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Informational Letter IL 89-5

11 May 1989

TO: ALL IN SITU OIL SANDS OPERATORS

WATER RECYCLE GUIDELINES AND WATER USE INFORMATION REPORTING FOR IN SITU OIL SANDS FACILITIES IN ALBERTA

The Energy Resources Conservation Board and Alberta Environment have detailed their decision respecting water recycle and water use information reporting at all in situ oil sands facilities in the attached document ERCB-AE 89-AA Water Recycle Guidelines and Reporting of Water Use Information for In Situ Oil Sands Facilities in Alberta. The guidelines and reporting requirements are effective immediately.

Inquiries concerning this letter or the attached document may be directed to the ERCB's Oil Sands Department at 297-3510, or to the Planning Division of Alberta Environment at 427-8985.

[signed by]

ENERGY RESOURCES CONSERVATION BOARD
N.A. Strom
Vice Chairman

and

ALBERTA ENVIRONMENT
P. G. Melnychuk
Assistant Deputy Minister

ERCB-AE 89-AA
Water Recycle Guidelines and Reporting of Water Use Information for In Situ Oil Sands Facilities in Alberta

May 1989

1 INTRODUCTION

Recognizing that the continued development of oil sands resources by in situ recovery methods will place large demands on Alberta's water resources, the Energy Resources Conservation Board (ERCB) and Alberta Environment (AE) have set out goals and guidelines to manage and conserve the available water supply.

The ERCB and AE, with the objectives of reducing freshwater requirements and wastewater disposal volumes, have as a goal the maximization of water recycling at all in situ oil sands projects. In working toward this goal, operators can expect regulatory approvals for those projects to address water reuse and to include water recycle stipulations. Such stipulations will include as a minimum the expected rate of recycle and a timetable for the implementation of water recycle. To assist those operators in the preparation of the necessary regulatory applications, the following guidelines have been adopted to outline and clarify the criteria used by the ERCB and AE when setting the recycle requirements for specific projects.

2 GUIDELINES FOR WATER RECYCLE

1. All in situ operators with freshwater requirements exceeding approximately 500 dam³/year (500 000 m³/year) will be required to recycle produced water. All in situ operators with freshwater requirements below 500 dam³/year will be required to actively investigate and test recycle technology.

   Oil sands operators have demonstrated that water recycle at large-scale projects can be efficient and economic. Experience to date would indicate that recycling is practical for projects where the freshwater demand exceeds approximately 500 dam³/year. Recycling at some smaller projects may not be as practical given the absence of the economics of scale characteristic of larger projects. Also, in some other cases, there may be only limited data available on produced water quality and quantity. In each case, however, the ERCB and AE would require that operators actively pursue the development and implementation of an appropriate recycle technology.

2. The target recycle rate assigned to a project will be based on produced water and will be defined as an annual level.

   As produced water recycle accounts for the greater part of the potential water reuse, target recycle rates will be based on produced water. The upper limit of the target rate will be 100 per cent or a rate sufficient to meet the total project water requirement, whichever is less.

   The actual target recycle rate designated by the ERCB and AE would be based primarily on the produced water quality - more specifically, the concentration of dissolved solids, the hardness, and the silica content. The target recycle rate would also take into consideration any environmental, technical, and economic factors that are demonstrated to be significant and limiting. It will be the responsibility of the applicant to demonstrate that factors are significant and limiting for a specific project.

   The ERCB and AE recognize that, in the province, experience with water recycle technology is varied and with some companies limited. Therefore, for those projects where new recycle facilities are to be incorporated into the plant, a phase-in period of 1 year, or other such period as stipulated in approvals and licences, would be allowed to reach the designated target recycle rate "granted".

3. These guidelines must be addressed in regulatory applications that are reviewed by the ERCB and AE.

   The ERCB and AE consider the development and incorporation of water recycle technology an integral part of all in situ oil sands projects. As such, water recycling must be addressed in the appropriate regulatory applications and supporting documents for these projects. These may include but are not limited to Environmental Impact Assessments, project and subsurface disposal applications to the ERCB, and any application to AE pursuant to the Water Resources Act and the Clean Water Act.

3 WATER USE REPORTING

Improved reporting of water use information is required by Alberta Environment to confirm that this goal is being achieved. A review of industry monitoring indicates the basic data needed by Alberta Environment is currently collected as part of the S series of monthly reports to the ERCB. The ERCB has agreed to provide the Department with the pertinent water information reported on these forms.

The resulting administrative change between the ERCB and Alberta Environment will not require any major changes in data collection or reporting by industry. More effective use of information now reported by industry to the ERCB will improve decision-making, minimize duplication, and reduce reporting under environmental protection approvals.

Inquiries regarding these guidelines may be directed to the ERCB's Oil Sands Department at 297-3510, or the Planning Division of Alberta Environment at 427-8985.