexane 7.9311 7.9311 0.0000 1.3779 1.3779 0.0000<br />
Peak annual cyclohexane<br />
0.1636 0.1636 0.0000 0.0191 0.0191 0.0000<br />
Peak 1-hour ethylbenzene 2.6672 2.6672 0.0000 0.5738 0.5738 0.0000<br />
Peak 1-hour xylenes<br />
19.5410 19.5410 0.0000 3.6065 3.6065 0.0000<br />
Clearwater (IR 175) Namur <strong>River</strong> (IR 174A)<br />
Maximum 1-hour acrolein 0.2323 0.2323 0.0000 0.1729 0.1729 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0110 0.0110 0.0000 0.0053 0.0053 0.0000<br />
1.0425 1.0425 0.0000 0.5878 0.5878 0.0000<br />
Peak 1-hour cyclohexane 3.6945 3.6945 0.0000 4.3907 4.3907 0.0000<br />
Peak annual cyclohexane<br />
0.0981 0.0981 0.0000 0.0560 0.0560 0.0000<br />
Peak 1-hour ethylbenzene 1.6727 1.6727 0.0000 1.5439 1.5439 0.0000<br />
Peak 1-hour xylenes<br />
9.8334 9.8334 0.0000 11.0820 11.0820 0.0000<br />
Poplar Point (IR 201G) Cabin A<br />
Maximum 1-hour acrolein 0.3084 0.3084 0.0000 0.6509 0.6509 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0148 0.0148 0.0000 0.0371 0.0371 0.0000<br />
0.7219 0.7219 0.0000 2.3595 2.3595 0.0000<br />
Peak 1-hour cyclohexane 3.3043 3.3043 0.0000 7.2422 7.2422 0.0000<br />
Peak annual cyclohexane<br />
0.1098 0.1098 0.0000 0.2733 0.2733 0.0000<br />
Peak 1-hour ethylbenzene 1.9207 1.9207 0.0000 3.4084 3.4084 0.0000<br />
Peak 1-hour xylenes<br />
8.6544 8.6544 0.0000 19.2460 19.2460 0.0000<br />
Cabin B Cabin C<br />
Maximum 1-hour acrolein 0.5939 0.5939 0.0000 0.7494 0.7494 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0280 0.0280 0.0000 0.0366 0.0366 0.0000<br />
1.0684 1.0684 0.0000 1.5974 1.5974 0.0000<br />
Peak 1-hour cyclohexane 5.2813 5.2813 0.0000 7.8124 7.8124 0.0000<br />
Peak annual cyclohexane<br />
0.1653 0.1653 0.0000 0.2621 0.2621 0.0000<br />
Peak 1-hour ethylbenzene 2.8170 2.8170 0.0000 3.6639 3.6639 0.0000<br />
Peak 1-hour xylenes<br />
14.6840 14.6840 0.0000 20.9310 20.9310 0.0000<br />
April 2010 Shell Canada Limited 6-11<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Table ERCB 41-8: Comparison of Select VOC Predictions In Regional Communities<br />
(cont’d)<br />
Parameter *<br />
Application<br />
Case<br />
(µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Application<br />
Case<br />
(µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Cabin D Cabin E<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Maximum 1-hour acrolein 0.7998 0.7998 0.0000 0.8602 0.8602 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0424 0.0424 0.0000 0.0437 0.0437 0.0000<br />
1.8764 1.8764 0.0000 1.4738 1.4738 0.0000<br />
Peak 1-hour cyclohexane 8.2120 8.2120 0.0000 7.9475 7.9475 0.0000<br />
Peak annual cyclohexane<br />
0.2990 0.2990 0.0000 0.2749 0.2749 0.0000<br />
Peak 1-hour ethylbenzene 3.9397 3.9397 0.0000 3.8848 3.8848 0.0000<br />
Peak 1-hour xylenes<br />
21.9530 21.9530 0.0000 21.3330 21.3330 0.0000<br />
Cabin F Cabin G<br />
Maximum 1-hour acrolein 0.8390 0.8390 0.0000 1.1758 1.1758 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0476 0.0476 0.0000 0.0547 0.0547 0.0000<br />
1.5323 1.5323 0.0000 2.3663 2.3663 0.0000<br />
Peak 1-hour cyclohexane 7.9440 7.9440 0.0000 5.1865 5.1865 0.0000<br />
Peak annual cyclohexane<br />
0.2987 0.2987 0.0000 0.2235 0.2235 0.0000<br />
Peak 1-hour ethylbenzene 3.9383 3.9383 0.0000 4.5595 4.5595 0.0000<br />
Peak 1-hour xylenes<br />
21.2780 21.2780 0.0000 19.9120 19.9120 0.0000<br />
Cabin H Cabin I<br />
Maximum 1-hour acrolein 0.7509 0.7509 0.0000 1.1099 1.1099 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0505 0.0505 0.0000 0.0884 0.0884 0.0000<br />
2.3907 2.3907 0.0000 2.9475 2.9475 0.0000<br />
Peak 1-hour cyclohexane 21.4590 21.4590 0.0000 12.7600 12.7600 0.0000<br />
Peak annual cyclohexane<br />
0.3854 0.3854 0.0000 0.6299 0.6299 0.0000<br />
Peak 1-hour ethylbenzene 7.9662 7.9662 0.0000 5.0327 5.0327 0.0000<br />
Peak 1-hour xylenes<br />
52.6840 52.6840 0.0000 32.9590 32.9590 0.0000<br />
Cabin J Cabin K<br />
Maximum 1-hour acrolein 2.3607 2.3607 0.0000 1.9498 1.9498 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.1426 0.1426 0.0000 0.1222 0.1222 0.0000<br />
6.4745 6.4745 0.0000 5.9531 5.9531 0.0000<br />
Peak 1-hour cyclohexane 55.4010 55.4010 0.0000 43.6900 43.6900 0.0000<br />
Peak annual cyclohexane<br />
0.9824 0.9824 0.0000 0.9190 0.9190 0.0000<br />
Peak 1-hour ethylbenzene 20.0700 20.0700 0.0000 21.6250 21.6250 0.0000<br />
Peak 1-hour xylenes<br />
141.1200 141.1200 0.0000 118.4800 118.4800 0.0000<br />
Cabin L Descharme Lake, SK<br />
Maximum 1-hour acrolein 1.2063 1.2063 0.0000 0.0384 0.0384 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0784 0.0784 0.0000 0.0021 0.0021 0.0000<br />
2.6249 2.6249 0.0000 0.1770 0.1770 0.0000<br />
Peak 1-hour cyclohexane 9.0573 9.0573 0.0000 1.0297 1.0297 0.0000<br />
Peak annual cyclohexane<br />
0.5284 0.5284 0.0000 0.0191 0.0191 0.0000<br />
Peak 1-hour ethylbenzene 4.9721 4.9721 0.0000 0.3655 0.3655 0.0000<br />
Peak 1-hour xylenes<br />
24.6910 24.6910 0.0000 2.5696 2.5696 0.0000<br />
La Loche, SK Oil Sands Lodge<br />
Maximum 1-hour acrolein 0.1662 0.1662 0.0000 1.7889 1.7889 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0326 0.0326 0.0000 0.1254 0.1254 0.0000<br />
1.4102 1.4102 0.0000 4.1488 4.1488 0.0000<br />
Peak 1-hour cyclohexane 0.9330 0.9330 0.0000 23.1360 23.1360 0.0000<br />
Peak annual cyclohexane<br />
0.0264 0.0264 0.0000 1.1160 1.1160 0.0000<br />
Peak 1-hour ethylbenzene 0.3389 0.3389 0.0000 8.0735 8.0735 0.0000<br />
6-12 Shell Canada Limited April 2010<br />
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AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Table ERCB 41-8: Comparison of Select VOC Predictions In Regional Communities<br />
(cont’d)<br />
Parameter *<br />
Peak 1-hour xylenes<br />
Application<br />
Case<br />
(µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
Application<br />
Case<br />
(µg/m³)<br />
Application<br />
Case Plus<br />
Boilers<br />
(µg/m³)<br />
Change Due<br />
to Boilers<br />
(µg/m³)<br />
2.3634 2.3634 0.0000 57.6200 57.6200 0.0000<br />
PTI Camp<br />
Maximum 1-hour acrolein 0.9210 0.9210 0.0000<br />
Peak annual acrolein<br />
Maximum 1-hour benzene<br />
0.0657 0.0657 0.0000<br />
8.8481 8.8481 0.0000<br />
Peak 1-hour cyclohexane 39.0100 39.0100 0.0000<br />
Peak annual cyclohexane<br />
2.3558 2.3558 0.0000<br />
Peak 1-hour ethylbenzene 13.1370 13.1370 0.0000<br />
Peak 1-hour xylenes<br />
96.4740 96.4740 0.0000<br />
Note *: The peak concentrations include the highest 1-hour predictions from the CALPUFF model.<br />
Table ERCB 41-9: Comparison of PM2.5 Predictions In Regional Communities<br />
98 th (a)<br />
Percentile 24-Hour PM2.5<br />
Application<br />
Application Case Plus Change Due to<br />
Case<br />
Boilers<br />
Boilers<br />
Community<br />
(µg/m³)<br />
(µg/m³)<br />
(b)<br />
(µg/m³)<br />
Anzac 11.7 11.7 0.0<br />
Conklin 9.7 9.7 0.0<br />
Fort Chipewyan 8.8 8.9 0.0<br />
Fort McKay 25.4 25.4 0.0<br />
Fort McMurray 18.0 18.0 0.0<br />
Janvier/Chard (IR 194) 10.2 10.2 0.0<br />
Clearwater (IR 175) 4.7 4.7 0.0<br />
Namur <strong>River</strong> (IR 174A) 4.5 4.6 0.1<br />
Poplar Point (IR 201G) 5.0 5.1 0.0<br />
Cabin A 9.9 9.9 0.0<br />
Cabin B 6.4 6.5 0.0<br />
Cabin C 9.4 9.4 0.0<br />
Cabin D 10.5 10.5 0.0<br />
Cabin E 8.9 8.9 0.0<br />
Cabin F 9.3 9.4 0.0<br />
Cabin G 9.7 9.7 0.0<br />
Cabin H 10.8 10.8 0.0<br />
Cabin I 15.2 15.2 0.0<br />
Cabin J 24.2 24.2 0.0<br />
Cabin K 20.5 20.5 0.0<br />
Cabin L 16.9 16.9 0.0<br />
Descharme Lake, SK 2.3 2.3 0.0<br />
La Loche, SK 9.3 9.4 0.0<br />
Oil Sands Lodge 21.1 21.2 0.1<br />
PTI Camp<br />
Note:<br />
13.1 13.2 0.0<br />
(a) The Canada-Wide Standard for PM2.5 is 30 µg/m³ and is based on the 98 th percentile 24-hour<br />
reading annually, averaged over three years (CCME 2000).<br />
(b) Although the modelling predictions in the table have been rounded for presentation purposes,<br />
the changes were calculated directly from model outputs. Therefore, it is possible to show<br />
small changes without an apparent change in the listed concentrations.<br />
April 2010 Shell Canada Limited 6-13<br />
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AIR ERCB SIRS 40 – 45<br />
References<br />
Question No. 42<br />
Section 6.1<br />
AENV (Alberta Environment). 2003. Air Quality Model Guideline. Prepared by<br />
the Science and Standards Branch, Environmental Services Division<br />
Alberta Environment. Edmonton, AB. March 2003.<br />
AENV. 2009. Alberta Ambient Air Quality Objectives and Guidelines. Air<br />
Policy Branch. June 2009.<br />
CCME (Canadian Council Ministry Environment). 2000. Canada-Wide<br />
Standards for Particulate Matter (PM) and Ozone. Accepted November<br />
29, 1999 for endorsement in May 2000.<br />
Request Volume 3, Section 3.4.3.2, Page 3-71, Table 3.4-13.<br />
Shell states, “The modeling results indicate that no occurrences above the 1-hr<br />
AAAQO [for benzene] were predicted for either the Base Case or Application<br />
Case for any of the regional communities.”<br />
42a Clarify if Shell is predicting any benzene concentrations above the AAAQO<br />
anywhere in the local study area (LSA) or regional study area (RSA), excluding<br />
the regional communities and developed areas.<br />
Response 42a The following analysis of local and regional benzene concentrations has been<br />
completed to clarify Shell’s benzene predictions. Ground-level 1-hour benzene<br />
concentrations were predicted in both the local study area (LSA) and the regional<br />
study area (RSA) for the Base Case and Application Case. A summary of the<br />
results for both cases is presented in Table ERCB 42-1. The Base Case maximum<br />
1-hour benzene concentration (excluding developed areas) is below the Alberta<br />
Ambient Air Quality Objective (AAAQO) in the LSA but above the AAAQO in<br />
the RSA. The Application Case maximum 1-hour benzene concentration<br />
(excluding developed areas) in the LSA is above the AAAQO with 13 hours per<br />
year predicted to exceed the AAAQO. In the RSA, both the Base Case and<br />
Application Case maximum 1-hour benzene concentrations excluding developed<br />
areas are above the AAAQO. There are 169 hours per year predicted to exceed<br />
the AAAQO in both cases.<br />
6-14 Shell Canada Limited April 2010<br />
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AIR ERCB SIRS 40 – 45<br />
Local Study Area (LSA)<br />
Table ERCB 42-1: Regional 1-Hour Benzene Predictions<br />
Section 6.1<br />
Parameter Base Case Application Case<br />
peak benzene (1) (µg/m³) 69.9 104.8<br />
maximum benzene (2) (µg/m³) 59.8 89.6<br />
maximum benzene (excluding developed areas) (2)(3) (µg/m³) 24.8 37.0<br />
distance to maximum concentration (4)(5) (km) 7.2 7.2<br />
direction to maximum concentration (4)(5) ESE ESE<br />
occurrences above AAAQO (5)(6) 0 13<br />
areal extent above AAAQO (5)(6) (excluding developed areas) (ha) 0 261<br />
Regional Study Area (RSA)<br />
peak benzene (1) (µg/m³) 1,196.9 1,196.9<br />
maximum benzene (2) (µg/m³) 1,038.4 1,038.4<br />
maximum benzene (excluding developed areas) (2)(3) (µg/m³) 211.4 211.5<br />
distance to maximum concentration (4)(5) (km) 29.6 29.6<br />
direction to maximum concentration (4)(5) SSW SSW<br />
occurrences above AAAQO (5)(6) 169 169<br />
areal extent above AAAQO (5)(6) (excluding developed areas) (ha) 16,324 16,602<br />
Note:<br />
1. The peak concentrations represent the highest 1-hour predictions from the CALPUFF model. However, the<br />
eight highest 1-hour predictions should be excluded (AENV 2003) when determining compliance with the<br />
AAAQOs.<br />
2. Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model<br />
guidelines (AENV 2003). The eight highest 1-hour benzene predictions were not excluded from the<br />
maximum 24-hour values.<br />
3. Developed areas include the <strong>Project</strong> Development Area and existing and approved open pit mines and<br />
upgrading complexes within the RSA and LSA.<br />
4. Locations are relative to the Jackpine <strong>Mine</strong> Expansion plant site.<br />
5. Locations, number of occurrences and areas are based on the maximum predictions outside developed<br />
areas.<br />
6. The 1-hour Ambient Air Quality Objective for benzene is 30 µg/m³ (AENV 2009).<br />
Figures ERCB 42-1, ERCB 42-2, ERCB 42-3 and ERCB 42-4 present the ground<br />
level 1-hour benzene concentration predictions for Base and Application cases<br />
and the likelihood of occurrence of predicted concentrations above the AAAQO,<br />
respectively. The concentration and likelihood of exceedance isopleths are<br />
centred on the primary benzene emission sources (i.e., tailings ponds, mine<br />
areas). In the LSA, the Application Case 1-hour benzene concentrations are<br />
focused on the Jackpine <strong>Mine</strong> Expansion tailings pond, with the highest predicted<br />
concentrations occurring over the surface of the ponds. The exceedances outside<br />
the developed areas in the LSA are because of the combined effect of the<br />
increased emissions from the Jackpine <strong>Mine</strong> Expansion tailings pond and tailings<br />
pond emissions from neighbouring projects (i.e., Syncrude Aurora South).<br />
The majority of the exceedances occur in areas where the public is not expected<br />
to spend extended periods of time due to restricted access. The air quality<br />
assessment and health risk assessment focused on locations where members of<br />
the public are expected to be, such as communities or cabins (see EIA, Volume 3,<br />
Section 3.4).<br />
April 2010 Shell Canada Limited 6-15<br />
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AIR ERCB SIRS 40 – 45<br />
References<br />
Section 6.1<br />
Because predicted short-term benzene concentrations were less than the healthbased<br />
guideline for all receptor locations, under all three development cases (see<br />
EIA, Volume 3, Section 5.3.3.1), predicted short-term benzene concentrations are<br />
not expected to result in adverse health effects on the area residents.<br />
AENV (Alberta Environment). 2003. Air Quality Model Guideline. Prepared by<br />
the Science and Standards Branch, Environmental Services Division<br />
Alberta Environment. Edmonton, AB. March 2003.<br />
AENV. 2009. Alberta Ambient Air Quality Objectives and Guidelines. Air<br />
Policy Branch. June 2009.<br />
Request 42b If so, how many and approximately where are the majority of predicted<br />
exceedances located?<br />
Response 42b See the response to ERCB SIR 42a.<br />
6-16 Shell Canada Limited April 2010<br />
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AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Figure ERCB 42-1: Base Case Maximum 1-Hour Benzene<br />
Predictions<br />
April 2010 Shell Canada Limited 6-17<br />
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AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Figure ERCB 42-2: Application Case Maximum 1-Hour<br />
Benzene Predictions<br />
April 2010 Shell Canada Limited 6-18<br />
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AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Figure ERCB 42-3: Base Case Likelihood of 1-Hour<br />
Benzene Predictions Exceeding 30 µg/m 3<br />
April 2010 Shell Canada Limited 6-19<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Figure ERCB 42-4: Application Case Likelihood of<br />
1-Hour Benzene Predictions Exceeding 30 µg/m 3<br />
April 2010 Shell Canada Limited 6-20<br />
CR029
AIR ERCB SIRS 40 – 45<br />
Question No. 43<br />
Section 6.1<br />
Request Volume 1, Section 11.1, Page 11-24, Supplemental Information Responses.<br />
Shell states, “Shell is still reviewing options for pollution control equipment for<br />
the AER cogeneration unit. Details of the air quality and monitoring control<br />
system will be finalized when pollution control equipment has been selected.”<br />
43a Explain how Shell intends to monitor the control efficiencies of the finalized<br />
pollution control equipment to achieve the pollution control performance targets.<br />
i. What is the basis for setting pollution control performance targets?<br />
Response 43a As stated in the response to SIR 230a in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 1, Shell is still reviewing options for<br />
pollution control equipment for the AER cogeneration unit. Details of the air<br />
quality and monitoring control system will be finalized once the pollution control<br />
equipment has been selected and the regulatory requirements are known. Stack<br />
monitoring could be used to confirm that emissions meet expectations, given the<br />
control efficiencies chosen.<br />
The proposed performance targets were based on realistic control efficiencies for<br />
pollution control equipment that could integrate with an AER cogeneration<br />
system. These performance targets for pollution control equipment efficiencies<br />
will guide the selection of equipment during the detailed design stage of the<br />
project.<br />
Request 43b Provide detailed characterization of the asphaltene feedstock e.g. S, N, Hg, Cr,<br />
etc.<br />
Response 43b Shell is still at an early stage in the assessment of the AER technology, and<br />
certain elements, including the feedstock, are considered confidential.<br />
Request 43c What are the expected products and by-products from the combustion of this<br />
asphaltene feedstock?<br />
Response 43c As discussed in EIA, Volume 2, Section 8.3, the products of the asphaltene-fired<br />
cogeneration plant are steam and electrical power. The by-products of this<br />
process are bottom and fly ash, flue gas desulphurization (FGD) solids, and flue<br />
gas. Ash and FGD solids would be collected and disposed of on site in a Class II<br />
landfill. Flue gas would be treated by pollution control equipment.<br />
April 2010 Shell Canada Limited 6-21<br />
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AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
Request 43d What is Shell’s position on providing detailed configuration of the pollution<br />
control technologies for the AER unit to the ERCB, when a final selection has<br />
been made?<br />
Response 43d Shell will provide the appropriate design details of the AER process to the<br />
applicable regulatory agencies, including the ERCB, once a final design basis has<br />
been selected.<br />
Question No. 44<br />
Request Volume 1, Section 10.1, Page 10-156, Supplemental Information Responses.<br />
Shell states, “If asphaltene recovery operations are not initiated, TSRU tailings<br />
will be incorporated into fluid fine tailings mixes. Some of these fluid fine tailings<br />
will be incorporated into NST and some will be stored in water capped mature<br />
fine tailings (MFT) end-pit lakes”.<br />
44a What are the implications for air emissions in the region if the TSRU tailings is<br />
incorporated into the NST deposit? Will there be a significant increase in the<br />
estimated air emissions for the project?<br />
Response 44a If the TSRU tailings are incorporated into the NST deposit the actual VOC<br />
emissions will be higher than if they are deposited sub-aqueously in the ETDA<br />
due to the capping effect of the water. However, as outlined below, the calculated<br />
air emissions used in the EIA for the region will remain unchanged.<br />
The primary source of air emissions from the ETDA or in-pit NST cells is due to<br />
unrecovered solvent. The unrecovered solvent is associated with asphaltenes and<br />
the tailings solvent recovery unit (TSRU) tailings. The Shell VOC emission<br />
estimates are based on the conservative assumption that diluent losses will be<br />
four barrels of diluent per 1,000 barrels of bitumen produced. This assumption<br />
does not differentiate between solvent loss due to unrecovered asphaltenes or<br />
TSRU tailings. Therefore, the calculated fugitive emission rates would remain<br />
unchanged if asphaltene recovery operations were not initiated.<br />
Request 44b If yes, what is the per cent increase in air emissions for the project?<br />
Response 44b See the response to ERCB SIR 44a.<br />
6-22 Shell Canada Limited April 2010<br />
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AIR ERCB SIRS 40 – 45<br />
Question No. 45<br />
Section 6.1<br />
Request Volume 1, Section 11.1, Page 11-29, Supplemental Information Responses.<br />
Shell states, “As stated in EIA, Volume 3, Air Quality, Noise and Environmental<br />
Health, Section 3.1.5.2, vehicles in the mine fleet will meet applicable emissions<br />
standards at the time of purchase.” Shell used Tier 4 emission standards to<br />
develop a regional emissions profile and this was modeled for the assessment of<br />
predicted acid input (PAI).<br />
45a Does Shell commit to purchasing mine fleet vehicles that meet Tier 4 emission<br />
standards if these standards have not been implemented in Canada at the time of<br />
purchase?<br />
Response 45a As stated in EIA, Volume 3, Section 3.1.5.2, vehicles in the mine fleet will meet<br />
applicable emission standards at the time of purchase. As Tier 4 emission<br />
standards are directed at the equipment manufacturers, they dictate when these<br />
products will become available in the United States and Canada. If Tier 4<br />
emission standards are not adopted in Canada, it is unlikely that manufacturers<br />
will produce Tier 4-compliant product lines solely for US markets. Shell expects<br />
that Tier 4-compliant mobile equipment manufactured for both Canada and the<br />
US will become available in alignment with the timelines set out by the US.<br />
Environmental Protection Agency (US EPA).<br />
Shell will commit to the purchase of Tier 4-compliant equipment only if these<br />
products are made available in both the US and Canada.<br />
Request 45b If not, explain why Shell will not make the commitment.<br />
Response 45b See the response to ERCB SIR 45a.<br />
April 2010 Shell Canada Limited 6-23<br />
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AIR ERCB SIRS 40 – 45<br />
Section 6.1<br />
6-24 Shell Canada Limited April 2010<br />
CR029
PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 2: ERCB SIRS – ROUND 2<br />
Question No. 46<br />
WATER<br />
ERCB SIRS 46 – 79<br />
Section 7.1<br />
Request Volume 1, Section 13.1, Page 13-6, Supplemental Information Responses.<br />
Shell states, “Shell is confident in its capability of design and build successful pit<br />
lakes, because key findings from CONRAD and CEMA research on wetlands,<br />
experimental ponds and pit lakes will be incorporated into the analysis.”<br />
46a CEMA’s End Pit Lake Technical Guidance Document (EPLTGD) was reviewed<br />
by CH2MHILL. The reviewers rejected the document and provided<br />
recommendations that should be considered in the 2012 EPLTGD update. What<br />
is the time limit to incorporate CEMA’s key findings into Shell’s plans in order to<br />
meet the 2018 deadline (i.e. proven efficacy of the demonstration lake)?<br />
Response 46a The first three areas of research are the focus of work currently underway by<br />
CEMA, CONRAD and the Oil Sands Tailings Research Facility, all of which are<br />
supported by Shell. While the goal is to incorporate this research into the 2012<br />
EPLTGD update, it is anticipated that this and related research will continue<br />
beyond the 2012 update, and likely beyond 2018 as well.<br />
CEMA’s End Pit Lake Technical Guidance Document (EPLTGD) was reviewed<br />
by 12 experts in various fields, and their reviews were synthesized by<br />
CH2MHILL. The draft review synthesis pointed to shortcomings with the CEMA<br />
End Pit Lake Technical Guidance Document, but did not evaluate whether pit<br />
lakes were a viable solution for remediation of oil sands mines.<br />
Reviewers expressed opinions that oil sands pit lakes would require some level of<br />
active treatment in conjunction with the planned passive treatment. Although<br />
Shell is confident that pit lakes will function as planned, several active treatment<br />
methods are available and could be used in the event that such technology is<br />
deemed necessary (see the response to SIR 312 in the May 2009 <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong>, Supplemental Information, Volume 1, Section 13).<br />
The synthesis report pointed to four main areas of research that should be<br />
addressed:<br />
• the toxicity of naphthenic acids and other hydrocarbon contaminants<br />
• lake modelling<br />
• active management<br />
April 2010 Shell Canada Limited 7-1<br />
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WATER ERCB SIRS 46 – 79<br />
• risk management<br />
Section 7.1<br />
Request 46b What would be Shell alternatives to the End Pit Lakes as a final sustainable<br />
solution in highlight of the new draft review report submitted to CEMA entitled<br />
“Synthesis of Reviewer Comments on the CEMA End Pit Lake Technical<br />
Guidance Document, May 2009”?<br />
Response 46b Alternatives to pit lakes are described in the response to SIR 312b in the May<br />
2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section 13.<br />
Question No. 47<br />
Request Volume 1, Section 13.1, Page 13-9, Supplemental Information Responses.<br />
Shell states, “Shell will have a physical test pit lake in place by, or before,<br />
2018.” Shell also states, “Over time, they [EPLs] will become self-sustaining<br />
habitat for local vegetation, invertebrates and fish.”<br />
47a Will Shell independently demonstrate the efficacy of EPLs by, or before, 2018? If<br />
not, provide sound reasons for not complying with the approval condition.<br />
Response 47a In the response to SIR 312f in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 1, Shell stated:<br />
Shell will have a physical test pit lake in place by, or before, 2018. In accordance<br />
with the ERCB’s conditions for approval of the Muskeg <strong>River</strong> <strong>Mine</strong> Expansion<br />
and the existing and expected EPEA approvals, this test pit lake work might be<br />
carried out by Shell or through a multi-stakeholder group that Shell<br />
cooperatively funds, such as CEMA or CONRAD.<br />
To clarify, Shell will be participating in research on the Syncrude Base <strong>Mine</strong><br />
Lake through the multi-stakeholder groups that Shell cooperatively funds.<br />
Demonstration research is scheduled to begin in 2012 when the lake will no<br />
longer be operated as a tailings pond.<br />
Shell’s operating mines are still early in their development and Shell will not<br />
have any end pits available for research by 2018. Shell currently has no other<br />
plans for research on a demonstration end pit lake. However, Shell will continue<br />
to participate in joint industry and government research, as outlined previously in<br />
the response to ERCB SIR 46.<br />
7-2 Shell Canada Limited April 2010<br />
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WATER ERCB SIRS 46 – 79<br />
Section 7.1<br />
Request 47b Provide Shell’s plans and timelines for completion of the 2018 demonstration<br />
lake.<br />
Response 47b See the response to ERCB SIR 47a.<br />
Request 47c Provide an update on the status of Shell’s demonstration lake.<br />
Response 47c See the response to ERCB SIR 47a.<br />
Question No. 48<br />
Request Volume 1, Section 13.1, Page 13-22, Supplemental Information Responses.<br />
Shell states, “Shell would consider several options if either insufficient water<br />
storage capacity or insufficient recycle water quality affected its ability to meet<br />
its water requirements.”<br />
48a Discuss Shell’s options to meet water requirements during exceptional low-flow<br />
periods.<br />
Response 48a See the response to AENV SIR 16.<br />
Question No. 49<br />
Request Volume 1, Section 13.1, Page 13-23, Supplemental Information Responses.<br />
Shell states, “Evaporation associated with the processing facilities accounts for<br />
about 2% of total water consumption. There are no plans to reduce such<br />
evaporation.”<br />
49a Why did Shell include “reducing losses to evaporation” in its water management<br />
strategies list if there are no plans to reduce such evaporation?<br />
Response 49a The conceptual design took into account minimizing losses and developing an<br />
efficient production facility. Currently, there are no plans to make changes to the<br />
project’s conceptual design. However, during detailed design and operations<br />
there will be further opportunities to potentially improve on the overall efficiency<br />
of the process, including reducing losses to evaporation.<br />
Request 49b Where and how could Shell implement this water management strategy (reducing<br />
losses to evaporation)?<br />
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Response 49b Most of the evaporative losses within the process area result from operating the<br />
open-loop cooling tower. During detailed design and operations, opportunities<br />
will be sought to find a use for this low-grade heat before it is sent through the<br />
cooling tower. This would result in lower evaporative losses.<br />
Request 49c Confirm which of the strategies listed in Shell’s water management plan will be<br />
implemented.<br />
Response 49c Shell intends to implement all of the strategies listed in its water management<br />
plan.<br />
Question No. 50<br />
Request Volume 1, Section 13.1, Page 13-23, Supplemental Information Responses.<br />
Shell states, “The simulation results showed that a system of recovery wells<br />
would be effective in capturing the ETDA seepage plume in the surficial deposits<br />
and would prevent seepage migration to the Athabasca <strong>River</strong> valley.”<br />
50a Elaborate on the effectiveness of the proposed system to capture vertical seepage<br />
underneath surficial deposits.<br />
Response 50a Groundwater interception measures for the external tailings disposal area<br />
(ETDA) focuses on lateral groundwater flow in the surficial deposits. Vertical<br />
seepage from the surficial deposits beneath the ETDA is not predicted to occur at<br />
appreciable rates because of the low hydraulic conductivity of the underlying<br />
McMurray Formation, as reported in EIA, Volume 4A, Section 6.3.6.2, page 6-<br />
212.<br />
Request 50b Elaborate on the additional mitigation measures (besides additional interception<br />
wells) that Shell would implement to increase the capture of ETDA seepage into<br />
surficial deposits and greater depths.<br />
Response 50b The current interception wells are predicted to adequately capture ETDA<br />
seepage. However, if further monitoring indicates additional mitigation measures<br />
are necessary, these measures would be to:<br />
• increase pumping rates, to increase the radius of influence of the interception<br />
well or wells<br />
• use slurry walls or grouting or both, to provide a barrier to groundwater flow<br />
which could be directed to installed interception wells<br />
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Question No. 51<br />
Section 7.1<br />
Request Volume 1, Section 13.1, Page 13-8, Supplemental Information Responses.<br />
Shell considers deep-well injection to discard large volumes of process-affected<br />
water.<br />
51a If Shell determines injecting Process-Affected Water (PAW) is a necessary step,<br />
at what locations and depth would this occur?<br />
Response 51a Shell is no longer considering deep-well injection as an option for disposing of<br />
process affected waters. Therefore, no additional information is being provided.<br />
Request 51b Elaborate on the impacts on groundwater systems due to the injection of large<br />
untreated volumes of PAW.<br />
Response 51b See the response to ERCB SIR 51a.<br />
Request 51c Shell lists deep well injection as a treatment option to remediate contaminated pit<br />
lake waters. Explain how deep well injection remediates contaminated pit lake<br />
waters.<br />
Response 51c See the response to ERCB SIR 51a.<br />
Request 51d What regulatory process will Shell use for approval of the deep well injection of<br />
PAW if this option determined to be a necessary step?<br />
Response 51d See the response to ERCB SIR 51a.<br />
Question No. 52<br />
Request Volume 1, Section 13.1, Page 13-21, Supplemental Information Responses.<br />
Shell states, “The project proposes to reuse all of this captured water in its<br />
bitumen extraction process. Because all available water is used, treatment would<br />
not provide extra water for use.” Also “makeup water from the Athabasca <strong>River</strong><br />
is required to offset losses of water to tailings pore space (over 90%).”<br />
52a Explain “over 90%” in the above quote.<br />
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Response 52a Table 10-2 from the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, <strong>Project</strong> Description, Volume 2 shows the<br />
annual water balance for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. According to this<br />
balance, the fraction of total water lost to tailings pore space (external and in-pit)<br />
versus total diverted water (Athabasca, basal water and runoff) is greater than<br />
90%.<br />
Request 52b What is the porosity of the sediments in the tailings ponds?<br />
Response 52b The porosity of the sediments in the external tailings disposal area is shown in<br />
Table ERCB 52-1.<br />
Question No. 53<br />
Table ERCB 52-1: Predicted Tailings Sediment Porosity<br />
External Tailings In-Pit<br />
Sediment Type Type Disposal Facility Facilities<br />
Coarse tailings Cell 0.37 -<br />
Beach 0.43 0.43<br />
Thickened tailings – 0.68 0.64<br />
Mature Fine tailings – 0.85 0.85<br />
TSRU tailings Solids 0.65 0.65<br />
Hydrocarbons 0.07 0.07<br />
Non-segregating tailings On-spec - 0.39<br />
Off-spec - 0.42<br />
Request Volume 1, Section 13.1, Page 13-21, Supplemental Information Responses.<br />
Shell states, “Treatment of water would not reduce the total volume of water<br />
required to fill the pit lakes,” and “Maximizing the reuse of process-affected<br />
water released by tailings will minimize the amount of process-affected water<br />
inventory at the end of mine life.”<br />
53a How do these two quotes relate to one another?<br />
Response 53a The statements are unrelated.<br />
The first statement points out that, even by treating and reusing process-affected<br />
water throughout the operating mine life, there will be no change in the amount<br />
of water required to fill the pit lakes because, regardless of treatment, all<br />
available water is used in the extraction process.<br />
The second statement explains that Shell’s process-affected water inventory near<br />
the end of the mine life is primarily the result of releasing water from nonsegregating<br />
tailings as it consolidates over time in the backfilled mine pits. Shell<br />
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will use this process-affected water to the end of operations to minimize the<br />
amount of additional fresh makeup water required. This results in less processaffected<br />
water inventory at the end of the mine life, as opposed to storing and<br />
ultimately using it to fill pit lakes.<br />
Request 53b How will Shell ensure actual tailings volumes will not exceed estimated volumes?<br />
Response 53b The planning basis for estimating tailings volumes uses conservative assumptions<br />
related to time-dependant consolidation of tailings that will help to ensure the<br />
total volume of tailings generated does not exceed the ultimate tailings storage<br />
capacity at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>. For example, as water is released during<br />
tailings consolidation, the reclaim systems in the external tailings disposal area<br />
and in-pit facilities will return the free water, via barge systems, to the plant for<br />
reuse. The planned tailings storage capacity considers only the water released<br />
upon initial discharge, not the additional incremental water volume that will be<br />
released over the life of the mine, thus conservatively overestimating the volume<br />
of the tailings deposit.<br />
Question No. 54<br />
Request Volume 1, Section 13.1, Page 13-21, Supplemental Information Responses.<br />
Shell states, “Shell will maximize the recycling of process-affected water for<br />
reuse in extraction by not carrying any unplanned process-affected water<br />
inventories.”<br />
54a Provide further clarification for the above statement and define what is meant by<br />
“unplanned process-affected water inventories”.<br />
Response 54a The statement Unplanned process-affected water inventories refers to clear water<br />
inventories in excess of the required clear water zone in the tailings disposal<br />
areas.<br />
The key principle in maximizing the recycling of process-affected water is<br />
minimizing water retention within tailings impoundments, both within external<br />
and in-pit facilities. This is achieved by restricting the clear water zone in the<br />
tailings facilities, and recovering all water of sufficient clarity for reuse in the<br />
extraction process.<br />
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Question No. 55<br />
Section 7.1<br />
Request Volume 1, Section 13.1, Page 13-23, Supplemental Information Responses.<br />
Shell states, “Groundwater quality will be considered acceptable when it can be<br />
demonstrated that, when released, it would have no adverse effects on the health<br />
of aquatic, terrestrial or human receptors.” Shell further states, “The actual<br />
percentage of seepage captured and sent back to the ETDA will depend on the<br />
results of the groundwater monitoring program that will be implemented to<br />
monitor the effectiveness of the mitigation measures (see EIA, Volume 4B,<br />
Appendix 4-9, and Section 2.1.4.3). If unacceptable quality is detected in<br />
groundwater originating from the ETDA, a groundwater response plan will be<br />
implemented.”<br />
55a Provide the discharge criteria that Shell will use to assess acceptability of<br />
released groundwater.<br />
Response 55a As described in the response to ERCB SIR 56, groundwater discharge criteria<br />
that will be used to assess the release acceptability will be evaluated using the<br />
following criteria:<br />
• a comparison against pre-mining or statistically established background<br />
values<br />
• a comparison against acceptable criteria, which may include Canadian Water<br />
Quality Guidelines, CCME, or ecological risk assessment methodologies<br />
Request 55b Provide details on the proposed monitoring program in terms of well locations,<br />
depths, and measured water quality parameters.<br />
Response 55b The EIA, Volume 4B, Appendix 4-9, Section 2.1.4.3 indicates that “monitoring<br />
wells will be installed along the perimeter of the ETDA in both the shallow and<br />
deep Quaternary deposits to monitor seepage and the effectiveness of the<br />
mitigation measures.”<br />
A list of analytical parameters to be measured to determine groundwater quality<br />
is provided in EIA, Volume 4B, Appendix 4-9, Section 2.1.3, Table 1.<br />
Request 55c What are the triggering criteria for considering the groundwater quality<br />
unacceptable?<br />
Response 55c The triggering criteria for considering the groundwater quality unacceptable<br />
would be based on a comparison against acceptable criteria, which may include<br />
Canadian Water Quality Guidelines, CCME, or ecological risk assessment<br />
methodologies.<br />
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As described in the response to ERCB SIR 56, key indicator parameters in the<br />
area of the ETDA will be identified based on the water quality of the tailings<br />
water and control limits will be defined for each key indicator parameter for each<br />
monitoring well. An exceedance of the control limits will trigger the initiation of<br />
the groundwater response plan, as stated in EIA, Volume 4B, Appendix 4-9,<br />
Section 2.1.5 and described further in the response to ERCB SIR 56.<br />
Request 55d What will be the monitored parameters taking into consideration the behaviors of<br />
various parameters?<br />
Response 55d The monitored parameters for the ETDA that would be taken into consideration,<br />
given the behaviours of various parameters, would include those listed in EIA,<br />
Volume 4B, Appendix 4-9, Section 2.1.3, Table 1. Once detailed groundwater<br />
characterization is complete, a set of indicator parameters will be developed for<br />
each specific area (see EIA, Volume 4B, Appendix 4-9, Section 2.1.4). In the<br />
area of the ETDA, key indicator parameters will be based on the water quality of<br />
the tailings water.<br />
Question No. 56<br />
Request Volume 1, Section 13.1, Page 13-24, Supplemental Information Responses.<br />
Shell states, “an ETDA-specific groundwater response plan will be developed to<br />
mitigate effects on groundwater quality beyond the interception points.”<br />
56a Provide a detailed scheme outlining Shell’s response if groundwater<br />
contamination is found beyond the interception wells in the Athabasca <strong>River</strong>.<br />
Provide a proposal that includes a reporting mechanism, water quality criteria<br />
and a timeframe for mitigation.<br />
Response 56a If the monitoring program detects unexpected effects on groundwater quality, an<br />
incident-specific groundwater response plan will be implemented (see EIA<br />
Volume 4B, Appendix 4-9, Section 2.1.5, page 13) to mitigate adverse effects on<br />
groundwater quality beyond the interception wells.<br />
Groundwater Monitoring Program<br />
The groundwater monitoring program for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will include:<br />
• identifying key indicator parameters for groundwater quality in the area of<br />
the ETDA. This will be based on the water quality of the tailings process<br />
water.<br />
• implementing a groundwater monitoring network in the area of the ETDA,<br />
including monitoring wells near and far from the interceptor wells<br />
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• defining control limits (or trigger values) for each key indicator parameter for<br />
each monitoring well<br />
• evaluating the monitoring results for trends in parameter concentrations and<br />
exceedance of the control limits for each monitoring well. If a trend is<br />
identified, the monitoring well will be closely tracked and the possible causes<br />
for the observed trend will be reviewed. If the control limits are exceeded,<br />
the initiation of the groundwater response plan will be triggered.<br />
• reporting the groundwater monitoring results and trend analysis to AENV<br />
through the annual groundwater monitoring reports<br />
Groundwater Response Plan<br />
The groundwater response plan would consist of the following steps:<br />
1. Verification<br />
2. Confirmation<br />
3. Delineation<br />
4. Evaluation<br />
5. Mitigation<br />
1. Verification<br />
Once a parameter concentration above the control limit has been identified, the<br />
initial phase is to review all available information to more fully understand the<br />
issue. Verification involves confirming the analytical results, i.e., review<br />
laboratory QA/QC, laboratory verification of results and re-analysis; reviewing<br />
sampling QA/QC procedures, reviewing well integrity, and reviewing historical<br />
data.<br />
Many of these steps are conducted for routine groundwater monitoring, i.e.,<br />
review field and laboratory QA/QC results and well integrity, but the<br />
Groundwater Response Plan requires specific detailed analysis and<br />
documentation of the process. If the suspect data point is found to be correct, it<br />
will trigger the confirmation phase of the response plan.<br />
2. Confirmation<br />
The objective of this phase is to confirm that the observed concentration is not an<br />
outlier. Once a parameter concentration above the control limit has been verified,<br />
the exceedance should be confirmed by additional sampling. As well, the<br />
groundwater sampling frequency should be increased to quarterly to allow for<br />
confirmation of recorded concentrations and for reviewing surrounding<br />
groundwater conditions and possible sources for the effects observed. The<br />
outcome of the confirmation step should be that:<br />
• if the parameter concentration remains above the control limit for three<br />
consecutive quarterly sampling events, an incident will be deemed to have<br />
occurred. This will trigger the delineation phase.<br />
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• if the parameter concentration remains below the control limit for three<br />
consecutive quarterly sampling events, the frequency of groundwater<br />
sampling will revert to the original monitoring frequency. The previous<br />
concentrations that were above the control limit will be deemed anomalous<br />
or outliers.<br />
With confirmation of an incident, Alberta Environment would be notified.<br />
3. Delineation<br />
Delineation of possible groundwater effects will be conducted in a staged manner<br />
so that high-quality information can be effectively obtained. During this process,<br />
the specific monitoring well where the exceedances have been observed will<br />
continue to be monitored quarterly.<br />
The delineation will include a detailed review of the available monitoring data,<br />
the use of non-intrusive techniques, such as geophysical surveys, and the<br />
installation of additional monitoring wells in each of the potentially affected<br />
aquifers or groundwater-bearing zones, to determine the horizontal and vertical<br />
extent of impacts.<br />
4. Evaluation<br />
The objective of the evaluation phase is to determine the need for further<br />
delineation and or mitigation. This involves compiling all information collected<br />
to date and developing a conceptual model that should include details on<br />
contaminate source zone characteristics, geology, background groundwater<br />
quality conditions, groundwater flow directions (lateral and vertical), the<br />
potential transport mechanisms, ion mobility, factors that will affect retardation<br />
or degradation, and downgradient receptors. Water quality data will be evaluated<br />
using the following approaches:<br />
• comparison against pre-mining or statistically established background values<br />
• comparison against acceptable criteria, which might include Canadian Water<br />
Quality Guidelines, CCME, or ecological risk assessment methodologies<br />
Follow-up action might range from conducting additional delineation activities,<br />
completing on of a risk assessment, implementation of mitigation measures, full<br />
scale remediation, to continued monitoring. Alberta Environmental would be<br />
provided with the proposed risk management strategy and the remediation plan<br />
for approval.<br />
5. Mitigation<br />
If the results of the evaluation phase indicate the need for mitigation, the level of<br />
risk posed by the incident will be assessed based on the type of contaminant<br />
detected, the transport and fate characteristics of that substance, the presence or<br />
absence of a pathway, and the potential end-point concentration at a<br />
downgradient receptor. A full-scale risk assessment (ecological or human health,<br />
or both) will also be considered when assessing mitigative measures.<br />
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Question No. 57<br />
Section 7.1<br />
Mitigation measures will be implemented to meet the site specific objectives.<br />
Timelines for mitigation will be determined on a case-by-case basis in<br />
consultation with Alberta Environment.<br />
Request Volume 2, Section 15.1, Page 15-21, Supplemental Information Responses.<br />
Shell states, “The area of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is characterized by downward<br />
hydraulic gradients between the Quaternary deposits and the basal aquifer, so<br />
that the vertical direction of groundwater flow across the McMurray Formation,<br />
which will be mined out and backfilled with tailings, is downward, away from the<br />
Quaternary deposits.”<br />
57a Explain the discrepancy between the above statement and the fact that the<br />
basal aquifer is under confined conditions and then depressurized during ore<br />
mining to prevent upward groundwater flow.<br />
Response 57a The potential for upward groundwater flow from the basal aquifer only arises<br />
because of the mining and removal of the confining layers of the McMurray<br />
Formations, including oil sands, above the basal aquifer. The removal or<br />
reduction in thickness of this confining layer creates the potential for upward<br />
groundwater flow because of the resulting lower head conditions in the mined out<br />
areas.<br />
Request 57b What prevents the basal aquifer from contributing waters to the tailings deposit<br />
post mining?<br />
Response 57b Following mining, it is expected that recharge and discharge relationships in the<br />
basal aquifer will be similar to those estimated before mining (see EIA, Volume<br />
4A, Section 6.3.5.2, page 6-140). Therefore, it is expected that groundwater flow<br />
will be primarily downward between the tailings deposit and the basal aquifer<br />
because the groundwater levels in the reclaimed pits will be similar to pre-mining<br />
conditions. In addition, the basal aquifer in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> mining area is<br />
generally thin, sparse, and poorly connected, thus minimizing the interaction<br />
between the tailings deposits and the basal aquifer.<br />
Request 57c Shell assumes that there is a downward hydraulic gradient; what is the fate of the<br />
seepage that seeps downward to the basal aquifer?<br />
Response 57c The Athabasca <strong>River</strong> is the regional discharge point for the basal aquifer. The<br />
effects of the project, including groundwater seepage, on water quality in the<br />
Athabasca <strong>River</strong> were assessed in EIA, Volume 4A, Section 6.5.7.3. The<br />
assessment concluded that the project would have negligible effects on key water<br />
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Question No. 58<br />
Section 7.1<br />
quality constituents and that changes in water quality in the Athabasca <strong>River</strong><br />
would have negligible effects on aquatic, human and wildlife health.<br />
Request Volume 2, Section 21.1, Page 21-14, Supplemental Information Responses.<br />
Shell states, “The rates of inflow presented for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA<br />
include lateral groundwater inflows to the LSA from up gradient areas.”<br />
58a Describe the simulation of lateral recharge from upgradient areas in the model.<br />
Response 58a Lateral groundwater inflow rates to the local study are (LSA) were calculated<br />
based on the simulated groundwater flows across the LSA boundaries in the<br />
regional groundwater model (see EIA, Appendix 4-1, Section 1.2.4.4, page 94).<br />
In the model, groundwater levels from the regional model were represented as<br />
general head boundaries at the lateral boundaries of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> local<br />
model in layers 4 (base of Quaternary), 9 (Basal Aquifer) and 12 (Methy<br />
Formation).<br />
Question No. 59<br />
Request Volume 2, Section 21.1, Page 21-59, Supplemental Information Responses.<br />
Shell states, “The Eymundson Sinkholes do not appear to have a marked<br />
influence on the groundwater flow pattern in the Quaternary deposits.”<br />
59a Provide the technical justification for this assumption including any geophysical<br />
surveys or detailed Karsts delineation studies.<br />
Response 59a The technical justification for this statement is the groundwater flow patterns<br />
illustrated in Figures 37 and 38 of the Hydrogeology Environmental Setting<br />
Report (WorleyParsons Komex 2007). Based on available groundwater-level<br />
information from piezometers in Quaternary deposits near the Eymundson<br />
Sinkholes, the groundwater flow patterns within and outside of the Eymundson<br />
Sinkholes Environmentally Sensitive Area (ESA) are similar. Overall, the<br />
groundwater flow patterns in the Quaternary deposits reflect topographical<br />
control and do not suggest any considerable alteration of the regional flow<br />
pattern within or near the Eymundson Sinkholes ESA.<br />
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Reference<br />
Section 7.1<br />
WorleyParsons Komex. 2007. Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
<strong>Project</strong> – Base Case Report. Prepared for Shell Canada Limited. Calgary,<br />
AB. Submitted December 2007.<br />
Request 59b How were Eymundson Sinkholes simulated in the groundwater conceptual<br />
model?<br />
Response 59b The Eymundson Sinkholes were not explicitly represented in the groundwater<br />
models developed for the project because the groundwater flow patterns in the<br />
Quaternary deposits were observed to reflect topographical control. Further, the<br />
sinkholes water level was near the crest of the sinkholes which is in general<br />
agreement with the inferred groundwater elevations of shallow Quaternary<br />
deposits.<br />
Question No. 60<br />
Request Environmental Setting Report, Hydrogeology, Figures, Figure 29.<br />
Shell illustrates “various cross-sections (G-G’, H-H’, and E-E’).”<br />
60a How were these cross-sections developed (sources of information, and<br />
interpolation method)?<br />
Response 60a The cross-sections were developed with the stratigraphic information interpreted<br />
from boreholes drilled for the hydrogeology environmental setting investigation<br />
for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> (WorleyParsons Komex 2007) and from coreholes<br />
drilled by Shell.<br />
References<br />
The available geological data were processed through the VIEWLOG software<br />
(Earth fx, 2009), which uses geo-statistics (kriging) to create surfaces or crosssections.<br />
Earth fx. 2009. Borehole Data Management and Interpretation System.<br />
http://www.earthfx.com/earthfx/Software/VIEWLOG30/Overview/Geost<br />
atistics/tabid/94/Default.aspx<br />
WorleyParsons Komex. 2007. Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
<strong>Project</strong> – Base Case Report. Prepared for Shell Canada Limited. Calgary,<br />
AB. Submitted December 2007.<br />
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Request 60b Discuss the reasons for omitting the geological structure features. If possible<br />
provide various structural features.<br />
Response 60b Boreholes and coreholes used in the cross-sections did not investigate deeper<br />
than the Upper Devonian because no interaction between the Devonian aquifers<br />
and the Cretaceous and surficial aquifers is expected. Therefore, boreholes and<br />
coreholes did not encounter this structural feature.<br />
Reference<br />
Section 3.2.5 of the Hydrogeology Environmental Setting Report<br />
(WorleyParsons Komex 2007) discusses the geological structure features which<br />
are important to the hydrogeology of the region. The Sewetakun Fault occurs on<br />
the Precambrian surface and appears to influence hydraulic heads in the Middle<br />
Devonian aquifers.<br />
WorleyParsons Komex. 2007. Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
<strong>Project</strong> – Base Case Report. Prepared for Shell Canada Limited. Calgary,<br />
AB. Submitted December 2007.<br />
Request 60c Does cross-section E-E’ pass through the proposed ETDA? If not, then provide a<br />
scaled cross-section that reflects ETDA location relative to the underlying<br />
formations.<br />
Response 60c Figure ERCB 60-1 shows that cross-section E-E’ passes through the proposed<br />
ETDA. Figure ERCB 60-2 illustrates the location of the ETDA along crosssection<br />
E-E’.<br />
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Figure ERCB 60-1: <strong>Pierre</strong> <strong>River</strong> Mining Area – Hydrogeologic Cross-Section Locations<br />
and Monitoring Wells in the Local Study Area<br />
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Figure ERCB 60-2: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Area –<br />
Hydrogeological Cross-Section E–E′<br />
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Question No. 61<br />
Request Volume 2, Section 13.3, Page 13-11.<br />
Shell states, “Three potential tailings disposal sites were evaluated.”<br />
61a Provide justification for not considering the north east end of Lease 351.<br />
Section 7.1<br />
Response 61a The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, <strong>Project</strong> Description, Volume 2, Section 13.3, states that<br />
the potential tailings disposal sites were evaluated based on the primary criteria,<br />
i.e., environmental, technical, operations and economics. Additional criteria<br />
include minimum ore sterilization, distance from the Athabasca <strong>River</strong> and<br />
distance from the plant. As the distance from the plant to the disposal site<br />
increases, the technical and operational factors become increasingly challenging.<br />
Therefore, the evaluation focused on potential southern sites as opposed to<br />
northern ones.<br />
Request 61b Why is the current proposed location considered the optimal location in light of<br />
the fact that it overlies the highest thickness of basal watersands (Figure 3-5)?<br />
Response 61b Thickness of basal watersands was not a primary evaluation criterion for locating<br />
the ETDA. Furthermore, the groundwater quality in the Basal aquifer beneath the<br />
proposed ETDA has high total dissolved solids (TDS), i.e., up to 85, 800 mg/l)<br />
(see the Hydrogeology ESR, Figure 29 and Table 11) which render it unsuitable<br />
as a fresh water source.<br />
Request 61c Were geophysical surveys conducted to assess the area beneath the proposed<br />
ETDA site to define any vertical and/or horizontal geological features (faults,<br />
cavities, sinkholes, etc.).<br />
Response 61c Further geophysical surveys will be conducted during the detailed design phase<br />
to assess the area beneath the proposed ETDA site to define any vertical or<br />
horizontal geological features.<br />
Question No. 62<br />
Request Volume 4A, Section 6.1.2, Page 6-159.<br />
Shell states, “Pre-development groundwater levels and flow direction in the<br />
basal aquifer.”<br />
62a What year was used for the pre-development groundwater levels?<br />
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Section 7.1<br />
Response 62a Groundwater levels were measured in May 2007 for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>.<br />
These water levels are considered pre-development as other existing or approved<br />
facilities are not expected to have had any effects on the groundwater resources<br />
of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> at that time (see EIA, Volume 4A, Section 6.3.6.1,<br />
page 6-156).<br />
Question No. 63<br />
Request Volume 4A, Section 6.1.2, Page 236.<br />
Shell states, “As such, proximity of a mine area to the Athabasca <strong>River</strong> does not<br />
influence predicted dewatering rates.” Also, “The water collected by the<br />
overburden dewatering system will be part of the open circuit, and will be routed<br />
to surface water bodies.”<br />
63a Was reverse recharge from the Athabasca <strong>River</strong> considered in case dewatering<br />
reaches a point below the river water head?<br />
Response 63a Figure 32 of the Hydrogeology Environmental Setting Report (WorleyParsons<br />
Komex 2007) illustrates that the overburden deposits in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
lease area are perched above the Athabasca <strong>River</strong> valley and are not directly<br />
connected hydraulically to the river.<br />
Reference<br />
Reverse recharge (i.e., river seepage into the mine pit) because of overburden<br />
dewatering was considered, but water levels in the overburden deposits do not<br />
fall below the stage of the river since the overburden deposits are hydraulically<br />
separated from the river by about 10 to 30 m of McMurray Formation.<br />
WorleyParsons Komex. 2007. Hydrogeology Environmental Setting Report for<br />
the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Prepared<br />
for Shell Canada Limited, Calgary, AB. Submitted December 2007.<br />
Request 63b Are there any quality control measures to ensure that overburden discharge<br />
routed to surface water bodies has not been contaminated by oil sands?<br />
Response 63b EIA, Volume 2, Section 19.2, page 19-12, states that all water drained from<br />
muskeg and overburden will be routed through sedimentation (polishing) ponds<br />
and controlled discharge points. No water will be released to receiving streams<br />
until applicable regulatory release criteria are met.<br />
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Request 63c What are the contingency plans in the event that the pumped groundwater quality<br />
does not meet release criteria and cannot be accommodated within the existing<br />
internal bonds?<br />
Response 63c In the unlikely event that the pumped groundwater does not meet release criteria<br />
and the volume exceeds the capacity of the planned storage ponds, Shell will<br />
adaptively manage the excess volume of water. This could be accomplished by<br />
increasing the number or capacity of the polishing ponds, or by redirecting the<br />
excess water to the closed-circuit system to be used in the process.<br />
Question No. 64<br />
Request Volume 4A, Section 6.1.2, Page 211.<br />
Shell states, “The possibility that an intra-orebody aquifer exists appears remote<br />
given that such a feature has not been identified from the large number of core<br />
holes advanced in the mine area. Appropriate mitigation measures will be<br />
implemented should an intra-ore aquifer be encountered during mine<br />
operations.”<br />
64a Were there any other assessment techniques used to support this assumption (e.g.<br />
Seismic survey) in light of the fact that geotechnical boreholes may not provide<br />
enough clarity regarding structural geological features?<br />
Response 64a No additional assessment techniques have been used. If an intra-orebody aquifer<br />
does exist, it is unlikely to be a large, continuous feature since it has not been<br />
identified by the 400 to 800 meter grid core hole drilling in the mining area.<br />
Request 64b Were any glacial channels and/or seated faults identified and delineated in the<br />
modeled area?<br />
Response 64b No glacial channels were identified within the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> local study area.<br />
This result is in agreement with Andriashek and Atkinson (2007).<br />
Section 3.2.5 of the Hydrogeology Environmental Setting Report<br />
(WorleyParsons Komex 2007) discusses the Sewetakun Fault, which has been<br />
interpreted to occur on the Precambrian surface and could influence hydraulic<br />
heads in the Middle Devonian aquifers. The groundwater flow models accounted<br />
for the possible influence of this fault zone on the groundwater flow regime<br />
through a specific hydraulic conductivity zone (see EIA, Appendix 4-1,<br />
Section 1.2.2.3, page 26).<br />
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References<br />
Question No. 65<br />
Andriashek, L.D. and N. Atkinson. 2007. Buried Channel and Glacial-Drift<br />
Aquifers in the Fort McMurray Region, Northeast Alberta. Alberta<br />
Geological Survey, Earth Sciences Report 2007-01.<br />
Section 7.1<br />
WorleyParsons Komex. 2007. Hydrogeology Environmental Setting Report for<br />
the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Prepared<br />
for Shell Canada Limited, Calgary, AB. Submitted December 2007.<br />
Request Volume 4A, Section 6.1.2, Page 217.<br />
Shell states, “This seepage will migrate towards (and potentially be captured by)<br />
the depressurization wells.”<br />
65a What is the fate of non-captured seepage in the basal aquifer?<br />
Response 65a The Athabasca <strong>River</strong> is the regional discharge point for the basal aquifer. The<br />
effects of the project, including groundwater seepage, on water quality in the<br />
Athabasca <strong>River</strong> were assessed in EIA, Volume 4A, Section 6.5.7.3. The<br />
assessment concluded that the project would have negligible effects on key water<br />
quality constituents and that changes in water quality in the Athabasca <strong>River</strong><br />
would have negligible effects on aquatic, human and wildlife health.<br />
Question No. 66<br />
Request Volume 4A, Section 6.1.2, Page 6-221.<br />
Shell states, “Substantial impacts to basal aquifer groundwater quality are not<br />
expected within this timeframe due to comparatively slow groundwater flow<br />
velocity.”<br />
66a Were the existing geological structures and characteristics (e.g. faults, secondary<br />
porosity, deep channels) considered in reaching this assumption? If yes, provide<br />
the technical approach used to incorporate those attributes.<br />
Response 66a Because of the low permeability of the overlying bitumen saturated sands, these<br />
geological features (faults, secondary porosity and deep channels) were<br />
considered to have no impact on the quality of the aquifer groundwater.<br />
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Question No. 67<br />
Request Volume 4A, Section 6.1.2, Page 6-222.<br />
Section 7.1<br />
Shell states, “Simulation results suggest that in the absence of mitigation, TDS<br />
will have migrated through the overburden deposits to Big Creek and the<br />
Athabasca <strong>River</strong> valley by 2031 (Figure 6.3-90), 13 years after the initiation of<br />
ETDA operation.”<br />
67a Define the techniques (e.g. pumping tests, geophysical surveys, infiltration tests)<br />
and assumptions that were used in assigning the hydraulic parameters to the<br />
various formations in the conceptual model.<br />
Response 67a Within the local study areas (LSAs) for each of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and<br />
Jackpine <strong>Mine</strong> Expansion, hydraulic parameters were assigned based on<br />
geometric mean values calculated from single well response tests. The response<br />
tests were conducted on monitoring wells installed in Quaternary deposits and<br />
the McMurray Formation (including the basal aquifer) during the baseline<br />
hydrogeological investigation (WorleyParsons Komex 2007).<br />
Reference<br />
Question No. 68<br />
In areas outside of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and Jackpine <strong>Mine</strong> Expansion LSAs<br />
and for the Devonian formations, model hydraulic parameters were assigned<br />
based on the parameterization described in previous hydrogeology baseline and<br />
EIA investigations in the region. For some formations, other data sources (i.e.,<br />
laboratory permeability testing and drill-stem testing data) were also reviewed if<br />
available well response testing (i.e., pumping test and single well response test)<br />
data were insufficient.<br />
WorleyParsons Komex. 2007. Hydrogeology Environmental Setting Report for<br />
the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Prepared<br />
for Shell Canada Limited, Calgary, AB. Submitted December 2007.<br />
Request Volume 4A, Section 6.3.6, Page 6-229.<br />
In Figure 6.3-95, the ETDA is overlying the basal aquifer outcropping recharge<br />
area; and in Figure 6.3-102, the intercepting wells are only capturing horizontal<br />
flow from the overburden sediments.<br />
68a Was the direct contact of the external tailings dump area (ETDA) with the basal<br />
aquifer considered in the model? If yes, then discuss the assumptions considered<br />
to simulate this zone.<br />
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Section 7.1<br />
Response 68a The basal aquifer is separated from the external tailings disposal area (ETDA) by<br />
overburden and oil sand deposits. Therefore, as there is no direct contact with the<br />
ETDA, it was not considered in the model.<br />
Request 68b Most of the anticipated results are based on the model simulation only. Due to<br />
proximity of the mine and EDTA to the Athabasca <strong>River</strong>, has Shell considered<br />
any other seepage prevention measures at the source? If so, discuss these<br />
measures and identify the reasons for omitting them.<br />
Response 68b See the response to AENV SIR 17a for the ETDA seepage management<br />
measures that Shell has considered.<br />
Question No. 69<br />
Request Volume 4A, Section 6.1.2, Page 6-229.<br />
Shell states, “Because of its low permeability, the buffer zone will be an effective<br />
barrier to eastward seepage.”<br />
69a Were seismic surveys performed to assess other geological features such as<br />
conduit paths, faults and deep channels which might enhance contaminant flow?<br />
What are the contingency plans in case such features exist?<br />
Response 69a Seismic surveys have not been conducted but it is unlikely that a large-scale<br />
geological feature exists in the mining area if it has not already been identified by<br />
core hole drilling in the mining area.<br />
Question No. 70<br />
If such geological features are identified in future detailed drilling programs for<br />
the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> area, Shell will assess the effects of such features on the<br />
low-permeability buffer zone and implement mitigation measures as appropriate.<br />
One such measure includes installing low permeability barriers, as described in<br />
EIA, Volume 4A, Section 6.3.6.2, page 6-237.<br />
Request Volume 4A, Section 6.1.4, Page 6-350.<br />
Shell states, “Therefore, the general water quality issues and potential mitigation<br />
for the <strong>Project</strong> were scoped with reference to past EIAs and experience gained by<br />
the assessment team in undertaking those assessments and participating in the<br />
public hearings for the corresponding projects.”<br />
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Section 7.1<br />
70a How does the above statement meet Shell’s commitment to use Best Available<br />
Environmental Practices?<br />
Response 70a Shell uses best industry practices in its activities, including the preparation of the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and Jackpine <strong>Mine</strong> Expansion environmental assessment. The<br />
quoted statement demonstrates that Shell has used the most current information<br />
available, and the advice of experts knowledgeable about water quality issues in<br />
the Athabasca area, which Shell believes represents best industry practices.<br />
Question No. 71<br />
Request Volume 4A, Section 6.1.4, Page 6-361.<br />
Shell states, “<strong>Project</strong> releases will not contribute to BTEX concentrations.” Shell<br />
further states, “Gypsum and thickeners may be used in creating NST” and<br />
“Water and sediment quality changes due to the <strong>Project</strong> effects are not classified<br />
in this section.”<br />
71a Describe the potential for BTEX compounds in end products due to the<br />
breakdown of the solvent.<br />
Response 71a The solvent is paraffinic and does not contain substantial amounts of toluene,<br />
ethyl benzene or xylene. The solvent contains only a small amount of benzene,<br />
the impact of which has been included in the environmental assessment. The<br />
compounds in the solvent (primarily pentanes and hexanes) are not expected to<br />
decompose into BTEX compounds.<br />
Request 71b What are the environmental impacts of asphaltene disposal in the tailings pond?<br />
Response 71b The addition of asphaltenes to a tailings pond is unlikely to degrade the water<br />
quality of the tailings pond and is supported by current operations at the Muskeg<br />
<strong>River</strong> <strong>Mine</strong>.<br />
Request 71c Identify potential flocculants/thickeners (other than gypsum) that are being<br />
considered.<br />
Response 71c Alum is currently being investigated as an alternative to gypsum for creating<br />
non-segregating tailings. The types of flocculants being considered are anionic<br />
polyacrylamides, such as the Hychem AF246 flocculant currently used in the<br />
thickeners at the Muskeg <strong>River</strong> <strong>Mine</strong>.<br />
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Section 7.1<br />
Request 71d Discuss the cumulative impacts to the groundwater quality during the life cycle<br />
of the operation.<br />
Response 71d Cumulative impacts to groundwater quality during the life cycle of the operation<br />
are assessed in EIA, Volume 4A, Sections 6.3.5 to 6.3.7.<br />
Question No. 72<br />
Request Volume 4A, Section 6.1.4, Page 6-368.<br />
Shell states, “The high background concentrations of these metals are<br />
characteristic of natural surface waters in the Oil Sands Region.”<br />
72a Provide references for this statement.<br />
Response 72a The statement cited indicates that the noted metals occur in natural surface waters<br />
in the Oil Sands Region at concentrations that exceed ambient water quality<br />
guideline values. Examples of where such concentrations have been exceeded<br />
and documented include:<br />
References<br />
• regional baseline data compiled by the Regional Aquatics Monitoring<br />
Program (RAMP 2006)<br />
• analytical results from water samples collected from natural surface waters<br />
by Alberta Environment (AENV 2006)<br />
• in environmental settings reports for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong> (Golder<br />
2007)<br />
• in applications by other oil sands operators (Golder 2005)<br />
AENV (Alberta Environment). 2006. Water Data System (WDS). Environmental<br />
Service, Environmental Services Division. Edmonton, AB.<br />
Golder (Golder Associates Ltd.). 2005. Water Quality Environmental Setting<br />
Report for the Suncor Voyageur <strong>Project</strong>. Prepared for Suncor Energy Inc.<br />
March 2005. Calgary, AB.<br />
Golder. 2007. Surface Water Quality Environmental Setting for the Jackpine<br />
<strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Submitted to Shell<br />
Canada Limited.<br />
RAMP (Regional Aquatics Monitoring Program). 2006. Regional Aquatics<br />
Monitoring Program (RAMP) 2005 Technical Report. Prepared for the<br />
RAMP Steering Committee. Submitted by the RAMP 2005<br />
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Question No. 73<br />
Request Volume 4A, Section 6.1.4, Page 6-369.<br />
Section 7.1<br />
Implementation Team consisting of Hatfield Consultants Ltd., Stantec<br />
Consulting Ltd., Mack, Slack and Associates Inc. and Western Resource<br />
Solutions. Submitted April, 2006.<br />
Shell states, “Concentrations of metals and Polycyclic Aromatic Hydrocarbons<br />
(PAHs) in sediments of watercourses and water bodies are generally lower than<br />
the Interim Sediment Quality Guideline. There are occasional exceedance of the<br />
ISQG values by concentrations of chromium in the upper Muskeg <strong>River</strong>, zinc in<br />
the middle Muskeg <strong>River</strong> and arsenic in Stanley Creek. Concentrations of six<br />
PAHs also occasionally exceed the ISQG values. These PAHs are<br />
dibenzo(a,h)anthracene, C1-substituted naphthalenes, benzo(a)anthracene,<br />
chrysene, phenanthrene and pyrene.”<br />
73a What is the time period, framework and sampling sequence for these field<br />
analyses?<br />
Response 73a The time period, framework and sampling sequence for the field program<br />
conducted in support of the EIA are presented in Section 3.2.4 of the surface<br />
water quality environmental setting report (Golder 2007). A description of<br />
historical data sources used in the analysis is presented in Section 3.2.3 of the<br />
surface water quality environmental setting report (Golder 2007).<br />
Reference<br />
Golder (Golder Associates Ltd.). 2007. Surface Water Quality Environmental<br />
Setting for the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>.<br />
Submitted to Shell Canada Limited.<br />
Request 73b Compare the streambed exceedences with the Interm Sediment Quality Guideline<br />
(ISQG) values.<br />
Response 73b Comparisons of <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> area sediment quality data with sediment<br />
quality guidelines are presented in Appendix F of the environmental setting<br />
report and discussed in Section 3.5 of the environmental setting report (Golder<br />
2007).<br />
Reference<br />
Golder (Golder Associates Ltd.). 2007. Surface Water Quality Environmental<br />
Setting for the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>.<br />
Submitted to Shell Canada Limited.<br />
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Question No. 74<br />
Request Appendex 4-1, Section 1.2.2.2, Page 12.<br />
Shell states, “Grid spacing was a uniform 500 m x 500 m.”<br />
Section 7.1<br />
74a How would the results of the sampling, if stratified, reflect the heterogeneity of<br />
the area (e.g., faces change, faults, rivers)?<br />
Response 74a The 500 m x 500 m grid cell is comparable to a legal subdivision (LSD) that has<br />
a size of about 400 m x 400 m. The cell provides sufficient horizontal resolution<br />
for the regional groundwater model over an area about 110 km x 120 km.<br />
Considering that the geological data were first interpolated and contoured to<br />
create a surface (e.g., top of McMurray Formation), which was then imported<br />
into the regional groundwater model, the 500 m x 500 m model grid cell used<br />
was compatible with the resolution of the available geological data and,<br />
therefore, reflected the heterogeneity present in the data set.<br />
Question No. 75<br />
The seven principal hydrostratigraphic units in the Regional Study Area (RSA)<br />
were represented using 12 model layers (see EIA, Volume 4B, Appendix 4-1,<br />
page 16) in order to provide adequate resolution of vertical groundwater flow<br />
within and between the units. This included:<br />
• three layers representing the Devonian formations<br />
• one layer representing the McMurray Formation basal aquifer<br />
• three layers representing the McMurray Formation oil sands<br />
• one layer representing the Clearwater and Grand Rapids Formations<br />
• four layers representing Quaternary deposits<br />
Request Appendix 4-1, Section 1.2.2.2, Page 25, Table 1.<br />
In Table 1, Shell refers to Calibrated Hydraulic Conductivity and Recharge<br />
Values in the Regional Model. Shell states, “as well as transient groundwater<br />
elevation data collected since the start-up of depressurization activities at the<br />
Syncrude Aurora North <strong>Mine</strong> and Albian Sands Muskeg <strong>River</strong> <strong>Mine</strong>.”<br />
75a Explain how values were initially estimated for the steady state calibration.<br />
Response 75a As discussed in the response to ERCB SIR 67a, hydraulic parameters were<br />
initially assigned within the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and Jackpine <strong>Mine</strong> Expansion<br />
local study areas (LSAs) based on geometric mean values calculated from single<br />
well response tests conducted during the baseline hydrogeological investigation.<br />
In areas outside of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and Jackpine <strong>Mine</strong> Expansion LSAs<br />
and for the Devonian formations, model hydraulic parameters were initially<br />
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assigned based on the parameterization described in previous hydrogeology<br />
baseline, EIA, and other selected investigations in the region.<br />
Section 7.1<br />
Recharge values were initially assigned based on professional judgment by<br />
referencing calibrated model values from other EIAs conducted in the region and<br />
other studies in similar hydrogeologic settings in Alberta.<br />
Request 75b Are the hydraulic values for each formation uniform?<br />
Response 75b Table 1 indicates that:<br />
• hydraulic conductivity values were generally uniform for each given<br />
geological material<br />
• there are regional variations within a formation. For example, four hydraulic<br />
conductivity values are assigned to McMurray Formation oil sands and two<br />
hydraulic conductivity values are assigned to the basal aquifer, for a total of<br />
six different hydraulic conductivity zones for the McMurray Formation<br />
The EIA, Appendix 4-1, Section 1.2.2.3, page 26, indicates that a uniform<br />
specific storage value was applied to all model layers.<br />
Request 75c Were the hydraulic conductivity values for the basal aquifer compared with other<br />
sources? If yes, then provide a summary of those sources and their reported<br />
values.<br />
Response 75c Table E on page 16 of the Hydrogeology Environmental Setting Report<br />
(WorleyParsons Komex 2007) lists reviewed sources and values of basal aquifer<br />
hydraulic conductivity in the region.<br />
Reference<br />
WorleyParsons Komex. 2007. Hydrogeology Environmental Setting Report for<br />
the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Prepared<br />
for Shell Canada Limited, Calgary, AB. Submitted December 2007.<br />
Request 75d Provide a chart illustrating the change in groundwater elevation and quality for<br />
the monitoring wells used in calibration from the pre-development groundwater<br />
levels to the present levels.<br />
Response 75d Figure 21 in EIA, Volume 4B, Appendix 4-1, Section 1.2.2.5, illustrates the<br />
changes in groundwater elevation from pre-development to the end of the<br />
calibration period (the end of December 2005) for select transient calibration<br />
points for the regional groundwater model.<br />
Since the model was calibrated to historical depressurization activities at Albian<br />
Sands Energy Inc.’s Muskeg <strong>River</strong> <strong>Mine</strong> and Syncrude Canada Ltd.’s Aurora<br />
North <strong>Mine</strong> and the effects of depressurization at these facilities is bounded to<br />
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Reference<br />
Section 7.1<br />
the west by the Athabasca <strong>River</strong>, no transient data calibration points are located<br />
on the west side of the river where the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will be located. The<br />
basal aquifer is thin and mostly absent in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> area to be mined<br />
(see Figure 5 in EIA, Volume 4B, Appendix 4-1).<br />
Groundwater quality data are not used in the calibration of groundwater flow<br />
models. As indicated in EIA, Volume 4B, Appendix 4-1, Section 1.2.2.5, the<br />
groundwater flow model was calibrated to measured groundwater levels and<br />
baseflow estimates.<br />
WorleyParsons Komex. 2007. Hydrogeology Environmental Setting Report for<br />
the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Prepared<br />
for Shell Canada Limited, Calgary, AB. Submitted December 2007.<br />
Request 75e Provide a cross-section of monitoring wells relative to the Syncrude Aurora<br />
North <strong>Mine</strong> and Albian Sands Muskeg <strong>River</strong> <strong>Mine</strong> illustrating their depth and<br />
penetration of the formation.<br />
Response 75e Cross-sections through the Muskeg <strong>River</strong> <strong>Mine</strong> and the Aurora North <strong>Mine</strong> were<br />
provided in the Hydrogeology Environmental Setting Report (see Figures 5 and<br />
10) that was prepared for the Muskeg <strong>River</strong> <strong>Mine</strong> Expansion <strong>Project</strong> (Komex<br />
International Ltd. 2004). These figures are reproduced here as Figure ERCB 75-1<br />
and ERCB 75-2. The cross-section locations are shown in Figures 1 and 9b of the<br />
Hydrogeology Environmental Setting Report, reproduced here as Figure ERCB<br />
75-3 and ERCB 75-4).<br />
Reference<br />
Komex International Ltd. 2004. Hydrogeology Environmental Setting – Muskeg<br />
<strong>River</strong> <strong>Mine</strong> Expansion. Prepared for Shell Canada Limited. December<br />
2004.<br />
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Section 7.1<br />
Figure ERCB 75-1: Geological Cross-Sections A–A′ and<br />
B–B′<br />
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Section 7.1<br />
Figure ERCB 75-2: Hydrogeological Cross-Sections C–<br />
C′, D–D′ and E–E′<br />
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Section 7.1<br />
Figure ERCB 75-3: Regional and Local Study Areas, Cross-Section Locations, Regional<br />
Topography and Drainage<br />
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Section 7.1<br />
Figure ERCB 75-4: Piezometer Locations – McMurray<br />
Formation – Basal Aquifer<br />
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Question No. 76<br />
Request Appendix 4-1, Section 1.2.2.2, Page 26.<br />
Section 7.1<br />
Shell states, “The Sewetaken Fault property zone (Figures 10 to 12) was<br />
introduced to reflect the possible influence of this fault on the groundwater flow<br />
regime.” Shell further states, “A uniform specific storage value of 3.5 x 10-5 m-1<br />
was applied to all model layers” and “The base of the local and regional<br />
groundwater flow models was also defined as a no-flow boundary condition.”<br />
76a Does the Sewetaken Fault extend to the Fort McMurray formation and further to<br />
the top overburden formations?<br />
Response 76a The Sewetakun Fault does not extend to the McMurray or overburden<br />
formations. Since the Sewetakun Fault occurs on the Precambrian surface and<br />
appears to influence hydraulic heads in the Middle Devonian aquifers, the<br />
Sewetakun Fault property zone was only implemented in the model layers (layers<br />
10 through 12) representing Devonian Formations (see EIA, Appendix 4-1,<br />
Section 1.2.2.3, page 26).<br />
Request 76b What were the geophysical techniques used to delineate the vertical and<br />
horizontal geological structures within the project area?<br />
Response 76b The Sewetakun Fault occurs at a depth below that expected for hydrogeological<br />
interaction with project activities, so no delineation of this structural feature was<br />
deemed necessary.<br />
Request 76c How does a low specific storage value of 3.5 x 10-5 m-1 reflect the higher<br />
Storativity values for the Quaternary formations (unconfined aquifers)?<br />
Response 76c In the numerical model (MODFLOW), the layer type for the upper three of four<br />
layers representing the Quaternary formations was specified to be Type 3. In<br />
MODFLOW, a Type 3 model layer means that the transmissivity of the layer<br />
varies based on the saturated thickness and hydraulic conductivity of the aquifer<br />
and that the storage coefficient can vary between confined (specific storage) and<br />
unconfined (specific yield) values. Therefore, if the model calculated the water<br />
level in a cell to be below the top of the cell, the storage value would be<br />
represented by the specific yield. In the upper three layers of the model, the<br />
specific yield value was 0.1.<br />
Request 76d Why were constant head values not assigned to the local and regional model<br />
boundaries instead of the no-flow boundary?<br />
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Section 7.1<br />
Response 76d The lateral boundaries of the regional model were chosen to approximate natural<br />
hydrogeologic boundaries (i.e., groundwater flow divides). Given the large<br />
distance from these lateral model boundaries to the stresses (overburden<br />
dewatering and basal aquifer depressurization) investigated in the regional<br />
model, the location of these groundwater divides is not affected by these stresses.<br />
Therefore, the no-flow boundary representation is conceptually more consistent<br />
with the natural functioning of a groundwater divide than a constant head<br />
boundary.<br />
The lateral boundaries of aquifers represented in the local models were assigned<br />
General Head Boundary (GHB) conditions to represent regional hydraulic<br />
gradients. Head values assigned to these GHBs were derived from the regional<br />
model results. Lateral boundaries of aquitards represented in the local models<br />
were assigned no flow boundary conditions (consistent with predominantly<br />
vertical flow in these aquitards).<br />
In the case of the model bases, no significant groundwater flow exchange is<br />
expected between the Precambrian and Devonian formations (i.e. the Devonian<br />
formations are interpreted to form the base of groundwater drainage in the<br />
Athabasca <strong>River</strong> basin) and, therefore, a no-flow boundary is appropriate.<br />
Request 76e How was lateral horizontal recharge from various sources accounted for (e.g.<br />
Birch Mountain)?<br />
Response 76e As stated in the response to ERCB SIR 76d, the lateral boundaries of the regional<br />
model were chosen to approximate groundwater flow divides, which are natural<br />
hydrogeologic boundaries. This means that lateral groundwater flow does not<br />
occur across these boundaries. Groundwater recharge enters the flow system<br />
vertically through the top model boundary of the regional model.<br />
Question No. 77<br />
Also stated in the response to ERCB SIR 76d, the lateral boundaries of aquifers<br />
represented in the local models were assigned General Head Boundary (GHB)<br />
conditions to represent regional hydraulic gradients. These GHBs account for the<br />
lateral horizontal recharge from other sources, including Birch Mountain.<br />
Request Appendix 4-1, Section 1.2.2.2, Page 28.<br />
Shell states, “Tailings area seepage was not represented in the regional model<br />
because the purpose of the model was to simulate basal aquifer depressurization<br />
and overburden dewatering. Tailings area seepage was represented in the JEMA<br />
and PRMA local models.”<br />
77a As both stresses (source and sink) are occurring simultaneously, how does<br />
simulating basal aquifer depressurization and overburden dewatering provide<br />
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sufficient confidence when one ongoing stress in not accounted for by the<br />
regional model?<br />
Section 7.1<br />
Response 77a At the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, the external tailings disposal area (ETDA) is separated<br />
from the mining area by about 3 km (see Figure 6.3-1 of EIA, Volume 4A,<br />
Section 6.3.1). Because of the physical separation, dewatering and<br />
depressurization activities at the mine site can be treated independently from<br />
ETDA seepage.<br />
Question No. 78<br />
At the Jackpine <strong>Mine</strong> Expansion, not incorporating seepage from the ETDA is<br />
considered conservative for overburden dewatering because of the ETDA<br />
seepage interceptor system that will be required for geotechnical purposes. This<br />
system would have been working for at least 10 years before overburden<br />
dewatering is required near the ETDA. Therefore, it would have, to some extent,<br />
effected drawdowns in the overburden material in the vicinity of the ETDA. By<br />
not incorporating ETDA seepage and the respective interception system, the<br />
overburden dewatering rates and duration are conservatively estimated. In<br />
relation to the basal aquifer depressurization, this aquifer is separated from the<br />
overburden deposits by the McMurray Formation, which is considered an<br />
aquitard. Therefore, ETDA seepage does not affect basal depressurization.<br />
Request Appendix 4-1, Section 1.2.4.2, Page 93, Table 8.<br />
In Table 8, Shell expresses Hydraulic Conductivity Values for <strong>Mine</strong> Materials in<br />
the <strong>Pierre</strong> <strong>River</strong> Mining Area Local Model.<br />
78a Provide the references used for assigning Hydraulic Permeability values for<br />
various materials listed in Table 8.<br />
Response 78a The hydraulic permeability values were determined independently based on<br />
values used in previous EIAs, professional experience and judgement.<br />
The hydraulic conductivity of 1 x 10 -8 m/s for mine pit backfill, as listed in EIA,<br />
Volume 4B, Appendix 4-1, Table 8, is in agreement with values used in previous<br />
assessments. In the Jackpine <strong>Mine</strong> Phase–1 EIA, Volume 3, Appendix VI, Table<br />
VI-3, page 38, (Shell 2002), the value for consolidated tailings (CT) was 1 x 10 -8<br />
m/s, and the value for mature fine tailings (MFT) was 2 x 10 -8 m/s. In the<br />
Muskeg <strong>River</strong> <strong>Mine</strong> EIA, Volume 3A, Appendix 3-1, Section 1.3.2.3, Table 1-6<br />
(Shell 2005), the hydraulic conductivity value for both non-segregating tailings<br />
(NST) and MFT was 1 x 10 -8 m/s.<br />
The fluid cells will contain thin fine tailings (TFT), which were assumed to be<br />
more permeable than the MFT because of the lower density of the TFT.<br />
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References<br />
Question No. 79<br />
Section 7.1<br />
Therefore, a hydraulic conductivity value of 1 x 10 -6 m/s was assigned to the<br />
fluid cells.<br />
The overburden cap hydraulic conductivity (1 x 10 -7 m/s) listed by Shell (2002;<br />
2005) is similar to the value (5 x 10 -7 m/s) listed in EIA, Volume 4B, Appendix<br />
4-1, Table 8, which was adjusted to reflect an average hydraulic conductivity<br />
value for overburden materials local to the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> area.<br />
EIA, Volume 4B, Appendix 4-1, Section 1.2.4.7, indicates that extensive<br />
prediction confidence simulations were conducted for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> local<br />
model by varying the hydraulic conductivity values of mine pit backfill, fluid<br />
tailings and overburden capping by factors of 10 from calibrated values. This<br />
factor of 10 addresses the uncertainty in the expected properties of these<br />
engineered materials.<br />
Shell (Shell Canada Limited). 2002. Application for Approval of the Jackpine<br />
<strong>Mine</strong> – Phase 1. Submitted to the Alberta Energy and Utilities Board and<br />
Alberta Environment. May 2002.<br />
Shell Canada Limited. 2005. Application for Approval of the Muskeg <strong>River</strong><br />
<strong>Mine</strong> Expansion <strong>Project</strong>. Submitted to the Alberta Energy and Utilities<br />
Board and Alberta Environment, April 2005.<br />
Request Appendix 4-1, Section 1.3.2, Page 102.<br />
Shell states, “The substances considered in this assessment represent a range of<br />
dissolved compound behaviors, including conservative (non-retarded and nondegradable),<br />
retarded and degradable constituents.”<br />
79a Discuss the chemical behavior pattern for non conservative constituents<br />
(Naphthenic acids and polycyclic aromatic hydrocarbons (PAHs)) in<br />
groundwater aquifers in terms of their adsorption tendency, fractionation<br />
(daughter products), organic carbon partitioning and oxidation-reduction<br />
potential.<br />
Response 79a The chemical behaviour of the indicator constituents included in the solute<br />
transport model, in terms of adsorption tendency (Kd) and anaerobic decay (halflife),<br />
are listed in EIA, Volume 4B, Appendix 4-1, Table 12. Organic carbon<br />
partitioning coefficients (Koc) for naphthenic acids, PAH Group 2 and PAH<br />
Group 8 were included in the distribution coefficients (Kd) by applying an<br />
organic carbon content fraction of 0.006 in the function Kd = Koc*foc. In the<br />
surface water quality assessment, retardation of PAH groups that were not<br />
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Section 7.1<br />
modelled explicitly in the solute transport model was applied based on structure<br />
similarity relative to indicator PAH groups.<br />
Anaerobic decay rates were applied to each PAH group and to labile naphthenic<br />
acids, as described in EIA, Volume 4B, Appendix 4-1, Table 12.<br />
No additional chemical or physical changes (e.g., oxidation-reduction potential)<br />
were modelled for naphthenic acids and PAHs in groundwater aquifers. If these<br />
processes occur, they will lead to reductions in solute concentrations beyond that<br />
predicted in the EIA modelling. Omitting these processes is, therefore,<br />
conservative.<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 2: ERCB SIRS – ROUND 2<br />
Question No. 80<br />
TERRESTRIAL<br />
ERCB SIR 80<br />
Request Volume 2, Section 20.3, Page 20-14.<br />
Section 8.1<br />
Shell states, “Development of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> requires diversion of natural<br />
watercourses during operations and at closure. Figure 20-2 shows these areas<br />
and their design features.”<br />
80a Provide an updated surface water diversion plan that ensures the diversion of<br />
natural watercourses during operations are integrated with future adjacent<br />
developers (e.g. UTS Energy Corporation/Teck Cominco Limited and CNRL).<br />
Response 80a The closure drainage plan for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> (see EIA, Volume 4B,<br />
Appendix 4-4) shows that the <strong>Pierre</strong> <strong>River</strong> diversion closure channel will be<br />
integrated with the Canadian Natural Resources Ltd. closure drainage channel<br />
from Calumet Lake.<br />
The UTS Energy Corporation/Teck Cominco Limited Equinox <strong>Mine</strong> was not<br />
included in the EIA because the project was not publicly disclosed six months<br />
before the EIA was submitted and there remains insufficient publicly available<br />
information on this project for inclusion in an integrated closure drainage plan.<br />
Therefore, the drainage plan presented in EIA, Volume 4B, Appendix 4-4 is<br />
appropriate and complete.<br />
Shell is aware of the need to integrate drainage with its industry neighbours.<br />
Shell is currently in discussions with its neighbours and expects that their<br />
concerns will be addressed in the foreseeable future.<br />
Request 80b Provide an updated final closure and drainage plan for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
that ensures the diversion of natural watercourses at closure are integrated with<br />
future adjacent developers (e.g. UTS Energy Corporation/Teck Cominco Limited<br />
and CNRL).<br />
Response 80b See the response to ERCB SIR 80a.<br />
April 2010 Shell Canada Limited 8-1<br />
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TERRESTRIAL ERCB SIR 80<br />
Section 8.1<br />
8-2 Shell Canada Limited April 2010<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 2: ERCB SIRS – ROUND 2<br />
Question No. 81<br />
ERRATA<br />
ERCB SIR 81<br />
Request Volume 1, Section 1.1, Page 1-2, Supplemental Information Responses;<br />
Volume 1, Section 8.1, Page 8-4, Supplemental Information Responses.<br />
Shell states, “The Athabasca Oil Sands <strong>Project</strong> (AOSP) is a joint venture<br />
between:<br />
• Shell Canada Energy (60%)<br />
• Chevron Canada Limited (20%)<br />
• Marathon Oil Sands L.P (20%)”<br />
Section 9.1<br />
81a Verify that Shell Canada Energy, not Shell Canada Limited, is a joint venture<br />
participant in the AOSP.<br />
Response 81a Yes, Shell Canada Energy is a joint venture participant in the AOSP.<br />
Shell Canada Limited will hold all permits and approvals for the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> on behalf of Shell Canada Energy, which will operate the mine on behalf of<br />
the joint venture participants.<br />
April 2010 Shell Canada Limited 9-1<br />
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ERRATA ERCB SIR 81<br />
Section 9.1<br />
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SUPPLEMENTAL INFORMATION<br />
PART 3: AENV SIRS – ROUND 2<br />
Question No. 1<br />
Request Volume 2, SIR 15, Page 15-8.<br />
GENERAL<br />
AENV SIRS 1 – 5<br />
Section 10.1<br />
Shell indicates that they are no longer considering an accelerated or closecoupled<br />
project execution scenario and are pursuing a more conservative<br />
execution plan, and consequently did not answer either SIR 15a or 15b.<br />
However, Shell also notes that if economic conditions change, they remain<br />
favourably positioned to revert to execution plans as presented in the original<br />
application and, once again, consider larger capital investments.<br />
1a Provide an overview of the potential environmental and social costs and benefits<br />
of pursuing a close-coupled or immediate development approach.<br />
Response 1a The environmental and social impacts associated with the close coupled (or<br />
immediate) development approach formed the basis of the Jackpine <strong>Mine</strong><br />
Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong> EIA that was submitted to the ERCB<br />
and Alberta Environment in December 2007 and updated in May 2008.<br />
Request 1b How does this compare to the potential environmental and social costs and<br />
benefits of delaying the development and/or increasing the time gaps between<br />
potential expansions?<br />
Response 1b As discussed in the December 2009 Jackpine <strong>Mine</strong> Expansion, Supplemental<br />
Information, Section 6.1, the broad scope of the original EIA assessment<br />
encompassed the possible impacts resulting from small project delays and<br />
concluded that no change to the EIA findings would occur.<br />
From an SEIA perspective, delaying the development or increasing the time gaps<br />
between expansions would create the need to demobilize and remobilize<br />
construction workforces. This would also delay the creation of long-term<br />
operations employment and associated revenues to government. In addition,<br />
population effects and associated service provider impacts would also be<br />
delayed. No other material impacts are expected.<br />
April 2010 Shell Canada Limited 10-1<br />
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GENERAL AENV SIRS 1 – 5<br />
Question No. 2<br />
Request Volume 1, Section 5, Page 5-10.<br />
Section 10.1<br />
Issues raised by the Community of Fort McMurray included adequate buffer<br />
zones along the Athabasca <strong>River</strong> and wildlife impacts.<br />
2a Provide further detail around the discussion held for these two issues.<br />
Response 2a These two issues were identified at an Open House held in Fort McMurray on<br />
May 1, 2008. This Open House was an open forum where community members<br />
could circulate among various project exhibits and ask questions of Shell staff in<br />
an informal atmosphere. Discussions regarding adequate buffers along the<br />
Athabasca <strong>River</strong> have been general and have related to:<br />
Question No. 3<br />
• maintenance of river navigability<br />
• access to the shoreline and visual impacts from the river<br />
Concerns associated with wildlife have generally focused on:<br />
• impacts to sport wildlife populations<br />
• changes to public access in areas used for hunting and trapping<br />
Request Volume 1, Section 4, Page 4-2; Volume 1, Section 4, Figure 3-2, Page 3-7.<br />
Shell describes the additional project components of two Class II landfills to be<br />
located adjacent to the plant site. One of these landfills is planned for the<br />
southeast corner of the plant site and appears to be approximately 250 m from<br />
the Athabasca <strong>River</strong> at its closest point.<br />
3a Given the toxicity of various waste categories planned for this site (e.g.,<br />
asphaltene fired boiler and co-generation fly ash and bottom ash, contaminated<br />
debris and soils), discuss the rationale behind locating this landfill close to the<br />
Athabasca <strong>River</strong>. Describe how the potential for contamination of the river over<br />
time was considered during the planning process.<br />
Response 3a The original basis for landfill placement was to allocate enough area while<br />
minimizing ore sterilization and maintaining the required 250 m river corridor.<br />
Further work has since been carried out regarding one of the two proposed<br />
locations of the Class II landfill. From an ore sterilization and river proximity<br />
perspective, the easternmost landfill is now proposed to be located within the<br />
north overburden disposal area footprint (see Figure AENV 3-1). Any potential<br />
contamination from the landfill will be managed in accordance with Alberta<br />
Environment’s Code of Practice for Landfills.<br />
10-2 Shell Canada Limited April 2010<br />
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GENERAL AENV SIRS 1 – 5<br />
Figure AENV 3-1: Revised Class II Landfill Site<br />
Section 10.1<br />
April 2010 Shell Canada Limited 10-3<br />
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GENERAL AENV SIRS 1 – 5<br />
Section 10.1<br />
Request 3b Present and discuss options for alternative landfill sites that are located further<br />
from the Athabasca <strong>River</strong> and which would reduce the potential for<br />
contamination of the river.<br />
Response 3b See the response to AENV SIR 3a.<br />
Request 3c Describe the design features planned for the class II landfills which ensure waste<br />
seepage will not contaminate groundwater and will not reach the Athabasca<br />
<strong>River</strong>.<br />
Response 3c Basic engineering has not been finalized on these landfills. Therefore, no<br />
information is available on their design features. As stated in the response to<br />
AENV SIR 3a, Shell will adhere to the appropriate Alberta codes and standards<br />
for designing Class II landfills and monitoring for any potential groundwater<br />
contamination.<br />
Question No. 4<br />
Request Volume 1, Section 4, Table 4-2, Page 4-8.<br />
Table 4-2 describes the various waste categories and disposal methods planned<br />
for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>. One of the waste categories is domestic garbage, food<br />
remnants and food contaminated waste to be deposited in the class II landfill.<br />
4a What design features and mitigation measures will Shell employ to ensure that<br />
the landfills will not attract wildlife? Has Shell considered fencing the landfills<br />
to prevent access by wildlife?<br />
Response 4a A portion of the Class II Landfill will be designated for domestic waste (food<br />
remnants and food-contaminated waste) and will be fenced to prevent wildlife<br />
access.<br />
Request 4b What is meant by the column title ‘storage location’ in Table 4-2? For example,<br />
when ‘bin’ is listed as the storage location, as it is for domestic garbage, does<br />
that mean all domestic garbage will be placed in some sort of vessel, and then<br />
dumped in the landfill? Clarify how waste materials will be handled at the<br />
landfill sites.<br />
Response 4b The storage location refers to how the waste material will be stored or<br />
transported. As in the example, bin refers to the receptacle in which waste<br />
material will be held before being taken to a landfill for final disposal. Waste<br />
material will be handled at Shell’s on-site landfills according to the Code of<br />
Practice for Landfills.<br />
10-4 Shell Canada Limited April 2010<br />
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GENERAL AENV SIRS 1 – 5<br />
Question No. 5<br />
Request Volume 2, SIR 13, Revised Table 13-1, Page 15-4.<br />
Section 10.1<br />
This table provides comments on the updated Waste Disposal Methods for the<br />
<strong>Pierre</strong> <strong>River</strong> Expansion Site. Two items in particular are proposed to be<br />
disposed of at the Regional Municipality of Wood Buffalo sewage lagoon<br />
facilities namely, filtered sewage cake and bar screenings. The address provided<br />
was the Regional Municipality of Wood Buffalo’s civic address. The Regional<br />
Municipality must be consulted for this service and there is no indication that<br />
this has been done.<br />
5a Provide confirmation from the Regional Municipality that they have been<br />
appropriately consulted regarding this specific question and that this is an<br />
acceptable practice and an acceptable solution for disposing of filtered sewage<br />
cake and bar screenings generated by the <strong>Project</strong>.<br />
Response 5a Personnel from the Fort McMurray Wastewater Facility, the new facility to<br />
replace the current sewage lagoon, confirmed acceptance of current and future<br />
sludge material from Shell’s facilities. They also confirmed that bar screenings<br />
would be better-suited for disposal in a landfill. Therefore, bar screenings will be<br />
placed in the on-site Class II Landfill.<br />
Table 4-2 of the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 1, has been updated with the new bar screening disposal method or<br />
location. The revised table is reproduced here as Table AENV 5-1.<br />
April 2010 Shell Canada Limited 10-5<br />
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GENERAL AENV SIRS 1 – 5<br />
Table AENV 5-1: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Waste Categories and Disposal Methods<br />
Section 10.1<br />
Waste Description<br />
Waste<br />
Category Storage Location Disposal Method or Location<br />
Liquid<br />
Amine 268 N/A Recycle water pond<br />
Aluminum sulphate 113 Labelled drums Approved off-site disposal facility<br />
Boiler blowdown water 136 N/A Recycle water pond<br />
Cooling tower system blowdown 136 N/A Recycle water pond<br />
Equipment wash 254 N/A Recycle water pond<br />
Filter backwash N/A N/A Recycle water pond<br />
Flammable liquids 271 Labelled drums Approved off-site recycle facility<br />
Flammable liquids 211/212 Labelled drums Approved off-site recycler<br />
Floor wash 254 N/A Extraction dump pond<br />
Glycol 222 Above-ground tank Reuse as spray on ore conveyor<br />
belts<br />
Kerosene 221 Labelled drums Approved off-site recycler<br />
Laboratory waste – hazardous solids<br />
and liquids<br />
263 Labelled drums Approved off-site recycler or disposal<br />
Laboratory waste – non-hazardous<br />
solids<br />
N/A Bin On-site landfill<br />
Methanol 212 Labelled drums Approved off-site recycler<br />
Oily water N/A Sumps ETDA<br />
Paint-related material 145 Labelled drums Approved off-site recycle facility<br />
Potassium hydroxide 121 Labelled drums Approved off-site disposal facility<br />
Sanitary sewage<br />
Spent acids, acid solutions and<br />
washings<br />
N/A Collection system<br />
and treatment plant<br />
Spent caustics, alkali solutions and<br />
washings<br />
Sanitary sewage plant, treated<br />
sewage to recycle water pond<br />
114 Labelled drums Approved off-site disposal facility<br />
122 Labelled drums Approved off-site disposal facility<br />
Spent solvents and solvent residues 211 Labelled drums Approved off-site recycler<br />
Steam condensate N/A N/A Approved off-site disposal facility<br />
Surface runoff water – clean N/A Industrial runoff<br />
collection ditch<br />
Surface runoff water – potentially oily N/A Industrial runoff<br />
collection ditch<br />
Recycle water pond<br />
Recycle water pond<br />
Transformer oil N/A Labelled drums Approved off-site recycler<br />
Vent or flare liquids N/A Flare knockout drum Returned to process<br />
Vessel drains N/A Sumps Returned to process or recycle water<br />
pond<br />
Waste oils (lubricating, hydraulic,<br />
transmission)<br />
252 Labelled drums,<br />
tank<br />
Approved off-site recycler<br />
Waste paint and paint-related materials 223 Labelled drums Approved off-site recycler<br />
Water contaminated with hydrocarbons 254 Labelled drums Approved off-site recycler<br />
Water treatment wastewater N/A N/A Recycle water pond<br />
10-6 Shell Canada Limited April 2010<br />
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GENERAL AENV SIRS 1 – 5<br />
Solid<br />
Section 10.1<br />
Table AENV 5-1: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Waste Categories and Disposal Methods (cont’d)<br />
Waste Description<br />
Asphaltene-fired boiler and cogeneration<br />
bottom ash<br />
Asphaltene-fired boiler and cogeneration<br />
fly ash<br />
Asphaltene-fired boiler and cogeneration<br />
gypsum<br />
Asphaltene-fired cogeneration spent<br />
activated carbon<br />
Asphaltene-fired boiler and cogeneration<br />
spent catalyst<br />
Waste<br />
Category Storage Location Disposal Method or Location<br />
146 Silo On-site landfill<br />
146 Silo On-site landfill<br />
132 Silo On-site landfill<br />
261 Labelled drums On-site landfill<br />
153 Original package Returned to manufacturer<br />
Bar screenings N/A Vacuum truck On-site landfill<br />
Batteries 151 Labelled drums or<br />
bins<br />
Approved off-site recycler<br />
Beverage containers N/A Recycle bin Approved off-site recycler<br />
Carbon filters (natural gas) 261 Filter housings On-site landfill<br />
Cardboard N/A Recycle bin Recycled<br />
Cartridge filters 256 Bin On-site landfill<br />
Construction material, wood, glass, other<br />
debris<br />
Contaminated debris and soil 138/275 Labelled drums or<br />
bins<br />
Corrosive solids N/A Labelled drums or<br />
bins<br />
275 Bin Recycled or sent to on-site landfill<br />
On-site landfill<br />
Desiccant (air dryers) 154 Bin On-site landfill<br />
Domestic garbage (food remnants and<br />
food-contaminated waste)<br />
N/A Bin On-site landfill<br />
Approved off-site disposal facility<br />
Drilling muds 272 Bin On-site waste dump<br />
Empty calibration gas and compressed<br />
gas cylinders<br />
Empty packages, drums, bags,<br />
containers<br />
331 Labelled drums or<br />
bins<br />
Empty, pressurized aerosol cans 145 Labelled drums or<br />
bins<br />
e-waste N/A Labelled drums or<br />
bins<br />
Approved off-site recycler<br />
152 Bins, drums or pails Returned to supplier, reused or sent<br />
to on-site landfill<br />
Approved off-site recycler<br />
Approved off-site recycler<br />
Filtered sewage cake 274 Vacuum truck Regional Municipality of Wood<br />
Buffalo sewage lagoon<br />
Fluorescent lamps 153 Cardboard box Approved off-site recycler<br />
Ion exchange resin (softeners) 136 Labelled drums On-site landfill<br />
Kitchen grease N/A Grease bin Approved off-site disposal facility<br />
Oil filters from internal combustion<br />
engines<br />
275 Labelled bins Approved off-site recycler<br />
April 2010 Shell Canada Limited 10-7<br />
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GENERAL AENV SIRS 1 – 5<br />
Section 10.1<br />
Table AENV 5-1: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Waste Categories and Disposal Methods (cont’d)<br />
Waste Description<br />
Solid (cont’d)<br />
Oily rags, sorbent pads and materials 274 Labelled drums or<br />
bins<br />
Waste<br />
Category Storage Location Disposal Method or Location<br />
Approved off-site disposal facility or<br />
recycler<br />
Paper B3020 Recycle bin Recycled<br />
Peroxide N/A Labelled drums or<br />
bins<br />
Approved off-site disposal facility<br />
Plastics, used N/A Recycle bin Approved off-site recycler<br />
Poison N/A Labelled drums or<br />
bins<br />
Approved off-site disposal facility<br />
Scrap metal N/A Recycle bin Approved off-site recycler<br />
Sock filters 256 Bin Approved off-site recycler or on-site<br />
landfill<br />
Spent batteries (acid, alkali, nickelcadmium,<br />
lithium)<br />
1151 Labelled drums,<br />
containers<br />
Approved off-site recycler<br />
Tires N/A Tire cage Approved off-site recycler<br />
Toner cartridges for copiers and printers N/A Original package Returned to supplier for recycle<br />
Waste inorganic chemicals, including<br />
laboratory packs<br />
Waste organic chemicals, including<br />
laboratory packs<br />
Sludge<br />
Truck wash sump 150 Drums and vacuum<br />
truck<br />
148 Labelled drums Approved off-site disposal facility<br />
263 Labelled drums Approved off-site disposal facility<br />
ETDA<br />
Heat exchanger bundle cleaning 251 Labelled container ETDA<br />
Oil and water separator 251 Labelled drums Approved off-site disposal facility<br />
Other<br />
First aid room waste N/A Marked hazardous<br />
biowaste containers<br />
Regional health centre treatment<br />
facility<br />
10-8 Shell Canada Limited April 2010<br />
CR029
PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 3: AENV SIRS – ROUND 2<br />
Question No. 6<br />
AIR<br />
Request Volume 2, SIR 240a, Page 20-9<br />
AENV SIRS 6 – 14<br />
Section 11.1<br />
6a Clearly describe the methods, the limitations of the methods used and the<br />
stochastic and empirical uncertainties in estimating predicted 1-hour average<br />
concentrations of benzene or TRS compounds and discuss the effects of these<br />
limitations on the assessment.<br />
Response 6a As stated in EIA Volume 3, Appendix 3-8, Section 3.2.1.5, the tailings pond<br />
fugitive emissions for the project were scaled from the Jackpine <strong>Mine</strong> – Phase 1<br />
tailings pond fugitive emissions presented in the Shell Jackpine <strong>Mine</strong> – Phase 1<br />
<strong>Project</strong> EIA (Shell 2002) on the basis of mined bitumen. The Jackpine <strong>Mine</strong> –<br />
Phase 1 tailings pond emissions were estimated by scaling the Baseline Case<br />
Muskeg <strong>River</strong> <strong>Mine</strong> emissions presented in the Syncrude Mildred Lake EIA<br />
(Syncrude 1998). The Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> tailings<br />
pond fugitive emissions were modelled at the constant maximum rate over the<br />
entire modelling period. The 1-hour, 24-hour and annual concentrations were<br />
predicted based on this emission rate.<br />
There are implicit uncertainties associated with using monthly emission rates<br />
rather than daily or hourly ones; however, this uncertainty is addressed by using<br />
the maximum emission rate for each month. It is not possible to predict<br />
concentrations due to hourly emission variations unless detailed monitoring data<br />
are available to aid in providing better estimates of emission rates from tailings<br />
ponds. Since there are no long-term hourly monitoring data available for tailings<br />
ponds in the region, the emissions were estimated based on data available from<br />
other EIAs.<br />
To determine how the CALPUFF model is performing in the Oil Sands Region, a<br />
performance evaluation was completed in EIA Volume 3, Appendix 3-8, Section<br />
2.5. This evaluation was conducted using the Existing Scenario model<br />
predictions (EIA, Volume 3, Appendix 3-8, Section 2.4) in comparison with<br />
available monitoring data. The Existing Scenario emissions were based on the<br />
assumed level of operations in 2002 and 2003. The fugitive VOC emissions from<br />
the tailings ponds in the Existing Scenario were estimated based on an annual<br />
average solvent loss of 4.0 to 4.5 barrels (bbl) of solvent per 1,000 bbl of bitumen<br />
produced.<br />
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AIR AENV SIRS 6 – 14<br />
Section 11.1<br />
Further analysis was completed for individual volatile organic compounds<br />
(VOCs) by comparing the Existing Scenario predictions with monitored<br />
concentrations. The VOC monitoring conducted in the region relies on noncontinuous<br />
techniques that collect 24-hour samples on a set schedule; therefore,<br />
only 24-hour and annual concentrations could be evaluated.<br />
A review of the monitoring data showed that higher concentrations were<br />
typically observed prior to 2008. This may be linked to higher annual average<br />
solvent losses as operators worked to optimize their solvent recovery technology.<br />
For example, the Shell Muskeg <strong>River</strong> <strong>Mine</strong> annual average solvent loss since<br />
2003 has ranged from 3.7 to 10.6 bbl of solvent per 1,000 bbl of bitumen<br />
produced (see the response to SIR 159a in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 1. While solvent loss information was not<br />
available from other operators in the region, the annual average solvent losses<br />
from these operations are expected to have been variable as well.<br />
In 2008 and 2009, the monitored concentrations were generally lower and are<br />
thought to correspond to the solvent loss rates used for the Existing Case. For<br />
example, the Shell Muskeg <strong>River</strong> <strong>Mine</strong> annual average solvent loss was 4.0 bbl<br />
of solvent per 1,000 bbl of bitumen produced in 2008 (see the response to SIR<br />
159a in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1).<br />
Since the Existing Case tailings pond emissions were based on solvent losses of 4<br />
to 4.5 bbl of solvent per 1,000 bbl of bitumen produced, as stated previously, it is<br />
likely that the VOC predictions are more representative of the 2008/2009 period.<br />
When compared to the 2008/2009 monitoring data, the maximum 24-hour<br />
predictions were generally within the same range when outlier concentrations<br />
were excluded. The outlier concentrations were removed from the analysis since<br />
they were likely due to upset events, which were not considered in the model.<br />
Only two data points, which accounted for 2% of the data, were removed from<br />
one station in the analysis.<br />
The highest 24-hour benzene concentration monitored at Fort McKay in<br />
2008/2009 was 1.8 µg/m³. Outliers were not identified in the Fort McKay data;<br />
therefore, none of the monitoring data were excluded. The 24-hour predicted<br />
maximum concentration at Fort McKay was 1.4 µg/m³. This difference of<br />
0.4 µg/m³, while lower than the highest monitored concentration, is considered<br />
within the accuracy of the model. The annual average Existing Scenario benzene<br />
predictions were generally within 2 µg/m³ lower than 2008/2009 monitored<br />
values at all the stations; however, this is considered within the accuracy of the<br />
model.<br />
While this analysis focused on VOCs, the same conclusions can be made for TRS<br />
compounds which are also primarily emitted from tailings ponds.<br />
11-2 Shell Canada Limited April 2010<br />
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AIR AENV SIRS 6 – 14<br />
Question No. 7<br />
Request Volume 2, SIR 240c, Page 20-10.<br />
Section 11.1<br />
Shell states that Higher air temperatures predicted for future climate change<br />
scenarios might alter the monthly distribution of emissions. However, the annual<br />
average emission rates are not expected to change.<br />
7a Provide evidence to support the statement quoted above, or describe and quantify<br />
the uncertainties pertaining to potential future increases in VOC and TRS<br />
emissions under warmer climatic conditions in the future.<br />
Response 7a Many variables may affect tailings pond emissions including:<br />
Question No. 8<br />
• amount of diluent lost to the pond<br />
• pond water temperature<br />
• atmospheric conditions – wind speed, temperature, stability<br />
Based on the methodology used for determining variable emissions in the EIA,<br />
increasing the number of monthly degree days would not measurably affect the<br />
model predictions. This is because the annual average emission rate is assumed<br />
to be fixed at 40% of the diluent lost to the pond. Since the annual average<br />
emission rate is dependant only upon diluent loss, increasing temperature would<br />
not affect the emission estimate. Only the distribution of the emissions would be<br />
affected if the number of monthly degree days was increased.<br />
Request Volume 2, SIR 244, Page 20-16.<br />
Though the formulae used for both the Ambient Ratio Method (ARM) and Ozone<br />
Limiting Method (OLM) methods were not provided, and hence cannot be<br />
independently validated. The outcome may be consistent with what is cited in the<br />
response to the SIR, however it appears to contradict the text associated with<br />
Tables 244-1 thru 244-3, where the textual response states: The maximum<br />
concentrations associated with the Jackpine <strong>Mine</strong> Expansion and the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> project NOx emissions are expected to occur at locations close to the<br />
large mine area sources. The predicted NO2 concentrations at these locations<br />
are typically much higher than the predicted concentrations at communities or<br />
location further away.<br />
April 2010 Shell Canada Limited 11-3<br />
CR029
AIR AENV SIRS 6 – 14<br />
TABLE 1 - THEOROETICAL NO2 VALUES USING OLM AND ARM<br />
NOx (ppm) OLM NO2 (ppm) ARM NO2 (ppm)<br />
0.000 0.000 0.000<br />
0.050 0.050 0.009<br />
0.100 0.060 0.018<br />
0.150 0.065 0.027<br />
0.200 0.070 0.036<br />
0.250 0.075 0.045<br />
0.300 0.080 0.054<br />
0.350 0.085 0.063<br />
0.400 0.090 0.072<br />
0.450 0.095 0.081<br />
0.500 0.100 0.090<br />
0.550 0.105 0.099<br />
0.600 0.110 0.108<br />
0.650 0.115 0.117<br />
0.700 0.120 0.126<br />
0.750 0.125 0.135<br />
0.800 0.130 0.144<br />
0.850 0.135 0.153<br />
0.900 0.140 0.162<br />
0.950 0.145 0.171<br />
1.000 0.150 0.180<br />
Section 11.1<br />
Tables 244-1 thru 244-3 indicate that the maximum NO2 concentrations occur<br />
approximately 20+ kilometres from the emission sources. This outcome is<br />
contradictory to the text noted above which indicates that the higher NO2<br />
concentrations will occur at close locations.<br />
8a Revise the text and/or tables to correct this apparent contradiction or<br />
inconsistency so that this component can be properly assessed.<br />
Response 8a The maximum 1-hour, 24-hour and annual nitrogen dioxide (NO2) predictions<br />
outside developed areas in the local study area (LSA) and regional study area<br />
(RSA), as shown in Tables 244-1 to 244-3, are related to other existing or<br />
approved mining projects (e.g., Imperial Oil Resources Ventures Limited Kearl<br />
Oil Sands <strong>Project</strong>). Therefore, the concept that predicted NO2 concentrations at<br />
locations close to major oxides of nitrogen (NOx) emissions sources are typically<br />
much higher than the predicted concentrations at communities or locations<br />
further away is valid.<br />
11-4 Shell Canada Limited April 2010<br />
CR029
AIR AENV SIRS 6 – 14<br />
Section 11.1<br />
Request 8b Shell states Overall, the results show that the maximum NO2 predictions near the<br />
major NOx emissions sources using ARM are lower than the OLM results. Based<br />
on the application of the OLM formulation as noted in Table 1, this statement<br />
should be corrected to allow a complete assessment of this component of the EIA.<br />
Response 8b The ambient ratio method (ARM) formula is provided in EIA Volume 3,<br />
Appendix 3-8, Section 2.3.5 and was applied to each model hour. The formula is<br />
provided below for reference.<br />
Syncrude North<br />
where:<br />
<strong>Mine</strong><br />
[ NO<br />
[NO2] = nitrogen dioxide concentration [ppm]<br />
2 −0.<br />
608<br />
= 0.<br />
100×<br />
[ NO ]<br />
[ NO ]<br />
X<br />
X<br />
[NOx] = oxides of nitrogen concentration [ppm]<br />
April 2010 Shell Canada Limited 11-5<br />
CR029<br />
]<br />
The ozone limiting factor (OLM) formula from the Air Quality Model Guideline<br />
(AENV 2003) is as follows:<br />
If [O3] > 0.9x[NOx] then [NO2] = [NOx]<br />
otherwise [NO2] = [O3] + 0.1x[NOx]<br />
where:<br />
[O3] = ozone concentration [ppm]<br />
[NO2] = nitrogen dioxide concentration [ppm]<br />
[NOx] = oxides of nitrogen concentration [ppm]<br />
Hourly ground-level ozone observations from the Wood Buffalo Environmental<br />
Association (WBEA) Fort McKay air quality monitoring station for 2002 were<br />
used in the OLM formula. The year 2002 was chosen to coincide with the<br />
meteorological data and modelling year. The OLM formula was applied by<br />
matching the hourly NOx predictions with the hourly monitored ozone<br />
concentrations.<br />
Since the background ozone concentrations and the predicted NOx concentrations<br />
vary by hour, it is not feasible to show calculations for every hour; however,<br />
example values are shown in Table AENV 8-1. These sample calculations show<br />
that either the OLM or the ARM method can produce higher NO2 predictions<br />
based on the hourly NOx and ozone concentrations. However, based on the<br />
results in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 2,<br />
SIR 244, Tables 244-1 to 244-3, the ARM-based 1-hour and 24-hour NO2<br />
predictions are consistently lower than those derived from the OLM when<br />
considering locations near the major NOx sources (e.g., active mine areas).
AIR AENV SIRS 6 – 14<br />
Table AENV 8-1: Example Hourly OLM and ARM NO2 Concentrations<br />
Hour<br />
Predicted NOx<br />
Concentration<br />
[µg/m³] (ppm)<br />
Observed<br />
Ozone<br />
Concentration<br />
[µg/m³]<br />
OLM NO2<br />
Concentration<br />
[µg/m³] (ppm)<br />
ARM NO2<br />
Concentration<br />
[µg/m³] (ppm)<br />
1 1,000 (0.532) 0.008 115 (0.061) 147 (0.078)<br />
2 1,050 (0.558) 0.010 143 (0.076) 150 (0.080)<br />
3 900 (0.479) 0.007 146 (0.078) 141 (0.075)<br />
4 800 (0.425) 0.005 127 (0.068) 135 (0.072)<br />
5 850 (0.452) 0.006 179 (0.095) 138 (0.073)<br />
Note: Unit conversions from µg/m³ to ppm are based on the molecular weight of NO2 and<br />
standard conditions of 25°C and 101.325 kPa.<br />
Reference<br />
Section 11.1<br />
AENV (Alberta Environment). 2003. Air Quality Model Guideline. Prepared by<br />
the Science and Standards Branch, Environmental Services Division,<br />
Alberta Environment. Edmonton, AB. March 2003.<br />
Request 8c Provide the data and formula used to generate the ARM or OLM NO2<br />
concentrations and provide an example of the calculations to verify the data<br />
contained in Tables 244-1 thru 244-3.<br />
Response 8c See the response to AENV SIR 8b.<br />
Question No. 9<br />
Request Volume 2, SIR 246, Page 20-30.<br />
The question that was raised in the SIR was fundamentally: “Will the CWS for<br />
PM2.5 be met when engine deterioration is included in the emission estimates?”<br />
9a Provide the details of how the model was employed, including but not limited to<br />
the data sets used, their statistical robustness, the numerical analysis,<br />
redundancy testing, model confidence and reliability and limitations of the model<br />
that allow confirmation of the EIA statements.<br />
Response 9a The NONROAD methodology (United States Environmental Protection Agency<br />
[US EPA] 2005) for estimating mine fleet emissions includes several key<br />
elements. First, it has developed emission factors for different vehicle types and<br />
ratings representing steady-state vehicle operation. Second, the NONROAD<br />
methodology includes a load factor accounting for the fact that mine vehicles<br />
cannot constantly operate at their maximum rated horsepower. Last, it<br />
11-6 Shell Canada Limited April 2010<br />
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AIR AENV SIRS 6 – 14<br />
Vehicle Emissions<br />
Section 11.1<br />
incorporates the emissions profile for a mobile engine during transient operating<br />
conditions and takes into consideration the engine’s deterioration over time.<br />
The NONROAD model estimates emission rates for a single vehicle based on the<br />
following equation:<br />
= Vehicle Horsepower × Steady − State Emission Factor × GrossOperating<br />
Hours ×<br />
Load Factor × Transient Adjustment Factor × Deterioration<br />
Factor<br />
The steady-state emission factors from the US EPA NONROAD are summarized<br />
in Table AENV 9-1. The transient adjustment factors and deterioration factors<br />
from the NONROAD methodology are presented in Table AENV 9-2. The load<br />
factors from the NONROAD methodology are listed in Table AENV 9-3.<br />
Inputs to the NONROAD model, including the engine rating, tier, operating<br />
hours and other characteristics associated with the vehicle fleet, are subject to the<br />
accuracy and availability of project specific data. The assumptions and<br />
parameterizations used in the model are required to simplify the calculation of<br />
mobile exhaust emissions, which inherently introduces limitations to the<br />
accuracy of the emissions. However, the NONROAD model has become widely<br />
accepted and provides results that are representative of project conditions. Details<br />
regarding the NONROAD model formulation, confidence, reliability and<br />
limitations are provided in two US EPA documents (US EPA 2005; 2009).<br />
Table AENV 9-1: Steady-State Emissions Factors for Nonroad Diesel Engines<br />
Model Emission Factors (Zero-Hour, Steady-State) [g/bhp-hr]<br />
Category of Vehicle<br />
Vehicles 300 to 600 bhp<br />
Year NOx CO PM HC<br />
tier 1 1996 6.015 1.306 0.201 0.203<br />
tier 2 2001 4.335 0.843 0.132 0.167<br />
tier 3 2006 2.500 0.843 0.150 0.167<br />
tier 4 final<br />
Vehicles 600 to 750 bhp<br />
2011 0.276 0.084 0.009 0.131<br />
tier 1 1996 5.822 1.327 0.220 0.147<br />
tier 2 2002 4.100 1.327 0.132 0.167<br />
tier 3 2006 2.500 1.327 0.150 0.167<br />
tier 4 final<br />
Vehicles >750 bhp<br />
2011 0.276 0.133 0.009 0.131<br />
tier 1 2000 6.153 0.764 0.193 0.286<br />
tier 2 2006 4.100 0.764 0.132 0.167<br />
tier 3 - - - - -<br />
tier 4 final 2011 2.392 0.076 0.069 (a) 0.282 (a)<br />
Note:<br />
(a) Tier 4 transitional emission factors that are more conservative than tier 4 final emission factors are used for both<br />
particulate matter (PM) and hydrocarbon (HC) emissions.<br />
- = No criteria available.<br />
Source: US EPA NONROAD Methodology (US EPA 2004).<br />
April 2010 Shell Canada Limited 11-7<br />
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AIR AENV SIRS 6 – 14<br />
Section 11.1<br />
Table AENV 9-2: Transient Adjustment and Deterioration Factors for Nonroad Diesel<br />
Engines<br />
Category of Vehicle<br />
Transient adjustment factors<br />
NOx CO PM HC<br />
tier 1 0.95 1.53 1.23 1.05<br />
tier 2 0.95 1.53 1.23 1.05<br />
tier 3 1.04 1.53 1.47 1.05<br />
tier 4(a) – – – –<br />
Deterioration factors(b)<br />
tier 1 1.024 1.101 1.473 1.036<br />
tier 2 1.009 1.101 1.473 1.034<br />
tier 3 1.008 1.151 1.473 1.027<br />
tier 4 1.008 1.151 1.473 1.027<br />
Note:<br />
(a) There is no transient adjustment factor for tier 4 engines since transient emission control is expected to be an integral part<br />
of all tier 4 engines.<br />
(b) Engines are assumed to be at the end of their median life to have conservative deterioration factors in calculations.<br />
- = No criteria available.<br />
Source: US EPA NONROAD Methodology (US EPA 2004).<br />
References<br />
Table AENV 9-3: Load Factors for Nonroad Diesel Engines<br />
Category of Vehicle Load Factor<br />
truck 0.58<br />
shovel 0.58<br />
dozer 0.58<br />
grader 0.58<br />
pipe layer 0.58<br />
cable reeler 0.58<br />
excavator 0.53<br />
Source: US EPA NONROAD Methodology (US EPA 2004).<br />
US EPA. 2004. Exhaust and Crankcase Emission Factors for Nonroad Engine<br />
Modelling – Compression Ignition. Prepared by the Office of<br />
Transportation and Air Quality, Research Triangle Park, NC. Report No.<br />
NR-009c.<br />
US EPA. 2005. Technical Highlights – Frequently Asked Questions About<br />
NONROAD 2005. Prepared by the Office of Transportation and Air<br />
Quality, Research Triangle Park, NC. Report No. EPA420-F-05-058.<br />
US EPA. 2009. NONROAD Model (nonroad engines, equipment, and vehicles).<br />
http://www.epa.gov/oms/nonrdmdl.htm#model. Accessed October 2009.<br />
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AIR AENV SIRS 6 – 14<br />
Question No. 10<br />
Request Volume 2, SIR 247, Page 20-31.<br />
Section 11.1<br />
The CALMET (meteorological component of the California Puff Model System)<br />
file input options were provided however there is one inconsistency when<br />
comparing the 1995 and 2002 files. The upper air station WSE (Stony Plain) has<br />
a significantly different easting associated with it: 692.114 km E in 1995 and<br />
294.641 km E in 2002. All other upper air, surface and precipitation stations are<br />
consistent between 1995 and 2002. This error or inaccuracy may have a<br />
significant effect on the results of the model but can only be definitively answered<br />
by correcting the data. That is, a difference in distance of this magnitude is<br />
likely to have an effect on the meteorological parameters assumed in the<br />
modeling and therefore on the predicted air quality results but this cannot be<br />
presently determined. It may be that the data input files which indicate for both<br />
the 1995 and 2002 runs, that the UTM zone used was 12 (the correct Zone is 11)<br />
indicates that the positioning of the Stony Plain station for 2002 was inaccurate,<br />
displaced by approximately 400 kilometres to the west near the Rocky<br />
Mountains. It effectively means that the Stony Plain meteorological data were<br />
not used in the dispersion modeling analysis.<br />
10a How does this error affect the California Puff Model (CALPUFF) results?<br />
Response 10a The coordinates of the Stony Plain upper air station were incorrect in the 1995<br />
CALMET data set but were correct in the 2002 CALMET data set. Because of<br />
the considerable distance between the Stony Plain station and the project (about<br />
450 km) and since the interpolation of the observations in CALMET is based on<br />
the inverse-squared method, the influence of these observations would be<br />
negligible in the project region. In addition, the Fort Smith upper air station is<br />
located about 300 km north of the project region and would likely have a greater<br />
influence than the Stony Plain station.<br />
To determine the effect of the incorrect location of the Stony Plain upper air<br />
station in the 1995 CALMET data set, a comparison of the original 1995<br />
CALMET and the corrected 1995 CALMET data (i.e., the Stony Plain upper<br />
station location corrected) for the grid cell containing the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> plant<br />
site was completed. The analysis included a comparison of hourly values of<br />
CALMET-derived mixing height, stability class and vertical profiles of<br />
temperature, wind speed and wind direction. The comparison of the hourly data<br />
indicated the following:<br />
• Mixing Height – Twelve hours of the 8,760 hours in the year had a difference<br />
greater than 5 m. The largest difference was 24 m.<br />
• Stability Class – Four hours out of the year had a difference in stability class<br />
• Temperature – Four hours out of all the levels showed a difference greater<br />
than 0.5°C.<br />
• Wind Speed – There were no hours with a difference greater than 0.5 m/s.<br />
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AIR AENV SIRS 6 – 14<br />
Height Above Ground (m)<br />
Height Above Ground (m)<br />
3,000<br />
2,500<br />
2,000<br />
1,500<br />
1,000<br />
500<br />
3,000<br />
2,500<br />
2,000<br />
1,500<br />
1,000<br />
Section 11.1<br />
• Wind Direction – A total of 11 hours at all levels had a difference greater<br />
than 5 degrees.<br />
Figure AENV 10-1 presents vertical profiles of temperature, wind speed and<br />
wind direction for the grid cell containing the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> plant site for two<br />
hours with the largest difference in wind direction. These comparisons show that<br />
the difference between the CALMET data sets is negligible; therefore, the<br />
CALPUFF predictions would not be measurably affected by the incorrect Stony<br />
Plain station location used in the 1995 CALMET data set. These differences<br />
would also not change the conclusions of the air quality impact assessment.<br />
0<br />
260 265 270 275 280 285 290<br />
Temperature (K)<br />
Original 1995 CALMET<br />
Corrected 1995 CALMET<br />
500<br />
0<br />
270 275 280 285 290 295<br />
Temperature (K)<br />
Original 1995 CALMET<br />
Corrected 1995 CALMET<br />
Height Above Ground (m)<br />
Height Above Ground Ground (m)<br />
3,000<br />
2,500<br />
2,000<br />
1,500<br />
1,000<br />
500<br />
May 4, 1995 2 p.m.<br />
0<br />
0 2 4 6<br />
Wind Speed (m/s)<br />
Original 1995 CALMET<br />
Corrected 1995 CALMET<br />
August 15, 1995 1 p.m.<br />
3,000<br />
2,500<br />
2,000<br />
1,500<br />
1,000<br />
500<br />
0<br />
0 2 4<br />
Wind Speed (m/s)<br />
Original 1995 CALMET<br />
Corrected 1995 CALMET<br />
6<br />
0<br />
0 100 200 300<br />
Wind Direction (deg)<br />
Original 1995 CALMET<br />
Corrected 1995 CALMET<br />
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Height Above Ground (m)<br />
Height Above Ground Ground (m)<br />
3,000<br />
2,500<br />
2,000<br />
1,500<br />
1,000<br />
500<br />
3,000<br />
2,500<br />
2,000<br />
1,500<br />
1,000<br />
500<br />
0<br />
0 100 200 300<br />
Wind Direction (deg)<br />
Original 1995 CALMET<br />
Corrected 1995 CALMET<br />
Figure AENV 10-1: Comparison of Temperature, Wind Speed and Wind Direction Vertical<br />
Profiles
AIR AENV SIRS 6 – 14<br />
Section 11.1<br />
Request 10b What might the range of new values be if the model was to be re-run, and how<br />
are these estimates are arrived at?<br />
Response 10b As discussed in AENV SIR 10a, the effect of the incorrect location of the Stony<br />
Plain upper air station in the 1995 CALMET data set was negligible; therefore,<br />
the CALPUFF predictions would not be measurably affected.<br />
Request 10c What is the statistical level of confidence that supports the estimated change in<br />
any of the expected outcomes?<br />
Response 10c As discussed in AENV SIR 10a, only a few hours of the 1995 CALMET data set<br />
were affected by the incorrect location of the Stony Plain upper air station. While<br />
it is not possible to determine the statistical confidence, professional judgment<br />
suggests that the CALPUFF predictions would not be measurably affected.<br />
Question No. 11<br />
Request Volume 2, SIR 249, Page 20-40.<br />
In concert with the concerns raised with SIR 247, Shell provides a data<br />
validation of MM5 with two supporting figures. Figure 249-2 in particular<br />
compares the upper air results for a particular sounding in 1995. As can be seen<br />
in this figure, at lower altitudes the MM5 and Fort Smith data are comparable<br />
while the Stony Plain data are different. All three data sources show good<br />
agreement at higher altitudes.<br />
Given the problem with the easting coordinate for Stony Plain in 1995 as<br />
previously noted, any errors in the projected wind field will be more prevalent at<br />
lower altitudes as opposed to the higher levels. Such errors would have a much<br />
greater effect on dispersion of air pollutant emissions at the lower altitudes,<br />
meaning that the concurrence of the data at the higher altitudes is largely<br />
irrelevant.<br />
11a Verify that the displacement of the Stony Plain upper air station does not affect<br />
the rawinsonde data used in the modeling, and as such did not affect the<br />
predicted dispersion modeling results.<br />
Response 11a The displacement of the Stony Plain upper air station does not affect the<br />
rawinsonde data used in the modelling and the CALPUFF predictions would not<br />
be measurably affected.<br />
The effects of the displacement of the Stony Plain upper air station in the 1995<br />
CALMET data set were assessed in AENV SIR 10a. The vertical profiles of<br />
temperature, wind speed and wind direction for the grid cell containing the <strong>Pierre</strong><br />
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Question No. 12<br />
Section 11.1<br />
<strong>River</strong> <strong>Mine</strong> plant site shown in that response illustrate that the difference between<br />
the original 1995 CALMET data set and the corrected data set is negligible.<br />
Request Volume 2, SIR 250b i-ii, Page 20-43.<br />
Shell indicates that the failure of the SO2 control equipment is expected to be<br />
once in every 17 years, and that the determination of this probability is consistent<br />
with the technique outlined in the EPRI FGD Redundancy Development<br />
document cited in the question.<br />
12a Provide supporting information on the calculation of SO2 control equipment<br />
failure probability, and demonstrate that the method used to estimate failure rate<br />
probability is consistent with the EPRI document.<br />
Response 12a The SO2 control equipment failure frequency was estimated by an engineering<br />
contractor engaged by Shell. Based on a preliminary equipment scope, Shell<br />
worked with an equipment manufacturer to incorporate industry experience on<br />
FGD reliability performance. Although this is not necessarily consistent with the<br />
EPRI document as stated in the response to SIR 250bii in the May 2009 <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 2, Shell believes that this level<br />
of reliability is achievable and reasonable at this stage of the process design. The<br />
level of design detail required by EPRI would typically be dealt with during the<br />
detailed engineering phase of the project.<br />
Question No. 13<br />
Despite this preliminary scope, it is expected the SO2 control equipment will<br />
have a high availability (see the response to ERCB SIR 40). In addition, the<br />
boiler and burner design will be capable of switching to natural gas on short<br />
notice (about 15 minutes) if the FGD system fails.<br />
Request Volume 2, SIR 250e, Page 20-47.<br />
An equipment failure rate of once in 17 years would not be considered an<br />
“unlikely” event based on the EPRI method of evaluating SO2 control systems<br />
because it means that the equipment is likely to fail at least once during the life of<br />
the facility. Furthermore, a probability of equipment failure of once in 17 years<br />
does not mean that the equipment will fail only once in every 17 years. For<br />
example, the equipment could fail twice in a 10 year period, and then not again<br />
for the next 25 years and still remain within the 1-in-17 year probability failure<br />
rate.<br />
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Section 11.1<br />
Risk management requires that the criticality of the failure be considered. This<br />
requires that both the probability and the consequence of failure be considered<br />
jointly. A piece of equipment that fails frequently but whose failure carries little<br />
consequence poses a low risk. On the other hand, equipment that has a low<br />
frequency of failure but whose failure has serious consequences is a high risk<br />
management issue. In the response to this SIR 250d, Shell acknowledges that<br />
there is a potential to create concentrations sufficient to cause acute injury to<br />
vegetation.<br />
13a Discuss potential human health effects as a result of accidental releases of SO2.<br />
Provide quantitative evidence in support of the discussion.<br />
Response 13a The health assessment for this upset scenario was included in EIA, Volume 3,<br />
Appendix 3-8, Section 4.3.3.<br />
Question No. 14<br />
As part of the health assessment, maximum predicted ground-level air<br />
concentrations of SO2 were compared to varying concentrations at which health<br />
effects are known to occur. As discussed, the aim of the health assessment was to<br />
establish the nature and severity of the health effects related to the predicted air<br />
concentrations associated with the described upset events.<br />
The findings of the health assessment indicated that some of the predicted SO2<br />
concentrations were high enough to potentially cause adverse health effects.<br />
However, Shell has committed to redundant SO2 pollution control equipment that<br />
will switch to natural gas within 15 minutes and, consequently, decrease the<br />
exposure time.<br />
Request Volume 2, SIR 235a, Page 20-2.<br />
Shell indicates The typical odour threshold for each compound was determined<br />
by calculating the geometric mean of the available odour thresholds. It is<br />
common practice in sensory evaluation to use geometric means as they account<br />
for the wide range of responses over several orders if magnitude. The SIR<br />
response then demonstrates the calculation of an H2S threshold using the<br />
maximum and minimum values from the 9 pieces of cited literature. The<br />
calculation assumes that all of the reported H2S odour thresholds in the cited<br />
references are equally valid in calculating the geometric mean. Many of the<br />
references Shell cites for odour thresholds are outdated and not appropriate for<br />
the objective of assessing the effects of odour. More recent sources of<br />
information provide confirmation of much lower odour thresholds for H2S (e.g.,<br />
Harvard University 2005 1 ; Iowa State University 2004 2 ; Lenntech 2006 3 ). All of<br />
these sources confirm an odour threshold of 1 ppb for H 2 S. The use of the<br />
geometric mean concentration value of 14 µg/m 3 underestimates H2S odour<br />
impacts due to the proposed development knowing that there are observation<br />
data to demonstrate that H2S is detectable at instantaneous odour concentrations<br />
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AIR AENV SIRS 6 – 14<br />
Section 11.1<br />
as low as 1 ppb (0.7 µg/m 3 ) by individuals who have been tested and found to<br />
have a sense of smell that falls within the normal range of the general<br />
population.<br />
______________________<br />
1 Harvard University 2006. Comparison of Odor Thresholds and PEL’s/TLV’s of<br />
Some Substances. http://research.dfci.harvard.edu/ehs/PPE/Respirators/<br />
2 Iowa State University 2004. The Science of Smell Part 1: Odor Perception and<br />
Physiological Response. PM 1963a, May 2004.<br />
3 Lenntech Holding B.V. 2006. Odorous Substances (Osmogenes) and Odor<br />
Thresholds. http://www.lenntech.com/table.htm<br />
14a Justify use of the geometric mean when, as Shell indicates, much lower available<br />
and scientifically valid thresholds could have been used.<br />
Response 14a If the hydrogen sulphide (H2S) odour threshold were set to 0.7 µg/m 3 , the<br />
predicted frequency of hours with concentrations above this revised odour<br />
threshold would increase. However, the odour threshold used in the EIA is<br />
appropriate for the following reasons:<br />
• One of the five guiding principles for developing the Federal National<br />
Ambient Air Quality Objectives (NAAQOs) states that the objectives should<br />
recognize the variable sensitivities of subgroups of the Canadian population<br />
and of particular ecosystems and organisms in the environment. Because of<br />
the large range of these sensitivities, it might not be possible to protect every<br />
sensitive individual and ecosystem from all effects (WGAQOG 1996). The<br />
use of an H2S odour threshold of 0.7 µg/m³ would overestimate odour<br />
impacts.<br />
• The typical H2S odour threshold of 14.1 µg/m³ is similar to the 1-hour<br />
Alberta Ambient Air Quality Objective (AAAQO), which is based on odour<br />
perception and is meant to protect the general population. The AAAQO is<br />
also one of the most stringent in Canada and the United States (AEP 1999;<br />
AENV 2004).<br />
• It is common practice in sensory evaluation to use geometric means as they<br />
account for the wide range of responses over several orders of magnitude<br />
(AIHA 1989). The odour standards and guidelines in Ontario are based on<br />
the geometric mean of odour detection thresholds reported in literature<br />
(Government of Ontario 2009, internet site).<br />
• The odour thresholds taken from the available literature are valid. Additional<br />
references of Harvard University (2006), Iowa State University (2004) and<br />
Lenntech (2006) do not change the calculated geometric mean for H2S, nor<br />
suggest that calculating an odour threshold using geometric mean is<br />
inappropriate.<br />
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AIR AENV SIRS 6 – 14<br />
References<br />
Section 11.1<br />
AENV (Alberta Environment). 2004. Assessment Report on Reduced Sulphur<br />
Compounds for Developing Ambient Air Quality Objectives. Prepared<br />
by AMEC Earth & Environmental Limited and University of Calgary.<br />
Pub. No: T/754. November 2004.<br />
AEP (Alberta Environmental Protection). 1999. A comparison of Alberta’s<br />
Environmental Standards to those of other North American Jurisdictions.<br />
Pub No. I/733. March 24, 1999.<br />
AIHA (American Industrial Hygiene Association). 1989. Odor Thresholds for<br />
Chemicals with Established Occupational Health Standards. Fairfax,<br />
Virginia.<br />
Government of Ontario. 2009. Proposed Approach for the Implementation of<br />
Odour-Based Standards and Guidelines. http://www.ebr.gov.on.ca/ERS-<br />
WEB-<br />
External/displaynoticecontent.do?noticeId=Mjc4ODc=&statusId=MTUw<br />
MDQ0&language=en. Accessed October 2009.<br />
Harvard University 2006. Comparison of Odor Thresholds and PEL’s/TLV’s of<br />
Some Substances. http://research.dfci.harvard.edu/ehs/PPE/Respirators/<br />
Iowa State University 2004. The Science of Smell Part 1: Odor Perception and<br />
Physiological Response. PM 1963a, May 2004.<br />
Lenntech Holding B.V. 2006. Odorous Substances (Osmogenes) and Odor<br />
Thresholds. http://www.lenntech.com/table.htm<br />
WGAQOG (Federal-Provincial Working Group on Air Quality Objectives and<br />
Guidelines). 1996. Protocol for the Development of National Ambient<br />
Air Quality Objectives. Part 1 Science Assessment Document and<br />
Derivation of the Reference Level(s). November 2006.<br />
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Section 11.1<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 3: AENV SIRS – ROUND 2<br />
Question No. 15<br />
Request Volume 2, SIR 265, Page 21-3.<br />
WATER<br />
AENV SIRS 15 – 43<br />
Section 12.1<br />
Shell describes the polishing ponds water treatment, pond residence time and<br />
other items.<br />
15a Since the ponds are designed to contain and convey flows for all hydrologic<br />
conditions up to the 100 year flood without uncontrolled spillage, provide the<br />
emergency response plans for potential spillage in the unlikely event of flows<br />
exceeding 100 year flood flows.<br />
Response 15a Polishing ponds are primarily required for mitigating elevated levels of total<br />
suspended solids (TSS) in runoff during high flow events. During a flood event<br />
exceeding the 100-year flood event, the outlet of the polishing pond would likely<br />
erode, becoming wider and deeper. Flows through the compromised pond would<br />
discharge along the outlet channel into the receiving streams. Levels of TSS<br />
discharging from the pond would be high, but would be similar to those in<br />
receiving streams. As a result, receiving stream TSS levels would not<br />
substantially increase with the addition of polishing pond discharge beyond the<br />
range of natural variability.<br />
Given that the TSS levels of the discharge would be similar to the receiving<br />
streams and that the flow path would remain intact, a detailed emergency<br />
response plan (ERP) for this unlikely failure scenario has not been developed.<br />
Request 15b Since the pond residence time is about eight hours and the TSS monitoring<br />
frequency is three times per week, what measures are proposed to be in place to<br />
confirm that uncontrolled releases are not occurring between sampling events?<br />
How will potential releases during these times be addressed, with specific<br />
reference to each potential parameter of concern?<br />
Response 15b As noted in the response to SIR 265 in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 2, Shell will monitor at the frequency<br />
specified in the EPEA approval, and may increase the monitoring frequency as<br />
appropriate when monitoring results indicate a potential non-compliance. In<br />
Shell’s experience, the frequency and quantity of monitoring prescribed by<br />
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WATER AENV SIRS 15 – 43<br />
Section 12.1<br />
AENV would readily detect any pond that had a water quality problem requiring<br />
action. Shell currently monitors over 100 parameters at the Jackpine <strong>Mine</strong><br />
polishing pond outlets on varying monitoring schedules in a very comprehensive<br />
monitoring program. Shell will comply with the water quality monitoring<br />
regulatory requirements for all parameters.<br />
Request 15c The water management systems are described as having a capacity to hold water<br />
and achieve zero discharge for extended periods.<br />
i. What are the anticipated holding times during the time of highest anticipated<br />
flows and what are the flows expected?<br />
ii. Where will the water be held during the extended periods of zero discharge<br />
and what is the water holding capacity of the holding area(s)?<br />
iii. What planning is in place to rehabilitate water quality in the unlikely event<br />
that the water cannot be held for a sufficient time to mitigate water quality<br />
issues?<br />
Response 15c i. The water management systems described in the response to SIR 265b in the<br />
May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 2, refer to<br />
areas with closed-circuit drainage. These areas do not include areas where<br />
muskeg and overburden are being dewatered, as these flows would be<br />
directed to the polishing ponds. For areas with closed circuit drainage, the<br />
holding times are anticipated to be essentially unlimited in most cases. For<br />
example:<br />
• the EDTA is designed to withstand the probable maximum flood<br />
• in the mine pit, all runoff is contained until it is actively pumped out of<br />
the pit. The water holding capacity remains extremely large at all times,<br />
even though it varies with the ever-evolving size of the mine pit.<br />
• former mine pits backfilled with tailings (i.e., in-pit deposition cells), like<br />
the active mine pits, are below grade until final capping. Like active<br />
mine pits, water would be contained until pumped out of the cells.<br />
• the plant site area would be at risk of releasing surface runoff to the<br />
environment, but only in extreme events when ditch and pump systems<br />
could be overwhelmed. During those events, water quality of the release,<br />
with elevated levels of TSS, would be similar to the water quality of the<br />
receiving environment.<br />
• overburden disposal areas drain through collection ditches that<br />
eventually make their way to the recycle water system<br />
• areas reclaimed back to grade would send water to collection ditches that<br />
would return to the water recycle system<br />
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WATER AENV SIRS 15 – 43<br />
Section 12.1<br />
ii. For the response to this question, see the response to AENV SIR 15ci.<br />
iii. For the response to this question, see the response to AENV SIR 15ci.<br />
Request 15d Shell describes corrective actions to include diverting water to vegetated areas to<br />
trap sediments and mitigate water quality for other parameters of concern.<br />
i. What are the other parameters of concern?<br />
ii. What physiological and biogeochemical processes will the vegetated areas<br />
employ to mitigate the water quality and how will Shell apply these processes<br />
to other parameters of concern?<br />
Response 15d i. Other parameters of concern include constituents that can be associated with<br />
sediment particles suspended in water, including aluminum, cadmium,<br />
chromium, copper, iron, lead, mercury, phosphorus, silver and zinc. These<br />
also can include parameters noted in EPEA Approvals, water management<br />
frameworks and other regulatory approvals, including biological oxygen<br />
demand (BOD), nitrogen, phosphorus, toxic organic compounds, and total<br />
dissolved solids (TDS).<br />
Reference<br />
ii. The vegetated areas of interest are typically wetlands, such as small<br />
watercourses, bogs and marshes on the mine surface lease, although upland<br />
vegetation in this area also provides many or all of the same functions to<br />
some degree. Kadlec and Knight (1996) provide a rule of thumb that a<br />
wetland removes about three-quarters of the incoming TSS, provided<br />
incoming TSS has concentrations greater than 20 mg/L. Data collected by<br />
Shell for releases of polishing pond water to Shelley Creek show that<br />
wetlands in the Oil Sands Region are similarly effective at removing TSS.<br />
Wetlands remove TSS via several pathways, including microscale and<br />
macroscale deposition, inertial deposition on plant stems, and sediment<br />
particles sticking to biofilms. Settling and filtration of suspended sediments<br />
would remove compounds that are bound to these sediments, such as<br />
aluminum, cadmium, chromium, copper, iron, lead, mercury, phosphorus,<br />
silver and zinc. In addition, wetlands are known to significantly improve<br />
water quality characteristics, such as BOD, nitrogen, phosphorus, toxic<br />
organic compounds, and TDS. Advantages of wetlands are they are selfmaintaining<br />
and they add no unnatural chemicals to the environment. They<br />
also support a viable natural ecosystem.<br />
Kadlec, R.H. and R.L. Knight. 1996. Treatment Wetlands. CRC Press/Lewis<br />
Publishers. Boca Raton, Florida. 893 pp.<br />
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WATER AENV SIRS 15 – 43<br />
Section 12.1<br />
Request 15e Shell states that if the water does not meet the water quality guidelines, the<br />
release will be reported to AENV and mitigation action plans implemented.<br />
i. What are the mitigation action plans for accidental releases of hydrocarbon<br />
containing waters to the environment (include mitigation action plans for<br />
soils impacts and surface water impacts)?<br />
ii. What are the action plans in place for the potential release for each potential<br />
parameter of concern?<br />
Response 15e i. In the unlikely event that hydrocarbon-containing waters are accidentally<br />
released to the environment, spill control measures would be undertaken to<br />
safely re-establish containment and to arrest the spread of the release in the<br />
receiving environment. These spill control measures can include the use of<br />
temporary earthen dams, oil skimmers and absorbent booms. Spill control<br />
would then be followed by an assessment of the impacts of the release. Based<br />
on the assessment, spill countermeasures would be employed. These could<br />
include cleaning up contaminated soils and contained waters, and monitoring<br />
and managing the effects of the spill, as appropriate.<br />
Question No. 16<br />
As noted in the response to SIR 265 in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 2, spill control and countermeasures<br />
would be developed on a case-by-case basis and implemented in consultation<br />
with AENV.<br />
ii. The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will build upon the existing emergency response plans<br />
already in place at the Muskeg <strong>River</strong> and Jackpine <strong>Mine</strong>s. Site-specific<br />
details for responding to the accidental release of hazardous substances will<br />
be developed during the detailed design phase of the project.<br />
Request Volume 1, SIR 318, Page 13-22.<br />
Shell was asked what their contingency plan was to meet water requirements if<br />
proposed storage capacity is not adequate or if the quality of recycled/reused<br />
water does not meet the project needs. Shell’s response was they would consider<br />
several options.<br />
16a What options would Shell consider?<br />
Response 16a Several contingency options may be available to Shell to meet water withdrawal<br />
requirements during exceptional low-flow periods in the Athabasca <strong>River</strong>. These<br />
include:<br />
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Section 12.1<br />
• ongoing and potentially increased instantaneous diversion of groundwater<br />
sources<br />
• use of untreated recycle water for gland water<br />
• reducing bitumen production to reduce water consumption<br />
These options individually or in combination could be used to complement<br />
Shell’s proposed raw water storage.<br />
Request 16b Discuss their feasibility and rank them.<br />
Response 16b Each of the contingency options discussed in the response to AENV SIR 16a<br />
may be technically feasible. However, the choice and ranking will be highly<br />
dependent on the prevailing environmental and mine operating circumstances.<br />
Currently, it would be speculative to comment on the preferred ranking.<br />
Question No. 17<br />
Request Volume 2, SIR 271, Page 21-11.<br />
Shell states An evaluation of options for ETDA subsurface seepage control was<br />
conducted for the closure stage of the facility.<br />
17a Provide a comparable assessment of various subsurface seepage control<br />
alternative (including liners) against interception pumping wells option taking<br />
into consideration its sustainability, efficiency, and maintenance requirements.<br />
Response 17a Shell’s proposed seepage management plan involving a series of recovery wells<br />
was determined to provide a high degree of efficiency in permeable soils and a<br />
wide degree of operational flexibility. Table AENV 17-1 compares the ETDA<br />
seepage management alternatives against the requirements for sustainability,<br />
efficiency, and maintenance.<br />
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Table AENV 17-1: Comparison of ETDA Seepage Management Alternatives<br />
Method Characteristics Sustainability<br />
Pumping<br />
wells<br />
• Appropriate in gravel to<br />
silty fine sand soils.<br />
• Unrestricted depths using<br />
submersible pumps.<br />
• Costs are relatively<br />
moderate.<br />
Slurry wall • Appropriate in silts, sands,<br />
gravels and cobbles.<br />
• Depths generally limited to<br />
40 to 60 m, depending on<br />
soil and site conditions.<br />
• Requires relief wells<br />
upgradient of slurry wall.<br />
• Costs are relatively high<br />
for deep cut-off walls.<br />
Clay liners • Requires large volumes of<br />
clay.<br />
• Requires substantial site<br />
preparation, detailed<br />
quality control, and<br />
protection against dry/wet<br />
and freeze/thaw cycles.<br />
• Requires installation of<br />
horizontal drains in ETDA<br />
to alleviate ETDA pore<br />
pressure.<br />
• Cost is relatively high, and<br />
can be even more costly if<br />
clay source not close to<br />
the ETDA site.<br />
Synthetic<br />
liners<br />
• Requires intense site<br />
preparation, detailed<br />
quality control.<br />
• Requires installation of<br />
horizontal drains in ETDA<br />
to alleviate ETDA pore<br />
pressure.<br />
• Cost is relatively high.<br />
• Temporary<br />
measure.<br />
• Affects groundwater<br />
flows while in<br />
operation.<br />
• Once pumps are<br />
decommissioned,<br />
the groundwater<br />
levels and flow<br />
directions will<br />
recover.<br />
• Permanent and<br />
passive measure.<br />
• Permanently affects<br />
groundwater levels<br />
and flow directions.<br />
• Permanent and<br />
passive measure.<br />
• Does not affect<br />
underlying<br />
groundwater flows,<br />
as seepage is<br />
contained above<br />
natural surface.<br />
• Permanent and<br />
passive measure.<br />
• Does not affect the<br />
underlying<br />
groundwater flows<br />
as seepage is<br />
contained above<br />
natural surface.<br />
Performance<br />
Efficiency<br />
• High efficiency in<br />
permeable soils<br />
(gravel to silty fine<br />
sand) as it creates a<br />
cone of depression<br />
that works as a<br />
hydraulic barrier.<br />
• High efficiency in<br />
containing seepage<br />
as it provides low<br />
permeability barriers<br />
as a result of<br />
bentonite or clay<br />
slurry.<br />
• High efficiency in<br />
containing seepage<br />
when constructed<br />
properly and<br />
protected.<br />
• High efficiency in<br />
containing seepage<br />
when properly<br />
installed and<br />
protected.<br />
• Resistant to variety<br />
of chemicals.<br />
Section 12.1<br />
Operational<br />
Maintenance<br />
• High. Requires<br />
monitoring of<br />
drawdown and<br />
pumping rates,<br />
systematic<br />
adjustment of<br />
pumping rates,<br />
monitoring of well<br />
efficiency and<br />
cleanup, pump<br />
replacement and well<br />
replacement.<br />
• No maintenance for<br />
slurry wall and relief<br />
well system.<br />
• No maintenance<br />
once covered by<br />
tailings.<br />
• No maintenance<br />
once covered by<br />
tailings.<br />
Request 17b Shell describes details that demonstrate a high confidence in the likelihood of<br />
successful mitigation of ETDA seepage water, anticipated seepage rates, and<br />
other aspects. The predicted seepage rate from the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA<br />
during operations was 240 L/s (Response 271b).<br />
i. How was this rate determined?<br />
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WATER AENV SIRS 15 – 43<br />
ii. What was the minimum and maximum predicted rate?<br />
Section 12.1<br />
Response 17b i. The predicted seepage rate from the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> external tailings<br />
disposal area (ETDA) during operations was determined using the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> local groundwater flow model (see EIA, Appendix 4-1, Section<br />
1.2.4, page 93). The hydrogeology modeling information provided in<br />
Appendix 4-1 describes the geological surfaces, model limits, parameters,<br />
boundary conditions and calibration.<br />
ii. During operations, the minimum predicted ETDA seepage rate was 50 L/s,<br />
whereas the maximum predicted ETDA seepage rate was 550 L/s (see EIA,<br />
Volume 4A, Section 6.3.6.2, Table 6.3-18).<br />
Request 17c What is the degree of confidence in the rate of 240 L/s?<br />
Response 17c The degree of confidence in the estimated seepage rate of 240 L/s is considered<br />
moderate. Because of the conservatism built into the prediction of the seepage<br />
rate, as described in the following, the predicted seepage rate of 240 L/s is<br />
expected to be representative of an upper-end estimate.<br />
The seepage rate from the ETDA ultimately depends on:<br />
• the rate at which the ETDA deposits can transmit water vertically<br />
• the hydraulic conductivity of the aquifer underlying the ETDA, reflecting the<br />
capacity of the aquifer to transmit the seepage from the ETDA deposits<br />
The ETDA was represented in the model with a general head boundary (GHB).<br />
Vertical tailings water transmission rates were controlled by the conductance (C)<br />
of the GHB (which depends on the thickness and hydraulic conductivity [K] of<br />
the tailings) and specified fluid levels in the tailings, as discussed in the response<br />
to AENV SIR 18fi.<br />
ETDA Thickness for GHB<br />
The thickness of the ETDA was conservatively represented as 5 m, although the<br />
ETDA design thickness is 45 m. In reality, the thickness of the ETDA will<br />
increase with time through the active lifetime of the ETDA. This assumption of a<br />
reduced thickness leads to more conservative seepage rates.<br />
ETDA Hydraulic Conductivity for GHB<br />
The vertical hydraulic conductivity of the ETDA deposits was assigned one value<br />
(1 x 10 -8 m/s) for the entire ETDA footprint. The hydraulic conductivity of the<br />
tailings deposits will vary based on the composition and deposition method of the<br />
tailings. The vertical hydraulic conductivity would be about 1 x 10 -10 m/s for<br />
thickened tailings (TT), about 1 x 10 -8 m/s for mature fine tailings (MFT), and<br />
about 2.5 x 10 -6 m/s for tailings sand (Volume 3A, Appendix 3-1, Tables 1-6 and<br />
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Section 12.1<br />
1-5 of the Muskeg <strong>River</strong> <strong>Mine</strong> Expansion EIA. Considering that most of the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA footprint will consist of areas of TT and of areas of<br />
tailings sand that are overlain by MFT, which will effectively limit the seepage<br />
rate to that of MFT, the overall hydraulic conductivity of 1 x 10 -8 m/s assigned to<br />
the ETDA deposits is considered conservative, leading to higher assumed<br />
seepage rates. Potential reduction of tailings sand hydraulic conductivity as a<br />
result of bitumen or sludge deposits and entrapment (Hunter, 2001) were not<br />
considered.<br />
ETDA Fluid Level Elevation for GHB<br />
The fluid level specified for the ETDA was constant and was based on the fluid<br />
elevation that will be present following complete filling of the ETDA. In reality,<br />
the fluid elevation will rise with time through the active lifetime of the ETDA.<br />
Therefore, the vertical hydraulic gradient between the ETDA and the underlying<br />
aquifer was also conservatively represented, as higher vertical gradients lead to<br />
higher seepage rates.<br />
Underlying Aquifer Hydraulic Conductivity<br />
Reference<br />
There is some uncertainty in the distribution and hydraulic conductivity of the<br />
sediments which underlie the ETDA, as described in EIA, Volume 4B, Appendix<br />
4-1, Section 1.2.4.5, page 98. Additional conservatism was built into the<br />
simulation of ETDA seepage, as the entire aquifer underlying the ETDA was<br />
represented by relatively high hydraulic conductivity sandy materials, with the<br />
assigned hydraulic conductivity (5 x 10 -5 m/s) being at the upper end of the range<br />
of hydraulic conductivity values measured in Quaternary deposits in Lease 9.<br />
Hunter, G. P. 2001. Investigation of groundwater flow within an oil sand tailings<br />
impoundment and environmental implications. M.Sc. Thesis, University<br />
of Waterloo,<br />
Request 17d Shell mentions that the expected time for groundwater extraction rates to<br />
stabilize or reach steady state will be defined when a detailed groundwater<br />
extraction system, with actual expected pumping well locations is designed and<br />
produced. Describe the timeframe and the standard procedures for designing<br />
and implementing a detailed groundwater extraction system.<br />
Response 17d The detailed design of a seepage management system requires that the conceptual<br />
models used to conservatively assess potential environmental impacts related to<br />
ETDA seepage be refined and updated. This typically requires additional<br />
geological and hydrogeological information specific to the proposed ETDA site<br />
and surrounding area, and tailoring of plans to align with detailed design<br />
purposes.<br />
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The typical steps in designing and implementing a detailed groundwater<br />
extraction system include:<br />
Section 12.1<br />
• updating the hydrogeological model to include additional geological and<br />
hydrogeological information and any modifications to ETDA design. This<br />
typically includes updates on hydraulic conductivity, aquifer thickness,<br />
groundwater flow direction and velocity, and subsurface chemical behaviour.<br />
• updating the groundwater flow model based on the updated hydrogeological<br />
conceptual model to assess the seepage management system components, to<br />
clearly define groundwater extraction rates, and to define the expected<br />
performance of the seepage management system<br />
• designing a seepage management system, including designing:<br />
• the extraction system, including the number and location of wells, well<br />
diameters, screen perforation and length, filter pack specifications, and<br />
completion intervals<br />
• the horizontal drains and interceptor trenches, including the depth and<br />
width of trenches, diameter, perforation size and slope of collector pipe,<br />
sand and gravel pack specifications, and maintenance manholes<br />
• the collection system, including the pipe diameter and length and pump<br />
specification<br />
• the surface infrastructure, electrical systems, instrumentation and<br />
controls<br />
• installing and commissioning the seepage management system<br />
Shell expects to start designing its seepage management system about 18 months<br />
before construction of the ETDA begins. Constructing and implementing the<br />
seepage management system will take between 12 and 18 months, and coincide<br />
with start-up of the ETDA.<br />
Request 17e Shell mentions they are aware of publicly reported information on seepage from<br />
ETDA at other facilities but are unable to provide details of the suspected causes<br />
of the exceedence events or how the interception measures implemented will<br />
function.<br />
i. Describe and discuss the known causes of seepage that are being considered<br />
for the design and construction of the seepage interception system.<br />
ii. In the event that seepage rates exceed the interception system what are the<br />
contingency design and construction measures that will be used?<br />
Response 17e i. External tailings disposal area seepage occurs as a result of the elevated fluid<br />
level in the ETDA relative to the groundwater level in the underlying<br />
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Question No. 18<br />
Section 12.1<br />
overburden deposits (see EIA, Volume 4A, Section 6.3.6.2, page 6-211).<br />
Design considerations for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA seepage interception<br />
system include all seepage through the base of the ETDA into the overburden<br />
deposits. This excludes seepage through the dike seepage faces, internal<br />
seepage collection systems, and toe drains, as these components of seepage<br />
are captured by different systems and do not enter the overburden deposits.<br />
ii. EIA, Volume 4A, Section 6.3.6.2, page 6-229, evaluated a system of<br />
recovery wells to capture seepage from the ETDA that entered the<br />
overburden deposits. A technically viable measure that could be considered<br />
is to increase the rate of pumping from the existing seepage interception<br />
wells to capture the higher seepage rates. If necessary, the proposed or<br />
existing pumps would be replaced with higher capacity pumps. Also, if<br />
required, additional seepage interception wells, including horizontal wells,<br />
could be installed to supplement the pumping efforts and effectively capture<br />
the ETDA seepage.<br />
Request Volume 2, SIR 279 a-b, Page 21-20.<br />
Figures 279-1 to 279-4 provide visual inspection of the residual distribution in<br />
the wells installed in different formations. The calibration results information<br />
provided on page 29 to 36 of Appendix 4-1 provides validity of the calibration<br />
based on the overall statistical results of residuals and visual observations.<br />
Validation of the calibration results in different areas of the models, including<br />
the wells in close proximity to the depressurization and dewatering areas in the<br />
regional models (both steady state and transient model) and tailing areas and pit<br />
lakes in JEMA and PRMA local models, is not provided. The concern is that<br />
residuals in the monitoring wells range between +9.99 m and -9.39 m and<br />
+28.5 m and -25.64 m in regional steady state and transient models, respectively,<br />
which are high. The same applies for the local JEMA and PRMA models, where<br />
the residuals range between +8.80 to – 27.50 m and +10.77 m and – 8.02 m.<br />
18a The spread and range of residuals is very high and indicates that the correlation<br />
is statistically weak. How has Shell compensated for this uncertainty in the final<br />
model results?<br />
Response 18a The range of residual values are not a good statistical measure of the quality of<br />
the model calibration. The model-averaged residuals are generally preferred to<br />
evaluate the overall quality of the model calibration. Average errors in the model<br />
(residual and absolute residual means, standard deviation and the ratio of the<br />
standard deviation to the range of values) were presented in EIA, Volume 4B,<br />
Appendix 4-1, Figure 18 (regional model, steady-state calibration), Figure 20<br />
(regional model, transient calibration), Figure 22 (Jackpine <strong>Mine</strong> Expansion local<br />
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Reference<br />
Section 12.1<br />
model, steady-state calibration) and Figure 23 (<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> local model,<br />
steady-state calibration).<br />
The maximum and minimum residual values represent a small portion (less than<br />
5%) of all calibration data and, therefore, should not be solely relied upon for an<br />
evaluation of the appropriateness of model calibration. Reilly and Harbaugh<br />
(2004) indicate that an evaluation of the appropriateness of the model in<br />
representing the problem objectives is more important than the values measuring<br />
the goodness of fit. Figure 21 of EIA, Volume 4B, Appendix 4-1 indicates that<br />
there was a good fit between measured and simulated head declines at various<br />
distances from the depressurization centres (pumping wells). This observation,<br />
combined with reasonable quantitative measures of model error, shows that,<br />
based on the available data, the model provides an accurate representation of the<br />
groundwater system under consideration, as shown in Figure 6.3-53 for the basal<br />
aquifer and in Figure 6.3-62 for the surficial deposits (EIA, Volume 4A).<br />
Reilly, T.E. and A.W. Harbaugh. 2004. Guidelines for Evaluating Ground-Water<br />
Flow Models. U.S. Geological Survey Scientific Investigations Report<br />
2004-5038.<br />
Request 18b Provide statistical analysis of residuals in the wells in close proximity to the<br />
abovementioned areas and discuss the validity of residuals in those areas.<br />
Response 18b The data available for calibration in the area of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> included 18<br />
static groundwater levels in surficial aquifers, one static groundwater level in the<br />
McMurray Formation oil sands, and 16 static groundwater levels in the basal<br />
aquifer. Individual residual values for wells in the area of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
were presented in EIA, Volume 4B, Appendix 4-1, Table 2 for the regional<br />
steady-state model and in Table 10 for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> local steady-state<br />
model.<br />
For the residual values shown in Table 10, the range is between -8.02 m and<br />
+10.77 m; the residual mean is 1.04 m; the median is 1.28 m; and the standard<br />
deviation is 4.55 m (see Figure 23 of EIA, Volume 4B, Appendix 4-1, page 97).<br />
The 5, 20, 40, 60, 80 and 95 percentiles are approximately -7.1, -2.9, -1.3, 1.9,<br />
4.8 and 8.8 m, respectively. Further statistical analysis on a subset of the data<br />
shown in Table 10 would not be statistically meaningful because of the small size<br />
of the subsets.<br />
Request 18c The mass balance information provided in Response 279b suggests that the<br />
major component of the inflow to the system in the regional model is from<br />
recharge boundary and major outflow from the system is from drain boundaries.<br />
Provide comments related to input parameters used in the inflow and outflow<br />
boundaries in the model when answering questions d to f below.<br />
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Response 18c See the responses to AENV SIR 18d through AENV SIR 18f.<br />
Section 12.1<br />
Request 18d Recharge description on page 27 in Appendix 4 -1 provides a range of recharge<br />
rates and mentions that these recharge values were calibrated to reproduce<br />
estimated baseflow. However, in Table 1 in Appendix 4-1, the same recharge<br />
values are shown as calibrated values.<br />
i. Clarify this discrepancy.<br />
ii. In Table 1 and on page 27, the recharge values of 16 mm/year and 25<br />
mm/year are described as assigned to opposite areas. Clarify which recharge<br />
value was assigned to which area.<br />
iii. Discuss the primary factors responsible for the different recharge rates.<br />
Response 18d i. The recharge description in EIA, Volume 4B, Appendix 4-1, page 27, and<br />
the values in Table 1 are the same, as they both refer to the model-calibrated<br />
recharge rates.<br />
ii. The description of recharge rates in EIA, Volume 4B, Appendix 4-1, page<br />
27, is correct. A recharge of 16 mm/yr was assigned to glacial (ground<br />
moraine) or glaciolacustrine deposits located east of the Athabasca <strong>River</strong>,<br />
whereas a recharge rate of 25 mm/yr was assigned to glacial (ground<br />
moraine) or glaciolacustrine deposits located west of the Athabasca <strong>River</strong>.<br />
Table 1, presented in EIA, Volume 4B, Appendix 4-1, page 27, incorrectly<br />
presented recharge values for the ground moraine or glaciolacustrine<br />
deposits. Table 1 has been corrected and is reproduced here as Table<br />
AENV 18-1. The revised rows have been shaded.<br />
iii. The recharge rates are primarily a function of the hydraulic conductivity of<br />
the soil or rock, for similar precipitation. Recharge rates will be higher in<br />
sand deposits than in clay deposits. Other factors, such as vegetation cover,<br />
rate of evapotranspiration, depth to water table and topography will also<br />
affect the recharge rates.<br />
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Section 12.1<br />
Table AENV 18-1: Calibrated Hydraulic Conductivity and Recharge Values in Regional<br />
Model (Revised)<br />
Material<br />
Glacial and glaciolacustrine deposits 1 (east of<br />
Athabasca)<br />
Glacial and glaciolacustrine deposits 1 (west of<br />
Athabasca)<br />
Horizontal<br />
Hydraulic<br />
Conductivity<br />
(m/s)<br />
Vertical<br />
Conductivity<br />
(m/s)<br />
Recharge<br />
(mm/yr)<br />
5E-7 5E-9 16<br />
5E-7 5E-9 25<br />
Glacial and glaciolacustrine deposits 2 5E-7 5E-9 25<br />
Ice contact deposits 1 (west of Jackpine <strong>Mine</strong> Expansion) 8E-6 8E-8 104<br />
Ice contact deposits 2 (east of Jackpine <strong>Mine</strong> Expansion) 2E-5 2E-7 104<br />
Outwash sand 5E-5 5E-6 104<br />
Aeolian deposits (west of <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>) 6E-5 6E-7 157<br />
Buried channel aquifers 3E-4 3E-6 157<br />
Clearwater and Grand Rapids formations 1 (Muskeg<br />
Mountain)<br />
1E-11 1E-13 –<br />
Clearwater and Grand Rapids formations 2 (elsewhere) 5E-11 5E-13 –<br />
McMurray Formation Oil Sands 1 (Muskeg Mountain) 1E-11 1E-13 –<br />
McMurray Formation Oil Sands 2 (below Clearwater<br />
elsewhere)<br />
1E-9 1E-10 –<br />
McMurray Formation Oil Sands 3 (areas of no<br />
Clearwater)<br />
6E-9 6E-10 –<br />
McMurray Formation Oil Sands 4 (Athabasca <strong>River</strong><br />
valley)<br />
2E-7 2E-8 –<br />
McMurray Formation Basal Sands 1 (4 m thickness) 8E-5 8E-6 –<br />
Waterways Formation 1E-9 1E-11 –<br />
Prairie evaporite (salt and anhydrite) 1E-10 1E-11 –<br />
Methy 1 (lower portion and below Waterways/Clearwater) 5E-8 5E-13 –<br />
Methy 2 (upper portion in areas of no<br />
Waterways/Clearwater)<br />
5E-7 5E-9 –<br />
Methy 3 (upper portion at Athabasca and Firebag <strong>River</strong><br />
valleys)<br />
5E-5 5E-7 –<br />
Sewataken fault<br />
Note: – = not defined.<br />
5E-8 5E-8 –<br />
Request 18e If the recharge values mentioned in Table 1 and on page 27 are calibrated<br />
values, what were the initial estimated values of recharge assigned to different<br />
zones of the model?<br />
i. Within what range were the recharge values changed during calibration?<br />
Explain how the applicable range for the site is appropriate.<br />
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ii. Explain how the calibrated values correspond to the recharge values<br />
estimated, based on the site specific hydrological conditions.<br />
Section 12.1<br />
Response 18e i. The initial recharge values were based on published studies of groundwater<br />
recharge and on the experience of other groundwater models in the oil sands<br />
area (e.g., Shell, 1997, 2002; Imperial Oil 2005;). Van der Kamp and<br />
Hayashi (1998) indicate that recharge rates for regional aquifers confined by<br />
aquitards of till and clay, including the Dalmeny aquifer, the Zehner aquifer,<br />
and the Estevan Valley aquifer, are generally in the range of 5 to 40 mm/yr.<br />
Simpkins and Parkin (1993) estimated recharge rates in the range of 3 to 76<br />
mm/yr through till of the Des Moines Lobe in Iowa. Sophocleous (1992)<br />
indicated that the recharge in the Great Bend Prairie of central Kansas ranged<br />
from about 0 to 177 mm/yr with a mean of 56 mm/yr. Walton (1985) reports<br />
recharge rates of about 160 to 260 mm/yr (20-25% of precipitation) for<br />
glacial drift composed largely of sand and gravel in west central Illinois.<br />
References<br />
As a general guidance, initial estimates of recharge were about 2 to 10% of<br />
precipitation (10 to 45 mm/yr) for fine-grained surficial deposits (e.g., tillcovered<br />
areas), and about 10 to 20% of precipitation (45 to 90 mm/yr) for<br />
sandy surficial deposits. The model was then calibrated by adjusting both the<br />
hydraulic conductivity of the different geological materials and the recharge<br />
rates in the different areas of the model so that observed water levels,<br />
piezometric levels and groundwater discharge rates were adequately<br />
reproduced. The model calibration indicated that higher recharge rates were<br />
required in select areas of high permeability characterized by aeolian<br />
deposits and near surface sand channels (e.g., Kearl Channel).<br />
Imperial Oil (Imperial Oil Resources Ventures Limited). 2005. Kearl Oil Sands<br />
<strong>Project</strong> - <strong>Mine</strong> Development. Submitted to Alberta Energy and Utilities<br />
Board and Alberta Environment. Calgary, AB. Submitted July 2005.<br />
Shell (Shell Canada Limited). 1997. Application for the Approval of Muskeg<br />
<strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Volumes 1 to 3. Submitted to Alberta Energy and<br />
Utilities Board and Alberta Environment. Calgary, AB. Submitted<br />
December 1997.<br />
Shell (Shell Canada Limited). 2002. Application for the Approval of Jackpine<br />
<strong>Mine</strong> –Phase 1. Submitted to Alberta Energy and Utilities Board and<br />
Alberta Environment. Calgary, AB. Submitted May 2002.<br />
Simpkins, W. W. and T. B. Parkin. 1993. Hydrogeology and redox geochemistry<br />
of CH4 in a Late Wisconsinan till and loess sequence in central Iowa.<br />
Water Resources Research 29:3643-57.<br />
Sophocleous, M. 1992. Groundwater recharge estimation and regionalization: the<br />
Great Bend Prairie of central Kansas and its recharge statistics. J.<br />
Hydrology Vol. 137, pp. 113-140.<br />
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References<br />
Section 12.1<br />
Van der Kamp, G. and M. Hayashi. 1998. The Groundwater Recharge Function<br />
of Small Wetlands in the Semi-Arid Northern Prairies. Great Plains<br />
Research Vol. 8 No. 1, pp. 39-56.<br />
Walton, W.C. 1985. Practical Aspects of Groundwater Modelling. 2nd Ed.,<br />
National Water Well Association, 587 pp.<br />
ii. The calibrated recharge values reflected relatively higher recharge rates in<br />
areas of higher hydraulic conductivity (sandy till, sand channels, aeolian<br />
deposits) than areas of lower hydraulic conductivity (ground moraine or<br />
glaciolacustrine deposits). This relationship is well established (see Walton<br />
1985, pg 56), and has been demonstrated by other EIAs conducted in the<br />
region and other studies in similar hydrogeologic settings in Alberta<br />
(Farvolden [1963]; Geoscience Consulting Ltd. [1976]; Hydrogeological<br />
Consultants Ltd. [1977]; Alberta Environment [1978]).<br />
Walton, W.C. 1985. Practical Aspects of Groundwater Modelling. 2nd Ed.,<br />
National Water Well Association, 587 pp.<br />
Alberta Environment, 1978. Edmonton regional utilities study, Volume IV,<br />
Groundwater. Material prepared by Research Council of Alberta,<br />
Groundwater Division. Compiled and edited by Alberta Environment<br />
and RPA Consultants Limited.<br />
Farvolden, R.N. 1963. Rate of groundwater recharge near Devon, Alberta. In:<br />
R.N. Farvolden, W.A. Meneley, E.G. Breton, D.H. Lennox, and P.<br />
Meyboom. Early contributions to the groundwater hydrology of Alberta;<br />
Research Council of Alberta Bulletin 12, p. 98-105.<br />
Geoscience Consulting Ltd. 1976. Groundwater evaluation, Sherwood Park-<br />
Ardrossan area; Report, 23 pp.<br />
Hydrogeological Consultants Ltd., 1977. Edmonton regional utilities study<br />
groundwater inventory, including St. Albert, Villeneuve, Onoway, Stony<br />
Plain, Spruce Grove, Warburg, Breton, Winfield, Fort Saskatchewan,<br />
Josephburg, Bruderheim, Lamont and Chipman, 72 pp.<br />
Request 18f On pages 26 to 28, general descriptions of boundary conditions are provided.<br />
However, the input parameters for different boundary conditions are not<br />
described (e.g., river stage elevations, river bottom elevations, and drain<br />
elevations). For riverbed and lake bed conductance, the vertical hydraulic<br />
conductivities used are 1 x 10-6 m/sec and 1 x 10-8, respectively.<br />
i. Provide the different input parameters of the boundary conditions, and<br />
describe the methods used to define the boundary input parameters,<br />
including the river and lake conductance values mentioned above.<br />
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Section 12.1<br />
ii. How did these parameters affect the calibration results and the model output<br />
results in terms of the variation in regional groundwater inflow and outflow?<br />
Response 18f i. For head-dependent flux boundaries (including rivers and general head<br />
boundaries), the Groundwater Vistas software calculated conductance based<br />
on the following (Environmental Simulations Inc. 2004):<br />
C = KLW/T<br />
where:<br />
C = conductance [L2/T]<br />
K is the hydraulic conductivity [L/T]<br />
L is the boundary length [L]<br />
W is the boundary width [L]<br />
T is the boundary thickness [L]<br />
The conductance term described above is similar to the coefficient that<br />
represents leakage through an aquitard under steady-state conditions (De<br />
Marsily, 1986, pg 365). De Marsily further indicates that, generally, neither<br />
K, (LW), or T are measured and that the conductance “is adjusted so that the<br />
difference in head Hr – Hi observed in reality is reproduced by the model<br />
when the flow balance is respected”. In De Marsily’s terminology, Hr is the<br />
hydraulic head in the river and Hi is the hydraulic head in the aquifer.<br />
Because of the generality of the Groundwater Vistas front-end/back-end<br />
software, inputs were provided for K, L, W and T (required by the software)<br />
so that C could be calculated. The values selected for L and W generally<br />
corresponded to the length and width of the model cell, but in the case of the<br />
river boundaries, the width was selected based on the relative width of the<br />
river or streams, but was not related to the actual width. The thickness of bed<br />
material was set to 1 m, or 5 m in the case of lakebed thickness. The reason<br />
for these selections was to facilitate calibration, as C was now focused on the<br />
hydraulic conductivity of the bed material, which is a parameter aligned with<br />
the hydraulic conductivity of the different geological materials.<br />
For river boundaries:<br />
• river stage (or head) was equal to topography<br />
• river bottom elevation was set 1 m below topography<br />
• width of the river boundaries ranged from 4 m for tributaries to 50 m for<br />
the Athabasca <strong>River</strong><br />
• river boundary length was equal to the length of the model cell<br />
• the riverbed thickness was 1 m<br />
• the riverbed hydraulic conductivity was 1 x 10 -6 m/s<br />
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References<br />
For lakes:<br />
• head was based on the lake elevation<br />
• the width was equal to the width of the model cell<br />
• the lakebed thickness was 5 m<br />
• the lakebed hydraulic conductivity was 1 x 10 -8 m/s<br />
For drain boundaries at the ground surface (representing wetlands and<br />
ephemeral streams):<br />
• the drain stage (or head) was equal to topography<br />
Section 12.1<br />
• the width and length of the drain was equal to the width and length of the<br />
model cell<br />
• the thickness of the drainbed was 1 m<br />
• the hydraulic conductivity of the drainbed was 1 x 10 -8 m/s<br />
For drain boundaries in aquifer layers (representing dewatering and<br />
depressurization):<br />
• the drain stage (or head) was equal to the bottom elevation of the<br />
Quaternary deposits (for overburden dewatering) or the top elevation of<br />
the basal aquifer<br />
• the width and length of the drain was equal to the width and length of the<br />
model cell<br />
• the thickness of the drainbed was 1 m<br />
• the hydraulic conductivity of the drainbed was 1 x 10 -8 m/s<br />
De Marsily, G. 1986. Quantitative Hydrogeology, Groundwater Hydrology for<br />
Engineers. Academic Press Inc., London. 440 pp.<br />
Environmental Simulations Inc. 2004. Guide to Using Groundwater Vistas,<br />
Version 4.<br />
ii. The calibration results were insensitive to the head-dependent flux boundary<br />
input parameters because the flows represented by these boundaries are<br />
generally small in comparison to the regional inflows and outflows.<br />
The calibration results were most sensitive to values of recharge and<br />
hydraulic conductivity, so these parameters were investigated with prediction<br />
confidence simulations (see EIA, Volume 4B, Appendix 4-1, Sections<br />
1.2.2.7, 1.2.3.7 and 1.2.4.7).<br />
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Question No. 19<br />
Request Volume 2, SIR 297, Page 21-51.<br />
Section 12.1<br />
Shell describes details of previous experience with successfully mitigating pit<br />
lake waters, those design and monitoring objectives that will be integrated into<br />
pit management planning to achieve timely mitigation of pit waters, best case<br />
time frames for pit water mitigation, and the state of current research that Shell<br />
will use to prevent pit waters from potentially becoming methanogenic. Shell<br />
states that modeling has been completed to confirm that the residence time will<br />
be sufficient to biodegrade organic constituents to acceptable levels based upon<br />
conservative degradation rates.<br />
19a What were the maximum residence times used in the pit lakes modeling?<br />
Response 19a Pit lake residence times are presented in EIA, Volume 4B, Appendix 4-2,<br />
Table 21. The residence times for the <strong>Pierre</strong> North Pit Lake and the <strong>Pierre</strong> South<br />
Pit Lake are one and 10 years, respectively. The residence time for the <strong>Pierre</strong><br />
South Pit Lake is presented in Table 21 as eight years in the upstream cell and<br />
two years in the downstream cell, for a total residence time in the lake of 10<br />
years.<br />
Request 19b What are the conservative degradation rates used for each organic constituent of<br />
concern, providing reference citations for similar climate environmental<br />
settings?<br />
Response 19b The conservative degradation rates used in the pit lake modelling are presented in<br />
EIA, Volume 4B, Appendix 4-2, Table 42, and the respective source references<br />
listed in the table are in EIA, Volume 4B, Appendix 4-2, Section 4. Decay rates<br />
were corrected for temperature to account for slower decay in cold, northern<br />
lakes.<br />
The aerobic decay rates applied to lakes and wetlands for ammonia, sulphide,<br />
acute toxicity and chronic toxicity are the slowest of the rates derived from<br />
available field research studies conducted on process-affected waters from oil<br />
sands operators.<br />
The aerobic decay rate listed for total phenolics is based on the slowest rate of<br />
degradation for phenol in studies listed in the CHEMFATE database (SRC 2007).<br />
Field-based studies listed in CHEMFATE have associated decay rates that vary<br />
from 28 y -1 at 21ºC for an estuarine river in Georgia (Lee and Ryan 1979) to<br />
3,152 y -1 for in-situ waters spiked with phenol in the St. Lawrence <strong>River</strong><br />
downstream of oil refinery wastewater outfalls (Visser et al. 1977).<br />
Tainting potential decay rates are based on decay of ethylbenzene. The aerobic<br />
decay rate of 2.3 y -1 is derived from observed persistence of ethylbenzene in<br />
shallow groundwaters monitored in the Netherlands (Zoetman et al. 1980), which<br />
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Decay Rates (y -1 )<br />
10,000<br />
1,000<br />
100<br />
10<br />
1<br />
0.1<br />
Section 12.1<br />
was slower than the observed persistence of ethylbenzene in river waters, with a<br />
decay rate of 6.94 y -1 (Zoetman et al. 1980). The anaerobic decay rate of 1.1 y -1<br />
for tainting potential is based on the slowest degradation rate for ethylbenzene in<br />
groundwater (Wilson et al. 1986). A field-based study listed in CHEMFATE<br />
(SRC 2007) had a much faster anaerobic decay rate for ethylbenzene of 57 y -1 in<br />
a sand aquifer (Batterman and Werner 1984).<br />
The aerobic decay for acrylamide monomer (32 y -1 ) was derived from a study on<br />
natural and polluted water samples spiked with acrylamide at a concentration of<br />
0.5 mg/L. The estimated decay rates ranged from 32 to over 1,000 y -1 (Brown et<br />
al. 1980; United Kingdom Environmental Agency [U.K.E.A. 2000]). The<br />
acrylamide monomer anaerobic decay rate of 8.4 y -1 was derived by the U.K.E.A<br />
(2000) based on an estimated half-life of 30 days in soil. Results of a microcosm<br />
study using oil sands tailings as a microbial inoculation source yielded faster<br />
anaerobic acrylamide decay rates, ranging from 19 to 31 y -1 at 22 ºC (Haveroen<br />
et al. 2003).<br />
Aerobic and anaerobic decay rates for polycyclic aromatic hydrocarbon (PAH)<br />
groups were based on the lowest aquatic decay rate for any individual PAH in<br />
each group, regardless of whether the rates were derived from laboratory or fieldbased<br />
studies, as field-based results were not always available for similar<br />
environmental settings. The PAH degradation rates used in the assessment were<br />
generally orders of magnitude slower than other published rates (Figure<br />
AENV 19-1).<br />
0.01<br />
0 1 2 3 4 5 6 7 8 9<br />
PAH Group<br />
Aerobic Rate Anaerobic Rate Aerobic Rate Used in EIA Anaerobic Rate Used in EIA<br />
Figure AENV 19-1: Aerobic and Anaerobic PAH Decay Rates<br />
The aerobic decay rate used for labile naphthenic acids was 3.2 y -1 . This rate is<br />
based on several studies that examined the decay of different fractions of<br />
naphthenic acids (Holowenko et al. 2002; Headley et al. 2002; Clemente et al.<br />
2004; Scott et al. 2005). The anaerobic decay rate used for labile naphthenic<br />
acids was derived in consultation with Dr. Mike MacKinnon, Syncrude Canada<br />
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References<br />
Section 12.1<br />
Ltd., following methods outlined in Howard et al. (1991). A decay rate of zero<br />
(i.e., no decay) was applied to refractory naphthenic acids, although a recent<br />
study by Han et al. (2009) observed aerobic degradation of refractory naphthenic<br />
acids at approximately 0.05 y -1 in field studies at Syncrude’s experimental<br />
reclamation waterbodies.<br />
Batermann, G. and P. Werner, P. 1984. Removal of Underground Contamination<br />
by Hydrocarbons Through Microbial Degradation (GER).; GWF-<br />
Wasser/Abwasser. 125:366-73.<br />
Brown L., M. M. Rhead, K. C. C. Bancroft and N. Allen. 1980. Model Studies of<br />
the Degradation of Acrylamide Monomer. Water Research. 14:775-778.<br />
Clemente, S., M. D. MacKinnon, and P.M. Fedorak. 2004. Aerobic<br />
biodegradation of two commercial naphthenic acids preparations.<br />
Environmental Science and Technology. 38:1009-1016.<br />
Han, X., M. D. MacKinnon and J. Martin. 2009. Estimating the in situ<br />
biodegradation of naphthenic acids in oil sands process waters by<br />
HPLC/HRMS. Chemosphere. 76(1):63-70.<br />
Haveroen, M.E., M.D. MacKinnon and P.M. Fedorak. 2003. Acrylamide<br />
Biodegradation in Oilsands Tailing Samples. Poster Presentation to<br />
CONRAD Wetlands and Aquatics Working Group.<br />
Headley, J. V., S. Tanapat, G. Putz and K. M. Peru. 2002. Biodegradation<br />
Kinetics of Geometric Isomers of Model Naphthenic Acids in Athabasca<br />
<strong>River</strong> Water. Canadian Water Resources Journal. Vol. 27, no. 1, pp. 25-<br />
42.<br />
Holowenko F. M., M. D. MacKinnon, and P. M. Fedorak. 2002. Characterization<br />
of Naphthenic Acids in Oil Sands Wastewaters by Gas Chromatography-<br />
Mass Spectrometry. Water Research. 36(11):2843-55.<br />
Howard, P. H., R. S. Boethling, W. F. Jarvis, W. M. Meylan and E. M.<br />
Michalenko. 1991. Handbook of Environmental Degradation Rates.<br />
Lewis Publishers Inc. Chelsea, MI.<br />
Lee, R. F. and C. Ryan. 1979. Microbial Degradation of Organochlorine<br />
Compounds in Estuarine Water and Sediments. In: EPA-600/9-79-012.<br />
Microbial Degradation of Pollutants in Marine Environments. Bourquin,<br />
A. W. and P. H. Pritchard, Eds. Gulf Breeze, Florida. US EPA. pp. 443-<br />
50.<br />
Scott, A. C., M. D. MacKinnon, and P. M. Fedorak. 2005. Naphthenic acids in<br />
Athabasca oil sands tailings waters are less biodegradable than<br />
commercial naphthenic acids. Environmental Science and Technology.<br />
39:8388-8394.<br />
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Section 12.1<br />
SRC (Syracuse Research Corporation). 2007. CHEMFATE Online Database.<br />
U.K.E.A. (United Kingdom Environmental Agency). 2000. Risk Assessment of<br />
Acrylamide (Draft Report). UKEA, Ecotoxicology & Hazardous<br />
Substances National Centre. CAS No. 79-06-1. Wallingford,<br />
Oxfordshire.<br />
Visser, S. A., G. Lamontagne, V. Zoulalian and A. Tessier. 1977. Bacteria Active<br />
in the Degradation of Phenols in Polluted Waters of the St. Lawrence<br />
<strong>River</strong>. Archives of Environmental Contamination and Toxicology.<br />
6:455-70.<br />
Wilson, B. H., G. B. Smith and J. F. Rees. 1986. Biotransformation of Selected<br />
Alkylbenzenes and Halogenated Aliphatic Hydrocarbons in<br />
Methanogenic Aquifer Material: A Microcosm Study. Environmental<br />
Science and Technology. 20:997-1002.<br />
Zoeteman, B.C.J., K. Harmsen, and J.B.H. Linders. 1980. Persistent Organic<br />
Pollutants in <strong>River</strong> Water and Ground Water of the Netherlands.<br />
Chemosphere. 9:231-249.<br />
Request 19c What is the maximum anticipated concentration modeled for each organic<br />
constituent of concern and what was the predicted time required to achieve<br />
acceptable levels based upon this concentration?<br />
Response 19c The maximum anticipated concentration modelled for each organic constituent of<br />
concern will occur at the end of mining operations, before the lakes are filled<br />
with fresh water. As described in EIA, Volume 4A, Section 6.5.6.3, the pit lakes<br />
will initially contain process-affected waters comprised of seepages from<br />
backfilled mine pits and reclaimed sand swale and ridge areas, consolidation flux<br />
from non-segregating tailings (NST) in reclaimed mine pits and mature fine<br />
tailings (MFT). The assumed chemical profiles of these waters is presented in<br />
EIA, Volume 4B, Appendix 4-2, Table 37. During this period, the lakes will not<br />
discharge to the receiving environment.<br />
As described in EIA, Volume 4A, Section 6.5.6.3, water quality in the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> pit lakes is anticipated to be acceptable for release at the time of<br />
initial discharge in 2049. Predicted concentrations for all constituents in each pit<br />
lake, in 2049 and in the future, are presented in EIA, Volume 4B, Appendix 4-7,<br />
Section 4.<br />
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Question No. 20<br />
Request Volume 2, SIR 280, Page 21-21.<br />
Section 12.1<br />
Shell states that the reaches of <strong>Pierre</strong> <strong>River</strong>, Eymundson Creek and Big Creek<br />
located within the LSA are considered to be lost in their entirety and any change<br />
in habitat as a result of change in flow was incorporated into the fish area lost,<br />
as described in EIA Vol. 4, Appendix 4-6, Table 7.<br />
20a Describe how the change in flow may affect fish and fish habitat outside the LSA,<br />
with particular focus on winter flows.<br />
Response 20a The Athabasca <strong>River</strong> downstream of the Firebag <strong>River</strong> confluence would be the<br />
only watercourse which may be potentially affected outside of the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> local study area (LSA) from changes in habitat area. Potential changes to<br />
flows in the Athabasca <strong>River</strong> from construction, operations and closure activities<br />
in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> development area were considered in Section 6.7.7.3<br />
(EIA, Volume 4, Section 6.7, page 6-663). The change in flows in the Athabasca<br />
<strong>River</strong> due to closed-circuit operations and reclaimed areas resulting from the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> is considered negligible (EIA, Volume 4, Section 6.4.7.3).<br />
Therefore, no impacts to fish habitat in the Athabasca <strong>River</strong> would be expected<br />
from changes to streamflows resulting from activities in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
development area, other than those potentially related to water withdrawals for<br />
the project.<br />
Reference<br />
A discussion of changes to Athabasca <strong>River</strong> flows and fish habitat relating to<br />
water withdrawals is in the EIA, Volume 4, Section 6.7.7.3. Flows in the<br />
Athabasca <strong>River</strong>, including winter flows, are being managed under the Water<br />
Management Framework for the lower Athabasca <strong>River</strong> (AENV and DFO 2007).<br />
A Phase 2 Framework is currently being developed by Alberta Environment and<br />
Fisheries and Oceans Canada, which will further define how cumulative<br />
withdrawals under low flow conditions will be managed and the potential effects<br />
on fish habitat associated with cumulative withdrawals. Shell has committed to<br />
operating under the current framework and any future frameworks that define<br />
limits to water withdrawals on the Athabasca <strong>River</strong>.<br />
AENV and DFO (Alberta Environment and Fisheries and Oceans Canada). 2007.<br />
Water Management Framework: Instream Flow Needs and Water<br />
Management System for the Lower Athabasca <strong>River</strong>. Edmonton, AB.<br />
37 pp.<br />
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Question No. 21<br />
Request Volume 2, SIR 288, Page 21-39.<br />
Section 12.1<br />
Shell states that streams outside the disturbance footprint will have a 100-m<br />
setback distance.<br />
21a Clarify if ephemeral watercourses were considered and included in this setback<br />
criterion.<br />
Response 21a As per the response to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 2, SIR 288, a 100 m setback will be maintained for streams<br />
around the periphery of the disturbance footprint. For this project, these streams<br />
are limited to constructed diversion channels adjacent to the main <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> footprint, such as the <strong>Pierre</strong> <strong>River</strong> diversion, which would maintain the 100<br />
m setback. Ephemeral watercourses were considered because ephemeral streams<br />
located around the periphery of the project footprint would be directed into the<br />
diversion channels, which will have the 100 m setback.<br />
Question No. 22<br />
Request Volume 2, SIR 289a, Page 21-40.<br />
Shell states that the Actual Evapotranspiration (AET) is estimated based on<br />
actual evapotranspiration simulated for natural areas using the Hydrologic<br />
Simulation Program Fortran (HSPF) model. The HSPF model determines an<br />
estimated AET based on an estimate of PET (potential evapotranspiration) and<br />
five other primary factors (HSPF subroutines). It is not clear how Shell<br />
estimated AET based on a simulated AET without first having PET estimates,<br />
accurate and reliable water storage values, and an adjustment for advective<br />
winds.<br />
22a Briefly describe the steps that provided input data, estimated PET, and<br />
calculated AET.<br />
Response 22a The steps used to estimate potential evapotranspiration (PET) using Morton’s<br />
evaporation model and actual evapotranspiration (AET) using HSPF, and the<br />
input data required for these models are as follows:<br />
• Morton’s Evaporation model is used to determine Potential<br />
Evapotranspiration (PET), areal actual evapotranspiration, potential lake<br />
evaporation (PE), and actual lake evaporation. The input to Morton’s<br />
Evaporation model includes mean annual precipitation, monthly mean wind<br />
speed, monthly mean relative humidity or dew point temperature, and<br />
monthly mean solar radiation data recorded at the Fort McMurray Airport<br />
climate station from 1954 to 2006.<br />
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Section 12.1<br />
• Then, AET is determined using the HSPF model. The input to the HSPF<br />
model is PET and actual lake evaporation. In the HSPF model, AET for<br />
specific sub-basin or land segment is calculated from five sources<br />
(interception, upper zone, lower zone, baseflow and groundwater storages) as<br />
a function of moisture storages and the PET.<br />
Request 22b Clarify why the Morton method was used for HSPF modeling in deference to the<br />
Thornthwaite or Penman-Monteith methods for ecosystems, or the Priestly-<br />
Taylor method. Provide a summary of information that compares the selected<br />
approach to these others, given that it could be argued that, for an extensive<br />
landscape covering a large area with different soil moisture storage properties,<br />
different advective wind and different precipitation patterns, Morton might not<br />
provide as accurate a representation of AET as other approaches.<br />
Response 22b The Morton’s method was used following a similar procedure to Alberta<br />
Environment’s to calculate evaporation and potential evapotranspiration for the<br />
Province of Alberta (AENV 1999).<br />
References<br />
There are several more or less empirical methods developed over the last 50<br />
years by numerous scientists and specialists worldwide to estimate PET from<br />
different climatic variables. These methods can be grouped into five categories:<br />
1. water budget (e.g. Guitjens 1982)<br />
2. mass-transfer (e.g. Harbeck 1962)<br />
3. combination (e.g. Penman 1948; Morton 1983)<br />
4. radiation (e.g. Priestley and Taylor 1972)<br />
5. temperature-based (e.g. Thornthwaite 1948; Blaney-Criddle 1950)<br />
The general conclusion from several studies in the literature that compare the<br />
performance of the various methods (e.g., Biftu and Gan 2000; Xu and Singh<br />
2002; and Weiß and Menzel 2008) using locally determined parameter values<br />
was that all methods provide estimates of PET that are comparable to PET<br />
estimated using the Penman-Monteith method.<br />
The Morton’s method for estimating PET is practically similar to the Penman-<br />
Monteith method. Morton’s method is based on solving simultaneously energy<br />
transfer and balance equations, using a constant energy transfer coefficient,<br />
unlike the Penman-Monteith potential evapotranspiration formulation in which<br />
the energy transfer coefficient is a function of wind speed.<br />
Abraham, C. (1999): Evaporation and evapotranspiration in Alberta: report 1912-<br />
1985 data 1912-1996; Alberta Environmental Protection, Water<br />
Management Division.<br />
Biftu, G.F., and Gan, T.W. 2000. Assessment of evapotranspiration models<br />
applied to a watershed in the Canadian Prairies with mixed land uses.<br />
Hydrological Processes, 14: 1305–1325.<br />
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Section 12.1<br />
Blaney, H. F. and Criddle, W. D. 1950. Determining Water Requirements in<br />
Irrigated Area from Climatological Irrigation Data, US Department of<br />
Agriculture, Soil Conservation Service, Tech. Pap. No. 96, 48 pp.<br />
Guitjens, J. C. 1982. Models of Alfalfa Yield and Evapotranspiration,. Journal of<br />
the Irrigation and Drainage Division, Proceedings of the American<br />
Society of Civil Engineers. 108(IR3), pp. 212–222.<br />
Harbeck Jr., G. E.1962. A Practical Field Technique for Measuring Reservoir<br />
Evaporation Utilizing Mass-transfer Theory. U.S. Geol. Surv., Paper<br />
272-E, pp. 101–105.<br />
Morton, F.I. 1983. Operational estimates of areal evapotranspiration and their<br />
significance to the science and practice of hydrology. Journal of<br />
Hydrology, 66, 1-76.<br />
Penman, H. L. 1948. Natural Evaporation from Open Water, Bare Soil and Grass.<br />
Proc., Royal Soc., London 193, 120–145.<br />
Priestley, C. H. B. and Taylor, R. J. 1972. On the Assessment of the Surface heat<br />
Flux and Evaporation using Large-scale Parameters. Monthly Weather<br />
Review 100, 81–92.<br />
Thornthwaite, C.W., 1948, An approach toward a rational classification of<br />
climate: Geographical Review, v. 38, p. 55–94.<br />
Weiß, M. and Menzel, L. A global comparison of four potential<br />
evapotranspiration equations and their relevance to stream flow<br />
modelling in semi-arid environments. Adv. Geosci., 18, 15-23, 2008.<br />
Xu, C.-Y. and Singh, V. P. 2002. Cross Comparison of Empirical Equations for<br />
calculating Potential Evapotranspiration with Data from Switzerland<br />
Water Resources Management 16: 197–219, 2002.<br />
Request 22c Explain why only one estimate or calculation of AET (314 mm) was used to<br />
represent both sides of the Athabasca <strong>River</strong>, given that <strong>Pierre</strong> <strong>River</strong> (with 374<br />
mm precipitation annually) differs appreciably (by 59 mm) from Jackpine (433<br />
mm). Different precipitation regimes can also be manifested in variations among<br />
other climate characteristics including those that may play a role in the<br />
calculation or estimation of AET; such parameters can include differences in<br />
cloud covers and insolation, vapour pressure deficits, and boundary layer<br />
conditions. Provide an explanation that addresses this particular concern<br />
related to AET determination.<br />
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Section 12.1<br />
Response 22c The 314 mm cited in the response to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 2, SIR 289a refers to areal actual<br />
evapotranspiration, which is different from actual evapotranspiration (AET).<br />
Question No. 23<br />
Actual evapotranspiration (AET) is the evapotranspiration that will take place<br />
over a specific area or land segment as a result of transpiration through plant<br />
canopy and evaporation from the soil. For a specific land segment, AET is<br />
determined in the HSPF model from five inputs (interception, upper zone, lower<br />
zone, baseflow and groundwater storages) as a function of moisture storages and<br />
the PET.<br />
Areal actual evapotranspiration is the evapotranspiration that actually takes place<br />
over a large area, assuming that the effects of any upwind boundary transitions<br />
are negligible and local variations are integrated to an areal average. The areal<br />
actual evapotranspiration for the Oil Sands Region was determined using<br />
Morton’s Evaporation model. The inputs to Morton’s Evaporation model<br />
included mean annual precipitation over a long period, monthly mean wind speed<br />
(dependent on boundary layer conditions), monthly mean relative humidity or<br />
dew point temperature (dependent on vapour pressure deficits), and monthly<br />
mean solar radiation data (dependent on cloud cover) recorded at the Fort<br />
McMurray Airport climate station from 1954 to 2006.<br />
Areal actual evapotranspiration, not AET, is assumed to be similar for the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> area and the Jackpine <strong>Mine</strong> Expansion area given that Morton’s<br />
model input data, with the exception of precipitation data, are assumed to be the<br />
same for both development areas. Though the precipitation values for the two<br />
development areas are different, this would have little effect on the estimated<br />
areal actual evapotranspiration output from the Morton’s model.<br />
Request Volume 2, SIR 290a, Table 290-1, Page 21-40.<br />
The table includes solar radiation used to calculate evapotranspiration using<br />
Morton’s method for evapotranspiration. It is not clear if this is for actual or<br />
potential evapotranspiration. Morton’s method to calculate AET using the HSPF<br />
requires an estimate of PET to be input, usually as a time-series using Class A<br />
Pan data, with a further adjustment factor applied for percent cover. There is no<br />
indication currently of where and how the PET data were derived or determined,<br />
in order to then generate the AET. Once PET is estimated then AET is calculated<br />
using five subroutines in HSPF that account for the water demand from five<br />
sources.<br />
23a What data were used to estimate potential evapotranspiration? This could<br />
perhaps be demonstrated in Table 290-1 by adding an entry for “actual<br />
evapotranspiration” as a data type, as well as indicating the method(s) used to<br />
estimate potential evapotranspiration.<br />
12-26 Shell Canada Limited April 2010<br />
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WATER AENV SIRS 15 – 43<br />
Section 12.1<br />
Response 23a Morton’s Evaporation model was used to determine Potential Evapotranspiration<br />
(PET). The input to Morton’s Evaporation model includes mean annual<br />
precipitation, monthly mean wind speed, monthly mean relative humidity or dew<br />
point temperature, and monthly mean solar radiation data recorded at the Fort<br />
McMurray Airport climate station from 1954 to 2006. The modified<br />
Table AENV 23-1 provides a list of specific input data used to estimate Potential<br />
Evapotranspiration (PET), areal actual evapotranspiration, Potential Lake<br />
Evaporation (PE), and Actual Lake Evaporation.<br />
Question No. 24<br />
Request Volume 2, SIR 292b, Page 21-45.<br />
Shell states that this question does not apply because it is not applicable to<br />
<strong>Pierre</strong> <strong>River</strong>. It is noted however that the same mapping techniques, symbology<br />
and EIA development systems have been used for both projects – Section 6.4.6.2,<br />
Figure 6.4-18, Page 6-317 shows that Question 292b is likely applicable, since<br />
the same mapping protocols appear to be in place for <strong>Pierre</strong> <strong>River</strong> as for<br />
Jackpine.<br />
24a Address SIR 292b in relation to <strong>Pierre</strong> <strong>River</strong> using Figure 6.4-18, Page 6-317 as<br />
a basis for reference, and address in relation to all proposed, reclaimed or<br />
created wetlands for <strong>Pierre</strong> <strong>River</strong>.<br />
Response 24a Figure AENV 24-1 presents a revised version of Figure 6.4-18.<br />
Request 24b Clarify what wetland ecosites are targeted in the littoral zone of pit lakes with<br />
examples of target plant and animals species.<br />
Response 24b Littoral zones will consist of marshes (MONG) and shallow open water wetlands.<br />
Plant and animal species typical of graminoid marsh (MONG) wetlands types are<br />
expected in the reclaimed marsh ecosite types. Emergent sedges, grasses, rushes,<br />
reeds, submerged and floating aquatics are among the plant families expected in<br />
the reclaimed marshes.<br />
The plant species anticipated include, but are not limited to:<br />
• Typha spp.<br />
• Carex spp.<br />
• Scirpus spp.<br />
• Polygonum spp.<br />
• Juncus spp.<br />
• Acorus calamus<br />
April 2010 Shell Canada Limited 12-27<br />
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WATER AENV SIRS 15 – 43<br />
Air temperature<br />
Precipitation<br />
Solar radiation<br />
Wind<br />
Data Type Name of Data Set Data Source<br />
Fort McMurray airport climate station<br />
(1944–2006)<br />
Environment<br />
Canada<br />
Fort McMurray climate station (1919-1944) Environment<br />
Canada<br />
Table AENV 23-1: Summary of Data Sets Used for Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong><br />
Level of<br />
Completeness<br />
(%)<br />
100 High<br />
Qualitative<br />
Confidence<br />
Rating 1, 2 How Data was Used? How was Historical Incompleteness Resolved?<br />
• Used to derive daily, monthly and annual air temperature statistics, to analyze any<br />
trends resulting from climate change or climate variability<br />
• Used to derive evaporation and evapotranspiration using Morton's Method<br />
• Used as an input for the hydrologic model simulation<br />
99.5 High • Combined with Fort McMurray airport climate station data to produce long-term records<br />
required for trend analysis<br />
Aurora climate station (1995–2006) RAMP 91 Medium • Used to establish spatial variation of air temperatures with elevation in the Oil Sands<br />
Region<br />
Calumet <strong>River</strong> climate station (2001–2005) RAMP 100 Medium • Used to establish spatial variation of air temperatures with elevation in the Oil Sands<br />
Region<br />
Fort McMurray airport climate station<br />
(1944–2006)<br />
Environment<br />
Canada<br />
Fort McMurray climate station (1920-1944) Environment<br />
Canada<br />
100 High<br />
Aurora climate station (1995–2006) RAMP 98 Medium<br />
Ells Lookout (1960–2006) ASRD 32 3 Medium<br />
• Used to derive monthly and annual precipitation statistics, and also to analyze any<br />
statistical trend resulting from climate change or climate variability<br />
• Used to derive areal evaporation, actual lake evaporation, potential evapotranspiration,<br />
and potential lake evaporation using Morton's Method, and also used as an input for<br />
hydrologic modelling<br />
• Used as an input for the hydrologic model simulation<br />
99.5 High • Combined with Fort McMurray airport climate station data to produce long-term records<br />
required for trend analysis<br />
• Used to establish the spatial variation of summer rainfall with elevation in the Oil Sands<br />
Region<br />
• Used as an input for the Hydrologic Model Validation for the Jackpine <strong>Mine</strong> Expansion<br />
local study area (LSA)<br />
• Used to establish the spatial variation of summer rainfall with elevation in the Oil Sands<br />
Region<br />
• Used as input for the Hydrologic Model Validation and Simulation for the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> LSA<br />
Birch Mountain Lookout (1961–2006) ASRD 38 3 Medium • Used to establish the spatial variation of summer rainfall with elevation in the Oil Sands<br />
Region<br />
Fort McMurray airport climate station<br />
(1971–1996)<br />
Environment<br />
Canada<br />
100 High<br />
Aurora climate station (1995–2006) RAMP 98 Medium<br />
Stoney Plain climate station (1953–1994) Environment<br />
Canada<br />
Fort McMurray climate station (1959–2006) Environment<br />
Canada<br />
• Used to derive monthly and annual solar radiation statistics for the Oil Sands Region<br />
• Used to derive areal evaporation, actual lake evaporation, potential evapotranspiration,<br />
and potential lake evaporation<br />
Section 12.1<br />
April 2010 Shell Canada Limited 12-28<br />
CR029<br />
N/A<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
N/A<br />
N/A<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
Filling missing data using recorded data at Fort McMurray airport station based on an established spatial<br />
relationship for the region<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
Filling missing data using recorded data at Fort McMurray airport station based on an established spatial<br />
relationship for the region<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
Recorded sunshine hours from 1971–1996 were converted to solar radiation using a derived relationship<br />
based on Aurora data review. The data was then extrapolated back to 1953, using a relationship established<br />
with the Stoney Plain data.<br />
• Used as an input for the hydrologic model simulation N/A<br />
• Used to establish the relationship that was used to convert sunshine hours recorded at<br />
Fort McMurray airport climate station to solar radiation<br />
• Used as an input for the hydrologic model simulation<br />
100 High • Used to establish the relationship with solar radiation derived for Fort McMurray airport<br />
station<br />
100 High<br />
N/A<br />
N/A<br />
Filling missing data using recorded data at the Fort McMurray airport station, assuming little spatial variation<br />
in solar radiation in the region<br />
• Used to determine extreme hourly, daily and monthly wind speed statistics N/A<br />
• Used as an input for the hydrologic model simulation<br />
• Used to derive areal evaporation, actual lake evaporation, potential evapotranspiration,<br />
and potential lake evaporation<br />
Aurora climate station (1995–2006) RAMP 100 Medium • Used to characterize spatial variation of wind speed in the Oil Sands Region N/A<br />
Dewpoint temperature Fort McMurray climate station (1953-2006) Environment<br />
Canada<br />
Stream flow Athabasca <strong>River</strong> below Fort McMurray<br />
(1957–2006)<br />
Environment<br />
Canada<br />
100 High<br />
97 High<br />
• Used as input to Morton's Model to derive areal evaporation, actual lake evaporation,<br />
potential evapotranspiration, and potential lake evaporation<br />
• Used as input for the hydrologic model simulation<br />
• Used to derive relative humidity for the Oil Sands Region<br />
• Used to derive monthly, seasonal, annual and extreme flood and low-flow events and to<br />
analyze any trends resulting from climate change or climate variability<br />
• Used to determine the allowable water withdrawal within the restriction of the Athabasca<br />
<strong>River</strong> Water Management Framework<br />
N/A<br />
N/A<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics
WATER AENV SIRS 15 – 43<br />
Data Type Name of Data Set Data Source<br />
Athabasca <strong>River</strong> at Embarras airport<br />
(1971–1984)<br />
Environment<br />
Canada<br />
Firebag <strong>River</strong> near the mouth (1970–2006) Environment<br />
Canada<br />
Muskeg <strong>River</strong> near Fort McKay<br />
(1974-2006)<br />
Environment<br />
Canada<br />
Poplar Creek (1973–1986) Environment<br />
Canada<br />
Beaver <strong>River</strong> (1975–2006) Environment<br />
Canada<br />
Joslyn Creek (1975–1993) Environment<br />
Canada<br />
Steepbank <strong>River</strong> (1972–2006) Environment<br />
Canada<br />
MacKay <strong>River</strong> (1972–2006) Environment<br />
Canada<br />
Ells <strong>River</strong> (1975–1986 and 2001–2005) Environment<br />
Canada<br />
Big Creek (1975–1993)<br />
Asphalt Creek (1975–1977)<br />
<strong>Pierre</strong> <strong>River</strong> (1975–1977)<br />
Several RAMP data in the Jackpine <strong>Mine</strong><br />
Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> regional<br />
study area (RSA), see Table 2.2-4 in the<br />
ESR<br />
Environment<br />
Canada<br />
Environment<br />
Canada<br />
Environment<br />
Canada<br />
Table AENV 23-1: Summary of Data Sets Used for Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong> (cont'd)<br />
Level of<br />
Completeness<br />
(%)<br />
Qualitative<br />
Confidence<br />
Rating 1, 2 How Data was Used? How was Historical Incompleteness Resolved?<br />
71 4 High • Used to characterize variation of the Athabasca <strong>River</strong> flows in the lower reaches in<br />
conjunction with measured flows below Fort McMurray<br />
80 5 High<br />
81 6 High<br />
100 High<br />
78 6 High<br />
75 7 High<br />
77 6 High<br />
80 6 High<br />
80 7 High<br />
• Used to characterize the variation of water yields in the Oil Sands Region<br />
• Used to characterize monthly, seasonal, annual and extreme flood and low flows for the<br />
Jackpine <strong>Mine</strong> Expansion LSA<br />
Monthly flow relationships with Athabasca <strong>River</strong> flows recorded below Fort McMurray were used to derive<br />
flow data for longer periods (1957–2006)<br />
Section 12.1<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
• Used for regional hydrologic model validation N/A<br />
• Used to characterize the variation of water yields in the Oil Sands Region<br />
• Used to characterize the variation of water yields in the Oil Sands Region<br />
• Used to characterize the variation of water yields in the Oil Sands Region<br />
• Used to characterize the variation of water yields in the Oil Sands Region<br />
• Used to characterize the variation of water yields in the Oil Sands Region<br />
• Used to characterize the variation of water yields in the Oil Sands Region<br />
76 8 High • Used to characterize monthly, seasonal, annual and extreme flood and low flows for the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
• Used for regional hydrologic model validation N/A<br />
90 High • Used to characterize monthly, seasonal, annual and extreme flood and low flows for the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
• Used for regional hydrologic model validation N/A<br />
90 High • Used to characterize monthly, seasonal, annual and extreme flood and low flows for the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA<br />
RAMP 60 9 Medium<br />
If more than 10 days are missing for a particular month, the data for that month was not taken into account to<br />
derive monthly and annual statistics<br />
• Used for regional hydrologic model validation N/A<br />
• Used for regional hydrologic model validation<br />
Stream geomorphic data Oil Sands Region Golder 100 High • Used to characterize the geomorphic condition for the LSA N/A<br />
Total suspended solids Muskeg <strong>River</strong>, Muskeg Creek, Kearl Lake,<br />
MacKay <strong>River</strong>, Ells <strong>River</strong>, Jackpine Creek,<br />
Wapasu Creek and Athabasca <strong>River</strong><br />
Sediment yield Several streams in the RSA, see<br />
Table 2.3-20 in the ESR<br />
Snow survey data Snow survey in the Jackpine <strong>Mine</strong><br />
Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA<br />
<strong>Project</strong> hydrometric<br />
monitoring<br />
Several stations, see Table 2.2-5 in the<br />
ESR report<br />
Alberta<br />
Environment<br />
Environment<br />
Canada<br />
100 Medium<br />
100 High<br />
• Data were used to characterize the baseline total suspended solids concentration in the<br />
receiving streams<br />
• Data were used to characterize the baseline sediment yield from various watersheds<br />
RAMP/Golder 100 High • Data were used to support the Hydrologic Simulation Program Fortran model calibration<br />
and validation<br />
Golder 50 8 High • Data used to establish site-specific flow data and also to establish rating curves for local<br />
streams<br />
Note:<br />
1. All data that has been rated as high for qualitative confidence assumed that several QA/QC were performed before releasing the data for public use.<br />
2. All data that has been rated as medium for qualitative confidence assumed that the data has gone through basic QA/QC before the data was released for public use.<br />
3. Precipitation at Ells Lookout and Birch Mountain Lookout were only measured during the summer.<br />
4. Flow was not recorded during winter months (November/December – Mar/April) from 1977–1984.<br />
5. Flow was not recorded during winter months (November–February) from 1984–2006.<br />
6. Flow was not recorded during winter months (November–February) from 1987–2006.<br />
7. Flow was not recorded during winter months (November–April) from 2001–2005.<br />
8. Flow was not recorded during winter months (November–February) from 1981–1993.<br />
9. Two stations operating during the winter months, seven stations operating during open-water season and nine stations operating all year.<br />
April 2010 Shell Canada Limited 12-29<br />
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N/A<br />
N/A<br />
N/A<br />
N/A<br />
N/A
WATER AENV SIRS 15 – 43<br />
Question No. 25<br />
Section 12.1<br />
The animal species anticipated are a wide variety of mammals, birds and<br />
amphibian species associated with wetlands. These include, but are not limited<br />
to:<br />
• Canadian toads<br />
• black terns<br />
• a variety of waterfowl (e.g., green-winged teal, mallard, northern pintail)<br />
• other waterbirds including lesser yellow legs and sora rails<br />
• raptors such as northern harrier and short-eared owl<br />
• mammals such as muskrat, beaver, mink and river otter<br />
Request Volume 2, SIR 294a, Page 21-46.<br />
Shell states that a drawdown of more than 1 meter is considered to have the<br />
potential to negatively affect fen structure and function in a manner that could<br />
reduce flood attenuation capacity. This suggests that a drawdown of no more<br />
than 1 m of wetland water level may not negatively affect fen structure and<br />
function.<br />
25a Clarify how the 1 m threshold was established, providing specific reference to<br />
the three articles referenced (i.e., Szumigalski and Bayley 1997, Thorman et al.<br />
1988, Halsey et al. 2003), and in particular, in relation to how a
WATER AENV SIRS 15 – 43<br />
Figure AENV 24-1: Application Case Oil Sands Developments in the <strong>Pierre</strong> <strong>River</strong> Mining Area Local Study Area in the Far-Future<br />
Section 12.1<br />
April 2010 Shell Canada Limited 12-31<br />
CR029
WATER AENV SIRS 15 – 43<br />
Section 12.1<br />
Request 25b Explain why flood attenuation is the only hydrological characteristic discussed<br />
when flooding is only one of a suite of hydrological events affiliated with<br />
wetlands.<br />
Response 25b Typically, hydrologic characteristics of wetlands (muskeg, peatlands or forested<br />
swamps) include considerable storage of precipitation runoff, considerable<br />
evapotranspiration and low runoff yield. In addition, these features attenuate<br />
large floods that extend to the flood plains.<br />
In general, the removal of wetland features within the mine footprint will result<br />
in reduced flows (i.e., water yield), including flood flows to receiving streams<br />
and rivers. However, the hydrologic effect of removal of wetlands will be on<br />
reduced flood attenuation capacity.<br />
Request 25c The sustainability of a wetland’s structure and function is highly dependant on<br />
sustaining the hydrodynamics of the wetland. Further clarify how wetland<br />
integrity will be maintained in relation to other key hydrodynamic<br />
characteristics, such as seasonal fluxes in mean low and mean high water levels,<br />
and in relation to typical interactions with wetland vegetation, for example,<br />
altered vigor or desiccation effects.<br />
Response 25c Wetland hydrodynamics in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> local study area (LSA) may be<br />
affected by a variety of site-specific factors. However, by assessing the effects of<br />
the drawdown on wetlands using a 0.1 m drawdown contour, the environmental<br />
consequences of drawdown on wetland function are estimated conservatively. In<br />
addition, a wetlands monitoring program will be implemented to determine the<br />
specific effects the drawdown has on <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> wetlands. The EIA,<br />
Appendix 5-6, Terrestrial Monitoring Programs, Section 4, page 8, describes the<br />
general wetlands monitoring program that will be implemented to determine<br />
potential change to wetlands associated with the project. If monitoring indicates<br />
that additional mitigation is necessary, the monitoring results will be used to<br />
develop site-specific adaptive management strategies.<br />
Request 25d Four items are listed that qualitatively describe drawdown effects on the<br />
hydrology of the remaining wetlands. In relation to wetland functionality<br />
provide additional supporting evidence (e.g., data, logical arguments, relevant<br />
literature citations).<br />
i. Compare observations of the hydro-dynamic character of adjacent<br />
undisturbed wetlands in relation to remaining affected wetlands;<br />
ii. Use observations from adjacent undisturbed wetlands regarding normal<br />
wetland succession, to better characterize the time it will take for remaining<br />
affected wetlands to “…return to their former functionality more quickly”;<br />
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WATER AENV SIRS 15 – 43<br />
Section 12.1<br />
iii. Clarify the responses of key vegetation species, based on observations in<br />
adjacent undisturbed wetlands, to characterize hydro-dynamic changes<br />
within remaining affected wetlands; and,<br />
iv. Clarify the responses of key plant communities, based on observations in<br />
adjacent undisturbed wetlands, to characterize hydro-dynamic changes<br />
within remaining affected wetlands.<br />
Response 25d i. A direct comparison between the hydro-dynamic character of affected<br />
wetlands in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA and adjacent undisturbed wetlands<br />
should not be made, because site-specific factors will influence the<br />
hydrodynamic character of those wetlands. However, certain hydrological<br />
influences are expected to be similar. For example, it is known that<br />
hydrology influences the physical and chemical parameters in wetlands,<br />
which in turn influence the establishment and maintenance of wetland types<br />
and wetland processes. Given the major role of hydrology in wetlands<br />
function, changes in hydrology can affect aspects of wetland ecology, such as<br />
water chemistry, vegetation species composition and diversity (Thormann et<br />
al. 1998; Whitehouse and Bayley 2005; Locky and Bayley 2006; Laitinen et<br />
al. 2008).<br />
The relationship between water table depth and peatlands (e.g., fens and<br />
bogs) type is particularly close, with seasonal and annual water fluctuations<br />
influencing vegetation species composition in these wetlands (Thormann et<br />
al. 1998; Whitehouse and Bayley 2005).<br />
In general, the hydrological regime in wetlands is influenced by the wetland<br />
water budget, a character that is dynamic in space and time. The potential<br />
water storage capacity, geologic setting and climate will determine how a<br />
wetland responds to hydrologic changes related to oil sands development.<br />
Accordingly, the effects on peatlands because of water drawdown in the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA are specific to those particular wetlands for such<br />
aspects as natural drainage, topography and hydrogeology, because they have<br />
dynamic and generally site-specific effects across the LSA. These dynamic<br />
and site-specific effects are addressed by developing detailed wetlands<br />
monitoring programs in the predicted drawdown area.<br />
In general, the influence of hydrology on peatlands can be summarized as<br />
follows:<br />
• wetlands type (e.g., fens, bog, swamps) and wetlands succession is<br />
controlled by water source, rate of water flow and water table<br />
fluctuations, which in turn may affect nutrient availability, alkalinity and<br />
the accumulation or decomposition of organic substrate (Devito and<br />
Mendoza 2006)<br />
• water table fluctuations naturally occur within the upper layer of peat<br />
(acrotelm) in fen and bog wetlands because it has high hydraulic<br />
April 2010 Shell Canada Limited 12-33<br />
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WATER AENV SIRS 15 – 43<br />
References<br />
conductivity (Laitinen et al. 2008). Deeper peat layers are more<br />
compacted and likely have less influence on the water table.<br />
Section 12.1<br />
• peak flows in boreal wetlands typically occur in late spring and early<br />
summer (Devito and Mendoza 2006). In general, the water balance in<br />
boreal wetlands is influenced by spring snow melt, but the numerous<br />
small precipitation events in spring through to fall that add water directly<br />
to wetlands are believed to have the most influence on boreal wetlands<br />
(Devito and Mendoza 2006). Surface runoff from surrounding terrestrial<br />
uplands is considered to be limited during these events relative to direct<br />
input from precipitation.<br />
• groundwater influences are uncertain and site specific primarily because<br />
glacial deposits are highly variable (Price and Waddington 2000; Devito<br />
and Mendoza 2006)<br />
• depth of water table in unaltered peatlands can fluctuate seasonally and<br />
annually. Thormann et al. (1998) have shown that annual water levels in<br />
fens range between approximately 7 cm below the moss surface to 20 cm<br />
above the moss surface. Patterned fens are typically subject to lower<br />
seasonal fluctuations in water depth (approximately 5 cm) (Laitinen et al.<br />
2008). Annual fluctuations in bogs are more consistent over time (Halsey<br />
et al. 2003).<br />
• drops in water table of 70 cm or more can drastically alter nutrient<br />
regime and vegetation composition in peatlands (Jeglum 1971). Water<br />
table declines (an estimated 20 cm for poor fens and 14 cm for<br />
moderate-rich fens) may lead to moderate changes in peatland function<br />
(Gignac et al. 1991).<br />
• high and stable water levels are important to rich fen communities, as<br />
these communities are generally dominated by sedges and moss<br />
(Kotowski et al. 2001; Whitehouse and Bayley 2005)<br />
Devito, K., and C. Mendoza. 2006. Maintenance and Dynamics of Natural<br />
Wetlands in Western Boreal Forests: Synthesis of Current Understanding<br />
from the Utikuma Research Study Area. In Guidelines for Wetland<br />
Establishment on Reclaimed Oil Sands Leases Revised (2007) Edition,<br />
Appendix C. Cumulative Environmental Management Association.<br />
Wood Buffalo Region, Alberta.<br />
Gignac, L.D., D.H. Vitt, and S.E. Bayley. 1991. Bryophyte Response Surfaces<br />
Along Ecological and Climatic Gradients. Vegetation 93:29-45.<br />
Halsey, L.A., D.H. Vitt, D. Beilman, S. Crow, S. Mehelcic, and R. Wells. 2003.<br />
Alberta Wetland Inventory Standards Version 2.0. Resource Data<br />
Division, Alberta Sustainable Resource Development. Edmonton,<br />
Alberta.<br />
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Section 12.1<br />
Jeglum, J.K. 1971. Plant Indicators of pH and Water Level in Peatlands at Candle<br />
Lake, Saskatchewan. Canadian Journal of Botany 49:1661-1676.<br />
Kotowski, W., J. van Andel, R. van Diggelen, and J. Hogendorf. 2001.<br />
Responses of Fen Plant Species to Groundwater Level and Light<br />
Intensity. Plant Ecology 155:147-156.<br />
Laitinen, J., S. Rehell, and J. Oksanen. 2008. Community and Species Responses<br />
to Water Level Fluctuations with Reference to Soil Layers in Different<br />
Habitats of Mid-boreal Mire Complexes. Plant Ecology 194:17-36.<br />
Locky, D.A., and S.E. Bayley. 2006. Plant Diversity, Composition, and Rarity in<br />
the Southern Boreal Peatlands of Manitoba, Canada. Canadian Journal of<br />
Botany 84:940-955.<br />
Price, J.S., and J.M. Waddington. 2000. Advances in Canadian Wetland<br />
Hydrology and Biochemistry. Hydrological Processes 14:1579-1589.<br />
Thormann, M.N., S.E. Bayley, and A.R. Szumigalski. 1998. Effects of<br />
Hydrologic Changes on Aboveground Production and Water Chemistry<br />
in Two Boreal Peatlands in Alberta: Implications for Global Warming.<br />
Hydrobiologia 362:171-183.<br />
Whitehouse, H.E., and S.E. Bayley. 2005. Vegetational Patterns and Biodiversity<br />
of Peatland Plant Communities Surrounding Mid-boreal Wetland Ponds<br />
in Alberta, Canada. Canadian Journal of Botany 83:621-637.<br />
ii. Observations from adjacent undisturbed wetlands are not currently available.<br />
EIA, Appendix 5-6, Terrestrial Monitoring Programs, Section 4, page 8,<br />
describes the general wetlands monitoring program that will be implemented<br />
to determine potential change to wetlands associated with the project and will<br />
include undisturbed reference monitoring plots to gauge the time it will take<br />
for remaining affected wetlands to return to their former functionality.<br />
iii. Adjacent undisturbed wetlands have not been monitored and, therefore, these<br />
observations are not available. However, based on the literature, differences<br />
in plant species composition, abundance and structure associated with<br />
wetlands types are a result of the hydrological regime and chemical<br />
parameters influencing the wetland (Thormann et al. 1998; Whitehouse and<br />
Bayley 2005). Vegetation species diversity in wetlands, in particular<br />
peatlands, is strongly associated with water depth and nutrient gradient (Vitt<br />
and Chee 1990; Whitehouse and Bayley 2005).<br />
Vegetation in peatlands has adapted to short-term and small seasonal<br />
fluctuations in water levels. However, when changes in water level are<br />
persistent and exceed seasonal normals, changes to vegetation communities<br />
can occur. Long-term changes in water levels, with durations over many<br />
seasons can affect vegetation species presence/absence in peatlands.<br />
Changes in hydrology can be associated with the following responses by<br />
vegetation; however, precise responses are dependent on site-specific factors:<br />
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References<br />
Section 12.1<br />
• an average water level of 1 to 40 cm above ground surface can result in<br />
the absence of trees and many shrub species from peatlands; at water<br />
depths of 0 to 19 cm below the ground surface, black spruce and<br />
tamarack abundance is reduced, though wetland shrubs can be abundant<br />
(Jeglum 1971)<br />
• at water depths greater than 0 to 19 cm above the surface, grasses and<br />
sedges and wetlands forbs may dominate (Jeglum 1971)<br />
• long-term water level declines greater than 20 cm in peatlands can allow<br />
peatland functions to continue, but vegetation community structure is<br />
expected to change (Gignac et al. 1991). Drops in water level below the<br />
natural range can cause decreases in sedges, grasses and mosses and<br />
increases in shrubs (Thormann and Bayley 1997).<br />
• surface water levels affect bryophyte community structure with brown<br />
mosses typically dominating wet environments, with Sphagnum species<br />
within moist depressions to top of hummock dry areas (Laitinen et al.<br />
2008)<br />
Gignac, L.D., D.H. Vitt, and S.E. Bayley. 1991. Bryophyte Response Surfaces<br />
Along Ecological and Climatic Gradients. Vegetation 93:29-45.<br />
Jeglum, J.K. 1971. Plant Indicators of pH and Water Level in Peatlands at Candle<br />
Lake, Saskatchewan. Canadian Journal of Botany 49:1661-1676.<br />
Laitinen, J., S. Rehell, and J. Oksanen. 2008. Community and Species Responses<br />
to Water Level Fluctuations with Reference to Soil Layers in Different<br />
Habitats of Mid-boreal Mire Complexes. Plant Ecology 194:17-36.<br />
Thormann, M.N., and S.E. Bayley. 1997. Aboveground Net Primary Production<br />
Along a Bog-fen-Marsh Gradient in Southern Boreal Alberta, Canada.<br />
Ecoscience 4:374-384.<br />
Thormann, M.N., S.E. Bayley, and A.R. Szumigalski. 1998. Effects of<br />
Hydrologic Changes on Aboveground Production and Water Chemistry<br />
in Two Boreal Peatlands in Alberta: Implications for Global Warming.<br />
Hydrobiologia 362:171-183.<br />
Vitt, D.H., and W.L. Chee. 1990. The Relationship of Vegetation to Surface<br />
Water Chemistry and Peat Chemistry in Fens of Alberta, Canada.<br />
Vegetation 89:87-106.<br />
Whitehouse, H.E., and S.E. Bayley. 2005. Vegetational Patterns and Biodiversity<br />
of Peatland Plant Communities Surrounding Mid-boreal Wetland Ponds<br />
in Alberta, Canada. Canadian Journal of Botany 83:621-637.<br />
iv. See the response to AENV SIR 25diii.<br />
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Section 12.1<br />
Request 25e Provide information on plans to monitor and mitigate the impacts of dewatering<br />
on the surrounding wetlands.<br />
Response 25e The conceptual wetlands monitoring program described in the EIA, Volume 5,<br />
Appendix 5-6, will expand on the Albian Sands Wetlands Monitoring Program,<br />
which has been ongoing since 2000 (Golder 2007). To assess the potential effects<br />
of the project on wetlands, the approach will be to monitor species abundance,<br />
richness, diversity and vigour according to plot distance from the mine over the<br />
duration of the monitoring program. The program will include collecting<br />
ecological field data and interpreting aerial photographs.<br />
Reference<br />
Question No. 26<br />
Groundwater monitoring, as conceptually described in the EIA, Volume 4B,<br />
Appendix 4-9, Section 2, will provide early indication of potential<br />
hydrogeological effects on wetlands due to dewatering. Should the groundwater<br />
monitoring program detect an unanticipated change to groundwater levels near a<br />
particular wetland, a groundwater response plan (EIA, Volume 4B, Appendix 4-<br />
9, Section 2.1.5) will be developed and implemented. The response plan will<br />
assess and mitigate, if necessary, the hydrogeological change to adaptively<br />
manage potential impacts of dewatering on a nearby wetland.<br />
Golder. 2007. Muskeg <strong>River</strong> <strong>Mine</strong>, Wetlands Monitoring Program, 2005 Annual<br />
Report. Prepared by Golder Associated Ltd. For Albian Sands Energy<br />
Inc.<br />
Request Volume 2, SIR 294b, Page 21-48.<br />
Shell states that wetlands function to attenuate flood runoff and then states that<br />
the removal of wetlands will result in reduced flows to streams and rivers.<br />
26a Clarify this apparent inconsistency.<br />
Response 26a There is no inconsistency. The removal of wetlands in the project areas (i.e.,<br />
areas within the mine footprint) because of mine development (closed-circuit<br />
operations) will result in reduced flows, including flood flows to receiving<br />
streams and rivers. However, the function of the remaining wetlands (wetlands<br />
located outside the closed-circuit operations) will not be affected by removal of<br />
wetland features within the mine footprint and will continue to attenuate flood<br />
runoff.<br />
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Question No. 27<br />
Request Volume 2, SIR 294d, Page 21-48.<br />
Section 12.1<br />
Shell states that wetlands in the reclaimed landscape are expected to succeed to<br />
marsh wetland types. Shell states that peatlands are not considered as part of<br />
the reclaimed landscape at closure because there is limited knowledge about<br />
requirements for peat-forming processes on reclaimed landscapes (CEMA 2007).<br />
27a Clarify where marsh wetland types are planned in the reclamation closure plan.<br />
Response 27a At the landscape level of planning, at the time of reclamation, marsh wetlands<br />
types will be created using current guidelines for wetlands establishment. At the<br />
meso-topographical scale, marsh wetlands types are expected to establish in<br />
depressional areas of reclaimed tailings cells and the external tailings facility, at<br />
the base of the north overburden disposal area, and within littoral zones and<br />
associated wetlands constructed at the inlet, outlet and margins of the pit lakes.<br />
On a micro-topographical scale, marsh wetlands types will be planned, where<br />
appropriate, along the vegetated waterways and drainage channels, identified by<br />
Sh2 and Sh3 on Figure 14 (EIA, Volume 5, Appendix 5-2).<br />
At the conceptual level of EIA planning, marsh wetlands types have been<br />
considered in depressions within low-lying areas on tailings cells and on the<br />
shorelines of the pit lakes. Reclamation target transitional ecosite types d1 and e2<br />
shown in Figure 14 (see EIA, Volume 5, Appendix 5-2) have been located at the<br />
transition between upland and wetlands areas, and support wetlands functions.<br />
Hydrological conditions, soil profiles and vegetation types will be reconstructed<br />
on the landscape to support wetlands functions and development, as described in<br />
the EIA, Volume 5, Appendix 5-2, Section 2.3.2.<br />
Request 27b Provide a map of the marsh ecosite phases and description of wetland plant and<br />
animal species that are anticipated.<br />
Response 27b Figure AENV 27-1 presents the areas where marsh ecosites and wetlands<br />
transtitional ecosites are planned on the conceptual closure landscape. As<br />
described in the response to AENV SIR 27a, marsh ecosites will also be planned<br />
at the landscape level.<br />
Plant and animal species typical to graminoid marsh (MONG) wetlands types are<br />
expected in the reclaimed marsh ecosite types. Emergent sedges, grasses, rushes,<br />
reeds, submerged and floating aquatics are among the plant families expected in<br />
the reclaimed marshes. The plant species anticipated include, but are not limited<br />
to Typha spp., Carex spp., Scirpus spp., Polygonum spp., Juncus spp., and<br />
Acorus calamus. The animal species anticipated are a wide variety of mammals,<br />
birds and amphibian species associated with wetlands. These include, but are not<br />
limited, to: Canadian toads; black terns, a variety of waterfowl (e.g., greenwinged<br />
teal, mallard, northern pintail), other waterbirds including lesser yellow<br />
legs and sora rails; raptors, such as northern harrier and short-eared owl; and<br />
mammals, such as muskrat, beaver, mink and river otter.<br />
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Figure AENV 27-1: Reclamation Ecosite Phase/Wetlands Types Planting Prescriptions<br />
Section 12.1<br />
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Section 12.1<br />
Request 27c Provide information on what is currently known about peat-forming processes on<br />
reclaimed landscapes in the oil sands region. Discuss current research studies<br />
and results.<br />
Response 27c There is ongoing research in the Oil Sands Region related to peatland<br />
reconstruction. Shell participates in the Canadian Oil Sands Network for<br />
Research and Development (CONRAD) and supports research projects,<br />
including studies on the initiation of wetlands and controls of soil moisture<br />
regimes on reconstructed landscapes. Shell supports Dale Vitt’s research on<br />
understanding peatland initiation processes that will contribute to the<br />
development of best practices for peatland reconstruction. Shell will continue to<br />
incorporate results from current research studies into its reclamation operations,<br />
where feasible.<br />
References<br />
Current reclamation knowledge and experience in the region states that organic<br />
bogs and fens (peatlands) cannot be reclaimed (CEMA 2007), but research is<br />
currently underway within CONRAD (CONRAD 2008) and the Wetlands and<br />
Aquatic Sub Group (WASG) of the Cumulative Environmental Management<br />
Association (CEMA) to investigate methodologies for wetlands reconstruction on<br />
reclaimed landscapes. For example, CONRAD supports fen reclamation research<br />
that is investigating the success of vegetation island transplants. The WASG has<br />
initiated reclamation research on the processes and function of existing wetlands<br />
for practical application in the Oil Sands Region.<br />
CEMA. 2007. Guideline for wetland establishment on reclaimed oil sands leases<br />
(revised edition) 2007. Prepared by Harris, M.L. for CEMA Wetlands<br />
and Aquatics Subgroup of the Reclamation Working Group, Fort<br />
McMurray, AB. Dec/07.<br />
CONRAD. 2008. 2008 Annual Update. Canadian Oil Sands Network for<br />
Research and Development – Environmental and Reclamation Research<br />
Group (CONRAD ERRG).<br />
Request 27d Clarify how this knowledge will be used in progressive wetland reclamation<br />
planning on the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Site.<br />
Response 27d Reclamation programs will be adaptively managed to incorporate the results and<br />
recommendations from ongoing research regarding the establishment of bogs and<br />
fens on the closure landscape. As discussed in the response to AENV SIR 27c,<br />
Shell will progressively incorporate the results of current wetlands reconstruction<br />
research into reclamation planning and operations, where feasible.<br />
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Question No. 28<br />
Request Volume 2, SIR 294e, Page 21-49.<br />
Section 12.1<br />
The assumption that storage capacity for a given surface area of a pit lake is<br />
greater than that of a wetland is misleading because it is not the surface area but<br />
rather the ‘active’ depth or volume that is critical in relation to patterns of water<br />
storage, retention and release. Peat soils and living Sphagnum may retain well<br />
in excess of their weight by volume of water, and in doing so, they buffer the<br />
rates at which fluxes of water storage, retention and release occur.<br />
28a Provide data and information to demonstrates how pit lakes will be regulated to<br />
respond in the manner that the natural wetland systems operate (e.g., in terms of<br />
mimicking time lags), in particular in relation to typical fluxes that occur, such<br />
as from storm and flood events, and extended periods of desiccation/drying.<br />
Response 28a The pit lakes will not be regulated (designed) to respond to various storm events<br />
in the same manner that the natural wetland systems operate (i.e. the pit lakes are<br />
not expected to exactly mimic the natural wetlands in terms of storage capacity<br />
and time lags to attenuate floods). Therefore, the reclaimed landscape will have a<br />
different hydrological response compared to natural conditions. The effects of<br />
this change in hydrological response are captured in the surface water hydrology<br />
assessment (see EIA, Volume 4A, Section 6.4.5).<br />
Question No. 29<br />
Request Volume 2, SIR 297a, Page 21-51.<br />
Shell states that Modeling has been completed to confirm that the residence time<br />
will be sufficient to biodegrade organic constituents to acceptable levels.<br />
29a Indicate where in the EIA this modeling is reported and assessed in relation to<br />
this question. If it is not in the EIA, provide the data and information.<br />
Response 29a Pit lake water quality modelling methods are presented in the EIA, Volume 4B,<br />
Appendix 4-2, Section 2.1.3.2; pit lake modelling results are presented in EIA,<br />
Volume 4B, Appendix 4-7, Section 4; assessment of modelling results is<br />
presented in EIA, Volume 4A, Section 6.5.6.3.<br />
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Question No. 30<br />
Request Volume 2, SIR 298a – d, Page 21-53.<br />
Section 12.1<br />
It is likely that the polishing pond temperatures for Jackpine and <strong>Pierre</strong> <strong>River</strong><br />
will be within close range of each other. Similarly, the Muskeg and <strong>Pierre</strong> <strong>River</strong><br />
streams also exhibit comparable water temperature regimes. On this basis, the<br />
four questions (i.e., SIR 298 a – d) are applicable to <strong>Pierre</strong> <strong>River</strong>.<br />
30a Provide answers to the four questions posed, in terms of polishing pond<br />
temperatures of the <strong>Pierre</strong> <strong>River</strong> project and the streams of the <strong>Pierre</strong> <strong>River</strong><br />
project that flow to the Athabasca <strong>River</strong>.<br />
Response 30a The following are responses to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 2, SIR 298 a to d, in terms of polishing pond temperatures<br />
of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong> and the streams of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong><br />
that flow to the Athabasca <strong>River</strong>:<br />
Original SIR 298a<br />
Clarify the first sentence of the pre-amble since most of the polishing pond<br />
temperatures presented in Figure 6.5-2 (Page 6-380) are above the seventy-fifth<br />
percentile of the Muskeg <strong>River</strong>, and not within the range of monthly background<br />
temperatures.<br />
Figure 6.5-2 shows that the range of polishing pond temperatures (0.0 to 20.6ºC)<br />
is within the range of background temperatures for the Muskeg <strong>River</strong> (-0.6 to<br />
23.3ºC). Episodic periods of warmer temperature for polishing ponds have been<br />
observed before ice-cover from August to December, and a few were outside of<br />
monthly background ranges (e.g., October 25, 2002). These periods corresponded<br />
to short-term periods of high solar radiation and air temperatures, when bottom<br />
heat flux from the shallow polishing ponds can appreciably affect water<br />
temperature.<br />
Original SIR 298b<br />
How will higher temperatures quantitatively influence downstream temperatures<br />
in the Muskeg <strong>River</strong>; that is, what will be the new downstream water<br />
temperatures at different times of the year under a range of river stages?<br />
A conservative temperature balance of a “worst-case” scenario for thermal<br />
impacts from polishing ponds releases was calculated as part of the EIA and is<br />
discussed in EIA, Volume 4A, Section 6.5.5.1, page 6-382. It was based on:<br />
• mean September and October streamflows and water temperature for the<br />
Muskeg <strong>River</strong><br />
• high flow from the polishing ponds<br />
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• temperature recorded at the ponds during the episodic warm period of<br />
October 25, 2002 (see Figure 6.5-3)<br />
Section 12.1<br />
The balance indicated that water temperatures in the Muskeg <strong>River</strong> are expected<br />
to increase by less than 0.1ºC. This “worst-case” scenario is unlikely to occur,<br />
since high pond outflow will typically correspond with high streamflow in the<br />
Muskeg <strong>River</strong>. Therefore, temperature increases in the river as a result of pond<br />
temperature are expected to be less than 0.1ºC for all the likely combinations of<br />
pond outflows and Muskeg <strong>River</strong> streamflows.<br />
For the reasons outlined above, increases in water temperatures in Eymundson<br />
Creek downstream of polishing ponds are similarly expected to be less than 0.1ºC<br />
for all the likely combinations of pond outflows and streamflows.<br />
Original SIR 298c<br />
What range of distances for the flow in ditches are required to return water<br />
temperature to ambient conditions, before discharging to the river at different<br />
times of the year?<br />
As mentioned in the response to SIR 298b, the maximum anticipated change in<br />
Muskeg <strong>River</strong> water temperatures is less than 0.1ºC, based on a conservative<br />
thermal balance. The small changes in Muskeg <strong>River</strong> temperatures downstream<br />
of polishing ponds have been confirmed by monitoring, as detailed in EIA,<br />
Volume 4, Section 6.5.5.1. Therefore, the ditch constructed to convey water from<br />
the polishing ponds to receiving waters would provide additional thermal<br />
equilibration above and beyond what is necessary in terms of minimizing thermal<br />
effects.<br />
Original SIR 298d<br />
What criteria, factors, probability levels and thresholds did Shell use to<br />
determine that the slightly higher temperatures in the Muskeg <strong>River</strong>, ranging<br />
from approximately less than 1 degree C to 3 degrees C caused by the polishing<br />
pond effluence is negligible?<br />
Neither Section 6.5.5.1 nor 6.5.5.3 refer to “slightly higher temperatures in the<br />
Muskeg <strong>River</strong>, ranging from approximately less than 1 degree C to 3 degrees C<br />
caused by the polishing pond effluence”. In the EIA, Volume 4A, Section<br />
6.5.5.1, page 6-379 states “polishing pond releases induce negligible changes to<br />
Muskeg <strong>River</strong> water temperatures (Figure 6.5-3)”. This statement refers to the<br />
very small change in temperature (well below 1ºC) observed in the Muskeg <strong>River</strong><br />
because of polishing pond discharge, even during periods when water<br />
temperature is high in the polishing ponds. It is expected that similar changes<br />
would be expected in Eymundson Creek downstream of polishing pond releases.<br />
The water quality guideline used in Alberta for the protection of freshwater<br />
aquatic life (AENV 1999) was the criterion employed to qualify the effect of<br />
polishing ponds and pit lakes on water temperature. The guideline specifies that<br />
instream water temperature is “not to be increased by more than 3°C above<br />
ambient water temperature”.<br />
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Reference<br />
Question No. 31<br />
Section 12.1<br />
AENV (Alberta Environment). 1999. Surface Water Quality Guidelines for Use<br />
in Alberta. Science and Standards Branch. Environmental Assurance<br />
Division. Edmonton, AB. Submitted November 1999. 25 pp.<br />
Request Volume 2, SIR 299, Page 21-54.<br />
It is likely that the polishing pond DO concentrations for Jackpine and <strong>Pierre</strong><br />
<strong>River</strong> will be within close range of each other. Similarly, the Muskeg and <strong>Pierre</strong><br />
<strong>River</strong> streams also exhibit comparable DO concentrations. On this basis, the two<br />
questions (i.e., SIR 299) are applicable to <strong>Pierre</strong> <strong>River</strong>.<br />
31a Provide the answers to SIR 299 posed in terms of polishing pond DO<br />
concentrations of the <strong>Pierre</strong> <strong>River</strong> project and its streams and receiving waters.<br />
Response 31a The following are responses to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 2, SIR 299a and b, in terms of polishing pond DO<br />
concentrations of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong> and its streams and receiving<br />
waters:<br />
References<br />
Original SIR 299a<br />
Explain why changing the annual frequency distribution of DO does not have an<br />
adverse effect on DO concentrations.<br />
Increases in dissolved oxygen concentrations, even up to 100% saturation, do not<br />
have adverse effects on aquatic life. Therefore, changes in the annual frequency<br />
distribution associated with increasing dissolved oxygen (DO) concentrations are<br />
not considered to adversely affect aquatic life. Dissolved oxygen is essential to<br />
the metabolism of all aerobic aquatic organisms (Wetzel 2001) and no adverse<br />
effects are associated with oxygen concentrations near saturation. Therefore,<br />
provided that water quality guidelines for the protection of aquatic life for<br />
dissolved oxygen (AENV 1999; CCME 1999; US EPA 2002) are met, and the<br />
waters are not becoming highly supersaturated, changes in DO within these<br />
bounds are not predicted to have an adverse effect.<br />
AENV (Alberta Environment). 1999. Surface Water Quality Guidelines for Use<br />
in Alberta. Science and Standards Branch. Environmental Assurance<br />
Division. Edmonton, AB. Submitted November 1999. 25 pp.<br />
CCME (Canadian Council of Ministers of the Environment). 1999. Canadian<br />
Environmental Quality Guidelines (with updates to 2006). Winnipeg,<br />
MB.<br />
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Reference<br />
Question No. 32<br />
Section 12.1<br />
US EPA (United States Environmental Protection Agency). 2002. National<br />
Recommended Water Quality Criteria: 2002. US EPA, Office of Water<br />
4304T. EPA 822-R-02-047.<br />
Wetzel, R. G. 2001. Limnology: Lake and <strong>River</strong> Ecosystems, 3rd Edition.<br />
Academic Press. New York, NY. 1006 pp.<br />
Original SIR 299b<br />
How does the change in the annual DO frequency distribution affect other water<br />
quality parameters, including but not limited to: pH, ion mobility, algae and<br />
plankton production and elemental biogeochemical cycling?<br />
Although some biogeochemical processes affect both pH and dissolved oxygen<br />
(DO), there is no direct relationship between these variables. Therefore, a change<br />
in the annual DO frequency distribution would not directly affect pH.<br />
The three major mechanisms controlling major ion concentrations in surface<br />
water are rock dominance, atmospheric precipitation and evaporationprecipitation<br />
processes (Wetzel 2001). A connection between DO and major ion<br />
mobility has not been identified, provided the water is not anoxic.<br />
In relatively well-oxygenated water, DO is not expected to be a limiting factor<br />
for algae plankton production. Therefore, small increases in DO would not be<br />
expected to have effects on productivity.<br />
Redox potential is relatively insensitive to changes in DO, and redox potential of<br />
surface waters will remain positive and fairly high as long as water is not near<br />
anoxia (Wetzel 2001). As discussed in EIA, Volume 4A, Section 6.5.6, DO<br />
concentrations are not expected to decline in receiving streams downstream of<br />
the project. Therefore, the annual DO frequency distribution is not expected to<br />
affect elemental biogeochemical cycling.<br />
Wetzel, R. G. 2001. Limnology: Lake and <strong>River</strong> Ecosystems, 3rd Edition.<br />
Academic Press. New York, NY. 1006 pp.<br />
Request Volume 2, SIR 301a-b, Page 21-55.<br />
Global action on climate change issues fundamentally requires the active<br />
cooperation of major industrial operators working at a regional or local level.<br />
32a What efforts are being made by Shell (in addition to efforts undertaken by<br />
CEMA) to integrate project information with other proposed projects?<br />
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Section 12.1<br />
Response 32a Shell continues to participate in a number of relevant regional, provincial and<br />
national initiatives, including:<br />
• Technology for Emission Reduction and Eco-Efficiency steering committee<br />
within the Petroleum Technology Alliance Canada<br />
• Industry Greenhouse Gas Benchmarking Advisory Group and the Fuel Best<br />
Management Practices Industry Advisory Group within the Canadian<br />
Environmental Technology Advancement Corporation – West<br />
• Electricity <strong>Project</strong> Team – Greenhouse Gas Allocation Subgroup of the<br />
Clean Air Strategic Alliance<br />
Request 32b What is Shell (in addition to efforts undertaken by RAMP) doing to share data at<br />
the western regional and national levels with other organizations?<br />
Response 32b See the response to AENV SIR 32a.<br />
Question No. 33<br />
Request Volume 2, SIR 306a-b, Page 21-59.<br />
The discussion of the role of Karst in the <strong>Pierre</strong> <strong>River</strong> area concludes by<br />
identifying that the Karst hydrology is primarily independent or separate of the<br />
deep basal aquifer. Shell states that, the sinkholes are considered to be part of<br />
the local shallow groundwater flow system but then, in the next sentence, makes<br />
the point that sinkholes do not appear to have an influence on the shallow<br />
groundwater system.<br />
33a Clarify this relationship, as the text seems to contradict itself, saying that karst is<br />
part of the local shallow groundwater system, but has no influence upon the local<br />
groundwater system.<br />
Response 33a The first conclusion, that “the sinkholes are considered to be part of the local<br />
shallow groundwater flow system”, indicates that the sinkholes are not connected<br />
to the basal aquifer because the sinkhole water chemistry is markedly different<br />
than that of the basal aquifer.<br />
The second conclusion, that “sinkholes do not appear to have an influence on the<br />
shallow groundwater system”, indicates that no differences were observed<br />
between the hydrogeologic characteristics of the sinkhole lakes and the shallow<br />
groundwater system for either water levels or water chemistry. If the sinkhole<br />
lakes were an expression of the basal aquifer, representing discharge of basal<br />
water, then the lake water chemistry would have reflected the basal water<br />
chemistry, but this was not the case. Therefore, it was concluded that the sinkhole<br />
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lakes would likely recharge the basal aquifer, in the same way as the surficial<br />
deposits recharge the basal aquifer. Accordingly, dewatering of the sinkholes is<br />
not expected to have any incremental effects to those caused by dewatering the<br />
surrounding shallow groundwater system. This was the basis for the conclusion<br />
that “the sinkholes will not likely contribute extensive, regional hydrologic effects<br />
to the project.”<br />
Request 33b Shell states that sinkholes will not likely contribute extensive, regional<br />
hydrologic effects on the project but regarding localized effects, there are no<br />
data provided or site-specific treatment discussed.<br />
i. Clarify what Karst effects or influences could be at a local level in relation to<br />
the development of the <strong>Project</strong>, and outline how these will be mitigated.<br />
ii. Provide any appropriate data or information that describes if or how<br />
calcium-enriched waters may continue to flow and contribute to the<br />
hydrology and ecology of the aquatic resources, within the local context.<br />
Response 33b i. No karst effects on the shallow groundwater were noted at the local level.<br />
Water levels in both the sinkhole lakes and the surficial deposits are similar<br />
and there is a downward vertical hydraulic gradient between the surficial<br />
deposits and the basal aquifer. This suggests that both the sinkhole lakes and<br />
the surficial deposits similarly recharge the basal aquifer.<br />
The conclusion reached in the response to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 2, SIR 306b was that “hydrologic and<br />
hydrogeologic effects of the project are not predicted to be materially<br />
exacerbated or attenuated by the Eymundson Sinkholes. Accordingly,<br />
mitigation measures are not required.” This conclusion applies to both local<br />
and regional effects.<br />
ii. The sinkholes will continue to function and contribute to local aquatic<br />
resources, including the basal aquifer system, until overburden dewatering is<br />
conducted in advance of mining the area. When overburden dewatering<br />
begins near the sinkhole lakes, the lakes will be drained, as will the<br />
surrounding shallow groundwater system.<br />
Although sinkhole waters will continue to flow and contribute to local<br />
hydrology prior to disturbance, the advance of the active mine pit will<br />
ultimately result in dewatering and removing the sinkholes. The reclaimed<br />
mining area, including the area that formerly contained the sinkholes, will<br />
have different shallow groundwater flow patterns than it did before the<br />
disturbance.<br />
Request 33c With respect to SIR 306b, provide data or analysis that supports Shell’s position.<br />
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Response 33c The data to support the position presented in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 2, SIR 306b, that the sinkholes do not<br />
exacerbate or attenuate effects of the project, were described in SIR 306a. These<br />
data included:<br />
Reference<br />
• local geology and hydrogeology (Section 5.4.3 and Figures 29, 32 to 38 of<br />
the Hydrogeology ESR, WorleyParsons Komex, 2007)<br />
• groundwater levels in shallow and deeper Quaternary deposits (Figures 37<br />
and 38; WorleyParsons Komex, 2007)<br />
• bathymetry data for Sinkhole Lakes 1 and 2 (EIA, Section 8.4.5.2, pp 8-77)<br />
• water chemistry for Sinkhole Lakes 1 and 2<br />
• groundwater chemistry for Quaternary deposits, McMurray Formation, Basal<br />
aquifer and Devonian Formation (Table 11, WorleyParsons Komex, 2007)<br />
• major ion characterization for Sinkhole Lake, Basal aquifer and Devonian<br />
Formation waters (Figure 306-1, May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 2)<br />
Based on these data, the following conclusions were reached:<br />
• the shallow groundwater flow direction is not altered by the sinkholes<br />
• the hydrochemical signature of the sinkhole lakes is calcium-bicarbonate<br />
(Ca-HCO3) type, indicative of freshwater<br />
• the hydrochemical signature of the basal aquifer near the sinkholes is<br />
sodium-bicarbonate-chloride (Na- HCO3-Cl) type, indicative of an older,<br />
deeper, regional groundwater flow system<br />
• the difference in hydrochemical signatures indicates a lack of hydraulic<br />
connection between the sinkholes and deeper deposits<br />
WorleyParsons Komex. 2007. Hydrogeology Environmental Setting Report for<br />
the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Prepared<br />
for Shell Canada Limited, Calgary, AB. Submitted December 2007.<br />
Request 33d In Shell’s discussion of Karst, a reference is made to Figure 8.4-6 in Volume 5 of<br />
the EIA, the Terrestrial Section. Figure 8.4-6 illustrates the locations of three<br />
sinkholes, while Figure 8.4-7 shows there to be four. Clarify this discrepancy.<br />
Response 33d Figure 8.4-7 is based on the surficial geology map by Bayrock (1971) and shows<br />
four sinkhole locations near the border of the Eymundson ESA and a fifth<br />
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References<br />
Question No. 34<br />
Section 12.1<br />
sinkhole location immediately north of Eymundson Creek. Figure 8.4-6 shows<br />
three water-filled sinkholes that have been captured in the hydrography layer of<br />
1:25,000 scale provincial maps (Altalis, 2004). Sinkhole Lakes 1 and 2 are those<br />
noted by Westworth (1990), whereas Sinkhole Lake 3 corresponds to the fifth<br />
sinkhole location shown in the map by Bayrock (1971). The air photo in Figure<br />
8.4-8 clearly shows the three large water-filled sinkholes (Sinkhole Lakes 1, 2<br />
and 3), one additional sinkhole lake, and other sinkholes (within the yellowdashed<br />
area) that do not appear water filled.<br />
Bayrock, L.A. 1971. Surficial Geology Bitumount (NTS 74E). Research Council<br />
of Alberta. Map 140, 1:250,000 scale.<br />
Westworth (Westworth and Associates Ltd.) 1990. Significant Natural Features<br />
of the Eastern Boreal Forest Region of Alberta. Technical Report. Report<br />
for Alberta Forestry, Lands and Wildlife. Edmonton, AB. 147 pp. +<br />
Maps.<br />
Request Volume 2, SIR 384a, Page 23-2.<br />
In response to the question of whether or not Shell considers all project effects<br />
reversible, Shell states that Only six project related effects on terrestrial<br />
resources were determined to be irreversible:…. Old growth forest is irreversible<br />
within the timeline of the assessment – but reversible in the far future. [And]<br />
Wetlands, including peatlands and patterned fens resulting from the assumption<br />
that peatlands cannot currently be reclaimed.<br />
In Table 480-1 included in their response to SIR 384 a, Shell states The<br />
environmental consequence for barred owl habitat is considered low because,<br />
although habitat loss is high in magnitude at 80 years post closure and<br />
reclamation, the reclamation landscape has the potential to develop barred owl<br />
habitat over 100 years or more.<br />
34a Clarify the timeline on which the assessment of project effects is made.<br />
Response 34a For the purposes of assessing project effects on terrestrial resources, closure and<br />
reclamation effects are considered 80 years after the completion of mining (EIA,<br />
Volume 5, Section 7.2.3, p.7-14).<br />
Request 34b Given that Shell acknowledges that old growth forests cannot be reclaimed, at<br />
least within the time line of the assessment, how can Shell conclude that the<br />
environmental consequence of the project on barred owls in the LSA is low?<br />
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i. Is the regeneration of old growth forest (>100 years) not explicitly outside of<br />
the assessment period (80 years post closure and reclamation)?<br />
ii. Explain this apparent discrepancy.<br />
Response 34b i. Yes, the regeneration time of old growth forest is explicitly outside the<br />
assessment period. The development of boreal old growth forest requires 100<br />
years or more (Schneider 2002).<br />
Reference<br />
Reference<br />
Schneider, R.R. 2002. Alternative Futures: Alberta's Boreal Forest at the<br />
Crossroads. The Federation of Alberta Naturalists. Edmonton, AB.<br />
ii. It is assumed that barred owls prefer breeding in areas with a high proportion<br />
of forest that is older than 80 years of age (Marzur et al. 1998). Forests will<br />
not exceed 80 years of age within the time frame of the assessment. As a<br />
result, the magnitude of habitat loss for barred owl is estimated to be high at<br />
closure (see EIA, Volume 5, Section 7.5.3.3, Table 7.5-37, p. 7-115).<br />
However, although a time frame of 80 years after closure was selected for the<br />
purposes of assessment, an assessment time frame only 10 years longer (i.e.,<br />
90 years) may have resulted in a net positive magnitude effect of the project<br />
on barred owl habitat. Therefore, given the few additional years beyond the<br />
assessment time frame that it would take for barred owl habitat to recover, it<br />
is unwarranted to assess the environmental consequence for barred owl<br />
habitat loss more severely than ‘low’. Such qualifying statements would not<br />
be valid for land cover types that are expected to take much longer than the<br />
assessment time frame to recover, such as peatlands.<br />
Mazur, K.M., S.D. Frith and P.C. James. 1998. Barred owl home range and<br />
habitat selection in the boreal forest of central Saskatchewan. The Auk.<br />
115(3): 746-754.<br />
Request 34c Clarify why wetlands are deemed to be irreversible when the Guideline for<br />
Wetland Establishment on Reclaimed Oil Sands Leases (2007) provides<br />
guidelines on their reclamation.<br />
Response 34c In order to ensure that the environmental impact analysis would be as<br />
conservative as possible, Shell has remained conservative in its assumptions<br />
regarding bog and fen peatlands establishment on the reclaimed landscape. Shell<br />
utilized the Draft Guideline for Wetland Establishment on Reclaimed Oil Sands<br />
Leases (released at the end of 2006) during Closure, Conservation and<br />
Reclamation planning, and will continue to use the Guideline for Wetland<br />
Establishment on Reclaimed Oil Sands Leases (CEMA 2007) for planning the<br />
establishment of other wetlands types in ongoing closure and reclamation<br />
planning. The results of peatland establishment research into reclamation<br />
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Reference<br />
planning and operations will be incorporated into closure and reclamation<br />
planning.<br />
Section 12.1<br />
Shell recognizes that research is currently underway with the Canadian Oil Sands<br />
Network for Research and Development (CONRAD) and the Wetlands and<br />
Aquatic Sub Group (WASG) of the Cumulative Environmental Management<br />
Association (CEMA) to further investigate methodologies for wetlands<br />
reconstruction on reclaimed landscapes. For example, CONRAD supports fen<br />
reclamation research that is investigating the success of vegetation island<br />
transplants. The WASG has initiated reclamation research on the processes and<br />
function of existing wetlands for practical application in the Oil Sands Region.<br />
Reclamation programs will be adaptively managed to incorporate the results and<br />
recommendations from ongoing research regarding establishment of wetlands,<br />
including peatlands, on the closure landscape.<br />
CEMA. 2007. Guideline for wetland establishment on reclaimed oil sands leases<br />
(revised edition) 2007. Prepared by Harris, M.L. for CEMA Wetlands<br />
and Aquatics Subgroup of the Reclamation Working Group, Fort<br />
McMurray, AB. Dec/07.<br />
Request 34d Clarify why peatlands are deemed irreversible given that current research is<br />
exploring their reclamation.<br />
Response 34d As discussed in the response to AENV SIR 34c, Shell has remained conservative<br />
in its assumptions regarding peatlands establishment on the reclaimed landscape<br />
in order to ensure that the environmental impact analysis would be as<br />
conservative as possible. Shell acknowledges that the results of peatland research<br />
may change the assumption that the effects on peatlands and patterned fens may<br />
be irreversible. Peatlands reclamation research is currently underway through<br />
CONRAD and CEMA as outlined in the response to AENV SIR 34c, and<br />
additionally through research groups, such as the Peatland Ecology Research<br />
Group (PERG) based at Laval University (see http://www.gret-perg.ulaval.ca/ ).<br />
Shell will incorporate the results of peatland establishment research into<br />
reclamation planning and operations.<br />
Request 34e Provide information on how Shell will incorporate progressive wetland<br />
reclamation to minimize irreversible effects on wetlands.<br />
Response 34e As previously discussed, Shell will utilize the Guideline for Wetland<br />
Establishment on Reclaimed Oil Sands Leases (CEMA 2007) for the reclamation<br />
of wetlands types within the guideline, and will incorporate the results of<br />
peatland establishment research into reclamation planning and operations.<br />
Reclamation programs will be adaptively managed to incorporate the results and<br />
recommendations from ongoing research regarding establishment of wetlands,<br />
including peatlands, on the closure landscape. All areas, including wetlands, will<br />
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Reference<br />
Section 12.1<br />
be progressively reclaimed on the landscape where mining operations have been<br />
completed.<br />
CEMA. 2007. Guideline for wetland establishment on reclaimed oil sands leases<br />
(revised edition) 2007. Prepared by Harris, M.L. for CEMA Wetlands<br />
and Aquatics Subgroup of the Reclamation Working Group, Fort<br />
McMurray, AB. Dec/07.<br />
Request 34f Provide information on how Shell will attempt to reclaim rare and special plant<br />
communities associated with wetlands.<br />
Response 34f As required by current Reclamation Criteria (ASRD 2007) and amended criteria<br />
currently in draft from Alberta Sustainable Resource Development, and operating<br />
approval conditions, Shell will provide the conditions for rare and special plant<br />
communities to establish on the reclaimed landscape, where appropriate. As<br />
presented in the EIA, Appendix 5-2, Section 2.5.1, Shell is planning to reclaim<br />
the project area to plant communities typical of the local boreal forest. As<br />
research findings present further methods to establish boreal peatlands and the<br />
rare or special plant communities associated with them, Shell will incorporate the<br />
results into reclamation planning and operations. Reclamation programs will be<br />
adaptively managed to incorporate the results and recommendations from<br />
ongoing research regarding establishment of rare and special plant communities<br />
associated with wetlands on the closure landscape.<br />
Reference<br />
Question No. 35<br />
ASRD. 2007. A guide to reclamation criteria for wellsites and associated<br />
facilities - 2007 - forested lands in the Green Area update. Edmonton,<br />
AB. April/07.<br />
Request Volume 2, SIR 389a, Page 23-10.<br />
Shell states that after closure the environmental consequences are high for<br />
wetlands (80% loss) at the local level, but are negligible at the regional level.<br />
However, there is no attempt to consider the effects of Shell’s impacts on<br />
wetlands at the regional level in the context of cumulative effects.<br />
35a Provide information of the consequence of wetland loss of Shell’s proposed<br />
development at the regional level in the context of cumulative effects.<br />
Response 35a The consequence of wetland loss at the regional level due to the Jackpine <strong>Mine</strong><br />
Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> are contained in the EIA. Taking into account<br />
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Question No. 36<br />
Section 12.1<br />
the revised estimate of the effects of hydrological drawdown on the Jackpine<br />
<strong>Mine</strong> Expansion (see the December 2009 Jackpine <strong>Mine</strong> Expansion,<br />
Supplemental Information, Volume 2, Part 4, Appendix B: Shell Jackpine <strong>Mine</strong><br />
Expansion & <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> EIA Update in the Jackpine <strong>Mine</strong> Expansion<br />
<strong>Project</strong> Update), the project applications for the Jackpine <strong>Mine</strong> Expansion and<br />
the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> predict a loss of 20,967 ha (2%) of wetlands in the RSA.<br />
The Jackpine <strong>Mine</strong> – Phase 1 predicted a loss of 3,783 ha of wetlands, which<br />
reflects a less than 1% change in the RSA.<br />
Request Volume 2, SIR 394a, Page 23-12.<br />
Shell was asked to discuss the strategies they will implement if the wetland<br />
monitoring program results show a major impact to the fen and other adjacent<br />
wetlands. Shell states that the question is not applicable to the PRM.<br />
36a Answer the SIR in the context of the PRM.<br />
Response 36a The lenticular fen is located only within the Jackpine <strong>Mine</strong> Expansion local study<br />
area (LSA); however other wetlands, including fens, bogs, swamps and marshes<br />
are located in and adjacent to the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA. These wetlands are<br />
predicted to be affected by water drawdown as a result of dewatering and mining<br />
operations in the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA. Hydrology influences the physical and<br />
chemical parameters in wetlands, which in turn influence the establishment and<br />
maintenance of wetland types and wetland processes. Given the major role of<br />
hydrology in wetlands function, changes in hydrology can affect aspects of<br />
wetland ecology, such as water chemistry, vegetation species composition and<br />
diversity (Thormann et al. 1998; Whitehouse and Bayley 2005; Locky and<br />
Bayley 2006). A water level drawdown of more than 0.1 m may negatively affect<br />
wetland structure and function.<br />
A wetlands monitoring program will be implemented to monitor wetlands<br />
vegetation during operations and after closure and reclamation. The wetlands<br />
monitoring program will expand on the Albian Sands Wetlands Monitoring<br />
Program, which has been ongoing since 2000 (Golder 2007). The main approach<br />
to assess the potential effects of the project on wetlands will be to monitor<br />
species abundance, richness, diversity and vigour according to plot distance from<br />
the mine over the length of the monitoring program. The program will include<br />
the collection of ecological field data and aerial photo interpretation. The EIA,<br />
Appendix 5-6, “Terrestrial Monitoring Programs”, Section 4, page 8, describes<br />
the general wetlands monitoring program that will be implemented to determine<br />
potential change to wetlands associated with the project.<br />
In addition, proposed monitoring of overburden dewatering is outlined in EIA,<br />
Volume 4B, Appendix 4-9, Section 2.1.4.2. Groundwater levels will be<br />
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References<br />
Question No. 37<br />
Section 12.1<br />
monitored semi-annually before mine development begins and then until the<br />
mine pit is backfilled.<br />
Should the wetlands or groundwater monitoring programs detect unexpected<br />
effects on groundwater levels as a result of overburden dewatering, a<br />
groundwater response plan (EIA, Volume 4B, Appendix 4-9, Section 2.1.5) will<br />
be developed to assess and mitigate, if necessary, the impacts of dewatering on<br />
the surrounding wetlands.<br />
Golder. 2007. Muskeg <strong>River</strong> <strong>Mine</strong>, Wetlands Monitoring Program, 2005 Annual<br />
Report. Prepared by Golder Associated Ltd. For Albian Sands Energy<br />
Inc.<br />
Locky, D.A., and S.E. Bayley. 2006. Plant Diversity, Composition, and Rarity in<br />
the Southern Boreal Peatlands of Manitoba, Canada. Canadian Journal of<br />
Botany 84:940-955.<br />
Thormann, M.N., S.E. Bayley, and A.R. Szumigalski. 1998. Effects of<br />
Hydrologic Changes on Aboveground Production and Water Chemistry<br />
in Two Boreal Peatlands in Alberta: Implications for Global Warming.<br />
Hydrobiologia 362:171-183.<br />
Whitehouse, H.E., and S.E. Bayley. 2005. Vegetational Patterns and Biodiversity<br />
of Peatland Plant Communities Surrounding Mid-boreal Wetland Ponds<br />
in Alberta, Canada. Canadian Journal of Botany 83:621-637.<br />
Request Volume 2, SIR 437a, Page 23-84.<br />
Shell states several barriers to peatland reclamation however no formal<br />
evaluation for re-establishment opportunities have been given.<br />
37a Provide formal evaluation of opportunities of these important ecosystems.<br />
Response 37a In the EIA, wetlands reclamation followed the conservative approach to<br />
peatlands reclamation based on the Guideline for Wetland Establishment on<br />
Reclaimed Oil Sands Leases (CEMA 2007). Peatlands were not shown to be<br />
reclaimed at project closure; however, it is anticipated that they will occur on the<br />
post-mining landscape in the far future scenario.<br />
Shell has evaluated the following opportunities for re-establishment of peatlands<br />
and wetlands. Examples include sites with high water table levels and a<br />
favourable hydrologic regime in the closure landscape will provide wet<br />
environments with the potential for moss establishment and peat accumulation.<br />
Such areas may develop into peatlands in the far future. For example, closure<br />
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Question No. 38<br />
Section 12.1<br />
ecosite type d1 (of the Athabasca Plains Natural Sub-region) is a transitional<br />
ecosite phase planned for the reclamation of wet landscapes. Closure ecosite type<br />
d1 is located around the margins and low-lying areas surrounding drainage<br />
channels and adjacent to littoral zones on the pit lakes. Transitional ecosite<br />
phases are included in the wet landscape category because they are poorly<br />
drained ecosite phases defined by a shallow peat layer over mineral subsoil, and<br />
are adjacent to peatlands or wetlands areas. Transitional ecosites phases are<br />
capable of supporting treed wetlands in the far future.<br />
Closure ecosite type c1 (of the Athabasca Plains Natural Sub-region) is an upland<br />
ecosite phase known to incorporate “pocket” wetlands areas, in which the gradual<br />
accumulation of peat may result in the development of numerous small, peatlands<br />
in the far future.<br />
As more is understood about the hydrological and substrate conditions required<br />
to support peatlands establishment during reclamation activities, further<br />
opportunities will warrant a formal evaluation. Results from the work currently<br />
carried out by the Canadian Oilsands Network for Research and Development<br />
(CONRAD) and the Cumulative Environmental Management Association<br />
(CEMA) Wetlands and Aquatics Sub-Group will assist in understanding these<br />
required conditions.<br />
CEMA. 2007. Guideline for wetland establishment on reclaimed oil sands leases<br />
(revised second edition). Prepared by Lorax Environmental for CEMA<br />
Wetlands and Aquatics Subgroup of the Reclamation Working Group,<br />
Fort McMurray, AB. Dec/07.<br />
Request Volume 2, SIR 455c, Page 23-120.<br />
Shell states that regional environmental consequences for all resources are<br />
predicted to be negligible or low because no significant cumulative impacts are<br />
predicted at the regional scale following closure.<br />
38a Explain why Shell does not think wetland reclamation is well understood given<br />
that CEMA has produced two guideline manuals on wetland reclamation.<br />
Response 38a Wetlands types, such as marshes and drainage channels, can be created as<br />
described in the Guideline for Wetlands Establishment on Reclaimed Oil Sands<br />
Leases. Current reclamation knowledge and experience in the region states that<br />
organic bogs and fens (peatlands) cannot be reclaimed (CEMA 2007), but<br />
research is currently underway to investigate methods for wetlands<br />
reconstruction on reclaimed landscapes.<br />
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Reference<br />
Section 12.1<br />
Shell has addressed this request in its response to all parts of AENV SIR 27 and<br />
AENV SIR 34c to 34f.<br />
CEMA. 2007. Guideline for wetland establishment on reclaimed oil sands leases<br />
(revised edition) 2007. Prepared by Harris, M.L. for CEMA Wetlands<br />
and Aquatics Subgroup of the Reclamation Working Group, Fort<br />
McMurray, AB. Dec/07.<br />
Request 38b Provide evidence that Shell is committed to wetland reclamation in closure<br />
planning and minimizing the environmental consequences of development.<br />
Provide a map with detailed wetland reclamation plans.<br />
Response 38b In the EIA, reclamation followed the conservative approach to wetlands<br />
establishment based on the Guideline for Wetland Establishment on Reclaimed<br />
Oil Sands Leases (CEMA 2007). Detailed reclamation planning is not provided<br />
in conceptual plans, however, details regarding criteria and methodology are<br />
provided in the above Guideline.<br />
Peatlands were not shown to be reclaimed at project closure. However, Shell is<br />
optimistic that ongoing research efforts will produce sufficient knowledge to<br />
create peatlands in the future.<br />
Marsh wetlands types, riparian shrublands and littoral zones were shown to be<br />
reclaimed at project closure at the conceptual level; however, it is expected that<br />
additional created wetlands will be established at the operational stage and that<br />
opportunistic wetlands will also develop on the closure landscape.<br />
Shell will present strategies for the creation of wetlands, and wet landscapes with<br />
the potential to develop into wetlands, as required by operating approval<br />
conditions. Most of the potential for wetlands development lies with the creation<br />
of suitable micro/meso landscape features at the detailed operational level.<br />
The closure areas that can be included within the wet landscape category (see<br />
Figure AENV 38-1) are poorly drained, low-lying areas:<br />
• littoral zones adjacent to open waterbodies<br />
• marsh wetlands types (MONG)<br />
• riparian shrublands surrounding drainage channels and waterbodies<br />
• reclamation transitional ecosite phase d1<br />
• depressional areas within reclamation ecosite phase c1<br />
The pit lake has been designed with littoral zones that will support wetlands<br />
species. Littoral vegetation is important for shoreline stability, nutrient cycling<br />
and providing habitat for aquatic invertebrates and cover for fish. Littoral zones<br />
will consist of marshes (MONG) and shallow open water wetlands. Littoral zones<br />
serve a different hydrological function than wetlands, but will provide unique<br />
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Section 12.1<br />
habitat for aquatic species, shorebirds and certain rare plants. The littoral zones<br />
are predicted to be sustainable into the far future.<br />
Figure AENV 38-1: Wet and Dry Surface Landscape at Closure for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
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Section 12.1<br />
Marshes will be designed according to the Guideline for Wetland Establishment<br />
on Reclaimed Oil Sands Leases (CEMA 2007) and are predicted to be sustainable<br />
features of the closure landscape.<br />
Primary drainage channels and pit lakes are designed to be permanent and<br />
sustainable into the far future. These features will be planted with a buffer of<br />
riparian shrubland species. Shallow channels with a constant, high water table<br />
have the potential to evolve from a shrubland community to a wetlands<br />
vegetation community.<br />
If a shrubland community is established in these areas, conditions may become<br />
appropriate for beaver colonization. Beavers use riparian species as a food source<br />
and for dam building. Beaver activity can result in the creation of ponds and<br />
flooded areas, which may create conditions conducive to wetlands and meadow<br />
development. Encouragement of beaver colonization may require the creation of<br />
areas of slightly better drained topography along watercourses to allow for the<br />
establishment of aspen.<br />
The transitional Labrador tea-subhygric black spruce-jack pine (d1) ecosite phase<br />
is planned for near-level areas of lower elevation or in areas adjacent to riparian<br />
shrublands. Reclamation ecosite phase d1 is designed for poorly drained areas<br />
and is characterized by development of a shallow peat layer over mineral subsoil.<br />
Transitional ecosite phases have the potential to support treed wetlands in the far<br />
future.<br />
The c1 ecosite phase at closure has potential for establishment of discontinuous<br />
wetlands. Within the natural c1 ecosite phase, as described by Beckingham and<br />
Archibald (1996), small depressional treed wetlands areas (identified as d1<br />
ecosite phase or BTNN wetlands type) occur intermittently on the landscape.<br />
Closure and reclamation landscape planning for c1 ecosite phases will include<br />
the topographic contouring to provide functional treed wetlands in the far future.<br />
Peatland restoration research has been underway since the early 1990s in Canada<br />
and, more recently, research on peatland creation in the oil sands. Favourable<br />
results will contribute to the development of best practices for oil sands peatland<br />
reconstruction. The reclaimed wet landscapes at the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will<br />
provide opportunities for wetlands development and will be integral components<br />
of the planned reclamation activities.<br />
Beckingham, J.D. and J.H. Archibald. 1996. Field Guide to Ecosites of Northern<br />
Alberta. Natural Resources Canada. Canadian Forest Service, Northwest<br />
Region, Northern Forestry Centre. Special Report 5. Edmonton, AB.<br />
CEMA. 2007. Guideline for wetland establishment on reclaimed oil sands leases<br />
(revised second edition). Prepared by Lorax Environmental for CEMA<br />
Wetlands and Aquatics Subgroup of the Reclamation Working Group,<br />
Fort McMurray, AB. Dec/07.<br />
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WATER AENV SIRS 15 – 43<br />
Question No. 39<br />
Request Volume 2, SIR 456c, Page 23-124.<br />
Section 12.1<br />
Shell is confident in its ability to reclaim the development area to self-sustaining<br />
ecosystems that will meet equivalent land capability at closure.<br />
39a Explain how the principles of equivalent land capability are consistent with the<br />
replacement of high productive and diverse wetlands (that support a wide array<br />
of plants and animals such as moose) with pit lakes.<br />
Response 39a The principle of equivalent land capability is to reclaim to land uses with an<br />
equivalent pre-disturbance capability, but is understood to mean not necessarily<br />
to the same land use, or on the same footprint. An example is peatlands where<br />
such wetlands cannot currently be reclaimed with confidence, and therefore,<br />
other land types, such as marshes, having equal or greater capability for a wide<br />
range of uses, are reclaimed.<br />
Reference<br />
Pit lakes are a necessary closure feature recognized by regulators and designed to<br />
perform water quality remediation functions. The functions of pit lakes could be<br />
considered of high value for the reclaimed landscape.<br />
Further, Shell is not claiming that pit lakes are a substitute for highly productive<br />
and diverse wetlands. Not all pre-disturbance wetlands should be considered<br />
highly productive and diverse unless there is data and a rating system to<br />
substantiate such claims. Pre-disturbance wetlands are not rated according to<br />
their individual capabilities to facilitate comparison of equivalent land capability<br />
after reclamation.<br />
Reclamation land capability is determined using the land capability classification<br />
(AENV 2006) which was designed to rate uplands for forest capability. Class 5<br />
capability includes lands with such severe limitations for successful forest<br />
potential that it is not feasible to “correct” the limitations. Thus, waterbodies (pit<br />
lakes), wetlands (marshes, shallow open waters including littoral zones) and<br />
other wet lands (shrublands) are collected together in the lowest class rating of<br />
‘5’.<br />
Table 6 (EIA, Appendix 5-2, Section 2.3.1) indicates that lakes will make up<br />
1,920 ha of the closure landscape. Areas classed as littoral zone, refer to marsh<br />
and shallow open water wetlands types and are planned to comprise 254 ha at<br />
closure. Class 5 soils will cover 1,020 ha of the closure landscape and refer<br />
specifically to shrublands (Sh2 and Sh3) prescriptions.<br />
AENV. 2006. Land Capability Classification System for Forest Ecosystems in<br />
the Oil Sands, 3rd Edition. Volume 1: Field Manual. Prepared for<br />
Alberta environment by the Cumulative Environmental Management<br />
Association. 53 pp + appendices.<br />
April 2010 Shell Canada Limited 12-59<br />
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WATER AENV SIRS 15 – 43<br />
Question No. 40<br />
Request Volume 2, SIR 474b, Page 23-166.<br />
Section 12.1<br />
Shell states that before reclamation, existing, currently-approved and disclosed<br />
mines will affect 48% of wetlands in the Muskeg <strong>River</strong> watershed.<br />
40a Explain how there is a low environmental consequence of development on<br />
regional basis given this information.<br />
Response 40a The low environmental consequence is based on the application of the<br />
assessment methodology outlined in the EIA (see EIA, Volume 5, Section 1.3).<br />
The environmental consequence of the loss of wetlands regionally is determined<br />
based on the magnitude of the loss of wetlands in the regional study area (RSA).<br />
The Muskeg <strong>River</strong> watershed represents a small proportion of the RSA used for<br />
this assessment. In addition, environmental consequence ratings are determined<br />
based on the incremental change resulting from the project (see EIA, Volume 5,<br />
Section 7.5.2, page 7-94) and planned developments (see EIA, Volume 5, Section<br />
7.6.2, page 7-142) from existing conditions, including existing oil sands<br />
developments. The response to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 2, SIR 474b reflects baseline conditions before oil sands<br />
developments and it has no bearing on environmental consequence ratings for the<br />
project. A low environmental consequence is predicted for the RSA in the<br />
Planned Development Case based on the loss of wetlands in the RSA relative to<br />
the Base Case.<br />
Request 40b Provide evidence that Shell will contribute to reclaiming the high local and<br />
regional loss of wetlands.<br />
Response 40b Refer to the responses to AENV SIRs 27, 34, 37 and 38b regarding Shell’s<br />
commitments to reclaiming wetlands on the closure landscape.<br />
Request 40c Provide detailed maps of closure plans with wetland ecosites and describe target<br />
wetland plant and animal species.<br />
Response 40c Refer to the response to AENV SIR 27 and Figure AENV 27-1 for a map of the<br />
target ecosites with wetlands. Also, refer to the response to AENV SIR 38b and<br />
Figure AENV 38-1 for a map with wet landscapes with potential to develop into<br />
peatlands in the far future. Revegetation plans and planting prescriptions for<br />
these ecosites are presented in the EIA, Volume 5, Appendix 5-2, Section 2.5.<br />
Animal species that will colonize in wetlands are described in the response to<br />
AENV SIR 27b.<br />
The conceptual closure plans outlined above are at the appropriate level of detail<br />
for the EIA and project application. More detailed reclamation plans will be<br />
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WATER AENV SIRS 15 – 43<br />
Question No. 41<br />
Section 12.1<br />
provided as required for operational purposes after project approval and will<br />
follow the applicable regulatory guidelines.<br />
Request Volume 2, SIR 342, Page 22-9.<br />
Shell indicates that fish and benthics are critical or important key indicators, and<br />
that aquatic health is assessed in relation to fish populations and other aquatic<br />
life (invertebrates, algae, aquatic plants).<br />
Subsequent to this statement, however, Shell notes that no data were or are being<br />
collected on algae and plants and that such data on algae may even be unreliable<br />
in this context. Shell states that algae and aquatic or wetland plant species are<br />
excluded as KIRs because fish and benthic invertebrates are sufficient<br />
representatives of aquatic health. Shell states that a healthy aquatic ecosystem<br />
refers to a diverse and functioning aquatic ecosystem, which is typically reflected<br />
by a healthy fish community.<br />
41a Clarify if an important key indicator is, in fact, algae, and if so, what direct or<br />
indirect measures of algae are appropriate for indicator tracking and<br />
measurement purposes.<br />
Response 41a Algae is not being considered as a key indicator resource (KIR) for fish and fish<br />
habitat for the purpose of assessing project-related effects on fish and fish<br />
habitat. See the response to AENV SIR 41b for the rationale of not including<br />
algae as a KIR.<br />
Request 41b Provide a rationale for excluding algae and aquatic plant species when they are<br />
important components of fish and benthic invertebrate habitat and form the basis<br />
of the food chain for a healthy aquatic ecosystem.<br />
Response 41b The rationale for selection of key indicator resources (KIRs) for Fish and Fish<br />
Habitat, as described in EIA, Volume 4, Section 6.7.2.4, considered previously<br />
established KIRs for oil sands EIAs and recommendations of regulatory agencies<br />
and stakeholders. The KIRs for the fish and fish habitat component are key fish<br />
species or guilds, benthic invertebrate populations and their respective habitats.<br />
The selected KIRs were considered to be suitable as sentinel species for the<br />
aquatic ecosystem. Algae were not specifically included as KIRs since benthic<br />
invertebrates were selected as representative of the lower trophic levels and are<br />
generally considered a better indicator of changes to fish habitat than algae, as<br />
described in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 2, SIR 342.<br />
April 2010 Shell Canada Limited 12-61<br />
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WATER AENV SIRS 15 – 43<br />
Reference<br />
Section 12.1<br />
Aquatic plants and algae are recognized as important features of the aquatic<br />
ecosystem, and as such, have been proposed as components of the conceptual<br />
monitoring plan for lakes (see EIA, Volume 4B, Aquatic Resources Appendices,<br />
Appendix 4-9, Section 5.2.5.1 and Section 5.2.5.2). For stream monitoring, the<br />
presence of submergent vegetation and percent of instream cover are common<br />
variables used for habitat suitability index (HSI) models for most species present<br />
within the project area and have been included in the Jackpine <strong>Mine</strong> – Phase 1<br />
monitoring program to support the validation of the HSI models. However, in the<br />
typical stream habitat in the project area, the scientific literature indicates that<br />
allochthonous organic carbon inputs from riparian vegetation and bogs is the<br />
largest component of the organic matter inputs and strongly affects the character<br />
of the heterotrophic food chain. For example, Jonsson et al. (2006) found that<br />
aquatic primary production was an insignificant input of organic carbon relative<br />
to terrestrial organic carbon in the aquatic environment in boreal forest in<br />
Sweden. The use of algae and aquatic plants as a separate KIR (outside of the<br />
consideration of fish habitat) for the purpose of completing the EIA was not<br />
considered necessary for assessing project-related effects on fish and fish habitat.<br />
Further details on monitoring aquatic plants will be developed in consultation<br />
with regulators and stakeholders in the development of the detailed NNLP<br />
compensation monitoring program.<br />
Jonsson, A., G. Algesten, A.-K. Bergstrom, K Bishop, S. Sobek, L.J. Tranvik and<br />
M. Jansson. 2006, Integrating aquatic carbon fluxes in a boreal<br />
catchment carbon budget. J Hydrology 334:141-150.<br />
Request 41c Provide a list of appropriate KIR’s for non-fish bearing shallow lakes and<br />
wetlands including plant and animal species.<br />
Response 41c Wetlands, such as bogs, fens and marshes, were assessed as part of the Terrestrial<br />
Resources Assessment (EIA, Volume 5, Section 7.5.1, 7.5.2 and 7.5.3). The key<br />
indicator resource (KIR) selection process for terrestrial resources is described in<br />
the EIA, Volume 5, Section 7.6.7.2; this assessment considers wetlands,<br />
vegetation and wildlife resources. Wetland KIRs include peatlands (fens and<br />
bogs), patterned fens, rare and special plant communities (i.e., lenticular<br />
patterned fen) and riparian communities, as they are associated with wetlands in<br />
many cases. Wildlife KIRs associated with wetlands include Canadian toad,<br />
yellow rail and beaver. The KIRs for shallow, non-fish bearing lakes would<br />
include benthic invertebrates and their habitat.<br />
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WATER AENV SIRS 15 – 43<br />
Question No. 42<br />
Request Volume 2, SIR 359, Page 22-25.<br />
Section 12.1<br />
Shell states that fall monitoring of fish is preferred based on results from<br />
Jackpine <strong>Mine</strong> Phase-1 monitoring. Spring spawning species are indirectly<br />
accounted for via presence of fry found in the fall sampling.<br />
42a Clarify how this sampling method will be inclusive to species that seasonally<br />
utilize but may not spawn in the sampling location.<br />
Response 42a The proposed fall monitoring program corresponds to the period between mid-<br />
August to mid-September (i.e., late summer and early fall) and was selected<br />
based on results from the Jackpine <strong>Mine</strong> – Phase 1 monitoring program. This<br />
period was selected as it avoids the migration to winter habitat while still<br />
capturing fish under optimal sampling conditions and at the peak of the annual<br />
population and biomass cycle.<br />
In addition to the fall monitoring program, fish presence data will also be<br />
obtained through spring fish passage monitoring that will be conducted in areas<br />
where fish passage would be affected by the project (see EIA, Volume 4B,<br />
Appendix 4-9, Section 5.2.5.4, page 63). Any species that might seasonally<br />
utilize habitats without spawning would be detected through the fish passage<br />
monitoring at these locations. As is occurring with current monitoring programs<br />
conducted by Shell, the monitoring program will be reviewed annually by Shell,<br />
DFO, SRD and stakeholders and adjusted where necessary based on the results<br />
from previous years.<br />
Request 42b Describe how this sampling method will account for juveniles that do not remain<br />
in the same habitat or location of their hatch.<br />
Response 42b Although juvenile fish often use different habitat from spawning habitat, that<br />
habitat use is addressed in the monitoring program through the sampling of all<br />
mesohabitat types within multiple stream reaches throughout the study area.<br />
Most of the fish living in the affected streams are habitat generalists and are<br />
usually found at some density in all habitats.<br />
Question No. 43<br />
Request Volume 2, SIR 361, Page 22- 27.<br />
Shell indicates that additional sampling methods will be used to assess fish<br />
abundance and diversity in the deeper water of beaver dams and compensation<br />
lake habitats.<br />
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WATER AENV SIRS 15 – 43<br />
Section 12.1<br />
43a Describe Shell’s sampling protocol, detailing when specific sampling techniques<br />
will be used.<br />
Response 43a The monitoring program will follow the protocols outlined in Shell’s strategy for<br />
compensation habitat monitoring currently under review by regulatory agencies<br />
and stakeholders (Hatfield 2009). The specific details of the monitoring program<br />
will be based initially on the Jackpine <strong>Mine</strong> – Phase 1 monitoring program,<br />
which has undergone several years of review with regulatory agencies to refine<br />
the program. Fish abundance will be assessed using multiple-pass electrofishing<br />
in stream habitats and mark-recapture studies will be used for deeper habitats.<br />
Specific locations of sampling for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will be developed before<br />
the monitoring program is implemented in consultation with regulators and<br />
stakeholders and will be dependent on site-specific conditions at the time of<br />
sampling.<br />
Reference<br />
Hatfield (Hatfield Consultants). 2009. Evaluating aquatic habitat loss and<br />
compensation offsets in the Athabasca oil sands. Prepared for Shell<br />
Canada Energy. Calgary, AB. December 2009.<br />
Request 43b Clarify how trend data will be comparable year-to-year if sampling techniques<br />
and effort are not constant.<br />
Response 43b A strategy has been developed to provide consistency in sampling for Shell’s<br />
monitoring programs (Hatfield 2009). Habitat conditions may change from year<br />
to year because of differences in flow condition or beaver activity, for example,<br />
which may warrant changing the sampling approach to match the conditions<br />
present. Fish abundance will be determined using either multiple-pass removal<br />
electrofishing when conditions are suitable or mark-recapture studies. The<br />
estimates of fish abundance will provide the trend information and habitat use<br />
assessment required for Alberta Environment and Fisheries and Oceans Canada<br />
monitoring. The physical habitat parameters measured seasonally each year<br />
(Hatfield 2009) will also help interpret differences that may be observed in the<br />
data amongst years.<br />
Reference<br />
Hatfield (Hatfield Consultants). 2009. Evaluating aquatic habitat loss and<br />
compensation offsets in the Athabasca oil sands. Prepared for Shell<br />
Canada Energy. Calgary, AB. December 2009.<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 3: AENV SIRS – ROUND 2<br />
Question No. 44<br />
Request Volume 1, SIR 379b, Page 14-22.<br />
TERRESTRIAL<br />
AENV SIRS 44 – 78<br />
Section 13.1<br />
In the EIA Volume 5, Appendix 5-2, Section 1.6, Page 18, Shell states that<br />
reconstructed soil performance will mimic natural soils over time. In the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> SIR Response, Shell references personal communication with L.<br />
Leskiw in July 2008, discussing the development of an incipient LF horizon on<br />
some of Suncor’s older upland reclamation areas and juvenile profile<br />
development (LF horizons and discontinuous Ae horizons) on direct placement<br />
reclamation areas at Syncrude.<br />
44a How old are the reclamation areas at Suncor and Syncrude where the juvenile<br />
profile development described above was found?<br />
Response 44a The reclamation areas discussed in the personal communication were between 20<br />
and 30 years old.<br />
Request 44b What is the Land Capability Class for each of the juvenile profiles described<br />
above?<br />
Response 44b The land capability class was not discussed in the personal communication of<br />
July 2008. The research referred to in this personal communication is the<br />
Nutrient Biogeochemistry II project currently being conducted through<br />
CONRAD. The results of this study are not available for public disclosure.<br />
Request 44c What was the reconstructed profile of the juvenile soils described above?<br />
Response 44c The reconstructed profile was not discussed in the personal communication of<br />
July 2008. The research referred to in this personal communication is the<br />
Nutrient Biogeochemistry II project currently being conducted through<br />
CONRAD. The results of this study are not available for public disclosure.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Request 44d How do they compare to the reconstructed profiles described in the Closure,<br />
Conservation, and Reclamation Plan for the <strong>Pierre</strong> <strong>River</strong> Mining Area (EIA<br />
Volume 5, Appendix 5-2, Section 2.4.5, Page 61, and Figure 10, Page 63)?<br />
Response 44d Since the reconstructed profiles were not discussed in the personal<br />
communication of July 2008, Shell cannot compare the profiles in Figure 10 of<br />
the EIA. The research referred to in this personal communication is the Nutrient<br />
Biogeochemistry II project currently being conducted through CONRAD. The<br />
results of this study are not available for public disclosure.<br />
Request 44e Based on the age and Land Capability Class of these juvenile profiles and a<br />
comparison of reconstructed profiles, discuss Shell’s assumptions and knowledge<br />
that equivalent capability will be achieved within the 80 year timeframe<br />
discussed in the original EIA, using the reconstruction profiles proposed in the<br />
Closure, Conservation, and Reclamation Plan for the <strong>Pierre</strong> <strong>River</strong> Mining Area.<br />
Response 44e Considering the degree of profile development on direct placement, peat-mineral<br />
mix areas after only 20 to 30 years, it is reasonable to expect that soil profile<br />
development will continue to evolve to a soil profile typical of the region. Shell<br />
expects that equivalent land capability will be achieved for similar profiles within<br />
the 80-year time frame, as discussed in the EIA, as well as incorporating<br />
advances in soil salvage and handling approaches through adaptive management.<br />
Question No. 45<br />
Request Volume 2, SIR 415, Page 21-31.<br />
This question was asked in the list of SIR 1 questions, but the reference provided<br />
(Shell EIA Update Report, Appendix II, Section 2.4.1 and 2.4.2, Table 20 and 21)<br />
was for the Jackpine <strong>Mine</strong> Expansion only. Shell states that they will answer the<br />
question in the Jackpine <strong>Mine</strong> Expansion <strong>Project</strong> Supplemental Information, but<br />
the question is applicable to both the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and Jackpine Expansion<br />
<strong>Mine</strong> areas and, as such, requires an answer for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong> as<br />
well. The <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> reference is: Volume 5, Appendix 5-2, Section 2.4.1<br />
and 2.4.2, Table10 and 11. Tables 10 and 11 outline the criteria to be used for<br />
determining the suitability of salvageable upland surface soils and subsoil for<br />
reclamation purposes, but it is unclear how Shell will be applying these ratings<br />
to additional data collected during soil salvage operations, or if they will be<br />
relying on the data collected during the Soil and Terrain ESR.<br />
45a Provide a response to SIR 415 in regards to <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>.<br />
Response 45a Professional agrologists and pedologists from Paragon Consulting Ltd. and Shell<br />
Albian Sands carry out monitoring programs to sample soil quality for<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Reference<br />
Section 13.1<br />
reclamation salvage programs. Reclamation suitability ratings are correlated to<br />
the soil and terrain mapping by the monitoring personnel and implemented<br />
during the direction of soil salvage operations. Operational scale assessments of<br />
reclamation suitability are confirmed using soil classification (soil series) and<br />
texture as guiding principles.<br />
As described in the response to the December 2009 Jackpine <strong>Mine</strong> Expansion,<br />
Supplemental Information, Volume 2, SIR 383a, soil salvage planning includes<br />
soil test pitting sample collection and lab analysis (in addition to field tests for<br />
calcareous materials, texture and pH) during the 100 m by 100 m test pitting<br />
process carried out one year ahead of salvage activities. The test pits are typically<br />
up to 2.5 m deep in peat areas and 1.5 m deep in upland areas. Lab analyses of<br />
soil samples help to determine surface soil and subsoil reclamation suitability<br />
using the Soil Quality Criteria Relative to Disturbance and Reclamation –<br />
Revised (Alberta Agriculture 1987). Results of the field and lab analyses are<br />
reviewed and integrated into salvage planning for the subsequent year to ensure<br />
that soil quality assessments are proactive and consistent.<br />
Alberta Agriculture. 1987. Soil Quality Criteria Relative to Disturbance and<br />
Reclamation – Revised. Prepared by the Soil Quality Working Group for<br />
Alberta Agriculture. Edmonton, AB.<br />
Request 45b Describe the field methods that will be used to identify surface and subsoil<br />
reclamation suitability during soil salvage operations, including any sampling<br />
and analysis programs that may be used.<br />
Response 45b See the response to AENV SIR 45a.<br />
Question No. 46<br />
Request Volume 2, SIR 422a-b, Page 23-41.<br />
Shell indicates that they have not studied the areas associated with diversion<br />
channels C6 and C11 as part of the EIA. Shell also states that their size is such<br />
that they will not materially affect the results of the EIA.<br />
46a Confirm that there are no other areas outside of the LSA that have not been<br />
studied (e.g., diversion channel C4).<br />
Response 46a Portions of drainage channels C4, C6 and C11 (see EIA, Volume 5, Appendix 5-<br />
2, Figure 4) are outside of the terrestrial resources local study area. The total area<br />
associated with these portions, including the channel, assumed construction areas<br />
and dykes, is 599 ha.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Request 46b Confirm why the EIA is complete and acceptable without the inclusion of data<br />
and information in the C6 and C11 areas, and any other areas that may have<br />
been identified in part a).<br />
Response 46b The EIA is considered complete because the disturbance related to these portions<br />
of drainage channels C4, C6 and C11 were assessed as part of the regional<br />
assessment study area of the project, and they are a small portion (less than 3%)<br />
of the area of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> local study area. Given this small percentage,<br />
Shell considered whether the exclusion of these portions of the drainage channels<br />
would affect the results of the EIA prior to submission and concluded that their<br />
exclusion will not materially affect the environmental consequences determined<br />
for the EIA.<br />
Request 46c Confirm that the areas in question are for a diversion channel.<br />
i. If so then does this require a Water Act approval?<br />
ii. If an approval is required then what studies will Shell undertake to gain such<br />
approval?<br />
Response 46c i. The areas outside of the local study area (LSA) are associated with closure<br />
drainage channels. These channels will be constructed a few years prior to<br />
2049. The Water Act approval for these channels is being sought as part of<br />
this application.<br />
Question No. 47<br />
ii. Shell will conduct soil and vegetation field surveys in the areas associated<br />
with drainage channels outside of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> terrestrial resources<br />
local study area prior to construction of these portions of the drainage<br />
channels. Findings from these surveys will be discussed with Alberta<br />
Environment and Alberta Sustainable Resource Development prior to<br />
construction in these areas.<br />
Request Volume 2, SIR 426a, Page 23-50; Page 23-64, Table 426-7.<br />
Shell states that Table 426-7 replaces Table 2.4-5 in the ESR. A comparison of<br />
the original and the revised tables indicates that the area of disturbed land and<br />
the area of water within the Jackpine <strong>Mine</strong> Expansion LSA have been reversed,<br />
resulting in a significant increase in the amount of surface water within the<br />
development area.<br />
47a Confirm that this reversal is an accurate reflection of the pre-disturbance<br />
conditions in the LSA.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Response 47a This reversal is not an accurate reflection of the pre-disturbance conditions in the<br />
local study area (LSA). The baseline disturbed areas in the LSA on Table 426-7<br />
should read 1,709 ha and the baseline open water areas in the LSA should read<br />
102 ha.<br />
Request 47b If the reversal is accurate, provide the appropriate updates to the EIA, ESR, and<br />
Closure, Conservation, and Reclamation plan.<br />
Response 47b As discussed in AENV SIR 47a, the reversal is not accurate and therefore the<br />
EIA, Environmental Setting Report (ESR), and Closure, Conservation and<br />
Reclamation Plan used the appropriate values for water and disturbance area<br />
estimates. There are no additional updates required because of the reversal of the<br />
water and disturbance values.<br />
Question No. 48<br />
Request Volume 1, Section 7, Table 11-2, Page 7-49 ; EIA Volume 5, Section 7, Page 7-<br />
112 ; EIA Volume 5, Appendix 5-4, Section 1.2.3, Page 14-24.<br />
In the Errors and Omissions section of the <strong>Project</strong> Update Volume 1, Shell<br />
indicates in Table 11-2, Page 7-49 that there will be no indirect habitat loss for<br />
moose, lynx, fisher/marten, black-throated green warbler, barred owl or beaver<br />
due to the project. Yet in the EIA, Volume 5, Appendix 5-4 Page 14, Shell<br />
explains that ‘Distance to nearest road’ was found to contribute negatively (-) to<br />
the most strongly supported RSF model for moose and ‘Distance to nearest edge<br />
C’ was a contributing negative factor in the most strongly supported model for<br />
fisher/marten.<br />
48a Given that these disturbance factors were found to be important in the RSF’s for<br />
moose and fisher/marten, explain how the indirect habitat loss could be zero for<br />
these species.<br />
Response 48a Resource Selection Functions (RSFs) are multivariate statistical equations that<br />
were developed to quantify habitat quality for some key indicator resources<br />
(KIRs) like moose and fisher/marten. RSFs for moose and fisher/marten<br />
incorporate the effects of disturbance features as variables that affect habitat<br />
quality as the reviewer indicates in the preamble to this question. However, the<br />
effects of individual variables on model output in multivariate statistical models<br />
like RSFs cannot be easily separated and quantified. Therefore, for moose and<br />
fisher/marten, both direct and indirect effects of the project are included in the<br />
column “Direct Habitat Change” in Table 11-2, page 7-49 of the May 2009<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section 7, Errors and<br />
Omissions. Nonetheless, the effects of proximity to disturbance are implicit in<br />
predictions of relative habitat quality for moose and fisher/marten, and affect<br />
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final model output. Indirect habitat loss is not zero for moose or fisher/marten<br />
because it has been taken into consideration with direct habitat change.<br />
The table structure used in the EIA and the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information was based on habitat suitability modelling output from<br />
Habitat Suitability Index (HSI) models in which direct and indirect effects were<br />
determined separately. This structure was not changed when some of the KIRs<br />
were modelled used RSFs. In those cases, a zero was placed in the “Indirect<br />
Habitat Change” column of the tables to reflect that indirect habitat loss could<br />
not be quantified separately.<br />
Request 48b What evidence does Shell have that indicates sensory disturbance will not lead to<br />
indirect habitat loss for moose, lynx, fisher/marten, black-throated green<br />
warbler, barred owl or beaver?<br />
Response 48b Indirect habitat loss through sensory disturbance was considered to affect all key<br />
indicator resources (KIRs) except for Canadian toads and beavers (see EIA,<br />
Volume 5, Section 7.5.3.2, p.7-112). Beavers are highly adaptable animals that<br />
live in close association with humans, provided that requirements for food and<br />
aquatic habitat are met (Nietfeld et al. 1984), suggesting that they are not<br />
sensitive to noise and other disturbances (see EIA, Volume 5, Section 7.5.3.2,<br />
page 7-112). Indirect habitat loss through sensory disturbance was considered to<br />
affect moose, Canada lynx, fisher/marten, black-throated green warbler and<br />
barred owl (see EIA, Volume 5, Section 7.5.3.2, page 7-112). However,<br />
quantified estimates of habitat loss for these species were produced using<br />
resource selection functions (RSFs). The RSFs incorporate the effects of<br />
disturbance features as variables in complex multivariate statistical equations.<br />
The effects of individual variables on model output in multivariate statistical<br />
models cannot be easily separated and quantified. Assessed effects of the project<br />
on indirect habitat loss incorporate both habitat suitability model output, as well<br />
as professional judgment.<br />
Reference<br />
Question No. 49<br />
Nietfeld, M., J. Wilk, K. Woolnough and B. Hoskin. 1984. Wildlife Habitat<br />
Requirement Summaries for Selected Wildlife Species in Alberta.<br />
Alberta Energy and Natural Resources, Fish and Wildlife Division,<br />
Wildlife Resource Inventory Unit.<br />
Request Volume 1, SIR 310a-c, Page 13-1 ; Volume 2, SIR 458d i, Page 23-137.<br />
Shell’s response to this question states Shell indicates that the current data<br />
suggest that genetic connectivity will be maintained. However, current research<br />
has not been designed to prove genetic connectivity nor are the data sufficiently<br />
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(statistically) robust to prove that genetic connectivity has been maintained …<br />
involves establishing not only movement from one location to another; but, also<br />
the survival and reproduction of migrants. Direct studies of survival and<br />
reproduction have not been conducted for wildlife in the Oil Sands Region. Yet,<br />
in a number of responses to other SIRs, Shell continues to indicate genetic<br />
connectivity will be maintained:<br />
- Volume 1. Section 13.1 Page 13-1 Question 310a and b. (ERCB)<br />
- Volume 1. Page 14-8 Question 371b (ERCB)<br />
- Volume 2. Page 23-2 Question 383a<br />
- Volume 2. Page 23-105 Question 449d<br />
- Volume 2. Page 23-181 Question 481b<br />
49a Shell acknowledges there is no evidence to support the assertion that genetic<br />
connectivity will be maintained, yet in contradiction to this, Shell asserts they<br />
will maintain genetic connectivity in several other SIR responses noted above.<br />
Clarify this apparent contradiction and revise the responses noted above as<br />
applicable.<br />
Response 49a Shell intended to highlight observations from current external research (Mills and<br />
Allendorf 1996; Wang 2004) suggesting the possibility for maintenance of<br />
genetic connectivity as opposed to asserting that genetic connectivity will be<br />
maintained. Responses noted above are revised as appropriate below.<br />
Volume 1. Section 13.1 Page 13-1 SIR 310a (ERCB)<br />
Previous Request 310a What studies have been done to determine that a<br />
setback of 250 m from the Athabasca <strong>River</strong> will be appropriate for habitat<br />
protection and will provide a suitable wildlife corridor?<br />
Revised Response 310a<br />
Wildlife corridor monitoring has been carried out in and around the Muskeg and<br />
Athabasca rivers, specifically to provide information on wildlife abundance and<br />
distribution in potential corridor areas, as documented in EIA, Volume 5,<br />
Section 7.5.4. Results from monitoring programs carried out as part of the<br />
Terrestrial Environmental Setting Report for the Jackpine <strong>Mine</strong> Expansion and<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong> (Golder 2007a) and the Jackpine <strong>Mine</strong> – Phase 1<br />
Wildlife Corridor Monitoring Program (Golder 2007b) have shown that many<br />
species use the riparian and upland areas adjacent to rivers, which suggests that<br />
genetic connectivity will likely be maintained for wildlife populations if corridors<br />
are provided along the Athabasca <strong>River</strong> system adjacent to the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
<strong>Project</strong>.<br />
Volume 1. Section 13.1 Page 13-1 SIR 310b (ERCB)<br />
Previous Request 310b What criteria did Shell apply to select 250 m as an<br />
appropriate setback from the high water line on the western shore of the<br />
Athabasca <strong>River</strong>?<br />
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Revised Response 310b<br />
Section 13.1<br />
A setback of 250 m along the western shore of the Athabasca <strong>River</strong> was selected<br />
on the basis of monitoring results from the Jackpine <strong>Mine</strong> – Phase 1 Wildlife<br />
Corridor Monitoring Program (Golder 2007b) and the Terrestrial Environmental<br />
Setting Report for the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong><br />
(Golder 2007a) in addition to information from corridor monitoring programs<br />
conducted in the area, e.g., Canadian Natural Resources Ltd.’s Horizon Oil Sands<br />
<strong>Project</strong>. Monitoring results have shown that most species are present in the<br />
existing Jackpine <strong>Mine</strong> – Phase 1 wildlife corridor areas and, therefore, suggest<br />
that the criterion of genetic connectivity for populations within the regional study<br />
area will likely be met. That is, a minimum of one and up to 10 effective<br />
migrants per generation of all wildlife species are likely to pass through wildlife<br />
corridors, and thus genetic connectivity is predicted to be maintained (Mills and<br />
Allendorf 1996; Wang 2004).<br />
Volume 1. Section 14.1 Page 14-8 SIR 371b (ERCB)<br />
Previous Request 371b What are the sensory affects of light and traffic on<br />
wildlife usage of the underpass?<br />
Revised Response 371b<br />
The effects of the bridge were considered in the assessment of wildlife<br />
movement. The sensory effects are considered an indirect disturbance to wildlife<br />
using the passageways under the bridge. The magnitude of the effect will be<br />
determined by such factors as the:<br />
• type of lighting used on the bridge<br />
• characteristics of the traffic using the bridge<br />
Noise levels generated by traffic will be affected by the speed, size and frequency<br />
of traffic over the bridge. Effects, such as noise, light and smell, are factors<br />
affecting habitat effectiveness. The wildlife passageway was regarded as a zone<br />
of influence (ZOI) with a disturbance coefficient (DC) of less than one. A<br />
disturbance coefficient of 1 (DC = 1) applies when there are no hindrances to<br />
movement, whereas a DC of zero reflects a complete barrier to movement. In this<br />
case, wildlife are predicted to use the passageway under the cover of darkness or<br />
during periods of lower traffic volume. If wildlife use the passageway as<br />
predicted, genetic connectivity is likely to be maintained throughout the region<br />
(Mills and Allendorf 1996; Wang 2004) as outlined in the EIA, Volume 5,<br />
Section 7.1.2.<br />
Volume 2. Section 23.1 Page 23-2 SIR 383a<br />
Previous Request 383a The CNRL requirement is 400 m. Has Shell<br />
completed a contingency plan if the requirement for this mine will be 400 m as<br />
well?<br />
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Revised Response 383a<br />
Section 13.1<br />
In developing the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Plan, Shell balanced the need to minimize<br />
impacts to the Athabasca <strong>River</strong> wildlife corridor with the obligation to maximize<br />
the recovery of bitumen resource for the province and its shareholders.<br />
Consistent with Shell’s EIA, Shell believes that the 250-m setback provides this<br />
balance, and is sufficient to allow the movement of wildlife along the Athabasca<br />
<strong>River</strong> corridor. The corridor is predicted to maintain genetic connectivity because<br />
a minimum of one and up to 10 effective migrants per generation of all wildlife<br />
species (Mills and Allendorf 1996; Wang 2004) are likely to travel through.<br />
Accordingly, Shell currently has no contingency plans to reflect a 400-m setback.<br />
Volume 2. Section 23.1 Page 23-105 SIR 449d<br />
Previous Request 449d Shell indicates it will provide for wildlife passage<br />
under the Athabasca <strong>River</strong> bridge on both the east and west banks of the river.<br />
i. Discuss wildlife movement criteria included in the design specifications for<br />
the proposed Athabasca <strong>River</strong> bridge.<br />
Revised Response 449d<br />
i. Preliminary work has been completed on the design of the wildlife<br />
passageways under the Athabasca <strong>River</strong> Bridge on both sides of the river. In<br />
its current location, the bridge height will exceed 2.5 m (current plans exceed<br />
10 m), and although the width of the wildlife passageway under the bridge<br />
will vary seasonally, it will exceed 10 m throughout the year because the<br />
escarpment is higher than the river at the current location and the bridge will<br />
be built from escarpment to escarpment. Because of the width of the road<br />
surface on the bridge and height above the passageway, the wildlife<br />
passageway will be open and well-lit. Passageway landscaping will be<br />
conducive to wildlife travel for a variety of species.<br />
Detailed engineering specifications are considered part of activities planned<br />
following project approval. EIA, Volume 5, Appendix 5-5, Section 4, page 7<br />
describes the approach that will be used. The design of the bridge spanning<br />
the Athabasca <strong>River</strong>, connecting Highway 63 with PRMA, will be high and<br />
long to provide for wildlife passage under the bridge on both the east and<br />
west banks (Figure 1). Long bridges allow for connectivity at the landscape<br />
level for a wide array of species, and are among the most effective mitigation<br />
measures for reducing road kill and for allowing for unhindered animal<br />
movement (Huijser et al. 2007). The cited figure depicts a conceptual model<br />
of the proposed bridge (see EIA, Volume 5, Appendix 5-5, Section 4, page<br />
8). This design is expected to meet the wildlife movement criteria likely to<br />
provide genetic connectivity (Mills and Allendorf 1996; Wang 2004) as<br />
outlined in the EIA, Volume 5, Section 7.1.2.<br />
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References<br />
Volume 2. Section 23.1 Page 23-181 SIR 481b<br />
Section 13.1<br />
Previous Request 481b Discuss features of the JEMA and PRMA<br />
development plan that might ensure maintenance of dispersal pathways from<br />
source populations.<br />
Revised Response 481b<br />
The retention of remnant corridors along rivers will contribute to the<br />
maintenance of dispersal pathways from source populations. As stated in the<br />
response to SIR 481a, the two wildlife movement corridors currently within the<br />
project area to maintain dispersal pathways are the Muskeg <strong>River</strong> and the<br />
Athabasca <strong>River</strong>. Regional developments along the Muskeg <strong>River</strong>, including the<br />
Jackpine <strong>Mine</strong> Expansion area, will create and maintain a 20-km-long remnant<br />
corridor about 400 m wide along the Muskeg <strong>River</strong> from the Athabasca <strong>River</strong> to<br />
Fort Hills. A 250 m buffer will be maintained along the Athabasca <strong>River</strong>. This<br />
buffer has also been committed to by Canadian Natural Resources Limited (see<br />
EIA, Volume 5, Section 7.1.2, page 7-7).<br />
These corridors are expected to function effectively as movement corridors<br />
because monitoring along the Muskeg <strong>River</strong> has demonstrated that many species<br />
use the riparian areas and upland areas adjacent to rivers, i.e., the Athabasca<br />
<strong>River</strong>, Muskeg <strong>River</strong> and Jackpine Creek. Wary, wide-ranging species, including<br />
Canada lynx, wolves, black bears, fishers and martens, were recorded within the<br />
corridors adjacent to developments. These preliminary monitoring results show<br />
that most wildlife species have been documented using habitat within the existing<br />
corridors along the Muskeg and Athabasca rivers. Therefore, these corridors are<br />
likely to act as dispersal pathways. These results suggest that genetic connectivity<br />
for most species of wildlife can be maintained within the regional landscape.<br />
That is, a minimum of one and up to 10 effective migrants per generation of all<br />
wildlife species are likely to pass through the wildlife corridors, and thus genetic<br />
connectivity is likely to be maintained (Mills and Allendorf 1996 and Wang<br />
2004). This information was presented in EIA, Volume 5, Section 7.1.2.<br />
Golder Associates Ltd. (Golder). 2007a. Terrestrial Environmental Setting<br />
Report for the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>.<br />
Prepared for Shell Canada Limited. Calgary, AB. Submitted December<br />
2007.<br />
Golder. 2007b. Jackpine <strong>Mine</strong> – Phase 1 Wildlife Corridor Monitoring Program:<br />
Year 1 Annual Report 2006. Prepared for Shell Canada Limited.<br />
Calgary, AB.<br />
Huijser, M.P., A. Kociolek, P. McGowen, A. Hardy, A.P. Clevenger and R.<br />
Ament. 2007. Wildlife-vehicle collision and crossing mitigation<br />
measures: A toolbox for the Montana Department of Transportation.<br />
Final report. Prepared for the State of Montana, Department of<br />
Transportation FHWA/MT-07-002/8117-34. Prepared for Western<br />
Transportation Institute, Montana State University – Bozeman.<br />
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Section 13.1<br />
Mills, L.S. and F.W. Allendorf. 1996. The One-Migrant-per-Generation Rule in<br />
Conservation and Management. Conservation Biology. 10(6): 1509-<br />
1518.<br />
Wang, J. 2004. Application of the One-Migrant-per-Generation Rule to<br />
Conservation and Management. Conservation Biology. 18(2): 332-343.<br />
Request 49b Regarding the Athabasca <strong>River</strong> setback and connectivity, Shell indicates that<br />
genetic connectivity will be maintained for wildlife populations.<br />
i. What species were considered in the determination that genetic connectivity<br />
will be maintained?<br />
ii. How did Shell determine that genetic connectivity would be maintained?<br />
Response 49b i. See the response to AENV SIR 49a for revisions to responses to previous<br />
SIRs 310a, 310b, 371b, 383a, 449d, and 481b.<br />
ii. See the response to AENV SIR 49a for revisions to responses to previous<br />
SIRs 310a, 310b, 371b, 383a, 449d, and 481b.<br />
Request 49c In response to the SIR asking what further assessments Shell will do to<br />
demonstrate 250 metres is an appropriate setback, Shell indicates it will monitor,<br />
and that the results of these monitoring programs will be used in adaptive<br />
management.<br />
i. What adaptive management strategies will Shell employ once the corridor<br />
has been reduced to 250 metres?<br />
Response 49c i. Once the corridor has been reduced to 250 m, if results of the ongoing<br />
wildlife corridor monitoring program indicate that wildlife are not using the<br />
corridor effectively, these results will be used to adaptively manage and help<br />
determine appropriate strategies to increase the functionality of the corridor<br />
for selected target wildlife species (e.g., wide-ranging mammals and/or<br />
species of concern as identified in the General Status of Alberta Wild Species<br />
[ASRD 2006]). Examples of such strategies could include, but are not limited<br />
to:<br />
• establishing food plants if monitoring suggests inadequate forage in the<br />
corridor<br />
• establishing cover and shelter elements (i.e., shrubs, coarse woody<br />
debris, brush and rock piles) if monitoring suggests inadequate cover or<br />
shelter in the corridor<br />
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Reference<br />
Question No. 50<br />
• implementing a weed control system if monitoring suggests weed<br />
competition with native food or cover vegetation is an issue in the<br />
corridor<br />
• building a sound attenuation wall if monitoring suggests sensory<br />
disturbance is an issue in the corridor<br />
Section 13.1<br />
ASRD (Alberta Sustainable Resource Development). 2006. The General Status<br />
of Alberta Wild Species 2005. Alberta Sustainable Resource<br />
Development. Fish and Wildlife Service. Edmonton, AB.<br />
Request Volume 1, SIR 372, Page 14-9.<br />
The SIR references the April 1 to August 30 time period. Shell indicates that preclearing<br />
migratory bird nest sweeps will be conducted to mark any nests within<br />
areas to be cleared. Areas are walked by a wildlife biologist to search for nests<br />
(stick, mud, ground, or cavity). Breeding bird behaviours are also noted and<br />
recorded.<br />
50a How does this mitigate for the owl nesting period which can begin in early<br />
March. Discuss the efficacy of locating owl nests by ‘walk through’.<br />
Response 50a Mitigation measures will not be required for owl nests. Owl nest sweeps are<br />
typically not done during the owl nesting period in early March. The Migratory<br />
Birds Convention Act (MBCA) prohibits “the damaging, destroying, removing or<br />
disturbing of nests,” but birds of prey, such as owls, are not included within the<br />
terms of this act (Government of Canada 1994). Birds of prey are protected under<br />
the Alberta Wildlife Act (AWA) which states that a “person shall not wilfully<br />
molest, disturb or destroy a house, nest or den of prescribed wildlife... in<br />
prescribed areas and at prescribed times” (Government of Alberta 2000). Owls<br />
do not have specific provisions under the AWA and Alberta Sustainable<br />
Resources Development (ASRD) is developing guidelines to address habitat and<br />
protection needs of sensitive species (A. Hubbs 2009, pers. comm.), such as the<br />
barred owl and the great gray owl (ASRD 2006).<br />
Call playback surveys and pre-clearing bird nest sweeps could be conducted in<br />
potential habitat for listed owl species to identify and flag any nests within areas<br />
to be cleared. Detailed habitat and nest microhabitat information is known for<br />
barred owls and great gray owls. For these owls, which have nesting periods<br />
beginning before April 1, habitat and nest microhabitat information, as well as<br />
playback calls, aid in effectively locating nests during search efforts (Olsen et al.<br />
2006).<br />
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References<br />
Question No. 51<br />
Section 13.1<br />
ASRD. 2006. The General Status of Alberta Wild Species 2005. Alberta<br />
Sustainable Resource Development, Fish and Wildlife Service Division,<br />
Edmonton. Available online at:<br />
http://www.srd.alberta.ca/BioDiversityStewardship/SpeciesAtRisk/Gener<br />
alStatus/StatusOfAlbertaWildSpecies2005/Search.aspx. Accessed on<br />
October 23, 2009.<br />
Government of Alberta. 2000. Wildlife Act. R.S.A. 2000, c. W-10. Current to<br />
June 4, 2009. Sustainable Resource Development. 65 pp.<br />
Government of Canada. 1994. Migratory Birds Convention Act, 1994. S.C.,<br />
1994, c. 22. Current to September 17, 2009. Published by the Minister of<br />
Justice. 54 pp.<br />
Hubbs, A. 2009. (Fish and Wildlife Management, Alberta Sustainable Resource<br />
Development, Rocky Mountain House). Personal communication with<br />
Amy Darling (Golder Associates Ltd.) on October 22, 2009.<br />
Olsen, B.T., S.J. Hannon and G.S. Court. 2006. Short-term response of breeding<br />
Barred Owls to forestry in a boreal mixedwood forest landscape. Avian<br />
Conservation and Ecology 1(3): 1. Available online at: http://www.aceeco.org/vol1/iss3/art1/.<br />
Accessed October 23, 2009.<br />
Request Volume 1, Question 380, Page 14-23.<br />
The SIR refers to analogues with the natural environment. The landforms<br />
planned, including terraces, for the closure landscape, do not appear to reflect<br />
landforms found in pre-development landscape.<br />
51a Discuss landscape design options that would more closely mimic the natural<br />
environment.<br />
Response 51a Terraces are designed into the construction of landforms created above natural<br />
topography (e.g., overburden dump areas, dyke walls) for a number of reasons,<br />
such as:<br />
• Access for vehicles during construction, reclamation and monitoring<br />
• Allowing access for progressive reclamation, as structures are designed in<br />
lifts from the outside to the inside, therefore making outside lifts complete<br />
and accessible for reclamation purposes before the entire structure is<br />
necessarily complete<br />
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Question No. 52<br />
Section 13.1<br />
• Stability of sloped areas, as terraced areas provide an opportunity to slow<br />
water flow downslope and therefore retain as much soil moisture as possible.<br />
Ecosites requiring moist soil conditions have therefore been located in<br />
terraced areas in the Closure, Conservation and Reclamation Plan for the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
Shell will design terraces to closely mimic natural landforms present in the<br />
region, although not necessarily those landforms in the pre-development<br />
landscape of the mine footprint. Natural landforms that are similar in structure<br />
include benches on escarpment wall areas and river floodplains. Structures will<br />
be designed to minimize ponding, concentrated runoff and erosion.<br />
Landform design principles are also being applied to the consideration of how to<br />
construct slopes on landforms above original topography without including<br />
terraced areas, although issues of overall footprint (greater area may be required<br />
to provide shallower slopes) and slope stability for drainage courses (e.g., path<br />
length for drainage channels from top of slope to perimeter drainage systems at<br />
the toe) are still in the design test process.<br />
Request Volume 2, SIR 7, Page 15-1 ; Volume 2, SIR 20b, Page 15-13.<br />
Shell states in the EIA The combined EIA for the Jackpine <strong>Mine</strong> Expansion and<br />
the new <strong>Pierre</strong> <strong>River</strong> mine concluded that there would be no unacceptable<br />
environmental or socio-economic effects from the projects provided that the<br />
proposed mitigation and monitoring are undertaken. The original SIRs were<br />
asking how Shell had determined ‘acceptability’. The answer provided a<br />
discussion of consequence ratings.<br />
52a Provide the criteria Shell used to determine whether an environmental or social<br />
consequence rating was ‘acceptable’ or ‘unacceptable’.<br />
Response 52a Shell worked with its EIA consultants, and is engaged in ongoing consultation<br />
with its stakeholders, to understand the potential environmental and socioeconomic<br />
effects of the proposed project. In an iterative manner, the project<br />
design evolved to minimize potential effects. The result is a project where the<br />
majority of the impacts are of primarily low or negligible consequence, and a<br />
limited number of impacts of higher consequence. The conclusions and<br />
predictions contained in the EIA are based on environmental consequence<br />
ratings, which are based on the criteria outlined by the Canadian Environmental<br />
Assessment Act and include direction, magnitude, geographic extent, duration,<br />
reversibility and frequency. All of these ratings are described in the EIA,<br />
Volumes 3, 4 and 5. In addition, as part of the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 2, Appendix B, Shell provided an<br />
Environmental Significance Assessment.<br />
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Section 13.1<br />
In addition to the detailed environmental consequence ratings outlined above,<br />
Shell’s Sustainable Development policy also guides Shell’s plans when assessing<br />
large projects such as this. This is particularly important in the case of large-scale<br />
mining projects, which necessarily involve some impacts on the environment<br />
during construction and operations. This project has been developed to date with<br />
a view toward reducing its environmental impacts, where possible, managing<br />
natural resources efficiently, generating robust profitability, and the clear need to<br />
produce social and economic benefits on a local, provincial and federal level.<br />
Shell’s view is that the predicted environmental impacts of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
<strong>Project</strong> and the Jackpine <strong>Mine</strong> Expansion <strong>Project</strong> are acceptable, when<br />
considered in light of these sustainable development principles and Shell’s<br />
obligation to efficiently produce the oil sands resource for the benefit of all<br />
Albertans.<br />
Shell will present evidence regarding the acceptability of environmental impacts.<br />
However, it is understood that the overall public interest determination is the<br />
responsibility of the appropriate provincial and federal regulatory agencies, in<br />
accordance with their respective legislative mandates.<br />
Request 52b Discuss the role of the public interest decision in determining ‘acceptability’.<br />
Response 52b For the requested information, see the response to ERCB SIR 52a.<br />
Question No. 53<br />
Request Volume 2, SIR 8b, Page 15-2.<br />
The SIR asked whether the current capacity of the diluent and diluted bitumen<br />
lines to Scotford was sufficient to address the needs of both the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
and the Jackpine <strong>Mine</strong> Expansion. The answer given was Yes, the capacity… is<br />
currently being expanded. This answer is unclear.<br />
53a Are new pipelines being installed?<br />
Response 53a The capacity of the diluent and diluted bitumen infrastructure to Scotford is being<br />
expanded in conjunction with the Muskeg <strong>River</strong> <strong>Mine</strong> Expansion. Once<br />
completed, the pipelines will have sufficient capacity to support the diluent and<br />
diluted bitumen volumes for future mining expansions, including the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> and the Jackpine <strong>Mine</strong> expansion. As these mining expansions progress,<br />
pumps will be added at the pump stations to support the increased volumes being<br />
shipped.<br />
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Request 53b Is additional right-of-way and consequent disturbance required to accommodate<br />
the additional capacity being developed, or is the capacity expansion a result of<br />
engineering optimization of the existing pipelines?<br />
Response 53b The Muskeg <strong>River</strong> <strong>Mine</strong> Expansion pipeline capacity will be sufficient to handle<br />
the additional diluent and diluted bitumen volumes between Lease 13 and<br />
Scotford. No additional disturbance or rights-of-way will be required as the only<br />
modifications expected would be the addition of pumping capacity.<br />
Question No. 54<br />
Request Volume 2, SIR 22d, Page 15-18.<br />
In response to the question of what is meant by a mining setback, Shell states that<br />
Mining set-back refers to the designation of a corridor between the expected<br />
disturbance footprint and a natural feature, in this case the Athabasca <strong>River</strong>,<br />
whereby no disturbance, including clearing will occur. The raw water intake<br />
and pipeline occur within the 250 m setback that Shell has committed to, which<br />
appears to contradict Shell’s statement that no disturbance, including clearing<br />
will occur within the 250 m setback.<br />
54a What will the effective width of the Athabasca <strong>River</strong> corridor be at the sites of the<br />
raw water intake and pipeline?<br />
Response 54a The raw water intake and buried pipeline are not predicted to alter the effective<br />
width of the Athabasca <strong>River</strong> corridor, nor is the associated clearing predicted to<br />
act as a barrier to wildlife movement. However, the intake building and clearing<br />
at the river’s edge will likely have a filter effect on wildlife by reducing the rates<br />
of wildlife movement through the corridor at the location of the disturbance. A<br />
sufficient number of individuals are expected to cross the clearing (i.e., a<br />
minimum of one effective migrant per generation), such that genetic connectivity<br />
is predicted to be maintained (Mills and Allendorf 1996; Wang 2004).<br />
References<br />
Mills, L.S. and F.W. Allendorf. 1996. The One-Migrant-per-Generation Rule in<br />
Conservation and Management. Conservation Biology. 10(6): 1509-<br />
1518.<br />
Wang, J. 2004. Application of the One-Migrant-per-Generation Rule to<br />
Conservation and Management. Conservation Biology. 18(2): 332-343.<br />
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Section 13.1<br />
Request 54b Describe the mitigation measures that Shell will implement along the raw water<br />
intake and pipeline to ensure that the effective corridor width is not reduced at<br />
these sites.<br />
Response 54b The raw water intake and buried pipeline are not predicted to reduce the effective<br />
width of the Athabasca <strong>River</strong> corridor and the resulting clearing is not expected<br />
to act as a barrier to wildlife movement. Rather, the clearing within the corridor<br />
will likely have a filter effect on wildlife such that rates of movement through the<br />
corridor at the location of the disturbance are reduced. To lessen the effect on the<br />
rates of movement across the clearing, Shell will undertake practical measures to<br />
minimize the clearing width and disturbance area of the raw water intake and<br />
buried pipeline footprint in compliance with regulatory guidelines. The footprint<br />
of the raw water intake and buried pipeline will be a clearing potentially 80 to<br />
230 m wide. The clearing will be a combination of the water intake building at<br />
the river’s edge which initially might be 5 ha because of space needs for<br />
construction laydown, and the pipeline right-of-way (30 to 50 m wide). Exact<br />
dimensions and location of the areas to be developed will be developed during<br />
future detailed design work.<br />
References<br />
The greatest disruption to wildlife movement along the Athabasca <strong>River</strong> corridor<br />
will be temporary during construction of the water intake and pipeline, which<br />
typically takes 3 years for similar projects. However, based on wildlife corridor<br />
monitoring conducted in 2006 through 2008 along the Athabasca <strong>River</strong> (Golder<br />
2009), genetic connectivity is predicted to be maintained during the construction<br />
period (i.e., a minimum of one effective migrant per generation) (Mills and<br />
Allendorf 1996, Wang 2004). The disturbance will be minimized following<br />
construction through immediate re-vegetation of the right-of-way and<br />
construction laydown areas.<br />
Golder. 2009. Shell Jackpine <strong>Mine</strong>-Phase 1 Wildlife Corridor Monitoring Year 3<br />
Annual Report 2008. Prepared for Shell Canada Ltd. Fort McMurray,<br />
AB.<br />
Mills, L.S. and F.W. Allendorf. 1996. The One-Migrant-per-Generation Rule in<br />
Conservation and Management. Conservation Biology. 10(6): 1509-<br />
1518.<br />
Wang, J. 2004. Application of the One-Migrant-per-Generation Rule to<br />
Conservation and Management. Conservation Biology. 18(2): 332-343.<br />
Request 54c Provide a conceptual map indicating the potential movement paths that wildlife<br />
are likely to take when travelling past the raw water intake and pipeline.<br />
Response 54c As the clearing created for the raw water intake and buried pipeline (potentially<br />
80 to 230 m wide) is not predicted to alter the movement paths of wildlife along<br />
the Athabasca <strong>River</strong> corridor, a description of wildlife movement has been<br />
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References<br />
Question No. 55<br />
Section 13.1<br />
provided rather than a conceptual map. That is, to travel from point A in the<br />
corridor on one side of the clearing to point B on the other side of the clearing,<br />
wildlife are likely to simply cross the clearing. Moose, white-tailed deer, coyote,<br />
Canada lynx, wolf and black bear readily cross pipeline rights-of-way, especially<br />
if the pipeline is not a physical obstruction (Dunne and Quinn 2009). Given that<br />
the pipeline will be buried, it will not act as a physical obstruction to wildlife.<br />
Some wildlife might stay in the corridor on the side of point A rather than<br />
crossing to point B, creating a filter effect. Nonetheless, genetic connectivity is<br />
predicted to be maintained (Mills and Allendorf 1996; Wang 2004). Connectivity<br />
across the opening is predicted to increase as the right-of-way and construction<br />
laydown areas are reclaimed and become re-vegetated following construction.<br />
Dunne, B.M. and M.S. Quinn. 2009. Effectiveness of above-ground pipeline<br />
mitigation for moose (Alces alces) and other large mammals. Biological<br />
Conservation 142: 332 –343.<br />
Mills, L.S. and F.W. Allendorf. 1996. The One-Migrant-per-Generation Rule in<br />
Conservation and Management. Conservation Biology. 10(6): 1509-<br />
1518.<br />
Wang, J. 2004. Application of the One-Migrant-per-Generation Rule to<br />
Conservation and Management. Conservation Biology. 18(2): 332-343.<br />
Request Volume 2, SIR 23a, Page 15-18<br />
55a Are there options to move the plant site further away from the Athabasca <strong>River</strong><br />
and what would these options entail?<br />
Response 55a Shell selected the plant site to maximize the footprint available for facilities’<br />
layout within the constraints of the lease boundary, mine pit, the Athabasca <strong>River</strong><br />
setbacks and to maximize resource recovery. All other options which involved<br />
moving the plant site off Lease 9 were rejected because of the incremental<br />
terrestrial disturbance and the increased haul distances, as described in the May<br />
2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 1, Section 13.2,<br />
page 13-8.<br />
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Question No. 56<br />
Request Volume 2, SIR 32 a-b, Page 15-26.<br />
Section 13.1<br />
In the original SIR, the reference to RIWG (now OSDG) came from Volume 2,<br />
Page 16-1 and 2 under Cooperation Initiatives which states Shell’s regional<br />
cooperation has led to a number of specific actions and initiatives, including: …<br />
planning utility and access corridors … locating regional access roads and<br />
corridors. Through the Regional Issues Working Group (RIWG) Transportation<br />
Committee, industry and government are evaluating options for permanent<br />
access and utility corridors to support oil sands development.<br />
56a How did the work of the RIWG (now OSDG) inform the infrastructure associated<br />
with the proposed <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> including the location of the water intake<br />
and pipeline, transmission, natural gas, bitumen and diluent corridors, access<br />
roads and bridge locations?<br />
Response 56a The Regional Issues Working Group, now the Oil Sands Development Group<br />
(OSDG), provides a forum for general discussion of infrastructure location plans,<br />
even in the absence of formal cooperation agreements between oil sands<br />
developers. In the case of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Shell provided updates to the<br />
OSDG on infrastructure requirements that resulted in a working group being<br />
struck to optimize the location and permanent access points for the proposed<br />
bridge across the Athabasca <strong>River</strong>. As a result of the working group, Shell now<br />
has an agreement with PetroCanada to design a permanent access corridor<br />
associated with the bridge.<br />
Question No. 57<br />
The OSDG also provides a forum for stakeholders to discuss potential locations<br />
of common infrastructure corridors. Shell’s participation in the group has already<br />
identified opportunities for common use. For example, the exchange of planning<br />
information with Imperial Oil Resources Ventures Limited in relation to<br />
upgrades to the Fort Chipewyan Road will provide common access to<br />
infrastructure located in this area. Further discussion related to the location of<br />
pipelines, utility corridors and other access roads is underway within the OSDG.<br />
Request Volume 2, SIR 266, Page 21-6.<br />
In the rationale for mining through the <strong>Pierre</strong> <strong>River</strong>, Shell indicates there is a<br />
significant bitumen resource below the <strong>Pierre</strong> <strong>River</strong> and that Shell has an<br />
obligation to its shareholders and the province to recover this resource. Further,<br />
Shell indicates that the <strong>Pierre</strong> <strong>River</strong> mine strikes a balance between resource<br />
recovery and impacts on the <strong>Pierre</strong> <strong>River</strong> upstream of Lease 9, as well as<br />
mitigating flow impacts on the Athabasca <strong>River</strong>.<br />
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57a With respect to the assertion that the <strong>Pierre</strong> <strong>River</strong> mine strikes a balance, how<br />
was this determined?<br />
Response 57a For information regarding the manner in which Shell makes determinations about<br />
how the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> strikes a balance between resource recovery and<br />
potential environmental impacts, see the response to AENV SIR 52. As stated in<br />
that response, Shell has prepared an EIA that makes environmental impact<br />
predictions based on environmental consequence ratings. These consequence<br />
ratings are based on the criteria outlined by the Canadian Environmental<br />
Assessment Act and include direction, magnitude, geographic extent, duration,<br />
reversibility and frequency. All of these ratings are described in the EIA,<br />
Volumes 3, 4 and 5. In addition, as part of the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>,<br />
Supplemental Information, Volume 2, Appendix B, Shell provided an<br />
Environmental Significance Assessment.<br />
In addition to the detailed environmental consequence ratings outlined<br />
previously, Shell’s Sustainable Development policy also guides Shell’s plans<br />
when assessing large projects such as this. This is particularly important in the<br />
case of large-scale mining projects, which necessarily involve some impacts on<br />
the environment during construction and operations. This project has been<br />
developed with a view toward reducing its environmental impacts, where<br />
possible, the efficient management of natural resources, the generation of<br />
profitability, and the clear need to provide social and economic benefits on a<br />
local, provincial and federal level. Shell’s view is that the predicted<br />
environmental impacts of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> and Jackpine <strong>Mine</strong> Expansion<br />
projects are acceptable, when considered in light of these sustainable<br />
development principles and Shell’s obligation to efficiently produce the oil sands<br />
resource for the benefit of all Albertans.<br />
Although the portion of the <strong>Pierre</strong> <strong>River</strong> located in the operational footprint of<br />
the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> will be affected during construction and operation, these<br />
effects will be mitigated by implementing Shell’s operational and closure<br />
drainage plans. Accordingly, Shell considered the loss of the <strong>Pierre</strong> <strong>River</strong> during<br />
construction and operation in conjunction with the implementation of operational<br />
and closure drainage plans, and determined that the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, as applied<br />
for, achieved a balance between impacts and resource recovery.<br />
Request 57b What are the criteria Shell used to assess whether this was a balanced decision?<br />
Response 57b See the response to AENV SIR 57a.<br />
Request 57c How was the loss of the <strong>Pierre</strong> <strong>River</strong> on the lease area accounted for in this<br />
decision?<br />
Response 57c See the response to AENV SIR 57a.<br />
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Question No. 58<br />
Request Volume 2, SIR 383a, Page 23-2.<br />
Section 13.1<br />
Shell indicates that it has not developed a contingency plan to reflect a 400 m<br />
setback from the Athabasca <strong>River</strong>, stating that Shell believes that the 250 m<br />
setback … is sufficient to allow the movement of wildlife along the Athabasca<br />
<strong>River</strong> Corridor and ensures genetic connectivity. Many of Shell’s responses to<br />
questions regarding the maintenance of movement corridors focus on genetic<br />
connectivity, suggesting that genetic connectivity is the primary concern with<br />
respect to the maintenance of adequate buffers along the Athabasca <strong>River</strong> and its<br />
tributaries.<br />
58a Provide a discussion of other benefits and outcomes of maintaining an adequate<br />
buffer along these watercourses. Focus on wildlife, fisheries, reclamation and<br />
human health and safety perspectives.<br />
Response 58a Maintaining a riparian buffer zone adjacent to watercourses provides a variety of<br />
benefits in addition to the predicted maintenance of genetic connectivity.<br />
From an aquatics ecosystems perspective, a riparian buffer zone adjacent to<br />
watercourses offers the following benefits, as documented in scientific literature<br />
(Wenger 1999, Parkyn 2004):<br />
• protecting the physical, chemical and biological integrity of the watercourse<br />
• preventing pollutants from entering the watercourse<br />
• reducing erosion by protecting and stabilizing banks and controlling<br />
sedimentation<br />
• providing flood control and base flow maintenance<br />
• contributing and controlling organic inputs and large woody debris<br />
• providing tree canopy to shade streams and promote desirable aquatic habitat<br />
These benefits also apply to human health and safety, by maintaining water<br />
quality and by stabilizing watercourse banks and providing flood control.<br />
The minimum width of a riparian buffer for protecting aquatic ecosystems can<br />
vary depending on the vegetation type, slope, and other factors. Recommended<br />
buffer widths for protecting aquatic ecosystems from different jurisdictions in<br />
Canada and the United States range between 7 m and 100 m (Mayer et al. 2006,<br />
Lee et al. 2004). A 250 m buffer width for the Athabasca <strong>River</strong> is considered<br />
adequate to protect aquatic function.<br />
From a wildlife perspective, the richness and complexity of riparian habitats<br />
often make these areas high in wildlife diversity and abundance (Anthony 1996,<br />
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References<br />
Section 13.1<br />
Olsen et al. 2007). The preservation and maintenance of riparian areas is<br />
important for the conservation of wildlife biodiversity. The maintenance of<br />
riparian buffers will provide corridors of mature forest for in-migration of<br />
wildlife onto the reclaimed lands from surrounding habitat. For this reason, a<br />
minimum 250 m setback from the Athabasca <strong>River</strong> is an integral part of Shell’s<br />
mine development plans.<br />
The proposed riparian corridor approaches a minimum 250 m width in an area<br />
less than 8 km long, and in general is much wider over the remainder of its length<br />
(see the responses to AENV SIR 69a and AENV SIR 70a). The purpose of a<br />
corridor is not to satisfy all life history requirements for all wildlife species that<br />
may be using it (Rosenberg et al. 1997). Rather, the purpose of a corridor is to<br />
maintain landscape connectivity for species (Beier and Noss 1998). Landscape<br />
connectivity helps maintain population viability by promoting gene flow between<br />
patches and increasing the effective size of populations (Noss and Harris 1987,<br />
Beier and Noss 1998, Olsen et al. 2007). Maintaining resident populations within<br />
a corridor is only necessary when the corridor length is long relative to the<br />
dispersal abilities of the species in question (Beier and Noss 1998). The 8 km<br />
length of the proposed corridor where the width approaches 250 m (minimum) is<br />
short relative to the dispersal capabilities of wide-ranging species (Sutherland et<br />
al. 2000). In the boreal mixedwood ecoregion of north-central Alberta, Hannon et<br />
al. (2002) found that 200 m wide riparian corridors were sufficient for<br />
maintaining natural small mammal, amphibian and bird communities. Therefore,<br />
a 250 m wide corridor is likely to be sufficient as both a fully functioning reserve<br />
for small mammal, amphibian and bird communities and a movement corridor<br />
for wide ranging species. Neither a 250 m or 400 m wide corridor would hold the<br />
territories of larger wide-ranging wildlife species, but as long as a corridor is not<br />
long relative to the dispersal abilities of a species, it does not need to be wide<br />
enough to satisfy all life history requirements for that species (Beier and Noss<br />
1998).<br />
From a reclamation perspective, the primary benefit of maintaining an adequate<br />
riparian buffer along watercourses is to conserve a diverse native seed source for<br />
natural ingress of vegetation (by seed or rooting) to adjacent reclamation areas.<br />
Also, the maintenance of a buffer will aid in retaining soil moisture conditions<br />
that will support the success of adjacent reclamation areas. Closure and<br />
reclamation plans typically integrate reclaimed ecosites into riparian buffers and<br />
adjacent undisturbed areas to ensure that there is landscape continuity around<br />
watercourses, and to optimize the benefit of the ingress of natural vegetation.<br />
Anthony, R.G., G.A. Green, E.D. Forsman, and S.K. Nelson. 1996. Avian<br />
abundance in riparian zones of three forest types in the Cascade<br />
Mountains, Oregon. Wilson Bulletin 108(2): 280-291.<br />
Beier, P. and R.F. Noss. 1998. Do habitat corridors provide connectivity?<br />
Conservation Biology 12(6): 1241-1252.<br />
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Question No. 59<br />
Section 13.1<br />
Lee, P, C. Smyth and S. Boutin. 2004. Quantitative review of riparian buffer<br />
width guidelines from Canada and the United States. Journal of<br />
Environmental Management 70: 165-180.<br />
Mayer, P.M., S.K. Reynolds, M.D. McCutchen, and T.J. Canfield. Riparian<br />
buffer width, vegetative cover, and nitrogen removal effectiveness: A<br />
review of current science and regulations. EPA/600/R-05/118.<br />
Cincinnati, OH, U.S. Environmental Protection Agency, 2006.<br />
Noss, R.F. and L.D. Harris. 1987. Nodes, networks, and MUMs: preserving<br />
diversity at all scales. Environmental Management 10(3): 299-309.<br />
Olson, D.H., P.D. Anderson, C.A. Frissell, H.H. Welsh Jr. and D.F. Bradford.<br />
2007. Biodiversity management approaches for stream-riparian areas:<br />
perspectives for Pacific Northwest headwater forests, microclimates, and<br />
amphibians. Forest Ecology and Management 246: 81-107.<br />
Parkyn, S. 2004. Review of riparian zone effectiveness. Prepared for Ministry of<br />
Agriculture and Forestry, MAF Technical Paper No: 2004/05.<br />
Wellington, New Zealand. September 2004.<br />
Wenger, S. 1999. A review of the scientific literature on riparian buffer width,<br />
extent and vegetation. Institute of Ecology, University of Georgia.<br />
Revised Version, March 5, 1999.<br />
Request Volume 2, SIR 453a, Page 23-112 ; Volume 2, SIR 469b, Page 23-153.<br />
Terms of Reference section 5.6.4 required current field data for all species of<br />
concern as a basis for understanding the effects of the project on local and<br />
regional populations. However, Shell indicates in SIR Response 469 that only<br />
generic sampling protocols were used and that surveys were not intended to<br />
provide detailed abundance estimates for all listed species. As a result Shell<br />
cannot provide estimates of the proportion of existing populations that will be<br />
displaced by the <strong>Pierre</strong> <strong>River</strong> project (Response 469b). However, Shell<br />
acknowledges the importance of this information in identifying a willingness to<br />
conduct yellow rail surveys in 2009 using a standardized protocol to better<br />
understand the distribution, abundance and habitat use of this species in the<br />
LSAs (Response 453a). Shell indicates an intention to provide this information<br />
on yellow rail (Response 453a) but similar targeted surveys and assessments of<br />
habitat availability are required for all species to meet Canadian Environmental<br />
Assessment Act and SARA information requirements.<br />
59a Based on available survey data, provide a population estimate (with confidence<br />
intervals) for each species currently listed under Schedule 1 of SARA and current<br />
COSEWIC-listed species known to occur in the LSA. If such a population<br />
estimate is not available for these species (as Shell states is the case for Yellow<br />
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rail, Olive-sided flycatcher and Rusty blackbird), indicate when Shell will<br />
conduct the surveys and prepare the population estimates.<br />
Section 13.1<br />
Response 59a Population estimates with confidence intervals for each species currently listed<br />
under Schedule 1 of the Species at Risk Act (SARA) and current Committee on<br />
the Status of Endangered Wildlife in Canada (COSEWIC)-listed species known<br />
to occur in the local study area (LSA) cannot be calculated based on the surveys<br />
conducted to date and the low numbers detected. Additional surveys to obtain<br />
population estimates with confidence intervals within the LSA are beyond the<br />
scope of an environmental impact assessment.<br />
Shell has met the requirements of the Canadian Environmental Assessment Act<br />
(CEAA), the SARA and the Terms of Reference (TOR) in assessing the effects<br />
of the project on listed species through the assessment of wildlife indicator<br />
species and their habitat. Neither the CEAA nor the SARA implicitly or<br />
explicitly require that species-specific population surveys be conducted. Rather,<br />
the CEAA requires that an assessment of the environmental effects of a project<br />
include any change that the project may have on a “listed wildlife species, its<br />
critical habitat or the residences of individuals of that species”. SARA requires<br />
that, when conducting an environmental assessment, any adverse effects of the<br />
project on the listed wildlife species and its critical habitat must be identified,<br />
and, if the project is carried out, must ensure that measures are taken to avoid or<br />
lessen those effects and to monitor them. Shell has done this.<br />
The TOR require an impact assessment for wildlife, including endangered<br />
species and species at risk, as well as a discussion of how populations may be<br />
impacted by the project, which Shell has done. As part of this impact assessment,<br />
the TOR specifically asks for a description of existing wildlife resources, and as<br />
part of that description, Shell is required to discuss current field data. In EIA,<br />
Volume 5, Section 7.3.4, Shell has provided a discussion of current field data<br />
through the use of indicator species. Nothing in the TOR expressly precludes the<br />
use of wildlife indicator species and, in fact, the use of wildlife indicators in<br />
assessing impacts on wildlife, including endangered species and species at risk, is<br />
a recognized protocol, and was recently considered by the Joint Review Panel<br />
reviewing the Mackenzie Gas <strong>Project</strong> application. The Panel found that the use of<br />
indicator or surrogate species for the assessment of other species, including<br />
SARA-listed species, was an acceptable method of impact assessment and<br />
provided sufficient evidence to enable the Panel to review the potential impacts.<br />
Shell has conducted the appropriate studies for the indicator species in<br />
compliance with the TOR and that information is appropriate for assessing the<br />
impacts on listed species. Accordingly, the studies conducted for the<br />
environmental assessment and the information contained in the EIA comply with<br />
both the TOR and the federal statutes.<br />
However, although Shell’s EIA provides sufficient data to assess the potential<br />
impacts to all relevant species, including SARA-listed species, Shell has<br />
proposed a wildlife monitoring program for the pre-development, operation and<br />
reclamation phases of the project, which will be developed in consultation with<br />
ASRD as described in EIA, Volume 5, Appendix 5-6, Section 6. During the<br />
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Section 13.1<br />
finalization of the wildlife monitoring program with ASRD after project<br />
approvals have been issued, Shell will consider monitoring for the presence of<br />
listed species as part of the pre-development wildlife monitoring program.<br />
Request 59b Using information from surveys, provide ecosite associations of species listed on<br />
Schedule 1 of SARA and current COSEWIC-listed species.<br />
i. Quantify the total area and proportion of area of each ecosite phase used by<br />
species listed on Schedule 1 of SARA and current COSEWIC-listed species<br />
that will be destroyed over the lifetime of the project.<br />
ii. Identify the reclamation targets for each ecosite phase currently used by<br />
species listed on Schedule 1 of SARA and current COSEWIC-listed species so<br />
that the base-case habitat availability can be compared to availability in the<br />
reclaimed landscape.<br />
Response 59b i. The total area and proportion of area of each ecosite phase and wetlands<br />
types in the local study areas (LSAs), including those used by species listed<br />
on Schedule 1 of the SARA and COSEWIC-listed species that will be<br />
removed as part of the project, are presented in EIA, Volume 5, Section<br />
7.5.2. The EIA acknowledges that, during construction and operations, direct<br />
and indirect habitat loss will be of a high magnitude for all key indicator<br />
resources (KIRs) (EIA, Volume 5, Section 7.5.3.3). However, environmental<br />
consequences of the project are based on the change in habitat availability<br />
between Base Case and Closure, after reclamation. As stated in the EIA, the<br />
key mitigation to minimize residual effects is reclamation (EIA, Volume 5,<br />
Section 7.1.3).<br />
Species that are on Schedule 1 of SARA and/or are listed by COSEWIC<br />
occur in insufficient numbers to detect any statistically significant changes<br />
because of the project. Therefore, baseline efforts and the subsequent EIA<br />
did not focus on these species. Beanlands and Duinker (1983) recommended<br />
that assessments concentrate on an ecological perspective rather than trying<br />
to assess all species; consequently, KIRs are used to provide focus for the<br />
assessment (EIA, Volume 1, Section 1.3.5, Table 1.3-2). The Joint Review<br />
Panel for the Mackenzie Gas <strong>Project</strong> (Joint Review Panel, 2010) in Sections<br />
5.2 and 10.3 noted that “the use of indicator species is, in principle, an<br />
acceptable method of impact assessment” (Section 5.10.2, page 274), and is<br />
not inconsistent with SARA and COSEWIC requirements. Beanlands and<br />
Duinker (1983) also recommended that an environmental assessment should<br />
have a focused study effort based on a compromise between the information<br />
needs of the decision-makers and what a sound, short-term applied science<br />
program can provide.<br />
To assess the impacts of the project on species listed on Schedule 1 of SARA<br />
and current COSEWIC-listed species, the habitat associations of these<br />
wildlife species observed or potentially occurring within the Jackpine <strong>Mine</strong><br />
Expansion and <strong>Pierre</strong> Rive <strong>Mine</strong> local study areas (LSAs) were compiled in<br />
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Western (Boreal) Toad<br />
Wood Bison<br />
Woodland Caribou<br />
Section 13.1<br />
order to quantify the change in total area and proportion of area of each<br />
ecosite phase or wetlands type between Base Case and Closure (see Table<br />
AENV 59-1). Habitat associations of federally-listed species were primarily<br />
derived from direct observations from baseline surveys conducted for the<br />
project from 2005 to 2007 (Wildlife Environmental Setting Report,<br />
Volume 5, Table 5.2-1) or from historic wildlife survey results in the Oil<br />
Sands Region. These associations are equated with ecosite phases and<br />
wetlands types in the LSAs as defined by vegetation mapping produced for<br />
the Terrestrial Vegetation, Wetlands and Forest Resources impact assessment<br />
(Volume 5, Section 7).<br />
Three boreal toads were detected during amphibian surveys conducted within<br />
the LSAs (Terrestrial Environmental Setting Report, Section 5.5.5.1). These<br />
observations occurred in wooded fen (FTNN) and wooded bog (BTNN)<br />
wetlands types. Additionally, historical data from the Oil Sands Region<br />
indicate boreal toads have been detected within a variety of habitat types<br />
(e.g., shrubby fen [FONS], marsh [MONG], lichen jack pine [a1], Labrador<br />
tea-subhygric black spruce-jack pine [g1]; Golder 2000; Canadian Natural<br />
2006; Rio Alto 2002; Table AENV 59-1). Using information from project<br />
surveys and historical surveys, the net gain of habitat types from Base Case<br />
to Closure for western toad is approximately 120 ha (less than 1% of the<br />
LSAs, as shown in Table AENV 59-1).<br />
Two incidental observations of wood bison were recorded within the <strong>Pierre</strong><br />
Rive <strong>Mine</strong> LSA. These observations occurred in lichen jackpine (a1) and<br />
Labrador tea-mesic jack pine–black spruce (c1) ecosite phases (Terrestrial<br />
Environmental Setting Report, Appendix T). Historical survey data on other<br />
habitat associations for wood bison were not available for the Oil Sands<br />
Region. Using information from project surveys, the net gain of habitat types<br />
from Base Case to Closure for wood bison is approximately 4,780 ha (9% of<br />
the LSAs; see Table AENV 59-1).<br />
A single woodland caribou track was recorded during winter tracking<br />
surveys in graminoid fen (FONG) on the Jackpine <strong>Mine</strong> Expansion LSA<br />
(Terrestrial Environmental Setting Report, Section 5.3.1.4). Historical survey<br />
observations for caribou in the Oil Sands Region occur across a wide variety<br />
of upland and wetland habitat types (e.g., wooded fen [FTNN], marsh<br />
[MONG], shrubby fen [FONS], low-bush cranberry aspen-white spruce [d2],<br />
Labrador tea-mesic jack pine-black spruce [c1], Labrador tea-subhygric<br />
black spruce-jack pine [g1], and lichen jack pine [a1]) (MEG 2005; Canadian<br />
Natural 2006; Golder 2003). Using information from project surveys and<br />
historical surveys, the net gain of habitat types from Base Case to Closure for<br />
woodland caribou is approximately 2,795 ha (6% of the LSAs; see Table<br />
AENV 59-1).<br />
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Common Nighthawk<br />
Rusty Blackbird<br />
Short-eared Owl<br />
Whooping Crane<br />
Section 13.1<br />
Eight common nighthawks were observed incidentally within the LSAs<br />
during field surveys. These observations occurred in lichen jack pine (a1),<br />
blueberry jack pine-aspen (b1), disturbance (DIS), and cutblock (CC)<br />
(Terrestrial Environmental Setting Report, Appendix T). Historical data from<br />
the Oil Sands Region suggest common nighthawks are associated with open<br />
or semi-open habitats in a variety of areas including forest clearings, burned<br />
areas, and grassy meadows (Golder 2004; Semenchuk 1992). These habitats<br />
closely equate to meadows (Me) and disturbed habitat areas such as<br />
cutblocks (CC) and burned upland (BUu). Using information from project<br />
surveys and historical surveys, the net gain of habitat types from Base Case<br />
to Closure for common nighthawk is approximately 1,745 ha (3% of the<br />
LSAs; see Table AENV 59-1).<br />
One rusty blackbird was recorded in graminoid fen (FONG) during surveys<br />
conducted for the project (Terrestrial Environmental Setting Report, Section<br />
5.4.4.2, Table 5.4-13). Historical data on other habitat associations for rusty<br />
blackbirds were not available for the Oil Sands Region. Using information<br />
from project surveys, the net loss of habitat types from Base Case to Closure<br />
for rusty blackbird is approximately 1,397 ha (3% of the LSAs; see Table<br />
AENV 59-1).<br />
Short-eared owls were not observed during field surveys conducted for the<br />
project. Historical data from the Oil Sands Region and relevant literature<br />
indicate that short-eared owls are associated with open habitats, including<br />
grassy or brushy meadows, marshland and previously forested areas that<br />
have been cleared (Semenchuk 1992; Canadian Natural 2000; Wiggins<br />
2006). In northern Alberta, these habitats equate to graminoid fen (FONG),<br />
marsh (MONG), shrubby swamps (SONS), meadows (Me) and cutblocks<br />
(CC). Using information from historical surveys and relevant literature, the<br />
net loss of habitat types from Base Case to Closure for short-eared owl is<br />
approximately 5,100 ha (10% of the LSAs; see Table AENV 59-1).<br />
Whooping cranes were not observed during field surveys conducted for the<br />
project. Whooping cranes are only present in the LSAs during spring and fall<br />
migration. There have been five confirmed and two probable historical<br />
incidental sightings of whooping cranes in the Oil Sands Region. The most<br />
recent sighting of a pair occurred in 2004 near the Suncor Firebag <strong>Project</strong> but<br />
habitat information was unavailable (Suncor 2008). Current nesting areas for<br />
whooping cranes within Wood Buffalo National Park consist of poorly<br />
drained, shallow-water wetlands separated by narrow ridges of white spruce,<br />
black spruce and willows (Salix spp.) (Lewis 1995). Other literature suggests<br />
whooping cranes are associated with large, relatively open, marshy areas<br />
(Semenchuk 1992). In northern Alberta, these habitats equate to marsh<br />
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Peregrine Falcon<br />
Northern Leopard Frog<br />
Wolverine<br />
Section 13.1<br />
(MONG) and shallow, open water (WONN) wetlands types. Using<br />
information from relevant literature, the net loss of habitat types from Base<br />
Case to Closure for whooping crane is approximately 681 ha (1% of the<br />
LSAs; see Table AENV 59-1).<br />
Peregrine falcons were not observed during field surveys conducted for the<br />
project and historical habitat association data from the Oil Sands Region<br />
were not available. Peregrine falcons are only present in the LSAs during<br />
spring and fall migration. Relevant literature suggests that peregrine falcons<br />
are associated with habitats that include cliffs near water for nesting and<br />
open fields, swamps and marshes for hunting (Semenchuk 1992; White et al.<br />
2002). It is difficult to equate ecosite phases with habitat descriptions that<br />
include geographical features; however, based on vegetation similarities,<br />
these habitats roughly equate to marsh (MONG), shrubby swamp (SONS)<br />
and shallow open water (WONN) wetlands types and disturbed areas<br />
including cutblocks (CC) and general disturbance (DIS). Using information<br />
from relevant literature, the net loss of habitat types from Base Case to<br />
Closure for peregrine falcon is approximately 3,511 ha (7% of the LSAs; see<br />
Table AENV 59-1).<br />
Northern leopard frogs were not detected during surveys conducted for the<br />
project and historical data from the Oil Sands Region were not available.<br />
Typically, northern leopard frogs are associated with permanent ponds that<br />
contain emergent vegetation (e.g., bulrushes, cattails) and areas of shallow,<br />
open water such as lakes and ponds (Russell and Bauer 2000). In northern<br />
Alberta, northern leopard frogs can occur within most wetland types. The net<br />
loss of all wetland types from Base Case to Closure is approximately 13,803<br />
ha (27% of the LSAs; see Table AENV 59-1).<br />
Wolverines were photographed on two occasions in the northern portion of<br />
the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA and wolverine tracks were recorded five times in<br />
the Jackpine <strong>Mine</strong> Expansion LSA (Terrestrial Environmental Setting<br />
Report, Section 5.3.5.2). These observations occurred in Labrador tea–mesic<br />
jack pine–black spruce (c1), along the Muskeg <strong>River</strong> and along smaller<br />
drainages flowing into the Athabasca <strong>River</strong>. Historical field data from the Oil<br />
Sands Region show evidence of wolverine occurring in Labrador tea /<br />
horsetail white spruce–black spruce (h1), dogwood white spruce (e3) and<br />
wooded bog (BTNN) (MEG 2008; Suncor 2005; Suncor 2007). Using<br />
information from project surveys and historical surveys, the net gain of<br />
habitat types from Base Case to Closure for wolverine is approximately<br />
3,259 ha (6% of the LSAs; see Table AENV 59-1).<br />
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References<br />
Section 13.1<br />
Beanlands, G. E., and P. N. Duinker. 1983. An ecological framework for<br />
environmental impact assessment in Canada. Institute for Resource and<br />
Environmental Studies, Dalhousie University, Halifax, Nova Scotia, and<br />
Federal Environmental Assessment Review Office, Hull, Quebec. 132<br />
pp.<br />
Canadian Natural (Canadian Natural Resources Ltd.). 2000. Primrose and Wolf<br />
Lake (PAW) In-Situ Oil Sands Expansion <strong>Project</strong>. Volumes I to VI.<br />
October 2000. Prepared by Golder Associates Ltd. Calgary, AB.<br />
Canadian Natural. 2006. Primrose In-Situ Oil Sands <strong>Project</strong>. Primrose East<br />
Expansion Application for Approval. Volumes 1 to 6. Submitted to<br />
Alberta Energy and Utilities Board and Alberta Environment. Prepared<br />
by Golder Associates Ltd. Calgary, AB. Submitted January 2006.<br />
Golder. 2000. Christina Lake Thermal <strong>Project</strong> Wildlife, Wetlands and Rare Plant<br />
Assessment Update 2000. Prepared for PanCanadian Petroleum Ltd.<br />
Calgary, AB.<br />
Golder. 2003. 2003 Winter Aerial Caribou Survey for the Petro-Canada Meadow<br />
Creek <strong>Project</strong>. Prepared for Petro-Canada. Prepared by Golder<br />
Associates Ltd. March 2003. 25 pp. + Appendices.<br />
Golder. 2004. 2004 Suncor Energy Wildlife Monitoring Program and Wildlife<br />
Assessment Update Year 5. Prepared for Suncor Energy Inc., Fort<br />
McMurray, AB. Prepared by Golder Associates Ltd.<br />
Joint Review Panel for the Mackenzie Gas <strong>Project</strong>. 2010. Foundation for a<br />
Sustainable Northern Future: Report of the Joint Review Panel for the<br />
Mackenzie Gas <strong>Project</strong>. Published under the Authority of the Minister of<br />
Environment, Government of Canada, December 2009.<br />
Lewis, James C. 1995. Whooping Crane (Grus americana), The Birds of North<br />
America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology;<br />
Retrieved from the Birds of North America Online:<br />
http://bna.birds.cornell.edu/bna/species/153.<br />
MEG (MEG Energy Corporation). 2005. Application for Approval of the<br />
Christina Lake Regional <strong>Project</strong>. Volumes 1 to 5. Submitted to Alberta<br />
Environment and Alberta Energy and Utilities Board. Calgary, AB.<br />
Submitted August 2005.<br />
MEG. 2008. Christina Lake Regional <strong>Project</strong> Wildlife Environmental Setting<br />
Report- Phase 3. Prepared for MEG Energy Corp., Calgary, AB. Morse,<br />
D.H. and A.F. Poole. 2005. Common Nighthawk (Chordeiles minor).<br />
The Birds of North America Online. A. Poole (Ed.). Cornell Laboratory<br />
of Ornithology. Ithaca, NY.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Rio Alto (Rio Alto Exploration Ltd.). 2002. Kirby <strong>Project</strong> Application for<br />
Approval to Alberta Energy and Utilities Board and to Alberta<br />
Environment. Volumes 1,2,3,5,6 and 7. Prepared by Golder Associates<br />
Ltd. Calgary, AB.<br />
Russell, A. P. and A. M. Bauer 2000. The Amphibians and Reptiles of Alberta. A<br />
Field Guide and Primer of Boreal Herpetology, Second Edition.<br />
University of Calgary Press. Calgary, AB. 292 pp.<br />
Semenchuk, G. P. 1992. The Atlas of Breeding Birds of Alberta. Federation of<br />
Alberta Naturalists. Edmonton, AB. 393 pp.<br />
Suncor (Suncor Energy Inc.). 2005. Voyageur <strong>Project</strong> Application and<br />
Environmental Impact Assessment. Submitted to Alberta Energy and<br />
Utilities Board and Alberta Environment. Volumes 1A, 1B, 2, 3, 4, 5 and<br />
6. Fort McMurray, AB. Submitted March 2005.<br />
Suncor. 2007. Wildlife Baseline Report for the Suncor Voyageur South <strong>Project</strong>.<br />
Prepared for Suncor Energy Inc. Fort McMurray, AB.<br />
Suncor. 2008. Firebag 2007 Conservation and Reclamation Annual Report.<br />
Submitted to Alberta Environment. March 2008. 45 pp. + Appendices.<br />
White, C. M., N. J. Clum, T. J. Cade and W. G. Hunt. 2002. Peregrine Falcon<br />
(Falco peregrinus), The Birds of North America Online (A. Poole, Ed.).<br />
Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North<br />
America Online: http://bna.birds.cornell.edu/bna/species/660.<br />
Wiggins, D. A., D. W. Holt and S. M. Leasure. 2006. Short-eared Owl (Asio<br />
flammeus), The Birds of North America Online (A. Poole, Ed.). Ithaca:<br />
Cornell Lab of Ornithology; Retrieved from the Birds of North America<br />
Online: http://bna.birds.cornell.edu/bna/species/062.<br />
ii. Reclamation targets for species listed on Schedule 1 of SARA and current<br />
COSEWIC-listed species are listed by ecosite phase and wetlands type in<br />
AENV SIR 59bi, Table AENV 59-1, based on the conceptual Closure,<br />
Conservation and Reclamation plan.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Table AENV 59-1: Potential and Observed Federally Listed Species and Associated Habitat to be Cleared and Reclaimed in the Local Study Area<br />
Common<br />
Name Latin Name COSEWIC SARA<br />
western<br />
(boreal)<br />
toad<br />
wood bison Bos bison<br />
athabascae<br />
woodland<br />
caribou<br />
Bufo boreas Special<br />
Concern<br />
Rangifer<br />
tarandus<br />
Schedule 1:<br />
Special<br />
Concern<br />
Threatened Schedule 1:<br />
Threatened<br />
Threatened Schedule 1:<br />
Threatened<br />
Observed<br />
During<br />
Surveys<br />
yes<br />
yes<br />
yes<br />
Ecosite<br />
Phase or<br />
Wetlands<br />
Type<br />
Base Case<br />
Area<br />
(ha)<br />
Loss/Alteration<br />
Due to the<br />
<strong>Project</strong> Closure (a)<br />
Net Change Due to the<br />
<strong>Project</strong> (b)<br />
April 2010 Shell Canada Limited 13-31<br />
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%<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
% of<br />
Resource<br />
e2** 592 1 -344 -1 405 1 -187 -
TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Table AENV 59-1: Potential and Observed Federally Listed Species and Associated Habitat to be Cleared and Reclaimed in the Local Study Area<br />
(cont'd)<br />
Common<br />
Name Latin Name COSEWIC SARA<br />
woodland<br />
caribou<br />
(cont’d)<br />
common<br />
nighthawk<br />
rusty<br />
blackbird<br />
short-eared<br />
owl<br />
whooping<br />
crane<br />
Chordeiles<br />
minor<br />
Eughagus<br />
caroinus<br />
Asio<br />
flammeus<br />
Grus<br />
americana<br />
Threatened No<br />
Schedule:<br />
No Status<br />
Special<br />
Concern<br />
Special<br />
Concern<br />
Schedule 1:<br />
Special<br />
Concern<br />
Schedule 3:<br />
Special<br />
Concern<br />
Endangered Schedule 1:<br />
Endangered<br />
Observed<br />
During<br />
Surveys<br />
Ecosite<br />
Phase or<br />
Wetlands<br />
Type<br />
Base Case<br />
Area<br />
(ha)<br />
Loss/Alteration<br />
Due to the<br />
<strong>Project</strong> Closure (a)<br />
Net Change Due to the<br />
<strong>Project</strong> (b)<br />
April 2010 Shell Canada Limited 13-32<br />
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%<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
% of<br />
Resource<br />
FONS** 3627 7 -2569 -5 1058 2 -2569 -5 -71<br />
MONG*** 671 1 -622 -1 50
TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Table AENV 59-1: Potential and Observed Federally Listed Species and Associated Habitat to be Cleared and Reclaimed in the Local Study Area<br />
(cont'd)<br />
Common<br />
Name Latin Name COSEWIC SARA<br />
peregrine<br />
falcon<br />
northern<br />
leopard frog<br />
Falco<br />
peregrinus<br />
Rana<br />
pipiens<br />
Special<br />
Concern<br />
Special<br />
Concern<br />
Schedule 1:<br />
Threatened<br />
Schedule 1:<br />
Special<br />
Concern<br />
Observed<br />
During<br />
Surveys<br />
no<br />
no<br />
Ecosite<br />
Phase or<br />
Wetlands<br />
Type<br />
Base Case<br />
Area<br />
(ha)<br />
Loss/Alteration<br />
Due to the<br />
<strong>Project</strong> Closure (a)<br />
Net Change Due to the<br />
<strong>Project</strong> (b)<br />
April 2010 Shell Canada Limited 13-33<br />
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%<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
% of<br />
Resource<br />
MONG*** 671 1 -622 -1 50
TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Table AENV 59-1: Potential and Observed Federally Listed Species and Associated Habitat to be Cleared and Reclaimed in the Local Study Area<br />
(cont'd)<br />
Common<br />
Name Latin Name COSEWIC SARA<br />
wolverine Gulo gulo Special<br />
Concern<br />
No<br />
Schedule:<br />
No Status<br />
Observed<br />
During<br />
Surveys<br />
no<br />
Ecosite<br />
Phase or<br />
Wetlands<br />
Type<br />
Base Case<br />
Area<br />
(ha)<br />
Loss/Alteration<br />
Due to the<br />
<strong>Project</strong> Closure (a)<br />
Net Change Due to the<br />
<strong>Project</strong> (b)<br />
April 2010 Shell Canada Limited 13-34<br />
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%<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
Area<br />
(ha)<br />
% of<br />
LSAs<br />
% of<br />
Resource<br />
e3** 360 1 -148 -
TERRESTRIAL AENV SIRS 44 – 78<br />
Question No. 60<br />
Request Volume 2, SIR 418, Page 23-35.<br />
Section 13.1<br />
Shell states Bird species, such as black-throated green warbler or barred owl,<br />
differ from mammals in that they are highly mobile, and often have smaller home<br />
ranges. Thus bird species can be expected to be less affected by fragmentation at<br />
the scale of a mineable oil sands project. Barred owl is listed as Sensitive<br />
provincially and is considered to be sensitive to fragmentation and habitat<br />
alteration (Status of the Barred Owl (Strix varia) in Alberta, Alberta Status<br />
Wildlife Report No. 56, 2005). This document states Habitat loss and<br />
fragmentation resulting from industrial development threaten this old-growth<br />
dependent species. Further, Shell chose barred owl as one if its Key Indicator<br />
Resources.<br />
Black-throated green warbler is on the “Blue list” of species that may be at risk<br />
in Alberta. Due to habitat loss and population declines in some areas (Status of<br />
the Black-throated Green Warbler (Dendroica virens) in Alberta, Alberta Status<br />
Wildlife Report No. 23, 1999).<br />
In discussion with Anne Hubbs with respect to fragmentation and Shell’s<br />
rationale stated above, she references habitat modeling work done by university<br />
professors (Fiona Schiegelow and Steve Cumming) for the Al-Pac FMA (as part<br />
of the company's DFMP requirements) based on relatively extensive data-sets.<br />
Page 15 of the report for SRD states The coarse-scale models showed that the<br />
presence or absence of these species within large (~100 ha) contiguous patches<br />
of presumably suitable old-forest habitat was related to the abundance and<br />
distribution of this habitat within the surrounding 10,000 ha landscape, and was<br />
negatively related to the density of industrial infrastructure (wells) and linear<br />
features (roads and pipelines) within these landscapes. Notably, the probability<br />
of detection of BGNW and BBWA within large contiguous patches of old forest<br />
habitat, was significantly related to measures of industrial activity (BBWA and<br />
BGNW) or total habitat abundance (BGNW) at the landscape scale.<br />
60a Provide further explanation for the assertion that smaller home ranges and<br />
increased mobility would translate into a species being less affected by<br />
fragmentation at the scale of a mineable oil sands project. Provide peerreviewed<br />
literature to support the assertion.<br />
Response 60a Many factors interact to determine how habitat fragmentation affects wildlife<br />
species. In general, it seems that direct habitat loss should have the dominant<br />
effect on wildlife species richness until the area of natural habitat declines below<br />
a threshold of about 30% or less (Andrén 1994; Fahrig 1998; Betts et al. 2007).<br />
Below this threshold, factors such as patch size and isolation/connectivity are<br />
more likely to affect species richness.<br />
Birds with small home ranges should exhibit fewer effects as a result of<br />
reductions in patch size (Schmiegelow and Mönkkönen 2002). It is intuitive that<br />
as long as habitat patches are large relative to individual home ranges, there<br />
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References<br />
Section 13.1<br />
should be fewer effects of habitat fragmentation. Species with smaller home<br />
ranges should therefore be better able to tolerate reductions in patch size above<br />
some threshold. Highly mobile species such as migrants (i.e., black-throated<br />
green warbler) or large predatory birds (i.e., barred owl) should be more resistant<br />
to increases in the distance between patches (D’Eon et al. 2002). Highly mobile<br />
species are able to utilize more isolated patches, and are likely to view the<br />
landscape as more connected than less mobile species (Andrén 1994; Fahrig<br />
1998).<br />
In the boreal forest, birds may be more resilient to habitat fragmentation because<br />
of historically high rates of natural disturbance (Schmiegelow et al. 1997). Most<br />
of the effects of landscape change appear to be a result of habitat loss, rather than<br />
habitat fragmentation (Schmiegelow et al. 2002). Where changes in bird species<br />
richness or abundance in association with habitat fragmentation have been<br />
documented, these changes have been largely attributed to increases in predation<br />
and nest parasitism near habitat edges (Schmiegelow et al. 1997). However,<br />
increased predation and nest parasitism in association with fragmentation has<br />
only been documented in the boreal forest when studies were conducted in<br />
agricultural landscapes (Schmiegelow et al. 1997; Bayne and Hobson 1997).<br />
Disturbances that do not create habitat that favours predators or nest parasites<br />
should therefore result in reduced effects of habitat fragmentation (Schmiegelow<br />
et al. 1997, 2002).<br />
In the preamble, there is discussion of a documented negative relationship<br />
between the probability of barred owl or black-throated green warbler detection<br />
and industrial disturbances. However, it is unclear whether it is habitat<br />
fragmentation (e.g., decreased patch size, increased patch isolation) or other<br />
confounding factors such as noise, light, human activity and dust that are<br />
responsible for observed changes in detection probability. This relationship is<br />
interesting, although the report by Schmiegelow and Cumming referenced in the<br />
question is currently not peer-reviewed or publicly available.<br />
Andrén, H. 1994. Effects of habitat fragmentation on birds and mammals in<br />
landscapes with different proportions of suitable habitat: a review. Oikos<br />
71: 355-366.<br />
Bayne, E. M., and K. A. Hobson. 1997. Comparing the effects of landscape<br />
fragmentation by forestry and agriculture on predation of artificial nests.<br />
Conservation Biology 11: 1418–1429.<br />
Betts, M.G., G.J. Forbes and A.W. Diamond. 2007. Thresholds in songbird<br />
occurrence in relation to landscape structure. Conservation Biology<br />
21(4): 1046-1058.<br />
D’Eon, R.G., S.M. Glenn, I. Parfitt and M.-J. Fortin. 2002. Landscape<br />
connectivity as a function of scale and organism vagility in a real<br />
forested landscape. Conservation Ecology 6(2): 10.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Fahrig, L. 1998. When does fragmentation of breeding habitat affect population<br />
survival? Ecological Modelling 105: 273-292.<br />
Schmiegelow, F.K.A., C.S. Machtans and S.J. Hannon. 1997. Are boreal birds<br />
resilient to forest fragmentation? An experimental study of short-term<br />
community responses. Ecology 78(6): 1914-1932.<br />
Schmiegelow, F.K.A. and M. Mönkkönen. 2002. Habitat loss and fragmentation<br />
in dynamic landscapes: avian perspectives from the boreal forest.<br />
Ecological Applications 12(2): 375-389.<br />
Request 60b Provide support for the assertion that these two species (black-throated green<br />
warbler and barred owl) would reflect the entire bird community’s response to<br />
fragmentation. Use peer-reviewed literature to support the discussion.<br />
Response 60b Black-throated green warbler and barred owl would not represent the entire bird<br />
community’s response to habitat fragmentation. Most bird species in the boreal<br />
forest are expected to be relatively insensitive to forest fragmentation as long as<br />
habitat is abundant regionally (Schmiegelow et al. 1997). However, evidence<br />
does suggest that black-throated green warbler (Schmiegelow et al. 1997;<br />
Hobson and Bayne 2000) and barred owl (Russell 2008) may be sensitive to<br />
forest fragmentation. As such, black-throated green warbler and barred owl<br />
function as suitable proxies for the bird communities within the local study areas<br />
(LSAs), which in general should be less sensitive to habitat fragmentation than<br />
these key indicator resources (KIRs). Fragmentation effects are expected to be<br />
most pronounced in agricultural landscapes, where disturbances create habitat<br />
that favours predators and nest parasites (Bayne and Hobson 1997; Schmiegelow<br />
et al. 1997, 2002). Disturbances such as forest clearing are less likely to create<br />
habitat for predators and nest parasites, and therefore should result in reduced<br />
effects of habitat fragmentation on neighbouring bird communities (Schmiegelow<br />
et al. 2002).<br />
References<br />
Bayne, E. M., and K. A. Hobson. 1997. Comparing the effects of landscape<br />
fragmentation by forestry and agriculture on predation of artificial nests.<br />
Conservation Biology 11: 1418–1429.<br />
Hobson, K.A. and E. Bayne. 2000. Effects of forest fragmentation by agriculture<br />
on avian communities in the southern boreal mixedwoods of western<br />
Canada. Wilson Bulletin. 112(3): 373-387.<br />
Russell, M.S. 2008. Habitat selection of barred owls (Strix varia) across multiple<br />
spatial scales in a boreal agricultural landscape in north-central Alberta.<br />
MSc Thesis. University of Alberta, Edmonton.<br />
Schmiegelow, F.K.A., C.S. Machtans and S.J. Hannon. 1997. Are boreal birds<br />
resilient to forest fragmentation? An experimental study of short-term<br />
community responses. Ecology 78(6): 1914-1932.<br />
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Section 13.1<br />
Schmiegelow, F.K.A. and M. Mönkkönen. 2002. Habitat loss and fragmentation<br />
in dynamic landscapes: avian perspectives from the boreal forest.<br />
Ecological Applications 12(2): 375-389.<br />
Request 60c Provide a fragmentation analysis for barred owl and black-throated green<br />
warbler as the KIRs chosen by Shell or provide fragmentation analyses for a<br />
suitable proxy including a reasonable biological rationale that supports its use<br />
as a proxy.<br />
Response 60c A fragmentation analysis was performed for barred owl and black-throated green<br />
warbler at the regional study area (RSA) scale (see Table AENV 60-1). Because<br />
a raster approach was used, the total area of linear disturbances had to be<br />
overestimated to ensure their representation on the landscape. This was necessary<br />
for the analysis of fragmentation, but results in an overestimation of habitat loss.<br />
In the Application Case, the number of high-quality habitat patches for blackthroated<br />
green warbler and barred owl decline by 1% relative to the Base Case.<br />
The average size of high-quality habitat patches for these key indicator resources<br />
(KIRs) decreases by less than 1%, while core area decreases by about 1% relative<br />
to Base Case conditions. The mean distance between predicted high-quality<br />
patches increases by about 1% for black-throated green warbler and barred owl in<br />
the Application Case (Table AENV 60-1).<br />
From Base Case to the Planned Development Case (PDC) for black-throated<br />
green warbler, high-quality habitat patches decrease by 6% in number, less than<br />
1% in average size and 8% in core area. The mean distance between predicted<br />
high-quality habitat patches for black-throated green warbler increases by 4% in<br />
the PDC relative to the Base Case (Table AENV 60-1).<br />
From the Base Case to the PDC for barred owl, the number of high-quality<br />
habitat patches decreases by 7% and the core area of high-quality habitat patches<br />
decreases by 6%. The average size of high-quality habitat patches for barred owl<br />
increases by less than 1%, suggesting that planned developments are affecting<br />
smaller patches on average. The mean distance between high-quality habitat<br />
patches for barred owl increases by 3% from the Base Case to the PDC (Table<br />
AENV 60-1).<br />
Fragmentation is predicted to be negative in direction, and low in magnitude for<br />
black-throated green warbler and barred owl in the PDC. The results of<br />
fragmentation analyses for black-throated-green warbler and barred owl do not<br />
alter the assessed environmental consequences of the project for these KIRs. In<br />
the PDC, the project was assessed as having a low environmental consequence<br />
on black-throated green warbler and barred owl habitat (EIA, Volume 5, Section<br />
7.6-3.1, Table 7.6-9, p. 7-149).<br />
Habitat fragmentation analysis was not conducted at the local study area (LSA)<br />
level for the project as site clearing for the development will occur as two patches<br />
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Section 13.1<br />
accounting for approximately 64% of the LSAs. Therefore, fragmentation is not a<br />
relevant measure for wildlife at the LSA scale.<br />
Table AENV 60-1: Predicted Key Indicator Resource Habitat Fragmentation Effects for the<br />
Base Case, Application Case and Planned Development Case in the Regional Study Area<br />
Net Change From Base Case<br />
to PDC<br />
Base Case Application Case<br />
Key Indicator<br />
MPS TCA ENN_MN<br />
MPS TCA ENN_MN NP MPS TCA<br />
Resource NP (ha) (ha) (m) NP (ha) (ha) (m) (%) (%) (%)<br />
blackthroated<br />
nil<br />
low<br />
6,748<br />
13,391<br />
110<br />
77<br />
467,305<br />
660,535<br />
222<br />
80<br />
6,577<br />
13,104<br />
115<br />
78<br />
485,949<br />
655,485<br />
223<br />
81<br />
-18<br />
-8<br />
36<br />
3<br />
21<br />
-3<br />
4<br />
3<br />
green<br />
warbler<br />
moderate<br />
high<br />
8,775<br />
11,177<br />
29<br />
22<br />
109,753<br />
72,065<br />
142<br />
143<br />
8,726<br />
11,043<br />
29<br />
22<br />
109,515<br />
71,084<br />
143<br />
144<br />
-10<br />
-6<br />
3<br />
>-1<br />
-6<br />
-8<br />
6<br />
4<br />
barred<br />
owl<br />
nil 6,748 110 467,305 222 6,577 115 485,949 223 -18 36 21 4<br />
low 13,573 80 702,165 77 13,301 81 696,600 78 -8 3 -4 2<br />
moderate 7,126 27 83,209 162 7,079 27 82,971 164 -11 3 -7 7<br />
high 11,197 22 74,788 138 11,070 22 74,149 139 -7
TERRESTRIAL AENV SIRS 44 – 78<br />
References<br />
Section 13.1<br />
bird nesting period which is typically April 1 to August 30 (Environment Canada<br />
2006; FAN 2007). Thus, clearing typically occurs outside of this nesting period<br />
(i.e., in September to March), as stated in EIA, Volume 5, Section 7.1.3, page<br />
7-10.<br />
Birds of prey are protected under the Alberta Wildlife Act (AWA) which states<br />
that a “person shall not wilfully molest, disturb or destroy a house, nest or den of<br />
prescribed wildlife... in prescribed areas and at prescribed times” (Government of<br />
Alberta 2000). Owls do not have specific provisions under the AWA, and Alberta<br />
Sustainable Resources Development (ASRD) is developing guidelines to address<br />
habitat and protection needs of sensitive species (A. Hubbs, 2009, pers. comm.).<br />
Shell recognizes that there are potential impacts on owl nests, and has included<br />
the potential impact within the EIA analysis. Shell is committed to conducting<br />
the pre-clearing nest surveys as required by the MBCA and AWA, and the<br />
primary mitigation for compliance is to conduct clearing outside of the main<br />
migratory bird nesting period which is typically April 1 to August 30<br />
(Environment Canada 2006; FAN 2007).<br />
Environment Canada. 2006. Submissions of the Government of Canada. The<br />
Joint Review Panel Established by the Alberta Energy and Utilities<br />
Board and the Canadian Environmental Assessment Agency. Kearl Oil<br />
Sands <strong>Project</strong>, Imperial Oil Resources Ventures Limited. Available<br />
online at<br />
http://www.ceaa.gc.ca/050/documents_staticpost/cearref_16237/KR-<br />
0029.pdf. Assessed October 23, 2009.<br />
FAN (Federation of Alberta Naturalists). 2007. The Atlas of Breeding Birds of<br />
Alberta: A Second Look. 626 pp.<br />
Government of Alberta. 2000. Wildlife Act. R.S.A. 2000, c. W-10. Current to<br />
June 4, 2009. Sustainable Resource Development. 65 pp.<br />
Government of Canada. 1994. Migratory Birds Convention Act, 1994. S.C.,<br />
1994, c. 22. Current to September 17, 2009. Published by the Minister of<br />
Justice. 54 pp.<br />
Hubbs, A. 2009. (Fish and Wildlife Management, Alberta Sustainable Resource<br />
Development, Rocky Mountain House). Personal communication with<br />
Amy Darling (Golder Associates Ltd.) on October 22, 2009.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Question No. 62<br />
Section 13.1<br />
Request Volume 2, SIR 441a, Page 23-90 ; Volume 2, SIR 457a, Page 23-90 ; EIA<br />
Volume 5, Appendix 5-4, Section 1.3.12, Page 80.<br />
In their response to SIRs 441a and 457a Shell states that habitat loss is not<br />
necessarily directly linked to a direct reduction in the abundance of wildlife<br />
KIRs. Population abundance and habitat suitability are not directly tied because<br />
many other factors are also important.<br />
One of the other factors that Shell suggests affects population abundance is<br />
carrying capacity. Shell offers moose as an example of a species that will not<br />
suffer population decreases due to habitat loss since the carrying capacity of the<br />
surrounding habitat has not been reached. Shell states that when moose are<br />
displaced from the LSA the moose density in surrounding area would double to<br />
0.44 moose/km 2 . This density is slightly higher than the highest density reported<br />
in the oil sands region but just 22% of the carrying capacity put forward by<br />
Crete (1987) and Messier (1994) (Page 23-128).<br />
In the original EIA Volume 5, Appendix 5-4; Section 1.3.12, Page 80, Shell<br />
predicts that In the PDC, [moose] populations increase from an initial density of<br />
0.21 to 0.71 moose/km 2 .<br />
62a Given that Shell acknowledges the estimate of moose density put forward by<br />
Crete and Messier was an estimate for North America, not northern Alberta, and<br />
for a predator-free environment, which is not the case in the RSA, describe the<br />
applicability of the Crete and Messier estimate to the habitat surrounding the<br />
LSA.<br />
Response 62a The Messier (1994) estimate of two moose per km 2 is appropriate for habitat<br />
surrounding the local study area (LSA), as this is the best estimate available for a<br />
food-limited population density equilibrium. A food-limited population density is<br />
a useful reference point, as harvest and predation rates may be affected by<br />
wildlife management. Although the estimate of population equilibrium put<br />
forward by Messier (1994) was produced including data from across North<br />
America, most selected studies were from northern coniferous forest, including<br />
two studies from northern Alberta, and are the best estimates available.<br />
Reference<br />
Messier, F. 1994. Ungulate population models with predation: a case study with<br />
the North American moose. Ecology. 75: 478-488.<br />
Request 62b What evidence is available that indicates the surrounding environment is<br />
currently underexploited by moose?<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Response 62b Evidence that the habitat surrounding the LSA may be underexploited by moose<br />
comes from population density estimates and known mortality sources in the<br />
region. Moose density in the Jackpine <strong>Mine</strong> Expansion local study area (LSA)<br />
was calculated at 0.22 moose/km 2 (Golder 2007). Moose population density<br />
estimates for Moose Management Areas (MMAs) 8 and 9 (about half the<br />
regional study area [RSA] falls into each Management Area) have ranged from<br />
0.10 moose/km 2 (wildlife management unit [WMU] 540, survey year 1993/1994)<br />
to 0.62 moose/km 2 (WMU 525, survey year 1995/1996) (ASRD 2002). Moose<br />
hunting is a very common activity in the RSA (ASRD 2009), and likely has<br />
reduced moose populations. Annual regulated harvest from WMUs in the RSA is<br />
about 100 per year (e.g., 104 in 2008, 106 in 2007). In addition, moose are a<br />
staple for First Nations in the region and their unregulated harvest is likely<br />
substantive. Finally, moose are the primary prey species for wolves in the region<br />
(James et al. 2004).<br />
References<br />
There has been a documented relationship of increasing moose populations with<br />
increasing levels of human development in northern Alberta (Schneider and<br />
Wasel 2000). This has been hypothesized to be due to lower predation and<br />
hunting pressure near areas of extensive human development in Alberta, as well<br />
as increasing forage availability with increasing forest fragmentation (Schneider<br />
and Wasel 2000). Mean moose population density in the White Zone of northern<br />
Alberta has been estimated to be about 0.50 moose/km 2 (Schneider and Wasel<br />
2000). Moose populations in the Oil Sands Region may be able to reach this level<br />
or higher, depending on wildlife management actions and the trajectory of<br />
landscape change.<br />
ASRD (Alberta Sustainable Resource Development). 2002. Northern Moose<br />
Management Program: moose population surveys. Available online at:<br />
http://www.srd.alberta.ca/ManagingPrograms/FishWildlifeManagement/<br />
NorthernMooseManagementProgram/MoosePopulationSurveys.aspx.<br />
Accessed November 10, 2009.<br />
ASRD (Alberta Sustainable Resource Development). 2009. Resident hunter<br />
harvest.<br />
http://www.mywildalberta.com/Hunting/GameSpecies/ResidentHunters<br />
Harvest.aspx. Accessed October 30, 2009.<br />
Golder (Golder Associates Ltd.). 2007. Wildlife and Wildlife Habitat<br />
Environmental Setting Report for the Jackpine <strong>Mine</strong> Expansion & <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. Prepared for Shell Canada Limited. Calgary, AB.<br />
Submitted December 2007.<br />
James, A.R.C., S. Boutin, D.M. Hebert, and A.B. Rippin. 2004. Spatial<br />
separation of caribou from moose and its relation to predation by wolves.<br />
Journal of Wildlife Management 68: 799-809.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Schneider, R.R. and S. Wasel. 2000. The effect of human settlement on the<br />
density of moose in northern Alberta. The Journal of Wildlife<br />
Management 64(2): 513-520.<br />
Section 13.1<br />
Request 62c Clarify what the predicted density of moose is for the LSA and RSA in the Base<br />
Case and Application Case.<br />
Response 62c The densities of moose in the RSA in the Base Case and Application Case were<br />
estimated to be 0.23 moose/km 2 initially. Population densities in the Base Case<br />
and Application Case were projected to increase to 0.78 and 0.74 moose/km 2 ,<br />
respectively (EIA, Volume 5, Appendix 5-4, Section 3.3.1.2, p. 80).<br />
References<br />
Uncertainty is always present in estimates of survival rates, fecundity rates and<br />
population density estimates. Because this uncertainty, the general consensus<br />
among population ecologists is that relative results of Population Viability<br />
Analysis (PVA), either from sensitivity analyses or comparisons among<br />
landscape scenarios, are more reliable for assessing effects than absolute results<br />
(McCarthy et al. 2003; Schtickzelle et al. 2005). Therefore, absolute results from<br />
a PVA, such as a population density, should not be given undue attention.<br />
Uncertainty in demographic rates is explicitly explored in sensitivity analyses,<br />
where vital rates within the PVA were decreased by an additional 10% to 20%<br />
(EIA, Volume 5, Appendix 5-4, Section 3.3.1). The result of sensitivity and<br />
effects analysis was that the estimated negative effects of the project on moose<br />
populations within the study area were very small, and did not alter population<br />
trajectory (EIA, Volume 5, Appendix 5-4, Section 3.3.1, Figure 32).<br />
McCarthy, M. A., S. J. Andelman, and H. P. Possingham. 2003. Reliability of<br />
Relative Predictions in Population Viability Analyses. Conservation<br />
Biology 17: 982-989.<br />
Schtickzelle, N., M. F. Wallis De Vries, and M. Baguette. 2005. Using Surrogate<br />
Data in Population Viability Analysis: The Case of the Critically<br />
Endangered Cranberry Fritillary Bitterfly. Oikos 109: 89-100.<br />
Request 62d Provide an explanation as to why Shell believes the surrounding area is not<br />
currently at carrying capacity for moose and therefore would be able to absorb<br />
and support a doubling of the moose population to a density slightly more than<br />
the highest density reported in the oil sands region to date (>0.43 moose/km2)<br />
Response 62d See the response to AENV SIR 62b.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Request 62e What are the habitat characteristics or features of the surrounding area that<br />
might enable it to support higher densities of moose than have been recorded<br />
anywhere else in the oil sands region?<br />
Response 62e As outlined in the response to AENV SIR 62a and b, habitat is unlikely to be<br />
limiting moose populations in the region. There are many factors besides habitat<br />
that are capable of regulating moose populations. Predation and human harvest<br />
are likely to have influenced historical moose population density in the Oil Sands<br />
Region. These factors are subject to change as management actions are capable<br />
of regulating harvest and predation pressures. Increasing human development<br />
may result in lower predation and harvest rates, as well as increasing forage<br />
availability through habitat fragmentation, leading to a higher moose population<br />
density (Schneider and Wasel 2000).<br />
Reference<br />
Schneider, R.R. and S. Wasel. 2000. The effect of human settlement on the<br />
density of moose in northern Alberta. The Journal of Wildlife<br />
Management 64(2): 513-520.<br />
Request 62f For what timeframe does Shell anticipate the surrounding environment could<br />
support the displaced moose from the LSA, resulting in moose densities as high<br />
as 0.44 moose/km2? Provide any evidence available to support Shell’s expected<br />
timeframe.<br />
Response 62f A population density equilibrium because of food limitation is likely much<br />
higher than 0.2 moose/km 2 (Messier 1994; Messier and Joly 2000). In addition,<br />
increased forest fragmentation in the regional study area (RSA) may further<br />
boost the productivity of moose habitat. Therefore, carrying capacity of the<br />
surrounding environment is unlikely to affect the time frame that elevated moose<br />
densities are maintained. It is likely that current low population densities in the<br />
RSA are because of a combination of human harvest and predation as described<br />
in the response to AENV SIR 62b. The time frame in which an elevated moose<br />
population density can be maintained will depend more on the regulation of<br />
human harvest and regional predator management actions.<br />
References<br />
Messier, F. 1994. Ungulate population models with predation: a case study with<br />
the North American moose. Ecology. 75: 478-488.<br />
Messier, F. and D.O. Joly. 2000. Comment: regulation of moose populations by<br />
wolf predation. Canadian Journal of Zoology 78: 506-510.<br />
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Question No. 63<br />
Request Volume 2, SIR 441a-b, Page 23-89.<br />
Section 13.1<br />
Shell’s response states the impacts of [on] wildlife abundance as a consequence<br />
of habitat loss over the 80-year project timeline were not generally discussed<br />
because habitat loss is not necessarily directly liked to a direct reduction in the<br />
abundance of wildlife KIRs. While there may be both direct and indirect links to<br />
a direct or indirect reduction in abundance, the characterization of the links and<br />
reduction source are not critical to the discussion and in this case seem to have<br />
obscured the answer. There are clear biological pathways between habitat loss<br />
and reduced abundance.<br />
Shell indicates that the overall local and regional environmental consequence on<br />
hunting because of site clearing effects are predicted to be negligible and directs<br />
the reviewer to Volume 5, Section 8.4.6.3, page 107 of the EIA. This section<br />
indicates that in the long-term, habitat will be restored with a potentially positive<br />
effect on moose as described. Wildlife abundance must be managed in the<br />
interim time period prior to the long-term goal of habitat restoration. This<br />
period may be up to 80 years.<br />
63a Provide a general discussion of the impacts on fish and wildlife abundance as a<br />
consequence of habitat loss over the 80-year project timeline, both from a<br />
<strong>Project</strong> perspective and a cumulative perspective. Discuss the fish and wildlife<br />
management implications and potential challenges of any expected changes in<br />
abundance.<br />
Response 63a The loss of fish habitat as a result of the project will be compensated for with the<br />
development of a compensation lake and stream channel habitats (EIA,<br />
Volume 4, Appendix 4-6). The compensation habitat for fish would be developed<br />
as habitat losses occur, and therefore substantial delays from when habitat is lost<br />
to when new habitat is available are not anticipated. As a result of mitigation<br />
measures and the planned compensation habitat, changes to regional fish<br />
abundance because of the project under the Application Case were considered to<br />
be negligible (EIA, Volume 4, Section 6.7.6.3). The Application Case for fish<br />
and fish habitat assessed in the EIA is a cumulative assessment as it assesses all<br />
residual impacts for the project in combination with potential impacts associated<br />
with all existing and approved developments (EIA, Volume 4, Section 6.7.6.2).<br />
Changes in wildlife abundance as a result of habitat loss are difficult to predict<br />
because abundance is controlled by many factors that may operate independently<br />
from habitat abundance (Garshelis 2000). For example, historical events, habitat<br />
quality, weather, disease, parasites, predators, and human harvest may all affect<br />
wildlife abundance, but are not necessarily linked directly to habitat abundance<br />
(Levin 1998). Habitat loss is likely to lead to direct reductions in species<br />
abundance only when the availability of habitat is reduced to the point that it<br />
becomes a limiting factor (i.e., when a population density equivalent to carrying<br />
capacity is reached).<br />
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As long as habitat is abundant regionally, habitat loss may not result in<br />
population declines. This assumes that population size directly tied to habitat<br />
abundance represents a ‘worst case scenario’. Population viability analyses<br />
(PVAs) were conducted for moose and black bear under the assumption that<br />
initial and carrying capacity population densities were fixed, and therefore loss of<br />
quality habitat would result in a decrease in population size (EIA, Volume 5,<br />
Appendix 5-4, Section 3.2, p. 77). Results suggest about a 2% population decline<br />
for moose, and a less than 1% decline for black bears as a result of the project. In<br />
the Planned Development Case (PDC), PVA results suggest about an 8% decline<br />
in the initial population size of moose within the regional study area (RSA), and<br />
a 9% decline in carrying capacity (EIA, Volume 5, Section 7.6.3.1, p. 7-143). For<br />
black bear, results of the PVA for the PDC estimate a reduction in initial and<br />
carrying capacity population sizes of about 4% (EIA, Volume 5, Section 7.6.3.1,<br />
p. 7-143).<br />
Whether landscape changes in the RSA as a result of the Application Case and<br />
the PDC have implications or potential challenges for fish and wildlife<br />
management depends on a variety of factors. For example, combined harvest and<br />
predation rates may affect fish and wildlife populations if population losses<br />
exceed recruitment. As has been the case since humans began harvesting fish and<br />
wildlife, monitoring is required and harvest rates need to be regularly evaluated<br />
to ensure that harvests remain sustainable. In addition to sources of mortality, the<br />
management of fish and wildlife populations may include manipulating factors<br />
that affect recruitment. For example, changes to the terrestrial landscape that<br />
result in species-specific habitat enhancements may benefit target species of<br />
management interest. Increased forest harvest associated with forestry and oil<br />
and gas development results in a landscape more suitable for moose and deer,<br />
both harvested species. Ultimately, objectives and strategies for the management<br />
of fish and wildlife populations at the RSA scale are the responsibility of the<br />
Alberta government.<br />
Request 63b Shell states that population abundance and habitat suitability are not directly<br />
tied because many other factors are also important. The original question asked<br />
about abundance and habitat loss not habitat suitability. Discuss changes to<br />
abundance as a result of habitat loss at both project and regional/cumulative<br />
level.<br />
Response 63b The abundance of wildlife populations are controlled by many factors that may<br />
operate independently from habitat abundance (Garshelis 2000). For example, all<br />
habitat is not of equal value in terms of mortality risk, the abundance of food, and<br />
overall productivity (van Horne 1983). As such, habitat quality is an important<br />
consideration when attempting to relate habitat loss to changes in wildlife<br />
abundance. The loss of low-quality, unproductive habitat is less likely to affect a<br />
population than the loss of high-quality habitat. Changes to fish and wildlife<br />
abundance as a result of habitat loss at the project and cumulative level are<br />
discussed in the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information,<br />
Volume 2, SIR 63a and take these considerations into account.<br />
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References<br />
Section 13.1<br />
Garshelis, D.L. 2000. Delusions in habitat evaluation: Measuring use, selection<br />
and importance. Pp. 111-164 in Research techniques in animal ecology,<br />
controversies and consequences. L. Boitani and T. K. Fuller (eds).<br />
Columbia University Press, New York.<br />
van Horne, B. 1983. Density as a Misleading Indicator of Habitat Quality.<br />
Journal of Wildlife Management 47(4): 893-901.<br />
Request 63c With respect to the discussion of moose and carrying capacity, Shell suggests<br />
that most moose will be displaced and that it is expected that moose density in<br />
the surrounding areas would double to 0.44 moose/km2. Is Shell asserting that<br />
this density doubling (greater than the highest density of 0.43 moose/km2<br />
reported earlier in the discussion) will remain for the 80-year period during<br />
which the project will displace moose? If not, and it is expected that moose<br />
densities will revert to existing levels, a reduction in abundance would be<br />
expected since density is area based. Discuss.<br />
Response 63c Population density is controlled by many factors that may operate independently<br />
of habitat abundance. Moose population density could be maintained at high<br />
levels (e.g., 0.44 moose/km 2 ) for the 80-year period before project reclamation.<br />
However, the factors controlling moose population densities within intact habitat<br />
beyond the lease boundaries are largely outside of Shell’s control. Moose<br />
population densities within the regional study area (RSA) may be strongly<br />
affected by wildlife management activities, as well as regional land use activities.<br />
References<br />
Crete (1987) and Messier (1994) have suggested that a food-limited carrying<br />
capacity for moose in North America is about 2 moose/km 2 . Site-specific<br />
carrying capacities will vary as a result of such factors as habitat quality, while<br />
population densities may be suppressed by harvest and predation. For example,<br />
there has been a documented relationship of increasing moose populations with<br />
increasing levels of human development in northern Alberta (Schneider and<br />
Wasel 2000). This has been hypothesized to be associated with lower predation<br />
and hunting pressure near areas of extensive human development in Alberta, as<br />
well as increasing forage availability with increasing forest fragmentation<br />
(Schneider and Wasel 2000). Mean moose population density in the White Zone<br />
of northern Alberta has been estimated to be about 0.50 moose/km 2 (Schneider<br />
and Wasel 2000). Moose populations in the Oil Sands Region may be able to<br />
reach this level or higher, depending on wildlife management actions and the<br />
trajectory of landscape change.<br />
Crete, M. 1987. The impact of sport hunting on North American moose. Swedish<br />
Wildlife Research Supplement 1: 553-563.<br />
Messier, F. 1994. Ungulate population models with predation: a case study with<br />
the North American moose. Ecology 75: 478-488.<br />
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Schneider, R.R. and S. Wasel. 2000. The effect of human settlement on the<br />
density of moose in northern Alberta. The Journal of Wildlife<br />
Management 64(2): 513-520.<br />
Section 13.1<br />
Request 63d Discuss the shift in fish relative abundance as a consequence of the project<br />
impacts and cumulative impacts (much of the proposed compensation habitat is<br />
different and will support alternate species assemblages and relative abundance<br />
than the habitat being compensated for).<br />
Response 63d As described in EIA, Volume 4, Section 6.7.6.3, the assessment of potential<br />
effects on fish habitat and fish abundance determined that the project will result<br />
in changes in habitat area throughout the development area. However, changes in<br />
area because of the loss of watercourse segments and waterbodies in the<br />
development area will be offset by developing habitat in the compensation lake<br />
and closure diversion channels, as described in the Conceptual Compensation<br />
Plan (CCP) (EIA, Volume 4, Appendix 4-6). All of the fish species that will be<br />
affected by the project will have suitable habitat developed as part of the<br />
compensation plan.<br />
Question No. 64<br />
The development of the compensation lake is expected to result in an increase in<br />
fish habitat productivity in the area based on providing a 2:1 compensation ratio<br />
and the conservative assumptions of species distribution within the affected<br />
habitats, which has the potential to increase fish abundance and positively affect<br />
fish species diversity in the region. The fish community that is proposed for the<br />
compensation lake habitat and closure diversion channels is expected to provide<br />
a similar or greater abundance of the same species assemblage currently present<br />
in the watercourse segments and waterbodies affected by the project. In addition,<br />
the proposed compensation will allow for development of new fish populations<br />
not currently present in the affected watersheds, such as lake whitefish, in order<br />
to increase species diversity and trophic complexity. The final compensation lake<br />
species assemblage is being developed in consultation with regulators, First<br />
Nations and Métis. The relative compensation habitat gained for each species<br />
will be identified through habitat modelling and will be provided in the detailed<br />
No Net Loss Plan.<br />
Request Volume 2, SIR 441b, Page 23-91.<br />
Shell states that for the period of operations (25 to 50 years) wildlife will be<br />
displaced to surrounding habitat, including movement corridors along river<br />
valleys and escarpments.<br />
64a Is Shell arguing that these displaced individuals will result in increased<br />
abundance of wildlife in the remaining habitat for 25 to 50 years? If so, provide<br />
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Section 13.1<br />
peer-reviewed literature that would support this assertion. Clearly articulate the<br />
ecological theory that would support the argument.<br />
Response 64a Shell is not suggesting that these displaced individuals will result in increased<br />
abundance of wildlife in the remaining habitat for 25 to 50 years. Wildlife<br />
abundance may increase initially. However, over time the abundance of wildlife<br />
in the adjacent area will change relative to the species-specific carrying capacity<br />
of habitat types in the adjacent landscape. If the surrounding landscape is not at<br />
carrying capacity, then densities may remain higher than before clearing.<br />
However, if the landscape is at carrying capacity or if there are other factors<br />
suppressing wildlife abundance (e.g., predation, hunting), the wildlife densities<br />
may decline to pre-clearing levels over time.<br />
Empirical data demonstrating these relationships are not available for most<br />
wildlife Key Indicator Resources. However, sufficient data are available for<br />
moose. Using moose as an example, moose populations are usually below<br />
carrying capacity of the habitat (i.e., the food-limited population density<br />
equilibrium) because of the effects of other factors (e.g., predation, competition,<br />
human harvest). For example, Messier (1994) and Messier and Joly (2000)<br />
estimated that the presence of wolves was sufficient to suppress moose<br />
population densities from 2.0 moose/km 2 to about 1.3 moose/km 2 , while wolves<br />
and black bears together could suppress population densities to 0.2 to 0.4<br />
moose/km 2 . Human harvest could suppress moose populations further.<br />
There is evidence that the habitat surrounding the local study area (LSA) may be<br />
underexploited by moose. Measured population density within the regional study<br />
area (RSA) of 0.2 is very low relative to the carrying capacity estimate of Crete<br />
(1997) and Messier (1994). Wolves and black bears are present in the RSA, and<br />
are likely suppressing moose population densities well below a food-limited<br />
carrying capacity (Messier 1994, Messier and Joly 2000). Also, moose hunting is<br />
a very common activity in the RSA (ASRD 2009), and likely has reduced moose<br />
populations. Annual regulated harvest from wildlife management units (WMUs)<br />
in the RSA is about 100 per year (e.g., 104 in 2008, 106 in 2007). Moose are a<br />
staple for First Nations in the region and their unregulated harvest is likely<br />
substantive. In addition, there has been a documented relationship in northern<br />
Alberta of increasing moose populations with increasing levels of human<br />
development (Schneider and Wasel 2000). This has been hypothesized to be due<br />
to lower predation and hunting pressure near areas of extensive human<br />
development in Alberta, as well as increasing forage availability with increasing<br />
forest fragmentation (Schneider and Wasel 2000). Mean population density in the<br />
White Zone of northern Alberta has been estimated to be about 0.50 moose/km 2<br />
(Schneider and Wasel 2000), and moose populations in the Oil Sands Region<br />
could reach this level.<br />
Most moose within the LSA will be displaced by habitat loss. Assuming that the<br />
moose density in the surrounding area is similar, when these moose are displaced<br />
to adjacent land of equivalent size, the moose density in the surrounding areas<br />
would double to 0.44 moose/km 2 . This density is slightly greater than the highest<br />
reported density in the Oil Sands Region, but just 22% of the food-limited<br />
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References<br />
Question No. 65<br />
Section 13.1<br />
carrying capacity put forward by Crete (1987) and Messier (1994). The<br />
timeframe in which a moose population density of 0.44 moose/km 2 can be<br />
achieved will depend on regional moose management actions. If wolf densities,<br />
black bear densities and hunting (i.e., licensed and First Nations harvest) are not<br />
regulated, then population densities will likely be reduced to levels present before<br />
the project.<br />
ASRD (Alberta Sustainable Resource Development). 2009. Resident hunter<br />
harvest.<br />
http://www.mywildalberta.com/Hunting/GameSpecies/ResidentHunters<br />
Harvest.aspx. Accessed October 30, 2009.<br />
Crete, M. 1987. The impact of sport hunting on North American moose. Swedish<br />
Wildlife Research Supplement 1:553-563.<br />
Messier, F. 1994. Ungulate population models with predation: a case study with<br />
the North American moose. Ecology. 75: 478-488.<br />
Messier, F. and D.O. Joly. 2000. Comment: regulation of moose populations by<br />
wolf predation. Canadian Journal of Zoology 78: 506-510.<br />
Schneider, R.R. and S. Wasel. 2000. The effect of human settlement on the<br />
density of moose in northern Alberta. The Journal of Wildlife<br />
Management 64(2): 513-520.<br />
Request Volume 2, SIR 450a, Page 23-109.<br />
CEMA used modelling to assess potential impacts of landscape change and<br />
compare different management/mitigation options. From a high level it is<br />
expected that the results of the CEMA SEWG modelling should be similar to<br />
those completed for environmental impact assessments in the area, as both are<br />
intended to provide insight into what the future might hold based on proposed<br />
activity in the regional area. Generally, the CEMA SEWG modelling showed a<br />
decline in wildlife KIR populations as a result of landscape impacts.<br />
65a The modelling presented by Shell largely does not reflect this decline. Discuss<br />
why.<br />
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Section 13.1<br />
Response 65a The modelling approach used in the recent Cumulative Environmental<br />
Management Association (CEMA) Sustainable Ecosystem Working Group<br />
(SEWG) modelling (CEMA SEWG 2008) uses a substantially different approach<br />
and suite of assumptions than the habitat modelling within the EIA. Therefore,<br />
the results are not comparable.<br />
References<br />
The recent CEMA SEWG modelling effort used the Alberta Landscape<br />
Cumulative Effects Simulator model (ALCES) (Forem Technologies 2009) to<br />
compare all estimated changes in wildlife habitat and populations to a ‘natural<br />
range of variability’ (NRV) (Wilson et al. 2008a). The NRV represents an<br />
approximation of the natural state in the decades or centuries before 1905, i.e., a<br />
pre-disturbance baseline (Wilson et al. 2008a). This makes comparisons with<br />
modelling results from the EIA difficult because in the EIA all landscape changes<br />
are expressed relative to a Base Case that approximates current conditions. In<br />
addition, the CEMA SEWG modelling forecasts changes to habitat as a result of<br />
simulated landscape alterations that follow predicted patterns of oil sands<br />
development and reclamation, forest harvesting, and fire (Wilson et al. 2008b).<br />
Patterns of oil sands development were simulated by translating a bitumen<br />
production forecast provided by the Alberta Energy Resources Conservation<br />
Board (ERCB) into either surface or in situ mine developments, depending on the<br />
scenario (CEMA SEWG 2008). The spatial pattern of development was<br />
simulated to follow locations of greatest anticipated return according to an ERCB<br />
bitumen pay map, i.e., deposit thickness where bitumen accounts for more than<br />
50% of the composition (Wilson et al. 2008b). Although details on simulated<br />
reclamation processes appear lacking in the documentation, patterns apparently<br />
followed trajectories designed to generalize the reclamation trajectories of<br />
existing mine reclamation plans (Wilson et al. 2008b).<br />
ALCES addresses existing, approved and predicted projects for 100 years,<br />
whereas the EIA addresses existing and planned projects disclosed up to six<br />
months before the EIA filing. Outside the LSA, only planned disturbances within<br />
the public domain within six months of the application are represented (i.e., July<br />
2007). As stated in the EIA (EIA, Volume 3, Section 1.3.3 and Errata), projects<br />
disclosed after June 2007, or projects where approvals were issued or plans were<br />
modified following June 2007, were considered in the EIA based on the relevant<br />
information available as of June 2007. In addition, the EIA assessment scenario<br />
does not include progressive reclamation over time, whereas assumptions related<br />
to progressive reclamation were included in the CEMA modelling.<br />
Forem Technologies. 2009. ALCES. Website:<br />
http://www.foremtech.com/home/Home. Accessed January 8, 2009.<br />
CEMA SEWG (Sustainable Ecosystem Working Group of the Cumulative<br />
Environmental Management Association). 2008. Terrestrial ecosystem<br />
management framework for the Regional Municipality of Wood Buffalo.<br />
57 pp. Available online:<br />
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Section 13.1<br />
http://www.cemaonline.ca/component/option,com_docman/task,doc_do<br />
wnload/gid,1484/<br />
Wilson, B., J.B. Stelfox, K. Porter, M. Patriquin, M. Ingen-Housz. 2008a.<br />
Summary of methodology for the development of the terrestrial<br />
ecosystem management framework. 27 pp. Available online:<br />
http://www.cemaonline.ca/component/option,com_docman/task,doc_do<br />
wnload/gid,1486/<br />
Wilson, B., J.B. Stelfox, M. Patriquin. 2008b. SEWG workplan facilitation and<br />
modelling project data inputs and assumptions. 68 pp. Available online:<br />
http://www.cemaonline.ca/component/option,com_docman/task,doc_do<br />
wnload/gid,1487/<br />
Request 65b Discuss which representation most closely approximates what should be<br />
expected and planned for.<br />
Response 65b Due to the great degree of uncertainty contained within the far future scenarios,<br />
and the difficulty of parsing out project-specific contributions to a predevelopment<br />
baseline, the CEMA SEWG approach is not appropriate for use in<br />
an EIA. At the scale of the project, the representation found within the EIA most<br />
closely represents what is likely expected and planned for. However, the far<br />
future planning used in the CEMA SEWG modelling effort does have value as a<br />
long term planning tool for the Province of Alberta.<br />
The CEMA SEWG modelling forecasts changes to habitat for 100 years based on<br />
predicted patterns of forest harvesting and fire, as well as forecasted patterns of<br />
oil sands development and reclamation (Wilson et al. 2008b). Patterns of<br />
development and reclamation were based on ratios of development footprints to<br />
Alberta Energy bitumen production estimates. The rate of footprint development<br />
is dependent on socio-economic factors as well as technological advancements.<br />
Wilson et al. (2008b) acknowledge some of this uncertainty by including an<br />
“Innovative Approaches Scenario”, that uses lower footprint to bitumen<br />
production ratios. However, further uncertainty exists than is recognized by the<br />
range of scenarios, as technological advancements, economic conditions, and<br />
societal tolerances for development are unpredictable. In contrast, the approach<br />
used for the terrestrial assessment of the EIA does not utilize disturbance<br />
scenarios based on high levels of uncertainty. The EIA addresses existing and<br />
planned projects disclosed up to six months before the EIA filing. In addition, the<br />
effects of disturbances on wildlife in the EIA are estimated conservatively by not<br />
including progressive reclamation in the Planned Development Case. Further<br />
development patterns are uncertain, and were not included in the EIA.<br />
For estimating effects to key indicator resources, the CEMA SEWG modelling<br />
effort compared estimated future wildlife habitat and population conditions to<br />
pre-development (Wilson et al 2008a) conditions. In contrast, the EIA compares<br />
habitat and population conditions in each scenario to a Base Case that<br />
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References<br />
Question No. 66<br />
Section 13.1<br />
approximates current conditions. This is done to properly focus the EIA on the<br />
project being proposed.<br />
The CEMA SEWG modelling effort applies very uncertain estimates of changes<br />
to the landscape over the next 100 years, and compares these changes to a predevelopment<br />
scenario. While this effort is an interesting research project and a<br />
useful long-term planning tool for the provincial government, it is not appropriate<br />
for use in an EIA. Future scenarios with too much uncertainty do not facilitate a<br />
realistic and useful impact assessment.<br />
Wilson, B., J.B. Stelfox, K. Porter, M. Patriquin, M. Ingen-Housz. 2008a.<br />
Summary of methodology for the development of the terrestrial<br />
ecosystem management framework. 27 pp. Available online:<br />
http://www.cemaonline.ca/component/option,com_docman/task,doc_do<br />
wnload/gid,1486/<br />
Wilson, B., J.B. Stelfox, M. Patriquin. 2008b. SEWG workplan facilitation and<br />
modelling project data inputs and assumptions. 68 pp. Available online:<br />
http://www.cemaonline.ca/component/option,com_docman/task,doc_do<br />
wnload/gid,1487/<br />
Request Volume 2, SIR 456a & c, Page 23-123.<br />
In Response 456a Shell states The natural areas category used in the<br />
heterogeneity and fragmentation analysis includes all undisturbed and reclaimed<br />
vegetation types … This is distinguished from the human disturbed category used<br />
in the assessment, which included cutblocks, agricultural areas and urban (e.g.,<br />
municipalities and roads) and industrial (e.g., mines, seismic lines, well pads,<br />
and pipelines) developments in the regional or local study areas.<br />
66a Given that ‘natural areas’ is a term generally perceived as implying the area is<br />
undisturbed, provide a justification for including reclaimed areas in the natural<br />
areas category. Discuss the potential for misinterpretation given the<br />
characterization of reclaimed areas as natural.<br />
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Section 13.1<br />
Response 66a Reclaimed areas were included in the natural areas category because Shell is<br />
committed to reclaiming disturbed areas in a manner that supports and maintains<br />
functional ecosystem processes. Shell is confident in its ability to reclaim the<br />
development areas to self-sustaining ecosystems that will meet equivalent land<br />
capability at closure and conditions will be adaptively managed to ensure that the<br />
reclaimed areas are following this expected trajectory. Based on this, the<br />
inclusion of reclaimed areas in the natural areas category is justified and there is<br />
very little potential for misinterpretation.<br />
Question No. 67<br />
Request Volume 2, SIR 456c iii, Page 23-125.<br />
Shell states Shell is confident that upland habitat on overburden dumps will be<br />
reclaimed based on the reclamation certification of Syncrude’s Gateway Hill and<br />
wildlife monitoring results from other reclamation efforts in the Oil Sands<br />
Region.<br />
The Syncrude Gateway Hill reclamation certificate was issued based on older<br />
approval conditions that do not necessarily reflect government’s current<br />
reclamation expectations. Standards have improved over time, and as such,<br />
Shell will be expected to meet current expectations regarding the reclamation of<br />
wildlife habitat.<br />
67a Provide details on how the wildlife monitoring results from other reclamation<br />
efforts in the Oil Sands region support Shell’s assertion that overburden dumps<br />
will be returned to pre-mining function with respect to wildlife habitat. Discuss<br />
the defensibility of the data used to support this assertion.<br />
Response 67a Although the responses to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 2, SIR 456ciii referred to Gateway Hill, Shell recognizes<br />
that the Syncrude Gateway Hill reclamation certificate was issued based on older<br />
approval conditions that do not necessarily reflect government’s current<br />
reclamation expectations. Wildlife monitoring has been conducted on reclaimed<br />
areas, including overburden dumps on Suncor’s Lease 86/17 and<br />
Steepbank/Millennium areas since 1999 (Suncor 2008). The data helps to<br />
determine whether the reclaimed land is returning to a state of equivalent<br />
capability for wildlife. Parameters measured include winter track count surveys,<br />
waterfowl and water bird visual surveys and small mammal surveys.<br />
Surveys on recent reclamation areas provide data on updated approval<br />
conditions, which is more applicable to advanced reclamation standards. Surveys<br />
have indicated that typical boreal species, including fisher marten, white-tailed<br />
deer, coyotes and wolf, are using reclaimed areas. However, species that prefer<br />
mature forest cover (e.g., fisher marten) are not as prevalent in young reclaimed<br />
areas (Suncor 2008). The application of coarse woody debris (CWD) on<br />
reclaimed lands at the Steepbank North Waste Dump (an overburden waste<br />
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References<br />
Question No. 68<br />
Section 13.1<br />
dump) has been monitored as well. The CWD was found to provide desirable<br />
habitat for deer mice as compared to control sites without CWD (Suncor 2008),<br />
thus demonstrating that new approaches to reclamation can provide wildlife<br />
benefits. Advances in reclamation research, wildlife monitoring and the use of<br />
adaptive management are expected to provide improvements in reclamation<br />
techniques and wildlife habitat.<br />
A specific example is Waste Area 8, an overburden dump on Suncor’s Lease<br />
86/17 that was reclaimed 25 years ago (Golder 2004). At its base is a 40 to 50 m<br />
buffer of natural riparian vegetation. A portion of Waste Area 8 was reclaimed in<br />
1984 with overburden, seeded with a barley mix and later planted with white<br />
spruce, pine, poplar, willow, dogwood, rose, buffalo-berry, wolf willow and<br />
saskatoon. In 1987, an additional area was reclaimed using muskeg soil placed<br />
over the overburden subsurface. The site was seeded with a barley nurse crop<br />
onto which white spruce, northwest poplar, lodgepole pine, rose, dogwood,<br />
buffalo-berry, saskatoon and sandbar willow were planted. Waste Area 8 is one<br />
of Suncor’s prominent reclaimed areas due to the presence of wildlife species<br />
typically noted for particular habitat requirements, such as moose, wolf, bear,<br />
wolverine, fisher marten, snowshoe hare and red-backed voles. Breeding bird<br />
species diversity and richness were low in Waste Area 8, with similar values to<br />
those found in the adjacent natural stand. The successful development of<br />
vegetation stands at Waste Area 8 reflects the efforts made to reclaiming it with<br />
native species as well as the area’s proximity to natural stands along the<br />
Athabasca <strong>River</strong> where encroachment of natural vegetation is facilitating the<br />
establishment of wildlife habitat.<br />
Golder. (Golder Associates Ltd.). 2004. Suncor Energy wildlife monitoring<br />
program and wildlife assessment update 1999-2003. Submitted to Suncor<br />
Energy Inc., Fort McMurray, Alberta.<br />
Suncor. (Suncor Energy Inc.). 2008. Firebag 2007 Conservation and Reclamation<br />
Annual Report. Submitted to Alberta Environment. March 2008. 45 pp.<br />
Request Volume 2, SIR 457a, Page 23-127 ; EIA Volume 5, Section 7, Page 7-112 ;<br />
EIA Volume 5, Appendix 5-4, Section 1.2.3, Page 14-24.<br />
In the response to the question of how wildlife abundance is affected by habitat<br />
loss (SIR 457a), Shell makes no mention of how indirect habitat loss caused by<br />
sensory disturbance would affect wildlife abundance. In the original application<br />
(Volume 5, Section 7, Page 7-112), Shell states that … black-throated green<br />
warbler and barred owl habitat was determined using RSF modelling and factors<br />
affecting habitat for these species are explicit in the modelling algorithms. By<br />
applying the model to the LSA’s with the superimposed mine footprint (i.e., the<br />
Application Case) the habitat affected by both direct and indirect effects<br />
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Section 13.1<br />
including sensory disturbance was determined for those species. Although the<br />
statement seems to indicate that indirect effects including sensory disturbance<br />
were incorporated into the models, there is no mention of indirect effects,<br />
including sensory disturbance, in either the barred owl or black-throated green<br />
warbler model descriptions (EIA Volume 5, Appendix 5-4, Section 1.2.3, Pages<br />
21-24 and Pages 17-21). Furthermore, no assumptions are listed for any of the<br />
models other than black bear.<br />
68a Explain how indirect effects including sensory disturbance were incorporated<br />
into the barred owl and black-throated green warbler models. How were the<br />
model results then incorporated into the impact assessment for these KIRs and<br />
the wildlife communities they represent?<br />
Response 68a The indirect effects of human disturbance were incorporated into the barred owl<br />
and black-throated green warbler models implicitly through the processes of<br />
model building and model selection. Anthropogenic disturbance was implicit in<br />
the construction of the barred owl resource selection function (RSF) model<br />
through a variable quantifying the percent area forested (Hubbs 2007, pers.<br />
com.). That variable did not occur within the final model selected, suggesting<br />
that it may not be as important for barred owl nest site selection as the variables<br />
that were present (i.e., the area of old coniferous forest and bog). Although the<br />
effect of disturbed areas on nest site selection in the barred owl RSF model was<br />
not addressed separately from other non-forested areas (i.e., water and terrestrial<br />
naturally non-forested areas), there was reason to believe that its inclusion may<br />
not have substantially altered model selection results. For example, additional<br />
research on barred owl nest site selection conducted in the Calling Lake area<br />
found that half of all barred owl nests located were within 50 m of a cutblock.<br />
Therefore, it did not seem that nesting barred owls were avoiding anthropogenic<br />
disturbances of that kind (Olsen et al. 2006). Research conducted in<br />
Saskatchewan also suggests that indirect effects of disturbance are not important<br />
determinants of barred owl nest site selection (Marzur et al. 1997). In a synthesis<br />
of barred owl research from across North America, Livezey (2007) reported that<br />
barred owls had been found to display preference for, avoidance of, and<br />
neutrality towards, fragmented habitat, depending on the study and variables<br />
measured.<br />
Anthropogenic edge density was also considered as a potential variable in<br />
construction of the black-throated green warbler model (Boyce et al. 2002;<br />
Vernier et al. 2002). However, the process of model selection found the variable<br />
to be relatively unimportant, or at least a statistically insignificant predictor of<br />
black-throated green warbler presence (Boyce et al. 2002) and abundance<br />
(Vernier et al. 2002). For barred owl and black-throated green warbler, it was<br />
assumed that the lack of representation of disturbance-related variables in the<br />
final model (despite their consideration), as well as literature support for<br />
insensitivity to disturbance, indicated that proximity to disturbance was relatively<br />
unimportant for explaining habitat selection. Therefore, if included explicitly, the<br />
indirect effects of human disturbance on barred owl and black-throated green<br />
warbler model output were expected to be negligible.<br />
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References<br />
Boyce, M.S., P.R. Vernier, S.E. Nielsen and F.K.A Schmiegelow. 2002.<br />
Evaluating resource selection functions. Ecological Modelling.<br />
157: 281-300.<br />
Section 13.1<br />
Livezey, K.B. 2007. Barred owl habitat and prey: a review and synthesis of the<br />
literature. The Journal of Raptor Research 41(3): 177-201.<br />
Mazur, K. M., P. C. James and S. D. Frith. 1997. Barred Owl nest site<br />
characteristics in the boreal forest of Saskatchewan, Canada. In J. R.<br />
Duncan, H. D. Johnson and T. H. Nicholls, editors. Biology and<br />
Conservation of Owls of the Northern Hemisphere: Second International<br />
Symposium, pages 267–271. U.S. Forest Service General Technical<br />
Report N-190. U.S. Dept. of Agriculture, Forest Service, North Central<br />
Forest Experiment Station, St. Paul, Minnesota, USA.<br />
Olsen, B.T., S.J. Hannon and G.S. Court. 2006. Short-term response of breeding<br />
barred owls to forestry in a boreal mixedwood forest landscape. Avian<br />
Conservation and Ecology 1(3):1.<br />
Vernier, P.R., F.K.A. Schmiegelow and S.G. Cumming. 2002. Modelling bird<br />
abundance from forest inventory data in the boreal mixed-wood forest of<br />
Canada. pp. 559-571. In: J.M. Scott, Heglund, P.J., Morrison, M.,<br />
Raphael, M., Haufler, J., Wall, B. (ed.), Predicting Species Occurrences:<br />
Issues of Scale and Accuracy. Island Press. Covello, CA.<br />
Personal Communication. 2007. Hubbs, A. (Area Wildlife Biologist, Fish and<br />
Wildlife Division). 2007. Alberta Sustainable Resource Development.<br />
Athabasca, AB. E-mail to Brock Simons (Golder) on January 30, 2007.<br />
Request 68b If a disturbance factor of some sort was not included in the barred owl or blackthroated<br />
green warbler models, explain how incorporation of this factor would<br />
affect the model results and the conclusions of the EIA.<br />
Response 68b As discussed in AENV SIR 68a, disturbance factors were incorporated implicitly<br />
in the process of model production and selection for the barred owl and blackthroated<br />
green warbler models. That is, variables that were most likely to be the<br />
primary determinants of habitat selection for these species were present in the<br />
RSF models used. Therefore, the weight of evidence in the literature (see AENV<br />
SIR 68a for a detailed description) suggests that barred owls and black-throated<br />
green warblers are not sensitive to proximity of disturbance features relative to<br />
the habitat variables contained in the respective predictive models. An addition of<br />
indirect disturbance factors for these two species is unnecessary, and would not<br />
be based on the available scientific literature.<br />
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Section 13.1<br />
Request 68c Explicitly list all assumptions inherent in each of the models used to assess the<br />
impacts of this project on all the respective KIRs.<br />
Response 68c The assumptions behind all models are listed explicitly in the Wildlife Modelling<br />
Appendix (see EIA, Volume 5, Appendix 5-4, Section 1.2).<br />
Question No. 69<br />
Request Volume 2, SIR 458c i, Page 23-130.<br />
The SIR requests peer-reviewed support for the adequacy of a 250 metre buffer.<br />
Shell makes reference to two peer-reviewed documents. Shell notes that the<br />
TROLS work (Hannon 2002), indicates 200 metre buffers were adequate for<br />
forest dwelling birds. Shell does not identify in their answer that this same work<br />
notes that a 200 metre buffer would not maintain wide-ranging species such as<br />
woodpeckers, raptors and mammalian carnivores. The second peer-reviewed<br />
reference is to Beier’s 1995 work noting cougar use of a 400 metre wide corridor<br />
in southern California with bottlenecks as narrow as 3.3 metres at road<br />
underpasses. It is unclear how this supports a 250 metre buffer width. Outside<br />
these two, the work referenced is largely completed by Golder or is monitoring<br />
data for Suncor. Neither is peer-reviewed.<br />
69a Provide peer-reviewed literature that supports Shell’s assertion that a 250 metre<br />
buffer from the high water mark of the Athabasca <strong>River</strong> is adequate, or revise the<br />
original statement as appropriate.<br />
Response 69a The purpose of a corridor is to maintain landscape connectivity for species.<br />
Landscape connectivity helps maintain population viability by promoting gene<br />
flow between patches and increasing the effective size of populations (Noss and<br />
Harris 1987, Beier and Noss 1998, Olsen et al. 2007). To be ultimately effective<br />
in maintaining genetic connectivity, the corridor only needs to facilitate passage<br />
of at least one effective migrant per generation (Mills and Allendorf 1996, Wang<br />
2004). The purpose of a corridor is not to satisfy all life history requirements for<br />
all wildlife species that may be using it (Rosenberg et al. 1997).<br />
In the boreal mixedwood ecoregion of north-central Alberta, Hannon et al.<br />
(2002) found that 200 m-wide riparian corridors were sufficient for maintaining<br />
natural small mammal, amphibian and bird communities. Hannon et al. (2002)<br />
then went on to say that a 200 m-wide corridor would not hold the territories of<br />
wide-ranging species. However, maintaining resident populations is only<br />
necessary when the corridor length is long relative to the dispersal abilities of the<br />
species in question (Beier and Noss 1998). The proposed Athabasca <strong>River</strong><br />
corridor is less than 8 km long where the width approaches 250 m (minimum)<br />
adjacent to the main mine site, which is short relative to the dispersal capabilities<br />
of wide-ranging species (Sutherland et al. 2000).<br />
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References<br />
Section 13.1<br />
There is a lack of peer-reviewed literature specifically regarding recommended<br />
buffer widths for wide-ranging wildlife species. However, findings from<br />
monitoring programs that have been implemented in the Oil Sands Region<br />
establish that wide-ranging wildlife species will use a 250 m-wide corridor.<br />
Although not from a peer reviewed source, these findings are real, relevant to the<br />
study area and important for evaluating the effectiveness of the proposed<br />
corridor.<br />
Winter track and remote camera corridor monitoring conducted for Shell’s<br />
Jackpine <strong>Mine</strong> – Phase 1 have documented that moose, wolves, black bears,<br />
fisher, marten, coyote and deer species were using habitat within existing<br />
corridors along the Muskeg and Athabasca rivers adjacent to active mines<br />
(Golder 2008). The setback distance along the Muskeg <strong>River</strong> varies from less<br />
than 100 m to more than 3 km, whereas the Athabasca <strong>River</strong> buffer is less than<br />
1 km.<br />
Wildlife movements were monitored for three years along the east side of the<br />
Athabasca <strong>River</strong> for Suncor’s Millennium and Steepbank <strong>Mine</strong> projects, where<br />
the corridor width varies from about 1 km to less than 200 m. The results of these<br />
surveys showed that all wildlife species, including large carnivores and large<br />
ungulates, used the variable-width corridor (Golder 2000, 2001).<br />
Wildlife corridor monitoring was conducted using remote cameras during nonwinter<br />
months along the Athabasca and Steepbank rivers (Suncor 2004, 2005 and<br />
2006). The Steepbank <strong>River</strong> buffer varies in size from 50 to 200 m, whereas the<br />
Athabasca <strong>River</strong> buffer zone is less than 1 km. Species detected along the<br />
Steepbank <strong>River</strong> escarpment included black bears and moose, while black bear,<br />
white-tailed deer, coyote, wolf, beaver, fisher marten and fox were recorded in<br />
the Athabasca <strong>River</strong> buffer zone.<br />
Due to the lack of peer-reviewed literature regarding appropriate corridor widths<br />
for larger wildlife species, it was determined that results from these studies were<br />
the best-available information for supporting the use of a 250 m buffer along the<br />
Athabasca <strong>River</strong>. Therefore, based on available corridor monitoring and wildlife<br />
habitat data specific to this region, a 250 m buffer from the Athabasca <strong>River</strong> is<br />
considered to be an effective width for maintaining landscape connectivity.<br />
Beier, P. and R.F. Noss. 1998. Do habitat corridors provide connectivity?<br />
Conservation Biology 12(6): 1241-1252.<br />
Golder (Golder Associates Ltd.). 2000. Suncor Millennium and Steepbank <strong>Mine</strong><br />
<strong>Project</strong>s Wildlife Monitoring Program & Wildlife Assessment Update<br />
2000. Submitted to Suncor Energy Inc., Oil Sands. Fort McMurray, AB.<br />
32 pp. + Appendices.<br />
Golder. 2001. Suncor Millennium and Steepbank <strong>Mine</strong> <strong>Project</strong>s Winter Wildlife<br />
Track Count Surveys 2001: Year Three. Prepared for Suncor Energy Inc.<br />
Fort McMurray, AB. 46 pp. + Appendices.<br />
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Section 13.1<br />
Golder. 2007. Canadian Natural Horizon Wildlife Corridor Monitoring Program<br />
– 2006 Data Report. Prepared for Canadian Natural, Calgary. 5 March<br />
2007.<br />
Golder. 2008. Shell Jackpine <strong>Mine</strong>-Phase 1 Wildlife Corridor Monitoring Year 2<br />
Annual Report 2007. Prepared for Shell Canada Ltd. Fort McMurray,<br />
AB.<br />
Hannon, S.J., C.A. Paszkowski, S. boutin, J. DeGroot, S.E. Macdonald, M.<br />
Wheatley and B.R. Eaton. 2002. Abundance and species composition of<br />
amphibians, small mammals, and songbirds in riparian forest buffer<br />
strips of varying widths in the boreal mixedwood of Alberta. Canadian<br />
Journal of Forest Research 32: 1784-1800.<br />
Mills, L.S. and F.W. Allendorf. 1996. The One-Migrant-per-Generation Rule in<br />
Conservation and Management. Conservation Biology. 10(6): 1509-<br />
1518.<br />
Noss, R.F. and L.D. Harris. 1987. Nodes, networks, and MUMs: preserving<br />
diversity at all scales. Environmental Management 10(3): 299-309.<br />
Olson, D.H., P.D. Anderson, C.A. Frissell, H.H. Welsh Jr. and D.F. Bradford.<br />
2007. Biodiversity management approaches for stream-riparian areas:<br />
perspectives for Pacific Northwest headwater forests, microclimates, and<br />
amphibians. Forest Ecology and Management 246: 81-107.<br />
Rosenberg, D.K., B.R. Noon and E.C. Meslow. 1997. Biological corridors: form,<br />
function, and efficacy. Bioscience 47(10): 677-687.<br />
Suncor (Suncor Energy Inc.) 2004. Wildlife Monitoring Program and Wildlife<br />
Assessment Year 1999-2003. Prepared for Suncor Energy Inc. Fort<br />
McMurray, AB.<br />
Suncor. 2005. Wildlife Monitoring Program and Wildlife Assessment Year 2004.<br />
Prepared for Suncor Energy Inc. Fort McMurray, AB.<br />
Suncor. 2006. Wildlife Monitoring Program and Wildlife Assessment Year 2005.<br />
Prepared for Suncor Energy Inc. Fort McMurray, AB.<br />
Sutherland, G.D., A.S Harestad, K. Price and K.P. Lertzman. 2000. Scaling of<br />
natal dispersal distances in terrestrial birds and mammals. Conservation<br />
Ecology 4(1): 16.<br />
Wang, J. 2004. Application of the One-Migrant-per-Generation Rule to<br />
Conservation and Management. Conservation Biology. 18(2): 332-343.<br />
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Question No. 70<br />
Request Volume 2, SIR 458c iv, Page 23-136.<br />
Section 13.1<br />
Shell was requested to discuss the usable corridor width once the buffers, or<br />
zones of influence, along the disturbance edge had been applied. Shell<br />
acknowledges that the corridor may only be used by 50% of black bears all of the<br />
time, or that all black bears will use it 50% of the time. Regardless, the<br />
implication is that the corridor will be 50% effective for black bears given its<br />
proximity to development. Shell does not however describe the effective<br />
corridor width once appropriate buffers have been applied for other KIRs.<br />
Sensory disturbance is known to affect several of the KIRs as indicated in the<br />
model descriptions provided in Appendix 5-4 of the EIA Volume 5 (e.g., Distance<br />
to nearest road was found to contribute negatively (-) to the most strongly<br />
supported RSF model for moose (EIA, Volume 5, Appendix 5-4 Page 14);<br />
Distance to nearest edge C (-) was also a contributing negative factor in the most<br />
strongly supported model for fisher/marten).<br />
70a Discuss the effective corridor width along the Athabasca <strong>River</strong> after appropriate<br />
disturbance buffers have been applied along the disturbance edge, for all KIRs.<br />
Response 70a Effective habitat quality within the corridor is projected to decrease for some<br />
KIRs. However, a decrease in effective habitat quality should not be interpreted<br />
as a decrease in effective corridor width. To be effective, habitat within a<br />
corridor does not need to satisfy all the life history requirements of the species<br />
that use it (Rosenberg et al. 1997). The purpose of a corridor is to maintain<br />
landscape connectivity, which helps maintain population viability by promoting<br />
gene flow between patches and increasing the effective size of populations (Noss<br />
and Harris 1987, Beier and Noss 1998, Olsen et al. 2007). To be ultimately<br />
effective in maintaining genetic connectivity, the corridor only needs to facilitate<br />
passage of at least one effective migrant per generation (Mills and Allendorf<br />
1996, Wang 2004). Although sensory disturbance may decrease the<br />
attractiveness of the corridor for some species, it is unlikely to exclude species.<br />
Documented evidence of wildlife species using corridors adjacent to operational<br />
mines in the Oil Sands Region that are in some locations less than 250 m wide is<br />
discussed in AENV SIR 69a.<br />
Although sensory disturbance affects all KIRs, buffers are only used to represent<br />
sensory disturbance for black bears. For black bears, a 250 m sensory disturbance<br />
buffer is applied around all roads and industrial facilities, within which HSI<br />
values are multiplied by a disturbance coefficient of 0.5 (EIA, Volume 5,<br />
Appendix 5-4, Section 1.2.5, p. 33). The effects of proximity to disturbance are<br />
incorporated implicitly into the moose, Canada lynx, fisher marten, blackthroated<br />
green warbler and barred owl models, but cannot be partitioned in terms<br />
of disturbance buffers (EIA, Volume 5, Appendix 5-4, Section 1). Canadian toad,<br />
black bear, beaver and yellow rail are also affected by water table drawdown,<br />
which is represented as a 0.1 m isopleth.<br />
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References<br />
Section 13.1<br />
Within the portion of the corridor that approaches 250 m wide (at minimum;<br />
Figure AENV 70-1), habitat quality and, therefore, effective corridor width, is<br />
predicted to be unaffected by the project for moose, Canada lynx, fisher marten,<br />
Canadian toad and beaver (Table AENV 70-1). For black-throated green warbler,<br />
the 11 ha of moderate-quality habitat present at the Base Case becomes low<br />
quality habitat during construction and operations. For barred owl, 1 ha of high<br />
quality habitat (0.4%) becomes low quality habitat during construction and<br />
operations. Due to the application of the sensory disturbance and water table<br />
drawdown buffers, 79 ha (85%) of high quality black bear habitat becomes low<br />
quality habitat.<br />
Beier, P. and R.F. Noss. 1998. Do habitat corridors provide connectivity?<br />
Conservation Biology 12(6): 1241-1252.<br />
Mills, L.S. and F.W. Allendorf. 1996. The One-Migrant-per-Generation Rule in<br />
Conservation and Management. Conservation Biology. 10(6): 1509-<br />
1518.<br />
Noss, R.F. and L.D. Harris. 1987. Nodes, networks, and MUMs: preserving<br />
diversity at all scales. Environmental Management 10(3): 299-309.<br />
Olson, D.H., P.D. Anderson, C.A. Frissell, H.H. Welsh Jr. and D.F. Bradford.<br />
2007. Biodiversity management approaches for stream-riparian areas:<br />
perspectives for Pacific Northwest headwater forests, microclimates, and<br />
amphibians. Forest Ecology and Management 246: 81-107.<br />
Rosenberg, D.K., B.R. Noon and E.C. Meslow. 1997. Biological corridors: form,<br />
function, and efficacy. Bioscience 47(10): 677-687.<br />
Wang, J. 2004. Application of the One-Migrant-per-Generation Rule to<br />
Conservation and Management. Conservation Biology. 18(2): 332-343.<br />
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Figure AENV 70-1: <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> Area Local Study Area Athabasca <strong>River</strong> Corridor<br />
Section 13.1<br />
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Section 13.1<br />
Table AENV 70-1: Wildlife Habitat Change Within the Corridor Between the <strong>Pierre</strong> <strong>River</strong><br />
Mining Areas Local Study Areas: Application Case<br />
Key Indicator<br />
Resource<br />
moose<br />
Canada lynx<br />
fisher/marten<br />
black-throated<br />
green warbler<br />
barred owl<br />
Canadian toad<br />
black bear<br />
beaver<br />
yellow rail<br />
Habitat<br />
Suitability<br />
Class<br />
Base Case<br />
Habitat<br />
Habitat<br />
Area<br />
[ha]<br />
% of<br />
LSAs<br />
Direct Habitat Change Due<br />
to Site Clearing of the<br />
<strong>Project</strong><br />
Change in<br />
Habitat Area<br />
[ha]<br />
Change<br />
[%]<br />
Indirect Habitat Change<br />
Due to the <strong>Project</strong><br />
Change in<br />
Habitat Area<br />
[ha]<br />
Change<br />
[%]<br />
Net Change From<br />
the <strong>Project</strong><br />
Change in<br />
Habitat<br />
Area<br />
[ha]<br />
Change<br />
[%]<br />
Nil 2 1.2 0 0.0 0 0.0 0 0.0<br />
Low 1 0.5 0 0.0 0 0.0 0 0.0<br />
moderate low 57 28.6 0 0.0 0 0.0 0 0.0<br />
Moderate 17 8.4 0 0.0 0 0.0 0 0.0<br />
moderate high 44 22.0 0 0.0 0 0.0 0 0.0<br />
High 78 39.3 0 0.0 0 0.0 0 0.0<br />
Nil 2 1.2 0 0.0 0 0.0 0 0.0<br />
Low 0 0.0 0 0.0 0 0.0 0 0.0<br />
moderate low 0 0.0 0 0.0 0 0.0 0 0.0<br />
Moderate 60 30.0 0 0.0 0 0.0 0 0.0<br />
moderate high 57 28.5 0 0.0 0 0.0 0 0.0<br />
High 80 40.3 0 0.0 0 0.0 0 0.0<br />
Nil 2 1.2 0 0.0 0 0.0 0 0.0<br />
Low 0 0.0 0 0.0 0 0.0 0 0.0<br />
moderate low 0 0.0 0 0.0 0 0.0 0 0.0<br />
Moderate 0 0.0 0 0.0 0 0.0 0 0.0<br />
moderate high 15 7.4 0 0.0 0 0.0 0 0.0<br />
High 182 91.4 0 0.0 0 0.0 0 0.0<br />
Nil 2 1.2 0 0.0 0 0.0 0 0.0<br />
Low 186 93.4 0 0.0 11 5.8 11 5.8<br />
Moderate 11 5.4 0 0.0 -11 -100.0 -11 -100.0<br />
High 0 0.0 0 0.0 0 0.0 0 0.0<br />
Nil 2 1.2 0 0.0 0 0.0 0 0.0<br />
Low 28 14.2 0 0.0 1 2.1 1 2.1<br />
High 168 84.6 0 0.0 -1 -0.4 -1 -0.4<br />
Nil 2 1.1 0 0.0 0 0.0 0 0.0<br />
Low 0 0.0 0 0.0 0 0.0 0 0.0<br />
Moderate 156 78.4 0 0.0 0 0.0 0 0.0<br />
High 43 21.4 0 0.0 0 0.0 0 0.0<br />
Nil 2 1.2 0 0.0 0 0.0 0 0.0<br />
Low 24 11.9 0 0.0 79 334.7 79 334.7<br />
Moderate 81 40.6 0 0.0 0 -0.1 0 -0.1<br />
High 92 46.3 0 0.0 -79 -85.7 -79 -85.7<br />
Nil 121 60.8 0 0.0 0 0.0 0 0.0<br />
Low 3 1.5 0 0.0 0 0.0 0 0.0<br />
Moderate 3 1.7 0 0.0 0 0.0 0 0.0<br />
High 72 36.1 0 0.0 0 0.0 0 0.0<br />
Nil 196 98.6 0 0.0 0 0.0 0 0.0<br />
High 3 1.4 0 0.0 0 0.0 0 0.0<br />
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Question No. 71<br />
Request Volume 2, SIR 459a, Page 23-139.<br />
Section 13.1<br />
In response to the SIR asking how long sight lines will mitigate impacts on<br />
wildlife, Shell suggests that this measure will reduce vehicle-wildlife collisions.<br />
Shell goes on to state that The construction of long lines of sight along roads is<br />
intended to mitigate impacts on medium to large size species, however Shell<br />
acknowledges that building straight roads with long straight sight-lines will not<br />
affect all species in the same way.<br />
71a What other consequences, (for example, reluctance to cross or improved<br />
detection by predators) could long sight lines potentially have on wildlife?<br />
Response 71a Long sight lines may increase the reluctance of some species to cross roads (e.g.,<br />
Dyer 1999, Dyer et al. 2002), or they may increase prey detection rates for<br />
predators (e.g., James 1999). However, they may also increase driver visibility<br />
thereby reducing accident rates. Increased driver visibility as a result of<br />
vegetation clearing on roadsides has been documented to reduce wildlife vehicle<br />
collisions (e.g., moose; Seiler 2005).<br />
References<br />
One documented example of risk to wildlife populations from vehicle collisions<br />
is from a woodland caribou herd in Alberta, where an 11% mortality rate from<br />
collisions with vehicles on a major highway, combined with a natural mortality<br />
rate of at least 10% (Edmonds and Smith 1991) exceeded the average calf<br />
recruitment of 14%. The effect was reported to have likely resulted in a<br />
population decline (Brown and Hobson 1998). Although the potential for<br />
increased predator detection rates for prey exists using long sight lines for roads,<br />
Shell is unaware of a documented wildlife population decline due to long sight<br />
lines alone. In addition, research using individual-based movement models for<br />
wolves, caribou and moose to determine how linear developments affect wolf<br />
movements and consequently predator-prey interactions suggest that the number<br />
of predators on the landscape is more important than the number of linear<br />
developments when explaining caribou and moose survival (McCutchen 2006).<br />
As it is unlikely that the project will increase the number of predators within the<br />
RSA, it is predicted that any change in the predator-prey encounter rate would<br />
not impact the viability of regional wildlife populations.<br />
Brown, W. K. and D. P. Hobson. 1998. Caribou in West-central Alberta:<br />
Information Review and Synthesis. Prep. for: The Research<br />
Subcommittee of the West-central Alberta Caribou Standing Committee.<br />
74 pp + Appendices.<br />
Dyer, S.J. 1999. Movement and Distribution of Woodland Caribou (Rangifer<br />
tarandus caribou) in Response to Industrial Development in Northeastern<br />
Alberta. M.Sc. Thesis. University of Alberta. 106 pp.<br />
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Section 13.1<br />
Dyer, S.J., J.P. O’Neill, S.M. Wasel and S. Boutin. 2002. Quantifying Barrier<br />
Effects of Roads and Seismic Lines on Movements of Female Woodland<br />
Caribou in Northeastern Alberta. Canadian Journal of Zoology 80: 839–<br />
845.<br />
Edmonds, E. J. and K. G. Smith. 1991. Mountain Caribou Calf Production and<br />
Survival, and Calving and Summer Habitat Use in West-central Alberta.<br />
Wildlife Research Series No. 4, Alberta Fish and Wildlife Division,<br />
Edmonton, AB. 16 pp.<br />
James, A.R.C. 1999. Effects of Industrial Development on the Predator-Prey<br />
Relationship Between Wolves and Caribou in Northeastern Alberta.<br />
Ph.D. Thesis Submitted to the University of Alberta. Edmonton, AB.<br />
McCutchen, N. 2006. Factors affecting caribou survival in northern Alberta: the<br />
role of wolves, moose, and linear features. Ph.D. Thesis Submitted to the<br />
University of Alberta. Edmonton, AB.<br />
Seiler, A. 2005. Predicting locations of moose-vehicle collisions in Sweden. J.<br />
Applied Ecol. 42: 371-382.<br />
Request 71b How could long sight lines affect predator-prey balances in the RSA?<br />
Response 71b See the response to AENV SIR 71a.<br />
Request 71c How could long lines of sight affect woodland caribou?<br />
Response 71c As stated in the EIA, Volume 5, Section 7.3.4, the local study areas are not<br />
frequented by woodland caribou. Therefore, long lines of sight are not expected<br />
to affect woodland caribou in and around the local study areas.<br />
Question No. 72<br />
Request Volume 2, SIR 461d, Page 23-143.<br />
In response to the question of expected wildlife mortalities associated with the<br />
tailings pond, Shell states that In the early stages of tailings pond construction<br />
and use, mammals, such as carnivores, ungulates and rodents, … may be able to<br />
access the Albian Sands <strong>Mine</strong> External Tailings Containment Facilities shoreline<br />
from surrounding undisturbed areas. Individual habituated animals such as<br />
bears, foxes, and coyotes may use the shoreline and are at risk of contamination.<br />
72a Why is Shell referring to the Albian Sands <strong>Mine</strong> External Tailings Containment<br />
Facility in Response 461d? Answer this question in relation to the Shell <strong>Pierre</strong><br />
<strong>River</strong> Tailings Areas.<br />
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Response 72a Shell incorrectly mentioned the Albian Sands <strong>Mine</strong> External Tailings<br />
Containment Facility when referring to the proposed external tailings disposal<br />
area (ETDA). The response to the May 2009 <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental<br />
Information, Volume 2, SIR 461d should have referenced Shell’s <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> ETDA. The corrected response to the original question follows.<br />
In the early stages of ETDA construction and use, mammals, amphibians and<br />
reptiles are unlikely to interact with the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> external tailings<br />
disposal area (ETDA) shoreline from surrounding undisturbed areas. Terrestrial<br />
wildlife will be further discouraged from accessing the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA<br />
because the dyke surrounding the ETDA will be about 7 m high before any<br />
tailings are released.<br />
As discussed in EIA, Volume 5, Section 7.5.3.2, residual impacts from activities<br />
associated with the interaction of wildlife with project infrastructure, such as<br />
mortality associated with the ETDA, after mitigation measures are applied (see<br />
EIA, Volume 5, Section 7.1.3) are predicted to have a low environmental<br />
consequence rating for yellow rail and black-throated green warbler, and a<br />
negligible rating for all other key indicator resources (KIRs), such as Canadian<br />
toad, barred owl, moose, black bear, Canada lynx, fisher marten and beaver (see<br />
EIA, Volume 5, Section 7.5.3.2, Table 7.5-36). Interactions with infrastructure<br />
are reasonably well understood but lack quantification. Therefore, prediction<br />
confidence was rated as moderate. From 2003 to 2008, the Muskeg <strong>River</strong> <strong>Mine</strong><br />
recorded 70 avian mortalities because of oiling, averaging 11.6 birds per year.<br />
Total avian mortalities at the Muskeg <strong>River</strong> <strong>Mine</strong> from 2003 to 2008 are 119,<br />
averaging 19.8 birds per year. Regional environmental consequences in the<br />
Planned Development Case for interactions with infrastructure are predicted to be<br />
negligible. Shell is continuing to manage its bird deterrent systems to mitigate the<br />
effects of the ETDA on birds.<br />
Request 72b What design features and mitigation measures will Shell implement to<br />
substantially reduce the potential for wildlife to become contaminated during the<br />
early stages of tailings pond construction and use?<br />
Response 72b In the early stages of the external tailings disposal area (ETDA) construction no<br />
tailings will be present. Before tailings are eventually released into the ETDA, a<br />
7 m-high dyke surrounding the ETDA will be constructed, further discouraging<br />
terrestrial wildlife from accessing the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA.<br />
Shell will continue to manage its bird deterrent systems to mitigate the effects of<br />
the ETDA on birds. Sensory disturbance from the waterfowl deterrent system<br />
may also deter other wildlife potentially utilizing the area. Surrounding<br />
vegetation will be managed to remove all remnant patches of natural habitat to<br />
ensure that animals are not attracted to the area. If shoreline vegetation growth<br />
occurs in the ETDA after production begins, the vegetation will be removed with<br />
herbicide, and muskeg mats that rise to the ETDA surface will be covered with<br />
tarpaulins until they sink. A zero tolerance policy for wildlife feeding on site will<br />
help to reduce animal habituation and reduce the removal of nuisance wildlife.<br />
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Request 72c How will the surrounding vegetation be managed to ensure wildlife are not<br />
attracted to the tailings areas?<br />
Response 72c As mentioned in AENV SIR 72b, Shell will implement several mitigation<br />
measures to substantially reduce the potential for wildlife to be attracted to or<br />
become contaminated by the proposed <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> external tailings<br />
disposal area (ETDA). Surrounding vegetation will be managed to remove all<br />
remnant patches of natural habitat to ensure that animals are not attracted to the<br />
area. If shoreline vegetation growth occurs in the ETDA after production begins,<br />
the vegetation will be removed with herbicide, and muskeg mats that rise to the<br />
ETDA surface will be covered with tarpaulins until they sink. In addition, a 150<br />
to 250 m wide buffer of infrastructure, including an access (haul) road and<br />
several utility rights-of-way will surround the ETDA, further suppressing<br />
vegetation growth and wildlife use near the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> ETDA.<br />
Request 72d Discuss the possibility of constructing the dyke around the External Tailings<br />
Containment Facility (tailings pond) before any tailings are added to further<br />
reduce the possibility of contamination of wildlife during the early stages of<br />
development.<br />
Response 72d As mentioned in AENV SIR 72a, terrestrial wildlife will be further discouraged<br />
from accessing the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> external tailings disposal area (ETDA)<br />
because the dyke surrounding the ETDA will be about 7 m high before any<br />
tailings are released.<br />
Question No. 73<br />
Request Volume 2, SIR 465d, Page 23-150.<br />
It is inappropriate to refer an estimate determined using a multiplier as a raw<br />
count of abundance. It should be referred to as an estimate.<br />
73a Do the references provided support multiplying the moose survey numbers by a<br />
factor of two to account for the 50% visual coverage?<br />
Response 73a The references provided were not intended to provide support for multiplying<br />
survey results by a factor of two. Rather, they were mentioned as supportive of<br />
the aerial survey methods used for estimating ungulate populations in the Shell<br />
local study areas (LSAs).<br />
The objective of Shell’s winter aerial ungulate surveys was to detect all<br />
ungulates, including caribou, deer species and moose, within the Jackpine <strong>Mine</strong><br />
Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSAs. In the study of natural systems, it is<br />
seldom practical to survey every member of a population, or all locations within<br />
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a study area. As a result, it is often necessary to collect a representative sample<br />
(Zar 1999).<br />
A line-transect technique was used and surveys were conducted in winter by<br />
helicopter. Fixed-width transects were spaced 400 m apart and three observers<br />
surveyed the ground, extending 100 m on either side of each transect, providing a<br />
total viewing area of 200 m for each transect. The resulting survey coverage was<br />
50% of the area flown. To compensate for the 50% survey coverage, a correction<br />
factor of two was applied to the number of individuals of each species observed.<br />
The density of moose in the LSA was calculated from the estimated number of<br />
animals in the LSA divided by the area (km 2 ) flown along transect lines in the<br />
LSA. This method assumes that the density of moose in the LSAs at the time of<br />
the survey can be determined based on 50% survey coverage (i.e., total estimated<br />
number of moose in the LSAs is approximately twice the number seen). Shell<br />
believes this is a reasonable assumption because the systematic line-transect<br />
technique reduces sampling bias and is representative of the habitat in the LSA.<br />
Zar, J.H. 1999. Biostatistical Analysis, 4th Edition. Prentice-Hall Inc. Simon and<br />
Schuster/A Viacom Company. Englewood Cliffs, NJ.<br />
Request 73b What are the drawbacks to this sampling method?<br />
Response 73b The potential drawbacks to the sampling method are that:<br />
Question No. 74<br />
• confidence intervals cannot be estimated from a single survey using the line<br />
transect methodology<br />
• survey results are an estimate of density and not a raw count of abundance<br />
Request Volume 2, SIR 465d, Page 23-150<br />
74a Which of the many… mitigation commitments made by Shell in the EIA, Volume<br />
5, Terrestrial Resources and Human Environment Section 7.1.3 will function to<br />
protect the bison in the PRMA?<br />
Response 74a The question above refers to SIR 468b, rather than 465d as cited in this question.<br />
Mitigation commitments made by Shell that will function to protect bison during<br />
construction and operations include:<br />
• constructing straight roads with long sight lines where feasible<br />
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Question No. 75<br />
• maintaining a 250-m wildlife corridor along the Athabasca <strong>River</strong><br />
Section 13.1<br />
• providing for wildlife passage under the Athabasca <strong>River</strong> bridge on both the<br />
east and west banks of the river<br />
• designing lighting to reduce light pollution in the adjacent wildlife corridor<br />
• fencing the approaches to the Athabasca <strong>River</strong> bridge<br />
• retaining treed buffers around or near watercourses<br />
• planning and sharing access with other industrial partners<br />
• posting wildlife crossing signage where key wildlife crossing areas are<br />
identified<br />
• reducing traffic volumes by continuing to transport staff to site using buses<br />
• enforcing traffic speed limits<br />
• undertaking dust control on roads<br />
• prohibiting staff and contractors from hunting and trapping on site<br />
• providing construction staff with environmental awareness training as part of<br />
their on-site orientation<br />
Request Volume 2, SIR 472, Table 472-2, Page 23-166.<br />
The table lists seven rare lichen species.<br />
75a Confirm that Shell expects, based on current data, the Shell <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong><br />
and/or Jackpine <strong>Mine</strong> expansion will regionally and in some cases provincially<br />
extirpate these seven species.<br />
Response 75a Shell does not expect that the project will result in the extirpation of these seven<br />
rare lichen species. Further field surveys would be required to estimate the<br />
distribution of these seven species within the Oil Sands Region. While many<br />
known and common lichen species in Alberta have far-ranging distributions (Vitt<br />
et al. 1988), recent surveys by Golder in the Oil Sands Region has resulted in the<br />
identification of many species not previously identified in Alberta or that are<br />
unranked by the Alberta Natural Heritage Information Center (ANHIC). In the<br />
northeastern boreal region of Alberta, data concerning individual lichens species<br />
distributions are very limited and therefore the distribution of many species, even<br />
common species, is uncertain. The lichen flora of Alberta is poorly known,<br />
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References<br />
Section 13.1<br />
especially in the north and eastern portions of the province (Goward 2007, pers.<br />
comm.).<br />
Lichens as a group are under-collected, at least in certain regions of North<br />
America, which has resulted in lack of species presence, abundance and<br />
distribution information (Thomson and Will-Wolf 2000 website; Esslinger 2006<br />
website; USGS 2007 website; NatureServe 2009 website).<br />
Esslinger, T. L. 2006. A Cumulative Checklist for the Lichen-Forming,<br />
Lichenicolus and Allied Fungi of the Continental United States and<br />
Canada. North Dakota State University:<br />
http://www.nusu.nodak.edu/instruct/esslinge/chklst7.htm. (First Posted 1<br />
December 1997, Most Recent Update 10 April 2006), Fargo North<br />
Dakota.<br />
NatureServe. 2009. Explorer, accessed from<br />
http://www.natureserve.org/explorer/servlet/NatureServe?post_processes=<br />
PostReset&loadTemplate=nameSearchSpecies.wmt&Type=Reset on<br />
April 6, 2009.<br />
Thomson, J.W. and S. Will-Wolf. 2000. Lichenized Fungi Which Appear Rare<br />
Due to Undercollecting. Wisconsin State Herbarium, Madison, WI,<br />
website viewed February 20, 2007<br />
http://www.botany.wisc.edu/Wislichens/LichenTAB-C.htm.<br />
USGS (United States Geological Survey). 2007. NPLichen, A Database of<br />
Lichens in the U. S. National Parks. Version 3.5. U. S. Geological Survey.<br />
http://www.ies.wisc.edu/nplichen. Accessed February 20, 2007.<br />
Vitt, D. H., J. E. Marsh and R. B. Bovey 1988. Mosses, Lichens and Ferns of<br />
Northwest North America. Lone Pine Publishing. 296 pp.<br />
Personal Communication. 2007. Goward, T. Enlichened Consulting Ltd. Personal<br />
Communication with Darrin Nielsen, Golder Associates Ltd. E-mail<br />
correspondence. January 11, 2007.<br />
Request 75b Confirm that Shell is not intending to mitigate these losses.<br />
Response 75b Shell does not intend to mitigate the loss of these seven rare lichen species within<br />
the project footprint. See the response to AENV SIR 75a for further discussion.<br />
Request 75c Confirm that Shell has chosen not to undertake any additional directed surveys to<br />
establish the presence of these species outside the <strong>Project</strong> Area.<br />
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Section 13.1<br />
Response 75c Because Shell does not expect that the project will result in the extirpation of<br />
these seven rare lichen species, as discussed in the response to AENV SIR 75a,<br />
Shell is not planning to undertake additional surveys outside of the project local<br />
study areas to establish the presence of these species in other areas.<br />
Question No. 76<br />
Request Volume 2, SIR 482a, Page 23-181 ; Volume 2, SIR 510a, Page 23-226.<br />
In response to the question of why not all listed species were modelled, Shell<br />
states that Wildlife KIRS were primarily identified based on CEMA SEWG<br />
ratified indicator list, provincial and federal status, representation across<br />
ecological stages i.e., wetlands, early and mid successional habitats, and<br />
taxonomic groupings i.e., mammals, birds and amphibians. Habitat modeling<br />
was conducted for all species that were chosen as Key Indicator Resources<br />
(KIRs) … and… Most of the habitat requirements of listed species are<br />
represented by KIRs. In Table 510-1 used to supplement Shell’s Response 510a,<br />
Shell indicates that woodland caribou were observed during field surveys in the<br />
Local Study Area.<br />
76a Given that woodland caribou seem to fit all of the criteria Shell has listed for<br />
selection of species for KIR inclusion, why were woodland caribou not selected<br />
as a KIR for assessment of this project?<br />
Response 76a Woodland caribou were not selected as a key indicator resource (KIR) for the<br />
project because the local study areas (LSAs) do not fall within a recognized<br />
caribou zone, and caribou are transient and therefore are observed in the area<br />
very infrequently (Golder 2007). One woodland caribou track was observed<br />
during 2004 winter track surveys in the Jackpine <strong>Mine</strong> Expansion LSA and no<br />
woodland caribou sign was located during extensive terrestrial surveys conducted<br />
within the LSA from 2005 through 2007 (Golder 2007) (see EIA, Volume 5,<br />
Section 7.3.4, p. 7-37). Interviews with current Registered Fur Management Area<br />
(RFMA) holders indicate that caribou are present only sporadically, if at all (see<br />
EIA, Volume 5, Section 7.3.4, p. 7-37). Recognized Caribou Areas are located<br />
about 15 km east of the Jackpine <strong>Mine</strong> Expansion LSA (i.e., the Steepbank<br />
Caribou Area) and 50 km northwest of the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA (i.e., the Birch<br />
Mountain Caribou Area).<br />
Reference<br />
Golder (Golder Associates Ltd.). 2007. Wildlife and wildlife habitat<br />
environmental setting for the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> <strong>Project</strong>. Submitted to Shell Canada Ltd. December, 2007. 191 pp.<br />
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Request 76b Which KIR represents the habitat requirements of woodland caribou? Explain<br />
how this listed species is represented by one or several of the KIRs.<br />
Response 76b The KIRs that could represent the habitat requirements of woodland caribou in<br />
the LSA are lichen – jackpine communities and peatlands. These two KIRs are<br />
considered primary habitat for woodland caribou in northeastern Alberta (Stelfox<br />
1993). These KIRs represent potential rather than realized caribou habitat<br />
because caribou are observed in the area very infrequently (Golder 2007), the<br />
LSAs do not fall within a recognized caribou zone and habitat in proximity to<br />
Base Case industrial development is of reduced value to caribou as a result of<br />
sensory disturbance (Dyer et al. 2001).<br />
References<br />
Question No. 77<br />
Dyer, S.J., J.P. O'Neil, S.M. Wasel and S. Boutin. 2001. Avoidance of Industrial<br />
Development by Woodland Caribou. Journal of Wildlife Management.<br />
65: 531-542.<br />
Golder (Golder Associates Ltd.). 2007. Wildlife and wildlife habitat<br />
environmental setting for the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> <strong>Project</strong>. Submitted to Shell Canada Ltd. December, 2007. 191 pp.<br />
Stelfox, J.B. (ed.). 1993. Hoofed Mammals of Alberta. Lone Pine Publishing.<br />
Edmonton, AB. 241 pp.<br />
Request Volume 2, SIR 483d, Page 23-184.<br />
Shell asserts that Currently the RSF model produced by Dr. Anne Hubbs is the<br />
best available data on barred owls. In discussion of Shell’s response with Dr.<br />
Anne Hubbs, she indicates the use of Mike Russell’s RSFs (M.Sc, Thesis 2008 –<br />
University of Alberta) would be more appropriate as they account for individual<br />
variability and edge effects which Anne’s model did not directly address.<br />
77a Provide a revised assessment using Mr. Russell’s work or an explanation of why<br />
Mr. Russell’s RSFs are not applicable to Shell’s project.<br />
Response 77a Mike Russell’s thesis was not published until the spring of 2008 (Russell 2008)<br />
and was not made available to Shell until November 2009 (Russell 2009, pers.<br />
comm.). The EIA was submitted in December 2007. Habitat suitability models<br />
are refined over time as ecological knowledge advances and new data become<br />
available. Shell contends that it would not be appropriate to re-work analyses or<br />
assessments based on incremental methodology refinements made subsequent to<br />
the time that the EIA was being produced, unless a qualitative assessment of<br />
those refinements suggests a basis for doing so.<br />
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References<br />
Question No. 78<br />
Section 13.1<br />
Accordingly, if Mike Russell’s RSF model were to be implemented in this<br />
assessment, it is very unlikely that the model would result in a change to the<br />
environmental consequence for the effect of the project on barred owl habitat.<br />
First, proximity to disturbance would likely have little effect on model output<br />
(Russell 2010, pers. comm.). Second, avoidance of disturbed areas in the model<br />
is likely a reflection of the landscape in which the model was developed. Data for<br />
model development was collected in an agricultural landscape with large open<br />
fields (Russell 2008). Barred owls were likely avoiding open fields because such<br />
areas have relatively high densities of great horned owls, which are predators of<br />
barred owls (Russell 2008). In contrast, industrial disturbances created by the<br />
project are unlikely to result in productive foraging habitat for great horned owls.<br />
Therefore, barred owls may avoid edges created by industrial disturbance less<br />
than they avoid edges created by agricultural or forestry activity.<br />
Russell, M.S. 2008. Habitat selection of barred owls (Strix varia) across multiple<br />
spatial scales in a boreal agricultural landscape in north-central Alberta.<br />
M.Sc. Thesis. University of Alberta, Edmonton.<br />
Personal Communication. Russell, M. 2010. Telephone communication with<br />
Brock Simons (Golder Associates Ltd.). January 13, 2010.<br />
Personal Communication. Russell, M. 2009. Email communication with Brock<br />
Simons (Golder Associates Ltd.). November 2, 2009.<br />
Request Volume 2, SIR 486-490, Page 23-188.<br />
Shell states that formal validation of HSI models through additional data<br />
collection is unnecessary to adequately characterize the impacts of the project.<br />
Models are simply tools and without data to support an HSI for species where<br />
habitat use knowledge is limited, confidence in the impacts predictions are<br />
necessarily suspect.<br />
78a How does Shell support its impact predictions for indicators where the HSI is<br />
unvalidated and there are insufficient data to assess whether the model is<br />
predicting appropriately?<br />
Response 78a Data for black bear, beaver and yellow rail are not available. Therefore, the<br />
habitat suitability index (HSI) models for these species could not be validated<br />
with empirical data. However, as rational, explicit expressions of the well<br />
understood habitat associations for these species, these expert-based HSI models<br />
have been conceptually validated and are therefore useful assessment tools.<br />
Validation of habitat suitability models with empirical data may be performed<br />
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Section 13.1<br />
when appropriate data are available. It is also important that models are<br />
conceptually validated to ensure that the theories and assumptions each model is<br />
based on are correct (Rykiel 1996).<br />
Model structure and output for the black bear, beaver and yellow rail HSI models<br />
correspond with well understood habitat associations and ecological relationships<br />
for those species. Black bears in central Alberta will opportunistically eat meat,<br />
but rely on berries in summer and early fall (Ruff 1978; Young and Ruff 1982)<br />
while using dense shrub cover and mature forest for security cover (Zapisocki et<br />
al. 1998). Black bears often avoid human disturbances (Aune 1994). When black<br />
bears are habituated and do not avoid disturbance, mortality risk increases<br />
(Manville 1983). The black bear HSI model incorporates expert ecological<br />
knowledge from the region to combine these well-established habitat associations<br />
and habitat risks into a mathematical equation. Beavers feed primarily on<br />
deciduous shrubs and trees within 100 m of water (Jenkins 1980, Novak 1999),<br />
and the beaver HSI expresses these known relationships. Yellow rail breeding<br />
habitat generally consists of fresh or brackish shallow wet meadows and sedge<br />
marshes with little to no woody vegetation (Goldade 2002; Prescott et al. 2002).<br />
In the Oil Sands Region, this equates to graminoid fen (FONG), shrubby fen<br />
(FONS) or graminoid marsh (MONG) wetlands types (Halsey et al. 2003), which<br />
are identified as habitat by the yellow rail HSI model. Model validation is<br />
important for evaluating model reliability (Conroy et al. 1995). However, the<br />
presence and abundance of wildlife species is affected by many factors, and can<br />
become uncoupled from habitat quality (Van Horne 1983). Therefore, validation<br />
results based on wildlife distribution data can be deceptive. For example, a<br />
species may inadvertently select habitats that contain elevated mortality risk, in<br />
which case a successfully validated model will predict that hazardous habitats are<br />
in fact high quality (Falcucci et al. 2009). Ideally, validation data would represent<br />
the survival rate, birth rate, and carrying capacity per habitat type, which is<br />
needed to truly assess habitat quality (Van Horne 1983). Unfortunately, data on<br />
demographic parameters are very difficult to collect, and are rarely available.<br />
This is not to suggest that habitat suitability models should not be validated with<br />
presence or abundance data, as this is commonly all that are available. Rather, it<br />
is important to note that an impact assessment is limited by the availability of<br />
data and assessment tools. The intent of an EIA is to use the best available data to<br />
assess the effects of the project and to outline uncertainty around the effects<br />
assessment. In the absence of available validation data or validated models, the<br />
alternative to using expert-based, but unvalidated, HSI models would be to use<br />
no quantitative tools for assessing the effects of the project on black bear, beaver<br />
and yellow rail habitat. To remove the output of these useful models from the<br />
assessment would be a step backwards in the quality and thoroughness of the<br />
assessment for wildlife key indicator resources (KIRs).<br />
Aune, K.E. 1994. Comparative ecology of black and grizzly bears on the Rocky<br />
Mountain Front, Montana. International Conference on Bear Research<br />
and Management 9: 365-74.<br />
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Section 13.1<br />
Conroy, M.J., Y. Cohen, F.C. James, Y. G. Matsinos, B.A. Maurer. 1995.<br />
Parameter estimation, reliability, and model improvement for spatially<br />
explicit models of animal populations. Ecological Applications 5(1):17-<br />
19.<br />
Falcucci, A., P. Ciucci, L. Maiorano, L. Gentile and L. Boitani. Assessing habitat<br />
quality for conservation using an integrated occurrence-mortality model.<br />
Journal of Applied Ecology 46: 600-609.<br />
Goldade, C.M., J.A. Dechant, D.H. Johnson, A.L. Zimmerman, B.E. Jamison,<br />
J.O. Church and B.R.Euliss. 2002. Effects of Management Practices on<br />
Wetland Birds: Yellow Rail. North Prairie Research Center, Jamestown.<br />
Halsey, L.A., D.H. Vitt, D. Beilman, S. Crow, S. Mehelcic and R. Wells. 2003.<br />
Alberta Wetlands Inventory Standards, Version 2.0. Alberta Sustainable<br />
Resource Development, Resource Data Branch, Edmonton, AB. 54 pp.<br />
Jenkins, S.H. 1980. A Size-Distance Relation in Food Selection by Beavers.<br />
Ecology. 61: 740-746.<br />
Manville, A.M. 1983. Human impact on the black bear in Michigan's lower<br />
peninsula. International Conference on Bear Research and Management<br />
5: 20-33.<br />
Novak, M. 1999. Beaver. Wild Furbearer Management and Conservation in<br />
North America, Section IV: Species Biology, Management and<br />
Conservation.<br />
25: 282-312.<br />
Prescott, D.R.C., M.R. Norton and I.M.G. Michaud. 2002. Night surveys of<br />
yellow rails, Corturnicops noveboracensis, and Virginia rails, Rallus<br />
limicola, in Alberta using call playbacks. The Canadian Field Naturalist.<br />
116(3): 408-415.<br />
Ruff, R.L. 1978. A Study of the Natural Regulatory Mechanisms Acting on an<br />
Unhunted Population of Black Bears near Cold Lake, AB. Proj. Rep.<br />
Dept Wildl. Ecol., Univ. Wisc., Madison. 107 pp.<br />
Rykiel Jr., E.J. 1996. Testing ecological models: the meaning of validation.<br />
Ecological Modelling 90: 229-244.<br />
Young, B.F. and R.L. Ruff. 1982. Population Dynamics and Movements of Black<br />
Bears in East Central Alberta. Journal of Wildlife Management. 46: 845-<br />
860.<br />
Van Horne, B. 1983. Density as a Misleading Indicator of Habitat Quality.<br />
Journal of Wildlife Management 47(4):893-901.<br />
Zapisocki, R., M. Todd, R. Bonar, J. Beck, B. Beck and R. Quinlan. 1998. Black<br />
Bear Summer/Fall Habitat: Habitat Suitability Index Model Version 5.<br />
Foothills Model Forest. Hinton, AB.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
Section 13.1<br />
Request 78b Provide a plan and schedule of implementation to augment the data collected to<br />
support the HSI models presented.<br />
Response 78b The HSI models for black bear, beaver and yellow rail have been conceptually<br />
validated and are therefore useful assessment tools (see response to AENV SIR<br />
78a). If appropriate data were available, validation with empirical data would be<br />
pursued. Unfortunately, data appropriate for the black bear, beaver and yellow<br />
rail HSI models are not available, and would be extremely difficult to obtain.<br />
Shell does not propose to collect additional empirical data to validate the HSI<br />
models.<br />
Black bears hibernate during winter, and therefore data on black bear distribution<br />
cannot be collected along with data for most other mammalian KIRs during<br />
winter track surveys. Black bear presence within the local study areas (LSAs) has<br />
been confirmed with bait station cameras (Golder 2007). However, baiting<br />
introduces bias that precludes the inference of habitat associations from bait<br />
camera data. Generally, unbiased location data for black bears can be collected<br />
using telemetry collars (Brody and Pelton 1989; Kasworm and Manley 1990;<br />
Lyons et al. 2003; Czetwertynski 2008). Shell has attempted to obtain black bear<br />
telemetry data that was utilized in a Ph.D. thesis at the University of Alberta, but<br />
has been unsuccessful (Boyce 2009, pers. comm.). Fitting black bears with<br />
telemetry collars for HSI model validation is beyond the scope of the EIA, as<br />
defined in the Terms of Reference (TOR) (AENV 2007).<br />
A fall beaver-muskrat aerial survey was performed in conjunction with waterfowl<br />
surveys in 2005 in the Jackpine <strong>Mine</strong> Expansion LSA and in 2005 and 2006 in<br />
the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> LSA (Golder 2007). However, these surveys are not<br />
conducted by randomly sampling the LSAs, but by systematically focusing<br />
survey effort on watercourses. Therefore, existing beaver-muskrat survey data is<br />
biased and is unsuitable for HSI model validation. As the beaver HSI model<br />
predicts that areas in an immediately adjacent to water are high quality habitats<br />
for beaver, model predictions do conform to the available data. Conducting a<br />
systematic aerial survey of the LSAs for beaver activity would be beyond the<br />
scope of the EIA, as defined by the TOR (AENV 2007).<br />
Yellow rails are distributed too sparsely in the Oil Sands Region for independent<br />
data suitable for model validation to be available. Yellow rail breeding habitat<br />
generally consists of fresh or brackish shallow wet meadows and sedge marshes<br />
with little or no woody vegetation (Goldade et al. 2002). In the Oil Sands region,<br />
this equates to graminoid fen (FONG), marsh (MONG) and shrubby fen (i.e.,<br />
FONS) wetlands types (Halsey et al. 2003), as designated in the yellow rail HSI<br />
model. Between 2003 and 2009, 16 yellow rails were recorded in five different<br />
project areas in the Oil Sands Region. Twelve of the 16 detections occurred in<br />
graminoid fen (FONG) or shrubby fen (FONS) habitat. Therefore, the yellow rail<br />
HSI model output does conform with the available data for the species.<br />
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TERRESTRIAL AENV SIRS 44 – 78<br />
References<br />
Section 13.1<br />
AENV (Alberta Environment). 2007. Final terms of reference Environmental<br />
Impact Assessment (EIA) report for the Shell Canada Limited Jackpine<br />
<strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>. 32 pp.<br />
Brody, A.J, M.R. Pelton. 1989. Effects of roads on black bear movements in<br />
western North Carolina. Wildlife Society Bulletin 17: 5-10.<br />
Czetwertynski, S.M. 2008. Effects of hunting on the demographics, movement,<br />
and habitat selection of American black bears (Ursus americanus). PhD<br />
Thesis. University of Alberta, Edmonton, Alberta. 153 pp.<br />
Goldade, C.M., J.A. Dechant, D.H. Johnson, A.L. Zimmerman, B.E. Jamison,<br />
J.O. Church and B.R. Euliss. 2002. Effects of Management Practices on<br />
Wetland Birds: Yellow Rail. Northern Prairie Wildlife Research Centre,<br />
Jamestown. 21 pp.<br />
Golder Associates Ltd. (Golder). 2007. Wildlife and wildlife habitat<br />
environmental setting for the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> <strong>Project</strong>. Prepared for Shell Canada Ltd. 185 pp.<br />
Halsey, L.A., D.H. Vitt, D. Beilman, S. Crowe, S. Melhelcic and R. Wells.<br />
Alberta Wetlands Inventory Standards, Version 2.0. Alberta Sustainable<br />
Resource Development, Resource Data Branch, Edmonton. 54 pp.<br />
Kasworm, W.F. and T.L. Manley. 1990. Road and trail influences on grizzly<br />
bears and black bears in northwest Montana. International Conference on<br />
Bear Research and Management 8: 79-84.<br />
Lyons, A.L., W.L. Gaines and C. Servheen. 2003. Black bear resource selection<br />
in the northeast Cascades, Washington. Biological Conservation 113: 55-<br />
62.<br />
Personal Communication. 2009. Boyce, M. Email communication to Brock<br />
Simons (Golder). November 9, 2009.<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 3: AENV SIRS – ROUND 2<br />
Question No. 79<br />
Request Volume 2, SIR 57a, Page 18-5.<br />
HEALTH<br />
AENV SIRS 79 – 89<br />
Section 14.1<br />
Shell was asked to discuss the response/mitigation plan for odour complaints.<br />
Shell states The existing Muskeg <strong>River</strong> <strong>Mine</strong> HSE management system will serve<br />
as the basis for health, safety and the environment (HSE) management system at<br />
the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>.<br />
79a Provide a copy of the HSE management system to help clarify the odor<br />
response/mitigation actions that take place in the event of a complaint.<br />
Response 79a The following provides excerpts from Shell’s health, safety and the environment<br />
(HSE) work practice manual, which is used at the Muskeg <strong>River</strong> <strong>Mine</strong> to respond<br />
to public or stakeholder complaints, including complaints about odours.<br />
The following outlines the process for handling public and stakeholder<br />
complaints:<br />
• the Security Dispatcher working 24/7 will be the focal point for receiving,<br />
recording, and forwarding complaints from stakeholders<br />
• only certain personnel, or their designates, are authorized to provide<br />
responses to complaints from the public and stakeholders<br />
• individuals will respond to stakeholder complaints only after they have been<br />
designated and briefed by the manager responsible<br />
• if a team member receives a complaint via phone or e-mail on Albian site, he<br />
or she will forward the phone call to Security, and e-mail it to the senior<br />
security specialist. If a verbal complaint is received off site, the team member<br />
will advise the individual to call Albian Security.<br />
The security dispatcher will carry out the following:<br />
• record all complaints from the public, outside sources, or regulatory<br />
authorities on the Public/Stakeholder Complaint form. Obtain as much<br />
information as possible from the caller, including a name and phone number<br />
where he or she could be contacted with a response to the complaint.<br />
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HEALTH AENV SIRS 79 – 89<br />
Question No. 80<br />
Section 14.1<br />
• notify the appropriate team of the complaint, such as Environment, External<br />
Affairs, Health, Safety & Emergency Response, Human Resources and<br />
Mining. If no team is known, direct the complaint to the security shift team<br />
leader or the on-call manager.<br />
• forward the completed Public/Stakeholder Complaint form to the appropriate<br />
team for action, with a copy to the Manager, External Affairs.<br />
• If the complaint is related to a major spill, release, or traffic disruption,<br />
which could endanger lives or property, immediately notify the Emergency<br />
Response Team (ERT). The ERT will address the situation according to<br />
established protocols.<br />
The responsible manager or team leader will carry out the following:<br />
• upon receiving a call from Security about a complaint, obtain all the relevant<br />
information and a copy of the Public/Stakeholder Complaint form<br />
• initiate a report based on the available information<br />
• conduct an investigation of the complaint, take appropriate action to correct<br />
the situation, and develop a response<br />
• review the response with the manager responsible for external affairs<br />
• if designated to do so, contact the person who had complained and provide a<br />
response on Albian’s behalf<br />
• complete the Public/Stakeholder Complaint form, brief the manager of<br />
external affairs, and provide a copy of the completed form<br />
• complete the SIRS report and communicate the findings to affected parties<br />
• forward a copy of the report to the consultation database<br />
Request Volume 2, SIR 58a, Page 18-5.<br />
In Table 58-1, Shell presents three-minute odour predictions.<br />
80a Clarify the substance the predictions represent.<br />
Response 80a The substances included in the odour assessment are shown in the EIA,<br />
Volume 3, Section 3.4.7.2, Tables 3.4-26 and 3.4-27.<br />
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HEALTH AENV SIRS 79 – 89<br />
Question No. 81<br />
Request Volume 2, SIR 58b, Page 18-8.<br />
Section 14.1<br />
Shell was asked to provide the predicted air concentrations that were used to<br />
compare to the odour thresholds. This information was not provided.<br />
81a Provide predicted air concentrations and compare them to odour thresholds.<br />
Assess the results.<br />
Response 81a Refer to the response to AENV SIR 82 for a complete odour assessment,<br />
including the predicted three-minute peak air concentrations and odour<br />
thresholds used to determine the contribution of project emissions to potential<br />
odours in the area.<br />
Question No. 82<br />
Request Volume 2, SIR 58c, Page 18-8.<br />
Shell was asked to provide the odour assessment for the PDC. This information<br />
was not provided.<br />
82a Provide this information.<br />
Response 82a In light of the supplemental information request, an odour assessment was<br />
completed using an alternative approach to the one originally presented in the<br />
EIA. Similar to the original odour assessment, the objective of the current<br />
assessment is to determine the potential contribution of project emissions to<br />
noticeable odours in the area.<br />
Guiding Principles<br />
It is important to recognize that odours are most commonly observed over a<br />
period ranging from a few seconds to a few minutes. As such, the assessment is<br />
based on predicted three-minute peak concentrations of the chemicals of potential<br />
concern (COPCs).<br />
The sense of smell is influenced by a variety of factors, such as individual,<br />
environmental or substance-based factors. On an individual level, a person’s<br />
ability to detect an odour can depend on their innate olfactory powers (i.e.,<br />
“acuteness” of smell), their attentiveness to the matter or their prior experience<br />
with that particular odour. Another strong factor that influences the sense of<br />
smell is the ability of the substance to excite the olfactory receptors. This is<br />
determined by the molecular structure and physical properties of the substance.<br />
These individual and substance-based factors, in combination with a number of<br />
environmental influences known to affect detection of odours, highlight the<br />
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Section 14.1<br />
complexity surrounding the sense of smell. This complexity should be respected<br />
as part of any odour assessment. Table AENV 82-1 lists the factors that influence<br />
sense of smell.<br />
Table AENV 82-1: Factors Affecting Sense of Smell<br />
Category Influences<br />
Individual Innate power of smell<br />
Age<br />
Sex<br />
Prior experience with odour<br />
State of health<br />
Degree of attentiveness<br />
Environment Temperature<br />
Humidity<br />
Wind speed and direction<br />
Chemical Molecular structure<br />
Stability/reactivity<br />
Physical properties (e.g., vapour<br />
pressure, water solubility)<br />
Source: Ruth (1986); Amoore and Hautala (1983)<br />
Because chemical exposures rarely occur in isolation, the number of components<br />
in a mixture will further influence an individual’s ability to detect, identify and<br />
discriminate the components of mixtures. Odourants in mixtures appear to be<br />
processed and perceived in series. Studies indicate that odourants are temporally<br />
processed with up to several hundred milliseconds separating individual<br />
constituents. Odourants determined to be “fast” were found to suppress the<br />
“slow” odourants. This was attributed to their relative chemical polarities, which<br />
affect access to and competition for membrane receptor sites in the olfactory<br />
epithelium (Laing et al. 1994a; Bell et al. 1987).<br />
A study that examined the interactions of odourants emitted from sewage<br />
treatment plants (including hydrogen sulphide) measured the perceived odour<br />
intensity or strength of the individual components alone and in mixtures. The<br />
odour characteristics and the unpleasantness of the mixtures were also measured<br />
(Laing et al. 1994b). The authors found the following:<br />
• The perceived odour intensity of mixtures was equal to or greater than that of<br />
any of the individual constituents, but less than the sum of their intensities.<br />
As the number of constituents in the mixtures increased, the intensity of the<br />
mixture was typically attributable to the intensity of the most dominant<br />
odourant.<br />
• The intensity of an odourant was never enhanced by another (i.e., no<br />
synergistic interactions were observed).<br />
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Methods<br />
Section 14.1<br />
• The greater the number of odourants in the mixture, the more difficult it was<br />
to identify the individual constituents.<br />
• The greater the number of components in the mixture, the greater the degree<br />
of suppression of the individual constituents.<br />
• Hydrogen sulphide was the least frequently suppressed odourant.<br />
• The unpleasantness of the odourant mixture was typically greater than that of<br />
the individual constituents, indicating that models for predicting complaint<br />
levels in communities affected by odourous mixtures, but which are based on<br />
single odourants, will usually underestimate the number of complaints.<br />
This assessment evaluated almost 400 chemicals through the use of chemical<br />
fractions and surrogates. As such, many of the odourants assessed might never be<br />
detected. However, other odourants, such as hydrogen sulphide, are not typically<br />
suppressed and make it very difficult to accurately predict the perceived intensity<br />
of the odourous mixture.<br />
It is possible that the individual odours could “cumulatively” register as a<br />
nuisance. However, current information on odourous mixtures does not indicate<br />
that hydrogen sulphide or any other odourants will be perceived at concentrations<br />
lower than the odour based air quality objectives or reported odour thresholds as<br />
a result of the odourant mixture.<br />
Potential odours were assessed by comparing three-minute peak COPC air<br />
concentrations with established odour thresholds. Three-minute peak<br />
concentrations were derived from the highest predicted one-hour ground-level air<br />
concentrations (i.e., including the eight highest one-hour predictions) using the<br />
following equation:<br />
C3-min = C1-hr x 3 minute multiplier<br />
C3-min = C1-hr x (60 min/3 min) 0.2<br />
Where:<br />
C3-min = predicted three-minute peak concentration<br />
C1-hr = predicted one-hour concentration<br />
0.2 = exponent for the three-minute multiplier based on<br />
neutral atmospheric conditions (OMOE 1996; Duffee et<br />
al. 1991).<br />
Three-minute peak concentrations were estimated for the COPCs given that<br />
odours can appear instantaneously and are commonly observed over very short<br />
periods. The potential for COPCs to contribute to nuisance odours was assessed<br />
as follows:<br />
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Section 14.1<br />
• The maximum three-minute peak air concentrations were predicted for the<br />
cabin residents, Aboriginal residents and community residents in the area.<br />
• The three-minute peak air concentrations were compared with the<br />
corresponding odour threshold for each assessment case (i.e., Base Case,<br />
Application Case and Planned Development Case).<br />
As the three-minute peak air concentrations were derived from the highest<br />
predicted one-hour ground-level air concentrations, the COPC concentrations<br />
that might be encountered under most circumstances may be exaggerated. This<br />
would result in conservative odour estimates.<br />
Determining the Threshold of Odour<br />
Critical to determining the likelihood of the project’s contribution to noticeable<br />
odours is the need to understand the intrinsic odourous properties of the various<br />
chemicals emitted, including their odour thresholds. The odour threshold refers to<br />
the lowest concentration of a chemical that can be detected by smell following<br />
presentation of the chemical in a clean, controlled environment, without<br />
influence of any outside odours (Ruth 1986).<br />
Odour thresholds are typically determined in clinical setting-type studies. A<br />
panel of subjects is presented with a series of concentrations of the same<br />
chemical in air or water and asked to record at what concentration the odour is<br />
first detected. These studies are difficult to compare as they often differ in sample<br />
presentation, panel selection, purity of the chemical used and data interpretation.<br />
Further, the definition of an odour threshold can vary across studies. In some<br />
cases, the odour threshold is the point at which an odour was detected and in<br />
other cases, the odour threshold is the point at which the odour was recognized.<br />
As a result, a wide variation in odour thresholds is reported in the scientific<br />
literature for most chemicals, including the COPCs associated with the project.<br />
For some chemicals, odour can act as a safeguard against adverse health effects.<br />
Under these circumstances, the odour threshold is lower than the concentration<br />
determined to produce toxicity. Odour may not serve as a warning against<br />
adverse health effects if the odour threshold is much higher than the<br />
concentration required to produce toxicity. Therefore, the presence of an odour<br />
might or might not serve as a warning. Health Canada, however, considers any<br />
detectable odour to have the potential to adversely affect human health. For<br />
instance, the presence of a strong odour could potentially lead to increased stress<br />
in an individual.<br />
For the odour threshold values assumed in the assessment, see Table<br />
AENV 82-2. In order to maintain consistency with the original odour assessment<br />
(see EIA, Volume 3, Section 3.4.7), the odour threshold values provided for the<br />
total reduced sulphur compounds and volatile organic compounds in Table<br />
3.4-26 and Table 3.4-27, respectively, of the EIA were used in the alternate<br />
approach (see Table AENV 82-2). For the chemical groups, odour threshold<br />
values were determined by calculating the geometric mean of available odour<br />
thresholds in the scientific literature (AIHA 1997; Amoore and Hautala 1983;<br />
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Section 14.1<br />
ASHRAE 1981; AWMA 2000; Fazzalari 1991; NIH 2004, website; Ruth 1986;<br />
US EPA 1992; van Gemert and Nettenbreijer 1977). For most COPCs, the mean<br />
odour thresholds and range of values reported in the literature are listed. The<br />
lower the odour threshold, the more odorous the chemical. The lower end of the<br />
range represents the “minimum” odour threshold.<br />
Metals were not included in the odour assessment as information regarding odour<br />
character and odour thresholds was not available.<br />
Table AENV 82-2: Odour Characteristics and Thresholds<br />
Odour Threshold<br />
(µg/m 3 Chemical of Potential Concern<br />
)<br />
1 Odour Character 1 Mean Range<br />
1,1-Dichloroethane Chloroform 1,139,323 216,339 to 6,000,094<br />
1,1,1-Trichloroethane Sweet, etherish 611,528 88,000 to 4,249,619<br />
1,1,1,2-Tetrachloroethane – – –<br />
1,1,2-Trichloroethane – 54,387 2,976 to 993,959<br />
1,1,2,2-Tetrachloroethane Solvent 10,094 1,722 to 59,160<br />
1,2-Dichloroethane Sweet 162,019 17,500 to 1,500,000<br />
1,2-Dichloropropane Sweet 1,774 1,200 to 2,621<br />
1,3-Butadiene Aromatic, rubber 6,312 217 to 183,410<br />
1,3-Dichloropropene – –
HEALTH AENV SIRS 79 – 89<br />
Table AENV 82-2: Odour Characteristics and Thresholds (cont’d)<br />
Odour Threshold<br />
(µg/m 3 )<br />
Chemical of Potential Concern 1 Odour Character 1 Mean Range<br />
Cumene Sharp 430 17 to 6,400<br />
Cyclohexane Pungent, solvent, oil 72,793 1,800 to 2,943,788<br />
Dichlorobenzene Camphor, mothballs 1,080 730 to
HEALTH AENV SIRS 79 – 89<br />
Section 14.1<br />
• With the exception of the aliphatic aldehyde group concentrations at the<br />
neighbouring cabins, maximum predicted air concentrations for all COPCs,<br />
lifestyle categories (i.e., cabin, Aboriginal and community residents) and<br />
assessment cases were less than their respective mean odour thresholds.<br />
• The project’s contribution to odour in the area is generally very small,<br />
indicated by the similarities between maximum predicted peak air<br />
concentrations for the Base Case and Application Case.<br />
• In many instances, maximum predicted peak air concentrations are less than<br />
the minimum reported odour thresholds.<br />
The maximum predicted three-minute air concentration of the aliphatic aldehyde<br />
group exceeded its mean odour threshold of 107 µg/m 3 at Cabin K under each<br />
development case. Maximum predicted peak concentrations of the aliphatic<br />
aldehyde group increased from 118 µg/m 3 under the Base Case to 119 µg/m 3<br />
under the Application Case and 132 µg/m 3 under the Planned Development Case<br />
(PDC), indicating that, although exceedances were identified in the Base Case,<br />
project emissions could influence odours relating to the aliphatic aldehyde group<br />
at Cabin K. Maximum predicted three-minute concentrations of the aliphatic<br />
aldehyde group were below the mean odour threshold at all remaining cabin<br />
locations under all three assessment cases.<br />
Based on the exceedances of the mean odour threshold, individuals living or<br />
working in the vicinity of Cabin K might experience odours described as<br />
pungent. Odours associated with some aldehydes are very fragrant, while others<br />
may smell like rotten fruit. These odours are primarily associated with the Base<br />
Case predictions and are likely to be sporadic, rather than continuous.<br />
Predicted maximum peak air concentrations exceeded the minimum reported<br />
odour thresholds for a number of COPCs for one or more lifestyle category.<br />
These include:<br />
• Acetaldehyde<br />
• Aliphatic aldehyde group<br />
• Aliphatic C5-C8 group<br />
• Aliphatic C9-C16 group<br />
• Aliphatic C17-C34 group<br />
• Aromatic C9-C16 group<br />
• Cumene<br />
• Formaldehyde<br />
• Hydrogen sulphide<br />
• Mercaptan group<br />
• Methyl ethyl ketone group<br />
• Nitrogen dioxide<br />
• Thiophene group<br />
• Toluene<br />
• Trimethylbenzenes<br />
• Xylenes<br />
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Section 14.1<br />
Individuals with very keen senses of smell might detect odours at levels above<br />
the minimal odour thresholds. However, only 7% of the population is thought to<br />
be made up of individuals hypersensitive to particular odours (Gouronnec and<br />
Tomasso 2000). As such, area residents with a keen sense of smell may be able<br />
to detect a number of different odours, but the majority of residents would be<br />
unaffected as maximum predicted concentrations are below mean odour<br />
thresholds.<br />
As well, the potential odours from a number of COPCs, especially the chemical<br />
groups, are likely to have been overestimated because of their low minimum<br />
odour thresholds. There is a wide variation in reported odour thresholds as a<br />
result of different methods used to determine odour thresholds. In some studies,<br />
the odour threshold is the level at which 50% of the panel subjects noticed or<br />
recognized and described the odour. Whereas, in other studies, the odour<br />
threshold is determined based on a 100% panel response. Odour thresholds based<br />
on the lowest concentration detected by a single subject (the so-called “absolute”<br />
threshold) are often a very low value. These variations in reporting findings<br />
result in a wide range of odour threshold values.<br />
It is difficult to predict potential odours from the project as the methods for<br />
testing olfactory responses occur in controlled, artificial environments that are<br />
different from normal ambient conditions. Odour thresholds are determined in a<br />
laboratory setting where the chemical is mixed with a highly purified gas,<br />
standardized, and subjected to a trained odour panel. These conditions are<br />
unnatural and do not reflect true ambient conditions. Odour intensities in the field<br />
have reportedly been shown to poorly correlate with odour concentrations<br />
measured in the lab (Zang et al. 2002). Further, sensitivities to odours are often<br />
exaggerated in a laboratory setting, suggesting that laboratory derived odour<br />
thresholds may be conservative. As such, assessing potential odour impacts<br />
should consider natural ambient conditions, such as shifting weather conditions,<br />
constant movement of people and the intermittent nature of some of the emission<br />
sources. These ambient conditions can lead to continuously changing odours at<br />
the individual’s breathing level. Overall, odours associated with the COPCs are<br />
likely to be sporadic, rather than continuous.<br />
Potential odour effects are complicated by the presence of chemical mixtures. As<br />
discussed previously, scientific studies have determined that large numbers of<br />
odourants in the mixture can result in difficulty identifying the individual<br />
constituents. The degree of possible suppression of the individual odourants also<br />
increases with larger numbers of odourants in mixtures (Bell et al. 1987; Laing et<br />
al. 1994a; Jinks and Laing 2001).<br />
Therefore, although some of the chemical mixtures (i.e., aliphatic C5-C8 group,<br />
aliphatic C9-C16 group, aliphatic C17-C34 group, aromatic C9-C16 group,<br />
mercaptan group, methyl ethyl ketone group, thiophene group, and<br />
trimethylbenzenes) exceed their minimal odour thresholds, this is not likely to<br />
result in nuisance odours. Further, the minimum odour thresholds for these<br />
mixtures are based on the minimum of all the individual chemical constituents of<br />
the group, rather than on the chemical mixture as a whole. As a result, the<br />
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minimum odour threshold of the individual constituent is likely to be a<br />
conservative estimate for the chemical group.<br />
Section 14.1<br />
The possibility that some individuals might detect nuisance odours from a few of<br />
the COPCs cannot be entirely dismissed. The following factors need to be<br />
considered:<br />
• A large majority of the COPCs that exceeded their respective minimum<br />
odour thresholds have very low odour thresholds and distinctive odours,<br />
making them very recognizable.<br />
• The presence of individuals possessing a “keen” sense of smell is possible.<br />
Women and children often have a remarkable sense of smell and can detect<br />
and distinguish odours at low levels.<br />
• Individual variables, such as breathing patterns, state of physical health, past<br />
experiences and state of awareness, can have a considerable bearing on the<br />
detection of odours.<br />
Despite this, the exceedances of the minimum and mean odour thresholds (in the<br />
case of the aliphatic aldehyde group at Cabin K) must be viewed in light of the<br />
conservative assumptions incorporated in the assessment and with full<br />
consideration of the complexity of the sense of smell which is influenced by<br />
individual, environmental, and substance-based factors. In addition, potential<br />
odours associated with these COPCs are likely to be sporadic, rather than<br />
continuous.<br />
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Table AENV 82-3: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Cabin Residents<br />
Odour Threshold<br />
(µg/m 3 )<br />
Maximum Peak Concentration<br />
(µg/m 3 ) 2<br />
Section 14.1<br />
Chemical of Potential Concern 1 Planned Development<br />
Mean Range Base Case Application Case<br />
Case<br />
1,1-Dichloroethane 1,139,323 216,339 to 6,000,094 0.000066 0.000066 0.000066<br />
1,1,1-Trichloroethane 611,528 88,000 to 4,249,619 0.00022 0.0038 0.0038<br />
1,1,2-Trichloroethane 54,387 2,976 to 993,959 0.000089 0.000089 0.000089<br />
1,1,2,2-Tetrachloroethane 10,094 1,722 to 59,160 0.00011 0.00011 0.00011<br />
1,2-Dichloroethane 162,019 17,500 to 1,500,000 0.000066 0.000066 0.000066<br />
1,2-Dichloropropane 1,774 1,200 to 2,621 0.000075 0.000075 0.000075<br />
1,3-Butadiene 6,312 217 to 183,410 0.59 0.59 0.66<br />
1,3-Dichloropropene –
HEALTH AENV SIRS 79 – 89<br />
Table AENV 82-3: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Cabin Residents (cont'd)<br />
Odour Threshold<br />
(µg/m 3 )<br />
Maximum Peak Concentration<br />
(µg/m 3 ) 2<br />
Section 14.1<br />
Chemical of Potential Concern 1 Planned Development<br />
Mean Range Base Case Application Case<br />
Case<br />
Ethylene 154,938 20,000 to 1,200,295 18 18 20<br />
Ethylene dibromide 76,800 76,800 to 76,800 0.00012 0.00012 0.00012<br />
Formaldehyde 18,726 27 to 13,088,069 42 43 47<br />
Hexane 468,301 230,000 to 953,502 724 724 883<br />
Hydrogen sulphide 14.1 0.1 to 2,000 13 13 13<br />
Mercaptan group 2.8 0 to18,000 1.5 1.5 1.5<br />
Methanol 1,057,355 4,300 to 260,000,000 0.0070 0.0070 0.0070<br />
Methyl ethyl ketone group 13,157 16 to 1,900,000 24 24 27<br />
Methylene chloride 94,106 4,100 to 2,160,000 0.000056 0.000056 0.000056<br />
Naphthalene group 440 7 to 5,340 0.29 0.29 0.33<br />
Nitrogen dioxide 730 1.2 to
HEALTH AENV SIRS 79 – 89<br />
Table AENV 82-4: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Aboriginal Residents<br />
Section 14.1<br />
Odour Threshold<br />
(µg/m 3 )<br />
Maximum Peak Concentration<br />
(µg/m 3 ) 2<br />
Chemical of Potential Concern 1 Mean Range Base Case Application Case Planned Development Case<br />
1,1-Dichloroethane 1,139,323 216,339 to 6,000,094 0.0033 0.0033 0.0033<br />
1,1,1-Trichloroethane 611,528 88,000 to 4,249,619 0.00037 0.00053 0.00053<br />
1,1,2-Trichloroethane 54,387 2,976 to 993,959 0.0044 0.0044 0.0044<br />
1,1,2,2-Tetrachloroethane 10,094 1,722 to 59,160 0.0055 0.0055 0.0055<br />
1,2-Dichloroethane 162,019 17,500 to 1,500,000 0.0033 0.0033 0.0033<br />
1,2-Dichloropropane 1,774 1,200 to 2,621 0.0037 0.0037 0.0037<br />
1,3-Butadiene 6,312 217 to 183,410 0.28 0.28 0.29<br />
1,3-Dichloropropene –
HEALTH AENV SIRS 79 – 89<br />
Table AENV 82-4: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Aboriginal Residents (cont'd)<br />
Section 14.1<br />
Odour Threshold<br />
(µg/m 3 )<br />
Maximum Peak Concentration<br />
(µg/m 3 ) 2<br />
Chemical of Potential Concern 1 Mean Range Base Case Application Case Planned Development Case<br />
Ethylene dibromide 76,800 76,800 to 76,800 0.0061 0.0061 0.0061<br />
Formaldehyde 18,726 27 to 13,088,069 20 20 21<br />
Hexane 468,301 230,000 to 953,502 480 480 581<br />
Hydrogen sulphide 14.1 0.1 to 2,000 2.4 2.4 3.6<br />
Mercaptan group 2.8 0 to18,000 0.7 0.7 0.9<br />
Methanol 1,057,355 4,300 to 260,000,000 0.35 0.35 0.35<br />
Methyl ethyl ketone group 13,157 16 to 1,900,000 16 16 26<br />
Methylene chloride 94,106 4,100 to 2,160,000 0.0028 0.0028 0.0028<br />
Naphthalene group 440 7 to 5,340 0.15 0.16 0.17<br />
Nitrogen dioxide 730 1.2 to
HEALTH AENV SIRS 79 – 89<br />
Table AENV 82-5: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Community Residents<br />
Odour Threshold<br />
(µg/m 3 )<br />
Maximum Peak Concentration<br />
(µg/m3) 2<br />
Section 14.1<br />
Chemical of Potential Concern 1 Mean Range Base Case Application Case Planned Development Case<br />
1,1-Dichloroethane 1,139,323 216,339 to 6,000,094 0.0033 0.0033 0.0033<br />
1,1,1-Trichloroethane 611,528 88,000 to 4,249,619 0.00037 0.00053 0.00053<br />
1,1,2-Trichloroethane 54,387 2,976 to 993,959 0.0044 0.0044 0.0044<br />
1,1,2,2-Tetrachloroethane 10,094 1,722 to 59,160 0.0055 0.0055 0.0055<br />
1,2-Dichloroethane 162,019 17,500 to 1,500,000 0.0033 0.0033 0.0033<br />
1,2-Dichloropropane 1,774 1,200 to 2,621 0.0037 0.0037 0.0037<br />
1,3-Butadiene 6,312 217 to 183,410 0.28 0.28 0.29<br />
1,3-Dichloropropene –
HEALTH AENV SIRS 79 – 89<br />
Table AENV 82-5: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Community Residents (cont'd)<br />
Odour Threshold<br />
(µg/m 3 )<br />
Maximum Peak Concentration<br />
(µg/m3) 2<br />
Section 14.1<br />
Chemical of Potential Concern 1 Mean Range Base Case Application Case Planned Development Case<br />
Ethylene dibromide 76,800 76,800 to 76,800 0.0061 0.0061 0.0061<br />
Formaldehyde 18,726 27 to 13,088,069 20 20 21<br />
Hexane 468,301 230,000 to 953,502 480 480 581<br />
Hydrogen sulphide 14.1 0.1 to 2,000 2.4 2.4 2.6<br />
Mercaptan group 2.8 0 to18,000 0.7 0.7 0.9<br />
Methanol 1,057,355 4,300 to 260,000,000 0.35 0.35 0.35<br />
Methyl ethyl ketone group 13,157 16 to 1,900,000 16 16 26<br />
Methylene chloride 94,106 4,100 to 2,160,000 0.0028 0.0028 0.0028<br />
Naphthalene group 440 7 to 5,340 0.15 0.16 0.17<br />
Nitrogen dioxide 730 1.2 to
HEALTH AENV SIRS 79 – 89<br />
References<br />
Section 14.1<br />
AIHA (American Industrial Hygiene Association). 1989. Odour Thresholds for<br />
Chemicals with Established Occupational Health Standards. AIHA Press.<br />
Alberta Energy and Utilities Board.<br />
AIHA (American Industrial Hygiene Association). 1997. Odor Thresholds for<br />
Chemicals with Established Occupational Health Standards. Fairfax,<br />
VA.<br />
Amoore, J.E. and E. Hautala. 1983. Odour as an aid to chemical safety: odor<br />
thresholds compared with threshold limit values and volatiles for 214<br />
industrial chemicals in air and water dilution. J. Appl. Toxicol. 3(6):<br />
272–290.<br />
ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning<br />
Engineers). 1981. ASHRAE Fundamentals Handbook. Chapter 12.<br />
AWMA (Air and Waste Management Association). 2000. Air Pollution<br />
Engineering Manual, Second Edition. Wayne T. Davis (ed.). John<br />
Wiley & Sons, Inc. Toronto, ON.<br />
Bell, G.A., D.G. Laing and H. Panhuber. 1987. Odour mixture suppression:<br />
evidence for a peripheral mechanism in human and rat. Brain Research<br />
426(1): 8–18.<br />
Duffee, R.A., M.A O’Brien and N. Ostojic. 1991. Recent developments and<br />
current practices in odour regulations, controls and technology. Odour<br />
Modeling – Why and How. Air and Waste Management Association<br />
Transactions Series No. 18: 289–306.<br />
Fazzalari, F. A. 1991. Compilation of Odor and Taste Threshold Values Data.<br />
American Society for Testing and Materials. DS 48A.<br />
Gouronnec, A.M. and V. Tomasso. 2000. Measurement of odours by sensory<br />
analysis or “olfactometry.” ANALUSIS 28(3): 188–199.<br />
Jinks, A. and D.G. Laing. 2001. The analysis of odor mixtures by humans:<br />
evidence for a configurational process. Physiology and Behavior 72: 51–<br />
63.<br />
Laing, D.G., A. Eddy, G.W. Francis and L. Stephens. 1994a. Evidence for the<br />
temporal processing of odor mixtures in humans. Brain Research 651(1-<br />
2): 317–328.<br />
Laing, D.G., A. Eddy and D.J. Best. 1994b. Perceptual characteristics of binary,<br />
trinary, and quaternary odor mixtures consisting of unpleasant<br />
constituents. Physiology and Behavior 56(1): 81–93.<br />
NIH (National Institutes of Health U.S. National Library of Medicine). 2004.<br />
Haz-Map: Occupational Exposure to Hazardous Agents. Internet<br />
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Question No. 83<br />
Section 14.1<br />
database available at http://hazmap.nlm.nih.gov/. Last accessed April<br />
2007.<br />
OMOE (Ontario Ministry of the Environment). 1996. Odour Impacts – An<br />
Overview. STB Technical Bulletin No. EES-1. February 1996.<br />
Ruth, J.N. 1986. Odour thresholds and irritation levels of several chemical<br />
substances: A review. Am. Ind. Hyg. Assoc. J. 47: 142–151.<br />
US EPA (United States Environmental Protection Agency). 1992. Reference<br />
Guide to Odor Thresholds for Hazardous Air Pollutants Listed in the<br />
Clean Air Act Amendments of 1990. EPA/600/R-92/047.<br />
van Gemert, L.J. and A.H. Nettenbreijer. 1977. Compilation of Odour Threshold<br />
Values in Air and Water. National Institute for Water Supply, Voorburg,<br />
Netherlands.<br />
Zang, Q., J.J.R. Feddes, I.K. Edeogu and X.J. Zhou. 2002. Correlation Between<br />
Odour Intensity Assessed by Using N-Butanol Reference Scale and<br />
Odour Concentration Measured with Olfactometers. Presented at the<br />
Agricultural Institute of Canada (AIC) Meeting, July 14–17, 2002.<br />
Saskatoon, Saskatchewan.<br />
Request Volume 2, SIR 60a, Page 18-10.<br />
Shell was asked to provide the rationale for, and evidence to support, the use of<br />
industrial emissions to determine community concentrations. The response<br />
explains how the approach was carried out, but does not explain the rationale for<br />
estimating community concentrations in this manner. Since communities will<br />
inevitably grow with the growth of industrial projects, it is reasonable to predict<br />
that community emission sources will increase as well.<br />
83a In the rationale, explain how this approach will accurately capture this<br />
community growth (and associated increased emissions).<br />
Response 83a Various regulatory agencies have provided guidance regarding the use of<br />
monitoring data to develop background values for use in a dispersion modelling<br />
analysis (AENV 2009; BC MOE 2008; US EPA 2005). In general, these<br />
guidance documents state that monitoring data can be used to represent other<br />
regional sources, if at least one full year of representative monitoring data is<br />
available.<br />
The United States Environmental Protection Agency (US EPA 2005) indicates<br />
that average monitored concentrations should be used to represent background<br />
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References<br />
Section 14.1<br />
concentrations, and that the monitoring data should be modified to exclude the<br />
contribution of the emission sources not modelled in the assessment.<br />
In developing the approach for the community background used in the EIA, it<br />
was recognized that the industrial contribution to the monitored air quality values<br />
had to be excluded, or community background might be misrepresented.<br />
Therefore, the industrial contribution was removed from the monitored<br />
background by using model predictions for the industrial sources only. The EIA,<br />
Volume 3, Appendix 3-8, Section 2.3.8 outlines the approach used to develop the<br />
community background concentrations, including the method used to remove the<br />
industrial contribution from the monitoring data. This approach was selected<br />
instead of using average monitored concentrations, as recommended by the US<br />
EPA, to provide a conservative estimate of community background<br />
concentrations.<br />
To verify the approach, the monitoring data collected at the communities would<br />
have to have no influence from regional industrial emissions. Because there is<br />
often some level of industrial influence on the monitored values, it is difficult to<br />
provide a quantitative verification.<br />
The Cumulative Environmental Management Association (CEMA) report<br />
reviewing background concentrations in Fort McKay (CEMA 2005) outlined<br />
three approaches for developing community background concentrations,<br />
including the method used in the air quality assessment. The CEMA report<br />
indicates that all three of the methods result in similar ranges of background<br />
concentrations.<br />
Statistically significant trends were not evident in Fort McKay, Fort McMurray<br />
and Fort Chipewyan between 1998 and 2006, despite community growth during<br />
this period (Kindzierski et al. 2006a, 2006b). One explanation for the lack of an<br />
increasing trend in the air monitoring data might be that the emission intensity<br />
per unit area within the communities did not increase significantly even though<br />
the geographical size of the communities increased, i.e., the population density<br />
remained similar. Therefore, the community background concentrations used in<br />
the EIA are expected to be appropriate for all assessment cases.<br />
AENV (Alberta Environment). 2009. Air Quality Model Guideline. Prepared by<br />
the Climate Change, Air and Land Policy Branch Alberta Environment.<br />
Edmonton, AB. Revised May 2009.<br />
BC MOE (British Columbia Ministry of Environment). 2008. Guidelines for Air<br />
Quality Dispersion Modelling in British Columbia. Prepared by<br />
Environmental Protection Division Environmental Quality Branch Air<br />
Protection Section. Victoria, BC. March 2008.<br />
CEMA (Cumulative Environmental Management Association) 2005. Estimating<br />
Contributions to Ambient Concentrations in Fort McKay. Prepared by<br />
Golder Associates Ltd. May 2005.<br />
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Section 14.1<br />
Kindzierski, W.B., K. Faisal and M. Gamal El-Din. 2006a. Establishment of<br />
Ambient Air Quality Trends Using Historical Monitoring Data from<br />
Edmonton and Fort McKay, Alberta. Presented at the 2006 Annual<br />
General Conference of the Canadian Society for Civil Engineering<br />
(CSCE).<br />
Kindzierski, W.B., W. Xu and M. Gamal El-Din. 2006b. Trend Analysis of<br />
Historical Ambient Air Monitoring Data in Edmonton and Fort McKay,<br />
Alberta.<br />
US EPA (United States Environmental Protection Agency). 2005. Revision to the<br />
Guideline on Air Quality Models: Adoption of a Preferred General<br />
Purpose (Flat and Complex Terrain) Dispersion Model and Other<br />
Revisions; Final Rule. November 9, 2005.<br />
Request 83b Provide the scientific evidence to support the approach.<br />
Response 83b See the response to AENV SIR 83a.<br />
Question No. 84<br />
Request Volume 2, SIR 64a, Page 18-17.<br />
Shell states that Alberta Health and Wellness (AHW) recently evaluated the<br />
potential health effects associated with short-term SO2 exposures. Based on a<br />
review of human clinical evidence, AHW (2006) concluded that healthy<br />
individuals can be exposed to concentrations up to 26,000 μg/m 3 (10 ppm) with<br />
transitory effects on pulmonary function, even under extreme conditions<br />
involving hyperventilation, mouth-only exposure and heavy exercise. It is<br />
inaccurate to state that AHW concluded that healthy individuals can be exposed<br />
to the mentioned concentrations, as the document referenced is a review of the<br />
available literature and reporting of the associated findings. The document was<br />
not intended to reflect AHW’s evaluation, or conclusions, regarding human<br />
health effects associated with SO2.<br />
84a Update the statement.<br />
Response 84a The following statement should replace the referenced text in the May 2009<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 2, SIR 64a, page 18-17:<br />
In 2006, Alberta Health and Wellness released a report on the potential health<br />
effects associated with short-term exposure to low levels of SO2. The goal of the<br />
report was to “provide a comprehensive review of the available primary scientific<br />
literature in order to develop a quantitative understanding of the current state of<br />
knowledge with respect to the dose-response relationship between exposure to<br />
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Reference<br />
Question No. 85<br />
Section 14.1<br />
[SO2] and health effects based on the weight of evidence in the peer-reviewed<br />
scientific literature” (Alberta Health and Wellness 2006, page 6). In the summary<br />
of their review of human clinical studies, Alberta Health and Wellness (2006)<br />
reported that “the weight of evidence for exposures up to 30 minutes suggest that<br />
healthy humans can experience exposures to SO2 up to 10 ppm with transitory<br />
effects on pulmonary function, even under challenging conditions involving<br />
hyperventilation, mouth-only exposure, and heavy exercise. Transitory effects<br />
may be observed at concentrations as low as 0.75 ppm” (page 7).<br />
Alberta Health and Wellness 2006. Health Effects Associated with Short-term<br />
Exposure to Low Levels of Sulphur Dioxide (SO2) – A Technical<br />
Review. ISBN 0-7785-3481-2PDF.<br />
Request Volume 2, SIR 66a, Page 18-22.<br />
Shell was asked to provide a quantitative discussion of effects associated with<br />
construction. Shell states emissions associated with constructing the plant<br />
facilities will be short term and substantially less than during the operations<br />
phase of the project. A quantitative assessment was not provided.<br />
85a Provide this assessment.<br />
Response 85a Emissions associated with constructing the plant facilities are expected to be<br />
short term and substantially less than during the operations phase of the project.<br />
The on-site vehicles and equipment associated with the overall construction of<br />
the project will have less fuel requirements than for project operations, resulting<br />
in a lower level of emissions during the construction phase. Regardless, an<br />
estimate of construction phase emissions has been completed.<br />
The basis for the emission estimates was the construction-phase greenhouse gas<br />
(GHG) emissions provided in EIA, Volume 3, Section 3.4.8. Table AENV 85-1<br />
provides a summary of the direct GHG emissions associated with both the<br />
construction and operations phases of the project. On a total carbon dioxide<br />
equivalent basis (CO2E) construction emissions would be approximately 5% of<br />
the Jackpine <strong>Mine</strong> Expansion operation emissions and 6% of the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> operations emissions.<br />
Using these ratios as a surrogate for representing other combustion emissions for<br />
each phase of the project it was concluded that the sulphur dioxide (SO2), oxides<br />
of nitrogen (NOx), particulate matter with a mean aerodynamic diameter of<br />
2.5 microns (PM2.5), carbon monoxide (CO) (and other non-criteria compounds)<br />
emissions during construction would be proportionally lower than operation<br />
levels.<br />
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Table AENV 85-1: Comparison of Construction and Operations Phase Greenhouse Gas<br />
Emissions<br />
<strong>Project</strong> Phase<br />
Construction (a)<br />
Question No. 86<br />
Operations (Scenario 1) (b)<br />
Jackpine <strong>Mine</strong><br />
Expansion<br />
Direct CO2E Emissions<br />
(t/yr)<br />
<strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> Total <strong>Project</strong><br />
103,658 207,316 310,974<br />
2,216,287 3,327,219 5,453,506<br />
Ratio of Construction to<br />
Operations<br />
Note:<br />
5% 6% 5%<br />
(a) The total construction GHG emissions are provided in EIA Volume 3, Section 3.4.8, Table 3.4-30.<br />
These construction emissions were annualized to facilitate a comparison to the operations<br />
emissions. The construction time period was assumed to be three years based on EIA, Volume 1,<br />
Section 14.0 and Volume 2, Section 14.0.<br />
(b) Source - EIA, Volume 3, Section 3.4.8, Tables 3.4-31 and 3.4-33.<br />
Given the considerably lower and transient nature of construction emissions,<br />
quantitative assessments of the construction phase of mining projects in the Oil<br />
Sands Region have not been conducted.<br />
Request Volume 2, SIR 72a, Page 18-39.<br />
In the original HHRA, Shell states that cabin Aboriginal residents will obtain all<br />
(100%) of their food and nutrition from local, natural food sources. In the SIR<br />
response, Shell states These rates do not account for consumption of non-sitespecific<br />
and non-traditional nutritional sources in the diet, such as root<br />
vegetables and leafy vegetables. The response suggests that the Aboriginal<br />
receptor predictions were not based on 100% consumption of food from local<br />
sources.<br />
86a If this is the case, provide an updated assessment for an Aboriginal receptor that<br />
does ingest all (100%) food from local, natural food sources.<br />
Response 86a In the Human Health Risk Assessment (HHRA; EIA, Volume 3, Section 5.3),<br />
cabin and Aboriginal residents were assumed to obtain all (100%) of their<br />
traditional foods (i.e., wild game, fish, berries, cattail roots, and wild mint and<br />
Labrador tea leaves) from local, natural sources. It was assumed that any nontraditional<br />
foods, which were not evaluated as part of the HHRA, would be<br />
purchased from local grocery stores. In this regard, the Terms of Reference<br />
assigned to the work specified consideration of the potential implications for<br />
public health arising from the project. Specifically:<br />
c) identify the human health impact of the potential contamination of<br />
country foods and natural food sources, taking into consideration all<br />
<strong>Project</strong> activities.<br />
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It was assumed as part of the HHRA that cabin and Aboriginal residents would<br />
only consume traditional meat, such as wild game and fish, and they would not<br />
consume any non-traditional meat obtained from local grocery stores. That is,<br />
cabin and Aboriginal residents were assumed to obtain all (100%) of their meat<br />
from local, natural sources. The wild game and fish consumption rates employed<br />
in the HHRA accurately reflected this assumption (see EIA, Volume 3, Section<br />
5.3.2). The HHRA consumption rates for wild game and fish are recommended<br />
by Health Canada for Canadian Aboriginal populations (Health Canada 2004).<br />
These consumption rates are based on summary data for wild game and fish<br />
‘eaters only’, which excludes individuals reporting no wild game or fish<br />
consumption. Using statistics for ‘eaters only’ ensures that the consumption rates<br />
of the individuals who consume the majority of the wild game and fish harvested<br />
are not under estimated.<br />
It was assumed that cabin and Aboriginal residents would rely to a lesser extent<br />
on local, natural sources for their fruits and vegetables (see EIA, Volume 3,<br />
Section 5.3.2). The fruit and vegetable consumption rates for cabin and<br />
Aboriginal residents were, therefore, designed to represent consumption of<br />
traditional berries, cattail roots, and wild mint and Labrador tea leaves only. The<br />
HHRA employed consumption rates for traditional berries, cattail roots, and wild<br />
mint and Labrador tea leaves that were based on a food consumption survey<br />
conducted near Wood Buffalo National Park (Wein 1989). The shortfall in<br />
nutritional requirements from local, natural fruits and vegetables was expected to<br />
be derived from produce purchased from the local grocery store.<br />
For comparative purposes, potential health risks associated with multiple<br />
pathways of exposure for cabin and Aboriginal residents were re-assessed such<br />
that all (100%) of their foods (traditional and non-traditional) would be obtained<br />
from local, natural sources. The revised consumption rates are listed in<br />
Table AENV 86-1.<br />
The updated risk quotients (RQ values) for the non-carcinogens are provided in<br />
Table AENV 86-2 for the cabin residents and in Table AENV 86-3 for the<br />
Aboriginal residents.<br />
In most instances, the updated RQ values did not exceed 1.0 for most chemicals<br />
of potential concern (COPCs), with the exceptions of:<br />
• manganese;<br />
• methyl mercury;<br />
• molybdenum;<br />
• the “neurotoxicants” mixture; and<br />
• the “reproductive and developmental toxicants” mixture.<br />
Risk quotients for methyl mercury, molybdenum, the “neurotoxicants” mixture<br />
and the “reproductive and developmental toxicants” mixture exceeded the<br />
benchmark of 1.0 in the Additional Environmental Setting Report (May 2009<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 2, Appendix B, Section 4,<br />
Table 4.7-1 and Table 4.7-2) and the HHRA (see EIA, Volume 3, Section<br />
5.3.3.3, Table 5.3-42 and Table 5.3-43). The updated RQ values for methyl<br />
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Section 14.1<br />
mercury and molybdenum, in fact, remain essentially unchanged from the<br />
Additional Environmental Setting Report and the HHRA because the fish<br />
consumption pathway remained the dominant exposure pathway contributing to<br />
the predicted RQ values for these COPCs. Discussion of predicted RQ values for<br />
methyl mercury and molybdenum can be found in EIA, Volume 3, Section<br />
5.3.3.3.<br />
Risk quotients for manganese, the “neurotoxicants” mixture and the<br />
“reproductive and developmental toxicants” mixture were predicted to increase<br />
from those reported in the Additional Environmental Setting Report (May 2009<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>, Supplemental Information, Volume 2, Appendix B, Section 4)<br />
and the HHRA (see EIA, Volume 3, Section 5.3.3.3). Manganese was the only<br />
COPC for which the predicted RQ values increased above the benchmark of 1.0<br />
due to the inclusion of non-traditional food consumption in the multiple pathway<br />
assessment.<br />
The predicted RQ values for manganese, the “neurotoxicants” mixture and the<br />
“reproductive and developmental toxicants” mixture are discussed below.<br />
Table AENV 86-1: Consumption Rates for the Cabin and Aboriginal Residents<br />
Consumption Rate<br />
Life Stages<br />
(a)<br />
(g/d) Infant (b) Toddler Child Adolescent Adult Reference<br />
Traditional Foods<br />
moose 0 65 95 133 205 Health Canada (2004a); Wein (1989)<br />
snowshoe hare 0 14 20 28 43 Health Canada (2004a); Wein (1989)<br />
ruffed grouse 0 7 10 14 22 Health Canada (2004a); Wein (1989)<br />
fish 0 22 40 47 51 Health Canada (2004a); FMES<br />
(1996); AHW (2007)<br />
berries 3 5 11 19 23 Wein (1989); AHW (2007)<br />
cattail root 0.4 1 1 3 3 Wein (1989); AHW (2007)<br />
wild mint and Labrador<br />
tea leaves<br />
0.4 1 1 3 3 Wein (1989); AHW (2007)<br />
Non-Traditional Foods<br />
fruit (c) 0 40 69 56 46 Health Canada (1994)<br />
root vegetables 0 105 161 227 188 Health Canada (2004a)<br />
leafy vegetables 0 67 98 120 137 Health Canada (2004a)<br />
Note:<br />
(a) Consumption rates for the traditional foods remain unchanged from the HHRA (EIA, Volume 3, Section 5.3.2,<br />
Table 5.3-5).<br />
(b) Infants are assumed to ingest 664 grams per day of breast milk (O’Connor and Richardson 1997; Health Canada 1994).<br />
(c) Fruit consumption rates based on composite of apples, apple sauce, cherries, strawberries, blueberries, jams and honey.<br />
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Table AENV 86-2: Chronic Risk Quotients from Multiple Pathways of Exposure – Cabin<br />
Residents<br />
Risk Quotient (a)<br />
Chemical of Potential Concern Base Case Application Case<br />
Planned<br />
Development Case<br />
1,1,1-trichloroethane 1.9E-04 1.9E-04 1.9E-04<br />
1,2-dichloropropane 4.4E-03 4.4E-03 4.4E-03<br />
aliphatic C5-C8 group 1.4E-04 3.5E-04 3.6E-04<br />
aliphatic C9-C16 group 1.9E-02 3.8E-02 4.0E-02<br />
aliphatic C17-C34 group 2.5E-07 1.1E-03 1.1E-03<br />
aluminum 5.7E-02 5.8E-02 5.8E-02<br />
antimony 3.5E-01 3.5E-01 3.6E-01<br />
aromatic C9-C16 group 3.1E-02 3.2E-02 3.4E-02<br />
aromatic C17-C34 group 2.5E-05 2.8E-05 2.8E-05<br />
barium 2.6E-01 2.6E-01 2.7E-01<br />
beryllium 3.2E-02 4.0E-02 4.0E-02<br />
biphenyls 7.4E-03 7.4E-03 7.4E-03<br />
boron 2.4E-01 2.9E-01 2.9E-01<br />
cadmium 3.3E-01 4.0E-01 4.9E-01<br />
chromium 2.3E-03 2.3E-03 2.3E-03<br />
chromium VI 1.1E-01 1.1E-01 1.1E-01<br />
copper 1.0E-01 1.0E-01 1.1E-01<br />
lead 2.8E-01 2.8E-01 2.9E-01<br />
manganese 1.3E+00 1.3E+00 1.3E+00<br />
mercury 3.3E-01 3.3E-01 3.5E-01<br />
methyl mercury 8.3E+00 8.3E+00 8.3E+00<br />
molybdenum 1.6E+00 3.0E+00 3.0E+00<br />
naphthalene group 1.8E-03 1.8E-03 1.8E-03<br />
nickel 2.7E-01 2.7E-01 2.7E-01<br />
selenium 4.8E-02 5.5E-02 5.8E-02<br />
silver 1.2E-01 1.2E-01 1.2E-01<br />
strontium 1.7E-01 1.7E-01 1.7E-01<br />
tin 7.5E-02 7.5E-02 7.5E-02<br />
vanadium 2.2E-01 2.5E-01 2.5E-01<br />
zinc 8.4E-01 8.4E-01 8.4E-01<br />
Mixtures (b)<br />
hepatotoxicants 5.4E-02 7.6E-02 7.9E-02<br />
renal toxicants 6.3E-01 7.1E-01 8.0E-01<br />
haematological toxicants 9.4E-01 9.6E-01 9.7E-01<br />
neurotoxicants 9.9E+00 9.9E+00 9.9E+00<br />
reproductive/developmental<br />
toxicants<br />
Note:<br />
9.2E+00 9.3E+00 9.3E+00<br />
(a) An RQ equal to or less than 1.0 signifies that the estimated exposure is less than the exposure limit and no health<br />
effects are expected. Boldface values show an RQ of greater than 1.0. With scientific notation, any value<br />
expressed to the negative power (i.e., E-x) shows that predicted exposures were less than the exposure limit;<br />
whereas, a value expressed to the positive power (i.e., E+x) shows that exposure estimates exceeded the<br />
exposure limit.<br />
(b) Individual constituents of the chemical mixtures are identified in EIA, Volume 3, Section 5.3.2.3, Table 5.3-13.<br />
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Table AENV 86-3: Chronic Risk Quotients from Multiple Pathways of Exposure –<br />
Aboriginal Residents<br />
Risk Quotient (a)<br />
Chemical of Potential Concern Base Case Application Case<br />
Planned<br />
Development Case<br />
1,1,1-trichloroethane 1.9E-04 1.9E-04 1.9E-04<br />
1,2-dichloropropane 4.4E-03 4.4E-03 4.4E-03<br />
aliphatic C5-C8 group 3.5E-03 3.7E-03 4.5E-03<br />
aliphatic C9-C16 group 1.7E-02 3.6E-02 3.7E-02<br />
aliphatic C17-C34 group 8.0E-05 1.2E-03 1.2E-03<br />
aluminum 6.2E-02 6.2E-02 6.2E-02<br />
antimony 3.4E-01 3.4E-01 3.4E-01<br />
aromatic C9-C16 group 7.2E-02 7.3E-02 7.6E-02<br />
aromatic C17-C34 group 3.1E-05 3.2E-05 3.3E-05<br />
barium 5.2E-02 5.2E-02 5.3E-02<br />
beryllium 2.8E-02 3.6E-02 3.6E-02<br />
biphenyls 7.4E-03 7.4E-03 7.4E-03<br />
boron 2.5E-01 2.7E-01 2.7E-01<br />
cadmium 3.1E-01 3.8E-01 5.1E-01<br />
chromium 2.2E-03 2.2E-03 2.2E-03<br />
chromium VI 1.1E-01 1.1E-01 1.1E-01<br />
copper 1.6E-01 1.6E-01 1.7E-01<br />
lead 2.7E-01 2.7E-01 2.8E-01<br />
manganese 1.3E+00 1.3E+00 1.3E+00<br />
mercury 3.3E-01 3.3E-01 3.5E-01<br />
methyl mercury 8.3E+00 8.3E+00 8.3E+00<br />
molybdenum 1.4E+00 2.6E+00 2.6E+00<br />
naphthalene group 1.8E-03 1.8E-03 1.8E-03<br />
nickel 2.2E-01 2.2E-01 2.2E-01<br />
selenium 4.4E-02 5.1E-02 5.4E-02<br />
silver 1.2E-01 1.2E-01 1.2E-01<br />
strontium 1.6E-01 1.7E-01 1.7E-01<br />
tin 7.5E-02 7.5E-02 7.5E-02<br />
vanadium 2.2E-01 2.4E-01 2.4E-01<br />
zinc 8.4E-01 8.4E-01 8.4E-01<br />
Mixtures (b)<br />
hepatotoxicants 9.4E-02 1.1E-01 1.2E-01<br />
renal toxicants 4.4E-01 5.1E-01 6.4E-01<br />
haematological toxicants 9.4E-01 9.6E-01 9.6E-01<br />
neurotoxicants 9.9E+00 9.9E+00 9.9E+00<br />
reproductive/developmental<br />
toxicants<br />
Note:<br />
9.2E+00 9.2E+00 9.2E+00<br />
(a) An RQ equal to or less than 1.0 signifies that the estimated exposure is less than the exposure limit and no health<br />
effects are expected. Boldface values show an RQ of greater than 1.0. With scientific notation, any value<br />
expressed to the negative power (i.e., E-x) shows that predicted exposures were less than the exposure limit;<br />
whereas, a value expressed to the positive power (i.e., E+x) shows that exposure estimates exceeded the<br />
exposure limit.<br />
(b) Individual constituents of the chemical mixtures are identified in EIA, Volume 3, Section 5.3.2.3, Table 5.3-13.<br />
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As shown in Table AENV 86-4 and Table AENV 86-5, the maximum predicted<br />
incremental lifetime cancer risks (ILCR values) associated with the project (i.e.,<br />
Application Case minus Base Case) and Future Emission Sources in the area<br />
(i.e., PDC minus Base Case) are all less than one in 100,000 indicating that the<br />
incremental cancer risk from the project and planned development is deemed to<br />
be “essentially negligible” (Health Canada 2004).<br />
Although lifetime cancer risks (LCR values) greater than 1.0 were predicted for<br />
the Base Case assessment of arsenic and the “liver carcinogen” mixture, these<br />
values represent the number of cancer cases that could theoretically result from<br />
the estimated exposures to these carcinogenic COPCs in a population of 100,000<br />
people. Lifetime cancer risks for arsenic and the “liver carcinogen” mixture were<br />
also found to exceed 1.0 in the HHRA (EIA, Volume 3, Section 5.3.3.3,<br />
Table 5.3-42 and Table 5.3-43).<br />
The predicted LCR values for arsenic and the “liver carcinogen” mixture are<br />
discussed below.<br />
Table AENV 86-4: Chronic Lifetime and Incremental Lifetime Cancer Risks per 100,000<br />
from Multiple Pathways of Exposure – Cabin Residents<br />
Chemical of Potential<br />
Concern Base Case<br />
Lifetime Cancer<br />
Risk (a) Incremental Lifetime Cancer Risk (b)<br />
<strong>Project</strong><br />
(Application-Base)<br />
Future Emission<br />
Sources<br />
(PDC-Base)<br />
1,1,2-trichloroethane 9.8E-01 4.8E-13 4.3E-13<br />
arsenic 1.9E+01 3.7E-03 2.6E-01<br />
carbon tetrachloride 1.3E-01 8.3E-13 1.5E-12<br />
carcinogenic PAH group 1 5.7E-01 2.0E-01 2.1E-01<br />
carcinogenic PAH group 2 7.8E-02 9.0E-02 9.6E-02<br />
carcinogenic PAH group 3 1.3E-02 4.6E-03 4.9E-03<br />
Mixtures (c)<br />
stomach carcinogens 6.6E-01 2.9E-01 3.1E-01<br />
liver carcinogens<br />
Note:<br />
2.0E+01 3.7E-03 2.6E-01<br />
(a) Lifetime cancer risks refer to the number of cancer cases that could potentially result from the estimated exposures<br />
to the carcinogenic COPCs among a population of 100,000 people. Since an acceptable cancer incidence rate has<br />
not been recommended for exposure to carcinogens associated with anything other than the <strong>Project</strong> and Future<br />
Emission Sources by any leading scientific or regulatory authority, interpretation of the significance of the LCR<br />
values determined for the Base Case could be not based on comparison against a numerical “benchmark” of one<br />
in 100,000.<br />
(b) An ILCR equal to or less than 1.0 signifies an incremental lifetime cancer risk that is below the benchmark ILCR of<br />
one in 100,000 (i.e., within the generally accepted limit deemed to be protective of public health). Boldface values<br />
show an ILCR of greater than the de minimus risk level of one in 100,000.<br />
(c) Individual constituents of the chemical mixtures are identified in EIA Volume 3, Section 5.3.2.3, Table 5.3-13.<br />
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Table AENV 86-5: Chronic Lifetime and Incremental Lifetime Cancer Risks per 100,000<br />
from Multiple Pathways of Exposure – Aboriginal Residents<br />
Chemical of Potential<br />
Concern Base Case<br />
Lifetime Cancer<br />
Risk (a) Incremental Lifetime Cancer Risk (b)<br />
<strong>Project</strong><br />
(Application-Base)<br />
Future Emission<br />
Sources<br />
(PDC-Base)<br />
1,1,2-trichloroethane 9.8E-01 3.2E-12 2.6E-11<br />
arsenic 2.0E+01 3.2E-03 2.6E-01<br />
carbon tetrachloride 1.3E-01 7.4E-13 2.2E-11<br />
carcinogenic PAH group 1 4.9E-01 1.9E-01 2.1E-01<br />
carcinogenic PAH group 2 6.1E-02 8.0E-02 8.7E-02<br />
carcinogenic PAH group 3 1.2E-02 4.5E-03 4.7E-03<br />
Mixtures (c)<br />
stomach carcinogens 5.6E-01 2.7E-01 3.0E-01<br />
liver carcinogens 2.1E+01 3.2E-03 2.6E-01<br />
Note:<br />
(a) Lifetime cancer risks refer to the number of cancer cases that could potentially result from the estimated exposures<br />
to the carcinogenic COPCs among a population of 100,000 people. Since an acceptable cancer incidence rate has<br />
not been recommended for exposure to carcinogens associated with anything other than the <strong>Project</strong> and Future<br />
Emission Sources by any leading scientific or regulatory authority, interpretation of the significance of the LCR<br />
values determined for the Base Case could be not based on comparison against a numerical “benchmark” of one<br />
in 100,000. With scientific notation, any value expressed to the negative power (i.e., E-x) shows that predicted<br />
exposures were less than the exposure limit; whereas, a value expressed to the positive power (i.e., E+x) shows<br />
that exposure estimates exceeded the exposure limit.<br />
(b) An ILCR equal to or less than 1.0 signifies an incremental lifetime cancer risk that is below the benchmark ILCR of<br />
one in 100,000 (i.e., within the generally accepted limit deemed to be protective of public health). Boldface values<br />
show an ILCR of greater than the de minimus risk level of one in 100,000. With scientific notation, any value<br />
expressed to the negative power (i.e., E-x) shows that predicted exposures were less than the exposure limit;<br />
whereas, a value expressed to the positive power (i.e., E+x) shows that exposure estimates exceeded the<br />
exposure limit.<br />
(c) Individual constituents of the chemical mixtures are identified in EIA, Volume 3, Section 5.3.2.3, Table 5.3-13.<br />
Manganese<br />
Risk quotients above 1.0 (i.e., 1.3) were predicted for cabin and Aboriginal<br />
residents under the Base Case, Application Case and Planned Development Case<br />
(PDC). In the HHRA, RQ values of 0.19 and 1.6 were predicted for the cabin and<br />
Aboriginal residents, respectively.<br />
Interpretation of these findings considered the following factors:<br />
• the potential contribution from the project to these predicted exceedances;<br />
• the primary exposure pathway(s) contributing to these predicted<br />
exceedances;<br />
• the use of the 95th upper confidence interval on the mean (95UCLM) of<br />
concentrations of manganese in various media versus the average<br />
concentration; and,<br />
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• the high degree of conservatism incorporated in the consumption patterns of<br />
these residents and the assumed exposure limit.<br />
The RQ values for the cabin and Aboriginal residents were not predicted to<br />
change between the Base Case and Application Case, indicating that all of the<br />
predicted RQ values under the Application Case and PDC are the result of the<br />
Base Case predictions, and that the project is not likely to increase the risk of<br />
long-term exposure to manganese.<br />
Examination of the contributing exposure pathways revealed that consumption of<br />
non-traditional fruits and vegetables represents most (86%) of the predicted RQ<br />
values for the cabin and Aboriginal residents. Lesser contributions were<br />
identified for the ingestion of berries, cattail roots and, in the case of cabin<br />
residents, the ingestion of drinking water. The contribution of each of these<br />
exposure pathways to the RQ values for manganese is shown in<br />
Table AENV 86-6. The contribution from the remaining exposure pathways was<br />
negligible.<br />
Table AENV 86-6: Contribution of Individual Exposure Pathways to Potential Risk<br />
Quotients for Manganese<br />
Contribution<br />
(%)<br />
Exposure Pathway (a) Planned<br />
Base Case Application Case Development Case<br />
ingestion of drinking water (b) Traditional Foods<br />
3 3 3<br />
ingestion of berries 6 6 6<br />
ingestion of cattail roots 2 2 2<br />
Non-Traditional Foods<br />
ingestion of fruit 30 30 30<br />
ingestion of root vegetables 13 13 13<br />
ingestion of leafy vegetables 43 43 43<br />
Note:<br />
(a) The most sensitive life stage was identified as the toddler.<br />
(b) The contribution reported for the ingestion of drinking water is specific to cabin residents. For the Aboriginal<br />
residents, the contribution from the ingestion of drinking water was negligible.<br />
With the exception of the drinking water pathway, all of the contributing<br />
exposure pathways identified above were highly influenced by the measured<br />
background soil concentration of manganese. Regional manganese soil<br />
concentrations ranged from 1.8 to 5,800 mg/kg, with an average concentration of<br />
460 mg/kg. The 95UCLM concentration of 610 mg/kg was used to characterize<br />
background soil concentrations of manganese and subsequently predict<br />
background manganese concentrations in local, natural foods consumed by cabin<br />
and Aboriginal residents.<br />
The assumption that cabin and Aboriginal residents would obtain all (100%) of<br />
their foods (traditional and non-traditional) from local, natural sources, when in<br />
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all likelihood some portion of their diet would be purchased from a local grocery<br />
store, together with the assumption that all local, natural foods would grow from<br />
soil containing the 95UCLM concentration of manganese, likely contributed to<br />
the exaggeration of the exposures that might be received by these residents under<br />
actual circumstances.<br />
A less conservative estimate of risk would be to assume that the average<br />
manganese soil concentration is representative of soil concentrations in the<br />
region. Based on this less conservative assumption, the manganese RQ values for<br />
cabin and Aboriginal residents would no longer exceed 1.0 under the Base Case,<br />
Application Case and PDC. This still conservatively assumes that cabin and<br />
Aboriginal residents would obtain all (100%) of their foods (traditional and nontraditional)<br />
from local, natural sources.<br />
With respect to the toxicity assessment of manganese, the oral exposure limit<br />
used in the multiple pathway assessment was derived by the US EPA using<br />
toxicity data obtained from large populations consuming normal diets over an<br />
extended period of time with no reported adverse health effects (US EPA 1996).<br />
In fact, the level at which adverse effects of dietary manganese exposure would<br />
be observed has not yet been identified (WHO 2004).<br />
Manganese is an essential element required for enzyme co-factors and constituent<br />
of metalloenzymes. No adverse health effects were noted among humans with<br />
daily intakes ranging from 2,000 to 7,000 µg/d (Health Canada 1987). On this<br />
basis, Health Canada (2006) has established a tolerable upper intake level (UL)<br />
for a toddler of 2,000 to 3,000 µg/d for manganese. The UL is the highest<br />
average daily nutrient intake level likely to pose no risk of adverse health effects<br />
to almost all individuals in the given life stage and gender group (Health Canada<br />
2006).<br />
The WHO (2004) reports that average adult manganese intakes range from 700 to<br />
10,900 µg/d and considers there to be no observable adverse effects at the upper<br />
range of dietary intakes for manganese. Furthermore, WHO (2004) noted in its<br />
toxicological review that dietary manganese is not considered to be very toxic to<br />
humans given the existence of homeostatic mechanisms.<br />
The predicted RQ value of 1.3 is associated with a maximum daily intake for a<br />
toddler of 3,100 µg/d. Although this maximum daily intake slightly exceeds<br />
Health Canada’s UL for manganese, it falls within the range of daily intakes for<br />
which Health Canada and WHO have reported no adverse health effects in<br />
humans.<br />
Overall, the likelihood for adverse health effects associated with manganese<br />
exposure in the region is low, for the following reasons:<br />
• Most (86%) of the RQ values under the Base Case are the result of nontraditional<br />
fruit and vegetable consumption.<br />
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Neurotoxicants<br />
Section 14.1<br />
• The high degree of conservatism incorporated in the predicted fruit and<br />
vegetable concentrations through the use of the 95UCLM soil concentration<br />
to represent regional background soil concentrations of manganese.<br />
• Cabin and Aboriginal residents were assumed to obtain all (100%) of their<br />
food (traditional and non-traditional) from local, natural sources over their<br />
lifetimes, and not supplement their diet with any foods from the local grocery<br />
store.<br />
• Estimates of daily exposure in the region remain within the range of typical<br />
human exposures (Health Canada 1987, WHO 2004).<br />
• The degree of conservatism incorporated in the oral exposure limit.<br />
The RQ values for the “neurotoxicants” mixture increased from 8.7 in the HHRA<br />
to 9.9 due to the inclusion of non-traditional foods in the multiple pathway<br />
assessment.<br />
For the following reasons, the likelihood for people living in the region to<br />
experience neurotoxicity as a result of the project or planned developments is<br />
low:<br />
• No change was predicted between the Base Case and Application Case RQ<br />
values.<br />
• All (100%) of the RQ values under the Application Case and the PDC were<br />
associated with the Base Case.<br />
• Risk quotients associated with methyl mercury, which is still the primary<br />
contributor to the mixture RQ values, are conservative estimates based on the<br />
assumptions made in the HHRA (see EIA, Volume 3, Section 5.3.3.3).<br />
• Most of the RQ values under the Base Case were still the result of assumed<br />
fish consumption.<br />
• It was assumed that residents would obtain all (100%) of their food,<br />
including fish, from the local, natural sources over their lifetimes.<br />
Reproductive and Developmental Toxicants<br />
The RQ values for the “reproductive and developmental toxicants” mixture<br />
increased for cabin residents from 8.9 to 9.0 in the HHRA to 9.2 to 9.3 due to the<br />
inclusion of non-traditional foods in the multiple pathway assessment. Similarly,<br />
the RQ values for Aboriginal residents increased from 8.8 to 9.2.<br />
For the following reasons, the project is not likely to result in adverse health<br />
effects associated with exposure to reproductive and developmental toxicants in<br />
the region:<br />
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• No or negligible change in predicted RQ values between the Base Case and<br />
Application Case.<br />
• The Base Case contributes most of the RQ values under the Application Case<br />
and the PDC (99 to 100%).<br />
• Risk quotients associated with methyl mercury, which is still the primary<br />
contributor to the mixture RQ values, are conservative estimates based on the<br />
assumptions made in the HHRA (see EIA, Volume 3, Section 5.3.3.3).<br />
• Most of the RQ values under the Base Case were the result of the assumed<br />
fish consumption.<br />
• It was assumed that residents would obtain all (100%) of their food,<br />
including fish, from the local, natural sources over their lifetimes.<br />
Arsenic and Liver Carcinogens<br />
The Base Case LCR values range from 19 to 21 for arsenic and the liver<br />
carcinogens, signifying that lifetime exposure to background levels of<br />
carcinogens via multiple pathway exposures could potentially account for up to<br />
21 cases of cancer when calculated on a 100,000 person population basis. The<br />
Base Case LCR values are up from those predicted as part of the HHRA (see<br />
EIA, Volume 3, Section 5.3.3.3).<br />
The regulatory benchmark of an acceptable incremental lifetime cancer risk of<br />
one in 100,000 is policy-based. Regulators have not recommended an acceptable<br />
cancer incidence rate (or LCR) for exposure to carcinogens associated with<br />
background or “baseline” conditions. The “acceptability” of this potential<br />
lifetime cancer risk from a public health perspective cannot be determined<br />
following a conventional approach since an acceptable “benchmark” cancer risk<br />
level for exposure to background levels of carcinogens is not available for<br />
comparison.<br />
In a recent study conducted on behalf of Alberta Health and Wellness, “baseline”<br />
lifetime cancer risks were estimated to range from 17 to 33 in 100,000 (AHW<br />
2007). Note that the risk estimates for the baseline scenario in the AHW study<br />
are similar to those presented for the revised Base Case.<br />
For the following reasons, the project is not likely to result in adverse health<br />
effects associated with exposure to arsenic and the liver carcinogens, as a whole,<br />
in the region:<br />
• Incremental lifetime cancer risks for arsenic and the liver carcinogens did not<br />
exceed the regulatory benchmark of 1.0.<br />
• Use of the exposure limit adopted from Health Canada, which was derived<br />
based on the premise that arsenic acts as a “non-threshold” carcinogen, may<br />
overstate the carcinogenic potency of arsenic and subsequently the<br />
carcinogenic potency of the liver carcinogens.<br />
April 2010 Shell Canada Limited 14-33<br />
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HEALTH AENV SIRS 79 – 89<br />
References<br />
Section 14.1<br />
AHW (Alberta Health and Wellness). 2007. Assessment of the Potential Lifetime<br />
Cancer Risks Associated with Exposure to Inorganic Arsenic among<br />
Indigenous People Living in the Wood Buffalo Region of Alberta.<br />
Prepared by Cantox Environmental Inc. March 2007.<br />
FMES( Fort McKay Environmental Services). 1996. A Survey of the<br />
Consumptive Use of Traditional Resources in the Community of Fort<br />
McKay. Completed for Syncrude Canada Ltd. May 23, 1997.<br />
Health Canada. 1987. Manganese. Guidelines for Canadian Drinking Water<br />
Quality – Supporting Documents. November 1987.<br />
Health Canada. 1994. Human Health Risk Assessment for Priority Substances.<br />
Canadian Communications Group Publishing. Ottawa, ON.<br />
Health Canada. 2004. Contaminated Sites Program - Federal Contaminated Site<br />
Risk Assessment in Canada Part I- Guidance on Preliminary Human<br />
Health Preliminary Quantitative Risk Assessment<br />
(PQRA).Environmental Health Assessment Services Safe Environments<br />
Program. Ottawa, ON. September 2004. ISBN 0-662-38244-7<br />
Health Canada. 2006. Dietary Reference Intakes Tables. ISBN 0-662-41134-X.<br />
Available at: http://www.hc-sc.gc.ca/fnan/nutrition/reference/table/index_e.html<br />
O’Connor and Richardson (O’Connor Associates Environmental Inc. and G.M.<br />
Richardson). 1997. Compendium, of Canadian Human Exposure Factors<br />
for Risk Assessment. Ottawa, ON.<br />
US EPA (United States Environmental Protection Agency). 1996. Manganese<br />
(CASRN 7439-96-5). Inhalation RfC Assessment. Integrated Risk<br />
Information System (IRIS) database on-line search. United States<br />
Environmental Protection Agency. Cincinnati, OH. Available at:<br />
http://www.epa.gov/iris/subst/0373.htm. Accessed September 2007.<br />
Wein, E.E. 1989. Nutrient Intakes and use of Country Foods by Native<br />
Canadians Near Wood Buffalo National Park. Thesis presented to the<br />
Faculty of Graduate Studies, University of Guelph. February 1989.<br />
WHO (World Health Organization). 2004. Manganese in Drinking-water –<br />
Background document for development of WHO Guidelines for<br />
Drinking-water Quality. World Health Organization.<br />
WHO/SDE/WSH/03.04/104.<br />
14-34 Shell Canada Limited April 2010<br />
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HEALTH AENV SIRS 79 – 89<br />
Question No. 87<br />
Request Volume 2, SIR 75c, Page 18-47.<br />
Section 14.1<br />
Shell states that as part of the water quality assessment and the aquatic<br />
assessment substances of potential concern were comprehensively screened.<br />
87a Clarify if the screening was based on human health endpoints. If not, update the<br />
HHRA accordingly.<br />
Response 87a All chemicals potentially released to local surface water, with the exceptions of<br />
dissolved solids and nutrients, were evaluated as part of the multiple pathway<br />
assessment in the Human Health Risk Assessment (see EIA, Volume 3, Section<br />
5.3.2.2). That is, no screening of the chemicals potentially released to local<br />
surface water bodies was conducted for the HHRA.<br />
Question No. 88<br />
Request Volume 2, SIR 80a, Page 18-75<br />
88a Clarify if cabin residents also share Aboriginal receptor characteristics. If so,<br />
identify.<br />
Response 88a Cabin and Aboriginal residents share the same physical characteristics (i.e., body<br />
weight, inhalation rate, soil ingestion rate, water ingestion rate and body surface<br />
area) and lifestyle characteristics (i.e., time spent at the cabin or residence and<br />
food consumption rates) (see EIA, Volume 3, Section 5.3). The only difference in<br />
the assessment of potential health risks for cabin and Aboriginal residents were<br />
the discrete locations at which they were assumed to permanently reside and the<br />
source of their drinking water.<br />
Cabin residents were assessed using the highest exposed of the 12 cabins<br />
identified in Table 5.3-4 of the HHRA (see EIA, Volume 3, Section 5.3), while<br />
Aboriginal residents were assessed using the highest exposed of the nine<br />
applicable communities (Anzac, Clearwater (IR 175), Conklin, Descharme Lake,<br />
Fort Chipewyan, Fort McKay, Fort McMurray, Janvier/Chard (IR 194), La<br />
Loche, Namur <strong>River</strong> (IR 174A) and Poplar Point (IR 201G)).<br />
With respect to drinking water, cabin residents were assumed to drink water from<br />
local surface waterbodies, while Aboriginal residents were assumed to have<br />
access to the Fort McKay municipal water supply.<br />
April 2010 Shell Canada Limited 14-35<br />
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HEALTH AENV SIRS 79 – 89<br />
Question No. 89<br />
Request Volume 2, SIR 99a, Page 18-130.<br />
Section 14.1<br />
Shell notes that, for aliphatic C5-C8 compounds and aromatic C9-C16 compounds,<br />
the use of a less conservative relative absorption factor (RAF) does not affect the<br />
predictions in the HHRA.<br />
89a Re-assess these compounds using the CCME recommended value of 0.2 in order<br />
to quantitatively prove this conclusion.<br />
Response 89a The aliphatic C5-C8 group and aromatic C9-C16 group were re-assessed using the<br />
CCME dermal relative absorption factor (RAF) of 0.2. The updated risk<br />
quotients (RQ values) for the aliphatic and aromatic group are presented for each<br />
of the lifestyle categories evaluated as part of the multiple pathway assessment<br />
(i.e., cabin residents, Aboriginal residents, community residents and workers).<br />
Updated RQ values are also provided for the cabin and Aboriginal residents that<br />
consider an alternative consumption pattern to that used in the HHRA (i.e., 100%<br />
of their food would be obtained from local, natural sources), as further discussed<br />
in the response to AENV SIR 86.<br />
As shown in Table AENV 89-1, use of the CCME RAF value did not materially<br />
change the results or the conclusion of the HHRA. The updated multiple pathway<br />
RQ values for the aliphatic C5-C8 group and aromatic C9-C16 group did not<br />
exceed 1.0 under any circumstance. This demonstrates that the estimated<br />
exposure remains less than the exposure limit (i.e., the assumed safe level of<br />
exposure). Therefore, health risks for the aliphatic C5-C8 group and aromatic C9-<br />
C16 group remain low.<br />
14-36 Shell Canada Limited April 2010<br />
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HEALTH AENV SIRS 79 – 89<br />
Table AENV 89-1: Chronic Risk Quotients from Multiple Pathways of Exposure<br />
Section 14.1<br />
Chemical of<br />
Base Case Application Case Planned Development Case<br />
Potential Concern HHRA SIR 86 SIR 89 HHRA SIR 86 SIR 89 HHRA SIR 86 SIR 89<br />
Cabin Residents<br />
aliphatic C5-C8 group 1.4E-04 1.4E-04 1.4E-04 3.5E-04 3.5E-04 3.5E-04 3.6E-04 3.6E-04 3.6E-04<br />
aromatic C9-C16 group 2.1E-02 3.1E-02 3.1E-02 2.2E-02 3.2E-02 3.2E-02 2.4E-02 3.4E-02 3.4E-02<br />
Aboriginal Residents<br />
aliphatic C5-C8 group 3.5E-03 3.5E-03 3.5E-03 3.7E-03 3.7E-03 3.7E-03 4.5E-03 4.5E-03 4.5E-03<br />
aromatic C9-C16 group 6.2E-02 7.2E-02 7.2E-02 6.3E-02 7.3E-02 7.3E-02 6.6E-02 7.6E-02 7.6E-02<br />
Community<br />
Residents<br />
aliphatic C5-C8 group 3.4E-03 n/a 3.4E-03 3.5E-03 n/a 3.5E-03 4.2E-03 n/a 4.3E-03<br />
aromatic C9-C16 group 6.4E-02 n/a 6.4E-02 6.4E-02 n/a 6.4E-02 7.4E-02 n/a 7.4E-02<br />
Workers<br />
aliphatic C5-C8 group 6.2E-03 n/a 6.2E-03 6.2E-03 n/a 6.2E-03 7.0E-03 n/a 7.0E-03<br />
aromatic C9-C16 group 6.2E-02 n/a 6.2E-02 7.7E-02 n/a 7.7E-02 7.8E-02 n/a 7.8E-02<br />
Note:<br />
1. AENV SIR 86 refers to an alternative scenario to the HHRA, whereby cabin and Aboriginal residents would obtain 100% of their food<br />
from local, natural sources. The HHRA assumed 100% except for fruit and vegetable consumption rates.<br />
2. AENV SIR 89 refers to an alternative scenario to the HHRA, as discussed above, whereby the dermal bioavailability of 0.2 for all<br />
aliphatic and aromatic compounds is applied<br />
April 2010 Shell Canada Limited 14-37<br />
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HEALTH AENV SIRS 79 – 89<br />
Section 14.1<br />
14-38 Shell Canada Limited April 2010<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 3: AENV SIRS – ROUND 2<br />
Question No. 90<br />
Request EIA Volume 2, Section 8.1, Page 8-4<br />
EPEA APPROVALS<br />
AENV SIRS 90 – 96<br />
Section 15.1<br />
90a Provide the water treatment and wastewater treatment plant designs, capacities,<br />
and expected effluent qualities to ensure the treatment plants will be capable of<br />
achieving the level of treatment required.<br />
Response 90a The wastewater treatment and water treatment facilities have not yet been<br />
designed. Therefore, design details, qualities and quantities are not currently<br />
available. The wastewater flows referenced in the application are estimates based<br />
on existing operations. As project engineering progresses, the facility sizing and<br />
requirements will be finalized. When designing these facilities, Shell will take<br />
into account the approved provincial guidelines and standards that exist at that<br />
time.<br />
Question No. 91<br />
Request EIA Volume 2, Section 20.2, Page 20-7.<br />
Shell indicates that within the proposed 10-year EPEA approval period (2010 to<br />
2019), soil salvage will not likely begin until 2017. Shell also states that Shell<br />
plans to salvage all upland surface soils in the mining areas and the plant site. It<br />
is unclear how a facility in the early stages of development will have no need to<br />
salvage soils in the first 7 years of operations.<br />
91a Confirm what activities (e.g., road construction, bridge construction, laydown<br />
yard construction, plant site development, etc.) will occur in the first 7 years that<br />
could trigger the need for soil salvage and stockpile.<br />
Response 91a Activities planned within the first seven years of development primarily occur<br />
within peatland soil types (dominant Muskeg, Mariana and Hartley organic soils,<br />
as shown in Figure 2.3-4 of Section 2 of the Jackpine <strong>Mine</strong> Expansion and <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> Environmental Setting Reports). As described in the <strong>Project</strong><br />
Description, Volume 2, Section 20.2, page 20-8, efforts were made in<br />
conservation planning to minimize time in stockpile by delaying salvage of peat-<br />
April 2010 Shell Canada Limited 15-1<br />
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EPEA APPROVALS AENV SIRS 90 – 96<br />
Question No. 92<br />
Section 15.1<br />
mineral materials until as late as possible in the development area, as more than<br />
twice the volume of peat is available within the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> development<br />
footprint as is required for closure and reclamation plans. Since the submittal of<br />
the Closure, Conservation and Reclamation (C,C&R) plan for the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> in 2007, further discussions with Alberta Environment and Alberta<br />
Sustainable Resource Development regarding methods of salvaging peat-mineral<br />
material, such as focusing salvage on the top 1 m of deeper peat areas, might<br />
alter the start date of salvage activities. This will be detailed in operational<br />
C,C&R plans.<br />
Activities, including access roads and bridge construction, will be underway by<br />
2011, and drainage of muskeg areas for plant site development will be underway<br />
by 2014. Reclamation material stockpile (RMS) areas will be created to store<br />
salvaged soils for reclamation activities, as shown in the C,C&R Plan for the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> (see <strong>Project</strong> Description, Volume 2, Section 20) and as further<br />
detailed in operational plans pending project approval.<br />
Request EIA Volume 2, Section 20.2, Tables 20-4 and 20-5, Page 20-9.<br />
The table indicates that no reclamation will occur for 20 years (2010-2029).<br />
92a Explain why there are no opportunities for earlier reclamation to occur.<br />
Response 92a The proposed <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> plan progression figures provided in EIA,<br />
Volume 5, Appendix 5-2 (and provided in a truncated version in EIA, Volume 2,<br />
Section 20) demonstrate that, between 2010 and 2029, all areas of the mine<br />
development area that are disturbed are still in active operation. By 2019, the<br />
mine development area is occupied by the plant site (active bitumen recovery<br />
status), the north overburden disposal area (first lift not yet completed) and the<br />
pit floor has been reached in 2018 in the first section of Cell 1 (active bitumen<br />
recovery status). By 2029, the plant site is still active, overburden from the Cell 1<br />
pit has been largely directed to in-pit dykes and the external tailings disposal area<br />
(active bitumen recovery status) and the north overburden dump disposal area is<br />
still completing the first lift. Table 20-4 and 20-5 in the <strong>Project</strong> Description,<br />
Volume 2, Section 20.2 note that reclamation material volumes after 2019 are<br />
aggregated into 10 year blocks. Therefore, reclamation started between 2029 and<br />
2039 is aggregated into the 2039 volumes.<br />
If opportunities become available, earlier reclamation of the active mine<br />
development structures will be detailed within closure and reclamation plans<br />
submitted as a requirement of an Environmental Protection and Enhancement<br />
Act approval for the <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>.<br />
15-2 Shell Canada Limited April 2010<br />
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EPEA APPROVALS AENV SIRS 90 – 96<br />
Question No. 93<br />
Request EIA Volume 2, Section 20.3, Table 20-6, Page 20-13.<br />
The table indicates that 62 ha are undisturbed pre-development.<br />
Section 15.1<br />
93a The table assumes that the land will remain undisturbed through operations to<br />
closure, however in the event that the land is disturbed in the future, the forestry<br />
capability class should be determined. Update the table to reflect the capability<br />
class of the 62 ha of land.<br />
Response 93a Table AENV 93-1 is an updated version of Table 20-6 to reflect the capability<br />
classes of the 62 ha of land.<br />
Table AENV 93-1: Changes in Predicted Forestry Capability Class Changes Following<br />
Reclamation in the <strong>Pierre</strong> <strong>River</strong> Mining Area - Revised<br />
Forestry<br />
Capability<br />
Class<br />
Area<br />
(ha)<br />
Pre-Development Closure Net Change<br />
% of<br />
Development<br />
Area<br />
Area<br />
(ha)<br />
% of<br />
Development<br />
Area<br />
April 2010 Shell Canada Limited 15-3<br />
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Area<br />
(ha)<br />
% of<br />
Development<br />
Area<br />
1 (high) 0 0 158 2 158 2<br />
2 (moderate) 556 5 1,361 13 805 8<br />
3 (low) 2,707 26 1,983 19 -724 -7<br />
4 (conditionally<br />
productive)<br />
3,739 36 3,696 35 -43 -1<br />
5 (nonproductive)<br />
littoral zones<br />
and marsh<br />
3,337 32 1,031 10 -2,306 -22<br />
0 0 254 2 254 2<br />
water/pit lake 65
EPEA APPROVALS AENV SIRS 90 – 96<br />
94a What other reclamation activities occur after end of mine life (2039)?<br />
Section 15.1<br />
Response 94a The following reclamation activities will follow applicable regulatory guidelines,<br />
approval conditions and approved reclamation plans:<br />
1. Facility decommissioning (e.g. plant site, camp areas, ancillary facilities).<br />
2. Recontouring landforms to maintain or create drainage, as outlined in the<br />
Closure Drainage Plan. This includes constructing the end pit lakes, final<br />
drainage channels, constructed wetlands, and outlet and inlet structures as<br />
required. Some recontouring of terrestrial areas may be required to respond<br />
to settlement of tailings materials, and to create appropriate slopes and<br />
aspects to achieve land capability objectives.<br />
3. Placement of suitable capping material (e.g., overburden), if required.<br />
4. Reclamation material placement on the recontoured areas.<br />
5. Revegetation of remaining landforms to target ecosites.<br />
6. The continuation of monitoring programs (water quality, soil, vegetation,<br />
wildlife, biodiversity), as necessary.<br />
7. Applying for Reclamation Certification of reclaimed areas.<br />
Request 94b How many years of reclamation work will need to occur after end of mine life?<br />
Response 94b Shell estimates that the reclamation activities described in the response to AENV<br />
SIR 94a will take approximately 10 years, except for monitoring and certification<br />
activities that will take place over a period negotiated with Alberta Environment.<br />
Request 94c At what year will Figure 29 of Volume 5 (final closure plan) be complete?<br />
Response 94c Shell estimates that Figure 29 will represent the year 2049.<br />
Question No. 95<br />
Request Volume 2, SIR 402b, Page 23-18.<br />
Shell provides a list of opportunities for progressive reclamation, including the<br />
construction of overburden dumps from the outside to the middle to allow<br />
reclamation of the outermost areas first. The response to SIR 402c and Figure<br />
402-2 indicates no reclamation will occur until 2031, when the dykes of the<br />
external tailings disposal area will occur (8 years prior to end of mine life). The<br />
15-4 Shell Canada Limited April 2010<br />
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EPEA APPROVALS AENV SIRS 90 – 96<br />
Section 15.1<br />
response to SIR 402c and Figure 402-2 do not seem to reflect those opportunities<br />
for reclaiming overburden dumps as they are constructed.<br />
95a Clarify and confirm that no opportunities for reclaiming any areas of overburden<br />
dumps exist prior to 2031 or revise the plan as applicable.<br />
Response 95a No opportunities exist for reclaiming areas of the overburden dumps at the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> before the end of 2029. As noted in the response to AENV SIR 92,<br />
construction of the first lift of the north overburden dump at the <strong>Pierre</strong> <strong>River</strong><br />
<strong>Mine</strong> will not be completed until after 2029 because of the diversion of<br />
overburden materials into in-pit dykes between 2018 and 2029. As soon as the<br />
first lift is completed, reclamation on the north overburden dump will begin.<br />
Question No. 96<br />
Request Volume 2, SIR Question 410a, Page 23-27.<br />
Shell indicates that care has been taken to minimize the stockpiled time of<br />
reclamation salvage materials.<br />
96a Given the large extent of disturbance and the fact that any reclamation is delayed<br />
until 2031, justify this statement.<br />
Response 96a Two mechanisms have been considered to minimize the time that reclamation<br />
salvage materials are stockpiled, bearing in mind that permanent reclamation<br />
might not be possible until 13 years after mine operations start in 2018.<br />
• Although permanent reclamation activities might not be available until 2031,<br />
the opportunity to farm salvaged soils, particularly surface soils during<br />
temporary reclamation activities will be considered for any area that might<br />
become available, such as the first lift of the north overburden disposal area.<br />
• Material balances for peat-mineral materials have been calculated for salvage<br />
and stockpiling as close as possible to the time of reclamation, to minimize<br />
the time materials are stockpiled, and to optimize opportunities for direct<br />
placement of peat. All upland soils will be salvaged and direct placed,<br />
stockpiled or farmed.<br />
April 2010 Shell Canada Limited 15-5<br />
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EPEA APPROVALS AENV SIRS 90 – 96<br />
Section 15.1<br />
15-6 Shell Canada Limited April 2010<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
PART 3: AENV SIRS – ROUND 2<br />
Question No. 97<br />
Request EIA Volume 2, Section 19.2.<br />
ERRATA<br />
AENV SIRS 97 – 98<br />
Section 16.1<br />
This section outlines the EPEA application requirements for approval of the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>. The header on the pages in this section indicate<br />
Application for Renewal. This is incorrect. Correct this header as this is an<br />
application for approval for a new (proposed) project.<br />
Response 97 Shell acknowledges that the header in EIA, Volume 2, Section 19.2, pp. 19-3 to<br />
19-34, was incorrect. The correct heading should have read Application for<br />
Approval. This information is also presented in Section 2.1, <strong>Project</strong> Description<br />
Errata.<br />
Question No. 98<br />
Request Volume 2, SIR 251, Page 20-48.<br />
Shell states that the chemical reaction scheme chosen for the CALGRID<br />
modelling assessment in 2000 was not specified.<br />
98a Given the potential for underestimating predicted ozone concentrations<br />
depending on which chemical reaction scheme is chosen as determined in the<br />
paper by Lueken et al. (2008) cited in the SIR, Shell should acknowledge that<br />
there is uncertainty in the accuracy of the predicted impacts on ambient ozone<br />
concentrations.<br />
Response 98a The ozone modelling work using the CALGRID model was completed by Earth<br />
Tech and Conor Pacific in 1998 and 2000. In the 1998 ozone modelling work<br />
(Earth Tech and Conor Pacific 1998), Carbon Bond 4 (CB4) was chosen as the<br />
chemical reaction mechanism in the CALGRID model. In the 2000 ozone<br />
modelling work (Earth Tech Inc. 2000), the chemical reaction mechanism chosen<br />
for the CALGRID model was not specified. While Shell did not perform the<br />
CALGRID modelling, it is understood that there is uncertainty in the accuracy of<br />
the predicted ambient ozone concentrations provided in these two studies.<br />
April 2010 Shell Canada Limited 16-1<br />
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ERRATA AENV SIRS 97 – 98<br />
References<br />
Section 16.1<br />
Earth Tech and Connor Pacific (Earth Tech Inc. and Connor Pacific<br />
Environmental Technologies Inc.) 1998. Initial CALGRID Ozone<br />
Modelling in the Athabasca Oil Sands Region. Prepared for Syncrude<br />
Canada Ltd.<br />
Earth Tech Inc. 2000. Draft Report – CALGRID Photochemical Modeling of<br />
Ozone Formation Around the Wood Buffalo National Park during the<br />
Summer of 1998. Prepared for the Wood Buffalo Environmental<br />
Association.<br />
16-2 Shell Canada Limited April 2010<br />
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PIERRE RIVER MINE<br />
SUPPLEMENTAL INFORMATION<br />
ROUND 2<br />
% The symbol for percent.<br />
< The symbol for less than.<br />
> The symbol for greater than.<br />
GLOSSARY<br />
°C The symbol for degrees Celsius.<br />
μg/m³ The symbol for microgram per cubic metre.<br />
μm The symbol for micron.<br />
μs/cm The symbol for microsiemens per cubic metre.<br />
a The metric symbol for year.<br />
AAAQO The abbreviation for Alberta Ambient Air Quality Objectives.<br />
absorption The penetration of a substance into the body of another substance.<br />
adsorption The surface retention of solid, liquid or gas particles by a solid or liquid.<br />
AENV The abbreviation for Alberta Environment.<br />
AEP The abbreviation for Alberta Environmental Protection.<br />
AER The abbreviation for asphaltene energy recovery.<br />
ALCES The abbreviation for Alberta landscape cumulative effects simulator.<br />
Al-Pac The abbreviation for Alberta-Pacific Forest Industries.<br />
AOSP The abbreviation for Athabasca Oil Sands <strong>Project</strong>.<br />
Application Case The environmental effects of the proposed projects, combined with the<br />
effects identified in the Base Case. The Application Case was used in the<br />
original EIA for a direct comparison with the Base Case results, to predict<br />
the changes that result from the Jackpine <strong>Mine</strong> Expansion and the <strong>Pierre</strong><br />
<strong>River</strong> <strong>Mine</strong> <strong>Project</strong>.<br />
April 2010 Shell Canada Limited GL-1<br />
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GLOSSARY<br />
aquatic Growing, living in or frequenting water. Also, occurring or situated in or<br />
on water.<br />
aquifer A water-saturated, permeable body of rock capable of transmitting<br />
significant or usable quantities of groundwater to wells and springs under<br />
ordinary hydraulic gradients.<br />
ARM The abbreviation for ambient ratio method.<br />
ASRD The abbreviation for Alberta Sustainable Resource Development.<br />
bank cubic metre A cubic metre of material in place.<br />
basal aquifer Permeable rock, deep below the surface, that is saturated with water.<br />
Base Case The existing environmental conditions and the environmental effects of<br />
existing and approved developments that might overlap with the<br />
environmental impacts of the proposed projects.<br />
baseline A surveyed or predicted condition that serves as a reference point on which<br />
later surveys are coordinated or correlated.<br />
bbl The abbreviation for barrel.<br />
bbl/cd The abbreviation for barrels per calendar day.<br />
bcm The abbreviation for bank cubic metres.<br />
benthic invertebrates Invertebrate organisms living at, in or in association with, the bottom<br />
(benthic) substrate of lakes, ponds and streams.<br />
BIP The abbreviation for bitumen in place.<br />
bitumen A naturally occurring viscous mixture, mainly of hydrocarbons heavier<br />
than pentane, that might contain sulphur compounds and that, in its<br />
naturally occurring state, will not flow to a well.<br />
blowdown The act of emptying or depressurizing material in a vessel.<br />
bog A peat-covered area or peat-filled wetland, generally with a high water<br />
table.<br />
C,C&R Plan The abbreviation for Closure, Conservation and Reclamation Plan.<br />
CALPUFF The California Puff air quality dispersion model, which predicts<br />
concentrations and deposition fluxes of air quality parameters.<br />
CCME The abbreviation for Canadian Council of Ministers of the Environment.<br />
cd The abbreviation for calendar day.<br />
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GLOSSARY<br />
CEAA The abbreviation for Canadian Environmental Assessment Association.<br />
CEMA The abbreviation for the Cumulative Environmental Management<br />
Association.<br />
closure plan A plan for the permanent closure of all or part of a mine or industrial<br />
facility, including removing process equipment, buildings and other<br />
structures, decontaminating the surface and subsurface, replacing soil,<br />
revegetating, designating end land uses and monitoring to ensure long-term<br />
performance.<br />
cm The metric symbol for centimetre.<br />
CO The chemical formula for carbon monoxide.<br />
cogeneration The simultaneous on-site generation of electrical power and process steam<br />
or heat from the same plant.<br />
CONRAD The abbreviation for Canadian Oil Sands Network for Research and<br />
Development.<br />
conservation The planning, management and implementation of an activity with the<br />
objective of protecting the essential physical, chemical and biological<br />
characteristics of the environment against degradation.<br />
consolidated tailings A non-segregating mixture of process plant tailings that consolidates<br />
quickly in tailings deposits.<br />
contouring The process of shaping the land surface to fit the form of the surrounding<br />
land.<br />
COPCs The abbreviation for chemicals of potential concern.<br />
COSEWIC The abbreviation for Committee on the Status of Endangered Wildlife in<br />
Canada.<br />
CT The abbreviation for consolidated tailings.<br />
CWD The abbreviation for coarse woody debris.<br />
d The abbreviation for day.<br />
DC The abbreviation for disturbance coefficient.<br />
DDA The abbreviation for designated disposal area.<br />
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GLOSSARY<br />
development area All areas to be disturbed for the project on and off Lease 13, including the<br />
overburden disposal area, reclamation stockpile areas, mine pit, external<br />
tailings disposal area, plant site, right-of-ways, Khahago Creek diversion,<br />
Kearl Lake outlet dam, Muskeg Creek realignment, and the new Kearl<br />
Lake outlet.<br />
DFO The abbreviation for Department of Fisheries and Oceans.<br />
dissolved oxygen Oxygen that is present (dissolved) in water and is, therefore, available for<br />
fish and other aquatic organisms. It is normally measured in mg/L<br />
(equivalent to ppm) and widely used as a criterion of water quality.<br />
DO The abbreviation for dissolved oxygen.<br />
dyke A bank of earth constructed to confine water.<br />
ecosite Ecological units that develop under similar environmental influences<br />
(climate, moisture and nutrient regime). Ecosites are groups of one or more<br />
ecosite phases that occur within the same portion of the moisture/nutrient<br />
grid. Ecosite is a functional unit defined by the moisture and nutrient<br />
regime. It is not tied to specific landforms or plant communities, but is<br />
based on the combined interaction of biophysical factors that together<br />
dictate the availability of moisture and nutrients for plant growth.<br />
ecosystem An integrated and stable association of living and nonliving resources<br />
functioning within a defined physical location.<br />
EIA The abbreviation for Environmental Impact Assessment.<br />
elevation The height above a given level, especially sea level.<br />
emissions Substances discharged into the atmosphere through a stack.<br />
environmental impact<br />
assessment<br />
A review of the effects that a proposed development will have on the local<br />
and regional environment.<br />
EPA The abbreviation for Environmental Protection Agency.<br />
EPEA The abbreviation for Environmental Protection and Enhancement Act.<br />
ERCB The abbreviation for Energy Resources Conservation Board.<br />
erosion The process by which material, such as rock or soil, is worn away or<br />
removed by wind or water.<br />
ERP The abbreviation for emergency response plan.<br />
ERT The abbreviation for emergency response team.<br />
ESP The abbreviation for electrostatic precipitator.<br />
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GLOSSARY<br />
ESR The abbreviation for environmental setting report.<br />
ETDA The abbreviation for external tailings disposal area.<br />
external tailings<br />
disposal area<br />
An artificial impoundment structure outside of the mine to contain tailings.<br />
The tailings disposal area is enclosed by dykes made to stringent<br />
geotechnical standards, using tailings and overburden materials.<br />
extraction The process of separating bitumen from oil sands, using warm water and<br />
steam.<br />
FGD The abbreviation for flue gas desulphurization.<br />
fines Silt and clay particles.<br />
footprint The amount and shape of the area occupied.<br />
g/d The abbreviation for grams per day.<br />
geology The study or science of the earth, its history, and its life as recorded in the<br />
rocks. It includes the study of geologic features of an area, such as the<br />
geometry of rock formations, weathering and erosion and sedimentation.<br />
geophysical Related to the physics of the earth and its environment, i.e., earth, air and<br />
space.<br />
geotechnical Related to the application of scientific methods and engineering principles<br />
to civil engineering problems, by acquiring, interpreting and using<br />
knowledge of materials of the crust of the earth.<br />
GHG The abbreviation for greenhouse gas.<br />
GJ The metric symbol for gigajoule.<br />
GJ/m 3 The metric symbol for gigajoules per cubic metre.<br />
graminoid fen or marsh Wetlands dominated by grass or sedge species.<br />
greenhouse gases Any of various gases, especially carbon dioxide, that contribute to the<br />
greenhouse effect.<br />
groundwater Subsurface water that occurs beneath the water table in soils and geological<br />
formations that are fully saturated. It is the water within the earth that<br />
supplies water wells and springs.<br />
H2S The chemical formula for hydrogen sulphide.<br />
ha The metric symbol for hectare.<br />
habitat The part of the physical environment in which a plant or animal lives.<br />
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GLOSSARY<br />
HHRA The abbreviation for human health risk assessment.<br />
HSE The abbreviation for health, safety and environment.<br />
HSI The abbreviation for habitat suitability index.<br />
hydrocarbon A compound consisting of only hydrogen and carbon. The simplest<br />
hydrocarbons are gases at ordinary temperatures. With increasing<br />
complexity of molecular structure they become liquids and solids. Natural<br />
gas and petroleum are mixes of hydrocarbons.<br />
hydrogeology The science dealing with the occurrence of surface and groundwater, its<br />
use, and its functions in modifying the earth, primarily by erosion and<br />
deposition.<br />
hydrology The science that treats the occurrence, circulation, distribution and<br />
properties of the waters of the earth, and their reaction with the<br />
environment.<br />
ILCR The abbreviation for incremental lifetime cancer risks.<br />
impact, environmental The effect on the environment.<br />
in situ In the ground, undisturbed. In its original place.<br />
interburden Sand and clay material that is interbedded with the bitumen ore.<br />
invertebrate An animal without a backbone and internal skeleton.<br />
karst A topography formed over limestone, dolomite, or gypsum and<br />
characterized by sinkholes, caves, and underground drainage.<br />
key indicator resource The environmental attributes or components identified as a result of a<br />
social scoping exercise as having legal, scientific, cultural, economic or<br />
aesthetic value.<br />
kg The metric symbol for kilogram.<br />
kg/m 3 The abbreviation for kilogram per cubic metre.<br />
KIR The abbreviation for key indicator resource.<br />
km The metric symbol for kilometre.<br />
km 2 The metric symbol for square kilometre.<br />
kPa The metric symbol for kilopascal.<br />
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GLOSSARY<br />
landform The configuration of the ground surface as a factor in soil formation. It<br />
includes slope steepness and aspect as well as relief. Also, configurations<br />
of land surfaces taking distinctive forms and produced by natural processes<br />
(e.g., hill, valley, plateau).<br />
lcm The abbreviation for loose cubic metres.<br />
LCR The abbreviation for lifetime cancer risks.<br />
Lease 13 The oil sands lease that Shell will mine for the Athabasca Oil Sands<br />
<strong>Project</strong>.<br />
littoral zone The zone in a lake that is closest to the shore. It includes the part of the<br />
lake bottom, and its overlying water, between the highest water level and<br />
the depth where there is enough light (about 1% of the surface light) for<br />
rooted aquatic plants and algae to colonize the bottom sediments.<br />
LSA The abbreviation for local study area.<br />
M The metric symbol for million.<br />
m The metric symbol for metre.<br />
m/s The metric abbreviation for metres per second.<br />
m 3 The metric symbol for cubic metres.<br />
m 3 /cd The abbreviation for cubic metres per calendar day.<br />
m 3 /d The abbreviation for cubic metres per day.<br />
m 3 /h The abbreviation for cubic metres per hour.<br />
m 3 /s/m The abbreviation for cubic metres per second per metre.<br />
mature fine tailings Fine tailings that have dewatered to about 30% solids during the three<br />
years following deposition.<br />
Mbbl The abbreviation for million barrels.<br />
Mbcm The abbreviation for million bank cubic metres.<br />
MFT The abbreviation for mature fine tailings.<br />
mg/kg The abbreviation for milligrams per kilogram.<br />
mg/L The metric symbol for milligrams per litre.<br />
migration Animals or birds changing their habitat, usually with the seasons.<br />
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mitigation The process of rectifying an impact by repairing, rehabilitating or restoring<br />
the affected environment, or the process of compensating for the impact by<br />
replacing or providing substitute resources or environments.<br />
mm The metric symbol for millimetre.<br />
Mm 3 The metric symbol for millions of cubic metres.<br />
modelling A simplified representation of a relationship or system of relationships.<br />
Modelling involves calculation techniques used to make quantitative<br />
estimates of an output parameter based on its relationship to input<br />
parameters. The input parameters influence the value of the output<br />
parameters.<br />
monitoring The process of measuring continuously, or at intervals, a condition that<br />
must be kept within set limits.<br />
Mt The metric symbol for millions of tonnes.<br />
Mt/a The metric symbol for millions of tonnes per annum.<br />
muskeg A thick deposit of partially decayed vegetable matter of wet boreal regions.<br />
N/A The abbreviation for not applicable.<br />
NAD The abbreviation for North American Datum.<br />
NIA The abbreviation for Noise Impact Assessment.<br />
NNLP The abbreviation for No Net Loss Plan.<br />
NO2 The chemical formula for nitrogen dioxide.<br />
NOx The chemical formula for oxides of nitrogen.<br />
NST The abbreviation for non-segregating tailings.<br />
nutrients Environmental substances, such as nitrogen or phosphorous, that are<br />
necessary for the growth and development of plants and animals.<br />
oil sands An unconsolidated, porous sand formation or sandstone containing or<br />
impregnated with petroleum or hydrocarbons.<br />
OLM The abbreviation for ozone limiting method.<br />
OMOE The abbreviation for Ontario Ministry of the Environment.<br />
orebody A solid and fairly continuous mass of ore, which may include low-grade<br />
ore and waste as well as pay ore, but is individualized by form or character<br />
from adjoining country rock.<br />
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GLOSSARY<br />
OSDG The abbreviation for Oil Sands Developers Group, formerly the Regional<br />
Issues Working Group.<br />
overburden Material below the soil profile and above the bituminous sand.<br />
PAH The abbreviation for polycyclic aromatic hydrocarbons.<br />
PAI The abbreviation for potential acid input.<br />
parameter A distinguishing or defining characteristic or feature, especially one that<br />
may be measured or quantified.<br />
PDC The abbreviation for Planned Development Case.<br />
peat–mineral mixture A mixture of an organic horizon and the underlying mineral soil, or an<br />
organic horizon and mineral soil from another source, where the mineral<br />
soil in both cases is rated as good, fair or poor.<br />
permeability The ease with which gases or liquids penetrate or pass through a bulk mass<br />
of material, such as soil or sediments.<br />
pH The measurement of a substance’s acidity or alkalinity.<br />
Planned Development<br />
Case<br />
Includes the predicted impacts of the Jackpine <strong>Mine</strong> Expansion and the<br />
<strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong> <strong>Project</strong>, plus the approved and publicly disclosed oil<br />
sands projects and planned oil sands projects in the region. In accordance<br />
with the Canadian Environmental Assessment Act, only residual impacts<br />
from the Application Case that were considered to have low to high<br />
environmental consequences were assessed in the Planned Development<br />
Case.<br />
PM The abbreviation for particulate matter.<br />
PM2.5<br />
The abbreviation for fine particulate matter with a diameter smaller than<br />
2.5 μm.<br />
polishing pond A water containment pond designed to remove suspended sediment from<br />
muskeg drainage, overburden dewatering, reclamation material storage<br />
area runoff and overburden disposal area runoff, before the waters are<br />
released to natural receiving streams. Also known as sedimentation pond.<br />
porewater Water between the grains of a soil or rock.<br />
ppb The abbreviation for parts per billion.<br />
ppm The abbreviation for parts per million.<br />
PRM The abbreviation for <strong>Pierre</strong> <strong>River</strong> <strong>Mine</strong>.<br />
PRMA The abbreviation for <strong>Pierre</strong> <strong>River</strong> Mining Area.<br />
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PSC The abbreviation for primary separation cell.<br />
PVA The abbreviation for population viability analysis.<br />
QA/QC The abbreviation for quality assurance and quality control.<br />
RAF The abbreviation for relative absorption factor.<br />
RAMP The acronym for Regional Aquatic Monitoring Program.<br />
receptor The person or organism subjected to chemical exposure.<br />
reclamation The process of returning disturbed land to a stable, biologically productive<br />
state.<br />
reclamation plan The detailed soil reconstruction and revegetation practices that are to be<br />
used for reclamation. Equivalent to the 10-year conservation and<br />
reclamation plan.<br />
reconstruction Selectively placing suitable overburden material on reshaped spoils.<br />
revegetation Establishing vegetation to replace the original ground cover following land<br />
disturbance.<br />
RfC The abbreviation for reference concentration.<br />
RFMA The abbreviation for registered fur management area.<br />
riparian Areas near or relating to a river.<br />
RIWG The abbreviation for Regional Issues Working Group, which has been<br />
renamed the Oil Sands Developers Group.<br />
RMS The abbreviation for reclamation material stockpile.<br />
RQ The abbreviation for risk quotient.<br />
RSA The abbreviation for regional study area.<br />
RSF The abbreviation for resource selection functions.<br />
runoff The portion of precipitation (rain and snow) that ultimately reaches streams<br />
via surface systems.<br />
sd The abbreviation for stream day.<br />
seepage The slow movement of water or other fluids through a process medium, or<br />
through small openings in the surface of unsaturated soil.<br />
SEIA The abbreviation for Socio-Economic Impact Assessment.<br />
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SEWG The abbreviation for Sustainable Ecosystem Working Group.<br />
SFR The abbreviation for sands-to-fines ratio.<br />
Shell The abbreviation for Shell Canada Limited.<br />
SIR The abbreviation for supplemental information request.<br />
slurry A free-flowing, pumpable suspension of fine solid material in liquid.<br />
SO2 The chemical formula for sulphur dioxide.<br />
soil Naturally occurring, unconsolidated mineral or organic material, at least<br />
10 cm thick, that occurs at the earth’s surface and is capable of supporting<br />
plant growth.<br />
species A group of organisms that actually or potentially interbreed and are<br />
reproductively isolated from all other such groups; a taxonomic grouping<br />
of genetically and morphologically similar individuals; the category below<br />
genus.<br />
SRD The abbreviation for sustainable resources and development.<br />
SRU The abbreviation for solvent recovery unit.<br />
stakeholders People or organizations with an interest or share in an undertaking, such as<br />
a commercial venture.<br />
stockpile A gradually accumulated reserve of material.<br />
Suncor The abbreviation for Suncor Energy Inc.<br />
Syncrude The abbreviation for Syncrude Canada Ltd.<br />
t The metric symbol for tonne.<br />
t/d The metric symbol for tonnes per day.<br />
t/h The metric symbol for tonnes per hour.<br />
t/sd The metric symbol for tonnes per stream day.<br />
tailings A by-product of oil sands extraction comprising water, coarse sand, fine<br />
minerals and minor amounts of rejected bitumen waste.<br />
TFT The abbreviation for thin fine tailings.<br />
topography The shape of the ground surface, such as hills, mountains or plains.<br />
TOR The abbreviation for terms of reference.<br />
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Total The abbreviation for Total E&P Canada Ltd.<br />
trapping Catching wild animals in traps.<br />
TROLS The abbreviation for terrestrial and riparian organisms, lakes and streams.<br />
TRS The abbreviation for total reduced sulphur.<br />
TSRU The abbreviation for tailings solvent recovery unit.<br />
TSS The abbreviation for total suspended solids.<br />
TT The abbreviation for thickened tailings.<br />
TV/BIP The abbreviation for total volume to bitumen in place.<br />
ungulate An animal that has hoofs.<br />
UTM The abbreviation for universal transverse mercator.<br />
UTS The abbreviation for UTS Energy.<br />
VOC The abbreviation for volatile organic compound.<br />
WASG The abbreviation for Wetlands and Aquatic Sub Group.<br />
WBEA The abbreviation for Wood Buffalo Environmental Association.<br />
WBMC The abbreviation for Wood Buffalo Métis Corporation.<br />
wetlands Land having the water table at, near, or above the land surface, or which is<br />
saturated for long enough periods to promote wetland or aquatic processes<br />
as indicated by biological activity adapted to the wet environment.<br />
WFGD The abbreviation for wet limestone flue gas desulphurization.<br />
WHO The abbreviation for World Health Organization.<br />
WMU The abbreviation for wildlife management unit.<br />
wt% The abbreviation for weight percent.<br />
yr The abbreviation for year.<br />
ZOI The abbreviation for zone of influence.<br />
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