Frontier Oil Sands Mine Project Joint Review Panel

Transcription

1 Frontier Oil Sands Mine Project Joint Review Panel December 16, 2016 Teck Resources Limited Attention: Sheila Risbud, Regulatory Manager, Energy Subject: Additional Information Required from Teck Resources Limited. Dear Ms. Risbud: The Joint Review Panel (the Panel) is reviewing the information submitted by Teck Resources Limited (Teck) to date for the Frontier Oil Sands Mine Project (the Project) as well as comments received in response to the public comment period which ended on October 17 th, The purpose of the review is to determine whether the information provided is sufficient to proceed to the public hearing stage of the review. Based on its review to date, the Panel has determined that additional information is required to allow it to meet the requirements outlined in the Joint Review Panel Agreement for the Project and the Panel s Terms of Reference before proceeding to a hearing. The attachment to this letter contains requests for additional information related to acoustics and air emissions. In some cases, components of the requested information may or may not be present in the Project Update, SIR responses or SOC responses, but spread throughout several sections or documents. In such cases, it would be helpful to the Panel and the other participants to present the information in a single, easily read response. The Panel s review will continue, and additional requests for information related to other disciplines will follow at a later date. If you require clarification with regard to these information requests, do not hesitate to contact David Haddon or Tara Wheaton, the Panel co-managers, at Frontier.Review@ceaa-acee.gc.ca. Yours truly, <Original signed by> Alex Bolton Chair, Joint Review Panel cc: Scott McKenzie, Teck Resources Limited Attach. c/o Canadian Environmental Assessment Agency 160 Elgin Street, 22nd floor, Ottawa ON K1A 0H3 Frontier.Review@ceaa-acee.gc.ca

2 Frontier Oil Sands Mine Project Joint Review Panel Information Request Package #3 December 16, 2016 Acoustics IR 3.1: Teck is proposing a speaker-type bird deterrent system with speaker locations along the internal and external tailings areas waterbody perimeter. Table 3-4 in Volume 3 of the Project Update lists the acoustics modelling parameters used in Teck s acoustic assessment. The table indicates that the model includes a ground absorption value of 0.6. Clarify if Teck has modelled the waterbody as reflective. If not, how would modelling the waterbody as reflective change the modelling results? IR 3.2: In Section 3.5 of the Project Update, Teck states that its management and monitoring for noise associated with aircraft activities will be similar to the management and monitoring conducted for noise associated with other non-aircraft Project activities including mine operations. Teck states that monitoring will verify noise associated with Project activities are in compliance with Directive 038. However, Directive 038 does not regulate aircraft noise. Provide applicable guidelines for noise from aircraft in the vicinity of aerodromes and describe how Teck will manage and monitor aircraft noise to verify compliance. IR 3.3: As discussed in Section of the Project Update, rather than conduct baseline noise monitoring within the LSA and at Poplar Point to identify actual ambient sound levels, Teck has assumed a default baseline sound level of 35 dba (decibel, A-weighted). While this is permitted under Directive 038, actual ambient sound levels may be higher or lower. Provide justification for not performing ambient noise monitoring within the LSA to identify actual baseline sound levels. Provide justification for not performing baseline ambient noise monitoring at Poplar Point or other receptor locations. Discuss Teck s level of confidence that the default baseline sound level accurately represents actual sound levels in the LSA and at Poplar point and how the results 1

3 of the noise assessment would change if the actual existing ambient noise levels are higher or lower than the 35 dba default used in the assessment. Air Quality IR 3.4: In Volume 3, Appendix 4A of the Project Update, Teck provides the stack parameters and parameters for the Project heaters and boilers that meet the Alberta Interim Emission Guidelines for Oxides of Nitrogen (NO x ) for New Boilers, Heaters and Turbine using Gaseous Fuels for the Oil Sands Region in the Regional Municipality of Wood Buffalo North of Fort McMurray based on a Review of Best Available Technology Economically Achievable (BATEA). On June 29, 2016, Environment and Climate Change Canada released the Multi-Sector Air Pollutants Regulations (MSAPR); which requires more stringent NO x limits. a) Describe how Teck will meet MSAPR requirements. b) Confirm that equipment and stack parameters, aside from NOx emission rates, remain unchanged in meeting MSAPR requirements. c) If equipment and stack parameters are expected to change, discuss how the changes will impact the conclusions from the air quality assessment. d) Describe or justify how the equipment selected and the corresponding emission performance standards represent BATEA. IR 3.5: NO x is a criteria air contaminant of increasing management concern in the Alberta mineable oil sands region. Once in force, the new Canadian Ambient Air Quality Standard (CAAAQ) for NO 2 will increase the need to manage and mitigate NO x emissions for the industry. Teck is proposing the use of dry low NOx 1+ (DLN) technology rather than selective catalytic reduction (SCR) for its cogeneration turbines. a) Compare the NO x emissions between DLN and SCR technologies; provide detailed calculations and sources of values used. b) Provide a cost/benefit analysis that compares the costs and environmental performance of DLN and SCR technologies. 2

4 IR 3.6: In Volume 3, Section of the Project Update, Teck states: Increases of NO x and SO x emissions are attributable only to increases in NO x. This statement contradicts the air assessment model, which predicts an increase in SO x deposition. Explain the contradiction between the above statement and the air model predictions. IR 3.7 In the Project Update, Teck states that because the model takes into account the retention of snowmelt substances in the terrestrial environment during overland flow, measured concentrations in snow would be expected to be higher than in modelled snowmelt at the edge of a creek or lake. However, some of the modelled metals and PAH concentrations were actually higher than the measured concentrations, which contradicts this hypothesis. Teck states that this is because the aerial deposition model incorporated conservative assumptions. However, it is unclear why this would result in only a few substances being over-predicted when others were under-predicted. a) Describe the modelling assumptions used in metals and PAH deposition modelling, and justify how these assumptions can be considered conservative. b) Provide an explanation for the variation between measured data and modelled results, and qualitatively or quantitatively demonstrate the resulting prediction confidence. IR 3.8: The Project Description and EIA contain numerous references to the Cumulative Effects Management Association (CEMA) and the Alberta Environmental Monitoring, Evaluation and Reporting Agency (AEMERA). CEMA and AEMERA have both ceased operations. a) Discuss how CEMA and AEMERA ceasing operations will change the Project commitments made by Teck or any of the conclusions of the EIA with respect to air emissions and air quality. b) Identify any regional monitoring and/or research initiatives related to air emissions or air quality in the Athabasca Oil Sands Region that Teck is either currently participating in, or is committed to participating in, should the project be approved. 3

5 IR 3.9: In response to Provincial SIRs (AER) 5: EIA Question 49a, Teck states that "The updated emissions profile will be verified by emission source monitoring." Teck also states that "The associated monitoring programs will include combustion and fugitive emission sources." a) For fugitive emissions sources, discuss the technology, frequency of monitoring, and pollutants that are being considered for source monitoring. b) Discuss what specific fugitive emission sources are being considered for source monitoring. IR 3.10 In the response to Round 5 SIR Question 170, Teck acknowledges recent research that has demonstrated the formation of secondary organic aerosols (SOA) downwind of oil sands activity. In its October 17, 2017 submission to the Panel, Environment and Climate Change Canada (ECCC) is of the view that SOA can make up a significant proportion of PM 2.5, which is known to have negative impacts on air quality, human health and climate. ECCC also states that emissions of organic compounds with intermediate- and semi-volatility from the oil sands contribute significantly to the formation of SOA downwind. This results in increased concentrations of organic aerosols and PM 2.5 far from the Project site a) Evaluate and quantify (where possible) the potential of the Project to contribute to SOA in the atmosphere by identifying emission sources of SOA precursor compounds. b) Describe how Teck proposes to mitigate the Project s contribution to SOA formation in the atmosphere. c) Describe how Teck will monitor the emission of SOA precursor compounds throughout the life of the Project. IR 3.11 To assess potential effects on air quality, Teck has conducted an air dispersion modelling assessment using a five year meteorological data set that represents a wide range of meteorological conditions. Meteorology has a large influence on the resulting ambient air quality, where certain conditions can be conducive to poor air quality. It is uncertain if the five year meteorological data set used by Teck sufficiently accounts for meteorological variability that can be driven by climate change; hence, there is uncertainty in the air quality predictions as they relate to climate change variability. 4

6 a) Describe the variability within the five year meteorological data set used, and determine if that variability sufficiently represents the impacts from future climate change influences and resultant effects on air quality. b) If the five year meteorological data set does not sufficiently represent future climate change influences, discuss and quantify the meteorological conditions that may affect ambient air quality. IR 3.12 In its air quality cumulative effects assessment, Teck models the effects of the Project on regional air quality. However, potential effects on the Peace-Athabasca Delta and Wood Buffalo National Park were not explicitly quantified or assessed. a) Assess whether there are likely to be measurable, cumulative adverse effects on air quality, deposition, or acid input to the Peace-Athabasca Delta and Wood Buffalo National Park. b) If statistically significant effects on the Peace-Athabasca Delta and Wood Buffalo National Park are predicted, describe how Teck proposes to mitigate and manage those effects. IR 3.13 Due to the nature of Projects operations, there is a possibility of odour causing events occurring, which may affect the residents of neighbouring communities. In Volume 1, Section of the Project Update, Teck states that an ongoing communication protocol between operators and community members to work within or improve any existing odour management plans needs to be established. The details of a comprehensive odour management and response plan are required to provide confidence that odour effects from the Project can be appropriately managed and mitigated. Provide a comprehensive odour management and response plan. The plan should detail Teck s strategy/approach to managing and mitigating odours, describe how Teck will communicate odour related issues with stakeholders, and describe Teck s proposed response to odour events. IR 3.14 Teck s fine fluid tailings (FFT) methane emissions estimates are intended to represent peak mine production. However, peak mine production may not reflect peak methane production from the FFT facilities. Maximum FFT volumes may not occur at the same point in time as peak mine production, which would result in a delay of peak methane production from the FFT. 5

7 Discuss the uncertainty relating to the timing and magnitude in FFT methane emissions and how this was considered in Teck s assessment. Does the timing of peak FFT methane emissions affect Teck s estimate of the magnitude of peak methane emissions from the Project? IR 3.15 Teck states that it will develop a comprehensive greenhouse gas (GHG) management plan during the feasibility and detailed engineering stages of the Project. Teck describes its current plan for managing GHG emissions as including: Awareness of regulations and guidelines for GHG emissions reduction; Confirmation from the Government of Alberta that the Project is "best-in-class"; and Identification of additional GHG reduction opportunities during engineering phases. Over 90% of the Project's GHG emissions will be from energy-related sources (cogeneration, boilers/heaters and mine fleet). Teck has committed to continual improvement in the efficiency of energy use and emission reduction technologies. Teck also states that a detailed plan would be informed by guidance from provincial and federal governments as well as outcomes from the Joint Review Panel s review. Section 2.7 [A](c) of the Final Terms of Reference for the Environmental Impact Assessment Report (CEAR #9) require a discussion of how the Project s greenhouse gas emissions intensity compares to other similar Projects. In Volume 1, Section of the Project Update, Teck provides estimated GHG emissions intensities for three other oil sands mining projects. Two of these projects (Joslyn North Mine and Jackpine Mine Expansion) have not been developed. In addition, the emission intensity range presented for the Kearl Oil Sands project originated from that project s application. There is no comparison of the Project s GHG emission intensity to any operating oil sands mining project provided. In its Climate Leadership Plan, the Government of Alberta has announced its intention to establish a 100 mega ton (MT) annual cap on GHG emissions from the oil sands and to reduce methane emissions from the oil and gas sector by 45% by Although details regarding the legislative framework and regulatory implementation plan associated with these policies have not yet been announced, these requirements may affect allowable emissions from the Project. a) Describe those elements of the GHG management plan (both the current and proposed detailed versions) that would support the statement that the Project is "best in-class" relative to similar oil sands mining projects. b) Provide a discussion of the efficacy of leading and emerging GHG mitigation technologies. 6

8 c) Provide details for the development and implementation of an energy management system to achieve the objective of continual improvement in energy efficiency and related GHG emissions mitigation. d) Summarize how Teck will quantify all sources of GHGs and the quality controls to ensure credible data is gathered. e) Provide a comparison of the project s estimated emission intensity to the historical intensities of currently operating, comparable oil sands mines. f) Discuss the potential implications to the Project of the Government of Alberta s proposed 100 MT annual cap on GHG emissions from the oil sands and 45% reduction in methane emissions from the oil and gas sector by What technologically and economically feasible management actions would be available to respond to future GHG and methane emission reduction policies? IR 3.16 Teck s estimate of GHG emissions intensity appears to be based on peak mine operation at a steadystate. It is not clear if upsets or malfunctions are considered in the intensity or overall total GHG estimates. Under CEAA 2012, and as required by the Panel s Terms of Reference for the review, the Panel is required to assess the potential adverse environmental effects of potential accidents and malfunctions associated with the Project. a) Describe upset/malfunction scenarios that may result in increased GHG emissions. b) Provide the upset/malfunction GHG intensity and a total emissions estimate. Provide the associated calculations. IR 3.17: In Volume 1, Section of the Project Update, Teck states that Emissions from the plant and related ore processing facilities will be reduced through: allocation of an area within the plant for future carbon capture and sequestration facilities should the need be identified. This implies that Teck has taken into consideration the use of carbon capture and sequestration (CCS) technology as a means of reducing GHG emissions. a) Describe how Teck considered and evaluated the use of CCS for the Project. b) Explain why CCS technology is not currently planned for the Project. 7

9 IR 3.18: The Project has the potential to adversely affect regional air quality, including air quality in the vicinity of Indigenous and urban communities. Teck makes numerous references to the use of adaptive management throughout the Environmental Impact Assessment. While general principles are discussed, no specific adaptive management plans are provided. For areas where predicted effects of the Project or the effectiveness of mitigation measures are uncertain, additional detail is required to assess the economic and technical feasibility of adaptive management as a mitigation strategy. Provide draft air quality monitoring plan. Provide a draft adaptive management plan to ensure effective mitigation of the effects of the Project on air quality. Specifically, the adaptive management plan should include: A description of the potential adverse effects of the Project on air quality that require mitigation; A description of the uncertainties that necessitate the use of adaptive management, including but not limited to, the influence of future climate change on meteorological conditions; A clear statement of the mitigation objective being pursued and identification of indicators that will be used to determine whether mitigation measures are effective; Details of the plan to monitor the indicators identified above, Thresholds that monitoring results will be compared to that will trigger the implementation of alternative management actions or mitigation measures; and A description of the technically and economically feasible management actions or mitigation measures that Teck will implement if thresholds are exceeded. 8