table of contents - albertasepiko kesik project i supplemental information request responses...

Sepiko Kesik Project i Supplemental Information Request Responses November 2014 Round 2

Osum Oil Sands Corp.

TABLE OF CONTENTS

1 SUPPLEMENTAL INFORMATION REQUEST RESPONSES ..................................................... 1 1.1 ALBERTA ENERGY REGULATOR ................................................................................. 1

OSCA Application No. 1756260 ........................................................................... 1 1.1.1 EPEA Application No. 001-320736 .................................................................... 39 1.1.2

1.2 ALBERTA ENVIRONMEMNT AND SUSTAINABLE RESOURCE DEVELOPMENT ............................................................................................................. 70

General ................................................................................................................ 70 1.2.1 Air ........................................................................................................................ 72 1.2.2 Water ................................................................................................................... 79 1.2.3 Terrestrial .......................................................................................................... 126 1.2.4

TABLES

SIR 2 Table AER 3-1 Footprint Components Located within 100 m of a Water Body..................... 5 SIR 2 Table AER 8-1 Conceptual Well Pad Construction and Reclamation Schedule ................... 32 SIR 2 Table AER 10-1 Predicted Nitrogen Dioxide Concentrations – Ozone Limiting

Method Using Time Series Ozone Data ......................................................... 36 SIR 2 Table AER 17-1 Summary of Water Quality Data from Tributaries to the Athabasca

River (2012) ..................................................................................................... 47 SIR 2 Table AER 17-2 Summary of Water Quality Data from the Athabasca River (2012 and

Historical Data Combined) ............................................................................. 49 SIR 2 Table AER 17-3 Summary of Water Quality Data from Lakes (Fall 2012) ................................ 51 SIR 2 Table AER 17-4 Summary of Sediment Quality Data (2012) ..................................................... 52 SIR 2 Table ESRD 4-1 Predicted Updated Nitrogen Dioxide Concentrations – Total

Conversion Method ......................................................................................... 73 SIR 2 Table ESRD 12-1 Measured Isopachs between the Grosmont C and Leduc Formations .......... 86 SIR 2 Table ESRD 24-1 Simulated and Observed Flow Comparisons ................................................ 110 SIR 2 Table ESRD 26-1 Borrow Area and Watercourse Outlet Elevations ....................................... 115 SIR 2 Table ESRD 32-1 Estimated Topsoil Reclamation Material Balance by Soil Map Units

within Facility Component Type ................................................................. 130 SIR 2 Table ESRD 32-2 Estimated Topsoil Reclamation Material Balance for the Project

Update ............................................................................................................ 133 SIR 2 Table ESRD 33-1 Predicted Changes in Land Capability for Forestry in the Terrestrial

Local Study Area Following Reclamation .................................................... 134 SIR 2 Table ESRD 33-2 Summary of Closure Land Capability Classes of the Baseline Case

Soil Disturbances in the Project Footprint ................................................... 135 SIR 2 Table ESRD 35-1 Corrected Areas (ha) of Contiguous Caribou Habitat at Baseline,

Application and Planned Development Case in the Moose and Woodland Caribou Local Study Area and Regional Study Area................. 144

Sepiko Kesik Project ii Supplemental Information Request Responses November 2014 Round 2


FIGURES

SIR 2 Figure AER 3-1 100 m Watercourse and Water Body Setbacks ................................................ 9 SIR 2 Figure AER 3-2 Facilities within 100 m of a Watercourse ...................................................... 10 SIR 2 Figure AER 7-1a-l Environmental Constraints ............................................................................. 18 SIR 2 Figure AER 7-2 Regional Wildlife Constraints ........................................................................ 30 SIR 2 Figure AER 14-1 Sulphur Emissions Process Flow Diagram ..................................................... 43 SIR 2 Figure AER 24-1 Water Chemistry Indicators in Arsenic in Sediment .................................... 61 SIR 2 Figure ESRD 6-1 Near Field Receptors ....................................................................................... 77 SIR 2 Figure ESRD 12-1 RSA Lower Ireton Formation Isopach Map ................................................... 88 SIR 2 Figure ESRD 24-1 14-H Rating Curve Uncertainty ................................................................... 111 SIR 2 Figure ESRD 24-2 2012 Hydrograph Site 14-H .......................................................................... 112 SIR 2 Figure ESRD 34-1 First Five Subsurface Pads in the Grosmont C ............................................. 142

APPENDICES

Appendix A Revised Traffic Impact Assessment

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Sepiko Kesik Project 2 Supplemental Information Request Responses

November 2014 Round 2


Fort McMurray #468 First Nation

Osum keeps in touch regularly with the FMFN through email and phone, and receives

regular updates on the progress of the TLU study. There was a meeting on April 24, 2014 at

the FMFN office to kick off the TLU study. Twelve elders attended as well as the Land Use

Manager and the Youth & Elder Coordinator for FMFN, and representatives from FMFN’s

TLU contractor.

At this time FMFN is finalizing a draft of the internal TLU report, which will be submitted to

FMFN council in fall 2014 and later released to Osum. Once the TLU report has been

reviewed, Osum will set up a meeting with the FMFN consultation department to discuss the

findings of the TLU report and the points raised in the SOC, and identify next steps.

Métis Local #1935

ML 1935 provided the TLU report to Osum and a consultation committee meeting was held

with representatives of Osum in Fort McMurray on June 26, 2014, to respond to concerns

raised by ML 1935 and answer questions about the Project. Before the meeting, Osum signed

a 4 year work plan agreement with ML 1935.

Osum is currently addressing two remaining items from the discussions with ML 1935 and

once the parties are in agreement, ML 1935 will withdraw its SOC regarding the Project. In

the TLU report, ML 1935 clearly indicated that none of its members harvest in or near the

Project Area. Many concerns identified are a considerable distance away from the Project and

due to the distance, Project-specific mitigation is not proposed.

Other Stakeholders

Osum also continues to consult with other regional stakeholders. The Métis Nation of Alberta

Region 5 (MNA R5) has not filed a statement of concern or objection, but Osum has made a

presentation to its members and MNA R5 has undertaken a TLU study to identify concerns

that they may have related to the Project. This study was carried out and Osum received the

report in July 2013. Consultation with MNA R5 will continue throughout the regulatory

process and updates will be provided regularly. Concerns and issues raised by MNA R5 were

addressed at an information session held in Slave Lake on September 7, 2013. MNA R5 has

indicated that its members do not harvest in or near the Project Area.

Sepiko Kesik Project 3 Supplemental Information Request Responses November 2014 Round 2


1.1.1.2. Reservoir

2 SIR Response, Question No. 26. Osum states “Osum will selectively deploy instrumentation for direct measurement of downhole pressure and temperature in the proposed thermal wells.” Provide the number of wells per pad in the initial development area which will have direct downhole pressure and temperature monitoring.

Response:

Because the recovery process under consideration is cyclic steam stimulation (CSS), for which only one horizontal well will be used for steaming and production, it is not imperative to conduct continuous surveillance of downhole temperature and pressures for the maintenance of wellbore sub-cool. Instead, the downhole measurements would provide diagnostics data for steam conformance, wellbore utilization, inflow profiling, and optimization of artificial lift operations.

The number of wells per pad in the initial development area selected for direct measurements will be determined by individual well performance. The instrumentation strings will be designed to be retrievable and deployed selectively in wells under study.



1.1.1.3. Surface Water

3 Supplemental Information Request Responses 1, #36, Figure AER 36-1 and Table AER 36-1; Supplemental Information Request Responses 1, #81, Figure ESRD 81-1.

In response to ESRD SIR1 #81 Osum identifies that well pads 9 and 12 are currently located within 100 m of a mapped watercourse however this is not identified in Table AER 36-1. Table AER 36-1 identifies only Well Pads Phase 1 – 13A and Well Pad Phase 1 – 13B as currently located within 100 m of an unnamed watercourse and an undefined watercourse respectively.

a. Provide a revised Table AER 36-1 to rectify any discrepancies.

Response:

a. Osum’s responses to Round 1 AER SIR 36 and ESRD SIR 81 differed based on two different interpretations of a water body.

For the response to Round 1 AER SIR 36, Osum used the definition of a water body typically used by the Alberta Energy Regulator (AER) under Directive 056: Energy Development Applications and Schedules (AER 2014), which considers undefined watercourses and mapped wetlands as water bodies. As a result, when asked to identify the closest water body to each facility, Osum identified well pads 9 and 12 as being located within a water body (i.e., having a 0 m setback from the mapped wetland), as opposed to being within 100 m of a mapped watercourse. Similarly, using this definition, the closest water bodies to well pads 13A and 13B were two undefined mapped watercourses that were ground-truthed in summer 2012.

For the response to Round 1 ESRD SIR 81, Osum used the definition of a water body historically used by Alberta Environment and Sustainable Resource Development (ESRD) when regulating the Water Act, which considers watercourses with defined channels and/or observed open water as water bodies (but does not include wetlands). Using that definition, Osum identified well pads 9 and 12 as being located within 64 and 61 m of a defined watercourse, respectively; and the operations camp as being located within 0 m of a defined watercourse. As the nearest watercourses to well pads 13A and 13B were considered to be undefined, these well pads were not identified on Figure ESRD 81-1.

To provide additional clarity, Osum has revised Round 1 Table AER 36-1 presented as SIR 2 Table AER 3-1. The revised table includes an additional column identifying the distance to the closest defined water bodies to each well pad.



SIR 2 Table AER 3-1 Footprint Components Located within 100 m of a Water Body

Footprint Component

Distance to Nearest Water Body (as defined by AER

Directive 056) (m)

Neighboring Water Body Identification

Distance to Nearest Defined Water

Body (m)

Well Pad Phase 1 - 1 0 Open Bog (BONS) 390 Well Pad Phase 1 - 2 0 Treed Bog (BTNN) 867 Well Pad Phase 1 - 3 0 Treed Bog (BTNN) 102 Well Pad Phase 1 - 4 0 Treed Bog (BTNN) 846 Well Pad Phase 1 - 5 0 Treed Bog (BTNN) 740 Well Pad Phase 1 - 6 0 Open Bog (BONS) 377 Well Pad Phase 1 - 7 0 Treed Swamp (STNN) 253 Well Pad Phase 1 - 8 0 Open Bog (BONS) 292 Well Pad Phase 1 - 9 0 Treed Bog (BTNN) 64

Well Pad Phase 1 - 10 0 Open Bog (BONS) 125 Well Pad Phase 1 - 12 0 Treed Swamp (STNN) 61

Well Pad Phase 1 - 13A 63 Unnamed watercourse 353 Well Pad Phase 1 - 13B 0 Undefined watercourse 305 Well Pad Phase 1 - 14 0 Treed Bog (BTNN) 404 Well Pad Phase 1 - 15 0 Open Bog (BONS) 116 Well Pad Phase 1 - 16 0 Open Bog (BONS) 374 Well Pad Phase 1 - 17 0 Open Bog (BONS) 216 Well Pad Phase 1 - 18 0 Treed Fen (FTNN) 116 Well Pad Phase 1 - 19 0 Treed Bog (BTNN) 281 Well Pad Phase 1 - 20 91 Treed Bog (BTNN) 324 Well Pad Phase 1 - 21 22 Open Swamp (SONS) 105 Well Pad Phase 1 - 23 78 Open Swamp (SONS) 106 Well Pad Phase 1 - 24 74 Open Swamp (SONS) 537 Well Pad Phase 2 - 25 0 Treed Bog (BTNN) 439 Well Pad Phase 2 - 26 0 Treed Bog (BTNN) 431 Well Pad Phase 2 - 27 10 Open Bog (BONS) 101 Well Pad Phase 2 - 28 0 Treed Bog (BTNN) 318 Well Pad Phase 2 - 29 0 Open Bog (BONS) 241 Well Pad Phase 2 - 30 0 Treed Bog (BTNN) 342 Well Pad Phase 2 - 31 0 Treed Bog (BTNN) 508 Well Pad Phase 2 - 32 0 Open Bog (BONS) 152 Well Pad Phase 2 - 33 0 Open Bog (BONS) 544 Well Pad Phase 2 - 34 0 Treed Bog (BTNN) 368



SIR 2 Table AER 3-1 Footprint Components Located within 100 m of a Water Body (continued)

Footprint Component


Directive 056) (m)



Body (m)

Well Pad Phase 2 - 35 0 Treed Fen (FTNN) 107 Well Pad Phase 2 - 36 0 Open Bog (BONS) 345 Well Pad Phase 2 - 37 0 Treed Swamp (STNN) 445 Well Pad Phase 2 - 38 0 Open Bog (BONS) 133 Well Pad Phase 2 - 39 0 Treed Bog (BTNN) 224 Well Pad Phase 2 - 40 0 Treed Bog (BTNN) 322 Well Pad Phase 2 - 41 0 Treed Swamp (STNN) 114 Well Pad Phase 2 - 42 70 Open Bog (BONS) 253 Well Pad Phase 2 - 43 0 Open Bog (BONS) 413 Well Pad Phase 2 - 44 0 Treed Bog (BTNN) 352 Well Pad Phase 2 - 45 0 Open Bog (BONS) 107 Well Pad Phase 2 - 46 0 Open Swamp (SONS) 290 Well Pad Phase 2 - 47 0 Open Swamp (SONS) 222 Well Pad Phase 2 - 48 0 Open Fen (FONS) 102 Well Pad Phase 2 - 49 0 Open Bog (BONS) 316

Well Pad Phase 3+4 - 50 87 Open Bog (BONS) 103 Well Pad Phase 3+4 - 53 0 Open Bog (BONS) 382 Well Pad Phase 3+4 - 56 0 Open Fen (FONS) 116 Well Pad Phase 3+4 - 59 0 Treed Swamp (STNN) 100 Well Pad Phase 3+4 - 62 0 Open Bog (BONS) 389 Well Pad Phase 3+4 - 63 0 Treed Bog (BTNN) 247 Well Pad Phase 3+4 - 65 0 Treed Bog (BTNN) 1101 Well Pad Phase 3+4 - 68 0 Treed Bog (BTNN) 299 Well Pad Phase 3+4 - 71 0 Treed Bog (BTNN) 325 Well Pad Phase 3+4 - 73 0 Open Bog (BONS) 157 Well Pad Phase 3+4 - 74 0 Treed Swamp (STNN) 496. Well Pad Phase 3+4 - 75 0 Treed Swamp (STNN) 110 Well Pad Phase 3+4 - 76 0 Open Swamp (SONS) 109 Well Pad Phase 3+4 - 77 32 Open Fen (FONG) 109 Well Pad Phase 3+4 - 83 14 Open Swamp (SONS) 100 Well Pad Phase 3+4 - 84 86 Open Swamp (SONS) 106 Well Pad Phase 3+4 - 85 0 Treed Bog (BTNN) 244 Well Pad Phase 3+4 - 87 0 Treed Bog (BTNN) 111



SIR 2 Table AER 3-1 Footprint Components Located within 100 m of a Water Body (continued)

Footprint Component


Directive 056) (m)



Body (m)

Well Pad Phase 3+4 - 88 0 Treed Bog (BTNN) 122 Well Pad Phase 3+4 - 89 0 Treed Bog (BTNN) 101 Well Pad Phase 3+4 - 90 0 Open Swamp (SONS) 104 Well Pad Phase 3+4 - 91 0 Treed Swamp (STNN) 201 Well Pad Phase 3+4 - 92 0 Open Bog (BONS) 105 Well Pad Phase 3+4 - 93 0 Treed Swamp (STNN) 206 Well Pad Phase 3+4 - 94 0 Treed Swamp (STNN) 110 Well Pad Phase 3+4 – 95 0 Open Bog (BONS) 102

3 b. In response to ESRD SIR1 #81, Osum indicates that the location of pads 9 and 12 were selected to optimally develop the bitumen resource based on current geologic data. Some flexibility is offered by CSS extraction to adjust the location of pads and the length of well bores. Discuss the potential surface constraints present in the vicinity of pads 13A, 13B, 9 and 12 that would prevent application of the 100 m setback.

Response:

b. A discussion regarding surface constraints for each of the four identified well pads is described further below:

• The location of well pad 9 was selected adjacent to the central processing facility (CPF), the operations camp, and the proposed right-of-way (ROW) corridor to create a contiguous disturbance and reduce habitat fragmentation. The nature of the mapped watercourse within 100 m of well pad 9 will be evaluated before construction of the operations camp (SIR 2 Figures AER 3-1 and 3-2). As described in the response to Round 2 AER SIR 8, well pad 9 is proposed for development in the year 2039. Assuming that the operations camp is constructed at its current location, mitigation to maintain drainage in the vicinity of the mapped watercourse will be completed before development of well pad 9.

• The location of well pad 12 was selected to optimally access drainage area 12 (to the north) while maintaining a minimum 100 m setback from the field-verified watercourse to the northwest. As described in the response to Round 2 AER SIR 8, well pad 12 is proposed for development in the year 2019. Osum will consider the option of extending well lengths to shift well pad 12 further south (to maintain a



100 m setback from the mapped watercourse) based on the outcome of a site-specific field survey to evaluate the nature of the mapped watercourse.

• The locations of well pads 13A and 13B were selected to optimally develop their associated drainage areas. The mapped watercourses in the vicinity of these well pads were ground-truthed in summer 2012 and determined to be undefined drainages with nil fish habitat. As described in the response to Round 2 AER SIR 8, well pads 13A and 13B are proposed for development in the years 2035 and 2040, respectively. If site-specific conditions change before development of these well pads, Osum will consider options to either relocate these well pads to maintain a 100 m setback from the mapped watercourses or to employ appropriate mitigation to maintain natural drainage patterns.

Reference:

Alberta Energy Regulator (AER). 2014. Directive 056: Energy Development Applications and Schedule. May 1, 2014.

http://www.aer.ca/documents/directives/Directive056_April2014.pdf


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C. BeaumontB. FuchsE. Johnston

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4 Volume 1, Section 3.1.1.15, Runoff Pond, Page 3-11. In Section 3.1.1.15, Osum indicates that the industrial runoff pond would be designed to meet the 1 in 25 year 24-hour storm event. Given that the proposed project would have an estimated lifespan of 40 years, provide the rationale behind why the proposed storm water pond is designed to meet a 1-in-25-year, 24-hour storm event and not a 1-in-50-year, 24-hour storm event.

Response:

Osum’s proposed design for the industrial runoff control system at the CPF and the well pads is compliant with the guidance provided in Appendix F of the Environmental Protection and Enhancement Act, Guide to Content for Energy Project Applications (AER 2014) and uses the same approach as other recently approved in situ oil sands projects (such as the Brion Energy Dover Commercial Project; Environmental Protection and Enhancement Act (EPEA) approval 00268285-00-00). The proposed CPF runoff pond design capacity exceeds the calculated runoff volume of the 1 in 25 year 24-hour rainfall event by 20%.

The runoff return for the 1 in 50 year, 24-hour storm event at the Fort McMurray Airport station is 0.0846 m. Using the calculations presented in Volume 1, Section 3.1.1.15 of the environmental impact assessment (EIA) report, the runoff volume to be contained for the 1 in 50 year 24-hour storm event would be 20,145 m3. This volume is less than the design capacity of the CPF runoff pond (21,630 m3).

Reference:

Alberta Energy Regulator (AER). 2014. Environmental Protection and Enhancement Act, Guide to Content for Energy Project Applications. Calgary, Alberta. March 29, 2014. 101 pp.



5 Volume 4, Section 6.6.4, Mitigation Measures, Pages 6-71 to 6-73; Volume 4, Figure 6.6-1; Supplemental Information Requests 1, AESRD #121, Page 2-449 to 2-450.

Figure 6.6-1 identifies “potential slope failure locations” as a result of deeply incised water channels. In response to ESRD SIR1 #121, Osum states that water erosion risk associated with stream channels, irrespective of slope class, was considered in the hydrology assessment and mitigation measures were outlined in Sections 6.6.3 and 6.6.4.5 of Volume 4. The only mitigation listed specific to the special circumstances of steep valley slopes is completing a slope stability assessment as part of detailed engineering when designing facilities near steep sloped valleys.

a. Provide examples of special construction techniques that may be used in construction of facilities near steep sloped valleys.

Response:

a. Specific construction techniques to be employed will be designed based on site-specific conditions encountered and with consideration for the results of the site-specific geotechnical assessment. Examples of typical construction techniques that could be used near steep-sloped valleys include:

• use of the “cut and fill” method to develop level slopes, with preference for construction on cut areas that tend to be more stable;

• use of appropriate soil compaction acceptance criteria to ensure stability of disturbed areas; and

• construction of retaining walls or other slope reinforcement measures as required.

5 In SIR1 #121 Osum identifies approximately 50% of the terrain and soils to be disturbed by the project footprint are susceptible to water erosion due to their occurrence on slopes.

b. On a map, identify the areas where erosion potential is greater due to greater slope length and steepness.

Response:

b. The requested map describing erosion potential in the vicinity of the Project was presented on Figure 9.5-9 (Volume 5, Section 9 of the EIA report). This figure was the basis for Osum’s statement in the response to Round 1 ESRD SIR 121 that approximately 50% of the terrain and soils to be disturbed by the Project have moderate erosion potential. Erosion sensitivity presented on Figure 9.5-9 was developed based on characteristics of local soils and topographic slope (i.e., low slope: less than 5%, moderate slope: from 5% to 9%, high slope: greater than 9%), as described in Volume 5, Section 9.5.8 of the EIA report. Although 50% of the Project footprint is located in areas with moderate erosion potential, only 3 ha (0.2%) of the Project footprint occurs on slopes greater than 9%. While erosion risks due to slope are greater with increasing slope length and steepness, overall erosion risks during facility



construction are influenced by both topographic slope and soil erodibility. For example, high sloped coarse-grained soils may have a lower erosion risk than low slope fine-grained soils during facility construction.

5 c. Provide a discussion that links vegetation removal estimates to potential increases in erosion potential. Include identification of how erosion and increased sedimentation would be managed with respect to vegetation removal in those areas specifically and indicate whether there are mitigation measures beyond those provided in Section 6.6.4 that could be used to specifically address increased erosion risks in the vicinity of steep sloped valleys.

Response:

c. Osum understands that cleared areas are more susceptible to erosion than vegetated slopes. The erosion potential map presented on Figure 9.5-9 (Volume 5, Section 9 of the EIA report) identifies areas of the Project footprint with moderate erosion potential. In these areas in particular, Osum will implement the mitigation measures described in the response to part a) above to reduce the potential for increased erosion.

5 d. Discuss whether a 100 m setback from the areas identified as “potential slope failure locations” is adequate or whether a different setback should be considered.

Response:

d. Osum identified the 100 m setback from defined watercourses as a standard mitigation measure for design of all facilities. For all infrastructure required to develop the Project Area, the measured setback from watercourses where historic slope failure has been observed exceeds 100 m. Before development of facilities near steep slopes, Osum will complete a site-specific geotechnical survey to evaluate local slope stability. If the results of that survey recommend a greater setback distance than proposed in the application, then Osum will work with regulators and revise the facility location as needed to increase the setback in order to construct safely.



1.1.1.4. Terrestrial

6 Volume 6, Figure 13.5-5: Registered Fur Management Areas. Figure 13.5-5 indicates that there are five registered RFMAs in the land use local study area, however it is not clear whether there are any trappers cabins associated with the identified traplines. Identify the location of any RFMA related surface infrastructure within the land use study area and discuss potential project effects (e.g., access, noise or light disturbance) and proposed mitigations.

Response:

There are two trappers cabins associated with the identified traplines located at 10-06-086-18 W4M and 03-25-086-20 W4M. These cabins were identified as receptor numbers 18 and 24, respectively, and were included in the air quality and noise modelling completed as part of the EIA (Volume 3, Section 2 and Volume 3, Section 3, respectively). The results of both the air quality and noise models predict that emissions from the Project will comply with applicable regulatory guidelines at these locations. Osum will continue to consult with the trapline holders throughout the life of the Project and will work to address identified issues related to access, light, or other disturbance due to the Project.



7 Volume 5, Section 10.6.2, Mitigation Measures, Page 10-115. In Section 10.6.2 Osum states “The mitigation measures focus on reducing or adjusting the Project footprint, therefore reducing the amount of vegetation loss.”

Aside from a 100 m water body setback and a 100 m buffer from the Grand Rapids Wildland Provincial Park, Osum has not identified specific environmental surface constraints considered in the footprint siting process or demonstrated how the project footprint considered environmentally sensitive areas.

a. Provide a surface constraints map that identifies all environmental constraints considered as part of the disturbance footprint selection process. The figure should illustrate sensitive areas located in the area of the proposed project (e.g. potential slope failure locations, anthropogenic features, wetlands of limited distribution, rare plants, old growth forest, sensitive wildlife habitat, etc.), a 100 m buffer on all water bodies, the proposed project and development area boundaries, and the full project footprint.

Response:

a. As described in Volume 1, Section 1.2 of the EIA report, the proposed Project footprint was superimposed on mapping systems that incorporate environmental information to analyze and mitigate potential environmental effects of surface facility locations. These mitigation measures include maximizing the use of existing land disturbances, reducing aquatic and terrestrial fragmentation, avoiding potentially sensitive ecosystems and maintaining required setbacks from sensitive features including water bodies and watercourses, key wildlife and biodiversity zones, the Grand Rapids Wildland Provincial Park, and local topography. During this footprint optimization process, Osum eliminated over 8 km of linear disturbance, approximately 50 ha of total disturbance, and five potential watercourse crossings. Refer to SIR 2 Figure AER 7-1 for an environmental surface constraints map identifying the following key constraints considered as part of this process:

• Grand Rapids Wildland Park • Goose Coulee (100 m buffer) • Water features (100 m buffer) • Baseline disturbance (roads, cut trail, powerline, and pipelines) • Soil map (uplands and organic)

In addition, the Project Area is located in the vicinity of both the West Side Athabasca River (WSAR) caribou range and a key wildlife and biodiversity zone, as presented on SIR 2 Figure AER 7-2. Although developing the Project Area required the placement of some surface facilities within the WSAR caribou range, Osum made efforts to avoid creating new habitat disturbance where practical. Osum maintained a minimum 100 m setback from the key wildlife and biodiversity zone for all surface facilities.



7 b. Reference each of the above-identified features and discuss how the footprint locations were selected in consideration of the constraints identified. Include a discussion of the specific trade-offs considered.

Response:

b. Development of the Project footprint proceeded in stages. Separate descriptions of how constraints mapping was utilized to select each of the CPF location, the main access road alignment, well pad locations, borrow area locations and pipeline ROW are described further below.

Based on the resource potential of the area, Osum determined that the Project design capacity would be 60,000 bpd, which helped dictate the approximate space required to develop the CPF. The selected CPF location would need to be centrally located within the proposed Project Area to feasibly provide steam to each of the identified well pads. In addition, it was preferred that the CPF location be selected in an area of upland mineral soil, to reduce fill requirements and to provide a stable base for construction. As presented on SIR 2 Figure AER 7-1, one large area of upland mineral soil was centrally located and large enough to accommodate the CPF location. In addition, as presented on SIR 2 Figure AER 7-2, this location was outside of both the WSAR caribou range and the adjacent key wildlife and biodiversity zone. Based on these factors, the current CPF location was selected. Other CPF locations could have been considered, but would have required additional fill for construction and/or longer steam lines to access the well pads and likely resulted in additional sensory and physical disturbance within the WSAR caribou range.

Once the CPF location was selected, Osum determined the most appropriate route to access the CPF. For the main access road, the existing Osum/Laricina Road (Volume 1, Figure 1.2-2 of the EIA report) currently extends as far as the Osum Laricina Saleski JV Pilot project. Osum initially considered a shorter main access road that continued directly east from the Saleski JV Pilot to the northwest corner of the Project CPF location. While that access road was shorter and would have required less cost and less fill material to construct, it also would have potentially overlapped with the proposed Commercial Phase 1 expansion of the Saleski JV Pilot, and also would have required the construction of additional watercourse crossings. Osum also considered the potential safety hazard of having to haul heavy loads (including modules) to the Project through the existing Saleski JV Pilot facility. As a result, Osum elected to deviate from the existing road just east of the existing bridge on the Livock River, and follow existing disturbance south and then east to the southwest corner of the selected CPF location. This selected main access road alignment was longer than originally proposed, but included fewer watercourse crossings.

Once the main access road alignment was selected, Osum’s subsurface teams provided optimal well pad locations to access each identified drainage area. Through collaboration with Osum’s facilities and environment teams, initial well pad locations were adjusted to accommodate identified surface constraints while still maintaining access to the resource. The main constraints considered during this exercise included avoiding overlaps within existing gas



pipelines in the area while also maintaining appropriate setbacks from the Goose Coulee, the nearby key wildlife and biodiversity zone and mapped watercourses and water bodies (SIR 2 Figure AER 7-1). Concurrent with this process, Osum retained a qualified aquatic environmental specialist to ground-truth mapped watercourses in the vicinity of the CPF and initial well pad locations and evaluate the nature of mapped watercourses. In areas where mapped watercourses were confirmed to have defined channels, well pad locations were revisited to maintain a minimum 100 m setback. One of the key tradeoffs considered during ROW placement was the sequencing of pad development. In order to minimize the number of watercourse crossings required, Osum considered several alternative ROW configurations. The selected ROW configuration had the lowest number of watercourse crossings, although the timing of required infrastructure development did not align with the optimal resource development timing.

Once the CPF, main access road and well pad locations were selected, Osum worked to identify appropriate borrow area locations to support the development. Approximations of the fill material required for development were based on topographic contours and available soil mapping (distinguishing upland soils from wetland soils). Borrow areas selected were considered suitable for development based on soil characteristics and on proximity to proposed ROW corridors. Osum avoided other potentially more suitable borrow area targets to minimize disturbance and select borrow areas adjacent to required ROW corridors.

The locations of the proposed saline and non-saline water source wells were determined based on the results of aquifer testing. Osum conducted extensive exploration programs from 2011 through 2013 to evaluate suitable water sources for the Project. Options to develop these water source wells closer to the CPF were considered, and would have been preferable from a surface constraints perspective, but suitable aquifer characteristics could not be identified in proximity to the CPF. Once the water source well locations were selected, pipeline ROWs were identified that aligned with other proposed disturbances to use a common corridor. Shorter, less expensive pipeline alignments were considered that followed direct lines to the identified water source wells, but these alternatives were rejected in order to parallel existing disturbances.

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C. BeaumontB.FuchsE.Johnston

FootprintProject AreaDevelopment AreaFuture Project AreaExisting DisturbanceGrand Rapids Wildland ParkGoose CouleeGoose Coulee 100m Buffer100m Water SetbackWater BodyWatercourseRoadIndustry RoadCut TrailPowerlinePipeline

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FootprintKey Wildlife and Biodiversity Zone 100m BufferCaribou RangeProject LeaseWildland Provincial ParkWater BodyWatercourseRoadIndustry RoadPowerlinePipeline

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Athabasca

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8 Volume 2, Section 8.5, Progressive Reclamation Plan, Page 8-21; Volume 2, Section 8.8, Timeline for Completion of Development and Reclamation, Page 8-23. On Page 8-21, Osum states, “Osum plans to progressively reclaim production well pads and associated facilities when these have reached the end of their useful life, following abandonment and decommissioning.”

Aside from identifying in Section 8.8 that reclamation was expected to begin in 2063, and providing an initial development schedule for the first six well pads (SIR1 Table AER 3-1), a conceptual well pad development schedule (e.g. construction, production, reclamation) was not provided. For an AER commercial scheme application, there must be discussion of the management of the full project’s footprint over the life of the project.

The AER understands and expects that project footprints will evolve as development occurs. However, in order to better discuss the management of the full project’s footprint over its life and assess temporal mitigations of footprint disturbance effects, provide a conceptual table of the life of the project that illustrates the estimated construction, operation and production, and reclamation start dates (by year or period) for each of the proposed pads.

Include identification (using unique well pad identification) of which pads are associated with which phase of the proposed project.

Response:

Refer to SIR 2 Table AER 8-1 for the conceptual well pad development schedule. As noted in SIR 2 Table AER 8-1, Osum’s current plan for initial development includes well pads 1, 2, 3 6 and 10. Development of well pads 4 and 5 is now planned for 2019. The schedule presented in SIR 2 Table AER 8-1 assumes that well pads have a life ranging from 10 to 15 years and that reclamation will begin approximately 2 years after production at a given well pad is complete. Phase 1 production at a rate of 30,000 bpd will be sustained from 2018 to 2022. The expansion to Phase 2 production at a rate of 60,000 bpd is planned to start in 2022.



SIR 2 Table AER 8-1 Conceptual Well Pad Construction and Reclamation Schedule

Year # Total Pads Developed

# Total Pads Reclaimed

Active Well Pads # Producing

Pads 2018 5 0 1, 2, 10, 6, 3 5 2019 11 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15 11 2020 13 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16 13 2021 15 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19 15 2022 23 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27 23 2023 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2024 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2025 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2026 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2027 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2028 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2029 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2030 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2031 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2032 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2033 25 0 1, 2, 10, 6, 3, 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29 25 2034 29 0 7, 4, 5, 11, 12, 15, 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29, 30, 31, 32, 33 24 2035 33 0 8, 16, 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37 22 2036 37 5 17, 19, 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41 24 2037 42 10 18, 21, 20, 23, 13A, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47 28 2038 44 13 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49 22 2039 46 15 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14 22 2040 48 23 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B 24 2041 48 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B 24



SIR 2 Table AER 8-1 Conceptual Well Pad Construction and Reclamation Schedule (continued)

Year # Total Pads Developed

# Total Pads Reclaimed

Active Well Pads # Producing

Pads 2042 48 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B 24 2043 48 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B 24 2044 48 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B 24 2045 48 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B 24 2046 49 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B, 24 25 2047 49 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B, 24 25 2048 49 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B, 24 25 2049 49 25 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B, 24 25 2050 49 25 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B, 24 21 2051 49 25 38, 39, 40, 41, 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B, 24 17 2052 49 29 42, 43, 44, 46, 47, 48, 49, 9, 14, 22, 13B, 24 13 2053 49 33 48, 49, 9, 14, 22, 13B, 24 7 2054 49 37 9, 14, 22, 13B, 24 5 2055 49 42 22, 13B, 24 3 2056 49 44 24 1 2057 49 46 24 1 2058 49 48 24 1 2059 49 48 24 1 2060 49 48 24 1 2061 49 48 24 1 2062 49 48

0

2063 49 48

0 2064 49 49

0



1.1.1.5. Air

9 Volume 3, Page 2A-27, Table 2A-21. The table titled “Table 2A-21 Miscellaneous Dispersion and Computational Parameters (Input Group 12)” indicated that the modelled “Elevation above seas level” is 334 m ASL. Table 2.6-1 in Volume 3 indicates that the site elevation is 569 m ASL. Confirm that the correct site elevation was used in the air dispersion modelling assessment.

Response:

All topographic elevations for terrain in the CALMET modelling, as well as for receptor and source elevations in the CALPUFF modelling, were obtained directly from the Shuttle Radar Topography Mission (3 Arc Second – 90 m) database. The CALMET pre-processor program, TERREL, was used to extract and format terrain data. The elevation indicated in Volume 3, Table 2A-21 of the EIA report was a manual typographical error. Osum confirms that the correct site elevation of 569 m was used in the modelling.



10 Volume 3, Page 2-20, Section 2.4.2.3 Approach of Nitrogen Oxides. Osum utilizes observed ozone (O3) concentrations from the Anzac air monitoring station for ozone limiting method (OLM) calculations. The 2009 Alberta Air Quality Model Guideline specifies that if no on-site ozone data is available; the ESRD prescribed ozone levels are to be used; which may be more conservative than data from Anzac. Explain why the Anzac ozone data was used, as opposed to using the ESRD prescribed levels to convert NOX to NO2.

Response:

Ozone data from Anzac was used because it was the closest air quality station that measured ambient ozone concentrations outside an urban area. Moreover, the 2009 Alberta Air Quality Model Guideline (AQMG; GoA 2009), under which the dispersion modelling for the EIA was conducted, did not clearly define “onsite measurements”. In the EIA this was interpreted to mean the nearest representative source of ozone data applicable to the Project.

The 2013 AQMG (GoA 2013a) has provided more clarity regarding the use of ozone data in the application of the Ozone Limiting Method. The 2013 AQMG now provides a province-wide ozone time-series dataset that can be used for modelling. The dispersion modelling results from Volume 3, Section 2 of the EIA report have been updated using this ozone time-series data set and are presented in SIR 2 Table AER 10-1. The updated results show that predicted ground-level NO2 concentrations using the time-series ozone data are nearly always lower than when local Anzac observations were used. All predicted results are still well below the applicable Alberta Ambient Air Quality Objectives Summary (AAAQO; GoA 2013b).

The use of time-series data also changed the locations of some of the predicted maximum points of impingement (MPOIs). The most prominent example of this can be seen in the local study area (LSA) predictions. In the original modelling, the MPOIs for the Baseline, Application and Planned Development Case assessments were located along the southern edge of the LSA, about 15 km away from the Project fenceline. In the updated modelling with the time-series ozone data, the addition of the Project shifted the MPOIs for the Application and Planned Development Case assessments to the Project fenceline.

The original predictions remain a conservative estimate of change in NO2 concentrations resulting from the Project.



SIR 2 Table AER 10-1 Predicted Nitrogen Dioxide Concentrations – Ozone Limiting Method Using Time Series Ozone Data

Receptor Location Baseline Case

[µg/m3] Application Case

[µg/m3]

Planned Development

Case [µg/m3]

Project Only [µg/m3]

Application Case Increase Over Baseline [%]

Planned Development Case

Increase Over Baseline [%]

9th Highest 1-Hour (99.9th Percentile) Overall Maximum (RSA MPOI) 164 (172) 164 (172) 164 (172) 91 (103) 0.0 (0.0) 0.0 (0.0)

Local Area Maximum (LSA MPOI) 75 (107) 92 (107) 92 (107) 91 (103) 23.0 (0.0) 23.1 (0.0)

CPF Boundary 55 (66) 85 (94) 85 (95) 85 (91) 53 (43) 53 (44)

Maximum from Health Receptors 164 (172) 164 (172) 164 (172) 69 (75) 0.0 (0.0) 0.0 (0.0)

ESRD AAAQO(a) 300 300 300 300 Annual Average Overall Maximum (RSA MPOI) 18 (30) 18 (30) 20 (32) 6.1 (6.1) 0.4 (0.2) 9.7 (7.1)

Local Area Maximum (LSA MPOI) 7.6 (7.6) 8.0 (8.1) 9.6 (9.7) 6.1 (6.1) 5.6 (5.9) 27 (27)

CPF Boundary 6.1 (6.1) 7.1 (7.2) 8.4 (8.4) 5.1 (5.2) 17 (17) 37 (37)

Maximum from Health Receptors 18 (30) 18 (30) 20 (32) 4.5 (4.6) 0.4 (0.2) 9.7 (7.1)

ESRD AAAQO(a) 45 45 45 45 (a) Source: ESRD 2013b. Bracketed predictions are from the EIA, using Anzac ozone measurements. Hatched Cells: AAAQOs are not applicable to predicted increases.



References:

Government of Alberta (GoA). 2009. Air Quality Model Guideline. Prepared by A. Idriss and F. Spurrell, Climate Change, Air and Land Policy Branch, Alberta Environment. Edmonton, Alberta. Revised May 2009. ISBN: 978-0-7785-8512-1. http://www.assembly.ab.ca/lao/library/egovdocs/2009/alen/173465.pdf

Government of Alberta (GoA). 2013a. Air Quality Model Guideline. Edmonton, Alberta. Effective October 1, 2013. ISBN: 978-1-4601-0599-3. http://environment.gov.ab.ca/info/library/8908.pdf

Government of Alberta (GoA). 2013b. Alberta Ambient Air Quality Objectives and Guidelines Summary. ISBN: 978-0-7785-9986-9 (Online). August 2013. http://environment.gov.ab.ca/info/library/5726.pdf

http://www.assembly.ab.ca/lao/library/egovdocs/2009/alen/173465.pdf

http://environment.gov.ab.ca/info/library/8908.pdf




11 Volume 3, Page 2-64, Section 2.7.10 Odour Assessment, Table 2.7-20. Osum conducted an odour assessment for the project and indicated that hydrogen sulphide (H2S) exceeded the odour threshold for the 3-minute predicted concentration in the Project Only scenario within the local study area. Provide an odour mitigation strategy.

Response:

As described in Volume 3, Section 2.7.10.2 of the EIA report, the dispersion modelling conducted for the Project predicted concentrations above the 3-minute odour threshold at a frequency of 0.37%, typically overnight during the winter. Based on the remote location of the CPF, it is considered unlikely that members of the public will routinely access this area. No specific odour mitigation is proposed at this time. If the public notices an odour, they can phone Osum’s toll free, 24-hour emergency number: 1-877-770-7782. Osum will work with the individual that registered the complaint to understand the details surrounding the odour incident. Key pieces of information will be the location of the odour, a description of the odour, the weather conditions, and the time of day. If the odour complaint is registered in real time, Osum will send a staff member to meet the individual where they are noticing the odour and gather information regarding the incident.

Osum is planning to have a weather station that measures temperature, wind speed, and direction. Osum will review the operations log concurrent with the weather information to attempt to determine the source of the odour and work to determine a fix to the issue causing the odour. If recurring odour issues are identified, Osum will work with regulators and stakeholders to identify appropriate corrective measures.



EPEA Application No. 001-320736 1.1.2

1.1.2.1. General

12 SIR Round 1 Responses, SIR 75, Page 2-354. Osum indicates that the Domestic wastewater treatment plant will meet the Alberta Private Sewage Systems Standard of Practice Handbook (Safety Codes Council 2009). Note that for a plant that will be treating greater than 25 m3/d of domestic wastewater, an EPEA approval will be required and it is to be designed to the Standards and Guidelines for Municipal Waterworks, Wastewater and Storm Drainage Systems (Alberta Environment and Sustainable Resource Development 2013).

Response:

Osum agrees with this interpretation and will obtain the required EPEA approval and municipal permits before operating the domestic wastewater treatment plant.



1.1.2.2. Air

13 SIR Round 1 Response, SIR 11, Page 2-196. Demonstrate with calculations how the proposed cogeneration unit complies with the CCME National Emission Guideline for Stationary Combustion Turbines and the CASA Alberta Air Emission Standards for Electricity Generation.

Response:

This calculation was provided in Volume 3, Appendix 2B, Section 2B.2.5 of the EIA report. The relevant portion of the calculation has been reproduced below.

Emissions for the cogeneration units were based on vendor estimates for an electrical output of 85 MW and heat output of 812 GJ/h from the heat recovery steam generator (HRSG) with supplementary firing. The following calculations show that the vendor oxides of nitrogen (NOx) emission estimates for the cogeneration unit is below both the National Emission Guidelines for Stationary Combustion Turbines (CCME 2002) and the Alberta Air Emission Standards for Electricity Generation and Alberta Air Emission Guidelines for Electricity Generation (AENV 2005).

National Emission Guidelines for Stationary Combustion Turbines (CCME 2002)

• guidelines = 140 g/GJ (power) + 40 g/GJ (heat) • estimated power output from Project cogeneration unit = 85 MW × (3.6 GJ/MWh) =

306 GJ/h • estimated heat input into HRSG (supplemental firing plus recovered energy) =

1002 GJ/h • estimated NOX emissions of each cogeneration unit based on the CCME guidelines =

(140 g/GJ) × (306.0 GJ/h) + (40 g/GJ) × (1,002 GJ/h) = 82,946 grams/hour (g/h) = 23.0 grams/second (g/s) = 1.99 t/d

• estimated NOX emissions from Project cogeneration unit = 1.43 t/d (which is below the CCME guideline limit of 1.99 t/d)

Alberta Air Emission Standards for Electricity Generation and Alberta Air Emission Guidelines for Electricity Generation (AENV 2005)

• standard = 0.3 kg/MWh (combined heat and electricity) • estimated power output from Project cogeneration unit = 85 MW • estimated recovered heat output of Project cogeneration unit = 812 GJ/h ×

0.278 MWh/GJ = 226 MW • maximum NOX emissions allowable based on ESRD standard = (0.3 kg/MWh) ×

(85 MW Electricity + 226 MW heat Output) = 93.2 kg/h = 25.9 g/s = 2.24 t/d • estimated NOX emissions from Project cogeneration unit used in modelling = 1.43 t/d

(which is below the ESRD guideline limit of 2.24 t/d)

References:



Alberta Environment (AENV). 2005. Alberta Air Emission Standards for Electricity Generation and Alberta Air Emission Guidelines for Electricity Generation. Environmental Policy Branch. Edmonton, Alberta. December 2005. ISBN: 978-0-7785-6759-2. http://www.environment.gov.ab.ca/info/library/7837.pdf

Canadian Council of Ministers of the Environment (CCME). 2002. National Emission Guidelines for Stationary Combustion Turbines. December 2002.

http://www.environment.gov.ab.ca/info/library/7837.pdf



14 SIR Round 1 Response, SIR 12b, SIR 154a and SIR 155, Pages 2-198, 2-518 and 2-519. Osum provides the sulphur emissions calculations and results for the project.

a. Provide a process flow diagram to for SIR 12b to illustrate the process described by the calculations.

Response:

a. SIR 2 Figure AER 14-1 shows the sulphur emissions for the Project.

14 b. Osum indicates that a portion of the treated produced gas will be used by the OTSG. Confirm whether Osum is routing a portion of the produced gas to the OTSG rather than sending it to the Sulphur recovery unit. If so, what is the percentage?

Response:

b. The produced gas will be sent to the amine absorber for sweetening. All the sweetened produced gas will be sent to the once-through steam generators (OTSGs) as supplemental fuel for combustion. The sweetened produced gas will still contain 200 ppmv or 0.026 t/d sulphur. The rich amine exiting from the absorber will be cooled and sent to the acid gas stripper where steam strips out hydrogen sulfide (H2S) and carbon dioxide (CO2) to produce acid gas. The acid gas will then be sent to the sulphur recover unit where 1.84 t/d sulphur is recovered and the remaining 0.724 t/d sulphur in the tail gas is incinerated.

14 c. Osum indicates that total sulphur dioxide (SO2) emissions from the incinerator and once through steam generators (OTSG) will be 1.499 t/d (SIR 12b) while SIR 155c indicates it will be 1.62 t/d. Clarify the discrepancy between the two SIRs SO2 emissions.

Response:

c. After a full review of the sulphur balance for the Project, Osum is unable to find any discrepancies in the sulphur emissions presented. The response to Round 1 ESRD SIR 12b calculated total sulphur to combustion sources (at the top of page 2-200) as 33.7 kg/h or 0.81 t/d. This translates to 1.62 t/d sulphur dioxide (SO2), which matches the response to Round 1 ESRD SIR 155c.

The 8.68 g/s sulphur (equivalent to 0.75 t/d sulphur or 1.499 t/d SO2) mentioned near the end of the response to Round 1 ESRD SIR 12b is the sulphur emissions resulting from the produced gas stream shown in the process flow diagram above, and excludes the potential sulphur contained in the natural gas. The 8.68 g/s (0.75 t S/d) sulphur emission rate includes the emissions resulting from the consumption of sweetened produced gas by the OTSGs



(0.30 g S/s or 0.026 t S/d) and the emissions from the treatment of the tail gas in the incinerator (8.38 g S/s or 0.724 t S/d).

The potential sulphur emissions from natural gas combustion was conservatively assumed to be 0.67 g S/s (0.058 t S/d).Therefore, the total sulphur emissions is 0.81 t S/d (0.026 t S/d + 0.724 t S/d + 0.058 t S/d), which is equivalent to 1.62 t/d of SO2.

SIR 2 Figure AER 14-1 Sulphur Emissions Process Flow Diagram



15 SIR Round 1 Response, SIR 154b, Page 2-518. Osum states “The selected inlet gas composition of 2% mol H2S is a conservatively high estimate that incorporates a safety factor of approximately 5:1 based on the Saleski JV Pilot performance to date.”

a. Explain why the 2% mol H2S composition is considered a conservatively high estimate.

Response:

a. Osum has monitored the H2S concentration in the produced gas at the Saleski JV Pilot from Q3 2011 to present. Monthly average results have ranged from 847 ppmv to 4,350 ppmv. Osum’s design estimate of 2%mol H2S (20,000 ppmv) is considered conservative because it substantially exceeds the H2S concentrations measured to date at the closest production analogue (the Saleski JV Pilot)

15 b. Discuss the conservativeness of the estimate as the project approaches end of life.

Response:

b. It is considered likely that the H2S concentration in the produced gas stream will increase over the life of the Project, but as stated in part a) above, the maximum monthly average H2S concentration observed to date at the Saleski JV Pilot has been 4,350 ppmv. Even if the H2S concentration was to increase as the Project approaches end of life, Osum does not anticipate that it would exceed the design concentration of 20,000 ppmv. However, Osum will monitor H2S concentration in the produced gas over the life of the Project, and will comply with the sulphur recovery guidelines presented in Interim Directive 2001-3 (EUB 2001) and the SO2

emission limit in the anticipated EPEA approval.

Reference:

Energy and Utilities Board (EUB). 2001. Interim Directive ID 2001-03 - Sulphur Recovery Guidelines for the Province of Alberta. Calgary, Alberta. August 2001.



1.1.2.3. Water Quality

16 Application, Volume 4, Section 7.5.1 Historical Information and 2012 Data, Page 7-21. The list of sediment quality indicators does not include particle size.

a. Given that concentrations of parameters of concern vary with sediment particle size, comment on why this parameter was not included in analyses of sediment metal and PAH data.

Response:

a. Sediment particle size was included in the list of parameters analyzed, and the results of this analysis are presented in Volume 4, Appendix 7B of the EIA report. Particle size was inadvertently omitted from the list of sediment quality indicators listed in the text presented in Volume 4, Section 7.5.1 of the EIA report.



17 Application, Volume 4, Section 7.5.1 Historical Information and 2012 Data, Page 7-22. Osum states “Non-detectable concentrations were set to one-half the detection limit to conduct summary statistics, except in the PAHs, where non-detectable concentrations were excluded from the analysis.” Tables 7.5-2 to 7.5-5 have several metal parameters indicated as ND (not detected).

a. Explain if ND in these tables is equivalent to below detection limit.

Response:

a. Osum confirms that the notation “ND” in Volume 4, Tables 7.5-2 through 7.5-5 of the EIA report is equivalent to below detection limit.

17 b. Provide revised tables using the protocol set out in Section 7.5.1 page 7-22, indicating which parameters are below detection limit and are represented by one-half the detection limit.

Response:

b. Revised tables are provided as requested as SIR 2 Tables AER 17-1 through 17-4. Parameters represented by one-half the detection limit are shown in italics.



SIR 2 Table AER 17-1 Summary of Water Quality Data from Tributaries to the Athabasca River (2012)

units Winter (N=7) Spring (N=14) Summer (N=11) Autumn (N=16)

Min Max Mean SD Min Max Mean SD Min Max Mean SD Min Max Mean SD Temperature Deg. 0 1.68 0.79 0.56 0.05 9.90 5.70 3.07 13.6 22.6 16.06 3.12 5.65 10.92 8.63 1.74 pH Unit 6.8 8.2 7.65 0.5 6.7 8.2 7.5 0.4 7.1 8.8 7.8 0.4 7.1 8.4 7.8 0.4 Conductivity µS/cm 141 2370 769 780 43 429 187 123 96 913 304 279 96 1350 444 462 Dissolved Oxygen mg/L 0.22 10.3 2.8 3.4 11.2 16.8 13.8 2.1 1.1 9.6 6.0 3.4 1.6 11.6 8.9 3.6 Total Dissolved Solids (TDS)

mg/L 224 1460 575 433 77 290 156 68 120 634 265 135 154 884 352 257

Hardness mg/L 50.2 307.0 160.5 95.9 14 77 35 19 34 134 73 28 37 232 88 56 Alkalinity mg/L 56 938 288 289 9 89 41 22 35 274 94 69 40 293 117 87 Bicarbonate mg/L 69 1140 351 351 12 108 50 27 42 334 115 84 49 352 142 104 Sodium mg/L 12 479 110 161 3 61 20 18 5 149 37 42 6 246 68 87 Chloride mg/L 0.25 58.2 8.5 20.2 0.25 2.62 0.94 0.79 0.25 19.90 3.03 5.84 0.03 20.8 4.1 6.6 Sulphate mg/L 0.25 379.0 103.9 150.6 0.81 106.0 27.3 35.0 0.51 154 30 46 0.6 438 97 149 Ammonia mg/L 0.16 1.24 0.52 0.41 0.025 0.225 0.058 0.056 0.025 0.08 0.04 0.02 0.002 0.900 0.085 0.128 TKN mg/L 1.30 3.64 2.43 0.89 0.96 1.93 1.41 0.31 1.07 6.10 1.91 1.42 0.39 2.91 1.42 0.66 TP mg/L 0.09 1.17 0.44 0.36 0.08 0.41 0.18 0.09 0.094 0.29 0.18 0.07 0.06 0.55 0.15 0.13 Dissolved Organic Carbon (DOC)

mg/L 27.7 92.8 59.3 29.1 22.2 41.4 28.3 5.1 0.50 80.0 51.3 22.12 13.0 65.0 43.0 14.9

Total Organic Carbon (TOC)

mg/L 28.6 101.0 65.0 31.0 22.5 42.0 28.6 5.5 35.5 83.8 56.5 14.8 13.3 72.3 44.2 15.3

Phenols mg/L 0.008 0.089 0.034 0.029 0.008 0.016 0.012 0.003 0.009 0.025 0.016 0.005 0.001 0.021 0.013 0.006 Aluminum µg/L 45 1,010 330 323 67 3,930 1,091 1,098 59.9 1,980 460 546 0.028 462 86 161 Arsenic µg/L 0.78 5.78 2.24 1.73 0.42 3.73 1.67 1.05 0.79 4.67 2.59 1.12 0.001 2.03 0.36 0.62 Cadmium µg/L 0.1 0.1 0.1 --- 0.02 3.00 0.27 0.79 0.005 1.22 0.209 0.404 0.1 0.194 0.02 0.04 Chromium µg/L 0.40 2.46 0.95 0.74 0.40 4.00 1.51 1.15 0.21 3.90 1.36 1.26 0.40 1.26 0.28 0.45 Copper µg/L 0.50 3.50 1.33 1.01 0.50 9.10 3.49 2.91 0.26 3970 569 1317 0.001 2.73 0.54 0.95 Iron µg/L 1,720 20,600 8,776 7,167 8 6,800 2,940 2,012 0.54 11,200 4,397 3968 0.19 4,920 715 1,339 Lead µg/L 0.05 1.52 0.47 0.50 0.05 5.87 1.66 1.75 0.05 96.9 15.8 34.0 0.05 0.826 0.146 0.270 Manganese µg/L 539 7010 2055 2080 38 576 248 188 0.005 1230 269 364 0.035 550 78.7 154 Mercury ng/L 0.02 23 3.5 .008 0.017 0.017 0.017 --- 50 7490 1050 2380 0.017 0.017 0.017 ---



SIR 2 Table AER 17-1 Summary of Water Quality Data from Tributaries to the Athabasca River (2012) (continued)


Min Max Mean SD Min Max Mean SD Min Max Mean SD Min Max Mean SD Nickel µg/L 1.99 22.1 7.00 6.80 0.76 23.1 7.20 7.44 0.12 12.5 4.25 4.41 0.002 33.7 4.2 9.8 Selenium µg/L 0.20 0.20 0.20 --- 0.20 0.20 0.20 --- 0.20 0.53 0.19 0.15 0.20 0.19 0.03 0.06 Silver µg/L 0.005 0.005 0.005 --- 0.005 0.005 0.005 --- 0.005 235 39 86 0.005 0.005 0.005 --- Strontium µg/L 81 882 389 317 26 238 96 71 0.025 392 114 106 0.06 808 99 227 Thallium µg/L 0.05 0.05 0.05 --- 0.05 0.05 0.05 --- 0.05 9.46 1.32 3.06 0.05 0.05 0.05 --- Titanium µg/L 2.5 34 9.90 13.3 2.5 41 12 13 2.5 24.7 5.83 7.42 2.5 9.35 2.5 2.79 Uranium µg/L 0.05 3.2 0.82 1.10 0.05 1.00 0.335 0.333 0.05 2.79 0.65 0.85 0.05 0.89 0.11 0.25 Vanadium µg/L 0.05 9.7 3.2 3.5 0.25 11.70 3.31 3.14 0.24 15.00 4.62 5.10 0.05 2.79 0.28 0.70 Zinc µg/L 7.6 20.6 12.3 4.4 2.00 36.50 15.35 12.23 0.5 133 19.64 38.9 0.003 41.0 7.26 12.7 Acenaphthene ng/L ND ND ND ND ND 4.09 2.83 0.91 ND ND ND ND --- --- --- --- Anthracene ng/L ND ND ND ND ND 1.04 0.62 0.59 0.14 2.3 0.6 0. 9 --- --- --- --- Benz[a]anthracene ng/L 0.09 0.13 0.11 0.03 ND 0.41 0.24 0.11 0.04 0.5 0. 2 0. 2 --- --- --- --- Benzo[a]pyrene ng/L 0.26 4.59 2.42 3.06 ND 0.16 1.10 0.44 0.17 0.53 0.40 0. 20 --- --- --- --- Fluoranthene ng/L 0.42 1.06 0.62 0.22 0.16 1.47 0.58 0.35 0.23 0.53 0. 37 0. 09 --- --- --- --- Fluorene ng/L 0.27 0.53 0.42 0.01 ND 0.38 0.29 0.06 0.23 0.48 0.30 0. 08 --- --- --- --- Naphthalene ng/L 3.03 190 34.7 68.9 2.71 9.56 4.33 1.84 0.26 6.32 3.45 1.75 --- --- --- --- Phenanthrene ng/L 0.95 2.51 1.61 0.49 0.69 1.89 1.19 0.35 0.62 1.26 0.96 0.21 --- --- --- --- Pyrene ng/L 0.38 0.89 0.18 0.171 0.14 1.57 0. 644 0.41 0.21 2.37 0.58 0.68 --- --- --- ---

ND = not detected. SD = standard deviation --- = no data Parameters where the maximum or minimum values were outside CCME or ESRD guidelines are shown in bold. Parameters where the minimum, maximum and/or mean were below the detection limit were set to half the detection limit and shown in italics. Polycyclic aromatic hydrocarbons (PAHs) below the detection limit are shown as ND. Note that mercury and PAHs are measured in nanogram quantities. Number of samples making up the analysis are shown as (N= ) at the top of each column.



SIR 2 Table AER 17-2 Summary of Water Quality Data from the Athabasca River (2012 and Historical Data Combined)


Min Max Mean SD Min Max Mean SD Min Max Mean SD Min Max Mean SD Temperature (N=2) Deg. 0.08 0.09 0.09 --- 10.40 10.61 11.01 --- 19.19 19.57 19.38 --- 13.46 --- --- --- pH Unit 8.2 8.2 8.2 0.05 8.2 8.2 8.2 0.01 8.1 8.1 8.1 0.01 7.9 8.4 8.2 0.1 Conductivity µS/cm 434 516 470 34 224 453 338 161 254 260 257 4.24 202 366 287 36 Dissolved Oxygen mg/L 9.8 13.8 12.1 2.0 12.0 12.5 12.2 0.36 8.28 9.69 8.99 0.99 8.4 15.2 10.8 2.1 TDS mg/L 270 313 289 17 160 223 177 31 86 187 145 43 40 282 174 56 Hardness mg/L 171 206 185 15 75 150 103 33 90 136 118 21 112 156 128 11.4 Alkalinity mg/L 167 193 175 10 80 135 98 25 86 108 101 10 98 145 113 12.2 Bicarbonate mg/L 204 235 214 12 98 165 120 31 105 132 121 13 118 177 138 15.0 Sodium mg/L 21 32 25 4 7.5 18.2 10.4 5.2 5.80 7.6 6.8 0.81 8.0 16.0 10.2 2.2 Chloride mg/L 5.6 13.0 8.4 2.8 1.54 6.42 2.90 2.36 1.13 2.23 1.45 0.53 1.79 7.20 3.14 1.57 Sulphate mg/L 48 65 56 7 13.7 33.4 20.08 8.99 12.3 28.1 20.2 6.5 16.9 48.6 30.0 6.77 Ammonia mg/L 0.025 0.16 0.06 0.05 0.025 0.11 0.05 0.04 0.025 0.03 0.025 0.01 0.03 0.27 0.09 0.08 TKN mg/L 0.41 0.72 0.54 0.10 0.78 2.25 1.22 0.69 0.44 2.13 0.92 0.81 0.01 0.70 0.43 0.19 TP mg/L 0.02 0.03 0.03 0.004 0.03 0.23 0.16 0.09 0.01 0.89 0.27 0.42 0.005 0.078 0.029 0.018 DOC mg/L 6.8 10.0 8.8 1.2 12.8 17.8 14.3 2.4 5.30 21.8 10.5 7.63 3.00 11.0 6.5 2.3 TOC mg/L 9.6 9.8 9.7 0.1 12.1 14.7 13.4 1.84 8.00 9.70 8.85 1.20 6.5 7.6 7.1 0.8 Phenols mg/L 0.001 0.005 0.003 0.001 0.003 0.005 0.004 0.001 0.001 0.008 0.004 0.003 0.001 0.016 0.004 0.004 Aluminum µg/L 0.066 48.00 15.06 23.26 0.77 3510 1529 1800 1.85 4690 1881 2295 0.14 199 13.9 51.1 Arsenic µg/L 0.0005 0.072 0.2304 0.3565 0.0008 3.040 1.296 1.539 0.001 2.560 1.171 1.361 0.001 0.58 0.039 0.15 Cadmium µg/L 0.05 0.100 0.0334 0.0516 0.05 0.090 0.039 0.046 0.05 0.108 0.042 0.052 0.05 0.023 0.002 0.006 Chromium µg/L 0.4 1.100 0.2502 0.4459 0.0007 5.270 2.235 2.266 0.002 6.65 2.62 3.23 0.4 0.800 0.054 0.206 Copper µg/L 0.001 0.500 0.1672 0.2577 0.001 7.30 3.302 3.851 0.002 6.74 3.25 3.75 0.001 1.51 0.10 0.39 Iron µg/L 0.134 200.0 62.296 96.586 0.533 7570 2912 3650 1.01 7320 3099 3686 0.24 384 26.3 99 Lead µg/L 0.05 0.050 0.0167 0.0257 0.0004 3.60 1.609 1.881 0.05 3.35 1.396 1.669 0.05 0.463 0.031 0.119 Manganese µg/L 0.005 5.000 1.5062 2.3404 0.0901 224 95.06 113 0.040 172 74.60 87.93 0.012 23.0 1.56 5.93 Mercury ng/L 0.060 0.721 0.320 0.301 0.018 1.15 0.312 0.559 0.240 50.00 25.40 28.41 0.017 0.001 0.0002 0.0002 Nickel µg/L 0.25 1.480 0.4671 0.7243 0.001 8.87 3.967 4.654 0.001 9.76 3.91 4.77 0.25 1.63 0.11 0.42



SIR 2 Table AER 17-2 Summary of Water Quality Data from the Athabasca River (2012 and Historical Data Combined) (continued)


Min Max Mean SD Min Max Mean SD Min Max Mean SD Min Max Mean SD Selenium µg/L 0.20 0.200 0.0668 0.0258 0.20 0.20 0.100 0.115 0.20 0.320 0.145 0.169 0.20 0.200 0.013 0.051 Silver µg/L 0.005 0.050 0.0167 0.0258 0.005 0.05 0.025 0.029 0.005 0.050 0.002 0.002 0.005 0.005 0.005 --- Strontium µg/L 0.278 378 93.946 157.34 0.136 187 92.86 107 0.149 271 131 151 0.196 335 22.6 86.4 Thallium µg/L 0.05 0.050 0.0167 0.0258 0.05 0.05 0.025 0.029 0.05 0.131 0.048 0.062 0.05 0.003 0.0002 0.0007 Titanium µg/L 0.0019 54.70 9.1186 22.330 0.008 54.7 25.87 29.93 0.027 52.10 23.77 27.66 0.003 3.30 0.234 0.848 Uranium µg/L 0.0006 0.74 0.2271 0.3528 0.0006 0.74 0.343 0.398 0.001 0.658 0.321 0.370 0.0004 0.573 0.039 0.147 Vanadium µg/L 0.0003 9.540 1.6319 3.8754 0.0015 9.54 4.186 4.919 0.003 11.60 4.701 5.707 0.001 0.78 0.053 0.200 Zinc µg/L 0.0030 16.20 3.5354 6.5183 0.0039 25.8 10.68 12.84 0.005 33.40 13.04 16.18 0.002 11.9 0.8 3.07 Acenaphthene (N=2)

ng/L ND ND ND --- 2.42 4.38 3.4 1.38 0.655 4.08 2.37 2.42 0.669 --- --- ---

Anthracene (N=2) ng/L 1.010 1.08 1.05 0.100 1.93 --- --- --- 1.24 2.13 1.58 0.48 0.129 0.533 0.331 0.286 Benz[a]anthracene (N=2)

ng/L ND ND ND --- 0.460 0.464 0.462 0.003 0.438 0.452 0.445 0.010 0.119 --- --- ---

Benzo[a]pyrene ng/L ND ND ND --- 1.29 --- --- --- 0.647 5.70 2.353 2.899 1.06 --- --- --- Fluoranthene (N=2)

ng/L 0.118 0.283 0.200 0.117 1.620 1.92 1.770 0.212 1.770 111 56.39 77.23 2.04 --- --- ---

Fluorene (N=2) ng/L 0.303 0.334 0.318 0.022 0.800 0.898 0.849 0.069 1.020 2.97 1.79 1.038 0.57 --- --- --- Naphthalene (N=2) ng/L 3.83 12.00 7.92 5.77 3.39 3.41 3.40 0.014 4.62 4.65 4.64 0.021 --- --- --- --- Phenanthrene (N=2)

ng/L 1.00 1.20 1.10 0.14 5.16 5.23 5.20 0.049 6.75 20.60 12.03 7.51 1.1 4.39 2.74 2.33

Pyrene (N=2) ng/L 2.44 3.46 2.95 0.072 2.13 2.62 2.375 0.346 2.15 12.30 5.75 5.68 0.54 2.66 1.6 1.5

ND = not detected. SD = standard deviation --- = no data Parameters where the maximum or minimum values were outside CCME or ESRD guidelines are shown in bold. Parameters where the minimum, maximum and/or mean were below the detection limit were set to half the detection limit and shown in italics. PAHs below the detection limit are shown as ND. Note that mercury and PAHs are measured in nanogram quantities. Number of samples making up the analysis are shown as (N= ) at the top of each column except where noted for specific parameters.



SIR 2 Table AER 17-3 Summary of Water Quality Data from Lakes (Fall 2012)

units Number of Samples Autumn

Min Max Mean SD pH Unit 16 6.9 8.2 7.6 0.37 Conductivity µS/cm 16 31.1 243 98.8 60.2 Dissolved Oxygen mg/L 12 7.66 12.19 9.49 1.41 TDS mg/L 7 40 144 83 41 Hardness mg/L 17 20 122 53 28 Alkalinity mg/L 17 10 129 51 36 Bicarbonate mg/L 13 22 157 76 41 Sodium mg/L 12 0.5 8.9 2.2 2.4 Chloride mg/L 17 0.05 3.0 1.26 0.78 Sulphate mg/L 13 0.25 4.1 1.28 1.07 Ammonia mg/L 3 0.03 0.08 0.05 0.03 TKN mg/L 17 0.60 1.80 1.08 0.37 TP mg/L 8 0.01 0.07 0.03 0.02 DOC mg/L 17 11.2 46.0 23.8 9.0 TOC mg/L 17 11.3 47.0 26.4 10.0 Phenols mg/L 9 0.004 0.015 0.009 0.004 Aluminum µg/L 16 0.003 131 30.1 33.8 Arsenic µg/L 9 0.001 0.850 0.389 0.320 Cadmium µg/L 6 0.005 0.010 0.005 --- Chromium µg/L 7 0.40 0.323 0.175 0.164 Copper µg/L 7 0.05 0.62 0.20 0.20 Iron µg/L 16 0.159 693 152 215 Lead µg/L 10 0.05 0.80 0.18 0.28 Manganese µg/L 16 0.05 44.0 16.7 13.9 Mercury ng/L 3 0.017 0.05 0.04 0.03 Nickel µg/L 7 0.25 0.74 0.21 0.27 Selenium µg/L 6 0.20 0.20 0.20 --- Silver µg/L 7 0.005 0.005 0.005 --- Strontium µg/L 7 0.04 28.2 12.0 11.8 Thallium µg/L 7 0.05 0.05 0.05 --- Titanium µg/L 7 0.5 0.5 0.5 --- Uranium µg/L 7 0.005 0.005 0.005 --- Vanadium µg/L 7 0.05 0.36 0.14 0.15 Zinc µg/L 8 0.5 11.7 4.40 5.04 Acenaphthene ng/L 4 ND ND ND --- Anthracene (N=2) ng/L 4 ND 0.24 --- --- Benz[a]anthracene (N=2) ng/L 4 0.06 0.45 0.20 0.18 Benzo[a]pyrene ng/L 4 ND ND ND --- Fluoranthene (N=2) ng/L 4 0.21 0.32 0.31 0.06 Fluorene (N=2) ng/L 4 0.13 0.26 0.22 0.05



SIR 2 Table AER 17-3 Summary of Water Quality Data from Lakes (Fall 2012) (continued)

units Number of

Samples Autumn

Min Max Mean SD Naphthalene (N=2) ng/L 4 4.21 6.58 5.04 1.09 Phenanthrene (N=2) ng/L 4 0.80 1.93 1.25 0.42 Pyrene (N=2) ng/L 4 0.19 0.61 0.32 0.17

ND = Not detected. SD = Standard deviation --- = no data Parameters where the maximum or minimum values were outside CCME or ESRD guidelines are shown in bold. Parameters where the minimum, maximum and/or mean were below the detection limit were set to half the detection limit and shown in italics. PAHs below the detection limit are shown as ND. Note that mercury and PAHs are measured in nanogram quantities. Number of samples making up the analysis are shown as (N= ) at the top of each column except where noted for specific parameters.

SIR 2 Table AER 17-4 Summary of Sediment Quality Data (2012)

units Spring (N=17)

Min Max Mean SD Arsenic mg/kg 1.96 18.7 6.34 4.01 Cadmium mg/kg 0.25 0.25 0.25 --- Chromium mg/kg 5.39 20.4 10.06 3.28 Copper mg/kg 3.80 19.3 8.56 3.99 Lead mg/kg 2.50 12.6 6.53 3.09 Mercury mg/kg 0.025 0.074 0.028 0.012 Nickel mg/kg 6.20 17.3 10.5 3.01 Selenium mg/kg 0.25 0.69 0.355 0.16 Silver mg/kg 0.5 0.25 0.25 --- Thallium mg/kg 0.25 0.25 0.25 --- Uranium mg/kg 1.00 3.3 1.1 0.57 Vanadium mg/kg 10.0 31.8 16.1 4.97 Zinc mg/kg 27.0 75.0 44.8 12.6 Acenaphthene mg/kg ND ND ND --- Anthracene mg/kg ND ND ND --- Benz[a]anthracene mg/kg ND ND ND --- Benzo[a]pyrene mg/kg ND ND ND --- Fluoranthene mg/kg ND ND ND --- Fluorene mg/kg ND ND ND --- Naphthalene mg/kg ND ND ND --- Phenanthrene mg/kg ND ND ND --- Pyrene mg/kg ND ND ND ---



SIR 2 Table AER 17-4 Summary of Sediment Quality Data (2012) (continued)

units Spring (N=17)

Min Max Mean SD Loss on Ignition % 1.0 21.4 3.01 5.12 F3 Hydrocarbons mg/kg 24 209 65 68 F4 Hydrocarbons mg/kg 32 123 71 47

ND = Not detected. SD = Standard deviation --- = no data Parameters where the maximum or minimum values were outside CCME or ESRD guidelines are shown in bold. Parameters where the minimum, maximum and/or mean were below the detection limit were set to half the detection limit and shown in italics. PAHs below the detection limit are shown as ND. Number of samples making up the analysis are shown as (N= ) at the top of each column except where noted for specific parameters.



18 Application, Volume 4, Section 7.5.3.1 Field and Conventional Parameters, Page 7-24. Field and conventional parameters were collected seasonally (one sample per season) at most sites. Describe the impacts of diurnal variation on conventional parameters and how this was accounted for in the sampling strategy used.

Response:

Due to respiration and photosynthesis in natural surface waters, diurnal cycling of dissolved oxygen (DO) and pH is common (Nimick et al. 2011). In general, DO levels are highest mid-afternoon and lowest before sunrise. Diurnal fluctuations of pH generally track with DO. These diurnal fluctuations in pH and DO occur primarily because uptake of CO2 from the water column due to photosynthesis exceeds release of CO2 due to respiration during daylight hours, and release of oxygen from photosynthesis also occurs during daylight. At night, only respiration occurs, releasing CO2 into the water column. CO2 is in equilibrium with carbonic acid (H2CO3) in water; therefore, addition of CO2 to water results in increased H2CO3, lowering the pH. The magnitude of diurnal fluctuations of DO and pH are dependent on the biomass and activity of photosynthetic and heterotrophic organisms in the water, and on temperature fluctuations and reaeration from the atmosphere.

In the sampling strategy used for the Project, grab samples were taken during daylight hours only, but could be taken at any time during the course of the day, from early morning to late afternoon. Time of sample collection was recorded for each sample taken. These samples represented water quality at a snapshot in time, but also provided a point around which diurnal fluctuations could be inferred.

Seasonal variations are superimposed on diurnal variation. The maximum concentration of oxygen that can be dissolved in water is inversely proportional to water temperature. Although colder water can hold more DO, ice cover during winter blocks the exchange of gases between water and the atmosphere, reducing DO in the water. During the summer months, as the water temperature increases the solubility of oxygen decreases. Concentrations of DO will affect the solubility and availability of nutrients that are released from bottom sediments and therefore will affect the overall productivity of the ecosystem.

In the sampling strategy used for the Project, four seasons of samples were taken. The variability between seasons gives some indication of seasonal variability overlaid on diurnal variation.

Bioindicator organisms, including certain fish and benthic invertebrates, can act as proxies for water quality (Hodkinson and Jackson 2005). Bioindicator organisms can be chosen, which have relatively narrow water quality parameters which they can tolerate, and the presence of these organisms in a particular area indicates that water quality parameters were within those limits during the life of the organism. Bioindicator sampling was completed at the same locations and at the same time as the grab sampling. Where measured water quality parameters were in a range that was suitable for sensitive bioindicator species, and those

http://www.ramp-alberta.org/river/water+sediment+quality/chemical/conventional.aspx



bioindicator species were present, it is inferred that the water quality at those sites was generally within the suitable range for those species, despite diurnal and seasonal variability.

References:

Hodkinson I.D. and J.K. Jackson. 2005. “Terrestrial and aquatic invertebrates as bioindicators for environmental monitoring, with particular reference to mountain ecosystems.” Environmental Management 35(5): 649-666.

Nimick D.A., Gammons C. H. and S.R. Parker. 2011. “Diel biogeochemical processes and their effects on the aqueous chemistry of streams: A review.” Chemical Geology 283(1-2): 3-17.



19 Application, Volume 4, Section 7.5.3.2 Carbon, Page 7-33. Osum states that high TOC concentrations in Unnamed Tributary 5 may result in reduced light penetration and subsequent species richness and benthic biomass. Provide information on whether true measures of light penetration (e.g. measuring photosynthetically active radiation or PAR) were conducted to confirm the above statement.

Response:

Direct measures of light penetration were not performed at any site; however, turbidity values were recorded at each site, and concentrations of total organic carbon (TOC) and dissolved organic carbon (DOC) were also recorded. Unnamed Tributary 5 has measured TOC and DOC concentrations up to 51 mg/L, and turbidity values up to 164.5 nephelometric turbidity units (NTU).

Lakes which have DOC levels above 5 mg/L are dominated by heterotrophic organisms (Jannson et al. 2000). The effect of TOC and DOC on primary (autotrophic) production in streams has not been well studied. However, the level of TOC and DOC in Unnamed Tributary 5 is ten times the level which causes a switch from autotrophic organism dominance to heterotrophic organism dominance in lakes. Therefore, it may be inferred that the TOC and DOC levels in Unnamed Tributary 5 are causing a reduction in autotrophic populations, reducing species richness, and biomass.

Turbidity may also impact community structure, diversity, density, biomass, and growth of aquatic organisms (Henley et al. 2000). Decreases in feeding efficiency of Daphnia pulex, a component of zooplankton, have been shown to occur at 6 NTU. Increases in turbidity by 25 NTU over baseline have shown reductions in carbohydrate production from photosynthesis of up to 50%.

References:

Henley W.F., Patterson M.A., Neves R.J. and A.D. Lemly. 2000. “Effects of sedimentation and turbidity on lotic food webs: A concise review for natural resource managers.” Reviews in Fisheries Science 8(2): 125-139.

Jannson M., Bergstrom A-K, Blomqvist P. and S. Drakare. 2000. “Allochthonous organic carbon and phytoplankton/bacterioplankton production relationships in lakes.” Ecology 81:3250-3255.



20 Application, Volume 4, Section 7.5.3.12 Quality Control, Page 7-39. Osum notes frequent detection of low-level PAH concentrations in trip and field blanks similar to lab blank concentrations.

a. Provide a comparison of field and trip blank PAH concentrations to PAH concentrations detected in samples collected from the various waterbodies.

Response:

PAHs were detected in field and trip blanks at concentrations less than five times the detection limits. Therefore, quality control (QC) sample results met QC evaluation criteria. The specific PAH with detections at the highest levels in the field and trip blanks was naphthalene.

Analysis of the field samples versus the field and trip blanks indicates that the mean concentration of PAHs detected in field samples was an order of magnitude higher than the mean concentration in both field and trip blanks. Detection of analytes at these levels in the QC samples (i.e., an order of magnitude less) do not approach real data values and therefore do not affect the interpretation of results.

Field Samples Field Blanks Trip Blanks Number of water samples analyzed 59 3 4 Number of PAHs analyzed 23 23 23 Mean number of PAHs detected 16.9 12.7 12.2 Mean concentration of PAHs detected (µg/L) 0.0024 0.0007 0.0009 Maximum concentration of PAHs detected (µg/L)

0.189* 0.0032** 0.0086***

Mean concentration of Naphthalene detected (µg/L)

0.01 0.0027 0.0043

* The specific PAH detected was naphthalene; this PAH was detected in winter in Unnamed Tributary 3. ** The specific PAH detected in the field blank was naphthalene; this was detected in summer. *** The specific PAH detected in the trip blank was naphthalene; this was detected in fall.

20 b. Comment on any actions taken to account for field and trip blank PAH detections in waterbody PAH samples.

Response:

All detections were reported. However, sample-specific detection limits were given by the reporting laboratory, and those limits were between 5 ng and 10 ng/L. All samples, which had detections of PAHs, both in field samples and in blanks, were scrutinized individually to determine if the reported values were above the sample-specific detection limits.



21 Application, Volume 4, Section 7.6.2.2 Mitigation, Page 7-56. Osum states “providing stormwater storage at the CPF and the production well pads to contain the 1 in 25 year, 24-hour storm event.” Provide a discussion on mitigation strategies which will be implemented should the 1 in 25 year 24-hour storm event be exceeded.

Response:

Osum has designed the industrial runoff pond to contain a 1 in 25 year 24-hour storm, which is typically the requirement specified in operating approvals for other similar industrial facilities. While the possibility of a storm exceeding the 1 in 25 year 24-hour magnitude exists, the planned industrial runoff pond has been designed based on this specification. As stated in the response to Round 2 AER SIR 4, Osum’s proposed industrial runoff pond was designed to contain the 1 in 25 year 24-hour storm event, but includes approximately 20% excess capacity, which is sufficient to contain a 1 in 50 year 24-hour storm event. An emergency outflow valve has been included in the pond’s design as means of preventing pond failure in the case of an extreme precipitation event. Osum does not expect that the emergency overflow outlet will be needed, but its inclusion is consistent with good engineering practice at operating industrial facilities.

If a release from the emergency overflow outlet did occur, it is expected that the quality of the water being released will be comparable to water quality from precipitation in the area since runoff water will not be collected from hydrocarbon storage areas at the CPF. Osum would collect samples of the runoff water discharged through the emergency overflow outlet to evaluate compliance with the discharge criteria specified in the operating approval. In the event of an extreme storm event that would require a discharge from the emergency overflow outlet, the most likely environmental effects would be erosion and sedimentation. Osum will use riprap on the apron of the emergency overflow outlet to reduce flow velocity and the associated erosion potential.



22 Application, Volume 4, Section 7.6.3.1 Potential Project Effects, Page 7-57. Osum identifies increased temperatures as a result of reduced water levels as a potential impact as result of groundwater withdrawals. Provide discussion on impacts of lower water levels and increased temperature on evaporative losses including mitigative measures.

Response:

The discussion presented in Volume 4, Section 7.6.3.1 of the EIA report identified potential Project effects on surface water quality. Osum has further evaluated the proposed non-saline water withdrawal from the Unnamed Valley E Aquifer, as described in the responses to Round 2 ESRD SIR 16a and 18. Osum concluded that non-saline groundwater withdrawal from the 10-22-086-21 W4M water source well is not predicted to have detectable impact on surface water resources.

As lower water levels are not anticipated due to groundwater pumping, increased temperature and greater evaporative losses are also not anticipated. As a result, no measures are proposed to mitigate changes in evaporative losses.



23 Application, Volume 4, Figures 7.5-3 to 7.5-38 Water Chemistry Indicators, Pages 7-44 to 7-52. Osum states “In the box plots, boxes represent the range within which the central 50% of values fall, whiskers represent the range within which 75% of the values fall, asterisks represent data that falls within three times the central range, and circles represent data that falls outside that range.” If the whiskers represent 75% of the data range, this would indicate the lower whisker represents the 12.5th percentile and the upper whisker the 87.5th percentile, which is non-standard in box and whisker plots.

a. Clarify what percentiles the lower whisker, upper whisker and box represent in the data.

Response:

a. There are several commonly used methods of constructing a box plot (Helsel and Hirsch 2002). In Volume 4, Section 7, Figures 7.5-3 to 7.5-38 of the EIA report, the top whisker may also be called the "upper hinge" and the lower whisker may also be called the "lower hinge.” The lower hinge is also called "the 25th percentile,’ the median is "the 50th percentile", and the upper hinge is "the 75th percentile.” This means that 25%, 50%, and 75% of the data, respectively, is at or below those points. The distance between the hinges may be referred to as the "H-spread" or the "interquartile range," abbreviated as IQR.

23 b. Provide information on whether the horizontal line within the box represents the average or median value.

Response:

b. The horizontal line represents the median value.

Reference:

Helsel D.R. and R. M. Hirsch. 2002. Statistical Methods in Water Resources Techniques of Water Resources Investigations. Techniques of Water-Resources Investigations of the United States Geological Survey. Book 4, Chapter A3. U.S. Geological Survey. 522 pages.



24 Application, Volume 4, Figure 7.5-39, Water Chemistry Indicators in Arsenic in Sediment, Page 7-53. An ESRD guideline is indicated in the legend but not included in the plot. Provide the figure with the appropriate guideline indicated on the plots.

Response:

A revised version of Volume 4, Section 7, Figure 7.5-39 is presented below as SIR 2 Figure AER 24-1. The interim sediment quality guideline (ESRD 2014) is represented as a dashed line on SIR 2 Figure AER 24-1.

Reference:

Alberta Environment and Sustainable Resource Development (ESRD). 2014. Environmental Quality Guidelines for Alberta Surface Waters. Water Policy Branch, Policy Division. Edmonton, Alberta. July 14, 2014. ISBN: 978 1 4601 1524 4. http://esrd.alberta.ca/water/education guidelines/documents/EnvironmentalQualitySurfaceWaters Jul14 2014A.pdf

SIR 2 Figure AER 24-1 Water Chemistry Indicators in Arsenic in Sediment



25 Application, Volume 4, Section 8, Aquatic Ecology. Osum collected data on fisheries, fish habitat and benthic invertebrate communities. Discuss why primary producers (phytoplankton and periphyton) were not included in the assessment of aquatic resources.

Response:

Benthic macroinvertebrates were used as a surrogate for assessing primary productivity. Benthic macroinvertebrates were chosen as a bioindicator group because they have numerous advantages. Some of these advantages include:

• sites can be chosen that reflect site-specific impacts above and below a point source; • sites can be chosen that reflect cumulative impacts both over an entire season and

where impacts are dispersed across a watershed; • benthic invertebrates respond to a wide range of stressors; • benthic invertebrates are ubiquitous in the aquatic environment; • benthic invertebrates are a key part of the food web; and • protocols for collection and analysis are well developed.

(Doughty 1994)

Phytoplankton is more commonly measured in lake environments or in slow-flowing rivers, since phytoplankton is washed away by higher energy streams. Within the aquatics LSA, there was only one lake and many of the watercourse sites were higher energy, making them inappropriate for phytoplankton measurements. Periphyton, which is common in higher-energy streams, gives comparable data to benthic invertebrate data. Therefore, it would have been appropriate to use either periphyton measurements or benthic invertebrate measurements. Benthic invertebrates were chosen as bioindicators since they have historically been used in the region, making data from the Osum sites comparable with regional and historical data.

Reference:

Doughty C. R. 1994. “Freshwater biomonitoring and benthic macroinvertebrates.” Aquatic Conservation: Marine and Freshwater Ecosystems 4(1): 92



26 Application, Volume 4, Appendix 8C, Section 8C.2.2 Field Sampling, Page 8C-3. Osum describes use of the travelling kicknet method for collection of benthic invertebrate samples. Describe how this method accounts for typically high natural variability in benthic invertebrate communities relative to collection of multiple individual samples.

Response:

The travelling kicknet method for collection of benthic invertebrate samples is described in the Canadian Aquatic Biomonitoring Network, Field Manual, Wadeable Streams (Environment Canada 2012) as cited in Volume 4, Appendix 8C, Section 8C2.2 of the EIA report. An effort of 3 minutes is used to standardise sample collections between sites. The zigzag travelling kicknet method, as described in Environment Canada (2012), collects benthic invertebrates from different habitat types within a given watercourse reach (i.e., areas around large boulders, riffle, runs, banks, and habitats of different water velocities, water depths, and shading). By using the travelling kicknet method, representative habitat within a watercourse is sampled, thereby reducing variability relative to the collection of multiple individual samples, where certain habitat types may be left out.

Reference:

Environment Canada. 2012. Canadian Aquatic Biomonitoring Network, Field Manual, Wadeable Streams. Freshwater Quality Monitoring and Surveillance Atlantic, Water Quality Monitoring and Surveillance Division, Water Science and Technology Directorate, Science and Technology Branch. Dartmouth, Nova Scotia. April 2012. ISBN 978 1 100 20816 9. http://ec.gc.ca/Publications/C183563B CF3E 42E3 9A9E F7CC856219E1/CABINFieldManual_EN_2012.pdf



1.1.2.4. Groundwater

27 SIR Round 1 Response, SIR 45a, Page 2-281. Osum states “Osum’s groundwater monitoring program will include installation of monitoring wells to detect potential changes in groundwater quality. The selected locations of these wells will be focused on sand and gravel lenses identified near the pads.” Osum indicates it will begin groundwater monitoring at one of the project’s first production pads. Considering that Osum’s proposed commercial scale project will consist of 95 well pads distributed across varied geological settings and in proximity to surface water bodies.

a. Clarify whether Osum intends to extend groundwater quality monitoring coverage to other pads.

Response:

a. Osum would like to clarify that development of the Project Area will only require 49 well pads, as described in Round 2 AER SIR 8. There are an additional 44 well pads that Osum has identified as part of a Future Project Area Expansion, which would only be developed subsequent to future amendments filed with the AER. For the well pads within the Project Area, Osum does plan to extend groundwater quality monitoring to other pads as the Project develops.

27 b. If so, what is the timeline for this work to occur following project start up?

Response:

b. As described in the response to Round 2 AER SIR 8, six additional well pads will be developed beginning in 2019, to maintain the bitumen production capacity of the Project. By that time, Osum will have completed approximately 3 years of groundwater monitoring for the Project. During the 2018 annual groundwater monitoring report, Osum will identify additional well pads (if any) proposed for baseline sampling to support future inclusion in the groundwater monitoring program. Osum would repeat this process in subsequent years, as additional well pads are added to the Project.



27 c. Describe the criteria that Osum will use in the selection of pads to be monitored to ensure that the monitoring program is robust and protective of groundwater and surface water receptors across the entire project area.

Response:

c. Identification of additional well pads to be included in the groundwater monitoring program will use a risk-based approach that would consider a combination of factors, including:

• potential receptors (e.g., domestic use aquifers and surface water bodies) in the vicinity of new well pads;

• aquifers believed to be present underlying the new well pads; and • the results of ongoing monitoring at the initial well pads.

The development and implementation of the groundwater monitoring program is considered both an iterative and adaptive process, as the program will be consistently evaluated, assessed and modified, if required, as more information becomes available and as the Project proceeds. The groundwater monitoring program is expected to include annual reporting, with opportunities for adaptation (in consultation with regulators) throughout the life of the Project.



1.1.2.5. Conservation and Reclamation

28 SIR Round 1 Response, SIR 108b, Page 2-412. Regarding the salvage and conservation of soils along the proposed right of way, Osum indicates that the topsoil would be "stored a windrows along roads...”

a. Confirm whether roads (along which the windrows will be located) are expected to be snow-ploughed in winter.

Response:

a. Osum will snow-plough roads in winter as required for maintaining access to facilities.

28 b. Discuss how Osum plans to prevent the possibility of losing stored topsoil in snow-ploughing events, should snow ploughing occur.

Response:

b. As indicated in Volume 2, Section 6.5.1 of the EIA report, the salvaged soil windrows will be placed along the outside margins of the access ROWs and beyond road side ditches, to prevent disturbance and loss of stored topsoil during snow-ploughing events.



29 SIR Round 1 Response, SIR 159, Page 2-524. In its response, Osum states, “[as] with all projects of this size and scope, change is constant”, and “Osum expects that the footprint will change”. This statement appears to suggest that borrow pit footprints may change from those proposed in the application. Importantly, Osum states on Page 6-18 (Volume 2, Section 6.4.1.2) that “dewatering of borrow areas developed in organic soil may be required”.

a. Discuss the likelihood that Osum may need more borrow areas such that borrow excavations may potentially accumulate much more water than initially anticipated.

Response:

a. Project footprint changes may occur that would either reduce or increase the requirements for borrow material. For example, relocation or shifting of a well pad onto mineral soil and away from Organic soil will reduce requirements for borrow material, whereas doing the opposite will increase the borrow requirements for the Project. If additional borrow area is required as a result of potential footprint changes, Osum will file appropriate amendments as required and then complete pre-disturbance assessment/conservation and reclamation (PDA/C&R) plans and geotechnical investigations (Volume 2, Section 6.4.1.1 of the EIA report; response to Round 1 ESRD SIR 114d) to better understand site-specific soil and hydrologic conditions in planning the development of a borrow area and the potential for management of borrow water.

29 b. Explain how Osum will conduct dewatering if much more water were to accumulate in borrow excavations covering much larger area.

Response:

b. Mineral soil in upland areas is preferred for the development of borrow areas (Volume 2, Section 6.4.1 of the EIA report) and Osum may avoid developing some portions of peatland Organic soils, to help manage the extent of borrow dewatering that may be required. As indicated in the response to part a) above, Osum will better understand site-specific soil and hydrologic conditions of a borrow area after a PDA/C&R Plan and a geotechnical investigation are completed. The proportion of the borrow areas in mineral soil map units for the current Project footprint is 97.0% of the extent of the total borrow area (refer to the response to Round 2 ESRD SIR 32a).

As part of surface and near surface water management, Osum will construct berms and ditches where appropriate to manage and limit potential inflow from the surrounding environment into borrow areas (Volume 2, Section 6.8.2 of the EIA report). Where practicable in a borrow area in which water accumulates, dewatering may involve pumping from an active excavation area to a portion of the borrow area that is exhausted of fill. Also, where water is retained in a borrow excavation, the water could be used to offset other non-saline water demands for the Project (e.g., dust suppression), reducing the water demand



from natural sources. Osum would obtain the required diversion license(s) under the Water Act before reuse of collected water. Borrow water that interferes with the extraction of fill for the Project that is not used for other purposes will be discharged offsite, as is further discussed in the response to part c) below.

29 c. Discuss how Osum proposes to dewater while ensuring that water quality and offsite impacts (e.g. inadvertent erosion and stream sedimentation) are addressed

Response:

c. As indicated in Volume 2, Sections 5.1.8.3 and 6.8.2 of the EIA report, the quality of borrow water will be tested to confirm its compliance with the parameters of the anticipated EPEA approval before being discharged offsite. Where required, Osum will discharge water offsite in a controlled manner by employing the following mitigations:

• dispersing of water using a diffuser system into relatively flat, vegetated terrain with low to moderate erosion risk to minimize soil erosion;

• discharging water at a rate that will avoid flooding in any one area; • directing discharge water away from watercourses or water bodies, and away from

slope breaks where practicable; and • discharging into areas of established plant communities where practicable, where new

species will be less likely to invade due to competition from the established vegetation.



1.1.2.6. Soils

30 SIR Round 1 Response, SIR 122, Page2-450. Osum uses planned mitigation and monitoring programs to justify the statement that impacts to physical and chemical properties of soil are negligible during construction and operation (SIR 122 Volume 5, Section 9.6.3.3, Page 9-15). During operations, there is the potential for spills and undetected leaks. Describe how the planned mitigation and monitoring plans will address the potential of spills and undetected leaks.

Response:

Osum recognizes that undetected leaks and spills can occur and the requirement for soil monitoring is based on the potential risks for release of substances. Osum will design and conduct a Soil Monitoring Program according to the methods outlined in the Soil Monitoring Directive (GoA 2009), as specified in the anticipated EPEA approval. The Project soil monitoring program will be designed to target the most likely locations on the facility for substance release by:

• reviewing all available environmental and relevant engineering information for the facility, including the most recent groundwater monitoring reports and any reports summarizing historical remediation or management activities conducted;

• reviewing AER and Osum spill reports; and • completing a site visit and interviews with appropriate operations personnel

regarding historical and current site management activities.

The soil monitoring program proposal will be prepared and submitted to the AER for approval before initiation of soil monitoring. Any deficiencies identified by the director will be addressed before implementation of the program. Soil monitoring will be conducted as per the schedule identified in the Project approval. Typically programs are implemented once every 5 years. If soil contamination is identified through soil monitoring, a Soil Management Plan will be developed. The Soil Management Plan is intended to manage and remediate contaminated soils, and must mitigate or eliminate adverse effects to human health and the environment (GoA 2009). The results of soil management activities will be reported to the AER annually or as required by the Approval.

Reference:

Alberta Environment (AENV). 2009. Soil Monitoring Directive. Edmonton, Alberta. May 2009. ISBN: 978 0 7785 8121 5. http://environment.gov.ab.ca/info/library/8159.pdf



1.2 ALBERTA ENVIRONMEMNT AND SUSTAINABLE RESOURCE DEVELOPMENT

General 1.2.1

1.2.1.1. Public Engagement and Aboriginal Consultation

1 SIR 4, Page 2-179

Osum states that it is premature at this time to prepare such a table as the information it has is incomplete.

a. Provide an update on when these tables will be submitted to the Aboriginal Consultation Office Consultation Advisor.

Response:

a. A summary of Osum’s Aboriginal consultation activities is presented in the response to Round 2 AER SIR 1. Copies of the final TLU reports from BCN and FMFN have not yet been provided to Osum. Submission of these reports is pending finalization by each of the respective groups.

Osum submitted the final TLU/traditional use studies (TUS) reports received to date (from ML 1935 and MNA R5) to the Aboriginal Consultation Office (ACO) in March 2014. Osum will provide other reports to the ACO as they become available and as Osum is authorized to release them by each Aboriginal group. Osum continues to submit bimonthly consultation reports to the ACO as required. Once the four TLU/TUS reports have been received, Osum will compile the requested information into a table as described in Round 1 ESRD SIR 4 that will be submitted to the ACO under separate cover. Osum anticipates that this table will be submitted in Q1 2015.



1.2.1.2. Transportation

2 SIR 7, Page 2-188

The Traffic Impact Assessment provided in Appendix ESRD 7-1 shows that a Type IVa intersection treatment is warranted by 2017, however the recommendation was to allow the intersection to remain at a Type IIIa intersection and re-assess for a Type IVa with the actual traffic count in 2017 as the values used in this assessment is considered conservative and that it is unlikely that these volumes will actually occur during the same peak hour. Alberta Transportation does not support this recommendation as the analysis was completed with what information is known to date, however there are possibilities of future developments that may be using the same access which was accounted for in the background traffic growth projections and with the estimated traffic generated by the other known developments. Therefore Alberta Transportation would require a Type IVa intersection to be built prior to 2017

a. Revise Traffic Impact Assessment’s recommended intersection treatment type to a Type IVa.

Response:

a. Osum continues to evaluate the transportation strategy for the Project. Osum has revised the vehicle loading estimates to reflect current planning, which has resulted in a revision of the previous Traffic Impact Assessment (TIA) submitted. A copy of the revised TIA is presented in Appendix A.

2 b. Confirm the timing of the improvement to a Type IVa intersection treatment.

Response:

b. Based on the results of the revised TIA presented in Appendix A, the improvement to a Type Iva intersection treatment is no longer required.



Air 1.2.2

1.2.2.1. Emissions management

3 SIR 8, Page 2-190 Volume 3, Appendix 2B, Table 2B-1

In response to SIR8b, Osum provides energy calculations for the process units. However, the duties of the process units used in the calculations are not consistent with those presented in Table 2B-1.

a. Discuss whether this inconsistency has any implications for the EIA report findings.

Response:

a. After a full review of the fired duty ratings of all process units, Osum is unable to find any discrepancies between the duties used in the response to Round 1 ESRD SIR 8b and those presented in Volume 3, Appendix 2B, Table 2B-1 of the EIA report. The duties used in the calculations in Round 1 ESRD SIR 8b are expressed on a lower heating value basis while the duties presented in Volume 3, Appendix 2B, Table 2B-1 of the EIA report are expressed on a higher heating value basis.



4 SIR 11, Page 2-197

In response to SIR11a, Osum presents in Table ESRD 11-1, updated NO2 concentrations for the emissions that are consistent with potential approved limits. This update does not include NO2 concentrations based on the Total Conversion Method that are required to be presented as prescribed in the 2009 and 2013 Air Quality Model Guideline.

a. Update Table ESRD 11-1 to include NO2 concentrations using the Total Conversion Method.

Response:

a. The NO2 predictions for Round 1 ESRD SIR 11a using the Total Conversion Method are included in SIR 2 Table ESRD 4-1.

SIR 2 Table ESRD 4-1 Predicted Updated Nitrogen Dioxide Concentrations – Total Conversion Method

Receptor Location

Baseline Case

[µg/m3]

Application Case

[µg/m3]

Planned Development

Case

[µg/m3]

Project Only

[µg/m3]

Application Case Increase Over Baseline

[%]

Planned Development Case Increase

Over Baseline [%]

Maximum 1-Hour Prediction

Overall Maximum (RSA MPOI) 1698 (1698)

1698 (1698)

1698 (1698) 731 (730) 0.0 (0.0) 0.0 (0.0)

Local Area Maximum (LSA MPOI)

454 (454) 732 (731) 733 (732) 731 (730) 61 (61) 62 (61)

CPF Boundary 100 (100) 648 (638) 648 (638) 647 (637) 544 (535) 545 (535)

Maximum from Health Receptors 1698 (1698)

1698 (1698)

1698 (1698) 204 (200) 0.0 (0.0) 0.0 (0.0)

ESRD AAAQO n/a n/a n/a n/a

9th Highest 1-Hour (99.9th Percentile) Overall Maximum (RSA MPOI) 804 (804) 804 (804) 804 (804) 114 (113) 0.0 (0.0) 0.0 (0.0)


146 (146) 146 (146) 147 (147) 114 (113) 0.0 (0.0) 0.2 (0.2)

CPF Boundary 66 (66) 94 (92) 95 (94) 91 (91) 43 (39) 44 (42)

Maximum from Health Receptors 804 (804) 804 (804) 804 (804) 75 (72) 0.0 (0.0) 0.0 (0.0)

ESRD AAAQO 300 300 300 300

Annual Average Overall Maximum (RSA MPOI) 30 (30) 30 (30) 32 (32) 6.1 (6.1) 0.2 (0.2) 7.1 (7.1)


7.6 (7.6) 8.1 (8.1) 9.7 (9.7) 6.1 (6.1) 5.9 (5.5) 27 (27)



SIR 2 Table ESRD 4-1 Predicted Updated Nitrogen Dioxide Concentrations – Total Conversion Method (continued)

Receptor Location

Baseline Case

[µg/m3]

Application Case

[µg/m3]

Planned Development

Case

[µg/m3]

Project Only

[µg/m3]

Application Case Increase Over Baseline

[%]

Planned Development Case Increase

Over Baseline [%]

Annual Average (continued) CPF Boundary 6.1 (6.1) 7.2 (7.2) 8.4 (8.4) 5.2 (5.1) 17 (17) 37 (37)

Maximum from Health Receptors 30 (30) 30 (30) 32 (32) 4.6 (4.5) 0.2 (0.2) 7.1 (7.1)

ESRD AAAQO 45 45 45 45

Source: GoA 2013. Bracketed values contain original predictions for comparison purposes.

Reference:

Government of Alberta (GoA). 2013. Alberta Ambient Air Quality Objectives and Guidelines Summary. August 2013. http://environment.alberta.ca/01009.html

http://environment.alberta.ca/01009.html



1.2.2.2. Dispersion Modelling

5 SIR 15, Page 2-204

In response to SIR15a, Osum indicates that the application of the Ozone Limiting Method using a single ozone value derived from the Anzac 2007-2011 dataset is in compliance with ESRD requirements in place at the time of EIA report submission. This assumption is incorrect regardless of which Air Quality Model Guideline (2009 or 2013) is considered.

a. Provide NO2 concentrations for the three model scenarios using the accepted methodology in the current 2013 Air Quality Model Guideline (GoA 20131).

Response:

a. The requested revised NO2 concentrations are presented in Round 2 AER SIR 10. Despite the changes in NO2 modelling predictions, Osum is confident the original predictions calculated using ozone data from Anzac are still valid as they are conservative and well below the AAAQOs.

1 Government of Alberta (GoA) 2013. Air Quality Model Guidelines: Effective October 1st, 2013, 58p



6 SIR 17, Page 2-207

In response to SIR 17a, Osum presents Figure ESRD 17-1 showing the receptor grid used in the modelling. However, the receptors are not visible in either the electronic or hard copy versions of Figure ESRD 17-1.

a. Correct Figure ESRD 17-1 as required.

Response:

a. A corrected Figure ESRD 17-1 has been included as SIR 2 Figure ESRD 6-1.

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ca R

iver

Buffalo

Cre

ek

375000 378000 381000 384000 387000 390000 393000 396000 399000 402000 405000

62

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62

39

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62

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Near Field Receptors

Date:

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1.2.2.3. Air Quality Assessment

7 SIR 21, Page 2-212

In response to SIR 21a, Osum clarifies by stating background concentrations for non-criteria air contaminants were not used in the assessment.

a. Discuss the potential for underestimating the air quality impacts and therefore health risks by not including background concentrations for non- criteria air contaminants.

Response:

a. Osum is confident that predictions of non-criteria air contaminants were not underestimated in the air quality assessment because the Project is located in a remote location in north-central Alberta and background concentrations of non-criteria air contaminants are likely negligible in comparison to predictions. The nearest significant industrial development is the Saleski JV Pilot project, which is located approximately 6 km away. The next nearest industrial development is located over 35 km away. There are also few non-industrial sources present in the area. The nearest community is Wabasca-Desmarais and it is located approximately 75 km away. Emissions from highways or railroads are non-existent in the area. Even though these industrial developments and non-industrial sources are located far from the Project, predicted emissions of non-criteria air contaminants from these sources have been included in the dispersion modelling.



Water 1.2.3

1.2.3.1. Water Management

8 SIR 5, Page 2-181

In SIR 5b, Osum’s response to Metis Nation of Alberta Region 5’s concern about environment degrading chemical spills appears to imply that routine surface water monitoring can effectively track the effects of upsets on water quality. However, it is unclear how regular water-quality sampling can be effective in monitoring the water-related effects of spill events, especially at the low sampling frequency typical of environmental monitoring programs.

a. With reference to spills, explain how routine water quality monitoring provides the information necessary to establish the environmental consequences of such upsets.

Response:

a. Osum’s response to Round 1 ESRD SIR 5b did not intend to imply that routine surface water monitoring would necessarily be effective to measure water quality effects due to a spill. As part of that response, Osum committed to transparency and communication with regulators and stakeholders in the event of a spill. In addition, Osum committed to the implementation of a surface water quality monitoring program at the site that could be used to provide regular updates on the state of surface water in the vicinity of the Project. The results of this routine water quality monitoring would not necessarily be used to detect a spill, as Osum will include instrumentation and control systems as part of the Project design that will be used to detect a change in pressure or flow rate in vessels or pipelines.

In the event of an identified release, Osum would work with regulators and stakeholders to develop an appropriate spill response plan (as described in Volume 1, Section 3.3.2.1 of the EIA report) that may include the implementation of a specific monitoring to evaluate the effects of the spill.

8 b. Contrast and compare the efficacy discussed in Part a) with that of other monitoring approaches such as chemical monitoring of in-stream sediment traps.

Response:

b. As described in the response to part a) above, the proposed routine water quality monitoring would not necessarily be used to detect or measure the environmental effects of a release. In the event of a release, other monitoring approaches (such as the use of in-stream sediment traps or passive sampling devices) could be employed based on the nature and the location of the release, and on discussions with appropriate regulators.



9 SIR 29, Page 2-222 Volume 2, Section 6.4.1.1, Page 6-11 Volume 2, Section 6.9, Table 6.9-2, Page 6-28 SIR 32, Page 2-230

In its response to SIR 29b, Osum indicates excess storm-water storage capacities of 16% and 4% for the CPF run-off pond and well pads, respectively. Osum also indicates in SIR 29b that these storage safety margins are based on respective run-off coefficients of 0.6 and 0.4, and that the Fort McMurray historical weather record was used in the updated analysis presented in the SIR 29b response, as opposed to the Slave Lake record used for the purpose in the EIA report

a. Describe Osum’s plans to conduct a regional analysis of LSA design rainfall intensity and discuss uncertainty about the run-off in the final design analysis.

Response:

a. As described further in Round 2 AER SIR 4, Osum’s proposed design for the industrial runoff control system at the CPF and the well pads is compliant with the guidance provided in Appendix F of the Guide to Content for Energy Project Applications (AER 2014) and uses the same approach as other recently approved in situ oil sands projects (such as the Brion Energy Dover Commercial Project; EPEA approval 00268285-00-00). As described in the response to Round 1 ESRD SIR 29b, the proposed CPF runoff pond design capacity exceeds the calculated runoff volume of the 1 in 25 year 24-hour rainfall event by 20%. Osum does not propose to undertake further precipitation analysis as part of the runoff pond design.

9 b. Alternatively, provide more conservative designs for storm-water pond and well-pad detention capacity that effectively subsume any substantive uncertainty and bias in the underlying calculations.

Response:

b. As described in part a) above, Osum considers the proposed design of the industrial runoff control system to be appropriate based on current regulatory guidance and recent approvals of other larger in situ oil sands developments in the region.

Reference:

Alberta Energy Regulator (AER). 2014. Environmental Protection and Enhancement Act, Guide to Content for Energy Project Applications. Calgary, Alberta. March 29, 2014. 101 pp.



10 SIR 30, Page 2-224 Volume 4, Section 6.6.1.2, Page 6-67

In response to SIR 30b, Osum indicates that a combination of wick drains, rock drains and culverts will be used to maintain through-road drainage and a properly dispersed flow pattern. Multi-Flow, the wick drain product cited in Osum’s response, has a published flow capacity of 360 L/min/m at a prescribed hydraulic gradient of 0.1. On Page 6-67, Osum indicates a nominal access road width of 16 m, whereby the hydraulic gradient of 0.1 translates into an end-to-end elevation difference of 1.6 m (assuming that the wick drain spans the full width of the access road).

a. Explain how Osum will ensure that wick drain installations will have sufficient conveyance capacity under head gradient conditions below the prescribed 0.1.

Response:

a. Wick drains will be one part of a site-specific conveyance system to be designed for each access road segment that crosses a wetland; the system will also likely include culverts and rock drains. Wick drains and rock drains are typically installed to maintain normal flow dispersion through wetlands whereas culverts are installed to help pass flows in ephemeral or defined watercourses. Each site-specific system will consider the local natural conditions influencing wick drain installation such as flow dispersion width and water surface gradient.

Wick drains will be designed to convey normal flows with acceptable differential head by accounting for the decrease in flow rate due to a decrease in hydraulic gradient. Based on the published capacity of Multi-Flow, a hydraulic gradient of 0.01 is assumed to result in a flow rate of 114 L/min/m (head loss is proportionate to the velocity squared); however, Osum will discuss the design assumptions with the manufacturer before implementation. For example, if the design flow is 500 L/min, the wick drain installation will be 4.4 m wide assuming a differential head of 0.16 m.

10 b. Provide Alberta examples where wick drains have been used to convey water flow beneath a road bed.

Response:

b. Osum does not currently operate any facilities where wick drains have been used to convey water flow beneath a road bed, but will work with vendors before construction to identify wick drain designs that have been proven successful in other areas of the province.

Osum is aware of at least one other in situ oil sands operator in Alberta that has used wick drains installed at the base of an access road to a well pad near Conklin, Alberta. In this case, the wick drains spanned the width of the road with wetland on either side.



10 c. If Osum is planning an alternative to wick drains for maintaining through-road drainage where low-flow gradient conditions may preclude the necessary conveyance capacity, discuss what method(s) would be used and how this(these) alternative(s) would overcome the low-gradient conveyance issue.

Response:

c. At this time, all through-flow drainage is expected to be conveyed using wick drains, rock drains, and culverts. The selection of the conveyance product will depend on the design flow and the acceptable differential head. Any alternatives to these identified products will only be proposed if the governing hydraulic setting and conditions suggest that a different product is more appropriate.



11 SIR 84, Page 2-374

In response to SIR 84a, Osum states that surface water drainage will be monitored during the spring freshet and during or shortly after an intense rainfall event.

a. Explain how the proposed monitoring of peak flows represents a reliable measure of low-flow maintenance.

Response:

a. Monitoring the performance of surface drainage infrastructure during peak flows and identify damage to or deterioration of this infrastructure after peak flows are important monitoring activities. It is essential that the infrastructure is capable of handling and enduring high energy flow events if it is to perform properly under low-flow conditions. Nonetheless, the low-flow periods are also important periods for the maintenance and health of aquatic ecosystems, and surface water drainage functionality will also be monitored during low-flow periods.

11 b. Discuss the direct monitoring procedures Osum will employ to verify the effectiveness of wick drains and rock drains during extended low-flow periods.

Response:

b. Wick drains and rock drains will be designed to maintain pre-development conditions. Site-specific pre-development water levels and drainage routes will be assessed before construction as part of detailed design.

During low-flow periods, Osum will conduct inspections of surface drainage routes that intersect Project components including the following specific activities:

• Verifying that no fish barriers (i.e., hanging culverts) exist at potentially fish-bearing watercourse crossings and remediating those fish barriers that do exist.

• Verifying that flow is being maintained through wick drains, rock drains, and culverts by conducting visual inspections of the inlets and outlets.

• Comparing post-development water levels and routes to pre-development conditions.

• Recording observations and recommending remedial measures if necessary.

• Photographing each monitoring location for the purposes outlined in the response to Round 1 ESRD SIR 84a.



1.2.3.2. Hydrogeology

12 SIR 33, Page 2-231 Volume 4, Section 5.5, Figure 5.5-74 Volume 4, Section 5.6.4, Page 201

In response to SIR-33a, Osum provides a description of the lithology and depositional environment of the Leduc reefal buildup in the RSA, but does not discuss its hydraulic properties, or address the depression in the Grosmont hydraulic head over the area of maximum Lower Ireton thinning, as requested.

In response to SIR-33b, Osum states To clarify, the location of the Cooking Lake disposal well is adjacent to the CPF. The GMC supply wells are in township 85-20 W4M which is two townships to the west. However, Figure ESRD 33-1 shows a disposal well (11-20) in township 85, range 20. In Section 5.6.4, Osum indicates that Laricina has an active disposal well completed in the Cooking Lake Formation at 05-23-085-20-W4M (shown on Figure 5.5-74). The 11-20 disposal well (uncertain status) and the Laricina disposal well (active status) are both located in close proximity to the proposed GMC supply wells and within the ridge of thinned Lower Ireton Formation over the Leduc reefal build-up.

a. Discuss the hydraulic properties of the Leduc reefal buildup in the LSA and adjoining RSA, and discuss a possible causal relationship (in terms of hydraulic connection) between the Grosmont hydraulic head depression and the area of Lower Ireton thinning overlying the Leduc reefal buildup in the vicinity of the LSA.

Response:

a. In 2013, Osum conducted a disposal test on a well located in the LSA at 11-20-085-20 W4M (Well ID 100/11-20-085-20W4). The well is constructed as an open hole completion, across the Leduc and Cooking Lake formations. Analysis of the disposal test results yields a permeability of 4.1 Darcies, equal to a hydraulic conductivity of approximately 4E-5 m/s. Such a hydraulic conductivity indicates that the formations have aquifer properties at the test location. Existence of a Laricina/Osum operational disposal well (102/05-23-085-20W4) provides additional confirmation of the favorable hydraulic conductivity conditions in the Cooking Lake/Leduc formations; even though the actual aquifer parameters are not publically available.

Hydraulic heads in the Grosmont Formation (undivided), as shown in Volume 4, Figure 5.5-64 of the EIA report, reveal apparently lower values in the north-central portion of the regional study area (RSA). In considering the groundwater level data, one should note the following:

• The data control points are sparse. The figure posts two sets of data, including groundwater levels measured during numerous drill stem tests (DSTs; posted as black dots), and groundwater levels (posted as red dots) measured at the Laricina Saleski, Laricina Germain, and Black Pearl Blackrod projects during disposal well programs.



Additional groundwater level data was also provided by Osum during the 2013 testing program (323 m asl at Grosmont well 1AA/01-28-085-20W4 and 322 m asl at Grosmont well 1AB/12-22-085-20W4).

• Based on a review of the combined data it is noted that the DST results indicate substantially higher groundwater elevations (i.e., 340 to 390 m asl), while the operators’ data are in the range of 310 to 325 m asl.

It is not certain if the higher DST-measured groundwater elevations result from the inaccuracy of the DST tests, or whether the lower heads reported by operators represent a new, lower piezometric surface in the Grosmont Formation associated with groundwater diversion at operational projects (Canadian Natural Brintnell, Cenovus Pelican Lake, and Black Pearl Blackrod projects).

It is noted that the 330 m asl groundwater elevation measured in the Cooking Lake/Leduc formation by Osum (100/11-20-085-20W4) indicates a slightly upward gradient from the Cooking Lake Formation to the Grosmont Formation (groundwater level in the Grosmont Aquifer measured in the range of 322 to 325 m asl).

The general conclusion of the above-noted information is that the lower hydraulic heads reported for the Grosmont aquifer are likely attributed to groundwater diversion at operational projects in the region. As the Lower Ireton aquitard is present over the entire LSA, and actual heads in the Cooking Lake Formation are slightly higher than or similar to the heads in the Grosmont Aquifer, it is highly unlikely that the Grosmont Aquifer is being under-drained by the Cooking Lake Formation.

In 2011, Dover Operating Corp. conducted a water test on well 1F1/11-25-088-20W4/00 and discussed the results in their ESRD Round 1 SIR responses. The reported properties are as follows (Dover 2011):

• net aquifer thickness: 101 m • permeability: >26 Darcies • well efficiency: 14% to 26% • theoretical radius of influence: 7 to 10 km • TDS: 23,000 mg/L

12 b. Discuss the current and future status of disposal well 11-20.

Response:

b. An error was made in Figure ESRD 33-1 and should not have identified well 11-20-085-20 W4M as a disposal well. Refer to the updated Figure ESRD 33-1 presented as SIR 2 Figure ESRD 12-1. The 11-20 well was a disposal well for the 01-28-085-20 W4M Grosmont C (GMC) aquifer test. The 11-20 well is not the well that will be used for the



Project wastewater disposal stream. The disposal well that will be used for the Project will be located close to the CPF in township 85-18 W4M, in the area identified as the salt cavern on Volume 1, Figure 1.2-2 of the EIA report. The 11-20 well is currently suspended.

12 c. Explain the decision to locate the GMC supply wells in such close proximity to the Laricina disposal well.

Response:

c. The 01-28 GMC aquifer test well is located over 2 km away from Laricina/Osum’s 05-23-085-20 W4M disposal well. In well 05-23, waste is being disposed into the Cooking Lake Formation, where over 70 m of Lower Ireton shale caps the Leduc Formation (SIR 2 Table ESRD 12-1). The low permeability Lower Ireton Formation is present throughout the RSA. The Lower Ireton Formation, which separates the overlying Grosmont Formation from the underlying Leduc and Cooking Lake formations, acts as a barrier to flow between the overlying and underlying formations. Although waste is being disposed into the Cooking Lake Formation, Osum estimates that there is a minimum of 80 m of low permeability strata between the Cooking Lake formation and the GMC (including the Lower Ireton aquitard and the low porosity Grosmont A and Grosmont B limestones). Volume 1, Figure 2.2-1 of the EIA report illustrates a significant thickness of intervening low permeability strata.

The lack of communication between the GMC and the Cooking Lake Formation is further supported by the fact that the GMC is characterized by a relatively low salinity (10,000 mg/L at Grosmont well 1AA/01-28-085-20W4), whereas the underlying Leduc and Cooking Lake formations have reported more saline groundwater (23,000 mg/L at Leduc and Cooking Lake well 1F1/11-25-088-20W4/00) (Canadian Discovery 2011).

While water is being withdrawn from the high permeability GMC, Osum expects that there should be no interaction with the underlying Leduc and Cooking Lake formations due to the intervening thick sequence of low permeability strata between the Cooking Lake Formation and the GMC.

SIR 2 Table ESRD 12-1 Measured Isopachs between the Grosmont C and Leduc Formations

Well Grosmont B Isopach (m)

Grosmont A Isopach (m)

Lower Ireton

Isopach (m)

Grosmont C to Leduc

Isopach (m)

Leduc Isopach

(m)

GMC to Cooking

Lake Isopach (m)

AA/02-16-086-21W4 12.8 38.9 28.21 79.9 82.6 82.6 00/11-20-085-20W4 15.0 41.2 53.5 110.5 162.4 162.4 00/05-23-085-20W4 14.9 44.1 71.9 130.9 47.0 47.0 02/05-23-085-20W4 15.1 44.4 71.9 131.3 157.5 157.5 00/02-26-085-19W4 15.6 41.7 101.8 159.1 35.8 35.8

Active Osum/Laricina disposal well is indicated in bold.



References:

Canadian Discovery Ltd. 2011. Hydrogeological Investigation of the Grosmont Formation as a Target Water Source for Oil Sands Development. Calgary, Alberta. August 2011.

Dover Operating Corp. (Dover OPCO). 2011. Dover Commercial Project, Project Update and Supplemental Information Request Responses (AENV #001-268285, ERCB #1673682). Prepared for Alberta Environment and Energy Resources Conservation Board. Calgary, Alberta. September 2011.

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13 SIR 39, Page 2-245 Volume 4, Section 5.3, Page 5-10 Volume 4, Section 5.6.2.4, Page 5-193

Osum’s response to SIR39a reiterates its aquifer productivity calculation discussion presented on Page 5-10. It does not address the lack of clarity and apparent inconsistency between Osum’s %AP detection threshold of 15% and the high degree of precision and accuracy achievable in routine water level monitoring. Osum’s response to SIR39b also repeats the Page 5-10 discussion, but does not rationalize Osum’s prescribed 30% high-effect threshold. In response to SIR39c’s similar request, in this case to rationalize the 10% low to high effect threshold for the proposed Cooking Lake Formation disposal well, Osum appeals to the use of this threshold in past EIAs, but does not explain its basis.

Osum assigns a final impact rating of negligible GMC pumping in Table 5.6-7, however, the effect is characterized as high magnitude, continuous, regional in extent, and long term. In the discussion on Page 5-193, Osum also included the pumping-induced change in GMC storage (i.e., water inventory) as an important impact assessment criterion, but omitted it from its issues and assessment criteria discussion in Section 5.3

a. In light of routinely achievable water level measurement precision and accuracy, discuss the appropriateness and usefulness of the %AP=15% effects-detection threshold.

Response:

a. Based on the wording, Osum is unsure if the focus of the SIR is (i) whether the accuracy and precision inherent in groundwater level measurement will allow for groundwater level changes to be detected where the change represents less than 15%AP, or (ii) whether it is related to the apparent subjectivity of the values used in the low, medium, and high effect %AP calculations. Osum will attempt to address both potential concerns hereafter.

Groundwater levels are typically measured to cm-level accuracy. Therefore, future changes to groundwater levels in the GMC aquifer at the Project and at other nearby non-Osum operations, whether related to pumping by a single operator or arising from cumulative effects, are expected to be resolved to cm-level accuracy. Given the appreciable available drawdown in the GMC aquifer in the region (Volume 4, Section 5, Table 5.6-3 of the EIA report), sustained changes in groundwater levels, even if measured of the order of a few cms or a few tens of cms at a given location, will represent significantly less than 15%AP, and likely less than 1%AP. Although Osum is confident that future monitoring can resolve groundwater level changes to cm-level accuracy, Osum does not believe that changes of this order represent significant effects to the aquifer productivity. Rather, Osum has used a relative %AP to assess the potential effect of pumping, as discussed below.

Consistent with the methods used for other EIAs (e.g., the Canadian Natural Kirby Expansion project [Canadian Natural 2011]; Cenovus Telephone Lake project [Cenovus 2011]; Korea National Oil Corporation BlackGold project (KNOC 2009), Osum used a low effect, medium effect, and high effect approach to assess potential impacts associated with pumping from the



GMC aquifer. As was discussed in the response to Round 1 ESRD SIR 39, the estimated %AP for the saline GMC aquifer was based on the predicted difference in the hydraulic head distribution between the Baseline, Application, and Planned Development cases. The magnitude of the potential impact on AP was assessed using the following three levels:

• Low effect: If the predicted %AP is less than 15%, the effect may be detectable; however, potential conflicts with other users within the hydrogeology RSA would likely not result.

• Medium effect: If the predicted %AP is between 15% and 30%, the effect would likely be detectable; however, conflicts with other users within the hydrogeology RSA would likely not result.

• High effect: If the predicted %AP is greater than 30%, potential conflicts with other users within the hydrogeology RSA could result.

It is recognized that the use of the low effect, medium effect, and high effect, for the range of %AP listed, is subjective. However, the method is viewed as acceptable for the purpose of providing a relative scale to assess the predicted impact on applicable receptors associated with groundwater extraction. The method is also viewed as suitable for the impact assessment given that the predicted changes in %AP are transient and that groundwater levels in the GMC aquifer are predicted to recover following the cessation of pumping.

Ultimately the groundwater levels that will actually be measured in the aquifer, at a given location and time in the future, will depend on the aquifer conditions at and around that location, on the GMC aquifer pumping schedule of Osum, and other regional water users. Osum will have no control of the pumping rates and schedule of other water users; therefore, attempting to quantify groundwater level impacts at a level of accuracy beyond that used in the %AP discussed herein, for the Baseline, Application, and Planned Development cases, is not considered beneficial. Ultimately, Osum and other operators in the region will monitor groundwater levels in the GMC aquifer and such future monitoring is expected to be to cm-level accuracy. The results of the monitoring will be used to facilitate the management of groundwater withdrawals from the saline GMC aquifer and to minimize cumulative effects.

13 b. Discuss the rationale underlying the 30% and 10% medium-to-high magnitude effect threshold for source and disposal well pumping respectively.

Response:

b. Osum’s rationale for the selected magnitude criteria to assess effects due to source water withdrawal is described in the response to part a) above. Osum’s selected approach for assessing the effects of wastewater disposal was based on the regulatory framework presented in Directive 051: Injection and Disposal Wells – Well Classifications, Completions, Logging, and Testing Requirements (AER 1994) which requires operators to demonstrate that use of



the planned disposal interval (i.e., the Cooking Lake Formation) will not affect overlying non-saline aquifers and surface water resources. Using this basis, Osum did not assess the magnitude of effects using a range of potential outcomes; a binary threshold of 10% AP was used as the cutoff for determining if the planned wastewater disposal could affect other users (i.e., low effect of <10% AP and high effect of >10% AP).

13 c. Given the nature of the underlying assessment criteria for GMC pumping, explain the final impact rating of negligible.

Response:

c. The GMC aquifer is a shared resource and groundwater monitoring by operators will be used to manage cumulative effects. Once groundwater pumping has ceased, groundwater levels, over time, are predicted to recover. For these reasons, and owing to Osum’s small proposed groundwater use, relative to the conservative estimate of the groundwater storage in the GMC aquifer (Volume 4, Section 5.6.2.4 of the EIA report), a final impact rating of negligible was assigned to pumping of the GMC aquifer.

13 d. Discuss the role of change in storage in the effects assessment and its relationship to the change in Aquifer Productivity effects criterion.

Response:

d. When considering aquifer storage the term being referred to is specific storage (Ss), which is defined as “the volume of water that a unit volume of aquifer releases from storage under a unit decline in hydraulic head” (Freeze and Cherry 1979). Aquifer storage differs for confined and unconfined aquifers as follows:

• Confined Aquifer: The storage term for confined aquifers, like the GMC aquifer, is called storativity (or coefficient of storage, S). The S of a saturated confined aquifer of thickness (b) is defined as “the volume of water that an aquifer releases from storage per unit surface area of aquifer per unit decline in the component of hydraulic head normal to that surface” (i.e., S = Ss × b). Values of S range from 0.00005 to 0.005 (unitless) (Freeze and Cherry 1979).

• Unconfined Aquifer: The storage term for unconfined aquifers is referred to as specific yield (Sy). It is defined as “the volume of water that an unconfined aquifer releases from storage per unit surface area of aquifer per unit decline in the water table.” Values of Sy range from 0.01 to 0.3 (unitless) (Freeze and Cherry 1979). In the case of an unconfined aquifer, the aquifer thickness (b) is defined as the “saturated thickness of the aquifer or height of the water table above the top of the underlying aquitard.”



When compared to S values, Sy values are much larger as pumping of an unconfined aquifer involves the physical dewatering of the aquifer pore space. Conversely, the release of water from pumping of a confined aquifer represents “only the secondary effects of water expansion and aquifer compaction caused by changes in fluid pressure” (Freeze and Cherry 1979).

Under all pumping scenarios presented for the Baseline, Application, and Planned Development cases, the pressure surface in the GMC aquifer is predicted to remain above the top of the aquifer, such that the aquifer will remain in a confined status. Therefore, all water released from storage during the planned pumping will occur as a result from the secondary effects of water expansion and aquifer compaction caused by changes in fluid pressure. Although not predicted to occur, should the pressure in the aquifer decline below the top of the aquifer, aquifer dewatering would commence and significant volumes of water would be released during the dewatering process.

References:

Alberta Energy Regulator (AER). 1994. Directive 051: Injection and Disposal Wells – Well Classifications, Logging and Testing Requirements. Calgary, Alberta. March 1994.

Canadian Natural Resources Limited (Canadian Natural). 2011. Application for Approval of the Kirby In Situ Oil Sands Expansion Project. Submitted to the Energy Resources Conservation and Alberta Environment and Water. December 2011.

Cenovus TL ULC (Cenovus). 2011. Telephone Lake Project. Joint Application for Approval and Environmental Impact Assessment submitted to: Energy Resources Conservation Board and Alberta Environment and Sustainable Resource Development. Calgary, Alberta. December 2011. http://www.cenovus.com/operations/oil/telephone-lake-expansion.html

Freeze R.A. and J.A. Cherry. 1979. Groundwater. Prentice Hall. Englewood Cliffs, New Jersey.

Korea National Oil Corporation (KNOC). 2009. Application for Approval of the BlackGold Expansion Project. Submitted to the Energy and Resources Conservation Board and Alberta Environment. Calgary, Alberta. December 2009.

http://www.cenovus.com/operations/oil/telephone-lake-expansion.html



14 SIR 40, Page 2-250 SIR 44, Figures 44-1 and 44-2 Volume 4, Section 5.6.2.1, Page 5-183 to Page 5-187 SIR 12a, Page 2-99

In response to SIR-40d, Osum presents the results of a Theis analysis for drawdown predictions that incorporates image wells to simulate the negative hydraulic boundary produced by the bitumen-water contact. At the location of Osum 12-22, the upper portion of the GMC is bitumen saturated, which decreases the thickness of the water saturated GMC at this location to roughly 25 m. In response to AER SIR12a, Osum indicates that a constant aquifer thickness of 65 m was used in the Theis forward solution. While this thickness is generally consistent with GMC thickness in the Canadian Natural 11-26 (60.4 m) and Cenovus 4-11 (63 m), it is approximately twice the thickness of the water-saturated GMC in the Osum 12-22.

In response to a request for upper and lower error-bar estimates, Osum provided isopleths for drawdown calculated using hydraulic conductivities of 1 × 10-4 m/sec and 4 × 10-4 m/sec. These show substantive differences in drawdown within the LSA and RSA between the two hydraulic conductivity ranges.

a. Given the lack of data for the GMC Aquifer and the uncertainty in hydraulic conductivity estimates from the aquifer test, explain why lower hydraulic conductivity values (e.g. values calculated from the pumping well) were not used for the low-end estimate of drawdown in the GMC

Response:

a. Osum would like to clarify that the water saturated portion of the GMC at the location of Osum’s 12-22 well is approximately 43 m thick, rather than 25 m as stated in the discussion above.

Results from the GMC aquifer test were presented in the response to Round 1 AER SIR 11, indicating bulk permeability over 200 D, which equates to a hydraulic conductivity of over 2 × 10-3 m/s. The calculations and predictions of drawdown for the GMC aquifer in response to Round 1 ESRD SIR 40d were done using the range of hydraulic conductivity values between 1 × 10-4 m/s and 4 × 10-4 m/s, which are considerably more conservative (i.e., low-end estimates of drawdown in the GMC). In consideration of the results from the GMC aquifer testing completed by Osum, the use of the hydraulic conductivity value of 1 × 10-4 m/s for determining the low-end estimate of drawdown is considered a conservative estimate for the hydraulic conductivity of the Grosmont Formation in the LSA.



15 SIR 43, Page 2-274 Volume 4, Section 5.5, Figure 5.5-74

In response to SIR 43d, Osum states that Monitoring water levels or water quality in the overlying and underlying aquifers near the GMC water source wells is not planned. Osum further states However, the proposed Cooking Lake disposal wells are located more than 20 km east of the proposed GMC water source wells. No interaction between the wastewater disposal injection into the Cooking Lake Formation and the source water withdrawal from the GMC is anticipated; therefore, an integrated monitoring program is not proposed for these aquifers.

Though Osum now plans to locate their disposal well near their CPF, Laricina has an active disposal well completed in the Cooking Lake Formation at 05-23-085-20 W4M (shown on Figure 5.5-74), which is in the same township and range as Osum’s proposed GMC supply wells, and within the ridge of thinned Lower Ireton Formation over the Leduc reefal build-up.

a. Taking into consideration the close proximity of the Laricina Cooking Lake wastewater disposal well and the GMC water source wells, and the thinned caprock and potentially high permeability Leduc reef separating the two formations, explain the decision to not propose an integrated monitoring program for these aquifers.

Response:

a. There should not be any interaction between the Cooking Lake (disposal zone) and the GMC (source zone) because the Lower Ireton is a regional aquitard that exists everywhere between the two systems (described in more detail in the response to Round 2 ESRD SIR 12). The current GMC water test is also over 2 km away from Laricina/Osum’s 05-23 Cooking Lake disposal well, and over 70 m of Lower Ireton shale separate the Cooking Lake/Leduc from the overlying Grosmont A at the 05-23 disposal location.

Because there should be no interaction between the two formations, no monitoring program is planned.



16 SIR 46, Page 2-284 Volume 4, Section 5.6.2, Page 5-182

In response to SIR 46a, Osum indicates that the results of the local hydrogeological assessment conducted in the vicinity of the proposed non-saline source well in 2013 are provided in the following two documents provided in Appendix ESRD 46-1:

Results of Winter 2013 Non-Saline Groundwater Exploration and Testing Program, Sepiko Kesik Project, and Water Act License Application Support Document, Osum Sepiko Kesik Project, 10-22-086-21 W4M, Near Fort McMurray, Alberta.

On Page 5-182, Osum states Further evaluation of local hydrogeology in the vicinity of the proposed non-saline utility water source wells in 2013 by Osum will include an assessment of potential groundwater-surface water interaction and specific mitigation measures (as required).

a. Explain why shallower groundwater bearing zones and/or surface water were not monitored during the aquifer pumping test for the purpose of evaluating the potential for groundwater-surface water interaction.

Response:

a. The non-saline groundwater source well at 10-22-086-21 W4M (WSW 10-22) is completed in an artesian aquifer, screened from 51 to 63 m below ground level (mbgl). The non-pumping groundwater level in this well was measured at 10.43 m above ground level. This aquifer is confined by significantly thick units of clay deposits, essentially providing hydraulic isolation from surface water bodies. In addition, as discussed in the responses to Round 1 ESRD SIR 46c and Round 2 ESRD SIR 18a, the water table at this site is approximately 6 mbgl. Therefore, there is a relatively thick unsaturated zone separating the water table from ground level. This well was tested under natural groundwater flow conditions (i.e., a pump was not installed in the well) and was allowed to flow for 3 days at 350 m3/d. Groundwater levels in this well and an associated monitoring well (installed in the same aquifer) were monitored during the flow portion of the test and after the well was shut-in (recovery portion of the test). Shallow monitoring zones were not monitored during the test as propagation of the effects of allowing the well to flow under natural artesian conditions was not anticipated to be detectable in shallower zones during the short-term aquifer test. Results from this test were evaluated and presented in Appendix ESRD 46-1 as part of the Round 1 SIR responses.

Taking into consideration the information above and results from the aquifer testing, groundwater withdrawal from this artesian well is not predicted to have detectable impact on surface water resources. Further discussion on the potential for groundwater-surface water interaction is discussed in the responses to Round 2 ESRD SIR 18.

A description of the longer term monitoring program planned to test predicted effects of groundwater withdrawal from the artesian aquifer is presented in Round 2 ESRD SIR 17b.



16 b. Provide a discussion of the shallow hydrogeology in the local area, including vertical and lateral hydrostratigraphic unit transitions and discontinuities (including unit thickness variations and distances to hydraulic boundaries) and their implications for drawdown and inter-zone hydraulic communication.

Response:

b. Drilling and testing programs have confirmed the Quaternary sequence is dominated by low permeability clay-rich deposits. Within the area of WSW 10-22, a confined artesian aquifer was encountered at a depth of 48.8 mbgl. Thick confining units of clay-rich deposits were encountered during drilling at this location and during drilling of the observation well at 10-22-086-21 W4M (OBSW 10-22). Relatively permeable deposits were encountered from approximately 24 to 35 mbgl during drilling at WSW 10-22. A similar sandy unit was encountered at OBSW 10-22 from approximately 22 to 28 mbgl. The full extent of this unit is not known.

WSW 10-22 and OBSW 10-22 are interpreted to be completed in the buried valley deposits of Unnamed Valley E. Negative boundaries encountered during testing at WSW 10-22 support the theory that this aquifer is not of infinite areal extent (as discussed in the response to Round 1 ESRD SIR 46a). Further details on the stratigraphy in this area and the potential for inter-zone hydraulic communication was discussed in detail in the responses to Round 1 ESRD SIR 46b and 46c, as well as in the responses to Round 2 ESRD SIR 18a and 21a.



17 SIR 46, Page 2-284

In its response to SIR46b, Osum refers to late-time pumping test data and a distal location calculation result that falls well below Osum’s prescribed effects threshold of %AP=15% to support use of a Theis analysis of Unnamed Valley E Aquifer draw-down due to pumping.

a. Explain how and to what extent the late-time transmissivity and predicted divergence from the prescribed effects threshold compensate the deficient realism.

Response:

a. Transmissivity calculated based on pre-negative boundary conditions (early to mid-time transmissivity) gives information on the aquifer materials with the assumption that the aquifer is of infinite areal extent. In consideration that this condition is rarely met in reality, and that the aquifer in which WSW 10-22 is completed is known to be completed in the buried valley deposits of Unnamed Valley E, this led to the prediction that this aquifer is not of lateral infinite areal extent, and a negative boundary was anticipated to be encountered during the aquifer test. Using the portion of the test where enhanced drawdown was recorded (i.e., post-negative boundary) to calculate the transmissivity, allows for use of the data to interpret and predict the drawdown and safe-yield of the aquifer for an aquifer of non-ideal conditions; in this case, of non-infinite areal extent.

17 b. Describe the monitoring program that will be used to test the predicted effects of Unnamed Valley E Aquifer pumping on overlying units, the surficial water table, and sensitive surface water bodies.

Response:

b. Osum will apply for a groundwater diversion licence under separate cover for the Project’s domestic and utility groundwater withdrawals from the non-saline buried valley aquifer. Based on assessments completed to date and included as part of the responses to Round 1 ESRD SIR 46a (Appendix 46-1) and Round 2 ESRD SIR 21, effects are not anticipated to surface water bodies. Groundwater monitoring is a fundamental component of the Water Act licence process, and Osum will comply with the terms and conditions of the Water Act license received. Osum anticipates that a typical groundwater monitoring program for a non-saline groundwater withdrawal of this scale would include ongoing monitoring of groundwater levels in the source well and one monitoring well within the same aquifer, along with reporting of groundwater withdrawal volumes. Should there be concern with respect to the potential effect to shallower aquifers or surface water bodies, Osum would install a monitoring well in the overlying potential aquifer unit (as defined in the response to Round 1 ESRD SIR 46c). Groundwater level monitoring in the shallower aquifer would be used as an indicator of potential effects of groundwater withdrawal from the target aquifer on overlying units and surface water bodies. This information would be used to determine if monitoring of the unconfined (water table) aquifer would be required. Once the licence is



issued, Osum will implement the monitoring program, including the target aquifer and other aquifers or water bodies that AER deems appropriate. As such, Osum will operate and monitor the non-saline water wells and monitoring well(s) as required under the Water Act and the Alberta Environment Guide to Groundwater Authorization (GoA 2011).

Reference:

Government of Alberta (GoA). 2011. Alberta Environment Guide to Groundwater Authorization. March 2011. http://environment.gov.ab.ca/info/library/8361.pdf




18 SIR 47, Page 2-293

In its response to SIR47a, Osum indicates that understanding of an aquifer’s water budget is not required in inferring hydraulic isolation from artesian flow conditions. The hydraulic connection between the Unnamed Valley E Aquifer and overlying strata is an important driver of potential environmental effects from Osum’s proposed non-saline well pumping.

a. Considering aquifer recharge at a distal location where surface elevation is higher than locally, explain how a non-zero local Darcy flux to surface from the aquifer precludes local artesian flow conditions.

Response:

a. A non-zero, albeit small, upward-directed Darcy flux was estimated in the response to Round 1 ESRD SIR 46. The upward groundwater flux may result in an increased pore pressure in the intermediate, confined water-bearing zone, encountered at a depth of 18.3 to 24.4 mbgl at 10-22-086-21 W4M. Given the variable geology of the Quaternary deposits, it can only be speculated whether flowing artesian conditions (i.e., heads above ground level) can be developed in this intermediate confined aquifer. However, it is known that the water table at the WSW 10-22 site is located at a depth of approximately 6 mbgl, rather than at ground surface. Therefore, regardless of the uncertainty of the groundwater level in the intermediate water-bearing zone, the net upward flux of groundwater must be minimal as the water table is at a depth of 6 mbgl and not at ground level as would be the case if significant artesian groundwater discharge to ground surface was occurring in the area.

18 b. If it does not preclude artesian local flow conditions, explain how this scenario does not apply to the Unnamed Valley E Aquifer.

Response:

b. Please refer to the response to part a) above.

18 c. If this scenario could apply to the Unnamed Valley E Aquifer, re-interpret the artesian nature of Unnamed Valley E Aquifer that takes uncertainties about aquifer water budget into account.

Response:

c. As discussed in the response to part a) above, a small upward-directed groundwater flux is expected from the Unnamed Valley E aquifer towards the water table. The planned pumping of the aquifer will change the upward flux (further discussed in the response to Round 2 ESRD SIR 21), although recovery to pre-pumping conditions is expected following cessation of groundwater withdrawal at the Project. Any uncertainty associated with the ability of the



Unnamed Valley E aquifer to support the Project non-injection water requirements will be addressed under the Water Act. Osum will develop a monitoring program to demonstrate compliance with the Water Act licence terms and conditions, as described in Round 2 ESRD SIR 17b. This monitoring program will be used to confirm that pumping is not resulting in adverse impacts to local water resources or users.



19 SIR 49, Page 2-299

In its response to SIR49a, Osum states …wells will be spud vertical, so there is not expected to be a measureable difference between the measured watercourse setback at surface and the measured watercourse setback in any discontinuous shallow Quaternary sediments. The meaning and/or relevance of this quotation to setback from overburden aquifers is unclear.

a. Taking well-pad layout into account, explain how vertical spudding precludes greater proximity to aquifers than to surface water bodies.

Response:

a. Osum’s referenced statement in the response to Round 1 ESRD SIR 49a was attempting to indicate that the distance between the wellhead and the closest water body when measured at surface would be the same as the distance between the vertical portion of the wellbore and the area beneath the water body when measured underground. More explicitly, Osum intended to convey that the source of potential thermal effects (the wellbore) would not be angled in such a way that it would be closer to a surface water body underground than the measured setback at surface. Osum recognizes that a vertically spudded well could still intersect discontinuous shallow Quaternary sediments present beneath the well pad, but this point of intersection would still be located greater than 150 m from the closest surface water body, as described in the responses to Round 1 ESRD SIR 45 and Round 2 ESRD SIR 27.



20 SIR 51, Page 2-303

In response to SIR51a, Osum states Also, there is a potential for low flows to be underestimated if the rate of discharge from deeper groundwater into the incised channels is significant.

a. Given that the low-flow estimates presented in the EIA report are based on measured flows, explain how groundwater discharge along incising channels biases these estimates.

Response:

a. The low-flow estimates presented in the EIA report are based on a 30-year simulated flow time-series created by the calibrated hydrologic model.

The hydrologic model does not account for groundwater discharge from deeper strata (i.e., those below the interflow zone, but above the bed of the incised channel). Instead, all simulated flow is a result of surface, interflow, and near-surface groundwater processes. These processes are more directly related to climate trends, which are the model input used to create the simulated flow. Conversely, groundwater discharge from deeper strata does not decrease substantially during extremely hot and dry periods. Although the groundwater contribution to normal flows is relatively small, it can represent a large percentage of the flow during low-flow periods. Collected field data supports this expectation as measured electrical conductivity (i.e., a measure of the groundwater contribution) increases as flows decrease.

Groundwater discharge was not included in the surface water modelling due to the limited localized groundwater data available and variability of groundwater flux estimates as discussed in the response to Round 1 ESRD SIR 46.

The model development and calibration process is sufficient to describe hydrologic conditions and to assess the potential change in hydrologic response between the Baseline Case and Application Case assessments. However, as deep groundwater discharge was not included within the model, low-flows may be underestimated and as a result, the model’s prediction of relative impacts of the Project on low-flows would be over-estimated.



1.2.3.3. Hydrology

21 SIR 36, Page 2-241 SIR 35, Page 2-239 Volume 4, Appendix 6B , Section 6B.2, Page 6B-1 Volume 4, Section 4.5.5.2, Page 6-37 Volume 4, Section 5.6.2, Page 5-182 Volume 4, Section 6, Table 6.5-3, Page 6-23

In response to SIR36a, Osum states that Deep groundwater refers to water in aquifers that do not discharge to the surface water in the Hydrology LSA.

In response to SIR35b, Osum declined to test the constraints on percolation loss to inactive groundwater, indicating that the percolation flux parameter is correlated with certain storage and flux parameters and that necessary percolation data are lacking. However, this response does not explain to what extent the calibration dataset is able to constrain the upper and lower bounds of percolation loss parameterization.

a. Explain the basis for Osum’s conclusion that the consequences to the water table of its Application Case best-estimate recharge flux, representing a best-estimate -89 mm/yr change in the upward flux of groundwater to overlying layers, would be undetectable.

Response:

a. Osum assumes that Round 2 ESRD SIR 21a refers to calculations that were provided as requested in the response to Round 1 ESRD SIR 46.

The proposed non-saline groundwater source well at 10-22-086-21 W4M (WSW 10-22) is located approximately 24 km west of the Osum Sepiko Kesik Project lease, beyond the extent of the surface water Hydrological Simulation Program Fortran (HSPF) model domain. Although the deep groundwater systems were not included in the surface water model, it is anticipated that groundwater and recharge contributions through the LSA subwatersheds are minimal with respect to the overall water balance.

WSW 10-22 is completed in an artesian aquifer, screened from 51 to 63 mbgl. Lithology of WSW 10-22 is presented in the response to Round 1 ESRD SIR 46, with an interpreted shallow unconfined aquifer from 0 to 18 mbgl and a potential intermediate confined aquifer from approximately 24 to 35 mbgl. Clay-dominated layers (confining aquitard units) were encountered between each of these units, effectively providing hydraulic isolation from surface water bodies.

As discussed in the response to Round 1 ESRD SIR 46c, the water table at the WSW 10-22 site is approximately 6 mbgl. Therefore, there is a relatively thick unsaturated zone separating the water table from ground level. This leads to the conclusion that any changes in groundwater conditions at depth would not directly impact surface water resources. Therefore, any changes in groundwater cross-formational flux would affect either the intermediate confined aquifer or the water table aquifer.



Analytical calculations of the estimated Darcy flux between the artesian aquifer and the shallow unconfined water table aquifer, and potential changes in the Darcy flux due to pumping of the artesian well located at 10-22-086-21 W4M, were completed as part of the response to Round 1 ESRD SIR 46. Using average values for estimated vertical hydraulic conductivity, the non-pumping Darcy flux (from the artesian aquifer to the water table aquifer) was calculated to be 70 mm/year in an upward direction. After 45 years of pumping, a resultant downward flux of 19 mm/year from the water table aquifer to the well, (potential change in flux of -89 mm/year), was calculated at the location of the water source well. This calculation applies only to the location of maximum drawdown (20.99 m of drawdown; at the pumping well) under continuous groundwater withdrawal of 600 m3/d for 45 consecutive years. Predicted drawdown in groundwater level decreases as distance from the pumping centre increases. At a distance of 150 m from the pumping well, predicted drawdown results in an upward flux of 31 mm/year (potential change in flux of -39 mm/year), and at a distance of 5 km from the pumping well the predicted drawdown results in an upward flux of 67 mm/year (potential change in flux of -3 mm/year).

As the water table was found at a depth of 6 mbgl and not at ground level, as would be the case if significant artesian groundwater discharge was occurring in the area, the net upward flux of groundwater is estimate to be minimal. The use of average values for estimated vertical hydraulic conductivity (and resultant calculated Darcy flux of 70 mm/year under non-pumping conditions) over estimates the actual upward flux of groundwater. Therefore, the lower range of vertical hydraulic conductivity values for the lithology encountered during drilling (as presented in the response to Round 1 ESRD SIR 46d, Table ESRD 46-2) are considered more representative of actual conditions. The re-calculated Darcy flux is 7.0 mm/year in an upward direction from the artesian aquifer to the water table aquifer under non-pumping conditions. Using this more representative Darcy flux value of 7.0 mm/year, the calculated resultant flux at the water source well after 45 years of pumping, is 1.9 mm/year downward from the water table aquifer to the well (potential change in flux of 8.9 mm/year). At a distance of 150 m from the pumping well, the resultant flux is estimate to be 3.1 mm/year (potential change in flux of 3.9 mm/year) and at a distance of 5 km from the pumping well, the resultant flux is estimate to be 6.7 mm/year (potential change in flux of -0.3 mm/year).

It is not known whether these calculated changes in vertical groundwater flux will reach the water table aquifer, or whether the upward groundwater flux will be laterally dissipated in the intermediate confined aquifer. Taking into consideration all of the above information, groundwater withdrawal from artesian well WSW 10-22 is not predicted to have detectable impact on surface water resources.



22 SIR 40, Page 2-248 SIR 60, Page 2-322

In its response to SIR60b, Osum states …the hydrologic changes between the Baseline and Application cases are estimated, and the hydrologic uncertainty common to both is minimized. The residual or relative hydrologic changes are negligible to low and there is a low uncertainty in these estimates given the small proportion of disturbances as compared to total land area. However, in response to SIR40a, Osum indicates that creating a 3D numerical model for the hydrogeological assessment would imply unwarranted prediction reliability.

a. Reconcile the two referenced statements.

Response:

a. The two statements in the responses to Round 1 ESRD SIR 40a and ESRD SIR 60b are referring to two different models, spatial scales and discipline assessments. The statement in the response to Round 1 ESRD SIR 60b discusses the uncertainties in the hydrologic model due to available data inputs. The statement in the response to Round 1 ESRD SIR 40a discusses the use of a regional three dimensional (3D) hydrogeologic model to perform an impact assessment without calibration to existing conditions.

There is a fundamental difference between hydrogeologic and hydrologic models in how they are conceptualized and developed. Conceptualization of a hydrogeologic model is based on geological interpretation in which there is uncertainty in areas without detailed subsurface data. Conceptualization of a hydrologic model is based on physical information that can be measured and observed at ground surface. As a result there is less uncertainty due to physical characterization in a hydrologic model than in a hydrogeologic model. In addition, the water balance in a hydrologic model is based on precipitation and potential evapotranspiration, both of which are well understood in northern Alberta and the LSA. The water balance in a hydrogeologic model is based primarily on groundwater recharge, aquifer thickness, and hydraulic conductivity, which is estimated based on point data measurements and therefore have greater uncertainty. Finally, typical hydrologic water balance conditions represented by precipitation, evapotranspiration, surface runoff, and storage can be relatively consistent across the landscape in northern Alberta. Comparatively, a local hydrogeologic water balance depends on many parameters such as groundwater recharge, hydrostratigraphy, and depth of shallow and deep systems, all of which are conceptualized with a higher level of uncertainty than in a hydrologic system.

Specifically, there is limited regional and local hydrogeological data available for the Devonian strata, including the Grosmont aquifer. Limited local and regional data on the Grosmont aquifer could lead to misrepresentation of the aquifer in a regional numerical groundwater flow model and a lack of data for model calibration. Osum concluded that constructing a regional groundwater flow numerical model for the Project was not justified, especially considering that it could not be appropriately calibrated.



The hydrologic model developed for the Project hydrology assessment was calibrated to local conditions. The long-term water balance and trends were compared to regional conditions reducing uncertainty with lack of local long-term data. Although there is uncertainty associated with hydrologic conditions in the LSA, it is considered to be less than the uncertainty that is associated with a 3D groundwater model.

22 b. If prediction error is unimportant in a relative analysis, as stated in the referenced statement, explain the reason for calibrating the model against measurement data, as opposed to basing parameter assignments on science-based expectations (i.e., educated guesses).

Response:

b. Calibrating the local hydrologic model provides greater benefit of refining model parameters that influence the timing of seasonal and event hydrologic response. Calibration establishes more certainty in the seasonal and temporal water balance under baseline conditions. Therefore, prediction error is reduced in the relative analysis through the local calibration, although it will always exist given the limitations of observed inputs and hydrologic modelling.



23 SIR 54, Page 2-311 SIR 60, Page 2-322 Volume 4, Appendix 6B, Section 6B.7, Page 6B-6

In its response to SIR54d, Osum references the EIA report to acknowledge the existence of measurement error and the EIA report’s conclusion that the watershed model was validated by predictions falling within the error envelop of measured streamflow. Measurement error per se is not discussed. Osum then states …and the water balance is consistent with that estimated from regional stations. As a result, the model is considered suitable to estimate the relative impacts…

In its response to SIR60a, Osum indicates that it has more confidence in modelled water balances than in modelled low flows. Osum provides a discussion comparing simulated LSA watersheds with regional ones and posits a reason for these differences as well as the reduced confidence in modelled low flows. Osum then indicates that annual and seasonal water balance modelling will be validated using future data. Osum’s statement on Page 6B-6: The second part of the calibration involved comparing the modelled 30-year stream flow to the recorded flow in the Hangingstone, Horse, and MacKay rivers. These stations were chosen because they represent the three regional watersheds surrounding the RSA. The results of this verification exercise indicated that the modelled mean monthly unit flows, water balance, and timing of snowmelt events was consistent with the long-term regional trends.

a. Discuss how rating curve uncertainty was accounted for in HSPF model development.If empirical error was not account for, explain why.

Response:

a. Rating curve uncertainty was accounted for in the HSPF modelling. The response to Round 2ESRD SIR 24a discusses the potential uncertainty associated with rating curves and theinfluence of this uncertainty on derived streamflow hydrographs.

23 b. Provide plots comparing modelled and measured monthly and annual flows for theHangingstone, Horse, and MacKay River watersheds. Provide standard measures ofdivergence, including absolute mean square error.

Response:

b. The model domain of the HSPF model covered the area of the LSA and was not extended tothe Hangingstone, Horse, and MacKay River watersheds. Modelled long-term monthly andannual streamflow was compared with recorded data at the Hangingstone, Horse, andMacKay River stations to verify in the model’s representation of long-term trends in nearbywatersheds. Since the model does not directly simulate flow in the Hangingstone, Horse, andMacKay rivers, statistical measures of model error are not appropriate.



23 c. Provide plots comparing modelled and measured daily streamflow-exceedance curves for the Hangingstone, Horse, and MacKay River watersheds.

Response:

c. Direct calibration to the Hangingstone, Horse, and MacKay River watersheds was not completed and daily streamflow comparisons were not made. As discussed in the response to part b) above, average long-term monthly and annual flows were used as verification of long-term trends in the modelled subwatersheds.

23 d. If watershed model validation presented in the EIA report did not include streamflow modelling of the Hangingstone, Horse and MacKay River watersheds using the calibrated HSPF watershed model, explain why.

Response:

d. The goal of the hydrologic model was to establish baseline hydrologic conditions, including a water balance, and to assess potential changes due to the development of the Project in the LSA. Modelling flows in the Horse, Hangingstone, and MacKay River watersheds was not completed as it would not contribute to the goal of the assessment. Effort was focussed on the characterization of the local area and not the surrounding regional watersheds.

23 e. Given the level of model skill robustness evident in the responses to Part a) through Part d) (or its lack), discuss the reliability of the HSPF-based predictions of Sepiko Kesik effects presented in the EIA report.

Response:

e. Osum assumes that model skill refers to the ability of the model to accurately represent and simulate hydrologic conditions with the subwatersheds of the model domain. As discussed in the response to Round 1 ESRD SIR 60a, a model’s skill is verified through calibration and validation using observed information and datasets. The focus of the hydrologic model is to predict the potential environmental impacts (i.e., changes) resulting from the Project. Although there is uncertainty relating to the hydrologic response for the various hydrologic response units (i.e., land types) and watercourses modelled within the LSA, the model is considered well calibrated given the available local data and degree of assessment. The residual or relative hydrologic changes predicted for the Application Case are negligible to low and there is a low uncertainty in these estimates given the small proportion of disturbances as compared to total land area. Further, the HSPF-based predictions of the Project effects are consistent with other recent assessments such as the Blackrod Commercial SAGD Project (BlackPearl 2012), Great Divide SAGD Expansion Project (Connacher 2010),



and the Pelican Lake Grand Rapids Project (Cenovus 2011) that have been completed using HSPF for the assessment of SAGD operations.

23 f. Support the discussion with a detailed analysis of error distribution if relative-analysis compensatory cancellation of uncertainties is invoked in the response to Part e).

Response:

f. Refer to the response to part e) above.

References:

BlackPearl Resources Inc. (BlackPearl). 2012. Application for Approval of the BlackPearl Resources Inc. Blackrod Commercial SAGD Project. Report submitted to Alberta Energy Resources Conservation Board and Alberta Environment and Water. Calgary, Alberta. May 2012. http://www.blackpearlresources.ca/i/pdf/BC_SAGD_RAV1.pdf

Connacher Oil and Gas Limited (Connacher). 2010. Great Divide SAGD Expansion Project Application and Environmental Impact Assessment. Report prepared for Energy Resources Conservation Board and Alberta Environment. Calgary, Alberta. May 2010.

Cenovus Energy Inc. (Cenovus). 2011. Application for Approval of the Pelican Lake Grand Rapids Project. Report prepared for Energy Resources Conservation Board and Alberta Environment and Water. Calgary, Alberta. December 2011.



24 SIR 54, Page 2-311

In its response to SIR54d, Osum states the model represents hydrological processes within the LSA because the simulated flow was within the range of uncertainty of the field data …

a. Provide a supported discussion demonstrating the extent to which the divergence in simulated LSA streamflows fell within the error envelop of the measured flows.

Response:

a. The uncertainty in flow calculations, even with 8- to 10-stage discharge measurements per year, ranges from 10% to 20% (Harmel et al. 2006). Furthermore, this uncertainty is higher during low-flow conditions and in under-ice measurements (Pelletier 1989). SIR 2 Figure ESRD 24-1 shows the potential variation in the rating curve development for site 14-H considering a 15% variation in each manual streamflow measurement and a 1 cm variation in surveyed water levels. SIR 2 Figure ESRD 24-2 shows the difference in hydrograph estimates based on recorded water level throughout the field season.

The calibrated hydrologic model parameters result in a 15% difference between average measured and simulated streamflow at site 14-H. Comparing discharge calculated using the initial rating curve against the alternative rating curves A and B, results in a -30% and 19% flow difference, respectively (SIR 2 Table ESRD 24-1). This variation in measured streamflows ranging from -30% to 19% of the original observed measurement demonstrates that the divergence of the simulated LSA streamflows fall within the error bounds of the measured streamflows.

SIR 2 Table ESRD 24-1 Simulated and Observed Flow Comparisons

Scenario Observed Flow

(m3/s) Comparison/Simulated Flow

(m3/s) Difference in Flow

(%) Simulated 0.302 0.256 15

Rating Curve A 0.302 0.213 -30 Rating Curve B 0.302 0.360 19

References:

Harmel R.D. et al. 2006. “Cumulative uncertainty in measured streamflow and water quality data for small watersheds.” Transactions of the ASABE 49 (3): 689−701.

Pelletier P.M. 1989. “Uncertainties in streamflow measurement under winter ice conditions a case study: The Red River at Emerson, Manitoba, Canada.” Water Resources Research 25 (8): 1,857-1,867.

F:\14834\Drafting\2014\14834-CH2-14.cdr

Figure

Date: Project: Technical: Reviewer: Drawn:September 2014 A. McKay J. Kern

Sepiko Kesik

14834-CH3-14 D. Van Vliet

Disclaimer: Prepared solely for the use of Osum Oil Sands Corp. as specified in the accompanying report. No representation of any kind is made to the other parties with which Osum Oil Sands Corp. has not entered into contract.

14-H Rating Curve Uncertainty

24-1SIR2 FigureESRD 24-1

F:\14834\Drafting\2014\14834-CH2-14.cdr

Figure

Date: Project: Technical: Reviewer: Drawn:September 2014 A. McKay J. Kern

Sepiko Kesik

14834-CH3-14 D. Van Vliet

Disclaimer: Prepared solely for the use of Osum Oil Sands Corp. as specified in the accompanying report. No representation of any kind is made to the other parties with which Osum Oil Sands Corp. has not entered into contract.

2012 Hydrograph Site 14-H

24-2SIR2 FigureESRD 24-2



25 SIR 55, Page 2-314

In its response to SIR55a Osum did not provide the requested explanation of how elevation was incorporated into the hydrological response discretization exercise.

a. Explain how elevation contributed to Osum’s HRU classification scheme.

Response:

a. Elevation did not directly contribute to the hydrologic response unit (HRU) classification scheme. As discussed in Volume 4, Section 6B.4 of the EIA report, the HRUs were selected based on topographic slope, surficial geology, vegetation, and land use.

25 b. Explain the relationship of this contribution to the correction factor used to extrapolate Fort McMurray precipitation data to the LSA.

Response:

b. The same precipitation dataset was applied to the entire LSA, regardless of the elevation of a specific HRU. The Fort McMurray precipitation dataset was adjusted to the LSA by using a global multiplication factor of 1.08. Selection of this factor is based on the results of the Alberta Climate Model that accounts for both topographic and geographic precipitation variability.



26 SIR 62, Page 2-326 Volume 4, Appendix 6B, Table 6B-2, Page 6B-5

In its response to SIR62b, Osum indicates that the disconnected nature of open-water areas and lack of bathymetry data precluded their representation as reaches in HSPF. Osum also states …modelled outflow from the borrow pits will consist completely of evaporation and infiltration…Since Osum assumed zero percolation loss, it is unclear that the implied active-groundwater recharge modelling of borrow pits is appropriate.

a. Further discuss the advantages and disadvantages of using PERLND as opposed to RCHRES to represent open-water. Include in the discussion the consequent representation of evaporation and the degree to which any lack of realism adversely affected the modelling of seasonal and annual water balance.

Response:

a. The disadvantage of using PERLND as opposed to RCHRES to represent open water areas is that it is not a physical interpretation of hydrology in open water areas. As discussed in the response to Round 1 ESRD SIR 62, a specific physical representation of open water areas, and borrow pits specifically, is not feasible given the information available for this assessment. However, the conceptualization of borrow pits using PERLND is similar to Osum’s use of hydrologic response units for various types of land cover and disturbances within the HSPF model, and this approach is consistent with other hydrologic modelling assessments as listed in the response to Round 2 ESRD SIR 23. Although representing the open water areas as PERLND, as opposed to RCHRES, is a less representative of actual environmental features, the results of the model reflect Osum’s expectation of hydrologic response in those areas. The open water areas, including borrow areas, make up 1% of the LSA and these areas would have a minimal effect on the estimated water balance for the LSA. Representing open water areas as RCHRES would not change the results of the assessment.

26 b. Discuss borrow-pit bottom elevations in relation to enclosing watershed outlet elevation and its implications to the HSPF model and its predictions.

Response:

b. The depth of borrow pits can range from 3 to 10 m dependent on material, location, and state of reclamation. The average elevation of each borrow pit, HSPF watershed outlet, and difference between them is shown in SIR 2 Table ESRD 26-1. The difference in elevation between the borrow pits and the watershed outlet ranges from 14 to 200 m; therefore, the bottom elevations of the borrow pits in relation to the outlet watershed would not influence the direction of surface water or subsurface flow within each watershed. The representation of borrow pits in the model, infiltrating to the shallow groundwater system and outflowing to watercourses through interflow and groundwater outflow, is a valid model representation with respect to the goal of estimating hydrologic effects in a watershed.



SIR 2 Table ESRD 26-1 Borrow Area and Watercourse Outlet Elevations

Borrow Pit Location Borrow Pit Elevation

(m asl) Watercourse Outlet

Elevation (m asl) Difference in Elevation

(m asl) Site 20-H Watershed 564.7 549.0 15.7 Site 20-H Watershed 569.6 549.0 20.6 Site 20-H Watershed 562.8 549.0 13.7 Site 26-G Watershed 560.0 369.3 190.7 Site 20-H Watershed 570.8 549.0 21.7 Site 4-G Watershed 555.9 373.3 182.5 Site 4-G Watershed 564.5 373.3 191.2 Site 4-G Watershed 561.3 373.3 188.0 Site 18-H Watershed 572.2 543.0 29.1 Site 4-G Watershed 557.2 373.3 183.8 Site 25-G Watershed 561.6 364.9 196.8 Site 6 Watershed 567.0 366.7 200.3 Site 25-G Watershed 549.9 364.9 185.0 Site 6 Watershed 562.0 366.7 195.3 Site 25-G Watershed 556.1 364.9 191.2 Site 6 Watershed 552.3 366.7 185.6 Site 6 Watershed 537.4 366.7 170.7 Site 7 Watershed 569.0 368.1 200.9 Site 7 Watershed 555.4 368.1 187.4 Site 7 Watershed 542.1 368.1 174.0 Site 18-H Watershed 571.9 543.0 28.8



1.2.3.4. Aquatics

27 SIR 36, Page 2-146 SIR 81, Page 2-364

The responses to the questions related to setbacks are not consistent in identifying infrastructure that is within 100m of watercourses. In SIR 36, the table states that Pads 13A and 13B are within 100m of watercourses. In SIR 81, pads 9 and 12 and the operating camp are identified as within 100m of a watercourse.

a. Provide information that reconciles these statements. Resubmit Figure 81-1 highlighting all infrastructure within 100m of watercourses. Label the pads and camp. Indicate where there is uncertainty in the channel that requires ground-truthing.

Response:

a. As described in the response to Round 2 AER SIR 3, Osum’s responses to Round 1 AER SIR 36 and Round 1 ESRD SIR 81 differed based on two different interpretations of a water body.

To provide additional clarity, Osum has revised Round 1 Figure ESRD 81-1 as presented on SIR 2 Figure AER 3-1. The revised figure includes labels for all surface facilities included as part of the footprint. Mapped watercourses that have been ground-truthed and determined to have undefined channels are indicated on SIR 2 Figure AER 3-1 using dashed blue lines. Mapped watercourses that have been ground-truthed and determined to have defined channels are indicated using solid blue lines. Mapped watercourses that have not yet been ground-truthed are presented as solid light blue lines. These watercourses are located in areas that will be developed beyond the initial development phase of the Project. Ground-truthing of these mapped watercourses will be completed before construction of these surface facilities. Measured setback distances from mapped watercourses for well pads 9 and 12, and the operations camp are presented on SIR 2 Figure AER 3-2.

27 In the discussion of thermal plumes (ESRD SIRs 45, 49, 83, 86), the minimum 100m setback from a watercourse (plus the distance from the well to the edge of the pad) is part of the rationale that 150m thermal plume is not likely to interact with the surface water.

b. Discuss the risk of thermal plumes reaching watercourses if pads are sited closer than 100m.

Response:

b. As described in the response to part a) above, only well pads 9 and 12 are currently proposed with a setback of less than 100 m from a defined watercourse. The minimum watercourse setback distance for well pads 9 and 12 is 64 m and 61 m, respectively. Considering the well pad layout described in the response to Round 1 ESRD SIR 45, the total setback distance from



the well bore to the defined watercourse at well pads 9 and 12 would be 134 m and 131 m, respectively. This total setback distance of 131 to 134 m is less than the maximum predicted 150 m plume extent described in the response to Round 1 ESRD SIR 45b. Osum reiterates that the predicted 150 m plume extent from a single well bore is considered a conservative estimate, based on the assumption that the maximum linear flow velocity (10 m/year) is ten times higher than anticipated (as described in the response to Round 1 ESRD SIR 45b). As a result, Osum does not consider the risk of thermal plumes reaching watercourses to be substantially greater at well pads 9 and 12 than at other watercourses throughout the lease. As described in the response to part a) above, the mapped watercourses at these locations will be ground-truthed before construction. In addition, as described in the response to Round 2 AER SIR 27, future sustaining well pads that do not maintain a minimum 100 m setback from field-verified watercourses will be considered as likely candidates for future monitoring as the Project progresses.

Reference:

Alberta Energy Regulator (AER). 2014. Directive 056: Energy Development Applications and Schedule. May 1, 2014.





28 SIR 5, Page 2-182 SIR 40, Page 2-167

There is considerable concern regarding spill management given the numerous fish bearing water courses and the proximity to the Athabasca River and Grand Rapids Wildland Provincial Park.

The Fort McMurray First Nation has identified the importance of fish in their traditional land use and the Metis Nation of Alberta Region 5 indicated that chemical spills are of grave concern to MNA R5 Aboriginal TK Council members who stated that there is potential for fish habitat, the Athabasca River and its tributaries, to be affected.

In AER SIR 40, Osum states that Surface spills associated with a pipeline will be contained using absorbents and physical portable barriers. Sub-surface release will be identified through the installed instrumentation and monitoring programs. Groundwater wells or observation wells in proximity to the release point will be utilized for initial recovery with more intensive recovery strategies employed if required.

a. In the event that a pipeline spill was to be within a watercourse, discuss the effectiveness of the proposed mitigation in preventing migration of a spill downstream. Include how the materials that could potentially be released would be expected to behave if they entered into a watercourse.

Response:

a. The Project will require pipelines for multiple purposes, as described below.

• A buried non-saline water pipeline will connect the Project CPF to the non-saline water source wells near 10-22-086-21 W4M. A release from the non-saline water pipeline is unlikely to cause an effect since the TDS of the water will typically be below 700 mg/L (Volume 4, Section 5, Table 5.5-3 of the EIA report), which is expected to be of the same magnitude of the receiving watercourse.

• A buried saline water pipeline will connect the Project CPF to the saline water source wells near 12-22-085-20 W4M. A release from the saline water pipeline could cause an effect within watercourses that it crosses should the leak occur near or within the watercourse. Watercourse crossed by the saline pipeline include the Livock River and related headwater tributaries. The Livock River flows into the Athabasca River within the Grand Rapids Wildland Provincial Park. The saline water pipeline crossings are located approximately 10 km from the Grand Rapids Wildland Provincial Park and the Athabasca River.

The watercourses in the vicinity of the saline water pipeline are typically slow moving, allowing for easier containment in the event of a spill than in a fast flowing environment. The saline water pipeline will also be located adjacent to the Osum/Laricina Road; therefore, mobilization to the spill site would be able to occur quickly and required equipment could be



accessed without great difficulty. Therefore, spill response measures, such as containment and removal, can be instituted quickly to minimize the extent of the spill.

The saline water pipeline will contain water with an expected TDS concentration of approximately 10,000 mg/L, while the receiving watercourses will likely have a TDS concentration below 500 mg/L. Osum will install emergency shutdown valves along the length of the saline water pipeline to limit the quantity of saline water released in the event of a spill.

Since saline water contains high concentrations of chloride that can diffuse quickly through a watercourse, rapid response will be required to minimize environmental effects. The change in TDS concentration in the receiving water will depend on the volume of the spill, initial containment measures, location relative to the watercourse, and most importantly the volume of water present in the watercourse.

Typically, spills are of short duration, so a pulse of saline water would become dilute in the watercourse. In a small watercourse, the spill would occupy the majority of the volume of the water; therefore, resident flora and fauna might be affected, while the TDS concentration in a larger watercourse might become dilute, having less of an effect on aquatic biota. In either scenario, the highly saline environment would be very short in duration and will likely be diluted prior being discharged downstream into the Athabasca River.

Containment measures to minimize the spread of the saline water spill include:

• installing aquadams upstream and downstream of the spill site to contain the water if the spill occurs in slow moving water, and then temporarily pumping unaffected water around the spill containment site;

• pumping out the water contained within the aquadam; and • cycling the spill water with freshwater to dilute the overall salt content.

Aboveground pipelines will connect the Project CPF to each of the production well pads. The liquids being transported will be high-pressure steam (going from the CPF to the pads) and produced emulsion (going from the pads back to the CPF). The pressure in these aboveground pipelines will be continuously monitored at the CPF control room to allow for immediate detection of a release.

The aboveground pipelines will be located adjacent to tributaries of the Livock and Athabasca rivers, and are located closer to the Grand Rapids Wildland Provincial Park than the saline water pipeline. Some of the aboveground pipeline ROWs cross slow moving headwater streams, which become fast moving as the water flows towards the Athabasca River.

Hydrocarbons from the bitumen emulsion in the aboveground pipelines will contain a mixture of volatile light hydrocarbons, such as benzene, toluene, ethylbenzene, and xylenes (BTEX), and petroleum hydrocarbons (PHC) fraction 1 (C6-C10, excluding BTEX) and fraction 2 (C>10-C16) to heavy hydrocarbons, such as PHC fraction 4 (C>34), as well as potentially certain PAH compounds, such as naphthalene and phenanthrene. During winter



conditions, the volatilization of light hydrocarbons occurs more slowly than during summer conditions. However, it is expected that light hydrocarbons would evaporate from the water column and heavier hydrocarbon fractions would settle in the sediment and not move freely downstream.

Sorbent booms can be mobilized to prevent the lighter hydrocarbons from flowing downstream. The sorbent material would be routinely replaced to allow for continuous adsorption of hydrocarbons found in the vicinity of the release site. The substrate of affected watercourses would be manually cleaned through a combination of hydrovac and manual removal of affected vegetative debris. The containment measures described above can also be implemented to isolate the spill and pump off contaminated water. The exposed sediment can then be manually cleaned to remove residual hydrocarbons. Sampling would be completed to verify whether clean up efforts were adequate before containment measures are removed.

Most of the hydrocarbon release would be contained to the vicinity of the release point due to slow moving waters. Trace light-end hydrocarbons would likely evaporate as the affected water flows downstream into the Athabasca River.

Osum will develop an Emergency Response Plan, which will include a Spill Response Plan. As described in the response to Round 1 AER SIR 40, Osum will have an inventory of spill containment booms, berms, and absorbent materials onsite for initial response efforts, which will be deployed immediately to minimize response time and maximize recovery of spilled fluids. Osum is a member of the Western Canadian Spill Services co-operative for Area D and, as such, has access to both shared resources and expertise of the co-operative members, which are located in Wabasca and Slave Lake. Response time for these services would be from 1 to 3 hours. Osum will also coordinate with other operators in the direct vicinity of the Project to discuss sharing available resources.

28 b. Would damming be feasible? If so, would the volumes dammed be manageable? If so,describe how? Provide both low flow and high flow scenarios.

Response:

b. In the event of a release, the spill response plan will be executed and site-specific measureswill be implemented to minimize the environmental effect and protect downstream areas.Site-specific measures could potentially include damming of small watercourse segmentsdepending on anticipated flows at the spill location. Before identifying damming as apotential solution, Osum will assess potential flooding impacts in the area that may occur as aresult of the dam.

Drainage areas in the LSA subwatersheds range from 27.8 to 154.2 km2 and have estimatedmonthly streamflows ranging from less than 0.02 to 13.35 L/s/km2. Therefore, the volume andflows at a point along the natural watercourse will vary depending on upstream drainageareas, timing of the year, and climate conditions at the time of spill. Consequently, damming



a watercourse as a part of spill management plan is considered viable, but needs to be developed and assessed on a site-specific basis.

28 c. Are the groundwater wells and observation wells situated in locations that would likely be able to intercept subsurface releases from reaching watercourses on lease and from the Athabasca River?

Response:

c. The specific location of a subsurface release cannot be predicted, so groundwater monitoring will focus on areas upgradient of ecologically sensitive receptors such as the Athabasca River. The monitoring program will include wells in each of the non-saline aquifer units downgradient of the site, with wells located between the Project facilities and the Athabasca River and its tributaries. A potential subsurface release would not necessarily intersect the locations of these monitoring wells, and therefore they would not necessarily act as potential recovery wells. However, these downgradient monitoring wells would allow for timely groundwater quality data collection downgradient of the potential release (including early detection). The monitoring results from these wells (including baseline data) would also help guide investigation and remediation (including potential recovery) programs by providing groundwater quality, groundwater flow, and contaminant transport information.



29 SIR 71, Page 2-342

Figure ESRD 71-1 does not provide additional information than Figure 2.3-18. The intent of the question was to clarify the extent of the drill path in relation to surface hydrology.

a. Is it correct to interpret this figure as all subsurface pads (i.e., all the area within the red grid) will have steaming and that there will be steaming beneath all watercourses that are within the grid?

Response:

a. Osum confirms that the reviewer’s interpretation Round 1 Figure ESRD 71-1 is correct. Each of the numbered red grids that fall within the Project Area (represented by the blue line on Round 1 Figure ESRD 71-1) represents a subsurface drainage pattern that will be developed as part of the Project, and would include steam injection. The numbered red grids that fall outside the Project Area (blue line) but within the Future Project Area (yellow line) would only be developed after approval of a subsequent future amendment application, as described in the response to Round 1 ESRD SIR 1. A discussion of the potential effects of steam injection on watercourses within the Project Area was presented in the response to Round 1 ESRD SIR 73.



30 SIR 72, Page 2-344

Osum was asked to provide a discussion on the potential risk associated with bitumen emulsion expression to the surface. Both likelihood of an event and magnitude of the outcome of an event are commonly considered in risk assessment. Osum provided information regarding actions to reduce the likelihood of a release, but did not describe the potential spatial, temporal or aquatic ecological scope of a potential breach.

a. Discuss the scope of a potential breach. Include possible implications to the Grand Rapids Wildland Provincial Park, to the Athabasca River, and to the Athabasca River valley and the magnitude of effects.

Response:

a. If an aboveground pipeline spill or flow-to surface bitumen emulsion release near a well head were to occur on the terrestrial surface or in watercourses in the area, PHCs and PAHs from the bitumen would be the primary constituents of concern.

As discussed in in the response to Round 2 ESRD SIR 28a, an aboveground pipeline release would be detected by the CPF control room, prompting a shutdown of the pipeline. Such a release would likely be of short duration and limited volume.

An aboveground pipeline release to land, depending on the proximity to water, would be contained prior to the spill entering water. An aboveground pipeline release within a watercourse would likely be contained using temporary aquadams and the water would be pumped out and disposed at a licensed third-party facility.

If it were to occur, a flow-to-surface bitumen emulsion release would be expected to originate from the resource base, where pressure would cause a portion of the steamed resource to reach the surface. Such a release would occur slowly over a long period of time. Such releases can occur over land or within a watercourse. Given the anticipated duration of such an event, a long-term containment structure would likely need to be constructed and a site-specific recovery strategy would then be developed based on the release rate and location of the release.

If a flow-to-surface bitumen emulsion release were to occur on land, the release location would be contained and contaminated soils would be disposed at a licensed third-party facility. If a flow-to-surface bitumen emulsion release were to occur in a watercourse, temporary containment measures would initially be installed to contain the spill and a long-term containment structure would then be constructed. The affected reach of the watercourse would be reconstructed around the containment structure to maintain habitat connectivity upstream and downstream of the flow-to-surface bitumen emulsion release site.

The magnitude of the release depends on the amount of spill material and how quickly it is contained by the spill response efforts. PAHs are readily absorbed by fish and benthic invertebrates during exposure to contaminated food, water, and sediments (Neff 1985). PAHs can cause chronic developmental problems in fish and can adversely impact fish populations



(Whitehead et al. 2011). Negative effects associated with PAHs in sediments include decreased benthic invertebrate abundance, diversity and growth, and physiological and behavioral changes (CCME 1999).

Other potential constituents of concern from a release at the Project would be TDS (e.g., chlorides) from the buried saline water pipeline. Elevated chlorides can cause osmotic stress on organisms. This can affect the endocrine balance, oxygen consumption following long-term exposure, and overall physiological processes (CCME 2011).

Indirect effects on species may be common and potentially more significant than direct toxic effects of a constituent (Fleeger et al. 2003). Indirect or secondary effects influence species, populations, and ecosystems in a number of ways. Effects of an accidental release could be determined through a biomonitoring program. The components of a biomonitoring program would be developed after an accidental release as the magnitude, downstream extent, and long-term effects would vary based on the nature of the actual release event. Depending on the extent and nature of the spill, a biomonitoring program might include bioassays to determine the toxicity of the water or sediment, or fish tissue analysis to determine if resident fish species are stressed from the spill.

If an aboveground pipeline spill were to occur adjacent to fast flowing watercourses in the vicinity of the Grand Rapids Wildland Provincial Park, it is expected that the volume of fluid that could be recovered as part of the initial spill response would be decreased. However, as described in the response to Round 2 ESRD SIR 28, such a spill is expected to be of limited volume and short duration. Osum would monitor the effects of the release as described above, but expects that the mitigation measures described above in the response to Round 2 ESRD SIR 28 would help mitigate the residual environmental effects of a release.

30 If a surface expression of bitumen were to occur at the Sepiko Kesik project, the main effect would be the potential coating of aquatic vegetation along the watercourse shoreline and the associated flora/fauna. In this event, Osum’s remedial action would focus on removing free-phase bitumen emulsion from the watercourse and associated shoreline, similar to the remedial actions taken by Canadian Natural at the Primrose project.

The topography and hydrology at Osum Sepiko Kesik are different than at CNRL Primrose. The Sepiko Kesik project has several tributaries flowing directly into Athabasca River and more dramatic changes in elevation.

b. Discuss the effectiveness of remedial actions proposed at the Osum site considering flow.

Response:

b. As discussed in the response to part a) above, a flow-to-surface bitumen emulsion would likely be released slowly. In groundwater, the impacts of a bitumen emulsion release would be dissolved phase concentrations of the bitumen emulsion constituents. The solubility of



bitumen emulsion in water is low and dissolved impacts would take months to years to reach significantly elevated levels downgradient of the release, even in a faster flowing environment. Therefore, the containment measures discussed in part a) above and in the response to Round 2 ESRD SIR 28 can be implemented.

Should coating of aquatic vegetation along the watercourse shoreline occur due to the release, affected vegetation and affected substrate would be removed. Biomonitoring, as described in part a) above, would then be completed to determine the effectiveness of the remedial activities and revegetation would be completed if determined to be feasible. All fauna affected by the release would be cleaned and rehabilitated, if possible, and wildlife deterrent measures would be instituted for the duration of containment and remediation activities.

References:

Canadian Council of Ministers of the Environment (CCME). 1999. Canadian Sediment Quality Guidelines for the Protection of Aquatic Life: Arsenic. Canadian Environmental Quality Guidelines. Winnipeg, Manitoba.

Canadian Council of Ministers of the Environment (CCME). 2011. Canadian water quality guidelines for the protection of aquatic life: Chloride. Canadian Environmental Quality Guidelines. Winnipeg. Manitoba.

Fleeger et al. 2003. “Indirect effects of contaminants in aquatic ecosystems.” Science of the Total Environment 317(1-3): 207-233. December 30, 2003.

Neff J.M. 1985. “Polycyclic Aromatic Hydrocarbons.” In: Rand G.M. and S.R. Petrocelli. 1985. Fundamentals of Aquatic Toxicology. pp. 416-454.

Whitehead et al. 2011. “Genomic and physiological footprint of the Deepwater Horizon oil spill on resident marsh fishes.” Proceeding of the National Academy of Sciences of the United States of America 109(50): 20298-20302.



Terrestrial 1.2.4

1.2.4.1. Conservation and Reclamation

31 SIR 109, Page 2-413 Volume 4, Section 5.6.1, Page 5-176

In response to SIR109c, Osum states that it expects groundwater inflow to balance an otherwise calculated 70 mm/yr water balance deficit. However, in acknowledging on Page 5-176 that the nominal water table is within 2 m of the surface, Osum also states However to the east of the CPF, due to the prevalence of deep surface topography drainage features (i.e. coulees and river valleys), it is expected that the undifferentiated Quaternary sediments may only have partial saturation where they exist in proximity…. Osum then states In some cases, perched aquifer conditions may exist…

a. Describe and discuss the expected or assumed range in borrow pit elevations at closure.

Response:

a. The borrow excavations were assumed to have an average excavation depth of 10 m; however, the excavation depths will vary based on site-specific conditions, which will be better understood after geotechnical investigations are undertaken closer to the time of construction (refer to the response to Round 1 ESRD SIR 168). The elevation of soil in the bottom of reclaimed, partially refilled borrow pits at closure was assumed to generally range in elevation from 3 to 7 m below the grade of the surrounding reclaimed upland portion. The quantities of fill that will be removed during reclamation and returned to the borrow areas are uncertain (refer to the response to Round 1 ESRD SIR 109).

31 b. Discuss the potential consequences of proximity to the referenced under-drainage to borrow-pit water balance.

Response:

b. The effect of under-drainage on borrow pit water level is mainly dependent on the local, shallow water table elevation; the borrow pit water level will equalize to the local water table elevation over time. The length of time that runoff water will remain in a borrow pit depends on the perviousness of the material on the bottom and along the sides of the borrow excavation. The higher the perviousness, the higher the infiltration rate and the faster the water level will equalize to the shallow water table elevation.

Where a borrow pit is located relatively close to a river valley under-drainage, the local water table may be near or below the bottom of the borrow pit and groundwater would not provide an inflow to the borrow pit, resulting in a shallow borrow water level or dry conditions. As the relative distance of a borrow pit from a river valley increases, this effect would decrease.



As described in the response to Round 2 ESRD SIR 33a, site-specific conditions at borrow pit locations will be better understood after geotechnical investigations are completed.

31 c. Discuss the potential consequences of perch water-table conditions on the waterbalance of affected borrow-pits.

Response:

c. Where a borrow pit is located relatively close to or in an area with a perched water table, theborrow pit water level would equalize with the water table in the short-term and theresponse to Round 1 ESRD SIR 109c would be applicable in the long-term.



32 SIR 113 Page 2-418 Volume 2, Section 8.3.4, Table 8.3-1, Page 8-11 Volume 2, Section 8.3.4, Page 8-12

In response to SIR113a Osum provides LFH/shallow O depths and deep peat depths (i.e., Table ESRD 113-1). The table indicates that Osum will salvage peat horizons found within the CPF and borrow areas. In response to SIR 113b Osum provides the soil map unit breakdown (area) for each facility (Table ESRD 113-2) and an explanation of how these topsoil material volume estimates were calculated. Osum’s response to SIR 113c states Osum recognizes that changes in salvaged topsoil/peat volumes will vary according to variation in thicknesses of low bulk density organic and higher bulk density mineral A horizons.

Based on the information provided by Osum in response to SIR113a-c, the material balance provided in Table 8.3-1 of the EIA report appears to be inaccurate in regard to the volume of deep peat Organic soil anticipated from the borrow areas and CPF. Using the borrow areas in Table ESRD 113-2 as an example, the stated area of the HLY-2 soil unit is 7.7 ha, while in Table ESRD 113-1, the stated average peat salvage depth for HLY-2 is 86 cm. If these values are correct, a minimum volume of approximately 66,000 m3 peat is anticipated, not including the deep peat inclusions within the DOV-1, KNS-1,STP-1 and STP-2 units also present within the borrow areas. In comparison to this, Table 8.3.1 indicates a deep peat organic volume of 52,175 m3.

While Osum recognizes that changes in salvaged topsoil and peat will vary according to thicknesses of low bulk density horizons, they do not provide a revised material balance or further explain how they arrive at a replacement volume of 80% of in situ volume. It might be inaccurate to suggest (as done on Page 8-12) that actual replacement depths will achieve a minimum of 80% of the topsoil stripping depths, given the relatively high proportion of organic material within the soil map units (e.g., ALG-1, BMT-1, STP-1).

a. Update the material balance, using the information provided in Table ESRD 113-2. Include the breakdown of anticipated volumes for each soil unit present within each facility type.

Response:

a. The reclamation materials breakdown by material volumes by soil map units within facility types has been updated (SIR 2 Table ESRD 32-1) for the minor footprint change described in the Round 1 Project Update. SIR 2 Table ESRD 32-1 includes the salvaged topsoil (LFH/ shallow peat with A horizon) and the deep peat (greater than 40 cm) for the 7.7 ha of HLY-2 within borrow areas, which was erroneously excluded from the reclamation materials balance presented in Volume 2, Section 8.3.4, Table 8.3-1 of the EIA report. The depths of topsoil salvage and the depths of replacement topsoil materials for the mineral soil map units are the same (Volume 2, Section 8.3.4, Table 8.3-1 of the EIA report).



The volume of deep peat in the HLY-1, HLY-2, MRN-1, and MRN-2 Organic map units, where deep peat will be extracted (borrow areas and CPF) was calculated using the proportion of the Organic soil series in each soil map unit. The proportion of the mineral soil series inclusion in the same Organic soil map units was used in calculating a topsoil material volume. The volume of deep peat in the Steepbank (STP)-1 and STP-2 soil map units, where deep peat will be extracted in borrow areas, was calculated based on the proportion of the Organic soil series in each STP map unit. The proportion of the applicable mineral soil series in STP-1 and STP-2 was used to calculate the topsoil material volumes. The response to Round 1 ESRD SIR 133 provides additional description of the topsoil and the peat salvage depths.



SIR 2 Table ESRD 32-1 Estimated Topsoil Reclamation Material Balance by Soil Map Units within Facility Component Type

Project Facility Type(a)

Soil Map Unit and Extent of Soil Salvage

LFH/ Shallow Peat With A horizon (Topsoil)

Deep Peat (Organic soil)

Total Surface Reclamation

Material Volume

(m3)

Replacement Topsoil/Peat Materials

Reclamation Balance (m3)

SMU Name Area (ha)

Salvage Depth (m)

Material Volume (m3)

Salvage Depth (m)

Material Volume

(m3)

Replaced Material

depth (m)

Estimated Volume (b)

(m3) Borrow Areas DOV-1 72.2 0.26 187,720 - - 187,720 0.26 46,930 140,790 Borrow Areas KNS-1 237.9 0.25 594,825 - - 594,825 0.25 148,706 446,119 Borrow Areas KNS-2 74.0 0.23 170,200 - - 170,200 0.23 42,550 127,650 Borrow Areas KNS-3 34.6 0.24 82,944 - - 82,944 0.24 20,736 62,208 Borrow Areas STP-1 12.1 0.36 43,507 - - 43,507 0.36 10,877 32,630 Borrow Areas STP-1 4.0 - 0 0.82 33,033 33,033 0.82 8,258 24,775 Borrow Areas STP-2 0.3 0.25 608 221 829 0.25 207 622 Borrow Areas HLY-2 6.6 - 0 0.86 56,625 56,625 0.86 14,156 42,469 Borrow Areas HLY-2 1.1 0.21 2,208 - - 2,208 0.21 552 1,656 Borrow Areas MRN-1 1.8 - 0 0.7 12,977 12,977 0.70 3,244 9,733 Borrow Areas MRN-1 0.6 0.21 973 - - 973 0.21 243 730 Borrow Areas MRN-2 0.7 - 0 0.92 7,263 7,263 - 1,816 5,447 Borrow Areas MRN-2 0.2 0.21 184 - - 184 0.21 46 138 Borrow Areas Disturbed 2.3 0.15 3,527 - - 3,527 0.15 882 2,645 CPF KNS-2 82.2 0.23 169,575 - - 169,575 0.23 169,575 0 CPF HLY-2 0.7 - 0 0.86 6,132 6,132 0.86 6,132 0 CPF HLY-2 0.1 0.21 264 - - 264 0.21 264 0 CPF Disturbed 0.5 0.15 736 - - 736 0.15 736 0 Main Camp HLY-2 5.9 - 0 - - 0 - 0 0 Main Camp HLY-2 1.0 0.21 2,171 - - 2,171 0.21 2,171 0 Main Camp STP-2 8.1 0.25 20,305 - - 20,305 0.25 20,305 0 Main Camp STP-2 0.9 - 0 - - 0 - 0 0 Main Camp Disturbed 0.4 0 0 - - 0 0.32 1,335 -1,335 Operations Camp KNS-2 6.2 0.23 14,348 - - 14,348 0.23 14,348 0



SIR 2 Table ESRD 32-1 Estimated Topsoil Reclamation Material Balance by Soil Map Units within Facility Component Type (continued)






Material Volume

(m3)



SMU Name Area (ha)

Salvage Depth (m)


Salvage Depth (m)

Material Volume

(m3)

Replaced Material

depth (m)


(m3) Production Well Pads ALG-1 36.9 0.24 144,287 - - 144,287 0.22 144,287 0 Production Well Pads DOV-1 44.7 0.26 116,274 - - 116,274 0.26 116,274 0 Production Well Pads KNS-1 152.2 0.25 380,395 - - 380,395 0.20 380,395 0 Production Well Pads KNS-2 26.0 0.23 59,724 - - 59,724 0.23 59,724 0 Production Well Pads KNS-3 35.7 0.24 85,744 - - 85,744 0.33 85,744 0 Production Well Pads STP-1 0.9 0.36 2,305 - - 2,305 0.15 2,305 0 Production Well Pads STP-2 41.4 0.25 93,177 - - 93,177 0.19 93,177 0 Production Well Pads HLY-1 6.2 0.21 3,233 - - 3,233 0.32 19,705 -16,472 Production Well Pads HLY-2 11.3 0.21 24,002 - - 24,002 0.32 243,828 -219,826 Production Well Pads MLD-2 2.3 - - - - 0 0.32 7,369 -7,369 Production Well Pads MRN-1 12.2 0.21 25,342 - - 25,342 0.32 193,078 -167,736 Production Well Pads MRN-2 6.0 0.21 12,625 - - 12,625 0.32 192,382 -179,757 Production Well Pads Disturbed 0.1 0.15 190 - - 190 0.17 250 -60 Access Road ROWs ALG-1 8.9 0.24 21,378 - - 21,378 0.24 21,378 0 Access Road ROWs BMT-1 1.5 0.23 3,558 - - 3,558 0.23 3,558 0 Access Road ROWs DOV-1 8.9 0.26 23,243 - - 23,243 0.26 23,243 0 Access Road ROWs KNS-1 29.2 0.25 73,045 - - 73,045 0.25 73,045 0 Access Road ROWs KNS-2 5.1 0.23 11,612 - - 11,612 0.23 11,612 0 Access Road ROWs KNS-3 6.8 0.24 16,335 - - 16,335 0.24 16,335 0 Access Road ROWs aaMNS-1 0.4 0.26 995 - - 995 0.26 995 0 Access Road ROWs STP-1 2.7 0.36 7,410 - - 7,410 0.36 7,410 0 Access Road ROWs STP-2 9.7 0.25 21,852 - - 21,852 0.25 21,852 0 Access Road ROWs HLY-1 7.0 - - - - 0 22,262 -22,262



SIR 2 Table ESRD 32-1 Estimated Topsoil Reclamation Material Balance by Soil Map Units within Facility Component Type (continued)






Material Volume

(m3)



SMU Name Area (ha)

Salvage Depth (m)


Salvage Depth (m)

Material Volume

(m3)

Replaced Material

depth (m)


(m3) Access Road ROWs HLY-1 2.3 0.21 4,870 - - 4,870 0.21 4,870 0 Access Road ROWs HLY-2 13.7 - - - - 0 0.32 43,839 -43,839 Access Road ROWs HLY-2 2.4 0.21 5,077 - - 5,077 0.21 5,077 0 Access Road ROWs MLD-1 3.3 - - - - 0 0.32 10,663 -10,663 Access Road ROWs MLD-2 0.6 - - - - 0 0.32 1,886 -1,886 Access Road ROWs MRN-1 21.6 - - - - 0 0.32 69,039 -69,039 Access Road ROWs MRN-1 5.4 0.21 11,327 - - 11,327 0.21 11,327 0 Access Road ROWs MRN-2 9.8 - 0 - - 0 0.32 31,371 -31,371 Access Road ROWs MRN-2 1.1 0.21 2,287 - - 2,287 0.21 2,287 0 Access Road ROWs SC-1 1.2 - - - - 0 0 0 0 Access Road ROWs Disturbed 3.8 0.15 1,995 - - 1,995 0.26 9,853 -7,858 Salt Cavern KNS-1 10.0 0.25 23,046 - - 23,046 0.25 23,046 0 Water Source Well KNS-3 0.6 0.24 1,536 - - 1,536 0.24 1,536 0 Water Source Well STP-1 0.6 0.36 1,727 - - 1,727 0.36 1,727 0 Water Source Well MRN-1 0.5 - - - - 0 0.32 2,240 -2,240 Water Source Well MRN-1 0.1 0.21 269 - - 269 1.54 269 0 Water Source Well Disturbed 0.8 0.15 1,199 - - 1,199 0.15 1,199 0 Total( c) 2,474,153 116,251 2,590,403 2,474,507 115,896

(a) Soil volumes for pipeline ROWs is not included because soil replacement is the end procedure in buried pipeline construction and there is no soil disturbance for aboveground pipeline construction. Also, there will be no soil salvage within the septic field or the power line ROWs.

(b) A thickness of 0.32 m was used for calculating the reclamation material volume for the placement of surplus topsoil materials from borrow areas on the access roads and the production well pads that will be reclaimed in peatlands.

(c) Total value might not equal the sum of the individual values, due to rounding.



The summary of the reclamation material balance by facility component type is presented in SIR 2 Table ESRD 32-2.

SIR 2 Table ESRD 32-2 Estimated Topsoil Reclamation Material Balance for the Project Update

Facility Type (a)

Extent of Facility

Type (ha)

LFH/Shallow Peat/Topsoil

(m3)

Deep Peat Organic

Soil (m3)


Material (m3)

Surface Reclamation

Material to be Replaced(b)

(m3)

Balance (m3)

Borrow areas (c) 448.4 1,086,696 110,119 1,196,815 299,204 897,611

CPF 83.6 170,575 6,132 176,707 176,707 0

Main Camp 16.3 22,476 0 22,476 23,812 -1,336

Operations Camp 6.2 14,348 0 14,348 14,348 0

Production Well Pads 572.6 947,297 0 947,297 1,538,518 -591,221 Access road ROWs 148.8 204,984 0 204,984 391,902 -186,918 Salt Cavern 10.0 23,045 0 23,045 23,045 0 Water Source Well 2.7 4,731 0 4,731 6,971 -2,240

Total( d) 2,474,153 116,251 2,590,403 2,474,507 115,896

(a) Soil volumes for pipeline ROWs are not included because soil replacement is the end procedure in buried pipeline construction and there is no soil disturbance for aboveground pipeline construction. Also, there will be no soil salvage within the septic field or the power line ROWs.

(b) A thickness of 0.32 m was used for calculating the reclamation material volume for the placement of topsoil materials from borrow areas on the reclaimed access roads and the production well pads in peatlands.

(c) Area includes total of all borrow area footprint. The surplus is the result of replacement of 25% of the salvaged topsoil volume on the areas reclaimed to upland around the reclaimed water body and associated shoreline area of the borrow pits.

(d) Total value might not equal the sum of the individual values, due to rounding.

32 b. Provide contingencies if less than an 80% replacement depth is attained due to the relatively high proportion of Organic material within the mineral soil map units (e.g., ALG-1, BMT-1, and STP-1).

Response:

b. As indicated in Volume 2, Section 8.3.4 of the EIA report, all salvaged soil materials will be replaced at the time of reclamation. Where replacement topsoil volumes may be reduced as a result of shrinkage of salvaged peat, the surplus topsoil and peat materials from the borrow areas will be available for replacement during reclamation should they be needed to achieve the reclamation objectives.



33 SIR 114, Page 2-424 Volume 2, Section 8.9.2, Table 8.9.2, Page 8-27

In its response to SIR114a, Osum indicates that the total area of unclassified land capability at closure is attributed both to borrow areas reclaimed to water and to unclassified Baseline Case disturbance restored to an equivalent land capability in surrounding areas.

a. Update Table 8.9-2 to include separate categories for existing disturbance and water.

Response:

a. Volume 2, Section 8.9.2, Table 8.9-2 of the EIA report has been updated (SIR 2 Table ESRD 33-1) to include categories for existing soil disturbance and water. The areas presented in SIR 2 Table ESRD 33-1 have also been updated for the minor footprint change described in the Round 1 Project Update.

SIR 2 Table ESRD 33-1 Predicted Changes in Land Capability for Forestry in the Terrestrial Local Study Area Following Reclamation

Forest Ecosystems Land Capability Class

Baseline Case Post-Reclamation Closure Scenario

Change at Closure Due to the Project (a)

Area (ha)

% of LSA Area (ha) % of LSA Area(b)

(ha) % of LSA

class1 and class 2 0 0 0 0 0 0 class 3 (low) 3,728 30.3 3,312 27.0 -416 -3.4 class 4 (conditionally productive) 247 2.0 249 2.0 2 0 class 5 (non-productive) 7,662 62.4 7,644 62.2 -18 -0.1 Unclassified (water) 3 <0.1 451 3.7 448 3.6 Unclassified (stream channel) 457 3.7 457 3.7 0 0 Unclassified (soil disturbance) 188 1.5 171 1.4 -17 -0.1 Total (c) 12,284 100.0 12,284 100.0 (a) Change at closure is calculated as the difference between the Baseline Case and the Closure Scenario. (b) Value might not equal the difference of the individual values, due to rounding. (c) Total value might not equal the sum or difference of the individual values, due to rounding.

33 b. Provide the anticipated land capability breakdown for the existing baseline disturbance at closure.

Response:

b. The anticipated land capability classes at closure, for the baseline soil disturbances within the updated Project footprint that Osum will reclaim, are presented in SIR 2 Table ESRD 33-2. The unclassified Baseline Case soil disturbance areas within the updated Project footprint will be restored to land capability classes equivalent to the pre-disturbance conditions.



SIR 2 Table ESRD 33-2 Summary of Closure Land Capability Classes of the Baseline Case Soil Disturbances in the Project Footprint

Type of Baseline Case Soil Disturbance Within Project

Footprint

Anticipated Land Capability Classification (LCC) for Forestry of Reclaimed Soil Disturbance at Closure

LCC Class 3 LCC Class 4 LCC Class 5 Unclassified Area (ha) Area (ha) Area (ha) Area (ha)

Development, Industrial Facilities 0.6 0 4.4 0 Miscellaneous Lease 0 0 0 0 Well Sites 2.0 0.4 1.2 2.4(a) Roads and Rights-of-way 0.4 1.5 3.8 0 Total (b) 3.0 1.9 9.4 2.4

(a) Represents the reclamation of a Baseline Case well site in a borrow area to water at closure. (b) Total value might not equal the sum of the individual values, due to rounding.



1.2.4.2. Wildlife

34 SIR 128a, Page 2-462

Osum states Osum does not currently have any plans to add to the existing seismic grids. However, Osum may conduct 4D seismic in select areas where investigation of well performance is required to understand operational or reservoir issues. No additional seismic lines will be required to understand operational or reservoir issues. Osum has indicated plans to construct the Project in two phases of 4,770 m3/d (30,000 bpd). Both phases were included as part of the assessment and Project footprint.

2D seismic is present throughout the entire LSA, and 3D and 4D seismic exploration has been completed within portions of the LSA (i.e., the east side of Twp 85, Rge 19 W4M and the west side of Twp 85, Rge 18 W4M; Volume 1, Section 2.1, Figure 2.1-3). 3D and 4D seismic exploration has not been completed within the east side of Twp 85, Rge 18 W4M or within Twp 86, Rge 18 W4M.

a. Provide evidence supporting the statement that no further seismic grids will be added to the landscape for Project development. If evidence cannot be provided to support this statement, describe in detail, all existing, planned and likely-to-occur exploration activities, including all 2D, 3D and 4D seismic and all core hole, exploratory and monitoring wells. For exploration activities that have not yet been spatially articulated but that are likely to occur, provide quantitative predictions of the footprint based on known exploration footprints from other in-situ projects in the region. Include, but do not limit the response to:

iii. grid spacing; iv. line widths; v. bin size; vi. extent/area of coverage; vii. linear density (km/km2); viii. frequency/periodicity of activity; ix. equipment/techniques to be used; x. density of core holes, exploratory and monitoring wells; and xi. schedule and duration of activities.

Response:

a. No further seismic grids will be added to the landscape for the Project Area because the 3D seismic dataset that was acquired to delineate the Project Area was planned with a sufficient spatial density to serve as a base dataset for future 4D seismic investigations. Future 4D seismic investigations would involve acquiring 3D seismic datasets (referred to as 4D monitor datasets) over the areas being developed using the exact same surface grid as the original base dataset. The purpose of a 4D seismic investigation is to determine changes in the subsurface attributable to production, so it is critical to minimize any change in acquisition geometry; preferably the monitor 4D seismic programs are carried out with no change to the



original acquisition geometry. This technique has been applied for the 4D monitoring of the Saleski JV Pilot Area shown on Figure 2.1-3 (Volume 1 of the EIA report) and will be applied to future 4D monitoring datasets at the Project.

iii, iv, v) As described in the response to part a) above, future 4D monitor seismic surveys will be acquired using the exact same surface grid as the original base dataset. The nominal acquisition geometry for future 4D monitor seismic surveys will therefore be the same as the base seismic survey, which is described in detail in Volume 1, Section 2.1.3 of the EIA report and shown on Figure 2.1-4 (Volume 1 of the EIA report). Receivers were laid out along the north-south grid lines every 20 m and sources were laid out in east-west grid lines every 20 m. The sources and geophones were laid out on grid lines that were set nominally 80 m apart. The number of shot holes was limited within the Goose Coulee and to make up for the loss of shot redundancy the number of receiver locations was increased by halving the receiver line interval. Overall this geometry gives a sub-surface natural bin size of 10 × 10 m.

vi, vii) The surface extent of future 4D monitor surveys will be determined by the actual subsurface area from which bitumen is being produced and will be a small spatial ‘patch’ of the original 3D grid. To properly image the reservoir using conventional seismic processing techniques requires a margin extending around the target of approximately 200 m. The linear density (km/km2) will be determined by the 4D ‘patch’ being acquired, using this same grid geometry.

viii) The frequency of 4D monitor acquisition is dependent on how often quantifying subsurface change is useful for ensuring efficient subsurface resource recovery. The frequency of acquisition is likely no more than twice per year and more likely just once per year. An example is the Saleski JV Pilot, which has acquired 4D monitor datasets just once per year.

ix) The equipment used for recording a 4D seismic monitor survey using the existing grid of the original 3D survey is also similar to what was used to record the original survey. Depending on how much vegetation regrowth has taken place, mulching machines may be deployed to clear grid lines and make them safe for personnel walking on foot. Snowmobiles may be used to access the grid lines. Tracked shot-hole rigs may be used to drill shot holes to a depth of 6 m and set the source charge of ¼ kg dynamite. Geophones are carried and deployed by hand; the current recording technology uses a three-component micro-electro-mechanical system device about the size of a golf-ball with a spike approximately 10 cm long, which is pressed into the ground. The geophones are connected to fiber-optic cables, which connect to a seismic recorder, usually located near the survey.

When the source locations are all drilled and loaded, and the geophones are all connected to the recorder, the ‘shooter’ (personnel responsible for discharging the shot) connects the charge leads to a detonator and fires the shot. The resulting seismic response is recorded from all the geophones. When all the seismic records have been recorded, the seismic crew walks the recording line to recover the geophones.



x) For delineation purposes, the following delineation wells will need to be drilled in the Project Area (85-18W4) before development can start (the Development Area is already delineated with four wells per section).

Section Number of Delineation Wells 33 1 18 3 17 4 16 4 9 4 8 3 7 3 6 4 5 3 4 4

Total 33

For initial development drainage boxes (five pads in total), Osum plans to use a minimum of five reservoir observation wells (average of one observation well per pad), except where precluded by surface constraints. For subsequent drainage boxes this will be reassessed based on learnings from and utility of these wells.

A typical delineation or observation well site is approximately 60 m × 90 m (0.54 ha), so an overall disturbance estimate for the 33 required delineation wells and 5 observation wells (38 wells) is 20.5 ha.

xi) The duration of the seismic activities is highly dependent on the number of personnel and machines deployed, but it is reasonable to estimate how long any future 4D monitor survey might take based on the schedule used to acquire the original 3D seismic dataset that will be used as the ‘baseline’ survey, and the actual time it has taken to acquire 4D monitors over the nearby Saleski JV Pilot.

The original 3D that will be used for the baseline survey was acquired during December 27, 2009 through March 27, 2010, to complete the 34 km2 dataset. Any future 4D monitors will take considerably less time to acquire as source and receiver lines have already been prepared and the area to be imaged will be a small sub-set of this original 3D area. Osum estimates that the largest 4D monitor might be approximately 5 km2, which could be acquired in approximately 2 weeks. Conversely, the Saleski JV Pilot offers a practical example of the smallest 4D monitor acquired with a very small crew: the 1.12 km2 area takes less than 1 week to drill and load all the source locations, and 3 days to deploy the geophones, record the seismic data, and recover the geophones.

In summary, the total duration of the field activities for acquiring future 4D surveys, including surveying, drilling and loading source locations, deploying geophones, recording seismic records, and picking up the geophones will range from 1 to 2 weeks.



34 b. Provide a figure(s) illustrating all existing, planned and likely-to-occur Project-relatedexploration activities.

Response:

b. The initial five development drainage boxes are displayed in black on SIR 2 FigureESRD 34-1. The drainage boxes will be drilled in sections 19 to 21 and 30 in 85-18 W4M.A minimum of five wells will be drilled as reservoir observation wells for these pads.

The delineation wells, which will be drilled, will be located in sections 4 to 9, 16 to 18, and 33as stated in the response to part a(x) above. The specific locations of the additional delineationwells are unknown but will require four wells per section. Where practical, Osum will aim toco-locate observation wells on former core hole sites. Any future exploration programs willbe in compliance with the Code of Practice for Exploration Activities (or the currentregulations in place at the time), and Osum will assess the effects of those explorationprograms at that time.

The current Project-related exploration disturbances are presented on Figure 2.1-3, whichshows the full 3D and 2D seismic outlines of the Project Area (Volume 1 of the EIA report),and on Figure 2.1-2, which shows the abandoned and active wells within the Project AreaVolume 1 of the EIA report). 3D seismic covers the entire Project Area and 39 wells havebeen drilled to date. This exploration disturbance was considered as part of the Baseline Caseassessments for vegetation, wildlife and biodiversity as presented in Volume 5 of the EIA.

34 c. Provide the data, information sources and assumptions that were used to support thepredictions made.

Response:

c. Osum assumes that no further disturbances will be made by shooting 4D seismic. 3D seismichas already been shot across the full Project Area and this will be re-used for the 4D seismic.

Osum assumes that delineation of four wells per section will be necessary to fulfill delineationrequirements, and that reservoir and caprock observation wells will be needed for monitoringpurposes. Where feasible, observation wells will be placed on existing disturbances.



34 d. Discuss the potential impacts that the planned and likely-to-occur exploration activities will have on terrestrial resources, including wildlife, vegetation (including rare plants, old growth forest and traditional use plants), and biodiversity. Revise the Application Case and Planned Development Case assessments to include these planned and likely-to-occur activities and discuss how the inclusion of these activities changes the impact ratings. Identify assumptions and areas of uncertainty.

Response:

d. As described in the response to part b) above, the specific locations of the 33 planned delineation wells and 5 planned observation wells are currently unknown. As a result, an evaluation of effects on vegetation (including rare plants, old growth forest and traditional use plants) and on biodiversity cannot be completed at this time. Once the locations are confirmed, the planned exploration activities will be permitted through the Public Lands Act.

The potential impacts of known exploration activities on wildlife habitat availability, habitat connectivity, and mortality were included in the EIA. Wildlife is predicted to be similarly affected by the Project with the additional exploration activities for the following reasons:

• no further seismic grids will be added to the landscape for the Project; • the drilling program will take place over a short time period during winter, which is

outside the breeding season and restricted activity periods for most species of wildlife; • for the 33 delineation wells, no permanent dispositions are typically required and the

wells will be reclaimed upon completion of exploration activities; and • the disturbance is minimal and estimated at 20.4 ha, representing approximately 1.2%

of the 1,655 ha Project footprint.

Given the small amount of habitat disturbed and the short-term nature of 4D seismic activity, the impact ratings for wildlife remain unchanged as those provided in Volume 5, Section 11.6 of the EIA report. General strategies to mitigate the impact of exploration activities on wildlife are provided in the response to part e) below.

34 e. Provide mitigation measures that will be implemented by Osum to minimize the impacts of the planned and likely-to-occur exploration activities on terrestrial resources.

Response:

e. All operations will be in accordance with the Code of Practice for Exploration Operations, the applicable AER guidelines and the Public Lands Act. The proposed mitigation measures are consistent with best management practices used throughout industry. Proposed mitigations are as follows:

• use existing disturbances and existing access where practical;



• follow speed restrictions on roads operated by other companies and impose speed restrictions on Osum operated roads to improve road safety and reduce risks of wildlife mortality;

• prohibit employees and contractors from having firearms onsite or at camp; Osum will prohibit hunting near active facilities for safety reasons, which is consistent with Alberta hunting regulations;

• prohibit workers from feeding wildlife, to prevent habituation; • dispose of garbage in an approved manner; • freeze access routes down for winter operations; • freeze well sites down to prevent damage and support the necessary equipment; • reclaim leases concurrently with operations as the core holes are drilled and

abandoned; depending on the preference of AER personnel, the area will be left to revegetate naturally (the strategy may involve other measures determined in cooperation with AER to ensure successful reclamation); if required, seedlings will be planted in the summer season;

• use native seed to re-establish the vegetation; • spread coarse woody debris, depending on the revegetation assessment of the

individual well sites; and • maintain a 100 m setback from all watercourses and riparian areas.

T:\GI

S\Sale

ski\M

XDs\E

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pikoK

esik\

SIRS

\ESR

D_Fig

ure_3

4-1_1

4092

4.mxd

Date: Project: Drawn:Reviewer:Technical:

FigureNAD 1983 UTM Zone 12N

24 Sep 2014 14834-514Disclaimer: Prepared solely for the use of Osum Oil Sands Corp. as specified in the accompanying report. Norepresentation of any kind is made to other parties with which Osum Oil Sands Corp. has not entered into contract.

A.TomlinsonQ. Tao

FIRST FIVE SUBSURFACE PADSIN THE GROSMONT C

A.Tomlinson

PowerlineRoadWinter RoadPipelineWatercourseWater BodyWildland Park

Sepiko Kesik Project AreaSepiko Kesik Future Project AreaSepiko Kesik Project Lease AreaFirst Five Subsurface PadsSample TracjectoryFuture Subsurface Pads

Grosmont C Reservoir Isopach Colour GradientMax: 21

Min: 0 (m)

07-11

1

3

2 610

07-08

R17W4R18W4R19W4

T86

T84

T85

3850

00

390000 395000

6245

000

6250

000

6255

000

Sepiko Kesik

Reference: Data obtained from AltaLIS and IHS, used under license.

W

1:45,000

1 0 1Kilometres SIR 2

ESRD 34-1



35 SIR 129a, Table ESRD 129-1, Page 2-467

The 11th row in Table ESRD 129-1 identifies the Maximum habitat patch size in caribou range, and more than 500 m from development. Within the RSA, it appears that patch size will increase from 10,735 at Baseline and Application to 12,214 at the Planned Development Case. Assuming that additional habitat will be lost at the Planned Development Case, the maximum patch size would be expected to decrease in size rather than increase.

a. Provide the rationale for this increase in patch size.

Response:

a. Osum understands that the table referenced in the question should refer to TableESRD 130-1. There was a GIS error in the patch size calculations provided in the response toRound 1 ESRD SIR 130, Table 130-1 due to the combination of adjacent areas of modelledhigh and medium quality caribou habitat. This error resulted in an inaccurate representationof patch sizes. The updated caribou habitat numbers are provided in SIR 2 Table ESRD 35-1.The corrected areas of contiguous caribou habitat do not change Osum’s evaluation of theProject’s effect on caribou at Baseline, Application, and Planned Development cases.



SIR 2 Table ESRD 35-1 Corrected Areas (ha) of Contiguous Caribou Habitat at Baseline, Application and Planned Development Case in the Moose and Woodland Caribou Local Study Area and Regional Study Area

Time period: Location:

MCLSA Baseline

Case

MCLSA Application

Case

MCLSA Planned Development Case

RSA Baseline

Case

RSA Application

Case

RSA Planned Development

Case Total area of caribou range 75% 75% 75% 71% 71% 71% Total quantity of contiguous caribou habitat (as defined on p11-16)

30,309* 29,613* 29,569* 731,349 730,653 722,604

Total quantity of contiguous caribou habitat within 500 m of development

26,040* 25,402* 25,359 595,136 594,611* 592,358*

Quantity of contiguous caribou habitat outside of caribou range

1,128* 920* 920* 63,993 63,785 63,785

Mean habitat patch size 6.69* 6.42* 6.40* 8.10* 8.08* 7.97* Maximum habitat patch size 14,892* 13,362* 13,362* 153,344* 153,344* 110,887* Minimum habitat patch size <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 Standard deviation of habitat patch size 249* 216* 216* 665* 662* 525* Quantity of contiguous caribou habitat inside caribou range, and further than 500 m from development

4,269* 4,210* 4,210* 136,213 136,043 130,247*

Mean habitat patch size in caribou range, and more than 500 m from development

4* 4 4 6* 6* 6*

Maximum habitat patch size in caribou range, and more than 500 m from development

373* 373* 373* 5,902* 5,902* 4,969*

Minimum habitat patch size in caribou range, and more than 500 m from development

<0.001 <0.001 <0.001 <0.001 <0.001 <0.001

Standard deviation of habitat patch size in caribou range, and more than 500 m from development

25* 25* 25* 77* 77* 70*

*denotes that the number has been updated from Table 130-1 in the response to Round 1 ESRD SIR 130.MCLSA = moose and woodland caribou local study area.



36 SIR Appendix A – Wildlife Baseline Surveys

Osum completed a winter tracking survey in 2013 to address information gaps in the wildlife baseline assessment. This survey was the first of the wildlife surveys to include the 11 km access road associated with the Project. Though some mammal data has now been collected along this access road, data gaps remain for all other wildlife groups (e.g., birds, amphibians, bats). Furthermore, the winter tracking survey did not include a large portion of the core Project development area (i.e., Sections 1 to 16 and 22 to 27, Twp 85, Rge 18 W4M and Sections 33 to 36, Twp 84, Rge 18, W4M), which represents an additional data gap for wildlife resources. As a result of these large data gaps in wildlife baseline information in the Terrestrial LSA, impacts that the Project will have on wildlife resources cannot be adequately assessed.

a. Discuss Osum’s plans for addressing these information gaps and conducting additionalwildlife surveys in the LSA. Provide a plan to complete these surveys prior to thecommencement of Project construction activities.

Response:

a. Additional wildlife surveys will be conducted along the length of the access road before thestart of winter construction. The following surveys and seasonal timing is proposed:

• owl survey (April);• amphibian/yellow rail survey (May/June);• breeding bird survey (June); and• bat survey (July).

The purpose of these surveys is to increase the spatial extent of baseline information on birds, amphibians and bats. The surveys will be conducted outside of the scope of the EIA and a summary of the results will be submitted as a supplemental baseline report. The results of the surveys are not expected to change the conclusions of the EIA since wildlife data will be collected in the vicinity of an existing access road and the surveys are intended to provide baseline information only.

Additional winter tracking surveys will not be conducted in the core Project development area (identified as Sections 1 to 16 and 22 to 27, Township 85, Range 18 W4M and Sections 33 to 36, Township 84, Range 18,W4M). This portion of the Project development area was not sampled during the 2013 winter tracking survey due to safety concerns. The area was too steep to safely access with snowmobiles or by snowshoeing in deep snow conditions. In addition, there are several watercourses that intersect the identified portion of the Project development area. The winter tracking survey safety protocol requires that these watercourses are not crossed by snowmobile or snowshoes to avoid risk to the surveyors.



36 b. Provide a timeframe and discussion outlining when and how Osum will submit theupdated wildlife assessment.

Response:

b. Osum will submit the supplemental baseline report to ESRD in September of the year inwhich the surveys are completed. The report will include methods and results from allsurveys, including figures depicting the supplemental survey locations, species at risk andwildlife indicator observations. The report will be submitted electronically as a pdf documentto Osum’s assigned regulatory coordinator with the AER. Additionally, data collected fromthe surveys will be submitted to the Fisheries and Wildlife Management Information System.

Prepared by: AECOM 200 – 6807 Railway Street SE 403 254 3301 tel Calgary, AB, Canada T2H 2V6 403 270 9196 fax www.aecom.com

Project Number: 60286723

Date: November 2014

Transportation

Osum Oil Sands Corporation

SEPIKO KESIK PROJECT Updated Transportation Impact Assessment

AECOM Osum Oil Sands Corporation Sepiko Kesik Project Updated Transportation Impact Assessment

AECOM: 2012-01-06 © 2009-2012 AECOM Canada Ltd. All Rights Reserved. RPT-2014-11-03 Osum Sepiko Kesik Updated TIA FINAL.Docx

Statement of Qualifications and Limitations

The attached Report (the “Report”) has been prepared by AECOM Canada Ltd. (“Consultant”) for the benefit of the Osum Oil Sands Corporation (“Client”) in accordance with the agreement between Consultant and Client, including the scope of work detailed therein (the “Agreement”).

The information, data, recommendations and conclusions contained in the Report (collectively, the “Information”):

o is subject to the scope, schedule, and other constraints and limitations in the Agreement and the qualificationscontained in the Report (the “Limitations”);

o represents Consultant’s professional judgement in light of the Limitations and industry standards for the preparationof similar reports;

o may be based on information provided to Consultant which has not been independently verified;o has not been updated since the date of issuance of the Report and its accuracy is limited to the time period and

circumstances in which it was collected, processed, made or issued;o must be read as a whole and sections thereof should not be read out of such context;o was prepared for the specific purposes described in the Report and the Agreement; ando in the case of subsurface, environmental or geotechnical conditions, may be based on limited testing and on the

assumption that such conditions are uniform and not variable either geographically or over time.

Consultant shall be entitled to rely upon the accuracy and completeness of information that was provided to it and has no obligation to update such information. Consultant accepts no responsibility for any events or circumstances that may have occurred since the date on which the Report was prepared and, in the case of subsurface, environmental or geotechnical conditions, is not responsible for any variability in such conditions, geographically or over time.

Consultant agrees that the Report represents its professional judgement as described above and that the Information has been prepared for the specific purpose and use described in the Report and the Agreement, but Consultant makes no other representations, or any guarantees or warranties whatsoever, whether express or implied, with respect to the Report, the Information or any part thereof.

Without in any way limiting the generality of the foregoing, any estimates or opinions regarding probable construction costs or construction schedule provided by Consultant represent Consultant’s professional judgement in light of its experience and the knowledge and information available to it at the time of preparation. Since Consultant has no control over market or economic conditions, prices for construction labour, equipment or materials or bidding procedures, Consultant, its directors, officers and employees are not able to, nor do they, make any representations, warranties or guarantees whatsoever, whether express or implied, with respect to such estimates or opinions, or their variance from actual construction costs or schedules, and accept no responsibility for any loss or damage arising therefrom or in any way related thereto. Persons relying on such estimates or opinions do so at their own risk.

Except (1) as agreed to in writing by Consultant and Client; (2) as required by-law; or (3) to the extent used by governmental reviewing agencies for the purpose of obtaining permits or approvals, the Report and the Information may be used and relied upon only by Client.

Consultant accepts no responsibility, and denies any liability whatsoever, to parties other than Client who may obtain access to the Report or the Information for any injury, loss or damage suffered by such parties arising from their use of, reliance upon, or decisions or actions based on the Report or any of the Information (“improper use of the Report”), except to the extent those parties have obtained the prior written consent of Consultant to use and rely upon the Report and the Information. Any injury, loss or damages arising from improper use of the Report shall be borne by the party making such use.

AECOM 200 – 6807 Railway Street SE 403 254 3301 tel Calgary, AB, Canada T2H 2V6 403 270 9196 fax www.aecom.com

November 3, 2014

Brian Fuchs Principal Engineer Matrix Solutions Inc. Suite 200, 150 – 13 Avenue SW Calgary, AB T2R 0V2

Dear Mr. Fuchs:

Project No: 60286723 Regarding: Sepiko Kesik Project

Updated Transportation Impact Assessment

AECOM is pleased to submit the above-mentioned report detailing our methodology in conducting a Transportation Impact Assessment (TIA) of traffic conditions related to the upcoming development of the Sepiko Kesik Project, and our associated findings and recommendations. This updated TIA has been prepared based on the revised project assumptions provided by Osum Oil Sands Corporation, and is intended to replace the original TIA report dated April 3, 2014.

Please contact the undersigned if you have any questions or concerns.

Sincerely, AECOM Canada Ltd.

Glen Holland, P.Eng., PTOE Manager, Transportation Planning and Operations Alberta South [email protected]

/cl Encl.


RPT-2014-11-03 Osum Sepiko Kesik Updated TIA FINAL.Docx

Distribution List # of Hard Copies PDF Required Association / Company Name

0 Yes Matrix Solutions Inc.

0 Yes Osum Oil Sands Corporation

Revision Log Revision # Revised By Date Issue / Revision Description

AECOM Signatures

Report Prepared By: Chris Lo, P.Eng., PTP Transportation Engineer

Report Reviewed By: Glen Holland, P.Eng., PTOE Manager, Transportation Planning and Operations, Alberta South



Table of Contents

Statement of Qualifications and Limitations Letter of Transmittal Distribution List

page

1. Introduction .................................................................................................................................. 1

2. Existing Conditions ..................................................................................................................... 42.1 Intersection Configuration ............................................................................................................... 4 2.2 Existing Traffic Volumes.................................................................................................................. 4 2.3 Intersection Sight Distances ............................................................................................................ 5

3. Site-generated Traffic .................................................................................................................. 63.1 Trip Generation ............................................................................................................................... 6 3.2 Site Traffic Distribution & Assignment ............................................................................................. 9

4. Background Traffic .................................................................................................................... 104.1 Scenarios for Analysis .................................................................................................................. 10 4.2 Highway 813 Traffic Growth .......................................................................................................... 10 4.3 Cumulative Traffic Impact from Other Planned Development ......................................................... 11 4.4 Background Traffic Volumes ......................................................................................................... 13

5. Combined Traffic Volumes for Analysis ................................................................................... 15

6. Intersection Capacity Analysis ................................................................................................. 17

7. Alberta Transportation Warrant Analysis ................................................................................. 207.1 Left-Turn Treatment Assessment .................................................................................................. 20 7.2 Right-Turn Lane Warrants ............................................................................................................. 21

8. Intersection Illumination Warrant Assessment ........................................................................ 22

9. Conclusions ............................................................................................................................... 239.1 Peak of Construction Scenario ...................................................................................................... 23 9.2 Normal Operations Scenario ......................................................................................................... 23



List of Figures

Figure 1: Project Location ....................................................................................................................................... 1 Figure 2: Proposed Site Access .............................................................................................................................. 2 Figure 3: 2013 Existing Traffic Volumes .................................................................................................................. 5 Figure 4: Site-generated Traffic Volumes - Peak of Construction ............................................................................. 9 Figure 5: Site-generated Traffic Volumes - Normal Operations ................................................................................ 9 Figure 6: 2017 Background Traffic Volumes .......................................................................................................... 13 Figure 7: 2022 Background Traffic Volumes .......................................................................................................... 13 Figure 8: 2042 Background Traffic Volumes .......................................................................................................... 14 Figure 9: Combined Traffic – 2017 Peak of Construction ....................................................................................... 15 Figure 10: Combined Traffic – 2022 Short Term Normal Operations ...................................................................... 16 Figure 11: Combined Traffic – 2042 Long Term Normal Operations ...................................................................... 16

List of Tables

Table 1: Required vs. Available Sight Distances ...................................................................................................... 5 Table 2: Type and Number of On-Site Workers ....................................................................................................... 6 Table 3: Site-generated Traffic Volumes – Phase 1 Peak Construction.................................................................... 8 Table 4: Site-generated Traffic Volumes – Normal Operations ................................................................................ 8 Table 5: Potential Oil Sands Developments ........................................................................................................... 11 Table 6: Estimated Traffic Generation from Other Area Developments .................................................................. 12 Table 7: LOS Criteria for Unsignalized Intersections .............................................................................................. 17 Table 8: Operating Conditions — 2013 Existing .................................................................................................... 18 Table 9: Operating Conditions — 2017 Background .............................................................................................. 18 Table 10: Operating Conditions — 2017 Peak of Construction .............................................................................. 18 Table 11: Operating Conditions — 2022 Background ............................................................................................ 19 Table 12: Operating Conditions — 2022 Short Term Normal Operations ............................................................... 19 Table 13: Operating Conditions — 2042 Background ............................................................................................ 19 Table 14: Operating Conditions — 2042 Long Term Normal Operations ................................................................ 19 Table 15: Left-Turn Lane Warrant Analysis ........................................................................................................... 20 Table 16: Right-Turn Lane Warrant Analysis ......................................................................................................... 21

Appendices

Appendix A. Correspondence Appendix B. Synchro Output Reports Appendix C. Left-Turn/Right-Turn Lane Warrant Worksheets Appendix D. Intersection Illumination Warrant Worksheets


RPT-2014-11-03 Osum Sepiko Kesik Updated TIA FINAL.Docx 1

1. IntroductionOsum Oil Sands Corporation (Osum) is proposing to develop the Sepiko Kesik Project in northeastern Alberta. The Project is located within the Municipal District of Opportunity No. 17, approximately 75 km northeast of the Hamlet of Wabasca-Desmarais and 90 km west of Fort McMurray, as shown in Figure 1.

AECOM prepared and submitted a Transportation Impact Assessment (TIA) in support of the Project in April 2014. Subsequent to the report submission, Osum has decided to revise some of the key Project details and assumptions, including implementation of overlapping work shifts, use of larger capacity buses to transport all Project personnel to and from the site, and a reduction in the amount of truck traffic needed to support the Project development. As a result, AECOM was commissioned by Osum to update the original TIA to reflect the changes and identify the associated traffic impacts.

The Sepiko Kesik Project lease area is located within Townships 85 through 87, Range 18 W4M, covering 58 sections of land. The Project will include a central processing facility (CPF) with a capacity of 9,540 m3/day (60,000 barrels per day [bpd]). Osum plans to construct the Project in two phases of 4,770 m3/day (30,000 bpd) each. Based on Osum’s anticipated approval timeline of an approval in mid Q1 2015, it is expected that road works and pad preparation will commence in Q3 2015 and first steam will be injected at Phase 1 in Q4 2018. Production from Phase 2 is anticipated for Q2 2020. The life of the Project is anticipated to be 45 years, with reclamation commencing in 2063.

Figure 1: Project Location



One of the key elements in the traffic impact assessment process is the routing of vehicular traffic to/from the site. It is expected that all of the construction workforce and operations staff will access the site on a fly-in/fly-out basis, using a regional airstrip that is being planned in the area by several other operators. However, some product vendors, as well as equipment and heavy loads, will still be routed to/from the site by road. The Project will be accessed via private roads, utilizing an existing connection to Highway 813 on Chipewyan Lake Road (also known as the Al-Pac Road) approximately 8 km east of Wabasca (measured from the Highway 813/Highway 754 intersection), as shown in Figure 2.

Figure 2: Proposed Site Access

As per Alberta Environment’s (AENV) Standard Terms of Reference, a TIA in support of the Sepiko Kesik Project is required to accompany the Environmental Impact Assessment (EIA), as part of an application to Alberta Environment and Sustainable Resource Development (AESRD).

At the outset of the original study, AECOM discussed the scope of work for the TIA with Alberta Transportation (AT); refer to correspondence in Appendix A. The TIA will include an evaluation of current traffic conditions, during peak construction of the facilities, and following completion of the facility (for both short- and long-term scenarios) with the new facility in normal day-to-day operation.



Osum retained AECOM (through their environmental consultant, Matrix Solutions Inc.) to carry out the required traffic study. The scope for this TIA addresses the following planning horizons/scenarios:

Existing traffic (Year 2013) Traffic operations at time of peak construction activity (Year 2017) Traffic operations for a short-term scenario, under normal operating conditions (Year 2022) Traffic operations for a long-term (20 years from project start-up) scenario, under normal operating conditions

(Year 2042)

This report presents our methodology in conducting the TIA, and our findings and recommendations.



2. Existing Conditions2.1 Intersection Configuration

Based on a site visit conducted by AECOM in February 2013, it is noted that Chipewyan Lake Road currently intersects with Highway 813 and forms a “T” intersection. Highway 813 generally runs in a northwest-southeast direction through the study area. Chipewyan Lake Road connects with Highway 813 at approximately 90 degrees and then turns to run north-south. For the purposes of this study, AECOM will refer to Highway 813 as the “east-west” road, and to Chipewyan Lake Road as the “north-south” road.

Highway 813 in the study area is a two-lane paved provincial highway. Based on field observations/measurements, the existing intersection is constructed to AT’s standard Type IIIa intersection configuration. Chipewyan Lake Road appears to be gravel surfaced, although it was difficult to determine this given the snow cover in place during the site visit. The available driving surface on the access road is approximately 13 m to 14 m wide for some distance to the north of the intersection. The intersection is unsignalized, with Highway 813 traffic having the right-of-way and southbound traffic on Chipewyan Lake Road controlled by a STOP sign at the intersection. The intersection is not illuminated.

2.2 Existing Traffic Volumes

AECOM completed a review of published traffic data on Highway 813 from the AT website. The website shows no automatic traffic count locations anywhere along Highway 813 in this area. There are only limited count data available from AT, with the closest turning movement counts along Highway 813 as follows:

Highway 754 and Highway 813 (in the centre of Wabasca) — counted in May 2005, June 2009 and June 2012, with estimated turning movements provided for other years.

Highway 813 and Township Road 801 (quite some distance east of the site access road intersection) — counted in September 2006, September 2007 and July 2012, with estimated turning movements provided for other years.

There are no published turning movement counts at the Chipewyan Lake Road intersection on Highway 813. To supplement the available AT data, AECOM conducted weekday morning and afternoon peak period turning movement counts at the subject intersection on the following days:

Monday, February 11, 2013 between 3:30 and 6:00 p.m. Tuesday, February 12, 2013 between 6:00 and 8:30 a.m.

All intersection movements were counted by 15-minute intervals, with two vehicle classifications as follows:

passenger vehicles (includes all types of pickup trucks, unless pulling a trailer), trucks (includes single-unit trucks, buses, pickups pulling a trailer, and any tractor-trailer combinations)

The count found the weekday morning peak hour was 7:30 - 8:30 a.m. and the weekday afternoon peak hour was 3:45 - 4:45 p.m. The resultant peak hour traffic volumes are illustrated in Figure 3. The figure also contains estimated daily traffic volumes for each leg of the intersection, based on factoring up of the peak hour traffic volumes. A review of peak hour-vs.-AADT volumes at the two available AT traffic count locations revealed that daily traffic volumes could be estimated using a factor of approximately 10 times the p.m. peak hour traffic volumes. It should also be noted that, based on historical traffic data at the nearest automated AT traffic counter (on Highway 88), seasonal variations in traffic volumes are significant, and, that the winter months (January to March)



A.M. Peak Hour 7:30 - 8:30300 vpd P.M. Peak Hour 3:45 - 4:45

7 151000 vpd 37 43 1150 vpd

4 4 Highway 81350 27

AM PM

4 7

Chipewyan Lake Road

3 15

generally exhibit the highest traffic volumes on the highway due to oil and gas exploration activities. Therefore, the traffic count conducted in February should already reflect peak seasonal traffic conditions.

Figure 3: 2013 Existing Traffic Volumes

2.3 Intersection Sight Distances

Figure 4.2.2.2 from the Alberta Transportation Highway Geometric Design Guide (HGDG) provides the required “intersection sight distance” along a two-lane highway at an intersecting roadway. The information pertinent to this study is summarized in Table 1 for various design vehicles making a left-turn manoeuvre from Chipewyan Lake Road to eastbound Highway 813 for both the 100 km/h posted speed limit and also for a 110 km/h design speed. Also shown in the table are the available existing sight distances for this left-turn movement as measured in the field. The existing sight distances as shown are based on driver eye heights (for the vehicle turning onto the highway) per Figure D-5a of the HGDG and a target height of 1.3 m, representing the roofline of a passenger vehicle (as required in the Guide) approaching the intersection from the east on Highway 813. During the field visit it was determined that there is almost unlimited sight distance looking to the east along the highway from the Chipewyan Lake Road intersection, with approaching vehicles being visible from approximately 1.3 km away from the intersection because of the flat, straight road geometry. As shown in the table, the available sight distances are acceptable for turning design vehicles up to and including the log truck category.

Table 1: Required vs. Available Sight Distances

Design Vehicle Speed: 100 km/h Speed: 110 km/h

Required Available Met? Required Available Met?

Passenger Vehicle 195 m >1000 m Yes 215 m >1000 m Yes

Single-Unit Truck / Bus 295 m >1000 m Yes 325 m >1000 m Yes

WB-15 / WB-17 Tractor Trailer 390 m >1000 m Yes 430 m >1000 m Yes

WB-21 / WB-23 / WB-28 / WB-33 510 m >1000 m Yes 560 m >1000 m Yes

Turnpike Double (WB-36) 550 m >1000 m Yes 600 m >1000 m Yes

Log Truck 610 m >1000 m Yes 675 m >1000 m Yes



3. Site-generated Traffic3.1 Trip Generation

There are two main timeframes to be considered with respect to traffic generation levels for the proposed development: traffic levels at the peak of site construction activity; and, traffic levels for normal day-to-day operation of the facility.

As mentioned earlier in the report, Osum plans to have all of its construction workforce and operation staff flying in and out of the site area via a proposed regional airstrip that will be shared by several other operators in the study area. The regional airstrip will be located along Chipewyan Lake Road and will be close enough to the project site such that it will allow for buses to transport the workers between the airstrip and the site. Osum will hire a bus company for transportation of Project personnel. For the purposes of this study, it is assumed that the bus company will be based in the local communities outside of the study area, thus buses will use Highway 813 and Chipewyan Lake Road to travel between their base and the airstrip or project site. Buses are expected to have a carrying capacity of 50 people each. These buses will complete one round trip (from their origin to the airstrip/site and then back to their origin) on both staff arrival days and departure days. That is:

On staff arrival days, the buses will travel from their base along the highway, enter through the Chipewyan Lake Road intersection, pick up arriving staff from the airstrip and deliver them to the work camp and/or the project site, and then return to their base (again passing through the Chipewyan Lake Road intersection on the highway).

On staff departure days, the buses will travel from their base along the highway, enter through the Chipewyan Lake Road intersection, pick up departing staff from the work camp and/or the project site, deliver them to the airstrip, and then return to their base (again passing through the Chipewyan Lake Road intersection on the highway).

Staff accommodation will be provided in camps. A ‘construction’ camp will be built close to the project site and is expected to house 850 people. An ‘operation’ camp will be built on site and will house 250 people. The daily commute between the camps and the project site will be via internal roads and hence will not impact the Highway 813/Chipewyan Lake Road intersection.

Construction for the Project will be separated into two phases. The peak of Phase 1 construction is expected to occur in 2017, and Phase 2 construction will peak in 2019. The Project plant will be completed and operating at full capacity in 2022. Osum anticipates the following workforce requirements for the various stages of the Project as shown in Table 2.

Table 2: Type and Number of On-Site Workers

Project Stage Construction Drilling and Completions Operations Total On-Site Workforce

Phase 1 Peak Construction 731 100 0 831

Phase 2 Peak Construction 538 100 75 713

Normal Operations 77 70 113 260



All of the construction, drilling/completions workers and operations staff will be flying into and out of the site area via the regional airstrip, and will be staying in the camps and the Project area during their work shift. Therefore, only a minimal amount of personal vehicle trips, if any, would be seen at the Highway 813/ Chipewyan Lake Road intersection, which may include product vendors, Osum head office staff coming in for meetings or inspections, and local community stakeholders. Osum estimated that the miscellaneous auto trips of these types could account for approximately six round trips per day during the construction phase, and three round trips per day during the operations phase.

Osum will have its workforce operate on a ‘10-days-on and 4-days-off’ schedule, with two shifts that are staggered in such a way that only half of the total workforce are arriving or departing during any given shift change. On the other hand, the exact start and end times of the work shift have not yet been determined. Osum is committed to working with other operators in the area to schedule shift changes in such a way as to avoid conflict with each other. For the purposes of this study, we will assume the work shift starts on a weekday morning traffic peak period and ends on a weekday afternoon traffic peak period, which represents a conservative approach in evaluating Osum’s traffic impact on the Chipewyan Lake Road intersection on Highway 813.

In addition to the bus trips for transporting the workforce, the Project will also generate different types of truck traffic on a daily basis, including, for example, construction trucks, drilling trucks, and service trucks. These trucks will access the site via the Highway 813/Chipewyan Lake Road intersection. Osum provided preliminary information regarding the anticipated truck traffic as follows:

Phase 1 Construction – an estimated total of 136 truck trips per day (68 inbound/68 outbound), composed of 120 construction truck trips and 16 drilling truck trips.

Phase 2 Construction – an estimated total of 104 truck trips per day (52 inbound/52 outbound), composed of 88 construction truck trips and 16 drilling truck trips.

Normal Operations – an estimated total of 20 truck trips per day (10 inbound/10 outbound), composed of 6 construction truck trips, 8 drilling truck trips, 2 chemical truck trips, 2 fluid truck trips and 2 service truck trips.

It is anticipated that the majority of the truck traffic would travel to/from the site during the off-peak hours, with the exception of some construction truck trips occurring during the a.m. and p.m. peak hours in the construction phase.

Based on the above workforce projections and truck traffic estimates, it is apparent that the Project will generate more traffic during the peak of Phase 1 construction than in Phase 2. Therefore, Phase 1 was selected for the “peak of construction” analysis scenario.

Based on the best available information from Osum at this stage in the planning process for the Sepiko Kesik Project, and applying the various assumptions stated above, the type and number of trips generated by the development during the a.m. peak hour, p.m. peak hour, and on a daily basis are presented in Tables 3 and 4, for the peak of construction and normal operations scenarios, respectively. Note that the figures in Tables 3 and 4 represent the total traffic volumes accessing the site by road, and therefore all of the trips will be passing through the Highway 813/Chipewyan Lake Road intersection.



Table 3: Site-generated Traffic Volumes – Phase 1 Peak Construction

Trip Types A.M. Peak Hour P.M. Peak Hour Off-Peak Period Daily

In Out In Out In Out Total

Weekday – Start of Work Shift

Workforce Bus Trips 9 9 0 0 0 0 18 Miscellaneous Auto Trips 0 0 0 0 6 6 12 Construction Truck Trips 10 0 0 10 50 50 120

Drilling Truck Trips 0 0 0 0 8 8 16 Total 19 9 0 10 64 64 166

Weekday – End of Work Shift

Workforce Bus Trips 0 0 9 9 0 0 18 Miscellaneous Auto Trips 0 0 0 0 6 6 12 Construction Truck Trips 10 0 0 10 50 50 120

Drilling Truck Trips 0 0 0 0 8 8 16 Total 10 0 9 19 64 64 166

Table 4: Site-generated Traffic Volumes – Normal Operations

Trip Types A.M. Peak Hour P.M. Peak Hour Off-Peak Period Daily

In Out In Out In Out Total

Weekday – Start of Work Shift Workforce Bus Trips 4 4 0 0 0 0 8

Miscellaneous Auto Trips 0 0 0 0 3 3 6 Construction Truck Trips 0 0 0 0 3 3 6

Drilling Truck Trips 0 0 0 0 4 4 8 Chemical Truck Trips 0 0 0 0 1 1 2

Fluid Truck Trips 0 0 0 0 1 1 2 Service Truck Trips 0 0 0 0 1 1 2

Total 4 4 0 0 13 13 34

Weekday – End of Work Shift Workforce Bus Trips 0 0 4 4 0 0 8

Miscellaneous Auto Trips 0 0 0 0 3 3 6

Construction Truck Trips 0 0 0 0 3 3 6 Drilling Truck Trips 0 0 0 0 4 4 8

Chemical Truck Trips 0 0 0 0 1 1 2

Fluid Truck Trips 0 0 0 0 1 1 2 Service Truck Trips 0 0 0 0 1 1 2

Total 0 0 4 4 13 13 34



34 vpd

3 310 vpd 24 vpd

1 1 Highway 813

AM PM

Chipewyan Lake Road

1 31 3

166 vpd

13 650 vpd 116 vpd

3 6 Highway 813

AM PM

6 13Chipewyan Lake Road

3 6

3.2 Site Traffic Distribution & Assignment

Directional distribution patterns for the traffic expected to be generated by the Sepiko Kesik Project, both during construction and under normal operating conditions, were estimated based on locations of the construction equipment/material/service companies, availability of workforce in the local areas, existing traffic distribution pattern at the Chipewyan Lake Road intersection on Highway 813, and, information provided by Osum. The estimated directional distribution for the site-generated traffic is 70% to/from the east and 30% to/from the west along Highway 813.

Based on the estimated traffic generation levels and trip distribution patterns, the a.m. and p.m. peak hour site traffic movements as assigned to the Highway 813/Chipewyan Lake Road intersection are illustrated in Figures 4 and 5, for the peak of construction and normal operations scenarios, respectively. Note that the a.m. peak hour traffic volumes were taken from the ‘start of work shift’ and the p.m. peak hour traffic volumes were taken from the ‘end of work shift’ as these represent the worst case scenario.

Figure 4: Site-generated Traffic Volumes - Peak of Construction

Figure 5: Site-generated Traffic Volumes - Normal Operations



4. Background Traffic4.1 Scenarios for Analysis

As noted previously, this traffic impact assessment addresses the following scenarios:

Traffic operations at time of peak construction activity (Year 2017) Traffic operations for a short-term scenario, under normal operating conditions (Year 2022) Traffic operations for a long-term (20-year) scenario, under normal operating conditions (Year 2042)

The following sections present our assessment of potential growth in background traffic at the Chipewyan Lake Road intersection on Highway 813.

4.2 Highway 813 Traffic Growth

To determine base traffic volume growth for the through movements on Highway 813 for the future analysis scenarios, historic traffic volume data from AT’s website have been reviewed and analyzed. The two closest locations to the Chipewyan Lake Road intersection where AT publishes historical AADT information are as follows:

Hwy 813:10 – West of TWP RD 801

2002 AADT = 470 2012 AADT = 980 10-Year Linear Traffic Growth Rate = 10.9%

Hwy 813:10 – East of Hwy 754 SE of Wabasca

2002 AADT = 2020 2012 AADT = 3110 10-Year Linear Traffic Growth Rate = 5.4%

It is noted that a majority of the traffic growth at the above locations would be attributed to the oil and gas development projects in the study area; for example, other developments along Chipewyan Lake Road would have generated traffic demands on Highway 813 at the above locations. Therefore, we anticipated that the traffic growth on the Highway 813 through movements at the subject intersection should be lower than the growth rates presented above, considering that this study will also be separately assessing the growth in traffic in the area attributable to a number of proposed development projects. As a result, the following approach has been followed in estimating future background traffic volumes on Highway 813, specifically for the eastbound and westbound through movements at the subject intersection:

We applied a 4 percent per year linear growth rate for the first four years (using the February 2013 counted traffic volumes as the base) to reach the 2017 timeframe for peak construction activity on the site.

We applied a 4 percent per year linear growth rate for the subsequent five years to reach the 2022 timeframe for the short-term scenario.

We then applied a 2.5 percent per year linear growth rate from 2022 to 2042, for the long-term scenario to reflect a more sustainable level of background traffic growth, typical of growth in traffic on Alberta’s highways.



4.3 Cumulative Traffic Impact from Other Planned Development

In order to estimate the future turning movement traffic volumes at the Chipewyan Lake Road intersection on Highway 813, it is necessary to review the potential development in the study area that would make use of the intersection. AECOM contacted AT to request traffic information related to the planned development projects in the area, but no specific development traffic information was given. Therefore, AECOM conducted online research (including searches of Alberta Energy, Alberta Business and individual oil sands companies’ websites) for information on potential developments in the area. Of particular interest to this study is a map titled ‘Athabasca Oil Sands Projects and Upgraders’ from Alberta Energy that illustrates the approximate geographic locations of other oil sands development in the area, and a report titled ‘Alberta Oil Sands Industry Quarterly Update’ from the Alberta Government website. This report contains individual oil sands project information such as the expected capacity in barrels per day, anticipated start-up year, and regulatory status.

Based on our research, there are several planned developments in the area that would be expected to generate traffic through the subject intersection on Highway 813; a summary of the relevant project information is presented in Table 5.

Table 5: Potential Oil Sands Developments

Oil Sands Company Project Name Phase Capacity (bpd) Start-Up Year

Cavalier Energy Inc. Hoole Grand Rapids

1 10,000 2017

2 35,000 TBD

3 35,000 TBD

Cenovus Energy Inc. Pelican Lake Grand Rapids

Pilot 600 2011

A 60,000 2017

B 60,000 TBD

C 60,000 TBD

Koch Exploration Canada Corporation

Muskwa Pilot 10,000 2015

Laricina Energy Ltd. Germain

1 5,000 2013

2 30,000 2016

3 60,000 TBD

4 60,000 TBD

Laricina Energy Ltd. Saleski

Pilot 1,800 2011

1 10,700 2016

2 30,000 2017

3 60,000 2020

4 60,000 2023

5 60,000 2026

6 60,000 TBD

AECOM then proceeded with researching relevant traffic generation information for the above developments. The following sources of information were reviewed:

Cavalier Energy Inc. – Application for Approval of the Hoole Grand Rapids Project, November 2012, by Cavalier Energy Inc., submitted to Alberta Energy Resources Conservation Board.



Cenovus Energy Inc. – Pelican Lake Grand Rapids Project Traffic Impact Assessment, August 2012, by Dillon Consulting Limited.

Koch Exploration Canada Corp. – Application for Approval of the Muskwa Oil Sands Project, February 2012, by Koch Exploration Canada Corp., submitted to Alberta Energy Resources Conservation Board.

Laricina Energy Ltd. – Germain Project Expansion Traffic Impact Assessment, November 2013, by OPUS Stewart Weir.

Based on the available information contained in the aforementioned documents, the estimated a.m. and p.m. peak hour traffic volumes generated by the other planned developments at the Highway 813/Chipewyan Lake Road intersection, for the 2017, 2022 and 2042 analysis horizons, are summarized in Table 6.

Table 6: Estimated Traffic Generation from Other Area Developments

Assessment Year

A.M. Peak Hour P.M. Peak Hour

Inbound Outbound Inbound Outbound West East West East West East West East

Cavalier Energy Inc. - Hoole Grand Rapids 2017 5 1 0 0 0 0 5 1

2022 5 1 0 0 0 0 5 1

2042 5 1 0 0 0 0 5 1

Cenovus Energy Inc. - Pelican Lake Grand Rapids 2017 57 49 14 12 14 12 57 49

2022 57 49 14 12 14 12 57 49

2042 52 45 9 8 9 8 52 45

Koch Exploration Canada Corporation – Muskwa 2017 7 2 0 0 0 0 7 2

2022 7 2 0 0 0 0 7 2

2042 7 2 0 0 0 0 7 2

Laricina Energy Ltd. – Germain 2017 10 1 4 1 4 1 10 1

2022 33 1 8 1 8 1 33 1

2042 12 1 7 1 7 1 12 1

Laricina Energy Ltd. – Saleski (Phase 1)

2017 2 0 2 0 2 0 2 0

2022 2 0 2 0 2 0 2 0

2042 6 1 2 0 2 0 6 1

Total Traffic Generation 2017 81 53 20 13 20 13 81 53

2022 104 53 24 13 24 13 104 53

2042 82 50 18 9 18 9 82 50



60 2843 50

24 85 Highway 81358 31

AM PM

23 28

Chipewyan Lake Road85 60

60 2850 58

28 108 Highway 81368 37

AM PM

27 28

Chipewyan Lake Road

108

60

4.4 Background Traffic Volumes

Future background traffic volumes levels at the Highway 813/Chipewyan Lake Road intersection were estimated by:

Applying the aforementioned annual traffic growth rates for the Highway 813 eastbound and westbound through movements.

Adding the anticipated future traffic from other developments onto existing (counted) turning movement traffic volumes.

The resultant background traffic volumes at the subject intersection for the 2017, 2022 and 2042 analysis scenarios are presented in Figures 6, 7 and 8, respectively.

Figure 6: 2017 Background Traffic Volumes

Figure 7: 2022 Background Traffic Volumes



57 2469 80

22 86 Highway 81393 50

AM PM21 24

Chipewyan Lake Road

86 57Figure 8: 2042 Background Traffic Volumes



73 3443 50

27 91 Highway 81358 31

AM PM

Chipewyan Lake Road

91 7326 34

5. Combined Traffic Volumes for AnalysisThe following sets of traffic volumes have been prepared for the assessment of operating conditions and geometric requirements at the Highway 813/Chipewyan Lake Road intersection:

Peak Construction Scenario:

o Figure 9: Peak of Construction 2017 Scenario – combined Year 2017 background traffic (Figure 6) withpeak of construction site traffic (Figure 4)

Normal Operations Scenario:

o Figure 10: Short Term Normal Operations 2022 Scenario — combined Year 2022 background traffic(Figure 7) with normal operations site traffic (Figure 5)

o Figure 11: Long Term Normal Operations 2042 Scenario — combined Year 2042 background traffic(Figure 8) with normal operations site traffic (Figure 5)

It should be noted that the expected site peak hours may not coincide exactly with the highway intersection peak hours. However, we have combined the intersection peak traffic volumes and the site-generated peak traffic volumes for analysis as a conservative approach.

Figure 9: Combined Traffic – 2017 Peak of Construction



63 3150 58

29 109 Highway 81368 37

AM PM

Chipewyan Lake Road

109

6328 31

60 2769 80

23 87 Highway 81393 50

AM PM

Chipewyan Lake Road

87 6022 27

Figure 10: Combined Traffic – 2022 Short Term Normal Operations

Figure 11: Combined Traffic – 2042 Long Term Normal Operations



6. Intersection Capacity AnalysisIntersection capacity analyses were performed using Synchro 7 software. This software predominantly uses methodology outlined in the Highway Capacity Manual 2000 (HCM 2000) edition.

The level of service (LOS) grading scale for intersection analysis is based on average control delay per vehicle. LOS ranges from ‘A’ to ‘F’ where LOS ‘A’ reflects ideal free flow conditions with little or no delay, and LOS ‘F’ indicates general failure of the movement. Grading criteria are different for signalized versus unsignalized intersections. The reason for this difference is that drivers expect signalized intersections to carry higher volumes and therefore tolerate longer control delays. The LOS grading for unsignalized intersection analysis is based on delay, this being the time elapsing from when a vehicle stops at the end of a queue until it departs from the stop line. Table 7 illustrates LOS criteria for unsignalized intersections.

Table 7: LOS Criteria for Unsignalized Intersections

Level of Service Average Delay (seconds)

A 10.0 or less B 10.1 to 15.0 C 15.1 to 25.0 D 25.1 to 35.0 E 35.1 to 50.0 F Greater than 50.0

Volume-to-capacity (v/c) ratios are important measures of effectiveness of at-grade intersections that Synchro 7 calculates. The v/c ratio, also calculated within Synchro, is an indication of the relative utilization of available capacity for a movement. Alberta Transportation’s acceptable standard for LOS is typically ‘D’ and a maximum v/c ratio of 0.90. Intersection improvements are assessed when the v/c ratios are greater than the recommended threshold of 0.90 and levels of service are ‘D’ or worse.

We note the following with respect to input data and parameters for the intersection capacity analysis:

The southbound approach to the intersection has been entered as a single lane, serving both left- and right-turning traffic. This is a conservative approach to the analysis, as it was observed during the field visit that the width of Chipewyan Lake Road allowed for both storage of a left-turning vehicle and a simultaneous right-turning vehicle.

A 100 km/h speed (as posted) on Highway 813 and an 80 km/h speed for Chipewyan Lake Road were used in the analysis (though it is noted that the “side street” posted/operating speed does not affect the unsignalized intersection capacity analysis).

This section presents the results of the operational analysis conducted at the Highway 813/Chipewyan Lake Road intersection for the following scenarios (Synchro reports for these intersection capacity analyses are provided in Appendix B):

2013 Existing Scenario - Table 8

2017 Background Scenario - Table 9

2017 Peak of Construction Scenario - Table 10




2022 Short Term Normal Operations Scenario - Table 12


2042 Long Term Normal Operations Scenario - Table 14

Based on the Synchro analysis, as shown in Tables 8 to 14, all intersection traffic movements are expected to operate at a good level of service for all scenarios assessed. The individual movements are expected to operate at LOS B or better, with a maximum v/c ratio of only 0.23 (occurred in the 2017 peak of construction and 2022 short term normal operations scenarios during the p.m. peak hour, on the southbound approach). The Synchro analysis was completed base on the existing lane configuration at the intersection for all scenarios assessed.

Table 8: Operating Conditions — 2013 Existing

Intersection Approach/Movement


v/c Ratio Average Delay

(sec/veh) LOS v/c Ratio

Average Delay (sec/veh)

LOS

EB Left 0.00 8.0 A 0.00 7.8 A

Through 0.02 0.0 A 0.03 0.0 A

WB Through 0.03 0.0 A 0.03 0.0 A

Right 0.00 0.0 A 0.01 0.0 A

SB Left/Right 0.03 9.7 A 0.02 9.5 A

Table 9: Operating Conditions — 2017 Background






LOS

EB Left 0.08 8.1 A 0.02 8.4 A

Through 0.02 0.0 A 0.04 0.0 A

WB Through 0.03 0.0 A 0.03 0.0 A

Right 0.04 0.0 A 0.02 0.0 A

SB Left/Right 0.10 11.4 B 0.19 10.3 B

Table 10: Operating Conditions — 2017 Peak of Construction






LOS

EB Left 0.09 8.2 A 0.03 8.4 A

Through 0.02 0.0 A 0.04 0.0 A

WB Through 0.03 0.0 A 0.03 0.0 A

Right 0.05 0.0 A 0.02 0.0 A

SB Left/Right 0.12 11.8 B 0.23 10.8 B









LOS

EB Left 0.10 8.1 A 0.03 8.4 A

Through 0.03 0.0 A 0.04 0.0 A

WB Through 0.03 0.0 A 0.04 0.0 A

Right 0.04 0.0 A 0.02 0.0 A

SB Left/Right 0.11 11.9 B 0.22 10.6 B

Table 12: Operating Conditions — 2022 Short Term Normal Operations






LOS

EB Left 0.10 8.1 A 0.03 8.4 A

Through 0.03 0.0 A 0.04 0.0 A

WB Through 0.03 0.0 A 0.04 0.0 A

Right 0.04 0.0 A 0.02 0.0 A

SB Left/Right 0.12 12.1 B 0.23 10.7 B







LOS

EB Left 0.08 8.1 A 0.02 8.5 A

Through 0.03 0.0 A 0.06 0.0 A

WB Through 0.05 0.0 A 0.05 0.0 A

Right 0.04 0.0 A 0.02 0.0 A

SB Left/Right 0.09 11.7 B 0.20 10.7 B

Table 14: Operating Conditions — 2042 Long Term Normal Operations






LOS

EB Left 0.08 8.1 A 0.02 8.5 A

Through 0.03 0.0 A 0.06 0.0 A

WB Through 0.05 0.0 A 0.05 0.0 A

Right 0.04 0.0 A 0.02 0.0 A

SB Left/Right 0.10 11.9 B 0.21 10.8 B



7. Alberta Transportation Warrant AnalysisSections D.7.6 and D.7.7 of the Alberta Transportation Highway Geometric Design Guide (HGDG) provides a system of warrants for determining the appropriate configuration of at-grade intersections on two-lane rural highways. For this study, AECOM has reviewed the intersection configuration requirements at the Highway 813/Chipewyan Lake Road intersection (assessment of the potential need for accommodating eastbound left-turn and/or westbound right-turn movements onto the site access road) for the following scenarios:

2017 Peak of Construction Scenario

2022 Short Term Normal Operations Scenario

2042 Long Term Normal Operations Scenario

7.1 Left-Turn Treatment Assessment

The following data form the basis of the left-turn movement analysis:

VL - Number of Left-Turning Vehicles Per Hour in the Advancing Volume

VA - Advancing Volume

VO - Opposing Volume

L% - Proportion of Left-Turns in Advancing Volume

Based on the above data and Figures D-7.6-1a through D-7.6-7d of the HGDG, left-turn treatment analysis was undertaken for each of the scenarios noted above and the results are presented in Table 15. The applicable left-turn warrant worksheets from the HGDG are provided in Appendix C.

Table 15: Left-Turn Lane Warrant Analysis

Year / Scenario Required Intersection Treatment


2017 Peak of Construction Type III None

2022 Short Term Normal Operations Type III None

2042 Long Term Normal Operations Type III Type II

Based on the left-turn lane warrant analyses conducted, it is apparent that the a.m. peak hour is the design hour as the eastbound left-turn movement carries the highest traffic volumes during the morning inbound peak period. It is noted that the existing Highway 813/Chipewyan Lake Road intersection is currently built to a Type IIIa configuration. According to the analysis results, the existing intersection configuration would be sufficient to accommodate the anticipated traffic volumes in the peak of construction, short-term and long-term normal operations scenarios.

The existing Type IIIa intersection configuration is designed to accommodate turning vehicles up to a WB-23 tractor-trailer combination. It is anticipated that some oversized loads will utilize the intersection. However, exact sizing of



oversized loads and the associated tractor/trailer configurations are unknown at this point in the planning process. In cases where large loads are expected, pilot vehicles will be used to safely facilitate the turning of oversized vehicles/loads.

7.2 Right-Turn Lane Warrants

The right-turn lane warrant analyses were undertaken based on the methodology of Section D.7.7 of the HGDG. To warrant an exclusive right-turn lane at a two-lane highway intersection, all three of the following conditions must be met:

1. Main road AADT (Average Annual Daily Traffic) 1800,

2. Intersecting road AADT 900, and

3. Right-turn daily traffic volume 360 for the movement in question.

Right-turn lane warrant analysis was completed for each of the scenarios noted above and the results are presented in Table 16. The applicable right-turn lane warrant worksheets are provided in Appendix C.

Table 16: Right-Turn Lane Warrant Analysis

Year / Scenario Right-Turn Lane Warranted?

2017 Peak of Construction Not Warranted

2022 Short Term Normal Operations Not Warranted

2042 Long Term Normal Operations Not Warranted

The warrant analysis indicates that a dedicated right-turn lane is not warranted at the Highway 813/Chipewyan Lake Road intersection in any of the scenarios assessed.



8. Intersection Illumination Warrant AssessmentThe intersection illumination assessment was conducted using the methodology outlined in the Transportation Association of Canada’s (TAC) publication Illumination of Isolated Rural Intersections. Key inputs to the illumination warrant assessment include physical aspects of the intersection (e.g., grades, sight distances, intersection skew angle, and proximity of horizontal curves to the intersection), traffic volumes on the major and minor roads, speed limits, and collision data. The threshold for warranting illumination is 120 points.

Illumination warrants were assessed at the Highway 813/Chipewyan Lake Road intersection (warrant worksheets are provided in Appendix D). The following presents the resultant warrant scores for each scenario:

2017 Peak of Construction Scenario - 88 points

2022 Short Term Normal Operations Scenario - 88 points

2042 Long Term Normal Operations Scenario - 98 points

As none of the future scenarios reach the illumination warrant threshold, we conclude that illumination of the Highway 813/Chipewyan Lake Road intersection is not required.



9. Conclusions9.1 Peak of Construction Scenario

The primary construction activity for the Sepiko Kesik project is expected to be completed in two phases, with the peak activity (in terms of personnel working on the site) to occur in 2017. Analysis of traffic conditions during the peak of construction period indicates that the Highway 813/Chipewyan Lake Road intersection is expected to operate at a good level of service during both the a.m. and p.m. peak hours based on the existing intersection lane configuration and traffic control.

The left-turn lane warrant analysis indicates that a Type IIIa intersection treatment is warranted in 2017; however, since the existing intersection is already built to the Type IIIa configuration today, no additional improvements will be required. The right-turn lane warrant and illumination warrant are not met at the intersection under this scenario.

9.2 Normal Operations Scenario

This study provides an operational assessment for two future scenarios with the plant operating under normal conditions: a short-term (2022) scenario and a long-term (2042) scenario. The intersection capacity analysis for both normal operations scenarios indicates that the Highway 813/Chipewyan Lake Road intersection will continue to be operating at a good level of service during the peak hours based on the current lane configuration and traffic control.

The left-turn lane warrant analysis again indicates that a Type IIIa intersection treatment is warranted in both short-term and long-term scenarios, and therefore no geometric improvements will be required beyond today’s configuration. The right-turn lane warrant and illumination warrant are not met at this intersection for both future normal operations scenarios.

Appendix A SEPIKO KESIK PROJECT Updated Transportation Impact Assessment

Correspondence

1

Lo, Chris

From: Peter Ngo (INFTRA) <[email protected]>Sent: Thursday, February 06, 2014 4:30 PMTo: Lo, ChrisCc: Holland, Glen; Ron Fraser; Nitesh Gupta; Helen Tran; Ali BarakatSubject: RE: Osum Sepiko Kesik Project

Hi Chris,

As mentioned before, the TIA should take into account all the existing and planned developments that will share the same accesses.

For your convenience, here is the direct link to Alberta Transportation’s TIA Guideline: http://www.transportation.alberta.ca/Content/docType329/Production/TIA_guideline.pdf. Although not explicitly stated in the TIA Guideline, the following should be included in the TIA report:

Traffic signal should only be considered as the last resort. Other intersection improvements should be considered first (including roundabout, as per Design Bulletin #68).

If intersection improvements are required, please provide the triggered year(s). For example: A Type III is required at opening day, and Type IV in 20 years. We want to know when the Type IV will be triggered.

Specify design vehicle type and turning template For multi-phase developments, consider scenarios of each phase as if the next phase will not occur; i.e. opening

day and 20 year horizon for each phase.

Regards,

(Peter) Doanh Ngo, P.Eng. Highway & Roadside Planning Engineer Regional Strategies and Integration Section Regional Operations & Planning Branch Alberta Transportation Email: [email protected] Tel.: (780) 427-8451

From: Lo, Chris [mailto:[email protected]] Sent: Thursday, February 06, 2014 2:51 PM To: Peter Ngo (INFTRA) Cc: ! GLEN.HOLLAND Subject: RE: Osum Sepiko Kesik Project

Hi Peter,

We have been contracted by Osum Oil Sands Corporation to conduct a TIA for their Sepiko Kesik Project. We would like to confirm with you the following scope of work for the traffic study:

We will review the existing conditions at the site access intersection on Highway 813. This includes a site visit and a traffic count at the subject intersection to record existing traffic volumes and available intersection sight distances.

2

We will gather development information from Osum to establish the site traffic generation levels at the various project time horizons. We will also determine appropriate traffic distribution patterns for the site-generated traffic.

We will estimate short-term and 20-year background traffic volumes at the subject intersection. To complete this task we will require inputs from your Strategic and Network Planning Group to establish suitable traffic growth rates on Highway 813, as well as additional traffic utilizing the intersection from other future developments in the area.

We will assess both background and post-development operating conditions (using Synchro 7 software) at the subject intersection for the following time horizons:

o At peak of construction activity (maximum workforce on site)o Normal plant operating conditions shortly after start-up of the processing facilityo Normal plant operating conditions in the longer future (20-year)o At the time of plant decommissioning (if enough information is available)

We will assess the needs for intersection improvements (operational improvements based on Synchro results, and the standard Alberta Transportation left- and right-turn lane warrants at rural intersections) that may be required to accommodate the anticipated traffic loading at the various time horizons.

We will carry out intersection illumination warrant calculation for the various time horizons. All of the study findings will be documented in a formal report for your review and approval.

Please let us know if the above proposed scope of work is acceptable to you, and don’t hesitate to call me if you have any questions regarding the study.

Thank you and we look forward to your feedback.

Chris Lo, P.Eng. Civil Engineer, Transportation D: 403.270.4878 Cisco Ext. 3614878 [email protected]

AECOM 200 - 6807 Railway Street SE, Calgary, Alberta T2H 2V6 T: 403.254.3301 F: 403.270.9196 www.aecom.com

From: Peter Ngo (INFTRA) [mailto:[email protected]] Sent: Thursday, July 18, 2013 1:03 PM To: Lo, Chris Cc: Holland, Glen; Cathy Maniego; Helen Tran; Moges Gebreleoul; Ron Fraser; Nitesh Gupta Subject: RE: Osum Sepiko Kesik Project

Hi Chris,

Below is the direct link to the Oil Sand Projects map on Alberta Energy’s website.

http://www.energy.alberta.ca/LandAccess/pdfs/OilSands_Projects.pdf

You can find detailed information on each project by going to ERCB website or go directly to the oil sands company’s website.

Regards,

(Peter) Doanh Ngo, P.Eng. Highway & Roadside Planning Engineer Regional Strategies and Integration Section

3

Alberta Transportation Email: [email protected] Tel.: (780) 427-8451

From: Lo, Chris [mailto:[email protected]] Sent: Thursday, July 18, 2013 11:04 AM To: Peter Ngo (INFTRA) Cc: ! GLEN.HOLLAND Subject: Osum Sepiko Kesik Project

Hi Peter,

AECOM is the consultant working on the Traffic Impact Assessment in support of the Osum Sepiko Kesik Project. Osum Oil Sands Corporation is proposing to develop the project site in the M.D. of Opportunity No. 17, and the site is located approximately 75 km northeast of Wabasca-Desmarais and 90 km west of Fort McMurray (please see attached Figure 1). The project site will be accessed via an existing private road, which has a connection to Highway 813 at approximately 8 km east of Wabasca (please see attached Figure 2). Osum proposed to have the majority of the workforce flying in and out, using a regional airstrip that is currently under planning by several other operators in the area. Nevertheless, there will still be some personnel and daily truck traffic accessing the site via the Highway 813 intersection.

Glen Holland at our office contacted you in February for a brief discussion about the project. At that time, you have named other potential development in the vicinity. In order for us to complete an accurate assessment of the traffic impact, is it possible for you to pass along any development information you have in this area?

Please contact me if you have any questions or wish to discuss this request further. Thank you.

Regards,

Chris Lo, P.Eng. Civil Engineer, Transportation D: 403.270.4878 Cisco Ext. 3614878 [email protected]

AECOM 200 - 6807 Railway Street SE, Calgary, Alberta T2H 2V6 T: 403.254.3301 F: 403.270.9196 www.aecom.com

Up-to-date road information, including traffic delays, is a click or a call away. Call 5-1-1 toll-free, visit 511.alberta.ca or follow us on Twitter @511Alberta to get on the road to safer travel.

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4

This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.

1

Lo, Chris

From: Orlando Rodriguez <[email protected]>Sent: Thursday, February 27, 2014 4:30 PMTo: Lo, ChrisCc: Peter Ngo (INFTRA); Holland, GlenSubject: RE: Osum Sepiko Kesik TIA

Hi Chris,

First off, I would like to apologize for not responding sooner. I have been away from the office for a few weeks on a personal matter.

Unfortunately, I cannot comment on which growth rate is reasonable. You will have to use your own engineering judgement as the one that is putting together the TIA. You may want to consider a sensitivity analysis where you use a low, medium and high growth rate to see what effects (if any) it has on your recommendations.

For your second question, the best source for future private developments is probably Peter Ngo.

Orlando Rodriguez, P.Eng. Network Planning and Traffic Monitoring Engineer Investment Strategies Branch Engineering Services Division Alberta Transportation p. (780) 643-1723 | e. [email protected]

From: Lo, Chris [mailto:[email protected]] Sent: Thursday, February 06, 2014 4:17 PM To: Orlando Rodriguez Cc: Peter Ngo (INFTRA); ! GLEN.HOLLAND Subject: Osum Sepiko Kesik TIA

Hi Orlando,

AECOM is the consultant working on the Traffic Impact Assessment in support of the Osum Sepiko Kesik Project. Osum Oil Sands Corporation is proposing to develop the project site in the M.D. of Opportunity No. 17, and the site is located approximately 75 km northeast of Wabasca-Desmarais and 90 km west of Fort McMurray (please see attached Figure 1). The project site will be accessed via an existing private road, which has a connection to Highway 813 at approximately 8 km east of Wabasca (please see attached Figure 2). Osum proposed to have the majority of the workforce flying in and out, using a regional airstrip that is currently under planning by several other operators in the area. Nevertheless, there will still be some personnel and daily truck traffic accessing the site via the Highway 813 intersection.

The two closest locations where Alberta Transportation publishes AADT data are as follow:

Hwy 813:10 – West of TWP RD 801 2002 AADT = 470 2012 AADT = 980 10-Year linear traffic growth rate = 10.9%

2

Hwy 813:10 – East of Hwy 754 SE of Wabasca 2002 AADT = 2020 2012 AADT = 3110 10-Year linear traffic growth rate = 5.4% Based on information provided by Osum, the peak of construction activities would occur in 2017 and full operation of the plant will commence in 2022. For the purpose of estimating future background traffic growth on Highway 813, is it reasonable to assume a higher growth rate (say 8-10% per year) up to the opening day of the plant (2022), and then use a moderate longer term growth rate (say 2-3% per year) to assess future conditions (after 2022)? In addition, do you have any information regarding the future plan of Highway 813 (widening / road improvement) that we should be aware of? Do you have traffic information on other private development that would impact the site access intersection? We knew that Cavalier Energy Ltd (Hoole Project), Laricina Energy Ltd (Germain Project) and Koch (Muskwa Project) will be developed in the vicinity. Please confirm if the above traffic growth rates are appropriate for the study. We would also appreciate if you can provide some insights on traffic information relating to the other development. Thank you. Chris Lo, P.Eng. Civil Engineer, Transportation D: 403.270.4878 Cisco Ext. 3614878 [email protected] AECOM 200 - 6807 Railway Street SE, Calgary, Alberta T2H 2V6 T: 403.254.3301 F: 403.270.9196 www.aecom.com Up-to-date road information, including traffic delays, is a click or a call away. Call 5-1-1 toll-free, visit 511.alberta.ca or follow us on Twitter @511Alberta to get on the road to safer travel. http://511.alberta.ca/ab/en.html https://twitter.com/511Alberta This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.

Appendix B SEPIKO KESIK PROJECT Updated Transportation Impact Assessment

Synchro Output Reports

HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2013 Existing AM Peak

Osum Sepiko Kesik Project TIA Synchro 7 - ReportAECOM Page 1

Movement EBL EBT WBT WBR SBL SBRLane ConfigurationsVolume (veh/h) 4 27 37 7 15 3Sign Control Free Free StopGrade 0% 0% 0%Peak Hour Factor 0.86 0.86 0.86 0.86 0.86 0.86Hourly flow rate (vph) 5 31 43 8 17 3PedestriansLane Width (m)Walking Speed (m/s)Percent BlockageRight turn flare (veh)Median type None NoneMedian storage veh)Upstream signal (m)pX, platoon unblockedvC, conflicting volume 51 84 43vC1, stage 1 conf volvC2, stage 2 conf volvCu, unblocked vol 51 84 43tC, single (s) 4.8 7.1 6.9tC, 2 stage (s)tF (s) 2.9 4.1 3.9p0 queue free % 100 98 100cM capacity (veh/h) 1193 777 870

Direction, Lane # EB 1 EB 2 WB 1 WB 2 SB 1Volume Total 5 31 43 8 21Volume Left 5 0 0 0 17Volume Right 0 0 0 8 3cSH 1193 1700 1700 1700 791Volume to Capacity 0.00 0.02 0.03 0.00 0.03Queue Length 95th (m) 0.1 0.0 0.0 0.0 0.6Control Delay (s) 8.0 0.0 0.0 0.0 9.7Lane LOS A AApproach Delay (s) 1.0 0.0 9.7Approach LOS A

Intersection SummaryAverage Delay 2.2Intersection Capacity Utilization 13.6% ICU Level of Service AAnalysis Period (min) 15

HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2013 Existing PM Peak



Direction, Lane # EB 1 EB 2 WB 1 WB 2 SB 1Volume Total 4 56 48 17 12Volume Left 4 0 0 0 8Volume Right 0 0 0 17 4cSH 1281 1700 1700 1700 813Volume to Capacity 0.00 0.03 0.03 0.01 0.02Queue Length 95th (m) 0.1 0.0 0.0 0.0 0.3Control Delay (s) 7.8 0.0 0.0 0.0 9.5Lane LOS A AApproach Delay (s) 0.6 0.0 9.5Approach LOS A


HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2017 Background AM Peak



Direction, Lane # EB 1 EB 2 WB 1 WB 2 SB 1Volume Total 99 36 50 70 59Volume Left 99 0 0 0 33Volume Right 0 0 0 70 27cSH 1272 1700 1700 1700 620Volume to Capacity 0.08 0.02 0.03 0.04 0.10Queue Length 95th (m) 1.9 0.0 0.0 0.0 2.4Control Delay (s) 8.1 0.0 0.0 0.0 11.4Lane LOS A BApproach Delay (s) 5.9 0.0 11.4Approach LOS B


HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2017 Background PM Peak





HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2017 Peak Construction AM Peak





HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2017 Peak Construction PM Peak





HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2022 Short Term Normal Operations AM Peak





HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2022 Short Term Normal Operations PM Peak





HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2042 Long Term Normal Operations AM Peak





HCM Unsignalized Intersection Capacity Analysis3: Highway 813 & Chipewyan Lake Road 2042 Long Term Normal Operations PM Peak





Appendix C SEPIKO KESIK PROJECT Updated Transportation Impact Assessment

Left-Turn/Right-Turn Lane Warrant Worksheets

Project Number: 60286723Project Name: Osum Sepiko KesikIntersection: Highway 813 / Chipewyan Lake RoadRoadway: Highway 813Direction: EBTime Period: AM PeakScenario: 2017 Peak of ConstructionDesign Speed: 110 / 120 / 130 km/h

1. Warrant for Right Turn Lane. To warrant an exclusive right turn lane at a two-lane highwayintersection in Alberta, the following three conditions must all be met:

a. Main Road (Highway 813) AADT 1800 vpd vpdb. Intersecting road (Chipewyan Lake Road) AADT 900 vpd vpdc. Right turn daily traffic volume AADT 360 vpd vpd

A right turn lane is not warranted.

2. Warrant for Left Turn Lane. When making a left turn into the driveway, the turning vehiclemay be delayed by a vehicle or vehicles in the opposing stream. Through vehicles in theadvancing stream following the left-turning vehicle may be delayed by, or exposed to collisionwith turning vehicle. The interference caused by standing left turning vehicles in the throughadvancing traffic can reduce capacity and create a safety hazard. The amount of interferenceis dependent on opposing volumes, advancing volumes and the number of left turning vehicles.

a. Number of left-turning vehicles per hour 91 vphb. Advancing volume 122 vphc. Proportion of left turns in Va L = V Va = 91 122 = 75 %d. Opposing volume 116 vph

A left turn lane (non-exclusive) with a Type III intersection treatment is warranted.

Alberta Transportation Intersection Improvement Warrant Analysis

Vo = 0 + 43 + 73 =

1550950290

V =Va = 91 + 31 + 0 =

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

Project Number: 60286723Project Name: Osum Sepiko KesikIntersection: Highway 813 / Chipewyan Lake RoadRoadway: Highway 813Direction: EBTime Period: PM PeakScenario: 2017 Peak of ConstructionDesign Speed: 110 / 120 / 130 km/h






A left turn lane is not warranted.


Vo = 0 + 50 + 34 =

1550950290

V =Va = 27 + 58 + 0 =


Project Number: 60286723Project Name: Osum Sepiko KesikIntersection: Highway 813 / Chipewyan Lake RoadRoadway: Highway 813Direction: EBTime Period: AM PeakScenario: 2022 Short Term Normal OperationsDesign Speed: 110 / 120 / 130 km/h








Vo = 0 + 50 + 63 =

1650850240

V =Va = 109 + 37 + 0 =


Project Number: 60286723Project Name: Osum Sepiko KesikIntersection: Highway 813 / Chipewyan Lake RoadRoadway: Highway 813Direction: EBTime Period: PM PeakScenario: 2022 Short Term Normal OperationsDesign Speed: 110 / 120 / 130 km/h






A left turn lane is not warranted.


Vo = 0 + 58 + 31 =

1650850240

V =Va = 29 + 68 + 0 =


Project Number: 60286723Project Name: Osum Sepiko KesikIntersection: Highway 813 / Chipewyan Lake RoadRoadway: Highway 813Direction: EBTime Period: AM PeakScenario: 2042 Long Term Normal OperationsDesign Speed: 110 / 120 / 130 km/h








Vo = 0 + 69 + 60 =

2100800230

V =Va = 87 + 50 + 0 =


Project Number: 60286723Project Name: Osum Sepiko KesikIntersection: Highway 813 / Chipewyan Lake RoadRoadway: Highway 813Direction: EBTime Period: PM PeakScenario: 2042 Long Term Normal OperationsDesign Speed: 110 / 120 / 130 km/h






A left turn lane (non-exclusive) with a Type II intersection treatment is warranted.


Vo = 0 + 80 + 27 =

2100800230

V =Va = 23 + 93 + 0 =


Appendix D SEPIKO KESIK PROJECT Updated Transportation Impact Assessment

Intersection Illumination Warrant Worksheets

Warrants for Intersection Lighting (See Note 2) Road Name Highway 813:10

From km 27 to km 29From: Transportation Association of Canada (TAC) "Illumination of Isolated Rural Intersections" (Feb. 2001) City Wabasca

Warrant Undertaken By Chris LoCompany Name AECOM

2017 Peak of Construction Conditions Date 24-Oct-14

Item No ClassificationFactor

Weight Subcategory (if applicable) Weight (W) Enter 'R' Here Score:

'R' x 'W'

0 1 2 3 4

Raised and Operating Speed Less Than 70km/h on at Least One Channelized

Approach or

15 0 0

Raised and Operating Speed Less Than 70km/h or More

on at Least One Channelized Approach or

20 0 0

Painted Only 5 3 15

2Approach Sight Distance on the Most Constrained

Approach (Relative to Recommended Minimum Intersection Sight Distance)

100% or More 75% to 99% 50% to 74% 25% to 49% < 25% 10 0 0

Horizontal Curvature (Radius) at or Immediately Before Intersection on Any Leg for Posted Speed Limit of:

110 km/h: Tangent > 1800 m 1150 to 1800 m 750 to 1150 m < 750 m90 or 100 km/h: Tangent > 1400 m 950 to 1400 m 600 to 950 m < 600 m

70 or 80 km/h: Tangent > 950 m 550 to 950 m 340 to 550 m < 340 m60 km/h: Tangent >575 m 320 to 575 m 190 to 320 m < 190 m

4 Angle of Intersection or Offset Intersection 90 Degree Angle 80 or 100 Degree Angle - 70 or 100 Degree Angle < 70 or >100 Degree

or Offset Intersection 5 0 0

5 Downhill Approach Grades at or Immediately Before Intersection on Any Leg < 3.0 %

3.1 to 3.9% and Meets Design Guidelines for Type and Speed of

Road


Road

5.0 to 7.0% and Meets Design Guidelines for

Type and Speed of Road

> 7.0% OR Exceeds Maximum Gradient for


3 0 0

6 Number of Legs - 3 4 5 6 or More 3 1 318 G

EitherAADT (2-way) (See Note 1)

On Major Road and < 1000 1000 to 2000 2000 to 3000 3000 to 5000 > 5000 10 1 10

On Minor Road OR <500 500 to 1000 1000 to 1500 1500 to 2000 > 2000 20 1 20

Signalization Warrant (See Note 1)

Intersection Not Signalized and Volume-Based Signal Warrant

is Less than 20% Satisfied


is 20% to 40% Satisfied

Intersection Not Signalized and Volume-Based Warrant is 40%

to 60% Satisfied

Intersection Not Signalized and Volume-Based

Warrant is 60% to 80% Satisfied

Intersection Not Signalized and Volume-Based Warrant is Over

80% Satisfied

30 0 0

8Regular Nighttime Hourly Pedestrian Volume

(See Note 2) No Pedestrians Up to 10 10 to 30 30 to 50 Over 50 10 0 0

9 Intersecting Roadway Classifications No Primary Road Involved

Primary/Rural Major, Primary/Rural Minor OR

Primary/Designated Community Access

Primary/ Secondary Primary/ Primary Intersection Includes Divided Highway 5 1 5

10Operating Speed or Posted Speed Limit on Major Road

(See Note 3) 50 km/h or Less 60 km/h 70 km/h 80 km/h 90 km/h or Over 5 4 20

11Operating Speed or Posted Speed Limit on Minor Road


70 O

12 Lighted Development Within 150 m Radius of Intersection - In One Quadrant In Two Quadrants In Three Quadrants In Four Quadrants 5.00 5 0 0

0 E

1 or 2 Collisions per Year 15 0 0

3 or More Collisions per Year or Rate >= 1.5 Collisions/MEV 30 0 0

0 A

G + O + E + A = Total Warranting Points 88Warranting Condition 120

Difference +/- -32 D

NOTES: 1. If the intersection is not signalized, the user should choose EITHER the AADT factor OR the signalization factor. The points from either factor, but not both factors, may be used for the warrant point calculations2. The number of certain types of vulnerable pedestrians should be factored to reflect their increased need for visibility.

The number of child pedestrians (ages 12 and under) should be multiplied by two, and the number of senior pedestrians (age 65 and over) should be multiplied by 1.5. Collisions: 2009 03. 85th percentile nighttime speed should be used, if available. Otherwise the posted speed may be used. 2010 04. Reported collisions, rounded to the nearest whole number. 2011 0

Only ONE 'R' Value is to be Entered for These Three Rows

Rating Factor (R)

Left and Right Turn Lanes on All Legs

Left Turn Lane(s) on Major Leg(s)

Right Turn Lane(s) Only on Major Leg(s)

Right and/or Left Turn Lanes on Minor Approach Only

None

Only ONE 'R' Value is to be Entered for These Two Rows

3

Subtotal Geometric Factors

5 0 0

Subtotal Environmental Factors

Geometric Factors (G)

Operational Factors (O)

Environmental Factors (E)

Subtotal Operational Factors

If the intersection is signalized, illumination is warranted. If the intersection is NOT signalized, Points should be calculated on the Basis of EITHER the AADT Factor OR the Signalization Warrant Factor

7

Channelization1


Subtotal Collision Factors

Collision Factors (A)

13Average Annual Nighttime Collision Frequency (See Note

4) or Rate Over Last Three Years (Only Collisions Potentially Attributable to Inadequate Lighting)

0 Collisions per Year 1 Collision per Year -

3 or More Collisions per Year OR At Least 1.5 Collisions

per Million Entering Vehicles per Year and an Average Ratio of All Night-to-Day Collisions of At Least 1.5




2022 Short Term Normal Operations Conditions Date 24-Oct-14



'R' x 'W'

0 1 2 3 4


Approach or

15 0 0



20 0 0

Painted Only 5 3 15



100% or More 75% to 99% 50% to 74% 25% to 49% < 25% 10 0 0








Road


Road





3 0 0











to 60% Satisfied




80% Satisfied

30 0 0











70 O


0 E



0 A






Rating Factor (R)





None


3


5 0 0







7

Channelization1












2042 Long Term Normal Operations Conditions Date 24-Oct-14



'R' x 'W'

0 1 2 3 4


Approach or

15 0 0



20 0 0

Painted Only 5 3 15



100% or More 75% to 99% 50% to 74% 25% to 49% < 25% 10 0 0








Road


Road





3 0 0











to 60% Satisfied




80% Satisfied

30 0 0











80 O


0 E



0 A






Rating Factor (R)





None


3


5 0 0







7

Channelization1









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