Pierre River Mine Project

Application for Approval of the 

Pierre River Mine Project 

Supplemental Information Round 2 

Volume 1: Project Update and ERCB SIRs 

Submitted by: 

Shell Canada Limited 

Submitted to: 

Alberta Energy Resources Conservation Board and 

to Alberta Environment 

May 2009

Pierre River Mine Project 

Supplemental Information 

Round 2 

April 2010

PIERRE RIVER MINE 

SUPPLEMENTAL INFORMATION 

ROUND 2 

Letter of Transmittal 

CONTENTS 

TABLE OF CONTENTS 

Contents 

Table of Contents.............................................................................................................................. i 

List of Illustrations..........................................................................................................................iii 

Part 1: Overview 

1. Introduction 

1. Overview..............................................................................................................................1-1 

2. Navigable Waters.................................................................................................................1-5 

3. Communication with the Applicant...................................................................................1-11 

2. Errata 

1. Project Description Errata....................................................................................................2-1 

2. EIA, EIA Update and ESR Errata........................................................................................2-3 

3. Supplemental Information Errata.........................................................................................2-9 

Part 2: ERCB SIRs 

3. General 

SIRs 1 – 2............................................................................................................................3-1 

4. Mining and Processing 

Geotechnical SIRs 3 – 4......................................................................................................4-1 

Mining SIRs 5 – 11 .............................................................................................................4-4 

Processing SIRs 12 – 28......................................................................................................4-9 

Tailings Management SIRs 29 – 38 ..................................................................................4-28 

5. Noise 

SIR 39 .................................................................................................................................5-1 

6. Air 

SIRs 40 – 45........................................................................................................................6-1 

7. Water 

Water Management SIRs 46 – 49 .......................................................................................7-1 

Hydrogeology SIRs 50 – 79................................................................................................7-4 

8. Terrestrial 

Conservation and Reclamation SIR 80 ...............................................................................8-1 

April 2010 Shell Canada Limited i 

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CONTENTS TABLE OF CONTENTS 

9. Errata 

SIR 81 .................................................................................................................................9-1 

Part 3: AENV SIRS 

10. General 

SIR 1 .................................................................................................................................10-1 

Public Engagement and Aboriginal Consultation SIR 2...................................................10-2 

Waste Management SIRs 3 – 5 .........................................................................................10-2 

11. Air 

Dispersion Modelling SIRs 6 – 13 ....................................................................................11-1 

Air Quality Assessment SIR 14 ......................................................................................11-13 

12. Water 

Water Management SIRs 15 – 16 .....................................................................................12-1 

Hydrogeology SIRs 17 – 19..............................................................................................12-5 

Hydrology SIRs 20 – 40..................................................................................................12-22 

Surface Water Quality SIR 41.........................................................................................12-61 

Aquatics SIRs 42 – 43.....................................................................................................12-63 

13. Terrestrial 

SIR 44 ...............................................................................................................................13-1 

Conservation and Reclamation SIR 45 .............................................................................13-2 

Terrain and Soils SIRs 46 – 47 .........................................................................................13-3 

Wildlife SIRs 48 – 59........................................................................................................13-5 

Biodiversity and Fragmentation SIRs 60 – 78 ................................................................13-35 

14. Health 

SIRs 79 – 89......................................................................................................................14-1 

15. EPEA Approvals 

SIRs 90 – 96......................................................................................................................15-1 

16. Errata 

SIRs 97 – 98......................................................................................................................16-1 

Glossary 

ii Shell Canada Limited April 2010 

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ROUND 2 

CONTENTS 

LIST OF FIGURES 

LIST OF ILLUSTRATIONS 

Figure ERCB 25-1 Pierre River Mine Material Balance – One Train (Calendar Day)..........................2-13 


Figure ERCB 3-1 Potential Sterilization Area .......................................................................................4-2 

Figure ERCB 12-1 Jackpine Mine Development...................................................................................4-10 

Figure ERCB 12-2 Pierre River Mine Development..............................................................................4-11 

Figure ERCB 19-1 Average Monthly Bitumen Recovery and Improvement Required.........................4-18 



Figure ERCB 34-1 Conceptual ETDA Construction Material Requirement .........................................4-35 

Figure ERCB 42-1 Base Case Maximum 1-Hour Benzene Predictions.................................................6-17 

Figure ERCB 42-2 Application Case Maximum 1-Hour Benzene Predictions......................................6-18 

Figure ERCB 42-3 Base Case Likelihood of 1-Hour Benzene Predictions Exceeding 30 µg/m 3 ..........6-19 

Figure ERCB 42-4 Application Case Likelihood of 1-Hour Benzene Predictions Exceeding 

30 µg/m 3 ..................................................................................................................6-20 

Figure ERCB 60-1 Pierre River Mining Area – Hydrogeologic Cross-Section Locations and 

Monitoring Wells in the Local Study Area .............................................................7-16 

Figure ERCB 60-2 Pierre River Mining Area – Hydrogeologic Cross-Section E–E′............................7-17 

Figure ERCB 75-1 Geological Cross-Sections A-A′ and B-B′ ..............................................................7-30 

Figure ERCB 75-2 Hydrogeological Cross-Sections C-C′, D-D′ and E-E′............................................7-31 

Figure ERCB 75-3 Regional and Local Study Areas, Cross-Section Locations, Regional 

Topography and Drainage.......................................................................................7-32 

Figure ERCB 75-4 Piezometer Locations – McMurray Formation – Basal Aquifer .............................7-33 

Figure AENV 3-1 Revised Class II Landfill Site..................................................................................10-3 

Figure AENV 10-1 Comparison of Temperature, Wind Speed and Wind Direction Vertical 

Profiles ..................................................................................................................11-10 

Figure AENV 19-1 Aerobic and Anaerobic PAH Decay Rates............................................................12-19 

Figure AENV 24-1 Application Case Oil Sands Developments in the Pierre River Mining Area 

Local Study Area in the Far-Future.......................................................................12-31 

Figure AENV 27-1 Reclamation Ecosite Phase/Wetlands Types Planting Prescriptions.....................12-39 

Figure AENV 38-1 Wet and Dry Surface Landscape at Closure for the Pierre River Mine ................12-57 

Figure AENV 70-1 Pierre River Mine Area Local Study Area Athabasca River Corridor ..................13-63 

LIST OF TABLES 

Table 1-1 Guide to the SIRs ......................................................................................................1-3 

Table ERCB 8-1 Lease 9 Resource Summary (2007 Data) ..................................................................2-1 

Table 2-1 Environmental Errata ................................................................................................2-3 

April 2010 Shell Canada Limited iii 

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CONTENTS LIST OF ILLUSTRATIONS 

Table 5.5-12 Winter Habitat Conditions at Waterbody Sampling Sites in the 

Eymundson Creek Watershed (Updated) ..................................................................2-6 

Table 18-1 Calibrated Hydraulic Conductivity and Recharge Values in Regional Model 

(Revised) ...................................................................................................................2-6 


Table ERCB 4-1 Internal Drain Flow Estimate ..................................................................................2-10 

Table ERCB 27-1 Comparison of Thermal Energy Requirements.......................................................2-11 

Table ERCB 3-1 Potential for UTS/Teck Resource Sterilization .........................................................4-3 

Table ERCB 4-1 Internal Drain Flow Estimate ....................................................................................4-4 

Table ERCB 4-2 Comparison of Pierre River Mine Estimated Seepage Flux and Measured 

Seepage Flux at the Muskeg River Mine External Tailings Disposal Area ..............4-4 



Table ERCB 23-1 Bitumen Recovery Comparison ..............................................................................4-21 

Table ERCB 26-1 Solvent Loss for Material Balances with Asphaltene Recovery Unit .....................4-23 

Table ERCB 26-2 Solvent Loss for Material Balances Without Asphaltene Recovery Unit ...............4-26 

Table ERCB 26-3 Solvent Loss for Material Balances with Asphaltene Recovery Unit 

(Volumetric) ............................................................................................................4-26 

Table ERCB 26-4 Solvent Loss for Material Balances Without Asphaltene Recovery Unit 

(Volumetric) ............................................................................................................4-26 



Table ERCB 33-1 Fines Capture in the Pierre River Mine ETDA TT Deposit....................................4-33 

Table ERCB 41-1 Project Emissions Summary including Additional Auxiliary Boilers.......................6-3 

Table ERCB 41-2 Comparison of Regional SO2 Predictions .................................................................6-4 

Table ERCB 41-3 Comparison of Regional NO2 Predictions.................................................................6-5 

Table ERCB 41-4 Comparison of SO2 Predictions In Regional Communities.......................................6-7 

Table ERCB 41-5 Comparison of NO2 Predictions In Regional Communities......................................6-8 

Table ERCB 41-6 Comparison of CO Predictions In Regional Communities .......................................6-9 

Table ERCB 41-7 Comparison of Benzene Predictions In Regional Communities .............................6-10 

Table ERCB 41-8 Comparison of Select VOC Predictions In Regional Communities........................6-11 

Table ERCB 41-9 Comparison of PM2.5 Predictions In Regional Communities..................................6-13 

Table ERCB 42-1 Regional 1-Hour Benzene Predictions ....................................................................6-15 

Table ERCB 52-1 Predicted Tailings Sediment Porosity .......................................................................7-6 

Table AENV 5-1 Pierre River Mine Waste Categories and Disposal Methods ..................................10-6 

Table AENV 8-1 Example Hourly OLM and ARM NO2 Concentrations...........................................11-6 

Table AENV 9-1 Steady-State Emissions Factors for Nonroad Diesel Engines.................................11-7 

Table AENV 9-2 Transient Adjustment and Deterioration Factors for Nonroad Diesel Engines.......11-8 

Table AENV 9-3 Load Factors for Nonroad Diesel Engines ..............................................................11-8 

Table AENV 17-1 Comparison of ETDA Seepage Management Alternatives.....................................12-6 

Table AENV 18-1 Calibrated Hydraulic Conductivity and Recharge Values in Regional Model 

(Revised) ...............................................................................................................12-13 

Table AENV 23-1 Summary of Data Sets Used for Jackpine Mine Expansion and Pierre River 

Mine Project ..........................................................................................................12-28 

Table AENV 59-1 Potential and Observed Federally Listed Species and Associated Habitat to 

be Cleared and Reclaimed in the Local Study Area..............................................13-31 

Table AENV 60-1 Predicted Key Indicator Resource Habitat Fragmentation Effects for the Base 

Case, Application Case and Planned Development Case in the Regional 

Study Area.............................................................................................................13-39 

iv Shell Canada Limited April 2010 

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Table AENV 70-1 Wildlife Habitat Change Within the Corridor Between the Pierre River 

Mining Areas Local Study Areas: Application Case ............................................13-64 

Table AENV 82-1 Factors Affecting Sense of Smell............................................................................14-4 

Table AENV 82-2 Odour Characteristics and Thresholds ....................................................................14-7 

Table AENV 82-3 Comparison of Predicted Peak Air Concentrations with Odour Thresholds – 

Cabin Residents.....................................................................................................14-12 


Aboriginal Residents .............................................................................................14-14 


Community Residents ...........................................................................................14-16 

Table AENV 85-1 Comparison of Construction and Operations Phase Greenhouse Gas 

Emissions ..............................................................................................................14-23 

Table AENV 86-1 Consumption Rates for the Cabin and Aboriginal Residents................................14-25 

Table AENV 86-2 Chronic Risk Quotients from Multiple Pathways of Exposure – Cabin 

Residents ...............................................................................................................14-26 

Table AENV 86-3 Chronic Risk Quotients from Multiple Pathways of Exposure – Aboriginal 

Residents ...............................................................................................................14-27 

Table AENV 86-4 Chronic Lifetime and Incremental Lifetime Cancer Risks per 100,000 from 

Multiple Pathways of Exposure – Cabin Residents ..............................................14-28 

Table AENV 86-5 Chronic Lifetime and Incremental Lifetime Cancer Risks per 100,000 from 

Multiple Pathways of Exposure – Aboriginal Residents.......................................14-29 

Table AENV 86-6 Contribution of Individual Exposure Pathways to Potential Risk Quotients 

for Manganese .......................................................................................................14-30 

Table AENV 89-1 Chronic Risk Quotients from Multiple Pathways of Exposure .............................14-37 

Table AENV 93-1 Changes in Predicted Forestry Capability Class Changes Following 

Reclamation in the Pierre River Mining Area - Revised.........................................15-3 

April 2010 Shell Canada Limited v 

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vi Shell Canada Limited April 2010 

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PART 1: OVERVIEW 

PURPOSE 

INTRODUCTION 

OVERVIEW 

Section 1.1 

This document provides responses to Supplemental Information Requests (SIRs) 

Round 2 for the Pierre River Mine Project. In addition to this document, Shell 

has also submitted: 

• an EIA Update, dated May 2008, that included updates for the Pierre River 

Mine and Jackpine Mine Expansion projects 

• a Supplemental Information document , dated May 2009, containing project 

update information and responses to the Alberta Energy Resources 

Conservation Board (ERCB) and Alberta Environment (AENV) information 

requests 

STRUCTURE OF THE SUPPLEMENTAL INFORMATION 

Part 1 – Overview 

This Supplemental Information has been divided into three parts: 

• Part 1: Overview 

• Part 2: ERCB SIRs 

• Part 3: AENV SIRs 

A glossary has also been provided at the end of the document. 

The Overview contains the following information: 

• corrections to errors and omissions identified in: 

• the application 

• the EIA, the May 2008 EIA Update, and the environmental setting 

reports (ESRs) 

• previously filed May 2009 supplementary documents 

• a letter from Transport Canada confirming the results of a navigability 

assessment for the waterways in and around the Pierre River Mine and 

Jackpine Mine Expansion project areas 

• regulatory contact information 

April 2010 Shell Canada Limited 1-1 

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INTRODUCTION OVERVIEW 

Parts 2 and 3 – Supplemental Information Responses 

Section 1.1 

As requested by the ERCB and AENV, the Pierre River Mine SIR responses to 

each regulator’s set of information requests are provided separately. Part 2 

contains the ERCB information requests and responses. Part 3 contains the 

AENV information requests and responses. 

Table 1-1 lists the numbers of the SIRs, the categories assigned by the regulators, 

and their location in this supplemental filing. 

1-2 Shell Canada Limited April 2010 

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Table 1-1: Guide to the SIRs 

ERCB SIRs (Part 2) AENV SIRs (Part 3) 

Section Name SIR No. 

Section 

No. Section Name SIR No. 

Section 1.1 

Section 

No. 

General 1 – 2 3 General 10 

Mining and Processing 

• Geotechnical 

• Mining 

3 – 4 

5 – 11 

4 • General 

• Public Engagement and 

Aboriginal Consultation 

• Processing 12 – 28 • Waste Management 3 – 5 

• Tailings Management 29 – 38 Air 11 

Noise 39 5 • Dispersion Modelling 6 – 13 

Air 40 – 45 6 • Air Quality Assessment 14 

Water 46 – 79 7 Water 12 

• Water Management 46 – 49 • Water Management 15 – 16 

• Hydrogeology 50 – 79 • Hydrogeology 17 – 19 

Terrestrial 80 8 • Hydrology 20 – 40 

Errata 81 9 • Surface Water Quality 41 

• Aquatics 42 – 43 

Terrestrial 13 

• General 44 

• Conservation and 

Reclamation 

45 

• Terrain and Soils 46 – 47 

• Wildlife 48 – 59 

• Biodiversity and 

Fragmentation 

60 – 78 

Health 79 – 89 14 

EPEA Approvals 90 – 96 15 

Errata 97 – 98 16 


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1 

2


Section 1.1 


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ASSESSMENT 

INTRODUCTION 

NAVIGABLE WATERS 

Section 1.2 

In a letter dated February 23, 2010, Transport Canada informed Shell that an 

assessment of the navigability of waterways in and around the proposed Pierre 

River Mine and Jackpine Mine Expansion projects had been conducted. The 

assessment identified two waterways, the Athabasca and Muskeg rivers, that 

were navigable and applicable to the Navigable Waters Protection Act (NWPA). 

Transport Canada has requested Shell to provide additional information about the 

proposed works. Once Shell responds to Transport Canada’s request, Transport 

Canada s will notify Shell which of the proposed works in the Pierre River Mine 

and Jackpine Mine Expansion project areas will require applications to be 

submitted under the NWPA. 

Transport Canada’s letter is provided in Attachment 1. 


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INTRODUCTION NAVIGABLE WATERS 

Section 1.2 


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Section 1.2 


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Section 1.2 


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Section 1.2 


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Section 1.2 


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REGULATORY COMMUNICATION CONTACTS 

INTRODUCTION 

COMMUNICATION WITH THE APPLICANT 

Section 1.3 

All communication with Shell on this regulatory application should be directed to 

both: 

Ms. Margwyn Zacaruk 

Mr. Shawn Denstedt 

Major Approvals Coordinator Osler, Hoskin & Harcourt LLP 

Shell Canada Energy Barristers and Solicitors 

Heavy Oil, Development Suite 2500, TransCanada Tower 

400 – 4 Avenue S.W. 450 – 1st Street S.W. 

PO Box 100, Station M Calgary, Alberta T2P 5H1 

Calgary, Alberta T2P 2H5 Tel: (403) 260-7088 

Tel: (403) 384-5194 Fax: (403) 260-7024 

Fax: (403) 691-4255 

e-mail: margwyn.zacaruk@shell.com 

e-mail: sdenstedt@osler.com 


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Section 1.3 

INTRODUCTION COMMUNICATION WITH THE APPLICANT 


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Volume 2, Section 4, Resource Base 

ERRATA 

PROJECT DESCRIPTION ERRATA 

Errata Subsection 4.2, Lease Resource Definition, page 4-13, Table 4-2 

The information provided in the Pierre River Mine Application, Volume 2, 

Table 4-2 was incorrect. 

Section 2.1 

Correction The correct information is shown here in Table ERCB 8-1. The information has 

been updated according to the block modelled geology data and pit shell design 

that were used to compile the Project Description. This information is also 

provided in the response to ERCB SIR 8a. 

Resource 

Category 

Total in situ 

resource 

Ore at >7% 

bitumen grade 

and minimum 3 m 

thickness 

Ore at 

TV/BIP < 12 

Table ERCB 8-1: Lease 9 Resource Summary (2007 Data) 

Volume 

of Ore 

(Mm 3 ) 

Lease 9 Area Lease 9 Pit Area 

Grade 

(wt%) 

Bitumen 

(Mm³) 

Bitumen 

(Mbbl) 

Volume 

of Ore 

(Mm³) 

Grade 

(wt%) 

Bitumen 

(Mm³) 

Bitumen 

(Mbbl) 

2,347 7.58 368 2,312 1.423 9.74 286 1,800 

1,346 11.03 307 1,930 1,116 11.22 259 1,627 

846 11.24 196 1,235 791 11.28 184 1,158 

Volume 2, Section 11, Waste Management 

Errata Subsection 11.2, Waste Classification and Management, page 11-6, 

Table 11-3 

The volumes presented in Table 11-3 of the application were incorrect for the 

following waste types: 

• flue gas desulphurization solids 

• bottom ash 

• fly ash 


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ERRATA PROJECT DESCRIPTION ERRATA 

Section 2.1 

When the application was prepared, the waste volumes presented did not 

correspond to the boiler size and the technology selected. This was an error in 

compiling the data for the application. 

Correction The correct waste information was presented in the May 2009 Pierre River Mine, 

Supplemental Information, Volume 1, Table 4-1. 

Volume 2, Section 19, Alberta Environment Approval Requirements 

Errata Subsection 19.2, Application for Renewal, page 19-3 to 19-34 

The header Application for Renewal was incorrect. 

Correction The header of this subsection should have read Application for Approval. This 

information is also provided in the response to AENV SIR 97a. 


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EIA Volume 

Number 

PRM EIA 

Update: 

Supplemental 

Information, 

Volume 2 

ERRATA 

EIA, EIA UPDATE AND ESR ERRATA 

Section 2.2 

Table 2-1 lists the errata from the EIA, environmental setting reports (ESRs) and 

the 2008 EIA Update. 

Table 2-1: Environmental Errata 

Page 

Number Error Correction 

21-7 PRM SIR 267a was incorrect in the 

following statements: 

“gravels as a result of mining is 2.1 

km (see EIA, Volume 3, Section 

6.5.1.3, page 5)” 

“the EIA for Shell’s Jackpine Mine 

Expansion and Pierre River Mine 

project (Shell 2007) indicates that a 

drawdown of 0.1 m is expected up to 

3 km west of, and up to 5 km north 

and south of, the Pierre River Mine 

pit limits” 

21-46 PRM SIR 294a was incorrect in the 


“For the purpose of this hydrological 

assessment, a drawdown of more 

than 1 m is considered to have the 

potential to negatively affect fen 

structure and function in a manner 

that could reduce flood attenuation 

capacity.” 

“Groundwater drawdown of more 

than 1 m in fens has the potential to 

negatively affect 9% (1,099 ha) of 

wetlands within the watershed 

areas.” 

“A water level drawdown of over 1 m 

may results in a shift in the structure 

and function of fens on landscapes, 

resulting in a reduced capacity to 

attenuate flows.” 

These statements have been 

corrected as follows: “gravels as a 

result of mining is 2.1 km (see 

Suncor [2007], Volume 3, Section 

6.5.1.3, page 5).” “the updated 

drawdown for Shell’s Jackpine Mine 

Expansion (refer to Update 

Appendix, Section 3) indicates that a 

drawdown of 0.1 m is expected up to 

7.8 km from the Jackpine Mine 

Expansion project footprint in certain 

areas (see Figure 3.1-1 in Section 3 

of the Update Appendix). 

These statements have been 

corrected as follows: “For the 

purpose of this hydrological 

assessment, a drawdown of more 

than 0.1 m is considered to have the 

potential to negatively affect wetland 

structure and function in a manner 

that could reduce flood attenuation 

capacity.” 

“Groundwater drawdown of more 

than 0.1 m in fens has the potential 

to negatively affect 37% (7,153 ha) 

of wetlands within the LSAs.” 

“A water level drawdown of over 0.1 

m may results in a shift in the 

structure and function of fens on 

landscapes, resulting in a reduced 

capacity to attenuate flows.” 


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Section 2.2 

ERRATA EIA, EIA UPDATE AND ESR ERRATA 

EIA Volume 

Number 

PRM EIA 

Update: 

Supplemental 

Information, 

Volume 2 

(cont’d) 

Table 2-1: Environmental Errata (cont’d) 

Page 


23-117 PRM SIR 454c was incorrect in the 


“Therefore, the total predicted 

drawdown area, as defined by the 

0.1 m drawdown isopleths in the 

LSAs, is 45,957 ha, 14,869 ha at 

Pierre River Mine and 31,088 ha at 

the Jackpine Mine Expansion.” 

“The areal extent of fens potentially 

affected by drawdown (1,833 ha) for 

the Pierre River Mine and Jackpine 

Mine Expansion account for 4% of 

this total area.” 

“The fens potentially affected are 

also 4% of the total drawdown area” 

“The 1,833 ha of fens potentially 

affected by drawdown is

Section 2.2 


EIA Volume 

Number 

PRM EIA 

Update: 

Supplemental 

Information, 

Volume 2 

(cont’d) 

Volume 4B, 

Appendix 4-1 

Volume 4B, 

Appendix 4-1 

Table 2-1: Environmental Errata (cont’d) 

Page 


23-50 In SIR 426a , Table 426-7 replaces 

Table 2.4-5 in the ESR. The area of 

disturbed land and the area of water 

within the Jackpine Mine Expansion 

LSA have been reversed. 

27 Table 1, presented in Appendix 4-1 

incorrectly presented recharge 

values for the ground moraine or 

glaciolacustrine deposits. 

95 Under the heading 'Calibration 

Results' the sentence reads “The 

PRMA local model was calibrated to 

17 static groundwater levels in the 

surficial aquifers, one static 

groundwater level in the McMurray 

Formation oil sands and eight static 

groundwater levels in the Basal 

Aquifer (Table 10). 

Aquatics ESR 5-209 Table 5.5-12 has a missing footnote 

“(b)” for the cells that were not 

measured 

Aquatics ESR 5-210 The sentence in line one “Water 

temperature and pH…” is incorrect 

This reversal is not an accurate 

reflection of the pre-disturbance 

conditions in the local study area 

(LSA). The baseline disturbed areas 

in the LSA on Table 426-7 should 

read 1,709 ha and the baseline open 

water areas in the LSA should read 

102 ha. For more information please 

see AENV SIR 47a. 

A corrected Table AENV 18-1 shows 

shaded rows that have been 

revised. Please refer to AENV SIR 

18dii for more detailed information. 

it should read "The PRMA local 

model was calibrated to 18 static 

groundwater levels in the surficial 

aquifers, one static groundwater 

level in the McMurray Formation oil 

sands and 16 static groundwater 

levels in the Basal Aquifer (Table 

10)" 

Updated Table 5.5-12 is shown 

below. 

Replace first sentence as “Water 

temperature was suitable for use by 

all fish species; however, pH was 

above the guideline for the 

protection of aquatic life (i.e., > 8.5) 

(Table 5.5-11)”. 


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Section 2.2 


Updated Table 5.5-12: Winter Habitat Conditions at Waterbody Sampling Sites in the 

Eymundson Creek Watershed 

Waterbody 

Unnamed 

Waterbody 5 

Unnamed 

Waterbody 6 

Sampling 

Site (a) Station 

14 

2 

Point or 

Profile 

Ice 

Thickness 

[m] 

Maximum 

Water 

Depth 

[m] 

1 profile 0.45 3.65 

(a) 

See Figure 5.2-2 for sample site locations. 

(b) 

Data not obtained due to equipment malfunction. 

– = Not measured. 

Sample 

Depth 

[m] 

Water Quality Field Parameters 

Temperature 

[°C] 

Dissolved 

Oxygen 

[mg/L] 

Conductivity 

[µS/cm] pH 

0.75 1.4 2.61 – (b) – (b) 

1.20 1.9 2.35 – (b) – (b) 

1.80 2.2 1.87 – (b) – (b) 

2.30 2.3 1.79 – (b) – (b) 

2.80 2.4 1.97 – (b) – (b) 

3.30 2.6 1.83 – (b) – (b) 

3.65 2.8 1.49 – (b) – (b) 

2 point 0.45 4.00 0.75 1.4 2.50 – (b) – (b) 

3 point 0.45 1.60 0.75 0.5 1.65 – (b) – (b) 

4 point 0.45 1.20 0.75 0.5 1.35 – (b) – (b) 

1 point 0.50 0.70 – 0.1 1.66 337 6.95 

2 point 0.50 1.25 0.80 0.8 3.19 479 6.86 

3 point 0.50 1.20 0.80 0.3 3.97 445 6.74 

4 point 0.50 1.20 0.80 1.2 4.03 487 6.37 

Table 18-1: Calibrated Hydraulic Conductivity and Recharge Values in Regional Model 

(Revised) 

Horizontal 

Hydraulic Vertical 

Conductivity Conductivity Recharge 

Material 

[m/s] 

[m/s] [mm/yr] 

Glacial and Glaciolacustrine deposits 1 (east of Athabasca) 5E-7 5E-9 16 

Glacial and Glaciolacustrine deposits 1 (west of Athabasca) 5E-7 5E-9 25 

Glacial and Glaciolacustrine deposits 2 5E-7 5E-9 25 

Ice Contact deposits 1 (west of Jackpine Mine Expansion) 8E-6 8E-8 104 

Ice Contact deposits 2 (east of Jackpine Mine Expansion) 2E-5 2E-7 104 

Outwash Sand 5E-5 5E-6 104 

Aeolian deposits (west of Pierre River Mine) 6E-5 6E-7 157 

Buried channel aquifers 3E-4 3E-6 157 

Clearwater and Grand Rapids formations 1 (Muskeg 

Mountain) 

1E-11 1E-13 – 

Clearwater and Grand Rapids formations 2 (elsewhere) 5E-11 5E-13 – 

McMurray Formation Oil Sands 1 (Muskeg Mountain) 1E-11 1E-13 – 

McMurray Formation Oil Sands 2 (below Clearwater 

elsewhere) 

1E-9 1E-10 – 

McMurray Formation Oil Sands 3 (areas of no Clearwater) 6E-9 6E-10 – 

McMurray Formation Oil Sands 4 (Athabasca River valley) 2E-7 2E-8 – 

McMurray Formation Basal Sands 1 (

Section 2.2 


Table 18-1: Calibrated Hydraulic Conductivity and Recharge Values in Regional Model 

(Revised) (cont’d) 

Horizontal 

Hydraulic Vertical 

Conductivity Conductivity Recharge 

Material 

[m/s] 

[m/s] [mm/yr] 

McMurray Formation Basal Sands 2 (>4 m thickness) 8E-5 8E-6 – 

Waterways Formation 1E-9 1E-11 – 

Prairie Evaporite (salt and anhydrite) 1E-10 1E-11 – 

Methy 1 (lower portion and below Waterways/Clearwater) 5E-8 5E-13 – 

Methy 2 (upper portion in areas of no Waterways/Clearwater) 5E-7 5E-9 – 

Methy 3 (upper portion at Athabasca and Firebag River 

valleys) 

5E-5 5E-7 – 

Sewataken Fault 5E-8 5E-8 – 

– = Not defined. 

References 

Mills, L.S. and F.W. Allendorf 1996. The One-Migrant-per-Generation Rule in 

Conservation and Management. Conservation Biology. 10(6): 1509- 

1518. 

Wang, J. 2004. Application of the One-Migrant-per-Generation Rule to 

Conservation and Management. Conservation Biology. 18(2): 332-343. 


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Section 2.2 



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Volume 1, Section 2, Geology 

ERRATA 

Errata Section 2.3, page 2-17, Tables 2-2 and 2-3 

SUPPLEMENTAL INFORMATION ERRATA 

Section 2.3 

The information provided in the May 2009 Pierre River Mine, Supplemental 

Information, Volume 1, Tables 2-2 and 2-3 was incorrect. 

Correction The correct information is shown here in Table ERCB 8-2. The information has 

been updated according to the updated block modelled geological data and 

revised pit shell design that were used to compile the Project Update. This 

information is also provided in the response to ERCB SIR 8a. 

Resource 

Category 

Total in situ 

resource 

Oil sand at >7% 

bitumen grade 


thickness 

Oil sand at 

TV/BIP < 12 


Volume 

of Oil 

Sand 

(Mm 3 ) 


Grade 

(wt %) 

Bitumen 

(Mm³) 

Bitumen 

(Mbbl) 

Volume 

of Oil 

Sand 

(Mm³) 

Grade 

(wt%) 

Bitumen 

(Mm³) 

Bitumen 

(Mbbl) 

2,169 7.15 321 2,017 1,334 9.11 253 1,591 

1,242 11.32 290 1,827 1,011 11.43 239 1,502 

940 11.63 226 1,421 859 11.60 206 1,294 

Volume 1, Section 10, Mining and Processing SIRs 

Errata Section 10.1, page 10-49, Table 136-2 

The flux and total expected flow data presented in the May 2009 Pierre River 

Mine, Supplemental Information, Volume 1, Table 136-2 were incorrect. The 

flux and total expected flow rows of data were transposed. 

Correction The correct information is shown here in Table ERCB 4-1. This information is 

also provided in the response to ERCB SIR 4a. 


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Section 2.3 

ERRATA SUPPLEMENTAL INFORMATION ERRATA 

Table ERCB 4-1: Internal Drain Flow Estimate 

Approximate Length of 

Perimeter Cell Dykes 

(m) 

Flux 

(m 3 /s/m) 

Total Expected Flow 

(m 3 /d) 

Thickened tailings 5,750 4.12E-05 20,500 

Mature fine tailings 9,000 9.56E-05 74,500 



Total Flow 95,000 

The statement “The top of the ore surface was modified to exclude any ore 

stringers of 3 m or greater that were separated from the main orebody by a waste 

band more than four times as thick” was incorrect. 

Correction The statement should have read “Both the top and bottom of ore surfaces were 

used unaltered to calculate ore volumes.” This information is also provided in 

the response to ERCB SIR 10a. 

Volume 1, Section 10, Mining and Processing 

Errata Section 10.1, page 10-127 and 10-128, Figures 197-1 and 197-2 

The information provided in Figures 197-1 and 197-2 was incorrect. 

Correction The corrected material balance for a typical operating calendar day case has been 

reproduced here as Figure ERCB 25-1. The corrected material balance for a 

typical operating stream day case has been reproduced here as Figure 

ERCB 25-2. 



The thermal requirement and natural gas consumed data presented in Table 199-1 

was incorrect. 

Correction The data should have been identical to that presented in Table 9-2 of the Pierre 

River Mine Project Update. The correct information is shown here in Table 

ERCB 27-1. This information is also provided in the response to ERCB SIR 27a. 


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Section 2.3 


Table ERCB 27-1: Comparison of Thermal Energy Requirements 

Operating Scenario 

Thermal 

Requirement 

(GJ/m 3 ) 

Natural Gas 

Consumed 

(GJ/m 3 ) 

Feed Grade 

(wt% Bitumen) 

Process 

Temperature 

(°C) 

Winter average-grade ore 2.44 0.86 10.9 40 

Winter coarse high-grade ore 2.34 0.97 11.7 40 

Summer low-grade ore 2.10 0.00 10.1 40 

Summer average-grade ore 1.65 0.05 10.9 40 

Summer high-grade ore 1.55 0.13 11.7 40 


Errata Section 10.1, page 10-154 

The statement “Of the 21% mineral solids, about 60% are finer than 44μm.” was 

incorrect. 

Correction The correct value used for the Pierre River Mine is about 50% finer than 44 μm 

which would result in a sands-to-fines ratio (SFR) of 1:1. This information is also 

provided in the response to ERCB SIR 29a. 

Volume 2, Section 23, Terrestrial SIRs 

Errata Section 23.1, page 23-143 

The Albian Sands Mine external tailings containment facility was incorrectly 

referenced instead of Shell’s proposed external tailings disposal area (ETDA). 

Correction The response to May 2009 Pierre River Mine, Supplemental Information, 

Volume 2, SIR 461d should have referenced Shell’s Pierre River Mine ETDA. 

The corrected response to the original question follows. 

In the early stages of ETDA construction and use, mammals, amphibians and 

reptiles are unlikely to interact with the Pierre River Mine external tailings 

disposal area (ETDA) shoreline from surrounding undisturbed areas. Terrestrial 

wildlife will be further discouraged from accessing the Pierre River Mine ETDA 

because the dyke surrounding the ETDA will be about 7 m high before any 

tailings are released. 

As discussed in EIA, Volume 5, Section 7.5.3.2, residual impacts from activities 

associated with the interaction of wildlife with project infrastructure, such as 

mortality associated with the ETDA, after mitigation measures are applied (see 

EIA, Volume 5, Section 7.1.3) are predicted to have a low environmental 

consequence rating for yellow rail and black-throated green warbler, and a 

negligible rating for all other key indicator resources (KIRs), such as Canadian 


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Section 2.3 


toad, barred owl, moose, black bear, Canada lynx, fisher marten and beaver (see 

EIA, Volume 5, Section 7.5.3.2, Table 7.5-36). Interactions with infrastructure 

are reasonably well understood but lack quantification. Therefore, prediction 

confidence was rated as moderate. From 2003 to 2008, the Muskeg River Mine 

recorded 70 avian mortalities because of oiling, averaging 11.6 birds per year. 

Total avian mortalities at the Muskeg River Mine from 2003 to 2008 are 119, 

averaging 19.8 birds per year. Regional environmental consequences at the 

Planned Development Case for interactions with infrastructure are predicted to be 

negligible. Shell is continuing to manage its bird deterrent systems to mitigate the 

effects of the ETDA on birds. 


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Section 2.3 


Figure ERCB 25-1: Pierre River Mine Material Balance – One Train (Calendar Day) 


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Section 2.3 




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PART 2: ERCB SIRS – ROUND 2 

Question No. 1 

GENERAL 

ERCB SIRS 1 – 2 

Request 1 Provide any updates that Shell has to the application, EIA or SEIA. 

Section 3.1 

Response 1 Any additional information pertaining to the Pierre River Mine application and 

supporting documents is contained in the responses to the second round of 

supplemental information requests (SIRs). 


Request Volume 1, Section 7.1, Page 7-1, Supplemental Information Responses. 

Shell states, “The correct proposed boundary is shown in the revised Figure 1- 

2.” In Volume 1, Section 10.1, Page 10-66, Supplemental Information Responses 

Shell states, “Overburden must be removed beyond lease boundaries to achieve 

design wall angles and to expose ore for recovery at the lease boundary.” 

2a Provide a revised project boundary for the Pierre River Mine that justifies the 

size of the boundary based on the needs for the life of the mine. Include the 250 

metre setback from the Athabasca River with the project boundary revision. 

Response 2a As discussed in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, Section 10.1, page 10-66, SIR 147, When an economic bitumen 

resource crosses a lease boundary, Shell designs the pit so that the wall 

intersects the top of the ore at the boundary, to maximize resource recovery from 

the lease. This necessitates removing some overburden from adjacent leases in 

order to achieve design wall angles and expose ore for recovery. This practice is 

typically facilitated through lease boundary agreements between adjacent lease 

holders. Shell is currently in discussion with its adjacent lease holders to ensure 

that resource recovery is maximized for both parties, and fully expects lease 

boundary agreements to be in place before operations start. If any of the adjacent 

lease holdings revert back to the Crown, then Shell would make the appropriate 

regulatory applications. 


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GENERAL ERCB SIRS 1 – 2 

Request 2b When will Shell apply for a revised lease boundary? 

Response 2b Application for a revised project boundary is not required. 

Section 3.1 


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MINING AND PROCESSING 


Section 4.1 

Request Provide a preliminary assessment of the setback distance for the North 

Overburden Disposal Area from the Lease boundary with UTS Energy (Lease 

14). Use the available geological information and consider the open pit on the 

UTS side. 

Response 3 The Pierre River Mine Plan was developed to maximize ore recovery on Oil 

Sands Lease (OSL) 740012009 (Lease 9). Consequently, most (60%) of the north 

overburden disposal area is built in-pit after the ore has been mined out. 

Additionally, in designing the north overburden disposal area, the available 

storage space within the external outline of the dump was balanced with the 

mining volume required to advance the mining sufficiently to enable the north 

overburden disposal area to be extended in-pit. 

Current mine plans show that the north overburden disposal area is offset 100 m 

from the UTS/Teck OSL 014 (Lease 14) boundary, with a portion of the north 

overburden disposal area initially being built on oil sands that are less than 12 

TV:BIP. Based on Shell’s interpretation of the geology, a narrow ore band under 

the dump in Lease 9 continues into UTS/Teck Lease 14 (see Figure ERCB 3-1). 

As UTS/Teck has not publicly disclosed mine plans for Lease 14, Shell 

considered two alternatives to provide a preliminary assessment of the setback 

distance from the north overburden disposal area to the UTS/Teck Lease 14 

boundary: 

1. Maintain the current design of the north overburden disposal area, i.e., 

100 m from UTS/Teck Lease 14 in the Pierre River Mine Plan 

2. Move the toe of the north overburden disposal area south to accommodate 

an open-pit mine on the UTS/Teck side of the lease 

The first alternative might result in sterilizing the UTS/Teck resource. This is 

calculated based on a narrow strip (less than 750 m) of mineable oil sands located 

north of the north overburden disposal area (see Figure ERCB 3-1). Here, an 

estimated location of the ultimate mine crest from the UTS/Teck lease line has 

been calculated and constrained within the resource delineated by the TV:BIP 12 

limit. Shell also assumed a typical geotechnical design setback from the external 

dump toe to a pit crest would be 150 m. 


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MINING AND PROCESSING ERCB SIRS 3 – 38 

Figure ERCB 3-1: Potential Sterilization Area 

Section 4.1 


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TV:BIP 

Cut-off 

Section 4.1 

Therefore, the potential UTS/Teck resource sterilization for TV:BIP 12 has been 

calculated between the estimated pit crest required to recover ore to the lease 

boundary and the design setback from the north overburden disposal area, and is 

summarized in Table ERCB 3-1. 

Table ERCB 3-1: Potential for UTS/Teck Resource Sterilization 

Ore 

(Mt) 

Overburden 

and 

Interburden 

(Mbcm) 

Diluted Ore 

Grade 

(wt%) 

Bitumen in 

Place 

(Mm³) 

TV/BIP 

(bcm/m³) 

12 3.97 3.32 12.18 0.49 10.6 1.74 


Strip Ratio 

(m³/m³) 

The second alternative is the potential for increased offset of the Pierre River 

Mine north overburden disposal area to accommodate an open pit on the 

UTS/Teck side of the lease. This scenario would require an additional 50 m 

offset of the Pierre River Mine north overburden disposal area from the lease 

boundary over a length of about 1,125 m. The additional offset would decrease 

the north overburden capacity by 8.44 Mbcm or about 8% of the total design 

capacity. However, during the first three years of operation, i.e., before in-pit 

space becomes available, the lost dump area would need to be added onto the 

south side of the dump by adjusting the opening sequence in the mine. Therefore, 

about the same sterilization (0.49 Mm 3 ) incurred on UTS/Teck Lease 14 in this 

scenario would be incurred on Shell’s Lease 9. 

Shell and UTS/Teck have had preliminary discussions on developing an 

agreement on the boundary issues. These discussions are ongoing and Shell fully 

expects them to be successfully completed before development begins on either 

side of UTS/Teck Lease 14 or Shell’s Lease 9. 


Table 136-2 presents the internal drain flow estimates. 

4a Review the information in the “Total Expected Flow” column in Table 136-2 

and resubmit the results. 

Response 4a The flux and total expected flow data presented in the May 2009 Pierre River 

Mine, Supplemental Information, Volume 1, Table 136-2, was incorrect. The 

flux and total expected flow rows of data were transposed. The correct 

information is presented in Table ERCB 4-1 and also provided in Section 2.3, 

Supplemental Information Errata. 


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Table ERCB 4-1: Internal Drain Flow Estimate 

Approximate Length of 

Perimeter Cell Dykes 

(m) 

Flux 

(m 3 /s/m) 

Section 4.1 

Total Expected Flow 

(m 3 /d) 

Thickened tailings 5,750 4.12E-05 20,500 

Mature fine tailings 9,000 9.56E-05 74,500 

Total Flow 95,000 

Request 4b Discuss the estimated seepage volume in cubic metre/day/metre (m 3 /day/m) by 

comparison to the seepage volume (m 3 /day/m) at the External Tailings Facility 

(ETF) in the Muskeg River Mine. 

Response 4b A comparison of the estimated seepage flux in cubic metre/day/metre (m 3 /d/m) at 

the external tailings disposal area (ETDA) in the Muskeg River Mine and the 

Pierre River Mine is presented in Table ERCB 4-2. 

The Pierre River Mine theoretical flows are higher than those measured at the 

Muskeg River Mine. This is expected, as the EIA predictions are based on 

conservative assumptions that frequently over-predict actual values. Differences 

in flux below the ETDAs at the Pierre River Mine and Muskeg River Mine result 

from the following factors: 

• the design basis of the Pierre River Mine flows assumed the pond to be at full 

height, or about 45 m above original ground, whereas the Muskeg River 

Mine pond is at a lower average elevation of 25 m above original ground, 

over the 2006 to 2009 time frame that seepage flows were collected 

• the theoretical flux from the Pierre River Mine is based on steady-state 

assumptions, whereas the Muskeg River Mine has likely not reached this 

state 

Table ERCB 4-2: Comparison of Pierre River Mine Estimated Seepage Flux and Measured 

Seepage Flux at the Muskeg River Mine External Tailings Disposal Area 


Pierre River Mine 

Theoretical Flux 

(m 3 /d/m) 

Muskeg River Mine 

Measured Flux 

(m 3 /d/m) 

Thickened tailings 3.6 0.5 

Mature fine tailings 8.3 1.2 

Request Provide the 3-D DXF electronic files for the top of the McMurray and the top of 

the Devonian surfaces for the proposed project area. 


CR029


Section 4.1 

Response 5 Shell will provide dxf files on CD to the ERCB under separate cover for review. 

Surface elevation contours will show the top of the McMurray and Devonian 

formations. Each formation will have two files – contours with annotations and 

closed contours only. 


Request Provide the entire drilling database (i.e. collar and assay files), in text format, 

used to build the resource model in the Project Update. 

Response 6 The requested information has been provided to the ERCB through the well 

licensing process. On February 24, 2010, the ERCB confirmed that the 

information is in its data set. 


Request Provide a hard copy of the updated TV/BIP contour map of an appropriate scale 

covering the Pierre River Mine project area. Include the Final Pit Limits (toe 

and crest), the UWI (or hole ID) and TV/BIP value posted beside each model 

drill hole in NAD 1983. 

Response 7 Two paper copies of the updated TV/BIP contour map, along with the 

corresponding electronic files of these maps, are being provided to the ERCB 

under separate cover. 


Request Volume 1, Section 2.2, Pages 2-11, 2-17 to 2-18, Tables 2-1, 2-2 & 2-3, 

Supplemental Information Responses; Volume 2, Section 4.2, Page 4-13, Table 

4-2. 

When comparing Tables 2-2 and 2-3 from the Update to Table 4-2 from the 

original application, there has been a significant increase in resource in the 

Lease 9 Area and a significant decrease in resource in the Lease 9 Pit Area. 

Table 2-1 indicates that no additional drilling was done in the Lease 9 area in 

2007-2008 drilling season. 

8a Provide the factors that contributed to the change in resource estimation for the 

Lease 9 Area and Lease 9 Pit Area. 


CR029


Section 4.1 

Response 8a In the original application, Volume 2, Project Description, Table 4-2, as well as 

in the May 2009 Pierre River Mine, Supplemental Information, Volume 1, Tables 

2-2 and 2-3, incorrect information was provided. This revised data is presented in 

Tables ERCB 8-1 and ERCB 8-2 and is also provided in Section 2, Errata. 

Resource 

Category 

Total in situ 

resource 

Ore at >7% 

bitumen grade 


thickness 

Ore at 

TV/BIP < 12 

Resource 

Category 

Total in situ 

resource 

Oil sand at >7% 

bitumen grade 


thickness 

Oil sand at 

TV/BIP < 12 

Table 4-2 has been updated according to the block modelled geology data and pit 

shell design that were used in the Project Description, and is shown here as Table 

ERCB 8-1. 


Volume 

of Ore 

(Mm 3 ) 


Grade 

(wt%) 

Bitumen 

(Mm³) 

Bitumen 

(Mbbl) 

Volume 

of Ore 

(Mm³) 

Grade 

(wt%) 

Bitumen 

(Mm³) 

Bitumen 

(Mbbl) 

2,347 7.58 368 2,312 1.423 9.74 286 1,800 

1,346 11.03 307 1,930 1,116 11.22 259 1,627 

846 11.24 196 1,235 791 11.28 184 1,158 

Tables 2-2 and 2-3 have been updated according to the updated block modelled 

geology data and revised pit shell design that were used in the May 2009 Pierre 

River Mine, Supplemental Information, Volume 1, and are shown here as Table 

ERCB 8-2. 


Volume 

of Oil 

sand 

(Mm 3 ) 


Grade 

(wt%) 

Bitumen 

(Mm³) 

Bitumen 

(Mbbl) 

Volume 

of Oil 

sand 

(Mm³) 

Grade 

(wt%) 

Bitumen 

(Mm³) 

Bitumen 

(Mbbl) 

2,169 7.15 321 2,017 1,334 9.11 253 1,591 

1,242 11.32 290 1,827 1,011 11.43 239 1,502 

940 11.63 226 1,421 859 11.60 206 1,294 

Request 8b Based on the new resource information found in Tables 2-2 and 2-3, update the 

following original application tables: 

• Table 5-4 in Section 5.4 




CR029


Section 4.1 

Response 8b As noted in the response to ERCB SIR 8a, Tables 2.2 and 2.3 have been revised 

and the revised information represents overall block model quantities and is not 

representative of mineable quantities. The update of mineable quantities is 

presented in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, Section 3.1, Table 3-1. 


The mine production schedule was not updated because of the minor changes to 

mineable quantities, i.e., less than 5% over the project life, detailed in the May 

2009 Pierre River Mine, Supplemental Information, Volume 1, Section 3.1, 

Table 3-1. As a result, the production details have not been updated for 

Volume 2, Project Description, Section 5.4, Table 5-4. 

The mine production schedule and waste material balance was not updated for 

the Project Update because of the minor changes in mine quantities described in 

the May 2009 Pierre River Mine, Supplemental Information, Volume 1, 

Section 3. Therefore, there is no new data available to update Volume 2, Project 

Description, Section 5.5, Table 5-8 and Section 5.6, Table 5-9. 

Request Volume 1, Section 3.1, Page 3-1, Table 3-1, Supplemental Information 

Responses; Volume 1, Section 2.2, Page 2-18, Table 2-3, Supplemental 

Information Responses. 

Table 3-1 compares the Pierre River Mine Project pit attributes and area 

between the Project Update and the original application. 

9a How is the “Final Bitumen Product” in Table 3-1 calculated from Bitumen in 

Place? 

Response 9a Final bitumen product is calculated by applying the design plant recovery to the 

mined ore quantity. For a description of the calculation for recoverable bitumen, 

see the response to SIR 150a in the May 2009 Pierre River Mine, Supplemental 

Information, Volume 1, Section 10.1. 

Request 9b What is the difference between “Bitumen in Place” in Table 3-1 and the “Total 

In Situ Resource” bitumen volume in Table 2-3? 

Response 9b The bitumen in place in Table 3-1 refers to the raw bitumen within the design 

mine pit that meets the minimum mineable criteria, as outlined in ERCB Interim 

Directive 2001-07. The total in situ resource in Table 2-3 refers to all bitumen 

that is located within the areal extent of the mine pit, i.e., no minimum mineable 

criteria. 


CR029



Section 4.1 

Request Volume 1, Section 10.1, Page 10-66, Supplemental Information Responses; 

Volume 1, Section 3.1, Page 3-1, Table 3-1, Supplemental Information 

Responses. 

Shell states, “The top of the ore surface was modified to exclude any ore 

stringers of 3 m or greater that were separated from the main orebody by a waste 

band more than four times as thick.” 

10a Is the resource in the 3 m or greater ore stringers included in the ore volume 

tabulated in Table 3-1? 

Response 10a The statement “The top of the ore surface was modified to exclude any ore 

stringers of 3 m or greater that were separated from the main ore body by a 

waste band more than four times as thick” was incorrect. The statement should 

have read “Both the top and bottom of ore surfaces were used unaltered to 

calculate ore volumes.” The resources tabulated in Table 3-1 include all 

resources within the lease area located below the topographic surface. For 

additional information, see Section 2.3, Supplemental Information Errata. 

Request 10b What is the quantity and grade of resource in the 3 m or greater ore stringers? 

Response 10b This question is no longer applicable. See the response to ERCB SIR 10a. 

Request 10c What contingency will Shell use to offset the loss of the resource associated with 

not recovering the 3 m or greater ore stringers? 

Response 10c This question is no longer applicable. See the response to ERCB SIR 10a. 




Information Responses; Volume 1, Section 2.2, Page 2-18, Table 2-3, 

Supplemental Information Responses. 

11a Discuss the differences between “In Situ Bitumen” for TV/BIP Cut-off equal to 

12 in Table 148-1, “Bitumen” volume for “Ore at TV/BIP ≤ 12” in Table 2-3 

and “Revised” bitumen volume for “Bitumen in Place” in Table 3-1. 


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Section 4.1 

Response 11a The quantities in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, Table 3-1 and Table 148-1 are not generated using the same 

assumptions or mine pit design. Table 148-1 summarizes the ore quantities from 

within mine pits limited by the respective TV/BIP cut-offs, as requested in SIR 

148b. Table 3-1 summarizes ore quantities for the Project Update mine pit, which 

includes all TV/BIP≤12 resource as well as marginal resource areas, as described 

in the May 2009 Pierre River Mine, Supplemental Information, Volume 1, 

Section 3.1. 

The quantities in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, Table 2-3 were incorrect, and have been updated in the response to 

ERCB SIR 8, and are also provided in Section 2.3, Supplemental Information 

Errata. In ERCB Table 8-2, the bitumen volume for oil sand ore at >7% bitumen 

grade and minimum 3 m thickness in the Lease 9 Pit Area is identical to the 

revised bitumen in place in the May 2009 Pierre River Mine, Supplemental 

Information, Volume 1, Table 3-1. 

Request 11b Discuss the differences between “Recovered Bitumen” volume for TV/BIP Cutoff 

equal to 12 in Table 148-1 and “Revised” bitumen volume for “Final bitumen 

product” in Table 3-1. 

Response 11b The quantities in Table 3-1 and Table 148-1 are not generated from the same 

mine pit design. For a description of the difference between the stated resources, 

see the response to ERCB SIR 11a. 



Volume 1, Section 10.1, Page 10-86, Supplemental Information Responses. 

Shell states, “This execution plan relies on a series of successive smaller 

investments, consisting of selective equipment additions and modifications in the 

following areas: 

• Jackpine mining equipment additions 

• Jackpine extraction facilities 

• Muskeg River Mine froth treatment and utilities” 

12a Provide a summary of the selective equipment additions and modifications for 

each area and an updated schedule showing proposed investment stages. 

Response 12a The statement cited was intended to point out that although Shell is adjusting to 

the current economic environment by making a series of smaller investments, the 

overall scope of the application did not change. Therefore, no new equipment or 

modifications from that described in the Jackpine Mine Expansion Application 


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Jackpine Mine 

Production Production Thousand bbl/cd 

350 

300 

250 

200 

150 

100 

50 

0 

2009 

Section 4.1 

and Project Update are contemplated. The timing of these equipment additions 

was originally described in the December 2009 Jackpine Mine Expansion, 

Supplemental Information, Volume 1, SIR 134 and is reproduced here. 

The overall development strategy and plan for Shell’s Jackpine Mine and Pierre 

River Mine was outlined in the December 2009 Jackpine Mine Expansion, 

Supplemental Information, Volume 1, Section 1.2, Overview. The following 

represents Shell’s current estimated schedule, based on regulatory approval being 

granted before 2011. 

First oil production from the Jackpine Mine – Phase 1 is expected in 2010 and 

will increase over time up to 15,900 m 3 /cd (100,000 bbl/cd). Additional bitumen 

production capacity from staged development could start as early as 2014, 

increasing as additional mining and extraction equipment is added. First oil 

production from the third extraction train is not expected until 2017, with full 

production expected by 2020 (see Figure ERCB 12-1). 

2010 

2011 

Muskeg River Mine 


Jackpine Mine – Phase 1 

Train 1 

Train 2 

Design and 

Construction 

2012 

2013 

2014 

Train 2 

Train 3 

Design and 

Construction 


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2015 

Year 

2016 

2017 

Jackpine Mine Expansion 

Train 3 

Figure ERCB 12-1: Jackpine Mine Development 

An investment decision has yet to be taken to expand the mining and extraction 

facilities of the Muskeg River Mine beyond the current capacity of 23,850 m 3 /cd 

(150,000 bbl/cd). Further expansion of the Muskeg River Mine will be dependent 

on the investment factors outlined in the Jackpine Mine Expansion Project 

Update, Section 1.2, Project Development Update, and the future operating 

performance of the Jackpine Mine and Muskeg River Mine. 

The Pierre River Mine is expected to produce first oil in 2018, with full 

production from the first train achieved around 2021 (see Figure ERCB 12-2). 

The timing of design and construction activities has yet to be determined. 

2018 

2019 

2020 

2021


Production Thousand bbl/cd 

250 

200 

150 

100 

50 

0 

2009 

2010 

2011 

2012 

Pierre River 

Design and Access Construction 

2013 

2014 

2015 

Section 4.1 


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2016 

Year 

2017 

2018 

2019 

Train 1 

Figure ERCB 12-2: Pierre River Mine Development 

2020 

2021 

Train 2 

Request 12b Clarify if Shell is applying for approval of these additions and modifications as 

part of this application. 

Response 12b Yes. 



Responses. 

Waste Type 

Shell states, “The AER cogeneration unit waste volumes have been updated to 

reflect the latest information available.” Below is a comparison of the updated 

waste tonnages from Table 4-1 and those identified in the initial application in 

Volume 2, Section 11.2, Page 11-6, Table 11-3. Both are based on annual waste 

generated at 31,800 m3/cd (200,000 bbl/d) production. 

Initial application (Dec 2007) 

Unit (Tonnes) 

Flue gas desulphurization solids 350,000 495,000 

Bottom ash 50,000 70,000 

Fly ash 185,000 265,000 

2022 

2023 

Updated application (May 2009) Unit 

(Tonnes) 

13a Provide an explanation for the increase in waste tonnage from the original 

application to the updated application. 

Response 13a Several scenarios were run with different combustion processes and fuel 

characteristics for the original application. When the application was prepared,


Section 4.1 

the waste volumes presented did not correspond to the boiler size and the 

technology selected. This was an error in compiling the data for the application. 

Request 13b Explain any impacts to the EIA based on the higher waste tonnage. 

Response 13b The higher waste tonnage does not affect the EIA. The asphaltene energy 

recovery (AER) cogeneration waste will be stored in one of two Class II landfills 

at the Pierre River Mine (see the May 2009 Pierre River Mine, Supplemental 

Information, Volume 1, Section 4.2, Waste Management), which were sized to 

accept the updated waste volumes. The Class II landfills are located within the 

boundaries of the proposed Pierre River Mine development area, which was 

assessed in the EIA. The landfill will be located with the project’s closed-circuit 

system for process-affected waters and will be constructed and operated based on 

best management practices to minimize air and aquatic emissions. Therefore, the 

impacts from the landfill are expected to be negligible and do not affect the 

findings of the EIA. 

Request 13c Update the EIA to reflect the larger waste volumes and emissions. 

Response 13c See the response to ERCB SIR 13b. 

Request 13d Provide a summary of the environmental measures and controls that will be 

included in the design to minimize emissions. 

Response 13d The asphaltene-fired cogeneration plant will include the following environmental 

control units: 


• selective catalytic reduction 

• limestone handling and preparation 

• a mercury control system 

• a baghouse 

• wet flue gas desulphurization (FGD) and wet electrostatic precipitator (ESP) 

• solid waste handling systems 

For a summary of each of these units, see the Pierre River Mine Project 

Description, Volume 2, Section 8.2, Electrical Power. 


Shell states, “Shell does not plan to have a permanent ore stockpile within the 

project area. However, during the commissioning of the mine, an ore stockpile 


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Section 4.1 

will be required for the ore removed before the plant start-up. Stockpiled ore 

will be blended into the extraction plant during early production.” 

14a For the temporary ore stockpile, provide a table that includes on an annual 

basis: 

i tonnes of ore moved to the temporary stockpile, 

ii. expected grade of the stockpiled ore, and 

iii. tonnes of ore processed from the temporary stockpile. 

Response 14a Details of the commissioning plan have not yet been finalized. The requirements 

for a temporary ore stockpile will be detailed when the opening mine cut is 

designed during commissioning planning and will be provided as part of the 

ERCB annual mine plans. 



Responses. 

Shell notes in Table 159-1 that the Solvent Loss based on TSRU only for 2003 

was 10.6 Vol solvent /kvol Bitumen. Information provided in the Muskeg River 

Mine Expansion supplementary information responses submitted in April, 2006 

indicated that the annual average solvent losses for 2003 were greater than 17 

volumes of solvent per 1000 volumes of bitumen produced. 

15a Clarify and provide the correct volumes of solvent losses per thousand volumes 

of bitumen production for 2003. 

Response 15a The solvent losses shown in Table 159-1 are correct. The differences referred to 

are the result of changes in the calculation method requested by the ERCB during 

the Muskeg River Mine Expansion approval. In 2003, the ERCB’s definition of 

solvent loss was based on the tailings solvent recovery unit (TSRU) losses only. 

In 2006, the Muskeg River Mine approval was amended to define solvent losses 

to include vapour recovery unit losses. In 2003, there were substantial vapour 

losses, primarily to flare, which resulted in greater than 17 vol/kvol solvent loss. 

Request 15b Based on the solvent losses summary in Table 159-1, it is acknowledged that 

Muskeg River Mine has experienced difficulties achieving ERCB solvent losses 

per bitumen production requirements since start-up. Shell is requesting approval 

to construct and operate a similar tailings solvent recovery unit (TSRU) for the 

Pierre River Mine Project. Justify the approval of similar design concepts in the 


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Section 4.1 

Pierre River Mine Application in light of Muskeg River Mine’s challenges in 

meeting existing approval conditions with a similar design. 

Response 15b As outlined in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, SIR 159, several improvements have been made to the Muskeg River 

Mine process in recent years to significantly improve solvent losses and achieve 

regulatory compliance. These improvements will be applied to future designs, 

including the Muskeg River Mine Expansion TRSU process starting up in 2010. 

Shell is confident that, as design and operational experience grows, the Pierre 

River Mine solvent losses will meet the current 4 vol/kvol requirement. 



Shell describes their development and investment philosophy. In Volume 1, 

Section 1.2, Page 1-7, Supplemental Information Responses. Shell states, 

“Although the overall scope of Shell’s development plans for the Pierre River 

Mine and the Jackpine Mine Expansion remain unchanged, the timing of the 

execution of certain approved Jackpine Mine and Muskeg River Mine facilities 

has required some adjustment.” 

16a Provide an updated integrated schedule for Jackpine Mine (JPM) Phase-1, 

Muskeg River Mine (MRM) debottlenecking, Muskeg River Mine Expansion 

(MRME), Jackpine Mine Expansion (JPME), and Pierre River Mine (PRM) 

projects that includes production capacity, timelines for construction, 

commissioning, and start-up. 

Response 16a For the requested information, see the response to ERCB SIR 12. 

Request 16b If an integrated schedule is not available, when will Shell commit to providing an 

integrated schedule for JPM Phase-1, MRM debottlenecking, MRME, JPME, and 

PRM projects that includes production capacity, timelines for construction, 

commissioning, and start-up? 

Response 16b Shell will provide updates to its plans for the Muskeg River Mine and Jackpine 

Mine as part of the annual reporting to the Board, or when changes to the design 

or operations scope necessitate the filing for amendments to the existing 

approvals. 


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Section 4.1 


Shell states, “Shell is applying for both natural gas and asphaltene fuel 

cogeneration to supply steam and power for the mine.” In Volume 1, Section 

10.1, Page 10-106, Supplemental Information Responses, Shell states, “The 

decision on when to build the asphaltene recovery plant depends on many 

factors, including prevailing market conditions, joint venture partners’ financial 

approval and regulatory conditions.” 

17a Is Shell applying for approval to build both a natural gas and asphaltene 

cogeneration system? 

Response 17a Yes, Shell is applying to build one asphaltene-fired cogeneration unit and one 

natural-gas-fired cogeneration unit. However, asphaltene energy recovery (AER) 

technology is still under development and must meet Shell’s investment criteria 

(see the May 2009 Pierre River Mine, Supplemental Information, Volume 1, 

Section 1, Overview, page 1-8) before proceeding to design and construction. If 

AER does not meet Shell’s investment criteria, then Shell will seek approval to 

build two natural-gas fired cogeneration units. An assessment of the alternative 

two natural-gas-fired cogeneration units was included in the EIA. 

Request 17b Verify that Shell is committing to building both a natural gas and asphaltene 

cogeneration system. 

Response 17b See the response to ERCB SIR 17a. 



Shell states, “Greenhouse gas emissions are expected to be higher with AER 

cogeneration than with natural gas as combustion.” 

18a Provide a summary of the measures and controls that Shell will implement to 

minimize greenhouse gas emissions for both asphaltene energy recovery (AER) 

cogeneration and natural gas units. 

Response 18a Shell is designing adequate plot space for both the natural-gas-fired cogeneration 

unit and the AER cogeneration unit to be retrofitted for carbon capture 

technology if this becomes a viable option in the future. 


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Section 4.1 

In addition, Shell expects that future energy reductions (and subsequent 

greenhouse gas reductions) will occur as experience from current and future 

operations are incorporated into the Pierre River Mine design. 

Request 18b Clarify Shell’s commitment to use the best available technology to minimize 

greenhouse gas emissions for both AER cogeneration and natural gas units. 

Response 18b Shell will comply with applicable policy and regulations for greenhouse gas 

emissions. 


Request Volume 1, Section 10.1, Page 10-91 to 10-92, Tables 166-1 and 166-2, 

Supplemental Information Responses. 

Table 166-1 provides a summary of monthly bitumen recovery with oil sands 

grade greater than 11%. Based on this table, on a monthly basis, Shell has 

exceeded 90% target recovery for 13 months out of 46 months. Table 166-2 

provides a summary of annual bitumen recovery. Based on this table submitted 

for 2003-2008, Shell had not achieved the bitumen recovery as required under 

ERCB ID 2001-7 Operating Criteria: Resource Recovery Requirements for Oil 

Sands Mine and Processing Plant Sites. 

19a Past performance shows that Shell has experienced challenges meeting bitumen 

recovery requirements. Explain how Shell will meet the required bitumen 

recovery to satisfy ERCB ID 2001-7. 

Response 19a The response to the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, SIR 166f, as well as the response to the December 2009 Jackpine 

Mine Expansion, Supplemental Information SIR 137h, highlight improvements 

to the original Muskeg River Mine design curve regarding bitumen recovery. 

Shell will incorporate improvements currently being made at the Muskeg River 

Mine, as well as those included in the new Jackpine Mine design to help improve 

bitumen recovery performance for all oil sand grades. The knowledge gained 

from these two operations will be used to improve the performance of the Pierre 

River Mine facilities. 

As stated in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, SIR 166f: 

Shell has taken several initiatives at the Muskeg River Mine regarding the initial 

design, with the objective of improving bitumen recovery, including: 

• adding sodium citrate to increase bitumen recovery. Sodium citrate is 

currently used at the Muskeg River Mine. The use of a chemical additive, 


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such as sodium citrate, will be considered at the Pierre River Mine, to 

improve recovery performance. 

Section 4.1 

• adjusting the hydrotransport temperature. The hydrotransport temperature is 

a critical variable affecting bitumen recovery. The current understanding 

indicates that a hydrotransport slurry temperature of 40 to 45°C is the 

optimum range, particularly for lower grade ore. 

• implementing bitumen recovery from the thickener. Bitumen recovery has 

been implemented on one train and might be implemented in future 

expansions. Alternatively, the upstream recovery equipment might be made 

more efficient. 

Depending on the operating conditions at the Pierre River Mine, some or all of 

these improvements might be implemented, as necessary. 

In addition, the response to the December 2009 Jackpine Mine Expansion, 

Supplemental Information, SIR 137h stated that: 

The Jackpine Mine Expansion project team will consider current Muskeg River 

Mine operations and build on the lessons learned from that development. 

In addition to the items listed in SIR 137f and SIR 137g, the Jackpine Mine 

design already includes several improvements over the Muskeg River Mine 

design, including: 

• a longer conditioning pipeline 

• reduced solids loading in the primary separation cell 

• primary separation cell design improvements, including improved feed 

distribution and froth underwash 

• increased flotation capacity 

All of these changes are expected to improve bitumen recovery. The effectiveness 

of the improvements will be evaluated once the Jackpine Mine is operational, 

and they will be considered, as needed, for the Jackpine Mine Expansion. 

Request 19b It is acknowledged that Muskeg River Mine has experienced difficulties achieving 

ERCB bitumen recovery requirements since start-up. Justify the design proposed 

in this application in light of Muskeg River Mine’s shortfalls in meeting existing 

bitumen recovery requirements. 

Response 19b Shell’s understanding of the technical and operational performance of bitumen 

extraction has increased significantly since the original Muskeg River Mine 

design. Shell is continuing to improve the Muskeg River Mine performance as 

well as including a number of design improvements in the Jackpine Mine. 


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Recovery (%) 

Section 4.1 

Additional operational improvements gathered from these two facilities will be 

considered in the Pierre River Mine design. 

Measuring small changes to the calculated annual bitumen recovery is a slow 

process. Recent changes made to the Muskeg River Mine operation are starting 

to show some improvement (see Figure ERCB 19-1) and Shell expects that this 

improvement will continue in 2010 as additional bitumen recovery improvement 

initiatives are implemented, such as a new PSC feed well and adjusting pH on the 

slurry line. 

90 

85 

80 

75 

70 

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

Month 

Required Actual 

Figure ERCB 19-1: Average Monthly Bitumen Recovery and Improvement Required 


Request Volume 1, Section 10.1, Page.10-96, Supplemental Information Responses. 

Shell states “Generally, the higher grade ores are associated with higher than 

average recovery, and produce froth with lower water content. Bitumen recovery 

at these higher rates and higher grades were within expectations.” Table 167-2 

indicates that an overall recovery of greater than 90% was achieved for 7 out of 

16 days based on the data provided. 

20a Explain what Shell considers “within expectations” for bitumen recovery as 

mentioned above. 

Response 20a The statement cited was part of a larger response in reference to the impact of 

higher rates on recovery. The data shown in the May 2009 Pierre River Mine, 

Supplemental Information, Volume 1, SIR 167 was used to indicate that, during 

that time period, recoveries at high rates were as good or better than average 

performance. 


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Section 4.1 

Request 20b Clarify if Shell’s bitumen recovery expectations are aligned with ERCB ID 2001- 

7 requirements. 

Response 20b Shell’s expectations for bitumen recovery are that, on an annual basis, the 

requirements of ID 2001-7 will be met. This is based on operational 

improvements achieved to date at the Muskeg River Mine and further design 

improvements, which have been incorporated into the current Jackpine Mine. 



Shell states, “Asphaltene rejection is about 10 wt% of the bitumen production.” 

21a Clarify Shell’s commitment to limiting asphaltene rejection to 10 weight per cent 

based on bitumen production. 

Response 21a The current design basis for the high-temperature froth treatment process is to 

reject less than 10 wt% asphaltene based on bitumen production. The asphaltene 

rejection level is a balance between upstream bitumen recovery and final bitumen 

quality. Lower asphaltene rejection rates favour higher bitumen recoveries but 

lower bitumen quality, whereas increased asphaltene rejection rates favour the 

application of technologies for asphaltene energy recovery (AER) and further 

upgrading at the AOSP Scotford Upgrader. This balance of adding value to the 

bitumen resource can and does shift over time, so that Shell cannot make a firm 

commitment on the level of asphaltene rejection. 



Shell states, “The diluted bitumen and solvent storage tanks are not connected to 

the vapour recovery system.” 

22a Clarify if the diluted bitumen and solvent storage tanks are fixed roof or floating 

roof tanks. 

Response 22a The diluted bitumen and solvent storage tanks are internal floating roof tanks. 

Request 22b Clarify if the diluted bitumen and solvent storage tanks are connected to any 

blanket system. 


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Section 4.1 

Response 22b The diluted bitumen and solvent storage tanks are not connected to any blanket 

system. 

Request 22c Clarify the typical and all alternate routings for the vapours from the diluted 

bitumen and solvent storage tanks. 

Response 22c As stated in the EIA, all above-ground storage tanks are designed to conform to 

the Canadian Council of Ministers of the Environment guidelines for Controlling 

Emissions of Volatile Organic Compounds from Aboveground Storage Tanks, 

1995. The floating roofs of both types of storage tanks are equipped with seals to 

minimize fugitive emissions. 


Request Volume 1, Section 10.1, Page 10-123, Figure 193-1, Supplemental Information 



Figure 193-1 indicates that bitumen recovery requirements will not be met for oil 

sand grades less than approximately 10.8% wt bitumen. Table 197-1 indicates 

that bitumen recovery requirements will not be met for each balance case. 

23a For areas on the curve where the bitumen recovery requirements as set out in 

ERCB ID 2001-7 are not met, explain the steps Shell will take to meet the 

requirements. 

Response 23a All of the initiatives listed in the following will improve bitumen recovery. 

However, the effectiveness of each initiative will vary with ore type, and benefits 

may overlap, making it difficult to attribute particular portions of recovery 

improvement to a particular initiative. As more experience is gained across a 

wider range of feed grades, a new design curve is expected to be derived. 

As stated in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, SIR 166f: 

Shell has taken several initiatives at the Muskeg River Mine regarding the initial 

design, with the objective of improving bitumen recovery, including: 

• adding sodium citrate to increase bitumen recovery through increased 

bitumen concentration in the primary settling vessel froth. The use of a 

chemical additive, such as sodium citrate, will be considered at the Pierre 

River Mine, to improve recovery performance. 

• adjusting the hydrotransport temperature. The hydrotransport temperature is 

a critical variable affecting bitumen recovery. The current operational 


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Section 4.1 

experience indicates an optimal range of hydrotransport slurry temperature 

between 40 to 45°C, particularly for lower grade ore. 

• implementing bitumen recovery from the thickener. Bitumen recovery has 

been implemented from a thickener on one extraction process train. 

Depending on the operating conditions at the Pierre River Mine, some or all of 

these improvements might be implemented, as necessary. 

In addition, the response to the December 2009 Jackpine Mine Expansion, 

Supplemental Information, SIR 137h stated that: 

The Jackpine Mine Expansion project team will consider current Muskeg River 

Mine operations and build on the lessons learned from that development. 

In addition to the items listed in SIR 137f and SIR 137g, the Jackpine Mine 

design already includes several improvements over the Muskeg River Mine 

design, including: 

• a longer conditioning pipeline 

• reduced solids loading in the primary separation cell 

• primary separation cell design improvements, including improved feed 

distribution and froth underwash 

• increased flotation capacity 

All of these changes are expected to improve bitumen recovery. The effectiveness 

of the improvements will be evaluated once the Jackpine Mine is operational, 

and they will be considered, as needed, for the Jackpine Mine Expansion. 

Request 23b Clarify Shell’s commitment to meet ERCB ID 2001-7 bitumen recovery 

requirements for all grades. 

Response 23b As stated in ERCB SIR 25, corrected site-wide material balances have been 

calculated for average feed grade on a calendar and stream day basis. Based on 

this new information, the comparison of design bitumen recovery to ERCB ID 

2001-7 presented in Table 197-1 of the May 2009 Pierre River Mine, 

Supplemental Information, Volume 1, Section 10.1, has been updated and is 

shown here as Table ERCB 23-1. 

Table ERCB 23-1: Bitumen Recovery Comparison 

Calculated Ore Calculated 

Grade 

Recovery ERCB ID 2001-7 

Basis 

(% Bitumen) 

(%) 

(%) 

Calendar day 10.9 90 90 

Stream day 10.9 90 90 


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Section 4.1 

Shell is confident that the steps outlined in the response to ERCB SIR 23a will 

result in continued recovery improvement toward meeting the requirements of 

ID-2001-7 on an annual basis. 


Shell states, “The densities used in these material balances are solvent = 650 

kg/m3 whole bitumen = 1,000 kg/m3 asphaltene = 1.050 kg/m3.” 

24a The densities used in these material balances are not consistent with the densities 

used at Muskeg River Mine. Clarify the difference in densities. 

Response 24a The densities used in the application are design values, not actuals. The design 

values were selected to support equipment sizing. For design purposes, these 

values are not significantly different from the actual values used for reporting 

purposes for the Muskeg River Mine i.e., Muskeg River Mine whole bitumen = 

1,007 kg/m 3 and solvent density = 657 kg/m 3 . Any consequences resulting from 

the differences between the actual values and design values are well within 

normal design margins. 

Request 24b Provide the density for the final bitumen product. 

Response 24b The final bitumen density (de-asphaltened bitumen) is 995 kg/m 3 . 


Request Volume 1, Section 7.1, Pages 7-11 and 7-12, Figures 9-1 and 9-2, 

Supplemental Information Responses; Volume 1, Section 10.1, Pages 10-127 

and 10-128, Figure 197-1 and 197-2, Supplemental Information Responses. 

The following clarifications are required in regards to the provided site-wide 

material balances: 

25a Provide corrected material balances on the calendar day basis for: 

i Deaeration and Froth Screening: Solids balance 

ii. Froth Treatment: Solids balance, Solvent balance 

iii. Tailings Solvent Recovery Unit: Solvent balance 

iv. Asphaltene Recovery Unit: Water balance, maltene balance, asphaltene 

balance, solids balance 


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Section 4.1 

Response 25a The corrected material balance for a typical operating calendar day case is shown 

in Figure ERCB 25-1 and is also provided in Section 2.3, Supplemental 

Information Errata. 

Request 25b Provide corrected material balances for the stream day basis for: 

i. Asphaltene Recovery Unit: Maltene balance, asphaltene balance, solids 

balance, solvent balance 

Response 25b The corrected material balance for a typical operating stream day case is shown 

in Figure ERCB 25-2. The correct information is also provided in Section 2.3, 

Supplemental Information Errata. 



Table 197-2 and Table 197-3 show the solvent losses from the TSRU unit only. 

26a Provide an updated table that includes site-wide solvent losses from all sources 

including flared losses, tank losses, etc. 

Response 26a Most of the solvent losses are from the TSRU tailings. The design basis for the 

Pierre River Mine is that there will be no solvent flaring. Other losses, such as 

tank losses, are relatively minor compared to the solvent loss in the TRSU 

tailings. The expected emission rate from the solvent tank is only 2,060 kg/a. 

Table 197-2 and 197-3 have been updated to reflect solvent losses from other 

sources, and are reproduced here as Table ERCB 26-1 and ERCB 26-2. 

Table ERCB 26-1: Solvent Loss for Material Balances with Asphaltene Recovery Unit 

Solvent Solvent Recovered 

Loss in Asphaltene Tank Losses 

Bitumen (TSRU) Recovery Unit Plus Other Solvent Loss per 

Basis (t/h) (t/h) 

(t/h) 

(t/h) 1,000 Volumes 

Calendar day 1,362 3.26 0.67 0.03 2.96 

Stream day 

Note: 

1,656 3.96 0.81 0.03 2.95 

specific gravity of solvent = 0.65 

specific gravity of bitumen = 1.0 

solvent loss per 1,000 volumes = (total solvent loss – AER solvent recovery) X 1000 

(solvent SAG * bitumen) 


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Section 4.1 



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Section 4.1 



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Section 4.1 

Table ERCB 26-2: Solvent Loss for Material Balances Without Asphaltene Recovery Unit 

Solvent Loss Tank losses plus 

Bitumen (TSRU) 

other Solvent Loss per 

Basis (t/h) 

(t/h) 

(t/h) 

1,000 Volumes 

Calendar day 1,362 3.26 0.03 3.72 

Stream day 1,656 3.96 0.03 3.71 

Note: 

specific gravity of solvent =0.65 

specific gravity of bitumen = 1.0 

solvent loss per 1,000 volumes = (total solvent loss) X 1000 

(solvent SAG * bitumen) 

Request 26b Update the table to include solvent losses and bitumen production on a 

volumetric basis. 

Response 26b Table ERCB 26-3 and ERCB 26-4 provide volumetric data for site-wide solvent 

loss for each material balance case with and without the asphaltene recovery unit. 

Table ERCB 26-3: Solvent Loss for Material Balances with Asphaltene Recovery Unit 

(Volumetric) 

Basis 

Bitumen 

m 3 Solvent 

Loss 

/h 

(TSRU) 

m 3 Solvent Recovered 

in Asphaltene 

/h 

Recovery Unit 

m 3 Tank Losses 

/h 

Plus Other 

m 3 /h 

Solvent Loss per 

1,000 Volumes 

Calendar day 1,362 5.02 1.03 0.047 2.96 

Stream day 1,656 6.09 1.25 0.047 2.95 

Note: 

solvent loss per 1,000 volumes = (total solvent loss – AER solvent recovery) X 1000 

(bitumen) 

Table ERCB 26-4: Solvent Loss for Material Balances Without Asphaltene Recovery Unit 

(Volumetric) 

Basis 

Bitumen 

m 3 Solvent Loss 

/h 

(TSRU) 

m 3 Tank Losses 

/h 

Plus Other 

m 3 /h 

Solvent Loss per 

1,000 Volumes 

Calendar day 1,362 5.02 0.047 3.72 

Stream day 1,656 6.09 0.047 3.71 

Note: 

solvent loss per 1,000 volumes = (total solvent loss) X 1000 

(bitumen) 


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Section 4.1 


Responses; Volume 1, Section 10.1, Page 10-130, Figure 198-1, Supplemental 


Table 199-1 and Figure 198-1 show different values for natural gas consumed 

for summer low-grade ore, summer average-grade ore, and summer high-grade 

ore. 

27a Explain the difference between the natural gas requirements identified in Figure 

198-1 and Table 199-1. 

Response 27a The thermal requirement and natural gas consumed data presented in Table 199-1 

was incorrect. The data should have been identical to that presented in Table 9-2 

in the May 2009 Pierre River Mine, Supplemental Information, Volume 1. The 

corrected table has been reproduced here as Table ERCB 27-1 and is also 

provided in Section 2.3, Supplemental Information Errata. 


Thermal 


Requirement 

(GJ/m 3 Natural Gas 

) 

Consumed 

(GJ/m 3 Process 

) 

Feed Grade 

(wt% Bitumen) 

Temperature 

(°C) 






There is still a difference between Figure 198-1 and Table ERCB 27-1. 

Table ERCB 27-1 includes total natural gas consumed, including gas consumed 

by the combustion turbine, the duct burner and the auxiliary boilers. Although 

Table ERCB 27-1 shows the total thermal energy required to heat process water 

and to create process steam, the natural gas consumption is only for the gas 

directly fired, i.e, the natural gas routed to the duct burner and the auxiliary 

boilers. The natural gas routed to the cogeneration unit is not included. 

If the energy recovered from the gas-fired cogeneration plant that is used for 

steam generation were associated with its equivalent natural gas consumption, 

the thermal energy requirements would appear as shown in Table ERCB 27-2. 


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Thermal 

Requirement 

(GJ/m 3 ) 

Natural Gas 

Consumed 

(GJ/m 3 ) 

Feed Grade 

(wt% Bitumen) 

Process 

Temperature 

(°C) 







Section 4.1 


Shell states, “Details of the commissioning and start-up plan for the Pierre River 

Mine ore preparation, primary extraction, froth treatment plants, and asphaltene 

recovery unit have not yet been developed.” 

28a Clarify Shell’s commitment to provide a commissioning and start-up plan to the 

ERCB for review and approval one year prior to the start of commissioning. 

Response 28a A commissioning and start-up plan for the Pierre River Mine will be provided to 

the ERCB for review and approval one year before commissioning starts. 


Request Volume 1, Section 10.1, Page 10-154 and 10-168, Supplemental Information 

Responses. 

Shell states, “Of the 21% mineral solids, about 60% are finer than 44μm.” Table 

218-5 on Page 10-168 presents the Sand-to-Fines Ratios (SFR) of different 

tailings streams. The SFR for the TSRU tailings stream is shown as 1.1:1. 

29a Explain the discrepancy in the fines content of the TSRU. 

Response 29a The statement “Of the 21% mineral solids, about 60% are finer than 44μm.” in 

the May 2009 Pierre River Mine, Supplemental Information, Volume 1, Section 

10.1, page 10-154, was incorrect (see also Section 2.3, Supplemental Information 

Errata). The correct value used for the Pierre River Mine is about 50% finer than 

44 μm, which would result in a sands-to-fines ratio (SFR) of 1:1. The SFR of the 

tailings solvent recovery unit (TSRU) stream of 1.1:1 shown in Table 218-5 of 


10.1, is an estimated SFR based on the general geology at the Pierre River Mine, 

and is used for tailings planning. 


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Section 4.1 




Table 3-1 indicates that revised data of Ore is 2,102 Mt. In Table 218-4, the 

sand, fines, bitumen and water from extraction sum to 2,263.8 Mt. 

30a Confirm the updated total ore tonnage. Update Table 3-1 or Table 218-4 

according to the latest information. 

Response 30a The mine quantities stated in the May 2009 Pierre River Mine, Supplemental 

Information, were updated to reflect the revised pit limits and updated block 

model. However, the mine production schedule and integrated tailings plan were 

not revised because of the small (5%) change in total mine volumes. Table 3-1 

(see the May 2009 Pierre River Mine, Supplemental Information, Volume 1) 

provided a comparison of the revised ore tonnage to the ore tonnage in the 

December 2007 application. 

Table 218-4 in the response to SIR 218 provided additional details on the tailings 

schedule submitted with the December 2007 Pierre River Mine, Project 

Description, Volume 2. Therefore, it cannot be reconciled with the total mine 

quantities from the May 2009 Pierre River Mine, Supplemental Information. The 

extraction ore properties provided in Table 218-4 excludes breaker rejects. 

Therefore, the breaker reject tonnage of 86 Mt must be added to the extraction 

ore tonnes to reconcile with the 2,349 Mt of total ore reported in the Pierre River 

Mine Project Description. 

Request 30b Update the following tables: 

i. Table 218-3: Supplemental Information Responses 

ii. Table 7-5: Volume 2 of the Pierre River Mine Application 

iii. Table 7-7: Volume 2 of the Pierre River Mine Application 

iv. Table 7-8: Volume 2 of the Pierre River Mine Application 

Response 30b The data was not re-calculated because the mine production schedule and 

integrated tailings plan were not updated for the Project Update, as stated in the 

response to ERCB SIR 30a. 

The general mine scheme and sequence of the development will be maintained. 


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Section 4.1 

Request Volume 1, Section 4.1, Page 4-1 to 4-3, Supplemental Information Responses. 

Shell states, “This update identifies the methodology and techniques that will be 

applied to ensure that the Pierre River Mine development complies with ERCB 

Directive 074.” 

31a Update Table 7-2: Volume 2 of the Pierre River Mine Application, according to 

the tailings management plan described in Section 4.1. 

Response 31a Table 7-2 in Volume 2, Section 7 of the Pierre River Mine application, outlines 

the tailings activity sequence. The sequence is a general list of activities for 

external and in-pit tailings disposal. The operating dates for the external tailings 

disposal area (ETDA) will not change in relation to current Directive 074 

compliance planning. Consistent with the Jackpine Mine, Pierre River Mine will 

use an external tailings disposal area with a thickened tailings cell for about 10 

years after start-up. When sufficient space is mined in-pit, non-segregating 

tailings (NST) deposition will begin. 


As outlined in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, Section 4.1, page 4-1, Shell intends to meet the objectives of ERCB 

Directive 074 by enhancing the tailings plan outlined in the application with one, 

or a combination of, the following: 

• applying the appropriate thickener design 

• using coagulants 

• potentially recycling thin fine tailings (TFT) to a supplemental thickening 

process 

The strategy implemented at the Pierre River Mine will be based on experience 

gained from the Jackpine Mine and other industry applications at existing mines. 

The Jackpine Mine ETDA will be commissioned in 2010 in conjunction with a 

thickened tailings dedicated disposal area (DDA). Experience gained at the 

Jackpine Mine in technology development and tailings operations and 

management will be considered at the Pierre River Mine to meet the objectives of 

ERCB Directive 074. 

Request Volume 2, Section 3.2, Page 3-11. 

Shell states, “In 2006 and 2007, under 100 auger holes were initiated to evaluate 

OB.” In Volume 1, Section 10.1, Page 10-165, Supplemental Information 

Responses, Shell states, “Pierre River Mine planning considered 75% of the 

overburden and interburden material to be acceptable dyke construction 


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Section 4.1 

material. Of this 75%, the overall use of available dyke construction material 

throughout the life of the mine is 40%.......Pre-stripping of overburden is 

advanced in the production schedule in years when there is an insufficient 

quantity of construction material available to meet the dyke placement 

requirement.” 

32a Explain how Shell determined the 75% value for construction quality overburden 

and interburden. 

Response 32a The approximate construction material availability and capture rates from 

existing operations were applied to the Pierre River Mine planning parameters. 

Detailed material properties for the Pierre River Mine overburden and 

interburden have not yet been consolidated. 

Request 32b What is Shell’s plan to further evaluate and update the assumptions of the 

amount of construction quality overburden and interburden material? 

Response 32b Shell will collect similar geotechnical data and conduct similar testing programs 

for the Pierre River Mine as those employed at the Muskeg River Mine and the 

Jackpine Mine. Data collection will focus on material samples collected from 

exploration programs, including detailed geotechnical laboratory testing for such 

properties as moisture, density, direct shear and triaxial shear. 

Request 32c Overburden pre-stripping does not increase construction quality overburden and 

interburden availability over the life of the project. If construction quality 

overburden and interburden estimates are lower, what is Shell’s contingency 

plan for dyke construction? 

Response 32c To clarify the availability and usage of overburden and interburden materials at 

Pierre River Mine: 

• the Pierre River Mine production schedule includes 1,127.8 Mbcm of total 

overburden and interburden waste over the mine life 

• an estimated 75% (780.1 Mbcm) of the total overburden and interburden 

waste is considered suitable in situ construction material 

• an estimated 80% (627.9 Mbcm) of the suitable in situ construction material 

is considered recoverable by mine operations 

• only 49% (310.1 Mbcm) of the recoverable construction material is 

scheduled for placement as suitable material in engineered structures. 

Therefore, 51% of the identified recoverable construction material remains as 

contingency. 


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Section 4.1 

• prestripping is used to increase construction quality overburden by advancing 

the mining of suitable material during specific periods when there is a 

construction material shortfall 

The design philosophy for all engineered structures is to maximize the use of 

available materials from the mine by tailoring construction material 

specifications for the structure to match the mine materials available. Therefore, 

the primary contingency for a construction material shortfall is to re-design the 

engineered structure and the associated material specifications to use as much of 

the available materials as possible. 

Request 32d Discuss its impact on the tailings management plan, including impact on nonsegregating 

tailings (NST) production, fines capture and mature fine tailings 

(MFT) inventory. 

Response 32d The contingency scenario where dyke structures are re-designed to optimize 

material use would result in increased material quantities being placed in the 

dykes, resulting in a revision to the integrated mine and tailings plan to 

accommodate the adjusted material placement schedule. 


Adjustments to the design of engineered structures and the waste material 

movement schedule are not expected to affect NST production, fines capture or 

MFT inventory. 


Shell states, “During operation of the ETDA (from 2018 to 2028), the TT will be 

contained in a discrete cell within the ETDA, built using coarse tailings sand. 

The TT cell within the ETDA will act as a designated disposal area for the 

thickened tailings deposit.” In Volume 1, Section 10.1, Page 10-168, Table 219- 

1, Supplemental Information Responses; it is indicated that the slurry density was 

lower than 1400 kg/m3 (46% solids) more than a third of the time. Also, in 

Volume 1, Section 10.1, Page 10-144, Supplemental Information Responses, 

Shell states, “The timing required to make the TT deposits trafficable is 

uncertain, as no full-scale stand-alone thickened tailings deposit has yet been 

created, capped and made ready for reclamation in oil sands industry. However, 

Shell understands the Directive’s requirement to have dedicated disposal areas 

capped and ready for reclamation within five years after deposition activities 

stop. Shell is evaluating, as a high priority, the means to shorten the time 

required to make TT deposits ready for reclamation at the Muskeg River Mine 

tailings test facility.” 


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Section 4.1 

33a Based on the updated Table 218-4, what is the annual percentage of fines in Ore 

Feed captured in thickened tailings (TT) deposit, i.e. excluding the thin fine 

tailings (TFT) formed from TT stream, during 2018-2028? 

Response 33a The fines captured in the TT deposit in the Pierre River Mine tailings plan are 

summarized in Table ERCB 33-1. As shown in Table ERCB 33-1, the fines 

capture averages 40% between 2018 and 2028. 

Period 

Table ERCB 33-1: Fines Capture in the Pierre River Mine ETDA TT Deposit 

Total Ore 

(t) 

Extraction Ore Feed Thickened Tailings Deposit (3) 

Course 

(t) (1) 

Fines 

(t) (2) 

Fines 

wt% 

Mineral 

Course 

(t) (1) 

Fines 

(t) (2) 

Fines 

(% of 

Extraction 

Fines) 

2018 5.98 4.16 0.85 16.9 1.95 0.38 44.7 

2019 19.02 13.22 2.69 16.9 0.93 1.03 38.5 

2020 54.59 37.96 7.73 16.9 2.66 2.97 38.5 

2021 66.51 46.44 9.45 16.9 4.43 3.67 38.9 

2022 75.97 53.12 10.82 16.9 5.05 4.20 38.9 

2023 114.51 79.80 16.24 16.9 10.61 6.41 39.5 

2024 117.65 82.18 16.73 16.9 10.64 6.59 39.4 

2025 109.68 76.19 15.51 16.9 9.34 6.09 39.3 

2026 116.61 81.63 16.62 16.9 9.21 6.50 39.1 

2027 116.08 81.03 16.50 16.9 7.67 6.41 38.8 

2028 108.91 75.45 15.36 16.9 23.56 6.49 42.3 

Total 905.51 631.18 128.49 16.9 86.05 50.76 39.5 

Note: 

1. Coarse refers to all mineral consisting of particle size greater than 44µm. 

2. Fines refers to all mineral consisting of particle size less than 44µm. 

3. Thickened tailings deposit includes all thickener underflow captured in the beach (excluding thin fine tailings 

runoff), as well as all cyclone underflow “lost” from cell construction on the centreline dyke and captured in the 

beach. 

Request 33b Is the annual percentage lower or higher than 50%? If lower, what constraints 

limit Shell’s ability to capture a minimum of 50% fines in feed in the TT deposit 

between 2018 and 2028? 

Response 33b The level of fines capture in thickened tailings deposits is currently constrained 

by Shell’s understanding of the capabilities of this technology. Shell recognizes 

that, at this stage, this level of fines capture, in isolation, will not meet the 

requirements of Directive 074. Therefore, in order to meet the 50% capture 

required, Shell will use supplementary technologies, such as: 

• applying the appropriate thickener design 


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• using coagulants 

• potentially recycling TFT to a supplemental thickening process 

Section 4.1 

The type and extent of supplementary technology employed at the Pierre River 

Mine will be based on the experience gained through commercial operations at 

the Muskeg River and Jackpine mines. Shell expects that these operations will 

comply with Directive 074 before the Pierre River Mine starts up. Shell is 

confident that, although some of the details of the Pierre River Mine plan still 

need to be determined, the knowledge gained at its existing operations will allow 

the Pierre River mine to meet the objectives of Directive 074. 

Request 33c What is Shell’s plan to meet the requirement of fines capture as specified in 

ERCB Directive 074: Tailings Performance Criteria and Requirements for Oil 

Sands Schemes, i.e., minimum 50% of fines in feed? 

Response 33c See the response to ERCB SIR 33b. 

Request 33d Discuss how Shell will measure the fines captured in the TT deposit and the 

strength of the deposit. 

Response 33d The techniques and procedures for measuring fines capture and deposit strength 

will be based on the Jackpine Mine Fines Measurement Plan, which is currently 

being developed. The Pierre River Mine Fines Measurement Plan will be 

submitted in conjunction with the Annual Compliance Report by September 30 

of the year before tailings deposition starts, as outlined in ERCB Directive 074: 

Tailings Performance Criteria and Requirements for Oil Sands Schemes Section 

4.4. 

Request 33e Clarify Shell’s commitment to meet the requirements of ERCB Directive 074. 

Response 33e Shell is committed to meeting the objectives of ERCB Directive 074 and will 

continue to work with the ERCB to ensure that the appropriate technology is 

successfully implemented to achieve the required targets and timelines. 



Shell states, “In 2029, the first mined pit area will be available to receive 

tailings……Non-segregating tailings will be made by combining a portion of the 

TT stream with the cyclone underflow stream and gypsum to produce a slurry 

with a sand-to-fines ratio of 5:1. The remaining TT will be disposed of in a 

separate in-pit cell (DDA). Thin fine tailings will be removed continually from 


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Section 4.1 

the active non-segregating tailings designated disposal area by pumping to the 

in-pit clarification cell.” In Volume 1, Section 10.1, Page 10-168, Table 218-5, 

Supplemental Information Responses, Shell states, “Sand to fines ratio is 6.7:1 

for Non-segregating tailings.” 

34a What are the constraints that will prevent Shell from starting NST production 

before 2029? 

Response 34a The Pierre River Mine has been designed to store tailings on start-up in an 

external tailings disposal area (ETDA). The ETDA has been designed to provide 

sufficient space to store tailings volumes until in-pit storage space is available. 

Volume Volume (Mbcm) (Mbcm) 

v 

V 

o 

L 

u 

m 

e 

M 

b 

c 

m 

Initially, the ETDA containment dykes will be constructed exclusively from 

overburden and mine waste material. Once operations start, course sand from 

extraction, together with mine waste, will be used to construct the ETDA dykes. 

Figure ERCB 34-1 is a conceptual example of the approximate requirement for 

EDTA construction material versus the amount of construction material available 

by year. The figure also illustrates the availability of construction material if NST 

production were initiated at the beginning of the project. 

If NST production were to start earlier than 2029, the course sand used to 

produce NST would not be available for ETDA construction. This material 

shortage would impede ETDA dyke construction resulting in insufficient tailings 

storage capacity. 

v 

Years 

Years 

Cumulative Cumulative Construction Construction Material Material Available Available (mine waste and coarse sand tailings) 

NST Cumulative Construction Material Available 

Cumulative Cumulative Construction Construction Material Required Available (mine waste only, coarse sand tailings 

used for NST) 

v 

Cumulative Construction Material Required for Tailings Containment 

Figure ERCB 34-1: Conceptual ETDA Construction Material Requirement 


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Section 4.1 

NST produced at start-up, before in-pit storage is available, would require aboveground 

containment structures. These structures might result in areas of ore 

sterilization. Furthermore, the use of overburden to construct NST storage at 

start-up would consume construction material required to build in-pit dykes and 

delay construction of in-pit storage. 

The plan to start NST production in 2029 is based on this balance between fluid 

generation, material balances and the availability of in-pit storage space. 

Request 34b What steps does Shell plan to take to diminish these constraints? 

Response 34b As new information becomes available and engineering constraints change, Shell 

will review its mine plans with the intent of advancing NST production and 

accelerating reclamation. Currently, the first opportunity to begin NST 

production is 2029. 

Request 34c Confirm the sand to fines ratio listed for NST. 

Response 34c The May 2009 Pierre River Mine, Supplemental Information, Volume 1, Section 

4.1, page 4-2, refers to the NST as produced from the tailings processing facility 

(SFR44 = 5:1). This ratio, which represents the limit of current pumping 

capability, is different from the sand to fines ratio of the orebody (SFR44 = 6.7:1). 

This is because coarse sand is bypassed around the NST process and placed 

concurrently within the NST deposit. 

The May 2009 Pierre River Mine, Supplemental Information, Volume 1, Section 

10.1, Table 218-5, lists the sand to fines ratio of the NST deposit as deposited, 

and matches the SFR of the orebody. 

Request 34d Discuss how Shell will measure the fines captured in the NST deposit and the 

strength of the deposit. 

Response 34d Shell will collect samples of the NST in the DDA from multiple locations on an 

annual basis. The samples will be analyzed to determine solids content and the 

percentage of fine minerals solids that are finer than 44 μm. This information 

will be used to determine total NST inventory, including density, total mass of 

solids and total mass of mineral solids finer than 44 μm. The strength of the NST 

deposit will be determined using cone or ball penetrometer results from annual 

DDA surveys. 

Request 34e What is Shell’s mitigation strategy if fines captured in NST deposit are lower 

than targeted? 


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Section 4.1 

Response 34e If fines captured in the NST are lower than targeted, a number of options may be 

evaluated to address the potentially reduced fines sequestration, including: 


• amending NST production and placement practices to enhance fines capture 

• marginal increases in fines content of the NST slurry delivered to the DDA 

for deposition to accommodate for fines losses during deposition (i.e. 

overshoot fines target) 

• supplemental offsets using alternative technologies, such as atmospheric 

fines drying of MFT or thickened tailings deposits 


Shell states, “non-segregating tailings deposits will be managed to meet the 

requirements of ERCB Directive 074, i.e., NST deposits will be targeted to have a 

minimum undrained shear strength of 5 kPa for the material deposited in the 

previous year, and they will be ready for reclamation within five years after 

active deposition has stopped. The planning basis for final NST deposits will be 

to have the strength, stability and structure necessary to establish a trafficable 

surface with minimum undrained shear strength of 10 kPa for the surface layer.” 

35a Elaborate on Shell’s plan to manage the NST deposit to comply with ERCB 

Directive 074. 

Response 35a Shell’s plan to manage the NST deposit to comply with ERCB Directive 074 is 

based on its current understanding of the technology derived from field-scale 

NST performance tests at its Muskeg River Mine tailings test facility. These tests 

also form the basis for the tailings management plans filed in accordance with 

Directive 074 for the Muskeg River Mine and the Jackpine Mine. Shell expects 

that commercial-scale demonstration of these field-scale predictions will be 

available before the Pierre River Mine NST operations start up, and that this 

commercial experience will be incorporated into the Pierre River Mine design. 

Request 35b What is the contingency plan if non-segregating tailings deposits do not comply 

with ERCB Directive 074? 

Response 35b Shell is confident that the non-segregating tailings deposits will meet the 

objectives of Directive 074, i.e. will meet the strength criteria, reduce fluid fine 

tailings production, and produce trafficable deposits. See the response to 

ERCB SIR 34e for contingencies if fines capture falls below target. If the NST 

deposit has a lower undrained shear strength than predicted, adaptive measures 

will be taken to enhance the rate of excess pore-pressure dissipation, such as 


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Section 4.1 

enhanced drainage, i.e., wick drains, and measures to stabilize the upper surface 

of the deposit through the placement of capping material. 


Responses, indicates that TT, TSRU and NST occur within in-pit cells. Also, in 

Volume 1, Section 10.1, Page 10-156, Supplemental Information Responses, 

Shell states “If concurrent deposition of NST and TSRU is not feasible, the TSRU 

tailings will be deposited and managed in the fine solids settling areas.” 

36a Will TT and/or TSRU be co-disposed with NST in the in-pit cells? If yes, does 

Shell consider in-pit cells as dedicated disposal areas (DDAs)? Elaborate on the 

rationale. If not, update Table 218-4 to be consistent with the statement. 

Response 36a As discussed in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, SIR 216, the tailings deposition plan calls for the concurrent 

deposition of non-segregating tailings (NST) and TSRU tailings into the 

deposition cells. Deposition will be primarily: 

• subaerial for the NST tailings 

• subaqueous for the TSRU tailings 

The introduction of a small percentage of TSRU tailings into a localized area of 

the NST deposit (i.e., runoff collection area) will not compromise the NST 

deposit performance and the in-pit cells will serve the function of DDAs. 

Request 36b How will co-disposing TSRU tailings impact the NST deposit performance? 

Explain. 

Response 36b The TSRU tailings will be deposited in the NST runoff collection pool at the toe 

of the subaerial NST deposit. Coarse hydrocarbon and mineral solids will settle 

out rapidly and be incorporated into the NST deposit, while some fine mineral 

solids and water will be released into the water column and transferred with NST 

deposit runoff as thin fine tailings (TFT) to clarification cells. Most of the fine 

solids will be transferred with runoff from the NST deposit to MFT holding 

ponds. Therefore, NST performance is not expected to be affected. 


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Section 4.1 


Shell states, “If asphaltene recovery operations are not initiated, the TSRU 

tailings will be incorporated into fluid fine tailings mixes. Some of these fluid 

fines tailings will be incorporated into NST and some will be stored in water 

capped mature fine tailings (MFT) end-pit lakes.” In Volume 1, Section 10.1, 

Page 10-136, Supplemental Information Responses, Shell states, “The TSRU 

tailings will be deposited at least 3 m below the water table in the ETDA.” 

37a Provide the reasons why asphaltene recovery operation may not be initiated. 

Response 37a The decision on whether or not to initiate asphaltene energy recovery (AER) will 

be based on the value assessment framework that Shell uses to test the viability 

of a development project proposal against changes in the investment climate over 

time. As discussed in the May 2009 Pierre River Mine, Supplemental 

Information, Volume 1, Section 1, Overview, page 1-8, this assessment considers 

the following factors: 

• technical 

• economic 

• commercial 

• operational 

• regulatory 

This decision will balance the various risks associated with the investment. If any 

of these risks are considered unacceptable, then asphaltene energy recovery 

would not be initiated. 

Request 37b Provide the technical and economic analysis of asphaltene recovery of TSRU 

tailings; elaborate on the issues Shell has with asphaltene recovery. 

Response 37b As described in the response to ERCB SIR 17, Shell is still in the process of 

developing AER technology as part of a full technical and economic evaluation 

of the project. This is not done in isolation, but in the context of the overall 

project during detailed engineering. 

Request 37c Discuss the impact on the asphaltene recoverability if TSRU tailings are mixed 

into fluid fine tailings. 

Response 37c Once TSRU tailings are mixed into fluid fine tailings, subsequent separation for 

asphaltene recoverability would be difficult because of the nature of this finely 

dispersed multi-phase mixture. 


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Request 37d Does Shell plan to deposit TSRU tailings separately? Discuss the option of 

depositing TSRU tailings separately. 

Section 4.1 

Response 37d Shell is not planning to deposit TSRU tailings separately because of the 

additional cost and the increased environmental footprint that would result from 

segregation. 



Shell states, “The application case shows a total of 251.1 Mm 3 of MFT, whereas 

the no-NST case results in a total of 300.2 Mm 3 of MFT, a net increase of 

49.1 Mm 3 of MFT over the final 12 years from 2028 to 2039.” 

38a What is the volume of MFT generated per volume of bitumen production? 

Response 38a The Pierre River Mine will produce 196 Mm 3 of recovered bitumen product (see 


3.1, Table 3-1). The estimated production of mature fine tailings (MFT) is 

251.1 Mm 3 . Therefore, the ratio of MFT to recovered bitumen is 1.28 m 3 

MFT/recovered bitumen m 3 . 

Request 38b What constraints will prevent Shell from minimizing the fluid tailings volume? 

Response 38b Shell’s principal constraint in minimizing fluid tailings volume is the availability 

of commercially proven technology. Shell believes that the tailings management 

plan outlined in the Pierre River Mine Application presents a balance between 

minimizing fluid tailings and the limits of current technology. 

Request 38c What is Shell’s plan to decrease the volume of MFT per volume of bitumen 

production? What is the target? 

Response 38c Shell’s estimate of the volume of MFT generated at the Pierre River Mine is 

based on the original project application and subsequent updates. Although the 

MFT to bitumen ratio is expected to improve as experience from the Jackpine 

Mine operation are incorporated into the detailed design, at this point in the 

project development, it is difficult to make informed projections or set targets in 

this regard. 


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NOISE 

ERCB SIR 39 

Section 5.1 


Shell states, “During detailed design, a noise management plan will be 

developed for the project. The plan will follow the requirements under Section 

5.1 of ERCB Directive 038. The program will incorporate commitments made in 

the EIA, plans for assessment updates or monitoring, as appropriate, and ERCB 

requirements for stakeholder involvement in the plan development.” “Shell will 

develop the project’s noise management plan, but the ERCB will have an 

opportunity to provide input to the plan.” “The plan is expected to be developed 

after detailed engineering and the associated noise control design work has been 

completed, before the start of construction. This will allow the plan to focus on 

sources of potential concern and on receptors that might be potentially affected.” 

39a Confirm Shells commitment to provide a revised noise impact assessment (NIA) 

to the ERCB based upon the detailed engineering design and associated noise 

control design work to verify compliance with ERCB Directive 038: Noise 

Control. This revised NIA would be included in the development of a noise 

management plan. 

Response 39a Shell will complete an update to the Noise Impact Assessment (NIA) at the 

completion of the detailed design process in order to verify compliance with 

ERCB Directive 038: Noise Control. The revised NIA would become part of the 

operations noise management plan for the project. 

Request 39b Confirm that the noise management plan will be submitted for ERCB review and 

approval as per Section 5.1.1 of ERCB Directive 038. 

Response 39b Shell will submit a draft of the plan for ERCB review and comment before this 

plan is implemented. 

Request 39c Identify the anticipated timeline (e.g. Q1 2010) for providing the revised NIA and 

proposed noise management plan to the ERCB. 


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NOISE ERCB SIR 39 

Section 5.1 

Response 39c The plan is expected to be developed after detailed engineering and the 

associated noise control design work has been completed, before the start of 

construction. This will allow the plan to focus on sources of potential concern 

and on receptors that might be potentially affected. Given current plans, the 

anticipated timeline for completion of the updated Noise Impact Assessment and 

the draft Noise Management Plan is two years prior to start up of operations. 


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AIR 


Section 6.1 


In relation to redundant SO2 pollution control equipment Shell states,“The 

current design has an estimated component availability of above 99%.” 

40a Provide the overall annual Wet Flue Gas Desulphurizer (WFGD) unit 

availability when all the component availabilities are factored in. 

Response 40a Each section of the wet flue gas desulphurizer (WFGD) includes spare major 

equipment that is critical to ensuring sustained operation of the unit. Sparing the 

critical equipment results in a high on-stream factor for the WFGD. The current 

design has an estimated component availability of above 99%. The overall 

WFGD on-stream availability is expected to be at least the same. 

Request 40b Discuss implications to the air assessment if the availability is less than 99%. 

Response 40b EIA, Volume 3, Appendix 3-8, Section 4.3, provides the air quality and health 

risk assessment for an upset scenario in which the asphaltene-fired cogeneration 

unit pollution control equipment malfunctions. Additional information on this 

scenario is also provided in the response to SIR 250 in the May 2009 Pierre River 

Mine, Supplemental Information, Volume 2, Section 20. 

In summary, the predicted maximum 1-hour sulphur dioxide (SO2) 

concentrations for this upset scenario are greater than the Alberta Ambient Air 

Quality Objective (AAAQO) of 450 µg/m³. The likelihood of exceeding the 

AAAQO outside developed areas during an event is 3.8%. This does not take 

into account the likelihood of the event actually occurring. The maximum 

predicted 1-hour SO2 concentrations are above the AAAQO at Cabins H and K 

with a likelihood of exceedance of 0.07% and 0.06%, respectively. While these 

concentrations are high and could result in adverse health effects, the likelihood 

of this upset event occurring is low, as Shell has committed to redundant SO2 

pollution control equipment. In addition, the duration of these impacts is 

expected to be brief, because if the pollution control equipment were to fail, 

operations personnel would react quickly and switch the fuel for the asphaltenefired 

cogeneration unit to natural gas within 15 minutes. 


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AIR ERCB SIRS 40 – 45 


Section 6.1 


Shell states, “A cold period is when additional thermal energy is required to 

provide heat inputs to oil sands feed and recycle water. Typically, this additional 

thermal energy will be provided by the co-generation units. However, during 

extreme winter conditions, or if there is capacity constraints as a result of 

undefined downtime of the co-generation unit, then one or more of the auxiliary 

boilers will be brought into service. Currently, historical data is not available to 

determine how frequently this backup heat generation will be required. Some of 

the main factors that define the cold period (or winter conditions) are: 

• oils sands feed temperatures being below 0°C 

• raw water and reclaim water makeup at, or below, 2°C 

• recycle pond temperatures below 5°C” 

41a Provide a discussion whereby Shell utilizes historical temperature records and 

its experience at the Muskeg River Mine and Jackpine Mine Phase-1 operations. 

Provide a conservative estimate for how often on an annual basis the main 

factors described above would be met. 

Response 41a In the EIA and in the May 2008 EIA Update, Shell conducted an air quality 

assessment, which reflected the continuous air emissions expected for both the 

Pierre River Mine and the Jackpine Mine Expansion projects. Shell premised the 

air quality assessment on the intermittent use of auxiliary boilers to supplement 

heat during cold periods. This premise has raised concerns that the air quality 

assessment for the projects might not be conservative if Shell is required to fire 

its auxiliary boilers more than currently expected. 

To provide assurance that potential air quality effects resulting from the projects 

are not understated, Shell is providing an air quality assessment of an alternative 

emissions scenario (see the response to ERCB SIR 41b). This alternative 

emissions scenario conservatively assumes that all of the projects’ auxiliary 

boilers are in continuous use. 

Shell does not capture historical data on all of the main factors which define the 

cold period and, consequently, the amount of time that the temporary boilers 

would need to be fired. In addition, the need to fire these boilers is influenced by 

other factors, some of which are not directly linked to ambient air conditions. 

As an alternative emissions scenario was assessed to indicate the potential 

impacts of firing auxiliary boilers continuously throughout a full year, a 

discussion of the factors that would dictate auxiliary boiler use is unnecessary, as 

impacts from this more conservative alternative emissions scenario do not change 

the EIA’s air quality impact assessment conclusions, as discussed in the response 

to ERCB SIR 41b. 


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Request 41b Based on the response above, how would the air assessment change if the 

additional thermal energy requirements would be met by additional boilers 

running at the same time as the co-generation units? 

Section 6.1 

Response 41b The conclusions of the air quality impact assessment do not change if the 

auxiliary boilers at the Jackpine Mine Expansion and the Pierre River Mine are 

assumed to be in continuous use. 

To assess the effect of the additional auxiliary boilers on the air quality 

assessment, the boiler emissions sources were added to the Application Case 

emissions and modelled according to the methodology outlined in the EIA (see 

EIA, Volume 3, Appendix 3-8, Section 2). The updated project emissions, 

including the additional auxiliary boilers, are presented in Table ERCB 41-1. 

Table ERCB 41-1: Project Emissions Summary including Additional Auxiliary Boilers 

Source 

Jackpine Mine Expansion 

Stream- 

Day 

SO2 

(t/sd) 

Calendar- 

Day SO2 

(t/cd) 

Emission Rates 

Change to Jackpine Mine – Phase 1 (a) -0.30 -0.30 -6.71 -1.60 -0.37 -0.78 0.00 

Addition of Jackpine Mine Expansion (b) 4.08 4.08 6.45 7.75 0.31 8.79 0.07 

Subtotal (c) 3.78 3.78 -0.26 6.15 -0.06 8.01 0.07 

Addition of Auxiliary Boilers (d) 0.02 0.02 1.25 2.03 0.18 0.13 — 

New Total with Auxiliary Boilers (c) 3.80 3.80 0.98 8.17 0.12 8.15 0.07 


Total (e) 4.10 4.10 12.45 13.31 0.51 17.39 0.14 

Addition of Auxiliary Boilers (d) 0.02 0.02 1.25 2.03 0.18 0.13 — 

New Total with Auxiliary Boilers (c) 4.11 4.11 13.70 15.34 0.69 17.52 0.14 

Project Total (c) 7.91 7.91 14.68 23.51 0.81 25.66 0.22 

Note: 

(a) Emissions from EIA, Volume 3, Appendix 3-8, Table 31 and expressed as tonnes per stream-day [t/sd], tonnes per calendar-day [t/cd] 

or tonnes per day [t/d]. The change is calculated in EIA, Volume 3, Appendix 3-8, Table 30 and represents the difference between the 

updated Jackpine Mine – Phase 1 and the Base Case Jackpine Mine – Phase 1. 

(b) Emissions from EIA, Volume 3, Appendix 3-8, Table 31. 

(c) Some numbers are rounded for presentation purposes. Therefore, it may appear that the totals do not equal the sum of the individual 

values. 

(d) The emissions displayed assume all three boilers in service. This represents a conservative winter operations scenario. 

(e) Emissions from EIA, Volume 3, Appendix 3-8, Table 36. 


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NOx 

(t/d) 

CO 

(t/d) 

PM2.5 

(t/d) 

VOC 

(t/d) 

Table ERCB 41-2 shows a comparison of regional sulphur dioxide (SO2) 

predictions for the Application Case and the Application Plus Boilers Case. A 

comparison of the regional nitrogen dioxide (NO2) predictions for the same cases 

is shown in Table ERCB 41-3. Note that the results for both cases do not include 

the Fort McKay Lease, according to the May 2008 EIA Update. The SO2 

TRS 

(t/d)


Section 6.1 

predictions do not increase as a result of adding the auxiliary boiler emissions. 

Only the annual NO2 predictions increase minimally. 

Table ERCB 41-2: Comparison of Regional SO2 Predictions 

EIA Update 

(May 2008) 

Application 

Case 

Application 

Case Plus 

Boilers 

Change 

Due to 

Boilers (a) 

Parameter 

Local Study Area 

maximum 1-hour SO2 (excluding developed areas) (b)(c) (µg/m³) 74.1 74.1 0.0 

occurrences above 1-hour AAAQO (d)(e) 0 0 0 

area above 1-hour AAAQO (excluding developed areas) (c)(d) (ha) 0 0 0 

peak 24-hour SO2 (excluding developed areas) (b)(c) (µg/m³) 47.9 47.9 0.0 



annual average SO2 (excluding developed areas) (b)(c) (µg/m³) 5.6 5.6 0.0 

occurrences above annual AAAQO (d)(e) 0 0 0 

area above annual AAAQO (excluding developed areas) (c)(d) (ha) 

Regional Study Area excluding Local Study Area 

0 0 0 







annual average SO2 (excluding developed areas) (b)(c) [µg/m³] 11.6 11.6 0.0 


area above annual AAAQO (excluding developed areas) (c)(d) [ha] 0 0 0 

Regional Study Area 







annual average SO2 (excluding developed areas) (b)(c) (µg/m³) 11.6 11.6 0.0 


area above annual AAAQO (excluding developed areas) (c)(d) (ha) 

Note: 

0 0 0 

(a) Although the modelling predictions in the table have been rounded for presentation purposes, the changes were calculated 

directly from model outputs. Therefore, it is feasible to show small changes without an apparent change in the listed 

concentrations. 

(b) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model guidelines 

(AENV 2003). 

(c) Developed areas include the Project Development Area and existing and approved open pit mines and upgrading complexes 

within the regional study area (RSA) and local study area (LSA). 

(d) The 1-hour, 24-hour and annual Alberta Ambient Air Quality Objectives for SO2 are 450, 150 and 30 µg/m³, respectively. 

(e) The number of occurrences is based on the concentrations outside of developed areas. 


CR029


Table ERCB 41-3: Comparison of Regional NO2 Predictions 

EIA Update 

(May 2008) 

Application 

Case 

Application 

Case Plus 

Boilers 

Section 6.1 

Change 

Due to 

Boilers (a) 

Parameter 

Local Study Area 

maximum 1-hour NO2 (excluding developed areas) (b)(c) (µg/m³) 189.9 189.9 0.0 



peak 24-hour NO2 (excluding developed areas) (b)(c) (µg/m³) 183.3 183.3 0.0 



annual average NO2 (excluding developed areas) (b)(c) (µg/m³) 46.4 46.5 0.1 


area above annual AAAQO (d) (excluding developed areas) (ha) 

Regional Study Area excluding Local Study Area 

0 0 0 






area above 24-hour AAAQO (excluding developed areas) (c)(d) (ha) 1,800 1,800 0 



area above annual AAAQO (d) (excluding developed areas) (ha) 626 627 1 

Regional Study Area 






area above 24-hour AAAQO (excluding developed areas) (c)(d) (ha) 1,800 1,800 0 



area above annual AAAQO (d) (excluding developed areas) (ha) 

Note: 

626 627 1 

(a) Although the modelling predictions in the table have been rounded for presentation purposes, the changes were calculated 

directly from model outputs. Therefore, it is feasible to show small changes without an apparent change in the listed 


(b) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model guidelines 

(AENV 2003). 

(c) Developed areas include the Project Development Area and existing and approved open pit mines and upgrading complexes 

within the regional study area (RSA) and local study area (LSA). 

(d) The 1-hour, 24-hour and annual Alberta Ambient Air Quality Objectives for NO2 are 400, 200 and 60 µg/m³, respectively. 

(e) The number of occurrences is based on the concentrations outside of developed areas. 


CR029


Section 6.1 

Tables ERCB 41-4 through ERCB 41-9 show the comparison of SO2, NO2, 

carbon monoxide (CO), benzene, other select volatile organic compounds 

(VOCs) and PM2.5 predictions at regional communities. Note that the VOC 

predictions are based on the revised external tailings disposal area speciation, as 

discussed in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, Section 7.2. The results indicate that the boiler emissions do not cause 

any material increases in predicted concentrations within regional communities. 

The decrease in the 1-hour NO2 maximum concentration at Anzac is due to the 

use of different oxides of nitrogen (NOX) to NO2 conversion method. As 

discussed in Appendix 3-8, Section 2.3.5 of the EIA, the ambient mine ratio 

method was used to calculate NO2 concentrations when the NOX concentration 

exceeded 0.03 ppm. The 1-hour maximum NOX concentration at Anzac was 

slightly lower than the 0.03 ppm threshold in the Application Case; however, 

when the boiler emissions were added, the maximum 1-hour NOX concentration 

was consequently above 0.03 ppm and the ambient ratio method was triggered. 

This resulted in a lower predicted NO2 concentration at that particular location. 


CR029


Community 

Table ERCB 41-4: Comparison of SO2 Predictions in Regional Communities 

Application 

Case (µg/m³) 

Maximum 1-Hour SO2 (a)(b) Peak 24-Hour SO2 (a)(b) 2 (a)(b) 

Peak Annual SO 

Application 

Case Plus 

Boilers 

(µg/m³) 

Change Due 

to Boilers 

(µg/m³) 

Application 


Application 

Case Plus 

Boilers 

(µg/m³) 

Change Due 

to Boilers 

(µg/m³) 

Application 


Application 

Case Plus 

Boilers 

(µg/m³) 

Section 6.1 

Change Due 

to Boilers 

(µg/m³) 

Anzac 46.4 46.4 0.0 22.7 22.7 0.0 3.4 3.4 0.0 

Conklin 20.9 20.9 0.0 11.5 11.5 0.0 1.2 1.2 0.0 

Fort Chipewyan 15.2 15.2 0.0 9.5 9.5 0.0 0.6 0.6 0.0 

Fort McKay 84.5 84.5 0.0 24.3 24.3 0.0 4.2 4.2 0.0 

Fort McMurray 48.1 48.1 0.0 17.3 17.3 0.0 3.0 3.0 0.0 

Janvier/Chard (IR 194) 28.3 28.3 0.0 14.4 14.4 0.0 1.6 1.6 0.0 

Clearwater (IR 175) 31.4 31.4 0.0 12.2 12.2 0.0 1.9 1.9 0.0 

Namur River (IR 174A) 29.9 29.9 0.0 13.5 13.5 0.0 1.1 1.1 0.0 

Poplar Point (IR 201G) 25.3 25.3 0.0 13.3 13.3 0.0 1.3 1.3 0.0 

Cabin A 38.6 38.7 0.1 16.4 16.4 0.0 2.1 2.1 0.0 

Cabin B 27.0 27.0 0.0 13.1 13.1 0.0 1.7 1.7 0.0 

Cabin C 37.4 37.4 0.0 14.2 14.2 0.0 2.1 2.1 0.0 

Cabin D 39.5 39.5 0.0 15.2 15.2 0.0 2.2 2.2 0.0 

Cabin E 35.4 35.4 0.0 14.3 14.3 0.0 2.3 2.3 0.0 

Cabin F 37.7 37.7 0.0 15.4 15.4 0.0 2.4 2.4 0.0 

Cabin G 28.6 28.6 0.0 12.4 12.4 0.0 2.4 2.4 0.0 

Cabin H 46.0 46.0 0.0 29.1 29.1 0.0 3.1 3.1 0.0 

Cabin I 62.6 62.6 0.0 25.4 25.4 0.0 3.8 3.8 0.0 

Cabin J 98.2 98.2 0.0 44.2 44.2 0.0 5.9 5.9 0.0 

Cabin K 64.9 64.9 0.0 27.8 27.8 0.0 4.2 4.2 0.0 

Cabin L 51.3 51.3 0.0 20.3 20.3 0.0 3.2 3.2 0.0 

Descharme Lake, SK 15.4 15.4 0.0 6.7 6.7 0.0 1.0 1.0 0.0 

La Loche, SK 15.6 15.6 0.0 9.6 9.6 0.0 1.1 1.1 0.0 

Oil Sands Lodge 68.3 68.3 0.0 25.7 25.7 0.0 4.6 4.6 0.0 

PTI Camp 104.7 104.7 0.0 32.4 32.4 0.0 4.5 4.5 0.0 

Note: 

(a) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model guidelines (AENV 2003). The eight highest 1-hour predictions were not excluded from 

the peak 24-hour and annual values. 

(b) The 1-hour, 24-hour and annual AAAQOs for SO2 are 450, 150 and 30 µg/m³, respectively (AENV 2009). 


CR029


Community 

Table ERCB 41-5: Comparison of NO2 Predictions in Regional Communities 

Application 

Case 

(µg/m³) 

Maximum 1-Hour NO2 (a)(b) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Change Due 

to Boilers 

(µg/m³) 

Application 

Case 

(µg/m³) 

Peak 24-Hour NO2 (a)(b) Peak Annual NO2 (a)(b) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Change Due 

to Boilers 

(µg/m³) 

Application 

Case 

(µg/m³) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Section 6.1 

Change Due 

to Boilers 

(µg/m³) 

Anzac 79.0 77.9 -1.1 42.6 42.6 0.0 6.3 6.3 0.0 

Conklin 85.0 85.0 0.0 39.3 39.4 0.1 3.8 3.8 0.0 

Fort Chipewyan 63.5 63.9 0.3 33.0 33.1 0.1 2.9 3.0 0.0 

Fort McKay 116.7 116.7 0.0 88.9 88.9 0.0 28.1 28.1 0.0 

Fort McMurray 100.8 100.8 0.0 78.3 78.4 0.1 20.8 20.8 0.0 

Janvier/Chard (IR 194) 58.0 58.1 0.0 24.2 24.3 0.1 3.9 3.9 0.0 

Clearwater (IR 175) 54.7 54.8 0.2 34.9 34.9 0.0 4.6 4.6 0.0 

Namur River (IR 174A) 45.2 45.3 0.1 29.8 29.9 0.1 2.2 2.2 0.0 

Poplar Point (IR 201G) 55.8 55.7 0.0 46.5 46.7 0.2 6.5 6.5 0.0 

Cabin A 81.7 81.7 0.0 64.0 64.1 0.1 14.2 14.3 0.1 

Cabin B 72.1 72.1 0.0 57.0 57.1 0.1 10.6 10.6 0.0 

Cabin C 82.1 82.1 0.0 65.1 65.2 0.1 13.7 13.8 0.1 

Cabin D 88.0 88.0 0.0 68.2 68.3 0.1 15.2 15.3 0.1 

Cabin E 81.1 81.1 0.0 65.4 65.4 0.0 14.6 14.6 0.1 

Cabin F 83.2 83.2 0.0 67.8 67.8 0.0 15.4 15.5 0.1 

Cabin G 101.9 101.9 0.0 75.5 75.6 0.0 14.8 14.8 0.0 

Cabin H 102.4 102.4 0.0 72.7 72.7 0.0 17.5 17.6 0.1 

Cabin I 122.4 122.4 0.0 95.0 95.0 0.0 28.7 28.7 0.0 

Cabin J 165.5 165.5 0.0 127.9 127.9 0.0 34.7 34.8 0.1 

Cabin K 151.3 151.3 0.0 112.4 112.4 0.0 32.0 32.1 0.1 

Cabin L 108.4 108.4 0.0 83.1 83.1 0.0 23.0 23.2 0.2 

Descharme Lake, SK 21.3 21.6 0.3 11.3 11.5 0.2 1.5 1.5 0.0 

La Loche, SK 49.8 49.9 0.1 21.9 22.0 0.1 3.4 3.4 0.0 

Oil Sands Lodge 133.5 133.6 0.0 93.2 93.2 0.1 30.4 30.4 0.0 

PTI Camp 94.5 94.5 0.0 67.8 67.9 0.1 24.0 24.0 0.0 

Note: 

(a) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model guidelines (AENV 2003). The eight highest 1-hour predictions were not excluded from 

the peak 24-hour and annual values. 

(b) The 1-hour, 24-hour and annual AAAQOs for NO2 are 400, 200 and 60 µg/m³, respectively (AENV 2009). 


CR029


Community 

Table ERCB 41-6: Comparison of CO Predictions in Regional Communities 

Application 

Case 

(µg/m³) 

Peak 1-Hour CO (a)(b) Peak 8-Hour CO (a)(b) 

Application 

Case Plus Boilers 

(µg/m³) 

Change Due to 

Boilers (c) 

(µg/m³) 

Application 

Case 

(µg/m³) 

Application 

Case Plus Boilers 

(µg/m³) 

Change Due to 

Boilers (c) 

(µg/m³) 

Anzac 989.4 990.9 1.5 586.0 587.6 1.6 

Conklin 336.1 336.1 0.0 189.1 189.1 0.0 

Fort Chipewyan 379.7 380.1 0.4 230.3 230.6 0.3 

Fort McKay 1,079.8 1,079.9 0.1 643.3 643.8 0.4 

Fort McMurray 5,052.9 5,052.9 0.0 2,362.6 2,362.6 0.0 

Janvier/Chard (IR 194) 423.9 424.6 0.8 258.2 258.9 0.7 

Clearwater (IR 175) 204.4 204.4 0.0 158.6 159.1 0.5 

Namur River (IR 174A) 86.9 87.0 0.1 81.4 81.5 0.1 

Poplar Point (IR 201G) 212.5 212.6 0.1 140.2 141.3 1.1 

Cabin A 307.3 307.3 0.0 254.2 254.3 0.1 

Cabin B 282.4 282.4 0.1 236.9 236.9 0.0 

Cabin C 347.1 347.1 0.1 282.9 283.0 0.1 

Cabin D 388.0 388.0 0.1 315.1 315.1 0.1 

Cabin E 371.4 371.4 0.0 288.5 288.6 0.1 

Cabin F 376.0 376.0 0.0 287.5 287.6 0.1 

Cabin G 584.4 584.4 0.0 414.5 414.5 0.0 

Cabin H 436.0 436.3 0.4 325.1 325.3 0.2 

Cabin I 488.6 488.6 0.0 305.4 305.4 0.0 

Cabin J 1,016.9 1,016.9 0.0 707.0 707.0 0.0 

Cabin K 1,212.1 1,212.1 0.0 714.3 714.3 0.0 

Cabin L 550.8 550.8 0.0 395.7 395.8 0.0 

Descharme Lake, SK 36.1 36.4 0.3 24.9 25.2 0.3 

La Loche, SK 500.2 501.3 1.1 289.4 290.0 0.6 

Oil Sands Lodge 914.4 914.4 0.0 610.0 611.6 1.6 

PTI Camp 518.5 518.6 0.1 276.4 276.8 0.4 

Note: 

(a) The peak concentrations include the highest 1-hour predictions from the CALPUFF model. 

(b) The 1-hour and 8-hour AAAQOs for CO are 15,000 and 6,000 µg/m³, respectively (AENV 2009). There is no annual AAAQO for CO. 

(c) Although the modelling predictions in the above table have been rounded for presentation purposes, the changes were calculated directly from model outputs. 

Therefore, it is possible to show small changes without an apparent change in the listed concentrations. 

Section 6.1 


CR029


Section 6.1 

Table ERCB 41-7: Comparison of Benzene Predictions In Regional Communities 

Maximum 1-Hour Benzene (a)(b) 

Application 

Case 

Application 

Case Plus 

Boilers 

Change Due 

to Boilers 

Community 

(µg/m³) (µg/m³) 

(c) 

(µg/m³) 

Anzac 1.4 1.4 0.0 

Conklin 0.3 0.3 0.0 

Fort Chipewyan 1.6 1.6 0.0 

Fort McKay 4.9 4.9 0.0 

Fort McMurray 28.6 28.6 0.0 

Janvier/Chard (IR 194) 0.3 0.3 0.0 

Clearwater (IR 175) 1.0 1.0 0.0 

Namur River (IR 174A) 0.6 0.6 0.0 

Poplar Point (IR 201G) 0.7 0.7 0.0 

Cabin A 2.4 2.4 0.0 

Cabin B 1.1 1.1 0.0 

Cabin C 1.6 1.6 0.0 

Cabin D 1.9 1.9 0.0 

Cabin E 1.5 1.5 0.0 

Cabin F 1.5 1.5 0.0 

Cabin G 2.4 2.4 0.0 

Cabin H 2.4 2.4 0.0 

Cabin I 2.9 2.9 0.0 

Cabin J 6.5 6.5 0.0 

Cabin K 6.0 6.0 0.0 

Cabin L 2.6 2.6 0.0 

Descharme Lake, SK 0.2 0.2 0.0 

La Loche, SK 1.4 1.4 0.0 

Oil Sands Lodge 4.1 4.1 0.0 

PTI Camp 8.8 8.8 0.0 

Note: 

(a) Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta 

model guidelines (AENV 2003). 

(b) The 1-hour AAAQO for benzene is 30 µg/m³ (AENV 2009). There are no 24-hour or annual 

AAAQOs for benzene. 

(c) Although the modelling predictions in the table have been rounded for presentation purposes, the 

changes between Base Case and Application Case predictions were calculated directly from 

model outputs. Therefore, it is possible to show small changes without an apparent change in the 

listed concentrations. 


CR029


Section 6.1 

Table ERCB 41-8: Comparison of Select VOC Predictions In Regional Communities 

Parameter * 

Application 

Case 

(µg/m³) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Change Due 

to Boilers 

(µg/m³) 

Application 

Case 

(µg/m³) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Anzac Conklin 

Change Due 

to Boilers 

(µg/m³) 

Maximum 1-hour acrolein 0.1416 0.1416 0.0000 0.1825 0.1825 0.0000 

Peak annual acrolein 

Maximum 1-hour benzene 

0.0122 0.0122 0.0000 0.0080 0.0080 0.0000 

1.3705 1.3705 0.0000 0.3145 0.3145 0.0000 

Peak 1-hour cyclohexane 2.7583 2.7583 0.0000 0.5123 0.5123 0.0000 

Peak annual cyclohexane 

0.0505 0.0505 0.0000 0.0114 0.0114 0.0000 

Peak 1-hour ethylbenzene 1.1342 1.1342 0.0000 0.2224 0.2224 0.0000 

Peak 1-hour xylenes 

7.2387 7.2387 0.0000 1.3596 1.3596 0.0000 

Fort Chipewyan Fort McKay 




0.0134 0.0134 0.0000 0.0943 0.0943 0.0000 

1.6217 1.6217 0.0000 4.9343 4.9343 0.0000 



0.0213 0.0213 0.0000 1.1659 1.1659 0.0000 



2.6227 2.6227 0.0000 58.3880 58.3880 0.0000 

Fort McMurray Janvier/Chard (IR 194) 




0.0668 0.0668 0.0000 0.0042 0.0042 0.0000 

28.6070 28.6070 0.0000 0.3330 0.3330 0.0000 



0.1636 0.1636 0.0000 0.0191 0.0191 0.0000 



19.5410 19.5410 0.0000 3.6065 3.6065 0.0000 

Clearwater (IR 175) Namur River (IR 174A) 




0.0110 0.0110 0.0000 0.0053 0.0053 0.0000 

1.0425 1.0425 0.0000 0.5878 0.5878 0.0000 



0.0981 0.0981 0.0000 0.0560 0.0560 0.0000 



9.8334 9.8334 0.0000 11.0820 11.0820 0.0000 

Poplar Point (IR 201G) Cabin A 




0.0148 0.0148 0.0000 0.0371 0.0371 0.0000 

0.7219 0.7219 0.0000 2.3595 2.3595 0.0000 



0.1098 0.1098 0.0000 0.2733 0.2733 0.0000 



8.6544 8.6544 0.0000 19.2460 19.2460 0.0000 

Cabin B Cabin C 




0.0280 0.0280 0.0000 0.0366 0.0366 0.0000 

1.0684 1.0684 0.0000 1.5974 1.5974 0.0000 



0.1653 0.1653 0.0000 0.2621 0.2621 0.0000 



14.6840 14.6840 0.0000 20.9310 20.9310 0.0000 


CR029


Section 6.1 


(cont’d) 

Parameter * 

Application 

Case 

(µg/m³) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Change Due 

to Boilers 

(µg/m³) 

Application 

Case 

(µg/m³) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Cabin D Cabin E 

Change Due 

to Boilers 

(µg/m³) 




0.0424 0.0424 0.0000 0.0437 0.0437 0.0000 

1.8764 1.8764 0.0000 1.4738 1.4738 0.0000 



0.2990 0.2990 0.0000 0.2749 0.2749 0.0000 



21.9530 21.9530 0.0000 21.3330 21.3330 0.0000 

Cabin F Cabin G 




0.0476 0.0476 0.0000 0.0547 0.0547 0.0000 

1.5323 1.5323 0.0000 2.3663 2.3663 0.0000 



0.2987 0.2987 0.0000 0.2235 0.2235 0.0000 



21.2780 21.2780 0.0000 19.9120 19.9120 0.0000 

Cabin H Cabin I 




0.0505 0.0505 0.0000 0.0884 0.0884 0.0000 

2.3907 2.3907 0.0000 2.9475 2.9475 0.0000 



0.3854 0.3854 0.0000 0.6299 0.6299 0.0000 



52.6840 52.6840 0.0000 32.9590 32.9590 0.0000 

Cabin J Cabin K 




0.1426 0.1426 0.0000 0.1222 0.1222 0.0000 

6.4745 6.4745 0.0000 5.9531 5.9531 0.0000 



0.9824 0.9824 0.0000 0.9190 0.9190 0.0000 



141.1200 141.1200 0.0000 118.4800 118.4800 0.0000 

Cabin L Descharme Lake, SK 




0.0784 0.0784 0.0000 0.0021 0.0021 0.0000 

2.6249 2.6249 0.0000 0.1770 0.1770 0.0000 



0.5284 0.5284 0.0000 0.0191 0.0191 0.0000 



24.6910 24.6910 0.0000 2.5696 2.5696 0.0000 

La Loche, SK Oil Sands Lodge 




0.0326 0.0326 0.0000 0.1254 0.1254 0.0000 

1.4102 1.4102 0.0000 4.1488 4.1488 0.0000 



0.0264 0.0264 0.0000 1.1160 1.1160 0.0000 



CR029


Section 6.1 


(cont’d) 

Parameter * 


Application 

Case 

(µg/m³) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Change Due 

to Boilers 

(µg/m³) 

Application 

Case 

(µg/m³) 

Application 

Case Plus 

Boilers 

(µg/m³) 

Change Due 

to Boilers 

(µg/m³) 

2.3634 2.3634 0.0000 57.6200 57.6200 0.0000 

PTI Camp 

Maximum 1-hour acrolein 0.9210 0.9210 0.0000 



0.0657 0.0657 0.0000 

8.8481 8.8481 0.0000 

Peak 1-hour cyclohexane 39.0100 39.0100 0.0000 


2.3558 2.3558 0.0000 

Peak 1-hour ethylbenzene 13.1370 13.1370 0.0000 


96.4740 96.4740 0.0000 

Note *: The peak concentrations include the highest 1-hour predictions from the CALPUFF model. 

Table ERCB 41-9: Comparison of PM2.5 Predictions In Regional Communities 

98 th (a) 

Percentile 24-Hour PM2.5 

Application 

Application Case Plus Change Due to 

Case 

Boilers 

Boilers 

Community 

(µg/m³) 

(µg/m³) 

(b) 

(µg/m³) 

Anzac 11.7 11.7 0.0 

Conklin 9.7 9.7 0.0 

Fort Chipewyan 8.8 8.9 0.0 

Fort McKay 25.4 25.4 0.0 

Fort McMurray 18.0 18.0 0.0 

Janvier/Chard (IR 194) 10.2 10.2 0.0 

Clearwater (IR 175) 4.7 4.7 0.0 

Namur River (IR 174A) 4.5 4.6 0.1 

Poplar Point (IR 201G) 5.0 5.1 0.0 

Cabin A 9.9 9.9 0.0 

Cabin B 6.4 6.5 0.0 

Cabin C 9.4 9.4 0.0 

Cabin D 10.5 10.5 0.0 

Cabin E 8.9 8.9 0.0 

Cabin F 9.3 9.4 0.0 

Cabin G 9.7 9.7 0.0 

Cabin H 10.8 10.8 0.0 

Cabin I 15.2 15.2 0.0 

Cabin J 24.2 24.2 0.0 

Cabin K 20.5 20.5 0.0 

Cabin L 16.9 16.9 0.0 

Descharme Lake, SK 2.3 2.3 0.0 

La Loche, SK 9.3 9.4 0.0 

Oil Sands Lodge 21.1 21.2 0.1 

PTI Camp 

Note: 

13.1 13.2 0.0 

(a) The Canada-Wide Standard for PM2.5 is 30 µg/m³ and is based on the 98 th percentile 24-hour 

reading annually, averaged over three years (CCME 2000). 

(b) Although the modelling predictions in the table have been rounded for presentation purposes, 

the changes were calculated directly from model outputs. Therefore, it is possible to show 

small changes without an apparent change in the listed concentrations. 


CR029


References 


Section 6.1 

AENV (Alberta Environment). 2003. Air Quality Model Guideline. Prepared by 

the Science and Standards Branch, Environmental Services Division 

Alberta Environment. Edmonton, AB. March 2003. 

AENV. 2009. Alberta Ambient Air Quality Objectives and Guidelines. Air 

Policy Branch. June 2009. 

CCME (Canadian Council Ministry Environment). 2000. Canada-Wide 

Standards for Particulate Matter (PM) and Ozone. Accepted November 

29, 1999 for endorsement in May 2000. 

Request Volume 3, Section 3.4.3.2, Page 3-71, Table 3.4-13. 

Shell states, “The modeling results indicate that no occurrences above the 1-hr 

AAAQO [for benzene] were predicted for either the Base Case or Application 

Case for any of the regional communities.” 

42a Clarify if Shell is predicting any benzene concentrations above the AAAQO 

anywhere in the local study area (LSA) or regional study area (RSA), excluding 

the regional communities and developed areas. 

Response 42a The following analysis of local and regional benzene concentrations has been 

completed to clarify Shell’s benzene predictions. Ground-level 1-hour benzene 

concentrations were predicted in both the local study area (LSA) and the regional 

study area (RSA) for the Base Case and Application Case. A summary of the 

results for both cases is presented in Table ERCB 42-1. The Base Case maximum 

1-hour benzene concentration (excluding developed areas) is below the Alberta 

Ambient Air Quality Objective (AAAQO) in the LSA but above the AAAQO in 

the RSA. The Application Case maximum 1-hour benzene concentration 

(excluding developed areas) in the LSA is above the AAAQO with 13 hours per 

year predicted to exceed the AAAQO. In the RSA, both the Base Case and 

Application Case maximum 1-hour benzene concentrations excluding developed 

areas are above the AAAQO. There are 169 hours per year predicted to exceed 

the AAAQO in both cases. 


CR029


Local Study Area (LSA) 

Table ERCB 42-1: Regional 1-Hour Benzene Predictions 

Section 6.1 

Parameter Base Case Application Case 

peak benzene (1) (µg/m³) 69.9 104.8 

maximum benzene (2) (µg/m³) 59.8 89.6 

maximum benzene (excluding developed areas) (2)(3) (µg/m³) 24.8 37.0 

distance to maximum concentration (4)(5) (km) 7.2 7.2 

direction to maximum concentration (4)(5) ESE ESE 

occurrences above AAAQO (5)(6) 0 13 

areal extent above AAAQO (5)(6) (excluding developed areas) (ha) 0 261 

Regional Study Area (RSA) 

peak benzene (1) (µg/m³) 1,196.9 1,196.9 

maximum benzene (2) (µg/m³) 1,038.4 1,038.4 

maximum benzene (excluding developed areas) (2)(3) (µg/m³) 211.4 211.5 

distance to maximum concentration (4)(5) (km) 29.6 29.6 

direction to maximum concentration (4)(5) SSW SSW 

occurrences above AAAQO (5)(6) 169 169 

areal extent above AAAQO (5)(6) (excluding developed areas) (ha) 16,324 16,602 

Note: 

1. The peak concentrations represent the highest 1-hour predictions from the CALPUFF model. However, the 

eight highest 1-hour predictions should be excluded (AENV 2003) when determining compliance with the 

AAAQOs. 

2. Maximum 1-hour predictions exclude the eight highest 1-hour concentrations, as per the Alberta model 

guidelines (AENV 2003). The eight highest 1-hour benzene predictions were not excluded from the 

maximum 24-hour values. 

3. Developed areas include the Project Development Area and existing and approved open pit mines and 

upgrading complexes within the RSA and LSA. 

4. Locations are relative to the Jackpine Mine Expansion plant site. 

5. Locations, number of occurrences and areas are based on the maximum predictions outside developed 

areas. 

6. The 1-hour Ambient Air Quality Objective for benzene is 30 µg/m³ (AENV 2009). 

Figures ERCB 42-1, ERCB 42-2, ERCB 42-3 and ERCB 42-4 present the ground 

level 1-hour benzene concentration predictions for Base and Application cases 

and the likelihood of occurrence of predicted concentrations above the AAAQO, 

respectively. The concentration and likelihood of exceedance isopleths are 

centred on the primary benzene emission sources (i.e., tailings ponds, mine 

areas). In the LSA, the Application Case 1-hour benzene concentrations are 

focused on the Jackpine Mine Expansion tailings pond, with the highest predicted 

concentrations occurring over the surface of the ponds. The exceedances outside 

the developed areas in the LSA are because of the combined effect of the 

increased emissions from the Jackpine Mine Expansion tailings pond and tailings 

pond emissions from neighbouring projects (i.e., Syncrude Aurora South). 

The majority of the exceedances occur in areas where the public is not expected 

to spend extended periods of time due to restricted access. The air quality 

assessment and health risk assessment focused on locations where members of 

the public are expected to be, such as communities or cabins (see EIA, Volume 3, 

Section 3.4). 


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References 

Section 6.1 

Because predicted short-term benzene concentrations were less than the healthbased 

guideline for all receptor locations, under all three development cases (see 

EIA, Volume 3, Section 5.3.3.1), predicted short-term benzene concentrations are 

not expected to result in adverse health effects on the area residents. 


the Science and Standards Branch, Environmental Services Division 


AENV. 2009. Alberta Ambient Air Quality Objectives and Guidelines. Air 

Policy Branch. June 2009. 

Request 42b If so, how many and approximately where are the majority of predicted 

exceedances located? 



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Section 6.1 

Figure ERCB 42-1: Base Case Maximum 1-Hour Benzene 

Predictions 


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Section 6.1 

Figure ERCB 42-2: Application Case Maximum 1-Hour 

Benzene Predictions 


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Section 6.1 

Figure ERCB 42-3: Base Case Likelihood of 1-Hour 

Benzene Predictions Exceeding 30 µg/m 3 


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Section 6.1 

Figure ERCB 42-4: Application Case Likelihood of 

1-Hour Benzene Predictions Exceeding 30 µg/m 3 


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Section 6.1 


Shell states, “Shell is still reviewing options for pollution control equipment for 

the AER cogeneration unit. Details of the air quality and monitoring control 

system will be finalized when pollution control equipment has been selected.” 

43a Explain how Shell intends to monitor the control efficiencies of the finalized 

pollution control equipment to achieve the pollution control performance targets. 

i. What is the basis for setting pollution control performance targets? 

Response 43a As stated in the response to SIR 230a in the May 2009 Pierre River Mine, 

Supplemental Information, Volume 1, Shell is still reviewing options for 

pollution control equipment for the AER cogeneration unit. Details of the air 

quality and monitoring control system will be finalized once the pollution control 

equipment has been selected and the regulatory requirements are known. Stack 

monitoring could be used to confirm that emissions meet expectations, given the 

control efficiencies chosen. 

The proposed performance targets were based on realistic control efficiencies for 

pollution control equipment that could integrate with an AER cogeneration 

system. These performance targets for pollution control equipment efficiencies 

will guide the selection of equipment during the detailed design stage of the 

project. 

Request 43b Provide detailed characterization of the asphaltene feedstock e.g. S, N, Hg, Cr, 

etc. 

Response 43b Shell is still at an early stage in the assessment of the AER technology, and 

certain elements, including the feedstock, are considered confidential. 

Request 43c What are the expected products and by-products from the combustion of this 

asphaltene feedstock? 

Response 43c As discussed in EIA, Volume 2, Section 8.3, the products of the asphaltene-fired 

cogeneration plant are steam and electrical power. The by-products of this 

process are bottom and fly ash, flue gas desulphurization (FGD) solids, and flue 

gas. Ash and FGD solids would be collected and disposed of on site in a Class II 

landfill. Flue gas would be treated by pollution control equipment. 


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Section 6.1 

Request 43d What is Shell’s position on providing detailed configuration of the pollution 

control technologies for the AER unit to the ERCB, when a final selection has 

been made? 

Response 43d Shell will provide the appropriate design details of the AER process to the 

applicable regulatory agencies, including the ERCB, once a final design basis has 

been selected. 



Shell states, “If asphaltene recovery operations are not initiated, TSRU tailings 

will be incorporated into fluid fine tailings mixes. Some of these fluid fine tailings 

will be incorporated into NST and some will be stored in water capped mature 

fine tailings (MFT) end-pit lakes”. 

44a What are the implications for air emissions in the region if the TSRU tailings is 

incorporated into the NST deposit? Will there be a significant increase in the 

estimated air emissions for the project? 

Response 44a If the TSRU tailings are incorporated into the NST deposit the actual VOC 

emissions will be higher than if they are deposited sub-aqueously in the ETDA 

due to the capping effect of the water. However, as outlined below, the calculated 

air emissions used in the EIA for the region will remain unchanged. 

The primary source of air emissions from the ETDA or in-pit NST cells is due to 

unrecovered solvent. The unrecovered solvent is associated with asphaltenes and 

the tailings solvent recovery unit (TSRU) tailings. The Shell VOC emission 

estimates are based on the conservative assumption that diluent losses will be 

four barrels of diluent per 1,000 barrels of bitumen produced. This assumption 

does not differentiate between solvent loss due to unrecovered asphaltenes or 

TSRU tailings. Therefore, the calculated fugitive emission rates would remain 

unchanged if asphaltene recovery operations were not initiated. 

Request 44b If yes, what is the per cent increase in air emissions for the project? 



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Section 6.1 


Shell states, “As stated in EIA, Volume 3, Air Quality, Noise and Environmental 

Health, Section 3.1.5.2, vehicles in the mine fleet will meet applicable emissions 

standards at the time of purchase.” Shell used Tier 4 emission standards to 

develop a regional emissions profile and this was modeled for the assessment of 

predicted acid input (PAI). 

45a Does Shell commit to purchasing mine fleet vehicles that meet Tier 4 emission 

standards if these standards have not been implemented in Canada at the time of 

purchase? 

Response 45a As stated in EIA, Volume 3, Section 3.1.5.2, vehicles in the mine fleet will meet 

applicable emission standards at the time of purchase. As Tier 4 emission 

standards are directed at the equipment manufacturers, they dictate when these 

products will become available in the United States and Canada. If Tier 4 

emission standards are not adopted in Canada, it is unlikely that manufacturers 

will produce Tier 4-compliant product lines solely for US markets. Shell expects 

that Tier 4-compliant mobile equipment manufactured for both Canada and the 

US will become available in alignment with the timelines set out by the US. 

Environmental Protection Agency (US EPA). 

Shell will commit to the purchase of Tier 4-compliant equipment only if these 

products are made available in both the US and Canada. 

Request 45b If not, explain why Shell will not make the commitment. 



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Section 6.1 


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WATER 


Section 7.1 


Shell states, “Shell is confident in its capability of design and build successful pit 

lakes, because key findings from CONRAD and CEMA research on wetlands, 

experimental ponds and pit lakes will be incorporated into the analysis.” 

46a CEMA’s End Pit Lake Technical Guidance Document (EPLTGD) was reviewed 

by CH2MHILL. The reviewers rejected the document and provided 

recommendations that should be considered in the 2012 EPLTGD update. What 

is the time limit to incorporate CEMA’s key findings into Shell’s plans in order to 

meet the 2018 deadline (i.e. proven efficacy of the demonstration lake)? 

Response 46a The first three areas of research are the focus of work currently underway by 

CEMA, CONRAD and the Oil Sands Tailings Research Facility, all of which are 

supported by Shell. While the goal is to incorporate this research into the 2012 

EPLTGD update, it is anticipated that this and related research will continue 

beyond the 2012 update, and likely beyond 2018 as well. 

CEMA’s End Pit Lake Technical Guidance Document (EPLTGD) was reviewed 

by 12 experts in various fields, and their reviews were synthesized by 

CH2MHILL. The draft review synthesis pointed to shortcomings with the CEMA 

End Pit Lake Technical Guidance Document, but did not evaluate whether pit 

lakes were a viable solution for remediation of oil sands mines. 

Reviewers expressed opinions that oil sands pit lakes would require some level of 

active treatment in conjunction with the planned passive treatment. Although 

Shell is confident that pit lakes will function as planned, several active treatment 

methods are available and could be used in the event that such technology is 

deemed necessary (see the response to SIR 312 in the May 2009 Pierre River 

Mine, Supplemental Information, Volume 1, Section 13). 

The synthesis report pointed to four main areas of research that should be 

addressed: 

• the toxicity of naphthenic acids and other hydrocarbon contaminants 

• lake modelling 

• active management 


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WATER ERCB SIRS 46 – 79 

• risk management 

Section 7.1 

Request 46b What would be Shell alternatives to the End Pit Lakes as a final sustainable 

solution in highlight of the new draft review report submitted to CEMA entitled 

“Synthesis of Reviewer Comments on the CEMA End Pit Lake Technical 

Guidance Document, May 2009”? 

Response 46b Alternatives to pit lakes are described in the response to SIR 312b in the May 

2009 Pierre River Mine, Supplemental Information, Volume 1, Section 13. 



Shell states, “Shell will have a physical test pit lake in place by, or before, 

2018.” Shell also states, “Over time, they [EPLs] will become self-sustaining 

habitat for local vegetation, invertebrates and fish.” 

47a Will Shell independently demonstrate the efficacy of EPLs by, or before, 2018? If 

not, provide sound reasons for not complying with the approval condition. 

Response 47a In the response to SIR 312f in the May 2009 Pierre River Mine, Supplemental 

Information, Volume 1, Shell stated: 

Shell will have a physical test pit lake in place by, or before, 2018. In accordance 

with the ERCB’s conditions for approval of the Muskeg River Mine Expansion 

and the existing and expected EPEA approvals, this test pit lake work might be 

carried out by Shell or through a multi-stakeholder group that Shell 

cooperatively funds, such as CEMA or CONRAD. 

To clarify, Shell will be participating in research on the Syncrude Base Mine 

Lake through the multi-stakeholder groups that Shell cooperatively funds. 

Demonstration research is scheduled to begin in 2012 when the lake will no 

longer be operated as a tailings pond. 

Shell’s operating mines are still early in their development and Shell will not 

have any end pits available for research by 2018. Shell currently has no other 

plans for research on a demonstration end pit lake. However, Shell will continue 

to participate in joint industry and government research, as outlined previously in 

the response to ERCB SIR 46. 


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Section 7.1 

Request 47b Provide Shell’s plans and timelines for completion of the 2018 demonstration 

lake. 


Request 47c Provide an update on the status of Shell’s demonstration lake. 

Response 47c See the response to ERCB SIR 47a. 



Shell states, “Shell would consider several options if either insufficient water 

storage capacity or insufficient recycle water quality affected its ability to meet 

its water requirements.” 

48a Discuss Shell’s options to meet water requirements during exceptional low-flow 

periods. 

Response 48a See the response to AENV SIR 16. 



Shell states, “Evaporation associated with the processing facilities accounts for 

about 2% of total water consumption. There are no plans to reduce such 

evaporation.” 

49a Why did Shell include “reducing losses to evaporation” in its water management 

strategies list if there are no plans to reduce such evaporation? 

Response 49a The conceptual design took into account minimizing losses and developing an 

efficient production facility. Currently, there are no plans to make changes to the 

project’s conceptual design. However, during detailed design and operations 

there will be further opportunities to potentially improve on the overall efficiency 

of the process, including reducing losses to evaporation. 

Request 49b Where and how could Shell implement this water management strategy (reducing 

losses to evaporation)? 


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Section 7.1 

Response 49b Most of the evaporative losses within the process area result from operating the 

open-loop cooling tower. During detailed design and operations, opportunities 

will be sought to find a use for this low-grade heat before it is sent through the 

cooling tower. This would result in lower evaporative losses. 

Request 49c Confirm which of the strategies listed in Shell’s water management plan will be 

implemented. 

Response 49c Shell intends to implement all of the strategies listed in its water management 

plan. 



Shell states, “The simulation results showed that a system of recovery wells 

would be effective in capturing the ETDA seepage plume in the surficial deposits 

and would prevent seepage migration to the Athabasca River valley.” 

50a Elaborate on the effectiveness of the proposed system to capture vertical seepage 

underneath surficial deposits. 

Response 50a Groundwater interception measures for the external tailings disposal area 

(ETDA) focuses on lateral groundwater flow in the surficial deposits. Vertical 

seepage from the surficial deposits beneath the ETDA is not predicted to occur at 

appreciable rates because of the low hydraulic conductivity of the underlying 

McMurray Formation, as reported in EIA, Volume 4A, Section 6.3.6.2, page 6- 

212. 

Request 50b Elaborate on the additional mitigation measures (besides additional interception 

wells) that Shell would implement to increase the capture of ETDA seepage into 

surficial deposits and greater depths. 

Response 50b The current interception wells are predicted to adequately capture ETDA 

seepage. However, if further monitoring indicates additional mitigation measures 

are necessary, these measures would be to: 

• increase pumping rates, to increase the radius of influence of the interception 

well or wells 

• use slurry walls or grouting or both, to provide a barrier to groundwater flow 

which could be directed to installed interception wells 


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Section 7.1 


Shell considers deep-well injection to discard large volumes of process-affected 

water. 

51a If Shell determines injecting Process-Affected Water (PAW) is a necessary step, 

at what locations and depth would this occur? 

Response 51a Shell is no longer considering deep-well injection as an option for disposing of 

process affected waters. Therefore, no additional information is being provided. 

Request 51b Elaborate on the impacts on groundwater systems due to the injection of large 

untreated volumes of PAW. 


Request 51c Shell lists deep well injection as a treatment option to remediate contaminated pit 

lake waters. Explain how deep well injection remediates contaminated pit lake 

waters. 

Response 51c See the response to ERCB SIR 51a. 

Request 51d What regulatory process will Shell use for approval of the deep well injection of 

PAW if this option determined to be a necessary step? 

Response 51d See the response to ERCB SIR 51a. 



Shell states, “The project proposes to reuse all of this captured water in its 

bitumen extraction process. Because all available water is used, treatment would 

not provide extra water for use.” Also “makeup water from the Athabasca River 

is required to offset losses of water to tailings pore space (over 90%).” 

52a Explain “over 90%” in the above quote. 


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Section 7.1 

Response 52a Table 10-2 from the Pierre River Mine, Project Description, Volume 2 shows the 

annual water balance for the Pierre River Mine Project. According to this 

balance, the fraction of total water lost to tailings pore space (external and in-pit) 

versus total diverted water (Athabasca, basal water and runoff) is greater than 

90%. 

Request 52b What is the porosity of the sediments in the tailings ponds? 

Response 52b The porosity of the sediments in the external tailings disposal area is shown in 

Table ERCB 52-1. 


Table ERCB 52-1: Predicted Tailings Sediment Porosity 

External Tailings In-Pit 

Sediment Type Type Disposal Facility Facilities 

Coarse tailings Cell 0.37 - 

Beach 0.43 0.43 

Thickened tailings – 0.68 0.64 

Mature Fine tailings – 0.85 0.85 

TSRU tailings Solids 0.65 0.65 

Hydrocarbons 0.07 0.07 

Non-segregating tailings On-spec - 0.39 

Off-spec - 0.42 


Shell states, “Treatment of water would not reduce the total volume of water 

required to fill the pit lakes,” and “Maximizing the reuse of process-affected 

water released by tailings will minimize the amount of process-affected water 

inventory at the end of mine life.” 

53a How do these two quotes relate to one another? 

Response 53a The statements are unrelated. 

The first statement points out that, even by treating and reusing process-affected 

water throughout the operating mine life, there will be no change in the amount 

of water required to fill the pit lakes because, regardless of treatment, all 

available water is used in the extraction process. 

The second statement explains that Shell’s process-affected water inventory near 

the end of the mine life is primarily the result of releasing water from nonsegregating 

tailings as it consolidates over time in the backfilled mine pits. Shell 


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Section 7.1 

will use this process-affected water to the end of operations to minimize the 

amount of additional fresh makeup water required. This results in less processaffected 

water inventory at the end of the mine life, as opposed to storing and 

ultimately using it to fill pit lakes. 

Request 53b How will Shell ensure actual tailings volumes will not exceed estimated volumes? 

Response 53b The planning basis for estimating tailings volumes uses conservative assumptions 

related to time-dependant consolidation of tailings that will help to ensure the 

total volume of tailings generated does not exceed the ultimate tailings storage 

capacity at the Pierre River Mine. For example, as water is released during 

tailings consolidation, the reclaim systems in the external tailings disposal area 

and in-pit facilities will return the free water, via barge systems, to the plant for 

reuse. The planned tailings storage capacity considers only the water released 

upon initial discharge, not the additional incremental water volume that will be 

released over the life of the mine, thus conservatively overestimating the volume 

of the tailings deposit. 



Shell states, “Shell will maximize the recycling of process-affected water for 

reuse in extraction by not carrying any unplanned process-affected water 

inventories.” 

54a Provide further clarification for the above statement and define what is meant by 

“unplanned process-affected water inventories”. 

Response 54a The statement Unplanned process-affected water inventories refers to clear water 

inventories in excess of the required clear water zone in the tailings disposal 

areas. 

The key principle in maximizing the recycling of process-affected water is 

minimizing water retention within tailings impoundments, both within external 

and in-pit facilities. This is achieved by restricting the clear water zone in the 

tailings facilities, and recovering all water of sufficient clarity for reuse in the 

extraction process. 


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Section 7.1 


Shell states, “Groundwater quality will be considered acceptable when it can be 

demonstrated that, when released, it would have no adverse effects on the health 

of aquatic, terrestrial or human receptors.” Shell further states, “The actual 

percentage of seepage captured and sent back to the ETDA will depend on the 

results of the groundwater monitoring program that will be implemented to 

monitor the effectiveness of the mitigation measures (see EIA, Volume 4B, 

Appendix 4-9, and Section 2.1.4.3). If unacceptable quality is detected in 

groundwater originating from the ETDA, a groundwater response plan will be 

implemented.” 

55a Provide the discharge criteria that Shell will use to assess acceptability of 

released groundwater. 

Response 55a As described in the response to ERCB SIR 56, groundwater discharge criteria 

that will be used to assess the release acceptability will be evaluated using the 

following criteria: 

• a comparison against pre-mining or statistically established background 

values 

• a comparison against acceptable criteria, which may include Canadian Water 

Quality Guidelines, CCME, or ecological risk assessment methodologies 

Request 55b Provide details on the proposed monitoring program in terms of well locations, 

depths, and measured water quality parameters. 

Response 55b The EIA, Volume 4B, Appendix 4-9, Section 2.1.4.3 indicates that “monitoring 

wells will be installed along the perimeter of the ETDA in both the shallow and 

deep Quaternary deposits to monitor seepage and the effectiveness of the 

mitigation measures.” 

A list of analytical parameters to be measured to determine groundwater quality 

is provided in EIA, Volume 4B, Appendix 4-9, Section 2.1.3, Table 1. 

Request 55c What are the triggering criteria for considering the groundwater quality 

unacceptable? 

Response 55c The triggering criteria for considering the groundwater quality unacceptable 

would be based on a comparison against acceptable criteria, which may include 

Canadian Water Quality Guidelines, CCME, or ecological risk assessment 

methodologies. 


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Section 7.1 

As described in the response to ERCB SIR 56, key indicator parameters in the 

area of the ETDA will be identified based on the water quality of the tailings 

water and control limits will be defined for each key indicator parameter for each 

monitoring well. An exceedance of the control limits will trigger the initiation of 

the groundwater response plan, as stated in EIA, Volume 4B, Appendix 4-9, 

Section 2.1.5 and described further in the response to ERCB SIR 56. 

Request 55d What will be the monitored parameters taking into consideration the behaviors of 

various parameters? 

Response 55d The monitored parameters for the ETDA that would be taken into consideration, 

given the behaviours of various parameters, would include those listed in EIA, 

Volume 4B, Appendix 4-9, Section 2.1.3, Table 1. Once detailed groundwater 

characterization is complete, a set of indicator parameters will be developed for 

each specific area (see EIA, Volume 4B, Appendix 4-9, Section 2.1.4). In the 

area of the ETDA, key indicator parameters will be based on the water quality of 

the tailings water. 



Shell states, “an ETDA-specific groundwater response plan will be developed to 

mitigate effects on groundwater quality beyond the interception points.” 

56a Provide a detailed scheme outlining Shell’s response if groundwater 

contamination is found beyond the interception wells in the Athabasca River. 

Provide a proposal that includes a reporting mechanism, water quality criteria 

and a timeframe for mitigation. 

Response 56a If the monitoring program detects unexpected effects on groundwater quality, an 

incident-specific groundwater response plan will be implemented (see EIA 

Volume 4B, Appendix 4-9, Section 2.1.5, page 13) to mitigate adverse effects on 

groundwater quality beyond the interception wells. 

Groundwater Monitoring Program 

The groundwater monitoring program for the Pierre River Mine will include: 

• identifying key indicator parameters for groundwater quality in the area of 

the ETDA. This will be based on the water quality of the tailings process 

water. 

• implementing a groundwater monitoring network in the area of the ETDA, 

including monitoring wells near and far from the interceptor wells 


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Section 7.1 

• defining control limits (or trigger values) for each key indicator parameter for 

each monitoring well 

• evaluating the monitoring results for trends in parameter concentrations and 

exceedance of the control limits for each monitoring well. If a trend is 

identified, the monitoring well will be closely tracked and the possible causes 

for the observed trend will be reviewed. If the control limits are exceeded, 

the initiation of the groundwater response plan will be triggered. 

• reporting the groundwater monitoring results and trend analysis to AENV 

through the annual groundwater monitoring reports 

Groundwater Response Plan 

The groundwater response plan would consist of the following steps: 

1. Verification 

2. Confirmation 

3. Delineation 

4. Evaluation 

5. Mitigation 

1. Verification 

Once a parameter concentration above the control limit has been identified, the 

initial phase is to review all available information to more fully understand the 

issue. Verification involves confirming the analytical results, i.e., review 

laboratory QA/QC, laboratory verification of results and re-analysis; reviewing 

sampling QA/QC procedures, reviewing well integrity, and reviewing historical 

data. 

Many of these steps are conducted for routine groundwater monitoring, i.e., 

review field and laboratory QA/QC results and well integrity, but the 

Groundwater Response Plan requires specific detailed analysis and 

documentation of the process. If the suspect data point is found to be correct, it 

will trigger the confirmation phase of the response plan. 

2. Confirmation 

The objective of this phase is to confirm that the observed concentration is not an 

outlier. Once a parameter concentration above the control limit has been verified, 

the exceedance should be confirmed by additional sampling. As well, the 

groundwater sampling frequency should be increased to quarterly to allow for 

confirmation of recorded concentrations and for reviewing surrounding 

groundwater conditions and possible sources for the effects observed. The 

outcome of the confirmation step should be that: 

• if the parameter concentration remains above the control limit for three 

consecutive quarterly sampling events, an incident will be deemed to have 

occurred. This will trigger the delineation phase. 


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Section 7.1 

• if the parameter concentration remains below the control limit for three 

consecutive quarterly sampling events, the frequency of groundwater 

sampling will revert to the original monitoring frequency. The previous 

concentrations that were above the control limit will be deemed anomalous 

or outliers. 

With confirmation of an incident, Alberta Environment would be notified. 

3. Delineation 

Delineation of possible groundwater effects will be conducted in a staged manner 

so that high-quality information can be effectively obtained. During this process, 

the specific monitoring well where the exceedances have been observed will 

continue to be monitored quarterly. 

The delineation will include a detailed review of the available monitoring data, 

the use of non-intrusive techniques, such as geophysical surveys, and the 

installation of additional monitoring wells in each of the potentially affected 

aquifers or groundwater-bearing zones, to determine the horizontal and vertical 

extent of impacts. 

4. Evaluation 

The objective of the evaluation phase is to determine the need for further 

delineation and or mitigation. This involves compiling all information collected 

to date and developing a conceptual model that should include details on 

contaminate source zone characteristics, geology, background groundwater 

quality conditions, groundwater flow directions (lateral and vertical), the 

potential transport mechanisms, ion mobility, factors that will affect retardation 

or degradation, and downgradient receptors. Water quality data will be evaluated 

using the following approaches: 

• comparison against pre-mining or statistically established background values 

• comparison against acceptable criteria, which might include Canadian Water 

Quality Guidelines, CCME, or ecological risk assessment methodologies 

Follow-up action might range from conducting additional delineation activities, 

completing on of a risk assessment, implementation of mitigation measures, full 

scale remediation, to continued monitoring. Alberta Environmental would be 

provided with the proposed risk management strategy and the remediation plan 

for approval. 

5. Mitigation 

If the results of the evaluation phase indicate the need for mitigation, the level of 

risk posed by the incident will be assessed based on the type of contaminant 

detected, the transport and fate characteristics of that substance, the presence or 

absence of a pathway, and the potential end-point concentration at a 

downgradient receptor. A full-scale risk assessment (ecological or human health, 

or both) will also be considered when assessing mitigative measures. 


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Section 7.1 

Mitigation measures will be implemented to meet the site specific objectives. 

Timelines for mitigation will be determined on a case-by-case basis in 

consultation with Alberta Environment. 


Shell states, “The area of the Pierre River Mine is characterized by downward 

hydraulic gradients between the Quaternary deposits and the basal aquifer, so 

that the vertical direction of groundwater flow across the McMurray Formation, 

which will be mined out and backfilled with tailings, is downward, away from the 

Quaternary deposits.” 

57a Explain the discrepancy between the above statement and the fact that the 

basal aquifer is under confined conditions and then depressurized during ore 

mining to prevent upward groundwater flow. 

Response 57a The potential for upward groundwater flow from the basal aquifer only arises 

because of the mining and removal of the confining layers of the McMurray 

Formations, including oil sands, above the basal aquifer. The removal or 

reduction in thickness of this confining layer creates the potential for upward 

groundwater flow because of the resulting lower head conditions in the mined out 

areas. 

Request 57b What prevents the basal aquifer from contributing waters to the tailings deposit 

post mining? 

Response 57b Following mining, it is expected that recharge and discharge relationships in the 

basal aquifer will be similar to those estimated before mining (see EIA, Volume 

4A, Section 6.3.5.2, page 6-140). Therefore, it is expected that groundwater flow 

will be primarily downward between the tailings deposit and the basal aquifer 

because the groundwater levels in the reclaimed pits will be similar to pre-mining 

conditions. In addition, the basal aquifer in the Pierre River Mine mining area is 

generally thin, sparse, and poorly connected, thus minimizing the interaction 

between the tailings deposits and the basal aquifer. 

Request 57c Shell assumes that there is a downward hydraulic gradient; what is the fate of the 

seepage that seeps downward to the basal aquifer? 

Response 57c The Athabasca River is the regional discharge point for the basal aquifer. The 

effects of the project, including groundwater seepage, on water quality in the 

Athabasca River were assessed in EIA, Volume 4A, Section 6.5.7.3. The 

assessment concluded that the project would have negligible effects on key water 


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Section 7.1 

quality constituents and that changes in water quality in the Athabasca River 

would have negligible effects on aquatic, human and wildlife health. 


Shell states, “The rates of inflow presented for the Pierre River Mine LSA 

include lateral groundwater inflows to the LSA from up gradient areas.” 

58a Describe the simulation of lateral recharge from upgradient areas in the model. 

Response 58a Lateral groundwater inflow rates to the local study are (LSA) were calculated 

based on the simulated groundwater flows across the LSA boundaries in the 

regional groundwater model (see EIA, Appendix 4-1, Section 1.2.4.4, page 94). 

In the model, groundwater levels from the regional model were represented as 

general head boundaries at the lateral boundaries of the Pierre River Mine local 

model in layers 4 (base of Quaternary), 9 (Basal Aquifer) and 12 (Methy 

Formation). 



Shell states, “The Eymundson Sinkholes do not appear to have a marked 

influence on the groundwater flow pattern in the Quaternary deposits.” 

59a Provide the technical justification for this assumption including any geophysical 

surveys or detailed Karsts delineation studies. 

Response 59a The technical justification for this statement is the groundwater flow patterns 

illustrated in Figures 37 and 38 of the Hydrogeology Environmental Setting 

Report (WorleyParsons Komex 2007). Based on available groundwater-level 

information from piezometers in Quaternary deposits near the Eymundson 

Sinkholes, the groundwater flow patterns within and outside of the Eymundson 

Sinkholes Environmentally Sensitive Area (ESA) are similar. Overall, the 

groundwater flow patterns in the Quaternary deposits reflect topographical 

control and do not suggest any considerable alteration of the regional flow 

pattern within or near the Eymundson Sinkholes ESA. 


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Reference 

Section 7.1 

WorleyParsons Komex. 2007. Jackpine Mine Expansion and Pierre River Mine 

Project – Base Case Report. Prepared for Shell Canada Limited. Calgary, 

AB. Submitted December 2007. 

Request 59b How were Eymundson Sinkholes simulated in the groundwater conceptual 

model? 

Response 59b The Eymundson Sinkholes were not explicitly represented in the groundwater 

models developed for the project because the groundwater flow patterns in the 

Quaternary deposits were observed to reflect topographical control. Further, the 

sinkholes water level was near the crest of the sinkholes which is in general 

agreement with the inferred groundwater elevations of shallow Quaternary 

deposits. 


Request Environmental Setting Report, Hydrogeology, Figures, Figure 29. 

Shell illustrates “various cross-sections (G-G’, H-H’, and E-E’).” 

60a How were these cross-sections developed (sources of information, and 

interpolation method)? 

Response 60a The cross-sections were developed with the stratigraphic information interpreted 

from boreholes drilled for the hydrogeology environmental setting investigation 

for the Pierre River Mine (WorleyParsons Komex 2007) and from coreholes 

drilled by Shell. 

References 

The available geological data were processed through the VIEWLOG software 

(Earth fx, 2009), which uses geo-statistics (kriging) to create surfaces or crosssections. 

Earth fx. 2009. Borehole Data Management and Interpretation System. 

http://www.earthfx.com/earthfx/Software/VIEWLOG30/Overview/Geost 

atistics/tabid/94/Default.aspx 





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Section 7.1 

Request 60b Discuss the reasons for omitting the geological structure features. If possible 

provide various structural features. 

Response 60b Boreholes and coreholes used in the cross-sections did not investigate deeper 

than the Upper Devonian because no interaction between the Devonian aquifers 

and the Cretaceous and surficial aquifers is expected. Therefore, boreholes and 

coreholes did not encounter this structural feature. 

Reference 

Section 3.2.5 of the Hydrogeology Environmental Setting Report 

(WorleyParsons Komex 2007) discusses the geological structure features which 

are important to the hydrogeology of the region. The Sewetakun Fault occurs on 

the Precambrian surface and appears to influence hydraulic heads in the Middle 

Devonian aquifers. 




Request 60c Does cross-section E-E’ pass through the proposed ETDA? If not, then provide a 

scaled cross-section that reflects ETDA location relative to the underlying 

formations. 

Response 60c Figure ERCB 60-1 shows that cross-section E-E’ passes through the proposed 

ETDA. Figure ERCB 60-2 illustrates the location of the ETDA along crosssection 

E-E’. 


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Section 7.1 

Figure ERCB 60-1: Pierre River Mining Area – Hydrogeologic Cross-Section Locations 

and Monitoring Wells in the Local Study Area 


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Section 7.1 

Figure ERCB 60-2: Pierre River Mine Area – 

Hydrogeological Cross-Section E–E′ 


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Shell states, “Three potential tailings disposal sites were evaluated.” 

61a Provide justification for not considering the north east end of Lease 351. 

Section 7.1 

Response 61a The Pierre River Mine, Project Description, Volume 2, Section 13.3, states that 

the potential tailings disposal sites were evaluated based on the primary criteria, 

i.e., environmental, technical, operations and economics. Additional criteria 

include minimum ore sterilization, distance from the Athabasca River and 

distance from the plant. As the distance from the plant to the disposal site 

increases, the technical and operational factors become increasingly challenging. 

Therefore, the evaluation focused on potential southern sites as opposed to 

northern ones. 

Request 61b Why is the current proposed location considered the optimal location in light of 

the fact that it overlies the highest thickness of basal watersands (Figure 3-5)? 

Response 61b Thickness of basal watersands was not a primary evaluation criterion for locating 

the ETDA. Furthermore, the groundwater quality in the Basal aquifer beneath the 

proposed ETDA has high total dissolved solids (TDS), i.e., up to 85, 800 mg/l) 

(see the Hydrogeology ESR, Figure 29 and Table 11) which render it unsuitable 

as a fresh water source. 

Request 61c Were geophysical surveys conducted to assess the area beneath the proposed 

ETDA site to define any vertical and/or horizontal geological features (faults, 

cavities, sinkholes, etc.). 

Response 61c Further geophysical surveys will be conducted during the detailed design phase 

to assess the area beneath the proposed ETDA site to define any vertical or 

horizontal geological features. 


Request Volume 4A, Section 6.1.2, Page 6-159. 

Shell states, “Pre-development groundwater levels and flow direction in the 

basal aquifer.” 

62a What year was used for the pre-development groundwater levels? 


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Section 7.1 

Response 62a Groundwater levels were measured in May 2007 for the Pierre River Mine. 

These water levels are considered pre-development as other existing or approved 

facilities are not expected to have had any effects on the groundwater resources 

of the Pierre River Mine at that time (see EIA, Volume 4A, Section 6.3.6.1, 

page 6-156). 


Request Volume 4A, Section 6.1.2, Page 236. 

Shell states, “As such, proximity of a mine area to the Athabasca River does not 

influence predicted dewatering rates.” Also, “The water collected by the 

overburden dewatering system will be part of the open circuit, and will be routed 

to surface water bodies.” 

63a Was reverse recharge from the Athabasca River considered in case dewatering 

reaches a point below the river water head? 

Response 63a Figure 32 of the Hydrogeology Environmental Setting Report (WorleyParsons 

Komex 2007) illustrates that the overburden deposits in the Pierre River Mine 

lease area are perched above the Athabasca River valley and are not directly 

connected hydraulically to the river. 

Reference 

Reverse recharge (i.e., river seepage into the mine pit) because of overburden 

dewatering was considered, but water levels in the overburden deposits do not 

fall below the stage of the river since the overburden deposits are hydraulically 

separated from the river by about 10 to 30 m of McMurray Formation. 

WorleyParsons Komex. 2007. Hydrogeology Environmental Setting Report for 

the Jackpine Mine Expansion and Pierre River Mine Project. Prepared 

for Shell Canada Limited, Calgary, AB. Submitted December 2007. 

Request 63b Are there any quality control measures to ensure that overburden discharge 

routed to surface water bodies has not been contaminated by oil sands? 

Response 63b EIA, Volume 2, Section 19.2, page 19-12, states that all water drained from 

muskeg and overburden will be routed through sedimentation (polishing) ponds 

and controlled discharge points. No water will be released to receiving streams 

until applicable regulatory release criteria are met. 


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Section 7.1 

Request 63c What are the contingency plans in the event that the pumped groundwater quality 

does not meet release criteria and cannot be accommodated within the existing 

internal bonds? 

Response 63c In the unlikely event that the pumped groundwater does not meet release criteria 

and the volume exceeds the capacity of the planned storage ponds, Shell will 

adaptively manage the excess volume of water. This could be accomplished by 

increasing the number or capacity of the polishing ponds, or by redirecting the 

excess water to the closed-circuit system to be used in the process. 



Shell states, “The possibility that an intra-orebody aquifer exists appears remote 

given that such a feature has not been identified from the large number of core 

holes advanced in the mine area. Appropriate mitigation measures will be 

implemented should an intra-ore aquifer be encountered during mine 

operations.” 

64a Were there any other assessment techniques used to support this assumption (e.g. 

Seismic survey) in light of the fact that geotechnical boreholes may not provide 

enough clarity regarding structural geological features? 

Response 64a No additional assessment techniques have been used. If an intra-orebody aquifer 

does exist, it is unlikely to be a large, continuous feature since it has not been 

identified by the 400 to 800 meter grid core hole drilling in the mining area. 

Request 64b Were any glacial channels and/or seated faults identified and delineated in the 

modeled area? 

Response 64b No glacial channels were identified within the Pierre River Mine local study area. 

This result is in agreement with Andriashek and Atkinson (2007). 

Section 3.2.5 of the Hydrogeology Environmental Setting Report 

(WorleyParsons Komex 2007) discusses the Sewetakun Fault, which has been 

interpreted to occur on the Precambrian surface and could influence hydraulic 

heads in the Middle Devonian aquifers. The groundwater flow models accounted 

for the possible influence of this fault zone on the groundwater flow regime 

through a specific hydraulic conductivity zone (see EIA, Appendix 4-1, 

Section 1.2.2.3, page 26). 


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References 


Andriashek, L.D. and N. Atkinson. 2007. Buried Channel and Glacial-Drift 

Aquifers in the Fort McMurray Region, Northeast Alberta. Alberta 

Geological Survey, Earth Sciences Report 2007-01. 

Section 7.1 





Shell states, “This seepage will migrate towards (and potentially be captured by) 

the depressurization wells.” 

65a What is the fate of non-captured seepage in the basal aquifer? 

Response 65a The Athabasca River is the regional discharge point for the basal aquifer. The 

effects of the project, including groundwater seepage, on water quality in the 

Athabasca River were assessed in EIA, Volume 4A, Section 6.5.7.3. The 

assessment concluded that the project would have negligible effects on key water 

quality constituents and that changes in water quality in the Athabasca River 

would have negligible effects on aquatic, human and wildlife health. 



Shell states, “Substantial impacts to basal aquifer groundwater quality are not 

expected within this timeframe due to comparatively slow groundwater flow 

velocity.” 

66a Were the existing geological structures and characteristics (e.g. faults, secondary 

porosity, deep channels) considered in reaching this assumption? If yes, provide 

the technical approach used to incorporate those attributes. 

Response 66a Because of the low permeability of the overlying bitumen saturated sands, these 

geological features (faults, secondary porosity and deep channels) were 

considered to have no impact on the quality of the aquifer groundwater. 


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Section 7.1 

Shell states, “Simulation results suggest that in the absence of mitigation, TDS 

will have migrated through the overburden deposits to Big Creek and the 

Athabasca River valley by 2031 (Figure 6.3-90), 13 years after the initiation of 

ETDA operation.” 

67a Define the techniques (e.g. pumping tests, geophysical surveys, infiltration tests) 

and assumptions that were used in assigning the hydraulic parameters to the 

various formations in the conceptual model. 

Response 67a Within the local study areas (LSAs) for each of the Pierre River Mine and 

Jackpine Mine Expansion, hydraulic parameters were assigned based on 

geometric mean values calculated from single well response tests. The response 

tests were conducted on monitoring wells installed in Quaternary deposits and 

the McMurray Formation (including the basal aquifer) during the baseline 

hydrogeological investigation (WorleyParsons Komex 2007). 

Reference 


In areas outside of the Pierre River Mine and Jackpine Mine Expansion LSAs 

and for the Devonian formations, model hydraulic parameters were assigned 

based on the parameterization described in previous hydrogeology baseline and 

EIA investigations in the region. For some formations, other data sources (i.e., 

laboratory permeability testing and drill-stem testing data) were also reviewed if 

available well response testing (i.e., pumping test and single well response test) 

data were insufficient. 





In Figure 6.3-95, the ETDA is overlying the basal aquifer outcropping recharge 

area; and in Figure 6.3-102, the intercepting wells are only capturing horizontal 

flow from the overburden sediments. 

68a Was the direct contact of the external tailings dump area (ETDA) with the basal 

aquifer considered in the model? If yes, then discuss the assumptions considered 

to simulate this zone. 


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Section 7.1 

Response 68a The basal aquifer is separated from the external tailings disposal area (ETDA) by 

overburden and oil sand deposits. Therefore, as there is no direct contact with the 

ETDA, it was not considered in the model. 

Request 68b Most of the anticipated results are based on the model simulation only. Due to 

proximity of the mine and EDTA to the Athabasca River, has Shell considered 

any other seepage prevention measures at the source? If so, discuss these 

measures and identify the reasons for omitting them. 

Response 68b See the response to AENV SIR 17a for the ETDA seepage management 

measures that Shell has considered. 



Shell states, “Because of its low permeability, the buffer zone will be an effective 

barrier to eastward seepage.” 

69a Were seismic surveys performed to assess other geological features such as 

conduit paths, faults and deep channels which might enhance contaminant flow? 

What are the contingency plans in case such features exist? 

Response 69a Seismic surveys have not been conducted but it is unlikely that a large-scale 

geological feature exists in the mining area if it has not already been identified by 

core hole drilling in the mining area. 


If such geological features are identified in future detailed drilling programs for 

the Pierre River Mine area, Shell will assess the effects of such features on the 

low-permeability buffer zone and implement mitigation measures as appropriate. 

One such measure includes installing low permeability barriers, as described in 

EIA, Volume 4A, Section 6.3.6.2, page 6-237. 


Shell states, “Therefore, the general water quality issues and potential mitigation 

for the Project were scoped with reference to past EIAs and experience gained by 

the assessment team in undertaking those assessments and participating in the 

public hearings for the corresponding projects.” 


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Section 7.1 

70a How does the above statement meet Shell’s commitment to use Best Available 

Environmental Practices? 

Response 70a Shell uses best industry practices in its activities, including the preparation of the 

Pierre River Mine and Jackpine Mine Expansion environmental assessment. The 

quoted statement demonstrates that Shell has used the most current information 

available, and the advice of experts knowledgeable about water quality issues in 

the Athabasca area, which Shell believes represents best industry practices. 



Shell states, “Project releases will not contribute to BTEX concentrations.” Shell 

further states, “Gypsum and thickeners may be used in creating NST” and 

“Water and sediment quality changes due to the Project effects are not classified 

in this section.” 

71a Describe the potential for BTEX compounds in end products due to the 

breakdown of the solvent. 

Response 71a The solvent is paraffinic and does not contain substantial amounts of toluene, 

ethyl benzene or xylene. The solvent contains only a small amount of benzene, 

the impact of which has been included in the environmental assessment. The 

compounds in the solvent (primarily pentanes and hexanes) are not expected to 

decompose into BTEX compounds. 

Request 71b What are the environmental impacts of asphaltene disposal in the tailings pond? 

Response 71b The addition of asphaltenes to a tailings pond is unlikely to degrade the water 

quality of the tailings pond and is supported by current operations at the Muskeg 

River Mine. 

Request 71c Identify potential flocculants/thickeners (other than gypsum) that are being 

considered. 

Response 71c Alum is currently being investigated as an alternative to gypsum for creating 

non-segregating tailings. The types of flocculants being considered are anionic 

polyacrylamides, such as the Hychem AF246 flocculant currently used in the 

thickeners at the Muskeg River Mine. 


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Section 7.1 

Request 71d Discuss the cumulative impacts to the groundwater quality during the life cycle 

of the operation. 

Response 71d Cumulative impacts to groundwater quality during the life cycle of the operation 

are assessed in EIA, Volume 4A, Sections 6.3.5 to 6.3.7. 



Shell states, “The high background concentrations of these metals are 

characteristic of natural surface waters in the Oil Sands Region.” 

72a Provide references for this statement. 

Response 72a The statement cited indicates that the noted metals occur in natural surface waters 

in the Oil Sands Region at concentrations that exceed ambient water quality 

guideline values. Examples of where such concentrations have been exceeded 

and documented include: 

References 

• regional baseline data compiled by the Regional Aquatics Monitoring 

Program (RAMP 2006) 

• analytical results from water samples collected from natural surface waters 

by Alberta Environment (AENV 2006) 

• in environmental settings reports for the Pierre River Mine Project (Golder 

2007) 

• in applications by other oil sands operators (Golder 2005) 

AENV (Alberta Environment). 2006. Water Data System (WDS). Environmental 

Service, Environmental Services Division. Edmonton, AB. 

Golder (Golder Associates Ltd.). 2005. Water Quality Environmental Setting 

Report for the Suncor Voyageur Project. Prepared for Suncor Energy Inc. 

March 2005. Calgary, AB. 

Golder. 2007. Surface Water Quality Environmental Setting for the Jackpine 

Mine Expansion and Pierre River Mine Project. Submitted to Shell 

Canada Limited. 

RAMP (Regional Aquatics Monitoring Program). 2006. Regional Aquatics 

Monitoring Program (RAMP) 2005 Technical Report. Prepared for the 

RAMP Steering Committee. Submitted by the RAMP 2005 


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Section 7.1 

Implementation Team consisting of Hatfield Consultants Ltd., Stantec 

Consulting Ltd., Mack, Slack and Associates Inc. and Western Resource 

Solutions. Submitted April, 2006. 

Shell states, “Concentrations of metals and Polycyclic Aromatic Hydrocarbons 

(PAHs) in sediments of watercourses and water bodies are generally lower than 

the Interim Sediment Quality Guideline. There are occasional exceedance of the 

ISQG values by concentrations of chromium in the upper Muskeg River, zinc in 

the middle Muskeg River and arsenic in Stanley Creek. Concentrations of six 

PAHs also occasionally exceed the ISQG values. These PAHs are 

dibenzo(a,h)anthracene, C1-substituted naphthalenes, benzo(a)anthracene, 

chrysene, phenanthrene and pyrene.” 

73a What is the time period, framework and sampling sequence for these field 

analyses? 

Response 73a The time period, framework and sampling sequence for the field program 

conducted in support of the EIA are presented in Section 3.2.4 of the surface 

water quality environmental setting report (Golder 2007). A description of 

historical data sources used in the analysis is presented in Section 3.2.3 of the 

surface water quality environmental setting report (Golder 2007). 

Reference 

Golder (Golder Associates Ltd.). 2007. Surface Water Quality Environmental 

Setting for the Jackpine Mine Expansion and Pierre River Mine Project. 

Submitted to Shell Canada Limited. 

Request 73b Compare the streambed exceedences with the Interm Sediment Quality Guideline 

(ISQG) values. 

Response 73b Comparisons of Pierre River Mine area sediment quality data with sediment 

quality guidelines are presented in Appendix F of the environmental setting 

report and discussed in Section 3.5 of the environmental setting report (Golder 

2007). 

Reference 

Golder (Golder Associates Ltd.). 2007. Surface Water Quality Environmental 

Setting for the Jackpine Mine Expansion and Pierre River Mine Project. 

Submitted to Shell Canada Limited. 


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Request Appendex 4-1, Section 1.2.2.2, Page 12. 

Shell states, “Grid spacing was a uniform 500 m x 500 m.” 

Section 7.1 

74a How would the results of the sampling, if stratified, reflect the heterogeneity of 

the area (e.g., faces change, faults, rivers)? 

Response 74a The 500 m x 500 m grid cell is comparable to a legal subdivision (LSD) that has 

a size of about 400 m x 400 m. The cell provides sufficient horizontal resolution 

for the regional groundwater model over an area about 110 km x 120 km. 

Considering that the geological data were first interpolated and contoured to 

create a surface (e.g., top of McMurray Formation), which was then imported 

into the regional groundwater model, the 500 m x 500 m model grid cell used 

was compatible with the resolution of the available geological data and, 

therefore, reflected the heterogeneity present in the data set. 


The seven principal hydrostratigraphic units in the Regional Study Area (RSA) 

were represented using 12 model layers (see EIA, Volume 4B, Appendix 4-1, 

page 16) in order to provide adequate resolution of vertical groundwater flow 

within and between the units. This included: 

• three layers representing the Devonian formations 

• one layer representing the McMurray Formation basal aquifer 

• three layers representing the McMurray Formation oil sands 

• one layer representing the Clearwater and Grand Rapids Formations 

• four layers representing Quaternary deposits 

Request Appendix 4-1, Section 1.2.2.2, Page 25, Table 1. 

In Table 1, Shell refers to Calibrated Hydraulic Conductivity and Recharge 

Values in the Regional Model. Shell states, “as well as transient groundwater 

elevation data collected since the start-up of depressurization activities at the 

Syncrude Aurora North Mine and Albian Sands Muskeg River Mine.” 

75a Explain how values were initially estimated for the steady state calibration. 

Response 75a As discussed in the response to ERCB SIR 67a, hydraulic parameters were 

initially assigned within the Pierre River Mine and Jackpine Mine Expansion 

local study areas (LSAs) based on geometric mean values calculated from single 

well response tests conducted during the baseline hydrogeological investigation. 

In areas outside of the Pierre River Mine and Jackpine Mine Expansion LSAs 

and for the Devonian formations, model hydraulic parameters were initially 


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assigned based on the parameterization described in previous hydrogeology 

baseline, EIA, and other selected investigations in the region. 

Section 7.1 

Recharge values were initially assigned based on professional judgment by 

referencing calibrated model values from other EIAs conducted in the region and 

other studies in similar hydrogeologic settings in Alberta. 

Request 75b Are the hydraulic values for each formation uniform? 

Response 75b Table 1 indicates that: 

• hydraulic conductivity values were generally uniform for each given 

geological material 

• there are regional variations within a formation. For example, four hydraulic 

conductivity values are assigned to McMurray Formation oil sands and two 

hydraulic conductivity values are assigned to the basal aquifer, for a total of 

six different hydraulic conductivity zones for the McMurray Formation 

The EIA, Appendix 4-1, Section 1.2.2.3, page 26, indicates that a uniform 

specific storage value was applied to all model layers. 

Request 75c Were the hydraulic conductivity values for the basal aquifer compared with other 

sources? If yes, then provide a summary of those sources and their reported 

values. 

Response 75c Table E on page 16 of the Hydrogeology Environmental Setting Report 

(WorleyParsons Komex 2007) lists reviewed sources and values of basal aquifer 

hydraulic conductivity in the region. 

Reference 




Request 75d Provide a chart illustrating the change in groundwater elevation and quality for 

the monitoring wells used in calibration from the pre-development groundwater 

levels to the present levels. 

Response 75d Figure 21 in EIA, Volume 4B, Appendix 4-1, Section 1.2.2.5, illustrates the 

changes in groundwater elevation from pre-development to the end of the 

calibration period (the end of December 2005) for select transient calibration 

points for the regional groundwater model. 

Since the model was calibrated to historical depressurization activities at Albian 

Sands Energy Inc.’s Muskeg River Mine and Syncrude Canada Ltd.’s Aurora 

North Mine and the effects of depressurization at these facilities is bounded to 


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Reference 

Section 7.1 

the west by the Athabasca River, no transient data calibration points are located 

on the west side of the river where the Pierre River Mine will be located. The 

basal aquifer is thin and mostly absent in the Pierre River Mine area to be mined 

(see Figure 5 in EIA, Volume 4B, Appendix 4-1). 

Groundwater quality data are not used in the calibration of groundwater flow 

models. As indicated in EIA, Volume 4B, Appendix 4-1, Section 1.2.2.5, the 

groundwater flow model was calibrated to measured groundwater levels and 

baseflow estimates. 




Request 75e Provide a cross-section of monitoring wells relative to the Syncrude Aurora 

North Mine and Albian Sands Muskeg River Mine illustrating their depth and 

penetration of the formation. 

Response 75e Cross-sections through the Muskeg River Mine and the Aurora North Mine were 

provided in the Hydrogeology Environmental Setting Report (see Figures 5 and 

10) that was prepared for the Muskeg River Mine Expansion Project (Komex 

International Ltd. 2004). These figures are reproduced here as Figure ERCB 75-1 

and ERCB 75-2. The cross-section locations are shown in Figures 1 and 9b of the 

Hydrogeology Environmental Setting Report, reproduced here as Figure ERCB 

75-3 and ERCB 75-4). 

Reference 

Komex International Ltd. 2004. Hydrogeology Environmental Setting – Muskeg 

River Mine Expansion. Prepared for Shell Canada Limited. December 

2004. 


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Section 7.1 

Figure ERCB 75-1: Geological Cross-Sections A–A′ and 

B–B′ 


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Section 7.1 

Figure ERCB 75-2: Hydrogeological Cross-Sections C– 

C′, D–D′ and E–E′ 


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Section 7.1 

Figure ERCB 75-3: Regional and Local Study Areas, Cross-Section Locations, Regional 

Topography and Drainage 


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Section 7.1 

Figure ERCB 75-4: Piezometer Locations – McMurray 

Formation – Basal Aquifer 


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Request Appendix 4-1, Section 1.2.2.2, Page 26. 

Section 7.1 

Shell states, “The Sewetaken Fault property zone (Figures 10 to 12) was 

introduced to reflect the possible influence of this fault on the groundwater flow 

regime.” Shell further states, “A uniform specific storage value of 3.5 x 10-5 m-1 

was applied to all model layers” and “The base of the local and regional 

groundwater flow models was also defined as a no-flow boundary condition.” 

76a Does the Sewetaken Fault extend to the Fort McMurray formation and further to 

the top overburden formations? 

Response 76a The Sewetakun Fault does not extend to the McMurray or overburden 

formations. Since the Sewetakun Fault occurs on the Precambrian surface and 

appears to influence hydraulic heads in the Middle Devonian aquifers, the 

Sewetakun Fault property zone was only implemented in the model layers (layers 

10 through 12) representing Devonian Formations (see EIA, Appendix 4-1, 

Section 1.2.2.3, page 26). 

Request 76b What were the geophysical techniques used to delineate the vertical and 

horizontal geological structures within the project area? 

Response 76b The Sewetakun Fault occurs at a depth below that expected for hydrogeological 

interaction with project activities, so no delineation of this structural feature was 

deemed necessary. 

Request 76c How does a low specific storage value of 3.5 x 10-5 m-1 reflect the higher 

Storativity values for the Quaternary formations (unconfined aquifers)? 

Response 76c In the numerical model (MODFLOW), the layer type for the upper three of four 

layers representing the Quaternary formations was specified to be Type 3. In 

MODFLOW, a Type 3 model layer means that the transmissivity of the layer 

varies based on the saturated thickness and hydraulic conductivity of the aquifer 

and that the storage coefficient can vary between confined (specific storage) and 

unconfined (specific yield) values. Therefore, if the model calculated the water 

level in a cell to be below the top of the cell, the storage value would be 

represented by the specific yield. In the upper three layers of the model, the 

specific yield value was 0.1. 

Request 76d Why were constant head values not assigned to the local and regional model 

boundaries instead of the no-flow boundary? 


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Section 7.1 

Response 76d The lateral boundaries of the regional model were chosen to approximate natural 

hydrogeologic boundaries (i.e., groundwater flow divides). Given the large 

distance from these lateral model boundaries to the stresses (overburden 

dewatering and basal aquifer depressurization) investigated in the regional 

model, the location of these groundwater divides is not affected by these stresses. 

Therefore, the no-flow boundary representation is conceptually more consistent 

with the natural functioning of a groundwater divide than a constant head 

boundary. 

The lateral boundaries of aquifers represented in the local models were assigned 

General Head Boundary (GHB) conditions to represent regional hydraulic 

gradients. Head values assigned to these GHBs were derived from the regional 

model results. Lateral boundaries of aquitards represented in the local models 

were assigned no flow boundary conditions (consistent with predominantly 

vertical flow in these aquitards). 

In the case of the model bases, no significant groundwater flow exchange is 

expected between the Precambrian and Devonian formations (i.e. the Devonian 

formations are interpreted to form the base of groundwater drainage in the 

Athabasca River basin) and, therefore, a no-flow boundary is appropriate. 

Request 76e How was lateral horizontal recharge from various sources accounted for (e.g. 

Birch Mountain)? 

Response 76e As stated in the response to ERCB SIR 76d, the lateral boundaries of the regional 

model were chosen to approximate groundwater flow divides, which are natural 

hydrogeologic boundaries. This means that lateral groundwater flow does not 

occur across these boundaries. Groundwater recharge enters the flow system 

vertically through the top model boundary of the regional model. 


Also stated in the response to ERCB SIR 76d, the lateral boundaries of aquifers 

represented in the local models were assigned General Head Boundary (GHB) 

conditions to represent regional hydraulic gradients. These GHBs account for the 

lateral horizontal recharge from other sources, including Birch Mountain. 

Request Appendix 4-1, Section 1.2.2.2, Page 28. 

Shell states, “Tailings area seepage was not represented in the regional model 

because the purpose of the model was to simulate basal aquifer depressurization 

and overburden dewatering. Tailings area seepage was represented in the JEMA 

and PRMA local models.” 

77a As both stresses (source and sink) are occurring simultaneously, how does 

simulating basal aquifer depressurization and overburden dewatering provide 


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sufficient confidence when one ongoing stress in not accounted for by the 

regional model? 

Section 7.1 

Response 77a At the Pierre River Mine, the external tailings disposal area (ETDA) is separated 

from the mining area by about 3 km (see Figure 6.3-1 of EIA, Volume 4A, 

Section 6.3.1). Because of the physical separation, dewatering and 

depressurization activities at the mine site can be treated independently from 

ETDA seepage. 


At the Jackpine Mine Expansion, not incorporating seepage from the ETDA is 

considered conservative for overburden dewatering because of the ETDA 

seepage interceptor system that will be required for geotechnical purposes. This 

system would have been working for at least 10 years before overburden 

dewatering is required near the ETDA. Therefore, it would have, to some extent, 

effected drawdowns in the overburden material in the vicinity of the ETDA. By 

not incorporating ETDA seepage and the respective interception system, the 

overburden dewatering rates and duration are conservatively estimated. In 

relation to the basal aquifer depressurization, this aquifer is separated from the 

overburden deposits by the McMurray Formation, which is considered an 

aquitard. Therefore, ETDA seepage does not affect basal depressurization. 

Request Appendix 4-1, Section 1.2.4.2, Page 93, Table 8. 

In Table 8, Shell expresses Hydraulic Conductivity Values for Mine Materials in 

the Pierre River Mining Area Local Model. 

78a Provide the references used for assigning Hydraulic Permeability values for 

various materials listed in Table 8. 

Response 78a The hydraulic permeability values were determined independently based on 

values used in previous EIAs, professional experience and judgement. 

The hydraulic conductivity of 1 x 10 -8 m/s for mine pit backfill, as listed in EIA, 

Volume 4B, Appendix 4-1, Table 8, is in agreement with values used in previous 

assessments. In the Jackpine Mine Phase–1 EIA, Volume 3, Appendix VI, Table 

VI-3, page 38, (Shell 2002), the value for consolidated tailings (CT) was 1 x 10 -8 

m/s, and the value for mature fine tailings (MFT) was 2 x 10 -8 m/s. In the 

Muskeg River Mine EIA, Volume 3A, Appendix 3-1, Section 1.3.2.3, Table 1-6 

(Shell 2005), the hydraulic conductivity value for both non-segregating tailings 

(NST) and MFT was 1 x 10 -8 m/s. 

The fluid cells will contain thin fine tailings (TFT), which were assumed to be 

more permeable than the MFT because of the lower density of the TFT. 


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References 


Section 7.1 

Therefore, a hydraulic conductivity value of 1 x 10 -6 m/s was assigned to the 

fluid cells. 

The overburden cap hydraulic conductivity (1 x 10 -7 m/s) listed by Shell (2002; 

2005) is similar to the value (5 x 10 -7 m/s) listed in EIA, Volume 4B, Appendix 

4-1, Table 8, which was adjusted to reflect an average hydraulic conductivity 

value for overburden materials local to the Pierre River Mine area. 

EIA, Volume 4B, Appendix 4-1, Section 1.2.4.7, indicates that extensive 

prediction confidence simulations were conducted for the Pierre River Mine local 

model by varying the hydraulic conductivity values of mine pit backfill, fluid 

tailings and overburden capping by factors of 10 from calibrated values. This 

factor of 10 addresses the uncertainty in the expected properties of these 

engineered materials. 

Shell (Shell Canada Limited). 2002. Application for Approval of the Jackpine 

Mine – Phase 1. Submitted to the Alberta Energy and Utilities Board and 

Alberta Environment. May 2002. 

Shell Canada Limited. 2005. Application for Approval of the Muskeg River 

Mine Expansion Project. Submitted to the Alberta Energy and Utilities 

Board and Alberta Environment, April 2005. 

Request Appendix 4-1, Section 1.3.2, Page 102. 

Shell states, “The substances considered in this assessment represent a range of 

dissolved compound behaviors, including conservative (non-retarded and nondegradable), 

retarded and degradable constituents.” 

79a Discuss the chemical behavior pattern for non conservative constituents 

(Naphthenic acids and polycyclic aromatic hydrocarbons (PAHs)) in 

groundwater aquifers in terms of their adsorption tendency, fractionation 

(daughter products), organic carbon partitioning and oxidation-reduction 

potential. 

Response 79a The chemical behaviour of the indicator constituents included in the solute 

transport model, in terms of adsorption tendency (Kd) and anaerobic decay (halflife), 

are listed in EIA, Volume 4B, Appendix 4-1, Table 12. Organic carbon 

partitioning coefficients (Koc) for naphthenic acids, PAH Group 2 and PAH 

Group 8 were included in the distribution coefficients (Kd) by applying an 

organic carbon content fraction of 0.006 in the function Kd = Koc*foc. In the 

surface water quality assessment, retardation of PAH groups that were not 


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Section 7.1 

modelled explicitly in the solute transport model was applied based on structure 

similarity relative to indicator PAH groups. 

Anaerobic decay rates were applied to each PAH group and to labile naphthenic 

acids, as described in EIA, Volume 4B, Appendix 4-1, Table 12. 

No additional chemical or physical changes (e.g., oxidation-reduction potential) 

were modelled for naphthenic acids and PAHs in groundwater aquifers. If these 

processes occur, they will lead to reductions in solute concentrations beyond that 

predicted in the EIA modelling. Omitting these processes is, therefore, 

conservative. 


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TERRESTRIAL 

ERCB SIR 80 


Section 8.1 

Shell states, “Development of the Pierre River Mine requires diversion of natural 

watercourses during operations and at closure. Figure 20-2 shows these areas 

and their design features.” 

80a Provide an updated surface water diversion plan that ensures the diversion of 

natural watercourses during operations are integrated with future adjacent 

developers (e.g. UTS Energy Corporation/Teck Cominco Limited and CNRL). 

Response 80a The closure drainage plan for the Pierre River Mine (see EIA, Volume 4B, 

Appendix 4-4) shows that the Pierre River diversion closure channel will be 

integrated with the Canadian Natural Resources Ltd. closure drainage channel 

from Calumet Lake. 

The UTS Energy Corporation/Teck Cominco Limited Equinox Mine was not 

included in the EIA because the project was not publicly disclosed six months 

before the EIA was submitted and there remains insufficient publicly available 

information on this project for inclusion in an integrated closure drainage plan. 

Therefore, the drainage plan presented in EIA, Volume 4B, Appendix 4-4 is 

appropriate and complete. 

Shell is aware of the need to integrate drainage with its industry neighbours. 

Shell is currently in discussions with its neighbours and expects that their 

concerns will be addressed in the foreseeable future. 

Request 80b Provide an updated final closure and drainage plan for the Pierre River Mine 

that ensures the diversion of natural watercourses at closure are integrated with 

future adjacent developers (e.g. UTS Energy Corporation/Teck Cominco Limited 

and CNRL). 



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TERRESTRIAL ERCB SIR 80 

Section 8.1 


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ERRATA 

ERCB SIR 81 


Volume 1, Section 8.1, Page 8-4, Supplemental Information Responses. 

Shell states, “The Athabasca Oil Sands Project (AOSP) is a joint venture 

between: 

• Shell Canada Energy (60%) 

• Chevron Canada Limited (20%) 

• Marathon Oil Sands L.P (20%)” 

Section 9.1 

81a Verify that Shell Canada Energy, not Shell Canada Limited, is a joint venture 

participant in the AOSP. 

Response 81a Yes, Shell Canada Energy is a joint venture participant in the AOSP. 

Shell Canada Limited will hold all permits and approvals for the Pierre River 

Mine on behalf of Shell Canada Energy, which will operate the mine on behalf of 

the joint venture participants. 


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ERRATA ERCB SIR 81 

Section 9.1 


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PART 3: AENV SIRS – ROUND 2 


Request Volume 2, SIR 15, Page 15-8. 

GENERAL 

AENV SIRS 1 – 5 

Section 10.1 

Shell indicates that they are no longer considering an accelerated or closecoupled 

project execution scenario and are pursuing a more conservative 

execution plan, and consequently did not answer either SIR 15a or 15b. 

However, Shell also notes that if economic conditions change, they remain 

favourably positioned to revert to execution plans as presented in the original 

application and, once again, consider larger capital investments. 

1a Provide an overview of the potential environmental and social costs and benefits 

of pursuing a close-coupled or immediate development approach. 

Response 1a The environmental and social impacts associated with the close coupled (or 

immediate) development approach formed the basis of the Jackpine Mine 

Expansion and Pierre River Mine Project EIA that was submitted to the ERCB 

and Alberta Environment in December 2007 and updated in May 2008. 

Request 1b How does this compare to the potential environmental and social costs and 

benefits of delaying the development and/or increasing the time gaps between 

potential expansions? 

Response 1b As discussed in the December 2009 Jackpine Mine Expansion, Supplemental 

Information, Section 6.1, the broad scope of the original EIA assessment 

encompassed the possible impacts resulting from small project delays and 

concluded that no change to the EIA findings would occur. 

From an SEIA perspective, delaying the development or increasing the time gaps 

between expansions would create the need to demobilize and remobilize 

construction workforces. This would also delay the creation of long-term 

operations employment and associated revenues to government. In addition, 

population effects and associated service provider impacts would also be 

delayed. No other material impacts are expected. 


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GENERAL AENV SIRS 1 – 5 


Request Volume 1, Section 5, Page 5-10. 

Section 10.1 

Issues raised by the Community of Fort McMurray included adequate buffer 

zones along the Athabasca River and wildlife impacts. 

2a Provide further detail around the discussion held for these two issues. 

Response 2a These two issues were identified at an Open House held in Fort McMurray on 

May 1, 2008. This Open House was an open forum where community members 

could circulate among various project exhibits and ask questions of Shell staff in 

an informal atmosphere. Discussions regarding adequate buffers along the 

Athabasca River have been general and have related to: 


• maintenance of river navigability 

• access to the shoreline and visual impacts from the river 

Concerns associated with wildlife have generally focused on: 

• impacts to sport wildlife populations 

• changes to public access in areas used for hunting and trapping 

Request Volume 1, Section 4, Page 4-2; Volume 1, Section 4, Figure 3-2, Page 3-7. 

Shell describes the additional project components of two Class II landfills to be 

located adjacent to the plant site. One of these landfills is planned for the 

southeast corner of the plant site and appears to be approximately 250 m from 

the Athabasca River at its closest point. 

3a Given the toxicity of various waste categories planned for this site (e.g., 

asphaltene fired boiler and co-generation fly ash and bottom ash, contaminated 

debris and soils), discuss the rationale behind locating this landfill close to the 

Athabasca River. Describe how the potential for contamination of the river over 

time was considered during the planning process. 

Response 3a The original basis for landfill placement was to allocate enough area while 

minimizing ore sterilization and maintaining the required 250 m river corridor. 

Further work has since been carried out regarding one of the two proposed 

locations of the Class II landfill. From an ore sterilization and river proximity 

perspective, the easternmost landfill is now proposed to be located within the 

north overburden disposal area footprint (see Figure AENV 3-1). Any potential 

contamination from the landfill will be managed in accordance with Alberta 

Environment’s Code of Practice for Landfills. 


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Figure AENV 3-1: Revised Class II Landfill Site 

Section 10.1 


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Section 10.1 

Request 3b Present and discuss options for alternative landfill sites that are located further 

from the Athabasca River and which would reduce the potential for 

contamination of the river. 

Response 3b See the response to AENV SIR 3a. 

Request 3c Describe the design features planned for the class II landfills which ensure waste 

seepage will not contaminate groundwater and will not reach the Athabasca 

River. 

Response 3c Basic engineering has not been finalized on these landfills. Therefore, no 

information is available on their design features. As stated in the response to 

AENV SIR 3a, Shell will adhere to the appropriate Alberta codes and standards 

for designing Class II landfills and monitoring for any potential groundwater 

contamination. 


Request Volume 1, Section 4, Table 4-2, Page 4-8. 

Table 4-2 describes the various waste categories and disposal methods planned 

for the Pierre River Mine. One of the waste categories is domestic garbage, food 

remnants and food contaminated waste to be deposited in the class II landfill. 

4a What design features and mitigation measures will Shell employ to ensure that 

the landfills will not attract wildlife? Has Shell considered fencing the landfills 

to prevent access by wildlife? 

Response 4a A portion of the Class II Landfill will be designated for domestic waste (food 

remnants and food-contaminated waste) and will be fenced to prevent wildlife 

access. 

Request 4b What is meant by the column title ‘storage location’ in Table 4-2? For example, 

when ‘bin’ is listed as the storage location, as it is for domestic garbage, does 

that mean all domestic garbage will be placed in some sort of vessel, and then 

dumped in the landfill? Clarify how waste materials will be handled at the 

landfill sites. 

Response 4b The storage location refers to how the waste material will be stored or 

transported. As in the example, bin refers to the receptacle in which waste 

material will be held before being taken to a landfill for final disposal. Waste 

material will be handled at Shell’s on-site landfills according to the Code of 

Practice for Landfills. 


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Request Volume 2, SIR 13, Revised Table 13-1, Page 15-4. 

Section 10.1 

This table provides comments on the updated Waste Disposal Methods for the 

Pierre River Expansion Site. Two items in particular are proposed to be 

disposed of at the Regional Municipality of Wood Buffalo sewage lagoon 

facilities namely, filtered sewage cake and bar screenings. The address provided 

was the Regional Municipality of Wood Buffalo’s civic address. The Regional 

Municipality must be consulted for this service and there is no indication that 

this has been done. 

5a Provide confirmation from the Regional Municipality that they have been 

appropriately consulted regarding this specific question and that this is an 

acceptable practice and an acceptable solution for disposing of filtered sewage 

cake and bar screenings generated by the Project. 

Response 5a Personnel from the Fort McMurray Wastewater Facility, the new facility to 

replace the current sewage lagoon, confirmed acceptance of current and future 

sludge material from Shell’s facilities. They also confirmed that bar screenings 

would be better-suited for disposal in a landfill. Therefore, bar screenings will be 

placed in the on-site Class II Landfill. 

Table 4-2 of the May 2009 Pierre River Mine, Supplemental Information, 

Volume 1, has been updated with the new bar screening disposal method or 

location. The revised table is reproduced here as Table AENV 5-1. 


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Table AENV 5-1: Pierre River Mine Waste Categories and Disposal Methods 

Section 10.1 

Waste Description 

Waste 

Category Storage Location Disposal Method or Location 

Liquid 

Amine 268 N/A Recycle water pond 

Aluminum sulphate 113 Labelled drums Approved off-site disposal facility 

Boiler blowdown water 136 N/A Recycle water pond 

Cooling tower system blowdown 136 N/A Recycle water pond 

Equipment wash 254 N/A Recycle water pond 

Filter backwash N/A N/A Recycle water pond 

Flammable liquids 271 Labelled drums Approved off-site recycle facility 

Flammable liquids 211/212 Labelled drums Approved off-site recycler 

Floor wash 254 N/A Extraction dump pond 

Glycol 222 Above-ground tank Reuse as spray on ore conveyor 

belts 

Kerosene 221 Labelled drums Approved off-site recycler 

Laboratory waste – hazardous solids 

and liquids 

263 Labelled drums Approved off-site recycler or disposal 

Laboratory waste – non-hazardous 

solids 

N/A Bin On-site landfill 

Methanol 212 Labelled drums Approved off-site recycler 

Oily water N/A Sumps ETDA 

Paint-related material 145 Labelled drums Approved off-site recycle facility 

Potassium hydroxide 121 Labelled drums Approved off-site disposal facility 

Sanitary sewage 

Spent acids, acid solutions and 

washings 

N/A Collection system 

and treatment plant 

Spent caustics, alkali solutions and 

washings 

Sanitary sewage plant, treated 

sewage to recycle water pond 

114 Labelled drums Approved off-site disposal facility 


Spent solvents and solvent residues 211 Labelled drums Approved off-site recycler 

Steam condensate N/A N/A Approved off-site disposal facility 

Surface runoff water – clean N/A Industrial runoff 

collection ditch 

Surface runoff water – potentially oily N/A Industrial runoff 

collection ditch 

Recycle water pond 

Recycle water pond 

Transformer oil N/A Labelled drums Approved off-site recycler 

Vent or flare liquids N/A Flare knockout drum Returned to process 

Vessel drains N/A Sumps Returned to process or recycle water 

pond 

Waste oils (lubricating, hydraulic, 

transmission) 

252 Labelled drums, 

tank 

Approved off-site recycler 

Waste paint and paint-related materials 223 Labelled drums Approved off-site recycler 

Water contaminated with hydrocarbons 254 Labelled drums Approved off-site recycler 

Water treatment wastewater N/A N/A Recycle water pond 


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Solid 

Section 10.1 

Table AENV 5-1: Pierre River Mine Waste Categories and Disposal Methods (cont’d) 


Asphaltene-fired boiler and cogeneration 

bottom ash 


fly ash 


gypsum 

Asphaltene-fired cogeneration spent 

activated carbon 


spent catalyst 

Waste 


146 Silo On-site landfill 



261 Labelled drums On-site landfill 

153 Original package Returned to manufacturer 

Bar screenings N/A Vacuum truck On-site landfill 

Batteries 151 Labelled drums or 

bins 


Beverage containers N/A Recycle bin Approved off-site recycler 

Carbon filters (natural gas) 261 Filter housings On-site landfill 

Cardboard N/A Recycle bin Recycled 

Cartridge filters 256 Bin On-site landfill 

Construction material, wood, glass, other 

debris 

Contaminated debris and soil 138/275 Labelled drums or 

bins 

Corrosive solids N/A Labelled drums or 

bins 

275 Bin Recycled or sent to on-site landfill 

On-site landfill 

Desiccant (air dryers) 154 Bin On-site landfill 

Domestic garbage (food remnants and 

food-contaminated waste) 

N/A Bin On-site landfill 

Approved off-site disposal facility 

Drilling muds 272 Bin On-site waste dump 

Empty calibration gas and compressed 

gas cylinders 

Empty packages, drums, bags, 

containers 

331 Labelled drums or 

bins 

Empty, pressurized aerosol cans 145 Labelled drums or 

bins 

e-waste N/A Labelled drums or 

bins 


152 Bins, drums or pails Returned to supplier, reused or sent 

to on-site landfill 



Filtered sewage cake 274 Vacuum truck Regional Municipality of Wood 

Buffalo sewage lagoon 

Fluorescent lamps 153 Cardboard box Approved off-site recycler 

Ion exchange resin (softeners) 136 Labelled drums On-site landfill 

Kitchen grease N/A Grease bin Approved off-site disposal facility 

Oil filters from internal combustion 

engines 

275 Labelled bins Approved off-site recycler 


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Section 10.1 

Table AENV 5-1: Pierre River Mine Waste Categories and Disposal Methods (cont’d) 


Solid (cont’d) 

Oily rags, sorbent pads and materials 274 Labelled drums or 

bins 

Waste 


Approved off-site disposal facility or 

recycler 

Paper B3020 Recycle bin Recycled 

Peroxide N/A Labelled drums or 

bins 


Plastics, used N/A Recycle bin Approved off-site recycler 

Poison N/A Labelled drums or 

bins 


Scrap metal N/A Recycle bin Approved off-site recycler 

Sock filters 256 Bin Approved off-site recycler or on-site 

landfill 

Spent batteries (acid, alkali, nickelcadmium, 

lithium) 

1151 Labelled drums, 

containers 


Tires N/A Tire cage Approved off-site recycler 

Toner cartridges for copiers and printers N/A Original package Returned to supplier for recycle 

Waste inorganic chemicals, including 

laboratory packs 

Waste organic chemicals, including 

laboratory packs 

Sludge 

Truck wash sump 150 Drums and vacuum 

truck 



ETDA 

Heat exchanger bundle cleaning 251 Labelled container ETDA 

Oil and water separator 251 Labelled drums Approved off-site disposal facility 

Other 

First aid room waste N/A Marked hazardous 

biowaste containers 

Regional health centre treatment 

facility 


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AIR 

Request Volume 2, SIR 240a, Page 20-9 


Section 11.1 

6a Clearly describe the methods, the limitations of the methods used and the 

stochastic and empirical uncertainties in estimating predicted 1-hour average 

concentrations of benzene or TRS compounds and discuss the effects of these 

limitations on the assessment. 

Response 6a As stated in EIA Volume 3, Appendix 3-8, Section 3.2.1.5, the tailings pond 

fugitive emissions for the project were scaled from the Jackpine Mine – Phase 1 

tailings pond fugitive emissions presented in the Shell Jackpine Mine – Phase 1 

Project EIA (Shell 2002) on the basis of mined bitumen. The Jackpine Mine – 

Phase 1 tailings pond emissions were estimated by scaling the Baseline Case 

Muskeg River Mine emissions presented in the Syncrude Mildred Lake EIA 

(Syncrude 1998). The Jackpine Mine Expansion and Pierre River Mine tailings 

pond fugitive emissions were modelled at the constant maximum rate over the 

entire modelling period. The 1-hour, 24-hour and annual concentrations were 

predicted based on this emission rate. 

There are implicit uncertainties associated with using monthly emission rates 

rather than daily or hourly ones; however, this uncertainty is addressed by using 

the maximum emission rate for each month. It is not possible to predict 

concentrations due to hourly emission variations unless detailed monitoring data 

are available to aid in providing better estimates of emission rates from tailings 

ponds. Since there are no long-term hourly monitoring data available for tailings 

ponds in the region, the emissions were estimated based on data available from 

other EIAs. 

To determine how the CALPUFF model is performing in the Oil Sands Region, a 

performance evaluation was completed in EIA Volume 3, Appendix 3-8, Section 

2.5. This evaluation was conducted using the Existing Scenario model 

predictions (EIA, Volume 3, Appendix 3-8, Section 2.4) in comparison with 

available monitoring data. The Existing Scenario emissions were based on the 

assumed level of operations in 2002 and 2003. The fugitive VOC emissions from 

the tailings ponds in the Existing Scenario were estimated based on an annual 

average solvent loss of 4.0 to 4.5 barrels (bbl) of solvent per 1,000 bbl of bitumen 

produced. 


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AIR AENV SIRS 6 – 14 

Section 11.1 

Further analysis was completed for individual volatile organic compounds 

(VOCs) by comparing the Existing Scenario predictions with monitored 

concentrations. The VOC monitoring conducted in the region relies on noncontinuous 

techniques that collect 24-hour samples on a set schedule; therefore, 

only 24-hour and annual concentrations could be evaluated. 

A review of the monitoring data showed that higher concentrations were 

typically observed prior to 2008. This may be linked to higher annual average 

solvent losses as operators worked to optimize their solvent recovery technology. 

For example, the Shell Muskeg River Mine annual average solvent loss since 

2003 has ranged from 3.7 to 10.6 bbl of solvent per 1,000 bbl of bitumen 

produced (see the response to SIR 159a in the May 2009 Pierre River Mine, 

Supplemental Information, Volume 1. While solvent loss information was not 

available from other operators in the region, the annual average solvent losses 

from these operations are expected to have been variable as well. 

In 2008 and 2009, the monitored concentrations were generally lower and are 

thought to correspond to the solvent loss rates used for the Existing Case. For 

example, the Shell Muskeg River Mine annual average solvent loss was 4.0 bbl 

of solvent per 1,000 bbl of bitumen produced in 2008 (see the response to SIR 

159a in the May 2009 Pierre River Mine, Supplemental Information, Volume 1). 

Since the Existing Case tailings pond emissions were based on solvent losses of 4 

to 4.5 bbl of solvent per 1,000 bbl of bitumen produced, as stated previously, it is 

likely that the VOC predictions are more representative of the 2008/2009 period. 

When compared to the 2008/2009 monitoring data, the maximum 24-hour 

predictions were generally within the same range when outlier concentrations 

were excluded. The outlier concentrations were removed from the analysis since 

they were likely due to upset events, which were not considered in the model. 

Only two data points, which accounted for 2% of the data, were removed from 

one station in the analysis. 

The highest 24-hour benzene concentration monitored at Fort McKay in 

2008/2009 was 1.8 µg/m³. Outliers were not identified in the Fort McKay data; 

therefore, none of the monitoring data were excluded. The 24-hour predicted 

maximum concentration at Fort McKay was 1.4 µg/m³. This difference of 

0.4 µg/m³, while lower than the highest monitored concentration, is considered 

within the accuracy of the model. The annual average Existing Scenario benzene 

predictions were generally within 2 µg/m³ lower than 2008/2009 monitored 

values at all the stations; however, this is considered within the accuracy of the 

model. 

While this analysis focused on VOCs, the same conclusions can be made for TRS 

compounds which are also primarily emitted from tailings ponds. 


CR029



Request Volume 2, SIR 240c, Page 20-10. 

Section 11.1 

Shell states that Higher air temperatures predicted for future climate change 

scenarios might alter the monthly distribution of emissions. However, the annual 

average emission rates are not expected to change. 

7a Provide evidence to support the statement quoted above, or describe and quantify 

the uncertainties pertaining to potential future increases in VOC and TRS 

emissions under warmer climatic conditions in the future. 

Response 7a Many variables may affect tailings pond emissions including: 


• amount of diluent lost to the pond 

• pond water temperature 

• atmospheric conditions – wind speed, temperature, stability 

Based on the methodology used for determining variable emissions in the EIA, 

increasing the number of monthly degree days would not measurably affect the 

model predictions. This is because the annual average emission rate is assumed 

to be fixed at 40% of the diluent lost to the pond. Since the annual average 

emission rate is dependant only upon diluent loss, increasing temperature would 

not affect the emission estimate. Only the distribution of the emissions would be 

affected if the number of monthly degree days was increased. 


Though the formulae used for both the Ambient Ratio Method (ARM) and Ozone 

Limiting Method (OLM) methods were not provided, and hence cannot be 

independently validated. The outcome may be consistent with what is cited in the 

response to the SIR, however it appears to contradict the text associated with 

Tables 244-1 thru 244-3, where the textual response states: The maximum 

concentrations associated with the Jackpine Mine Expansion and the Pierre 

River Mine project NOx emissions are expected to occur at locations close to the 

large mine area sources. The predicted NO2 concentrations at these locations 

are typically much higher than the predicted concentrations at communities or 

location further away. 


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TABLE 1 - THEOROETICAL NO2 VALUES USING OLM AND ARM 

NOx (ppm) OLM NO2 (ppm) ARM NO2 (ppm) 

0.000 0.000 0.000 

0.050 0.050 0.009 

0.100 0.060 0.018 

0.150 0.065 0.027 

0.200 0.070 0.036 

0.250 0.075 0.045 

0.300 0.080 0.054 

0.350 0.085 0.063 

0.400 0.090 0.072 

0.450 0.095 0.081 

0.500 0.100 0.090 

0.550 0.105 0.099 

0.600 0.110 0.108 

0.650 0.115 0.117 

0.700 0.120 0.126 

0.750 0.125 0.135 

0.800 0.130 0.144 

0.850 0.135 0.153 

0.900 0.140 0.162 

0.950 0.145 0.171 

1.000 0.150 0.180 

Section 11.1 

Tables 244-1 thru 244-3 indicate that the maximum NO2 concentrations occur 

approximately 20+ kilometres from the emission sources. This outcome is 

contradictory to the text noted above which indicates that the higher NO2 

concentrations will occur at close locations. 

8a Revise the text and/or tables to correct this apparent contradiction or 

inconsistency so that this component can be properly assessed. 

Response 8a The maximum 1-hour, 24-hour and annual nitrogen dioxide (NO2) predictions 

outside developed areas in the local study area (LSA) and regional study area 

(RSA), as shown in Tables 244-1 to 244-3, are related to other existing or 

approved mining projects (e.g., Imperial Oil Resources Ventures Limited Kearl 

Oil Sands Project). Therefore, the concept that predicted NO2 concentrations at 

locations close to major oxides of nitrogen (NOx) emissions sources are typically 

much higher than the predicted concentrations at communities or locations 

further away is valid. 


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Section 11.1 

Request 8b Shell states Overall, the results show that the maximum NO2 predictions near the 

major NOx emissions sources using ARM are lower than the OLM results. Based 

on the application of the OLM formulation as noted in Table 1, this statement 

should be corrected to allow a complete assessment of this component of the EIA. 

Response 8b The ambient ratio method (ARM) formula is provided in EIA Volume 3, 

Appendix 3-8, Section 2.3.5 and was applied to each model hour. The formula is 

provided below for reference. 

Syncrude North 

where: 

Mine 

[ NO 

[NO2] = nitrogen dioxide concentration [ppm] 

2 −0. 

608 

= 0. 

100× 

[ NO ] 

[ NO ] 

X 

X 

[NOx] = oxides of nitrogen concentration [ppm] 


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] 

The ozone limiting factor (OLM) formula from the Air Quality Model Guideline 

(AENV 2003) is as follows: 

If [O3] > 0.9x[NOx] then [NO2] = [NOx] 

otherwise [NO2] = [O3] + 0.1x[NOx] 

where: 

[O3] = ozone concentration [ppm] 

[NO2] = nitrogen dioxide concentration [ppm] 

[NOx] = oxides of nitrogen concentration [ppm] 

Hourly ground-level ozone observations from the Wood Buffalo Environmental 

Association (WBEA) Fort McKay air quality monitoring station for 2002 were 

used in the OLM formula. The year 2002 was chosen to coincide with the 

meteorological data and modelling year. The OLM formula was applied by 

matching the hourly NOx predictions with the hourly monitored ozone 


Since the background ozone concentrations and the predicted NOx concentrations 

vary by hour, it is not feasible to show calculations for every hour; however, 

example values are shown in Table AENV 8-1. These sample calculations show 

that either the OLM or the ARM method can produce higher NO2 predictions 

based on the hourly NOx and ozone concentrations. However, based on the 

results in the May 2009 Pierre River Mine, Supplemental Information, Volume 2, 

SIR 244, Tables 244-1 to 244-3, the ARM-based 1-hour and 24-hour NO2 

predictions are consistently lower than those derived from the OLM when 

considering locations near the major NOx sources (e.g., active mine areas).


Table AENV 8-1: Example Hourly OLM and ARM NO2 Concentrations 

Hour 

Predicted NOx 

Concentration 

[µg/m³] (ppm) 

Observed 

Ozone 

Concentration 

[µg/m³] 

OLM NO2 

Concentration 


ARM NO2 

Concentration 


1 1,000 (0.532) 0.008 115 (0.061) 147 (0.078) 

2 1,050 (0.558) 0.010 143 (0.076) 150 (0.080) 

3 900 (0.479) 0.007 146 (0.078) 141 (0.075) 

4 800 (0.425) 0.005 127 (0.068) 135 (0.072) 

5 850 (0.452) 0.006 179 (0.095) 138 (0.073) 

Note: Unit conversions from µg/m³ to ppm are based on the molecular weight of NO2 and 

standard conditions of 25°C and 101.325 kPa. 

Reference 

Section 11.1 


the Science and Standards Branch, Environmental Services Division, 


Request 8c Provide the data and formula used to generate the ARM or OLM NO2 

concentrations and provide an example of the calculations to verify the data 

contained in Tables 244-1 thru 244-3. 

Response 8c See the response to AENV SIR 8b. 



The question that was raised in the SIR was fundamentally: “Will the CWS for 

PM2.5 be met when engine deterioration is included in the emission estimates?” 

9a Provide the details of how the model was employed, including but not limited to 

the data sets used, their statistical robustness, the numerical analysis, 

redundancy testing, model confidence and reliability and limitations of the model 

that allow confirmation of the EIA statements. 

Response 9a The NONROAD methodology (United States Environmental Protection Agency 

[US EPA] 2005) for estimating mine fleet emissions includes several key 

elements. First, it has developed emission factors for different vehicle types and 

ratings representing steady-state vehicle operation. Second, the NONROAD 

methodology includes a load factor accounting for the fact that mine vehicles 

cannot constantly operate at their maximum rated horsepower. Last, it 


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Vehicle Emissions 

Section 11.1 

incorporates the emissions profile for a mobile engine during transient operating 

conditions and takes into consideration the engine’s deterioration over time. 

The NONROAD model estimates emission rates for a single vehicle based on the 

following equation: 

= Vehicle Horsepower × Steady − State Emission Factor × GrossOperating 

Hours × 

Load Factor × Transient Adjustment Factor × Deterioration 

Factor 

The steady-state emission factors from the US EPA NONROAD are summarized 

in Table AENV 9-1. The transient adjustment factors and deterioration factors 

from the NONROAD methodology are presented in Table AENV 9-2. The load 

factors from the NONROAD methodology are listed in Table AENV 9-3. 

Inputs to the NONROAD model, including the engine rating, tier, operating 

hours and other characteristics associated with the vehicle fleet, are subject to the 

accuracy and availability of project specific data. The assumptions and 

parameterizations used in the model are required to simplify the calculation of 

mobile exhaust emissions, which inherently introduces limitations to the 

accuracy of the emissions. However, the NONROAD model has become widely 

accepted and provides results that are representative of project conditions. Details 

regarding the NONROAD model formulation, confidence, reliability and 

limitations are provided in two US EPA documents (US EPA 2005; 2009). 

Table AENV 9-1: Steady-State Emissions Factors for Nonroad Diesel Engines 

Model Emission Factors (Zero-Hour, Steady-State) [g/bhp-hr] 

Category of Vehicle 

Vehicles 300 to 600 bhp 

Year NOx CO PM HC 

tier 1 1996 6.015 1.306 0.201 0.203 

tier 2 2001 4.335 0.843 0.132 0.167 

tier 3 2006 2.500 0.843 0.150 0.167 

tier 4 final 

Vehicles 600 to 750 bhp 

2011 0.276 0.084 0.009 0.131 

tier 1 1996 5.822 1.327 0.220 0.147 

tier 2 2002 4.100 1.327 0.132 0.167 

tier 3 2006 2.500 1.327 0.150 0.167 

tier 4 final 

Vehicles >750 bhp 

2011 0.276 0.133 0.009 0.131 

tier 1 2000 6.153 0.764 0.193 0.286 

tier 2 2006 4.100 0.764 0.132 0.167 

tier 3 - - - - - 

tier 4 final 2011 2.392 0.076 0.069 (a) 0.282 (a) 

Note: 

(a) Tier 4 transitional emission factors that are more conservative than tier 4 final emission factors are used for both 

particulate matter (PM) and hydrocarbon (HC) emissions. 

- = No criteria available. 

Source: US EPA NONROAD Methodology (US EPA 2004). 


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Section 11.1 

Table AENV 9-2: Transient Adjustment and Deterioration Factors for Nonroad Diesel 

Engines 

Category of Vehicle 

Transient adjustment factors 

NOx CO PM HC 

tier 1 0.95 1.53 1.23 1.05 

tier 2 0.95 1.53 1.23 1.05 

tier 3 1.04 1.53 1.47 1.05 

tier 4(a) – – – – 

Deterioration factors(b) 

tier 1 1.024 1.101 1.473 1.036 

tier 2 1.009 1.101 1.473 1.034 

tier 3 1.008 1.151 1.473 1.027 

tier 4 1.008 1.151 1.473 1.027 

Note: 

(a) There is no transient adjustment factor for tier 4 engines since transient emission control is expected to be an integral part 

of all tier 4 engines. 

(b) Engines are assumed to be at the end of their median life to have conservative deterioration factors in calculations. 

- = No criteria available. 


References 

Table AENV 9-3: Load Factors for Nonroad Diesel Engines 

Category of Vehicle Load Factor 

truck 0.58 

shovel 0.58 

dozer 0.58 

grader 0.58 

pipe layer 0.58 

cable reeler 0.58 

excavator 0.53 


US EPA. 2004. Exhaust and Crankcase Emission Factors for Nonroad Engine 

Modelling – Compression Ignition. Prepared by the Office of 

Transportation and Air Quality, Research Triangle Park, NC. Report No. 

NR-009c. 

US EPA. 2005. Technical Highlights – Frequently Asked Questions About 

NONROAD 2005. Prepared by the Office of Transportation and Air 

Quality, Research Triangle Park, NC. Report No. EPA420-F-05-058. 

US EPA. 2009. NONROAD Model (nonroad engines, equipment, and vehicles). 

http://www.epa.gov/oms/nonrdmdl.htm#model. Accessed October 2009. 


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Section 11.1 

The CALMET (meteorological component of the California Puff Model System) 

file input options were provided however there is one inconsistency when 

comparing the 1995 and 2002 files. The upper air station WSE (Stony Plain) has 

a significantly different easting associated with it: 692.114 km E in 1995 and 

294.641 km E in 2002. All other upper air, surface and precipitation stations are 

consistent between 1995 and 2002. This error or inaccuracy may have a 

significant effect on the results of the model but can only be definitively answered 

by correcting the data. That is, a difference in distance of this magnitude is 

likely to have an effect on the meteorological parameters assumed in the 

modeling and therefore on the predicted air quality results but this cannot be 

presently determined. It may be that the data input files which indicate for both 

the 1995 and 2002 runs, that the UTM zone used was 12 (the correct Zone is 11) 

indicates that the positioning of the Stony Plain station for 2002 was inaccurate, 

displaced by approximately 400 kilometres to the west near the Rocky 

Mountains. It effectively means that the Stony Plain meteorological data were 

not used in the dispersion modeling analysis. 

10a How does this error affect the California Puff Model (CALPUFF) results? 

Response 10a The coordinates of the Stony Plain upper air station were incorrect in the 1995 

CALMET data set but were correct in the 2002 CALMET data set. Because of 

the considerable distance between the Stony Plain station and the project (about 

450 km) and since the interpolation of the observations in CALMET is based on 

the inverse-squared method, the influence of these observations would be 

negligible in the project region. In addition, the Fort Smith upper air station is 

located about 300 km north of the project region and would likely have a greater 

influence than the Stony Plain station. 

To determine the effect of the incorrect location of the Stony Plain upper air 

station in the 1995 CALMET data set, a comparison of the original 1995 

CALMET and the corrected 1995 CALMET data (i.e., the Stony Plain upper 

station location corrected) for the grid cell containing the Pierre River Mine plant 

site was completed. The analysis included a comparison of hourly values of 

CALMET-derived mixing height, stability class and vertical profiles of 

temperature, wind speed and wind direction. The comparison of the hourly data 

indicated the following: 

• Mixing Height – Twelve hours of the 8,760 hours in the year had a difference 

greater than 5 m. The largest difference was 24 m. 

• Stability Class – Four hours out of the year had a difference in stability class 

• Temperature – Four hours out of all the levels showed a difference greater 

than 0.5°C. 

• Wind Speed – There were no hours with a difference greater than 0.5 m/s. 


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Height Above Ground (m) 


3,000 

2,500 

2,000 

1,500 

1,000 

500 

3,000 

2,500 

2,000 

1,500 

1,000 

Section 11.1 

• Wind Direction – A total of 11 hours at all levels had a difference greater 

than 5 degrees. 

Figure AENV 10-1 presents vertical profiles of temperature, wind speed and 

wind direction for the grid cell containing the Pierre River Mine plant site for two 

hours with the largest difference in wind direction. These comparisons show that 

the difference between the CALMET data sets is negligible; therefore, the 

CALPUFF predictions would not be measurably affected by the incorrect Stony 

Plain station location used in the 1995 CALMET data set. These differences 

would also not change the conclusions of the air quality impact assessment. 

0 

260 265 270 275 280 285 290 

Temperature (K) 

Original 1995 CALMET 

Corrected 1995 CALMET 

500 

0 

270 275 280 285 290 295 

Temperature (K) 




Height Above Ground Ground (m) 

3,000 

2,500 

2,000 

1,500 

1,000 

500 

May 4, 1995 2 p.m. 

0 

0 2 4 6 

Wind Speed (m/s) 



August 15, 1995 1 p.m. 

3,000 

2,500 

2,000 

1,500 

1,000 

500 

0 

0 2 4 

Wind Speed (m/s) 



6 

0 

0 100 200 300 

Wind Direction (deg) 




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Height Above Ground Ground (m) 

3,000 

2,500 

2,000 

1,500 

1,000 

500 

3,000 

2,500 

2,000 

1,500 

1,000 

500 

0 

0 100 200 300 

Wind Direction (deg) 



Figure AENV 10-1: Comparison of Temperature, Wind Speed and Wind Direction Vertical 

Profiles


Section 11.1 

Request 10b What might the range of new values be if the model was to be re-run, and how 

are these estimates are arrived at? 

Response 10b As discussed in AENV SIR 10a, the effect of the incorrect location of the Stony 

Plain upper air station in the 1995 CALMET data set was negligible; therefore, 

the CALPUFF predictions would not be measurably affected. 

Request 10c What is the statistical level of confidence that supports the estimated change in 

any of the expected outcomes? 

Response 10c As discussed in AENV SIR 10a, only a few hours of the 1995 CALMET data set 

were affected by the incorrect location of the Stony Plain upper air station. While 

it is not possible to determine the statistical confidence, professional judgment 

suggests that the CALPUFF predictions would not be measurably affected. 



In concert with the concerns raised with SIR 247, Shell provides a data 

validation of MM5 with two supporting figures. Figure 249-2 in particular 

compares the upper air results for a particular sounding in 1995. As can be seen 

in this figure, at lower altitudes the MM5 and Fort Smith data are comparable 

while the Stony Plain data are different. All three data sources show good 

agreement at higher altitudes. 

Given the problem with the easting coordinate for Stony Plain in 1995 as 

previously noted, any errors in the projected wind field will be more prevalent at 

lower altitudes as opposed to the higher levels. Such errors would have a much 

greater effect on dispersion of air pollutant emissions at the lower altitudes, 

meaning that the concurrence of the data at the higher altitudes is largely 

irrelevant. 

11a Verify that the displacement of the Stony Plain upper air station does not affect 

the rawinsonde data used in the modeling, and as such did not affect the 

predicted dispersion modeling results. 

Response 11a The displacement of the Stony Plain upper air station does not affect the 

rawinsonde data used in the modelling and the CALPUFF predictions would not 

be measurably affected. 

The effects of the displacement of the Stony Plain upper air station in the 1995 

CALMET data set were assessed in AENV SIR 10a. The vertical profiles of 

temperature, wind speed and wind direction for the grid cell containing the Pierre 


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Section 11.1 

River Mine plant site shown in that response illustrate that the difference between 

the original 1995 CALMET data set and the corrected data set is negligible. 

Request Volume 2, SIR 250b i-ii, Page 20-43. 

Shell indicates that the failure of the SO2 control equipment is expected to be 

once in every 17 years, and that the determination of this probability is consistent 

with the technique outlined in the EPRI FGD Redundancy Development 

document cited in the question. 

12a Provide supporting information on the calculation of SO2 control equipment 

failure probability, and demonstrate that the method used to estimate failure rate 

probability is consistent with the EPRI document. 

Response 12a The SO2 control equipment failure frequency was estimated by an engineering 

contractor engaged by Shell. Based on a preliminary equipment scope, Shell 

worked with an equipment manufacturer to incorporate industry experience on 

FGD reliability performance. Although this is not necessarily consistent with the 

EPRI document as stated in the response to SIR 250bii in the May 2009 Pierre 

River Mine, Supplemental Information, Volume 2, Shell believes that this level 

of reliability is achievable and reasonable at this stage of the process design. The 

level of design detail required by EPRI would typically be dealt with during the 

detailed engineering phase of the project. 


Despite this preliminary scope, it is expected the SO2 control equipment will 

have a high availability (see the response to ERCB SIR 40). In addition, the 

boiler and burner design will be capable of switching to natural gas on short 

notice (about 15 minutes) if the FGD system fails. 

Request Volume 2, SIR 250e, Page 20-47. 

An equipment failure rate of once in 17 years would not be considered an 

“unlikely” event based on the EPRI method of evaluating SO2 control systems 

because it means that the equipment is likely to fail at least once during the life of 

the facility. Furthermore, a probability of equipment failure of once in 17 years 

does not mean that the equipment will fail only once in every 17 years. For 

example, the equipment could fail twice in a 10 year period, and then not again 

for the next 25 years and still remain within the 1-in-17 year probability failure 

rate. 


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Section 11.1 

Risk management requires that the criticality of the failure be considered. This 

requires that both the probability and the consequence of failure be considered 

jointly. A piece of equipment that fails frequently but whose failure carries little 

consequence poses a low risk. On the other hand, equipment that has a low 

frequency of failure but whose failure has serious consequences is a high risk 

management issue. In the response to this SIR 250d, Shell acknowledges that 

there is a potential to create concentrations sufficient to cause acute injury to 

vegetation. 

13a Discuss potential human health effects as a result of accidental releases of SO2. 

Provide quantitative evidence in support of the discussion. 

Response 13a The health assessment for this upset scenario was included in EIA, Volume 3, 

Appendix 3-8, Section 4.3.3. 


As part of the health assessment, maximum predicted ground-level air 

concentrations of SO2 were compared to varying concentrations at which health 

effects are known to occur. As discussed, the aim of the health assessment was to 

establish the nature and severity of the health effects related to the predicted air 

concentrations associated with the described upset events. 

The findings of the health assessment indicated that some of the predicted SO2 

concentrations were high enough to potentially cause adverse health effects. 

However, Shell has committed to redundant SO2 pollution control equipment that 

will switch to natural gas within 15 minutes and, consequently, decrease the 

exposure time. 

Request Volume 2, SIR 235a, Page 20-2. 

Shell indicates The typical odour threshold for each compound was determined 

by calculating the geometric mean of the available odour thresholds. It is 

common practice in sensory evaluation to use geometric means as they account 

for the wide range of responses over several orders if magnitude. The SIR 

response then demonstrates the calculation of an H2S threshold using the 

maximum and minimum values from the 9 pieces of cited literature. The 

calculation assumes that all of the reported H2S odour thresholds in the cited 

references are equally valid in calculating the geometric mean. Many of the 

references Shell cites for odour thresholds are outdated and not appropriate for 

the objective of assessing the effects of odour. More recent sources of 

information provide confirmation of much lower odour thresholds for H2S (e.g., 

Harvard University 2005 1 ; Iowa State University 2004 2 ; Lenntech 2006 3 ). All of 

these sources confirm an odour threshold of 1 ppb for H 2 S. The use of the 

geometric mean concentration value of 14 µg/m 3 underestimates H2S odour 

impacts due to the proposed development knowing that there are observation 

data to demonstrate that H2S is detectable at instantaneous odour concentrations 


CR029


Section 11.1 

as low as 1 ppb (0.7 µg/m 3 ) by individuals who have been tested and found to 

have a sense of smell that falls within the normal range of the general 

population. 

______________________ 

1 Harvard University 2006. Comparison of Odor Thresholds and PEL’s/TLV’s of 

Some Substances. http://research.dfci.harvard.edu/ehs/PPE/Respirators/ 

2 Iowa State University 2004. The Science of Smell Part 1: Odor Perception and 

Physiological Response. PM 1963a, May 2004. 

3 Lenntech Holding B.V. 2006. Odorous Substances (Osmogenes) and Odor 

Thresholds. http://www.lenntech.com/table.htm 

14a Justify use of the geometric mean when, as Shell indicates, much lower available 

and scientifically valid thresholds could have been used. 

Response 14a If the hydrogen sulphide (H2S) odour threshold were set to 0.7 µg/m 3 , the 

predicted frequency of hours with concentrations above this revised odour 

threshold would increase. However, the odour threshold used in the EIA is 

appropriate for the following reasons: 

• One of the five guiding principles for developing the Federal National 

Ambient Air Quality Objectives (NAAQOs) states that the objectives should 

recognize the variable sensitivities of subgroups of the Canadian population 

and of particular ecosystems and organisms in the environment. Because of 

the large range of these sensitivities, it might not be possible to protect every 

sensitive individual and ecosystem from all effects (WGAQOG 1996). The 

use of an H2S odour threshold of 0.7 µg/m³ would overestimate odour 

impacts. 

• The typical H2S odour threshold of 14.1 µg/m³ is similar to the 1-hour 

Alberta Ambient Air Quality Objective (AAAQO), which is based on odour 

perception and is meant to protect the general population. The AAAQO is 

also one of the most stringent in Canada and the United States (AEP 1999; 

AENV 2004). 

• It is common practice in sensory evaluation to use geometric means as they 

account for the wide range of responses over several orders of magnitude 

(AIHA 1989). The odour standards and guidelines in Ontario are based on 

the geometric mean of odour detection thresholds reported in literature 

(Government of Ontario 2009, internet site). 

• The odour thresholds taken from the available literature are valid. Additional 

references of Harvard University (2006), Iowa State University (2004) and 

Lenntech (2006) do not change the calculated geometric mean for H2S, nor 

suggest that calculating an odour threshold using geometric mean is 

inappropriate. 


CR029


References 

Section 11.1 

AENV (Alberta Environment). 2004. Assessment Report on Reduced Sulphur 

Compounds for Developing Ambient Air Quality Objectives. Prepared 

by AMEC Earth & Environmental Limited and University of Calgary. 

Pub. No: T/754. November 2004. 

AEP (Alberta Environmental Protection). 1999. A comparison of Alberta’s 

Environmental Standards to those of other North American Jurisdictions. 

Pub No. I/733. March 24, 1999. 

AIHA (American Industrial Hygiene Association). 1989. Odor Thresholds for 

Chemicals with Established Occupational Health Standards. Fairfax, 

Virginia. 

Government of Ontario. 2009. Proposed Approach for the Implementation of 

Odour-Based Standards and Guidelines. http://www.ebr.gov.on.ca/ERS- 

WEB- 

External/displaynoticecontent.do?noticeId=Mjc4ODc=&statusId=MTUw 

MDQ0&language=en. Accessed October 2009. 

Harvard University 2006. Comparison of Odor Thresholds and PEL’s/TLV’s of 

Some Substances. http://research.dfci.harvard.edu/ehs/PPE/Respirators/ 

Iowa State University 2004. The Science of Smell Part 1: Odor Perception and 

Physiological Response. PM 1963a, May 2004. 

Lenntech Holding B.V. 2006. Odorous Substances (Osmogenes) and Odor 

Thresholds. http://www.lenntech.com/table.htm 

WGAQOG (Federal-Provincial Working Group on Air Quality Objectives and 

Guidelines). 1996. Protocol for the Development of National Ambient 

Air Quality Objectives. Part 1 Science Assessment Document and 

Derivation of the Reference Level(s). November 2006. 


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Section 11.1 


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WATER 


Section 12.1 

Shell describes the polishing ponds water treatment, pond residence time and 

other items. 

15a Since the ponds are designed to contain and convey flows for all hydrologic 

conditions up to the 100 year flood without uncontrolled spillage, provide the 

emergency response plans for potential spillage in the unlikely event of flows 

exceeding 100 year flood flows. 

Response 15a Polishing ponds are primarily required for mitigating elevated levels of total 

suspended solids (TSS) in runoff during high flow events. During a flood event 

exceeding the 100-year flood event, the outlet of the polishing pond would likely 

erode, becoming wider and deeper. Flows through the compromised pond would 

discharge along the outlet channel into the receiving streams. Levels of TSS 

discharging from the pond would be high, but would be similar to those in 

receiving streams. As a result, receiving stream TSS levels would not 

substantially increase with the addition of polishing pond discharge beyond the 

range of natural variability. 

Given that the TSS levels of the discharge would be similar to the receiving 

streams and that the flow path would remain intact, a detailed emergency 

response plan (ERP) for this unlikely failure scenario has not been developed. 

Request 15b Since the pond residence time is about eight hours and the TSS monitoring 

frequency is three times per week, what measures are proposed to be in place to 

confirm that uncontrolled releases are not occurring between sampling events? 

How will potential releases during these times be addressed, with specific 

reference to each potential parameter of concern? 

Response 15b As noted in the response to SIR 265 in the May 2009 Pierre River Mine, 

Supplemental Information, Volume 2, Shell will monitor at the frequency 

specified in the EPEA approval, and may increase the monitoring frequency as 

appropriate when monitoring results indicate a potential non-compliance. In 

Shell’s experience, the frequency and quantity of monitoring prescribed by 


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WATER AENV SIRS 15 – 43 

Section 12.1 

AENV would readily detect any pond that had a water quality problem requiring 

action. Shell currently monitors over 100 parameters at the Jackpine Mine 

polishing pond outlets on varying monitoring schedules in a very comprehensive 

monitoring program. Shell will comply with the water quality monitoring 

regulatory requirements for all parameters. 

Request 15c The water management systems are described as having a capacity to hold water 

and achieve zero discharge for extended periods. 

i. What are the anticipated holding times during the time of highest anticipated 

flows and what are the flows expected? 

ii. Where will the water be held during the extended periods of zero discharge 

and what is the water holding capacity of the holding area(s)? 

iii. What planning is in place to rehabilitate water quality in the unlikely event 

that the water cannot be held for a sufficient time to mitigate water quality 

issues? 

Response 15c i. The water management systems described in the response to SIR 265b in the 

May 2009 Pierre River Mine, Supplemental Information, Volume 2, refer to 

areas with closed-circuit drainage. These areas do not include areas where 

muskeg and overburden are being dewatered, as these flows would be 

directed to the polishing ponds. For areas with closed circuit drainage, the 

holding times are anticipated to be essentially unlimited in most cases. For 

example: 

• the EDTA is designed to withstand the probable maximum flood 

• in the mine pit, all runoff is contained until it is actively pumped out of 

the pit. The water holding capacity remains extremely large at all times, 

even though it varies with the ever-evolving size of the mine pit. 

• former mine pits backfilled with tailings (i.e., in-pit deposition cells), like 

the active mine pits, are below grade until final capping. Like active 

mine pits, water would be contained until pumped out of the cells. 

• the plant site area would be at risk of releasing surface runoff to the 

environment, but only in extreme events when ditch and pump systems 

could be overwhelmed. During those events, water quality of the release, 

with elevated levels of TSS, would be similar to the water quality of the 

receiving environment. 

• overburden disposal areas drain through collection ditches that 

eventually make their way to the recycle water system 

• areas reclaimed back to grade would send water to collection ditches that 

would return to the water recycle system 


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Section 12.1 

ii. For the response to this question, see the response to AENV SIR 15ci. 

iii. For the response to this question, see the response to AENV SIR 15ci. 

Request 15d Shell describes corrective actions to include diverting water to vegetated areas to 

trap sediments and mitigate water quality for other parameters of concern. 

i. What are the other parameters of concern? 

ii. What physiological and biogeochemical processes will the vegetated areas 

employ to mitigate the water quality and how will Shell apply these processes 

to other parameters of concern? 

Response 15d i. Other parameters of concern include constituents that can be associated with 

sediment particles suspended in water, including aluminum, cadmium, 

chromium, copper, iron, lead, mercury, phosphorus, silver and zinc. These 

also can include parameters noted in EPEA Approvals, water management 

frameworks and other regulatory approvals, including biological oxygen 

demand (BOD), nitrogen, phosphorus, toxic organic compounds, and total 

dissolved solids (TDS). 

Reference 

ii. The vegetated areas of interest are typically wetlands, such as small 

watercourses, bogs and marshes on the mine surface lease, although upland 

vegetation in this area also provides many or all of the same functions to 

some degree. Kadlec and Knight (1996) provide a rule of thumb that a 

wetland removes about three-quarters of the incoming TSS, provided 

incoming TSS has concentrations greater than 20 mg/L. Data collected by 

Shell for releases of polishing pond water to Shelley Creek show that 

wetlands in the Oil Sands Region are similarly effective at removing TSS. 

Wetlands remove TSS via several pathways, including microscale and 

macroscale deposition, inertial deposition on plant stems, and sediment 

particles sticking to biofilms. Settling and filtration of suspended sediments 

would remove compounds that are bound to these sediments, such as 

aluminum, cadmium, chromium, copper, iron, lead, mercury, phosphorus, 

silver and zinc. In addition, wetlands are known to significantly improve 

water quality characteristics, such as BOD, nitrogen, phosphorus, toxic 

organic compounds, and TDS. Advantages of wetlands are they are selfmaintaining 

and they add no unnatural chemicals to the environment. They 

also support a viable natural ecosystem. 

Kadlec, R.H. and R.L. Knight. 1996. Treatment Wetlands. CRC Press/Lewis 

Publishers. Boca Raton, Florida. 893 pp. 


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Section 12.1 

Request 15e Shell states that if the water does not meet the water quality guidelines, the 

release will be reported to AENV and mitigation action plans implemented. 

i. What are the mitigation action plans for accidental releases of hydrocarbon 

containing waters to the environment (include mitigation action plans for 

soils impacts and surface water impacts)? 

ii. What are the action plans in place for the potential release for each potential 

parameter of concern? 

Response 15e i. In the unlikely event that hydrocarbon-containing waters are accidentally 

released to the environment, spill control measures would be undertaken to 

safely re-establish containment and to arrest the spread of the release in the 

receiving environment. These spill control measures can include the use of 

temporary earthen dams, oil skimmers and absorbent booms. Spill control 

would then be followed by an assessment of the impacts of the release. Based 

on the assessment, spill countermeasures would be employed. These could 

include cleaning up contaminated soils and contained waters, and monitoring 

and managing the effects of the spill, as appropriate. 


As noted in the response to SIR 265 in the May 2009 Pierre River Mine, 

Supplemental Information, Volume 2, spill control and countermeasures 

would be developed on a case-by-case basis and implemented in consultation 

with AENV. 

ii. The Pierre River Mine will build upon the existing emergency response plans 

already in place at the Muskeg River and Jackpine Mines. Site-specific 

details for responding to the accidental release of hazardous substances will 

be developed during the detailed design phase of the project. 


Shell was asked what their contingency plan was to meet water requirements if 

proposed storage capacity is not adequate or if the quality of recycled/reused 

water does not meet the project needs. Shell’s response was they would consider 

several options. 

16a What options would Shell consider? 

Response 16a Several contingency options may be available to Shell to meet water withdrawal 

requirements during exceptional low-flow periods in the Athabasca River. These 

include: 


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Section 12.1 

• ongoing and potentially increased instantaneous diversion of groundwater 

sources 

• use of untreated recycle water for gland water 

• reducing bitumen production to reduce water consumption 

These options individually or in combination could be used to complement 

Shell’s proposed raw water storage. 

Request 16b Discuss their feasibility and rank them. 

Response 16b Each of the contingency options discussed in the response to AENV SIR 16a 

may be technically feasible. However, the choice and ranking will be highly 

dependent on the prevailing environmental and mine operating circumstances. 

Currently, it would be speculative to comment on the preferred ranking. 



Shell states An evaluation of options for ETDA subsurface seepage control was 

conducted for the closure stage of the facility. 

17a Provide a comparable assessment of various subsurface seepage control 

alternative (including liners) against interception pumping wells option taking 

into consideration its sustainability, efficiency, and maintenance requirements. 

Response 17a Shell’s proposed seepage management plan involving a series of recovery wells 

was determined to provide a high degree of efficiency in permeable soils and a 

wide degree of operational flexibility. Table AENV 17-1 compares the ETDA 

seepage management alternatives against the requirements for sustainability, 

efficiency, and maintenance. 


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Table AENV 17-1: Comparison of ETDA Seepage Management Alternatives 

Method Characteristics Sustainability 

Pumping 

wells 

• Appropriate in gravel to 

silty fine sand soils. 

• Unrestricted depths using 

submersible pumps. 

• Costs are relatively 

moderate. 

Slurry wall • Appropriate in silts, sands, 

gravels and cobbles. 

• Depths generally limited to 

40 to 60 m, depending on 

soil and site conditions. 

• Requires relief wells 

upgradient of slurry wall. 

• Costs are relatively high 

for deep cut-off walls. 

Clay liners • Requires large volumes of 

clay. 

• Requires substantial site 

preparation, detailed 

quality control, and 

protection against dry/wet 

and freeze/thaw cycles. 

• Requires installation of 

horizontal drains in ETDA 

to alleviate ETDA pore 

pressure. 

• Cost is relatively high, and 

can be even more costly if 

clay source not close to 

the ETDA site. 

Synthetic 

liners 

• Requires intense site 

preparation, detailed 

quality control. 

• Requires installation of 

horizontal drains in ETDA 

to alleviate ETDA pore 

pressure. 

• Cost is relatively high. 

• Temporary 

measure. 

• Affects groundwater 

flows while in 

operation. 

• Once pumps are 

decommissioned, 

the groundwater 

levels and flow 

directions will 

recover. 

• Permanent and 

passive measure. 

• Permanently affects 

groundwater levels 

and flow directions. 



• Does not affect 

underlying 

groundwater flows, 

as seepage is 

contained above 

natural surface. 



• Does not affect the 

underlying 

groundwater flows 

as seepage is 

contained above 

natural surface. 

Performance 

Efficiency 

• High efficiency in 

permeable soils 

(gravel to silty fine 

sand) as it creates a 

cone of depression 

that works as a 

hydraulic barrier. 


containing seepage 

as it provides low 

permeability barriers 

as a result of 

bentonite or clay 

slurry. 



when constructed 

properly and 

protected. 



when properly 

installed and 

protected. 

• Resistant to variety 

of chemicals. 

Section 12.1 

Operational 

Maintenance 

• High. Requires 

monitoring of 

drawdown and 

pumping rates, 

systematic 

adjustment of 

pumping rates, 

monitoring of well 

efficiency and 

cleanup, pump 

replacement and well 

replacement. 

• No maintenance for 

slurry wall and relief 

well system. 

• No maintenance 

once covered by 

tailings. 

• No maintenance 

once covered by 

tailings. 

Request 17b Shell describes details that demonstrate a high confidence in the likelihood of 

successful mitigation of ETDA seepage water, anticipated seepage rates, and 

other aspects. The predicted seepage rate from the Pierre River Mine ETDA 

during operations was 240 L/s (Response 271b). 

i. How was this rate determined? 


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ii. What was the minimum and maximum predicted rate? 

Section 12.1 

Response 17b i. The predicted seepage rate from the Pierre River Mine external tailings 

disposal area (ETDA) during operations was determined using the Pierre 

River Mine local groundwater flow model (see EIA, Appendix 4-1, Section 

1.2.4, page 93). The hydrogeology modeling information provided in 

Appendix 4-1 describes the geological surfaces, model limits, parameters, 

boundary conditions and calibration. 

ii. During operations, the minimum predicted ETDA seepage rate was 50 L/s, 

whereas the maximum predicted ETDA seepage rate was 550 L/s (see EIA, 

Volume 4A, Section 6.3.6.2, Table 6.3-18). 

Request 17c What is the degree of confidence in the rate of 240 L/s? 

Response 17c The degree of confidence in the estimated seepage rate of 240 L/s is considered 

moderate. Because of the conservatism built into the prediction of the seepage 

rate, as described in the following, the predicted seepage rate of 240 L/s is 

expected to be representative of an upper-end estimate. 

The seepage rate from the ETDA ultimately depends on: 

• the rate at which the ETDA deposits can transmit water vertically 

• the hydraulic conductivity of the aquifer underlying the ETDA, reflecting the 

capacity of the aquifer to transmit the seepage from the ETDA deposits 

The ETDA was represented in the model with a general head boundary (GHB). 

Vertical tailings water transmission rates were controlled by the conductance (C) 

of the GHB (which depends on the thickness and hydraulic conductivity [K] of 

the tailings) and specified fluid levels in the tailings, as discussed in the response 

to AENV SIR 18fi. 

ETDA Thickness for GHB 

The thickness of the ETDA was conservatively represented as 5 m, although the 

ETDA design thickness is 45 m. In reality, the thickness of the ETDA will 

increase with time through the active lifetime of the ETDA. This assumption of a 

reduced thickness leads to more conservative seepage rates. 

ETDA Hydraulic Conductivity for GHB 

The vertical hydraulic conductivity of the ETDA deposits was assigned one value 

(1 x 10 -8 m/s) for the entire ETDA footprint. The hydraulic conductivity of the 

tailings deposits will vary based on the composition and deposition method of the 

tailings. The vertical hydraulic conductivity would be about 1 x 10 -10 m/s for 

thickened tailings (TT), about 1 x 10 -8 m/s for mature fine tailings (MFT), and 

about 2.5 x 10 -6 m/s for tailings sand (Volume 3A, Appendix 3-1, Tables 1-6 and 


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Section 12.1 

1-5 of the Muskeg River Mine Expansion EIA. Considering that most of the 

Pierre River Mine ETDA footprint will consist of areas of TT and of areas of 

tailings sand that are overlain by MFT, which will effectively limit the seepage 

rate to that of MFT, the overall hydraulic conductivity of 1 x 10 -8 m/s assigned to 

the ETDA deposits is considered conservative, leading to higher assumed 

seepage rates. Potential reduction of tailings sand hydraulic conductivity as a 

result of bitumen or sludge deposits and entrapment (Hunter, 2001) were not 

considered. 

ETDA Fluid Level Elevation for GHB 

The fluid level specified for the ETDA was constant and was based on the fluid 

elevation that will be present following complete filling of the ETDA. In reality, 

the fluid elevation will rise with time through the active lifetime of the ETDA. 

Therefore, the vertical hydraulic gradient between the ETDA and the underlying 

aquifer was also conservatively represented, as higher vertical gradients lead to 

higher seepage rates. 

Underlying Aquifer Hydraulic Conductivity 

Reference 

There is some uncertainty in the distribution and hydraulic conductivity of the 

sediments which underlie the ETDA, as described in EIA, Volume 4B, Appendix 

4-1, Section 1.2.4.5, page 98. Additional conservatism was built into the 

simulation of ETDA seepage, as the entire aquifer underlying the ETDA was 

represented by relatively high hydraulic conductivity sandy materials, with the 

assigned hydraulic conductivity (5 x 10 -5 m/s) being at the upper end of the range 

of hydraulic conductivity values measured in Quaternary deposits in Lease 9. 

Hunter, G. P. 2001. Investigation of groundwater flow within an oil sand tailings 

impoundment and environmental implications. M.Sc. Thesis, University 

of Waterloo, 

Request 17d Shell mentions that the expected time for groundwater extraction rates to 

stabilize or reach steady state will be defined when a detailed groundwater 

extraction system, with actual expected pumping well locations is designed and 

produced. Describe the timeframe and the standard procedures for designing 

and implementing a detailed groundwater extraction system. 

Response 17d The detailed design of a seepage management system requires that the conceptual 

models used to conservatively assess potential environmental impacts related to 

ETDA seepage be refined and updated. This typically requires additional 

geological and hydrogeological information specific to the proposed ETDA site 

and surrounding area, and tailoring of plans to align with detailed design 

purposes. 


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The typical steps in designing and implementing a detailed groundwater 

extraction system include: 

Section 12.1 

• updating the hydrogeological model to include additional geological and 

hydrogeological information and any modifications to ETDA design. This 

typically includes updates on hydraulic conductivity, aquifer thickness, 

groundwater flow direction and velocity, and subsurface chemical behaviour. 

• updating the groundwater flow model based on the updated hydrogeological 

conceptual model to assess the seepage management system components, to 

clearly define groundwater extraction rates, and to define the expected 

performance of the seepage management system 

• designing a seepage management system, including designing: 

• the extraction system, including the number and location of wells, well 

diameters, screen perforation and length, filter pack specifications, and 

completion intervals 

• the horizontal drains and interceptor trenches, including the depth and 

width of trenches, diameter, perforation size and slope of collector pipe, 

sand and gravel pack specifications, and maintenance manholes 

• the collection system, including the pipe diameter and length and pump 

specification 

• the surface infrastructure, electrical systems, instrumentation and 

controls 

• installing and commissioning the seepage management system 

Shell expects to start designing its seepage management system about 18 months 

before construction of the ETDA begins. Constructing and implementing the 

seepage management system will take between 12 and 18 months, and coincide 

with start-up of the ETDA. 

Request 17e Shell mentions they are aware of publicly reported information on seepage from 

ETDA at other facilities but are unable to provide details of the suspected causes 

of the exceedence events or how the interception measures implemented will 

function. 

i. Describe and discuss the known causes of seepage that are being considered 

for the design and construction of the seepage interception system. 

ii. In the event that seepage rates exceed the interception system what are the 

contingency design and construction measures that will be used? 

Response 17e i. External tailings disposal area seepage occurs as a result of the elevated fluid 

level in the ETDA relative to the groundwater level in the underlying 


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Section 12.1 

overburden deposits (see EIA, Volume 4A, Section 6.3.6.2, page 6-211). 

Design considerations for the Pierre River Mine ETDA seepage interception 

system include all seepage through the base of the ETDA into the overburden 

deposits. This excludes seepage through the dike seepage faces, internal 

seepage collection systems, and toe drains, as these components of seepage 

are captured by different systems and do not enter the overburden deposits. 

ii. EIA, Volume 4A, Section 6.3.6.2, page 6-229, evaluated a system of 

recovery wells to capture seepage from the ETDA that entered the 

overburden deposits. A technically viable measure that could be considered 

is to increase the rate of pumping from the existing seepage interception 

wells to capture the higher seepage rates. If necessary, the proposed or 

existing pumps would be replaced with higher capacity pumps. Also, if 

required, additional seepage interception wells, including horizontal wells, 

could be installed to supplement the pumping efforts and effectively capture 

the ETDA seepage. 

Request Volume 2, SIR 279 a-b, Page 21-20. 

Figures 279-1 to 279-4 provide visual inspection of the residual distribution in 

the wells installed in different formations. The calibration results information 

provided on page 29 to 36 of Appendix 4-1 provides validity of the calibration 

based on the overall statistical results of residuals and visual observations. 

Validation of the calibration results in different areas of the models, including 

the wells in close proximity to the depressurization and dewatering areas in the 

regional models (both steady state and transient model) and tailing areas and pit 

lakes in JEMA and PRMA local models, is not provided. The concern is that 

residuals in the monitoring wells range between +9.99 m and -9.39 m and 

+28.5 m and -25.64 m in regional steady state and transient models, respectively, 

which are high. The same applies for the local JEMA and PRMA models, where 

the residuals range between +8.80 to – 27.50 m and +10.77 m and – 8.02 m. 

18a The spread and range of residuals is very high and indicates that the correlation 

is statistically weak. How has Shell compensated for this uncertainty in the final 

model results? 

Response 18a The range of residual values are not a good statistical measure of the quality of 

the model calibration. The model-averaged residuals are generally preferred to 

evaluate the overall quality of the model calibration. Average errors in the model 

(residual and absolute residual means, standard deviation and the ratio of the 

standard deviation to the range of values) were presented in EIA, Volume 4B, 

Appendix 4-1, Figure 18 (regional model, steady-state calibration), Figure 20 

(regional model, transient calibration), Figure 22 (Jackpine Mine Expansion local 


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Reference 

Section 12.1 

model, steady-state calibration) and Figure 23 (Pierre River Mine local model, 

steady-state calibration). 

The maximum and minimum residual values represent a small portion (less than 

5%) of all calibration data and, therefore, should not be solely relied upon for an 

evaluation of the appropriateness of model calibration. Reilly and Harbaugh 

(2004) indicate that an evaluation of the appropriateness of the model in 

representing the problem objectives is more important than the values measuring 

the goodness of fit. Figure 21 of EIA, Volume 4B, Appendix 4-1 indicates that 

there was a good fit between measured and simulated head declines at various 

distances from the depressurization centres (pumping wells). This observation, 

combined with reasonable quantitative measures of model error, shows that, 

based on the available data, the model provides an accurate representation of the 

groundwater system under consideration, as shown in Figure 6.3-53 for the basal 

aquifer and in Figure 6.3-62 for the surficial deposits (EIA, Volume 4A). 

Reilly, T.E. and A.W. Harbaugh. 2004. Guidelines for Evaluating Ground-Water 

Flow Models. U.S. Geological Survey Scientific Investigations Report 

2004-5038. 

Request 18b Provide statistical analysis of residuals in the wells in close proximity to the 

abovementioned areas and discuss the validity of residuals in those areas. 

Response 18b The data available for calibration in the area of the Pierre River Mine included 18 

static groundwater levels in surficial aquifers, one static groundwater level in the 

McMurray Formation oil sands, and 16 static groundwater levels in the basal 

aquifer. Individual residual values for wells in the area of the Pierre River Mine 

were presented in EIA, Volume 4B, Appendix 4-1, Table 2 for the regional 

steady-state model and in Table 10 for the Pierre River Mine local steady-state 

model. 

For the residual values shown in Table 10, the range is between -8.02 m and 

+10.77 m; the residual mean is 1.04 m; the median is 1.28 m; and the standard 

deviation is 4.55 m (see Figure 23 of EIA, Volume 4B, Appendix 4-1, page 97). 

The 5, 20, 40, 60, 80 and 95 percentiles are approximately -7.1, -2.9, -1.3, 1.9, 

4.8 and 8.8 m, respectively. Further statistical analysis on a subset of the data 

shown in Table 10 would not be statistically meaningful because of the small size 

of the subsets. 

Request 18c The mass balance information provided in Response 279b suggests that the 

major component of the inflow to the system in the regional model is from 

recharge boundary and major outflow from the system is from drain boundaries. 

Provide comments related to input parameters used in the inflow and outflow 

boundaries in the model when answering questions d to f below. 


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Response 18c See the responses to AENV SIR 18d through AENV SIR 18f. 

Section 12.1 

Request 18d Recharge description on page 27 in Appendix 4 -1 provides a range of recharge 

rates and mentions that these recharge values were calibrated to reproduce 

estimated baseflow. However, in Table 1 in Appendix 4-1, the same recharge 

values are shown as calibrated values. 

i. Clarify this discrepancy. 

ii. In Table 1 and on page 27, the recharge values of 16 mm/year and 25 

mm/year are described as assigned to opposite areas. Clarify which recharge 

value was assigned to which area. 

iii. Discuss the primary factors responsible for the different recharge rates. 

Response 18d i. The recharge description in EIA, Volume 4B, Appendix 4-1, page 27, and 

the values in Table 1 are the same, as they both refer to the model-calibrated 

recharge rates. 

ii. The description of recharge rates in EIA, Volume 4B, Appendix 4-1, page 

27, is correct. A recharge of 16 mm/yr was assigned to glacial (ground 

moraine) or glaciolacustrine deposits located east of the Athabasca River, 

whereas a recharge rate of 25 mm/yr was assigned to glacial (ground 

moraine) or glaciolacustrine deposits located west of the Athabasca River. 

Table 1, presented in EIA, Volume 4B, Appendix 4-1, page 27, incorrectly 

presented recharge values for the ground moraine or glaciolacustrine 

deposits. Table 1 has been corrected and is reproduced here as Table 

AENV 18-1. The revised rows have been shaded. 

iii. The recharge rates are primarily a function of the hydraulic conductivity of 

the soil or rock, for similar precipitation. Recharge rates will be higher in 

sand deposits than in clay deposits. Other factors, such as vegetation cover, 

rate of evapotranspiration, depth to water table and topography will also 

affect the recharge rates. 


CR029


Section 12.1 

Table AENV 18-1: Calibrated Hydraulic Conductivity and Recharge Values in Regional 

Model (Revised) 

Material 

Glacial and glaciolacustrine deposits 1 (east of 

Athabasca) 

Glacial and glaciolacustrine deposits 1 (west of 

Athabasca) 

Horizontal 

Hydraulic 

Conductivity 

(m/s) 

Vertical 

Conductivity 

(m/s) 

Recharge 

(mm/yr) 

5E-7 5E-9 16 

5E-7 5E-9 25 

Glacial and glaciolacustrine deposits 2 5E-7 5E-9 25 

Ice contact deposits 1 (west of Jackpine Mine Expansion) 8E-6 8E-8 104 

Ice contact deposits 2 (east of Jackpine Mine Expansion) 2E-5 2E-7 104 

Outwash sand 5E-5 5E-6 104 

Aeolian deposits (west of Pierre River Mine) 6E-5 6E-7 157 

Buried channel aquifers 3E-4 3E-6 157 

Clearwater and Grand Rapids formations 1 (Muskeg 

Mountain) 

1E-11 1E-13 – 

Clearwater and Grand Rapids formations 2 (elsewhere) 5E-11 5E-13 – 

McMurray Formation Oil Sands 1 (Muskeg Mountain) 1E-11 1E-13 – 

McMurray Formation Oil Sands 2 (below Clearwater 

elsewhere) 

1E-9 1E-10 – 

McMurray Formation Oil Sands 3 (areas of no 

Clearwater) 

6E-9 6E-10 – 

McMurray Formation Oil Sands 4 (Athabasca River 

valley) 

2E-7 2E-8 – 

McMurray Formation Basal Sands 1 (4 m thickness) 8E-5 8E-6 – 

Waterways Formation 1E-9 1E-11 – 

Prairie evaporite (salt and anhydrite) 1E-10 1E-11 – 

Methy 1 (lower portion and below Waterways/Clearwater) 5E-8 5E-13 – 

Methy 2 (upper portion in areas of no 

Waterways/Clearwater) 

5E-7 5E-9 – 

Methy 3 (upper portion at Athabasca and Firebag River 

valleys) 

5E-5 5E-7 – 

Sewataken fault 

Note: – = not defined. 

5E-8 5E-8 – 

Request 18e If the recharge values mentioned in Table 1 and on page 27 are calibrated 

values, what were the initial estimated values of recharge assigned to different 

zones of the model? 

i. Within what range were the recharge values changed during calibration? 

Explain how the applicable range for the site is appropriate. 


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ii. Explain how the calibrated values correspond to the recharge values 

estimated, based on the site specific hydrological conditions. 

Section 12.1 

Response 18e i. The initial recharge values were based on published studies of groundwater 

recharge and on the experience of other groundwater models in the oil sands 

area (e.g., Shell, 1997, 2002; Imperial Oil 2005;). Van der Kamp and 

Hayashi (1998) indicate that recharge rates for regional aquifers confined by 

aquitards of till and clay, including the Dalmeny aquifer, the Zehner aquifer, 

and the Estevan Valley aquifer, are generally in the range of 5 to 40 mm/yr. 

Simpkins and Parkin (1993) estimated recharge rates in the range of 3 to 76 

mm/yr through till of the Des Moines Lobe in Iowa. Sophocleous (1992) 

indicated that the recharge in the Great Bend Prairie of central Kansas ranged 

from about 0 to 177 mm/yr with a mean of 56 mm/yr. Walton (1985) reports 

recharge rates of about 160 to 260 mm/yr (20-25% of precipitation) for 

glacial drift composed largely of sand and gravel in west central Illinois. 

References 

As a general guidance, initial estimates of recharge were about 2 to 10% of 

precipitation (10 to 45 mm/yr) for fine-grained surficial deposits (e.g., tillcovered 

areas), and about 10 to 20% of precipitation (45 to 90 mm/yr) for 

sandy surficial deposits. The model was then calibrated by adjusting both the 

hydraulic conductivity of the different geological materials and the recharge 

rates in the different areas of the model so that observed water levels, 

piezometric levels and groundwater discharge rates were adequately 

reproduced. The model calibration indicated that higher recharge rates were 

required in select areas of high permeability characterized by aeolian 

deposits and near surface sand channels (e.g., Kearl Channel). 

Imperial Oil (Imperial Oil Resources Ventures Limited). 2005. Kearl Oil Sands 

Project - Mine Development. Submitted to Alberta Energy and Utilities 

Board and Alberta Environment. Calgary, AB. Submitted July 2005. 

Shell (Shell Canada Limited). 1997. Application for the Approval of Muskeg 

River Mine Project. Volumes 1 to 3. Submitted to Alberta Energy and 

Utilities Board and Alberta Environment. Calgary, AB. Submitted 

December 1997. 

Shell (Shell Canada Limited). 2002. Application for the Approval of Jackpine 

Mine –Phase 1. Submitted to Alberta Energy and Utilities Board and 

Alberta Environment. Calgary, AB. Submitted May 2002. 

Simpkins, W. W. and T. B. Parkin. 1993. Hydrogeology and redox geochemistry 

of CH4 in a Late Wisconsinan till and loess sequence in central Iowa. 

Water Resources Research 29:3643-57. 

Sophocleous, M. 1992. Groundwater recharge estimation and regionalization: the 

Great Bend Prairie of central Kansas and its recharge statistics. J. 

Hydrology Vol. 137, pp. 113-140. 


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References 

Section 12.1 

Van der Kamp, G. and M. Hayashi. 1998. The Groundwater Recharge Function 

of Small Wetlands in the Semi-Arid Northern Prairies. Great Plains 

Research Vol. 8 No. 1, pp. 39-56. 

Walton, W.C. 1985. Practical Aspects of Groundwater Modelling. 2nd Ed., 

National Water Well Association, 587 pp. 

ii. The calibrated recharge values reflected relatively higher recharge rates in 

areas of higher hydraulic conductivity (sandy till, sand channels, aeolian 

deposits) than areas of lower hydraulic conductivity (ground moraine or 

glaciolacustrine deposits). This relationship is well established (see Walton 

1985, pg 56), and has been demonstrated by other EIAs conducted in the 

region and other studies in similar hydrogeologic settings in Alberta 

(Farvolden [1963]; Geoscience Consulting Ltd. [1976]; Hydrogeological 

Consultants Ltd. [1977]; Alberta Environment [1978]). 

Walton, W.C. 1985. Practical Aspects of Groundwater Modelling. 2nd Ed., 

National Water Well Association, 587 pp. 

Alberta Environment, 1978. Edmonton regional utilities study, Volume IV, 

Groundwater. Material prepared by Research Council of Alberta, 

Groundwater Division. Compiled and edited by Alberta Environment 

and RPA Consultants Limited. 

Farvolden, R.N. 1963. Rate of groundwater recharge near Devon, Alberta. In: 

R.N. Farvolden, W.A. Meneley, E.G. Breton, D.H. Lennox, and P. 

Meyboom. Early contributions to the groundwater hydrology of Alberta; 

Research Council of Alberta Bulletin 12, p. 98-105. 

Geoscience Consulting Ltd. 1976. Groundwater evaluation, Sherwood Park- 

Ardrossan area; Report, 23 pp. 

Hydrogeological Consultants Ltd., 1977. Edmonton regional utilities study 

groundwater inventory, including St. Albert, Villeneuve, Onoway, Stony 

Plain, Spruce Grove, Warburg, Breton, Winfield, Fort Saskatchewan, 

Josephburg, Bruderheim, Lamont and Chipman, 72 pp. 

Request 18f On pages 26 to 28, general descriptions of boundary conditions are provided. 

However, the input parameters for different boundary conditions are not 

described (e.g., river stage elevations, river bottom elevations, and drain 

elevations). For riverbed and lake bed conductance, the vertical hydraulic 

conductivities used are 1 x 10-6 m/sec and 1 x 10-8, respectively. 

i. Provide the different input parameters of the boundary conditions, and 

describe the methods used to define the boundary input parameters, 

including the river and lake conductance values mentioned above. 


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Section 12.1 

ii. How did these parameters affect the calibration results and the model output 

results in terms of the variation in regional groundwater inflow and outflow? 

Response 18f i. For head-dependent flux boundaries (including rivers and general head 

boundaries), the Groundwater Vistas software calculated conductance based 

on the following (Environmental Simulations Inc. 2004): 

C = KLW/T 

where: 

C = conductance [L2/T] 

K is the hydraulic conductivity [L/T] 

L is the boundary length [L] 

W is the boundary width [L] 

T is the boundary thickness [L] 

The conductance term described above is similar to the coefficient that 

represents leakage through an aquitard under steady-state conditions (De 

Marsily, 1986, pg 365). De Marsily further indicates that, generally, neither 

K, (LW), or T are measured and that the conductance “is adjusted so that the 

difference in head Hr – Hi observed in reality is reproduced by the model 

when the flow balance is respected”. In De Marsily’s terminology, Hr is the 

hydraulic head in the river and Hi is the hydraulic head in the aquifer. 

Because of the generality of the Groundwater Vistas front-end/back-end 

software, inputs were provided for K, L, W and T (required by the software) 

so that C could be calculated. The values selected for L and W generally 

corresponded to the length and width of the model cell, but in the case of the 

river boundaries, the width was selected based on the relative width of the 

river or streams, but was not related to the actual width. The thickness of bed 

material was set to 1 m, or 5 m in the case of lakebed thickness. The reason 

for these selections was to facilitate calibration, as C was now focused on the 

hydraulic conductivity of the bed material, which is a parameter aligned with 

the hydraulic conductivity of the different geological materials. 

For river boundaries: 

• river stage (or head) was equal to topography 

• river bottom elevation was set 1 m below topography 

• width of the river boundaries ranged from 4 m for tributaries to 50 m for 

the Athabasca River 

• river boundary length was equal to the length of the model cell 

• the riverbed thickness was 1 m 

• the riverbed hydraulic conductivity was 1 x 10 -6 m/s 


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References 

For lakes: 

• head was based on the lake elevation 

• the width was equal to the width of the model cell 

• the lakebed thickness was 5 m 

• the lakebed hydraulic conductivity was 1 x 10 -8 m/s 

For drain boundaries at the ground surface (representing wetlands and 

ephemeral streams): 

• the drain stage (or head) was equal to topography 

Section 12.1 

• the width and length of the drain was equal to the width and length of the 

model cell 

• the thickness of the drainbed was 1 m 

• the hydraulic conductivity of the drainbed was 1 x 10 -8 m/s 

For drain boundaries in aquifer layers (representing dewatering and 

depressurization): 

• the drain stage (or head) was equal to the bottom elevation of the 

Quaternary deposits (for overburden dewatering) or the top elevation of 

the basal aquifer 

• the width and length of the drain was equal to the width and length of the 

model cell 

• the thickness of the drainbed was 1 m 

• the hydraulic conductivity of the drainbed was 1 x 10 -8 m/s 

De Marsily, G. 1986. Quantitative Hydrogeology, Groundwater Hydrology for 

Engineers. Academic Press Inc., London. 440 pp. 

Environmental Simulations Inc. 2004. Guide to Using Groundwater Vistas, 

Version 4. 

ii. The calibration results were insensitive to the head-dependent flux boundary 

input parameters because the flows represented by these boundaries are 

generally small in comparison to the regional inflows and outflows. 

The calibration results were most sensitive to values of recharge and 

hydraulic conductivity, so these parameters were investigated with prediction 

confidence simulations (see EIA, Volume 4B, Appendix 4-1, Sections 

1.2.2.7, 1.2.3.7 and 1.2.4.7). 


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Section 12.1 

Shell describes details of previous experience with successfully mitigating pit 

lake waters, those design and monitoring objectives that will be integrated into 

pit management planning to achieve timely mitigation of pit waters, best case 

time frames for pit water mitigation, and the state of current research that Shell 

will use to prevent pit waters from potentially becoming methanogenic. Shell 

states that modeling has been completed to confirm that the residence time will 

be sufficient to biodegrade organic constituents to acceptable levels based upon 

conservative degradation rates. 

19a What were the maximum residence times used in the pit lakes modeling? 

Response 19a Pit lake residence times are presented in EIA, Volume 4B, Appendix 4-2, 

Table 21. The residence times for the Pierre North Pit Lake and the Pierre South 

Pit Lake are one and 10 years, respectively. The residence time for the Pierre 

South Pit Lake is presented in Table 21 as eight years in the upstream cell and 

two years in the downstream cell, for a total residence time in the lake of 10 

years. 

Request 19b What are the conservative degradation rates used for each organic constituent of 

concern, providing reference citations for similar climate environmental 

settings? 

Response 19b The conservative degradation rates used in the pit lake modelling are presented in 

EIA, Volume 4B, Appendix 4-2, Table 42, and the respective source references 

listed in the table are in EIA, Volume 4B, Appendix 4-2, Section 4. Decay rates 

were corrected for temperature to account for slower decay in cold, northern 

lakes. 

The aerobic decay rates applied to lakes and wetlands for ammonia, sulphide, 

acute toxicity and chronic toxicity are the slowest of the rates derived from 

available field research studies conducted on process-affected waters from oil 

sands operators. 

The aerobic decay rate listed for total phenolics is based on the slowest rate of 

degradation for phenol in studies listed in the CHEMFATE database (SRC 2007). 

Field-based studies listed in CHEMFATE have associated decay rates that vary 

from 28 y -1 at 21ºC for an estuarine river in Georgia (Lee and Ryan 1979) to 

3,152 y -1 for in-situ waters spiked with phenol in the St. Lawrence River 

downstream of oil refinery wastewater outfalls (Visser et al. 1977). 

Tainting potential decay rates are based on decay of ethylbenzene. The aerobic 

decay rate of 2.3 y -1 is derived from observed persistence of ethylbenzene in 

shallow groundwaters monitored in the Netherlands (Zoetman et al. 1980), which 


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Decay Rates (y -1 ) 

10,000 

1,000 

100 

10 

1 

0.1 

Section 12.1 

was slower than the observed persistence of ethylbenzene in river waters, with a 

decay rate of 6.94 y -1 (Zoetman et al. 1980). The anaerobic decay rate of 1.1 y -1 

for tainting potential is based on the slowest degradation rate for ethylbenzene in 

groundwater (Wilson et al. 1986). A field-based study listed in CHEMFATE 

(SRC 2007) had a much faster anaerobic decay rate for ethylbenzene of 57 y -1 in 

a sand aquifer (Batterman and Werner 1984). 

The aerobic decay for acrylamide monomer (32 y -1 ) was derived from a study on 

natural and polluted water samples spiked with acrylamide at a concentration of 

0.5 mg/L. The estimated decay rates ranged from 32 to over 1,000 y -1 (Brown et 

al. 1980; United Kingdom Environmental Agency [U.K.E.A. 2000]). The 

acrylamide monomer anaerobic decay rate of 8.4 y -1 was derived by the U.K.E.A 

(2000) based on an estimated half-life of 30 days in soil. Results of a microcosm 

study using oil sands tailings as a microbial inoculation source yielded faster 

anaerobic acrylamide decay rates, ranging from 19 to 31 y -1 at 22 ºC (Haveroen 

et al. 2003). 

Aerobic and anaerobic decay rates for polycyclic aromatic hydrocarbon (PAH) 

groups were based on the lowest aquatic decay rate for any individual PAH in 

each group, regardless of whether the rates were derived from laboratory or fieldbased 

studies, as field-based results were not always available for similar 

environmental settings. The PAH degradation rates used in the assessment were 

generally orders of magnitude slower than other published rates (Figure 

AENV 19-1). 

0.01 

0 1 2 3 4 5 6 7 8 9 

PAH Group 

Aerobic Rate Anaerobic Rate Aerobic Rate Used in EIA Anaerobic Rate Used in EIA 

Figure AENV 19-1: Aerobic and Anaerobic PAH Decay Rates 

The aerobic decay rate used for labile naphthenic acids was 3.2 y -1 . This rate is 

based on several studies that examined the decay of different fractions of 

naphthenic acids (Holowenko et al. 2002; Headley et al. 2002; Clemente et al. 

2004; Scott et al. 2005). The anaerobic decay rate used for labile naphthenic 

acids was derived in consultation with Dr. Mike MacKinnon, Syncrude Canada 


CR029


References 

Section 12.1 

Ltd., following methods outlined in Howard et al. (1991). A decay rate of zero 

(i.e., no decay) was applied to refractory naphthenic acids, although a recent 

study by Han et al. (2009) observed aerobic degradation of refractory naphthenic 

acids at approximately 0.05 y -1 in field studies at Syncrude’s experimental 

reclamation waterbodies. 

Batermann, G. and P. Werner, P. 1984. Removal of Underground Contamination 

by Hydrocarbons Through Microbial Degradation (GER).; GWF- 

Wasser/Abwasser. 125:366-73. 

Brown L., M. M. Rhead, K. C. C. Bancroft and N. Allen. 1980. Model Studies of 

the Degradation of Acrylamide Monomer. Water Research. 14:775-778. 

Clemente, S., M. D. MacKinnon, and P.M. Fedorak. 2004. Aerobic 

biodegradation of two commercial naphthenic acids preparations. 

Environmental Science and Technology. 38:1009-1016. 

Han, X., M. D. MacKinnon and J. Martin. 2009. Estimating the in situ 

biodegradation of naphthenic acids in oil sands process waters by 

HPLC/HRMS. Chemosphere. 76(1):63-70. 

Haveroen, M.E., M.D. MacKinnon and P.M. Fedorak. 2003. Acrylamide 

Biodegradation in Oilsands Tailing Samples. Poster Presentation to 

CONRAD Wetlands and Aquatics Working Group. 

Headley, J. V., S. Tanapat, G. Putz and K. M. Peru. 2002. Biodegradation 

Kinetics of Geometric Isomers of Model Naphthenic Acids in Athabasca 

River Water. Canadian Water Resources Journal. Vol. 27, no. 1, pp. 25- 

42. 

Holowenko F. M., M. D. MacKinnon, and P. M. Fedorak. 2002. Characterization 

of Naphthenic Acids in Oil Sands Wastewaters by Gas Chromatography- 

Mass Spectrometry. Water Research. 36(11):2843-55. 

Howard, P. H., R. S. Boethling, W. F. Jarvis, W. M. Meylan and E. M. 

Michalenko. 1991. Handbook of Environmental Degradation Rates. 

Lewis Publishers Inc. Chelsea, MI. 

Lee, R. F. and C. Ryan. 1979. Microbial Degradation of Organochlorine 

Compounds in Estuarine Water and Sediments. In: EPA-600/9-79-012. 

Microbial Degradation of Pollutants in Marine Environments. Bourquin, 

A. W. and P. H. Pritchard, Eds. Gulf Breeze, Florida. US EPA. pp. 443- 

50. 

Scott, A. C., M. D. MacKinnon, and P. M. Fedorak. 2005. Naphthenic acids in 

Athabasca oil sands tailings waters are less biodegradable than 

commercial naphthenic acids. Environmental Science and Technology. 

39:8388-8394. 


CR029


Section 12.1 

SRC (Syracuse Research Corporation). 2007. CHEMFATE Online Database. 

U.K.E.A. (United Kingdom Environmental Agency). 2000. Risk Assessment of 

Acrylamide (Draft Report). UKEA, Ecotoxicology & Hazardous 

Substances National Centre. CAS No. 79-06-1. Wallingford, 

Oxfordshire. 

Visser, S. A., G. Lamontagne, V. Zoulalian and A. Tessier. 1977. Bacteria Active 

in the Degradation of Phenols in Polluted Waters of the St. Lawrence 

River. Archives of Environmental Contamination and Toxicology. 

6:455-70. 

Wilson, B. H., G. B. Smith and J. F. Rees. 1986. Biotransformation of Selected 

Alkylbenzenes and Halogenated Aliphatic Hydrocarbons in 

Methanogenic Aquifer Material: A Microcosm Study. Environmental 

Science and Technology. 20:997-1002. 

Zoeteman, B.C.J., K. Harmsen, and J.B.H. Linders. 1980. Persistent Organic 

Pollutants in River Water and Ground Water of the Netherlands. 

Chemosphere. 9:231-249. 

Request 19c What is the maximum anticipated concentration modeled for each organic 

constituent of concern and what was the predicted time required to achieve 

acceptable levels based upon this concentration? 

Response 19c The maximum anticipated concentration modelled for each organic constituent of 

concern will occur at the end of mining operations, before the lakes are filled 

with fresh water. As described in EIA, Volume 4A, Section 6.5.6.3, the pit lakes 

will initially contain process-affected waters comprised of seepages from 

backfilled mine pits and reclaimed sand swale and ridge areas, consolidation flux 

from non-segregating tailings (NST) in reclaimed mine pits and mature fine 

tailings (MFT). The assumed chemical profiles of these waters is presented in 

EIA, Volume 4B, Appendix 4-2, Table 37. During this period, the lakes will not 

discharge to the receiving environment. 

As described in EIA, Volume 4A, Section 6.5.6.3, water quality in the Pierre 

River Mine pit lakes is anticipated to be acceptable for release at the time of 

initial discharge in 2049. Predicted concentrations for all constituents in each pit 

lake, in 2049 and in the future, are presented in EIA, Volume 4B, Appendix 4-7, 

Section 4. 


CR029




Section 12.1 

Shell states that the reaches of Pierre River, Eymundson Creek and Big Creek 

located within the LSA are considered to be lost in their entirety and any change 

in habitat as a result of change in flow was incorporated into the fish area lost, 

as described in EIA Vol. 4, Appendix 4-6, Table 7. 

20a Describe how the change in flow may affect fish and fish habitat outside the LSA, 

with particular focus on winter flows. 

Response 20a The Athabasca River downstream of the Firebag River confluence would be the 

only watercourse which may be potentially affected outside of the Pierre River 

Mine local study area (LSA) from changes in habitat area. Potential changes to 

flows in the Athabasca River from construction, operations and closure activities 

in the Pierre River Mine development area were considered in Section 6.7.7.3 

(EIA, Volume 4, Section 6.7, page 6-663). The change in flows in the Athabasca 

River due to closed-circuit operations and reclaimed areas resulting from the 

Pierre River Mine is considered negligible (EIA, Volume 4, Section 6.4.7.3). 

Therefore, no impacts to fish habitat in the Athabasca River would be expected 

from changes to streamflows resulting from activities in the Pierre River Mine 

development area, other than those potentially related to water withdrawals for 

the project. 

Reference 

A discussion of changes to Athabasca River flows and fish habitat relating to 

water withdrawals is in the EIA, Volume 4, Section 6.7.7.3. Flows in the 

Athabasca River, including winter flows, are being managed under the Water 

Management Framework for the lower Athabasca River (AENV and DFO 2007). 

A Phase 2 Framework is currently being developed by Alberta Environment and 

Fisheries and Oceans Canada, which will further define how cumulative 

withdrawals under low flow conditions will be managed and the potential effects 

on fish habitat associated with cumulative withdrawals. Shell has committed to 

operating under the current framework and any future frameworks that define 

limits to water withdrawals on the Athabasca River. 

AENV and DFO (Alberta Environment and Fisheries and Oceans Canada). 2007. 

Water Management Framework: Instream Flow Needs and Water 

Management System for the Lower Athabasca River. Edmonton, AB. 

37 pp. 


CR029




Section 12.1 

Shell states that streams outside the disturbance footprint will have a 100-m 

setback distance. 

21a Clarify if ephemeral watercourses were considered and included in this setback 

criterion. 

Response 21a As per the response to the May 2009 Pierre River Mine, Supplemental 

Information, Volume 2, SIR 288, a 100 m setback will be maintained for streams 

around the periphery of the disturbance footprint. For this project, these streams 

are limited to constructed diversion channels adjacent to the main Pierre River 

Mine footprint, such as the Pierre River diversion, which would maintain the 100 

m setback. Ephemeral watercourses were considered because ephemeral streams 

located around the periphery of the project footprint would be directed into the 

diversion channels, which will have the 100 m setback. 



Shell states that the Actual Evapotranspiration (AET) is estimated based on 

actual evapotranspiration simulated for natural areas using the Hydrologic 

Simulation Program Fortran (HSPF) model. The HSPF model determines an 

estimated AET based on an estimate of PET (potential evapotranspiration) and 

five other primary factors (HSPF subroutines). It is not clear how Shell 

estimated AET based on a simulated AET without first having PET estimates, 

accurate and reliable water storage values, and an adjustment for advective 

winds. 

22a Briefly describe the steps that provided input data, estimated PET, and 

calculated AET. 

Response 22a The steps used to estimate potential evapotranspiration (PET) using Morton’s 

evaporation model and actual evapotranspiration (AET) using HSPF, and the 

input data required for these models are as follows: 

• Morton’s Evaporation model is used to determine Potential 

Evapotranspiration (PET), areal actual evapotranspiration, potential lake 

evaporation (PE), and actual lake evaporation. The input to Morton’s 

Evaporation model includes mean annual precipitation, monthly mean wind 

speed, monthly mean relative humidity or dew point temperature, and 

monthly mean solar radiation data recorded at the Fort McMurray Airport 

climate station from 1954 to 2006. 


CR029


Section 12.1 

• Then, AET is determined using the HSPF model. The input to the HSPF 

model is PET and actual lake evaporation. In the HSPF model, AET for 

specific sub-basin or land segment is calculated from five sources 

(interception, upper zone, lower zone, baseflow and groundwater storages) as 

a function of moisture storages and the PET. 

Request 22b Clarify why the Morton method was used for HSPF modeling in deference to the 

Thornthwaite or Penman-Monteith methods for ecosystems, or the Priestly- 

Taylor method. Provide a summary of information that compares the selected 

approach to these others, given that it could be argued that, for an extensive 

landscape covering a large area with different soil moisture storage properties, 

different advective wind and different precipitation patterns, Morton might not 

provide as accurate a representation of AET as other approaches. 

Response 22b The Morton’s method was used following a similar procedure to Alberta 

Environment’s to calculate evaporation and potential evapotranspiration for the 

Province of Alberta (AENV 1999). 

References 

There are several more or less empirical methods developed over the last 50 

years by numerous scientists and specialists worldwide to estimate PET from 

different climatic variables. These methods can be grouped into five categories: 

1. water budget (e.g. Guitjens 1982) 

2. mass-transfer (e.g. Harbeck 1962) 

3. combination (e.g. Penman 1948; Morton 1983) 

4. radiation (e.g. Priestley and Taylor 1972) 

5. temperature-based (e.g. Thornthwaite 1948; Blaney-Criddle 1950) 

The general conclusion from several studies in the literature that compare the 

performance of the various methods (e.g., Biftu and Gan 2000; Xu and Singh 

2002; and Weiß and Menzel 2008) using locally determined parameter values 

was that all methods provide estimates of PET that are comparable to PET 

estimated using the Penman-Monteith method. 

The Morton’s method for estimating PET is practically similar to the Penman- 

Monteith method. Morton’s method is based on solving simultaneously energy 

transfer and balance equations, using a constant energy transfer coefficient, 

unlike the Penman-Monteith potential evapotranspiration formulation in which 

the energy transfer coefficient is a function of wind speed. 

Abraham, C. (1999): Evaporation and evapotranspiration in Alberta: report 1912- 

1985 data 1912-1996; Alberta Environmental Protection, Water 

Management Division. 

Biftu, G.F., and Gan, T.W. 2000. Assessment of evapotranspiration models 

applied to a watershed in the Canadian Prairies with mixed land uses. 

Hydrological Processes, 14: 1305–1325. 


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Section 12.1 

Blaney, H. F. and Criddle, W. D. 1950. Determining Water Requirements in 

Irrigated Area from Climatological Irrigation Data, US Department of 

Agriculture, Soil Conservation Service, Tech. Pap. No. 96, 48 pp. 

Guitjens, J. C. 1982. Models of Alfalfa Yield and Evapotranspiration,. Journal of 

the Irrigation and Drainage Division, Proceedings of the American 

Society of Civil Engineers. 108(IR3), pp. 212–222. 

Harbeck Jr., G. E.1962. A Practical Field Technique for Measuring Reservoir 

Evaporation Utilizing Mass-transfer Theory. U.S. Geol. Surv., Paper 

272-E, pp. 101–105. 

Morton, F.I. 1983. Operational estimates of areal evapotranspiration and their 

significance to the science and practice of hydrology. Journal of 

Hydrology, 66, 1-76. 

Penman, H. L. 1948. Natural Evaporation from Open Water, Bare Soil and Grass. 

Proc., Royal Soc., London 193, 120–145. 

Priestley, C. H. B. and Taylor, R. J. 1972. On the Assessment of the Surface heat 

Flux and Evaporation using Large-scale Parameters. Monthly Weather 

Review 100, 81–92. 

Thornthwaite, C.W., 1948, An approach toward a rational classification of 

climate: Geographical Review, v. 38, p. 55–94. 

Weiß, M. and Menzel, L. A global comparison of four potential 

evapotranspiration equations and their relevance to stream flow 

modelling in semi-arid environments. Adv. Geosci., 18, 15-23, 2008. 

Xu, C.-Y. and Singh, V. P. 2002. Cross Comparison of Empirical Equations for 

calculating Potential Evapotranspiration with Data from Switzerland 

Water Resources Management 16: 197–219, 2002. 

Request 22c Explain why only one estimate or calculation of AET (314 mm) was used to 

represent both sides of the Athabasca River, given that Pierre River (with 374 

mm precipitation annually) differs appreciably (by 59 mm) from Jackpine (433 

mm). Different precipitation regimes can also be manifested in variations among 

other climate characteristics including those that may play a role in the 

calculation or estimation of AET; such parameters can include differences in 

cloud covers and insolation, vapour pressure deficits, and boundary layer 

conditions. Provide an explanation that addresses this particular concern 

related to AET determination. 


CR029


Section 12.1 

Response 22c The 314 mm cited in the response to the May 2009 Pierre River Mine, 

Supplemental Information, Volume 2, SIR 289a refers to areal actual 

evapotranspiration, which is different from actual evapotranspiration (AET). 


Actual evapotranspiration (AET) is the evapotranspiration that will take place 

over a specific area or land segment as a result of transpiration through plant 

canopy and evaporation from the soil. For a specific land segment, AET is 

determined in the HSPF model from five inputs (interception, upper zone, lower 

zone, baseflow and groundwater storages) as a function of moisture storages and 

the PET. 

Areal actual evapotranspiration is the evapotranspiration that actually takes place 

over a large area, assuming that the effects of any upwind boundary transitions 

are negligible and local variations are integrated to an areal average. The areal 

actual evapotranspiration for the Oil Sands Region was determined using 

Morton’s Evaporation model. The inputs to Morton’s Evaporation model 

included mean annual precipitation over a long period, monthly mean wind speed 

(dependent on boundary layer conditions), monthly mean relative humidity or 

dew point temperature (dependent on vapour pressure deficits), and monthly 

mean solar radiation data (dependent on cloud cover) recorded at the Fort 

McMurray Airport climate station from 1954 to 2006. 

Areal actual evapotranspiration, not AET, is assumed to be similar for the Pierre 

River Mine area and the Jackpine Mine Expansion area given that Morton’s 

model input data, with the exception of precipitation data, are assumed to be the 

same for both development areas. Though the precipitation values for the two 

development areas are different, this would have little effect on the estimated 

areal actual evapotranspiration output from the Morton’s model. 

Request Volume 2, SIR 290a, Table 290-1, Page 21-40. 

The table includes solar radiation used to calculate evapotranspiration using 

Morton’s method for evapotranspiration. It is not clear if this is for actual or 

potential evapotranspiration. Morton’s method to calculate AET using the HSPF 

requires an estimate of PET to be input, usually as a time-series using Class A 

Pan data, with a further adjustment factor applied for percent cover. There is no 

indication currently of where and how the PET data were derived or determined, 

in order to then generate the AET. Once PET is estimated then AET is calculated 

using five subroutines in HSPF that account for the water demand from five 

sources. 

23a What data were used to estimate potential evapotranspiration? This could 

perhaps be demonstrated in Table 290-1 by adding an entry for “actual 

evapotranspiration” as a data type, as well as indicating the method(s) used to 

estimate potential evapotranspiration. 


CR029


Section 12.1 

Response 23a Morton’s Evaporation model was used to determine Potential Evapotranspiration 

(PET). The input to Morton’s Evaporation model includes mean annual 

precipitation, monthly mean wind speed, monthly mean relative humidity or dew 

point temperature, and monthly mean solar radiation data recorded at the Fort 

McMurray Airport climate station from 1954 to 2006. The modified 

Table AENV 23-1 provides a list of specific input data used to estimate Potential 

Evapotranspiration (PET), areal actual evapotranspiration, Potential Lake 

Evaporation (PE), and Actual Lake Evaporation. 


Request Volume 2, SIR 292b, Page 21-45. 

Shell states that this question does not apply because it is not applicable to 

Pierre River. It is noted however that the same mapping techniques, symbology 

and EIA development systems have been used for both projects – Section 6.4.6.2, 

Figure 6.4-18, Page 6-317 shows that Question 292b is likely applicable, since 

the same mapping protocols appear to be in place for Pierre River as for 

Jackpine. 

24a Address SIR 292b in relation to Pierre River using Figure 6.4-18, Page 6-317 as 

a basis for reference, and address in relation to all proposed, reclaimed or 

created wetlands for Pierre River. 

Response 24a Figure AENV 24-1 presents a revised version of Figure 6.4-18. 

Request 24b Clarify what wetland ecosites are targeted in the littoral zone of pit lakes with 

examples of target plant and animals species. 

Response 24b Littoral zones will consist of marshes (MONG) and shallow open water wetlands. 

Plant and animal species typical of graminoid marsh (MONG) wetlands types are 

expected in the reclaimed marsh ecosite types. Emergent sedges, grasses, rushes, 

reeds, submerged and floating aquatics are among the plant families expected in 

the reclaimed marshes. 

The plant species anticipated include, but are not limited to: 

• Typha spp. 

• Carex spp. 

• Scirpus spp. 

• Polygonum spp. 

• Juncus spp. 

• Acorus calamus 


CR029


Air temperature 

Precipitation 

Solar radiation 

Wind 

Data Type Name of Data Set Data Source 

Fort McMurray airport climate station 

(1944–2006) 

Environment 

Canada 

Fort McMurray climate station (1919-1944) Environment 

Canada 

Table AENV 23-1: Summary of Data Sets Used for Jackpine Mine Expansion and Pierre River Mine Project 

Level of 

Completeness 

(%) 

100 High 

Qualitative 

Confidence 

Rating 1, 2 How Data was Used? How was Historical Incompleteness Resolved? 

• Used to derive daily, monthly and annual air temperature statistics, to analyze any 

trends resulting from climate change or climate variability 

• Used to derive evaporation and evapotranspiration using Morton's Method 

• Used as an input for the hydrologic model simulation 

99.5 High • Combined with Fort McMurray airport climate station data to produce long-term records 

required for trend analysis 

Aurora climate station (1995–2006) RAMP 91 Medium • Used to establish spatial variation of air temperatures with elevation in the Oil Sands 

Region 

Calumet River climate station (2001–2005) RAMP 100 Medium • Used to establish spatial variation of air temperatures with elevation in the Oil Sands 

Region 


(1944–2006) 

Environment 

Canada 

Fort McMurray climate station (1920-1944) Environment 

Canada 

100 High 

Aurora climate station (1995–2006) RAMP 98 Medium 

Ells Lookout (1960–2006) ASRD 32 3 Medium 

• Used to derive monthly and annual precipitation statistics, and also to analyze any 

statistical trend resulting from climate change or climate variability 

• Used to derive areal evaporation, actual lake evaporation, potential evapotranspiration, 

and potential lake evaporation using Morton's Method, and also used as an input for 

hydrologic modelling 


99.5 High • Combined with Fort McMurray airport climate station data to produce long-term records 

required for trend analysis 

• Used to establish the spatial variation of summer rainfall with elevation in the Oil Sands 

Region 

• Used as an input for the Hydrologic Model Validation for the Jackpine Mine Expansion 

local study area (LSA) 

• Used to establish the spatial variation of summer rainfall with elevation in the Oil Sands 

Region 

• Used as input for the Hydrologic Model Validation and Simulation for the Pierre River 

Mine LSA 

Birch Mountain Lookout (1961–2006) ASRD 38 3 Medium • Used to establish the spatial variation of summer rainfall with elevation in the Oil Sands 

Region 


(1971–1996) 

Environment 

Canada 

100 High 

Aurora climate station (1995–2006) RAMP 98 Medium 

Stoney Plain climate station (1953–1994) Environment 

Canada 

Fort McMurray climate station (1959–2006) Environment 

Canada 

• Used to derive monthly and annual solar radiation statistics for the Oil Sands Region 


and potential lake evaporation 

Section 12.1 


CR029 

N/A 

If more than 10 days are missing for a particular month, the data for that month was not taken into account to 

derive monthly and annual statistics 



N/A 

N/A 





Filling missing data using recorded data at Fort McMurray airport station based on an established spatial 

relationship for the region 



Filling missing data using recorded data at Fort McMurray airport station based on an established spatial 

relationship for the region 



Recorded sunshine hours from 1971–1996 were converted to solar radiation using a derived relationship 

based on Aurora data review. The data was then extrapolated back to 1953, using a relationship established 

with the Stoney Plain data. 

• Used as an input for the hydrologic model simulation N/A 

• Used to establish the relationship that was used to convert sunshine hours recorded at 

Fort McMurray airport climate station to solar radiation 


100 High • Used to establish the relationship with solar radiation derived for Fort McMurray airport 

station 

100 High 

N/A 

N/A 

Filling missing data using recorded data at the Fort McMurray airport station, assuming little spatial variation 

in solar radiation in the region 

• Used to determine extreme hourly, daily and monthly wind speed statistics N/A 



and potential lake evaporation 

Aurora climate station (1995–2006) RAMP 100 Medium • Used to characterize spatial variation of wind speed in the Oil Sands Region N/A 

Dewpoint temperature Fort McMurray climate station (1953-2006) Environment 

Canada 

Stream flow Athabasca River below Fort McMurray 

(1957–2006) 

Environment 

Canada 

100 High 

97 High 

• Used as input to Morton's Model to derive areal evaporation, actual lake evaporation, 

potential evapotranspiration, and potential lake evaporation 

• Used as input for the hydrologic model simulation 

• Used to derive relative humidity for the Oil Sands Region 

• Used to derive monthly, seasonal, annual and extreme flood and low-flow events and to 

analyze any trends resulting from climate change or climate variability 

• Used to determine the allowable water withdrawal within the restriction of the Athabasca 

River Water Management Framework 

N/A 

N/A 


derive monthly and annual statistics


Data Type Name of Data Set Data Source 

Athabasca River at Embarras airport 

(1971–1984) 

Environment 

Canada 

Firebag River near the mouth (1970–2006) Environment 

Canada 

Muskeg River near Fort McKay 

(1974-2006) 

Environment 

Canada 

Poplar Creek (1973–1986) Environment 

Canada 

Beaver River (1975–2006) Environment 

Canada 

Joslyn Creek (1975–1993) Environment 

Canada 

Steepbank River (1972–2006) Environment 

Canada 

MacKay River (1972–2006) Environment 

Canada 

Ells River (1975–1986 and 2001–2005) Environment 

Canada 

Big Creek (1975–1993) 

Asphalt Creek (1975–1977) 

Pierre River (1975–1977) 

Several RAMP data in the Jackpine Mine 

Expansion and Pierre River Mine regional 

study area (RSA), see Table 2.2-4 in the 

ESR 

Environment 

Canada 

Environment 

Canada 

Environment 

Canada 

Table AENV 23-1: Summary of Data Sets Used for Jackpine Mine Expansion and Pierre River Mine Project (cont'd) 

Level of 

Completeness 

(%) 

Qualitative 

Confidence 

Rating 1, 2 How Data was Used? How was Historical Incompleteness Resolved? 

71 4 High • Used to characterize variation of the Athabasca River flows in the lower reaches in 

conjunction with measured flows below Fort McMurray 

80 5 High 

81 6 High 

100 High 

78 6 High 

75 7 High 

77 6 High 

80 6 High 

80 7 High 

• Used to characterize the variation of water yields in the Oil Sands Region 

• Used to characterize monthly, seasonal, annual and extreme flood and low flows for the 

Jackpine Mine Expansion LSA 

Monthly flow relationships with Athabasca River flows recorded below Fort McMurray were used to derive 

flow data for longer periods (1957–2006) 

Section 12.1 



• Used for regional hydrologic model validation N/A 







76 8 High • Used to characterize monthly, seasonal, annual and extreme flood and low flows for the 

Pierre River Mine LSA 




90 High • Used to characterize monthly, seasonal, annual and extreme flood and low flows for the 





90 High • Used to characterize monthly, seasonal, annual and extreme flood and low flows for the 


RAMP 60 9 Medium 




• Used for regional hydrologic model validation 

Stream geomorphic data Oil Sands Region Golder 100 High • Used to characterize the geomorphic condition for the LSA N/A 

Total suspended solids Muskeg River, Muskeg Creek, Kearl Lake, 

MacKay River, Ells River, Jackpine Creek, 

Wapasu Creek and Athabasca River 

Sediment yield Several streams in the RSA, see 

Table 2.3-20 in the ESR 

Snow survey data Snow survey in the Jackpine Mine 

Expansion and Pierre River Mine LSA 

Project hydrometric 

monitoring 

Several stations, see Table 2.2-5 in the 

ESR report 

Alberta 

Environment 

Environment 

Canada 

100 Medium 

100 High 

• Data were used to characterize the baseline total suspended solids concentration in the 

receiving streams 

• Data were used to characterize the baseline sediment yield from various watersheds 

RAMP/Golder 100 High • Data were used to support the Hydrologic Simulation Program Fortran model calibration 

and validation 

Golder 50 8 High • Data used to establish site-specific flow data and also to establish rating curves for local 

streams 

Note: 

1. All data that has been rated as high for qualitative confidence assumed that several QA/QC were performed before releasing the data for public use. 

2. All data that has been rated as medium for qualitative confidence assumed that the data has gone through basic QA/QC before the data was released for public use. 

3. Precipitation at Ells Lookout and Birch Mountain Lookout were only measured during the summer. 

4. Flow was not recorded during winter months (November/December – Mar/April) from 1977–1984. 

5. Flow was not recorded during winter months (November–February) from 1984–2006. 


7. Flow was not recorded during winter months (November–April) from 2001–2005. 


9. Two stations operating during the winter months, seven stations operating during open-water season and nine stations operating all year. 


CR029 

N/A 

N/A 

N/A 

N/A 

N/A



Section 12.1 

The animal species anticipated are a wide variety of mammals, birds and 

amphibian species associated with wetlands. These include, but are not limited 

to: 

• Canadian toads 

• black terns 

• a variety of waterfowl (e.g., green-winged teal, mallard, northern pintail) 

• other waterbirds including lesser yellow legs and sora rails 

• raptors such as northern harrier and short-eared owl 

• mammals such as muskrat, beaver, mink and river otter 


Shell states that a drawdown of more than 1 meter is considered to have the 

potential to negatively affect fen structure and function in a manner that could 

reduce flood attenuation capacity. This suggests that a drawdown of no more 

than 1 m of wetland water level may not negatively affect fen structure and 

function. 

25a Clarify how the 1 m threshold was established, providing specific reference to 

the three articles referenced (i.e., Szumigalski and Bayley 1997, Thorman et al. 

1988, Halsey et al. 2003), and in particular, in relation to how a


Figure AENV 24-1: Application Case Oil Sands Developments in the Pierre River Mining Area Local Study Area in the Far-Future 

Section 12.1 


CR029


Section 12.1 

Request 25b Explain why flood attenuation is the only hydrological characteristic discussed 

when flooding is only one of a suite of hydrological events affiliated with 

wetlands. 

Response 25b Typically, hydrologic characteristics of wetlands (muskeg, peatlands or forested 

swamps) include considerable storage of precipitation runoff, considerable 

evapotranspiration and low runoff yield. In addition, these features attenuate 

large floods that extend to the flood plains. 

In general, the removal of wetland features within the mine footprint will result 

in reduced flows (i.e., water yield), including flood flows to receiving streams 

and rivers. However, the hydrologic effect of removal of wetlands will be on 

reduced flood attenuation capacity. 

Request 25c The sustainability of a wetland’s structure and function is highly dependant on 

sustaining the hydrodynamics of the wetland. Further clarify how wetland 

integrity will be maintained in relation to other key hydrodynamic 

characteristics, such as seasonal fluxes in mean low and mean high water levels, 

and in relation to typical interactions with wetland vegetation, for example, 

altered vigor or desiccation effects. 

Response 25c Wetland hydrodynamics in the Pierre River Mine local study area (LSA) may be 

affected by a variety of site-specific factors. However, by assessing the effects of 

the drawdown on wetlands using a 0.1 m drawdown contour, the environmental 

consequences of drawdown on wetland function are estimated conservatively. In 

addition, a wetlands monitoring program will be implemented to determine the 

specific effects the drawdown has on Pierre River Mine wetlands. The EIA, 

Appendix 5-6, Terrestrial Monitoring Programs, Section 4, page 8, describes the 

general wetlands monitoring program that will be implemented to determine 

potential change to wetlands associated with the project. If monitoring indicates 

that additional mitigation is necessary, the monitoring results will be used to 

develop site-specific adaptive management strategies. 

Request 25d Four items are listed that qualitatively describe drawdown effects on the 

hydrology of the remaining wetlands. In relation to wetland functionality 

provide additional supporting evidence (e.g., data, logical arguments, relevant 

literature citations). 

i. Compare observations of the hydro-dynamic character of adjacent 

undisturbed wetlands in relation to remaining affected wetlands; 

ii. Use observations from adjacent undisturbed wetlands regarding normal 

wetland succession, to better characterize the time it will take for remaining 

affected wetlands to “…return to their former functionality more quickly”; 


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Section 12.1 

iii. Clarify the responses of key vegetation species, based on observations in 

adjacent undisturbed wetlands, to characterize hydro-dynamic changes 

within remaining affected wetlands; and, 

iv. Clarify the responses of key plant communities, based on observations in 

adjacent undisturbed wetlands, to characterize hydro-dynamic changes 

within remaining affected wetlands. 

Response 25d i. A direct comparison between the hydro-dynamic character of affected 

wetlands in the Pierre River Mine LSA and adjacent undisturbed wetlands 

should not be made, because site-specific factors will influence the 

hydrodynamic character of those wetlands. However, certain hydrological 

influences are expected to be similar. For example, it is known that 

hydrology influences the physical and chemical parameters in wetlands, 

which in turn influence the establishment and maintenance of wetland types 

and wetland processes. Given the major role of hydrology in wetlands 

function, changes in hydrology can affect aspects of wetland ecology, such as 

water chemistry, vegetation species composition and diversity (Thormann et 

al. 1998; Whitehouse and Bayley 2005; Locky and Bayley 2006; Laitinen et 

al. 2008). 

The relationship between water table depth and peatlands (e.g., fens and 

bogs) type is particularly close, with seasonal and annual water fluctuations 

influencing vegetation species composition in these wetlands (Thormann et 

al. 1998; Whitehouse and Bayley 2005). 

In general, the hydrological regime in wetlands is influenced by the wetland 

water budget, a character that is dynamic in space and time. The potential 

water storage capacity, geologic setting and climate will determine how a 

wetland responds to hydrologic changes related to oil sands development. 

Accordingly, the effects on peatlands because of water drawdown in the 

Pierre River Mine LSA are specific to those particular wetlands for such 

aspects as natural drainage, topography and hydrogeology, because they have 

dynamic and generally site-specific effects across the LSA. These dynamic 

and site-specific effects are addressed by developing detailed wetlands 

monitoring programs in the predicted drawdown area. 

In general, the influence of hydrology on peatlands can be summarized as 

follows: 

• wetlands type (e.g., fens, bog, swamps) and wetlands succession is 

controlled by water source, rate of water flow and water table 

fluctuations, which in turn may affect nutrient availability, alkalinity and 

the accumulation or decomposition of organic substrate (Devito and 

Mendoza 2006) 

• water table fluctuations naturally occur within the upper layer of peat 

(acrotelm) in fen and bog wetlands because it has high hydraulic 


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References 

conductivity (Laitinen et al. 2008). Deeper peat layers are more 

compacted and likely have less influence on the water table. 

Section 12.1 

• peak flows in boreal wetlands typically occur in late spring and early 

summer (Devito and Mendoza 2006). In general, the water balance in 

boreal wetlands is influenced by spring snow melt, but the numerous 

small precipitation events in spring through to fall that add water directly 

to wetlands are believed to have the most influence on boreal wetlands 

(Devito and Mendoza 2006). Surface runoff from surrounding terrestrial 

uplands is considered to be limited during these events relative to direct 

input from precipitation. 

• groundwater influences are uncertain and site specific primarily because 

glacial deposits are highly variable (Price and Waddington 2000; Devito 

and Mendoza 2006) 

• depth of water table in unaltered peatlands can fluctuate seasonally and 

annually. Thormann et al. (1998) have shown that annual water levels in 

fens range between approximately 7 cm below the moss surface to 20 cm 

above the moss surface. Patterned fens are typically subject to lower 

seasonal fluctuations in water depth (approximately 5 cm) (Laitinen et al. 

2008). Annual fluctuations in bogs are more consistent over time (Halsey 

et al. 2003). 

• drops in water table of 70 cm or more can drastically alter nutrient 

regime and vegetation composition in peatlands (Jeglum 1971). Water 

table declines (an estimated 20 cm for poor fens and 14 cm for 

moderate-rich fens) may lead to moderate changes in peatland function 

(Gignac et al. 1991). 

• high and stable water levels are important to rich fen communities, as 

these communities are generally dominated by sedges and moss 

(Kotowski et al. 2001; Whitehouse and Bayley 2005) 

Devito, K., and C. Mendoza. 2006. Maintenance and Dynamics of Natural 

Wetlands in Western Boreal Forests: Synthesis of Current Understanding 

from the Utikuma Research Study Area. In Guidelines for Wetland 

Establishment on Reclaimed Oil Sands Leases Revised (2007) Edition, 

Appendix C. Cumulative Environmental Management Association. 

Wood Buffalo Region, Alberta. 

Gignac, L.D., D.H. Vitt, and S.E. Bayley. 1991. Bryophyte Response Surfaces 

Along Ecological and Climatic Gradients. Vegetation 93:29-45. 

Halsey, L.A., D.H. Vitt, D. Beilman, S. Crow, S. Mehelcic, and R. Wells. 2003. 

Alberta Wetland Inventory Standards Version 2.0. Resource Data 

Division, Alberta Sustainable Resource Development. Edmonton, 

Alberta. 


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Section 12.1 

Jeglum, J.K. 1971. Plant Indicators of pH and Water Level in Peatlands at Candle 

Lake, Saskatchewan. Canadian Journal of Botany 49:1661-1676. 

Kotowski, W., J. van Andel, R. van Diggelen, and J. Hogendorf. 2001. 

Responses of Fen Plant Species to Groundwater Level and Light 

Intensity. Plant Ecology 155:147-156. 

Laitinen, J., S. Rehell, and J. Oksanen. 2008. Community and Species Responses 

to Water Level Fluctuations with Reference to Soil Layers in Different 

Habitats of Mid-boreal Mire Complexes. Plant Ecology 194:17-36. 

Locky, D.A., and S.E. Bayley. 2006. Plant Diversity, Composition, and Rarity in 

the Southern Boreal Peatlands of Manitoba, Canada. Canadian Journal of 

Botany 84:940-955. 

Price, J.S., and J.M. Waddington. 2000. Advances in Canadian Wetland 

Hydrology and Biochemistry. Hydrological Processes 14:1579-1589. 

Thormann, M.N., S.E. Bayley, and A.R. Szumigalski. 1998. Effects of 

Hydrologic Changes on Aboveground Production and Water Chemistry 

in Two Boreal Peatlands in Alberta: Implications for Global Warming. 

Hydrobiologia 362:171-183. 

Whitehouse, H.E., and S.E. Bayley. 2005. Vegetational Patterns and Biodiversity 

of Peatland Plant Communities Surrounding Mid-boreal Wetland Ponds 

in Alberta, Canada. Canadian Journal of Botany 83:621-637. 

ii. Observations from adjacent undisturbed wetlands are not currently available. 

EIA, Appendix 5-6, Terrestrial Monitoring Programs, Section 4, page 8, 

describes the general wetlands monitoring program that will be implemented 

to determine potential change to wetlands associated with the project and will 

include undisturbed reference monitoring plots to gauge the time it will take 

for remaining affected wetlands to return to their former functionality. 

iii. Adjacent undisturbed wetlands have not been monitored and, therefore, these 

observations are not available. However, based on the literature, differences 

in plant species composition, abundance and structure associated with 

wetlands types are a result of the hydrological regime and chemical 

parameters influencing the wetland (Thormann et al. 1998; Whitehouse and 

Bayley 2005). Vegetation species diversity in wetlands, in particular 

peatlands, is strongly associated with water depth and nutrient gradient (Vitt 

and Chee 1990; Whitehouse and Bayley 2005). 

Vegetation in peatlands has adapted to short-term and small seasonal 

fluctuations in water levels. However, when changes in water level are 

persistent and exceed seasonal normals, changes to vegetation communities 

can occur. Long-term changes in water levels, with durations over many 

seasons can affect vegetation species presence/absence in peatlands. 

Changes in hydrology can be associated with the following responses by 

vegetation; however, precise responses are dependent on site-specific factors: 


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References 

Section 12.1 

• an average water level of 1 to 40 cm above ground surface can result in 

the absence of trees and many shrub species from peatlands; at water 

depths of 0 to 19 cm below the ground surface, black spruce and 

tamarack abundance is reduced, though wetland shrubs can be abundant 

(Jeglum 1971) 

• at water depths greater than 0 to 19 cm above the surface, grasses and 

sedges and wetlands forbs may dominate (Jeglum 1971) 

• long-term water level declines greater than 20 cm in peatlands can allow 

peatland functions to continue, but vegetation community structure is 

expected to change (Gignac et al. 1991). Drops in water level below the 

natural range can cause decreases in sedges, grasses and mosses and 

increases in shrubs (Thormann and Bayley 1997). 

• surface water levels affect bryophyte community structure with brown 

mosses typically dominating wet environments, with Sphagnum species 

within moist depressions to top of hummock dry areas (Laitinen et al. 

2008) 

Gignac, L.D., D.H. Vitt, and S.E. Bayley. 1991. Bryophyte Response Surfaces 

Along Ecological and Climatic Gradients. Vegetation 93:29-45. 

Jeglum, J.K. 1971. Plant Indicators of pH and Water Level in Peatlands at Candle 

Lake, Saskatchewan. Canadian Journal of Botany 49:1661-1676. 

Laitinen, J., S. Rehell, and J. Oksanen. 2008. Community and Species Responses 

to Water Level Fluctuations with Reference to Soil Layers in Different 

Habitats of Mid-boreal Mire Complexes. Plant Ecology 194:17-36. 

Thormann, M.N., and S.E. Bayley. 1997. Aboveground Net Primary Production 

Along a Bog-fen-Marsh Gradient in Southern Boreal Alberta, Canada. 

Ecoscience 4:374-384. 





Vitt, D.H., and W.L. Chee. 1990. The Relationship of Vegetation to Surface 

Water Chemistry and Peat Chemistry in Fens of Alberta, Canada. 

Vegetation 89:87-106. 




iv. See the response to AENV SIR 25diii. 


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Section 12.1 

Request 25e Provide information on plans to monitor and mitigate the impacts of dewatering 

on the surrounding wetlands. 

Response 25e The conceptual wetlands monitoring program described in the EIA, Volume 5, 

Appendix 5-6, will expand on the Albian Sands Wetlands Monitoring Program, 

which has been ongoing since 2000 (Golder 2007). To assess the potential effects 

of the project on wetlands, the approach will be to monitor species abundance, 

richness, diversity and vigour according to plot distance from the mine over the 

duration of the monitoring program. The program will include collecting 

ecological field data and interpreting aerial photographs. 

Reference 


Groundwater monitoring, as conceptually described in the EIA, Volume 4B, 

Appendix 4-9, Section 2, will provide early indication of potential 

hydrogeological effects on wetlands due to dewatering. Should the groundwater 

monitoring program detect an unanticipated change to groundwater levels near a 

particular wetland, a groundwater response plan (EIA, Volume 4B, Appendix 4- 

9, Section 2.1.5) will be developed and implemented. The response plan will 

assess and mitigate, if necessary, the hydrogeological change to adaptively 

manage potential impacts of dewatering on a nearby wetland. 

Golder. 2007. Muskeg River Mine, Wetlands Monitoring Program, 2005 Annual 

Report. Prepared by Golder Associated Ltd. For Albian Sands Energy 

Inc. 


Shell states that wetlands function to attenuate flood runoff and then states that 

the removal of wetlands will result in reduced flows to streams and rivers. 

26a Clarify this apparent inconsistency. 

Response 26a There is no inconsistency. The removal of wetlands in the project areas (i.e., 

areas within the mine footprint) because of mine development (closed-circuit 

operations) will result in reduced flows, including flood flows to receiving 

streams and rivers. However, the function of the remaining wetlands (wetlands 

located outside the closed-circuit operations) will not be affected by removal of 

wetland features within the mine footprint and will continue to attenuate flood 

runoff. 


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Request Volume 2, SIR 294d, Page 21-48. 

Section 12.1 

Shell states that wetlands in the reclaimed landscape are expected to succeed to 

marsh wetland types. Shell states that peatlands are not considered as part of 

the reclaimed landscape at closure because there is limited knowledge about 

requirements for peat-forming processes on reclaimed landscapes (CEMA 2007). 

27a Clarify where marsh wetland types are planned in the reclamation closure plan. 

Response 27a At the landscape level of planning, at the time of reclamation, marsh wetlands 

types will be created using current guidelines for wetlands establishment. At the 

meso-topographical scale, marsh wetlands types are expected to establish in 

depressional areas of reclaimed tailings cells and the external tailings facility, at 

the base of the north overburden disposal area, and within littoral zones and 

associated wetlands constructed at the inlet, outlet and margins of the pit lakes. 

On a micro-topographical scale, marsh wetlands types will be planned, where 

appropriate, along the vegetated waterways and drainage channels, identified by 

Sh2 and Sh3 on Figure 14 (EIA, Volume 5, Appendix 5-2). 

At the conceptual level of EIA planning, marsh wetlands types have been 

considered in depressions within low-lying areas on tailings cells and on the 

shorelines of the pit lakes. Reclamation target transitional ecosite types d1 and e2 

shown in Figure 14 (see EIA, Volume 5, Appendix 5-2) have been located at the 

transition between upland and wetlands areas, and support wetlands functions. 

Hydrological conditions, soil profiles and vegetation types will be reconstructed 

on the landscape to support wetlands functions and development, as described in 

the EIA, Volume 5, Appendix 5-2, Section 2.3.2. 

Request 27b Provide a map of the marsh ecosite phases and description of wetland plant and 

animal species that are anticipated. 

Response 27b Figure AENV 27-1 presents the areas where marsh ecosites and wetlands 

transtitional ecosites are planned on the conceptual closure landscape. As 

described in the response to AENV SIR 27a, marsh ecosites will also be planned 

at the landscape level. 

Plant and animal species typical to graminoid marsh (MONG) wetlands types are 

expected in the reclaimed marsh ecosite types. Emergent sedges, grasses, rushes, 

reeds, submerged and floating aquatics are among the plant families expected in 

the reclaimed marshes. The plant species anticipated include, but are not limited 

to Typha spp., Carex spp., Scirpus spp., Polygonum spp., Juncus spp., and 

Acorus calamus. The animal species anticipated are a wide variety of mammals, 

birds and amphibian species associated with wetlands. These include, but are not 

limited, to: Canadian toads; black terns, a variety of waterfowl (e.g., greenwinged 

teal, mallard, northern pintail), other waterbirds including lesser yellow 

legs and sora rails; raptors, such as northern harrier and short-eared owl; and 

mammals, such as muskrat, beaver, mink and river otter. 


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Figure AENV 27-1: Reclamation Ecosite Phase/Wetlands Types Planting Prescriptions 

Section 12.1 


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Section 12.1 

Request 27c Provide information on what is currently known about peat-forming processes on 

reclaimed landscapes in the oil sands region. Discuss current research studies 

and results. 

Response 27c There is ongoing research in the Oil Sands Region related to peatland 

reconstruction. Shell participates in the Canadian Oil Sands Network for 

Research and Development (CONRAD) and supports research projects, 

including studies on the initiation of wetlands and controls of soil moisture 

regimes on reconstructed landscapes. Shell supports Dale Vitt’s research on 

understanding peatland initiation processes that will contribute to the 

development of best practices for peatland reconstruction. Shell will continue to 

incorporate results from current research studies into its reclamation operations, 

where feasible. 

References 

Current reclamation knowledge and experience in the region states that organic 

bogs and fens (peatlands) cannot be reclaimed (CEMA 2007), but research is 

currently underway within CONRAD (CONRAD 2008) and the Wetlands and 

Aquatic Sub Group (WASG) of the Cumulative Environmental Management 

Association (CEMA) to investigate methodologies for wetlands reconstruction on 

reclaimed landscapes. For example, CONRAD supports fen reclamation research 

that is investigating the success of vegetation island transplants. The WASG has 

initiated reclamation research on the processes and function of existing wetlands 

for practical application in the Oil Sands Region. 

CEMA. 2007. Guideline for wetland establishment on reclaimed oil sands leases 

(revised edition) 2007. Prepared by Harris, M.L. for CEMA Wetlands 

and Aquatics Subgroup of the Reclamation Working Group, Fort 

McMurray, AB. Dec/07. 

CONRAD. 2008. 2008 Annual Update. Canadian Oil Sands Network for 

Research and Development – Environmental and Reclamation Research 

Group (CONRAD ERRG). 

Request 27d Clarify how this knowledge will be used in progressive wetland reclamation 

planning on the Pierre River Mine Site. 

Response 27d Reclamation programs will be adaptively managed to incorporate the results and 

recommendations from ongoing research regarding the establishment of bogs and 

fens on the closure landscape. As discussed in the response to AENV SIR 27c, 

Shell will progressively incorporate the results of current wetlands reconstruction 

research into reclamation planning and operations, where feasible. 


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Request Volume 2, SIR 294e, Page 21-49. 

Section 12.1 

The assumption that storage capacity for a given surface area of a pit lake is 

greater than that of a wetland is misleading because it is not the surface area but 

rather the ‘active’ depth or volume that is critical in relation to patterns of water 

storage, retention and release. Peat soils and living Sphagnum may retain well 

in excess of their weight by volume of water, and in doing so, they buffer the 

rates at which fluxes of water storage, retention and release occur. 

28a Provide data and information to demonstrates how pit lakes will be regulated to 

respond in the manner that the natural wetland systems operate (e.g., in terms of 

mimicking time lags), in particular in relation to typical fluxes that occur, such 

as from storm and flood events, and extended periods of desiccation/drying. 

Response 28a The pit lakes will not be regulated (designed) to respond to various storm events 

in the same manner that the natural wetland systems operate (i.e. the pit lakes are 

not expected to exactly mimic the natural wetlands in terms of storage capacity 

and time lags to attenuate floods). Therefore, the reclaimed landscape will have a 

different hydrological response compared to natural conditions. The effects of 

this change in hydrological response are captured in the surface water hydrology 

assessment (see EIA, Volume 4A, Section 6.4.5). 



Shell states that Modeling has been completed to confirm that the residence time 

will be sufficient to biodegrade organic constituents to acceptable levels. 

29a Indicate where in the EIA this modeling is reported and assessed in relation to 

this question. If it is not in the EIA, provide the data and information. 

Response 29a Pit lake water quality modelling methods are presented in the EIA, Volume 4B, 

Appendix 4-2, Section 2.1.3.2; pit lake modelling results are presented in EIA, 

Volume 4B, Appendix 4-7, Section 4; assessment of modelling results is 

presented in EIA, Volume 4A, Section 6.5.6.3. 


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Request Volume 2, SIR 298a – d, Page 21-53. 

Section 12.1 

It is likely that the polishing pond temperatures for Jackpine and Pierre River 

will be within close range of each other. Similarly, the Muskeg and Pierre River 

streams also exhibit comparable water temperature regimes. On this basis, the 

four questions (i.e., SIR 298 a – d) are applicable to Pierre River. 

30a Provide answers to the four questions posed, in terms of polishing pond 

temperatures of the Pierre River project and the streams of the Pierre River 

project that flow to the Athabasca River. 

Response 30a The following are responses to the May 2009 Pierre River Mine, Supplemental 

Information, Volume 2, SIR 298 a to d, in terms of polishing pond temperatures 

of the Pierre River Mine Project and the streams of the Pierre River Mine Project 

that flow to the Athabasca River: 

Original SIR 298a 

Clarify the first sentence of the pre-amble since most of the polishing pond 

temperatures presented in Figure 6.5-2 (Page 6-380) are above the seventy-fifth 

percentile of the Muskeg River, and not within the range of monthly background 

temperatures. 

Figure 6.5-2 shows that the range of polishing pond temperatures (0.0 to 20.6ºC) 

is within the range of background temperatures for the Muskeg River (-0.6 to 

23.3ºC). Episodic periods of warmer temperature for polishing ponds have been 

observed before ice-cover from August to December, and a few were outside of 

monthly background ranges (e.g., October 25, 2002). These periods corresponded 

to short-term periods of high solar radiation and air temperatures, when bottom 

heat flux from the shallow polishing ponds can appreciably affect water 

temperature. 

Original SIR 298b 

How will higher temperatures quantitatively influence downstream temperatures 

in the Muskeg River; that is, what will be the new downstream water 

temperatures at different times of the year under a range of river stages? 

A conservative temperature balance of a “worst-case” scenario for thermal 

impacts from polishing ponds releases was calculated as part of the EIA and is 

discussed in EIA, Volume 4A, Section 6.5.5.1, page 6-382. It was based on: 

• mean September and October streamflows and water temperature for the 

Muskeg River 

• high flow from the polishing ponds 


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• temperature recorded at the ponds during the episodic warm period of 

October 25, 2002 (see Figure 6.5-3) 

Section 12.1 

The balance indicated that water temperatures in the Muskeg River are expected 

to increase by less than 0.1ºC. This “worst-case” scenario is unlikely to occur, 

since high pond outflow will typically correspond with high streamflow in the 

Muskeg River. Therefore, temperature increases in the river as a result of pond 

temperature are expected to be less than 0.1ºC for all the likely combinations of 

pond outflows and Muskeg River streamflows. 

For the reasons outlined above, increases in water temperatures in Eymundson 

Creek downstream of polishing ponds are similarly expected to be less than 0.1ºC 

for all the likely combinations of pond outflows and streamflows. 

Original SIR 298c 

What range of distances for the flow in ditches are required to return water 

temperature to ambient conditions, before discharging to the river at different 

times of the year? 

As mentioned in the response to SIR 298b, the maximum anticipated change in 

Muskeg River water temperatures is less than 0.1ºC, based on a conservative 

thermal balance. The small changes in Muskeg River temperatures downstream 

of polishing ponds have been confirmed by monitoring, as detailed in EIA, 

Volume 4, Section 6.5.5.1. Therefore, the ditch constructed to convey water from 

the polishing ponds to receiving waters would provide additional thermal 

equilibration above and beyond what is necessary in terms of minimizing thermal 

effects. 

Original SIR 298d 

What criteria, factors, probability levels and thresholds did Shell use to 

determine that the slightly higher temperatures in the Muskeg River, ranging 

from approximately less than 1 degree C to 3 degrees C caused by the polishing 

pond effluence is negligible? 

Neither Section 6.5.5.1 nor 6.5.5.3 refer to “slightly higher temperatures in the 

Muskeg River, ranging from approximately less than 1 degree C to 3 degrees C 

caused by the polishing pond effluence”. In the EIA, Volume 4A, Section 

6.5.5.1, page 6-379 states “polishing pond releases induce negligible changes to 

Muskeg River water temperatures (Figure 6.5-3)”. This statement refers to the 

very small change in temperature (well below 1ºC) observed in the Muskeg River 

because of polishing pond discharge, even during periods when water 

temperature is high in the polishing ponds. It is expected that similar changes 

would be expected in Eymundson Creek downstream of polishing pond releases. 

The water quality guideline used in Alberta for the protection of freshwater 

aquatic life (AENV 1999) was the criterion employed to qualify the effect of 

polishing ponds and pit lakes on water temperature. The guideline specifies that 

instream water temperature is “not to be increased by more than 3°C above 

ambient water temperature”. 


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Reference 


Section 12.1 

AENV (Alberta Environment). 1999. Surface Water Quality Guidelines for Use 

in Alberta. Science and Standards Branch. Environmental Assurance 

Division. Edmonton, AB. Submitted November 1999. 25 pp. 


It is likely that the polishing pond DO concentrations for Jackpine and Pierre 

River will be within close range of each other. Similarly, the Muskeg and Pierre 

River streams also exhibit comparable DO concentrations. On this basis, the two 

questions (i.e., SIR 299) are applicable to Pierre River. 

31a Provide the answers to SIR 299 posed in terms of polishing pond DO 

concentrations of the Pierre River project and its streams and receiving waters. 

Response 31a The following are responses to the May 2009 Pierre River Mine, Supplemental 

Information, Volume 2, SIR 299a and b, in terms of polishing pond DO 

concentrations of the Pierre River Mine Project and its streams and receiving 

waters: 

References 

Original SIR 299a 

Explain why changing the annual frequency distribution of DO does not have an 

adverse effect on DO concentrations. 

Increases in dissolved oxygen concentrations, even up to 100% saturation, do not 

have adverse effects on aquatic life. Therefore, changes in the annual frequency 

distribution associated with increasing dissolved oxygen (DO) concentrations are 

not considered to adversely affect aquatic life. Dissolved oxygen is essential to 

the metabolism of all aerobic aquatic organisms (Wetzel 2001) and no adverse 

effects are associated with oxygen concentrations near saturation. Therefore, 

provided that water quality guidelines for the protection of aquatic life for 

dissolved oxygen (AENV 1999; CCME 1999; US EPA 2002) are met, and the 

waters are not becoming highly supersaturated, changes in DO within these 

bounds are not predicted to have an adverse effect. 

AENV (Alberta Environment). 1999. Surface Water Quality Guidelines for Use 

in Alberta. Science and Standards Branch. Environmental Assurance 

Division. Edmonton, AB. Submitted November 1999. 25 pp. 

CCME (Canadian Council of Ministers of the Environment). 1999. Canadian 

Environmental Quality Guidelines (with updates to 2006). Winnipeg, 

MB. 


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Reference 


Section 12.1 

US EPA (United States Environmental Protection Agency). 2002. National 

Recommended Water Quality Criteria: 2002. US EPA, Office of Water 

4304T. EPA 822-R-02-047. 

Wetzel, R. G. 2001. Limnology: Lake and River Ecosystems, 3rd Edition. 

Academic Press. New York, NY. 1006 pp. 

Original SIR 299b 

How does the change in the annual DO frequency distribution affect other water 

quality parameters, including but not limited to: pH, ion mobility, algae and 

plankton production and elemental biogeochemical cycling? 

Although some biogeochemical processes affect both pH and dissolved oxygen 

(DO), there is no direct relationship between these variables. Therefore, a change 

in the annual DO frequency distribution would not directly affect pH. 

The three major mechanisms controlling major ion concentrations in surface 

water are rock dominance, atmospheric precipitation and evaporationprecipitation 

processes (Wetzel 2001). A connection between DO and major ion 

mobility has not been identified, provided the water is not anoxic. 

In relatively well-oxygenated water, DO is not expected to be a limiting factor 

for algae plankton production. Therefore, small increases in DO would not be 

expected to have effects on productivity. 

Redox potential is relatively insensitive to changes in DO, and redox potential of 

surface waters will remain positive and fairly high as long as water is not near 

anoxia (Wetzel 2001). As discussed in EIA, Volume 4A, Section 6.5.6, DO 

concentrations are not expected to decline in receiving streams downstream of 

the project. Therefore, the annual DO frequency distribution is not expected to 

affect elemental biogeochemical cycling. 

Wetzel, R. G. 2001. Limnology: Lake and River Ecosystems, 3rd Edition. 

Academic Press. New York, NY. 1006 pp. 

Request Volume 2, SIR 301a-b, Page 21-55. 

Global action on climate change issues fundamentally requires the active 

cooperation of major industrial operators working at a regional or local level. 

32a What efforts are being made by Shell (in addition to efforts undertaken by 

CEMA) to integrate project information with other proposed projects? 


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Section 12.1 

Response 32a Shell continues to participate in a number of relevant regional, provincial and 

national initiatives, including: 

• Technology for Emission Reduction and Eco-Efficiency steering committee 

within the Petroleum Technology Alliance Canada 

• Industry Greenhouse Gas Benchmarking Advisory Group and the Fuel Best 

Management Practices Industry Advisory Group within the Canadian 

Environmental Technology Advancement Corporation – West 

• Electricity Project Team – Greenhouse Gas Allocation Subgroup of the 

Clean Air Strategic Alliance 

Request 32b What is Shell (in addition to efforts undertaken by RAMP) doing to share data at 

the western regional and national levels with other organizations? 




The discussion of the role of Karst in the Pierre River area concludes by 

identifying that the Karst hydrology is primarily independent or separate of the 

deep basal aquifer. Shell states that, the sinkholes are considered to be part of 

the local shallow groundwater flow system but then, in the next sentence, makes 

the point that sinkholes do not appear to have an influence on the shallow 

groundwater system. 

33a Clarify this relationship, as the text seems to contradict itself, saying that karst is 

part of the local shallow groundwater system, but has no influence upon the local 

groundwater system. 

Response 33a The first conclusion, that “the sinkholes are considered to be part of the local 

shallow groundwater flow system”, indicates that the sinkholes are not connected 

to the basal aquifer because the sinkhole water chemistry is markedly different 

than that of the basal aquifer. 

The second conclusion, that “sinkholes do not appear to have an influence on the 

shallow groundwater system”, indicates that no differences were observed 

between the hydrogeologic characteristics of the sinkhole lakes and the shallow 

groundwater system for either water levels or water chemistry. If the sinkhole 

lakes were an expression of the basal aquifer, representing discharge of basal 

water, then the lake water chemistry would have reflected the basal water 

chemistry, but this was not the case. Therefore, it was concluded that the sinkhole 


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Section 12.1 

lakes would likely recharge the basal aquifer, in the same way as the surficial 

deposits recharge the basal aquifer. Accordingly, dewatering of the sinkholes is 

not expected to have any incremental effects to those caused by dewatering the 

surrounding shallow groundwater system. This was the basis for the conclusion 

that “the sinkholes will not likely contribute extensive, regional hydrologic effects 

to the project.” 

Request 33b Shell states that sinkholes will not likely contribute extensive, regional 

hydrologic effects on the project but regarding localized effects, there are no 

data provided or site-specific treatment discussed. 

i. Clarify what Karst effects or influences could be at a local level in relation to 

the development of the Project, and outline how these will be mitigated. 

ii. Provide any appropriate data or information that describes if or how 

calcium-enriched waters may continue to flow and contribute to the 

hydrology and ecology of the aquatic resources, within the local context. 

Response 33b i. No karst effects on the shallow groundwater were noted at the local level. 

Water levels in both the sinkhole lakes and the surficial deposits are similar 

and there is a downward vertical hydraulic gradient between the surficial 

deposits and the basal aquifer. This suggests that both the sinkhole lakes and 

the surficial deposits similarly recharge the basal aquifer. 

The conclusion reached in the response to the May 2009 Pierre River Mine, 

Supplemental Information, Volume 2, SIR 306b was that “hydrologic and 

hydrogeologic effects of the project are not predicted to be materially 

exacerbated or attenuated by the Eymundson Sinkholes. Accordingly, 

mitigation measures are not required.” This conclusion applies to both local 

and regional effects. 

ii. The sinkholes will continue to function and contribute to local aquatic 

resources, including the basal aquifer system, until overburden dewatering is 

conducted in advance of mining the area. When overburden dewatering 

begins near the sinkhole lakes, the lakes will be drained, as will the 

surrounding shallow groundwater system. 

Although sinkhole waters will continue to flow and contribute to local 

hydrology prior to disturbance, the advance of the active mine pit will 

ultimately result in dewatering and removing the sinkholes. The reclaimed 

mining area, including the area that formerly contained the sinkholes, will 

have different shallow groundwater flow patterns than it did before the 

disturbance. 

Request 33c With respect to SIR 306b, provide data or analysis that supports Shell’s position. 


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Section 12.1 

Response 33c The data to support the position presented in the May 2009 Pierre River Mine, 

Supplemental Information, Volume 2, SIR 306b, that the sinkholes do not 

exacerbate or attenuate effects of the project, were described in SIR 306a. These 

data included: 

Reference 

• local geology and hydrogeology (Section 5.4.3 and Figures 29, 32 to 38 of 

the Hydrogeology ESR, WorleyParsons Komex, 2007) 

• groundwater levels in shallow and deeper Quaternary deposits (Figures 37 

and 38; WorleyParsons Komex, 2007) 

• bathymetry data for Sinkhole Lakes 1 and 2 (EIA, Section 8.4.5.2, pp 8-77) 

• water chemistry for Sinkhole Lakes 1 and 2 

• groundwater chemistry for Quaternary deposits, McMurray Formation, Basal 

aquifer and Devonian Formation (Table 11, WorleyParsons Komex, 2007) 

• major ion characterization for Sinkhole Lake, Basal aquifer and Devonian 

Formation waters (Figure 306-1, May 2009 Pierre River Mine, Supplemental 

Information, Volume 2) 

Based on these data, the following conclusions were reached: 

• the shallow groundwater flow direction is not altered by the sinkholes 

• the hydrochemical signature of the sinkhole lakes is calcium-bicarbonate 

(Ca-HCO3) type, indicative of freshwater 

• the hydrochemical signature of the basal aquifer near the sinkholes is 

sodium-bicarbonate-chloride (Na- HCO3-Cl) type, indicative of an older, 

deeper, regional groundwater flow system 

• the difference in hydrochemical signatures indicates a lack of hydraulic 

connection between the sinkholes and deeper deposits 




Request 33d In Shell’s discussion of Karst, a reference is made to Figure 8.4-6 in Volume 5 of 

the EIA, the Terrestrial Section. Figure 8.4-6 illustrates the locations of three 

sinkholes, while Figure 8.4-7 shows there to be four. Clarify this discrepancy. 

Response 33d Figure 8.4-7 is based on the surficial geology map by Bayrock (1971) and shows 

four sinkhole locations near the border of the Eymundson ESA and a fifth 


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References 


Section 12.1 

sinkhole location immediately north of Eymundson Creek. Figure 8.4-6 shows 

three water-filled sinkholes that have been captured in the hydrography layer of 

1:25,000 scale provincial maps (Altalis, 2004). Sinkhole Lakes 1 and 2 are those 

noted by Westworth (1990), whereas Sinkhole Lake 3 corresponds to the fifth 

sinkhole location shown in the map by Bayrock (1971). The air photo in Figure 

8.4-8 clearly shows the three large water-filled sinkholes (Sinkhole Lakes 1, 2 

and 3), one additional sinkhole lake, and other sinkholes (within the yellowdashed 

area) that do not appear water filled. 

Bayrock, L.A. 1971. Surficial Geology Bitumount (NTS 74E). Research Council 

of Alberta. Map 140, 1:250,000 scale. 

Westworth (Westworth and Associates Ltd.) 1990. Significant Natural Features 

of the Eastern Boreal Forest Region of Alberta. Technical Report. Report 

for Alberta Forestry, Lands and Wildlife. Edmonton, AB. 147 pp. + 

Maps. 


In response to the question of whether or not Shell considers all project effects 

reversible, Shell states that Only six project related effects on terrestrial 

resources were determined to be irreversible:…. Old growth forest is irreversible 

within the timeline of the assessment – but reversible in the far future. [And] 

Wetlands, including peatlands and patterned fens resulting from the assumption 

that peatlands cannot currently be reclaimed. 

In Table 480-1 included in their response to SIR 384 a, Shell states The 

environmental consequence for barred owl habitat is considered low because, 

although habitat loss is high in magnitude at 80 years post closure and 

reclamation, the reclamation landscape has the potential to develop barred owl 

habitat over 100 years or more. 

34a Clarify the timeline on which the assessment of project effects is made. 

Response 34a For the purposes of assessing project effects on terrestrial resources, closure and 

reclamation effects are considered 80 years after the completion of mining (EIA, 

Volume 5, Section 7.2.3, p.7-14). 

Request 34b Given that Shell acknowledges that old growth forests cannot be reclaimed, at 

least within the time line of the assessment, how can Shell conclude that the 

environmental consequence of the project on barred owls in the LSA is low? 


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Section 12.1 

i. Is the regeneration of old growth forest (>100 years) not explicitly outside of 

the assessment period (80 years post closure and reclamation)? 

ii. Explain this apparent discrepancy. 

Response 34b i. Yes, the regeneration time of old growth forest is explicitly outside the 

assessment period. The development of boreal old growth forest requires 100 

years or more (Schneider 2002). 

Reference 

Reference 

Schneider, R.R. 2002. Alternative Futures: Alberta's Boreal Forest at the 

Crossroads. The Federation of Alberta Naturalists. Edmonton, AB. 

ii. It is assumed that barred owls prefer breeding in areas with a high proportion 

of forest that is older than 80 years of age (Marzur et al. 1998). Forests will 

not exceed 80 years of age within the time frame of the assessment. As a 

result, the magnitude of habitat loss for barred owl is estimated to be high at 

closure (see EIA, Volume 5, Section 7.5.3.3, Table 7.5-37, p. 7-115). 

However, although a time frame of 80 years after closure was selected for the 

purposes of assessment, an assessment time frame only 10 years longer (i.e., 

90 years) may have resulted in a net positive magnitude effect of the project 

on barred owl habitat. Therefore, given the few additional years beyond the 

assessment time frame that it would take for barred owl habitat to recover, it 

is unwarranted to assess the environmental consequence for barred owl 

habitat loss more severely than ‘low’. Such qualifying statements would not 

be valid for land cover types that are expected to take much longer than the 

assessment time frame to recover, such as peatlands. 

Mazur, K.M., S.D. Frith and P.C. James. 1998. Barred owl home range and 

habitat selection in the boreal forest of central Saskatchewan. The Auk. 

115(3): 746-754. 

Request 34c Clarify why wetlands are deemed to be irreversible when the Guideline for 

Wetland Establishment on Reclaimed Oil Sands Leases (2007) provides 

guidelines on their reclamation. 

Response 34c In order to ensure that the environmental impact analysis would be as 

conservative as possible, Shell has remained conservative in its assumptions 

regarding bog and fen peatlands establishment on the reclaimed landscape. Shell 

utilized the Draft Guideline for Wetland Establishment on Reclaimed Oil Sands 

Leases (released at the end of 2006) during Closure, Conservation and 

Reclamation planning, and will continue to use the Guideline for Wetland 

Establishment on Reclaimed Oil Sands Leases (CEMA 2007) for planning the 

establishment of other wetlands types in ongoing closure and reclamation 

planning. The results of peatland establishment research into reclamation 


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Reference 

planning and operations will be incorporated into closure and reclamation 

planning. 

Section 12.1 

Shell recognizes that research is currently underway with the Canadian Oil Sands 

Network for Research and Development (CONRAD) and the Wetlands and 

Aquatic Sub Group (WASG) of the Cumulative Environmental Management 

Association (CEMA) to further investigate methodologies for wetlands 

reconstruction on reclaimed landscapes. For example, CONRAD supports fen 

reclamation research that is investigating the success of vegetation island 

transplants. The WASG has initiated reclamation research on the processes and 

function of existing wetlands for practical application in the Oil Sands Region. 

Reclamation programs will be adaptively managed to incorporate the results and 

recommendations from ongoing research regarding establishment of wetlands, 

including peatlands, on the closure landscape. 





Request 34d Clarify why peatlands are deemed irreversible given that current research is 

exploring their reclamation. 

Response 34d As discussed in the response to AENV SIR 34c, Shell has remained conservative 

in its assumptions regarding peatlands establishment on the reclaimed landscape 

in order to ensure that the environmental impact analysis would be as 

conservative as possible. Shell acknowledges that the results of peatland research 

may change the assumption that the effects on peatlands and patterned fens may 

be irreversible. Peatlands reclamation research is currently underway through 

CONRAD and CEMA as outlined in the response to AENV SIR 34c, and 

additionally through research groups, such as the Peatland Ecology Research 

Group (PERG) based at Laval University (see http://www.gret-perg.ulaval.ca/ ). 

Shell will incorporate the results of peatland establishment research into 

reclamation planning and operations. 

Request 34e Provide information on how Shell will incorporate progressive wetland 

reclamation to minimize irreversible effects on wetlands. 

Response 34e As previously discussed, Shell will utilize the Guideline for Wetland 

Establishment on Reclaimed Oil Sands Leases (CEMA 2007) for the reclamation 

of wetlands types within the guideline, and will incorporate the results of 

peatland establishment research into reclamation planning and operations. 

Reclamation programs will be adaptively managed to incorporate the results and 

recommendations from ongoing research regarding establishment of wetlands, 

including peatlands, on the closure landscape. All areas, including wetlands, will 


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Reference 

Section 12.1 

be progressively reclaimed on the landscape where mining operations have been 

completed. 





Request 34f Provide information on how Shell will attempt to reclaim rare and special plant 

communities associated with wetlands. 

Response 34f As required by current Reclamation Criteria (ASRD 2007) and amended criteria 

currently in draft from Alberta Sustainable Resource Development, and operating 

approval conditions, Shell will provide the conditions for rare and special plant 

communities to establish on the reclaimed landscape, where appropriate. As 

presented in the EIA, Appendix 5-2, Section 2.5.1, Shell is planning to reclaim 

the project area to plant communities typical of the local boreal forest. As 

research findings present further methods to establish boreal peatlands and the 

rare or special plant communities associated with them, Shell will incorporate the 

results into reclamation planning and operations. Reclamation programs will be 

adaptively managed to incorporate the results and recommendations from 

ongoing research regarding establishment of rare and special plant communities 

associated with wetlands on the closure landscape. 

Reference 


ASRD. 2007. A guide to reclamation criteria for wellsites and associated 

facilities - 2007 - forested lands in the Green Area update. Edmonton, 

AB. April/07. 


Shell states that after closure the environmental consequences are high for 

wetlands (80% loss) at the local level, but are negligible at the regional level. 

However, there is no attempt to consider the effects of Shell’s impacts on 

wetlands at the regional level in the context of cumulative effects. 

35a Provide information of the consequence of wetland loss of Shell’s proposed 

development at the regional level in the context of cumulative effects. 

Response 35a The consequence of wetland loss at the regional level due to the Jackpine Mine 

Expansion and Pierre River Mine are contained in the EIA. Taking into account 


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Section 12.1 

the revised estimate of the effects of hydrological drawdown on the Jackpine 

Mine Expansion (see the December 2009 Jackpine Mine Expansion, 

Supplemental Information, Volume 2, Part 4, Appendix B: Shell Jackpine Mine 

Expansion & Pierre River Mine EIA Update in the Jackpine Mine Expansion 

Project Update), the project applications for the Jackpine Mine Expansion and 

the Pierre River Mine predict a loss of 20,967 ha (2%) of wetlands in the RSA. 

The Jackpine Mine – Phase 1 predicted a loss of 3,783 ha of wetlands, which 

reflects a less than 1% change in the RSA. 


Shell was asked to discuss the strategies they will implement if the wetland 

monitoring program results show a major impact to the fen and other adjacent 

wetlands. Shell states that the question is not applicable to the PRM. 

36a Answer the SIR in the context of the PRM. 

Response 36a The lenticular fen is located only within the Jackpine Mine Expansion local study 

area (LSA); however other wetlands, including fens, bogs, swamps and marshes 

are located in and adjacent to the Pierre River Mine LSA. These wetlands are 

predicted to be affected by water drawdown as a result of dewatering and mining 

operations in the Pierre River Mine LSA. Hydrology influences the physical and 

chemical parameters in wetlands, which in turn influence the establishment and 

maintenance of wetland types and wetland processes. Given the major role of 

hydrology in wetlands function, changes in hydrology can affect aspects of 

wetland ecology, such as water chemistry, vegetation species composition and 

diversity (Thormann et al. 1998; Whitehouse and Bayley 2005; Locky and 

Bayley 2006). A water level drawdown of more than 0.1 m may negatively affect 

wetland structure and function. 

A wetlands monitoring program will be implemented to monitor wetlands 

vegetation during operations and after closure and reclamation. The wetlands 

monitoring program will expand on the Albian Sands Wetlands Monitoring 

Program, which has been ongoing since 2000 (Golder 2007). The main approach 

to assess the potential effects of the project on wetlands will be to monitor 

species abundance, richness, diversity and vigour according to plot distance from 

the mine over the length of the monitoring program. The program will include 

the collection of ecological field data and aerial photo interpretation. The EIA, 

Appendix 5-6, “Terrestrial Monitoring Programs”, Section 4, page 8, describes 

the general wetlands monitoring program that will be implemented to determine 

potential change to wetlands associated with the project. 

In addition, proposed monitoring of overburden dewatering is outlined in EIA, 

Volume 4B, Appendix 4-9, Section 2.1.4.2. Groundwater levels will be 


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References 


Section 12.1 

monitored semi-annually before mine development begins and then until the 

mine pit is backfilled. 

Should the wetlands or groundwater monitoring programs detect unexpected 

effects on groundwater levels as a result of overburden dewatering, a 

groundwater response plan (EIA, Volume 4B, Appendix 4-9, Section 2.1.5) will 

be developed to assess and mitigate, if necessary, the impacts of dewatering on 

the surrounding wetlands. 

Golder. 2007. Muskeg River Mine, Wetlands Monitoring Program, 2005 Annual 

Report. Prepared by Golder Associated Ltd. For Albian Sands Energy 

Inc. 

Locky, D.A., and S.E. Bayley. 2006. Plant Diversity, Composition, and Rarity in 

the Southern Boreal Peatlands of Manitoba, Canada. Canadian Journal of 

Botany 84:940-955. 









Shell states several barriers to peatland reclamation however no formal 

evaluation for re-establishment opportunities have been given. 

37a Provide formal evaluation of opportunities of these important ecosystems. 

Response 37a In the EIA, wetlands reclamation followed the conservative approach to 

peatlands reclamation based on the Guideline for Wetland Establishment on 

Reclaimed Oil Sands Leases (CEMA 2007). Peatlands were not shown to be 

reclaimed at project closure; however, it is anticipated that they will occur on the 

post-mining landscape in the far future scenario. 

Shell has evaluated the following opportunities for re-establishment of peatlands 

and wetlands. Examples include sites with high water table levels and a 

favourable hydrologic regime in the closure landscape will provide wet 

environments with the potential for moss establishment and peat accumulation. 

Such areas may develop into peatlands in the far future. For example, closure 


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Reference 


Section 12.1 

ecosite type d1 (of the Athabasca Plains Natural Sub-region) is a transitional 

ecosite phase planned for the reclamation of wet landscapes. Closure ecosite type 

d1 is located around the margins and low-lying areas surrounding drainage 

channels and adjacent to littoral zones on the pit lakes. Transitional ecosite 

phases are included in the wet landscape category because they are poorly 

drained ecosite phases defined by a shallow peat layer over mineral subsoil, and 

are adjacent to peatlands or wetlands areas. Transitional ecosites phases are 

capable of supporting treed wetlands in the far future. 

Closure ecosite type c1 (of the Athabasca Plains Natural Sub-region) is an upland 

ecosite phase known to incorporate “pocket” wetlands areas, in which the gradual 

accumulation of peat may result in the development of numerous small, peatlands 

in the far future. 

As more is understood about the hydrological and substrate conditions required 

to support peatlands establishment during reclamation activities, further 

opportunities will warrant a formal evaluation. Results from the work currently 

carried out by the Canadian Oilsands Network for Research and Development 

(CONRAD) and the Cumulative Environmental Management Association 

(CEMA) Wetlands and Aquatics Sub-Group will assist in understanding these 

required conditions. 


(revised second edition). Prepared by Lorax Environmental for CEMA 

Wetlands and Aquatics Subgroup of the Reclamation Working Group, 

Fort McMurray, AB. Dec/07. 


Shell states that regional environmental consequences for all resources are 

predicted to be negligible or low because no significant cumulative impacts are 

predicted at the regional scale following closure. 

38a Explain why Shell does not think wetland reclamation is well understood given 

that CEMA has produced two guideline manuals on wetland reclamation. 

Response 38a Wetlands types, such as marshes and drainage channels, can be created as 

described in the Guideline for Wetlands Establishment on Reclaimed Oil Sands 

Leases. Current reclamation knowledge and experience in the region states that 

organic bogs and fens (peatlands) cannot be reclaimed (CEMA 2007), but 

research is currently underway to investigate methods for wetlands 

reconstruction on reclaimed landscapes. 


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Reference 

Section 12.1 

Shell has addressed this request in its response to all parts of AENV SIR 27 and 

AENV SIR 34c to 34f. 





Request 38b Provide evidence that Shell is committed to wetland reclamation in closure 

planning and minimizing the environmental consequences of development. 

Provide a map with detailed wetland reclamation plans. 

Response 38b In the EIA, reclamation followed the conservative approach to wetlands 

establishment based on the Guideline for Wetland Establishment on Reclaimed 

Oil Sands Leases (CEMA 2007). Detailed reclamation planning is not provided 

in conceptual plans, however, details regarding criteria and methodology are 

provided in the above Guideline. 

Peatlands were not shown to be reclaimed at project closure. However, Shell is 

optimistic that ongoing research efforts will produce sufficient knowledge to 

create peatlands in the future. 

Marsh wetlands types, riparian shrublands and littoral zones were shown to be 

reclaimed at project closure at the conceptual level; however, it is expected that 

additional created wetlands will be established at the operational stage and that 

opportunistic wetlands will also develop on the closure landscape. 

Shell will present strategies for the creation of wetlands, and wet landscapes with 

the potential to develop into wetlands, as required by operating approval 

conditions. Most of the potential for wetlands development lies with the creation 

of suitable micro/meso landscape features at the detailed operational level. 

The closure areas that can be included within the wet landscape category (see 

Figure AENV 38-1) are poorly drained, low-lying areas: 

• littoral zones adjacent to open waterbodies 

• marsh wetlands types (MONG) 

• riparian shrublands surrounding drainage channels and waterbodies 

• reclamation transitional ecosite phase d1 

• depressional areas within reclamation ecosite phase c1 

The pit lake has been designed with littoral zones that will support wetlands 

species. Littoral vegetation is important for shoreline stability, nutrient cycling 

and providing habitat for aquatic invertebrates and cover for fish. Littoral zones 

will consist of marshes (MONG) and shallow open water wetlands. Littoral zones 

serve a different hydrological function than wetlands, but will provide unique 


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Section 12.1 

habitat for aquatic species, shorebirds and certain rare plants. The littoral zones 

are predicted to be sustainable into the far future. 

Figure AENV 38-1: Wet and Dry Surface Landscape at Closure for the Pierre River Mine 


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References 

Section 12.1 

Marshes will be designed according to the Guideline for Wetland Establishment 

on Reclaimed Oil Sands Leases (CEMA 2007) and are predicted to be sustainable 

features of the closure landscape. 

Primary drainage channels and pit lakes are designed to be permanent and 

sustainable into the far future. These features will be planted with a buffer of 

riparian shrubland species. Shallow channels with a constant, high water table 

have the potential to evolve from a shrubland community to a wetlands 

vegetation community. 

If a shrubland community is established in these areas, conditions may become 

appropriate for beaver colonization. Beavers use riparian species as a food source 

and for dam building. Beaver activity can result in the creation of ponds and 

flooded areas, which may create conditions conducive to wetlands and meadow 

development. Encouragement of beaver colonization may require the creation of 

areas of slightly better drained topography along watercourses to allow for the 

establishment of aspen. 

The transitional Labrador tea-subhygric black spruce-jack pine (d1) ecosite phase 

is planned for near-level areas of lower elevation or in areas adjacent to riparian 

shrublands. Reclamation ecosite phase d1 is designed for poorly drained areas 

and is characterized by development of a shallow peat layer over mineral subsoil. 

Transitional ecosite phases have the potential to support treed wetlands in the far 

future. 

The c1 ecosite phase at closure has potential for establishment of discontinuous 

wetlands. Within the natural c1 ecosite phase, as described by Beckingham and 

Archibald (1996), small depressional treed wetlands areas (identified as d1 

ecosite phase or BTNN wetlands type) occur intermittently on the landscape. 

Closure and reclamation landscape planning for c1 ecosite phases will include 

the topographic contouring to provide functional treed wetlands in the far future. 

Peatland restoration research has been underway since the early 1990s in Canada 

and, more recently, research on peatland creation in the oil sands. Favourable 

results will contribute to the development of best practices for oil sands peatland 

reconstruction. The reclaimed wet landscapes at the Pierre River Mine will 

provide opportunities for wetlands development and will be integral components 

of the planned reclamation activities. 

Beckingham, J.D. and J.H. Archibald. 1996. Field Guide to Ecosites of Northern 

Alberta. Natural Resources Canada. Canadian Forest Service, Northwest 

Region, Northern Forestry Centre. Special Report 5. Edmonton, AB. 


(revised second edition). Prepared by Lorax Environmental for CEMA 

Wetlands and Aquatics Subgroup of the Reclamation Working Group, 

Fort McMurray, AB. Dec/07. 


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Section 12.1 

Shell is confident in its ability to reclaim the development area to self-sustaining 

ecosystems that will meet equivalent land capability at closure. 

39a Explain how the principles of equivalent land capability are consistent with the 

replacement of high productive and diverse wetlands (that support a wide array 

of plants and animals such as moose) with pit lakes. 

Response 39a The principle of equivalent land capability is to reclaim to land uses with an 

equivalent pre-disturbance capability, but is understood to mean not necessarily 

to the same land use, or on the same footprint. An example is peatlands where 

such wetlands cannot currently be reclaimed with confidence, and therefore, 

other land types, such as marshes, having equal or greater capability for a wide 

range of uses, are reclaimed. 

Reference 

Pit lakes are a necessary closure feature recognized by regulators and designed to 

perform water quality remediation functions. The functions of pit lakes could be 

considered of high value for the reclaimed landscape. 

Further, Shell is not claiming that pit lakes are a substitute for highly productive 

and diverse wetlands. Not all pre-disturbance wetlands should be considered 

highly productive and diverse unless there is data and a rating system to 

substantiate such claims. Pre-disturbance wetlands are not rated according to 

their individual capabilities to facilitate comparison of equivalent land capability 

after reclamation. 

Reclamation land capability is determined using the land capability classification 

(AENV 2006) which was designed to rate uplands for forest capability. Class 5 

capability includes lands with such severe limitations for successful forest 

potential that it is not feasible to “correct” the limitations. Thus, waterbodies (pit 

lakes), wetlands (marshes, shallow open waters including littoral zones) and 

other wet lands (shrublands) are collected together in the lowest class rating of 

‘5’. 

Table 6 (EIA, Appendix 5-2, Section 2.3.1) indicates that lakes will make up 

1,920 ha of the closure landscape. Areas classed as littoral zone, refer to marsh 

and shallow open water wetlands types and are planned to comprise 254 ha at 

closure. Class 5 soils will cover 1,020 ha of the closure landscape and refer 

specifically to shrublands (Sh2 and Sh3) prescriptions. 

AENV. 2006. Land Capability Classification System for Forest Ecosystems in 

the Oil Sands, 3rd Edition. Volume 1: Field Manual. Prepared for 

Alberta environment by the Cumulative Environmental Management 

Association. 53 pp + appendices. 


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Section 12.1 

Shell states that before reclamation, existing, currently-approved and disclosed 

mines will affect 48% of wetlands in the Muskeg River watershed. 

40a Explain how there is a low environmental consequence of development on 

regional basis given this information. 

Response 40a The low environmental consequence is based on the application of the 

assessment methodology outlined in the EIA (see EIA, Volume 5, Section 1.3). 

The environmental consequence of the loss of wetlands regionally is determined 

based on the magnitude of the loss of wetlands in the regional study area (RSA). 

The Muskeg River watershed represents a small proportion of the RSA used for 

this assessment. In addition, environmental consequence ratings are determined 

based on the incremental change resulting from the project (see EIA, Volume 5, 

Section 7.5.2, page 7-94) and planned developments (see EIA, Volume 5, Section 

7.6.2, page 7-142) from existing conditions, including existing oil sands 

developments. The response to the May 2009 Pierre River Mine, Supplemental 

Information, Volume 2, SIR 474b reflects baseline conditions before oil sands 

developments and it has no bearing on environmental consequence ratings for the 

project. A low environmental consequence is predicted for the RSA in the 

Planned Development Case based on the loss of wetlands in the RSA relative to 

the Base Case. 

Request 40b Provide evidence that Shell will contribute to reclaiming the high local and 

regional loss of wetlands. 

Response 40b Refer to the responses to AENV SIRs 27, 34, 37 and 38b regarding Shell’s 

commitments to reclaiming wetlands on the closure landscape. 

Request 40c Provide detailed maps of closure plans with wetland ecosites and describe target 

wetland plant and animal species. 

Response 40c Refer to the response to AENV SIR 27 and Figure AENV 27-1 for a map of the 

target ecosites with wetlands. Also, refer to the response to AENV SIR 38b and 

Figure AENV 38-1 for a map with wet landscapes with potential to develop into 

peatlands in the far future. Revegetation plans and planting prescriptions for 

these ecosites are presented in the EIA, Volume 5, Appendix 5-2, Section 2.5. 

Animal species that will colonize in wetlands are described in the response to 

AENV SIR 27b. 

The conceptual closure plans outlined above are at the appropriate level of detail 

for the EIA and project application. More detailed reclamation plans will be 


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Section 12.1 

provided as required for operational purposes after project approval and will 

follow the applicable regulatory guidelines. 


Shell indicates that fish and benthics are critical or important key indicators, and 

that aquatic health is assessed in relation to fish populations and other aquatic 

life (invertebrates, algae, aquatic plants). 

Subsequent to this statement, however, Shell notes that no data were or are being 

collected on algae and plants and that such data on algae may even be unreliable 

in this context. Shell states that algae and aquatic or wetland plant species are 

excluded as KIRs because fish and benthic invertebrates are sufficient 

representatives of aquatic health. Shell states that a healthy aquatic ecosystem 

refers to a diverse and functioning aquatic ecosystem, which is typically reflected 

by a healthy fish community. 

41a Clarify if an important key indicator is, in fact, algae, and if so, what direct or 

indirect measures of algae are appropriate for indicator tracking and 

measurement purposes. 

Response 41a Algae is not being considered as a key indicator resource (KIR) for fish and fish 

habitat for the purpose of assessing project-related effects on fish and fish 

habitat. See the response to AENV SIR 41b for the rationale of not including 

algae as a KIR. 

Request 41b Provide a rationale for excluding algae and aquatic plant species when they are 

important components of fish and benthic invertebrate habitat and form the basis 

of the food chain for a healthy aquatic ecosystem. 

Response 41b The rationale for selection of key indicator resources (KIRs) for Fish and Fish 

Habitat, as described in EIA, Volume 4, Section 6.7.2.4, considered previously 

established KIRs for oil sands EIAs and recommendations of regulatory agencies 

and stakeholders. The KIRs for the fish and fish habitat component are key fish 

species or guilds, benthic invertebrate populations and their respective habitats. 

The selected KIRs were considered to be suitable as sentinel species for the 

aquatic ecosystem. Algae were not specifically included as KIRs since benthic 

invertebrates were selected as representative of the lower trophic levels and are 

generally considered a better indicator of changes to fish habitat than algae, as 

described in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 2, SIR 342. 


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Reference 

Section 12.1 

Aquatic plants and algae are recognized as important features of the aquatic 

ecosystem, and as such, have been proposed as components of the conceptual 

monitoring plan for lakes (see EIA, Volume 4B, Aquatic Resources Appendices, 

Appendix 4-9, Section 5.2.5.1 and Section 5.2.5.2). For stream monitoring, the 

presence of submergent vegetation and percent of instream cover are common 

variables used for habitat suitability index (HSI) models for most species present 

within the project area and have been included in the Jackpine Mine – Phase 1 

monitoring program to support the validation of the HSI models. However, in the 

typical stream habitat in the project area, the scientific literature indicates that 

allochthonous organic carbon inputs from riparian vegetation and bogs is the 

largest component of the organic matter inputs and strongly affects the character 

of the heterotrophic food chain. For example, Jonsson et al. (2006) found that 

aquatic primary production was an insignificant input of organic carbon relative 

to terrestrial organic carbon in the aquatic environment in boreal forest in 

Sweden. The use of algae and aquatic plants as a separate KIR (outside of the 

consideration of fish habitat) for the purpose of completing the EIA was not 

considered necessary for assessing project-related effects on fish and fish habitat. 

Further details on monitoring aquatic plants will be developed in consultation 

with regulators and stakeholders in the development of the detailed NNLP 

compensation monitoring program. 

Jonsson, A., G. Algesten, A.-K. Bergstrom, K Bishop, S. Sobek, L.J. Tranvik and 

M. Jansson. 2006, Integrating aquatic carbon fluxes in a boreal 

catchment carbon budget. J Hydrology 334:141-150. 

Request 41c Provide a list of appropriate KIR’s for non-fish bearing shallow lakes and 

wetlands including plant and animal species. 

Response 41c Wetlands, such as bogs, fens and marshes, were assessed as part of the Terrestrial 

Resources Assessment (EIA, Volume 5, Section 7.5.1, 7.5.2 and 7.5.3). The key 

indicator resource (KIR) selection process for terrestrial resources is described in 

the EIA, Volume 5, Section 7.6.7.2; this assessment considers wetlands, 

vegetation and wildlife resources. Wetland KIRs include peatlands (fens and 

bogs), patterned fens, rare and special plant communities (i.e., lenticular 

patterned fen) and riparian communities, as they are associated with wetlands in 

many cases. Wildlife KIRs associated with wetlands include Canadian toad, 

yellow rail and beaver. The KIRs for shallow, non-fish bearing lakes would 

include benthic invertebrates and their habitat. 


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Section 12.1 

Shell states that fall monitoring of fish is preferred based on results from 

Jackpine Mine Phase-1 monitoring. Spring spawning species are indirectly 

accounted for via presence of fry found in the fall sampling. 

42a Clarify how this sampling method will be inclusive to species that seasonally 

utilize but may not spawn in the sampling location. 

Response 42a The proposed fall monitoring program corresponds to the period between mid- 

August to mid-September (i.e., late summer and early fall) and was selected 

based on results from the Jackpine Mine – Phase 1 monitoring program. This 

period was selected as it avoids the migration to winter habitat while still 

capturing fish under optimal sampling conditions and at the peak of the annual 

population and biomass cycle. 

In addition to the fall monitoring program, fish presence data will also be 

obtained through spring fish passage monitoring that will be conducted in areas 

where fish passage would be affected by the project (see EIA, Volume 4B, 

Appendix 4-9, Section 5.2.5.4, page 63). Any species that might seasonally 

utilize habitats without spawning would be detected through the fish passage 

monitoring at these locations. As is occurring with current monitoring programs 

conducted by Shell, the monitoring program will be reviewed annually by Shell, 

DFO, SRD and stakeholders and adjusted where necessary based on the results 

from previous years. 

Request 42b Describe how this sampling method will account for juveniles that do not remain 

in the same habitat or location of their hatch. 

Response 42b Although juvenile fish often use different habitat from spawning habitat, that 

habitat use is addressed in the monitoring program through the sampling of all 

mesohabitat types within multiple stream reaches throughout the study area. 

Most of the fish living in the affected streams are habitat generalists and are 

usually found at some density in all habitats. 


Request Volume 2, SIR 361, Page 22- 27. 

Shell indicates that additional sampling methods will be used to assess fish 

abundance and diversity in the deeper water of beaver dams and compensation 

lake habitats. 


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Section 12.1 

43a Describe Shell’s sampling protocol, detailing when specific sampling techniques 

will be used. 

Response 43a The monitoring program will follow the protocols outlined in Shell’s strategy for 

compensation habitat monitoring currently under review by regulatory agencies 

and stakeholders (Hatfield 2009). The specific details of the monitoring program 

will be based initially on the Jackpine Mine – Phase 1 monitoring program, 

which has undergone several years of review with regulatory agencies to refine 

the program. Fish abundance will be assessed using multiple-pass electrofishing 

in stream habitats and mark-recapture studies will be used for deeper habitats. 

Specific locations of sampling for the Pierre River Mine will be developed before 

the monitoring program is implemented in consultation with regulators and 

stakeholders and will be dependent on site-specific conditions at the time of 

sampling. 

Reference 

Hatfield (Hatfield Consultants). 2009. Evaluating aquatic habitat loss and 

compensation offsets in the Athabasca oil sands. Prepared for Shell 

Canada Energy. Calgary, AB. December 2009. 

Request 43b Clarify how trend data will be comparable year-to-year if sampling techniques 

and effort are not constant. 

Response 43b A strategy has been developed to provide consistency in sampling for Shell’s 

monitoring programs (Hatfield 2009). Habitat conditions may change from year 

to year because of differences in flow condition or beaver activity, for example, 

which may warrant changing the sampling approach to match the conditions 

present. Fish abundance will be determined using either multiple-pass removal 

electrofishing when conditions are suitable or mark-recapture studies. The 

estimates of fish abundance will provide the trend information and habitat use 

assessment required for Alberta Environment and Fisheries and Oceans Canada 

monitoring. The physical habitat parameters measured seasonally each year 

(Hatfield 2009) will also help interpret differences that may be observed in the 

data amongst years. 

Reference 

Hatfield (Hatfield Consultants). 2009. Evaluating aquatic habitat loss and 

compensation offsets in the Athabasca oil sands. Prepared for Shell 

Canada Energy. Calgary, AB. December 2009. 


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TERRESTRIAL 


Section 13.1 

In the EIA Volume 5, Appendix 5-2, Section 1.6, Page 18, Shell states that 

reconstructed soil performance will mimic natural soils over time. In the Pierre 

River Mine SIR Response, Shell references personal communication with L. 

Leskiw in July 2008, discussing the development of an incipient LF horizon on 

some of Suncor’s older upland reclamation areas and juvenile profile 

development (LF horizons and discontinuous Ae horizons) on direct placement 

reclamation areas at Syncrude. 

44a How old are the reclamation areas at Suncor and Syncrude where the juvenile 

profile development described above was found? 

Response 44a The reclamation areas discussed in the personal communication were between 20 

and 30 years old. 

Request 44b What is the Land Capability Class for each of the juvenile profiles described 

above? 

Response 44b The land capability class was not discussed in the personal communication of 

July 2008. The research referred to in this personal communication is the 

Nutrient Biogeochemistry II project currently being conducted through 

CONRAD. The results of this study are not available for public disclosure. 

Request 44c What was the reconstructed profile of the juvenile soils described above? 

Response 44c The reconstructed profile was not discussed in the personal communication of 

July 2008. The research referred to in this personal communication is the 

Nutrient Biogeochemistry II project currently being conducted through 

CONRAD. The results of this study are not available for public disclosure. 


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TERRESTRIAL AENV SIRS 44 – 78 

Section 13.1 

Request 44d How do they compare to the reconstructed profiles described in the Closure, 

Conservation, and Reclamation Plan for the Pierre River Mining Area (EIA 

Volume 5, Appendix 5-2, Section 2.4.5, Page 61, and Figure 10, Page 63)? 

Response 44d Since the reconstructed profiles were not discussed in the personal 

communication of July 2008, Shell cannot compare the profiles in Figure 10 of 

the EIA. The research referred to in this personal communication is the Nutrient 

Biogeochemistry II project currently being conducted through CONRAD. The 

results of this study are not available for public disclosure. 

Request 44e Based on the age and Land Capability Class of these juvenile profiles and a 

comparison of reconstructed profiles, discuss Shell’s assumptions and knowledge 

that equivalent capability will be achieved within the 80 year timeframe 

discussed in the original EIA, using the reconstruction profiles proposed in the 

Closure, Conservation, and Reclamation Plan for the Pierre River Mining Area. 

Response 44e Considering the degree of profile development on direct placement, peat-mineral 

mix areas after only 20 to 30 years, it is reasonable to expect that soil profile 

development will continue to evolve to a soil profile typical of the region. Shell 

expects that equivalent land capability will be achieved for similar profiles within 

the 80-year time frame, as discussed in the EIA, as well as incorporating 

advances in soil salvage and handling approaches through adaptive management. 



This question was asked in the list of SIR 1 questions, but the reference provided 

(Shell EIA Update Report, Appendix II, Section 2.4.1 and 2.4.2, Table 20 and 21) 

was for the Jackpine Mine Expansion only. Shell states that they will answer the 

question in the Jackpine Mine Expansion Project Supplemental Information, but 

the question is applicable to both the Pierre River Mine and Jackpine Expansion 

Mine areas and, as such, requires an answer for the Pierre River Mine Project as 

well. The Pierre River Mine reference is: Volume 5, Appendix 5-2, Section 2.4.1 

and 2.4.2, Table10 and 11. Tables 10 and 11 outline the criteria to be used for 

determining the suitability of salvageable upland surface soils and subsoil for 

reclamation purposes, but it is unclear how Shell will be applying these ratings 

to additional data collected during soil salvage operations, or if they will be 

relying on the data collected during the Soil and Terrain ESR. 

45a Provide a response to SIR 415 in regards to Pierre River Mine. 

Response 45a Professional agrologists and pedologists from Paragon Consulting Ltd. and Shell 

Albian Sands carry out monitoring programs to sample soil quality for 


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Reference 

Section 13.1 

reclamation salvage programs. Reclamation suitability ratings are correlated to 

the soil and terrain mapping by the monitoring personnel and implemented 

during the direction of soil salvage operations. Operational scale assessments of 

reclamation suitability are confirmed using soil classification (soil series) and 

texture as guiding principles. 

As described in the response to the December 2009 Jackpine Mine Expansion, 

Supplemental Information, Volume 2, SIR 383a, soil salvage planning includes 

soil test pitting sample collection and lab analysis (in addition to field tests for 

calcareous materials, texture and pH) during the 100 m by 100 m test pitting 

process carried out one year ahead of salvage activities. The test pits are typically 

up to 2.5 m deep in peat areas and 1.5 m deep in upland areas. Lab analyses of 

soil samples help to determine surface soil and subsoil reclamation suitability 

using the Soil Quality Criteria Relative to Disturbance and Reclamation – 

Revised (Alberta Agriculture 1987). Results of the field and lab analyses are 

reviewed and integrated into salvage planning for the subsequent year to ensure 

that soil quality assessments are proactive and consistent. 

Alberta Agriculture. 1987. Soil Quality Criteria Relative to Disturbance and 

Reclamation – Revised. Prepared by the Soil Quality Working Group for 

Alberta Agriculture. Edmonton, AB. 

Request 45b Describe the field methods that will be used to identify surface and subsoil 

reclamation suitability during soil salvage operations, including any sampling 

and analysis programs that may be used. 




Shell indicates that they have not studied the areas associated with diversion 

channels C6 and C11 as part of the EIA. Shell also states that their size is such 

that they will not materially affect the results of the EIA. 

46a Confirm that there are no other areas outside of the LSA that have not been 

studied (e.g., diversion channel C4). 

Response 46a Portions of drainage channels C4, C6 and C11 (see EIA, Volume 5, Appendix 5- 

2, Figure 4) are outside of the terrestrial resources local study area. The total area 

associated with these portions, including the channel, assumed construction areas 

and dykes, is 599 ha. 


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Section 13.1 

Request 46b Confirm why the EIA is complete and acceptable without the inclusion of data 

and information in the C6 and C11 areas, and any other areas that may have 

been identified in part a). 

Response 46b The EIA is considered complete because the disturbance related to these portions 

of drainage channels C4, C6 and C11 were assessed as part of the regional 

assessment study area of the project, and they are a small portion (less than 3%) 

of the area of the Pierre River Mine local study area. Given this small percentage, 

Shell considered whether the exclusion of these portions of the drainage channels 

would affect the results of the EIA prior to submission and concluded that their 

exclusion will not materially affect the environmental consequences determined 

for the EIA. 

Request 46c Confirm that the areas in question are for a diversion channel. 

i. If so then does this require a Water Act approval? 

ii. If an approval is required then what studies will Shell undertake to gain such 

approval? 

Response 46c i. The areas outside of the local study area (LSA) are associated with closure 

drainage channels. These channels will be constructed a few years prior to 

2049. The Water Act approval for these channels is being sought as part of 

this application. 


ii. Shell will conduct soil and vegetation field surveys in the areas associated 

with drainage channels outside of the Pierre River Mine terrestrial resources 

local study area prior to construction of these portions of the drainage 

channels. Findings from these surveys will be discussed with Alberta 

Environment and Alberta Sustainable Resource Development prior to 

construction in these areas. 

Request Volume 2, SIR 426a, Page 23-50; Page 23-64, Table 426-7. 

Shell states that Table 426-7 replaces Table 2.4-5 in the ESR. A comparison of 

the original and the revised tables indicates that the area of disturbed land and 

the area of water within the Jackpine Mine Expansion LSA have been reversed, 

resulting in a significant increase in the amount of surface water within the 

development area. 

47a Confirm that this reversal is an accurate reflection of the pre-disturbance 

conditions in the LSA. 


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Section 13.1 

Response 47a This reversal is not an accurate reflection of the pre-disturbance conditions in the 

local study area (LSA). The baseline disturbed areas in the LSA on Table 426-7 

should read 1,709 ha and the baseline open water areas in the LSA should read 

102 ha. 

Request 47b If the reversal is accurate, provide the appropriate updates to the EIA, ESR, and 

Closure, Conservation, and Reclamation plan. 

Response 47b As discussed in AENV SIR 47a, the reversal is not accurate and therefore the 

EIA, Environmental Setting Report (ESR), and Closure, Conservation and 

Reclamation Plan used the appropriate values for water and disturbance area 

estimates. There are no additional updates required because of the reversal of the 

water and disturbance values. 


Request Volume 1, Section 7, Table 11-2, Page 7-49 ; EIA Volume 5, Section 7, Page 7- 

112 ; EIA Volume 5, Appendix 5-4, Section 1.2.3, Page 14-24. 

In the Errors and Omissions section of the Project Update Volume 1, Shell 

indicates in Table 11-2, Page 7-49 that there will be no indirect habitat loss for 

moose, lynx, fisher/marten, black-throated green warbler, barred owl or beaver 

due to the project. Yet in the EIA, Volume 5, Appendix 5-4 Page 14, Shell 

explains that ‘Distance to nearest road’ was found to contribute negatively (-) to 

the most strongly supported RSF model for moose and ‘Distance to nearest edge 

C’ was a contributing negative factor in the most strongly supported model for 

fisher/marten. 

48a Given that these disturbance factors were found to be important in the RSF’s for 

moose and fisher/marten, explain how the indirect habitat loss could be zero for 

these species. 

Response 48a Resource Selection Functions (RSFs) are multivariate statistical equations that 

were developed to quantify habitat quality for some key indicator resources 

(KIRs) like moose and fisher/marten. RSFs for moose and fisher/marten 

incorporate the effects of disturbance features as variables that affect habitat 

quality as the reviewer indicates in the preamble to this question. However, the 

effects of individual variables on model output in multivariate statistical models 

like RSFs cannot be easily separated and quantified. Therefore, for moose and 

fisher/marten, both direct and indirect effects of the project are included in the 

column “Direct Habitat Change” in Table 11-2, page 7-49 of the May 2009 

Pierre River Mine, Supplemental Information, Volume 1, Section 7, Errors and 

Omissions. Nonetheless, the effects of proximity to disturbance are implicit in 

predictions of relative habitat quality for moose and fisher/marten, and affect 


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Section 13.1 

final model output. Indirect habitat loss is not zero for moose or fisher/marten 

because it has been taken into consideration with direct habitat change. 

The table structure used in the EIA and the May 2009 Pierre River Mine, 

Supplemental Information was based on habitat suitability modelling output from 

Habitat Suitability Index (HSI) models in which direct and indirect effects were 

determined separately. This structure was not changed when some of the KIRs 

were modelled used RSFs. In those cases, a zero was placed in the “Indirect 

Habitat Change” column of the tables to reflect that indirect habitat loss could 

not be quantified separately. 

Request 48b What evidence does Shell have that indicates sensory disturbance will not lead to 

indirect habitat loss for moose, lynx, fisher/marten, black-throated green 

warbler, barred owl or beaver? 

Response 48b Indirect habitat loss through sensory disturbance was considered to affect all key 

indicator resources (KIRs) except for Canadian toads and beavers (see EIA, 

Volume 5, Section 7.5.3.2, p.7-112). Beavers are highly adaptable animals that 

live in close association with humans, provided that requirements for food and 

aquatic habitat are met (Nietfeld et al. 1984), suggesting that they are not 

sensitive to noise and other disturbances (see EIA, Volume 5, Section 7.5.3.2, 

page 7-112). Indirect habitat loss through sensory disturbance was considered to 

affect moose, Canada lynx, fisher/marten, black-throated green warbler and 

barred owl (see EIA, Volume 5, Section 7.5.3.2, page 7-112). However, 

quantified estimates of habitat loss for these species were produced using 

resource selection functions (RSFs). The RSFs incorporate the effects of 

disturbance features as variables in complex multivariate statistical equations. 

The effects of individual variables on model output in multivariate statistical 

models cannot be easily separated and quantified. Assessed effects of the project 

on indirect habitat loss incorporate both habitat suitability model output, as well 

as professional judgment. 

Reference 


Nietfeld, M., J. Wilk, K. Woolnough and B. Hoskin. 1984. Wildlife Habitat 

Requirement Summaries for Selected Wildlife Species in Alberta. 

Alberta Energy and Natural Resources, Fish and Wildlife Division, 

Wildlife Resource Inventory Unit. 

Request Volume 1, SIR 310a-c, Page 13-1 ; Volume 2, SIR 458d i, Page 23-137. 

Shell’s response to this question states Shell indicates that the current data 

suggest that genetic connectivity will be maintained. However, current research 

has not been designed to prove genetic connectivity nor are the data sufficiently 


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Section 13.1 

(statistically) robust to prove that genetic connectivity has been maintained … 

involves establishing not only movement from one location to another; but, also 

the survival and reproduction of migrants. Direct studies of survival and 

reproduction have not been conducted for wildlife in the Oil Sands Region. Yet, 

in a number of responses to other SIRs, Shell continues to indicate genetic 

connectivity will be maintained: 

- Volume 1. Section 13.1 Page 13-1 Question 310a and b. (ERCB) 

- Volume 1. Page 14-8 Question 371b (ERCB) 

- Volume 2. Page 23-2 Question 383a 

- Volume 2. Page 23-105 Question 449d 

- Volume 2. Page 23-181 Question 481b 

49a Shell acknowledges there is no evidence to support the assertion that genetic 

connectivity will be maintained, yet in contradiction to this, Shell asserts they 

will maintain genetic connectivity in several other SIR responses noted above. 

Clarify this apparent contradiction and revise the responses noted above as 

applicable. 

Response 49a Shell intended to highlight observations from current external research (Mills and 

Allendorf 1996; Wang 2004) suggesting the possibility for maintenance of 

genetic connectivity as opposed to asserting that genetic connectivity will be 

maintained. Responses noted above are revised as appropriate below. 

Volume 1. Section 13.1 Page 13-1 SIR 310a (ERCB) 

Previous Request 310a What studies have been done to determine that a 

setback of 250 m from the Athabasca River will be appropriate for habitat 

protection and will provide a suitable wildlife corridor? 

Revised Response 310a 

Wildlife corridor monitoring has been carried out in and around the Muskeg and 

Athabasca rivers, specifically to provide information on wildlife abundance and 

distribution in potential corridor areas, as documented in EIA, Volume 5, 

Section 7.5.4. Results from monitoring programs carried out as part of the 

Terrestrial Environmental Setting Report for the Jackpine Mine Expansion and 

Pierre River Mine Project (Golder 2007a) and the Jackpine Mine – Phase 1 

Wildlife Corridor Monitoring Program (Golder 2007b) have shown that many 

species use the riparian and upland areas adjacent to rivers, which suggests that 

genetic connectivity will likely be maintained for wildlife populations if corridors 

are provided along the Athabasca River system adjacent to the Pierre River Mine 

Project. 

Volume 1. Section 13.1 Page 13-1 SIR 310b (ERCB) 

Previous Request 310b What criteria did Shell apply to select 250 m as an 

appropriate setback from the high water line on the western shore of the 

Athabasca River? 


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Revised Response 310b 

Section 13.1 

A setback of 250 m along the western shore of the Athabasca River was selected 

on the basis of monitoring results from the Jackpine Mine – Phase 1 Wildlife 

Corridor Monitoring Program (Golder 2007b) and the Terrestrial Environmental 

Setting Report for the Jackpine Mine Expansion and Pierre River Mine Project 

(Golder 2007a) in addition to information from corridor monitoring programs 

conducted in the area, e.g., Canadian Natural Resources Ltd.’s Horizon Oil Sands 

Project. Monitoring results have shown that most species are present in the 

existing Jackpine Mine – Phase 1 wildlife corridor areas and, therefore, suggest 

that the criterion of genetic connectivity for populations within the regional study 

area will likely be met. That is, a minimum of one and up to 10 effective 

migrants per generation of all wildlife species are likely to pass through wildlife 

corridors, and thus genetic connectivity is predicted to be maintained (Mills and 

Allendorf 1996; Wang 2004). 

Volume 1. Section 14.1 Page 14-8 SIR 371b (ERCB) 

Previous Request 371b What are the sensory affects of light and traffic on 

wildlife usage of the underpass? 


The effects of the bridge were considered in the assessment of wildlife 

movement. The sensory effects are considered an indirect disturbance to wildlife 

using the passageways under the bridge. The magnitude of the effect will be 

determined by such factors as the: 

• type of lighting used on the bridge 

• characteristics of the traffic using the bridge 

Noise levels generated by traffic will be affected by the speed, size and frequency 

of traffic over the bridge. Effects, such as noise, light and smell, are factors 

affecting habitat effectiveness. The wildlife passageway was regarded as a zone 

of influence (ZOI) with a disturbance coefficient (DC) of less than one. A 

disturbance coefficient of 1 (DC = 1) applies when there are no hindrances to 

movement, whereas a DC of zero reflects a complete barrier to movement. In this 

case, wildlife are predicted to use the passageway under the cover of darkness or 

during periods of lower traffic volume. If wildlife use the passageway as 

predicted, genetic connectivity is likely to be maintained throughout the region 

(Mills and Allendorf 1996; Wang 2004) as outlined in the EIA, Volume 5, 

Section 7.1.2. 

Volume 2. Section 23.1 Page 23-2 SIR 383a 

Previous Request 383a The CNRL requirement is 400 m. Has Shell 

completed a contingency plan if the requirement for this mine will be 400 m as 

well? 


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Revised Response 383a 

Section 13.1 

In developing the Pierre River Mine Plan, Shell balanced the need to minimize 

impacts to the Athabasca River wildlife corridor with the obligation to maximize 

the recovery of bitumen resource for the province and its shareholders. 

Consistent with Shell’s EIA, Shell believes that the 250-m setback provides this 

balance, and is sufficient to allow the movement of wildlife along the Athabasca 

River corridor. The corridor is predicted to maintain genetic connectivity because 

a minimum of one and up to 10 effective migrants per generation of all wildlife 

species (Mills and Allendorf 1996; Wang 2004) are likely to travel through. 

Accordingly, Shell currently has no contingency plans to reflect a 400-m setback. 

Volume 2. Section 23.1 Page 23-105 SIR 449d 

Previous Request 449d Shell indicates it will provide for wildlife passage 

under the Athabasca River bridge on both the east and west banks of the river. 

i. Discuss wildlife movement criteria included in the design specifications for 

the proposed Athabasca River bridge. 

Revised Response 449d 

i. Preliminary work has been completed on the design of the wildlife 

passageways under the Athabasca River Bridge on both sides of the river. In 

its current location, the bridge height will exceed 2.5 m (current plans exceed 

10 m), and although the width of the wildlife passageway under the bridge 

will vary seasonally, it will exceed 10 m throughout the year because the 

escarpment is higher than the river at the current location and the bridge will 

be built from escarpment to escarpment. Because of the width of the road 

surface on the bridge and height above the passageway, the wildlife 

passageway will be open and well-lit. Passageway landscaping will be 

conducive to wildlife travel for a variety of species. 

Detailed engineering specifications are considered part of activities planned 

following project approval. EIA, Volume 5, Appendix 5-5, Section 4, page 7 

describes the approach that will be used. The design of the bridge spanning 

the Athabasca River, connecting Highway 63 with PRMA, will be high and 

long to provide for wildlife passage under the bridge on both the east and 

west banks (Figure 1). Long bridges allow for connectivity at the landscape 

level for a wide array of species, and are among the most effective mitigation 

measures for reducing road kill and for allowing for unhindered animal 

movement (Huijser et al. 2007). The cited figure depicts a conceptual model 

of the proposed bridge (see EIA, Volume 5, Appendix 5-5, Section 4, page 

8). This design is expected to meet the wildlife movement criteria likely to 

provide genetic connectivity (Mills and Allendorf 1996; Wang 2004) as 

outlined in the EIA, Volume 5, Section 7.1.2. 


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References 

Volume 2. Section 23.1 Page 23-181 SIR 481b 

Section 13.1 

Previous Request 481b Discuss features of the JEMA and PRMA 

development plan that might ensure maintenance of dispersal pathways from 

source populations. 


The retention of remnant corridors along rivers will contribute to the 

maintenance of dispersal pathways from source populations. As stated in the 

response to SIR 481a, the two wildlife movement corridors currently within the 

project area to maintain dispersal pathways are the Muskeg River and the 

Athabasca River. Regional developments along the Muskeg River, including the 

Jackpine Mine Expansion area, will create and maintain a 20-km-long remnant 

corridor about 400 m wide along the Muskeg River from the Athabasca River to 

Fort Hills. A 250 m buffer will be maintained along the Athabasca River. This 

buffer has also been committed to by Canadian Natural Resources Limited (see 

EIA, Volume 5, Section 7.1.2, page 7-7). 

These corridors are expected to function effectively as movement corridors 

because monitoring along the Muskeg River has demonstrated that many species 

use the riparian areas and upland areas adjacent to rivers, i.e., the Athabasca 

River, Muskeg River and Jackpine Creek. Wary, wide-ranging species, including 

Canada lynx, wolves, black bears, fishers and martens, were recorded within the 

corridors adjacent to developments. These preliminary monitoring results show 

that most wildlife species have been documented using habitat within the existing 

corridors along the Muskeg and Athabasca rivers. Therefore, these corridors are 

likely to act as dispersal pathways. These results suggest that genetic connectivity 

for most species of wildlife can be maintained within the regional landscape. 

That is, a minimum of one and up to 10 effective migrants per generation of all 

wildlife species are likely to pass through the wildlife corridors, and thus genetic 

connectivity is likely to be maintained (Mills and Allendorf 1996 and Wang 

2004). This information was presented in EIA, Volume 5, Section 7.1.2. 

Golder Associates Ltd. (Golder). 2007a. Terrestrial Environmental Setting 

Report for the Jackpine Mine Expansion and Pierre River Mine Project. 

Prepared for Shell Canada Limited. Calgary, AB. Submitted December 

2007. 

Golder. 2007b. Jackpine Mine – Phase 1 Wildlife Corridor Monitoring Program: 

Year 1 Annual Report 2006. Prepared for Shell Canada Limited. 

Calgary, AB. 

Huijser, M.P., A. Kociolek, P. McGowen, A. Hardy, A.P. Clevenger and R. 

Ament. 2007. Wildlife-vehicle collision and crossing mitigation 

measures: A toolbox for the Montana Department of Transportation. 

Final report. Prepared for the State of Montana, Department of 

Transportation FHWA/MT-07-002/8117-34. Prepared for Western 

Transportation Institute, Montana State University – Bozeman. 


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Section 13.1 

Mills, L.S. and F.W. Allendorf. 1996. The One-Migrant-per-Generation Rule in 


1518. 



Request 49b Regarding the Athabasca River setback and connectivity, Shell indicates that 

genetic connectivity will be maintained for wildlife populations. 

i. What species were considered in the determination that genetic connectivity 

will be maintained? 

ii. How did Shell determine that genetic connectivity would be maintained? 

Response 49b i. See the response to AENV SIR 49a for revisions to responses to previous 

SIRs 310a, 310b, 371b, 383a, 449d, and 481b. 

ii. See the response to AENV SIR 49a for revisions to responses to previous 

SIRs 310a, 310b, 371b, 383a, 449d, and 481b. 

Request 49c In response to the SIR asking what further assessments Shell will do to 

demonstrate 250 metres is an appropriate setback, Shell indicates it will monitor, 

and that the results of these monitoring programs will be used in adaptive 

management. 

i. What adaptive management strategies will Shell employ once the corridor 

has been reduced to 250 metres? 

Response 49c i. Once the corridor has been reduced to 250 m, if results of the ongoing 

wildlife corridor monitoring program indicate that wildlife are not using the 

corridor effectively, these results will be used to adaptively manage and help 

determine appropriate strategies to increase the functionality of the corridor 

for selected target wildlife species (e.g., wide-ranging mammals and/or 

species of concern as identified in the General Status of Alberta Wild Species 

[ASRD 2006]). Examples of such strategies could include, but are not limited 

to: 

• establishing food plants if monitoring suggests inadequate forage in the 

corridor 

• establishing cover and shelter elements (i.e., shrubs, coarse woody 

debris, brush and rock piles) if monitoring suggests inadequate cover or 

shelter in the corridor 


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Reference 


• implementing a weed control system if monitoring suggests weed 

competition with native food or cover vegetation is an issue in the 

corridor 

• building a sound attenuation wall if monitoring suggests sensory 

disturbance is an issue in the corridor 

Section 13.1 

ASRD (Alberta Sustainable Resource Development). 2006. The General Status 

of Alberta Wild Species 2005. Alberta Sustainable Resource 

Development. Fish and Wildlife Service. Edmonton, AB. 


The SIR references the April 1 to August 30 time period. Shell indicates that preclearing 

migratory bird nest sweeps will be conducted to mark any nests within 

areas to be cleared. Areas are walked by a wildlife biologist to search for nests 

(stick, mud, ground, or cavity). Breeding bird behaviours are also noted and 

recorded. 

50a How does this mitigate for the owl nesting period which can begin in early 

March. Discuss the efficacy of locating owl nests by ‘walk through’. 

Response 50a Mitigation measures will not be required for owl nests. Owl nest sweeps are 

typically not done during the owl nesting period in early March. The Migratory 

Birds Convention Act (MBCA) prohibits “the damaging, destroying, removing or 

disturbing of nests,” but birds of prey, such as owls, are not included within the 

terms of this act (Government of Canada 1994). Birds of prey are protected under 

the Alberta Wildlife Act (AWA) which states that a “person shall not wilfully 

molest, disturb or destroy a house, nest or den of prescribed wildlife... in 

prescribed areas and at prescribed times” (Government of Alberta 2000). Owls 

do not have specific provisions under the AWA and Alberta Sustainable 

Resources Development (ASRD) is developing guidelines to address habitat and 

protection needs of sensitive species (A. Hubbs 2009, pers. comm.), such as the 

barred owl and the great gray owl (ASRD 2006). 

Call playback surveys and pre-clearing bird nest sweeps could be conducted in 

potential habitat for listed owl species to identify and flag any nests within areas 

to be cleared. Detailed habitat and nest microhabitat information is known for 

barred owls and great gray owls. For these owls, which have nesting periods 

beginning before April 1, habitat and nest microhabitat information, as well as 

playback calls, aid in effectively locating nests during search efforts (Olsen et al. 

2006). 


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References 


Section 13.1 

ASRD. 2006. The General Status of Alberta Wild Species 2005. Alberta 

Sustainable Resource Development, Fish and Wildlife Service Division, 

Edmonton. Available online at: 

http://www.srd.alberta.ca/BioDiversityStewardship/SpeciesAtRisk/Gener 

alStatus/StatusOfAlbertaWildSpecies2005/Search.aspx. Accessed on 

October 23, 2009. 

Government of Alberta. 2000. Wildlife Act. R.S.A. 2000, c. W-10. Current to 

June 4, 2009. Sustainable Resource Development. 65 pp. 

Government of Canada. 1994. Migratory Birds Convention Act, 1994. S.C., 

1994, c. 22. Current to September 17, 2009. Published by the Minister of 

Justice. 54 pp. 

Hubbs, A. 2009. (Fish and Wildlife Management, Alberta Sustainable Resource 

Development, Rocky Mountain House). Personal communication with 

Amy Darling (Golder Associates Ltd.) on October 22, 2009. 

Olsen, B.T., S.J. Hannon and G.S. Court. 2006. Short-term response of breeding 

Barred Owls to forestry in a boreal mixedwood forest landscape. Avian 

Conservation and Ecology 1(3): 1. Available online at: http://www.aceeco.org/vol1/iss3/art1/. 

Accessed October 23, 2009. 

Request Volume 1, Question 380, Page 14-23. 

The SIR refers to analogues with the natural environment. The landforms 

planned, including terraces, for the closure landscape, do not appear to reflect 

landforms found in pre-development landscape. 

51a Discuss landscape design options that would more closely mimic the natural 

environment. 

Response 51a Terraces are designed into the construction of landforms created above natural 

topography (e.g., overburden dump areas, dyke walls) for a number of reasons, 

such as: 

• Access for vehicles during construction, reclamation and monitoring 

• Allowing access for progressive reclamation, as structures are designed in 

lifts from the outside to the inside, therefore making outside lifts complete 

and accessible for reclamation purposes before the entire structure is 

necessarily complete 


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Section 13.1 

• Stability of sloped areas, as terraced areas provide an opportunity to slow 

water flow downslope and therefore retain as much soil moisture as possible. 

Ecosites requiring moist soil conditions have therefore been located in 

terraced areas in the Closure, Conservation and Reclamation Plan for the 


Shell will design terraces to closely mimic natural landforms present in the 

region, although not necessarily those landforms in the pre-development 

landscape of the mine footprint. Natural landforms that are similar in structure 

include benches on escarpment wall areas and river floodplains. Structures will 

be designed to minimize ponding, concentrated runoff and erosion. 

Landform design principles are also being applied to the consideration of how to 

construct slopes on landforms above original topography without including 

terraced areas, although issues of overall footprint (greater area may be required 

to provide shallower slopes) and slope stability for drainage courses (e.g., path 

length for drainage channels from top of slope to perimeter drainage systems at 

the toe) are still in the design test process. 

Request Volume 2, SIR 7, Page 15-1 ; Volume 2, SIR 20b, Page 15-13. 

Shell states in the EIA The combined EIA for the Jackpine Mine Expansion and 

the new Pierre River mine concluded that there would be no unacceptable 

environmental or socio-economic effects from the projects provided that the 

proposed mitigation and monitoring are undertaken. The original SIRs were 

asking how Shell had determined ‘acceptability’. The answer provided a 

discussion of consequence ratings. 

52a Provide the criteria Shell used to determine whether an environmental or social 

consequence rating was ‘acceptable’ or ‘unacceptable’. 

Response 52a Shell worked with its EIA consultants, and is engaged in ongoing consultation 

with its stakeholders, to understand the potential environmental and socioeconomic 

effects of the proposed project. In an iterative manner, the project 

design evolved to minimize potential effects. The result is a project where the 

majority of the impacts are of primarily low or negligible consequence, and a 

limited number of impacts of higher consequence. The conclusions and 

predictions contained in the EIA are based on environmental consequence 

ratings, which are based on the criteria outlined by the Canadian Environmental 

Assessment Act and include direction, magnitude, geographic extent, duration, 

reversibility and frequency. All of these ratings are described in the EIA, 

Volumes 3, 4 and 5. In addition, as part of the May 2009 Pierre River Mine, 

Supplemental Information, Volume 2, Appendix B, Shell provided an 

Environmental Significance Assessment. 


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Section 13.1 

In addition to the detailed environmental consequence ratings outlined above, 

Shell’s Sustainable Development policy also guides Shell’s plans when assessing 

large projects such as this. This is particularly important in the case of large-scale 

mining projects, which necessarily involve some impacts on the environment 

during construction and operations. This project has been developed to date with 

a view toward reducing its environmental impacts, where possible, managing 

natural resources efficiently, generating robust profitability, and the clear need to 

produce social and economic benefits on a local, provincial and federal level. 

Shell’s view is that the predicted environmental impacts of the Pierre River Mine 

Project and the Jackpine Mine Expansion Project are acceptable, when 

considered in light of these sustainable development principles and Shell’s 

obligation to efficiently produce the oil sands resource for the benefit of all 

Albertans. 

Shell will present evidence regarding the acceptability of environmental impacts. 

However, it is understood that the overall public interest determination is the 

responsibility of the appropriate provincial and federal regulatory agencies, in 

accordance with their respective legislative mandates. 

Request 52b Discuss the role of the public interest decision in determining ‘acceptability’. 

Response 52b For the requested information, see the response to ERCB SIR 52a. 



The SIR asked whether the current capacity of the diluent and diluted bitumen 

lines to Scotford was sufficient to address the needs of both the Pierre River Mine 

and the Jackpine Mine Expansion. The answer given was Yes, the capacity… is 

currently being expanded. This answer is unclear. 

53a Are new pipelines being installed? 

Response 53a The capacity of the diluent and diluted bitumen infrastructure to Scotford is being 

expanded in conjunction with the Muskeg River Mine Expansion. Once 

completed, the pipelines will have sufficient capacity to support the diluent and 

diluted bitumen volumes for future mining expansions, including the Pierre River 

Mine and the Jackpine Mine expansion. As these mining expansions progress, 

pumps will be added at the pump stations to support the increased volumes being 

shipped. 


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Section 13.1 

Request 53b Is additional right-of-way and consequent disturbance required to accommodate 

the additional capacity being developed, or is the capacity expansion a result of 

engineering optimization of the existing pipelines? 

Response 53b The Muskeg River Mine Expansion pipeline capacity will be sufficient to handle 

the additional diluent and diluted bitumen volumes between Lease 13 and 

Scotford. No additional disturbance or rights-of-way will be required as the only 

modifications expected would be the addition of pumping capacity. 



In response to the question of what is meant by a mining setback, Shell states that 

Mining set-back refers to the designation of a corridor between the expected 

disturbance footprint and a natural feature, in this case the Athabasca River, 

whereby no disturbance, including clearing will occur. The raw water intake 

and pipeline occur within the 250 m setback that Shell has committed to, which 

appears to contradict Shell’s statement that no disturbance, including clearing 

will occur within the 250 m setback. 

54a What will the effective width of the Athabasca River corridor be at the sites of the 

raw water intake and pipeline? 

Response 54a The raw water intake and buried pipeline are not predicted to alter the effective 

width of the Athabasca River corridor, nor is the associated clearing predicted to 

act as a barrier to wildlife movement. However, the intake building and clearing 

at the river’s edge will likely have a filter effect on wildlife by reducing the rates 

of wildlife movement through the corridor at the location of the disturbance. A 

sufficient number of individuals are expected to cross the clearing (i.e., a 

minimum of one effective migrant per generation), such that genetic connectivity 

is predicted to be maintained (Mills and Allendorf 1996; Wang 2004). 

References 



1518. 




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Section 13.1 

Request 54b Describe the mitigation measures that Shell will implement along the raw water 

intake and pipeline to ensure that the effective corridor width is not reduced at 

these sites. 

Response 54b The raw water intake and buried pipeline are not predicted to reduce the effective 

width of the Athabasca River corridor and the resulting clearing is not expected 

to act as a barrier to wildlife movement. Rather, the clearing within the corridor 

will likely have a filter effect on wildlife such that rates of movement through the 

corridor at the location of the disturbance are reduced. To lessen the effect on the 

rates of movement across the clearing, Shell will undertake practical measures to 

minimize the clearing width and disturbance area of the raw water intake and 

buried pipeline footprint in compliance with regulatory guidelines. The footprint 

of the raw water intake and buried pipeline will be a clearing potentially 80 to 

230 m wide. The clearing will be a combination of the water intake building at 

the river’s edge which initially might be 5 ha because of space needs for 

construction laydown, and the pipeline right-of-way (30 to 50 m wide). Exact 

dimensions and location of the areas to be developed will be developed during 

future detailed design work. 

References 

The greatest disruption to wildlife movement along the Athabasca River corridor 

will be temporary during construction of the water intake and pipeline, which 

typically takes 3 years for similar projects. However, based on wildlife corridor 

monitoring conducted in 2006 through 2008 along the Athabasca River (Golder 

2009), genetic connectivity is predicted to be maintained during the construction 

period (i.e., a minimum of one effective migrant per generation) (Mills and 

Allendorf 1996, Wang 2004). The disturbance will be minimized following 

construction through immediate re-vegetation of the right-of-way and 

construction laydown areas. 

Golder. 2009. Shell Jackpine Mine-Phase 1 Wildlife Corridor Monitoring Year 3 

Annual Report 2008. Prepared for Shell Canada Ltd. Fort McMurray, 

AB. 



1518. 



Request 54c Provide a conceptual map indicating the potential movement paths that wildlife 

are likely to take when travelling past the raw water intake and pipeline. 

Response 54c As the clearing created for the raw water intake and buried pipeline (potentially 

80 to 230 m wide) is not predicted to alter the movement paths of wildlife along 

the Athabasca River corridor, a description of wildlife movement has been 


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References 


Section 13.1 

provided rather than a conceptual map. That is, to travel from point A in the 

corridor on one side of the clearing to point B on the other side of the clearing, 

wildlife are likely to simply cross the clearing. Moose, white-tailed deer, coyote, 

Canada lynx, wolf and black bear readily cross pipeline rights-of-way, especially 

if the pipeline is not a physical obstruction (Dunne and Quinn 2009). Given that 

the pipeline will be buried, it will not act as a physical obstruction to wildlife. 

Some wildlife might stay in the corridor on the side of point A rather than 

crossing to point B, creating a filter effect. Nonetheless, genetic connectivity is 

predicted to be maintained (Mills and Allendorf 1996; Wang 2004). Connectivity 

across the opening is predicted to increase as the right-of-way and construction 

laydown areas are reclaimed and become re-vegetated following construction. 

Dunne, B.M. and M.S. Quinn. 2009. Effectiveness of above-ground pipeline 

mitigation for moose (Alces alces) and other large mammals. Biological 

Conservation 142: 332 –343. 



1518. 




55a Are there options to move the plant site further away from the Athabasca River 

and what would these options entail? 

Response 55a Shell selected the plant site to maximize the footprint available for facilities’ 

layout within the constraints of the lease boundary, mine pit, the Athabasca River 

setbacks and to maximize resource recovery. All other options which involved 

moving the plant site off Lease 9 were rejected because of the incremental 

terrestrial disturbance and the increased haul distances, as described in the May 

2009 Pierre River Mine, Supplemental Information, Volume 1, Section 13.2, 

page 13-8. 


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Request Volume 2, SIR 32 a-b, Page 15-26. 

Section 13.1 

In the original SIR, the reference to RIWG (now OSDG) came from Volume 2, 

Page 16-1 and 2 under Cooperation Initiatives which states Shell’s regional 

cooperation has led to a number of specific actions and initiatives, including: … 

planning utility and access corridors … locating regional access roads and 

corridors. Through the Regional Issues Working Group (RIWG) Transportation 

Committee, industry and government are evaluating options for permanent 

access and utility corridors to support oil sands development. 

56a How did the work of the RIWG (now OSDG) inform the infrastructure associated 

with the proposed Pierre River Mine including the location of the water intake 

and pipeline, transmission, natural gas, bitumen and diluent corridors, access 

roads and bridge locations? 

Response 56a The Regional Issues Working Group, now the Oil Sands Development Group 

(OSDG), provides a forum for general discussion of infrastructure location plans, 

even in the absence of formal cooperation agreements between oil sands 

developers. In the case of the Pierre River Mine, Shell provided updates to the 

OSDG on infrastructure requirements that resulted in a working group being 

struck to optimize the location and permanent access points for the proposed 

bridge across the Athabasca River. As a result of the working group, Shell now 

has an agreement with PetroCanada to design a permanent access corridor 

associated with the bridge. 


The OSDG also provides a forum for stakeholders to discuss potential locations 

of common infrastructure corridors. Shell’s participation in the group has already 

identified opportunities for common use. For example, the exchange of planning 

information with Imperial Oil Resources Ventures Limited in relation to 

upgrades to the Fort Chipewyan Road will provide common access to 

infrastructure located in this area. Further discussion related to the location of 

pipelines, utility corridors and other access roads is underway within the OSDG. 


In the rationale for mining through the Pierre River, Shell indicates there is a 

significant bitumen resource below the Pierre River and that Shell has an 

obligation to its shareholders and the province to recover this resource. Further, 

Shell indicates that the Pierre River mine strikes a balance between resource 

recovery and impacts on the Pierre River upstream of Lease 9, as well as 

mitigating flow impacts on the Athabasca River. 


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Section 13.1 

57a With respect to the assertion that the Pierre River mine strikes a balance, how 

was this determined? 

Response 57a For information regarding the manner in which Shell makes determinations about 

how the Pierre River Mine strikes a balance between resource recovery and 

potential environmental impacts, see the response to AENV SIR 52. As stated in 

that response, Shell has prepared an EIA that makes environmental impact 

predictions based on environmental consequence ratings. These consequence 

ratings are based on the criteria outlined by the Canadian Environmental 

Assessment Act and include direction, magnitude, geographic extent, duration, 

reversibility and frequency. All of these ratings are described in the EIA, 

Volumes 3, 4 and 5. In addition, as part of the May 2009 Pierre River Mine, 

Supplemental Information, Volume 2, Appendix B, Shell provided an 

Environmental Significance Assessment. 

In addition to the detailed environmental consequence ratings outlined 

previously, Shell’s Sustainable Development policy also guides Shell’s plans 

when assessing large projects such as this. This is particularly important in the 

case of large-scale mining projects, which necessarily involve some impacts on 

the environment during construction and operations. This project has been 

developed with a view toward reducing its environmental impacts, where 

possible, the efficient management of natural resources, the generation of 

profitability, and the clear need to provide social and economic benefits on a 

local, provincial and federal level. Shell’s view is that the predicted 

environmental impacts of the Pierre River Mine and Jackpine Mine Expansion 

projects are acceptable, when considered in light of these sustainable 

development principles and Shell’s obligation to efficiently produce the oil sands 

resource for the benefit of all Albertans. 

Although the portion of the Pierre River located in the operational footprint of 

the Pierre River Mine will be affected during construction and operation, these 

effects will be mitigated by implementing Shell’s operational and closure 

drainage plans. Accordingly, Shell considered the loss of the Pierre River during 

construction and operation in conjunction with the implementation of operational 

and closure drainage plans, and determined that the Pierre River Mine, as applied 

for, achieved a balance between impacts and resource recovery. 

Request 57b What are the criteria Shell used to assess whether this was a balanced decision? 


Request 57c How was the loss of the Pierre River on the lease area accounted for in this 

decision? 

Response 57c See the response to AENV SIR 57a. 


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Section 13.1 

Shell indicates that it has not developed a contingency plan to reflect a 400 m 

setback from the Athabasca River, stating that Shell believes that the 250 m 

setback … is sufficient to allow the movement of wildlife along the Athabasca 

River Corridor and ensures genetic connectivity. Many of Shell’s responses to 

questions regarding the maintenance of movement corridors focus on genetic 

connectivity, suggesting that genetic connectivity is the primary concern with 

respect to the maintenance of adequate buffers along the Athabasca River and its 

tributaries. 

58a Provide a discussion of other benefits and outcomes of maintaining an adequate 

buffer along these watercourses. Focus on wildlife, fisheries, reclamation and 

human health and safety perspectives. 

Response 58a Maintaining a riparian buffer zone adjacent to watercourses provides a variety of 

benefits in addition to the predicted maintenance of genetic connectivity. 

From an aquatics ecosystems perspective, a riparian buffer zone adjacent to 

watercourses offers the following benefits, as documented in scientific literature 

(Wenger 1999, Parkyn 2004): 

• protecting the physical, chemical and biological integrity of the watercourse 

• preventing pollutants from entering the watercourse 

• reducing erosion by protecting and stabilizing banks and controlling 

sedimentation 

• providing flood control and base flow maintenance 

• contributing and controlling organic inputs and large woody debris 

• providing tree canopy to shade streams and promote desirable aquatic habitat 

These benefits also apply to human health and safety, by maintaining water 

quality and by stabilizing watercourse banks and providing flood control. 

The minimum width of a riparian buffer for protecting aquatic ecosystems can 

vary depending on the vegetation type, slope, and other factors. Recommended 

buffer widths for protecting aquatic ecosystems from different jurisdictions in 

Canada and the United States range between 7 m and 100 m (Mayer et al. 2006, 

Lee et al. 2004). A 250 m buffer width for the Athabasca River is considered 

adequate to protect aquatic function. 

From a wildlife perspective, the richness and complexity of riparian habitats 

often make these areas high in wildlife diversity and abundance (Anthony 1996, 


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References 

Section 13.1 

Olsen et al. 2007). The preservation and maintenance of riparian areas is 

important for the conservation of wildlife biodiversity. The maintenance of 

riparian buffers will provide corridors of mature forest for in-migration of 

wildlife onto the reclaimed lands from surrounding habitat. For this reason, a 

minimum 250 m setback from the Athabasca River is an integral part of Shell’s 

mine development plans. 

The proposed riparian corridor approaches a minimum 250 m width in an area 

less than 8 km long, and in general is much wider over the remainder of its length 

(see the responses to AENV SIR 69a and AENV SIR 70a). The purpose of a 

corridor is not to satisfy all life history requirements for all wildlife species that 

may be using it (Rosenberg et al. 1997). Rather, the purpose of a corridor is to 

maintain landscape connectivity for species (Beier and Noss 1998). Landscape 

connectivity helps maintain population viability by promoting gene flow between 

patches and increasing the effective size of populations (Noss and Harris 1987, 

Beier and Noss 1998, Olsen et al. 2007). Maintaining resident populations within 

a corridor is only necessary when the corridor length is long relative to the 

dispersal abilities of the species in question (Beier and Noss 1998). The 8 km 

length of the proposed corridor where the width approaches 250 m (minimum) is 

short relative to the dispersal capabilities of wide-ranging species (Sutherland et 

al. 2000). In the boreal mixedwood ecoregion of north-central Alberta, Hannon et 

al. (2002) found that 200 m wide riparian corridors were sufficient for 

maintaining natural small mammal, amphibian and bird communities. Therefore, 

a 250 m wide corridor is likely to be sufficient as both a fully functioning reserve 

for small mammal, amphibian and bird communities and a movement corridor 

for wide ranging species. Neither a 250 m or 400 m wide corridor would hold the 

territories of larger wide-ranging wildlife species, but as long as a corridor is not 

long relative to the dispersal abilities of a species, it does not need to be wide 

enough to satisfy all life history requirements for that species (Beier and Noss 

1998). 

From a reclamation perspective, the primary benefit of maintaining an adequate 

riparian buffer along watercourses is to conserve a diverse native seed source for 

natural ingress of vegetation (by seed or rooting) to adjacent reclamation areas. 

Also, the maintenance of a buffer will aid in retaining soil moisture conditions 

that will support the success of adjacent reclamation areas. Closure and 

reclamation plans typically integrate reclaimed ecosites into riparian buffers and 

adjacent undisturbed areas to ensure that there is landscape continuity around 

watercourses, and to optimize the benefit of the ingress of natural vegetation. 

Anthony, R.G., G.A. Green, E.D. Forsman, and S.K. Nelson. 1996. Avian 

abundance in riparian zones of three forest types in the Cascade 

Mountains, Oregon. Wilson Bulletin 108(2): 280-291. 

Beier, P. and R.F. Noss. 1998. Do habitat corridors provide connectivity? 

Conservation Biology 12(6): 1241-1252. 


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Section 13.1 

Lee, P, C. Smyth and S. Boutin. 2004. Quantitative review of riparian buffer 

width guidelines from Canada and the United States. Journal of 

Environmental Management 70: 165-180. 

Mayer, P.M., S.K. Reynolds, M.D. McCutchen, and T.J. Canfield. Riparian 

buffer width, vegetative cover, and nitrogen removal effectiveness: A 

review of current science and regulations. EPA/600/R-05/118. 

Cincinnati, OH, U.S. Environmental Protection Agency, 2006. 

Noss, R.F. and L.D. Harris. 1987. Nodes, networks, and MUMs: preserving 

diversity at all scales. Environmental Management 10(3): 299-309. 

Olson, D.H., P.D. Anderson, C.A. Frissell, H.H. Welsh Jr. and D.F. Bradford. 

2007. Biodiversity management approaches for stream-riparian areas: 

perspectives for Pacific Northwest headwater forests, microclimates, and 

amphibians. Forest Ecology and Management 246: 81-107. 

Parkyn, S. 2004. Review of riparian zone effectiveness. Prepared for Ministry of 

Agriculture and Forestry, MAF Technical Paper No: 2004/05. 

Wellington, New Zealand. September 2004. 

Wenger, S. 1999. A review of the scientific literature on riparian buffer width, 

extent and vegetation. Institute of Ecology, University of Georgia. 

Revised Version, March 5, 1999. 

Request Volume 2, SIR 453a, Page 23-112 ; Volume 2, SIR 469b, Page 23-153. 

Terms of Reference section 5.6.4 required current field data for all species of 

concern as a basis for understanding the effects of the project on local and 

regional populations. However, Shell indicates in SIR Response 469 that only 

generic sampling protocols were used and that surveys were not intended to 

provide detailed abundance estimates for all listed species. As a result Shell 

cannot provide estimates of the proportion of existing populations that will be 

displaced by the Pierre River project (Response 469b). However, Shell 

acknowledges the importance of this information in identifying a willingness to 

conduct yellow rail surveys in 2009 using a standardized protocol to better 

understand the distribution, abundance and habitat use of this species in the 

LSAs (Response 453a). Shell indicates an intention to provide this information 

on yellow rail (Response 453a) but similar targeted surveys and assessments of 

habitat availability are required for all species to meet Canadian Environmental 

Assessment Act and SARA information requirements. 

59a Based on available survey data, provide a population estimate (with confidence 

intervals) for each species currently listed under Schedule 1 of SARA and current 

COSEWIC-listed species known to occur in the LSA. If such a population 

estimate is not available for these species (as Shell states is the case for Yellow 


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rail, Olive-sided flycatcher and Rusty blackbird), indicate when Shell will 

conduct the surveys and prepare the population estimates. 

Section 13.1 

Response 59a Population estimates with confidence intervals for each species currently listed 

under Schedule 1 of the Species at Risk Act (SARA) and current Committee on 

the Status of Endangered Wildlife in Canada (COSEWIC)-listed species known 

to occur in the local study area (LSA) cannot be calculated based on the surveys 

conducted to date and the low numbers detected. Additional surveys to obtain 

population estimates with confidence intervals within the LSA are beyond the 

scope of an environmental impact assessment. 

Shell has met the requirements of the Canadian Environmental Assessment Act 

(CEAA), the SARA and the Terms of Reference (TOR) in assessing the effects 

of the project on listed species through the assessment of wildlife indicator 

species and their habitat. Neither the CEAA nor the SARA implicitly or 

explicitly require that species-specific population surveys be conducted. Rather, 

the CEAA requires that an assessment of the environmental effects of a project 

include any change that the project may have on a “listed wildlife species, its 

critical habitat or the residences of individuals of that species”. SARA requires 

that, when conducting an environmental assessment, any adverse effects of the 

project on the listed wildlife species and its critical habitat must be identified, 

and, if the project is carried out, must ensure that measures are taken to avoid or 

lessen those effects and to monitor them. Shell has done this. 

The TOR require an impact assessment for wildlife, including endangered 

species and species at risk, as well as a discussion of how populations may be 

impacted by the project, which Shell has done. As part of this impact assessment, 

the TOR specifically asks for a description of existing wildlife resources, and as 

part of that description, Shell is required to discuss current field data. In EIA, 

Volume 5, Section 7.3.4, Shell has provided a discussion of current field data 

through the use of indicator species. Nothing in the TOR expressly precludes the 

use of wildlife indicator species and, in fact, the use of wildlife indicators in 

assessing impacts on wildlife, including endangered species and species at risk, is 

a recognized protocol, and was recently considered by the Joint Review Panel 

reviewing the Mackenzie Gas Project application. The Panel found that the use of 

indicator or surrogate species for the assessment of other species, including 

SARA-listed species, was an acceptable method of impact assessment and 

provided sufficient evidence to enable the Panel to review the potential impacts. 

Shell has conducted the appropriate studies for the indicator species in 

compliance with the TOR and that information is appropriate for assessing the 

impacts on listed species. Accordingly, the studies conducted for the 

environmental assessment and the information contained in the EIA comply with 

both the TOR and the federal statutes. 

However, although Shell’s EIA provides sufficient data to assess the potential 

impacts to all relevant species, including SARA-listed species, Shell has 

proposed a wildlife monitoring program for the pre-development, operation and 

reclamation phases of the project, which will be developed in consultation with 

ASRD as described in EIA, Volume 5, Appendix 5-6, Section 6. During the 


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Section 13.1 

finalization of the wildlife monitoring program with ASRD after project 

approvals have been issued, Shell will consider monitoring for the presence of 

listed species as part of the pre-development wildlife monitoring program. 

Request 59b Using information from surveys, provide ecosite associations of species listed on 

Schedule 1 of SARA and current COSEWIC-listed species. 

i. Quantify the total area and proportion of area of each ecosite phase used by 

species listed on Schedule 1 of SARA and current COSEWIC-listed species 

that will be destroyed over the lifetime of the project. 

ii. Identify the reclamation targets for each ecosite phase currently used by 

species listed on Schedule 1 of SARA and current COSEWIC-listed species so 

that the base-case habitat availability can be compared to availability in the 

reclaimed landscape. 

Response 59b i. The total area and proportion of area of each ecosite phase and wetlands 

types in the local study areas (LSAs), including those used by species listed 

on Schedule 1 of the SARA and COSEWIC-listed species that will be 

removed as part of the project, are presented in EIA, Volume 5, Section 

7.5.2. The EIA acknowledges that, during construction and operations, direct 

and indirect habitat loss will be of a high magnitude for all key indicator 

resources (KIRs) (EIA, Volume 5, Section 7.5.3.3). However, environmental 

consequences of the project are based on the change in habitat availability 

between Base Case and Closure, after reclamation. As stated in the EIA, the 

key mitigation to minimize residual effects is reclamation (EIA, Volume 5, 

Section 7.1.3). 

Species that are on Schedule 1 of SARA and/or are listed by COSEWIC 

occur in insufficient numbers to detect any statistically significant changes 

because of the project. Therefore, baseline efforts and the subsequent EIA 

did not focus on these species. Beanlands and Duinker (1983) recommended 

that assessments concentrate on an ecological perspective rather than trying 

to assess all species; consequently, KIRs are used to provide focus for the 

assessment (EIA, Volume 1, Section 1.3.5, Table 1.3-2). The Joint Review 

Panel for the Mackenzie Gas Project (Joint Review Panel, 2010) in Sections 

5.2 and 10.3 noted that “the use of indicator species is, in principle, an 

acceptable method of impact assessment” (Section 5.10.2, page 274), and is 

not inconsistent with SARA and COSEWIC requirements. Beanlands and 

Duinker (1983) also recommended that an environmental assessment should 

have a focused study effort based on a compromise between the information 

needs of the decision-makers and what a sound, short-term applied science 

program can provide. 

To assess the impacts of the project on species listed on Schedule 1 of SARA 

and current COSEWIC-listed species, the habitat associations of these 

wildlife species observed or potentially occurring within the Jackpine Mine 

Expansion and Pierre Rive Mine local study areas (LSAs) were compiled in 


CR029


Western (Boreal) Toad 

Wood Bison 

Woodland Caribou 

Section 13.1 

order to quantify the change in total area and proportion of area of each 

ecosite phase or wetlands type between Base Case and Closure (see Table 

AENV 59-1). Habitat associations of federally-listed species were primarily 

derived from direct observations from baseline surveys conducted for the 

project from 2005 to 2007 (Wildlife Environmental Setting Report, 

Volume 5, Table 5.2-1) or from historic wildlife survey results in the Oil 

Sands Region. These associations are equated with ecosite phases and 

wetlands types in the LSAs as defined by vegetation mapping produced for 

the Terrestrial Vegetation, Wetlands and Forest Resources impact assessment 

(Volume 5, Section 7). 

Three boreal toads were detected during amphibian surveys conducted within 

the LSAs (Terrestrial Environmental Setting Report, Section 5.5.5.1). These 

observations occurred in wooded fen (FTNN) and wooded bog (BTNN) 

wetlands types. Additionally, historical data from the Oil Sands Region 

indicate boreal toads have been detected within a variety of habitat types 

(e.g., shrubby fen [FONS], marsh [MONG], lichen jack pine [a1], Labrador 

tea-subhygric black spruce-jack pine [g1]; Golder 2000; Canadian Natural 

2006; Rio Alto 2002; Table AENV 59-1). Using information from project 

surveys and historical surveys, the net gain of habitat types from Base Case 

to Closure for western toad is approximately 120 ha (less than 1% of the 

LSAs, as shown in Table AENV 59-1). 

Two incidental observations of wood bison were recorded within the Pierre 

Rive Mine LSA. These observations occurred in lichen jackpine (a1) and 

Labrador tea-mesic jack pine–black spruce (c1) ecosite phases (Terrestrial 

Environmental Setting Report, Appendix T). Historical survey data on other 

habitat associations for wood bison were not available for the Oil Sands 

Region. Using information from project surveys, the net gain of habitat types 

from Base Case to Closure for wood bison is approximately 4,780 ha (9% of 

the LSAs; see Table AENV 59-1). 

A single woodland caribou track was recorded during winter tracking 

surveys in graminoid fen (FONG) on the Jackpine Mine Expansion LSA 

(Terrestrial Environmental Setting Report, Section 5.3.1.4). Historical survey 

observations for caribou in the Oil Sands Region occur across a wide variety 

of upland and wetland habitat types (e.g., wooded fen [FTNN], marsh 

[MONG], shrubby fen [FONS], low-bush cranberry aspen-white spruce [d2], 

Labrador tea-mesic jack pine-black spruce [c1], Labrador tea-subhygric 

black spruce-jack pine [g1], and lichen jack pine [a1]) (MEG 2005; Canadian 

Natural 2006; Golder 2003). Using information from project surveys and 

historical surveys, the net gain of habitat types from Base Case to Closure for 

woodland caribou is approximately 2,795 ha (6% of the LSAs; see Table 

AENV 59-1). 


CR029


Common Nighthawk 

Rusty Blackbird 

Short-eared Owl 

Whooping Crane 

Section 13.1 

Eight common nighthawks were observed incidentally within the LSAs 

during field surveys. These observations occurred in lichen jack pine (a1), 

blueberry jack pine-aspen (b1), disturbance (DIS), and cutblock (CC) 

(Terrestrial Environmental Setting Report, Appendix T). Historical data from 

the Oil Sands Region suggest common nighthawks are associated with open 

or semi-open habitats in a variety of areas including forest clearings, burned 

areas, and grassy meadows (Golder 2004; Semenchuk 1992). These habitats 

closely equate to meadows (Me) and disturbed habitat areas such as 

cutblocks (CC) and burned upland (BUu). Using information from project 

surveys and historical surveys, the net gain of habitat types from Base Case 

to Closure for common nighthawk is approximately 1,745 ha (3% of the 

LSAs; see Table AENV 59-1). 

One rusty blackbird was recorded in graminoid fen (FONG) during surveys 

conducted for the project (Terrestrial Environmental Setting Report, Section 

5.4.4.2, Table 5.4-13). Historical data on other habitat associations for rusty 

blackbirds were not available for the Oil Sands Region. Using information 

from project surveys, the net loss of habitat types from Base Case to Closure 

for rusty blackbird is approximately 1,397 ha (3% of the LSAs; see Table 

AENV 59-1). 

Short-eared owls were not observed during field surveys conducted for the 

project. Historical data from the Oil Sands Region and relevant literature 

indicate that short-eared owls are associated with open habitats, including 

grassy or brushy meadows, marshland and previously forested areas that 

have been cleared (Semenchuk 1992; Canadian Natural 2000; Wiggins 

2006). In northern Alberta, these habitats equate to graminoid fen (FONG), 

marsh (MONG), shrubby swamps (SONS), meadows (Me) and cutblocks 

(CC). Using information from historical surveys and relevant literature, the 

net loss of habitat types from Base Case to Closure for short-eared owl is 

approximately 5,100 ha (10% of the LSAs; see Table AENV 59-1). 

Whooping cranes were not observed during field surveys conducted for the 

project. Whooping cranes are only present in the LSAs during spring and fall 

migration. There have been five confirmed and two probable historical 

incidental sightings of whooping cranes in the Oil Sands Region. The most 

recent sighting of a pair occurred in 2004 near the Suncor Firebag Project but 

habitat information was unavailable (Suncor 2008). Current nesting areas for 

whooping cranes within Wood Buffalo National Park consist of poorly 

drained, shallow-water wetlands separated by narrow ridges of white spruce, 

black spruce and willows (Salix spp.) (Lewis 1995). Other literature suggests 

whooping cranes are associated with large, relatively open, marshy areas 

(Semenchuk 1992). In northern Alberta, these habitats equate to marsh 


CR029


Peregrine Falcon 

Northern Leopard Frog 

Wolverine 

Section 13.1 

(MONG) and shallow, open water (WONN) wetlands types. Using 

information from relevant literature, the net loss of habitat types from Base 

Case to Closure for whooping crane is approximately 681 ha (1% of the 

LSAs; see Table AENV 59-1). 

Peregrine falcons were not observed during field surveys conducted for the 

project and historical habitat association data from the Oil Sands Region 

were not available. Peregrine falcons are only present in the LSAs during 

spring and fall migration. Relevant literature suggests that peregrine falcons 

are associated with habitats that include cliffs near water for nesting and 

open fields, swamps and marshes for hunting (Semenchuk 1992; White et al. 

2002). It is difficult to equate ecosite phases with habitat descriptions that 

include geographical features; however, based on vegetation similarities, 

these habitats roughly equate to marsh (MONG), shrubby swamp (SONS) 

and shallow open water (WONN) wetlands types and disturbed areas 

including cutblocks (CC) and general disturbance (DIS). Using information 

from relevant literature, the net loss of habitat types from Base Case to 

Closure for peregrine falcon is approximately 3,511 ha (7% of the LSAs; see 

Table AENV 59-1). 

Northern leopard frogs were not detected during surveys conducted for the 

project and historical data from the Oil Sands Region were not available. 

Typically, northern leopard frogs are associated with permanent ponds that 

contain emergent vegetation (e.g., bulrushes, cattails) and areas of shallow, 

open water such as lakes and ponds (Russell and Bauer 2000). In northern 

Alberta, northern leopard frogs can occur within most wetland types. The net 

loss of all wetland types from Base Case to Closure is approximately 13,803 

ha (27% of the LSAs; see Table AENV 59-1). 

Wolverines were photographed on two occasions in the northern portion of 

the Pierre River Mine LSA and wolverine tracks were recorded five times in 

the Jackpine Mine Expansion LSA (Terrestrial Environmental Setting 

Report, Section 5.3.5.2). These observations occurred in Labrador tea–mesic 

jack pine–black spruce (c1), along the Muskeg River and along smaller 

drainages flowing into the Athabasca River. Historical field data from the Oil 

Sands Region show evidence of wolverine occurring in Labrador tea / 

horsetail white spruce–black spruce (h1), dogwood white spruce (e3) and 

wooded bog (BTNN) (MEG 2008; Suncor 2005; Suncor 2007). Using 

information from project surveys and historical surveys, the net gain of 

habitat types from Base Case to Closure for wolverine is approximately 

3,259 ha (6% of the LSAs; see Table AENV 59-1). 


CR029


References 

Section 13.1 

Beanlands, G. E., and P. N. Duinker. 1983. An ecological framework for 

environmental impact assessment in Canada. Institute for Resource and 

Environmental Studies, Dalhousie University, Halifax, Nova Scotia, and 

Federal Environmental Assessment Review Office, Hull, Quebec. 132 

pp. 

Canadian Natural (Canadian Natural Resources Ltd.). 2000. Primrose and Wolf 

Lake (PAW) In-Situ Oil Sands Expansion Project. Volumes I to VI. 

October 2000. Prepared by Golder Associates Ltd. Calgary, AB. 

Canadian Natural. 2006. Primrose In-Situ Oil Sands Project. Primrose East 

Expansion Application for Approval. Volumes 1 to 6. Submitted to 

Alberta Energy and Utilities Board and Alberta Environment. Prepared 

by Golder Associates Ltd. Calgary, AB. Submitted January 2006. 

Golder. 2000. Christina Lake Thermal Project Wildlife, Wetlands and Rare Plant 

Assessment Update 2000. Prepared for PanCanadian Petroleum Ltd. 

Calgary, AB. 

Golder. 2003. 2003 Winter Aerial Caribou Survey for the Petro-Canada Meadow 

Creek Project. Prepared for Petro-Canada. Prepared by Golder 

Associates Ltd. March 2003. 25 pp. + Appendices. 

Golder. 2004. 2004 Suncor Energy Wildlife Monitoring Program and Wildlife 

Assessment Update Year 5. Prepared for Suncor Energy Inc., Fort 

McMurray, AB. Prepared by Golder Associates Ltd. 

Joint Review Panel for the Mackenzie Gas Project. 2010. Foundation for a 

Sustainable Northern Future: Report of the Joint Review Panel for the 

Mackenzie Gas Project. Published under the Authority of the Minister of 

Environment, Government of Canada, December 2009. 

Lewis, James C. 1995. Whooping Crane (Grus americana), The Birds of North 

America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; 

Retrieved from the Birds of North America Online: 

http://bna.birds.cornell.edu/bna/species/153. 

MEG (MEG Energy Corporation). 2005. Application for Approval of the 

Christina Lake Regional Project. Volumes 1 to 5. Submitted to Alberta 

Environment and Alberta Energy and Utilities Board. Calgary, AB. 

Submitted August 2005. 

MEG. 2008. Christina Lake Regional Project Wildlife Environmental Setting 

Report- Phase 3. Prepared for MEG Energy Corp., Calgary, AB. Morse, 

D.H. and A.F. Poole. 2005. Common Nighthawk (Chordeiles minor). 

The Birds of North America Online. A. Poole (Ed.). Cornell Laboratory 

of Ornithology. Ithaca, NY. 


CR029


Section 13.1 

Rio Alto (Rio Alto Exploration Ltd.). 2002. Kirby Project Application for 

Approval to Alberta Energy and Utilities Board and to Alberta 

Environment. Volumes 1,2,3,5,6 and 7. Prepared by Golder Associates 

Ltd. Calgary, AB. 

Russell, A. P. and A. M. Bauer 2000. The Amphibians and Reptiles of Alberta. A 

Field Guide and Primer of Boreal Herpetology, Second Edition. 

University of Calgary Press. Calgary, AB. 292 pp. 

Semenchuk, G. P. 1992. The Atlas of Breeding Birds of Alberta. Federation of 

Alberta Naturalists. Edmonton, AB. 393 pp. 

Suncor (Suncor Energy Inc.). 2005. Voyageur Project Application and 

Environmental Impact Assessment. Submitted to Alberta Energy and 

Utilities Board and Alberta Environment. Volumes 1A, 1B, 2, 3, 4, 5 and 

6. Fort McMurray, AB. Submitted March 2005. 

Suncor. 2007. Wildlife Baseline Report for the Suncor Voyageur South Project. 

Prepared for Suncor Energy Inc. Fort McMurray, AB. 

Suncor. 2008. Firebag 2007 Conservation and Reclamation Annual Report. 

Submitted to Alberta Environment. March 2008. 45 pp. + Appendices. 

White, C. M., N. J. Clum, T. J. Cade and W. G. Hunt. 2002. Peregrine Falcon 

(Falco peregrinus), The Birds of North America Online (A. Poole, Ed.). 

Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North 

America Online: http://bna.birds.cornell.edu/bna/species/660. 

Wiggins, D. A., D. W. Holt and S. M. Leasure. 2006. Short-eared Owl (Asio 

flammeus), The Birds of North America Online (A. Poole, Ed.). Ithaca: 

Cornell Lab of Ornithology; Retrieved from the Birds of North America 

Online: http://bna.birds.cornell.edu/bna/species/062. 

ii. Reclamation targets for species listed on Schedule 1 of SARA and current 

COSEWIC-listed species are listed by ecosite phase and wetlands type in 

AENV SIR 59bi, Table AENV 59-1, based on the conceptual Closure, 

Conservation and Reclamation plan. 


CR029


Section 13.1 

Table AENV 59-1: Potential and Observed Federally Listed Species and Associated Habitat to be Cleared and Reclaimed in the Local Study Area 

Common 

Name Latin Name COSEWIC SARA 

western 

(boreal) 

toad 

wood bison Bos bison 

athabascae 

woodland 

caribou 

Bufo boreas Special 

Concern 

Rangifer 

tarandus 

Schedule 1: 

Special 

Concern 

Threatened Schedule 1: 

Threatened 

Threatened Schedule 1: 

Threatened 

Observed 

During 

Surveys 

yes 

yes 

yes 

Ecosite 

Phase or 

Wetlands 

Type 

Base Case 

Area 

(ha) 

Loss/Alteration 

Due to the 

Project Closure (a) 

Net Change Due to the 

Project (b) 


CR029 

% 

LSAs 

Area 

(ha) 

% of 

LSAs 

Area 

(ha) 

% of 

LSAs 

Area 

(ha) 

% of 

LSAs 

% of 

Resource 

e2** 592 1 -344 -1 405 1 -187 -


Section 13.1 


(cont'd) 

Common 


woodland 

caribou 

(cont’d) 

common 

nighthawk 

rusty 

blackbird 

short-eared 

owl 

whooping 

crane 

Chordeiles 

minor 

Eughagus 

caroinus 

Asio 

flammeus 

Grus 

americana 

Threatened No 

Schedule: 

No Status 

Special 

Concern 

Special 

Concern 

Schedule 1: 

Special 

Concern 

Schedule 3: 

Special 

Concern 

Endangered Schedule 1: 

Endangered 

Observed 

During 

Surveys 

Ecosite 

Phase or 

Wetlands 

Type 

Base Case 

Area 

(ha) 


Due to the 





CR029 

% 

LSAs 

Area 

(ha) 

% of 

LSAs 

Area 

(ha) 

% of 

LSAs 

Area 

(ha) 

% of 

LSAs 

% of 

Resource 

FONS** 3627 7 -2569 -5 1058 2 -2569 -5 -71 

MONG*** 671 1 -622 -1 50


Section 13.1 


(cont'd) 

Common 


peregrine 

falcon 

northern 

leopard frog 

Falco 

peregrinus 

Rana 

pipiens 

Special 

Concern 

Special 

Concern 

Schedule 1: 

Threatened 

Schedule 1: 

Special 

Concern 

Observed 

During 

Surveys 

no 

no 

Ecosite 

Phase or 

Wetlands 

Type 

Base Case 

Area 

(ha) 


Due to the 





CR029 

% 

LSAs 

Area 

(ha) 

% of 

LSAs 

Area 

(ha) 

% of 

LSAs 

Area 

(ha) 

% of 

LSAs 

% of 

Resource 

MONG*** 671 1 -622 -1 50


Section 13.1 


(cont'd) 

Common 


wolverine Gulo gulo Special 

Concern 

No 

Schedule: 

No Status 

Observed 

During 

Surveys 

no 

Ecosite 

Phase or 

Wetlands 

Type 

Base Case 

Area 

(ha) 


Due to the 





CR029 

% 

LSAs 

Area 

(ha) 

% of 

LSAs 

Area 

(ha) 

% of 

LSAs 

Area 

(ha) 

% of 

LSAs 

% of 

Resource 

e3** 360 1 -148 -




Section 13.1 

Shell states Bird species, such as black-throated green warbler or barred owl, 

differ from mammals in that they are highly mobile, and often have smaller home 

ranges. Thus bird species can be expected to be less affected by fragmentation at 

the scale of a mineable oil sands project. Barred owl is listed as Sensitive 

provincially and is considered to be sensitive to fragmentation and habitat 

alteration (Status of the Barred Owl (Strix varia) in Alberta, Alberta Status 

Wildlife Report No. 56, 2005). This document states Habitat loss and 

fragmentation resulting from industrial development threaten this old-growth 

dependent species. Further, Shell chose barred owl as one if its Key Indicator 

Resources. 

Black-throated green warbler is on the “Blue list” of species that may be at risk 

in Alberta. Due to habitat loss and population declines in some areas (Status of 

the Black-throated Green Warbler (Dendroica virens) in Alberta, Alberta Status 

Wildlife Report No. 23, 1999). 

In discussion with Anne Hubbs with respect to fragmentation and Shell’s 

rationale stated above, she references habitat modeling work done by university 

professors (Fiona Schiegelow and Steve Cumming) for the Al-Pac FMA (as part 

of the company's DFMP requirements) based on relatively extensive data-sets. 

Page 15 of the report for SRD states The coarse-scale models showed that the 

presence or absence of these species within large (~100 ha) contiguous patches 

of presumably suitable old-forest habitat was related to the abundance and 

distribution of this habitat within the surrounding 10,000 ha landscape, and was 

negatively related to the density of industrial infrastructure (wells) and linear 

features (roads and pipelines) within these landscapes. Notably, the probability 

of detection of BGNW and BBWA within large contiguous patches of old forest 

habitat, was significantly related to measures of industrial activity (BBWA and 

BGNW) or total habitat abundance (BGNW) at the landscape scale. 

60a Provide further explanation for the assertion that smaller home ranges and 

increased mobility would translate into a species being less affected by 

fragmentation at the scale of a mineable oil sands project. Provide peerreviewed 

literature to support the assertion. 

Response 60a Many factors interact to determine how habitat fragmentation affects wildlife 

species. In general, it seems that direct habitat loss should have the dominant 

effect on wildlife species richness until the area of natural habitat declines below 

a threshold of about 30% or less (Andrén 1994; Fahrig 1998; Betts et al. 2007). 

Below this threshold, factors such as patch size and isolation/connectivity are 

more likely to affect species richness. 

Birds with small home ranges should exhibit fewer effects as a result of 

reductions in patch size (Schmiegelow and Mönkkönen 2002). It is intuitive that 

as long as habitat patches are large relative to individual home ranges, there 


CR029


References 

Section 13.1 

should be fewer effects of habitat fragmentation. Species with smaller home 

ranges should therefore be better able to tolerate reductions in patch size above 

some threshold. Highly mobile species such as migrants (i.e., black-throated 

green warbler) or large predatory birds (i.e., barred owl) should be more resistant 

to increases in the distance between patches (D’Eon et al. 2002). Highly mobile 

species are able to utilize more isolated patches, and are likely to view the 

landscape as more connected than less mobile species (Andrén 1994; Fahrig 

1998). 

In the boreal forest, birds may be more resilient to habitat fragmentation because 

of historically high rates of natural disturbance (Schmiegelow et al. 1997). Most 

of the effects of landscape change appear to be a result of habitat loss, rather than 

habitat fragmentation (Schmiegelow et al. 2002). Where changes in bird species 

richness or abundance in association with habitat fragmentation have been 

documented, these changes have been largely attributed to increases in predation 

and nest parasitism near habitat edges (Schmiegelow et al. 1997). However, 

increased predation and nest parasitism in association with fragmentation has 

only been documented in the boreal forest when studies were conducted in 

agricultural landscapes (Schmiegelow et al. 1997; Bayne and Hobson 1997). 

Disturbances that do not create habitat that favours predators or nest parasites 

should therefore result in reduced effects of habitat fragmentation (Schmiegelow 

et al. 1997, 2002). 

In the preamble, there is discussion of a documented negative relationship 

between the probability of barred owl or black-throated green warbler detection 

and industrial disturbances. However, it is unclear whether it is habitat 

fragmentation (e.g., decreased patch size, increased patch isolation) or other 

confounding factors such as noise, light, human activity and dust that are 

responsible for observed changes in detection probability. This relationship is 

interesting, although the report by Schmiegelow and Cumming referenced in the 

question is currently not peer-reviewed or publicly available. 

Andrén, H. 1994. Effects of habitat fragmentation on birds and mammals in 

landscapes with different proportions of suitable habitat: a review. Oikos 

71: 355-366. 

Bayne, E. M., and K. A. Hobson. 1997. Comparing the effects of landscape 

fragmentation by forestry and agriculture on predation of artificial nests. 

Conservation Biology 11: 1418–1429. 

Betts, M.G., G.J. Forbes and A.W. Diamond. 2007. Thresholds in songbird 

occurrence in relation to landscape structure. Conservation Biology 

21(4): 1046-1058. 

D’Eon, R.G., S.M. Glenn, I. Parfitt and M.-J. Fortin. 2002. Landscape 

connectivity as a function of scale and organism vagility in a real 

forested landscape. Conservation Ecology 6(2): 10. 


CR029


Section 13.1 

Fahrig, L. 1998. When does fragmentation of breeding habitat affect population 

survival? Ecological Modelling 105: 273-292. 

Schmiegelow, F.K.A., C.S. Machtans and S.J. Hannon. 1997. Are boreal birds 

resilient to forest fragmentation? An experimental study of short-term 

community responses. Ecology 78(6): 1914-1932. 

Schmiegelow, F.K.A. and M. Mönkkönen. 2002. Habitat loss and fragmentation 

in dynamic landscapes: avian perspectives from the boreal forest. 

Ecological Applications 12(2): 375-389. 

Request 60b Provide support for the assertion that these two species (black-throated green 

warbler and barred owl) would reflect the entire bird community’s response to 

fragmentation. Use peer-reviewed literature to support the discussion. 

Response 60b Black-throated green warbler and barred owl would not represent the entire bird 

community’s response to habitat fragmentation. Most bird species in the boreal 

forest are expected to be relatively insensitive to forest fragmentation as long as 

habitat is abundant regionally (Schmiegelow et al. 1997). However, evidence 

does suggest that black-throated green warbler (Schmiegelow et al. 1997; 

Hobson and Bayne 2000) and barred owl (Russell 2008) may be sensitive to 

forest fragmentation. As such, black-throated green warbler and barred owl 

function as suitable proxies for the bird communities within the local study areas 

(LSAs), which in general should be less sensitive to habitat fragmentation than 

these key indicator resources (KIRs). Fragmentation effects are expected to be 

most pronounced in agricultural landscapes, where disturbances create habitat 

that favours predators and nest parasites (Bayne and Hobson 1997; Schmiegelow 

et al. 1997, 2002). Disturbances such as forest clearing are less likely to create 

habitat for predators and nest parasites, and therefore should result in reduced 

effects of habitat fragmentation on neighbouring bird communities (Schmiegelow 

et al. 2002). 

References 

Bayne, E. M., and K. A. Hobson. 1997. Comparing the effects of landscape 

fragmentation by forestry and agriculture on predation of artificial nests. 

Conservation Biology 11: 1418–1429. 

Hobson, K.A. and E. Bayne. 2000. Effects of forest fragmentation by agriculture 

on avian communities in the southern boreal mixedwoods of western 

Canada. Wilson Bulletin. 112(3): 373-387. 

Russell, M.S. 2008. Habitat selection of barred owls (Strix varia) across multiple 

spatial scales in a boreal agricultural landscape in north-central Alberta. 

MSc Thesis. University of Alberta, Edmonton. 

Schmiegelow, F.K.A., C.S. Machtans and S.J. Hannon. 1997. Are boreal birds 

resilient to forest fragmentation? An experimental study of short-term 

community responses. Ecology 78(6): 1914-1932. 


CR029


Section 13.1 

Schmiegelow, F.K.A. and M. Mönkkönen. 2002. Habitat loss and fragmentation 

in dynamic landscapes: avian perspectives from the boreal forest. 

Ecological Applications 12(2): 375-389. 

Request 60c Provide a fragmentation analysis for barred owl and black-throated green 

warbler as the KIRs chosen by Shell or provide fragmentation analyses for a 

suitable proxy including a reasonable biological rationale that supports its use 

as a proxy. 

Response 60c A fragmentation analysis was performed for barred owl and black-throated green 

warbler at the regional study area (RSA) scale (see Table AENV 60-1). Because 

a raster approach was used, the total area of linear disturbances had to be 

overestimated to ensure their representation on the landscape. This was necessary 

for the analysis of fragmentation, but results in an overestimation of habitat loss. 

In the Application Case, the number of high-quality habitat patches for blackthroated 

green warbler and barred owl decline by 1% relative to the Base Case. 

The average size of high-quality habitat patches for these key indicator resources 

(KIRs) decreases by less than 1%, while core area decreases by about 1% relative 

to Base Case conditions. The mean distance between predicted high-quality 

patches increases by about 1% for black-throated green warbler and barred owl in 

the Application Case (Table AENV 60-1). 

From Base Case to the Planned Development Case (PDC) for black-throated 

green warbler, high-quality habitat patches decrease by 6% in number, less than 

1% in average size and 8% in core area. The mean distance between predicted 

high-quality habitat patches for black-throated green warbler increases by 4% in 

the PDC relative to the Base Case (Table AENV 60-1). 

From the Base Case to the PDC for barred owl, the number of high-quality 

habitat patches decreases by 7% and the core area of high-quality habitat patches 

decreases by 6%. The average size of high-quality habitat patches for barred owl 

increases by less than 1%, suggesting that planned developments are affecting 

smaller patches on average. The mean distance between high-quality habitat 

patches for barred owl increases by 3% from the Base Case to the PDC (Table 

AENV 60-1). 

Fragmentation is predicted to be negative in direction, and low in magnitude for 

black-throated green warbler and barred owl in the PDC. The results of 

fragmentation analyses for black-throated-green warbler and barred owl do not 

alter the assessed environmental consequences of the project for these KIRs. In 

the PDC, the project was assessed as having a low environmental consequence 

on black-throated green warbler and barred owl habitat (EIA, Volume 5, Section 

7.6-3.1, Table 7.6-9, p. 7-149). 

Habitat fragmentation analysis was not conducted at the local study area (LSA) 

level for the project as site clearing for the development will occur as two patches 


CR029


Section 13.1 

accounting for approximately 64% of the LSAs. Therefore, fragmentation is not a 

relevant measure for wildlife at the LSA scale. 

Table AENV 60-1: Predicted Key Indicator Resource Habitat Fragmentation Effects for the 

Base Case, Application Case and Planned Development Case in the Regional Study Area 

Net Change From Base Case 

to PDC 

Base Case Application Case 

Key Indicator 

MPS TCA ENN_MN 

MPS TCA ENN_MN NP MPS TCA 

Resource NP (ha) (ha) (m) NP (ha) (ha) (m) (%) (%) (%) 

blackthroated 

nil 

low 

6,748 

13,391 

110 

77 

467,305 

660,535 

222 

80 

6,577 

13,104 

115 

78 

485,949 

655,485 

223 

81 

-18 

-8 

36 

3 

21 

-3 

4 

3 

green 

warbler 

moderate 

high 

8,775 

11,177 

29 

22 

109,753 

72,065 

142 

143 

8,726 

11,043 

29 

22 

109,515 

71,084 

143 

144 

-10 

-6 

3 

>-1 

-6 

-8 

6 

4 

barred 

owl 

nil 6,748 110 467,305 222 6,577 115 485,949 223 -18 36 21 4 

low 13,573 80 702,165 77 13,301 81 696,600 78 -8 3 -4 2 

moderate 7,126 27 83,209 162 7,079 27 82,971 164 -11 3 -7 7 

high 11,197 22 74,788 138 11,070 22 74,149 139 -7


References 

Section 13.1 

bird nesting period which is typically April 1 to August 30 (Environment Canada 

2006; FAN 2007). Thus, clearing typically occurs outside of this nesting period 

(i.e., in September to March), as stated in EIA, Volume 5, Section 7.1.3, page 

7-10. 

Birds of prey are protected under the Alberta Wildlife Act (AWA) which states 

that a “person shall not wilfully molest, disturb or destroy a house, nest or den of 

prescribed wildlife... in prescribed areas and at prescribed times” (Government of 

Alberta 2000). Owls do not have specific provisions under the AWA, and Alberta 

Sustainable Resources Development (ASRD) is developing guidelines to address 

habitat and protection needs of sensitive species (A. Hubbs, 2009, pers. comm.). 

Shell recognizes that there are potential impacts on owl nests, and has included 

the potential impact within the EIA analysis. Shell is committed to conducting 

the pre-clearing nest surveys as required by the MBCA and AWA, and the 

primary mitigation for compliance is to conduct clearing outside of the main 

migratory bird nesting period which is typically April 1 to August 30 

(Environment Canada 2006; FAN 2007). 

Environment Canada. 2006. Submissions of the Government of Canada. The 

Joint Review Panel Established by the Alberta Energy and Utilities 

Board and the Canadian Environmental Assessment Agency. Kearl Oil 

Sands Project, Imperial Oil Resources Ventures Limited. Available 

online at 

http://www.ceaa.gc.ca/050/documents_staticpost/cearref_16237/KR- 

0029.pdf. Assessed October 23, 2009. 

FAN (Federation of Alberta Naturalists). 2007. The Atlas of Breeding Birds of 

Alberta: A Second Look. 626 pp. 

Government of Alberta. 2000. Wildlife Act. R.S.A. 2000, c. W-10. Current to 

June 4, 2009. Sustainable Resource Development. 65 pp. 

Government of Canada. 1994. Migratory Birds Convention Act, 1994. S.C., 

1994, c. 22. Current to September 17, 2009. Published by the Minister of 

Justice. 54 pp. 

Hubbs, A. 2009. (Fish and Wildlife Management, Alberta Sustainable Resource 

Development, Rocky Mountain House). Personal communication with 

Amy Darling (Golder Associates Ltd.) on October 22, 2009. 


CR029



Section 13.1 

Request Volume 2, SIR 441a, Page 23-90 ; Volume 2, SIR 457a, Page 23-90 ; EIA 

Volume 5, Appendix 5-4, Section 1.3.12, Page 80. 

In their response to SIRs 441a and 457a Shell states that habitat loss is not 

necessarily directly linked to a direct reduction in the abundance of wildlife 

KIRs. Population abundance and habitat suitability are not directly tied because 

many other factors are also important. 

One of the other factors that Shell suggests affects population abundance is 

carrying capacity. Shell offers moose as an example of a species that will not 

suffer population decreases due to habitat loss since the carrying capacity of the 

surrounding habitat has not been reached. Shell states that when moose are 

displaced from the LSA the moose density in surrounding area would double to 

0.44 moose/km 2 . This density is slightly higher than the highest density reported 

in the oil sands region but just 22% of the carrying capacity put forward by 

Crete (1987) and Messier (1994) (Page 23-128). 

In the original EIA Volume 5, Appendix 5-4; Section 1.3.12, Page 80, Shell 

predicts that In the PDC, [moose] populations increase from an initial density of 

0.21 to 0.71 moose/km 2 . 

62a Given that Shell acknowledges the estimate of moose density put forward by 

Crete and Messier was an estimate for North America, not northern Alberta, and 

for a predator-free environment, which is not the case in the RSA, describe the 

applicability of the Crete and Messier estimate to the habitat surrounding the 

LSA. 

Response 62a The Messier (1994) estimate of two moose per km 2 is appropriate for habitat 

surrounding the local study area (LSA), as this is the best estimate available for a 

food-limited population density equilibrium. A food-limited population density is 

a useful reference point, as harvest and predation rates may be affected by 

wildlife management. Although the estimate of population equilibrium put 

forward by Messier (1994) was produced including data from across North 

America, most selected studies were from northern coniferous forest, including 

two studies from northern Alberta, and are the best estimates available. 

Reference 

Messier, F. 1994. Ungulate population models with predation: a case study with 

the North American moose. Ecology. 75: 478-488. 

Request 62b What evidence is available that indicates the surrounding environment is 

currently underexploited by moose? 


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Section 13.1 

Response 62b Evidence that the habitat surrounding the LSA may be underexploited by moose 

comes from population density estimates and known mortality sources in the 

region. Moose density in the Jackpine Mine Expansion local study area (LSA) 

was calculated at 0.22 moose/km 2 (Golder 2007). Moose population density 

estimates for Moose Management Areas (MMAs) 8 and 9 (about half the 

regional study area [RSA] falls into each Management Area) have ranged from 

0.10 moose/km 2 (wildlife management unit [WMU] 540, survey year 1993/1994) 

to 0.62 moose/km 2 (WMU 525, survey year 1995/1996) (ASRD 2002). Moose 

hunting is a very common activity in the RSA (ASRD 2009), and likely has 

reduced moose populations. Annual regulated harvest from WMUs in the RSA is 

about 100 per year (e.g., 104 in 2008, 106 in 2007). In addition, moose are a 

staple for First Nations in the region and their unregulated harvest is likely 

substantive. Finally, moose are the primary prey species for wolves in the region 

(James et al. 2004). 

References 

There has been a documented relationship of increasing moose populations with 

increasing levels of human development in northern Alberta (Schneider and 

Wasel 2000). This has been hypothesized to be due to lower predation and 

hunting pressure near areas of extensive human development in Alberta, as well 

as increasing forage availability with increasing forest fragmentation (Schneider 

and Wasel 2000). Mean moose population density in the White Zone of northern 

Alberta has been estimated to be about 0.50 moose/km 2 (Schneider and Wasel 

2000). Moose populations in the Oil Sands Region may be able to reach this level 

or higher, depending on wildlife management actions and the trajectory of 

landscape change. 

ASRD (Alberta Sustainable Resource Development). 2002. Northern Moose 

Management Program: moose population surveys. Available online at: 

http://www.srd.alberta.ca/ManagingPrograms/FishWildlifeManagement/ 

NorthernMooseManagementProgram/MoosePopulationSurveys.aspx. 

Accessed November 10, 2009. 

ASRD (Alberta Sustainable Resource Development). 2009. Resident hunter 

harvest. 

http://www.mywildalberta.com/Hunting/GameSpecies/ResidentHunters 

Harvest.aspx. Accessed October 30, 2009. 

Golder (Golder Associates Ltd.). 2007. Wildlife and Wildlife Habitat 

Environmental Setting Report for the Jackpine Mine Expansion & Pierre 

River Mine Project. Prepared for Shell Canada Limited. Calgary, AB. 

Submitted December 2007. 

James, A.R.C., S. Boutin, D.M. Hebert, and A.B. Rippin. 2004. Spatial 

separation of caribou from moose and its relation to predation by wolves. 

Journal of Wildlife Management 68: 799-809. 


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Schneider, R.R. and S. Wasel. 2000. The effect of human settlement on the 

density of moose in northern Alberta. The Journal of Wildlife 

Management 64(2): 513-520. 

Section 13.1 

Request 62c Clarify what the predicted density of moose is for the LSA and RSA in the Base 

Case and Application Case. 

Response 62c The densities of moose in the RSA in the Base Case and Application Case were 

estimated to be 0.23 moose/km 2 initially. Population densities in the Base Case 

and Application Case were projected to increase to 0.78 and 0.74 moose/km 2 , 

respectively (EIA, Volume 5, Appendix 5-4, Section 3.3.1.2, p. 80). 

References 

Uncertainty is always present in estimates of survival rates, fecundity rates and 

population density estimates. Because this uncertainty, the general consensus 

among population ecologists is that relative results of Population Viability 

Analysis (PVA), either from sensitivity analyses or comparisons among 

landscape scenarios, are more reliable for assessing effects than absolute results 

(McCarthy et al. 2003; Schtickzelle et al. 2005). Therefore, absolute results from 

a PVA, such as a population density, should not be given undue attention. 

Uncertainty in demographic rates is explicitly explored in sensitivity analyses, 

where vital rates within the PVA were decreased by an additional 10% to 20% 

(EIA, Volume 5, Appendix 5-4, Section 3.3.1). The result of sensitivity and 

effects analysis was that the estimated negative effects of the project on moose 

populations within the study area were very small, and did not alter population 

trajectory (EIA, Volume 5, Appendix 5-4, Section 3.3.1, Figure 32). 

McCarthy, M. A., S. J. Andelman, and H. P. Possingham. 2003. Reliability of 

Relative Predictions in Population Viability Analyses. Conservation 

Biology 17: 982-989. 

Schtickzelle, N., M. F. Wallis De Vries, and M. Baguette. 2005. Using Surrogate 

Data in Population Viability Analysis: The Case of the Critically 

Endangered Cranberry Fritillary Bitterfly. Oikos 109: 89-100. 

Request 62d Provide an explanation as to why Shell believes the surrounding area is not 

currently at carrying capacity for moose and therefore would be able to absorb 

and support a doubling of the moose population to a density slightly more than 

the highest density reported in the oil sands region to date (>0.43 moose/km2) 

Response 62d See the response to AENV SIR 62b. 


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Section 13.1 

Request 62e What are the habitat characteristics or features of the surrounding area that 

might enable it to support higher densities of moose than have been recorded 

anywhere else in the oil sands region? 

Response 62e As outlined in the response to AENV SIR 62a and b, habitat is unlikely to be 

limiting moose populations in the region. There are many factors besides habitat 

that are capable of regulating moose populations. Predation and human harvest 

are likely to have influenced historical moose population density in the Oil Sands 

Region. These factors are subject to change as management actions are capable 

of regulating harvest and predation pressures. Increasing human development 

may result in lower predation and harvest rates, as well as increasing forage 

availability through habitat fragmentation, leading to a higher moose population 

density (Schneider and Wasel 2000). 

Reference 



Management 64(2): 513-520. 

Request 62f For what timeframe does Shell anticipate the surrounding environment could 

support the displaced moose from the LSA, resulting in moose densities as high 

as 0.44 moose/km2? Provide any evidence available to support Shell’s expected 

timeframe. 

Response 62f A population density equilibrium because of food limitation is likely much 

higher than 0.2 moose/km 2 (Messier 1994; Messier and Joly 2000). In addition, 

increased forest fragmentation in the regional study area (RSA) may further 

boost the productivity of moose habitat. Therefore, carrying capacity of the 

surrounding environment is unlikely to affect the time frame that elevated moose 

densities are maintained. It is likely that current low population densities in the 

RSA are because of a combination of human harvest and predation as described 

in the response to AENV SIR 62b. The time frame in which an elevated moose 

population density can be maintained will depend more on the regulation of 

human harvest and regional predator management actions. 

References 



Messier, F. and D.O. Joly. 2000. Comment: regulation of moose populations by 

wolf predation. Canadian Journal of Zoology 78: 506-510. 


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Section 13.1 

Shell’s response states the impacts of [on] wildlife abundance as a consequence 

of habitat loss over the 80-year project timeline were not generally discussed 

because habitat loss is not necessarily directly liked to a direct reduction in the 

abundance of wildlife KIRs. While there may be both direct and indirect links to 

a direct or indirect reduction in abundance, the characterization of the links and 

reduction source are not critical to the discussion and in this case seem to have 

obscured the answer. There are clear biological pathways between habitat loss 

and reduced abundance. 

Shell indicates that the overall local and regional environmental consequence on 

hunting because of site clearing effects are predicted to be negligible and directs 

the reviewer to Volume 5, Section 8.4.6.3, page 107 of the EIA. This section 

indicates that in the long-term, habitat will be restored with a potentially positive 

effect on moose as described. Wildlife abundance must be managed in the 

interim time period prior to the long-term goal of habitat restoration. This 

period may be up to 80 years. 

63a Provide a general discussion of the impacts on fish and wildlife abundance as a 

consequence of habitat loss over the 80-year project timeline, both from a 

Project perspective and a cumulative perspective. Discuss the fish and wildlife 

management implications and potential challenges of any expected changes in 

abundance. 

Response 63a The loss of fish habitat as a result of the project will be compensated for with the 

development of a compensation lake and stream channel habitats (EIA, 

Volume 4, Appendix 4-6). The compensation habitat for fish would be developed 

as habitat losses occur, and therefore substantial delays from when habitat is lost 

to when new habitat is available are not anticipated. As a result of mitigation 

measures and the planned compensation habitat, changes to regional fish 

abundance because of the project under the Application Case were considered to 

be negligible (EIA, Volume 4, Section 6.7.6.3). The Application Case for fish 

and fish habitat assessed in the EIA is a cumulative assessment as it assesses all 

residual impacts for the project in combination with potential impacts associated 

with all existing and approved developments (EIA, Volume 4, Section 6.7.6.2). 

Changes in wildlife abundance as a result of habitat loss are difficult to predict 

because abundance is controlled by many factors that may operate independently 

from habitat abundance (Garshelis 2000). For example, historical events, habitat 

quality, weather, disease, parasites, predators, and human harvest may all affect 

wildlife abundance, but are not necessarily linked directly to habitat abundance 

(Levin 1998). Habitat loss is likely to lead to direct reductions in species 

abundance only when the availability of habitat is reduced to the point that it 

becomes a limiting factor (i.e., when a population density equivalent to carrying 

capacity is reached). 


CR029


Section 13.1 

As long as habitat is abundant regionally, habitat loss may not result in 

population declines. This assumes that population size directly tied to habitat 

abundance represents a ‘worst case scenario’. Population viability analyses 

(PVAs) were conducted for moose and black bear under the assumption that 

initial and carrying capacity population densities were fixed, and therefore loss of 

quality habitat would result in a decrease in population size (EIA, Volume 5, 

Appendix 5-4, Section 3.2, p. 77). Results suggest about a 2% population decline 

for moose, and a less than 1% decline for black bears as a result of the project. In 

the Planned Development Case (PDC), PVA results suggest about an 8% decline 

in the initial population size of moose within the regional study area (RSA), and 

a 9% decline in carrying capacity (EIA, Volume 5, Section 7.6.3.1, p. 7-143). For 

black bear, results of the PVA for the PDC estimate a reduction in initial and 

carrying capacity population sizes of about 4% (EIA, Volume 5, Section 7.6.3.1, 

p. 7-143). 

Whether landscape changes in the RSA as a result of the Application Case and 

the PDC have implications or potential challenges for fish and wildlife 

management depends on a variety of factors. For example, combined harvest and 

predation rates may affect fish and wildlife populations if population losses 

exceed recruitment. As has been the case since humans began harvesting fish and 

wildlife, monitoring is required and harvest rates need to be regularly evaluated 

to ensure that harvests remain sustainable. In addition to sources of mortality, the 

management of fish and wildlife populations may include manipulating factors 

that affect recruitment. For example, changes to the terrestrial landscape that 

result in species-specific habitat enhancements may benefit target species of 

management interest. Increased forest harvest associated with forestry and oil 

and gas development results in a landscape more suitable for moose and deer, 

both harvested species. Ultimately, objectives and strategies for the management 

of fish and wildlife populations at the RSA scale are the responsibility of the 

Alberta government. 

Request 63b Shell states that population abundance and habitat suitability are not directly 

tied because many other factors are also important. The original question asked 

about abundance and habitat loss not habitat suitability. Discuss changes to 

abundance as a result of habitat loss at both project and regional/cumulative 

level. 

Response 63b The abundance of wildlife populations are controlled by many factors that may 

operate independently from habitat abundance (Garshelis 2000). For example, all 

habitat is not of equal value in terms of mortality risk, the abundance of food, and 

overall productivity (van Horne 1983). As such, habitat quality is an important 

consideration when attempting to relate habitat loss to changes in wildlife 

abundance. The loss of low-quality, unproductive habitat is less likely to affect a 

population than the loss of high-quality habitat. Changes to fish and wildlife 

abundance as a result of habitat loss at the project and cumulative level are 

discussed in the May 2009 Pierre River Mine, Supplemental Information, 

Volume 2, SIR 63a and take these considerations into account. 


CR029


References 

Section 13.1 

Garshelis, D.L. 2000. Delusions in habitat evaluation: Measuring use, selection 

and importance. Pp. 111-164 in Research techniques in animal ecology, 

controversies and consequences. L. Boitani and T. K. Fuller (eds). 

Columbia University Press, New York. 

van Horne, B. 1983. Density as a Misleading Indicator of Habitat Quality. 

Journal of Wildlife Management 47(4): 893-901. 

Request 63c With respect to the discussion of moose and carrying capacity, Shell suggests 

that most moose will be displaced and that it is expected that moose density in 

the surrounding areas would double to 0.44 moose/km2. Is Shell asserting that 

this density doubling (greater than the highest density of 0.43 moose/km2 

reported earlier in the discussion) will remain for the 80-year period during 

which the project will displace moose? If not, and it is expected that moose 

densities will revert to existing levels, a reduction in abundance would be 

expected since density is area based. Discuss. 

Response 63c Population density is controlled by many factors that may operate independently 

of habitat abundance. Moose population density could be maintained at high 

levels (e.g., 0.44 moose/km 2 ) for the 80-year period before project reclamation. 

However, the factors controlling moose population densities within intact habitat 

beyond the lease boundaries are largely outside of Shell’s control. Moose 

population densities within the regional study area (RSA) may be strongly 

affected by wildlife management activities, as well as regional land use activities. 

References 

Crete (1987) and Messier (1994) have suggested that a food-limited carrying 

capacity for moose in North America is about 2 moose/km 2 . Site-specific 

carrying capacities will vary as a result of such factors as habitat quality, while 

population densities may be suppressed by harvest and predation. For example, 

there has been a documented relationship of increasing moose populations with 

increasing levels of human development in northern Alberta (Schneider and 

Wasel 2000). This has been hypothesized to be associated with lower predation 

and hunting pressure near areas of extensive human development in Alberta, as 

well as increasing forage availability with increasing forest fragmentation 

(Schneider and Wasel 2000). Mean moose population density in the White Zone 

of northern Alberta has been estimated to be about 0.50 moose/km 2 (Schneider 

and Wasel 2000). Moose populations in the Oil Sands Region may be able to 

reach this level or higher, depending on wildlife management actions and the 

trajectory of landscape change. 

Crete, M. 1987. The impact of sport hunting on North American moose. Swedish 

Wildlife Research Supplement 1: 553-563. 


the North American moose. Ecology 75: 478-488. 


CR029




Management 64(2): 513-520. 

Section 13.1 

Request 63d Discuss the shift in fish relative abundance as a consequence of the project 

impacts and cumulative impacts (much of the proposed compensation habitat is 

different and will support alternate species assemblages and relative abundance 

than the habitat being compensated for). 

Response 63d As described in EIA, Volume 4, Section 6.7.6.3, the assessment of potential 

effects on fish habitat and fish abundance determined that the project will result 

in changes in habitat area throughout the development area. However, changes in 

area because of the loss of watercourse segments and waterbodies in the 

development area will be offset by developing habitat in the compensation lake 

and closure diversion channels, as described in the Conceptual Compensation 

Plan (CCP) (EIA, Volume 4, Appendix 4-6). All of the fish species that will be 

affected by the project will have suitable habitat developed as part of the 

compensation plan. 


The development of the compensation lake is expected to result in an increase in 

fish habitat productivity in the area based on providing a 2:1 compensation ratio 

and the conservative assumptions of species distribution within the affected 

habitats, which has the potential to increase fish abundance and positively affect 

fish species diversity in the region. The fish community that is proposed for the 

compensation lake habitat and closure diversion channels is expected to provide 

a similar or greater abundance of the same species assemblage currently present 

in the watercourse segments and waterbodies affected by the project. In addition, 

the proposed compensation will allow for development of new fish populations 

not currently present in the affected watersheds, such as lake whitefish, in order 

to increase species diversity and trophic complexity. The final compensation lake 

species assemblage is being developed in consultation with regulators, First 

Nations and Métis. The relative compensation habitat gained for each species 

will be identified through habitat modelling and will be provided in the detailed 

No Net Loss Plan. 


Shell states that for the period of operations (25 to 50 years) wildlife will be 

displaced to surrounding habitat, including movement corridors along river 

valleys and escarpments. 

64a Is Shell arguing that these displaced individuals will result in increased 

abundance of wildlife in the remaining habitat for 25 to 50 years? If so, provide 


CR029


Section 13.1 

peer-reviewed literature that would support this assertion. Clearly articulate the 

ecological theory that would support the argument. 

Response 64a Shell is not suggesting that these displaced individuals will result in increased 

abundance of wildlife in the remaining habitat for 25 to 50 years. Wildlife 

abundance may increase initially. However, over time the abundance of wildlife 

in the adjacent area will change relative to the species-specific carrying capacity 

of habitat types in the adjacent landscape. If the surrounding landscape is not at 

carrying capacity, then densities may remain higher than before clearing. 

However, if the landscape is at carrying capacity or if there are other factors 

suppressing wildlife abundance (e.g., predation, hunting), the wildlife densities 

may decline to pre-clearing levels over time. 

Empirical data demonstrating these relationships are not available for most 

wildlife Key Indicator Resources. However, sufficient data are available for 

moose. Using moose as an example, moose populations are usually below 

carrying capacity of the habitat (i.e., the food-limited population density 

equilibrium) because of the effects of other factors (e.g., predation, competition, 

human harvest). For example, Messier (1994) and Messier and Joly (2000) 

estimated that the presence of wolves was sufficient to suppress moose 

population densities from 2.0 moose/km 2 to about 1.3 moose/km 2 , while wolves 

and black bears together could suppress population densities to 0.2 to 0.4 

moose/km 2 . Human harvest could suppress moose populations further. 

There is evidence that the habitat surrounding the local study area (LSA) may be 

underexploited by moose. Measured population density within the regional study 

area (RSA) of 0.2 is very low relative to the carrying capacity estimate of Crete 

(1997) and Messier (1994). Wolves and black bears are present in the RSA, and 

are likely suppressing moose population densities well below a food-limited 

carrying capacity (Messier 1994, Messier and Joly 2000). Also, moose hunting is 

a very common activity in the RSA (ASRD 2009), and likely has reduced moose 

populations. Annual regulated harvest from wildlife management units (WMUs) 

in the RSA is about 100 per year (e.g., 104 in 2008, 106 in 2007). Moose are a 

staple for First Nations in the region and their unregulated harvest is likely 

substantive. In addition, there has been a documented relationship in northern 

Alberta of increasing moose populations with increasing levels of human 

development (Schneider and Wasel 2000). This has been hypothesized to be due 

to lower predation and hunting pressure near areas of extensive human 

development in Alberta, as well as increasing forage availability with increasing 

forest fragmentation (Schneider and Wasel 2000). Mean population density in the 

White Zone of northern Alberta has been estimated to be about 0.50 moose/km 2 

(Schneider and Wasel 2000), and moose populations in the Oil Sands Region 

could reach this level. 

Most moose within the LSA will be displaced by habitat loss. Assuming that the 

moose density in the surrounding area is similar, when these moose are displaced 

to adjacent land of equivalent size, the moose density in the surrounding areas 

would double to 0.44 moose/km 2 . This density is slightly greater than the highest 

reported density in the Oil Sands Region, but just 22% of the food-limited 


CR029


References 


Section 13.1 

carrying capacity put forward by Crete (1987) and Messier (1994). The 

timeframe in which a moose population density of 0.44 moose/km 2 can be 

achieved will depend on regional moose management actions. If wolf densities, 

black bear densities and hunting (i.e., licensed and First Nations harvest) are not 

regulated, then population densities will likely be reduced to levels present before 

the project. 

ASRD (Alberta Sustainable Resource Development). 2009. Resident hunter 

harvest. 

http://www.mywildalberta.com/Hunting/GameSpecies/ResidentHunters 

Harvest.aspx. Accessed October 30, 2009. 

Crete, M. 1987. The impact of sport hunting on North American moose. Swedish 

Wildlife Research Supplement 1:553-563. 



Messier, F. and D.O. Joly. 2000. Comment: regulation of moose populations by 

wolf predation. Canadian Journal of Zoology 78: 506-510. 



Management 64(2): 513-520. 


CEMA used modelling to assess potential impacts of landscape change and 

compare different management/mitigation options. From a high level it is 

expected that the results of the CEMA SEWG modelling should be similar to 

those completed for environmental impact assessments in the area, as both are 

intended to provide insight into what the future might hold based on proposed 

activity in the regional area. Generally, the CEMA SEWG modelling showed a 

decline in wildlife KIR populations as a result of landscape impacts. 

65a The modelling presented by Shell largely does not reflect this decline. Discuss 

why. 


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Section 13.1 

Response 65a The modelling approach used in the recent Cumulative Environmental 

Management Association (CEMA) Sustainable Ecosystem Working Group 

(SEWG) modelling (CEMA SEWG 2008) uses a substantially different approach 

and suite of assumptions than the habitat modelling within the EIA. Therefore, 

the results are not comparable. 

References 

The recent CEMA SEWG modelling effort used the Alberta Landscape 

Cumulative Effects Simulator model (ALCES) (Forem Technologies 2009) to 

compare all estimated changes in wildlife habitat and populations to a ‘natural 

range of variability’ (NRV) (Wilson et al. 2008a). The NRV represents an 

approximation of the natural state in the decades or centuries before 1905, i.e., a 

pre-disturbance baseline (Wilson et al. 2008a). This makes comparisons with 

modelling results from the EIA difficult because in the EIA all landscape changes 

are expressed relative to a Base Case that approximates current conditions. In 

addition, the CEMA SEWG modelling forecasts changes to habitat as a result of 

simulated landscape alterations that follow predicted patterns of oil sands 

development and reclamation, forest harvesting, and fire (Wilson et al. 2008b). 

Patterns of oil sands development were simulated by translating a bitumen 

production forecast provided by the Alberta Energy Resources Conservation 

Board (ERCB) into either surface or in situ mine developments, depending on the 

scenario (CEMA SEWG 2008). The spatial pattern of development was 

simulated to follow locations of greatest anticipated return according to an ERCB 

bitumen pay map, i.e., deposit thickness where bitumen accounts for more than 

50% of the composition (Wilson et al. 2008b). Although details on simulated 

reclamation processes appear lacking in the documentation, patterns apparently 

followed trajectories designed to generalize the reclamation trajectories of 

existing mine reclamation plans (Wilson et al. 2008b). 

ALCES addresses existing, approved and predicted projects for 100 years, 

whereas the EIA addresses existing and planned projects disclosed up to six 

months before the EIA filing. Outside the LSA, only planned disturbances within 

the public domain within six months of the application are represented (i.e., July 

2007). As stated in the EIA (EIA, Volume 3, Section 1.3.3 and Errata), projects 

disclosed after June 2007, or projects where approvals were issued or plans were 

modified following June 2007, were considered in the EIA based on the relevant 

information available as of June 2007. In addition, the EIA assessment scenario 

does not include progressive reclamation over time, whereas assumptions related 

to progressive reclamation were included in the CEMA modelling. 

Forem Technologies. 2009. ALCES. Website: 

http://www.foremtech.com/home/Home. Accessed January 8, 2009. 

CEMA SEWG (Sustainable Ecosystem Working Group of the Cumulative 

Environmental Management Association). 2008. Terrestrial ecosystem 

management framework for the Regional Municipality of Wood Buffalo. 

57 pp. Available online: 


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Section 13.1 

http://www.cemaonline.ca/component/option,com_docman/task,doc_do 

wnload/gid,1484/ 

Wilson, B., J.B. Stelfox, K. Porter, M. Patriquin, M. Ingen-Housz. 2008a. 

Summary of methodology for the development of the terrestrial 

ecosystem management framework. 27 pp. Available online: 



Wilson, B., J.B. Stelfox, M. Patriquin. 2008b. SEWG workplan facilitation and 

modelling project data inputs and assumptions. 68 pp. Available online: 



Request 65b Discuss which representation most closely approximates what should be 

expected and planned for. 

Response 65b Due to the great degree of uncertainty contained within the far future scenarios, 

and the difficulty of parsing out project-specific contributions to a predevelopment 

baseline, the CEMA SEWG approach is not appropriate for use in 

an EIA. At the scale of the project, the representation found within the EIA most 

closely represents what is likely expected and planned for. However, the far 

future planning used in the CEMA SEWG modelling effort does have value as a 

long term planning tool for the Province of Alberta. 

The CEMA SEWG modelling forecasts changes to habitat for 100 years based on 

predicted patterns of forest harvesting and fire, as well as forecasted patterns of 

oil sands development and reclamation (Wilson et al. 2008b). Patterns of 

development and reclamation were based on ratios of development footprints to 

Alberta Energy bitumen production estimates. The rate of footprint development 

is dependent on socio-economic factors as well as technological advancements. 

Wilson et al. (2008b) acknowledge some of this uncertainty by including an 

“Innovative Approaches Scenario”, that uses lower footprint to bitumen 

production ratios. However, further uncertainty exists than is recognized by the 

range of scenarios, as technological advancements, economic conditions, and 

societal tolerances for development are unpredictable. In contrast, the approach 

used for the terrestrial assessment of the EIA does not utilize disturbance 

scenarios based on high levels of uncertainty. The EIA addresses existing and 

planned projects disclosed up to six months before the EIA filing. In addition, the 

effects of disturbances on wildlife in the EIA are estimated conservatively by not 

including progressive reclamation in the Planned Development Case. Further 

development patterns are uncertain, and were not included in the EIA. 

For estimating effects to key indicator resources, the CEMA SEWG modelling 

effort compared estimated future wildlife habitat and population conditions to 

pre-development (Wilson et al 2008a) conditions. In contrast, the EIA compares 

habitat and population conditions in each scenario to a Base Case that 


CR029


References 


Section 13.1 

approximates current conditions. This is done to properly focus the EIA on the 

project being proposed. 

The CEMA SEWG modelling effort applies very uncertain estimates of changes 

to the landscape over the next 100 years, and compares these changes to a predevelopment 

scenario. While this effort is an interesting research project and a 

useful long-term planning tool for the provincial government, it is not appropriate 

for use in an EIA. Future scenarios with too much uncertainty do not facilitate a 

realistic and useful impact assessment. 

Wilson, B., J.B. Stelfox, K. Porter, M. Patriquin, M. Ingen-Housz. 2008a. 

Summary of methodology for the development of the terrestrial 

ecosystem management framework. 27 pp. Available online: 



Wilson, B., J.B. Stelfox, M. Patriquin. 2008b. SEWG workplan facilitation and 

modelling project data inputs and assumptions. 68 pp. Available online: 



Request Volume 2, SIR 456a & c, Page 23-123. 

In Response 456a Shell states The natural areas category used in the 

heterogeneity and fragmentation analysis includes all undisturbed and reclaimed 

vegetation types … This is distinguished from the human disturbed category used 

in the assessment, which included cutblocks, agricultural areas and urban (e.g., 

municipalities and roads) and industrial (e.g., mines, seismic lines, well pads, 

and pipelines) developments in the regional or local study areas. 

66a Given that ‘natural areas’ is a term generally perceived as implying the area is 

undisturbed, provide a justification for including reclaimed areas in the natural 

areas category. Discuss the potential for misinterpretation given the 

characterization of reclaimed areas as natural. 


CR029


Section 13.1 

Response 66a Reclaimed areas were included in the natural areas category because Shell is 

committed to reclaiming disturbed areas in a manner that supports and maintains 

functional ecosystem processes. Shell is confident in its ability to reclaim the 

development areas to self-sustaining ecosystems that will meet equivalent land 

capability at closure and conditions will be adaptively managed to ensure that the 

reclaimed areas are following this expected trajectory. Based on this, the 

inclusion of reclaimed areas in the natural areas category is justified and there is 

very little potential for misinterpretation. 


Request Volume 2, SIR 456c iii, Page 23-125. 

Shell states Shell is confident that upland habitat on overburden dumps will be 

reclaimed based on the reclamation certification of Syncrude’s Gateway Hill and 

wildlife monitoring results from other reclamation efforts in the Oil Sands 

Region. 

The Syncrude Gateway Hill reclamation certificate was issued based on older 

approval conditions that do not necessarily reflect government’s current 

reclamation expectations. Standards have improved over time, and as such, 

Shell will be expected to meet current expectations regarding the reclamation of 

wildlife habitat. 

67a Provide details on how the wildlife monitoring results from other reclamation 

efforts in the Oil Sands region support Shell’s assertion that overburden dumps 

will be returned to pre-mining function with respect to wildlife habitat. Discuss 

the defensibility of the data used to support this assertion. 

Response 67a Although the responses to the May 2009 Pierre River Mine, Supplemental 

Information, Volume 2, SIR 456ciii referred to Gateway Hill, Shell recognizes 

that the Syncrude Gateway Hill reclamation certificate was issued based on older 

approval conditions that do not necessarily reflect government’s current 

reclamation expectations. Wildlife monitoring has been conducted on reclaimed 

areas, including overburden dumps on Suncor’s Lease 86/17 and 

Steepbank/Millennium areas since 1999 (Suncor 2008). The data helps to 

determine whether the reclaimed land is returning to a state of equivalent 

capability for wildlife. Parameters measured include winter track count surveys, 

waterfowl and water bird visual surveys and small mammal surveys. 

Surveys on recent reclamation areas provide data on updated approval 

conditions, which is more applicable to advanced reclamation standards. Surveys 

have indicated that typical boreal species, including fisher marten, white-tailed 

deer, coyotes and wolf, are using reclaimed areas. However, species that prefer 

mature forest cover (e.g., fisher marten) are not as prevalent in young reclaimed 

areas (Suncor 2008). The application of coarse woody debris (CWD) on 

reclaimed lands at the Steepbank North Waste Dump (an overburden waste 


CR029


References 


Section 13.1 

dump) has been monitored as well. The CWD was found to provide desirable 

habitat for deer mice as compared to control sites without CWD (Suncor 2008), 

thus demonstrating that new approaches to reclamation can provide wildlife 

benefits. Advances in reclamation research, wildlife monitoring and the use of 

adaptive management are expected to provide improvements in reclamation 

techniques and wildlife habitat. 

A specific example is Waste Area 8, an overburden dump on Suncor’s Lease 

86/17 that was reclaimed 25 years ago (Golder 2004). At its base is a 40 to 50 m 

buffer of natural riparian vegetation. A portion of Waste Area 8 was reclaimed in 

1984 with overburden, seeded with a barley mix and later planted with white 

spruce, pine, poplar, willow, dogwood, rose, buffalo-berry, wolf willow and 

saskatoon. In 1987, an additional area was reclaimed using muskeg soil placed 

over the overburden subsurface. The site was seeded with a barley nurse crop 

onto which white spruce, northwest poplar, lodgepole pine, rose, dogwood, 

buffalo-berry, saskatoon and sandbar willow were planted. Waste Area 8 is one 

of Suncor’s prominent reclaimed areas due to the presence of wildlife species 

typically noted for particular habitat requirements, such as moose, wolf, bear, 

wolverine, fisher marten, snowshoe hare and red-backed voles. Breeding bird 

species diversity and richness were low in Waste Area 8, with similar values to 

those found in the adjacent natural stand. The successful development of 

vegetation stands at Waste Area 8 reflects the efforts made to reclaiming it with 

native species as well as the area’s proximity to natural stands along the 

Athabasca River where encroachment of natural vegetation is facilitating the 

establishment of wildlife habitat. 

Golder. (Golder Associates Ltd.). 2004. Suncor Energy wildlife monitoring 

program and wildlife assessment update 1999-2003. Submitted to Suncor 

Energy Inc., Fort McMurray, Alberta. 

Suncor. (Suncor Energy Inc.). 2008. Firebag 2007 Conservation and Reclamation 

Annual Report. Submitted to Alberta Environment. March 2008. 45 pp. 

Request Volume 2, SIR 457a, Page 23-127 ; EIA Volume 5, Section 7, Page 7-112 ; 

EIA Volume 5, Appendix 5-4, Section 1.2.3, Page 14-24. 

In the response to the question of how wildlife abundance is affected by habitat 

loss (SIR 457a), Shell makes no mention of how indirect habitat loss caused by 

sensory disturbance would affect wildlife abundance. In the original application 

(Volume 5, Section 7, Page 7-112), Shell states that … black-throated green 

warbler and barred owl habitat was determined using RSF modelling and factors 

affecting habitat for these species are explicit in the modelling algorithms. By 

applying the model to the LSA’s with the superimposed mine footprint (i.e., the 

Application Case) the habitat affected by both direct and indirect effects 


CR029


Section 13.1 

including sensory disturbance was determined for those species. Although the 

statement seems to indicate that indirect effects including sensory disturbance 

were incorporated into the models, there is no mention of indirect effects, 

including sensory disturbance, in either the barred owl or black-throated green 

warbler model descriptions (EIA Volume 5, Appendix 5-4, Section 1.2.3, Pages 

21-24 and Pages 17-21). Furthermore, no assumptions are listed for any of the 

models other than black bear. 

68a Explain how indirect effects including sensory disturbance were incorporated 

into the barred owl and black-throated green warbler models. How were the 

model results then incorporated into the impact assessment for these KIRs and 

the wildlife communities they represent? 

Response 68a The indirect effects of human disturbance were incorporated into the barred owl 

and black-throated green warbler models implicitly through the processes of 

model building and model selection. Anthropogenic disturbance was implicit in 

the construction of the barred owl resource selection function (RSF) model 

through a variable quantifying the percent area forested (Hubbs 2007, pers. 

com.). That variable did not occur within the final model selected, suggesting 

that it may not be as important for barred owl nest site selection as the variables 

that were present (i.e., the area of old coniferous forest and bog). Although the 

effect of disturbed areas on nest site selection in the barred owl RSF model was 

not addressed separately from other non-forested areas (i.e., water and terrestrial 

naturally non-forested areas), there was reason to believe that its inclusion may 

not have substantially altered model selection results. For example, additional 

research on barred owl nest site selection conducted in the Calling Lake area 

found that half of all barred owl nests located were within 50 m of a cutblock. 

Therefore, it did not seem that nesting barred owls were avoiding anthropogenic 

disturbances of that kind (Olsen et al. 2006). Research conducted in 

Saskatchewan also suggests that indirect effects of disturbance are not important 

determinants of barred owl nest site selection (Marzur et al. 1997). In a synthesis 

of barred owl research from across North America, Livezey (2007) reported that 

barred owls had been found to display preference for, avoidance of, and 

neutrality towards, fragmented habitat, depending on the study and variables 

measured. 

Anthropogenic edge density was also considered as a potential variable in 

construction of the black-throated green warbler model (Boyce et al. 2002; 

Vernier et al. 2002). However, the process of model selection found the variable 

to be relatively unimportant, or at least a statistically insignificant predictor of 

black-throated green warbler presence (Boyce et al. 2002) and abundance 

(Vernier et al. 2002). For barred owl and black-throated green warbler, it was 

assumed that the lack of representation of disturbance-related variables in the 

final model (despite their consideration), as well as literature support for 

insensitivity to disturbance, indicated that proximity to disturbance was relatively 

unimportant for explaining habitat selection. Therefore, if included explicitly, the 

indirect effects of human disturbance on barred owl and black-throated green 

warbler model output were expected to be negligible. 


CR029


References 

Boyce, M.S., P.R. Vernier, S.E. Nielsen and F.K.A Schmiegelow. 2002. 

Evaluating resource selection functions. Ecological Modelling. 

157: 281-300. 

Section 13.1 

Livezey, K.B. 2007. Barred owl habitat and prey: a review and synthesis of the 

literature. The Journal of Raptor Research 41(3): 177-201. 

Mazur, K. M., P. C. James and S. D. Frith. 1997. Barred Owl nest site 

characteristics in the boreal forest of Saskatchewan, Canada. In J. R. 

Duncan, H. D. Johnson and T. H. Nicholls, editors. Biology and 

Conservation of Owls of the Northern Hemisphere: Second International 

Symposium, pages 267–271. U.S. Forest Service General Technical 

Report N-190. U.S. Dept. of Agriculture, Forest Service, North Central 

Forest Experiment Station, St. Paul, Minnesota, USA. 

Olsen, B.T., S.J. Hannon and G.S. Court. 2006. Short-term response of breeding 

barred owls to forestry in a boreal mixedwood forest landscape. Avian 

Conservation and Ecology 1(3):1. 

Vernier, P.R., F.K.A. Schmiegelow and S.G. Cumming. 2002. Modelling bird 

abundance from forest inventory data in the boreal mixed-wood forest of 

Canada. pp. 559-571. In: J.M. Scott, Heglund, P.J., Morrison, M., 

Raphael, M., Haufler, J., Wall, B. (ed.), Predicting Species Occurrences: 

Issues of Scale and Accuracy. Island Press. Covello, CA. 

Personal Communication. 2007. Hubbs, A. (Area Wildlife Biologist, Fish and 

Wildlife Division). 2007. Alberta Sustainable Resource Development. 

Athabasca, AB. E-mail to Brock Simons (Golder) on January 30, 2007. 

Request 68b If a disturbance factor of some sort was not included in the barred owl or blackthroated 

green warbler models, explain how incorporation of this factor would 

affect the model results and the conclusions of the EIA. 

Response 68b As discussed in AENV SIR 68a, disturbance factors were incorporated implicitly 

in the process of model production and selection for the barred owl and blackthroated 

green warbler models. That is, variables that were most likely to be the 

primary determinants of habitat selection for these species were present in the 

RSF models used. Therefore, the weight of evidence in the literature (see AENV 

SIR 68a for a detailed description) suggests that barred owls and black-throated 

green warblers are not sensitive to proximity of disturbance features relative to 

the habitat variables contained in the respective predictive models. An addition of 

indirect disturbance factors for these two species is unnecessary, and would not 

be based on the available scientific literature. 


CR029


Section 13.1 

Request 68c Explicitly list all assumptions inherent in each of the models used to assess the 

impacts of this project on all the respective KIRs. 

Response 68c The assumptions behind all models are listed explicitly in the Wildlife Modelling 

Appendix (see EIA, Volume 5, Appendix 5-4, Section 1.2). 


Request Volume 2, SIR 458c i, Page 23-130. 

The SIR requests peer-reviewed support for the adequacy of a 250 metre buffer. 

Shell makes reference to two peer-reviewed documents. Shell notes that the 

TROLS work (Hannon 2002), indicates 200 metre buffers were adequate for 

forest dwelling birds. Shell does not identify in their answer that this same work 

notes that a 200 metre buffer would not maintain wide-ranging species such as 

woodpeckers, raptors and mammalian carnivores. The second peer-reviewed 

reference is to Beier’s 1995 work noting cougar use of a 400 metre wide corridor 

in southern California with bottlenecks as narrow as 3.3 metres at road 

underpasses. It is unclear how this supports a 250 metre buffer width. Outside 

these two, the work referenced is largely completed by Golder or is monitoring 

data for Suncor. Neither is peer-reviewed. 

69a Provide peer-reviewed literature that supports Shell’s assertion that a 250 metre 

buffer from the high water mark of the Athabasca River is adequate, or revise the 

original statement as appropriate. 

Response 69a The purpose of a corridor is to maintain landscape connectivity for species. 

Landscape connectivity helps maintain population viability by promoting gene 

flow between patches and increasing the effective size of populations (Noss and 

Harris 1987, Beier and Noss 1998, Olsen et al. 2007). To be ultimately effective 

in maintaining genetic connectivity, the corridor only needs to facilitate passage 

of at least one effective migrant per generation (Mills and Allendorf 1996, Wang 

2004). The purpose of a corridor is not to satisfy all life history requirements for 

all wildlife species that may be using it (Rosenberg et al. 1997). 

In the boreal mixedwood ecoregion of north-central Alberta, Hannon et al. 

(2002) found that 200 m-wide riparian corridors were sufficient for maintaining 

natural small mammal, amphibian and bird communities. Hannon et al. (2002) 

then went on to say that a 200 m-wide corridor would not hold the territories of 

wide-ranging species. However, maintaining resident populations is only 

necessary when the corridor length is long relative to the dispersal abilities of the 

species in question (Beier and Noss 1998). The proposed Athabasca River 

corridor is less than 8 km long where the width approaches 250 m (minimum) 

adjacent to the main mine site, which is short relative to the dispersal capabilities 

of wide-ranging species (Sutherland et al. 2000). 


CR029


References 

Section 13.1 

There is a lack of peer-reviewed literature specifically regarding recommended 

buffer widths for wide-ranging wildlife species. However, findings from 

monitoring programs that have been implemented in the Oil Sands Region 

establish that wide-ranging wildlife species will use a 250 m-wide corridor. 

Although not from a peer reviewed source, these findings are real, relevant to the 

study area and important for evaluating the effectiveness of the proposed 

corridor. 

Winter track and remote camera corridor monitoring conducted for Shell’s 

Jackpine Mine – Phase 1 have documented that moose, wolves, black bears, 

fisher, marten, coyote and deer species were using habitat within existing 

corridors along the Muskeg and Athabasca rivers adjacent to active mines 

(Golder 2008). The setback distance along the Muskeg River varies from less 

than 100 m to more than 3 km, whereas the Athabasca River buffer is less than 

1 km. 

Wildlife movements were monitored for three years along the east side of the 

Athabasca River for Suncor’s Millennium and Steepbank Mine projects, where 

the corridor width varies from about 1 km to less than 200 m. The results of these 

surveys showed that all wildlife species, including large carnivores and large 

ungulates, used the variable-width corridor (Golder 2000, 2001). 

Wildlife corridor monitoring was conducted using remote cameras during nonwinter 

months along the Athabasca and Steepbank rivers (Suncor 2004, 2005 and 

2006). The Steepbank River buffer varies in size from 50 to 200 m, whereas the 

Athabasca River buffer zone is less than 1 km. Species detected along the 

Steepbank River escarpment included black bears and moose, while black bear, 

white-tailed deer, coyote, wolf, beaver, fisher marten and fox were recorded in 

the Athabasca River buffer zone. 

Due to the lack of peer-reviewed literature regarding appropriate corridor widths 

for larger wildlife species, it was determined that results from these studies were 

the best-available information for supporting the use of a 250 m buffer along the 

Athabasca River. Therefore, based on available corridor monitoring and wildlife 

habitat data specific to this region, a 250 m buffer from the Athabasca River is 

considered to be an effective width for maintaining landscape connectivity. 



Golder (Golder Associates Ltd.). 2000. Suncor Millennium and Steepbank Mine 

Projects Wildlife Monitoring Program & Wildlife Assessment Update 

2000. Submitted to Suncor Energy Inc., Oil Sands. Fort McMurray, AB. 

32 pp. + Appendices. 

Golder. 2001. Suncor Millennium and Steepbank Mine Projects Winter Wildlife 

Track Count Surveys 2001: Year Three. Prepared for Suncor Energy Inc. 

Fort McMurray, AB. 46 pp. + Appendices. 


CR029


Section 13.1 

Golder. 2007. Canadian Natural Horizon Wildlife Corridor Monitoring Program 

– 2006 Data Report. Prepared for Canadian Natural, Calgary. 5 March 

2007. 

Golder. 2008. Shell Jackpine Mine-Phase 1 Wildlife Corridor Monitoring Year 2 

Annual Report 2007. Prepared for Shell Canada Ltd. Fort McMurray, 

AB. 

Hannon, S.J., C.A. Paszkowski, S. boutin, J. DeGroot, S.E. Macdonald, M. 

Wheatley and B.R. Eaton. 2002. Abundance and species composition of 

amphibians, small mammals, and songbirds in riparian forest buffer 

strips of varying widths in the boreal mixedwood of Alberta. Canadian 

Journal of Forest Research 32: 1784-1800. 



1518. 







Rosenberg, D.K., B.R. Noon and E.C. Meslow. 1997. Biological corridors: form, 

function, and efficacy. Bioscience 47(10): 677-687. 

Suncor (Suncor Energy Inc.) 2004. Wildlife Monitoring Program and Wildlife 

Assessment Year 1999-2003. Prepared for Suncor Energy Inc. Fort 

McMurray, AB. 

Suncor. 2005. Wildlife Monitoring Program and Wildlife Assessment Year 2004. 


Suncor. 2006. Wildlife Monitoring Program and Wildlife Assessment Year 2005. 


Sutherland, G.D., A.S Harestad, K. Price and K.P. Lertzman. 2000. Scaling of 

natal dispersal distances in terrestrial birds and mammals. Conservation 

Ecology 4(1): 16. 




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Request Volume 2, SIR 458c iv, Page 23-136. 

Section 13.1 

Shell was requested to discuss the usable corridor width once the buffers, or 

zones of influence, along the disturbance edge had been applied. Shell 

acknowledges that the corridor may only be used by 50% of black bears all of the 

time, or that all black bears will use it 50% of the time. Regardless, the 

implication is that the corridor will be 50% effective for black bears given its 

proximity to development. Shell does not however describe the effective 

corridor width once appropriate buffers have been applied for other KIRs. 

Sensory disturbance is known to affect several of the KIRs as indicated in the 

model descriptions provided in Appendix 5-4 of the EIA Volume 5 (e.g., Distance 

to nearest road was found to contribute negatively (-) to the most strongly 

supported RSF model for moose (EIA, Volume 5, Appendix 5-4 Page 14); 

Distance to nearest edge C (-) was also a contributing negative factor in the most 

strongly supported model for fisher/marten). 

70a Discuss the effective corridor width along the Athabasca River after appropriate 

disturbance buffers have been applied along the disturbance edge, for all KIRs. 

Response 70a Effective habitat quality within the corridor is projected to decrease for some 

KIRs. However, a decrease in effective habitat quality should not be interpreted 

as a decrease in effective corridor width. To be effective, habitat within a 

corridor does not need to satisfy all the life history requirements of the species 

that use it (Rosenberg et al. 1997). The purpose of a corridor is to maintain 

landscape connectivity, which helps maintain population viability by promoting 

gene flow between patches and increasing the effective size of populations (Noss 

and Harris 1987, Beier and Noss 1998, Olsen et al. 2007). To be ultimately 

effective in maintaining genetic connectivity, the corridor only needs to facilitate 

passage of at least one effective migrant per generation (Mills and Allendorf 

1996, Wang 2004). Although sensory disturbance may decrease the 

attractiveness of the corridor for some species, it is unlikely to exclude species. 

Documented evidence of wildlife species using corridors adjacent to operational 

mines in the Oil Sands Region that are in some locations less than 250 m wide is 

discussed in AENV SIR 69a. 

Although sensory disturbance affects all KIRs, buffers are only used to represent 

sensory disturbance for black bears. For black bears, a 250 m sensory disturbance 

buffer is applied around all roads and industrial facilities, within which HSI 

values are multiplied by a disturbance coefficient of 0.5 (EIA, Volume 5, 

Appendix 5-4, Section 1.2.5, p. 33). The effects of proximity to disturbance are 

incorporated implicitly into the moose, Canada lynx, fisher marten, blackthroated 

green warbler and barred owl models, but cannot be partitioned in terms 

of disturbance buffers (EIA, Volume 5, Appendix 5-4, Section 1). Canadian toad, 

black bear, beaver and yellow rail are also affected by water table drawdown, 

which is represented as a 0.1 m isopleth. 


CR029


References 

Section 13.1 

Within the portion of the corridor that approaches 250 m wide (at minimum; 

Figure AENV 70-1), habitat quality and, therefore, effective corridor width, is 

predicted to be unaffected by the project for moose, Canada lynx, fisher marten, 

Canadian toad and beaver (Table AENV 70-1). For black-throated green warbler, 

the 11 ha of moderate-quality habitat present at the Base Case becomes low 

quality habitat during construction and operations. For barred owl, 1 ha of high 

quality habitat (0.4%) becomes low quality habitat during construction and 

operations. Due to the application of the sensory disturbance and water table 

drawdown buffers, 79 ha (85%) of high quality black bear habitat becomes low 

quality habitat. 





1518. 







Rosenberg, D.K., B.R. Noon and E.C. Meslow. 1997. Biological corridors: form, 

function, and efficacy. Bioscience 47(10): 677-687. 




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Figure AENV 70-1: Pierre River Mine Area Local Study Area Athabasca River Corridor 

Section 13.1 


CR029


Section 13.1 

Table AENV 70-1: Wildlife Habitat Change Within the Corridor Between the Pierre River 

Mining Areas Local Study Areas: Application Case 

Key Indicator 

Resource 

moose 

Canada lynx 

fisher/marten 

black-throated 

green warbler 

barred owl 

Canadian toad 

black bear 

beaver 

yellow rail 

Habitat 

Suitability 

Class 

Base Case 

Habitat 

Habitat 

Area 

[ha] 

% of 

LSAs 

Direct Habitat Change Due 

to Site Clearing of the 

Project 

Change in 

Habitat Area 

[ha] 

Change 

[%] 

Indirect Habitat Change 

Due to the Project 

Change in 

Habitat Area 

[ha] 

Change 

[%] 

Net Change From 

the Project 

Change in 

Habitat 

Area 

[ha] 

Change 

[%] 

Nil 2 1.2 0 0.0 0 0.0 0 0.0 

Low 1 0.5 0 0.0 0 0.0 0 0.0 

moderate low 57 28.6 0 0.0 0 0.0 0 0.0 

Moderate 17 8.4 0 0.0 0 0.0 0 0.0 

moderate high 44 22.0 0 0.0 0 0.0 0 0.0 

High 78 39.3 0 0.0 0 0.0 0 0.0 

Nil 2 1.2 0 0.0 0 0.0 0 0.0 

Low 0 0.0 0 0.0 0 0.0 0 0.0 

moderate low 0 0.0 0 0.0 0 0.0 0 0.0 

Moderate 60 30.0 0 0.0 0 0.0 0 0.0 

moderate high 57 28.5 0 0.0 0 0.0 0 0.0 

High 80 40.3 0 0.0 0 0.0 0 0.0 

Nil 2 1.2 0 0.0 0 0.0 0 0.0 

Low 0 0.0 0 0.0 0 0.0 0 0.0 

moderate low 0 0.0 0 0.0 0 0.0 0 0.0 

Moderate 0 0.0 0 0.0 0 0.0 0 0.0 

moderate high 15 7.4 0 0.0 0 0.0 0 0.0 

High 182 91.4 0 0.0 0 0.0 0 0.0 

Nil 2 1.2 0 0.0 0 0.0 0 0.0 

Low 186 93.4 0 0.0 11 5.8 11 5.8 

Moderate 11 5.4 0 0.0 -11 -100.0 -11 -100.0 

High 0 0.0 0 0.0 0 0.0 0 0.0 

Nil 2 1.2 0 0.0 0 0.0 0 0.0 

Low 28 14.2 0 0.0 1 2.1 1 2.1 

High 168 84.6 0 0.0 -1 -0.4 -1 -0.4 

Nil 2 1.1 0 0.0 0 0.0 0 0.0 

Low 0 0.0 0 0.0 0 0.0 0 0.0 

Moderate 156 78.4 0 0.0 0 0.0 0 0.0 

High 43 21.4 0 0.0 0 0.0 0 0.0 

Nil 2 1.2 0 0.0 0 0.0 0 0.0 

Low 24 11.9 0 0.0 79 334.7 79 334.7 

Moderate 81 40.6 0 0.0 0 -0.1 0 -0.1 

High 92 46.3 0 0.0 -79 -85.7 -79 -85.7 

Nil 121 60.8 0 0.0 0 0.0 0 0.0 

Low 3 1.5 0 0.0 0 0.0 0 0.0 

Moderate 3 1.7 0 0.0 0 0.0 0 0.0 

High 72 36.1 0 0.0 0 0.0 0 0.0 

Nil 196 98.6 0 0.0 0 0.0 0 0.0 

High 3 1.4 0 0.0 0 0.0 0 0.0 


CR029




Section 13.1 

In response to the SIR asking how long sight lines will mitigate impacts on 

wildlife, Shell suggests that this measure will reduce vehicle-wildlife collisions. 

Shell goes on to state that The construction of long lines of sight along roads is 

intended to mitigate impacts on medium to large size species, however Shell 

acknowledges that building straight roads with long straight sight-lines will not 

affect all species in the same way. 

71a What other consequences, (for example, reluctance to cross or improved 

detection by predators) could long sight lines potentially have on wildlife? 

Response 71a Long sight lines may increase the reluctance of some species to cross roads (e.g., 

Dyer 1999, Dyer et al. 2002), or they may increase prey detection rates for 

predators (e.g., James 1999). However, they may also increase driver visibility 

thereby reducing accident rates. Increased driver visibility as a result of 

vegetation clearing on roadsides has been documented to reduce wildlife vehicle 

collisions (e.g., moose; Seiler 2005). 

References 

One documented example of risk to wildlife populations from vehicle collisions 

is from a woodland caribou herd in Alberta, where an 11% mortality rate from 

collisions with vehicles on a major highway, combined with a natural mortality 

rate of at least 10% (Edmonds and Smith 1991) exceeded the average calf 

recruitment of 14%. The effect was reported to have likely resulted in a 

population decline (Brown and Hobson 1998). Although the potential for 

increased predator detection rates for prey exists using long sight lines for roads, 

Shell is unaware of a documented wildlife population decline due to long sight 

lines alone. In addition, research using individual-based movement models for 

wolves, caribou and moose to determine how linear developments affect wolf 

movements and consequently predator-prey interactions suggest that the number 

of predators on the landscape is more important than the number of linear 

developments when explaining caribou and moose survival (McCutchen 2006). 

As it is unlikely that the project will increase the number of predators within the 

RSA, it is predicted that any change in the predator-prey encounter rate would 

not impact the viability of regional wildlife populations. 

Brown, W. K. and D. P. Hobson. 1998. Caribou in West-central Alberta: 

Information Review and Synthesis. Prep. for: The Research 

Subcommittee of the West-central Alberta Caribou Standing Committee. 

74 pp + Appendices. 

Dyer, S.J. 1999. Movement and Distribution of Woodland Caribou (Rangifer 

tarandus caribou) in Response to Industrial Development in Northeastern 

Alberta. M.Sc. Thesis. University of Alberta. 106 pp. 


CR029


Section 13.1 

Dyer, S.J., J.P. O’Neill, S.M. Wasel and S. Boutin. 2002. Quantifying Barrier 

Effects of Roads and Seismic Lines on Movements of Female Woodland 

Caribou in Northeastern Alberta. Canadian Journal of Zoology 80: 839– 

845. 

Edmonds, E. J. and K. G. Smith. 1991. Mountain Caribou Calf Production and 

Survival, and Calving and Summer Habitat Use in West-central Alberta. 

Wildlife Research Series No. 4, Alberta Fish and Wildlife Division, 

Edmonton, AB. 16 pp. 

James, A.R.C. 1999. Effects of Industrial Development on the Predator-Prey 

Relationship Between Wolves and Caribou in Northeastern Alberta. 

Ph.D. Thesis Submitted to the University of Alberta. Edmonton, AB. 

McCutchen, N. 2006. Factors affecting caribou survival in northern Alberta: the 

role of wolves, moose, and linear features. Ph.D. Thesis Submitted to the 

University of Alberta. Edmonton, AB. 

Seiler, A. 2005. Predicting locations of moose-vehicle collisions in Sweden. J. 

Applied Ecol. 42: 371-382. 

Request 71b How could long sight lines affect predator-prey balances in the RSA? 


Request 71c How could long lines of sight affect woodland caribou? 

Response 71c As stated in the EIA, Volume 5, Section 7.3.4, the local study areas are not 

frequented by woodland caribou. Therefore, long lines of sight are not expected 

to affect woodland caribou in and around the local study areas. 



In response to the question of expected wildlife mortalities associated with the 

tailings pond, Shell states that In the early stages of tailings pond construction 

and use, mammals, such as carnivores, ungulates and rodents, … may be able to 

access the Albian Sands Mine External Tailings Containment Facilities shoreline 

from surrounding undisturbed areas. Individual habituated animals such as 

bears, foxes, and coyotes may use the shoreline and are at risk of contamination. 

72a Why is Shell referring to the Albian Sands Mine External Tailings Containment 

Facility in Response 461d? Answer this question in relation to the Shell Pierre 

River Tailings Areas. 


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Section 13.1 

Response 72a Shell incorrectly mentioned the Albian Sands Mine External Tailings 

Containment Facility when referring to the proposed external tailings disposal 

area (ETDA). The response to the May 2009 Pierre River Mine, Supplemental 

Information, Volume 2, SIR 461d should have referenced Shell’s Pierre River 

Mine ETDA. The corrected response to the original question follows. 

In the early stages of ETDA construction and use, mammals, amphibians and 

reptiles are unlikely to interact with the Pierre River Mine external tailings 

disposal area (ETDA) shoreline from surrounding undisturbed areas. Terrestrial 

wildlife will be further discouraged from accessing the Pierre River Mine ETDA 



As discussed in EIA, Volume 5, Section 7.5.3.2, residual impacts from activities 

associated with the interaction of wildlife with project infrastructure, such as 

mortality associated with the ETDA, after mitigation measures are applied (see 

EIA, Volume 5, Section 7.1.3) are predicted to have a low environmental 

consequence rating for yellow rail and black-throated green warbler, and a 

negligible rating for all other key indicator resources (KIRs), such as Canadian 

toad, barred owl, moose, black bear, Canada lynx, fisher marten and beaver (see 

EIA, Volume 5, Section 7.5.3.2, Table 7.5-36). Interactions with infrastructure 

are reasonably well understood but lack quantification. Therefore, prediction 

confidence was rated as moderate. From 2003 to 2008, the Muskeg River Mine 

recorded 70 avian mortalities because of oiling, averaging 11.6 birds per year. 

Total avian mortalities at the Muskeg River Mine from 2003 to 2008 are 119, 

averaging 19.8 birds per year. Regional environmental consequences in the 

Planned Development Case for interactions with infrastructure are predicted to be 

negligible. Shell is continuing to manage its bird deterrent systems to mitigate the 

effects of the ETDA on birds. 

Request 72b What design features and mitigation measures will Shell implement to 

substantially reduce the potential for wildlife to become contaminated during the 

early stages of tailings pond construction and use? 

Response 72b In the early stages of the external tailings disposal area (ETDA) construction no 

tailings will be present. Before tailings are eventually released into the ETDA, a 

7 m-high dyke surrounding the ETDA will be constructed, further discouraging 

terrestrial wildlife from accessing the Pierre River Mine ETDA. 

Shell will continue to manage its bird deterrent systems to mitigate the effects of 

the ETDA on birds. Sensory disturbance from the waterfowl deterrent system 

may also deter other wildlife potentially utilizing the area. Surrounding 

vegetation will be managed to remove all remnant patches of natural habitat to 

ensure that animals are not attracted to the area. If shoreline vegetation growth 

occurs in the ETDA after production begins, the vegetation will be removed with 

herbicide, and muskeg mats that rise to the ETDA surface will be covered with 

tarpaulins until they sink. A zero tolerance policy for wildlife feeding on site will 

help to reduce animal habituation and reduce the removal of nuisance wildlife. 


CR029


Section 13.1 

Request 72c How will the surrounding vegetation be managed to ensure wildlife are not 

attracted to the tailings areas? 

Response 72c As mentioned in AENV SIR 72b, Shell will implement several mitigation 

measures to substantially reduce the potential for wildlife to be attracted to or 

become contaminated by the proposed Pierre River Mine external tailings 

disposal area (ETDA). Surrounding vegetation will be managed to remove all 

remnant patches of natural habitat to ensure that animals are not attracted to the 

area. If shoreline vegetation growth occurs in the ETDA after production begins, 

the vegetation will be removed with herbicide, and muskeg mats that rise to the 

ETDA surface will be covered with tarpaulins until they sink. In addition, a 150 

to 250 m wide buffer of infrastructure, including an access (haul) road and 

several utility rights-of-way will surround the ETDA, further suppressing 

vegetation growth and wildlife use near the Pierre River Mine ETDA. 

Request 72d Discuss the possibility of constructing the dyke around the External Tailings 

Containment Facility (tailings pond) before any tailings are added to further 

reduce the possibility of contamination of wildlife during the early stages of 

development. 

Response 72d As mentioned in AENV SIR 72a, terrestrial wildlife will be further discouraged 

from accessing the Pierre River Mine external tailings disposal area (ETDA) 





It is inappropriate to refer an estimate determined using a multiplier as a raw 

count of abundance. It should be referred to as an estimate. 

73a Do the references provided support multiplying the moose survey numbers by a 

factor of two to account for the 50% visual coverage? 

Response 73a The references provided were not intended to provide support for multiplying 

survey results by a factor of two. Rather, they were mentioned as supportive of 

the aerial survey methods used for estimating ungulate populations in the Shell 

local study areas (LSAs). 

The objective of Shell’s winter aerial ungulate surveys was to detect all 

ungulates, including caribou, deer species and moose, within the Jackpine Mine 

Expansion and Pierre River Mine LSAs. In the study of natural systems, it is 

seldom practical to survey every member of a population, or all locations within 


CR029


Reference 

Section 13.1 

a study area. As a result, it is often necessary to collect a representative sample 

(Zar 1999). 

A line-transect technique was used and surveys were conducted in winter by 

helicopter. Fixed-width transects were spaced 400 m apart and three observers 

surveyed the ground, extending 100 m on either side of each transect, providing a 

total viewing area of 200 m for each transect. The resulting survey coverage was 

50% of the area flown. To compensate for the 50% survey coverage, a correction 

factor of two was applied to the number of individuals of each species observed. 

The density of moose in the LSA was calculated from the estimated number of 

animals in the LSA divided by the area (km 2 ) flown along transect lines in the 

LSA. This method assumes that the density of moose in the LSAs at the time of 

the survey can be determined based on 50% survey coverage (i.e., total estimated 

number of moose in the LSAs is approximately twice the number seen). Shell 

believes this is a reasonable assumption because the systematic line-transect 

technique reduces sampling bias and is representative of the habitat in the LSA. 

Zar, J.H. 1999. Biostatistical Analysis, 4th Edition. Prentice-Hall Inc. Simon and 

Schuster/A Viacom Company. Englewood Cliffs, NJ. 

Request 73b What are the drawbacks to this sampling method? 

Response 73b The potential drawbacks to the sampling method are that: 


• confidence intervals cannot be estimated from a single survey using the line 

transect methodology 

• survey results are an estimate of density and not a raw count of abundance 

Request Volume 2, SIR 465d, Page 23-150 

74a Which of the many… mitigation commitments made by Shell in the EIA, Volume 

5, Terrestrial Resources and Human Environment Section 7.1.3 will function to 

protect the bison in the PRMA? 

Response 74a The question above refers to SIR 468b, rather than 465d as cited in this question. 

Mitigation commitments made by Shell that will function to protect bison during 

construction and operations include: 

• constructing straight roads with long sight lines where feasible 


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• maintaining a 250-m wildlife corridor along the Athabasca River 

Section 13.1 

• providing for wildlife passage under the Athabasca River bridge on both the 

east and west banks of the river 

• designing lighting to reduce light pollution in the adjacent wildlife corridor 

• fencing the approaches to the Athabasca River bridge 

• retaining treed buffers around or near watercourses 

• planning and sharing access with other industrial partners 

• posting wildlife crossing signage where key wildlife crossing areas are 

identified 

• reducing traffic volumes by continuing to transport staff to site using buses 

• enforcing traffic speed limits 

• undertaking dust control on roads 

• prohibiting staff and contractors from hunting and trapping on site 

• providing construction staff with environmental awareness training as part of 

their on-site orientation 

Request Volume 2, SIR 472, Table 472-2, Page 23-166. 

The table lists seven rare lichen species. 

75a Confirm that Shell expects, based on current data, the Shell Pierre River Mine 

and/or Jackpine Mine expansion will regionally and in some cases provincially 

extirpate these seven species. 

Response 75a Shell does not expect that the project will result in the extirpation of these seven 

rare lichen species. Further field surveys would be required to estimate the 

distribution of these seven species within the Oil Sands Region. While many 

known and common lichen species in Alberta have far-ranging distributions (Vitt 

et al. 1988), recent surveys by Golder in the Oil Sands Region has resulted in the 

identification of many species not previously identified in Alberta or that are 

unranked by the Alberta Natural Heritage Information Center (ANHIC). In the 

northeastern boreal region of Alberta, data concerning individual lichens species 

distributions are very limited and therefore the distribution of many species, even 

common species, is uncertain. The lichen flora of Alberta is poorly known, 


CR029


References 

Section 13.1 

especially in the north and eastern portions of the province (Goward 2007, pers. 

comm.). 

Lichens as a group are under-collected, at least in certain regions of North 

America, which has resulted in lack of species presence, abundance and 

distribution information (Thomson and Will-Wolf 2000 website; Esslinger 2006 

website; USGS 2007 website; NatureServe 2009 website). 

Esslinger, T. L. 2006. A Cumulative Checklist for the Lichen-Forming, 

Lichenicolus and Allied Fungi of the Continental United States and 

Canada. North Dakota State University: 

http://www.nusu.nodak.edu/instruct/esslinge/chklst7.htm. (First Posted 1 

December 1997, Most Recent Update 10 April 2006), Fargo North 

Dakota. 

NatureServe. 2009. Explorer, accessed from 

http://www.natureserve.org/explorer/servlet/NatureServe?post_processes= 

PostReset&loadTemplate=nameSearchSpecies.wmt&Type=Reset on 

April 6, 2009. 

Thomson, J.W. and S. Will-Wolf. 2000. Lichenized Fungi Which Appear Rare 

Due to Undercollecting. Wisconsin State Herbarium, Madison, WI, 

website viewed February 20, 2007 

http://www.botany.wisc.edu/Wislichens/LichenTAB-C.htm. 

USGS (United States Geological Survey). 2007. NPLichen, A Database of 

Lichens in the U. S. National Parks. Version 3.5. U. S. Geological Survey. 

http://www.ies.wisc.edu/nplichen. Accessed February 20, 2007. 

Vitt, D. H., J. E. Marsh and R. B. Bovey 1988. Mosses, Lichens and Ferns of 

Northwest North America. Lone Pine Publishing. 296 pp. 

Personal Communication. 2007. Goward, T. Enlichened Consulting Ltd. Personal 

Communication with Darrin Nielsen, Golder Associates Ltd. E-mail 

correspondence. January 11, 2007. 

Request 75b Confirm that Shell is not intending to mitigate these losses. 

Response 75b Shell does not intend to mitigate the loss of these seven rare lichen species within 

the project footprint. See the response to AENV SIR 75a for further discussion. 

Request 75c Confirm that Shell has chosen not to undertake any additional directed surveys to 

establish the presence of these species outside the Project Area. 


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Section 13.1 

Response 75c Because Shell does not expect that the project will result in the extirpation of 

these seven rare lichen species, as discussed in the response to AENV SIR 75a, 

Shell is not planning to undertake additional surveys outside of the project local 

study areas to establish the presence of these species in other areas. 


Request Volume 2, SIR 482a, Page 23-181 ; Volume 2, SIR 510a, Page 23-226. 

In response to the question of why not all listed species were modelled, Shell 

states that Wildlife KIRS were primarily identified based on CEMA SEWG 

ratified indicator list, provincial and federal status, representation across 

ecological stages i.e., wetlands, early and mid successional habitats, and 

taxonomic groupings i.e., mammals, birds and amphibians. Habitat modeling 

was conducted for all species that were chosen as Key Indicator Resources 

(KIRs) … and… Most of the habitat requirements of listed species are 

represented by KIRs. In Table 510-1 used to supplement Shell’s Response 510a, 

Shell indicates that woodland caribou were observed during field surveys in the 

Local Study Area. 

76a Given that woodland caribou seem to fit all of the criteria Shell has listed for 

selection of species for KIR inclusion, why were woodland caribou not selected 

as a KIR for assessment of this project? 

Response 76a Woodland caribou were not selected as a key indicator resource (KIR) for the 

project because the local study areas (LSAs) do not fall within a recognized 

caribou zone, and caribou are transient and therefore are observed in the area 

very infrequently (Golder 2007). One woodland caribou track was observed 

during 2004 winter track surveys in the Jackpine Mine Expansion LSA and no 

woodland caribou sign was located during extensive terrestrial surveys conducted 

within the LSA from 2005 through 2007 (Golder 2007) (see EIA, Volume 5, 

Section 7.3.4, p. 7-37). Interviews with current Registered Fur Management Area 

(RFMA) holders indicate that caribou are present only sporadically, if at all (see 

EIA, Volume 5, Section 7.3.4, p. 7-37). Recognized Caribou Areas are located 

about 15 km east of the Jackpine Mine Expansion LSA (i.e., the Steepbank 

Caribou Area) and 50 km northwest of the Pierre River Mine LSA (i.e., the Birch 

Mountain Caribou Area). 

Reference 

Golder (Golder Associates Ltd.). 2007. Wildlife and wildlife habitat 

environmental setting for the Jackpine Mine Expansion and Pierre River 

Mine Project. Submitted to Shell Canada Ltd. December, 2007. 191 pp. 


CR029


Section 13.1 

Request 76b Which KIR represents the habitat requirements of woodland caribou? Explain 

how this listed species is represented by one or several of the KIRs. 

Response 76b The KIRs that could represent the habitat requirements of woodland caribou in 

the LSA are lichen – jackpine communities and peatlands. These two KIRs are 

considered primary habitat for woodland caribou in northeastern Alberta (Stelfox 

1993). These KIRs represent potential rather than realized caribou habitat 

because caribou are observed in the area very infrequently (Golder 2007), the 

LSAs do not fall within a recognized caribou zone and habitat in proximity to 

Base Case industrial development is of reduced value to caribou as a result of 

sensory disturbance (Dyer et al. 2001). 

References 


Dyer, S.J., J.P. O'Neil, S.M. Wasel and S. Boutin. 2001. Avoidance of Industrial 

Development by Woodland Caribou. Journal of Wildlife Management. 

65: 531-542. 

Golder (Golder Associates Ltd.). 2007. Wildlife and wildlife habitat 


Mine Project. Submitted to Shell Canada Ltd. December, 2007. 191 pp. 

Stelfox, J.B. (ed.). 1993. Hoofed Mammals of Alberta. Lone Pine Publishing. 

Edmonton, AB. 241 pp. 


Shell asserts that Currently the RSF model produced by Dr. Anne Hubbs is the 

best available data on barred owls. In discussion of Shell’s response with Dr. 

Anne Hubbs, she indicates the use of Mike Russell’s RSFs (M.Sc, Thesis 2008 – 

University of Alberta) would be more appropriate as they account for individual 

variability and edge effects which Anne’s model did not directly address. 

77a Provide a revised assessment using Mr. Russell’s work or an explanation of why 

Mr. Russell’s RSFs are not applicable to Shell’s project. 

Response 77a Mike Russell’s thesis was not published until the spring of 2008 (Russell 2008) 

and was not made available to Shell until November 2009 (Russell 2009, pers. 

comm.). The EIA was submitted in December 2007. Habitat suitability models 

are refined over time as ecological knowledge advances and new data become 

available. Shell contends that it would not be appropriate to re-work analyses or 

assessments based on incremental methodology refinements made subsequent to 

the time that the EIA was being produced, unless a qualitative assessment of 

those refinements suggests a basis for doing so. 


CR029


References 


Section 13.1 

Accordingly, if Mike Russell’s RSF model were to be implemented in this 

assessment, it is very unlikely that the model would result in a change to the 

environmental consequence for the effect of the project on barred owl habitat. 

First, proximity to disturbance would likely have little effect on model output 

(Russell 2010, pers. comm.). Second, avoidance of disturbed areas in the model 

is likely a reflection of the landscape in which the model was developed. Data for 

model development was collected in an agricultural landscape with large open 

fields (Russell 2008). Barred owls were likely avoiding open fields because such 

areas have relatively high densities of great horned owls, which are predators of 

barred owls (Russell 2008). In contrast, industrial disturbances created by the 

project are unlikely to result in productive foraging habitat for great horned owls. 

Therefore, barred owls may avoid edges created by industrial disturbance less 

than they avoid edges created by agricultural or forestry activity. 

Russell, M.S. 2008. Habitat selection of barred owls (Strix varia) across multiple 

spatial scales in a boreal agricultural landscape in north-central Alberta. 

M.Sc. Thesis. University of Alberta, Edmonton. 

Personal Communication. Russell, M. 2010. Telephone communication with 

Brock Simons (Golder Associates Ltd.). January 13, 2010. 

Personal Communication. Russell, M. 2009. Email communication with Brock 

Simons (Golder Associates Ltd.). November 2, 2009. 

Request Volume 2, SIR 486-490, Page 23-188. 

Shell states that formal validation of HSI models through additional data 

collection is unnecessary to adequately characterize the impacts of the project. 

Models are simply tools and without data to support an HSI for species where 

habitat use knowledge is limited, confidence in the impacts predictions are 

necessarily suspect. 

78a How does Shell support its impact predictions for indicators where the HSI is 

unvalidated and there are insufficient data to assess whether the model is 

predicting appropriately? 

Response 78a Data for black bear, beaver and yellow rail are not available. Therefore, the 

habitat suitability index (HSI) models for these species could not be validated 

with empirical data. However, as rational, explicit expressions of the well 

understood habitat associations for these species, these expert-based HSI models 

have been conceptually validated and are therefore useful assessment tools. 

Validation of habitat suitability models with empirical data may be performed 


CR029


References 

Section 13.1 

when appropriate data are available. It is also important that models are 

conceptually validated to ensure that the theories and assumptions each model is 

based on are correct (Rykiel 1996). 

Model structure and output for the black bear, beaver and yellow rail HSI models 

correspond with well understood habitat associations and ecological relationships 

for those species. Black bears in central Alberta will opportunistically eat meat, 

but rely on berries in summer and early fall (Ruff 1978; Young and Ruff 1982) 

while using dense shrub cover and mature forest for security cover (Zapisocki et 

al. 1998). Black bears often avoid human disturbances (Aune 1994). When black 

bears are habituated and do not avoid disturbance, mortality risk increases 

(Manville 1983). The black bear HSI model incorporates expert ecological 

knowledge from the region to combine these well-established habitat associations 

and habitat risks into a mathematical equation. Beavers feed primarily on 

deciduous shrubs and trees within 100 m of water (Jenkins 1980, Novak 1999), 

and the beaver HSI expresses these known relationships. Yellow rail breeding 

habitat generally consists of fresh or brackish shallow wet meadows and sedge 

marshes with little to no woody vegetation (Goldade 2002; Prescott et al. 2002). 

In the Oil Sands Region, this equates to graminoid fen (FONG), shrubby fen 

(FONS) or graminoid marsh (MONG) wetlands types (Halsey et al. 2003), which 

are identified as habitat by the yellow rail HSI model. Model validation is 

important for evaluating model reliability (Conroy et al. 1995). However, the 

presence and abundance of wildlife species is affected by many factors, and can 

become uncoupled from habitat quality (Van Horne 1983). Therefore, validation 

results based on wildlife distribution data can be deceptive. For example, a 

species may inadvertently select habitats that contain elevated mortality risk, in 

which case a successfully validated model will predict that hazardous habitats are 

in fact high quality (Falcucci et al. 2009). Ideally, validation data would represent 

the survival rate, birth rate, and carrying capacity per habitat type, which is 

needed to truly assess habitat quality (Van Horne 1983). Unfortunately, data on 

demographic parameters are very difficult to collect, and are rarely available. 

This is not to suggest that habitat suitability models should not be validated with 

presence or abundance data, as this is commonly all that are available. Rather, it 

is important to note that an impact assessment is limited by the availability of 

data and assessment tools. The intent of an EIA is to use the best available data to 

assess the effects of the project and to outline uncertainty around the effects 

assessment. In the absence of available validation data or validated models, the 

alternative to using expert-based, but unvalidated, HSI models would be to use 

no quantitative tools for assessing the effects of the project on black bear, beaver 

and yellow rail habitat. To remove the output of these useful models from the 

assessment would be a step backwards in the quality and thoroughness of the 

assessment for wildlife key indicator resources (KIRs). 

Aune, K.E. 1994. Comparative ecology of black and grizzly bears on the Rocky 

Mountain Front, Montana. International Conference on Bear Research 

and Management 9: 365-74. 


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Section 13.1 

Conroy, M.J., Y. Cohen, F.C. James, Y. G. Matsinos, B.A. Maurer. 1995. 

Parameter estimation, reliability, and model improvement for spatially 

explicit models of animal populations. Ecological Applications 5(1):17- 

19. 

Falcucci, A., P. Ciucci, L. Maiorano, L. Gentile and L. Boitani. Assessing habitat 

quality for conservation using an integrated occurrence-mortality model. 

Journal of Applied Ecology 46: 600-609. 

Goldade, C.M., J.A. Dechant, D.H. Johnson, A.L. Zimmerman, B.E. Jamison, 

J.O. Church and B.R.Euliss. 2002. Effects of Management Practices on 

Wetland Birds: Yellow Rail. North Prairie Research Center, Jamestown. 

Halsey, L.A., D.H. Vitt, D. Beilman, S. Crow, S. Mehelcic and R. Wells. 2003. 

Alberta Wetlands Inventory Standards, Version 2.0. Alberta Sustainable 

Resource Development, Resource Data Branch, Edmonton, AB. 54 pp. 

Jenkins, S.H. 1980. A Size-Distance Relation in Food Selection by Beavers. 

Ecology. 61: 740-746. 

Manville, A.M. 1983. Human impact on the black bear in Michigan's lower 

peninsula. International Conference on Bear Research and Management 

5: 20-33. 

Novak, M. 1999. Beaver. Wild Furbearer Management and Conservation in 

North America, Section IV: Species Biology, Management and 

Conservation. 

25: 282-312. 

Prescott, D.R.C., M.R. Norton and I.M.G. Michaud. 2002. Night surveys of 

yellow rails, Corturnicops noveboracensis, and Virginia rails, Rallus 

limicola, in Alberta using call playbacks. The Canadian Field Naturalist. 

116(3): 408-415. 

Ruff, R.L. 1978. A Study of the Natural Regulatory Mechanisms Acting on an 

Unhunted Population of Black Bears near Cold Lake, AB. Proj. Rep. 

Dept Wildl. Ecol., Univ. Wisc., Madison. 107 pp. 

Rykiel Jr., E.J. 1996. Testing ecological models: the meaning of validation. 

Ecological Modelling 90: 229-244. 

Young, B.F. and R.L. Ruff. 1982. Population Dynamics and Movements of Black 

Bears in East Central Alberta. Journal of Wildlife Management. 46: 845- 

860. 

Van Horne, B. 1983. Density as a Misleading Indicator of Habitat Quality. 

Journal of Wildlife Management 47(4):893-901. 

Zapisocki, R., M. Todd, R. Bonar, J. Beck, B. Beck and R. Quinlan. 1998. Black 

Bear Summer/Fall Habitat: Habitat Suitability Index Model Version 5. 

Foothills Model Forest. Hinton, AB. 


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Section 13.1 

Request 78b Provide a plan and schedule of implementation to augment the data collected to 

support the HSI models presented. 

Response 78b The HSI models for black bear, beaver and yellow rail have been conceptually 

validated and are therefore useful assessment tools (see response to AENV SIR 

78a). If appropriate data were available, validation with empirical data would be 

pursued. Unfortunately, data appropriate for the black bear, beaver and yellow 

rail HSI models are not available, and would be extremely difficult to obtain. 

Shell does not propose to collect additional empirical data to validate the HSI 

models. 

Black bears hibernate during winter, and therefore data on black bear distribution 

cannot be collected along with data for most other mammalian KIRs during 

winter track surveys. Black bear presence within the local study areas (LSAs) has 

been confirmed with bait station cameras (Golder 2007). However, baiting 

introduces bias that precludes the inference of habitat associations from bait 

camera data. Generally, unbiased location data for black bears can be collected 

using telemetry collars (Brody and Pelton 1989; Kasworm and Manley 1990; 

Lyons et al. 2003; Czetwertynski 2008). Shell has attempted to obtain black bear 

telemetry data that was utilized in a Ph.D. thesis at the University of Alberta, but 

has been unsuccessful (Boyce 2009, pers. comm.). Fitting black bears with 

telemetry collars for HSI model validation is beyond the scope of the EIA, as 

defined in the Terms of Reference (TOR) (AENV 2007). 

A fall beaver-muskrat aerial survey was performed in conjunction with waterfowl 

surveys in 2005 in the Jackpine Mine Expansion LSA and in 2005 and 2006 in 

the Pierre River Mine LSA (Golder 2007). However, these surveys are not 

conducted by randomly sampling the LSAs, but by systematically focusing 

survey effort on watercourses. Therefore, existing beaver-muskrat survey data is 

biased and is unsuitable for HSI model validation. As the beaver HSI model 

predicts that areas in an immediately adjacent to water are high quality habitats 

for beaver, model predictions do conform to the available data. Conducting a 

systematic aerial survey of the LSAs for beaver activity would be beyond the 

scope of the EIA, as defined by the TOR (AENV 2007). 

Yellow rails are distributed too sparsely in the Oil Sands Region for independent 

data suitable for model validation to be available. Yellow rail breeding habitat 

generally consists of fresh or brackish shallow wet meadows and sedge marshes 

with little or no woody vegetation (Goldade et al. 2002). In the Oil Sands region, 

this equates to graminoid fen (FONG), marsh (MONG) and shrubby fen (i.e., 

FONS) wetlands types (Halsey et al. 2003), as designated in the yellow rail HSI 

model. Between 2003 and 2009, 16 yellow rails were recorded in five different 

project areas in the Oil Sands Region. Twelve of the 16 detections occurred in 

graminoid fen (FONG) or shrubby fen (FONS) habitat. Therefore, the yellow rail 

HSI model output does conform with the available data for the species. 


CR029


References 

Section 13.1 

AENV (Alberta Environment). 2007. Final terms of reference Environmental 

Impact Assessment (EIA) report for the Shell Canada Limited Jackpine 

Mine Expansion and Pierre River Mine. 32 pp. 

Brody, A.J, M.R. Pelton. 1989. Effects of roads on black bear movements in 

western North Carolina. Wildlife Society Bulletin 17: 5-10. 

Czetwertynski, S.M. 2008. Effects of hunting on the demographics, movement, 

and habitat selection of American black bears (Ursus americanus). PhD 

Thesis. University of Alberta, Edmonton, Alberta. 153 pp. 

Goldade, C.M., J.A. Dechant, D.H. Johnson, A.L. Zimmerman, B.E. Jamison, 

J.O. Church and B.R. Euliss. 2002. Effects of Management Practices on 

Wetland Birds: Yellow Rail. Northern Prairie Wildlife Research Centre, 

Jamestown. 21 pp. 

Golder Associates Ltd. (Golder). 2007. Wildlife and wildlife habitat 


Mine Project. Prepared for Shell Canada Ltd. 185 pp. 

Halsey, L.A., D.H. Vitt, D. Beilman, S. Crowe, S. Melhelcic and R. Wells. 

Alberta Wetlands Inventory Standards, Version 2.0. Alberta Sustainable 

Resource Development, Resource Data Branch, Edmonton. 54 pp. 

Kasworm, W.F. and T.L. Manley. 1990. Road and trail influences on grizzly 

bears and black bears in northwest Montana. International Conference on 

Bear Research and Management 8: 79-84. 

Lyons, A.L., W.L. Gaines and C. Servheen. 2003. Black bear resource selection 

in the northeast Cascades, Washington. Biological Conservation 113: 55- 

62. 

Personal Communication. 2009. Boyce, M. Email communication to Brock 

Simons (Golder). November 9, 2009. 


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HEALTH 


Section 14.1 

Shell was asked to discuss the response/mitigation plan for odour complaints. 

Shell states The existing Muskeg River Mine HSE management system will serve 

as the basis for health, safety and the environment (HSE) management system at 

the Pierre River Mine. 

79a Provide a copy of the HSE management system to help clarify the odor 

response/mitigation actions that take place in the event of a complaint. 

Response 79a The following provides excerpts from Shell’s health, safety and the environment 

(HSE) work practice manual, which is used at the Muskeg River Mine to respond 

to public or stakeholder complaints, including complaints about odours. 

The following outlines the process for handling public and stakeholder 

complaints: 

• the Security Dispatcher working 24/7 will be the focal point for receiving, 

recording, and forwarding complaints from stakeholders 

• only certain personnel, or their designates, are authorized to provide 

responses to complaints from the public and stakeholders 

• individuals will respond to stakeholder complaints only after they have been 

designated and briefed by the manager responsible 

• if a team member receives a complaint via phone or e-mail on Albian site, he 

or she will forward the phone call to Security, and e-mail it to the senior 

security specialist. If a verbal complaint is received off site, the team member 

will advise the individual to call Albian Security. 

The security dispatcher will carry out the following: 

• record all complaints from the public, outside sources, or regulatory 

authorities on the Public/Stakeholder Complaint form. Obtain as much 

information as possible from the caller, including a name and phone number 

where he or she could be contacted with a response to the complaint. 


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HEALTH AENV SIRS 79 – 89 


Section 14.1 

• notify the appropriate team of the complaint, such as Environment, External 

Affairs, Health, Safety & Emergency Response, Human Resources and 

Mining. If no team is known, direct the complaint to the security shift team 

leader or the on-call manager. 

• forward the completed Public/Stakeholder Complaint form to the appropriate 

team for action, with a copy to the Manager, External Affairs. 

• If the complaint is related to a major spill, release, or traffic disruption, 

which could endanger lives or property, immediately notify the Emergency 

Response Team (ERT). The ERT will address the situation according to 

established protocols. 

The responsible manager or team leader will carry out the following: 

• upon receiving a call from Security about a complaint, obtain all the relevant 

information and a copy of the Public/Stakeholder Complaint form 

• initiate a report based on the available information 

• conduct an investigation of the complaint, take appropriate action to correct 

the situation, and develop a response 

• review the response with the manager responsible for external affairs 

• if designated to do so, contact the person who had complained and provide a 

response on Albian’s behalf 

• complete the Public/Stakeholder Complaint form, brief the manager of 

external affairs, and provide a copy of the completed form 

• complete the SIRS report and communicate the findings to affected parties 

• forward a copy of the report to the consultation database 


In Table 58-1, Shell presents three-minute odour predictions. 

80a Clarify the substance the predictions represent. 

Response 80a The substances included in the odour assessment are shown in the EIA, 

Volume 3, Section 3.4.7.2, Tables 3.4-26 and 3.4-27. 


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Section 14.1 

Shell was asked to provide the predicted air concentrations that were used to 

compare to the odour thresholds. This information was not provided. 

81a Provide predicted air concentrations and compare them to odour thresholds. 

Assess the results. 

Response 81a Refer to the response to AENV SIR 82 for a complete odour assessment, 

including the predicted three-minute peak air concentrations and odour 

thresholds used to determine the contribution of project emissions to potential 

odours in the area. 



Shell was asked to provide the odour assessment for the PDC. This information 

was not provided. 

82a Provide this information. 

Response 82a In light of the supplemental information request, an odour assessment was 

completed using an alternative approach to the one originally presented in the 

EIA. Similar to the original odour assessment, the objective of the current 

assessment is to determine the potential contribution of project emissions to 

noticeable odours in the area. 

Guiding Principles 

It is important to recognize that odours are most commonly observed over a 

period ranging from a few seconds to a few minutes. As such, the assessment is 

based on predicted three-minute peak concentrations of the chemicals of potential 

concern (COPCs). 

The sense of smell is influenced by a variety of factors, such as individual, 

environmental or substance-based factors. On an individual level, a person’s 

ability to detect an odour can depend on their innate olfactory powers (i.e., 

“acuteness” of smell), their attentiveness to the matter or their prior experience 

with that particular odour. Another strong factor that influences the sense of 

smell is the ability of the substance to excite the olfactory receptors. This is 

determined by the molecular structure and physical properties of the substance. 

These individual and substance-based factors, in combination with a number of 

environmental influences known to affect detection of odours, highlight the 


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Section 14.1 

complexity surrounding the sense of smell. This complexity should be respected 

as part of any odour assessment. Table AENV 82-1 lists the factors that influence 

sense of smell. 

Table AENV 82-1: Factors Affecting Sense of Smell 

Category Influences 

Individual Innate power of smell 

Age 

Sex 

Prior experience with odour 

State of health 

Degree of attentiveness 

Environment Temperature 

Humidity 

Wind speed and direction 

Chemical Molecular structure 

Stability/reactivity 

Physical properties (e.g., vapour 

pressure, water solubility) 

Source: Ruth (1986); Amoore and Hautala (1983) 

Because chemical exposures rarely occur in isolation, the number of components 

in a mixture will further influence an individual’s ability to detect, identify and 

discriminate the components of mixtures. Odourants in mixtures appear to be 

processed and perceived in series. Studies indicate that odourants are temporally 

processed with up to several hundred milliseconds separating individual 

constituents. Odourants determined to be “fast” were found to suppress the 

“slow” odourants. This was attributed to their relative chemical polarities, which 

affect access to and competition for membrane receptor sites in the olfactory 

epithelium (Laing et al. 1994a; Bell et al. 1987). 

A study that examined the interactions of odourants emitted from sewage 

treatment plants (including hydrogen sulphide) measured the perceived odour 

intensity or strength of the individual components alone and in mixtures. The 

odour characteristics and the unpleasantness of the mixtures were also measured 

(Laing et al. 1994b). The authors found the following: 

• The perceived odour intensity of mixtures was equal to or greater than that of 

any of the individual constituents, but less than the sum of their intensities. 

As the number of constituents in the mixtures increased, the intensity of the 

mixture was typically attributable to the intensity of the most dominant 

odourant. 

• The intensity of an odourant was never enhanced by another (i.e., no 

synergistic interactions were observed). 


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Methods 

Section 14.1 

• The greater the number of odourants in the mixture, the more difficult it was 

to identify the individual constituents. 

• The greater the number of components in the mixture, the greater the degree 

of suppression of the individual constituents. 

• Hydrogen sulphide was the least frequently suppressed odourant. 

• The unpleasantness of the odourant mixture was typically greater than that of 

the individual constituents, indicating that models for predicting complaint 

levels in communities affected by odourous mixtures, but which are based on 

single odourants, will usually underestimate the number of complaints. 

This assessment evaluated almost 400 chemicals through the use of chemical 

fractions and surrogates. As such, many of the odourants assessed might never be 

detected. However, other odourants, such as hydrogen sulphide, are not typically 

suppressed and make it very difficult to accurately predict the perceived intensity 

of the odourous mixture. 

It is possible that the individual odours could “cumulatively” register as a 

nuisance. However, current information on odourous mixtures does not indicate 

that hydrogen sulphide or any other odourants will be perceived at concentrations 

lower than the odour based air quality objectives or reported odour thresholds as 

a result of the odourant mixture. 

Potential odours were assessed by comparing three-minute peak COPC air 

concentrations with established odour thresholds. Three-minute peak 

concentrations were derived from the highest predicted one-hour ground-level air 

concentrations (i.e., including the eight highest one-hour predictions) using the 

following equation: 

C3-min = C1-hr x 3 minute multiplier 

C3-min = C1-hr x (60 min/3 min) 0.2 

Where: 

C3-min = predicted three-minute peak concentration 

C1-hr = predicted one-hour concentration 

0.2 = exponent for the three-minute multiplier based on 

neutral atmospheric conditions (OMOE 1996; Duffee et 

al. 1991). 

Three-minute peak concentrations were estimated for the COPCs given that 

odours can appear instantaneously and are commonly observed over very short 

periods. The potential for COPCs to contribute to nuisance odours was assessed 

as follows: 


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Section 14.1 

• The maximum three-minute peak air concentrations were predicted for the 

cabin residents, Aboriginal residents and community residents in the area. 

• The three-minute peak air concentrations were compared with the 

corresponding odour threshold for each assessment case (i.e., Base Case, 

Application Case and Planned Development Case). 

As the three-minute peak air concentrations were derived from the highest 

predicted one-hour ground-level air concentrations, the COPC concentrations 

that might be encountered under most circumstances may be exaggerated. This 

would result in conservative odour estimates. 

Determining the Threshold of Odour 

Critical to determining the likelihood of the project’s contribution to noticeable 

odours is the need to understand the intrinsic odourous properties of the various 

chemicals emitted, including their odour thresholds. The odour threshold refers to 

the lowest concentration of a chemical that can be detected by smell following 

presentation of the chemical in a clean, controlled environment, without 

influence of any outside odours (Ruth 1986). 

Odour thresholds are typically determined in clinical setting-type studies. A 

panel of subjects is presented with a series of concentrations of the same 

chemical in air or water and asked to record at what concentration the odour is 

first detected. These studies are difficult to compare as they often differ in sample 

presentation, panel selection, purity of the chemical used and data interpretation. 

Further, the definition of an odour threshold can vary across studies. In some 

cases, the odour threshold is the point at which an odour was detected and in 

other cases, the odour threshold is the point at which the odour was recognized. 

As a result, a wide variation in odour thresholds is reported in the scientific 

literature for most chemicals, including the COPCs associated with the project. 

For some chemicals, odour can act as a safeguard against adverse health effects. 

Under these circumstances, the odour threshold is lower than the concentration 

determined to produce toxicity. Odour may not serve as a warning against 

adverse health effects if the odour threshold is much higher than the 

concentration required to produce toxicity. Therefore, the presence of an odour 

might or might not serve as a warning. Health Canada, however, considers any 

detectable odour to have the potential to adversely affect human health. For 

instance, the presence of a strong odour could potentially lead to increased stress 

in an individual. 

For the odour threshold values assumed in the assessment, see Table 

AENV 82-2. In order to maintain consistency with the original odour assessment 

(see EIA, Volume 3, Section 3.4.7), the odour threshold values provided for the 

total reduced sulphur compounds and volatile organic compounds in Table 

3.4-26 and Table 3.4-27, respectively, of the EIA were used in the alternate 

approach (see Table AENV 82-2). For the chemical groups, odour threshold 

values were determined by calculating the geometric mean of available odour 

thresholds in the scientific literature (AIHA 1997; Amoore and Hautala 1983; 


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Section 14.1 

ASHRAE 1981; AWMA 2000; Fazzalari 1991; NIH 2004, website; Ruth 1986; 

US EPA 1992; van Gemert and Nettenbreijer 1977). For most COPCs, the mean 

odour thresholds and range of values reported in the literature are listed. The 

lower the odour threshold, the more odorous the chemical. The lower end of the 

range represents the “minimum” odour threshold. 

Metals were not included in the odour assessment as information regarding odour 

character and odour thresholds was not available. 

Table AENV 82-2: Odour Characteristics and Thresholds 

Odour Threshold 

(µg/m 3 Chemical of Potential Concern 

) 

1 Odour Character 1 Mean Range 

1,1-Dichloroethane Chloroform 1,139,323 216,339 to 6,000,094 

1,1,1-Trichloroethane Sweet, etherish 611,528 88,000 to 4,249,619 

1,1,1,2-Tetrachloroethane – – – 

1,1,2-Trichloroethane – 54,387 2,976 to 993,959 

1,1,2,2-Tetrachloroethane Solvent 10,094 1,722 to 59,160 

1,2-Dichloroethane Sweet 162,019 17,500 to 1,500,000 

1,2-Dichloropropane Sweet 1,774 1,200 to 2,621 

1,3-Butadiene Aromatic, rubber 6,312 217 to 183,410 

1,3-Dichloropropene – –


Table AENV 82-2: Odour Characteristics and Thresholds (cont’d) 


(µg/m 3 ) 

Chemical of Potential Concern 1 Odour Character 1 Mean Range 

Cumene Sharp 430 17 to 6,400 

Cyclohexane Pungent, solvent, oil 72,793 1,800 to 2,943,788 

Dichlorobenzene Camphor, mothballs 1,080 730 to


Section 14.1 

• With the exception of the aliphatic aldehyde group concentrations at the 

neighbouring cabins, maximum predicted air concentrations for all COPCs, 

lifestyle categories (i.e., cabin, Aboriginal and community residents) and 

assessment cases were less than their respective mean odour thresholds. 

• The project’s contribution to odour in the area is generally very small, 

indicated by the similarities between maximum predicted peak air 

concentrations for the Base Case and Application Case. 

• In many instances, maximum predicted peak air concentrations are less than 

the minimum reported odour thresholds. 

The maximum predicted three-minute air concentration of the aliphatic aldehyde 

group exceeded its mean odour threshold of 107 µg/m 3 at Cabin K under each 

development case. Maximum predicted peak concentrations of the aliphatic 

aldehyde group increased from 118 µg/m 3 under the Base Case to 119 µg/m 3 

under the Application Case and 132 µg/m 3 under the Planned Development Case 

(PDC), indicating that, although exceedances were identified in the Base Case, 

project emissions could influence odours relating to the aliphatic aldehyde group 

at Cabin K. Maximum predicted three-minute concentrations of the aliphatic 

aldehyde group were below the mean odour threshold at all remaining cabin 

locations under all three assessment cases. 

Based on the exceedances of the mean odour threshold, individuals living or 

working in the vicinity of Cabin K might experience odours described as 

pungent. Odours associated with some aldehydes are very fragrant, while others 

may smell like rotten fruit. These odours are primarily associated with the Base 

Case predictions and are likely to be sporadic, rather than continuous. 

Predicted maximum peak air concentrations exceeded the minimum reported 

odour thresholds for a number of COPCs for one or more lifestyle category. 

These include: 

• Acetaldehyde 

• Aliphatic aldehyde group 

• Aliphatic C5-C8 group 



• Aromatic C9-C16 group 

• Cumene 

• Formaldehyde 

• Hydrogen sulphide 

• Mercaptan group 

• Methyl ethyl ketone group 

• Nitrogen dioxide 

• Thiophene group 

• Toluene 

• Trimethylbenzenes 

• Xylenes 


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Section 14.1 

Individuals with very keen senses of smell might detect odours at levels above 

the minimal odour thresholds. However, only 7% of the population is thought to 

be made up of individuals hypersensitive to particular odours (Gouronnec and 

Tomasso 2000). As such, area residents with a keen sense of smell may be able 

to detect a number of different odours, but the majority of residents would be 

unaffected as maximum predicted concentrations are below mean odour 

thresholds. 

As well, the potential odours from a number of COPCs, especially the chemical 

groups, are likely to have been overestimated because of their low minimum 

odour thresholds. There is a wide variation in reported odour thresholds as a 

result of different methods used to determine odour thresholds. In some studies, 

the odour threshold is the level at which 50% of the panel subjects noticed or 

recognized and described the odour. Whereas, in other studies, the odour 

threshold is determined based on a 100% panel response. Odour thresholds based 

on the lowest concentration detected by a single subject (the so-called “absolute” 

threshold) are often a very low value. These variations in reporting findings 

result in a wide range of odour threshold values. 

It is difficult to predict potential odours from the project as the methods for 

testing olfactory responses occur in controlled, artificial environments that are 

different from normal ambient conditions. Odour thresholds are determined in a 

laboratory setting where the chemical is mixed with a highly purified gas, 

standardized, and subjected to a trained odour panel. These conditions are 

unnatural and do not reflect true ambient conditions. Odour intensities in the field 

have reportedly been shown to poorly correlate with odour concentrations 

measured in the lab (Zang et al. 2002). Further, sensitivities to odours are often 

exaggerated in a laboratory setting, suggesting that laboratory derived odour 

thresholds may be conservative. As such, assessing potential odour impacts 

should consider natural ambient conditions, such as shifting weather conditions, 

constant movement of people and the intermittent nature of some of the emission 

sources. These ambient conditions can lead to continuously changing odours at 

the individual’s breathing level. Overall, odours associated with the COPCs are 

likely to be sporadic, rather than continuous. 

Potential odour effects are complicated by the presence of chemical mixtures. As 

discussed previously, scientific studies have determined that large numbers of 

odourants in the mixture can result in difficulty identifying the individual 

constituents. The degree of possible suppression of the individual odourants also 

increases with larger numbers of odourants in mixtures (Bell et al. 1987; Laing et 

al. 1994a; Jinks and Laing 2001). 

Therefore, although some of the chemical mixtures (i.e., aliphatic C5-C8 group, 

aliphatic C9-C16 group, aliphatic C17-C34 group, aromatic C9-C16 group, 

mercaptan group, methyl ethyl ketone group, thiophene group, and 

trimethylbenzenes) exceed their minimal odour thresholds, this is not likely to 

result in nuisance odours. Further, the minimum odour thresholds for these 

mixtures are based on the minimum of all the individual chemical constituents of 

the group, rather than on the chemical mixture as a whole. As a result, the 


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minimum odour threshold of the individual constituent is likely to be a 

conservative estimate for the chemical group. 

Section 14.1 

The possibility that some individuals might detect nuisance odours from a few of 

the COPCs cannot be entirely dismissed. The following factors need to be 

considered: 

• A large majority of the COPCs that exceeded their respective minimum 

odour thresholds have very low odour thresholds and distinctive odours, 

making them very recognizable. 

• The presence of individuals possessing a “keen” sense of smell is possible. 

Women and children often have a remarkable sense of smell and can detect 

and distinguish odours at low levels. 

• Individual variables, such as breathing patterns, state of physical health, past 

experiences and state of awareness, can have a considerable bearing on the 

detection of odours. 

Despite this, the exceedances of the minimum and mean odour thresholds (in the 

case of the aliphatic aldehyde group at Cabin K) must be viewed in light of the 

conservative assumptions incorporated in the assessment and with full 

consideration of the complexity of the sense of smell which is influenced by 

individual, environmental, and substance-based factors. In addition, potential 

odours associated with these COPCs are likely to be sporadic, rather than 

continuous. 


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Table AENV 82-3: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Cabin Residents 


(µg/m 3 ) 

Maximum Peak Concentration 

(µg/m 3 ) 2 

Section 14.1 

Chemical of Potential Concern 1 Planned Development 

Mean Range Base Case Application Case 

Case 

1,1-Dichloroethane 1,139,323 216,339 to 6,000,094 0.000066 0.000066 0.000066 

1,1,1-Trichloroethane 611,528 88,000 to 4,249,619 0.00022 0.0038 0.0038 

1,1,2-Trichloroethane 54,387 2,976 to 993,959 0.000089 0.000089 0.000089 

1,1,2,2-Tetrachloroethane 10,094 1,722 to 59,160 0.00011 0.00011 0.00011 

1,2-Dichloroethane 162,019 17,500 to 1,500,000 0.000066 0.000066 0.000066 

1,2-Dichloropropane 1,774 1,200 to 2,621 0.000075 0.000075 0.000075 

1,3-Butadiene 6,312 217 to 183,410 0.59 0.59 0.66 

1,3-Dichloropropene –


Table AENV 82-3: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Cabin Residents (cont'd) 


(µg/m 3 ) 


(µg/m 3 ) 2 

Section 14.1 

Chemical of Potential Concern 1 Planned Development 

Mean Range Base Case Application Case 

Case 

Ethylene 154,938 20,000 to 1,200,295 18 18 20 

Ethylene dibromide 76,800 76,800 to 76,800 0.00012 0.00012 0.00012 

Formaldehyde 18,726 27 to 13,088,069 42 43 47 

Hexane 468,301 230,000 to 953,502 724 724 883 

Hydrogen sulphide 14.1 0.1 to 2,000 13 13 13 

Mercaptan group 2.8 0 to18,000 1.5 1.5 1.5 

Methanol 1,057,355 4,300 to 260,000,000 0.0070 0.0070 0.0070 

Methyl ethyl ketone group 13,157 16 to 1,900,000 24 24 27 

Methylene chloride 94,106 4,100 to 2,160,000 0.000056 0.000056 0.000056 

Naphthalene group 440 7 to 5,340 0.29 0.29 0.33 

Nitrogen dioxide 730 1.2 to


Table AENV 82-4: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Aboriginal Residents 

Section 14.1 


(µg/m 3 ) 


(µg/m 3 ) 2 

Chemical of Potential Concern 1 Mean Range Base Case Application Case Planned Development Case 







1,3-Butadiene 6,312 217 to 183,410 0.28 0.28 0.29 



Table AENV 82-4: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Aboriginal Residents (cont'd) 

Section 14.1 


(µg/m 3 ) 


(µg/m 3 ) 2 




Hexane 468,301 230,000 to 953,502 480 480 581 

Hydrogen sulphide 14.1 0.1 to 2,000 2.4 2.4 3.6 


Methanol 1,057,355 4,300 to 260,000,000 0.35 0.35 0.35 






Table AENV 82-5: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Community Residents 


(µg/m 3 ) 


(µg/m3) 2 

Section 14.1 








1,3-Butadiene 6,312 217 to 183,410 0.28 0.28 0.29 



Table AENV 82-5: Comparison of Predicted Peak Air Concentrations with Odour Thresholds – Community Residents (cont'd) 


(µg/m 3 ) 


(µg/m3) 2 

Section 14.1 




Hexane 468,301 230,000 to 953,502 480 480 581 

Hydrogen sulphide 14.1 0.1 to 2,000 2.4 2.4 2.6 


Methanol 1,057,355 4,300 to 260,000,000 0.35 0.35 0.35 






References 

Section 14.1 

AIHA (American Industrial Hygiene Association). 1989. Odour Thresholds for 

Chemicals with Established Occupational Health Standards. AIHA Press. 

Alberta Energy and Utilities Board. 

AIHA (American Industrial Hygiene Association). 1997. Odor Thresholds for 

Chemicals with Established Occupational Health Standards. Fairfax, 

VA. 

Amoore, J.E. and E. Hautala. 1983. Odour as an aid to chemical safety: odor 

thresholds compared with threshold limit values and volatiles for 214 

industrial chemicals in air and water dilution. J. Appl. Toxicol. 3(6): 

272–290. 

ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning 

Engineers). 1981. ASHRAE Fundamentals Handbook. Chapter 12. 

AWMA (Air and Waste Management Association). 2000. Air Pollution 

Engineering Manual, Second Edition. Wayne T. Davis (ed.). John 

Wiley & Sons, Inc. Toronto, ON. 

Bell, G.A., D.G. Laing and H. Panhuber. 1987. Odour mixture suppression: 

evidence for a peripheral mechanism in human and rat. Brain Research 

426(1): 8–18. 

Duffee, R.A., M.A O’Brien and N. Ostojic. 1991. Recent developments and 

current practices in odour regulations, controls and technology. Odour 

Modeling – Why and How. Air and Waste Management Association 

Transactions Series No. 18: 289–306. 

Fazzalari, F. A. 1991. Compilation of Odor and Taste Threshold Values Data. 

American Society for Testing and Materials. DS 48A. 

Gouronnec, A.M. and V. Tomasso. 2000. Measurement of odours by sensory 

analysis or “olfactometry.” ANALUSIS 28(3): 188–199. 

Jinks, A. and D.G. Laing. 2001. The analysis of odor mixtures by humans: 

evidence for a configurational process. Physiology and Behavior 72: 51– 

63. 

Laing, D.G., A. Eddy, G.W. Francis and L. Stephens. 1994a. Evidence for the 

temporal processing of odor mixtures in humans. Brain Research 651(1- 

2): 317–328. 

Laing, D.G., A. Eddy and D.J. Best. 1994b. Perceptual characteristics of binary, 

trinary, and quaternary odor mixtures consisting of unpleasant 

constituents. Physiology and Behavior 56(1): 81–93. 

NIH (National Institutes of Health U.S. National Library of Medicine). 2004. 

Haz-Map: Occupational Exposure to Hazardous Agents. Internet 


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Section 14.1 

database available at http://hazmap.nlm.nih.gov/. Last accessed April 

2007. 

OMOE (Ontario Ministry of the Environment). 1996. Odour Impacts – An 

Overview. STB Technical Bulletin No. EES-1. February 1996. 

Ruth, J.N. 1986. Odour thresholds and irritation levels of several chemical 

substances: A review. Am. Ind. Hyg. Assoc. J. 47: 142–151. 

US EPA (United States Environmental Protection Agency). 1992. Reference 

Guide to Odor Thresholds for Hazardous Air Pollutants Listed in the 

Clean Air Act Amendments of 1990. EPA/600/R-92/047. 

van Gemert, L.J. and A.H. Nettenbreijer. 1977. Compilation of Odour Threshold 

Values in Air and Water. National Institute for Water Supply, Voorburg, 

Netherlands. 

Zang, Q., J.J.R. Feddes, I.K. Edeogu and X.J. Zhou. 2002. Correlation Between 

Odour Intensity Assessed by Using N-Butanol Reference Scale and 

Odour Concentration Measured with Olfactometers. Presented at the 

Agricultural Institute of Canada (AIC) Meeting, July 14–17, 2002. 

Saskatoon, Saskatchewan. 


Shell was asked to provide the rationale for, and evidence to support, the use of 

industrial emissions to determine community concentrations. The response 

explains how the approach was carried out, but does not explain the rationale for 

estimating community concentrations in this manner. Since communities will 

inevitably grow with the growth of industrial projects, it is reasonable to predict 

that community emission sources will increase as well. 

83a In the rationale, explain how this approach will accurately capture this 

community growth (and associated increased emissions). 

Response 83a Various regulatory agencies have provided guidance regarding the use of 

monitoring data to develop background values for use in a dispersion modelling 

analysis (AENV 2009; BC MOE 2008; US EPA 2005). In general, these 

guidance documents state that monitoring data can be used to represent other 

regional sources, if at least one full year of representative monitoring data is 

available. 

The United States Environmental Protection Agency (US EPA 2005) indicates 

that average monitored concentrations should be used to represent background 


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References 

Section 14.1 

concentrations, and that the monitoring data should be modified to exclude the 

contribution of the emission sources not modelled in the assessment. 

In developing the approach for the community background used in the EIA, it 

was recognized that the industrial contribution to the monitored air quality values 

had to be excluded, or community background might be misrepresented. 

Therefore, the industrial contribution was removed from the monitored 

background by using model predictions for the industrial sources only. The EIA, 

Volume 3, Appendix 3-8, Section 2.3.8 outlines the approach used to develop the 

community background concentrations, including the method used to remove the 

industrial contribution from the monitoring data. This approach was selected 

instead of using average monitored concentrations, as recommended by the US 

EPA, to provide a conservative estimate of community background 


To verify the approach, the monitoring data collected at the communities would 

have to have no influence from regional industrial emissions. Because there is 

often some level of industrial influence on the monitored values, it is difficult to 

provide a quantitative verification. 

The Cumulative Environmental Management Association (CEMA) report 

reviewing background concentrations in Fort McKay (CEMA 2005) outlined 

three approaches for developing community background concentrations, 

including the method used in the air quality assessment. The CEMA report 

indicates that all three of the methods result in similar ranges of background 


Statistically significant trends were not evident in Fort McKay, Fort McMurray 

and Fort Chipewyan between 1998 and 2006, despite community growth during 

this period (Kindzierski et al. 2006a, 2006b). One explanation for the lack of an 

increasing trend in the air monitoring data might be that the emission intensity 

per unit area within the communities did not increase significantly even though 

the geographical size of the communities increased, i.e., the population density 

remained similar. Therefore, the community background concentrations used in 

the EIA are expected to be appropriate for all assessment cases. 


the Climate Change, Air and Land Policy Branch Alberta Environment. 

Edmonton, AB. Revised May 2009. 

BC MOE (British Columbia Ministry of Environment). 2008. Guidelines for Air 

Quality Dispersion Modelling in British Columbia. Prepared by 

Environmental Protection Division Environmental Quality Branch Air 

Protection Section. Victoria, BC. March 2008. 

CEMA (Cumulative Environmental Management Association) 2005. Estimating 

Contributions to Ambient Concentrations in Fort McKay. Prepared by 

Golder Associates Ltd. May 2005. 


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Section 14.1 

Kindzierski, W.B., K. Faisal and M. Gamal El-Din. 2006a. Establishment of 

Ambient Air Quality Trends Using Historical Monitoring Data from 

Edmonton and Fort McKay, Alberta. Presented at the 2006 Annual 

General Conference of the Canadian Society for Civil Engineering 

(CSCE). 

Kindzierski, W.B., W. Xu and M. Gamal El-Din. 2006b. Trend Analysis of 

Historical Ambient Air Monitoring Data in Edmonton and Fort McKay, 

Alberta. 

US EPA (United States Environmental Protection Agency). 2005. Revision to the 

Guideline on Air Quality Models: Adoption of a Preferred General 

Purpose (Flat and Complex Terrain) Dispersion Model and Other 

Revisions; Final Rule. November 9, 2005. 

Request 83b Provide the scientific evidence to support the approach. 




Shell states that Alberta Health and Wellness (AHW) recently evaluated the 

potential health effects associated with short-term SO2 exposures. Based on a 

review of human clinical evidence, AHW (2006) concluded that healthy 

individuals can be exposed to concentrations up to 26,000 μg/m 3 (10 ppm) with 

transitory effects on pulmonary function, even under extreme conditions 

involving hyperventilation, mouth-only exposure and heavy exercise. It is 

inaccurate to state that AHW concluded that healthy individuals can be exposed 

to the mentioned concentrations, as the document referenced is a review of the 

available literature and reporting of the associated findings. The document was 

not intended to reflect AHW’s evaluation, or conclusions, regarding human 

health effects associated with SO2. 

84a Update the statement. 

Response 84a The following statement should replace the referenced text in the May 2009 

Pierre River Mine, Supplemental Information, Volume 2, SIR 64a, page 18-17: 

In 2006, Alberta Health and Wellness released a report on the potential health 

effects associated with short-term exposure to low levels of SO2. The goal of the 

report was to “provide a comprehensive review of the available primary scientific 

literature in order to develop a quantitative understanding of the current state of 

knowledge with respect to the dose-response relationship between exposure to 


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Reference 


Section 14.1 

[SO2] and health effects based on the weight of evidence in the peer-reviewed 

scientific literature” (Alberta Health and Wellness 2006, page 6). In the summary 

of their review of human clinical studies, Alberta Health and Wellness (2006) 

reported that “the weight of evidence for exposures up to 30 minutes suggest that 

healthy humans can experience exposures to SO2 up to 10 ppm with transitory 

effects on pulmonary function, even under challenging conditions involving 

hyperventilation, mouth-only exposure, and heavy exercise. Transitory effects 

may be observed at concentrations as low as 0.75 ppm” (page 7). 

Alberta Health and Wellness 2006. Health Effects Associated with Short-term 

Exposure to Low Levels of Sulphur Dioxide (SO2) – A Technical 

Review. ISBN 0-7785-3481-2PDF. 


Shell was asked to provide a quantitative discussion of effects associated with 

construction. Shell states emissions associated with constructing the plant 

facilities will be short term and substantially less than during the operations 

phase of the project. A quantitative assessment was not provided. 

85a Provide this assessment. 

Response 85a Emissions associated with constructing the plant facilities are expected to be 

short term and substantially less than during the operations phase of the project. 

The on-site vehicles and equipment associated with the overall construction of 

the project will have less fuel requirements than for project operations, resulting 

in a lower level of emissions during the construction phase. Regardless, an 

estimate of construction phase emissions has been completed. 

The basis for the emission estimates was the construction-phase greenhouse gas 

(GHG) emissions provided in EIA, Volume 3, Section 3.4.8. Table AENV 85-1 

provides a summary of the direct GHG emissions associated with both the 

construction and operations phases of the project. On a total carbon dioxide 

equivalent basis (CO2E) construction emissions would be approximately 5% of 

the Jackpine Mine Expansion operation emissions and 6% of the Pierre River 

Mine operations emissions. 

Using these ratios as a surrogate for representing other combustion emissions for 

each phase of the project it was concluded that the sulphur dioxide (SO2), oxides 

of nitrogen (NOx), particulate matter with a mean aerodynamic diameter of 

2.5 microns (PM2.5), carbon monoxide (CO) (and other non-criteria compounds) 

emissions during construction would be proportionally lower than operation 

levels. 


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Section 14.1 

Table AENV 85-1: Comparison of Construction and Operations Phase Greenhouse Gas 

Emissions 

Project Phase 

Construction (a) 


Operations (Scenario 1) (b) 

Jackpine Mine 

Expansion 

Direct CO2E Emissions 

(t/yr) 

Pierre River 

Mine Total Project 

103,658 207,316 310,974 

2,216,287 3,327,219 5,453,506 

Ratio of Construction to 

Operations 

Note: 

5% 6% 5% 

(a) The total construction GHG emissions are provided in EIA Volume 3, Section 3.4.8, Table 3.4-30. 

These construction emissions were annualized to facilitate a comparison to the operations 

emissions. The construction time period was assumed to be three years based on EIA, Volume 1, 

Section 14.0 and Volume 2, Section 14.0. 

(b) Source - EIA, Volume 3, Section 3.4.8, Tables 3.4-31 and 3.4-33. 

Given the considerably lower and transient nature of construction emissions, 

quantitative assessments of the construction phase of mining projects in the Oil 

Sands Region have not been conducted. 


In the original HHRA, Shell states that cabin Aboriginal residents will obtain all 

(100%) of their food and nutrition from local, natural food sources. In the SIR 

response, Shell states These rates do not account for consumption of non-sitespecific 

and non-traditional nutritional sources in the diet, such as root 

vegetables and leafy vegetables. The response suggests that the Aboriginal 

receptor predictions were not based on 100% consumption of food from local 

sources. 

86a If this is the case, provide an updated assessment for an Aboriginal receptor that 

does ingest all (100%) food from local, natural food sources. 

Response 86a In the Human Health Risk Assessment (HHRA; EIA, Volume 3, Section 5.3), 

cabin and Aboriginal residents were assumed to obtain all (100%) of their 

traditional foods (i.e., wild game, fish, berries, cattail roots, and wild mint and 

Labrador tea leaves) from local, natural sources. It was assumed that any nontraditional 

foods, which were not evaluated as part of the HHRA, would be 

purchased from local grocery stores. In this regard, the Terms of Reference 

assigned to the work specified consideration of the potential implications for 

public health arising from the project. Specifically: 

c) identify the human health impact of the potential contamination of 

country foods and natural food sources, taking into consideration all 

Project activities. 


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Section 14.1 

It was assumed as part of the HHRA that cabin and Aboriginal residents would 

only consume traditional meat, such as wild game and fish, and they would not 

consume any non-traditional meat obtained from local grocery stores. That is, 

cabin and Aboriginal residents were assumed to obtain all (100%) of their meat 

from local, natural sources. The wild game and fish consumption rates employed 

in the HHRA accurately reflected this assumption (see EIA, Volume 3, Section 

5.3.2). The HHRA consumption rates for wild game and fish are recommended 

by Health Canada for Canadian Aboriginal populations (Health Canada 2004). 

These consumption rates are based on summary data for wild game and fish 

‘eaters only’, which excludes individuals reporting no wild game or fish 

consumption. Using statistics for ‘eaters only’ ensures that the consumption rates 

of the individuals who consume the majority of the wild game and fish harvested 

are not under estimated. 

It was assumed that cabin and Aboriginal residents would rely to a lesser extent 

on local, natural sources for their fruits and vegetables (see EIA, Volume 3, 

Section 5.3.2). The fruit and vegetable consumption rates for cabin and 

Aboriginal residents were, therefore, designed to represent consumption of 

traditional berries, cattail roots, and wild mint and Labrador tea leaves only. The 

HHRA employed consumption rates for traditional berries, cattail roots, and wild 

mint and Labrador tea leaves that were based on a food consumption survey 

conducted near Wood Buffalo National Park (Wein 1989). The shortfall in 

nutritional requirements from local, natural fruits and vegetables was expected to 

be derived from produce purchased from the local grocery store. 

For comparative purposes, potential health risks associated with multiple 

pathways of exposure for cabin and Aboriginal residents were re-assessed such 

that all (100%) of their foods (traditional and non-traditional) would be obtained 

from local, natural sources. The revised consumption rates are listed in 

Table AENV 86-1. 

The updated risk quotients (RQ values) for the non-carcinogens are provided in 

Table AENV 86-2 for the cabin residents and in Table AENV 86-3 for the 

Aboriginal residents. 

In most instances, the updated RQ values did not exceed 1.0 for most chemicals 

of potential concern (COPCs), with the exceptions of: 

• manganese; 

• methyl mercury; 

• molybdenum; 

• the “neurotoxicants” mixture; and 

• the “reproductive and developmental toxicants” mixture. 

Risk quotients for methyl mercury, molybdenum, the “neurotoxicants” mixture 

and the “reproductive and developmental toxicants” mixture exceeded the 

benchmark of 1.0 in the Additional Environmental Setting Report (May 2009 

Pierre River Mine, Supplemental Information, Volume 2, Appendix B, Section 4, 

Table 4.7-1 and Table 4.7-2) and the HHRA (see EIA, Volume 3, Section 

5.3.3.3, Table 5.3-42 and Table 5.3-43). The updated RQ values for methyl 


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Section 14.1 

mercury and molybdenum, in fact, remain essentially unchanged from the 

Additional Environmental Setting Report and the HHRA because the fish 

consumption pathway remained the dominant exposure pathway contributing to 

the predicted RQ values for these COPCs. Discussion of predicted RQ values for 

methyl mercury and molybdenum can be found in EIA, Volume 3, Section 

5.3.3.3. 

Risk quotients for manganese, the “neurotoxicants” mixture and the 

“reproductive and developmental toxicants” mixture were predicted to increase 

from those reported in the Additional Environmental Setting Report (May 2009 

Pierre River Mine, Supplemental Information, Volume 2, Appendix B, Section 4) 

and the HHRA (see EIA, Volume 3, Section 5.3.3.3). Manganese was the only 

COPC for which the predicted RQ values increased above the benchmark of 1.0 

due to the inclusion of non-traditional food consumption in the multiple pathway 

assessment. 

The predicted RQ values for manganese, the “neurotoxicants” mixture and the 

“reproductive and developmental toxicants” mixture are discussed below. 

Table AENV 86-1: Consumption Rates for the Cabin and Aboriginal Residents 

Consumption Rate 

Life Stages 

(a) 

(g/d) Infant (b) Toddler Child Adolescent Adult Reference 

Traditional Foods 

moose 0 65 95 133 205 Health Canada (2004a); Wein (1989) 

snowshoe hare 0 14 20 28 43 Health Canada (2004a); Wein (1989) 

ruffed grouse 0 7 10 14 22 Health Canada (2004a); Wein (1989) 

fish 0 22 40 47 51 Health Canada (2004a); FMES 

(1996); AHW (2007) 

berries 3 5 11 19 23 Wein (1989); AHW (2007) 

cattail root 0.4 1 1 3 3 Wein (1989); AHW (2007) 

wild mint and Labrador 

tea leaves 

0.4 1 1 3 3 Wein (1989); AHW (2007) 

Non-Traditional Foods 

fruit (c) 0 40 69 56 46 Health Canada (1994) 

root vegetables 0 105 161 227 188 Health Canada (2004a) 

leafy vegetables 0 67 98 120 137 Health Canada (2004a) 

Note: 

(a) Consumption rates for the traditional foods remain unchanged from the HHRA (EIA, Volume 3, Section 5.3.2, 

Table 5.3-5). 

(b) Infants are assumed to ingest 664 grams per day of breast milk (O’Connor and Richardson 1997; Health Canada 1994). 

(c) Fruit consumption rates based on composite of apples, apple sauce, cherries, strawberries, blueberries, jams and honey. 


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Section 14.1 

Table AENV 86-2: Chronic Risk Quotients from Multiple Pathways of Exposure – Cabin 

Residents 

Risk Quotient (a) 

Chemical of Potential Concern Base Case Application Case 

Planned 

Development Case 

1,1,1-trichloroethane 1.9E-04 1.9E-04 1.9E-04 

1,2-dichloropropane 4.4E-03 4.4E-03 4.4E-03 

aliphatic C5-C8 group 1.4E-04 3.5E-04 3.6E-04 



aluminum 5.7E-02 5.8E-02 5.8E-02 

antimony 3.5E-01 3.5E-01 3.6E-01 

aromatic C9-C16 group 3.1E-02 3.2E-02 3.4E-02 


barium 2.6E-01 2.6E-01 2.7E-01 

beryllium 3.2E-02 4.0E-02 4.0E-02 

biphenyls 7.4E-03 7.4E-03 7.4E-03 

boron 2.4E-01 2.9E-01 2.9E-01 

cadmium 3.3E-01 4.0E-01 4.9E-01 

chromium 2.3E-03 2.3E-03 2.3E-03 

chromium VI 1.1E-01 1.1E-01 1.1E-01 

copper 1.0E-01 1.0E-01 1.1E-01 

lead 2.8E-01 2.8E-01 2.9E-01 

manganese 1.3E+00 1.3E+00 1.3E+00 

mercury 3.3E-01 3.3E-01 3.5E-01 

methyl mercury 8.3E+00 8.3E+00 8.3E+00 

molybdenum 1.6E+00 3.0E+00 3.0E+00 

naphthalene group 1.8E-03 1.8E-03 1.8E-03 

nickel 2.7E-01 2.7E-01 2.7E-01 

selenium 4.8E-02 5.5E-02 5.8E-02 

silver 1.2E-01 1.2E-01 1.2E-01 

strontium 1.7E-01 1.7E-01 1.7E-01 

tin 7.5E-02 7.5E-02 7.5E-02 

vanadium 2.2E-01 2.5E-01 2.5E-01 

zinc 8.4E-01 8.4E-01 8.4E-01 

Mixtures (b) 

hepatotoxicants 5.4E-02 7.6E-02 7.9E-02 

renal toxicants 6.3E-01 7.1E-01 8.0E-01 

haematological toxicants 9.4E-01 9.6E-01 9.7E-01 

neurotoxicants 9.9E+00 9.9E+00 9.9E+00 

reproductive/developmental 

toxicants 

Note: 

9.2E+00 9.3E+00 9.3E+00 

(a) An RQ equal to or less than 1.0 signifies that the estimated exposure is less than the exposure limit and no health 

effects are expected. Boldface values show an RQ of greater than 1.0. With scientific notation, any value 

expressed to the negative power (i.e., E-x) shows that predicted exposures were less than the exposure limit; 

whereas, a value expressed to the positive power (i.e., E+x) shows that exposure estimates exceeded the 

exposure limit. 

(b) Individual constituents of the chemical mixtures are identified in EIA, Volume 3, Section 5.3.2.3, Table 5.3-13. 


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Section 14.1 

Table AENV 86-3: Chronic Risk Quotients from Multiple Pathways of Exposure – 

Aboriginal Residents 

Risk Quotient (a) 

Chemical of Potential Concern Base Case Application Case 

Planned 

Development Case 


1,2-dichloropropane 4.4E-03 4.4E-03 4.4E-03 




aluminum 6.2E-02 6.2E-02 6.2E-02 

antimony 3.4E-01 3.4E-01 3.4E-01 



barium 5.2E-02 5.2E-02 5.3E-02 

beryllium 2.8E-02 3.6E-02 3.6E-02 

biphenyls 7.4E-03 7.4E-03 7.4E-03 

boron 2.5E-01 2.7E-01 2.7E-01 

cadmium 3.1E-01 3.8E-01 5.1E-01 

chromium 2.2E-03 2.2E-03 2.2E-03 

chromium VI 1.1E-01 1.1E-01 1.1E-01 

copper 1.6E-01 1.6E-01 1.7E-01 

lead 2.7E-01 2.7E-01 2.8E-01 

manganese 1.3E+00 1.3E+00 1.3E+00 

mercury 3.3E-01 3.3E-01 3.5E-01 

methyl mercury 8.3E+00 8.3E+00 8.3E+00 

molybdenum 1.4E+00 2.6E+00 2.6E+00 

naphthalene group 1.8E-03 1.8E-03 1.8E-03 

nickel 2.2E-01 2.2E-01 2.2E-01 

selenium 4.4E-02 5.1E-02 5.4E-02 

silver 1.2E-01 1.2E-01 1.2E-01 

strontium 1.6E-01 1.7E-01 1.7E-01 

tin 7.5E-02 7.5E-02 7.5E-02 

vanadium 2.2E-01 2.4E-01 2.4E-01 

zinc 8.4E-01 8.4E-01 8.4E-01 

Mixtures (b) 

hepatotoxicants 9.4E-02 1.1E-01 1.2E-01 

renal toxicants 4.4E-01 5.1E-01 6.4E-01 

haematological toxicants 9.4E-01 9.6E-01 9.6E-01 

neurotoxicants 9.9E+00 9.9E+00 9.9E+00 

reproductive/developmental 

toxicants 

Note: 

9.2E+00 9.2E+00 9.2E+00 

(a) An RQ equal to or less than 1.0 signifies that the estimated exposure is less than the exposure limit and no health 

effects are expected. Boldface values show an RQ of greater than 1.0. With scientific notation, any value 




(b) Individual constituents of the chemical mixtures are identified in EIA, Volume 3, Section 5.3.2.3, Table 5.3-13. 


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Section 14.1 

As shown in Table AENV 86-4 and Table AENV 86-5, the maximum predicted 

incremental lifetime cancer risks (ILCR values) associated with the project (i.e., 

Application Case minus Base Case) and Future Emission Sources in the area 

(i.e., PDC minus Base Case) are all less than one in 100,000 indicating that the 

incremental cancer risk from the project and planned development is deemed to 

be “essentially negligible” (Health Canada 2004). 

Although lifetime cancer risks (LCR values) greater than 1.0 were predicted for 

the Base Case assessment of arsenic and the “liver carcinogen” mixture, these 

values represent the number of cancer cases that could theoretically result from 

the estimated exposures to these carcinogenic COPCs in a population of 100,000 

people. Lifetime cancer risks for arsenic and the “liver carcinogen” mixture were 

also found to exceed 1.0 in the HHRA (EIA, Volume 3, Section 5.3.3.3, 

Table 5.3-42 and Table 5.3-43). 

The predicted LCR values for arsenic and the “liver carcinogen” mixture are 

discussed below. 

Table AENV 86-4: Chronic Lifetime and Incremental Lifetime Cancer Risks per 100,000 

from Multiple Pathways of Exposure – Cabin Residents 

Chemical of Potential 

Concern Base Case 

Lifetime Cancer 

Risk (a) Incremental Lifetime Cancer Risk (b) 


(Application-Base) 

Future Emission 

Sources 

(PDC-Base) 


arsenic 1.9E+01 3.7E-03 2.6E-01 

carbon tetrachloride 1.3E-01 8.3E-13 1.5E-12 

carcinogenic PAH group 1 5.7E-01 2.0E-01 2.1E-01 



Mixtures (c) 

stomach carcinogens 6.6E-01 2.9E-01 3.1E-01 

liver carcinogens 

Note: 

2.0E+01 3.7E-03 2.6E-01 

(a) Lifetime cancer risks refer to the number of cancer cases that could potentially result from the estimated exposures 

to the carcinogenic COPCs among a population of 100,000 people. Since an acceptable cancer incidence rate has 

not been recommended for exposure to carcinogens associated with anything other than the Project and Future 

Emission Sources by any leading scientific or regulatory authority, interpretation of the significance of the LCR 

values determined for the Base Case could be not based on comparison against a numerical “benchmark” of one 

in 100,000. 

(b) An ILCR equal to or less than 1.0 signifies an incremental lifetime cancer risk that is below the benchmark ILCR of 

one in 100,000 (i.e., within the generally accepted limit deemed to be protective of public health). Boldface values 

show an ILCR of greater than the de minimus risk level of one in 100,000. 

(c) Individual constituents of the chemical mixtures are identified in EIA Volume 3, Section 5.3.2.3, Table 5.3-13. 


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Section 14.1 

Table AENV 86-5: Chronic Lifetime and Incremental Lifetime Cancer Risks per 100,000 

from Multiple Pathways of Exposure – Aboriginal Residents 

Chemical of Potential 

Concern Base Case 

Lifetime Cancer 

Risk (a) Incremental Lifetime Cancer Risk (b) 


(Application-Base) 

Future Emission 

Sources 

(PDC-Base) 


arsenic 2.0E+01 3.2E-03 2.6E-01 

carbon tetrachloride 1.3E-01 7.4E-13 2.2E-11 




Mixtures (c) 

stomach carcinogens 5.6E-01 2.7E-01 3.0E-01 

liver carcinogens 2.1E+01 3.2E-03 2.6E-01 

Note: 

(a) Lifetime cancer risks refer to the number of cancer cases that could potentially result from the estimated exposures 

to the carcinogenic COPCs among a population of 100,000 people. Since an acceptable cancer incidence rate has 

not been recommended for exposure to carcinogens associated with anything other than the Project and Future 

Emission Sources by any leading scientific or regulatory authority, interpretation of the significance of the LCR 

values determined for the Base Case could be not based on comparison against a numerical “benchmark” of one 

in 100,000. With scientific notation, any value expressed to the negative power (i.e., E-x) shows that predicted 

exposures were less than the exposure limit; whereas, a value expressed to the positive power (i.e., E+x) shows 

that exposure estimates exceeded the exposure limit. 

(b) An ILCR equal to or less than 1.0 signifies an incremental lifetime cancer risk that is below the benchmark ILCR of 

one in 100,000 (i.e., within the generally accepted limit deemed to be protective of public health). Boldface values 

show an ILCR of greater than the de minimus risk level of one in 100,000. With scientific notation, any value 




(c) Individual constituents of the chemical mixtures are identified in EIA, Volume 3, Section 5.3.2.3, Table 5.3-13. 

Manganese 

Risk quotients above 1.0 (i.e., 1.3) were predicted for cabin and Aboriginal 

residents under the Base Case, Application Case and Planned Development Case 

(PDC). In the HHRA, RQ values of 0.19 and 1.6 were predicted for the cabin and 

Aboriginal residents, respectively. 

Interpretation of these findings considered the following factors: 

• the potential contribution from the project to these predicted exceedances; 

• the primary exposure pathway(s) contributing to these predicted 

exceedances; 

• the use of the 95th upper confidence interval on the mean (95UCLM) of 

concentrations of manganese in various media versus the average 

concentration; and, 


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Section 14.1 

• the high degree of conservatism incorporated in the consumption patterns of 

these residents and the assumed exposure limit. 

The RQ values for the cabin and Aboriginal residents were not predicted to 

change between the Base Case and Application Case, indicating that all of the 

predicted RQ values under the Application Case and PDC are the result of the 

Base Case predictions, and that the project is not likely to increase the risk of 

long-term exposure to manganese. 

Examination of the contributing exposure pathways revealed that consumption of 

non-traditional fruits and vegetables represents most (86%) of the predicted RQ 

values for the cabin and Aboriginal residents. Lesser contributions were 

identified for the ingestion of berries, cattail roots and, in the case of cabin 

residents, the ingestion of drinking water. The contribution of each of these 

exposure pathways to the RQ values for manganese is shown in 

Table AENV 86-6. The contribution from the remaining exposure pathways was 

negligible. 

Table AENV 86-6: Contribution of Individual Exposure Pathways to Potential Risk 

Quotients for Manganese 

Contribution 

(%) 

Exposure Pathway (a) Planned 

Base Case Application Case Development Case 

ingestion of drinking water (b) Traditional Foods 

3 3 3 

ingestion of berries 6 6 6 

ingestion of cattail roots 2 2 2 

Non-Traditional Foods 

ingestion of fruit 30 30 30 

ingestion of root vegetables 13 13 13 

ingestion of leafy vegetables 43 43 43 

Note: 

(a) The most sensitive life stage was identified as the toddler. 

(b) The contribution reported for the ingestion of drinking water is specific to cabin residents. For the Aboriginal 

residents, the contribution from the ingestion of drinking water was negligible. 

With the exception of the drinking water pathway, all of the contributing 

exposure pathways identified above were highly influenced by the measured 

background soil concentration of manganese. Regional manganese soil 

concentrations ranged from 1.8 to 5,800 mg/kg, with an average concentration of 

460 mg/kg. The 95UCLM concentration of 610 mg/kg was used to characterize 

background soil concentrations of manganese and subsequently predict 

background manganese concentrations in local, natural foods consumed by cabin 

and Aboriginal residents. 

The assumption that cabin and Aboriginal residents would obtain all (100%) of 

their foods (traditional and non-traditional) from local, natural sources, when in 


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Section 14.1 

all likelihood some portion of their diet would be purchased from a local grocery 

store, together with the assumption that all local, natural foods would grow from 

soil containing the 95UCLM concentration of manganese, likely contributed to 

the exaggeration of the exposures that might be received by these residents under 

actual circumstances. 

A less conservative estimate of risk would be to assume that the average 

manganese soil concentration is representative of soil concentrations in the 

region. Based on this less conservative assumption, the manganese RQ values for 

cabin and Aboriginal residents would no longer exceed 1.0 under the Base Case, 

Application Case and PDC. This still conservatively assumes that cabin and 

Aboriginal residents would obtain all (100%) of their foods (traditional and nontraditional) 

from local, natural sources. 

With respect to the toxicity assessment of manganese, the oral exposure limit 

used in the multiple pathway assessment was derived by the US EPA using 

toxicity data obtained from large populations consuming normal diets over an 

extended period of time with no reported adverse health effects (US EPA 1996). 

In fact, the level at which adverse effects of dietary manganese exposure would 

be observed has not yet been identified (WHO 2004). 

Manganese is an essential element required for enzyme co-factors and constituent 

of metalloenzymes. No adverse health effects were noted among humans with 

daily intakes ranging from 2,000 to 7,000 µg/d (Health Canada 1987). On this 

basis, Health Canada (2006) has established a tolerable upper intake level (UL) 

for a toddler of 2,000 to 3,000 µg/d for manganese. The UL is the highest 

average daily nutrient intake level likely to pose no risk of adverse health effects 

to almost all individuals in the given life stage and gender group (Health Canada 

2006). 

The WHO (2004) reports that average adult manganese intakes range from 700 to 

10,900 µg/d and considers there to be no observable adverse effects at the upper 

range of dietary intakes for manganese. Furthermore, WHO (2004) noted in its 

toxicological review that dietary manganese is not considered to be very toxic to 

humans given the existence of homeostatic mechanisms. 

The predicted RQ value of 1.3 is associated with a maximum daily intake for a 

toddler of 3,100 µg/d. Although this maximum daily intake slightly exceeds 

Health Canada’s UL for manganese, it falls within the range of daily intakes for 

which Health Canada and WHO have reported no adverse health effects in 

humans. 

Overall, the likelihood for adverse health effects associated with manganese 

exposure in the region is low, for the following reasons: 

• Most (86%) of the RQ values under the Base Case are the result of nontraditional 

fruit and vegetable consumption. 


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Neurotoxicants 

Section 14.1 

• The high degree of conservatism incorporated in the predicted fruit and 

vegetable concentrations through the use of the 95UCLM soil concentration 

to represent regional background soil concentrations of manganese. 

• Cabin and Aboriginal residents were assumed to obtain all (100%) of their 

food (traditional and non-traditional) from local, natural sources over their 

lifetimes, and not supplement their diet with any foods from the local grocery 

store. 

• Estimates of daily exposure in the region remain within the range of typical 

human exposures (Health Canada 1987, WHO 2004). 

• The degree of conservatism incorporated in the oral exposure limit. 

The RQ values for the “neurotoxicants” mixture increased from 8.7 in the HHRA 

to 9.9 due to the inclusion of non-traditional foods in the multiple pathway 

assessment. 

For the following reasons, the likelihood for people living in the region to 

experience neurotoxicity as a result of the project or planned developments is 

low: 

• No change was predicted between the Base Case and Application Case RQ 

values. 

• All (100%) of the RQ values under the Application Case and the PDC were 

associated with the Base Case. 

• Risk quotients associated with methyl mercury, which is still the primary 

contributor to the mixture RQ values, are conservative estimates based on the 

assumptions made in the HHRA (see EIA, Volume 3, Section 5.3.3.3). 

• Most of the RQ values under the Base Case were still the result of assumed 

fish consumption. 

• It was assumed that residents would obtain all (100%) of their food, 

including fish, from the local, natural sources over their lifetimes. 

Reproductive and Developmental Toxicants 

The RQ values for the “reproductive and developmental toxicants” mixture 

increased for cabin residents from 8.9 to 9.0 in the HHRA to 9.2 to 9.3 due to the 

inclusion of non-traditional foods in the multiple pathway assessment. Similarly, 

the RQ values for Aboriginal residents increased from 8.8 to 9.2. 

For the following reasons, the project is not likely to result in adverse health 

effects associated with exposure to reproductive and developmental toxicants in 

the region: 


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Section 14.1 

• No or negligible change in predicted RQ values between the Base Case and 

Application Case. 

• The Base Case contributes most of the RQ values under the Application Case 

and the PDC (99 to 100%). 

• Risk quotients associated with methyl mercury, which is still the primary 

contributor to the mixture RQ values, are conservative estimates based on the 

assumptions made in the HHRA (see EIA, Volume 3, Section 5.3.3.3). 

• Most of the RQ values under the Base Case were the result of the assumed 

fish consumption. 

• It was assumed that residents would obtain all (100%) of their food, 

including fish, from the local, natural sources over their lifetimes. 

Arsenic and Liver Carcinogens 

The Base Case LCR values range from 19 to 21 for arsenic and the liver 

carcinogens, signifying that lifetime exposure to background levels of 

carcinogens via multiple pathway exposures could potentially account for up to 

21 cases of cancer when calculated on a 100,000 person population basis. The 

Base Case LCR values are up from those predicted as part of the HHRA (see 

EIA, Volume 3, Section 5.3.3.3). 

The regulatory benchmark of an acceptable incremental lifetime cancer risk of 

one in 100,000 is policy-based. Regulators have not recommended an acceptable 

cancer incidence rate (or LCR) for exposure to carcinogens associated with 

background or “baseline” conditions. The “acceptability” of this potential 

lifetime cancer risk from a public health perspective cannot be determined 

following a conventional approach since an acceptable “benchmark” cancer risk 

level for exposure to background levels of carcinogens is not available for 

comparison. 

In a recent study conducted on behalf of Alberta Health and Wellness, “baseline” 

lifetime cancer risks were estimated to range from 17 to 33 in 100,000 (AHW 

2007). Note that the risk estimates for the baseline scenario in the AHW study 

are similar to those presented for the revised Base Case. 

For the following reasons, the project is not likely to result in adverse health 

effects associated with exposure to arsenic and the liver carcinogens, as a whole, 

in the region: 

• Incremental lifetime cancer risks for arsenic and the liver carcinogens did not 

exceed the regulatory benchmark of 1.0. 

• Use of the exposure limit adopted from Health Canada, which was derived 

based on the premise that arsenic acts as a “non-threshold” carcinogen, may 

overstate the carcinogenic potency of arsenic and subsequently the 

carcinogenic potency of the liver carcinogens. 


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References 

Section 14.1 

AHW (Alberta Health and Wellness). 2007. Assessment of the Potential Lifetime 

Cancer Risks Associated with Exposure to Inorganic Arsenic among 

Indigenous People Living in the Wood Buffalo Region of Alberta. 

Prepared by Cantox Environmental Inc. March 2007. 

FMES( Fort McKay Environmental Services). 1996. A Survey of the 

Consumptive Use of Traditional Resources in the Community of Fort 

McKay. Completed for Syncrude Canada Ltd. May 23, 1997. 

Health Canada. 1987. Manganese. Guidelines for Canadian Drinking Water 

Quality – Supporting Documents. November 1987. 

Health Canada. 1994. Human Health Risk Assessment for Priority Substances. 

Canadian Communications Group Publishing. Ottawa, ON. 

Health Canada. 2004. Contaminated Sites Program - Federal Contaminated Site 

Risk Assessment in Canada Part I- Guidance on Preliminary Human 

Health Preliminary Quantitative Risk Assessment 

(PQRA).Environmental Health Assessment Services Safe Environments 

Program. Ottawa, ON. September 2004. ISBN 0-662-38244-7 

Health Canada. 2006. Dietary Reference Intakes Tables. ISBN 0-662-41134-X. 

Available at: http://www.hc-sc.gc.ca/fnan/nutrition/reference/table/index_e.html 

O’Connor and Richardson (O’Connor Associates Environmental Inc. and G.M. 

Richardson). 1997. Compendium, of Canadian Human Exposure Factors 

for Risk Assessment. Ottawa, ON. 

US EPA (United States Environmental Protection Agency). 1996. Manganese 

(CASRN 7439-96-5). Inhalation RfC Assessment. Integrated Risk 

Information System (IRIS) database on-line search. United States 

Environmental Protection Agency. Cincinnati, OH. Available at: 

http://www.epa.gov/iris/subst/0373.htm. Accessed September 2007. 

Wein, E.E. 1989. Nutrient Intakes and use of Country Foods by Native 

Canadians Near Wood Buffalo National Park. Thesis presented to the 

Faculty of Graduate Studies, University of Guelph. February 1989. 

WHO (World Health Organization). 2004. Manganese in Drinking-water – 

Background document for development of WHO Guidelines for 

Drinking-water Quality. World Health Organization. 

WHO/SDE/WSH/03.04/104. 


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Section 14.1 

Shell states that as part of the water quality assessment and the aquatic 

assessment substances of potential concern were comprehensively screened. 

87a Clarify if the screening was based on human health endpoints. If not, update the 

HHRA accordingly. 

Response 87a All chemicals potentially released to local surface water, with the exceptions of 

dissolved solids and nutrients, were evaluated as part of the multiple pathway 

assessment in the Human Health Risk Assessment (see EIA, Volume 3, Section 

5.3.2.2). That is, no screening of the chemicals potentially released to local 

surface water bodies was conducted for the HHRA. 



88a Clarify if cabin residents also share Aboriginal receptor characteristics. If so, 

identify. 

Response 88a Cabin and Aboriginal residents share the same physical characteristics (i.e., body 

weight, inhalation rate, soil ingestion rate, water ingestion rate and body surface 

area) and lifestyle characteristics (i.e., time spent at the cabin or residence and 

food consumption rates) (see EIA, Volume 3, Section 5.3). The only difference in 

the assessment of potential health risks for cabin and Aboriginal residents were 

the discrete locations at which they were assumed to permanently reside and the 

source of their drinking water. 

Cabin residents were assessed using the highest exposed of the 12 cabins 

identified in Table 5.3-4 of the HHRA (see EIA, Volume 3, Section 5.3), while 

Aboriginal residents were assessed using the highest exposed of the nine 

applicable communities (Anzac, Clearwater (IR 175), Conklin, Descharme Lake, 

Fort Chipewyan, Fort McKay, Fort McMurray, Janvier/Chard (IR 194), La 

Loche, Namur River (IR 174A) and Poplar Point (IR 201G)). 

With respect to drinking water, cabin residents were assumed to drink water from 

local surface waterbodies, while Aboriginal residents were assumed to have 

access to the Fort McKay municipal water supply. 


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Section 14.1 

Shell notes that, for aliphatic C5-C8 compounds and aromatic C9-C16 compounds, 

the use of a less conservative relative absorption factor (RAF) does not affect the 

predictions in the HHRA. 

89a Re-assess these compounds using the CCME recommended value of 0.2 in order 

to quantitatively prove this conclusion. 

Response 89a The aliphatic C5-C8 group and aromatic C9-C16 group were re-assessed using the 

CCME dermal relative absorption factor (RAF) of 0.2. The updated risk 

quotients (RQ values) for the aliphatic and aromatic group are presented for each 

of the lifestyle categories evaluated as part of the multiple pathway assessment 

(i.e., cabin residents, Aboriginal residents, community residents and workers). 

Updated RQ values are also provided for the cabin and Aboriginal residents that 

consider an alternative consumption pattern to that used in the HHRA (i.e., 100% 

of their food would be obtained from local, natural sources), as further discussed 

in the response to AENV SIR 86. 

As shown in Table AENV 89-1, use of the CCME RAF value did not materially 

change the results or the conclusion of the HHRA. The updated multiple pathway 

RQ values for the aliphatic C5-C8 group and aromatic C9-C16 group did not 

exceed 1.0 under any circumstance. This demonstrates that the estimated 

exposure remains less than the exposure limit (i.e., the assumed safe level of 

exposure). Therefore, health risks for the aliphatic C5-C8 group and aromatic C9- 

C16 group remain low. 


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Table AENV 89-1: Chronic Risk Quotients from Multiple Pathways of Exposure 

Section 14.1 

Chemical of 

Base Case Application Case Planned Development Case 

Potential Concern HHRA SIR 86 SIR 89 HHRA SIR 86 SIR 89 HHRA SIR 86 SIR 89 

Cabin Residents 

aliphatic C5-C8 group 1.4E-04 1.4E-04 1.4E-04 3.5E-04 3.5E-04 3.5E-04 3.6E-04 3.6E-04 3.6E-04 

aromatic C9-C16 group 2.1E-02 3.1E-02 3.1E-02 2.2E-02 3.2E-02 3.2E-02 2.4E-02 3.4E-02 3.4E-02 

Aboriginal Residents 

aliphatic C5-C8 group 3.5E-03 3.5E-03 3.5E-03 3.7E-03 3.7E-03 3.7E-03 4.5E-03 4.5E-03 4.5E-03 

aromatic C9-C16 group 6.2E-02 7.2E-02 7.2E-02 6.3E-02 7.3E-02 7.3E-02 6.6E-02 7.6E-02 7.6E-02 

Community 

Residents 

aliphatic C5-C8 group 3.4E-03 n/a 3.4E-03 3.5E-03 n/a 3.5E-03 4.2E-03 n/a 4.3E-03 

aromatic C9-C16 group 6.4E-02 n/a 6.4E-02 6.4E-02 n/a 6.4E-02 7.4E-02 n/a 7.4E-02 

Workers 

aliphatic C5-C8 group 6.2E-03 n/a 6.2E-03 6.2E-03 n/a 6.2E-03 7.0E-03 n/a 7.0E-03 

aromatic C9-C16 group 6.2E-02 n/a 6.2E-02 7.7E-02 n/a 7.7E-02 7.8E-02 n/a 7.8E-02 

Note: 

1. AENV SIR 86 refers to an alternative scenario to the HHRA, whereby cabin and Aboriginal residents would obtain 100% of their food 

from local, natural sources. The HHRA assumed 100% except for fruit and vegetable consumption rates. 

2. AENV SIR 89 refers to an alternative scenario to the HHRA, as discussed above, whereby the dermal bioavailability of 0.2 for all 

aliphatic and aromatic compounds is applied 


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Section 14.1 


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Request EIA Volume 2, Section 8.1, Page 8-4 

EPEA APPROVALS 


Section 15.1 

90a Provide the water treatment and wastewater treatment plant designs, capacities, 

and expected effluent qualities to ensure the treatment plants will be capable of 

achieving the level of treatment required. 

Response 90a The wastewater treatment and water treatment facilities have not yet been 

designed. Therefore, design details, qualities and quantities are not currently 

available. The wastewater flows referenced in the application are estimates based 

on existing operations. As project engineering progresses, the facility sizing and 

requirements will be finalized. When designing these facilities, Shell will take 

into account the approved provincial guidelines and standards that exist at that 

time. 


Request EIA Volume 2, Section 20.2, Page 20-7. 

Shell indicates that within the proposed 10-year EPEA approval period (2010 to 

2019), soil salvage will not likely begin until 2017. Shell also states that Shell 

plans to salvage all upland surface soils in the mining areas and the plant site. It 

is unclear how a facility in the early stages of development will have no need to 

salvage soils in the first 7 years of operations. 

91a Confirm what activities (e.g., road construction, bridge construction, laydown 

yard construction, plant site development, etc.) will occur in the first 7 years that 

could trigger the need for soil salvage and stockpile. 

Response 91a Activities planned within the first seven years of development primarily occur 

within peatland soil types (dominant Muskeg, Mariana and Hartley organic soils, 

as shown in Figure 2.3-4 of Section 2 of the Jackpine Mine Expansion and Pierre 

River Mine Environmental Setting Reports). As described in the Project 

Description, Volume 2, Section 20.2, page 20-8, efforts were made in 

conservation planning to minimize time in stockpile by delaying salvage of peat- 


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EPEA APPROVALS AENV SIRS 90 – 96 


Section 15.1 

mineral materials until as late as possible in the development area, as more than 

twice the volume of peat is available within the Pierre River Mine development 

footprint as is required for closure and reclamation plans. Since the submittal of 

the Closure, Conservation and Reclamation (C,C&R) plan for the Pierre River 

Mine in 2007, further discussions with Alberta Environment and Alberta 

Sustainable Resource Development regarding methods of salvaging peat-mineral 

material, such as focusing salvage on the top 1 m of deeper peat areas, might 

alter the start date of salvage activities. This will be detailed in operational 

C,C&R plans. 

Activities, including access roads and bridge construction, will be underway by 

2011, and drainage of muskeg areas for plant site development will be underway 

by 2014. Reclamation material stockpile (RMS) areas will be created to store 

salvaged soils for reclamation activities, as shown in the C,C&R Plan for the 

Pierre River Mine (see Project Description, Volume 2, Section 20) and as further 

detailed in operational plans pending project approval. 

Request EIA Volume 2, Section 20.2, Tables 20-4 and 20-5, Page 20-9. 

The table indicates that no reclamation will occur for 20 years (2010-2029). 

92a Explain why there are no opportunities for earlier reclamation to occur. 

Response 92a The proposed Pierre River Mine plan progression figures provided in EIA, 

Volume 5, Appendix 5-2 (and provided in a truncated version in EIA, Volume 2, 

Section 20) demonstrate that, between 2010 and 2029, all areas of the mine 

development area that are disturbed are still in active operation. By 2019, the 

mine development area is occupied by the plant site (active bitumen recovery 

status), the north overburden disposal area (first lift not yet completed) and the 

pit floor has been reached in 2018 in the first section of Cell 1 (active bitumen 

recovery status). By 2029, the plant site is still active, overburden from the Cell 1 

pit has been largely directed to in-pit dykes and the external tailings disposal area 

(active bitumen recovery status) and the north overburden dump disposal area is 

still completing the first lift. Table 20-4 and 20-5 in the Project Description, 

Volume 2, Section 20.2 note that reclamation material volumes after 2019 are 

aggregated into 10 year blocks. Therefore, reclamation started between 2029 and 

2039 is aggregated into the 2039 volumes. 

If opportunities become available, earlier reclamation of the active mine 

development structures will be detailed within closure and reclamation plans 

submitted as a requirement of an Environmental Protection and Enhancement 

Act approval for the Pierre River Mine Project. 


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Request EIA Volume 2, Section 20.3, Table 20-6, Page 20-13. 

The table indicates that 62 ha are undisturbed pre-development. 

Section 15.1 

93a The table assumes that the land will remain undisturbed through operations to 

closure, however in the event that the land is disturbed in the future, the forestry 

capability class should be determined. Update the table to reflect the capability 

class of the 62 ha of land. 

Response 93a Table AENV 93-1 is an updated version of Table 20-6 to reflect the capability 

classes of the 62 ha of land. 

Table AENV 93-1: Changes in Predicted Forestry Capability Class Changes Following 

Reclamation in the Pierre River Mining Area - Revised 

Forestry 

Capability 

Class 

Area 

(ha) 

Pre-Development Closure Net Change 

% of 

Development 

Area 

Area 

(ha) 

% of 

Development 

Area 


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Area 

(ha) 

% of 

Development 

Area 

1 (high) 0 0 158 2 158 2 

2 (moderate) 556 5 1,361 13 805 8 

3 (low) 2,707 26 1,983 19 -724 -7 

4 (conditionally 

productive) 

3,739 36 3,696 35 -43 -1 

5 (nonproductive) 

littoral zones 

and marsh 

3,337 32 1,031 10 -2,306 -22 

0 0 254 2 254 2 

water/pit lake 65


94a What other reclamation activities occur after end of mine life (2039)? 

Section 15.1 

Response 94a The following reclamation activities will follow applicable regulatory guidelines, 

approval conditions and approved reclamation plans: 

1. Facility decommissioning (e.g. plant site, camp areas, ancillary facilities). 

2. Recontouring landforms to maintain or create drainage, as outlined in the 

Closure Drainage Plan. This includes constructing the end pit lakes, final 

drainage channels, constructed wetlands, and outlet and inlet structures as 

required. Some recontouring of terrestrial areas may be required to respond 

to settlement of tailings materials, and to create appropriate slopes and 

aspects to achieve land capability objectives. 

3. Placement of suitable capping material (e.g., overburden), if required. 

4. Reclamation material placement on the recontoured areas. 

5. Revegetation of remaining landforms to target ecosites. 

6. The continuation of monitoring programs (water quality, soil, vegetation, 

wildlife, biodiversity), as necessary. 

7. Applying for Reclamation Certification of reclaimed areas. 

Request 94b How many years of reclamation work will need to occur after end of mine life? 

Response 94b Shell estimates that the reclamation activities described in the response to AENV 

SIR 94a will take approximately 10 years, except for monitoring and certification 

activities that will take place over a period negotiated with Alberta Environment. 

Request 94c At what year will Figure 29 of Volume 5 (final closure plan) be complete? 

Response 94c Shell estimates that Figure 29 will represent the year 2049. 



Shell provides a list of opportunities for progressive reclamation, including the 

construction of overburden dumps from the outside to the middle to allow 

reclamation of the outermost areas first. The response to SIR 402c and Figure 

402-2 indicates no reclamation will occur until 2031, when the dykes of the 

external tailings disposal area will occur (8 years prior to end of mine life). The 


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Section 15.1 

response to SIR 402c and Figure 402-2 do not seem to reflect those opportunities 

for reclaiming overburden dumps as they are constructed. 

95a Clarify and confirm that no opportunities for reclaiming any areas of overburden 

dumps exist prior to 2031 or revise the plan as applicable. 

Response 95a No opportunities exist for reclaiming areas of the overburden dumps at the Pierre 

River Mine before the end of 2029. As noted in the response to AENV SIR 92, 

construction of the first lift of the north overburden dump at the Pierre River 

Mine will not be completed until after 2029 because of the diversion of 

overburden materials into in-pit dykes between 2018 and 2029. As soon as the 

first lift is completed, reclamation on the north overburden dump will begin. 


Request Volume 2, SIR Question 410a, Page 23-27. 

Shell indicates that care has been taken to minimize the stockpiled time of 

reclamation salvage materials. 

96a Given the large extent of disturbance and the fact that any reclamation is delayed 

until 2031, justify this statement. 

Response 96a Two mechanisms have been considered to minimize the time that reclamation 

salvage materials are stockpiled, bearing in mind that permanent reclamation 

might not be possible until 13 years after mine operations start in 2018. 

• Although permanent reclamation activities might not be available until 2031, 

the opportunity to farm salvaged soils, particularly surface soils during 

temporary reclamation activities will be considered for any area that might 

become available, such as the first lift of the north overburden disposal area. 

• Material balances for peat-mineral materials have been calculated for salvage 

and stockpiling as close as possible to the time of reclamation, to minimize 

the time materials are stockpiled, and to optimize opportunities for direct 

placement of peat. All upland soils will be salvaged and direct placed, 

stockpiled or farmed. 


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Section 15.1 


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Request EIA Volume 2, Section 19.2. 

ERRATA 


Section 16.1 

This section outlines the EPEA application requirements for approval of the 

Pierre River Mine Project. The header on the pages in this section indicate 

Application for Renewal. This is incorrect. Correct this header as this is an 

application for approval for a new (proposed) project. 

Response 97 Shell acknowledges that the header in EIA, Volume 2, Section 19.2, pp. 19-3 to 

19-34, was incorrect. The correct heading should have read Application for 

Approval. This information is also presented in Section 2.1, Project Description 

Errata. 



Shell states that the chemical reaction scheme chosen for the CALGRID 

modelling assessment in 2000 was not specified. 

98a Given the potential for underestimating predicted ozone concentrations 

depending on which chemical reaction scheme is chosen as determined in the 

paper by Lueken et al. (2008) cited in the SIR, Shell should acknowledge that 

there is uncertainty in the accuracy of the predicted impacts on ambient ozone 


Response 98a The ozone modelling work using the CALGRID model was completed by Earth 

Tech and Conor Pacific in 1998 and 2000. In the 1998 ozone modelling work 

(Earth Tech and Conor Pacific 1998), Carbon Bond 4 (CB4) was chosen as the 

chemical reaction mechanism in the CALGRID model. In the 2000 ozone 

modelling work (Earth Tech Inc. 2000), the chemical reaction mechanism chosen 

for the CALGRID model was not specified. While Shell did not perform the 

CALGRID modelling, it is understood that there is uncertainty in the accuracy of 

the predicted ambient ozone concentrations provided in these two studies. 


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ERRATA AENV SIRS 97 – 98 

References 

Section 16.1 

Earth Tech and Connor Pacific (Earth Tech Inc. and Connor Pacific 

Environmental Technologies Inc.) 1998. Initial CALGRID Ozone 

Modelling in the Athabasca Oil Sands Region. Prepared for Syncrude 

Canada Ltd. 

Earth Tech Inc. 2000. Draft Report – CALGRID Photochemical Modeling of 

Ozone Formation Around the Wood Buffalo National Park during the 

Summer of 1998. Prepared for the Wood Buffalo Environmental 

Association. 


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ROUND 2 

% The symbol for percent. 

< The symbol for less than. 

> The symbol for greater than. 

GLOSSARY 

°C The symbol for degrees Celsius. 

μg/m³ The symbol for microgram per cubic metre. 

μm The symbol for micron. 

μs/cm The symbol for microsiemens per cubic metre. 

a The metric symbol for year. 

AAAQO The abbreviation for Alberta Ambient Air Quality Objectives. 

absorption The penetration of a substance into the body of another substance. 

adsorption The surface retention of solid, liquid or gas particles by a solid or liquid. 

AENV The abbreviation for Alberta Environment. 

AEP The abbreviation for Alberta Environmental Protection. 

AER The abbreviation for asphaltene energy recovery. 

ALCES The abbreviation for Alberta landscape cumulative effects simulator. 

Al-Pac The abbreviation for Alberta-Pacific Forest Industries. 

AOSP The abbreviation for Athabasca Oil Sands Project. 

Application Case The environmental effects of the proposed projects, combined with the 

effects identified in the Base Case. The Application Case was used in the 

original EIA for a direct comparison with the Base Case results, to predict 

the changes that result from the Jackpine Mine Expansion and the Pierre 

River Mine Project. 

April 2010 Shell Canada Limited GL-1 

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GLOSSARY 

aquatic Growing, living in or frequenting water. Also, occurring or situated in or 

on water. 

aquifer A water-saturated, permeable body of rock capable of transmitting 

significant or usable quantities of groundwater to wells and springs under 

ordinary hydraulic gradients. 

ARM The abbreviation for ambient ratio method. 

ASRD The abbreviation for Alberta Sustainable Resource Development. 

bank cubic metre A cubic metre of material in place. 

basal aquifer Permeable rock, deep below the surface, that is saturated with water. 

Base Case The existing environmental conditions and the environmental effects of 

existing and approved developments that might overlap with the 

environmental impacts of the proposed projects. 

baseline A surveyed or predicted condition that serves as a reference point on which 

later surveys are coordinated or correlated. 

bbl The abbreviation for barrel. 

bbl/cd The abbreviation for barrels per calendar day. 

bcm The abbreviation for bank cubic metres. 

benthic invertebrates Invertebrate organisms living at, in or in association with, the bottom 

(benthic) substrate of lakes, ponds and streams. 

BIP The abbreviation for bitumen in place. 

bitumen A naturally occurring viscous mixture, mainly of hydrocarbons heavier 

than pentane, that might contain sulphur compounds and that, in its 

naturally occurring state, will not flow to a well. 

blowdown The act of emptying or depressurizing material in a vessel. 

bog A peat-covered area or peat-filled wetland, generally with a high water 

table. 

C,C&R Plan The abbreviation for Closure, Conservation and Reclamation Plan. 

CALPUFF The California Puff air quality dispersion model, which predicts 

concentrations and deposition fluxes of air quality parameters. 

CCME The abbreviation for Canadian Council of Ministers of the Environment. 

cd The abbreviation for calendar day. 

GL-2 Shell Canada Limited April 2010 

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GLOSSARY 

CEAA The abbreviation for Canadian Environmental Assessment Association. 

CEMA The abbreviation for the Cumulative Environmental Management 

Association. 

closure plan A plan for the permanent closure of all or part of a mine or industrial 

facility, including removing process equipment, buildings and other 

structures, decontaminating the surface and subsurface, replacing soil, 

revegetating, designating end land uses and monitoring to ensure long-term 

performance. 

cm The metric symbol for centimetre. 

CO The chemical formula for carbon monoxide. 

cogeneration The simultaneous on-site generation of electrical power and process steam 

or heat from the same plant. 

CONRAD The abbreviation for Canadian Oil Sands Network for Research and 

Development. 

conservation The planning, management and implementation of an activity with the 

objective of protecting the essential physical, chemical and biological 

characteristics of the environment against degradation. 

consolidated tailings A non-segregating mixture of process plant tailings that consolidates 

quickly in tailings deposits. 

contouring The process of shaping the land surface to fit the form of the surrounding 

land. 

COPCs The abbreviation for chemicals of potential concern. 

COSEWIC The abbreviation for Committee on the Status of Endangered Wildlife in 

Canada. 

CT The abbreviation for consolidated tailings. 

CWD The abbreviation for coarse woody debris. 

d The abbreviation for day. 

DC The abbreviation for disturbance coefficient. 

DDA The abbreviation for designated disposal area. 


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GLOSSARY 

development area All areas to be disturbed for the project on and off Lease 13, including the 

overburden disposal area, reclamation stockpile areas, mine pit, external 

tailings disposal area, plant site, right-of-ways, Khahago Creek diversion, 

Kearl Lake outlet dam, Muskeg Creek realignment, and the new Kearl 

Lake outlet. 

DFO The abbreviation for Department of Fisheries and Oceans. 

dissolved oxygen Oxygen that is present (dissolved) in water and is, therefore, available for 

fish and other aquatic organisms. It is normally measured in mg/L 

(equivalent to ppm) and widely used as a criterion of water quality. 

DO The abbreviation for dissolved oxygen. 

dyke A bank of earth constructed to confine water. 

ecosite Ecological units that develop under similar environmental influences 

(climate, moisture and nutrient regime). Ecosites are groups of one or more 

ecosite phases that occur within the same portion of the moisture/nutrient 

grid. Ecosite is a functional unit defined by the moisture and nutrient 

regime. It is not tied to specific landforms or plant communities, but is 

based on the combined interaction of biophysical factors that together 

dictate the availability of moisture and nutrients for plant growth. 

ecosystem An integrated and stable association of living and nonliving resources 

functioning within a defined physical location. 

EIA The abbreviation for Environmental Impact Assessment. 

elevation The height above a given level, especially sea level. 

emissions Substances discharged into the atmosphere through a stack. 

environmental impact 

assessment 

A review of the effects that a proposed development will have on the local 

and regional environment. 

EPA The abbreviation for Environmental Protection Agency. 

EPEA The abbreviation for Environmental Protection and Enhancement Act. 

ERCB The abbreviation for Energy Resources Conservation Board. 

erosion The process by which material, such as rock or soil, is worn away or 

removed by wind or water. 

ERP The abbreviation for emergency response plan. 

ERT The abbreviation for emergency response team. 

ESP The abbreviation for electrostatic precipitator. 


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GLOSSARY 

ESR The abbreviation for environmental setting report. 

ETDA The abbreviation for external tailings disposal area. 

external tailings 

disposal area 

An artificial impoundment structure outside of the mine to contain tailings. 

The tailings disposal area is enclosed by dykes made to stringent 

geotechnical standards, using tailings and overburden materials. 

extraction The process of separating bitumen from oil sands, using warm water and 

steam. 

FGD The abbreviation for flue gas desulphurization. 

fines Silt and clay particles. 

footprint The amount and shape of the area occupied. 

g/d The abbreviation for grams per day. 

geology The study or science of the earth, its history, and its life as recorded in the 

rocks. It includes the study of geologic features of an area, such as the 

geometry of rock formations, weathering and erosion and sedimentation. 

geophysical Related to the physics of the earth and its environment, i.e., earth, air and 

space. 

geotechnical Related to the application of scientific methods and engineering principles 

to civil engineering problems, by acquiring, interpreting and using 

knowledge of materials of the crust of the earth. 

GHG The abbreviation for greenhouse gas. 

GJ The metric symbol for gigajoule. 

GJ/m 3 The metric symbol for gigajoules per cubic metre. 

graminoid fen or marsh Wetlands dominated by grass or sedge species. 

greenhouse gases Any of various gases, especially carbon dioxide, that contribute to the 

greenhouse effect. 

groundwater Subsurface water that occurs beneath the water table in soils and geological 

formations that are fully saturated. It is the water within the earth that 

supplies water wells and springs. 

H2S The chemical formula for hydrogen sulphide. 

ha The metric symbol for hectare. 

habitat The part of the physical environment in which a plant or animal lives. 


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GLOSSARY 

HHRA The abbreviation for human health risk assessment. 

HSE The abbreviation for health, safety and environment. 

HSI The abbreviation for habitat suitability index. 

hydrocarbon A compound consisting of only hydrogen and carbon. The simplest 

hydrocarbons are gases at ordinary temperatures. With increasing 

complexity of molecular structure they become liquids and solids. Natural 

gas and petroleum are mixes of hydrocarbons. 

hydrogeology The science dealing with the occurrence of surface and groundwater, its 

use, and its functions in modifying the earth, primarily by erosion and 

deposition. 

hydrology The science that treats the occurrence, circulation, distribution and 

properties of the waters of the earth, and their reaction with the 

environment. 

ILCR The abbreviation for incremental lifetime cancer risks. 

impact, environmental The effect on the environment. 

in situ In the ground, undisturbed. In its original place. 

interburden Sand and clay material that is interbedded with the bitumen ore. 

invertebrate An animal without a backbone and internal skeleton. 

karst A topography formed over limestone, dolomite, or gypsum and 

characterized by sinkholes, caves, and underground drainage. 

key indicator resource The environmental attributes or components identified as a result of a 

social scoping exercise as having legal, scientific, cultural, economic or 

aesthetic value. 

kg The metric symbol for kilogram. 

kg/m 3 The abbreviation for kilogram per cubic metre. 

KIR The abbreviation for key indicator resource. 

km The metric symbol for kilometre. 

km 2 The metric symbol for square kilometre. 

kPa The metric symbol for kilopascal. 


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GLOSSARY 

landform The configuration of the ground surface as a factor in soil formation. It 

includes slope steepness and aspect as well as relief. Also, configurations 

of land surfaces taking distinctive forms and produced by natural processes 

(e.g., hill, valley, plateau). 

lcm The abbreviation for loose cubic metres. 

LCR The abbreviation for lifetime cancer risks. 

Lease 13 The oil sands lease that Shell will mine for the Athabasca Oil Sands 

Project. 

littoral zone The zone in a lake that is closest to the shore. It includes the part of the 

lake bottom, and its overlying water, between the highest water level and 

the depth where there is enough light (about 1% of the surface light) for 

rooted aquatic plants and algae to colonize the bottom sediments. 

LSA The abbreviation for local study area. 

M The metric symbol for million. 

m The metric symbol for metre. 

m/s The metric abbreviation for metres per second. 

m 3 The metric symbol for cubic metres. 

m 3 /cd The abbreviation for cubic metres per calendar day. 

m 3 /d The abbreviation for cubic metres per day. 

m 3 /h The abbreviation for cubic metres per hour. 

m 3 /s/m The abbreviation for cubic metres per second per metre. 

mature fine tailings Fine tailings that have dewatered to about 30% solids during the three 

years following deposition. 

Mbbl The abbreviation for million barrels. 

Mbcm The abbreviation for million bank cubic metres. 

MFT The abbreviation for mature fine tailings. 

mg/kg The abbreviation for milligrams per kilogram. 

mg/L The metric symbol for milligrams per litre. 

migration Animals or birds changing their habitat, usually with the seasons. 


CR029

GLOSSARY 

mitigation The process of rectifying an impact by repairing, rehabilitating or restoring 

the affected environment, or the process of compensating for the impact by 

replacing or providing substitute resources or environments. 

mm The metric symbol for millimetre. 

Mm 3 The metric symbol for millions of cubic metres. 

modelling A simplified representation of a relationship or system of relationships. 

Modelling involves calculation techniques used to make quantitative 

estimates of an output parameter based on its relationship to input 

parameters. The input parameters influence the value of the output 

parameters. 

monitoring The process of measuring continuously, or at intervals, a condition that 

must be kept within set limits. 

Mt The metric symbol for millions of tonnes. 

Mt/a The metric symbol for millions of tonnes per annum. 

muskeg A thick deposit of partially decayed vegetable matter of wet boreal regions. 

N/A The abbreviation for not applicable. 

NAD The abbreviation for North American Datum. 

NIA The abbreviation for Noise Impact Assessment. 

NNLP The abbreviation for No Net Loss Plan. 

NO2 The chemical formula for nitrogen dioxide. 

NOx The chemical formula for oxides of nitrogen. 

NST The abbreviation for non-segregating tailings. 

nutrients Environmental substances, such as nitrogen or phosphorous, that are 

necessary for the growth and development of plants and animals. 

oil sands An unconsolidated, porous sand formation or sandstone containing or 

impregnated with petroleum or hydrocarbons. 

OLM The abbreviation for ozone limiting method. 

OMOE The abbreviation for Ontario Ministry of the Environment. 

orebody A solid and fairly continuous mass of ore, which may include low-grade 

ore and waste as well as pay ore, but is individualized by form or character 

from adjoining country rock. 


CR029

GLOSSARY 

OSDG The abbreviation for Oil Sands Developers Group, formerly the Regional 

Issues Working Group. 

overburden Material below the soil profile and above the bituminous sand. 

PAH The abbreviation for polycyclic aromatic hydrocarbons. 

PAI The abbreviation for potential acid input. 

parameter A distinguishing or defining characteristic or feature, especially one that 

may be measured or quantified. 

PDC The abbreviation for Planned Development Case. 

peat–mineral mixture A mixture of an organic horizon and the underlying mineral soil, or an 

organic horizon and mineral soil from another source, where the mineral 

soil in both cases is rated as good, fair or poor. 

permeability The ease with which gases or liquids penetrate or pass through a bulk mass 

of material, such as soil or sediments. 

pH The measurement of a substance’s acidity or alkalinity. 

Planned Development 

Case 

Includes the predicted impacts of the Jackpine Mine Expansion and the 

Pierre River Mine Project, plus the approved and publicly disclosed oil 

sands projects and planned oil sands projects in the region. In accordance 

with the Canadian Environmental Assessment Act, only residual impacts 

from the Application Case that were considered to have low to high 

environmental consequences were assessed in the Planned Development 

Case. 

PM The abbreviation for particulate matter. 

PM2.5 

The abbreviation for fine particulate matter with a diameter smaller than 

2.5 μm. 

polishing pond A water containment pond designed to remove suspended sediment from 

muskeg drainage, overburden dewatering, reclamation material storage 

area runoff and overburden disposal area runoff, before the waters are 

released to natural receiving streams. Also known as sedimentation pond. 

porewater Water between the grains of a soil or rock. 

ppb The abbreviation for parts per billion. 

ppm The abbreviation for parts per million. 

PRM The abbreviation for Pierre River Mine. 

PRMA The abbreviation for Pierre River Mining Area. 


CR029

GLOSSARY 

PSC The abbreviation for primary separation cell. 

PVA The abbreviation for population viability analysis. 

QA/QC The abbreviation for quality assurance and quality control. 

RAF The abbreviation for relative absorption factor. 

RAMP The acronym for Regional Aquatic Monitoring Program. 

receptor The person or organism subjected to chemical exposure. 

reclamation The process of returning disturbed land to a stable, biologically productive 

state. 

reclamation plan The detailed soil reconstruction and revegetation practices that are to be 

used for reclamation. Equivalent to the 10-year conservation and 

reclamation plan. 

reconstruction Selectively placing suitable overburden material on reshaped spoils. 

revegetation Establishing vegetation to replace the original ground cover following land 

disturbance. 

RfC The abbreviation for reference concentration. 

RFMA The abbreviation for registered fur management area. 

riparian Areas near or relating to a river. 

RIWG The abbreviation for Regional Issues Working Group, which has been 

renamed the Oil Sands Developers Group. 

RMS The abbreviation for reclamation material stockpile. 

RQ The abbreviation for risk quotient. 

RSA The abbreviation for regional study area. 

RSF The abbreviation for resource selection functions. 

runoff The portion of precipitation (rain and snow) that ultimately reaches streams 

via surface systems. 

sd The abbreviation for stream day. 

seepage The slow movement of water or other fluids through a process medium, or 

through small openings in the surface of unsaturated soil. 

SEIA The abbreviation for Socio-Economic Impact Assessment. 


CR029

GLOSSARY 

SEWG The abbreviation for Sustainable Ecosystem Working Group. 

SFR The abbreviation for sands-to-fines ratio. 

Shell The abbreviation for Shell Canada Limited. 

SIR The abbreviation for supplemental information request. 

slurry A free-flowing, pumpable suspension of fine solid material in liquid. 

SO2 The chemical formula for sulphur dioxide. 

soil Naturally occurring, unconsolidated mineral or organic material, at least 

10 cm thick, that occurs at the earth’s surface and is capable of supporting 

plant growth. 

species A group of organisms that actually or potentially interbreed and are 

reproductively isolated from all other such groups; a taxonomic grouping 

of genetically and morphologically similar individuals; the category below 

genus. 

SRD The abbreviation for sustainable resources and development. 

SRU The abbreviation for solvent recovery unit. 

stakeholders People or organizations with an interest or share in an undertaking, such as 

a commercial venture. 

stockpile A gradually accumulated reserve of material. 

Suncor The abbreviation for Suncor Energy Inc. 

Syncrude The abbreviation for Syncrude Canada Ltd. 

t The metric symbol for tonne. 

t/d The metric symbol for tonnes per day. 

t/h The metric symbol for tonnes per hour. 

t/sd The metric symbol for tonnes per stream day. 

tailings A by-product of oil sands extraction comprising water, coarse sand, fine 

minerals and minor amounts of rejected bitumen waste. 

TFT The abbreviation for thin fine tailings. 

topography The shape of the ground surface, such as hills, mountains or plains. 

TOR The abbreviation for terms of reference. 


CR029

GLOSSARY 

Total The abbreviation for Total E&P Canada Ltd. 

trapping Catching wild animals in traps. 

TROLS The abbreviation for terrestrial and riparian organisms, lakes and streams. 

TRS The abbreviation for total reduced sulphur. 

TSRU The abbreviation for tailings solvent recovery unit. 

TSS The abbreviation for total suspended solids. 

TT The abbreviation for thickened tailings. 

TV/BIP The abbreviation for total volume to bitumen in place. 

ungulate An animal that has hoofs. 

UTM The abbreviation for universal transverse mercator. 

UTS The abbreviation for UTS Energy. 

VOC The abbreviation for volatile organic compound. 

WASG The abbreviation for Wetlands and Aquatic Sub Group. 

WBEA The abbreviation for Wood Buffalo Environmental Association. 

WBMC The abbreviation for Wood Buffalo Métis Corporation. 

wetlands Land having the water table at, near, or above the land surface, or which is 

saturated for long enough periods to promote wetland or aquatic processes 

as indicated by biological activity adapted to the wet environment. 

WFGD The abbreviation for wet limestone flue gas desulphurization. 

WHO The abbreviation for World Health Organization. 

WMU The abbreviation for wildlife management unit. 

wt% The abbreviation for weight percent. 

yr The abbreviation for year. 

ZOI The abbreviation for zone of influence. 


CR029

Pierre River Mine Project

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