4.0 risk management and compliance - alberta · 2017-11-08 · risk management and compliance...

MEADOW CREEK WEST PROJECT VOLUME 1 PROJECT APPLICATION

Risk Management and Compliance September 2017

Suncor Energy Inc. 4.1

4.0 RISK MANAGEMENT AND COMPLIANCE

4.1 RISK MANAGEMENT

4.1.1 Risk Management Principles

Risk management at Suncor is driven through its Operational Excellence Management System (OEMS), which defines the framework Suncor uses to assess and systematically eliminate root causes of risks that affect reputation, performance in safety, reliability, environment and cost while also allowing Suncor to identify opportunities for continuous improvement in all of these areas (Section 1.1). The OEMS framework uses a continual improvement cycle (plan-do-check-act) approach through a number of system elements including risk management, legal requirements and commitments, operations and maintenance controls, emergency management, communication and stakeholder relations, quality assurance, incident management, and corrective actions, among others.

As set out in Suncor’s Risk Management Policy, we are committed to a culture of operational discipline including the proactive, transparent and consistent identification and management of risk. This discipline allows Suncor to balance risks and opportunities in a structured and systematic way. Suncor makes risk-informed decisions that reflect our triple-bottom line responsibilities and obligations, the input of our stakeholders, and our guiding principles for risk management.

4.1.2 Risk Management Approach

Suncor’s Risk Management Standard provides a consistent approach to risk management and the tools to implement the standard. Suncor’s risk management approach is an iterative process that is aligned with CAN/CSA-ISO 31000-10 Risk Management - Principles and Guidelines. Over Meadow Creek West Project’s lifecycle, the risk management program will ensure that Suncor:

• delivers on sustainable development commitments (economic, environmental, and social)

• operates in a safe, reliable, and compliant manner

• drives efficient, orderly, and environmentally responsible development of the oil sands resource.



4.2 Suncor Energy Inc.

The risk management process applied to the Meadow Creek West Project includes the following steps:

1. Set the Context: Understand the external setting in which the Project will be developed and operated to be taken into account when setting the scope for managing risk and risk analysis. In general, the external setting for the Project includes the sub-surface context (geology and reservoir), environmental context (air, terrestrial, aquatic) and the socio-cultural context (traditional land use, socio-economics, land use, human health). The Meadow Creek West Project context is detailed in Section 2.

2. Risk Assessment: Identify context-specific risks through the Project EIA (Volume 2) and stakeholder engagement by considering the potential for Project activities (Section 3) to impact the environment, stakeholders, resource conservation and public safety, within the Project context. Determine principal risks that are considered unacceptable after considering standard operational and design controls, standard operating procedures and best management practices and mitigations. For risks identified through the EIA, principal risks are defined as those potential environmental consequences rated as moderate or high after considering standard mitigations.

3. Risk Treatment: Identify risk treatment plans. Treatment options may include risk receptor monitoring, engineered controls, procedural solutions and adaptive management plans.

4. Monitor and Review: Evaluate and review the effectiveness of risk treatment plans and implemented controls. Regularly review project risks and modify as required based on changes to the project context or project activities.

5. Communicate and Engage: For potentially impacted stakeholders and/or appropriate regulators, communicate information on the status of relevant risks and the effectiveness of risk treatments. Engage with stakeholders and/or appropriate regulators throughout the risk management process (Section 5). Suncor will provide updates on the status of and changes to principal risks to stakeholders and/or appropriate regulators as part of the long--term stakeholder engagement plan (Section 5) and/or to the AER as part of performance and environmental reporting (Section 4.4).




4.2 INDENTIFIED RISKS

4.2.1 Principal Risks Identified by Environmental Impact Assessment

The Meadow Creek West EIA identified potential interactions between the Project and the environment and evaluated these interactions in the context of potential residual and cumulative effects (Volume 2). Project-related environmental effects and cumulative environmental effects were assessed using a standardized methodological framework for each environmental or social valued component as part of the EIA (Volume 2, Section 2).

Residual Project-related social and environmental effects were characterized using specific criteria (i.e., direction, magnitude, geographic extent, duration, frequency and reversibility). Where practical, the consequences of the Project-related social and environmental effects were then determined based on pre-defined criteria that reflect a variety of considerations including provincial and federal regulatory requirements, standards, objectives, guidelines, and other planning objectives. In some cases, particularly where standards, guidelines or regulatory requirements do not exist, thresholds for measurable parameters inform the determination of consequence (Volume 2, Section 2).

A summary of the consequence ratings of residual effects and cumulative effects as determined by the EIA is provided in Table 4-1 and Table 4-2, respectively. Generally, the consequence ratings for Project effects were determined to be low or it was determined that the Project activities will meet regulated criteria (air quality and acoustic environment). No residual or cumulative effects were determined to have a high consequence rating.

Based on the EIA, three residual effects are predicted to have moderate consequence ratings:

• Effects on groundwater levels in the Leismer Channel Aquifer and Lower Grand Rapids Aquifer due to groundwater withdrawals by the Project and cumulatively in combination with other existing and proposed nearby projects.

• Effects on a local woodland caribou herd (and associated change in biodiversity) due to loss of moderate and high suitability habitat by the Project and cumulatively in combination with other existing and proposed projects.

• Effects on the availability of traditional resources for current use.

Based on these results, impacts to groundwater resources, specific wildlife and wildlife habitat, and Aboriginal stakeholders are considered principal risks and are further discussed in Section 4.3.




4.2.2 Principal Risks Identified by Stakeholder Engagement

Aboriginal stakeholders have expressed concern that Project activities and land disturbance could affect traditional land use and environmental resources that traditional land use activities depend on, such as wildlife, water bodies and wetlands (Section 5.2). Aboriginal stakeholders have also expressed concern that development of the Project, and industrial development in general in the Wood Buffalo region, could result in adverse socio-economic impacts. Non-Aboriginal stakeholders have expressed concern that Project activities could affect their activities related to surface rights they currently hold within the Project Area or may seek in the future.

Based on stakeholder engagement, impacts to Aboriginal stakeholders, wildlife and wildlife habitat, water bodies and wetlands, socio-economic conditions, surface rights holders and land disturbance are considered principal risks of the Project.

4.2.3 Other Principal Risks

Other principal risks identified by Suncor based on planned long-term project activities include the remote possibility of a failure of the potential high-pressure steam pipeline crossing of Highway 63, and the resulting risk to public safety and transportation infrastructure.

4.2.4 Other Identified Risks

Other risks, not considered principal risks, are identified in Table 4-3. As risk management by definition is transitory, the risks identified in Table 4-3 are not an exhaustive list of all risks the Project may be subject to change over the lifetime of the Project. Suncor will develop and maintain an active Meadow Creek West risk management plan, in accordance with Suncor’s Risk Management Standard, to identify and manage identified risks associated with the Project.

4.2.5 Sensitivity Mapping of Principle Risks

Suncor undertook sensitivity mapping to assist with the identification of siting considerations of principle risks in the Project area. Sensitivity mapping considered the following: third party surface rights holders under the Public Lands Act; moderate and high suitability habitat for woodland caribou; and mapped watercourses and their corresponding development setback. The corresponding setbacks around the mapped watercourses also encompass suitable habitat for a variety of wildlife species of concern. These risks were included because they have the potential to impact the siting of Project infrastructure and help Suncor implement its risk management program.

Figure 4-1 shows third party surface rights holders. Third party surface rights in the Project area are in place for pipeline and power transmission line rights-of-way, oil and gas exploration, surface resource extraction, Sand Tiger Lodge and disposition reserves (research plots and Grayling Creek Fire Base).




Figure 4-2 illustrates Order 3, 4 and 5 surface watercourses and their corresponding development setbacks, and areas of moderate to high caribou habitat. Order 3, 4 and 5 watercourses include the Hangingstone River, Little Horse Creek, the Horse River and associated tributaries. Mapping was limited to higher classes of watercourses because these are more likely to have definable bed and banks where codes of practice for watercourse crossings will be implemented. Also included on Figure 4-2 are moderate and high suitability caribou habitat, which is most prominent across the north and northwest parts of the Project area. The spatial representation of watercourses and caribou habitat in the Project area will assist with the implementation of mitigation for these principle risks.

Mitigation measures for working within or near to third party surface rights holders, sensitive wildlife habitat (including caribou) and defined watercourses are provided in Section 4.3.

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Figure 4-1

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Third Party Disposition Holders in the Project Area

Disclaimer: This map is for illustrative purposes to support this Suncor project; questions can be directed to the issuing agency.Sources: Base Data - GeoLogic (2015), AltaLIS. Thematic Data - Stantec (2017).

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Disposition TypeDisposiion ReservationEasementIndustrial Sample PlotLicense of Occupation

Minerals Surface LeaseMiscellaneous LeaseMiscellaneous PermitPipeline AgreementPipeline InstallationLeaseRoadwaySurface MaterialExplorationLicense/SurfaceMaterial Lease

FootprintProject AreaAccess (Primary)Access (Secondary)Township

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Figure 4-2

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SUNCOR ENERGY - MEADOW CREEK WEST

Environmental Sensitivities within the Project Area

Disclaimer: This map is for illustrative purposes to support this Suncor project; questions can be directed to the issuing agency.Sources: Base Data - GeoLogic (2015), AltaLIS. Thematic Data - Stantec (2017).

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Class 3 Watercourse with45 m SetbackClass 4/5 Watercoursewith 100 m SetbackModerate SuitabilityHabitat for WoodlandCaribouHigh Suitability Habitatfor Woodland Caribou

FootprintProject AreaAccess (Primary)Access (Secondary)Township

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Table 4-1 Summary of Environmental Consequence Ratings of Project Residual Effects

Valued component

Potential Environmental Effect Summary of Project Activities Associated with Valued Component

Consequence Rating

EIA (Volume 2) Section

Reference Air Quality Change in ambient air

quality Evaluation of potential emissions from the Project and other emission sources in the region; ambient air quality compared with air quality and acid forming deposition criteria

Meets criteria Section 5.9

Change in deposition Below critical deposition load criteria

Section 5.9, 9.7, 11.10, 12.10

Acoustic Environment

Change in acoustic environment

The acoustics assessment identified and quantified noise effects associated with Project operation, along with noise from other sources in the region.

Complies with AER Directive 38 criteria.

Section 6.5

Hydrogeology Change in groundwater quantity

The hydrogeology assessment considered groundwater resources that could be directly or indirectly affected by Project activities including groundwater withdrawal, construction and operation of surface facilities, steam injection into SAGD wells and wastewater disposal.

Moderate Section 7, Appendix 7A

Change in groundwater quality

Low Section 7.6

Hydrology Change in hydrology Project effects on hydrology resulting from alteration of land cover, seasonal base flow, ground heave/subsidence, surface water withdrawals and watercourse erosion.

Low Section 8.6

Surface Water Quality

Change in surface water quality

Interaction of the Project on surface water quality was assessed for: introduction of sediment to waterways, accidental spills, water withdrawals from surface water sources

Low Section 10.10

steam injection and groundwater heating Low Section 7.6

oxides of sulphur (SOX) and oxides of nitrogen (NOX) emissions and compared to critical load criteria

Low (below critical load criteria)

Section 9.7

Fisheries Alteration of fish habitat Project activities that could potentially affect fisheries would occur during construction, resulting in changes in changes in fish habitat availability, barriers to movement, direct mortality and release of deleterious substances

Low Section 10.10

Loss of fish habitat

Fish mortality





Valued component


Consequence Rating


Reference Soils and Terrain

Change in soil quality Project activities that could affect soil quantity and quality include soil salvage, storage and replacement, spills and releases, vehicle traffic, air emissions, vegetation removal and coarse woody debris management and reclamation activities.

Low

Section 11.10 Change in soil quantity

Change in soil series diversity

Change in soil acidification

Low (below critical load criteria)

Section 11.10

Vegetation and Wetlands

Change in landscape diversity

Project activities associated with soil stripping and vegetation removal, along with spills and releases have the potential to affect vegetation and wetlands. Changes in water levels can affect wetland hydrology. Project related air emissions also have the potential to affect vegetation and wetland health.

Low

Section 12.10

Change in community diversity

Change in species diversity

Change in air emissions and vegetation health

Wildlife Change in habitat Project activities can directly or indirectly affect wildlife or wildlife habitat. These include activities that result in destruction and degradation of habitat, including soil stripping and vegetation clearing, sensory and mortality through increased traffic. For each key indicator species, the determination of environmental consequence was assessed, using the magnitudes of change predicted under the Project residual effects classification. Magnitude ratings were based on ratings for changes in habitat, movement and mortality risk

Low Section 13.10 Change in movement

Change in mortality risk Moderate





Valued component


Consequence Rating


Reference Biodiversity Change in landscape

and community diversity Project activities that potentially affect both vegetation and wetland and wildlife are also likely to affect biodiversity.

Low Section 12.10

Change in habitat

Change in biodiversity potential

Low Section 13.7

Change in woodland caribou

Moderate Section 13.10

Land-Use and Management

Change to oil and gas and other industrial activities

Project activities can be directly and indirectly affect land use and land users through activities on Crown land, oil and gas and other industrial developments, commercial timber harvesting, consumptive recreation and non-consumptive recreation including parks and protected areas.

Low Section 14.10

Change to forestry and fire management

Change to consumptive recreation

Change to non-consumptive recreation

Historical Resources

Loss of historical resources site contents, context and interpretive value

Project activities have the potential to adversely affect historical resources primarily through the construction phase.

Neutral – no interaction predicted

Section 15.5





Valued component


Consequence Rating


Reference Traditional Ecological Knowledge and Land Use

Change in availability of traditional resources for current use

The Project could affect traditional activities, sites and resources identified by Aboriginal groups. Interaction of the Project on availability of traditional resource for current use was assessed for habitat for traditionally used plant or animal species, movement patterns, mortality risk and wildlife health were assessed to have a low to moderate residual effect.

Not rated: TLU assessment assesses effects on people who use the environment, but there is currently no clearly established means to judge and gauge how affected individuals and groups may respond to project effects.

Section 16.5

Change in access to traditional resources for current use or current use sites and locations

Interaction of the Project on access to traditional resources for current use or current use sites and locations was assessed for loss or alteration of trails and travelways, restrictions on the ability to navigate to and through current use areas or limitations on the ability to undertake current use activities were assessed to have a low residual effect.

Change in current use of sites or areas

Interaction of the Project on current use of sites or areas was assessed for harvesting sites and areas, sites and areas for cultural or spiritual practices, or archaeological or palaeontological sites and areas were assessed to have a moderate residual effect.

Socio-economics

Change in employment, income and fiscal benefits

Interaction of the Project on employment, income and fiscal benefits was assessed for construction and operation spending including personal employment, local business and contracting opportunities, regional and provincial economic and fiscal benefits, including personal and business income, and government tax and royalty income Interaction of the Project on aspects of the human environment were assessed for population, housing, health services, education, emergency services, transportation, social and municipal infrastructure and Aboriginal traditional land use and culture.

Not rated: The Project will have a net positive economic effect.

Section 17.11

Change in aspects of the human environment

Human Health Acute health risks Project acute health risks was assessed for acute inhalation risk estimates, expressed as RQs, were based on exposure periods that range from a few minutes to 24 hours for Aboriginal peoples, workers and area users.

Not rated: no management measures recommended.

Section 18.4

Chronic health risks Project chronic health risks was assessed for potential health risks that could result from chronic exposure to the COPC for the Aboriginal peoples and workers. Separate assessments were completed for (i) the primary inhalation pathway; and (ii) all exposure pathways combined (i.e., inhalation and applicable secondary exposure pathways).




Table 4-2 Summary of Environmental Consequence Ratings of Cumulative Effects

Valued component

Potential Environmental

Effect Summary of Project Interaction with Valued Component Consequence

Rating


Reference Air Quality Change in ambient

air quality Interaction of the Project on ambient air quality was compared cumulatively to respective ambient air quality criteria with Project contribution to air quality found not to make a substantive contribution to these values.

Meets criteria. Section 5.9

Change in deposition

Interaction of the Project on deposition of acid-forming (PAI) emissions and nitrogen was compared to critical load criteria.

Low Section 5.9, 9.7, 11.10, 12.10

Acoustic Environment

n/a n/a n/a Section 6.5

Hydrogeology Change in groundwater quantity

Cumulative effects on groundwater quantity were assessed for changes in shallow non-saline Quaternary aquifers as a result of groundwater withdrawal.

Low Section 7, Appendix 7A

Change in groundwater quality

Cumulative effects on groundwater quality were assessed for changes in shallow non-saline Quaternary aquifers as a result of surface facilities and production and steaming.

Low Section 7.6

Hydrology n/a n/a n/a Section 8.6

Surface Water Quality

Change in surface water quality as a result of air emissions

Potential effects of air emissions on surface water quality were assessed for changes in PAI deposition.

Low Section 9.7

Fisheries Fish mortality The low magnitude of residual cumulative effects is predicted to not affect quantity and productive capacity of the aquatic environment or the sustainability and ongoing productivity of CRA fisheries. Serious harm to fish is not predicted.

Low Section 10.8

Soils and Terrain

Change in soil acidification

Potential effects of air emissions on soils and terrain were assessed for changes in PAI deposition.

Low Section 11.10





Valued component



Rating


Reference Vegetation and Wetlands

Landscape diversity Cumulative effects for landscape diversity assessed changes to regional vegetation cover classes, vegetation patch dynamics and traditional plant use potential.

Low Section 12.10

Air emissions and vegetation health

Effects of air emissions on vegetation health were assessed cumulatively based on critical levels of SO2, critical levels of NOX, and critical loads of nitrogen deposition.

Low Section 12.10

Wildlife Key indicator species: changes in habitat, movement and mortality risk

moose, fisher, Canada lynx, beaver, little brown and northern myotis, yellow rail, olive-sided flycatcher, Canada warbler, rusty blackbird, western toad, Canadian toad

Low Section 13.10

woodland (boreal) caribou Moderate to high Section 13.10

Biodiversity Change in biodiversity

Cumulative effects to biodiversity were assessed for landscape diversity, biodiversity potential and woodland caribou.

Low to moderate Section 12.10, 13.10

Land Use and Management

Change in land-use and management

The Project will comply with established land use plans or policies including LARP, which supports development of the region and optimizing its oil sands reserves while maintaining economic opportunities in forestry, minerals and recreational opportunities.

Low Section 14.10

Historical Resources

n/a n/a n/a Section 15.4





Valued component



Rating


Reference Traditional Ecological Knowledge and Land Use

Availability of traditional resources for current use

The Project’s contribution to effects on the availability of traditional resources will be localized in the context of the TRSA. The greatest decrease in regional cover classes for wildlife species of traditional importance represent <1% of the TRSA. The Project will have a limited contribution to the loss of availability of traditional resources in the TRSA and is assessed as contributing a low to high cumulative residual effect.

Not rated: TLU assessment assesses effects on people who use the environment, but there is currently no clearly established means to judge and gauge how affected individuals and groups may respond to project effects.

Section 16.6

Access to traditional resources for current use or to current use sites and locations

The Project’s contribution to effects on access to traditional resources will localized in the context of the TRSA. The project is not expected to alter overall access to Traditional Resources within the RSA and is assessed as contributing a low cumulative residual effect.

Change in current use of sites or areas

The Project’s contribution to effects on current use sites and areas will be localized in the context of the TRSA. The Project will have a limited contribution to the loss of land available to practice TLU activities within the TRSA and is assessed as contributing a low to moderate cumulative residual effect.

Socio-economics

n/a n/a Not Rated: The Project will have a net positive economic effect.

Section 17.11

Human Health Acute health risks Interaction of the Project on acute health risks was assessed for acute inhalation risk estimates, expressed as RQs, were based on exposure periods that range from a few minutes to 24 hours for Aboriginal peoples, workers and area users.

Not rated: no management measures recommended.

Section 18.4

Chronic health risks Interaction of the Project on chronic health risks was assessed for potential health risks that could result from chronic exposure to the COPC for the Aboriginal peoples and workers. Separate assessments were completed for (i) the primary inhalation pathway; and (ii) all exposure pathways combined (i.e., inhalation and applicable secondary exposure pathways).

NOTE: n/a – not applicable – residual effects for the valued component are not predicted to act cumulatively at either local and regional scales.




4.3 RISK MITIGATIONS

4.3.1 Principal Risks

4.3.1.1 Impacts to Aboriginal Stakeholders

Consultation and engagement has been ongoing with Aboriginal communities to ensure the regulatory process is fulfilled and concerns with the Project are addressed. Engagement has also been underway to support Traditional Use Studies and to share information with community members so the Project is informed of local concerns (Section 5.2).

Engagement efforts have allowed Suncor to mitigate risk through improvements to project design that avoid culturally sensitive areas and provide economic opportunity where possible. Suncor has also developed a long term consultation plan for the life of the project to continue to share information with members of the community and ensure that a process is in place for concerns to be communicated to Suncor on an ongoing basis.

The Project will reduce risks to Aboriginal communities through:

• ongoing engagement about concerns and potential impacts over the life of the project (Section 5.4)

• open and transparent dialogue

• regulatory updates

4.3.1.2 Impacts to Groundwater Resources

Numerical groundwater modelling conducted as part of the Hydrogeology Impact Assessment (Volume 2, Section 7, Appendix 7A) indicated that cumulative groundwater withdrawals from the Grand Rapids ‘C’ aquifer, before planned groundwater withdrawals by the approved Meadow Creek East and subject Meadow Creek West projects are considered, could be near or at regulated groundwater drawdown limits (50% drawdown within 150 m of water source wells) as specified in Alberta’s Water Conservation and Allocation Guideline for Oilfield Injection. After factoring in planned withdrawals by both the Meadow Creek projects and other projects, the groundwater model predicted that groundwater drawdown limits will be exceeded in the Grand Rapids ‘C’ aquifer. Available empirical data collected by Suncor at Meadow Creek and by Nexen at Long Lake suggests that the Project groundwater flow numerical model is conservative in that it is over predicting the drawdown in the Grand Rapids ‘C’ aquifer within the Project area (Volume 2, Section 7, Appendix 7A).




To mitigate the risk of the Project affecting groundwater levels, Suncor will develop and implement a Groundwater Management Plan (Section 3.8) acceptable to the AER prior to initiating groundwater withdrawals that will include the following objectives and commitments:

• comply with the Government of Alberta’s Water Conservation and Allocation Guideline for Oilfield Injection which specifies that aquifer drawdown must be limited to 35 percent during the first year of operation and no more than 50 percent over the life of the Project, as measured in an observation well at a distance of 150 metres from a water source well

• install groundwater monitoring wells within 150 m of all water source wells in the Empress and Grand Rapids ‘C’ aquifers to ensure compliance with Alberta’s Water Conservation and Allocation Guideline for Oilfield Injection

• monitor for changes in groundwater quality due to thermal effects

• develop an adaptive water source pumping strategy whereby the distribution of pumping rates between Grand Rapids ‘C’ and Empress water source wells will be modified in response to observed aquifer drawdown

• continue to participate in regional groundwater modelling of the South Athabasca oil sands region to understand impacts on hydraulic pressure in aquifer given cumulative oil sands in-situ development

• strive to achieve COSIA’s in-situ performance goal to reduce fresh water use intensity by 50% by 2022 across Suncor’s in-situ assets

• continue to research alternative make-up water sources such as saline groundwater and treated industrial or municipal wastewater.




4.3.1.3 Impacts to Wildlife and Wildlife Habitat (and Biodiversity)

The Project area is known to provide habitat for a number of provincial and federal wildlife species of concern and is mostly encompassed by the East Side Athabasca River Caribou Range (Section 2.3). Impacts to these species and their habitat may be expected during project construction and to a lesser degree, during operations. These potential impacts will be largely controlled through compliance with existing regulations and guidelines including restricted activity periods, constructing wildlife crossings for above-ground pipelines, avoidance of dens and nesting sites, implementation of a Caribou Protection Plan, and mitigating the impacts of land disturbance (Section 4.3.1.4). Suncor will also develop and implement a Wildlife Mitigation and Monitoring Plan (Section 3.8) acceptable to the AER prior to construction focusing on selected provincial and federal species of concern to reduce potential impacts to wildlife and wildlife habitat. This plan is typically placed on a three year renewal cadence to incorporate adaptive management to assess mitigations against metrics and targets. The plan will include:

• implementing a Caribou Protection Plan

• designing and constructing wildlife crossings for above-ground pipelines to comply with Alberta Environment and Park’s Above Ground Pipeline Wildlife Crossing Directive

• monitoring selected species at risk, and culturally important species and their habitat

• implementing traffic and speed controls for roads under the control of Suncor

• prohibiting hunting in the Project area by Suncor staff and contractors while on shift

• reporting and tracking all wildlife sightings including incidental observations

• ensuring the Project meets the Alberta BearSmart objectives

• managing site domestic waste to discourage scavengers.

Suncor will also collaborate with others to understand the ecosystem value of existing, disturbed, and future reclaimed lands to better develop wildlife mitigation plans. Suncor is already working collaboratively at a regional scale on initiatives related to caribou. For example, restoring historic linear disturbances has the potential for improved woodland caribou habitat quality and herd survival. Two major COSIA initiatives are underway to address legacy linear disturbances and return the boreal forest to high quality caribou habitat. The Algar Historic Restoration Project (Algar) and the Linear Deactivation Project (LiDea) are both aimed at addressing rehabilitating seismic lines. The two projects involve different approaches and methodologies, with the intent of sharing learnings across the COSIA companies as the projects progress.




4.3.1.4 Impacts of Land Disturbance

The Meadow Creek West Project will disturb land due to the development of roads, wells, well pads, facilities and pipelines. Land conservation and reclamation is integral to limiting adverse impacts due to land disturbance.

A Conceptual Conservation and Reclamation Plan has been provided in Section 6, which describes how lands developed within the footprint of the Project will be returned to equivalent land-use capability after reclamation. The objective of the plan is to serve as a guide for the construction, operation and reclamation of the Project in a manner which allows for the return of project-level equivalent land capability post-reclamation. Suncor’s goal is to certify reclaimed land and return it to the Crown. The general objective of the reclamation program at Meadow Creek West is as follows:

Developed lands shall be reclaimed to a self-sustaining, locally common boreal forest ecosystem, compatible with pre-development, including forested areas, wetlands and streams. The reclaimed lands will provide a range of end uses, including forestry, wildlife habitat, traditional use and recreation.

In addition, through COSIA, Suncor is working towards reducing the footprint intensity and impact of its oil sands projects on the land and wildlife of northern Alberta by working on the following key issues;

• footprint reduction — more efficient use of land by reducing the extent of industrial footprints

• accelerated reclamation — reclaiming and restoring disturbed land in a timely manner;

• preserving biodiversity — maintaining natural diversity including bird, mammal and fish species with a focus on species of management concern.

Suncor will provide conservation and reclamation updates to stakeholders as part of the long-term stakeholder engagement plan (Section 5.4), and will provide updates to the AER in a manner deemed appropriate to the Director. The regular conservation and reclamation updates may include as-built information from the previous year including: tree clearing, soil salvage, soil stockpile, soil placement, revegetation, erosion control, weed control, reclamation monitoring and may also include submission of geospatial information.

4.3.1.5 Impacts to Wetlands and other Water Bodies

The Meadow Creek West Project area contains wetlands. Suncor will strive to limit disturbance to wetlands during Project development; however, some disturbance to wetlands is expected.




Suncor will limit adverse impacts to wetlands and other water bodies by implementing the following measures:

• locating surface development outside of setbacks from water bodies, with the exception of water body crossings, and limiting disturbance of wetlands (Section 3)

• using industry best practices and follow codes of practices including Alberta Environment and Parks’ Code of Practice for Pipelines and Telecommunication Lines Crossing a Water Body and Code of Practice for Watercourse Crossings

• placing culverts along roads in appropriate locations to maintain surface and near-surface water drainage patterns during operations

• ground-truthing wetland and water body maps as part of the construction planning process

• reclaiming wetlands where appropriate as part of the project reclamation and closure plan (Section 6)

• considering learnings from the Firebag Wetland Reclamation Trial Program (EPEA Approval No. 80105‐01‐00), which is investigating whether building surface developments directly on top of shallow peat will improve the likelihood of successful wetland reclamation and return to a suitable hydrologic environment.

Suncor will also implement a Wetland and Water Body Monitoring Plan that will include monitoring for Project impacts and natural variability (Section 3.8).

4.3.1.6 Impacts to Surface Rights Holders

There are currently other surface rights holders within the Project area (Volume 2, Section 14) and other land users may be granted surface rights in the future. There is a risk that the Meadow Creek West Project could impact other surface rights holders within the Project area (Figure 4-1).

Suncor’s normal course of business for any new surface disturbance within approved project boundaries in the planning stages includes a thorough review of up-to-date title searches and engagement with any third parties identified on the land to request an appropriate third party agreement to access, cross, or work in proximity to existing dispositions. No work begins until required agreements are in-place; copies of which are provided to field personnel for referral as work proceeds. Normal agreement terms include ongoing notification to the third parties of activity to ensure safe operations are conducted and not restrictive to the overlapping rights holders.




This aligns with industry best practices of shared use of public lands when/as required for responsible energy development. If any concerns are raised through the process (e.g., engineering specifications required for managing weight factors across roads), Suncor consults with the third-party to ensure relevant risks are managed. Suncor also builds and maintains positive and cooperative relationships with third-parties within project boundaries through ongoing dialogue at the field level of upcoming activities and information sharing. Surface rights holders will also be engaged through the long-term stakeholder engagement plan for the Project (Section 5.4).

4.3.1.7 Pipeline Failure

The Project development plan includes pipelines that will transport fluids from well pads to the Project CPF and pipelines that will transport steam to well pads. A failure of a pipeline could result in a spill or steam release that could affect wildlife, vegetation, soils, water quality, aquatic ecology, groundwater, traditional land use and public safety.

Mitigation of this risk includes Suncor’s commitment to construct pipelines to Canadian Standards Association (CSA) standards. High quality pipeline material, anti-corrosion coatings and consideration to CSA Z662 will be incorporated into the pipeline design. The pipelines will be pressure tested before being put in active service to identify any potential weak areas. The pipelines will also be monitored, inspected and preventive maintenance programs initiated as part of the Project’s risk management program.

In the event of a release Suncor will have a spill response, reporting and remediation standard operating procedures in place to direct field and site staff. If required, Suncor environmental subject matter experts will manage the secondary assessment and any remediation of spill and release sites to appropriate remediation and reclamation guidelines.

4.3.1.8 Steam Pipeline Crossing under Highway 63

The development plan for the Meadow Creek West project includes a potential, future pipeline crossing of Highway 63 at NW8-85-10-W4M (Figure 1-2). A high pressure steam pipeline carrying steam from the CPF to well pads east of Highway 63 is included in the planned pipeline crossings. A failure of this steam pipeline at Highway 63 could pose a risk to public safety and transportation infrastructure.

The current schedule for development of Meadow Creek West would not require the Highway 63 crossing until approximately 2040. Suncor will engage with Alberta Transportation, ABSA, the AER and stakeholders as the schedule for design and construction of the crossing draws nearer. Suncor is committed to safe pipeline design and operations (Section 4.3.17) and will ensure the crossing design effectively mitigates risks to public safety and transportation infrastructure.




4.3.2 Other Identified Risks

Mitigations for risks that are not considered principal risks are identified in Table 4-3.

4.3.3 Project Commitments

A complete list of Project commitments, including standard operational and design controls, standard operating procedures, best management practices and Project-specific mitigations to mitigate Project risks, is included in Table 4-4.




Table 4-3 Other Project Related Risks and Mitigations

Risk Mitigation

Non-optimal resource recovery

Suncor has conducted and will continue extensive geologic investigations including a comprehensive oil sands exploration program and acquisition of 2D and 3D seismic data periodically to facilitate optimal placement of SAGD wells, within operational constraints (Section 3.2).

Reservoir containment and formation integrity

Geological studies have demonstrated the Clearwater Shale as competent caprock (Section 2.2). Suncor has conducted mini-frac studies to understand the reservoir pressure restrictions. The pressure restrictions are reflected in the maximum operating pressure strategy which is designed to maintain formation integrity (Section 3.2). Suncor will install caprock monitoring wells before the commencement of SAGD operations.

Impacts to fish and fish habitat

Surface development will be conducted using industry best practices and follow codes of practices including Alberta Environment and Parks’ Code of Practice for Pipelines and Telecommunication Lines Crossing a Water Body and Code of Practice for Watercourse Crossings. Fishing within the Project Area will be prohibited by Suncor staff and contractors while on shift.

Impacts to groundwater quality

The intermediate sections of the wells will be cased and cemented with thermal cement from the intermediate total depth to ground surface to hydraulically isolate non-saline groundwater and any permeable strata that may be encountered in these sections of the borehole. Industry-recommended practices will be used during drilling and cementing to hydraulically isolate non-saline groundwater intervals. Suncor will construct the Project disposal wells in accordance with AER directives including Directive 051: Injection and Disposal Wells – Well Classifications, Completions, Logging, and Testing Requirements. Adequate wellbore construction will ensure wellbore integrity and disposal fluid containment within the disposal zone and minimize potential impacts to adjacent or up-hole aquifers.

Impacts to historical resource

Suncor will obtain Historical Resources Act clearances for specific Project elements prior to surface disturbance as development proceeds.

Potential for spills, releases and ground contamination

In the event of a release Suncor has spill response, reporting and remediation standard operating procedures in place to direct field and site staff. If required, Suncor environmental subject matter experts will manage the secondary assessment and remediation of a spill and release sites to the appropriate remediation and reclamation guidelines. Above-ground storage tanks for hydrocarbons and other process-related fluids will be engineered, constructed, operated and maintained in accordance with AER Directive 055: Storage Requirements for the Upstream Petroleum Industry

Risk to public safety An emergency response plan will be designed in accordance to Directive 071: Emergency Preparedness and Response Requirements for the Petroleum Industry.

Potential for resource sterilization and impacts on resource conservation

Scheme performance is required reporting in the annual performance presentation as required by Directive 054: Performance Presentations, Auditing, and Surveillance of In Situ Oil Sands Schemes. Suncor will provide information on Project performance during the annual reporting cycle with the AER (Section 4.4).




Table 4-3 Other Project Related Risks and Mitigations

Risk Mitigation

Greenhouse gas emissions

The expected GHG emission intensity for the Project is based on the best available technology economically achievable for a SAGD project, considering local reservoir conditions. Suncor is investing in technology development to reduce natural gas consumption and resulting GHG intensity of in-situ extraction. As new in situ extraction technologies become proven and economically feasible, Suncor will look for opportunities for deployment at Meadow Creek West.

Thermal effects of steaming under waterbodies

The reservoir in which steaming will take place within the Project Area is deep (approximately 450 m below surface). As such, thermal effects of steaming are not expected to be transmitted to surface water.

Thermal mobilization of trace elements at SAGD wells

Groundwater quality indicators will be monitored in formations that are stratigraphically located above the producing formations. This monitoring will enable Suncor to detect potential changes in groundwater quality resulting from thermal operations.




Table 4-4 Meadow Creek West Project Commitments and Risks Mitigated by Commitments

Commitment Number Commitment Description

Risk Receptor Category Mitigated by Commitment

Project Phase or Trigger for Implementation of

Commitment

Application Reference

Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours

Aboriginal Stakeholders

Non-A

boriginal Stakeholders

Integrated Land Managem

ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource

Personnel, Contractor and Public Safety

Engineering and Design

Construction

Operations

Reclam

ation and Closure

Specific Trigger

1 The Meadow Creek West project will be developed, operated and managed in a manner that is consistent with Suncor’s OEMS and its approach to risk management.

X X X X X Volume 1, Section 1.1.1 Volume 1, Section 3.8.2 Volume 1, Section 4.5

2 Suncor will strive to limit project development within sensitivities, limitations and constraints and reduce risks to stakeholders, the environment, public safety and resource conservation.

X X X X X Volume 1, Section 2.0 Volume 1, Section 3.0, 3.1, 3.2.1, 3.3.3, 3.3.4, 3.4.2

3 Future resource delineation programs will be executed within the Development Area prior to first steam.

X Volume 1, Section 2.2.1

4 Suncor will continue to acquire new information on the Empress Aquifer in future years and incorporate this information to enhance the geological interpretation and ongoing mapping.

X X Volume 1, Section 2.2.2

5 Prior to pad development and pad sequencing, future testing (e.g. Mini-Frac) will be conducted to confirm the caprock integrity.


6 Suncor will install caprock monitoring wells before commencement of SAGD operations.

X Volume 1, Section 2.2.3 Volume 1, Section 3.2.2 Volume 1, Section 4.3.2

7 If geological risks are identified upon geological risk assessment for thermal compatibility of wells, the area of review will be expanded beyond 300 m and geologists will review the offset well logs in the area.









Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

8 Non-thermally compatible wells will be reviewed in detail, plans developed and actions taken to ensure each well is completed in a manner appropriate for SAGD operations.

X X Volume 1, Section 2.2.4 Volume 1, Section 3.2.2

9 The product tanks will have a dedicated vapour recovery system.

X X Volume1, Section 3.1.1 Volume 2, Section 5.6.2, 5.6.5

10 De-oiled water from the produced water surge vessel will be routed to an evaporator system.

X X Volume1, Section 3.1.3

11 Flaring at the CPF will comply with AER Directive 060.

X Volume 1, Section 3.1.8, 3.7.4, 3.7.6 Volume 2, Section 5.6.4

12 Storage tanks, containment and leak detection will be provided according to AER Directive 055. Above ground storage tanks to conform to the Environmental Guidelines for Controlling Emissions of Volatile Organic Compounds from Above Ground Storage Tanks

X X X Volume 1, Section 3.1.10 Volume 1, Section 4.3.2 Volume 2, Section 5.6.2 Volume 2, Section 7.5.2 Volume 2, Section 18.3

13 Sulphur emissions will be evaluated using a sulphur balance analysis and if required Suncor will employ control options that potentially include chemical scavengers and sulphur recovery units to comply with AER Interim Directive ID 2001-3.

X X Volume 1, Section 3.1.12, 3.7.7

14 Cogeneration will be used to generate both heat and electricity.

X X Volume 1, Section 3.1.13 Volume 2, Section 4.1 Volume 2, Section 5.6.2








Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

15 Waste water disposal volumes will be in compliance with AER Directive 081.


16 Suncor will submit a MARP in accordance with AER Directive 042 prior to construction of the CPF.


17 Suncor will establish agreements with operators of offsetting leases with regards to lease boundary setback and ongoing operating pressures when pads are being planned near to other projects.


18 Suncor will calculate well pad or pattern specific maximum operationg pressure consistent with Directive 086


20 The maximum operating opressures will be monitored and re-assessed when steam chambers in adjacent patterns near coalescence.

X Volume1, Section 3.2.2

21 If caprock monitoring suggests a loss of fluid containment at Meadow Creek West may have occurred, Suncor will immediately investigate the cause and take the necessary actions to mitigate any incremental steam loss. The precise field operating protocol will be developed prior to the commencement of operations.

X Volume1, Section 3.2.2 Volume 2, Section 18.3.2

22 Suncor will also continue to evaluate other appropriate operating and winddown strategies for the Meadow Creek West project.









Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

23 Suncor will continue to explore new technologies for drilling and completing the SAGD wells in addition to incorporating continuous improvement opportunities.


24 Class 1 or Class 2 blowout preventers (BOP) will be installed that comply with AER Directives 008, 009, 010 and 036, and other applicable regulations.

X X X Volume1, Section 3.2.2

25 Drilling waste handling procedures for drilling wastes will be in accordance with AER Directives 050 and 058.

X Volume1, Section 3.2.2 Volume 2, Section 9.3, 9.3.3 Volume 2, Section 10.3.3

26 Waste cement from drilling will be disposed of as per AER Directives 050 and 055 guidelines.


27 Alternative artificial lift strategies will continue to be evaluated as detailed design progresses and new technologies emerge.


28 The SAGD design, completions, and wellheads will be compatible with thermal operations.

X X X Volume1, Section 3.2.2 Volume 2, Section 11.4.2

29 Suncor will directly monitor producer bottom hole pressures via blanket gas injection or, in wells where ESPs or other instrumentation is in place during startup, monitor direct bottom hole pressure and/or temperature.









Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

30 Distributed Control Systems controls and trips will automatically shut-in steam to ensure MOPs are not exceeded on any SAGD well.

X Volume1, Section 3.2.2 Volume 2, Section 7.5.2

31 A field operating protocol will be in place to deal with an exceedance of MOP.


32 SAGD observation wells will be equipped with instrumentation to monitor temperature and/or pressure in the caprock and/or McMurray Formation.


33 Suncor will design, construct, operate, suspend and abandon wells using standards based on experience from Suncor’s existing in situ properties and industry recommended practices.

X X X Volume 1, Section 3.2.2 Volume 2, Section 7.5.2 Volume 2, Section 18.3.2

34 Casing integrity practices will comply with current AER Directive 051.


35 Suncor will prepare a Surface Heave Monitoring Plan to monitor the size and distribution of surface heave in the development area of Meadow Creek West.


36 Well pads will include a stormwater containment pond.

X X X Volume 1, Section 3.2.3








Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

37 Design and construction of water course crossings will comply with the Water Act Codes of Practice.

X X Volume 1, Section 3.3.2, 3.5.2, 3.5.4 Volume 1, Section 4.3.1, 4.3.2 Volume 1, Section 6.4.1 Volume 2, Section 4.4 Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3, 10.5.2, 10.6.2, 10.7.2, 10.12

38 Wildlife crossings for pipelines will be designed and constructed to comply with Alberta Environment and Park’s Above Ground Pipeline Wildlife Crossing Directive.

X X X Volume 1, Section 3.3.2, 3.4.1 Volume 1, Section 6.4.1 Volume 2, Section 13.5.2, 13.10.1 Volume 2, Section 16.5.1

39 Pipeline designs will conform to CSA standards.

X Volume 1, Section 3.4.3 Volume 1, Section 4.3.1

40 If water for dust control is sourced from surface water bodies, Suncor will endeavor to use water from industrial runoff ponds or borrow areas prior to sourcing water from natural water bodies.


41 Suncor will follow the terms and conditions of Temproary Diversion Licences and the Water Act Code of Practice for the Temporary Diversion of Water for Hydrostatic Testing of Pipelines.

X Volume 1, Section 3.5.2, 3.8.6 Volume 1, Section 6.4.1 Volume 2, Section 4.4 Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3, 10.6.2

42 Diversion ditches will be provided to shed the run-off away from the central processing facilities and will be designed with minimum slope to avoid erosion and need for liner protection.









Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

43 The CPF stormwater containment pond will be constructed to provide storage volume required to contain surface water run-off for a 1 in 10-year storm with a 24-hour duration. The pond will have a single primary liner system with a permeability of no greater than 1x10-7 cm/sec. The pond will be designed with 3:1 side slopes and a minimum 0.3 m freeboard.


44 Surface water will be managed in order to avoid erosion and the transport of silt to water bodies. Where activities have a risk of erosion and the introduction of silt to water bodies, a Sediment and Erosion Control Plan will be developed.

X X X Volume 1, Section 3.5.3 Volume 1, Section 6.4.4, 6.5.1, 6.5.2 Volume 2, Section 10.5.2 Volume 2, Section 11.3.2, 11.5.2, 11.6.2 Volume 2, Section 12.3.3

45 Disposal wells will be tested, drilled and completed in compliance with AER regulatory requirements.


46 Each disposal wellhead will be equipped with flow and pressure measurement instrumentation. The wellhead injection pressure and injection rate for each well will be monitored and recorded. A packer isolation test will be conducted on a regular basis to ensure that the well integrity is maintained.


47 All domestic wastewater will be directed to a septic tank with subsequent disposal to a treatment facility holding a valid approval under EPEA.









Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

48 Suncor will develop a Waste Management Plan that will be followed by Meadow Creek West personnel and contractors, and will comply with AER Directives 050 and 058

X X X Volume 1, Section 3.6, 3.6.1, 3.6.2 Volume 2, Section 13.3.3

49 An Emergency Response Plan for the Meadow Creek West project will be developed in accordance with Suncor’s Emergency Planning and Response Standard.

X X X Volume 1, Section 3.8.3 Volume 1, Section 4.3.2

50 A Spill Response Plan will be developed for the Project.

X X X Volume 1, Section 3.8.4 Volume 1, Section 4.3.2 Volume 2, Section 9.3, 9.3.3 Volume 2, Section 10.3.3 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3 Volume 2, Section 18.3.2

51 A FireSmart Plan, a Wildfire Emergency Response Plan and an Industrial Wildfire Control Plan will be developed for the Meadow Creek West project.

X X X Volume 1, Section 3.8.5 Volume 1, Section 3.8.6 Volume 1, Section 6.4.2 Volume 2, Section 4.6 Volume 2, Section 14.5.2

52 Suncor will implement an adaptive management approach through of life of the Project develop, modify and update project operations and reclamation techniques/approaches to reduce Project risks.

X X X X X Volume 1, Section 3.8.6 Volume 1, Section 4.4 Volume 1, Section 6.3.6, 6.9, 6.10 Volume 2, Section 4.5 Volume 2, Section 12.3.3, 12.12.2 Volume 2, Section 13.3.3, 13.6.3, 13.12.2 Volume 2, Section 16.5.1 Volume 2, Section 17.4.2








Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

53 Crossing structures (bridges and culverts) will be inspected and corrective actions will be performed to maintain surface drainage patterns.

X Volume 1, Section 3.8.6 Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3

54 Suncor will implement environmental monitoring and reporting for air emission sources, ambient air quality, industrial runoff release, EPEA reporting, groundwater, soil, reclamation, wetlands and waterbodies and wildlife.

X X X Volume 1, Section 3.7.3, 3.8.7 Volume 1, Section 4.3.1, 4.3.2 Volume 1, Section 6.3.3, 6.3.6, 6.4.1, 6.9 Volume 2, Section 4.3, 4.5 Volume 2, Section 7.5.2, 7.6.1, 7.8.3 Volume 2, Section 8.4.2, 8.8 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3, 10.12 Volume 2, Section 11.3.2, 11.12.2 Volume 2, Sectiion 12.3.3, 12.12.2 Volume 2, Section 13.3.3, 13.5.2, 13.6.3, 13.6.4, 13.12.1 Volume 2, Section 16.5.1, 16.9

55 Suncor has committed to a robust, long-term stakeholder engagement plan that will ensure stakeholders are kept informed of Project activities and opportunities, and that a process is in place for concerns about the Project to be communicated to Suncor.

X X X X X Volume 1, Section 4.3.1 Volume 1, Section 5.2.2, 5.2.3, 5.2.4, 5.2.5, 5.4 Volume 1, Section 6.3.6, 6.4.1 Volume 2, Section 4.6, 4.8, 4.9 Volume 2, Section 6.4.5 Volume 2, Section 13.12.2 Volume 2, Section 14.4.2, 14.5.2, 14.6.2, 14.7.2 Volume 2, Section 16.2.2, 16.5.1, 16.5.2, 16.7.1, 16.7.2, 16.7.3, 16.7.4 16.7.5, 16.7.6, 16.7.7, 16.7.8, 16.9 Volume 2, Section 17.1.2, 17.7.3, 17.8.3, 17.9.3, 17.14








Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

56 Suncor will comply with restricted activity period guidance, avoid dens and nesting sites, and implement a Caribou Protection Plan.

Volume 1, Section 4.3.1 Volume 1, Section 6.3.3, 6.3.6, 6.4.1, 6.4.2 Volume 2, Section 4.5 Volume 2, Section 13.3.3, 13.4.3, 13.6.3, 13.6.4, 13.8.1, 13.10.1, 13.12.1 Volume 2, Section 16.5.1

57 Suncor will collaborate with others to understand the ecosystem services value of existing, disturbed, and future reclaimed lands to better develop wildlife mitigation plans.


58 Surface development will be located outside of setbacks from water bodies, with the exception of water body crossings and limiting disturbance of wetlands.

X X Volume 1, Section 4.3.1 Volume 1, Section 6.4.1 Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3 Volume 2, Section 16.5.1

59 Reclaim wetlands where appropriate as part of the project reclamation plan.


60 Consideri learnings from the Firebag Wetland Reclamation Trail Program.


61 Pipelines will be monitored, inspected and preventive maintenance programs initiated as part of the Project’s risk management program.









Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

62 Project components will be oriented, contoured and designed to maintain natural drainage patterns to the extent practical.

X X X Volume 1, Section 4.3.1 Volume 1, Section 6.4.1, 6.4.4 Volume 2, Section 8.4.2 Volume 2, Section 10.3.3 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3, 12.4.3 Volume 2, Section 13.3.3

63 Suncor will engage with Alberta Transportation, ABSA, the AER and stakeholders as the schedule for design and construction of the potential Highway 63 pipeline crossing draws nearer.

X X X X Volume 1, Section 3.3.2 Volume 1, Section 4.3.1 Volume 1, Section 5.2.5

64 As new in situ extraction technologies become proven and economically feasible, Suncor will look for opportunities for deployment at Meadow Creek West.


65 Suncor has conducted and will continue geologic investigations including an oil sands exploration program to facilitate placement of SAGD wells, within operational constraints.


66 Fishing and hunting within the Project Area by Suncor staff and contractors while on shift will be prohibited.

X X X Volume 1, Section 4.3.2 Volume 2, Section 10.7.2, 10.7.3 Volume 2, Section 13.3.3, 13.6.3 Volume 2, Section 16.5.1, 16.7.2, 16.7.5, 16.7.6, 16.7.7

67 Suncor will obtain Historical Resources Act clearances for specific Project elements prior to surface disturbance as development proceeds.

X Volume 1, Section 4.3.2 Volume 2, Section 15.4.2 Volume 2, Section 15.6








Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

68 Suncor will provide information on Project performance during the annual Directive 054 reporting cycle with the AER.


69 Suncor will comply with all applicable legislation, regulations, policy, guidelines and directives unless otherwise requested.

X X X X X Volume 1, Section 4.5 Volume 1, Section 6.3.6, 6.4.1 Volume 2, Section 4.4, 4.5 Volume 2, Section 7.6.1 Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3, 10.7.2 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3 Volume 2, Section 14.10 Volume 2, Section 15.4.2

70 Suncor will follow industry best practices for low impact seismic and delineation drilling techniques and the Code of Practice for Exploration Operations


71 Low impact mechanical equipment and hand cutting will be used for seismic lines.

X X Volume 1, Section 6.3.3 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3, 13.6.3 Volume 2, Section 14.5.2








Commitment


Greenhouse G

ases

Energy Efficiency

Air Q

uality and Odours


Non-A



ent

Historical R

esources

Public Health

Socio-econmom

ics

Wildlife and W

ildlife Habitat

Biodiversity

Aquatic Life and A

quatic Habitat

Wetlands

Vegetation and Soil

Surface Hydrology

Groundw

ater Resources

Conservation of R

esource



Construction

Operations

Reclam

ation and Closure

Specific Trigger

72 Suncor will apply integrated land management practices to reduce land disturbance, and allow for multi-stakeholder access and coordination by using previously disturbed land, common access corridors and existing access wherever practicable.

X X X X Volume 1, Section 6.3.6, 6.4.1 Volume 2, Section 4.6 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3, 13.4.3, 13.4.4 Volume 2, Section 14.4.2, 14.5.2, 14.6.2, 14.7.2, 14.10 Volume 2, Section 16.5.1, 16.5.2

73 Suncor will design and construct wellpads to reduce cut and fill by considering elevation differences across a site where practical.


74 Decommission Project components that meet the definition of ready for reclamation and progressively reclaim the disturbance as soon as practicable.

X Volume 1, Section 6.3.6 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3, 12.4.3 Volume 2, Section 13.3.3 Volume 2, Section 16.5.1

75 Preferentially construct Project components under frozen conditions or in dry ground conditions.

X X Volume 1, Section 6.3.6, 6.4.4 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3 Volume 2, Section 16.5.1

76 Lands will be reclaimed to re-establish predisturbance relief and develop component-specific revegetation plans considering local topography, drainage characteristics and the surrounding ecosite type to establish equivalent land capability









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77 Incorporate land-use objectives for lands zoned for mixed use in the Lower Athabasca Regional Plan.


78 Rights-of-way will be sized to the minimum width required, considering safety issues such as traffic flow on roads and possible tree-fall into the work area.


79 Implement a weed management program with a focus on the control of noxious weeds (as designated in the Alberta Weed Control Regulation).

X X X Volume 1, Section 6.3.6 Volume 2, Section 12.3.3, 12.6.4, 12.12.2 Volume 2, Section 13.8.1 Volume 2, Section 16.5.1

80 Land will be cleared according to the Timber Management Regulations and the Forest and Prairie Protection Act, Regulations, Parts 1 and 2


81 During the final siting of Project components, wellpad locations and linear corridors will consider effects on high quality wildlife habitat and reduce clearing and fragmentation as feasible, especially in caribou habitat and wetlands with high habitat diversity.


82 During the final layout planning for Project components, Suncor will strive to maintain undisturbed habitat, particularly old growth, by avoiding larger patches on the landscape, as is reasonably practicable considering FireSmart planning.









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83 Suncor will strive to avoid or limit disturbance of areas that are under-represented at both the landscape and community levels.


84 During Project construction, where opportunities to conserve reclamation materials other than soils exist, Suncor will implement best management practices to retain these materials


85 Project components sited in or near wetlands will meet the requirements of the Alberta Wetland Policy, Alberta Wetland Mitigation Directive and the Water Act.

X X X X Volume 1, Section 6.4.1 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3

86 Follow the Water Act Code of Practice for the Release of Hydrostatic Test Water from Hydrostatic Testing of Petroleum Liquid and Gas Pipelines.

X Volume 1, Section 6.4.1 Volume 2, Section 4.4 Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3

87 Vegetation clearing will be limited to the extent necessary to allow the safe operation of the Project.


88 Mitigation measures for effects on rare plants will be implemented, with preference given to avoidance


89 Timber salvage will be in accordance with the Public Lands Operational Handbook, or as specified in the terms of Al Pac’s FMA.









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90 Woody material will be handled in compliance with the Public Lands Operational Handbook and Directive SD 2009-01: Management of Wood Chips on Public Land.

X X X Volume 1, Section 6.4.3 Volume 2, Section 11.4.2 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3

91 Project construction and clearing schedules will be reviewed in order to maximize the use of non-merchantable timber and coarse woody material to the degree practical.


92 Suncor will consult with Alberta Agriculture and Forestry, and an approved burn plan will be in place before burning.


94 Prior to fill material excavation, samples will be analyzed for basic soil characteristics.


95 Implement over-stripping of peat deposits into the under-lying mineral material (peat-mineral mix) to increase the volume of reclamation resources.


96 If pump-offs are required for de-watering, pumps will be placed inside secondary containment, intake hoses will be equipped with floats to reduce the uptake of sediment and release points will be in vegetated locations with appropriate diffusion measures to prevent erosion.


97 Salvage activities will occur when ground conditions are suitable, e.g., frozen or dry and trafficable.









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98 Soil salvage operations will be conducted under the supervision of a qualified individual. Adjustments will be made, as required, to salvage depths based on the conditions encountered in the field. The qualified individual will have the component-specific Conservation and Construction Plan on hand.


99 Soil stockpiles will be located on a competent base and will be contoured to a stable slope gradient, employ rough and loose on slopes to protect against erosion and promote natural vegetation recovery.

X X Volume 1, Section 6.4.4, 6.5.1 Volume 2, Section 11.5.2

100 Compaction will be alleviated during reclamation using appropriate methods (e.g., paratilling, harrowing, deep ripping).


101 Suncor will continue to participate in and review industry-wide reclamation research programs and incorporate any relevant findings or new reclamation techniques that are appropriate into the Project reclamation program.

X X Volume 1, Section 6.8, 6.10.2

102 Suncor will follow the requirements of AER SED-001.

X X X X Volume 1, Section 6.9 Volume 2, Section 11.12.1 Volume 2, Section 12.6.3, 12.12.1








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103 Suncor will collect and deploy plant material according to the Alberta Forest Genetic Resource Management and Conservation Standards, 2nd Revision of STIA.

X X Volume 1, Section 6, Appendix 6C Volume 2, Section 12.5.3, 12.6.3 Volume 2, Section 14.5.2

104 Low emission gas turbines will be used for the cogeneration units to limit NOX emissions to levels less than the CCME Emission Guideline for Stationary Gas Turbines, AEP Emission Standards for Electricity Generation and the guidelines proposed by Environment and Climate Change Canada.

X X Volume 2, Section 4.1 Volume 2, Section 5.63

105 Low-NOX burner technology will be used for steam generators and heaters to comply with the applicable NOX and CO emission levels specified by CCME and Environment and Climate Change Canada.

X X Volume 2, Section 5.63

106 Mixed fuel gas will be combusted in the steam generators, as opposed to direct venting or flaring.


107 Insulated steam lines will be used to minimize heat losses associated with the transport of steam to the well pads.


108 Continuous flare stack emissions will be limited to a pilot in the flare at the CPF.









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109 Direct inspection and maintenance techniques will be applied to achieve efficient management of fugitive emissions from equipment leaks, including daily walk-throughs by operations personnel, use of gas detection monitoring systems, and effective repairs and after-repair monitoring program.

X Volume 2, Section 5.63

110 The hydrocarbon service tanks will be blanketed with natural gas.


111 Where practical, construction activities (e.g., piling) will be scheduled during daytime hours (i.e., 7 am to 10 pm) to limit noise.

X X Volume 2, Section 6.4.5 Volume 2, Section 13.4.3 Volume 2, Section 16.5.1

112 Noise mitigation measures installed on construction equipment (e.g., mufflers) will be maintained in good working condition.


113 Construction traffic to and from the site will be restricted to approved access routes, or use of alternative routes will be considered to reduce travel near residences.


114 Where practical, equipment will be turned off when it is not in use.


115 Material stockpiles or earth berms may be used as noise barriers where field conditions allow.









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116 Noise emitting equipment (i.e. turbo fans, TSSGTM Boilers) will be located inside a building or enclosure with a minimum Sound Transmission Class specification.


117 Buildings housing indoor noise-generating equipment will be sealed to grade specifications to prevent noise breakout between the building skid and the ground


118 Flanking paths and penetrations from plumbing, heating ducts and electrical wire in the buildings will be properly insulated and covered so that noise does not escape through them.


119 Inlet and exhaust silencers for combustion equipment (drilling activities) will be installed.


120 Target equipment noise emission limits will be specified to vendors.


121 Building doors and windows will be kept closed.


122 Equipment will be maintained on a regular basis and confirmed in good working condition (e.g., motors will be lubricated to reduce screeching noise).









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123 During drilling, standard noise control measures, such as the use of exhaust silencers and equipment enclosures, will be implemented.


124 A noise complaint mechanism will be implemented. If a noise complaint is received, Suncor will conduct a noise complaint investigation in accordance with Directive 038.

X X X Volume 2, Section 4.2 Volume 2, Section 6.4.5, 6.7 Volume 2, Section 16.5.1

125 Industry-recommended practices will be used during drilling and cementing to hydraulically isolate non-saline groundwater intervals.


126 The non-saline formations of the borehole will be drilled using a low-TDS water or light, polymer-based drilling fluid. Bentonite, polymers and lost circulation materials may be used to limit fluid invasion into any permeable strata.


127 Flow lines and storage tanks will be located above ground to facilitate leak detection.


128 Develop and implement a Groundwater Management Plan.

X X X Volume 2, Section 7.5.2, 7.6.1, 7.8, 7.8.3

129 Activities near water will be carried out following standard guidance that reduces effects on fish habitat.

X X X X Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3, 10.5.2, 10.6.2, 10.7.2








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130 Follow construction practices as outlined in the Conceptual Conservation and Reclamation Plan and implement the site specific Conservation and Construction Plan.

X X Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3

131 Implement the operations plan as outlined in the Conceptual Conservation and Reclamation Plan.

X Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3

132 Clearly mark crossing structures (bridges and culverts) to prevent damage by maintenance equipment.


133 Refer to the reclamation plan prior to commencing reclamation activities.

X Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3 Volume 2, Section 11.3.2 Volume 2, Section 12.3.3 Volume 2, Section 13.3.3

134 Avoid instream work when decommissioning and removing watercourse crossings.

X Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3 Volume 2, Section 10.5.2 Volume 2, Section 10.6.2

135 Reclaim riparian vegetation using an appropriate seed mix as described in the Conceptual Conservation and Reclamation Plan.









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136 Reclaim roads when they are no longer required and roll back right-of-ways to reduce access.

X Volume 2, Section 8.4.2 Volume 2, Section 9.3.3 Volume 2, Section 10.3.3 Volume 2, Section 10.7.3 Volume 2, Section 13.10.1 Volume 2, Section 14.6.2 Volume 2, Section 14.7.2

137 When maintaining road surfaces, selectively grade away from bridges.


138 Develop and implement an Access Management Plan for the Project. The traditional land use portion of Access Management Plan will be discussed with Aboriginal groups prior to finalization.

X X X Volume 2, Section 4.6 Volume 2, Section 10.7.2 Volume 2, Section 13.6.4, 13.8.1 Volume 2, Section 14.4.2, 14.6.2, 14.7.2, 14.7.3 Volume 2, Section 16.5.1, 16.7.2, 16.7.5, 16.7.6, 16.7.7, 16.7.8 Volume 2, Section 17.10.3

139 Machinery appropriate to the season and soil conditions will be used during construction.


140 Salvage and replacement operations will be planned to reduce the distance and number of times that salvaged soils are handled.


141 Surface water flow impediments will be used where needed in ditches to slow water velocity.


142 Soil disturbance will be limited to the Project footprint.









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143 Limit soil disturbance under topsoil stockpiles, powerline and above-ground pipeline right-of-ways.


144 Disturbed surfaces will be contoured to avoid concentrated surface flow and formation of rills/gullies down long slopes.


145 Where the material balance allows, construction fill will be removed.


146 Where possible, soils will be directly placed on the contoured landscape and left rough.


147 Establish successional species on the reclaimed landscape that exhibit a trajectory towards functional and ecologically resilient boreal forest ecosystems, including wetlands representative of native plant communities in the lower Athabasca region.


148 Where practical, maintain disturbances to mimic natural variability in size and shape.


149 Where linear disturbance is maintained for Project operations, allow natural woody vegetation to grow back along the edge of cleared pipeline and powerline right-of-ways to reduce lines of site, while accommodating safety and pipeline monitoring concerns.

X X Volume 2, Section 12.3.3 Volume 2, Section 13.3.3, 13.6.3 Volume 2, Section 16.5.1








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150 Implement dust control measures. X X X Volume 2, Section 12.3.3, 12.7.4 Volume 2, Section 13.3.3, 13.4.3 Volume 2, Section 16.5.1

151 The Project will comply with established land use plans or policies including the Lower Athabasca Regional Plan.

X X X X Volume 2, Section 12.4.4 Volume 2, Section 13.12.2 Volume 2, Section 14.10

152 Participate in collaborative initiatives such as the COSIA-led project to reduce fragmentation and reduce effects on woodland caribou. Consider COSIA recommendations for reclamation of linear corridors.

X Volume 2, Section 12.4.4 Volume 2, Section 13.9.2, 13.10.2, 13.12.2

153 Implement traffic and speed controls where under the control of Suncor.

X X X Volume 2, Section 13.3.3, 13.6.3, 13.6.4, 13.8.1

154 Report and track wildlife sightings including incidental observations and wildlife collisions.

X X X Volume 2, Section 13.3.3, 13.6.3

155 Ensure the Project meets the Alberta BearSmart objectives.


156 Limit nighttime lighting to the amount needed for safety and use light shields, where practical, during construction.


157 Encourage wildlife onto reclaimed sites with habitat enhancement techniques.

X Volume 2, Section 13.4.3, 13.7.2

158 Take guidance from the East Side Athabasca caribou range plan when available.

X X X X Volume 2, Section 13.4.3, 13.4.4








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159 Install culverts to allow for movement by amphibians and small mammals across linear disturbance; culverts will be kept clear of debris.


160 During construction activities, wildlife crossing of linear developments will be facilitated by the provision of breaks and crossing points in pipe strings, spoil piles and open ditches, particularly at any identified intersections with wildlife movement corridors.


161 Use buses to transport Project personnel to and from site.

X X Volume 2, Section 13.5.2, 13.6.3, 13.6.4, 13.8.1

162 Revegetate roadsides with low-palatable native plant species.

X X Volume 2, Section 13.6.3, 13.6.4, 13.8.1

163 Promote awareness of wildlife-vehicle collision prevention strategies with employees and contractors.

X X X Volume 2, Section 13.6.3, 13.6.4, 13.8.1

164 Ban feeding and harassing wildlife for all Project personnel while working on-site.


165 Adopt mitigation standards for powerlines to reduce bird collision risk, as outlined by the Avian Powerline Interaction Committee.


166 Provide environmental awareness training for personnel.









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167 Logs recovered from disturbed forests will be reused as snags or wildlife trees to create perches and nesting sites for birds and habitat for other wildlife.


168 Establish plant communities that consider colonization by wildlife species of primary interest to traditional and local land users in upland and wetland ecosystems.


169 During reclamation and closure, Suncor, where practicable, will salvage and repurpose or sell aggregate.


170 Timber salvage will follow the requirements outlined in Forest Management Branch Directive 2007-01 Fire Salvage Planning and Operations (if applicable).


171 Suncor will engage with the Fort McMurray Office - Forestry and Emergency Response Division Dept. of Environment and Sustainable Resources to discuss Project effects to existing dispositions for lands held for fire management prior to construction.









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172 Suncor will provide a reasonable level of support to CPDFN if updates to the Meadow Creek East TLU study, to incorporate Meadow Creek West, are required. Results of the review and/or study update will be considered in Project planning as development progress. Should new project effects to TLU sites or activities be identified by CDPFN in a TLU study, Suncor will work with CDPFN to identify reasonable and effective mitigations strategies.

X X X X Volume 2, Section 16.2.2

173 If effects on intangible values (cultural transmission, language retention, governance systems, patterns of cultural behavior, and the sensorial experience of traditional land users) are identified by Aboriginal groups through Aboriginal engagement activities, Suncor will consider the information in the regulatory process or project planning, as applicable.

X X X X Volume 2, Section 16.3.4

174 Provide Aboriginal Cultural Awareness training to employees and contractors that outlines TLU requirements and sensitivities.


175 Construction and other project activities will be timed to avoid key harvesting periods, where possible.


176 Provide opportunities for the harvesting of traditional plants or other resources prior to disturbance.









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177 Use fencing and/or habitat buffers to encourage wildlife to avoid Project areas and to reconnect habitats and facilitate wildlife movement.


178 Employ techniques that minimize effects on the natural habitat, including minimal clearing and stripping.





4.4 ADAPATIVE MANAGEMENT

Suncor’s OEMS framework uses a continual improvement cycle of plan-do-check-act (Section 1.1), which is in alignment with an adaptive management approach. Suncor will implement an adaptive management approach through the life of the Project which will develop, modify and update Project operations and conservation and reclamation techniques to reduce Project risks.

The adaptive management approach will be closely linked with monitoring programs proposed for the Project (Section 3.8) and commitments made to mitigate Project risks (Table 4-4). The adaptive management approach will allow Suncor to:

• use data collected from Project monitoring programs

• incorporate data collected from regional research programs and other projects in the region

• consider new technologies and bitumen recovery methods to improve GHG performance

• improve reclamation plans

• incorporate feedback collected from stakeholders as part of the long-term stakeholder engagement plan (Section 5.4)

• adapt to changes in the regulatory regime

• adapt to climate change

• modify reclamations plans as advancements to reclamation strategies are made and new technologies or techniques are developed

• modify reclamation and monitoring plans as new targets and thresholds that are established for the region.

4.5 COMPLIANCE AND REPORTING

Suncor will comply with applicable legislation, regulations, policy, guidelines and directives. Compliance requirements will be managed in accordance with Suncor’s Operational Excellence Management System, which spells out expectations and a framework for regulatory compliance to aid in the execution of compliance tasks and ensure timely and appropriate reporting.

Reporting for Project performance to the AER will take place in conjunction with the annual presentation as required by Directive 054: Performance Presentations, Auditing, and Surveillance of In Situ Oil Sands Schemes. Environmental reporting will be completed to meet EPEA approval requirements (Section 3.8).

4.0 risk management and compliance - alberta · 2017-11-08 · risk management and compliance...

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