application for approval of the - alberta · 2016. 6. 10. · volume 5 – sir: round 2 september...

$: APPLICATION FOR APPROVAL OF THE - Alberta · 2016. 6. 10. · Volume 5 – SIR: Round 2 September 2009 S:\Project Ce\Ce03786\Volume 5\fin Vol 5-SWSS Round 2 SIRs_ce03786-sep09-tlc.doc$

APPLICATION FOR APPROVAL OF THE SOUTHWEST SAND STORAGE CONVERSION PROJECT

VOLUME 5 – SUPPLEMENTAL INFORMATION REQUEST: ROUND 2 (SIR2)

Submitted to: Energy Resources Conservation Board

and Alberta Environment

Submitted by: Syncrude Canada Ltd. Fort McMurray, Alberta

September 2009

CE03786

Syncrude Canada Ltd. SWSS Conversion Project Volume 5 – SIR: Round 2 September 2009

S:\Project Ce\Ce03786\Volume 5\fin Vol 5-SWSS Round 2 SIRs_ce03786-sep09-tlc.doc Preamble

PREAMBLE This document, identified as Volume 5 – Supplemental Information Request Round 2, forms part of the application submitted by Syncrude Canada Ltd (Syncrude) to the Energy Resources Conservation Board (ERCB) and to Alberta Environment (AENV) for approval of the Southwest Sand Storage Conversion Project. Pending approval, Syncrude plans to amend the tailings management scheme of its Mildred Lake site located near Fort McMurray in the Regional Municipality of Wood Buffalo (RMWB) in northeastern Alberta. Specifically, Syncrude requests approval to utilize the existing Southwest Sand Storage (SWSS) facility to store tailings fluids on an interim basis and approval to continue with the implementation of a supplemental mature fine tailings (MFT) conversion technology to reduce MFT volumes in the long-term so as to achieve the tailings management objectives that are included in its currently approved scheme of production and Conservation and Reclamation (C&R) Plan. Applications Nos. 1595820 (ERBC), 027-00000026(AENV) and 25419 (Water Act) for approval of the project were submitted by Syncrude to the ERCB and AENV on 7 November 2008. The application documents (in three volumes of hard copy and in CD format) were made available for public review and commentary. The ERCB and AENV completed a review of the Applications, and on 20 March 2009 the ERBC issued to Syncrude a combined Supplementary Information Request (SIR). On 7 May 2009, Syncrude provided the ERCB with a response to the SIR, forming Volume 4 of its project application. Additionally, on 7 July 2009, Syncrude issued a Supplementary Submission: Air Quality and Human Health Risk Assessments. The ERCB and AENV completed reviews of these two additional documents provided by Syncrude and on 30 July 2009 jointly issued a Supplemental Information Request – Round 2 (SIR2). The SIR2 contains 71 questions and is organized according to combined requests from the ERCB and AENV. Volume 5 – Supplemental Information Request: Round 2 is organized as follows:

• SIR2 is a systematic response to the 71 information requests; information is provided in the same sequence as the questions posed in the SIR;

• Appendix A is a copy of the Round 2 SIR request of 30 July 2009; • Appendix B contains drill logs for groundwater calibration wells; and • Appendix C contains the Plan and Cross-Sections for Cell 32.


S:\Project Ce\Ce03786\Volume 5\fin Vol 5-SWSS Round 2 SIRs_ce03786-sep09-tlc.doc Table of Contents

TABLE OF CONTENTS PAGE

1.0 ERCB .....................................................................................................................ERCB-1 1.1 PROCESSING ...........................................................................................ERCB-1 1.2 TAILINGS MANAGEMENT ......................................................................ERCB-10 1.3 TERRESTRIAL.........................................................................................ERCB-17 1.4 HYDROGEOLOGY ..................................................................................ERCB-25 1.5 AQUATICS ...............................................................................................ERCB-49 1.6 AIR ...........................................................................................................ERCB-55 1.7 ERRATA...................................................................................................ERCB-64

2.0 AENV .....................................................................................................................AENV-1 2.1 AIR ............................................................................................................. AENV-1 2.2 TERRESTRIAL........................................................................................... AENV-7 2.3 HEALTH ................................................................................................... AENV-10 2.4 APPROVALS............................................................................................ AENV-30 2.5 ERRATA................................................................................................... AENV-31


S:\Project Ce\Ce03786\Volume 5\fin Vol 5-SWSS Round 2 SIRs_ce03786-sep09-tlc.doc Table of Contents

TABLE OF CONTENTS (cont) PAGE

LIST OF TABLES

Table SIR2 ERCB 20-1: Measured Water Levels ....................................................ERCB-29 Table SIR2 ERCB 22-1: Ionic Balance for SWSS Wells (2008) ..............................ERCB-31 Table SIR2 ERCB 23-1: Monitored Groundwater Elevations for Wells Used

for Flow Model Calibration ................................................ERCB-33 Table SIR2 ERCB 27-1: Model Sensitivity to Transport Parameters .......................ERCB-43 Table SIR2 ERCB 28-1: Model Results Summary...................................................ERCB-44 Table SIR2 ERCB 30-1: Typical Response Sequence ............................................ERCB-47 Table SIR2 ERCB 32-1: Calculations of Mass Loadings and Substance

Concentrations in the MacKay River at Reach 50 for Naphthenic Acids.........................................................ERCB-50

Table A1.19 (Rev): Summary of VOC Emissions from Syncrude Dry Sands .........................................................................ERCB-56

Table A1.20 (Rev): Summary of VOC Emissions from Syncrude SWSS Pond ......................................................................ERCB-57

Table A1.21 (Rev): Summary of VOC Emissions from Syncrude SWSS Bitumen Slick.........................................................ERCB-58

Table SIR2 AENV 12-1: Inhalation-based Chemical Screening According to the Cumulated Toxic Potency Method .......................... AENV-14

LIST OF FIGURES

Figure SIR2 ERCB 5-1: Fines Not Captured Per Directive 074 ................................ERCB-8

LIST OF APPENDICES

Appendix A: Supplemental Information Request from the Energy Conservation Board – 30 July 2009

Appendix B: Drill Logs for Groundwater Calibration Wells Appendix C: Plan and Cross-Sections – Cell 32

ERCB – Application No. 1595820


S:\Project Ce\Ce03786\Volume 5\fin Vol 5-SWSS Round 2 SIRs_ce03786-sep09-tlc.doc Page ERCB-1

1.0 ERCB

1.1 PROCESSING 1. Volume 4, SIR 12a, Page ERCB-18. Syncrude states “Opportunities under

consideration will be further developed and prioritized. Budgets and schedules will be developed to support the selected continuous improvement opportunities.”

a. Provide the basis for prioritization of the opportunities.

The prioritization of improvement opportunities for CT will be evaluated based on CT production requirements derived from the tailings plan. The current tailings plan shows lower CT production volumes prior to 2014. CT production limitations in the short term are primarily due to sand availability and CT placement area availability. Further details on tailings planning assumptions have been included in Volume 1, Section 3.6, Pages 3-47 to 3-52. Placement location and volumes are the main factors influencing the prioritization of improvement opportunities for CT. The planned placement locations for CT include the East In-Pit (EIP) facility (present-2011), the Southwest In-Pit (SWIP) facility (2009-2014), followed by the North Mine South Pond (NMSP) facility (2014-2027). The planned CT deposit volumes average 6.5 Mm3 annually until 2013 with a step up to an average of 9.4 Mm3 from 2014 to 2027. Improvement opportunities will be prioritized to meet the CT production needs; based on expected volumes and placement location and methods. In its current configuration, the CT plant is capable of delivering the required CT volumes to the EIP facility. However, improvements related to the MFT supply to the CT plant would likely translate in an improvement in overall CT plant reliability and potentially enhance quality control of the CT product. Cyclone sizing is also being evaluated to improve CT performance by widening the range of coarse tailings densities that the CT plant is able to process. Alternatives related to MFT supply and cyclone sizing are being evaluated; recommended improvements to MFT supply and cyclone sizing will be scoped and defined by 31 March 2010. Starting in 2009, CT placement is scheduled to begin in the SWIP facility. As a new tailings disposal facility, SWIP will present challenges for CT placement. The configuration of the SWIP facility is different from the CT deposition environment in the EIP facility. Whereas CT was allowed to deposit sub-aerially in long beaches in the EIP; the SWIP facility is planned to contain significant amounts of fluids (MFT and recycle water), preventing the development of long CT beaches for sub-aerial deposition. As such, deposition techniques and equipment are currently being evaluated to support CT placement in SWIP; a discharge method (e.g., tremie diffuser or other) is planned to be tested on the SWIP CT pipeline discharge in 2010. The CT production increase to a deposit volume averaging 9.4 Mm3 annually will necessitate upgrading and/or debottlenecking the CT plant to produce the required volume of on-spec CT. CT plant improvements to support the CT production increase are currently being evaluated.



The evaluation will take into consideration MFT supply, gypsum system, cyclones, piping, vessels, infrastructure, and discharge locations and methods. Project scope identifying CT plant upgrades required to support CT production beyond 2014 will be defined by Q4 2010.

b. What are the timelines for selection, development and implementation of options?

See response to ERCB 1(a).

c. What resources are being allocated to selection and development of options?

The necessary resources will be allocated to complete the project assessments and discharge technology field test described in the response to ERCB 1(a).

d. What work has been done since the CT Works project in 2005 to advance CT process and performance improvements?

CT plant/process improvements that have been completed since the CT Works project in 2005 are as follows:

• MFT Pumping: Mechanical seals on MFT supply pumps replaced with grease packed seals to

improve reliability; and Improved access to MFT supply barge.

• Gypsum Mixing System: Changed from “side dump” gypsum supply truck to “end dump” truck with ejector,

smoothing out the gypsum batching and mixing process; and Established on-site gypsum stockpile to avoid delays due to gypsum delivery.

• Instrumentation: MFT addition control valves changed to improve process stability; Installed instrumentation on cyclone overflow system; Increased frequency of densometer calibrations; and Installed auto-sampler and fines analyzer on CT pipeline.

• Cyclones: Replaced DS cyclones with more efficient GMAX cyclones.

• Management: Improved work procedures in CT plant to minimize production interruptions; and Assigned a dedicated process operations trainer to CT process.



2. Volume 4, SIR 13, Page ERCB-20. While referring to centrifuge plants, Syncrude states “An overall utilization factor of 80% was applied to the process to account for plant maintenance and other factors affecting plant availability.”

a. How did Syncrude determine the overall utilization factor of 80%?

As plant design and equipment selection for the MFT centrifuge plant is still in the conceptual stages, the 80% utilization factor is meant to illustrate a degree of expected operating complexity. As the design of the MFT centrifuging plant progresses, availability and utilization will be factored in to ensure that the components are sized adequately to achieve the required annual MFT conversion target. Factors that will affect process availability, and therefore will influence to some degree the design of the facility, include:

• operating window (summer-only or year-round operation); • MFT source; • MFT pumping system; • size and number of centrifuges; • cake handling methods; • material placement logistics; and • handling sloppy material during shoulder seasons.

b. List the other factors that may affect process availability.

See response to 2a above.

c. Under what scenarios may the service factor be less than 80%? List, explain and provide contingencies in each case.

See response to 2a above.

d. At what utilization factor will the technology no longer be economically feasible?

The decision by Syncrude to implement MFT centrifuging technology for fines management is not primarily based on economics; simplifying the feasibility of MFT centrifuging technology in relation to a utilization factor is not practical. Syncrude selected MFT centrifuging technology based on a number of criteria as detailed in Volume 1, Table 4.3-2, Page 4-9. Selection criteria include:

• environmental impact (and changes to C&R Plan); • timing of earliest implementation; • operational complexity; • ability to deal with legacy MFT; • flexibility to adjust fines treatment rates; and • cost.



3. Volume 4, SIR 14, Page ERCB-21. Based on the preliminary results from the 2008 centrifuge field pilot (Volume 1 Table 4.4-4) provide the following information:

a. The impact on air quality parameters due to the release of VOCs and other compounds as a result of the MFT Centrifuging process.

A limited sampling campaign, including flux chamber measurements from the deposited centrifuge cake, was carried out during the 2008 centrifuge field pilot. Three measurements were taken by Clearstone Engineering on October 3rd, 2008, using a U.S. EPA isolation flux chamber. The flux chamber measurements showed that carbon dioxide (CO2) is the principal substance being emitted to the atmosphere from the cake (dewatered MFT); CO2 was present in measurable quantities in only two of the three measurements, for a flux average of 105 µg/m2/s. CO2 is also the principal substance emitted from the Mildred Lake Settling Basin (MLSB) and was measured at an average flux of 280 µg/m2/s during the same sampling campaign. The tests also demonstrated that VOC emissions from the centrifuge cake are less than or comparable to those taken from the surface of the MLSB. Hydrogen sulphide (H2S) was not detected in any of the samples collected. At the time of survey, odors from the MFT pilot plant were not perceptible more than a short distance away from the operation (e.g., less than 100 m).

b. The techniques that were assessed for transporting the centrifuged material and which technique has been adopted.

Transport methods that were tested during the 2008 centrifuge field pilot include conveyance and deposition using a stacker conveyor, trucking (using a loader to simulate truck transport), as well as pumping. All transportation methods were proven satisfactory at the field pilot scale. A transportation method has not been selected at this time; selection and optimization will be completed during the project development process for the commercial demonstration and subsequent scale-up stages to a commercial facility.

c. The cake deposition thicknesses that were assessed, which thicknesses were deemed acceptable, and which thickness has been adopted.

The cake deposition thicknesses that were assessed were nominally 1 m, 2 m, and 3 m as-placed. Geotechnical performance evaluation of the deposits formed during the 2008 centrifuge field pilot has not been completed as a testing period of one-year has been chosen to ensure a thorough evaluation; the deposits were formed in October 2008.



The optimum placement thickness has not been selected at this time. A deposition plan for centrifuge cake will be developed once the geotechnical performance evaluation has been completed. The optimum placement thickness may also be influenced by placement method and physical location of the centrifuge cake deposit.



4. Volume 4, SIR 19a, Page ERCB-33. Syncrude states “Similarly, if the application is not approved until 2010, Syncrude would rely on the interim measures noted in Section 3.1.3 and summarized above. Preparatory activities for the stockpiling scenario noted in Section 3.1.3 would also be contemplated at this time.” Further to the ore stockpiling and the other scenarios mentioned in this answer, what process improvements has Syncrude considered/evaluated to reduce the production of fluids fine tails. Explain.

As described in Volume 1, Chapter 4, fluid fine tailings management has been and continues to be the focus of significant research and development (R&D) efforts at Syncrude. Volume 1, Figure 4.3-1, Page 4-8, summarizes the decision/evaluation process that led to the selection of MFT centrifuging for implementation to supplement existing technologies in managing fluid fine tailings accumulation. Also, Volume 1, Table 4.4-1, Page 4-11, shows the R&D strategy for continuing fluid fine tailings technology development. As explained in Volume 1, Section 3.3.6, Page 3-18, Syncrude evaluated the implementation of fines treatment technologies as an alternative to address the fluid containment shortfall identified in the SWSS Conversion Project application. It was concluded that sufficient MFT conversion capacity could not be implemented in time to address the containment shortfall.



5. Volume 4, SIR 35, Page ERCB-62, Table 6.3-1 (Rev 1). From the table:

ERCB text: The criterion establishes a minimum mass of dry fines in the oil sands feed expressed as a percentage of total fines in feed that must report to the DDAs. Syncrude states: “The plan proposed by Syncrude in this application meets the fines consumption target on a long term cumulative basis.”

ERCB text: The phase-in sequence will be as follows: 20 per cent from July 1, 2010, to June 30, 2011. 30 per cent from July 1, 2011, to June 30, 2012. 50 per cent from July 1, 2012, to June 30, 2013, and annually thereafter. Syncrude states: “The proposed plan shows total fines to CT as 9% from July 1, 2010 to June 30, 2011. The proposed plan shows total fines to CT as 12% from July 1, 2011 to June 30, 2012. The proposed plan shows total fines to CT as 14% from July 1, 2012 to June 30, 2013. The proposed plan shows fines to DDAs increasing to 57% in 2015 with commercial implementation of MFT Centrifuging technology.” Volume 4, Question 19a, Page ERCB-33. Syncrude states “…a delay in approval has…detrimental impacts on Syncrude’s ability to comply with Directive 074...”

a. Provide an estimate on schedules for fines captures based on legacy fluid fine tailings and future tailings production separately.

Syncrude is unable to provide the information in the requested format. As there is no fines separation step within the Syncrude extraction process, newly created fluid fine tailings report to the same MFT deposit that already contains legacy MFT. As such, fines management technologies such as CT, MFT centrifuging and MFT water capping all draw from the same source of fluid fine tailings without differentiation between legacy and newly formed MFT. In its simplest form, the schedule requested is included in Volume 1, Figure 3.1-3, Page 3-6, which represents Syncrude’s MFT reduction commitment for the Mildred Lake site. The red line on the chart represents Syncrude’s MFT reduction commitment including the implementation of MFT centrifuging technology as detailed in the application. An annual increase in total MFT volume indicates that more fresh MFT is created than the volume being consumed in tailings deposits (now-2014); similarly, annual decreases in total MFT volume indicates that more MFT is consumed into tailings deposits than the volume of newly created MFT, allowing a drawdown of legacy volumes as well (2015-2045).

b. What is the volume of fines accumulation in years 2010 to 2015 (by year) that will not be captured as required by Directive 074?

The requested information is represented graphically in Figure SIR2 ERCB 5-1. The chart shows the tonnage of fines that will not be captured annually when comparing the SWSS Conversion Project plan to the Directive 074 prescription. The information is shown based on tonnage rather than volume as the fines tonnage is not influenced by MFT consolidation modelling assumptions.

FIG. SIR2 ERCB 5-1

SOUTHWEST SAND STORAGE CONVERSIONPROJECT:

TITLE:

Fines Not Captured Per Directive 074DESIGN

CADD

CHECK

REVIEWSCALE: AS SHOWN REV 0

1.3

3.7

5.3

7.5

2.8

(0.7)

-2

-1

0

1

2

3

4

5

6

7

8

9

10

2010

2011

2012

2013

2014

2015

Year

Fine

s no

t cap

ture

d (M

illio

n to

nnes

)

Note: This chart represents the tonnage of fines that will not be captured in DDAs annually from 2010 to 2015, comparing the SWSS Conversion Project plan to the Directive 074 prescription.

Any negative values represent fines captured in excess of the Directive 074 prescription.



c. Provide additional justification to support Syncrude’s proposed plan that does not meet Directive 074 requirements prior to 2015.

Syncrude notes that the SWSS Conversion Project application was submitted to regulators on 20 November 2008; the ERCB Directive 074 (“the Directive”) was released on 3 February 2009. Syncrude understands that the intent of the Directive is to ensure responsible tailings management by oil sands operators, with specific focus on the disposition of fluid fine tailings. Syncrude submits that the tailings management plan outlined in the SWSS Conversion Project application satisfies that intent. The proposed tailings management plan provides a solution to a short-term fluid containment shortage and ensures that the closure plan is not compromised in the process. Syncrude commits to a risk managed technology development approach to implementing MFT centrifuging technology at Mildred Lake. The addition of MFT centrifuging to the portfolio of fines management technologies positions Syncrude well to achieve the requirements of the Directive within a reasonable timeframe. Syncrude notes that normal progression of the MFT centrifuging commercial demonstration project is dependent on the outcome of this application.

d. What would be the consequences of imposing approval conditions that would hold Syncrude to the implementation of MFT Centrifuging or alternate technology by the dates as specified in Directive 074?

Syncrude maintains that the schedule proposed for the implementation of MFT Centrifuging presents a risk-managed approach to the introduction of a fines management technology. The proposed schedule includes a commercial demonstration in 2012 followed by the commercial-scale MFT Centrifuging operation in 2015, with a further increase in plant capacity in 2018. Advancing the schedule for any of the proposed implementation stages results in unacceptable geotechnical, environmental, and reclamation/closure risks. The outstanding risks in implementing MFT Centrifuging are listed in Volume 1, Table 4.4-4, Page 4-22. The proposed development schedule is intended to mitigate the identified risks. From a tailings placement point of view, areas suitable for the permanent storage of centrifuge cake at the Mildred Lake site are limited prior to the North Mine South Pond becoming available. Advancing MFT Centrifuging volumes would force the storage of large volumes of centrifuge cake above grade in areas such as the EIP or the SWSS facilities. As long-term geotechnical performance of centrifuge cake remains an outstanding risk of MFT Centrifuging technology, the placement plan proposed by Syncrude sequesters this material in a small unconfined deposit in the case of the commercial demonstration; and below original grade in mined out pits where it can be sufficiently capped for reclamation as a dry landscape feature in the case of the commercial plant. Until geotechnical performance can be confirmed on large deposits, Syncrude does not support placement of large volumes of centrifuge cake above original grade.



1.2 TAILINGS MANAGEMENT 6. Volume 4, SIR 9, Page ERCB-12. Syncrude refers to the “2004 Lease Development

Plan” and mentions that “…the 2004 Plan included thickened tailings deposit from in-line flocculation of the cyclone overflow by-product from the CT Plant. This technology was not implemented at the Mildred Lake site. The SWSS Plan includes a commitment to implement MFT Centrifuging technology.”

a. Considering the “…thickened tailings deposit from in-line flocculation of the cyclone overflow by-product from the CT Plant…” technology that was not implemented as per the 2004 Lease Development Plan, what certainty does Syncrude have in the implementation of MFT Centrifuging technology? Explain.

In-line flocculation and MFT Centrifuging are both fines management technologies that have been demonstrated at the field pilot scale; two fundamental differences between the technologies serve as the basis for the explaining the commitment made to implement MFT Centrifuging vs. the decision not to pursue in-line flocculation further at this time. First, in terms of process integration, one of the main disadvantages of in-line flocculation is the direct-coupling of the technology with the CT plant; which in turn is directly coupled with the Extraction plant. The dependence of in-line flocculation on availability of the Extraction and CT plants limits the total fines conversion capability of the technology. On the other hand, MFT Centrifuging is independent of the Extraction plant; fully decoupled from bitumen production. The fact that MFT Centrifuging is decoupled from bitumen production allows for a steady fines conversion volume independent of other plant processes. Second, in-line flocculation is intended to manage new fines whereas MFT Centrifuging is able to address both new and legacy MFT. The total fines conversion capacity of MFT Centrifuging technology can be designed to outpace the production of new MFT, independent of bitumen production. Given the large volume of accumulated legacy MFT at the Mildred Lake site, MFT Centrifuging provides the fines conversion flexibility that Syncrude needs to support the approved C&R Plan. Volume 1, Table 3.6-2, Page 3-53 can be used to illustrate the capacity comparison between in-line flocculation of the cyclone overflow by-product from the CT plant and MFT Centrifuging. The total annual volume of cyclone overflow beach varies between 0.3 and 1.1 Mm3 and is directly dependent on total CT production; MFT Centrifuging volumes are 2 to 10 times higher than the cyclone overflow beach volumes and are independent of CT or bitumen production. Syncrude believes that more than one fines management technology will be required to achieve closure goals, the overall fines conversion capability of the technologies evaluated is an important factor in selecting technologies to implement.



b. What is required to accelerate the implementation of commercial demonstration of MFT Centrifuging technology?

See response to SIR2 ERCB 5(d).

c. What is the plan and schedule to manage unresolved “outstanding technology risks” of MFT Centrifuging technology?

Outstanding technology risks associated with the implementation of MFT Centrifuging technology are being addressed through a combination of:

• continued evaluation of the centrifuge cake deposits formed during the 2008 Centrifuge Pilot;

• engineering assessments, ongoing as part of the project development process; • design and project execution of a commercial demonstration scheduled to begin in 2012;

and • applying design and operational learnings to subsequent project stages.



7. Volume 4, SIR 29a, Page ERCB -25, Table SIR-16-ERCB-1. Syncrude states”…the current design of the BML is based on an import of 20 Mm3 of Athabasca River or Beaver Creek Reservoir water to establish the water cap…This improvement in design reduces the amount of water transferred to the recycle water pond and other fluid containing structures by a factor of one-third (relative to the initial projections of 30 Mm3).”

a. Provide the corresponding time reference regarding the containment assumptions to reflect when these containment volumes will be required.

Establishment of the water cap for the Base Mine Lake (BML) is scheduled to take place over the 2012 to 2013 timeframe. The optimized BML fresh water requirements have not been incorporated into the tailings plan at this time; although the volumes may be optimized further, the timing for the establishment of the water cap has not changed from that presented in the SWSS Conversion Project application and outlined in Table SIR-16-ERCB-1.

b. Clarify the 45.8 Mm3 column for “2007 Sand/CT deposit volume”, column (B).

The constant value of 45.8 Mm3 shown in column (B), 2007 sand/CT deposit volume, does not represent an actual measured volume of material. The constant value is purely cosmetic for charting purposes. To ensure that the chart remains readable, only go-forward volumes of sand and CT are shown. The constant value of 45.8 Mm3 was assigned to the year-end 2007 sand/CT volume to allow projection to the desired y-intercept for sand/CT volume.

c. Column (E), what is the reason for the volume increases to 60.0 Mm3 and 90.0 Mm3 for the last two entries of the column?

The 60.0 Mm3 and 90.0 Mm3 entries for the years 2045 and 2046 in column (E) are place holders to reflect the expectation that additional fresh water will be required in those years to establish the required water cap in the North Mine End-Pit-Lake (EPL).

d. Column (E), explain why 30.0 Mm3 Fresh Water Cap for BML/EPL does not require containment for column (F)?

As the West In-Pit (WIP) facility becomes Base Mine Lake (BML) in 2012, it is assumed that the facility becomes isolated from active tailings operation at the Mildred Lake site. As such, the BML water cap of 30.0 Mm3 shown in column (E) is represented as a drop in available containment on the chart rather than a volume requiring containment.



e. Explain the apparent conflict of the 30.0 Mm3 Fresh Water Cap for BML/EPL column (E) with the response to SIR Question 29a. Explain how this “improvement in design” can reduce the containment requirement for SWSS.

The Base Mine Lake project design optimization has not yet been incorporated into the tailings plan. Changes to the BML planning basis will be incorporated into future tailings plans. Directionally, taking in less fresh water to establish the water cap will provide some relief to the identified fluid containment shortage in the 2012-2013 timeframe. However, an adjustment of +/-10 Mm3 to the water volume required to establish the water cap are within the working error-band of the overall tailings fluid balance and may be offset by other planning variables.



8. Volume 1, Section 3.6.1.6, Page 3-51. Syncrude states “Tailings deposition in the NMSP is planned to begin in 2013.” Volume 4, SIR 18c, Page ERCB-32. Syncrude states “…the North Mine South Pond opening up for tailings storage in 2014…”

a. Explain the discrepancy between these two statements.

The North Mine South Pond (NMSP) is planned to be used for tailings placement beginning in 2014. The statement from Volume 1, Section 3.6.1.6, Page 3-51, should read: “Tailings deposition in the NMSP is planned to begin in 2014.” Figure 3.6-1 (Volume 1, Page 3-57), Mildred Lake Tailings Disposal Schedule, and Table 3.6-3 (Volume 1, Page 3-55), Tailings Placement Schedule (Mildred Lake) are both consistent with the corrected statement, showing tailings placement beginning in 2014 in the NMSP.

b. What is the contingency plan if the North Mine South Pond is not ready for storage when required?

As tailings production is directly related to mining tonnages, Syncrude is confident that mining activities will be completed in time; as both mining and tailings rates would increase or decrease in tandem. A variable that has the potential to affect the availability of the North Mine South Pond (NMSP) is the construction of the North-South (N/S) Dyke to isolate the west portion of the NMSP for tailings placement to begin in 2014. The construction of the N/S Dyke is currently planned to be completed in its entirety using overburden. Construction delays could potentially be mitigated by modifying the design for the structure to allow construction using hydraulically placed tailings sand. However, the dyke construction schedule is not the critical path to meet the tailings placement schedule in the NMSP and is not expected to result in delays in NMSP availability for tailings.

c. What are the factors that limit the accelerated ore/overburden removal to allow earlier tailings deposition into the North Mine South Pond (west), and therefore result in less reliance on the SWSS for fluid tailings containment? Explain and provide details.

Factors that limit the accelerated ore/overburden removal to allow earlier tailings deposition into the North Mine South Pond (west) include:

• ore grade/fines and blending requirements; • mining equipment efficiency/potential congestion; and • N/S Dyke construction timing. Based on the factors listed above, the aerial extent of the west portion of the NMSP is not sufficient to maintain planned mining rates while focusing all mining activity in that area. In addition, accelerating the availability of the NMSP (west) would have negative impacts on the availability of the main (east) portion of the NMSP by delaying exposure of the footprint and construction of the E/W Dyke 1.



9. Volume 4, SIR 23d, Page ERCB-38, Table SIR-23-ERCB-1. Syncrude references “Smart Sand” in this table. Provide definition of and uses for “Smart Sand”.

Smart Sand is utilized in the construction of upstream sand blankets against overburden structures. The term Smart Sand was coined to describe an efficient coarse tailings placement operation that maximizes solids capture. Smart Sand construction consists of contained beaching of coarse tailings into a long cell parallel to the structure against which the sand blanket is to be placed. For increased solids capture, a small pond may be allowed to form at the end of the cell to reduce the energy in the system. The concept of contained beaching is widely utilized in conventional dyke construction using hydraulically placed tailings; Smart Sand construction efficiency applies specifically to contained beaching against an existing structure.



10. Volume 4, SIR 31c, Page ERCB-49 and Table 4.4.3 (Rev 1), Page ERCB-50. Syncrude states “This update has been prepared using the unit cost information provided in Table 4.3.2. {of the application}.” What other factors were considered when calculating the costs for the years 2012 to 2014? (1.5 Mm3 x $2.10 per m3 = $3.2M and 1.5 Mm3 x $2.75 per m3 = $4.1M).

Unit costs for the commercial demonstration facility were estimated at $3.33 to $5.00 per m3 MFT. It was assumed that a facility of this scale would have higher unit costs. Such costs were derived on a ‘scale factor’ basis, with a ‘scale factor of 0.5 to 0.6. Formulae as follows:

• Annual Operating Cost = $10.5M * (1.5/5)0.6 = $5.1M (Rounded to $5M); and • Annual Operating Cost = $13.8M * (1.5/5)0.5 = $7.6M (Rounded to $7.5M).



1.3 TERRESTRIAL 11. Volume 4, SIR 40, Page ERCB-73. Regarding the in-flow and out-flow rates for

BML, Syncrude states “This optimum balance is being determined via predictive modelling as well as interpretation of the body of research on water capped MFT.”

a. Provide a list of the research presently being conducted to determine the final details of water inflow and outflow requirements to sustain Base Mine Lake.

As noted in Volume 4, SIR 40, Syncrude is in the process of developing, calibrating, and operating a three dimensional flow and quality model to establish the range of flow required to facilitate a sustainable design basis for Base Mine Lake. Initial results suggest that an annual flow of 6-10 Mm3/yr is required to attenuate water quality in such time as to facilitate initiation of ecosystem development in the 5-10 year time frame. Syncrude is in the process of preparing a compilation of research undertaken in support of the current design basis for Base Mine Lake. This compilation will be ready for distribution in 2010. Future research consists of a monitoring program to validate the design basis and hypotheses advanced from research to date and contained in the current Base Mine Lake design basis. Syncrude is also developing contingency plans to adjust the Base Mine Lake design basis in the event that water quality attenuation and ecosystem advance deviates from current forecasts. Syncrude has initiated work on this program, and plans to complete this body of work prior to Base Mine Lake initiation in 2012. Syncrude notes that the SWSS Conversion Project Application seeks approval of a change to the duty of SWSS and inclusion of centrifuge technology in the Project Scheme. Approval for the demonstration of MFT water capping through the Base Mine Lake Project has already been secured per ERCB Decision 94-5 and has since been incorporated into Syncrude’s C & R plans by AENV under EPEA.

b. Provide a list of planned research in order to determine the final details of water inflow and outflow requirements to sustain Base Mine Lake. Include dates when this research is planned.

See response to SIRs ERCB 11(a) above.



12. Volume 4, SIR 41a, Page ERCB-74. Syncrude states “Preliminary sand cap design for watershed management remains as per the 2006 C&R Plan submitted for the Application for renewal of Syncrude’s approvals under the Alberta Environmental Protection and Enhancement Act (March 2006 )”

a. Provide the proposed sand cap design for SWSS watershed management.

Sand cap design, in the context of the response to Volume 4, SIR 41a, Page ERCB-74, refers specifically to sand capping of a CT tailings product in preparation for final reclamation. CT is not planned to be placed at the SWSS. At closure, the SWSS facility will be reclaimed as a sand deposit. The MFT and water will be removed from the internal pond area and a channel will be established through the dyke to allow drainage of the interior slopes. Additional sand is not being allocated to cap the facility for closure, where required, existing sand will be reshaped to meet the final landform design as represented conceptually in Volume 2, Figure 14.1, Page 14-3.

b. Discuss the details of research being conducted on the topic of sand cap designs. Include the depth and shape of the sand cap as well as the depth of the saline water table.

Syncrude has undertaken significant research in soft tailings capping technology development. Numerous field and pilot-scale screening experiments have been conducted to refine our understanding of soft tailings capping focusing on placement technologies and material requirements for effective hummock performance. The Sandhill Fen Pilot, currently in early construction, will advance technology around the creation of sand hummocks using conventional tailings pouring technologies. As a prelude to the Sandhill Fen Pilot, Syncrude constructed three hummocks using closed open and closed cell construction techniques in the North East In-Pit (NEIP). This work has demonstrated, and confirmed earlier pilot-scale tests, that 2.5m to 3.0m of sand placed hydraulically over a soft-tailings deposit will allow for trafficking of Tailings equipment, which permits hummock construction and reclamation. Water table monitoring is expected to confirm earlier field and pilot tests that the constructed hummock will result in a minimum water table depth of 1.0m below the top of the sand in the swale and 2.0m at the crest of the hummock. Conceptual sand cap and shape and configuration for the Mildred Lake and Aurora Leases are detailed in Syncrude’s 2006 AEPEA Application.

c. Discuss when the watershed management design will be completed.

The final landform design for the SWSS is represented conceptually in Volume 2, Figure 14.1, Page 14-3. As mentioned above, additional sand placement is not being allocated to cap the SWSS facility.



13. Volume 4, SIR 42a, Page ERCB-75. Syncrude states “Laboratory and test pond data indicate that: MFT may mitigate some toxicity associated with OSPW.” Syncrude also states that “Sub-lethal chronic effects on fish will decline with time.”

a. Elaborate on the statement that MFT may mitigate some toxicity associated with OSPW. Provide the associated research and discuss the findings.

The combined field and laboratory studies of the chemistry of pore and release waters from Syncrude MFT indicate that most compounds disappear from overlying water caps within months. The potential build-up of dissolved salts in a lake habitat could be mitigated by creating flow-through using freshwater, which would thereby dilute the salts. However, optimal conditions for the degradation of naphthenic acids would occur where water retention times are extended for several years; long retention times would necessitate minimal flow-through. These competing requirements will need to be balanced through careful design, to create the optimal conditions for both water exchange and retention. Syncrude is in the process of preparing a compilation of research undertaken in support of the current design basis for Base Mine Lake. This compilation will be ready for distribution in 2010. Future research consists of a monitoring program to validate the design basis and hypotheses advanced from research to date and contained in the current Base Mine Lake design basis. Syncrude is also developing contingency plans to adjust the Base Mine Lake design basis in the event that water quality attenuation and ecosystem advance deviates from current forecasts. Syncrude has initiated work on this program, and plans to complete this body of work prior to Base Mine Lake initiation in 2012. Syncrude notes that the SWSS Conversion Project Application seeks approval of a change to the duty of SWSS and inclusion of centrifuge technology in the Project Scheme. Approval for the demonstration of MFT water capping through the Base Mine Lake Project has already been secured per ERCB Decision 94-5 and has since been incorporated into Syncrude’s C & R plans by AENV under EPEA.

b. What levels of chemistry associated with Oil Sand Process Affected water cause chronic effects in fish over time? The concentrations of concern are those that would prevent locally native fish species from being as healthy as those of natural lakes in the region.

See response to SIR2 ERCB 13(a) above.

c. Discuss the required period of time to observe a reduction in the sub-lethal chronic effects on fish and for the fish population to be as healthy as those of the natural lakes of the region.




d. Discuss if fish living in water-capped tailings lakes would have flesh that would have a taste or odor that varies from those that are found in the natural lakes of the region.




14. Volume 4, SIR 51, Page ERCB-87. Syncrude states “The concept of sand capped soft tailings and the tipped in bench design of the SWSS address groundwater salinity by providing an initial condition buffer of 2m from top of saline water table to closure predicted root zone?

a. What period of time is required to establish the 2 m buffer from the top of the saline water table to the closure predicted root zone?

Timing required in establishing the 2m buffer is dependent on consolidation rate of the soft tailings deposit that is being capped, the permeability of the sand capping material, slope of the capped deposit and environmental conditions. Currently the timing is unknown, however, monitoring of the NEIP test hummocks is currently underway providing us with information to predict when the buffer will be established.

b. What percentage of the slope area with the inward tipped benches will have the 2 m buffer from top of saline water table to closure predicted root zone?

The percentage of the slope area with tipped-in benches to have a 2m buffer from the top of the saline water table at closure is currently unknown. Previous studies on the tipped-in benches of the SWSS were undertaken during operating conditions and showed variability in the water table along the slopes during normal operating conditions and precipitation events (Price A, 2005. Evaluation of Groundwater Flow and Salt Transport within an Undrained Tailings Sand Dam).

c. Discuss the erosion gullies and sustainability of inward tipped benches found on the SWSS to establish vegetated waterways.

The existing gullies have been formed when ponds formed on tipped-in benches during rapid snow melt or intense summer storms resulting in spillage over the bench. This type of event results in large bench-to-bench gullies that develop from the crest of the bench and expand rapidly downwards to the lower bench. They do not occur in the absence of tipped-in benches. Gullies also form as a result of accumulating surface runoff that begins as sheet flow but becomes channelized as a result of topographic irregularities. Another cause of gullying is a piping phenomenon beneath the ice or frozen sand layer of existing deep bench-to-bench water courses that penetrate the local ground water table. It is this third cause of gullying that could affect the sustainability of the SWSS. Preventing the occurrence of bench-to-bench gullies that penetrate the local groundwater table can control this phenomenon. The second cause of gullying involving flow concentration at the lower slopes is expected to be eliminated by the development of a mature surface vegetation cover on the SWSS over time. The development of a new bench-to-bench gullies resulting from bench pond spillage (first cause discussed above) will be controlled by providing suitable drainage of tipped-in benches to prevent the occurrence of bench ponds.



d. Discuss the apparent contradiction with SIR Response 50a, which states that salinity (TDS) of existing SWSS slopes varies from 1800 – 3400 mg/l.

The statement that salinity varies from 1,800-3,400 mg/l shows the range in salinity of the monitoring data. This range is due to readings taken during prolonged operating conditions and meteorological events. Flushing from infiltration of rainwater or snowmelt will dilute groundwater and show a lower salinity whereas period of drier conditions without infiltration events will show higher salinity levels.



15. Volume 4, SIR 54b, Page ERCB-90. Syncrude states “A copy of “Oil Sands Mine Closure Drainage Design Parameters, Syncrude Canada, 2005” has been sent to AENV and the ERCB under separate cover…”. Provide all available peer reviews that were conducted by the Science and Government communities.

Syncrude presumes the ERCB is referencing SIR 52, Page ERCB-88. Syncrude was reliant on this document in the preparation and submission of the 2006 EPEA Permit Renewal Application. This Application was discussed extensively with regulatory and stakeholder communities.



16. Volume 4, SIR 54b, Page ERCB-90. Syncrude states “Syncrude strives to maximize the planting of berry producing and other traditional use species on reclaimed land as they are available” Clarify Syncrude’s commitment to planting berry producing and other traditional use species on lands they reclaim. Will Syncrude create boreal forests with conditions favorable to these traditional use species or will they create alternative ecosystems that will focus on enhancing the establishment and productivity of these species?

Syncrude is committed to planting traditional species on lands they reclaim. For over 10 years, revegetation research has focused on developing propagation techniques for native plant species, as well as on the use of the surface leaf litter/fibric/humic layer (LFH) or shallow soil salvage and placement techniques to enhance native species re-establishment, including berry producing and traditional use species. LFH-shallow soil salvage research has clearly shown the benefits of this specialized soil conservation technique, with treated areas showing significantly better native plant establishment than standard reclamation approaches. The success of the LFH program has resulted in Syncrude incorporating shallow soil salvage and placement into our standard reclamation practice. As LFH reclaimed areas grow and mature, research is underway to study ecosite development and productivity.



1.4 HYDROGEOLOGY 17. Volume 4, SIR 60a, ERCB Page-98. Syncrude states “The statement refers to

seepage of water through the constructed sand dyke.”

a. How does Syncrude model and/or monitor vertical seepage from the SWSS into the groundwater system?

Vertical seepage from the SWSS into the groundwater system is incorporated in the model and can be calculated in the model by assigning a Budget Zone at the pond floor. The groundwater monitoring wells located around the SWSS are intended to detect process-related water if seepage reaches the saturated zone and migrates horizontally.

b. What is the estimated volume of vertical seepage through the pond floor once it is at full capacity?

The calculated vertical seepage through the pond floor is 1,580 m3/day for the Application Case during Operational Phase.

c. What infiltration rate is used to make this estimation?

A recharge rate of 45 mm/year was assigned to the SWSS exposed ground surface (i.e., the tailings dyke surface). The tailing pond area was modelled by assigning a Constant Head boundary condition during the Operational Phase. The Constant Head boundary condition was removed during the Closure Phase (i.e., after 2030) and a recharge rate of 45 mm/year was then assigned to that area, and all exposed land surfaces of the SWSS.

d. What mitigation measures would Syncrude implement should vertical seepage be detected?

Two mitigation measures have been considered in concept. The modelling indicates that the most significant flow path is the sand channel known as G-Pit. Extraction wells in the G-Pit channel to capture affected groundwater could be installed, or a flow barrier (such as a slurry wall) could be constructed across the channel to direct flow into low permeability material outside of the G-Pit channel.



18. Volume 4, SIR 64a, ERCB Page-103. Syncrude states “The dewatered groundwater is discharged into the North Mine dirty water ditch and reports to the Recycle Pond.”

a. Provide an estimate on the quantity of annual dewatered groundwater and the Recycle Pond capacity.

The approximate annual volume attributed to the dewatering of G-Pit is in the range of 0.2 to 0.5 Mm3. In comparison, a water volume in excess of 200 Mm3 cycles through the Recycle Pond on an annual basis; the contribution from G-Pit a mere 0.1 to 0.25% of the total. Independent of the water reporting to the Recycle Pond from the ditching system, the water level in the Recycle Pond is controlled by adjusting inflows from the MLSB siphon or the WIP recycle barge.

b. What are the contingency measures for containment of dewatered groundwater , in the event that the Recycle Pond is full?

See response to ERCB-18(a).



19. Volume 4, SIR 64b, ERCB Page-103. Syncrude states “Although the G-Pit channel dewatering was not included in the current EIA model, several scenarios integrating the G-Pit channel dewatering were run during the EIA study to test the sensitivity of the model to dewatering.” Explain the above mentioned G-Pit channel dewatering scenarios (include changing hydraulic parameters, stresses, boundaries, etc.)

Several scenarios integrating the G-Pit channel dewatering during Operational Phase were run. Six dewatering wells were considered to be located in the centre of the G-Pit channel south limb. They were integrated and used to simulate the dewatering in that area to control the flow of groundwater into the north mine as the north mine advances. The objective of the dewatering was to lower the groundwater heads in the G-Pit channel to its base (i.e., complete dewatering) during the Operational Phase. The model utilized a “Drain” boundary condition to simulate the dewatering wells rather than assigning a “Well” boundary condition. “Drain” is a special form of the General Head Boundary (GHB) condition, and only functions to allow flow out of the groundwater system when the simulated groundwater head exceeds the fixed drain elevation. The specified water heads of these “Drains” were fixed at 0.1 m above the bottom of the G-Pit channel at each location. Therefore, by assigning the “Drain” boundary condition to those locations where the dewatering wells were screened, the groundwater heads in the G-Pit channel in that area would essentially be dewatered to the bottom of the G-Pit channel. The dewatering periods were assumed to be 10 years (2006-2016) for the Baseline Case, Operational Phase, and 4 years (2012-2016) for the Application Case, Operational Phase. The “Drain” boundary conditions were removed from the models after 2016 for both scenarios. Therefore it was assumed that dewatering of the G-Pit channel would cease at the end of operations, in 2016. The simulated results indicated that plume migration was not sensitive to the dewatering because the plume would not reach the “capture” zone of the wells before 2016, which was the end of the “pumping” period.



20. Volume 4, SIR 64c, ERCB Page-103. Syncrude states “The flow model was calibrated based on the 28 wells in the vicinity of the SWSS facility representing the local flow regime.” Provide cross sections of the monitoring wells illustrating their numbers, locations relative to SWSS, penetration depth, aquifer name, and measured water level.

Syncrude has included logs (see Appendix B) for the monitoring wells used in the calibration of the flow model. As the logs for wells OW91-10R, OW94-09, and OW04FGD09A were found to contain incomplete interpretations, the log for well OW91-10 is substituted to represent well OW91-10R, the log for well OW92-03A should be used as a representative section of well OW94-09, and the log for well OW04FGD09 should be used as a representative section for well OW04FGD-09A. The logs provided include the well number, penetration depth and facies description. Refer to Volume 1, Figure 3.4-2, Page 3-22 for a description of facies present at the Mildred Lake site. Refer to Volume 2, Figure 6.2, Page 6-14 for the location of each well relative to the SWSS facility. Measured water levels are included in Table SIR2 ERCB 20-1.



Table SIR2 ERCB 20-1: Measured Water Levels

Part (a) Well Number/Measured Water Level

Year OW03-23 OW04

FGD-05 OW04

FGD-06 OW04

FGD-09 OW04

FGD-10 OW04

FGD-12 OW91-07A OW91-10R OW91-11 OW91-13 OW91-15 OW91-16 OW92-01A OW92-02A

1991 344.37 347.39 350.36 353.33 1992 344.85 348.2 351.98 353.34 361.79 366.24 1993 349.11 344.3 347.1 351.42 352.1 362 365.3 1994 348.52 344.78 347.07 351.5 352.56 362.11 365.61 1995 348.52 344.3 346.72 351.32 352.23 361.78 365.23 1996 348.66 344.76 347.08 351.89 353.3 363.16 365.81 1997 349.42 348.79 344.62 347.76 351.77 353.36 363.65 365.45 1998 349.43 348.5 344.55 347.3 351.26 354.35 363.48 365.56 1999 349.48 348.52 344.22 346.28 350.99 351.92 362.97 365.48 2000 349.69 348.5 344.69 345.97 351.2 351.9 362.57 364.75 2001 350.2 348.47 344.13 345.89 350.84 351.92 362.55 364.992 2002 349.94 348.58 343.58 345.31 350.04 351.3 361.94 364.51 2003 385 349.97 348.51 344.39 345.41 350.59 351.48 362.19 364.84 2004 384.405 337.07 337.85 334.81 336.15 332.16 349.66 348.232 343.64 346.135 350.69 351.61 363.587 365.417 2005 2006 384.63 336.95 337.97 335.05 333.07 349.54 348.58 344.17 346.47 350.89 351.57 363.54 365.412 2007 384.22 336.86 337.51 349.33 348.71 344 343.22 350.6 351.88 363.58 365.332

Part (b)

Well Number/Measured Water Level Year OW92-03A OW94-09 OW96-01 OW96-02 OW98-10 OW98-11 OW98-12 OW98-13 OW98-14 OW98-15 OW99-29 OW99-30 OW99-31

1991 1992 369.78 1993 369.11 1994 369.76 1995 369.53 372.05 1996 370.17 373.63 369.14 351.19 1997 369.68 371.66 366.83 351.12 1998 369.9 372.5 369.19 351.18 358.42 1999 370.49 372.07 368.95 351.14 348.78 348.53 349.32 349.49 354.17 358.48 2000 370.18 372.07 368.21 351.16 348.83 348.76 349.31 349.5 354.63 358.73 373.27 380.46 390.35 2001 369.976 372.12 368.983 351.129 348.88 348.32 349.02 349.4 354.84 359.32 372.33 379.8 389.89 2002 369.66 371.15 367.85 348.34 348.02 349.23 349.37 353.67 358.82 371.4 379.33 389.43 2003 370.11 371.53 368 349.83 348.79 348.61 349.19 349.49 354.27 359.1 372.73 379.93 390.13 2004 369.906 372.09 369.153 348.929 347.53 348.26 348.845 349.36 354.83 359.535 372.19 379.68 389.62 2005 2006 369.856 372.42 369.113 349.319 348.5 348.29 348.97 349.39 354.91 359.34 372.36 379.98 389.69 2007 369.866 372.69 369.183 349.069 348.89 348.57 348.88 349.62 359.15 372.61 380.11 389.9



21. Volume 4, SIR 65, ERCB Page-105. Syncrude states “There is limited information documenting this activity.” Syncrude also states that “the results of Golder’s sensitivity modelling indicated that there should have been solute breakthrough at monitoring wells OW91-06 and OW96-02” and “The borrow area could not be realistically represented in the model, given the limited information available.” Discuss in detail Syncrude’s preventative measures to tackle process affected water vertical seepage in south limb portion of G-Pit in highlight of the high hydraulic conductivity.

To clarify, the previous modelling conducted by Golder showed that the area is not backfilled with high hydraulic conductivity materials, as their modelling shows that, in the absence of lower permeability backfill, monitoring wells OW91-06 and OW96-02 would observe “breakthrough”. Since “breakthrough” of process related water has not been observed yet at these wells, it is reasonable to conclude that lower permeability backfill was likely used in the G-Pit channel. Syncrude will continue to monitor wells located around the SWSS and in the G-Pit channel for process-related parameters. In the event that chemical parameters are identified in the G-Pit channel that could be due to process-affected water resulting from vertical seepage in the south limb portion, parameter concentrations will be monitored. Comparisons will be made with expected “breakthrough” concentrations from current and previous modelling efforts in order to determine the appropriate time to implement mitigation measures if needed. This should allow time to design and implement mitigation measures. As mentioned in the response to question 17.d, mitigation measures could involve either dewatering of the G-Pit channel to capture and contain contaminated groundwater or construction of a flow barrier (such as a slurry wall) to slow down and/or divert process-affected water from the G-Pit channel.



22. Volume 4, SIR 67, ERCB Page-108. Syncrude states “Chlorides concentrations are considered the most conservative indicator for process-affected plume development.” According to the provided diagrams, the chloride concentration in OW91-11, OW91-12, OW91-13, OW92-01A, OW92-02A, OW92-02A, OW94-09, OW96-01, OW98-14/OW91-17, OW98-15/OW91-01A, OW99-29, OW99-30, OW99-31, and OW03-23 are between 0-10 ppm (15 out of 17 wells). Accordingly, provide the chemical water balance for the anions and cations for these wells.

The diagrams provided in the response to Volume 4, SIR 67, Page ERCB-108, contain the historical trends and annual measured values for the major ions. The ionic balance has been completed on the 2008 measured values to complement the information shown on the diagrams. The ionic balance is shown in Table SIR2 ERCB 22-1 below.

Table SIR2 ERCB 22-1: Ionic Balance for SWSS Wells (2008)

Well ID Date Sampled Field pH Ion Balance OW91-07A 20-Jun-08 7.33 1.05 OW91-10R 20-Jun-08 7.57 1.01 OW91-11 20-Jun-08 7.22 1.04 OW91-12 20-Jun-08 6.69 1.05 OW91-13 20-Jun-08 6.03 1.08 OW91-15 6-Jun-08 10.1 1.05 OW91-16 6-Jun-08 9.79 1.01 OW92-01-A 12-Jun-08 7.14 1.05 OW92-02A 12-Jun-08 7.39 1.01 OW92-03A 10-Jun-08 7.06 1.06 OW94-09 10-Jun-08 6.97 1.04 OW96-01 20-Jun-08 7.98 1.01 OW98-14 10-Jun-08 6.86 1.05 OW98-15 20-Jun-08 8.08 1.04 OW99-29 20-Jun-08 7.66 1.04 OW99-30 20-Jun-08 7.21 1.08 OW99-31 20-Jun-08 8.55 1.07 OW03-23 10-Jun-08 6.95 1.00



23. Volume 4, SIR 70a, ERCB Page-131. Syncrude states “It was not considered necessary, relevant or practical to prepare a baseline case that dates back to equilibrium conditions. It was necessary to establish a moment in time at which to represent baseline conditions for ease of comparison to the Project conditions. 2006 was selected as the baseline year because it provided the most recent dataset.”

a. If the initial head was launched from a non-equilibrium condition (2006), then explain how the groundwater flow steady-state calibration was achieved?

The regional groundwater flow regime was considered to be relatively steady. The focus of the modelling effort was to determine the effect of changing the SWSS design on groundwater levels and flow. Therefore it was the difference in simulated conditions for the two cases that was considered important. For the local groundwater flow regime, the record of monitored groundwater levels in wells installed around SWSS was examined (i.e., the 28 wells used for the flow model calibration). The historical groundwater level record (dating back as far as 1991) indicates that the local groundwater flow regime near the SWSS facility can be considered to be relatively steady for the purposes of the current study (Table SIR2 ERCB 23-1). Observed groundwater levels generally fluctuated less than two metres, and many wells exhibited much less fluctuation over the period of record that could be interpreted as being near-steady, or due to natural fluctuations.

b. What were the stresses that were incorporated and simulated in the initial model run?

Constant Head boundary conditions were assigned at several locations in the model, i.e., the tailings pond, the MacKay River and Athabasca River. Drain boundary conditions were also assigned at the MacKay River and Athabasca River for those cells above the river elevations. By assigning Drain boundary conditions to those cells, the groundwater was allowed to flow out of the groundwater system at the escarpment of the MacKay River and the Athabasca River. In addition, a recharge boundary condition was assigned to the top layer of the model. There were no temporal changes in stresses, except for simulations that involved closure (and resulting change in boundary conditions).



Table SIR2 ERCB 23-1: Monitored Groundwater Elevations for Wells Used for Flow Model Calibration

Well ID UTM Zone 12 Easting

UTM Zone 12 Northing

Top Elevation (m asl)

Depth of Well (m)

Date of Measurement

Calculated Groundwater

Elevation (m asl) OW03-23 454952.24 6311331.46 385.47 12.19 07/28/2003 385.00

07/22/2004 384.41 06/29/2006 384.63

OW91-11 456172.41 6318019.45 345 9.20 05/02/1991 344.37 06/23/1992 344.85 09/13/1993 344.30 06/28/1994 344.78 07/10/1995 344.30 06/12/1996 344.76 06/23/1997 344.62 06/16/1998 344.55 10/19/1998 343.16 06/02/1999 344.22 06/21/2000 344.69 07/10/2001 344.13 07/08/2002 343.58 06/16/2003 344.39 07/20/2004 343.64 06/29/2006 344.17

OW91-13 456152.01 6317447.65 349.7 9.20 05/02/1991 347.39 05/19/1992 348.20 05/16/1993 347.10 06/28/1994 347.07 07/10/1995 346.72 06/12/1996 347.08 06/26/1997 347.76 06/18/1998 347.30 10/19/1998 346.79 10/21/1998 346.79 06/02/1999 346.28 06/21/2000 345.97 06/22/2000 345.96 07/10/2001 345.89 07/08/2002 345.31 06/16/2003 345.41 08/18/2003 345.52 07/26/2004 346.14 08/26/2004 346.05 06/29/2006 346.47

OW91-15 456082.04 6316304.5 352.4 9.20 05/02/1991 350.36 05/19/1992 351.98 05/30/1993 351.42 06/13/1994 351.50 06/12/1995 351.32 06/04/1996 351.89 06/04/1997 351.77 06/15/1998 351.26 10/15/1998 350.19






Depth of Well (m)

Date of Measurement


Elevation (m asl) 06/08/1999 350.99 OW91-15

continued 05/29/2000 351.20 07/09/2001 350.84 07/08/2002 350.04 06/16/2003 350.59 07/21/2004 350.69 06/29/2006 350.89

OW91-16 456080.89 6315877.39 353.7 10.70 09/09/1991 353.33 05/19/1992 353.34 05/30/1993 352.10 06/13/1994 352.56 06/12/1995 352.23 06/03/1996 353.30 06/05/1997 353.36 06/22/1998 354.35 10/15/1998 351.52 10/27/1998 351.50 06/08/1999 351.92 05/29/2000 351.90 07/09/2001 351.92 07/08/2002 351.30 06/16/2003 351.48 07/21/2004 351.61 06/29/2006 351.57

OW92-01A 455986.34 6314210.58 364.4 9.20 09/28/1992 361.79 05/16/1993 362.00 06/06/1994 362.11 06/06/1995 361.78 06/04/1996 363.16 06/18/1997 363.65 06/22/1998 363.48 10/15/1998 362.74 06/02/1999 362.97 05/29/2000 362.57 07/10/2001 362.55 07/08/2002 361.94 06/16/2003 362.19 07/22/2004 363.59 06/29/2006 363.54

OW92-02A 455986.8 6313802.24 366.422 9.20 06/22/1992 366.24 05/30/1993 365.30 06/06/1994 365.61 06/06/1995 365.23 06/04/1996 365.81 06/05/1997 365.45 06/22/1998 365.56 10/15/1998 365.05 06/02/1999 365.48 05/29/2000 364.75 07/10/2001 364.99 07/08/2002 364.51






Depth of Well (m)

Date of Measurement


Elevation (m asl) 06/16/2003 364.84 OW92-02A

continued 08/18/2003 365.17 07/21/2004 365.42 06/29/2006 365.41

OW92-03A 455982.5 6313275.45 370.71 7.60 06/22/1992 369.78 05/16/1993 369.11 06/06/1994 369.76 06/06/1995 369.53 06/06/1996 370.17 06/05/1997 369.68 06/22/1998 369.90 10/15/1998 369.49 06/02/1999 370.49 05/29/2000 370.18 07/10/2001 369.98 07/08/2002 369.66 06/16/2003 370.11 08/18/2003 369.87 07/21/2004 369.91 06/29/2006 369.86

OW94-09 455916.95 6312353.96 374.06 6.90 06/06/1995 372.05 06/06/1996 373.63 06/05/1997 371.66 06/23/1998 372.50 10/16/1998 371.29 06/02/1999 372.07 05/29/2000 372.07 07/10/2001 372.12 07/08/2002 371.15 06/11/2003 371.53 07/22/2004 372.09 06/29/2006 372.42

OW96-01 451225.18 6317332.24 370.243 13.30 06/12/1996 369.14 06/26/1997 366.83 06/16/1998 369.19 10/16/1998 369.03 06/08/1999 368.95 03/28/2000 368.21 07/04/2000 369.13 07/18/2001 368.98 07/09/2002 367.85 06/16/2003 368.00 07/20/2004 369.15 06/30/2006 369.11

OW96-02 454029.56 6319387.51 351.689 22.90 07/17/1996 351.19 07/17/1997 351.12 07/13/1998 351.18 06/15/1999 351.14 06/22/2000 351.16 07/19/2001 351.13 07/09/2002






Depth of Well (m)

Date of Measurement



continued 07/22/2004 348.93 06/28/2006 349.32

OW98-10 455979.95 6317020.86 349.37 7.01 01/22/1999 348.13 06/08/1999 348.78 05/30/2000 348.83 07/09/2001 348.88 07/08/2002 348.34 06/16/2003 348.79 12/08/2004 347.53 06/29/2006 348.50

OW98-11 455943.5 6317039.22 349.61 7.01 01/22/1999 347.73 06/08/1999 348.53 05/30/2000 348.76 07/09/2001 348.32 07/08/2002 348.02 06/16/2003 348.61 07/20/2004 348.26 06/29/2006 348.29

OW98-12 455949.25 6316977.22 349.65 6.71 01/22/1999 348.17 06/08/1999 349.32 05/29/2000 349.31 07/09/2001 349.02 07/08/2002 349.23 06/16/2003 349.19 07/20/2004 348.85 06/29/2006 348.97

OW98-13 455892.23 6316994.97 350.63 9.75 01/22/1999 348.78 06/08/1999 349.49 05/29/2000 349.50 07/09/2001 349.40 07/08/2002 349.37 10/04/2002 349.12 06/16/2003 349.49 07/20/2004 349.36 06/29/2006 349.39

OW98-14 456060.33 6315325.02 356.2 8.23 01/22/1999 353.99 05/26/1999 354.17 05/29/2000 354.63 07/09/2001 354.84 07/08/2002 353.67 06/16/2003 354.27 08/18/2003 354.37 07/21/2004 354.83 06/29/2006 354.91

OW98-15 452580.6 6318635.71 360.52 10.67 12/11/1998 358.42 12/14/1998 358.95 01/22/1999 358.72 03/10/1999 358.48 04/06/1999 358.71 05/07/1999 359.15






Depth of Well (m)

Date of Measurement



continued 06/30/1999 359.30 03/28/2000 358.73 07/18/2000 359.47 07/19/2001 359.32 07/09/2002 358.82 06/16/2003 359.10 07/20/2004 359.54 06/29/2006 359.34

OW99-29 451248.7 6316241.78 373.55 12.19 07/04/2000 373.27 07/18/2001 372.33 07/09/2002 371.40 06/16/2003 372.73 07/20/2004 372.19 06/30/2006 372.36

OW99-30 451272.6 6315207.36 380.97 10.67 07/04/2000 380.46 07/18/2001 379.80 07/09/2002 379.33 06/16/2003 379.93 07/20/2004 379.68 06/30/2006 379.98

OW99-31 451278.91 6314162.36 390.35 7.62 07/04/2000 390.35 07/18/2001 389.89 07/09/2002 389.43 06/11/2003 390.13 07/20/2004 389.62 06/30/2006 389.69

OW04FGD-05 457475.3793 6318255.646 337.2 3.80 09/09/2004 337.07 07/19/2006 336.95

OW04FGD-06 457615.8947 6317866.351 338.1 6.60 09/08/2004 337.85 07/19/2006 337.97

OW04FGD-09 457844.4572 6318560.724 335.3 7.60 09/08/2004 334.81 07/19/2006 335.05

OW04FGD09A 457842.1993 6318560.247 335.3 4.30 07/19/2006 335.03 OW04FGD-10 457924.4127 6317915.466 336.4 4.50 09/08/2004 336.15

07/19/2006 336.17 OW04FGD-12 458349.0856 6319026.911 333.4 3.50 09/08/2004 332.16

07/19/2006 333.07 OW91-07A 454190.04 6319851.9 349.3 10.70 09/21/1993 349.11

07/17/1997 349.42 07/13/1998 349.43 06/15/1999 349.48 06/22/2000 349.69 07/19/2001 350.20 07/09/2002 349.94 06/17/2003 349.97 07/22/2004 349.66 06/28/2006 349.54






Depth of Well (m)

Date of Measurement


Elevation (m asl) OW91-10R 455581.64 6318067.93 350.3 9.80 09/27/1994 348.52

10/07/1995 348.52 06/03/1996 348.66 06/04/1997 348.79 06/15/1998 348.50 10/15/1998 347.99 06/08/1999 348.52 05/30/2000 348.50 07/09/2001 348.47 07/08/2002 348.58 06/16/2003 348.51 08/18/2003 348.42 07/20/2004 348.23 06/29/2006 348.58



24. Volume 4, SIR 71, ERCB Page-132. Syncrude states “A series of modelling scenarios have been run and the results indicated that migration of the process-affected fluid is not sensitive to dewatering.” What were the assumptions in these modelling scenarios and how were they simulated?

As mentioned in the response to SIR2 ERCB 19, a set of four scenarios that integrate the G-Pit channel dewatering during the Operational Phase were carried out:

1. Baseline Case, Operational Phase; 2. Baseline Case, Closure Phase; 3. Application case, Operational Phase; and 4. Application Case, Closure Phase “Drain” boundary conditions were used to simulate 6 dewatering wells in the centre of the G-Pit channel south limb. The “pumping” periods were assumed to be 10 years for the Baseline Case, Operational Phase and 4 years for the Application Case, Operational Phase. The sensitivity of process-affected water migration to dewatering was determined based on the comparison of simulated concentrations at two G-Pit channel discharging points to the MacKay River. The simulated results indicated that plume migration was not sensitive to the dewatering because the plume would not reach the “capture” zone of the wells before 2016, which was the end of the “pumping” period.



25. Volume 4, SIR 73, ERCB Page-135, Table 6.5. Syncrude states “The model domain and lateral grid are unchanged. Table 6.5 (Rev 1) presents the updated layers and surfaces.”

a. Why was the basal aquifer not considered in the model?

As noted in Volume 4, SIR-ERCB-61, the isopach map of the basal Aquifer unit is very thin or non-existent under the SWSS. Therefore, it was not considered to be of significance for this study. In addition, when considering the thickness of the overlying Clearwater Formation (30-70 m) and McMurray Formation (>40 m) and their relatively low hydraulic conductivity values (K =1x10-9 m/s and K =5.0 x10-8 m/s, respectively) which separate the quaternary aquifer system from the basal aquifer, the potential impact to the basal aquifer from upward or downward groundwater flow was considered to be negligible. Thus, there was no need to include the basal aquifer in the model.

b. How were the hydraulic heterogeneity of aquifers in various formations incorporated into the conceptual model?

Each formation or hydrostratigraphic unit in the model has been assigned their own hydraulic properties (i.e., the materials within the same formation were assumed to be homogeneous and uniform.) Thus, only one value was assigned to each hydraulic parameter for each formation. Normally, each hydrostratigraphic unit was represented by an individual layer in the model. However, for those layers integrating G-Pit channel and/or north mine backfilling materials, two to three hydraulic parameter zones were used in order to assign the different hydraulic parameters in the same layer.



26. Volume 4, SIR 76a, ERCB Page-161. Syncrude states “Chloride is an example of an ion that would be transported primarily by mass transport, because it is very soluble, does not readily degrade, and is not readily retarded by interaction with soil particles (i.e., adsorbed).”

a. After decommissioning and closure will the aquifer continue to release contaminants that were accumulated during the operation life of the pond?

Yes. Residual process related constituents that entered the subsurface during the operating life of the pond will remain in the subsurface after closure. However, these constituents will be subject to attenuation processes, such as dispersion, which will reduce their concentrations.

b. If so, how was this long term behaviour of accumulated contaminants in the aquifers considered in this approach

A constant concentration (i.e., 1 mg/L) was assigned at the “source” area (i.e., representing the distribution of MFT) during the Operational Phase for both the Baseline Case and the Application Case. This loaded process-related fluid mass into the model. The constant concentration boundary condition was then removed from the model during the Closure Phase for both the Baseline Case and the Application Case, as all MFT will be removed from the facility at closure. The accumulated concentrations that had already migrated from the storage area during model simulation remained in the groundwater system at the time of source removal, and continued to migrate along groundwater flowpaths during the remainder of the simulation. The process-related fluids were conservatively assumed to be non-reactive and conservative, so that all mass added to the model from the source area was accounted for throughout the duration of the simulation.



27. Volume 4, SIR 76b, ERCB Page-161. Syncrude states “The model was not calibrated to any observed groundwater parameter concentrations; therefore there is no sensitivity analysis available. The uncertainties in modelling were address [sic] using the mass transport approach for all constituents of groundwater.” Describe the level of confidence in the model results given that no sensitivity analysis was available?

Given that the groundwater flow model calibrated well based on groundwater elevations and the adjustment of hydraulic properties within a realistic range, the groundwater flux is considered to be well represented in the model. As advection and dispersion were the only transport terms considered in the model, the solute transport results are considered to conservatively represent actual solute transport. In order to respond to this SIR, three additional model scenarios were run and completed to examine the sensitivity of the transport model to two parameters which affect process related fluid transport (longitudinal dispersivity and effective porosity). The results of the sensitivity analysis are presented in Table SIR2 ERCB 27-1. The value of longitudinal dispersivity that was assigned in the Base Case model was 30m, representing approximately 1% of the flow path length between the ‘elbow’ of G-Pit and the MacKay River. Sensitivity to this parameter was tested by adjusting it up to 35m (Test Run 1) and down to 17m (Test Run 2). A value of 17m was determined using the equation developed by Xu and Eckstein (1995). Results from Test Runs 1 and 2 indicate that the model’s sensitivity to longitudinal dispersivity is low, with no change to the predicted peak concentrations at the MacKay River (i.e., observation wells COW7 and COW8) and minor differences in the anticipated time of peak concentration. By reducing effective porosity (Test Run 3) the groundwater velocity would increase and the peak concentrations at two observation wells (COW7 and COW8) are expected to increase slightly. Travel time would be reduced by 27% or approximately 50 years earlier than the Base Case. Based on this sensitivity analysis, it is concluded that the solute transport model has provided useful and reasonable results for groundwater transport of a conservative constituent. The model was not sensitive to longitudinal dispersivity. Since constituents from process-affected water would be expected to be affected by additional attenuation processes that were not modelled and would reduce solute concentration and increase travel time, these model results can be considered to represent a conservative case.

Literature Cited:

Xu, M. and Y. Eckstein, 1995, Use of Weighted Least-Squares Method in Evaluation of the Relationship Between Dispersivity and Scale, J. Ground Water, 33(6): 905-908.



Table SIR2 ERCB 27-1: Model Sensitivity to Transport Parameters

Tested Parameter Assumption of Parameters Location Peak Concentration (mg/L) Time of Peak Concentration

COW7 0.012 2461 (431 years after 2030) – Longitudinal Dispersivity, 30 m and Effective Porosity, 0.25

COW8 0.026 2240 (210 years after 2030)

COW7 0.012 2460 (430 years after 2030) Dispersivity Longitudinal Dispersivity, 35 m and Effective Porosity, 0.25

COW8 0.026 2240 (210 years after 2030)

COW7 0.012 2459 (429 years after 2030) Dispersivity Longitudinal Dispersivity, 17 m and Effective Porosity, 0.25

COW8 0.026 2240 (210 years after 2030)

COW7 0.013 2368 (338 years after 2030) Porosity Longitudinal Dispersivity, 30 m and Effective Porosity, 0.20

COW8 0.030 2191 (161 years after 2030)



28. Volume 4, SIR 84, ERCB Page-176b. Syncrude states “An incident-specific response plan will be developed as required in the event that a problem is identified through field observations.”

a. Discuss any simulation of mitigation scenarios taking into consideration the vertical and horizontal flow of groundwater flow.

Table SIR2 ERCB 28-1 provides a comparison of maximum concentrations (and year in which said maximum is reached) for four cases, as follows:

• per the original Application; • per SIR1, ERCB-3, reflecting a revised interpretation of the G-Pit ‘footprint’; • per above, revised to reflect the actual thickness of the G-Pit extension; and • per above, with a slurry wall assumed installed in G-Pit.

Table SIR2 ERCB 28-1: Model Results Summary

Baseline Scenario

Application Scenario

(1) Original Application COW 7 Maximum Concentration 1.147% 2.712% – Year of Maximum Concentration 2,531 2,486 COW 8 Maximum Concentration 1.209% 3.002% – Year of Maximum Concentration 2,476 2,405

(2) Per (1), Revised Channel Area per SIR1, ERCB-3 COW 7 Maximum Concentration 1.158% 2.341% – Year of Maximum Concentration 2461 2426 COW 8 Maximum Concentration 2.559% 5.459% – Year of Maximum Concentration 2,240 2,220

(3) Per (2), revised channel thickness COW 7 Maximum Concentration 0.83% 2.35% – Year of Maximum Concentration 2,483 2,420 COW 8 Maximum Concentration 1.71% 3.78% – Year of Maximum Concentration 2,297 2,281

(4) Per (3), Slurry Wall Assumed COW 7 Maximum Concentration 1.55% – Year of Maximum Concentration 2,548 COW 8 Maximum Concentration 1.40% – Year of Maximum Concentration 2,490



b. Given the complex nature of the groundwater flow system and the time needed to commission a response plan, how will Syncrude ensure that an incident-specific response plan, developed after detection, will fully mitigate the effects of contamination?

A comprehensive water monitoring well network is in place along the full perimeter of the SWSS facility, including a series of wells in the G-Pit channel north of the facility. A plan view showing the monitoring well locations in the vicinity of the SWSS facility is available in Volume 1, Figure 3.7-1, Page 3-69. Through continued water quality monitoring, coupled with a well-populated database providing historical trends and background concentrations for all well locations, Syncrude is confident that anomalies would be detected early on allowing sufficient time to develop and implement an adequate response plan to mitigate the effects of contamination. Syncrude has demonstrated the ability to implement incident-specific response plans to adequately mitigate groundwater seepage problems (see Volume 4, SIR 84c, Page ERCB-176). Depending on the nature and extent of the problem, mitigation such as a pumping system could be implemented in a timeframe of weeks to months; whereas larger initiatives such as a the installation of a cutoff wall would take an estimated one to three years to implement. Based on the problem, a combination of mitigation measures may be required to alleviate a seepage problem in the short-term while a permanent solution is implemented. More detail on a typical response sequence is included in the response to SIR2 ERCB 30.



29. Volume 4, SIR 91b, ERCB Page-186. Table SIR-91-ERCB-1: 2012-2013 Water. Explain why seepage/infiltration was not accounted for?

Assumptions for seepage and infiltration are included as a general component of net runoff in Table SIR-91-ERCB-1: 2012-2013 Water.



30. Volume 4, SIR 93, ERCB Page-189b. Syncrude states “Response time for a slurry wall is one to three years, as some investigation and design work is involved.” Outline and discuss the mitigation measures that would be undertaken after contamination was discovered and before the slurry wall was constructed. Provide a schedule.

The typical sequence of actions showing the steps to the potential implementation of measures to mitigate a groundwater quality incident due to seepage from a tailings facility is outlined Table SIR2 ERCB 30-1.

Table SIR2 ERCB 30-1: Typical Response Sequence

Step Description of Activities Duration/Timing 1 Routine sampling identifies abnormal groundwater quality reading(s). Annually 2 Re-sampling is carried out to confirm abnormal reading(s). 1 month 3 AENV is notified of abnormal reading. Upon confirmation (step 2) 4 Increased monitoring frequency if required. Dependent on nature and

extent of the problem. 5 A response plan is prepared outlining proposed problem mitigation and

implementation plan (includes investigation to define the nature and extent of the problem).

1 week to 2 months

6 The proposed response plan is communicated and endorsed by AENV. 1 to 4 weeks 7 Early response is implemented if required (e.g., pumping wells). 2 weeks to 3 months 8 Design of long-term mitigation alternative per response plan (e.g.,

pumping system, cutoff wall, etc.). 6 months to 1 year

9 Implementation of long-term mitigation alternative. 3 months to 3 years (depending on alternative selected)

10 Reporting to AENV as required. As required



31. Volume 4, SIR 93, ERCB Page-199a. Syncrude states “a comparison between the concentrations in the process-affected plume and natural waters was conducted.” How would this methodology (ratio formula) account for the accumulated concentrations in the aquifer rock matrix during the operational life of the project?

The ratio methodology described in the response to SIR 95 was used to identify substances, or parameters, of interest to be modelled in the surface water quality assessment. The model used for this application (Hydrologic Simulation Program-FORTRAN or HSPF) utilized inputs based on actual groundwater and tailings pond data, as well as the results from the groundwater model.



1.5 AQUATICS 32. Volume 4, SIR 125a, Page AENV-21. Syncrude states “the predicted maximum

baseline and application case concentrations of naphthenic acids in groundwater discharging into the MacKay River are 2.10 and 4.49 mg/L, respectively.” As per RAMP 2008 Technical Report the concentration of Naphthenic Acids [NA] in the MacKay River is <1 mg/L.

a. Elaborate on the impacts on surface water quality as a result of the discharge of groundwater, with the predicted concentration of NA, into the MacKay River.

Using the mass loading methodology described in Volume 2, Section 8.6.2.2 and the NA concentrations indicated above (2.10 mg/L for the base case, 4.49 mg/L for the application case, and 0.5 mg/L for the MacKay River), the NA concentrations have been recalculated (Table SIR2 ERCB 32-1). The difference between concentrations in the base case and the application case is negligible (approximately 0.1%).

b. What measures will Syncrude implement to mitigate the impact on surface water quality?

As impacts to surface water quality in the MacKay River are predicted to be negligible, no mitigation measures are contemplated. Potential mitigation measures to address groundwater in G-PIT are described in the response to SIR2 ERCB 30.



Table SIR2 ERCB 32-1: Calculations of Mass Loadings and Substance Concentrations in the MacKay River at Reach 50 for Naphthenic Acids

Groundwater Concentrations

Groundwater Annual Mass

Loading MacKay River Concentration

MacKay River Annual Mass

Loading

Combined Groundwater

and MacKay RiverAnnual Mass

Loadings

New Concentrations in the MacKay River

Process-Affected Water Median Concentration (mg/L)

Bas

e (m

g/L)

App

licat

ion

(mg/

L)

Bas

e (k

g)

App

licat

ion

(kg)

Bas

e (m

g/L)

App

licat

ion

(mg/

L)

Bas

e (k

g)

App

licat

ion

(kg)

Bas

e (k

g)

App

licat

ion

(kg)

Bas

e (m

g/L)

App

licat

ion

(mg/

L)

% D

iffer

ence

Naphthenic Acids 68.50 2.10 4.49 207 420 0.5 0.5 186,062 186,062 186,269 186,482 0.500 0.501 0.1



33. Volume 4, SIR 42b, Page ERCB-75. Syncrude states that for Base Mine Lake (BML) “The range of predicted TDS concentration is 800 to 3,000 mg/L [3 to 11 times greater than Athabasca River maximum TDS concentration, as per RAMP 2008 Technical Report], within a water cap containing 50% fresh water at initiation. Peak TDS concentrations are expected to decline to 1,800 mg/L [7 times greater than Athabasca River maximum TDS concentration, as per RAMP 2008 Technical Report] after 10 years.” SIR, Page ERCB-188, Question 92, Syncrude states “The Base Mine Lake demonstration (test) period is expected to take 10 years, beginning in 2012. This would be followed by a period within which the lake would continue to develop towards a final reclamation outcome.”

a. As per Syncrude’s modelled results, will BML be deemed a self-sustaining aquatic environment in 2022?

Syncrude is in the process of preparing a compilation of research undertaken in support of the current design basis for Base Mine Lake. This compilation will be ready for distribution in 2010.

Future research consists of a monitoring program to validate the design basis and hypotheses advanced from research to date and contained in the current Base Mine Lake design basis. Syncrude is also developing contingency plans to adjust the Base Mine Lake design basis in the event that water quality attenuation and ecosystem advance deviates from current forecasts. Syncrude has initiated work on this program, and plans to complete this body of work prior to Base Mine Lake initiation in 2012.

Syncrude notes that the SWSS Conversion Project Application seeks approval of a change to the duty of SWSS and inclusion of centrifuge technology in the Project Scheme. Approval for the demonstration of MFT water capping through the Base Mine Lake Project has already been secured per ERCB Decision 94-5 and has since been incorporated into Syncrude’s C & R plans by AENV under EPEA.

b. Provide an action plan to monitor performance and measure successful compliance of the proposed target. Include Key Performance Indicators and the criteria for selecting them.


c. Provide alternative plan to treat the end pit lake water should BML does not prove to be successful at the end of the demonstration phase.


d. Discuss the alternatives that Syncrude may use to address MFT management should the results from the BML demonstration period prove to not be successful.




34. Volume 4, SIR 93, Page ERCB-189. Syncrude mentions the potential mitigation measures and the response time “if changes to groundwater quality are detected as a result of the project”. As per Syncrude statement in Question 60c, the groundwater monitoring along the perimeter of the SWSS shows no indication of process-water contamination.

a. What pro-active measures could Syncrude implement to prevent seepage from reaching the MacKay River or any other water body?

See response to SIR2 ERCB 28(a).

b. How could Syncrude ensure the success of the mentioned interception methods if these are subject to

– the installation of additional monitoring wells for confirmation of the existence of a plume, and

– a minimum three-month implementation period once the problem is detected?

A comprehensive network of monitoring wells is in place along the full perimeter of the SWSS facility. Syncrude believes that the existing well network is adequate to detect the formation of a plume. The installation of additional monitoring wells may assist in defining the extent of the problem if a plume were to develop. Per the response sequence outlined in SIR2 ERCB 30, Table SIR2 ERCB 30-1, Syncrude includes a potential “early response” step in its typical response sequence. In the event that the problem is of a nature and extent such that immediate response is required, immediate action would be taken. Early response may include increased sampling frequency, ditching, installation of pumping wells, etc.

c. Should changes in groundwater quality be detected, how will Syncrude determine if they are as a result of the project?

Syncrude would identify changes in groundwater quality as being a result of the project in the event that groundwater samples display water chemistry similar to process-affected water or concentration of specific components trending toward process-affected water concentrations.



35. Volume 4, SIR 88b, Page ERCB-182. Syncrude stated that the vast majority of tailings fluids do not constitute an unrefined product and no reporting protocol is initiated. As per OSCR, Part 1, (0) “liquid spill” means any crude bitumen, oil sands product, condensate, salt water or contaminated water that … (iii) is in excess of 2 cubic meters if released on an oil sands site. As part of the requirements of Directive 23, Section 2.6.1, provide a copy of the Spill Contingency Plan for this project.

Syncrude submits that the scenario under discussion (incidental release of tailings within the approved operating area) does not constitute a ‘liquid spill’ as contemplated by OSCR or several other ERCB publications. Notwithstanding, the spill contingency plan is as described in Volume 4, SIR 88b: Operational management of these events includes direction or transport of spilled material to containment, cessation of pumping, isolation of the area in question, and repair.



36. Volume 4, SIR 89b, Page ERCB-183, Question 89b, Page ERCB-185, Question 90g, Page ERCB-187, Question 91d. In these sections Syncrude discusses that process-affected waters, including those released from MFT, are within the range of treatment capabilities currently available in water treatment technologies. Elaborate on the currently available water treatment technologies that Syncrude would commit to use should process-affected waters require treatment prior to releasing them into the environment.

Syncrude is not in a position to discuss potential commitments regarding process-affected water treatment. The selection of a water treatment technology for implementation would depend on a number of factors such as:

• the volume of water to be treated; • treatment for discharge or for re-use; • the quality of the water source (e.g., end of pit lake outflow or recycle water); • the required water quality to be achieved; and • consideration for environmental risks related to the storage of waste from the water

treatment process.



1.6 AIR 37. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Section 2.5.1, Page 2-12. Syncrude states “The SWSS contains three phases; a water phase, a bitumen phase and a dry or sand phase. Each of these phases emits substances at different rates”.

Appendix A1, Tables A1.19, A1.20 and A1.21 show the summary of VOC emissions from the Syncrude SWSS ponds. These tables seem to have missing information or incorrect information.

a. Provide the missing Baseline and Project emissions data for compounds such as C6-C16 Aliphatics that have flux rates but no emission rates.

The individual compound flux rates were summed and the total annual emissions are provided in the baseline and project emission columns. Table A1.19 has been reformatted to make this clearer.

b. Explain why in Tables A1.20 and 21 compounds such as H2S and Carbon Disulfide have very different (or zero) flux rates and yet have identical Baseline and Project emissions?

The column labelled “Flux Rate” in the Supplemental Submission is actually the total emission calculated by multiplying the flux rate in g/s/m2 by the total area of the respective pond areas. The Baseline and Project emissions are based on different seasonal flux rates and areas as provided in Table A1.18. Updated Tables A1.19, A1.20 & A1. 21 are provided to more clearly show the flux rates and clarify the approach used in calculating the annual emissions.

c. Provide updated tables with the correct and complete summary of VOC emissions for Syncrude and confirm that the correct emissions data was used in the updated assessment.

As noted in answers (a) and (b) above, additional tables are provided to clarify emissions data. Emissions rates used in the model are consistent with this information.



Table A1.19 (Rev): Summary of VOC Emissions from Syncrude Dry Sands

Compound Summer Flux Rate (g/s/m2)

Winter Flux Rate (g/s/m2)

Baseline Annual

Emission (kg/yr)

Project AnnualEmissions

(kg/yr)

H2S 1.19E-08 2.99E-09 3756 1954 Naphthalene 0.00E+00 0.00E+00 0 0 1,2,4-Trimethylbenzene 5.95E-10 1.49E-10 187 97 1,3,5-Trimethylbenzene 0.00E+00 0.00E+00 0 0 Benzene 0.00E+00 0.00E+00 0 0 Carbon disulfide 1.94E-08 4.86E-09 6099 3174 COS 6.09E-09 1.53E-09 1919 999 Toluene 6.24E-09 1.57E-09 1968 1024 1-Methylbenzene 0.00E+00 0.00E+00 0 0 Ethylbenzene 0.00E+00 0.00E+00 0 0 Propylene 0.00E+00 0.00E+00 0 0 C9-C16 Aromatics n-butylbenzene n-propylbenzene 1-methyl-3-propyl-benzene 1-methylpropyl-benzene p-isopropyltoluene

0.00E+00 0.00E+00 0 0

C9-C16 Aliphatics (Total) decane 1,2-diethyl-3-methyl-cyclohexane 1,1-dimethyl-2-propylcyclohexane 2-cyclohexyl-3-methyl-butane hexadecane (3-methybutyl)-cyclopentane 1,1,3,5-tetramethyl-,trans-cyclohexane 1-ethyl-2,2,6-trimethylcyclohexane 2,3-dimethyl-1,3-heptadiene (e)-5-decene 2,4-diethyl-1-methyl-cyclohexane 4-methyl-1-(1-methylethyl)-cyclohexane 1,3,5-trimethyl-cyclohexane

1.83E-08 4.59E-09 5758 2996

C5-C8 Aliphatics (Total) 6.12E-09 1.54E-09 1927 1003 C17-C34 Aliphatics (Total) 1,3,5-trimethyl-2-octadecyl-cyclohexane 1,4-dimethyl-2-octadecyl-cyclohexane

0.00E+00 0.00E+00 0 0

Xylenes (Total) m,p-xylene 1,2-dimethyl-benzene

1.40E-09 3.52E-10 442 230



Table A1.20 (Rev): Summary of VOC Emissions from Syncrude SWSS Pond

Compound Summer Flux Rate (g/s/m2)

Winter Flux Rate (g/s/m2)

Baseline Annual

Emission (kg/yr)

Project Annual Emissions

(kg/yr)

H2S 4.36E-09 1.09E-09 597 898 Naphthalene 1.99E-09 5.00E-10 273 411 1,2,4-Trimethylbenzene 7.18E-09 1.80E-09 983 1478 1,3,5-Trimethylbenzene 6.24E-09 1.57E-09 854 1285 Benzene 7.97E-10 2.00E-10 109 164 Carbon disulfide 6.16E-09 1.55E-09 844 1269 COS 2.40E-08 6.02E-09 3286 4942 Toluene 3.90E-09 9.80E-10 534 804 1-Methylbenzene 0.00E+00 0.00E+00 0 0 Ethylbenzene 1.03E-09 2.57E-10 140 211 Propylene 0.00E+00 0.00E+00 0 0 C9-C16 Aromatics n-butylbenzene n-propylbenzene 1-methyl-3-propyl-benzene 1-methylpropyl-benzene p-isopropyltoluene

8.30E-08 2.08E-08 11364 17091


9.02E-08 2.26E-08 12350 18574

C5-C8 Aliphatics (Total) 3.08E-09 7.72E-10 421 633 C17-C34 Aliphatics (Total) 1,3,5-trimethyl-2-octadecyl-cyclohexane 1,4-dimethyl-2-octadecyl-cyclohexane

0.00E+00 0.00E+00 0 0


3.84E-09 9.65E-10 527 792



Table A1.21 (Rev): Summary of VOC Emissions from Syncrude SWSS Bitumen Slick

Compound Summer Flux

Rate (g/s/m2)

Winter Flux Rate

(g/s/m2)

Baseline Annual

Emission (kg/yr)

Project Annual Emissions

(kg/yr)

H2S 0.00E+00 0.00E+00 0.0 0.0 Naphthalene 0.00E+00 0.00E+00 0.0 0.0 1,2,4-Trimethylbenzene 5.64E-09 1.42E-09 5.0 7.5 1,3,5-Trimethylbenzene 1.79E-09 4.50E-10 1.6 2.4 Benzene 5.13E-10 1.29E-10 0.5 0.7 Carbon disulfide 0.00E+00 0.00E+00 0.0 0.0 COS 3.69E-08 9.27E-09 32.8 49.4 Toluene 1.54E-09 3.86E-10 1.4 2.1 1-Methylbenzene 0.00E+00 0.00E+00 0.0 0.0 Ethylbenzene 0.00E+00 0.00E+00 0.0 0.0 Propylene 8.46E-09 2.12E-09 7.5 11.3 C9-C16 Aromatics n-butylbenzene n-propylbenzene 1-methyl-3-propyl-benzene 1-methylpropyl-benzene p-isopropyltoluene

3.18E-08 7.98E-09 28.3 42.5


2.19E-07 5.50E-08 194.5 293.1

C5-C8 Aliphatics (Total) 0.00E+00 0.00E+00 0.0 0.0 C17-C34 Aliphatics (Total) 1,3,5-trimethyl-2-octadecyl-cyclohexane 1,4-dimethyl-2-octadecyl-cyclohexane

8.20E-09 2.06E-09 7.3 11.0


2.82E-09 7.08E-10 2.5 3.8



38. Supplemental Submission: Air Quality and Human Health Risk Assessments, Appendix A1, Tables A1.23 and A1.24, Page 17. Metals emissions from the SWSS are contrasted to the rest of the Syncrude facility, however only the main Syncrude stack in Table A1.24 is shown. How would the metal emission change for the Syncrude facility if a more comprehensive accounting of all other stacks and mine fleet equipment were to be included in the assessment?

Table A1.24 shows the sum of all metal emissions from all Syncrude stacks. Metal emissions from each stack was accounted for in the modelling. Total Syncrude mine fleet metal emissions from fuel combustion are similar in amount to the total stack emissions.



39. Supplemental Submission: Air Quality and Human Health Risk Assessments, Page 3-15. Syncrude states that it did not perform a cumulative assessment for trace metals and PAHs. A CEA was performed on the particulate CACs.

The response to SIR #99 states that “Sources of VOC, PAH, and metal emissions from other facilities are not available so only the existing and project case for these species will be reported.

a. What is the change from baseline for trace metals and PAH under this current revised assessment and how much does it differ from the originally reported 2% and 7%?

In the Supplemental Submission the change from baseline for trace metals is 0.3% and the change from baseline for PAHs (naphthalene) is 15%. It should be noted that the total baseline emission for naphthalene in the Supplemental Submission has decreased by almost 50%, so the absolute increase in naphthalene emissions has not substantially changed from the EIA.

b. Recent EIAs have been able to present a CEA for trace metals and selected PAHs. Why was Syncrude unable to acquire this information?

Estimates of PAH emissions vary widely between recently submitted EIAs, but EnCana Borealis appears to provide the most complete treatment. Regional naphthalene emissions are just over 56 kg/d. The baseline naphthalene emissions for the SWSS is 0.74 kg/d. Syncrude submits that the regional emissions so dwarf the project emissions that no useful information regarding project effects would be gleaned by modelling regional (CEA) emissions so this was not done. Metal emission from fuel consumption were reviewed from the Shell Jackpine EIA (Shell 2007) and the Borealis EIA (EnCana 2007) does not consider metal emissions. The Jackpine EIA provided results but not emission inventories or methodologies for estimating metal emission inventories. Syncrude is not prepared to use information without reference or understanding of the source of the information. Syncrude believes it has provided a reasonably conservative assessment of the incremental change in emissions and the health risks associated with those emissions by not including other large inventories that tend to overwhelm small sources like the SWSS project.

c. Provide the CEA on trace metals and PAHs.

See response to SIR2 ERCB-39(b) above.



Literature Cited

EnCana Corporation (EnCana). 2007. Borealis In-Situ Project. Application & Environmental Impact Assessment. Submitted to Alberta Energy and Utilities Board and Alberta Environment. December 2007.

Shell Canada Limited (Shell). 2007. Application for Approval of the Jackpine Mine Expansion Project and Pierre River Mine Project. Environmental Impact Assessment, Volume 3: Air Quality, Noise and Environmental Health. Submitted to Alberta Energy and Utilities Board and Alberta Environment. December 2007.



40. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5.1, Page 2-34. Syncrude states that with the exception of benzene, predicted RSC, VOC and PAH concentrations are below the AAAQOs where they apply. Consistent with SIR #102, how many exceedances of the AAAQO for benzene are predicted?

There were 505 1-hour exceedances predicted for Benzene in the Baseline case and 481 1-hour exceedances predicted for Benzene in the Project case.



41. Supplemental Submission: Air Quality and Human Health Risk Assessments, Appendix A1, Tables A1.19 to A1.21, Pages 13-15. These tables reflect Syncrude’s VOC emissions from the current operations (baseline) and the SWSS project.

Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5.1, Tables 2.5 & 2.8, Pages 22 & 26.

In these tables Syncrude reflects summaries of baseline and project emissions for VOCs, RSCs and PAHs.

a. Table 2.5 for example shows baseline Carbon Disulphide emissions to be 0.0186 t/d while Table A.19 in Appendix A1 shows an emissions total of approximately 15 t/d (5499 t/yr). Provide an explanation for why the t/d of compounds such as H2S and Carbon Disulphide appear to be so different between Tables 2.5, 2.8 & A.19, A.20.

Units listed in Table A.19 should be in kg/yr. Replacement tables have been provided that show corrected emissions.

b. Confirm that the correct emissions data was used in the revised assessment?

The correct emission rate was used in the modelling.



1.7 ERRATA 42. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Appendix A1, Section 4. There seem to be errors associated with stack temperatures units and labels for different units. For example Stack 8-3 appears to have a stack temperature of 75 Kelvin which is unlikely. Confirm the validity of these Tables and that the correct information was used for the updated assessment.

The temperature units in Appendix A1, Section 4.1, Tables A1.6 and A1.7 should be in Celsius. Table A1.9 is labelled as Celsius, but the numbers provided are in Kelvin, so the correct stack temperature in Celsius is 343°C. The correct temperature was used in the updated assessment.



43. Volume 3, Appendix B, Page 5, Table B1.5. Syncrude lists the primary stack emission source. This summary is different from the updated Table A1.6 in Appendix A1. Syncrude states that the 1998/1999 EIA is the source for both tables. Clarify why the emission are different for TSP, PM10, PM2.5, CO & SO2 for both the main stack and the 8-3 stack if updated information was not used for the revised assessment.

The 1998/1999 EIA was not used as the source of emission information for the modelling conducted for the Supplemental Submission. The emission information listed in Table A1.6 of the Supplemental Submission reflects the impact of the Sulphur Emission Reduction Project and are from:

• Golder Associates Ltd. 2003a. Air Quality Assessment of the Syncrude Emissions Reduction Project: Report A. Submitted to Syncrude Canada Ltd., 3 July 2003.

AENV EPEA Application No. 027-00000026 Water Act File No. 25419


S:\Project Ce\Ce03786\Volume 5\fin Vol 5-SWSS Round 2 SIRs_ce03786-sep09-tlc.doc Page AENV-1

2.0 AENV

2.1 AIR 1. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Section 2.5, Table 2.4, Page 2-20. Table 2.4 lists the baseline emissions of particulate matter and trace metals for both the Syncrude facility and background sources. Particulate matter emissions for the Syncrude stack emission sources have significantly dropped compared to those presented in the original Syncrude SWSS EIA, Air Quality Assessment, November 2008 (Volume 2, Section 4.5.3, Table 4.3, Page 4-13). However, in both reports Syncrude states it has based the emissions on the 1998/1999 EIA.

a. Clarify the decrease in particulate matter emissions from the Syncrude stacks from the current submission compared to the original air quality assessment (November, 2008).

The reference for Syncrude emissions for the Supplemental Submission should be:

Golder Associates Ltd. 2003a. Air Quality Assessment of the Syncrude Emissions Reduction Project: Report A. Submitted to Syncrude Canada Ltd., 3 July 2003.

b. Confirm that the correct particulate matter (TSP, PM10 and PM2.5) emissions were used in the updated dispersion modelling assessment. Provide updated modelling results if necessary.

The correct particulate emission rates were used in the latest CALPUFF modelling.



2. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5, Table 2.6, Page 2-23 and Table 2.9, Page 2-27. Table 2.6 lists the baseline air quality modelling results. For PM2.5 it states that it is the 98% value. Effective, Feb 1, 2007, the ambient objective in Alberta for PM2.5 as a 24-hour average is 30 µg/m³ based on the maximum predicted concentration. This is more stringent than the Canada Wide Standard which is based on the 98th percentile concentration averaged over 3 years.

a. Provide an updated Table 2.6 containing the maximum predicted 24-hr PM2.5

concentrations for comparison to the Alberta Environment Ambient Air Quality Objectives (AAAQO).

The 24-hr PM2.5 concentrations listed in Table 2.6 are the maximum values, the results were incorrectly labelled in the table.

b. Confirm that the values in Table 2.9 are the maximum predicted PM2.5 values. If not, provide an updated Table 2.9 containing the maximum predicted 24-hr PM2.5

concentrations for comparison to the AAAQO.

The 24-hr PM2.5 concentrations listed in Table 2.9 are the maximum values.



3. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5, Table 2.5, Page 2-22. Table 2.5 lists the baseline emissions of volatile organic carbons (VOCs), reduced sulphur compounds (RSCs) and polycyclic aromatic hydrocarbons (PAHs). Emissions are only listed for the Syncrude emission sources. In the original Syncrude SWSS EIA, Air Quality Assessment, November 2008, Volume 2, Section 4.5.3, Table 4.4, Page 4-14 emissions were listed for the Syncrude emission sources as well as for several background sources.

a. Provide rationale for why VOC, RSC and PAH emissions not evaluated for the baseline background sources in the updated air quality assessment?

Estimates of VOC, RSC and PAH emissions vary widely between recently submitted EIAs. Syncrude submits that the regional emissions so dwarf the project emissions that no useful information regarding project effects would be gleaned by modelling regional (CEA) emissions, so this was not done. As examples, regional naphthalene emissions are just over 56 kg/d. The baseline naphthalene emissions from the SWSS are 0.74 kg/d. Similarly, the regional total VOC emissions are 632 t/d while the baseline SWSS emissions are 0.09 t/d.

b. How would the inclusion of the background emission sources affect the maximum predicted VOC, RSC and PAH concentrations?

See response to SIR2 AENV 3(a) above.



4. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5, Table 2.11, Page 2-34. Table 2.11 presents the SWSS Conversion VOC, PAH and RSC dispersion model results. Specifically, the maximum predicted hydrogen sulphide and benzene concentrations are 3.05 µg/m3 and 291 µg/m3, respectively. The original Syncrude SWSS EIA, Air Quality Assessment, November 2008, Volume 2, Section 4.5.6, Table 4.10, Page 4-36 predicted a maximum hydrogen sulphide concentration of 2,931 µg/m3 and a benzene concentration of 1,543 µg/m3. These are significant differences in predicted concentrations, considering the emissions did not fluctuate greatly between the two assessments.

a. Provide clarification and explanation of the difference in predicted hydrogen sulphide and benzene concentrations between the updated (July, 2009) and previous (November, 2008) air assessments.

The previous modelling used the dispersion coefficients from internally calculated sigma-v and sigma-w using micrometeorological variables (MDISP =2). The updated modelling used the recommended default dispersion methodology (PG dispersion coefficients for Rural areas) MDISP =3. It was found that large area sources modelled with MDISP=2 in CALPUFF yielded unrealistically high concentrations in the nearfield, therefore the recommended default methodology (MDISP = 3) was used in the updated assessment.



5. Supplemental Submission: Air Quality and Human Health Risk Assessments, Appendix A1, Section 2.0, Page 3. Syncrude states “operational emissions were taken from the most recent Syncrude EIA” (Conor Pacific, 1999). In 2003, Syncrude submitted an approval amendment application, which contained an updated dispersion modelling assessment. In response to AENV’s SIR round 1, Volume 4, SIR 113a, Syncrude responded that 3D CALPUFF runs were being preformed using updated emissions data.

a. Provide justification for not using the most recent emissions data in the updated dispersion modelling assessment.

The reference is incorrect and the emissions shown in the 2003 report were used for Syncrude emissions as described in the response to question 1a above.

b. How would the predicted concentrations be affected using up to date emissions information?

The 2003 emission data was used for the Supplemental Submission.



6. Supplemental Submission: Air Quality and Human Health Risk Assessments, Appendix A1, Section 4.6, Table A1.24, Page A1-17. Table A1.24 summarizes the metal emissions from the existing Syncrude facility. Only one Syncrude stack is listed as a source of metal emissions. However, the original Syncrude SWSS EIA, Air Quality Assessment November 2008, Volume 3, Appendix B1, Section 4.6, Table B1.24, Page B1-17, listed metal emissions from numerous stacks and fugitive emission sources.

a. Provide justification for only modelling the metal emissions from one Syncrude stack and not including all stacks and fugitive emission sources.

Table A1.24 provides the sum of all Syncrude stacks. Individual stacks with respective emissions were used in the modelling.



2.2 TERRESTRIAL 7. SIR 38 a, Page ERCB-68 and SIR 49 b, Page ERCB-85. Syncrude indicates that

scare cannons are “very effective at discouraging waterfowl and other wildlife from entering the SWSS Settling Basin as evidenced by low mortality numbers disclosed in Syncrude’s response to Information Request No 49.”

Syncrude also states “the Syncrude investigation into the 2008 Waterfowl Incident has concluded the delays in deploying the noise cannons at the Aurora pond was the reason we failed to protect the birds; it wasn’t due to the triggering technology used.”

Syncrude does not yet have an approved waterfowl protection plan that is satisfactory to ASRD and AENV.

a. Describe the monitoring program or scientific study Syncrude is conducting to determine the effectiveness of cannons in deterring waterfowl from entering the SWSS Settling Basin.

The current Syncrude monitoring program has the following elements:

• workers in the areas of the ponds have been instructed to report waterfowl sightings to a central emergency dispatcher who mobilizes a response;

• patrols of the tailings ponds are conducted in conjunction with cannon maintenance rounds. These patrols are supplemented with additional tours to observe waterfowl activity;

• oil or injured birds are collected, and incidents are reported to Alberta Sustainable Resource Development (from whom directions on handling, care and disposition are received);

• a spring migration bird watch is conducted over April and May at several sites around the Syncrude leases; and

• a recently purchased radar system has been commissioned in order to understand how radar can be used to supplement ground monitoring and bird watch activities. Using the radar tracking system, Syncrude hopes to design studies that provide information that will lead to improved waterfowl conservation, as well as to understand the mechanisms that make continuously-fired noise cannons more effective.

b. What monitoring protocol was in place historically to ensure accurate detection of all waterfowl mortality incidents?

Past monitoring protocols have included the pond patrols and pond worker reporting activities noted above.



8. SIR 38 a, Page ERCB-68. Syncrude states “it should also be noted that scare cannons were not deployed on April 28, 2008 at the Aurora Settling Basin when 1606 waterfowl died, which vastly exceeded anything experienced by Syncrude since commencement of its operations.” ASRD understands that Syncrude experienced a similarly large mortality incident in the late 1970’s.

a. Confirm, or modify as necessary, the statement.

Syncrude reported a mortality count of 608 birds in 1979, of which 231 were waterfowl, 373 were shorebirds, and 4 were other species.



9. SIR 38 c, Page ERCB-68. Syncrude lists the major components of its new site-wide waterfowl protection program. The original SIR referred to all wildlife, and was not limited to waterfowl.

a. Describe how Syncrude will deter wildlife (including moose, coyote, deer etc.) from entering the SWSS tailings pond area.

The measures that Syncrude has in place to deter wildlife from entering the SWSS tailings pond area include components of the waterfowl protection program and limiting vegetation availability at the edge of the pond. The scare cannon component of the waterfowl protection program serves to deter waterfowl and other wildlife from the pond area. Syncrude also strives to eliminate accessible vegetation at the edge of the pond, making the area less attractive to wildlife. Syncrude does not seek to deter wildlife from the reclaimed slopes of the SWSS facility. The presence of wildlife on the reclaimed slopes is viewed as a reclamation success. As outlined in the response to SIR 38a (Volume 4, Page ERCB-68), there have been no reports of mammal mortality in the area of the SWSS facility due to contact with the tailings pond.

b. What design considerations and mitigation measures will/has Syncrude undertake(n) to minimize the risk of wildlife and birds entering the SWSS tailings pond? Provide a detailed list.

See response to AENV-9(a) above and Syncrude’s Waterfowl Protection Plan for a detailed list of mitigation measures in place to minimize the risk of wildlife and birds entering tailings pond areas.



2.3 HEALTH 10. SIR 147, Page AENV-49. Syncrude was asked to provide an updated health risk

assessment that takes in to account all contaminants in surface water that are of concern to regulators and stakeholders. In response, Syncrude states “Using the same methodology as described in the response to SIR 95 a to c, the ratios of natural, tailings and maximum process affected plume concentration is presented in Table SIR-147-AENV-1. The ratios for these parameters are low (i.e., less than 1), indicating that the natural water is not substantially different from the maximum plume concentration, therefore these parameters were not included in the modelling.” To understand the overall or total potential health effects associated with the project, the requested assessment is needed, regardless of whether contaminant concentrations change substantially.

a. Provide the required assessment.

In the human health risk assessment, the predicted surface water quality values based on the maximum groundwater plume concentrations were used in the human health risk modelling, as presented in Table 3.16 page 3-31 (Concentration of Chemical of Potential Concerns in Surface Water) in the document titled: “SOUTHWEST SAND STORAGE CONVERSION PROJECT, Supplementary Submission; Air Quality and Human Health Risk Assessments”, that was submitted to ERCB and Alberta Environment. The HQ (Hazard Quotients) and ILCRs for human health risks (Table 3.22 to 3.70) associated with surface water ingestion and dermal exposure were calculated from those predicted values. AENV had expressed concerns with respect to selenium, anthracene and benzo(a)pyrene. From the human health perspective, anthracene was taken out of the chemical of concern list because, the criteria exceeded is solely for the protection of aquatic life, not human health. Selenium has been ruled out because the criteria exceeded is based on what appears to be an outlying data point. Selenium was detected in only one sample, while all other samples had results below the detection limit. Therefore, the results with selenium were deemed unreliable for the purpose of risk assessment and so were not included in the human health assessment. Benzo(a)pyrene was ruled out because it was below the applicable criteria.



11. SIR 151, Page AENV-53 and SIR 125, Page AENV-21 and Supplemental Submission: Air Quality and Human Health Risk Assessments.

a. Clarify if the naphthenic acids mobilized during oil sands processing and found in seepage water from the tailings are expected to be chemically and toxicologically similar to those found naturally in the receiving water bodies.

In the response to SIR 125, Page AENV-21, Syncrude states “the predicted maximum baseline and application case concentrations of naphthenic acids in groundwater discharging to the MacKay River are 2.10 and 4.49 mg/L, respectively.” This is greater than the normal range of total naphthenic acid concentrations in the receiving water bodies as listed in SIR-151.

Analytical methods have been developed to measure the total NA concentrations in oil and water. However, there is no analytical method that will completely separate the individual compounds found in the complex mixture of NAs. Therefore, differentiation between naturally occurring NAs and the ones coming from the oil sands processing would be difficult. This being said, the toxicological difference between both groups of NAs is virtually impossible to distinguish in absence of a better analytical method. It should be noted that caution needs to be exercised in comparing groundwater quality with surface water concentrations. Although the concentrations of naphthenic acids in groundwater are higher than surface water concentrations, these groundwater concentrations may be similar to concentrations found in the natural seepages and discharges into the river, not due to anthropogenic sources. Surface water concentrations of naphthenic acids have accounted for the natural attenuative and dispersion processes of the groundwater.

b. Discuss the expected loading of naphthenic acids into receiving water bodies in terms of the total quantities expected (estimated loading) and in terms of their expected contribution to concentrations in these water bodies.

Refer to Table SIR2 ERCB 32-1 for the mass loading calculation of naphthenic acids (NA) into Reach 50 of the MacKay River using the NA concentrations as indicated. The total annual loads from groundwater in the base and application case are 207 kg and 420 kg, respectively. These loads are less than 0.2% of the total annual load (186,062 kg) from the MacKay River. The impact of groundwater contributions of NA to the concentrations in MacKay River is negligible.

c. Provide numerical estimates that can be readily compared to the background levels.

See response to (b) above.



d. In the absence of an established human health Toxicological Reference Value (TRV) for naphthenic acids, discuss whether or not Syncrude is doing or plans to do any work to address this data gap.

Volume 3, Appendix L1, Section 1.0, notes that the TRV's referenced in the impact assessment are obtained from regulatory agencies. Syncrude submits that derivation of additional reference values should be undertaken or managed by regulatory agencies. At present, Syncrude is not undertaking or contemplating any work to address this matter.



12. SIR 152b, Pages AENV-54 to 56 and Supplemental Submission: Air Quality and Human Health Risk Assessments. Syncrude was asked to provide a chemical screening that considers toxicity and bioaccumulation for all the chemicals for all pathways that could potentially be released from the project. Syncrude states that the screening included an assessment of “chemicals according to their toxicity.”

In the EIA report Syncrude states “according to guidance received from Alberta Health and Wellness (AHW), chemicals of greatest concern were defined as 1) chemicals viewed as a concern by the regulatory authorities, 2) chemicals perceived as a concern by the public during consultation, and 3) chemicals presently of concern in the region under study relevant to Syncrude’s Project.” The interpretation of the guidance provided by AHW is not entirely correct. A screening to prioritize chemicals for the Human Health Risk Assessment should also incorporate both toxicity and bioaccumulation information. Syncrude has only provided evidence of the latter.

a. A screening assessment for both inhalation and oral pathways of exposure is required.

The soil screening was done by comparing the concentration in the soil with Alberta Tier 1 soil quality guidelines, which is defined as the lowest soil concentration criteria for all exposure pathways including the oral pathway. Therefore, this conservative screening approach adequately addressed the oral exposure pathway, even if another exposure pathway would lead to a lower criterion than the oral route. In order to provide an objective assessment of the toxic potential, another screening process was employed that evaluated each chemical versus its inhalation toxicity. The inhalation toxicity was used as an endpoint for assessment since one of the major exposure interfaces with receptors would be the inhalation pathway. All VOCs were automatically carried forward into the assessment, so only metals were included in this screening process. The toxic potency of each noncarcinogenic chemical was determined by comparing the soil concentration with the most conservative health-based criteria (i.e., threshold toxicity limit). The health-based criteria were sourced primarily from Health Canada (2004), U.S. EPA (2007), Ontario Ministry of the Environment (1997), California EPA (2007), ATSDR (2007), RAIS (2007), RIVM (Baars et al. 2001), Texas Commission on Environmental Quality (TCEQ 2009), WHO (2000), and the Michigan Department of Environmental Quality (MDEQ 2007). In some cases, no chronic inhalation criteria were available. In such cases, the health-based criteria was extrapolated from the respective oral health based exposure limit assuming a toddler weight of 16.5 kg and an inhalation rate of 9.3 m3/d. The total toxicological potential of the site was then determined by the summation of the individual toxicological potentials.



The contribution of each individual chemical in the total toxicological potential was calculated as:

RTPn =TPn

∑i= 1

n

TPi

where: RTPn = Relative toxicological potential of ‘nth’ chemical TPn = Toxicological potential of ‘nth’ chemical ∑TPi = Total toxicological potential Chemicals that represent 95% of the total toxicological potential were then considered for inclusion in the human health risk assessment as the chemicals of potential concern (COPC). The 95% level was selected based on discussions with Alberta Health and Wellness because it represents a significant level of the potential risks to people and the environment (Bodo, pers. comm.). Table SIR2 AENV 12-1 presents the results of the screening of the noncarcinogenic chemicals using the health-based criteria.

Table SIR2 AENV 12-1: Inhalation-based Chemical Screening According to the Cumulated Toxic Potency Method

Chemical Maximum Soil Concentration

at Source Reference

Concentration Toxic Potential Weighting Cumulated Toxic Potential

mg/kg mg/m3 % Mn 470 0.00005 9400000 57.80% 57.80% Al 18900 0.005 3780000 23.24% 81.04% Ni 20 0.000018 1111111 6.83% 87.87% V 35 0.00005 700000 4.30% 92.17% Co 10 0.00002 500000 3.07% 95.25% Ba 128 0.0005 256000 1.57% 96.82% Cr 23.4 0.0001 234000 1.44% 98.26% As 6.5 0.00003 216667 1.33% 99.59% Be 1 0.00002 50000 0.31% 99.90% Cu 16 0.002235 7159 0.04% 99.94% Pb 9 0.0015 6000 0.04% 99.98% Hg 0.06 0.00003 2000 0.01% 99.99% Zn 49 0.044696 1096 0.01% 100.00% Se 0.5 0.02 25 0.00% 100.00% Sr 60 2.68 22 0.00% 100.00% Cd 0 0 0.00% 100.00% Mo 0 0 0.00% 100.00% Th 0 0 0.00% 100.00% Total 16264081 100.00% 100.00%

* Chemicals in bold and underlined are chemicals of potential concern.

Although the screening process indicates that nickel, vanadium and cobalt should be included in the assessment, the maximum soil concentrations from Table SIR2 AENV 12-1 are comparable to the background baseline soil concentrations from the sampling that was completed by AMEC for the application. Therefore, nickel, vanadium and cobalt were not included as COPCs in the assessment, as the potential human health risks associated with these three parameters would similar to the risks associated with exposures to background concentrations.



Literature Cited:

Agency of Toxic Substances and Disease Registry (ATSDR). 2007. Minimal Risk Levels (MRLs) for Hazardous Substances. Available at http://www.atsdr.cdc.gov/mrls/.

Baars, A.J., R.M.C. Theelen, P.J.C.M. Janssen, J.M. Hesse, M.E. van Apeldoorn, M.C.M. Meijerink, L. Verdam, and M.J. Zeilmaker. 2001. Re-evaluation of Human-Toxicological Maximum Permissible Risk Levels. RIVM Report No. 711701025. National Institute of Public Health and the Environment. Bilthoven, The Netherlands.

California Environmental Protection Agency (California EPA). Toxicity Criteria Database. Office of Environmental Health Hazard Assessment. Available at http://www.oehha.ca.gov/ risk/ChemicalDB/index.asp.

Health Canada. 2004. Federal Contaminated Site Risk Assessment in Canada. Park II: Health Canada Toxicological Reference Values (TRVs). Cat. H46-2/04-368E.

Michigan Department of Environmental Quality (MDEQ). 2007. Operational Memoranda for the Part 201 and Part 213 Programs. Available at http:///www.michigan.gov/deq/0,1607,7-135-3311_4109_9846_30022-101581--,00.html.

Ontario Ministry of the Environment. 1997. Guideline for Use at Contaminated Sites in Ontario. Available at http://www.ene.gov.on.ca/envision/land/decomm/index.htm.

Risk Assessment Information System (RAIS). 2007. Oak Ridge National Laboratory Risk Assessment Information System. Available at http://risk.lsd.ornl.gov.

Texas Commission on Environmental Quality (TCEQ). 2009. Risk Reduction Program Protective Concentration Levels. March 2009 table.

U.S. EPA (EPA). 2007. Integrated Risk Information System (IRIS). Available at http://www.epa. gov/iris.

World Health Organization (WHO). 2000. Air Quality Guidelines for Europe – 2nd Edition. WHO Regional Publications, European Series, No. 91. Available at http://www.euro.who.int/ document/e71922.pdf.

Personal Communication

Bodo K. Environmental Health Specialist, Environmental Assessment and Operations, Health Surveillance, Population Health Division. Alberta Health and Wellness. Personal communication, October 29, 2994.



13. SIR 160b, Page AENV-78 and Supplemental Submission: Air Quality and Human Health Risk Assessments. Syncrude responded to the question that background concentrations were included in the Incremental Lifetime Cancer Risk (ILCR). Background concentrations should not be included in the calculation of ILCRs. ILCRs are described as incremental lifetime cancer risks above background according to Health Canada.

a. Recalculate all ILCRs without background included.

It was Syncrude’s initial understanding that SIR 160b was focused on assessing the baseline values as background, and therefore, the ILCRs were calculated accordingly for the project. However, this clarification of the original SIR has indicated that the “background values” refers to background exposures associated with exposures aside from the Project (i.e., food, water, soil, air, and consumer products). These background exposures were not considered in the assessment.



14. SIR 156a, Page AENV-66.

a. Confirm that maximum concentrations for all media were used in the updated Human Health Risk Assessment (HHRA)?

Maximum concentrations for soil, vegetation (i.e., Labrador tea, willow and berries), groundwater and surface water quality were used, if available, otherwise estimated concentrations were obtained from modelled approaches.



15. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.3.1, Page 2-6. Syncrude states “non-Syncrude fence line receptor grid points within approximately 100 m of non-point sources were removed because preliminary modelling showed excessively high results at receptors near to these sources.”

a. Provide further discussion of the rationale for the removal of these receptor grid points.

A warning against placing receptors within 100 m from sources is found in page 1-15 of U.S. EPA 1995. User's Guide for the Industrial Source Complex (ISC3) Dispersion Models: Volume II - Description of Model Algorithms. EPA-454/B-95-003b (http://www.epa.gov/scram001/ userg/regmod/isc3v2.pdf). Office of Air Quality Planning and Standards, Emissions, Monitoring, and Analysis Division, Research Triangle Park, North Carolina 27711. The reason is that the empirical dispersion coefficients used in Gaussian models (including CALPUFF) are not reliable at these distances. Although models do allow calculations to be made at receptors as close as 1 m to a source, "the area source algorithm will not provide reliable results for receptors located within or adjacent to very small areas" (p. 1-51). Since a large area source is treated as the sum (through Romberg integration) of many small sources, sections of the area sources close to a receptor will cause unrealistic concentrations to appear at the receptor. A value of 100 m is generally applied as the minimum source-receptor distance to use in the case of very large area sources.



16. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.0, Page 3-1. Syncrude states “responses to these and other SIRs necessitated revision to the human health risk assessment as data from other disciplines were updated.” Acute inhalation exposures were not updated.

a. Provide an explanation as to why acute inhalation exposures were not updated. If there were changes in acute modelled concentrations update the HHRA accordingly.

PM2.5, PM10 and TSP acute concentrations were provided in the initial Application. These parameters were updated in the Supplemental Submission: Air Quality and Human Health Risk Assessments, as shown in Table 3.19, page 3-37 of that document.



17. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.2.3, Page 3-9. On page 18-20, Volume 2 of the EIA Syncrude states “on-site receptors were considered to be the Syncrude workers in this assessment. The evaluation of the risks to the workers will be assumed to be at the Fenceline location since the air modelling restrictions do not allow for prediction of ambient air concentrations within the source area.”

a. Confirm the above-statement applies to the updated HHRA. If not, provide an explanation.

Syncrude confirms that the risks to worker exposures were assessed at the Fenceline location.



18. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.4.5, Page 3-22. Syncrude states “using predicted soil concentrations in Table 3.10.” In the EIA Syncrude indicates that they have taken soil samples for the HHRA.

a. Provide an explanation as to why predicted soil concentrations were used when measured samples were collected.

Some chemicals that were screened in the assessment were not analyzed in the soil or vegetation sampling and analysis program. This was because of the need to initiate and complete the field programs before the chemical screening was completed. By the time the COPCs had been finalized, the laboratory’s holding times were exceeded and there cannot be any reliance on the results of any additional analyses. Therefore, the soil or plant tissue concentration for these chemicals, had to be modelled (predicted), from the air concentration and/or deposition onto soil and plants.



19. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.1, Page 3-36. Syncrude states “another component of this risk characterization is a discussion about the uncertainties in the process, which is described in Section 1.8.” The revised HHRA does not include a Section 1.8.

a. Provide Section 1.8.

The aforementioned Section 1.8 listed on page 3-36 is a typographical error. The correct text should read “Section 3.6.”



20. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.2.2, Page 3-44. Syncrude states “exposures to arsenic for the off-site receptor resulted in a total hazard quotient (HQ) value of 43.4 for the Baseline scenario and 86.3 for the Project scenario (Table 3.26).”

a. Provide scientific evidence that indicates the potential human health effects that may be observed given this increased level of exposure to arsenic.

Syncrude re-evaluated the results of the arsenic assessment and determined that the HQ and ILCR values were a function of an overly conservative assessment. Syncrude used toxicological reference values from California EPA based on Alberta Health and Wellness’ recommendation that the most conservative TRVs be used. However, in Alberta Health and Wellness’ report titled “Assessment of the Potential Lifetime Cancer Risks Associated with Exposure to Inorganic Arsenic among Indigenous People Living in the Wood Buffalo Region of Alberta,” the TRVs used in that assessment are significantly higher than the values that AHW requested be applied for the application. The California EPA’s oral reference dose of 0.0035 µg/kg/day was applied in the SIR responses rather than the US EPA’s oral reference dose of 0.3 µg/kg/day used in the original application. This exaggerated the risks 100-fold in the SIR responses compared to the application. Although utilized in the SIR response, Syncrude does not consider the California EPA TRVs as acceptable because the toxicological studies that supported their respective TRVs were deemed not credible and/or reasonable, as it takes into account a lowest observable adverse effect level (LOAEL) based on a reduction of one point in IQ (Intelligence Quotient) among children exposed to arsenic. This endpoint is considered extremely conservative and too imprecise (i.e., subject to confounding factors) to be used in the derivation of a TRV. These TRVs may be overly conservative and therefore exaggerate the likelihood of health effects. On the other hand, the US EPA RfD, is based on a more conventional population study (Tseng 1977), with a bigger pool of individuals, and a control group. The data reported in Tseng (1977) show an increased incidence of blackfoot disease that increases with age and dose. Blackfoot disease is a significant adverse effect.

Literature Cited

TSENG. 1977.Effects and dose-response relationships of skin cancer and blackfoot disease with arsenic. Environ. Health Perspect. 19: 109-119.



21. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.2.2, Page 3-45. With respect to increases in the ILCR associated with arsenic exposure, Syncrude states “the contribution of arsenic from the Project to the Baseline is marginal and therefore, the risks remain the same between the Baseline and the Project.” The highest ILCR in the Project scenario id 2.9 x 10-3, while in the Baseline scenario it is 7.0 x 10-4. This difference is near an order of magnitude.

a. Explain how this difference is considered marginal.

The difference in ILCR associated with arsenic exposure in both Project and Baseline scenarios is significant and the inclusion of the word “marginal” is a typographical error. The statement should be read: “…the contribution of arsenic from the project to the baseline is significant. However, the project contribution is solely based on a very conservative fish bioaccumulation model that does not take into account the speciation of arsenic. The organic forms of arsenic are much less toxic than the inorganic forms, but the model used in the assessment does not differentiate between the two of them. Therefore, the model may produce an overly conservative risk value”.

b. Comment on the potential health risks that may be experienced in the Project scenario, using available scientific evidence.

As mentioned in the toxicological profiles, some potential health risks include acute effects like nausea, vomiting, shortness of breath and haemolytic reactions. It should be noted that laboratory animals are generally less sensitive than humans to the toxic effects of inorganic arsenic. In addition, the critical effects appear to be immunosuppression and hepato-renal dysfunction in rodents whereas in humans, the skin, vascular system, and peripheral nervous system are the primary target organs (Amdur et al., 1991). For chronic exposure to arsenic in drinking water, skin lesions are common and there are many documented cases of skin cancer related to the consumption of arsenic in the drinking water (Amdur et al., 1991). Sensory loss of the peripheral nervous system is one the most common effects of acute exposure to arsenic. Liver injury is more characteristic of chronic exposure which manifests as jaundice and may progress to cirrhosis and liver cancer. However, Syncrude cannot confirm that these possible effects to arsenic exposure are likely to occur for human receptors at the indicated exposure levels. Also, as previously mentioned in part a. above, California EPA’s TRV used in the SIR may be overly conservative. Literature Cited Amdur M.O., J. Doull and C.D. Klaasen (eds). 1991. Casarett and Doull’s Toxicology – The Basic Science of Poisons (4th Edition). Pergamon Press, New York, NY.



22. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.2.3, Page 3-45 and Table 3.29, Page 3-52. Syncrude states the HQ for noncarcinogenic risk is greater than 1.0 for the on-site worker, however Table 3.29 indicates the total HQ to be 0.16.

a. Explain this discrepancy.

This is a typographical error, the correct value is 0.16, and therefore the text should be modified accordingly.



23. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.3.1, Page 3-90. Syncrude states “exposures to manganese in the various media results in total HQ estimates of 3.4 for the toddler receptor in the Baseline scenario and 4.0 in the Project scenario, respectively at all receptor locations” (Table 3.56).

a. Based on the toxicological endpoints associated with exposure, and the available Reference Dose (RfD) and No Observable Adverse Effect Level (NOAEL) values provided in Appendix B1, comment on whether any of the potential health effects associated with exposure to manganese will be seen in the study area.

The total HQ in Table 3.56 were 2.3 in the baseline scenario and 2.8 in the in the project scenario (not 3.4 and 4.0 as mentioned above). These HQ values are also 4 times higher than in the initial assessment (0.61 for the baseline and 0.64 for the project scenario). The TRV used in the SIR compared to the TRV used in the initial assessment is 4 times lower and resulted in a greater total HQ value. Alberta Health and Wellness requested a more conservative value to be used in the SIR for the SWSS project. Therefore, a lower oral and dermal TDI value of 0.047 mg/kg-day provided by Michigan Department of Environmental Quality (MDEQ) was used for manganese in the SIR instead of the less conservative oral TDI value of 0.14 mg/kg-day, which was provided by U.S. EPA and used in the original report. The oral TDI value provided by MDEQ was not considered in the original report because there were no toxicological studies that supported the MDEQ oral TDI value. The TRVs listed by MDEQ may be overly conservative but there is no criteria document to review to determine the basis of the TRV derivation. Syncrude is overestimating the health risk by using a lower TRV at the request of Alberta Health and Wellness.



24. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.3.3, Page 3-96. For both the on-site worker and off-site receptors, HQ estimates exceed 1.0 (6.3 for workers and up to 24 for off-site receptors). The only comment provided is that the values are not different from Baseline to Project scenario.

a. Discuss the possibility that these levels of exposure will lead to the toxicological effects associated with naphthalene exposure (e.g., hemolytic anemia, liver, neurologic or ophthalmologic effects)?

The value for the off-site receptor is 4.4, not 24. The air inhalation and fish concentrations used in the SIR were higher when compared to the initial report which led to high total HQ values. The air inhalation for worker receptor was 6.3 (0.13 in the initial report). The fish concentrations for the off-site receptor were in the range of 2.97 and 3.21 (0.012 to 6.8 x 10-5 in the initial report). The large discrepancy between the original report and the SIR is due to higher naphthalene concentrations and overly conservative fish modelling data which was used in the SIR. Acute exposures to naphthalene by inhalation, ingestion, and dermal contact are associated with hemolytic anemia, damage to the liver, and neurological damage. Occupational epidemiological investigations have also reported the development of cataracts for workers that acutely inhaled or ingested naphthalene. Chronic exposures to naphthalene have also been reported to cause cataracts and damage to the retina of workers and rodents (ATSDR 2007). However, Syncrude cannot confirm that these possible effects to naphthalene exposure are likely to occur for human receptors at the indicated exposure levels.

Literature Cited:

Agency of Toxic Substances and Disease Registry (ATSDR). 2007. Minimal Risk Levels (MRLs) for Hazardous Substances. Available at http://www.atsdr.cdc.gov/mrls/.



25. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.6, Page 3-119. Syncrude states “therefore, in the assessment, a value equivalent to half the detection limit was used. This contributed to the elevated HQ value, but is a gross over-estimate of the risk since it was essentially non-detected.” This is an in correct statement. Even if a chemical is non-detect it does not mean that it is essentially zero. The chemical may be present just below the detection limit, at half the detection limit (as Syncrude assumed) or less than half the detection limit.

a. Did Syncrude consider modelling those substances that were non-detect to better understand a chemical concentration below the detection limit? If not, provide an explanation.

This is a misunderstanding on how the values were included in the modelling. The values that were not detected were effectively included in the modelling as half the detection limit. However, there is an uncertainty associated with these values, as Syncrude attempted to explain in the statement reported above. U.S. EPA specifically notes that parameters for which all data are below detection limits should not be carried forward as COCs in a quantitative assessment. Where some data are below detection limits but some are not, it is recommended to consider the positively detected results with the non-detected results in a site-specific manner; i.e., if the parameter was detected in some samples at the site and concentrations were below the guideline, then samples with elevated detection limits may be assumed to have concentrations below the guideline as well. However, throughout the guidance document, the U.S. EPA notes the following overriding principle: use of data within the risk assessment is at the discretion of the risk assessor. U.S. EPA acknowledges that professional judgment should be employed in the identification of COCs, especially with respect to identifying those parameters likely to be present, given the known past activities at the site, fate and transport of that chemical or similar chemicals, concentrations of that parameter in other media, and levels of naturally occurring (e.g., metals) or ubiquitous chemicals (e.g., persistent organic pollutants). The U.S. EPA specifically notes that parameters should not be identified as COCs in the absence of any data suggesting that parameter is present at the site. For parameters where all samples were below detection limits and detection limits in all samples exceeded the guideline, Syncrude's preference would be to apply professional judgment in determining whether it is likely that parameter is present in that medium.



26. Supplemental Submission: Air Quality and Human Health Risk Assessments, Appendix A3, Pages A3-41. Some of the predicted concentrations (i.e., for C17-C34 aliphatics) show that the project will act to decrease the concentrations of some chemicals of concern in certain locations.

a. Provide rationale as to why this would occur.

The positive or negative change between baseline and project cases for certain VOCs is a result of the changes in the source physical parameters and relative strength of VOC emissions from the three sources (dry sands, pond & bitumen slick). The dry sands and pond sources also have different elevations (400 vs 395 masl). All three sources change area and centroid between baseline and project cases and in all cases where we see variable directionality of change the relative proportion of a given substance between the three sources changes from baseline to project. For substances that are only emitted from one source, like carbon disulphide or 1,3,5 trimethyl benzene, the same directional change in concentration is seen at all locations. However, for substances where emissions are relatively evenly split between sources, like xylene, we see both positive and negative relative changes. This is a result of the multiple changes in source parameters, size, centroid of emissions and elevation and changes in fraction of the VOC emitted by each source.



2.4 APPROVALS The responses to questions in this Approvals section will not be considered as part of the EIA completeness decision made by Alberta Environment. 27. SIR 136 b, Page AENV-36. The original SIR requested a reclamation plan to

address the Cell 32 erosion gulley. Syncrude did not provide it in their response. Syncrude indicates the Cell 32 gulley will be repaired prior to raising the pond elevation above 385 masl at the SWSS.

a. Indicate the approximate timing of the development of the reclamation plan and the subsequent raising of the pond elevation.

A design has been developed for the repair of the large gulley located in Cell 32. Repair of the Cell 32 gulley is required prior to the SWSS pond level being raised above the currently approved 385 masl. Timing of the pond rise above the 385 masl elevation is dependent upon approval of the SWSS Conversion Project application. The design drawing for the Cell 32 gulley repair is provided in Appendix C. As illustrated, the design to remediate the Cell 32 gulley involves the installation of a filter drain along the length of the gulley as well as perpendicular to the slope at the top of the gulley over a distance of 400 metres, to ensure adequate drainage of the bench in order to capture sub-surface seepage and to minimize the potential for future gulley formation in the area. Once the filter drain installation is completed per design, the gulley will be backfilled with compacted tailings sand. The backfill sand will be placed in a manner to form a shallow channel along the alignment of the existing gulley. The channel will be armoured using a form of riprap equivalent (such as Geo-Cell and gravel) underlain by a geotextile to protect against erosion and to ensure adequate drainage of the benches. Execution of the gulley remediation scope as designed in Cell 32 is currently scheduled to take place in September-October 2009.

b. Clarify how the reclamation plan will be communicated to AENV and through which forum: a letter, the 2010 soil salvage and placement plans due this fall, the annual report due in April 2010, or through the 2011 Mine Reclamation Plan update?

The response to this information request constitutes communication of the remediation plan specific to the Cell 32 gulley. A description of the repairs completed will also be included in the 2010 Annual Reclamation Report to AENV.



2.5 ERRATA 28. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Section 3.4.3, Table 3.4, Page 3-17.

a. Table 3.4 lists AAAQO for PM10 as 400, 200 and 60 µg/m3 for the 1-hr, 24-hr and annual averaging periods, respectively. These numbers are incorrect as AENV does not currently have an AAAQO for PM10.

Acknowledged.

Appendix A

Supplemental Information Request from the Energy Conservation Board – 30 July 2009

July 30, 2009 Mr. Fred Payne Regulatory and External Affairs Syncrude Canada Ltd. P.O. Bag 4009, M.D. 3800 Fort McMurray, AB T9H 3L1 Dear Sir: SUPPLEMENTAL INFORMATION REQUEST-ROUND 2 SYNCRUDE CANADA LTD. SOUTHWEST SAND STORAGE CONVERSION PROJECT ERCB Application No. 1595820 AENV EPEA Application No. 027-00000026 Water Act File No. 25419 The Provincial government regulatory agencies have completed their review of the supplemental information received for the above noted applications. The attached questions detail additional supplemental information that is required to continue our review. If you have any questions concerning the above please contact the undersigned at (780)- 743-7482. Yours truly, Original Signed by Dennis Vroom Dennis Vroom Syncrude Southwest Sand Storage Application Coordinator Fort McMurray Regional Office Enclosure Cc: Terry Abel, ERCB

Corinne Kristensen, AENV

Supplemental Information Request – July 30, 2009

SYNCRUDE CANADA LTD. SOUTHWEST SAND STORAGE CONVERSION PROJECT

SUPPLEMENTAL INFORMATION REQUEST

ERCB Application No. 1595820 AENV EPEA Application No. 027-00000026

Water Act File No. 25419

July 30, 2009

TABLE OF CONTENTS

1.0 ERCB .................................................................................................................. 1-1

1.1 Processing...................................................................................................... 1-1 1.2 Tailings Management ................................................................................... 1-2 1.3 Terrestrial........................................................................................................ 1-4 1.4 Hydrogeology ................................................................................................. 1-5 1.5 Aquatics .......................................................................................................... 1-8 1.6 Air................................................................................................................... 1-10 1.7 Errata............................................................................................................. 1-11

2.0 AENV ................................................................................................................ 2-13

2.1 Air................................................................................................................... 2-13 2.2 Terrestrial...................................................................................................... 2-15 2.3 Health ............................................................................................................ 2-16 2.4 Approvals...................................................................................................... 2-20 2.5 Errata............................................................................................................. 2-20

3.0 ACRONYMS.................................................................................................... 3-21

1-1

1.0 ERCB 1.1 Processing 1. Volume 4, SIR 12a, Page ERCB-18. Syncrude states: “Opportunities under

consideration will be further developed and prioritized. Budgets and schedules will be developed to support the selected continuous improvement opportunities.”

a. Provide the basis for prioritization of the opportunities.

b. What are the timelines for selection, development and implementation of options?

c. What resources are being allocated to selection and development of options?

d. What work has been done since the CT Works project in 2005 to advance CT process and performance improvements?

2. Volume 4, SIR 13, Page ERCB-20. While referring to centrifuge plants,

Syncrude states: “An overall utilization factor of 80% was applied to the process to account for plant maintenance and other factors affecting plant availability.”

a. How did Syncrude determine the overall utilization factor of 80%?

b. List the other factors that may affect process availability.

c. Under what scenarios may the service factor be less than 80%? List, explain and provide contingencies in each case.

d. At what utilization factor will the technology no longer be economically feasible?

3. Volume 4, SIR 14, Page ERCB-21. Based on the preliminary results from the 2008 centrifuge field pilot (Volume 1 Table 4.4-4) provide the following information:

a. The impact on air quality parameters due to the release of VOCs and other compounds as a result of the MFT Centrifuging process.

b. The techniques that were assessed for transporting the centrifuged material and which technique has been adopted.

c. The cake deposition thicknesses that were assessed, which thicknesses were deemed acceptable, and which thickness has been adopted.

4. Volume 4, SIR 19a, Page ERCB-33. Syncrude States: “Similarly, if the application is not approved until 2010, Syncrude would rely on the interim measures noted in Section 3.1.3 and summarized above. Preparatory activities for the stockpiling scenario noted in Section 3.1.3 would also be contemplated at this time.” Further to the ore stockpiling and the other scenarios mentioned in this answer, what process improvements has Syncrude considered/evaluated to reduce the production of fluids fine tails. Explain.

5. Volume 4, SIR 35, Page ERCB-62, Table 6.3-1 (Rev 1). From the table:

ERCB text: The criterion establishes a minimum mass of dry fines in the oil sands feed expressed as a percentage of total fines in feed that must report to the DDAs. Syncrude states: “The plan proposed by Syncrude in this application meets the fines consumption target on a long term cumulative basis.” ERCB text: The phase-in sequence will be as follows: 20 per cent from July 1, 2010, to June 30, 2011. 30 per cent from July 1, 2011, to June 30, 2012. 50 per cent from July 1, 2012, to June 30, 2013, and annually thereafter. Syncrude states: “The proposed plan shows total fines to CT as 9% from July 1, 2010 to June 30, 2011. The proposed plan shows total fines to CT as 12% from July 1, 2011 to June 30, 2012. The proposed plan shows total fines to CT as 14% from July 1, 2012 to June 30, 2013. The proposed plan shows fines to DDAs increasing to 57% in 2015 with commercial implementation of MFT Centrifuging technology.” Volume 4, Question 19a, Page ERCB-33. Syncrude states, “…a delay in approval has…detrimental impacts on Syncrude’s ability to comply with Directive 074...”

a. Provide an estimate on schedules for fines captures based on legacy fluid fine tailings and future tailings production separately.

b. What is the volume of fines accumulation in years 2010 to 2015 (by year) that will not be captured as required by Directive 074?

c. Provide additional justification to support Syncrude’s proposed plan that does not meet Directive 074 requirements prior to 2015.

d. What would be the consequences of imposing approval conditions that would hold Syncrude to the implementation of MFT Centrifuging or alternate technology by the dates as specified in Directive 074?

1.2 Tailings Management 6. Volume 4, SIR 9, Page ERCB-12. Syncrude refers to the “2004 Lease

Development Plan” and mentions that “…the 2004 Plan included thickened tailings deposit from in-line flocculation of the cycloneoverflow by-product from the CT Plant. This technology was not implemented at the Mildred Lake site. The SWSS Plan includes a commitment to implement MFT Centrifuging technology.”

a. Considering the “…thickened tailings deposit from in-line flocculation of the cycloneoverflow by-product from the CT Plant…” technology that was not implemented as per the 2004 Lease Development Plan, what certainty does Syncrude have in the implementation of MFT Centrifuging technology? Explain.

b. What is required to accelerate the implementation of commercial demonstration of MFT Centrifuging technology?

c. What is the plan and schedule to manage unresolved “outstanding technology risks” of MFT Centrifuging technology?

7. Volume 4, SIR 29a, Page ERCB -25, Table SIR-16-ERCB-1. Syncrude

states,”…the current design of the BML is based on an import of 20 Mm3 of Athabasca River or Beaver Creek Reservoir water to establish the water cap…This improvement in design reduces the amount of water transferred to the recycle water pond and other fluid containing structures by a factor of one-third (relative to the initial projections of 30 Mm3).”

a. Provide the corresponding time reference regarding the containment assumptions to reflect when these containment volumes will be required.

b. Clarify the 45.8Mm3 column for “2007 Sand / CT deposit volume”, column (B).

c. Column (E), what is the reason for the volume increases to 60.0 Mm3 and 90.0 Mm3 for the last two entries of the column?

d. Column (E), explain why 30.0 Mm3 Fresh Water Cap for BML/EPL does not require containment for column (F)?

e. Explain the apparent conflict of the 30.0Mm3 Fresh Water Cap for BML/EPL column (E) with the response to SIR Question 29a. Explain how this “improvement in design” can reduce the containment requirement for SWSS.

8. Volume 1, Section 3.6.1.6, Page 3-51. Syncrude states, “Tailings deposition in

the NMSP is planned to begin in 2013.” Volume 4, SIR 18c, Page ERCB-32. Syncrude states, “…the North Mine South Pond opening up for tailings storage in 2014…”

a. Explain the discrepancy between these two statements.

b. What is the contingency plan if the North Mine South Pond is not ready for storage when required?

c. What are the factors that limit the accelerated ore/overburden removal to allow earlier tailings deposition into the North Mine South Pond (west), and

therefore result in less reliance on the SWSS for fluid tailings containment? Explain and provide details.

9. Volume 4, SIR 23d, Page ERCB-38, Table SIR-23-ERCB-1. Syncrude

references “Smart Sand” in this table. Provide definition of and uses for “Smart Sand”.

10. Volume 4, SIR 31c, Page ERCB-49 and Table 4.4.3 (Rev 1), Page ERCB-50.

Syncrude states, “This update has been prepared using the unit cost information provided in Table 4.3.2. {of the application}.” What other factors were considered when calculating the costs for the years 2012 to 2014? (1.5Mm3 x $2.10 per m3 = $3.2M and 1.5Mm3 x $2.75 per m3 = $4.1M).

1.3 Terrestrial 11. Volume 4, SIR 40, Page ERCB-73. Regarding the in-flow and out-flow rates for

BML, Syncrude states “This optimum balance is being determined via predictive modeling as well as interpretation of the body of research on water capped MFT.”

a. Provide a list of the research presently being conducted to determine the final details of water inflow and outflow requirements to sustain Base Mine Lake.

b. Provide a list of planned research in order to determine the final details of water inflow and outflow requirements to sustain Base Mine Lake. Include dates when this research is planned.

12. Volume 4, SIR 41a, Page ERCB-74. Syncrude states “Preliminary sand cap

design for watershed management remains as per the 2006 C&R Plan submitted for the Application for renewal of Syncrude’s approvals under the Alberta Environmental Protection and Enhancement Act (March 2006 )”

a. Provide the proposed sand cap design for SWSS watershed management.

b. Discuss the details of research being conducted on the topic of sand cap designs. Include the depth and shape of the sand cap as well as the depth of the saline water table.

c. Discuss when the watershed management design will be completed.

13. Volume 4, SIR 42a, Page ERCB-75. Syncrude states “Laboratory and test pond data indicate that: MFT may mitigate some toxicity associated with OSPW.” Syncrude also states that “Sub-lethal chronic effects on fish will decline with time.”

a. Elaborate on the statement that MFT may mitigate some toxicity associated with OSPW. Provide the associated research and discuss the findings.

b. What levels of chemistry associated with Oil Sand Process Affected water cause chronic effects in fish over time? The concentrations of concern are those that would prevent locally native fish species from being as healthy as those of natural lakes in the region.

c. Discuss the required period of time to observe a reduction in the sub-lethal chronic effects on fish and for the fish population to be as healthy as those of the natural lakes of the region.

d. Discuss if fish living in water-capped tailings lakes would have flesh that would have a taste or odor that varies from those that are found in the natural lakes of the region.

14. Volume 4, SIR 51, Page ERCB-87. Syncrude states “The concept of sand

capped soft tailings and the tipped in bench design of the SWSS address groundwater salinity by providing an initial condition buffer of 2m from top of saline water table to closure predicted root zone?

a. What period of time is required to establish the 2 m buffer from the top of the saline water table to the closure predicted root zone?

b. What percentage of the slope area with the inward tipped benches will have the 2 m buffer from top of saline water table to closure predicted root zone?

c. Discuss the erosion gullies and sustainability of inward tipped benches found on the SWSS to establish vegetated waterways.

d. Discuss the apparent contradiction with SIR Response 50a, which states that salinity (TDS) of existing SWSS slopes varies from 1800 – 3400 mg/l.

15. Volume 4, SIR 54b, Page ERCB-90. Syncrude states “A copy of “Oil Sands

Mine Closure Drainage Design Parameters, Syncrude Canada, 2005” has been sent to AENV and the ERCB under separate cover…”. Provide all available peer reviews that were conducted by the Science and Government communities.

16. Volume 4, SIR 54b, Page ERCB-90. Syncrude states “ Syncrude strives to

maximize the planting of berry producing and other traditional use species on reclaimed land as they are available” Clarify Syncrude’s commitment to planting berry producing and other traditional use species on lands they reclaim. Will Syncrude create boreal forests with conditions favorable to these traditional use species or will they create alternative ecosystems that will focus on enhancing the establishment and productivity of these species?

1.4 Hydrogeology 17. Volume 4, SIR 60a, ERCB Page-98. Syncrude states that “The statement refers

to seepage of water through the constructed sand dyke.”

a. How does Syncrude model and/or monitor vertical seepage from the SWSS into the groundwater system?

b. What is the estimated volume of vertical seepage through the pond floor once it is at full capacity?

c. What infiltration rate is used to make this estimation?

d. What mitigation measures would Syncrude implement should vertical seepage be detected?

18. Volume 4, SIR 64a, ERCB Page-103. Syncrude states that “The dewatered groundwater is discharged into the North Mine dirty water ditch and reports to the Recycle Pond.”

a. Provide an estimate on the quantity of annual dewatered groundwater and the Recycle Pond capacity.

b. What are the contingency measures for containment of dewatered groundwater , in the event that the Recycle Pond is full?

19. Volume 4, SIR 64b, ERCB Page-103. Syncrude states that “Although the G-Pit

channel dewatering was not included in the current EIA model, several scenarios integrating the G-Pit channel dewatering were run during the EIA study to test the sensitivity of the model to dewatering.” Explain the above mentioned G-Pit channel dewatering scenarios (include changing hydraulic parameters, stresses, boundaries, etc.)

20. Volume 4, SIR 64c, ERCB Page-103. Syncrude states that “The flow model was

calibrated based on the 28 wells in the vicinity of the SWSS facility representing the local flow regime.” Provide cross sections of the monitoring wells illustrating their numbers, locations relative to SWSS, penetration depth, aquifer name, and measured water level.

21. Volume 4, SIR 65, ERCB Page-105. Syncrude states that “There is limited

information documenting this activity.” Syncrude also states that “the results of Golder’s sensitivity modeling indicated that there should have been solute breakthrough at monitoring wells OW91-06 and OW96-02” and “The borrow area could not be realistically represented in the model, given the limited information available.” Discuss in detail Syncrude’s preventative measures to tackle process affected water vertical seepage in south limb portion of G-Pit in highlight of the high hydraulic conductivity.

22. Volume 4, SIR 67, ERCB Page-108. Syncrude states that “Chlorides

concentrations are considered the most conservative indicator for process-affected plume development.” According to the provided diagrams, the chloride concentration in OW91-11, OW91-12, OW91-13, OW92-01A, OW92-02A,

OW92-02A, OW94-09, OW96-01, OW98-14/OW91-17, OW98-15/OW91-01A, OW99-29, OW99-30, OW99-31, and OW03-23 are between 0-10ppm (15 out of 17 wells). Accordingly, provide the chemical water balance for the anions and cations for these wells.

23. Volume 4, SIR 70a, ERCB Page-131. Syncrude states that “It was not

considered necessary, relevant or practical to prepare a baseline case that dates back to equilibrium conditions. It was necessary to establish a moment in time at which to represent baseline conditions for ease of comparison to the Project conditions. 2006 was selected as the baseline year because it provided the most recent dataset.”

a. If the initial head was launched from a non-equilibrium condition (2006), then explain how the groundwater flow steady-state calibration was achieved?

b. What were the stresses that were incorporated and simulated in the initial model run?

24. Volume 4, SIR 71, ERCB Page-132. Syncrude states that “A series of modeling

scenarios have been run and the results indicated that migration of the process-affected fluid is not sensitive to dewatering.” What were the assumptions in these modeling scenarios and how were they simulated?

25. Volume 4, SIR 73, ERCB Page-135, Table 6.5. Syncrude states that “The model

domain and lateral grid are unchanged. Table 6.5 (Rev 1) presents the updated layers and surfaces.”

a. Why was the basal aquifer not considered in the model?

b. How were the hydraulic heterogeneity of aquifers in various formations incorporated into the conceptual model?

26. Volume 4, SIR 76a, ERCB Page-161. Syncrude states that “Chloride is an

example of an ion that would be transported primarily by mass transport, because it is very soluble, does not readily degrade, and is not readily retarded by interaction with soil particles (i.e., adsorbed).”

a. After decommissioning and closure will the aquifer continue to release contaminants that were accumulated during the operation life of the pond?

b. If so, how was this long term behavior of accumulated contaminants in the aquifers considered in this approach

27. Volume 4, SIR 76b, ERCB Page-161. Syncrude states that “The model was not

calibrated to any observed groundwater parameter concentrations; therefore there is no sensitivity analysis available. The uncertainties in modeling were address [sic] using the mass transport approach for all constituents of

groundwater.” Describe the level of confidence in the model results given that no sensitivity analysis was available?

28. Volume 4, SIR 84, ERCB Page-176b. Syncrude states that “An incident-specific

response plan will be developed as required in the event that a problem is identified through field observations.”

a. Discuss any simulation of mitigation scenarios taking into consideration the vertical and horizontal flow of groundwater flow.

b. Given the complex nature of the groundwater flow system and the time needed to commission a response plan, how will Syncrude ensure that an incident-specific response plan, developed after detection, will fully mitigate the effects of contamination?

29. Volume 4, SIR 91b, ERCB Page-186. Table SIR-91-ERCB-1: 2012-2013

Water. Explain why seepage/infiltration was not accounted for? 30. Volume 4, SIR 93, ERCB Page-189b. Syncrude states that “Response time for a

slurry wall is one to three years, as some investigation and design work is involved.” Outline and discuss the mitigation measures that would be undertaken after contamination was discovered and before the slurry wall was constructed. Provide a schedule.

31. Volume 4, SIR 93, ERCB Page-199a. Syncrude states that “a comparison

between the concentrations in the process-affected plume and natural waters was conducted.” How would this methodology (ratio formula) account for the accumulated concentrations in the aquifer rock matrix during the operational life of the project?

1.5 Aquatics 32. Volume 4, SIR 125a, Page AENV-21. Syncrude states “the predicted maximum

baseline and application case concentrations of naphthenic acids in groundwater discharging into the MacKay River are 2.10 and 4.49 mg/L, respectively.” As per RAMP 2008 Technical Report the concentration of Naphthenic Acids [NA] in the MacKay River is <1 mg/L.

a. Elaborate on the impacts on surface water quality as a result of the discharge of groundwater, with the predicted concentration of NA, into the MacKay River.

b. What measures will Syncrude implement to mitigate the impact on surface water quality?

33. Volume 4, SIR 42b, Page ERCB-75. Syncrude states that for Base Mine Lake (BML) “The range of predicted TDS concentration is 800 to 3,000 mg/L [3 to 11 times greater than Athabasca River maximum TDS concentration, as per RAMP 2008 Technical Report], within a water cap containing 50% fresh water at initiation. Peak TDS concentrations are expected to decline to 1,800 mg/L [7 times greater than Athabasca River maximum TDS concentration, as per RAMP 2008 Technical Report] after 10 years.” SIR, Page ERCB-188, Question 92, Syncrude states “The Base Mine Lake demonstration (test) period is expected to take 10 years, beginning in 2012. This would be followed by a period within which the lake would continue to develop towards a final reclamation outcome.”

a. As per Syncrude’s modelled results, will BML be deemed a self-sustaining aquatic environment in 2022?

b. Provide an action plan to monitor performance and measure successful compliance of the proposed target. Include Key Performance Indicators and the criteria for selecting them.

c. Provide alternative plan to treat the end pit lake water should BML does not prove to be successful at the end of the demonstration phase.

d. Discuss the alternatives that Syncrude may use to address MFT management should the results from the BML demonstration period prove to not be successful.

34. Volume 4, SIR 93, Page ERCB-189. Syncrude mentions the potential mitigation

measures and the response time “if changes to groundwater quality are detected as a result of the project”. As per Syncrude statement in Question 60c, the groundwater monitoring along the perimeter of the SWSS shows no indication of process-water contamination.

a. What pro-active measures could Syncrude implement to prevent seepage from reaching the MacKay River or any other water body?

b. How could Syncrude ensure the success of the mentioned interception methods if these are subject to • the installation of additional monitoring wells for confirmation of the

existence of a plume, and • a minimum three-month implementation period once the problem is

detected?

c. Should changes in groundwater quality be detected, how will Syncrude determine if they are as a result of the project?

35. Volume 4, SIR 88b, Page ERCB-182. Syncrude stated that the vast majority of

tailings fluids do not constitute an unrefined product and no reporting protocol is

initiated. As per OSCR, Part 1, (0) “liquid spill” means any crude bitumen, oil sands product, condensate, salt water or contaminated water that … (iii) is in excess of 2 cubic meters if released on an oil sands site. As part of the requirements of Directive 23, Section 2.6.1, provide a copy of the Spill Contingency Plan for this project.

36. Volume 4, SIR 89b, Page ERCB-183, Question 89b, Page ERCB-185, Question

90g, Page ERCB-187, Question 91d. In these sections Syncrude discusses that process-affected waters, including those released from MFT, are within the range of treatment capabilities currently available in water treatment technologies. Elaborate on the currently available water treatment technologies that Syncrude would commit to use should process-affected waters require treatment prior to releasing them into the environment.

1.6 Air 37. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Section 2.5.1, Page 2-12. Syncrude states “The SWSS contains three phases; a water phase, a bitumen phase and a dry or sand phase. Each of these phases emits substances at different rates”.

Appendix A1, Tables A1.19, A1.20 and A1.21 show the summary of VOC emissions from the Syncrude SWSS ponds. These tables seem to have missing information or incorrect information.

a. Provide the missing Baseline and Project emissions data for compounds such as C6-C16 Aliphatics that have flux rates but no emission rates.

b. Explain why in Tables A1.20 and 21 compounds such as H2S and Carbon Disulfide have very different (or zero) flux rates and yet have identical Baseline and Project emissions?

c. Provide updated tables with the correct and complete summary of VOC emissions for Syncrude and confirm that the correct emissions data was used in the updated assessment.

38. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Appendix A1, Tables A1.23 and A1.24, Page 17. Metals emissions from the SWSS are contrasted to the rest of the Syncrude facility, however only the main Syncrude stack in Table A1.24 is shown. How would the metal emission change for the Syncrude facility if a more comprehensive accounting of all other stacks and mine fleet equipment were to be included in the assessment?

39. Supplemental Submission: Air Quality and Human Health Risk Assessments, Page 3-15. Syncrude states that it did not perform a cumulative assessment for trace metals and PAH’s. A CEA was performed on the particulate CAC’s.

The response to SIR #99 states that “Sources of VOC, PAH, and metal emissions from other facilities are not available so only the existing and project case for these species will be reported.

a. What is the change from baseline for trace metals and PAH under this current revised assessment and how much does it differ from the originally reported 2% and 7%?

b. Recent EIA’s have been able to present a CEA for trace metals and selected PAH’s. Why was Syncrude unable to acquire this information?

c. Provide the CEA on trace metals and PAH’s. 40. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Section 2.5.1, Page 2-34. Syncrude states that with the exception of benzene, predicted RSC, VOC and PAH concentrations are below the AAAQOs where they apply. Consistent with SIR #102, how many exceedances of the AAAQO for benzene are predicted?

41. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Appendix A1, Tables A1.19 to A1.21, Pages 13-15. These tables reflect Syncrude’s VOC emissions from the current operations (baseline) and the SWSS project.

Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5.1, Tables 2.5 & 2.8, Pages 22 & 26. In these tables Syncrude reflects summaries of baseline and project emissions for VOCs, RSCs and PAHs.

a. Table 2.5 for example shows baseline Carbon Disulphide emissions to be 0.0186 t/d while Table A.19 in Appendix A1 shows an emissions total of approximately 15 t/d (5499 t/yr). Provide an explanation for why the t/d of compounds such as H2S and Carbon Disulphide appear to be so different between Tables 2.5, 2.8 & A.19, A.20.

b. Confirm that the correct emissions data was used in the revised assessment?

1.7 Errata 42. Supplemental Submission: Air Quality and Human Health Risk Assessments,

Appendix A1, Section 4. There seem to be errors associated with stack temperatures units and labels for different units. For example Stack 8-3 appears to have a stack temperature of 75 Kelvin which is unlikely. Confirm the validity of these Tables and that the correct information was used for the updated assessment.

43. Volume 3, Appendix B, Page 5, Table B1.5. Syncrude lists the primary stack emission source. This summary is different from the updated Table A1.6 in Appendix A1. Syncrude states that the 1998/1999 EIA is the source for both tables. Clarify why the emission are different for TSP, PM10, PM2.5, CO & SO2 for both the main stack and the 8-3 stack if updated information was not used for the revised assessment.

2.0 AENV 2.1 Air

1. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5, Table 2.4, Page 2-20. Table 2.4 lists the baseline emissions of particulate matter and trace metals for both the Syncrude facility and background sources. Particulate matter emissions for the Syncrude stack emission sources have significantly dropped compared to those presented in the original Syncrude SWSS EIA, Air Quality Assessment, November 2008 (Volume 2, Section 4.5.3, Table 4.3, Page 4-13). However, in both reports Syncrude states it has based the emissions on the 1998/1999 EIA.

a. Clarify the decrease in particulate matter emissions from the Syncrude stacks from the current submission compared to the original air quality assessment (November, 2008).

b. Confirm that the correct particulate matter (TSP, PM10 and PM2.5) emissions were used in the updated dispersion modelling assessment. Provide updated modelling results if necessary.

2. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5, Table 2.6, Page 2-23 and Table 2.9, Page 2-27. Table 2.6 lists the baseline air quality modelling results. For PM2.5 it states that it is the 98% value. Effective, Feb 1, 2007, the ambient objective in Alberta for PM2.5 as a 24-hour average is 30 µg/m³ based on the maximum predicted concentration. This is more stringent than the Canada Wide Standard which is based on the 98th percentile concentration averaged over 3 years.

a. Provide an updated Table 2.6 containing the maximum predicted 24-hr PM2.5 concentrations for comparison to the Alberta Environment Ambient Air Quality Objectives (AAAQO).

b. Confirm that the values in Table 2.9 are the maximum predicted PM2.5 values. If not, provide an updated Table 2.9 containing the maximum predicted 24-hr PM2.5 concentrations for comparison to the AAAQO.

3. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5, Table 2.5, Page 2-22. Table 2.5 lists the baseline emissions of volatile organic carbons (VOCs), reduced sulphur compounds (RSCs) and polycyclic aromatic hydrocarbons (PAHs). Emissions are only listed for the Syncrude emission sources. In the original Syncrude SWSS EIA, Air Quality Assessment, November 2008, Volume 2, Section 4.5.3, Table 4.4, Page 4-14 emissions were listed for the Syncrude emission sources as well as for several background sources.

a. Provide rationale for why VOC, RSC and PAH emissions not evaluated for the baseline background sources in the updated air quality assessment?

b. How would the inclusion of the background emission sources affect the maximum predicted VOC, RSC and PAH concentrations?

4. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.5, Table 2.11, Page 2-34. Table 2.11 presents the SWSS Conversion VOC, PAH and RSC dispersion model results. Specifically, the maximum predicted hydrogen sulphide and benzene concentrations are 3.05 µg/m3 and 291 µg/m3, respectively. The original Syncrude SWSS EIA, Air Quality Assessment, November 2008, Volume 2, Section 4.5.6, Table 4.10, Page 4-36 predicted a maximum hydrogen sulphide concentration of 2,931 µg/m3 and a benzene concentration of 1,543µg/m3. These are significant differences in predicted concentrations, considering the emissions did not fluctuate greatly between the two assessments.

a. Provide clarification and explanation of the difference in predicted hydrogen sulphide and benzene concentrations between the updated (July, 2009) and previous (November, 2008) air assessments.

5. Supplemental Submission: Air Quality and Human Health Risk Assessments, Appendix A1, Section 2.0, Page 3. Syncrude states operational emissions were taken from the most recent Syncrude EIA (Conor Pacific, 1999). In 2003, Syncrude submitted an approval amendment application, which contained an updated dispersion modelling assessment. In response to AENV’s SIR round 1, Volume 4, SIR 113a, Syncrude responded that 3D CALPUFF runs were being preformed using updated emissions data.

a. Provide justification for not using the most recent emissions data in the updated dispersion modelling assessment.

b. How would the predicted concentrations be affected using up to date emissions information?

6. Supplemental Submission: Air Quality and Human Health Risk Assessments, Appendix A1, Section 4.6, Table A1.24, Page A1-17. Table A1.24 summarizes the metal emissions from the existing Syncrude facility. Only one Syncrude stack is listed as a source of metal emissions. However, the original Syncrude SWSS EIA, Air Quality Assessment November 2008, Volume 3, Appendix B1, Section 4.6, Table B1.24, Page B1-17, listed metal emissions from numerous stacks and fugitive emission sources.

a. Provide justification for only modelling the metal emissions from one Syncrude stack and not including all stacks and fugitive emission sources.

2.2 Terrestrial

7. SIR 38 a, Page ERCB-68 and SIR 49 b, Page ERCB-85. Syncrude indicates that scare cannons are very effective at discouraging waterfowl and other wildlife from entering the SWSS Settling Basin as evidenced by low mortality numbers disclosed in Syncrude’s response to Information Request No 49. Syncrude also states the Syncrude investigation into the 2008 Waterfowl Incident has concluded the delays in deploying the noise cannons at the Aurora pond was the reason we failed to protect the birds; it wasn’t due to the triggering technology used. Syncrude does not yet have an approved waterfowl protection plan that is satisfactory to ASRD and AENV.

a. Describe the monitoring program or scientific study Syncrude is conducting to determine the effectiveness of cannons in deterring waterfowl from entering the SWSS Settling Basin.

b. What monitoring protocol was in place historically to ensure accurate detection of all waterfowl mortality incidents?

8. SIR 38 a, Page ERCB-68. Syncrude states it should also be noted that scare cannons were not deployed on April 28,2008 at the Aurora Settling Basin when 1606 waterfowl died, which vastly exceeded anything experienced by Syncrude since commencement of its operations. ASRD understands that Syncrude experienced a similarly large mortality incident in the late 1970’s.

a. Confirm, or modify as necessary, the statement.

9. SIR 38 c, Page ERCB-68. Syncrude lists the major components of its new site-wide waterfowl protection program. The original SIR referred to all wildlife, and was not limited to waterfowl.

a. Describe how Syncrude will deter wildlife (including moose, coyote, deer etc.) from entering the SWSS tailings pond area.

b. What design considerations and mitigation measures will/has Syncrude undertake(n) to minimize the risk of wildlife and birds entering the SWSS tailings pond? Provide a detailed list.

2.3 Health

10. SIR147, Page AENV-49. Syncrude was asked to provide an updated health risk assessment that takes in to account all contaminants in surface water that are of concern to regulators and stakeholders. In response, Syncrude states Using the same methodology as described in the response to SIR 95 a to c, the ratios of natural, tailings and maximum process affected plume concentration is presented in Table SIR-147-AENV-1. The ratios for these parameters are low (i.e., less than 1), indicating that the natural water is not substantially different from the maximum plume concentration, therefore these parameters were not included in the modeling. To understand the overall or total potential health effects associated with the project, the requested assessment is needed, regardless of whether contaminant concentrations change substantially.

a. Provide the required assessment.

11. SIR151, Page AENV-53 and SIR 125, Page AENV-21 and Supplemental Submission: Air Quality and Human Health Risk Assessments.

a. Clarify if the naphthenic acids mobilized during oil sands processing and found in seepage water from the tailings are expected to be chemically and toxicologically similar to those found naturally in the receiving water bodies.

In the response to SIR 125, Page AENV-21, Syncrude states the predicted maximum baseline and application case concentrations of naphthenic acids in groundwater discharging to the MacKay River are 2.10 and 4.49 mg/L, respectively. This is greater than the normal range of total naphthenic acid concentrations in the receiving water bodies as listed in SIR-151.

b. Discuss the expected loading of naphthenic acids into receiving water bodies in terms of the total quantities expected (estimated loading) and in terms of their expected contribution to concentrations in these water bodies.

c. Provide numerical estimates that can be readily compared to the background levels.

d. In the absence of an established human health Toxicological Reference Value (TRV) for naphthenic acids, discuss whether or not Syncrude is doing or plans to do any work to address this data gap.

12. SIR 152b, Pages AENV-54 to 56 and Supplemental Submission: Air Quality and Human Health Risk Assessments. Syncrude was asked to provide a chemical screening that considers toxicity and bioaccumulation for all the chemicals for all pathways that could potentially be released from the project. Syncrude states that the screening included an assessment of chemicals according to their toxicity. In the EIA report Syncrude states according to guidance received from Alberta Health and Wellness (AHW), chemicals of greatest concern were defined as 1) chemicals viewed as a concern by the regulatory authorities, 2) chemicals perceived as a concern by the public during consultation, and 3) chemicals presently of concern in the region under study relevant to Syncrude’s Project. The interpretation of the guidance provided by AHW is not entirely correct. A screening to prioritize chemicals for the Human Health Risk Assessment should also incorporate both toxicity and bioaccumulation information. Syncrude has only provided evidence of the latter.

a. A screening assessment for both inhalation and oral pathways of exposure is required.

13. SIR 160b, Page AENV-78 and Supplemental Submission: Air Quality and Human Health Risk Assessments. Syncrude responded to the question that background concentrations were included in the Incremental Lifetime Cancer Risk (ILCR). Background concentrations should not be included in the calculation of ILCRs. ILCRs are described as incremental lifetime cancer risks above background according to Health Canada.

a. Recalculate all ILCRs without background included.

14. SIR 156a, Page AENV-66.

a. Confirm that maximum concentrations for all media were used in the updated Human Health Risk Assessment (HHRA)?

15. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 2.3.1, Page 2-6. Syncrude states non-Syncrude fence line receptor grid points within approximately 100 m of non-point sources were removed because preliminary modeling showed excessively high results at receptors near to these sources.

a. Provide further discussion of the rationale for the removal of these receptor grid points.

16. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.0, Page 3-1. Syncrude states responses to these and other SIRs necessitated revision to the human health risk assessment as data from other disciplines were updated. Acute inhalation exposures were not updated.

a. Provide an explanation as to why acute inhalation exposures were not updated. If there were changes in acute modeled concentrations update the HHRA accordingly.

17. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.2.3, Page 3-9. On page 18-20, Volume 2 of the EIA Syncrude states on-site receptors were considered to be the Syncrude workers in this assessment. The evaluation of the risks to the workers will be assumed to be at the Fenceline location since the air modeling restrictions do not allow for prediction of ambient air concentrations within the source area.

a. Confirm the above-statement applies to the updated HHRA. If not, provide an explanation.

18. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.4.5, Page 3-22. Syncrude states using predicted soil concentrations in Table 3.10. In the EIA Syncrude indicates that they have taken soil samples for the HHRA.

a. Provide an explanation as to why predicted soil concentrations were used when measured samples were collected.

19. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.1, Page 3-36. Syncrude states another component of this risk characterization is a discussion about the uncertainties in the process, which is described in Section 1.8. The revised HHRA does not include a Section 1.8.

a. Provide Section 1.8.

20. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.2.2, Page 3-44. Syncrude states exposures to arsenic for the off-site receptor resulted in a total hazard quotient (HQ) value of 43.4 for the Baseline scenario and 86.3 for the Project scenario (Table 3.26).

a. Provide scientific evidence that indicates the potential human health effects that may be observed given this increased level of exposure to arsenic.

21. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.2.2, Page 3-45. With respect to increases in the ILCR associated with arsenic exposure, Syncrude states the contribution of arsenic from the Project to the Baseline is marginal and therefore, the risks remain the same between the Baseline and the Project. The highest ILCR in the Project scenario id 2.9 x 10-3, while in the Baseline scenario it is 7.0 x 10-4. This difference is near an order of magnitude.

a. Explain how this difference is considered marginal.

b. Comment on the potential health risks that may be experienced in the Project scenario, using available scientific evidence.

22. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.2.3, Page 3-45 and Table 3.29, Page 3-52. Syncrude states the HQ for noncarcinogenic risk is greater than 1.0 for the on-site worker, however Table 3.29 indicates the total HQ to be 0.16.

a. Explain this discrepancy.

23. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.3.1, Page 3-90. Syncrude states exposures to manganese in the various media results in total HQ estimates of 3.4 for the toddler receptor in the Baseline scenario and 4.0 in the Project scenario, respectively at all receptor locations (Table 3.56).

a. Based on the toxicological endpoints associated with exposure, and the available Reference Dose (RfD) and No Observable Adverse Effect Level (NOAEL) values provided in Appendix B1, comment on whether any of the potential health effects associated with exposure to manganese will be seen in the study area.

24. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.5.3.3, Page 3-96. For both the on-site worker and off-site receptors, HQ estimates exceed 1.0 (6.3 for workers and up to 24 for off-site receptors). The only comment provided is that the values are not different from Baseline to Project scenario.

a. Discuss the possibility that these levels of exposure will lead to the toxicological effects associated with naphthalene exposure (e.g. hemolytic anemia, liver, neurologic or ophthalmologic effects)?

25. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.6, Page 3-119. Syncrude states therefore, in the assessment, a value equivalent to half the detection limit was used. This contributed to the elevated HQ value, but is a gross over-estimate of the risk since it was essentially non-detected. This is an in correct statement. Even if a chemical is non-detect it does not mean that it is essentially zero. The chemical may be present just below the detection limit, at half the detection limit (as Syncrude assumed) or less than half the detection limit.

a. Did Syncrude consider modeling those substances that were non-detect to better understand a chemical concentration below the detection limit? If not, provide an explanation.

26. Supplemental Submission: Air Quality and Human Health Risk Assessments, Appendix A3, Pages A3-41. Some of the predicted concentrations (i.e. for C17-C34 aliphatics) show that the project will act to decrease the concentrations of some chemicals of concern in certain locations.

a. Provide rationale as to why this would occur.

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

27. SIR 136 b, Page AENV-36. The original SIR requested a reclamation plan to address the Cell 32 erosion gulley. Syncrude did not provide it in their response. Syncrude indicates the Cell 32 gulley will be repaired prior to raising the pond elevation above 385 masl at the SWSS.

a. Indicate the approximate timing of the development of the reclamation plan and the subsequent raising of the pond elevation.

b. Clarify how the reclamation plan will be communicated to AENV and through which forum: a letter, the 2010 soil salvage and placement plans due this fall, the annual report due in April 2010, or through the 2011 Mine Reclamation Plan update?

2.5 Errata

28. Supplemental Submission: Air Quality and Human Health Risk Assessments, Section 3.4.3, Table 3.4, Page 3-17.

a. Table 3.4 lists AAAQO for PM10 as 400, 200 and 60 µg/m3 for the 1-hr, 24-hr and annual averaging periods, respectively. These numbers are incorrect as AENV does not currently have an AAAQO for PM10.

3.0 Acronyms The following acronyms are used in this Supplemental Information Request. AAAQO Alberta Environment Ambient Air Quality Objectives AENV Alberta Environment AHW Alberta Health and Wellness ASRD Alberta Sustainable Resource Development EIA Environmental Impact Assessment EPEA Environmental Protection and Enhancement Act ERCB Energy Resources Conservation Board g gram HHRA Human Health Risk Assessment HQ Hazard quotient hr Hour ILCR Incremental Lifetime Cancer Risk l litre m Metre masl Metres above sea level mg milligram NOAEL No observable adverse effect level PAH Polycyclic aromatic hydrocarbons PM2.5 Particulate matter with diameter below 2.5 microns PM10 Particulate matter with diameter below 10 microns RfD Reference dose RSC Reduced sulphur compounds SIR Supplemental Information Request SWSS Southwest Sand Storage Syncrude Syncrude Canada Ltd. TRV Toxicological Reference Value TSP Total suspended particulates µ micro VOC Volatile Organic Carbon

Appendix B

Drill Logs for Groundwater Calibration Wells

Appendix C

Plan and Cross-Sections – Cell 32

application for approval of the - alberta · 2016. 6. 10. · volume 5 – sir: round 2 september...

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