actions and status from the aenv october 2, 2007 meeting · aenv october 2, 2007 meeting december...

Actions and Status from the AENV October 2, 2007 Meeting

Actions and Status AENV October 2, 2007 Meeting

Fort Hills Energy L.P. December 2007 Page i

Table of Contents

Terrestrial Meeting with AENV, 2007-10-02 ............................................................................. 1 1 SIRs Round 1, Responses 164 and 180: Wetland Delineation ............................................1

2 SIRs Round 1, Response 166: Creeks at the Project Site ....................................................1

3 SIRs Round 1, Response 170: Error in Table 170-1 ............................................................1

4 SIRs Round 1, Response 179: Editorial Errors ....................................................................2

5 SIRs Round 1, Response 176: Reference Error ...................................................................2

6 SIRs Round 1, Response 177: Reference Error ...................................................................2

7 Water Intake Report (SIRs Round 1, Appendix B): Editorial Errors ..................................3

8 SIRs Round 1, Responses 190-198: Farmland ....................................................................3

9 SIRs Round 1, Response 195: Honey Production ...............................................................3

Air Meeting with AENV, 2007-10-02 .......................................................................................... 5

10 Revised Sulphur Ratio .........................................................................................................5

11 Fuel Gas Sulphur Content ....................................................................................................5

12 Ammonia Monitoring on the SMR Furnace Exhaust Stack ................................................5

13 25 ppm (3% O2) Performance Target ..................................................................................6

14 Sulphur Recovery Approval ................................................................................................6

15 Coker Technology Selection ................................................................................................6

16 BATEA ................................................................................................................................7

17 Vacuum Distillation .............................................................................................................7

18 Coke Storage and Leaching .................................................................................................7

19 Ozone Modeling: TOR #4.2i ...............................................................................................8

20 CO2 Pipeline.........................................................................................................................8

21 Air Cooling ..........................................................................................................................8

22 Plant Fuel Gas (FG) .............................................................................................................8

Water Meeting with AENV, 2007-10-02 ..................................................................................... 9 23 ACR Water Supply Option ..................................................................................................9

24 Footprint and Design of the River Water Intake Structure ..................................................9

25 SIRs Round 1, Response 37: Removal of Contaminants .....................................................9

26 Water Intake Report (SIRs Round 1, Appendix B), Relative Velocity in the River .........10


December 2007 Fort Hills Energy L.P. Page ii

27 Water Intake Report (SIRs Round 1, Appendix B), Channel Formation ..........................10

28 SIRs Round 1, Response 76 ...............................................................................................13

29 SIRs Round 1, Response 78: Deposition of Sediments .....................................................13

30 SIRs Round 1, Response 81: Tributary Distances .............................................................13

31 SIRs Round 1, Response 85: Phenols in Winter ................................................................14

32 SIRs Round 1, Response 86: Phenols ................................................................................14

33 SIRs, Round 1, Response 92: KIR .....................................................................................14

34 SIRs Round 1, Response 93: Phenols ................................................................................15

35 SIRs Round 1, Response 105: Plumes ...............................................................................15

Health Meeting with AENV, 2007-10-02 .................................................................................. 16 36 SIRs Round 1, Response 203: ERP ...................................................................................16

37 SIRs Round 1, Responses 132 and 207: Flaring ................................................................16

38 SIRs Round 1, Response 210: Particulate Matter ..............................................................16

39 SIRs Round 1, Response 213: ERP ...................................................................................17

40 SIRs Round 1, Response 224: Acrolein .............................................................................17

41 SIRs Round 1, Response 1: Revised Air Quality ..............................................................17

42 SIRs Round 1, Responses 5 and 218: Fish consumption in NSR ......................................17

43 SIRs Round 1, Response 46; Fish Consumption in NSR – Cyanides and Trace Metals ...18

44 SIRs Round 1, Responses 76, 78, 85 and 218: Water quality Concerns ...........................18

45 SIRs Round 1, Response 221: First Nations Receptors .....................................................18

46 SIRs Round 1, Response 228: Construction Emissions.....................................................18

47 SIRs Round 1, Response 220: Metals in Emissions ..........................................................19

Glossary ....................................................................................................................................... 20


Fort Hills Energy L.P. December 2007 Page iii

Abbreviations

ASRD ................................................ Alberta Sustainable Resource Development AENV ....................................................................................... Alberta Environment FG ...............................................................................................................fuel gas ppm .............................................................................. parts per million by volume t/d .................................................................................................... tonnes per day SMR ................................................................................. steam methane reformer SCR ........................................................................... Selective Catalytic Reduction ACR ..................................................................................... Alberta Capital Region m/s ............................................................................................... metre per second m3/s .................................................................................... cubic metre per second KIR ..................................................................................... key indicator resources KIS .......................................................................................... key indicator species ERP .............................................................................. Emergency Response Plan NSR ............................................................................... North Saskatchewan River


December 2007 Fort Hills Energy L.P. Page iv


Fort Hills Energy L.P. December 2007 Page 1

TERRESTRIAL MEETING WITH AENV 2007-10-02

1 SIRs Round 1, Responses 164 and 180: Wetland Delineation

PCOSI indicated that the wetland delineation work is complete.

ACTION:

The wetland delineation work will be provided to ASRD and AENV.

STATUS:

The wetland delineation work is available in SIRs Round 2, Appendix A (on CD).

2 SIRs Round 1, Response 166: Creeks at the Project Site

ASRD informed PCOSI that the company must contact ASRD in regards to the creeks at the Project site and ASRD interest in them. Part of this process will include a determination of whether these are permanent watercourses or not.

ACTION:

PCOSI will follow up with Public Lands to determine who owns bed and shore of the creeks.

STATUS:

This action is in progress.

3 SIRs Round 1, Response 170: Error in Table 170-1

Confirm error in the table – i.e., all zeroes in the second column relate to a “YES” in the third column.

ACTION:

PCOSI will confirm.

STATUS:

With respect to Table 170-1, the second and third column headings are reversed. The second column should read “Number of Occurrences Inside the Project Development Area,” and the third column should read “Number of Occurrences Outside the Project Development Area.”


December 2007 Fort Hills Energy L.P. Page 2

4 SIRs Round 1, Response 179: Editorial Errors

ACTION:

PCOSI will confirm.

STATUS:

Figure 179-1 legend has some inconsistencies in comparison with the associated text. The first vegetation type in the legend should read “Upland Trembling Aspen Woodland Alliance”. On page 295, in the text of the third bullet point, the vegetation type in italics should read “Upland White Spruce Mixed Deciduous Woodland Alliance”. On page 296, in the text the fifth bullet point, vegetation type in italics should read “Riparian White Spruce Mixed Deciduous Woodland Alliance”. In Table 179-1, the first vegetation type should read “Upland Trembling Aspen Woodland Alliance”.

5 SIRs Round 1, Response 176: Reference Error

Confirm whether Russell and Bauer is the correct reference.

ACTION:

PCOSI will confirm.

STATUS:

The Russell and Bauer 1993 reference was included for amphibian breeding times and life stages and not for the survey protocol.

6 SIRs Round 1, Response 177: Reference Error

ACTION:

PCOSI will confirm.

STATUS:

Response 177 should not reference Appendix 7A, Volume 2. Instead, it should have referenced Appendix B, Section 7 of that set of responses (SIRs Round 1).



7 Water Intake Report (SIRs Round 1, Appendix B): Editorial Errors

Confirm editorial errors in Table 7C-1 and page 7-16.

ACTION:

PCOSI will confirm.

STATUS:

In Table 7C-1, the information row on warbling vireo should be moved up in the table to follow the information row on red-eyed vireo. At the bottom of page 7-16, least flycatcher should replace clay-coloured sparrow in the list of the four most common species observed during surveys.

8 SIRs Round 1, Responses 190-198: Farmland

Issue remains that good farmland is being used.

ACTION:

PCOSI indicated a strong desire to move topsoil to an area where topsoil is marginal so that there is no such loss. However, PCOSI is constrained by current guidelines.

STATUS:

PCOSI is working with AENV to see if there is any opportunity to move topsoil.

9 SIRs Round 1, Response 195: Honey Production

Honey production not addressed.

ACTION:

PCOSI has completed additional research into the presence of commercial honey production in Sturgeon County.

STATUS:

Additional research into commercial honey production in Sturgeon County was undertaken, to supplement what was completed for the land use component of the EIA. Subsequent data sources were checked and one commercial honey producer was located in the Bon Accord area, which produces solid (raw) or liquid honey, pollen, beeswax, comb honey and propolis through approximately 80 hives.

The main pollen source for bees in Alberta is canola. While bees will travel up to two miles in search of pollen, they tend to work most heavily on the crops nearest to their yard sites (From Alberta Beekeepers Association presentation to Super Canola Workshop



1999). Crop health and associated yields may be affected by air emissions, specifically SO2 and NO2. WHO (2000a and 2000b) defines annual critical levels of SO2 and NO2 on crops at 30 µg/m3. At this annual critical level, health and associated yields can be reduced. If health and yields are reduced, flower and associated pollen production could also be affected which could, in turn, affect the foraging patterns and efficiency for bees.

An assessment of effects from the Project (see SIRs Round 1, Response 191) found no areas where the annual critical level of SO2 was exceeded for the Base, Application or Future cases. Therefore, SO2 emissions should not affect crops and hence associated honey production. For NO2, a slight increase relative to the Base Case was noted for both the Application Case (0.3 %) as well as the Future Case (1.0%). Because predicted increases are small and the critical level isopleths are adjacent to Edmonton and Fort Saskatchewan, effects of NO2 emissions on cultivated crops used as a pollen source by bees and on associated honey production are not expected to be measurable. References:

WHO (World Health Organization). 2000a. Chapter 10: Effects of sulphur dioxide on vegetation: critical levels, WHO Air Quality Guidelines, 2nd Edition. WHO Regional Office for Europe. Available at: http://www.euro.who.int/document/aiq/10effso2.pdf. Accessed July 2007.

WHO (World Health Organization). 2000b. Chapter 11: Effects of nitrogen containing air pollutants: critical levels, WHO Air Quality Guidelines, 2nd Edition. WHO Regional Office for Europe. Available at: http://www.euro.who.int/document/aiq/11no2level.pdf. Accessed July 2007.

http://www.euro.who.int/document/aiq/10effso2.pdf

http://www.euro.who.int/document/aiq/11no2level.pdf



AIR MEETING WITH AENV 2007-10-02

10 Revised Sulphur Ratio

The revised sulphur ratio of 368 ppm/50 ppm in the fuel gas (FG) does not equal 1.96 t/d to 0.10 t/d reduction in projected emissions.

ACTION:

Provide a revision of the report with requested information.

STATUS:

The Air Quality Report will be provided under separate cover.

11 Fuel Gas Sulphur Content

All fuel gas will now be at a maximum 50 ppm sulphur content due to working with a 3rd party.

ACTION:

PCOSI will confirm.

STATUS:

Addressed in SIRs Round 2, Response 1

12 Ammonia Monitoring on the SMR Furnace Exhaust Stack

AENV would like to see ammonia monitoring on the SMR furnace exhaust stack and for PCOSI to estimate what the ammonia emissions will be.

ACTION:

Add monitoring to the scope of work and PCOSI is to estimate ammonia emissions.

STATUS:

Ammonia monitoring is indicated in SIRs Round 2, Response 23. See the Air Quality Report (under separate cover) for the emissions estimate.



13 25 ppm (3% O2) Performance Target

The performance target for most heaters, boilers and furnaces is 25 ppm (3% O2), and the target is 15 ppm for SMR furnace.

ACTION:

PCOSI is working with vendors to achieve these targets but they are aggressive especially due to the Project using FG in the boilers, and because PCOSI has no experience operating an SCR system.

STATUS:

See the Air Quality Report (under separate cover).

14 Sulphur Recovery Approval

PCOSI clarified that it wants to be approved based on 99.7% annual sulphur recovery for the first few months of operation, 99.8% annual long term, 99.5% quarter calendar year recover.

ACTION:

PCOSI is designing to 99.9% sulphur recovery.

STATUS:


15 Coker Technology Selection

More details are needed on the upgrading option selected, and information on upgrading options is requested from the confidential report.

ACTION:

PCOSI will not release the confidential conceptual study; however, in technology selection many factors were considered, including economics, environment, reliability and safety. Petro-Canada has a history with coking and knows how to operate cokers.

STATUS:




16 BATEA

AENV would like PCOSI to list a summary of the technologies that were considered for the upgrader and how each of the final technologies was selected (and on what basis). This is not limited to just primary upgrading but throughout the upgrader. Show that PCOSI has selected BATEA in each case.

ACTION:

Follow up answer from PCOSI required.

STATUS:


17 Vacuum Distillation

If Phase 2/3 does not proceed, will vacuum distillation be installed?

ACTION:

PCOSI will confirm.

STATUS:

This is addressed in SIRs Round 2, Response 21.

18 Coke Storage and Leaching

There is research that indicates leaching from coke can occur. Could leachate generation change how the coke management system is designed?

ACTION:

PCOSI will review 2005 Fedorak paper. However, regardless of whether coke may form leachates or not, process will not change since to the leachate will be contained, treated and reused.

STATUS:

This item is further addressed in SIRs Round 2, Response 50.



19 Ozone Modeling: TOR #4.2i

ACTION:

AENV and Petro-Canada agree that ozone modelling is not normally done by a single proponent and if a single proponent is required, a better approach would be to do ozone modelling at a regional level. The regional requirement is a function of the size and distribution of NOx sources and the complexity of ozone models.

STATUS:


20 CO2 Pipeline

ACTION:

PCOSI believes that a regional approach is required. Gasification in Phase 2/3 means capture-ready CO2.

STATUS:

PCOSI is willing to work with industry and government.

21 Air Cooling

PCOSI: Air cooling about 80% of load. AENV asked for plus or minus.

ACTION:

PCOSI did not offer a plus or minus.

STATUS:


22 Plant Fuel Gas (FG)

ACTION:

If PCOSI did not use this gas in the Upgrader, PCOSI would have to flare it (undesirable). Therefore, the gas is used as fuel.

STATUS:




WATER MEETING WITH AENV 2007-10-02

23 ACR Water Supply Option

ASRD wants a better understanding of how to consider the ACR water supply option for the purposes of the application.

ACTION:

A letter will be provided to AENV and EUB for distribution to the coordination group.

STATUS:

A letter was provided, dated October 03, 2007.

24 Footprint and Design of the River Water Intake Structure

DFO requires detailed information regarding the footprint and design of the river water intake structure and a conceptual compensation plan. Transport Canada needs the same level of information.

ACTION:

PCOSI is to set up a meeting to discuss the Federal agencies requirements.

STATUS:

The meeting was held on October 12, 2007 and all roles were clarified at that time.

25 SIRs Round 1, Response 37: Removal of Contaminants

SIRs Round 1, Response 37 does not explain how contaminants are removed from the forebays.

ACTION:

It should be stated, as should the assumption, that contaminants are light hydrocarbons (i.e., they float) and are skimmed off the surface.

STATUS:




26 Water Intake Report (SIRs Round 1, Appendix B), Relative Velocity in the River

Fish section and hydrology section disagree on relative velocity in the river. Action: No action is required.

ACTION:

No action is required.

STATUS:

The two sections are using a different scale. The fish section (Section 4.4.2) of the intake report is reporting on observations made during a site visit, and states that the “velocity was high relative to the rest of the river.” The “rest of the river” was intended to mean elsewhere in the same cross section. The statement in the hydrology section (Section 2.3) is that “water depths will be greater and velocities lower at the water intake and pumphouse than in some other reaches of the river.” This was intended to mean that the cross-section average velocity is lower at the intake location than at some other sections upstream and downstream. There is no disagreement between the two statements.

27 Water Intake Report (SIRs Round 1, Appendix B), Channel Formation

Figure 2.5 in the intake report illustrates that velocities over 1 m/s could be channel forming.

ACTION:

See the discussion under status.

STATUS:

The concern over whether the constriction of river width associated with the construction of an intake may cause river scour and erosion can be addressed from several different perspectives:

a) The natural flow regime in the North Saskatchewan River before the construction of the upstream Brazeau and Bighorn Dams is compared to the post-dam regime in Figure 27-1, a revised version of Figure 12-9 in Volume 2, Section 12 of the Application. The figure shows that the effect of the flow regulation has been to reduce the high flows and increase the low flows in the river. Specifically, the figure shows that the flow exceeded 5% of the time was approximately 700 m3/s before 1961, but is now approximately 430 m3/s.



Figure 1North Saskatchewan River

Annual Flow-Duration Curve

10

100

1000

10000

0 10 20 30 40 50 60 70 80 90 1Percent of time exceeded (%)

Dai

ly D

isch

arge

(m3 /s

)

00

1911-19611974-2005 Based on data from WSC Station 05DF001,

North Saskatchewan River at Edmonton.

Figure 27-1

River velocities at the intake cross section corresponding to a range of discharges are shown on Figure 27-2, an extended version of Figure 2-5 from the water intake report (SIRs Round 1, Appendix B). The figure shows that at a discharge of 700 m3/s, the velocity at the intake section would be approximately 1.2 m/s under existing conditions (i.e., with no cofferdam). With a structural cofferdam in place, the same velocity would occur at a discharge of approximately 450 m3/s. Therefore, the frequency of occurrence of a velocity of 1.2 m/s would be approximately the same under regulated conditions with a structural cofferdam in place as it was pre-regulation without a cofferdam.

Based on air photo information, the river has not yet adjusted to the regulated flow regime, as discussed in SIRs Round 1, Response 18. Therefore, the channel is expected to be as stable at the current 5 percent exceedance discharge with a structural cofferdam, as it was historically without a cofferdam.



Figure 2Estimated Effect of Cofferdam Construction on

North Saskatchewan River Flow Velocities

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

0 100 200 300 400 500 600 700 800

Discharge (m3/s)

Velo

city

(m/s

)

Earthfill Cofferdam

Structural Cofferdam

Existing

Pre-1962 river discharges were in the range of 15 m3/s to 700 m3/s, 90% of the time.

Post-1973 river discharges are in the range of 85 m3/s to 430 m3/s, 90% of the time.

Figure 27-1

b) Velocities at the water intake section with a structural cofferdam in place are expected to be no higher than at some other cross sections of the river under existing conditions, as discussed in Section 2.4 of the water intake report (SIRs Round 1, Appendix B).

c) The NHC (2006) found that the riverbed near the intake is composed of cobbles with a D50 of 85 mm, as discussed in SIRs Round 1, Response 18. That size of bed material is expected to be stable for velocities of over 2 m/s compared to velocities under 1.5 m/s with a structural cofferdam in place and river discharges up to 700 m3/s.

Reference:

Northwest Hydraulic Consultants Ltd. (NHC). 2006. Design Brief: Proposed RawWater Intake: Fort Hills Sturgeon Upgrader: Bathymetric Survey and Preliminary Evaluation of Intake Alternatives. A report to Stantec Consulting Ltd, Edmonton, AB. October 2006.



28 SIRs Round 1, Response 76

Why was recent data not used?

ACTION:

No further action is required.

STATUS:

It takes AENV a year to review data before it becomes available. Recent data is provided and is comparable.

29 SIRs Round 1, Response 78: Deposition of Sediments

ACTION:


STATUS:

The area is erosional, not depositional, and there is no way to predict where sediments will deposit.

30 SIRs Round 1, Response 81: Tributary Distances

Clarify distance in tributaries before the river is reached.

ACTION:

PCOSI will confirm.

STATUS:

The distance from the stormwater ponds to tributary streams would vary from over 1600 m to less than 100 m. The tributary streams from the PCOSI property to the river is more than 2 km in length.



31 SIRs Round 1, Response 85: Phenols in Winter

Phenols may not be rapidly degraded in winter.

ACTION:

PCOSI to clarify if effluent is now going to ACR rather than river. A letter will be provided.

STATUS:

The letter was provided October 03, 2007. Since wastewater is sent to ACR rather than the river, the issue of phenols in the Upgrader effluent degrading in the river is no longer relevant.

32 SIRs Round 1, Response 86: Phenols

Clarify types of phenols.

ACTION:


STATUS:

The letter was provided on October 03, 2007. Since wastewater is sent to ACR rather than the river, the issue of types of phenols in the Upgrader effluent is no longer relevant.

33 SIRs, Round 1, Response 92: KIR

ACTION:


STATUS:

Key indicator resources (KIR) are used interchangeably with key indicator species (KIS). Communities are picked rather than species as emphasis is on protection of habitat for communities. No further action is required.



34 SIRs Round 1, Response 93: Phenols

Guideline for phenol may be exceeded:

ACTION:


STATUS:

A letter was provided on October 03, 2007.

35 SIRs Round 1, Response 105: Plumes

Overlapping of plumes may be a problem

ACTION:


STATUS:




HEALTH MEETING WITH AENV 2007-10-02

36 SIRs Round 1, Response 203: ERP

A more detailed outline of ERP is required, as well as confirmation that AB Health will receive a copy of the ERP

ACTION:

PCOSI will provide the ERP.

STATUS:


37 SIRs Round 1, Responses 132 and 207: Flaring

AB Health is concerned about how flaring is managed since Upgraders are not bound by EUB Directive 60.

ACTION:

PCOSI will provide this information.

STATUS:


38 SIRs Round 1, Response 210: Particulate Matter

More information is required concerning PM2.5 for upset scenarios.

ACTION:

PCOSI to provide (see See PCOSI statement in SIR Question 210, “Short-term…assessment”)

STATUS:




39 SIRs Round 1, Response 213: ERP

Need a more detailed outline of ERP as well as confirmation that AB Health will receive a copy of the ERP

ACTION:

PCOSI will provide the ERP.

STATUS:

Provided in SIRs Round 2, Response 30. AHW will receive the site-specific ERP when it is completed, prior to operations.

40 SIRs Round 1, Response 224: Acrolein

ACTION:

Acrolein will be included.

STATUS:


41 SIRs Round 1, Response 1: Revised Air Quality

ACTION:

PCOSI will respond.

STATUS:

See the Air Quality Report (under separate cover).

42 SIRs Round 1, Responses 5 and 218: Fish consumption in NSR

ACTION:

PCOSI to provide letter on effluent going to ACR rather than NSR.

STATUS:




43 SIRs Round 1, Response 46; Fish Consumption in NSR – Cyanides and Trace Metals

ACTION:

PCOSI is to provide a letter on effluent going to ACR rather than NSR.

STATUS:


44 SIRs Round 1, Responses 76, 78, 85 and 218: Water quality Concerns

ACTION:

PCOSI is to provide letter on effluent going to ACR rather than NSR.

STATUS:


45 SIRs Round 1, Response 221: First Nations Receptors

Intrinsik discussed that agricultural receptors were more conservative.

ACTION:

More information will be provided.

STATUS:

Addressed in SIRs Round 2, Response 37.

46 SIRs Round 1, Response 228: Construction Emissions

ACTION:

PCOSI will provide.

STATUS:




47 SIRs Round 1, Response 220: Metals in Emissions

Are there any metals in natural gas / plant emissions?

ACTION:

PCOSI will clarify.

STATUS:




GLOSSARY air quality A description of the type and amount of trace constituents in ambient

air, which can be described as contaminants. A contaminant (or pollutant) has the connotation of being derived from human activities.

channel The bed and banks of a stream or river.

county A region created by territorial division for the purpose of local government.

depth The distance from a surface.

m3/s (for water measurement) The standard measure of water flow in rivers, i.e., the volume of water in cubic metres that passes a given point in one second.

NOx Oxides of nitrogen.

sediment Soil material, both mineral and organic, that is transported by, suspended in, or deposited from water.

topsoil The layer of soil moved in cultivation, including Ah and Ap horizons.

water intake Structure intended to take water from a waterbody.

actions and status from the aenv october 2, 2007 meeting · aenv october 2, 2007 meeting december...

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