Thermal in situ oil sands operations use steam to soften underground oil sands and bring bitumen deposits to the surface. The public is invited to comment on newly proposed rules for thermal water use for thermal in situ oil sands recovery by no later than April 1, 2009. On February 18, 2009 Alberta Environment and the Energy Resources and Conservation Board (ERCB) proposed new rules designed to limit freshwater use by thermal in situ oil sands operations that will largely affect groundwater use. If approved after a public comment period, the regulations would set a water recycle formula while minimizing freshwater use. The directive would also set more firm criteria for reporting fresh, saline, and recycled water use and establish enhanced monitoring and reporting requirements affecting in situ operations in the Beaver, Athabasca, and Peace River basins.

New! Read submitted comments from the Environmental Law Centre

Specifically, the directive would require operators of thermal in situ oil sands operations to maximize the use of recycled water by limiting freshwater use to 10 percent of the annual water use requirements and 25 percent from brackish (saline) water resources. The remaining water would therefore be required to come from recycled sources.

Recycling limits and limits on freshwater use are not new. Since 1989, the Energy and Utilities Board (now the ERCB) required the establishment of water recycling rates for in situ thermal water use as part of project approvals. Recycling rates included within EUB approvals have varied depending on the type of technology used. Until now, the EUG recycling rate related to fresh (non-saline) water rather than total water used. By contrast, the proposed directive aims to address total water use and sets consistent standards for the whole sector, likely affecting some operations not already reaching the target recycling and freshwater use targets in the directive.

Updated rules on water use for in situ oil sands recovery

According to the proposed directive, the following changes would occur to the current management system:

1. The draft directive requires operators to monitor and report all water streams. Monitoring is required for calculating water balances.

2. The use of fresh and brackish water will be limited to a specified percentage of total water use whereas in the past there was significant flexibility with respect to reporting and use.

3. For operations that use more than 500,000 cubic metres annually (fresh and/or brackish), operators are required to meet water use targets for fresh, brackish, and recycled water.

Three types of water are used in thermal in situ operations:

1. Fresh water (or non-saline water of not more than 4,000 mg/l total dissolved solids) from surface or groundwater sources.
2. Brackish or saline groundwater. Under the Alberta Water (Ministerial) Regulation, May 6, 1999, "‘saline groundwater means water that has total dissolved solids exceeding 4000 milligrams per litre". In the draft directive the ERCB uses the term "brackish" which is defined, for the purpose of the directive, in the same way as saline groundwater.
3. Produced water recovered in association with the oil produced from the well.

Water use targets

Under the proposed directive, freshwater must not exceed more than 10 percent of the total annual water use for an individual operation. If brackish or saline water is used by an in situ operation, it must not exceed 25 percent of the total annual water use. Together, the use of brackish and freshwater must not exceed 25 percent of water use. As a result of these limits, produced water, through capture and recycling, must account for a minimum of 90 percent of the water consumption needs if fresh water alone is used but no less than 75 percent of the water consumption requirements if both fresh and brackish water are used.

Existing thermal in situ schemes will be given five years to phase in the new limits. For new thermal in situ schemes, enforcement of the new limits will be relaxed for the first twelve months of steam injection to allow for the initial retention of steam in the reservoir.

Increasing use of groundwater for in situ bitumen recovery

While the volume of surface water used for thermal in situ bitumen recovery remained roughly constant between 2001 and 2007, the total volume of groundwater allocated and use increased substantially, doubling between 2002 and 2007, with saline water use growing faster than the growth in freshwater use.

Today, operators of in situ oil sands operations actually use 14 million cubic metres (88.2 million barrels) of freshwater annually. The volume of water allocated is larger, but since some operations are still being built or not yet operating at full capacity water used is less than allocated.

Future projected water use and potential impact of Directive

According to the ERCB, the production of bitumen from in situ operations is expected to increase by 140 percent by 2015 with a corresponding increase in water use. It is projected that thermal in situ bitumen production will increase from 69,700 cubic metres per day in 2005 to 170,000 cubic metres by 2015. Forecasts of water use for thermal recovery in the Athabasca River Basin (largely consisting of bitumen production) is projected to increased by 378 percent by 2015 under a "low growth scenario." According to Alberta Environment, only 33 percent of the total oil sands water allocations (surface and groundwater for mining and in situ operations) were being utilized by 2005.

For more detailed information regarding water consumption for oilfield injection including water use for in situ production in the Beaver, Athabasca, and Peace River Basins as of 2007, go to Heating Up in Alberta by the Pembina Institute Figure 3-10, p. 40.

It is unclear to what extent the directive will address the projected increase in the use of water for thermal in situ bitumen recovery. While the government estimates that implementation of the directive would save approximately 35 million cubic metres (220.5 million barrels) of fresh water over the next decade, the Directive does not ensure that the cumulative impacts to aquifers will be prevented. In addition, it should be noted that the directive does not address the use of cold freshwater to extract oilsands (waterflood) which occurs in the Peace River Basin.

Electronic feedback on the draft directive, which is available on the ERCB website www.ercb.ca under Industry Zone: Rules, Regulations, and Requirements: Directives. Feedback on this draft directive is being invited from February 18, 2009 until April 1, 2009. Send feedback to thermalinsitu@ercb.ca.

Feedback should include:

1. Company or individual name,
2. Contact Information,
3. The specific section(s) of the draft directive that you wish to provide feedback on,
4. The issue, and
5. Your possible solutions, recommendations, and comments.

If you have additional questions, contact Tom Keelen, ERCB, or Sarah Moody, AENV, at thermalinsitu@ercb.ca

Sources

Cooper, Dave. February 18, 2009. Oilpatch to see new rules on water use: Proposal calls for lower consumption. The Edmonton Journal.

Alberta Environment. 1990. Ground Water Allocation for Oilfield Injection Announced, News Release and Fact Sheet, March 27. This is reproduced as Appendix A in Alberta Environment. 2003. Groundwater Evaluation Guidelines: Information Required when Submitting an Application under the Water Act.

Alberta Energy and Utilities Board. 1989. Water Recycle Guidelines and Water Information Reporting for In Situ Oil Sands Facilities in Alberta.

Griffiths M., A. Taylor, D. Woynillowicz. May 2006. Troubled Waters, Troubling Trends. Technology and Policy Options to Reduce Water Use in Oil and Oil Sands Development in Alberta. The Pembina Institute.

Griffiths, M, and D. Woynillowicz. February 2009. Heating Up in Alberta: Climate Change, Energy Development and Water. The Pembina Institute.

Energy Resources Conservation Board and Alberta Environment. February 18, 2009. ERCB and Alberta Environment call for input on thermal in situ oil sands water use. Press Release.

Energy Resources Conservation Board. February 2009. Requirements for Water Measurement, Reporting, and Use for Thermal In Situ Oil Sands Schemes. Draft.

Alberta Environment. 2006. Water Conservation and Allocation Policy for Oilfield Injection.