Environmental protection order: Updates on Imperial’s actions

On May 4, Environment and Climate Change Canada (ECCC) announced it has started an investigation into the situation at Kearl. Imperial is cooperating with the department. We have been providing information on the situation at Kearl and have hosted regulatory officials for tours and testing at our site.

Imperial continued to advance work to address shallow seepage and collect water on site. Pumping systems are operating at all four seep locations and work is continuing to complete final seep mitigations. Collection systems are being activated and continuous monitoring is also in place to ensure mitigations are working as intended. As work is completed in some areas, work crews are being demobilized from the site. About 150 people continue to work on related activities at the site.

Total off-lease surface area impacted by seepage locations covers about one hectare. Additional fencing continues to be installed as work is completed to prevent potential access by wildlife. Wildlife monitoring is ongoing, with regularly scheduled sweeps in the area. We are working in collaboration with communities to incorporate their feedback on our monitoring plans.

The company has determined the seepage was caused by shallow subsurface pathways from on-lease industrial wastewater sources bypassing the existing Seepage Interception System (SIS). This shallow groundwater pathway was created by placement of construction fill material, generated through the development of on-lease infrastructure. We are taking actions to prevent the reoccurrence of industrial wastewater seepage leaving the Kearl lease boundary:

• Monitoring of the surface and groundwater seep locations has been enhanced
• Design upgrades and infrastructure improvements to the SIS have been completed
• Surface and shallow ground water interception trenches, complete with water return pumps, have been constructed
• A shallow well point vacuum system has been installed in the vicinity of Waterbody 3

Sampling has been conducted to confirm cleanup of impacted materials resulting from wastewater released from a drainage pond on January 31, 2023. Imperial continues to work with the Alberta Energy Regulator on cleanup certification.

Based on our monitoring, released fluids did not enter any waterways and water sampling shows there has been no impact to local drinking water sources. There is no indication of impact to wildlife.

The company has determined the overflow was caused by a combination of equipment problems and process failure. We are taking actions to prevent reoccurrence at all drainage ponds:

• Inspected and re-programmed all level measurement equipment around the ponds
• Enhancing processes for sediment management
• Increased inspection requirements during regular operator surveillance
• Conducted additional training for all operators working in this area

Imperial continues to take actions to prevent potential impacts to downstream waterbodies. We continue to actively monitor Waterbody 3, which is primarily located on the Kearl lease.  Surface water continues to be sampled on a weekly basis, with results provided to the regulator and communities. At Waterbody 3, Imperial latest water quality results showed no detection of F2 hydrocarbons and naphthenic acids. Recovery equipment near the waterbody, which includes a vacuum system to collect the shallow groundwater, has been installed and fully activated.

Alberta Environment and Protected Areas has indicated there is no evidence that municipal drinking water sources located more than 200 kilometres downstream in Lake Athabasca have been affected. 

Imperial, with participation and observation from community representatives, has collected a sample of fish from Waterbody 3. These samples were submitted to a third-party for analysis and results will be shared with communities.

As a further precaution, we have installed a barrier to prevent fish from entering the waterbody.

On June 5, Imperial notified regulators about eight deceased minnows found near Waterbody 3, which is located on the Kearl lease. The fish were identified during regular sampling and monitoring programs in the area. The information was also shared with communities. 

The minnows have been collected for testing. Additional visual inspections were completed in the area and live populations of similar-sized fish were observed.

Imperial continues to engage directly with Indigenous community leaders and other community members to answer questions, provide information and begin to rebuild trust. We recognize that we still have work to do in this area and are committed to improving our communications in the future.

Community representatives were onsite with our environment and regulatory teams in early May to observe fish tissue sampling from Waterbody 3. We will continue to provide opportunities for community participation in environmental monitoring activities that take place over the summer.

We have shared our mitigation and monitoring plans with communities and their independent technical reviews are underway. We are also seeking input from communities on our plans to improve our communications going forward. 

What happened?

• On January 31, 2023, Imperial experienced an overflow from a process water drainage pond resulting in the release of 5300m³. The Alberta Energy Regulator was notified immediately upon detection of the release on February 4, 2023. 
• The water drainage pond is separate from the facility’s main tailing storage area. This pond collects water from the seepage interception system and other surface water drainage systems. 

What is being done to mitigate the overflow?

• Imperial has been working around the clock to clean up the overflow that was released. 
• Based on our monitoring, released fluids have not entered any waterways and there is no indication of impact to wildlife. 

Who was informed of the release?

• Per company policy, the Alberta Energy Regulator and local Indigenous communities were informed. 

Why did the release occur?

• Imperial is still working with the Alberta Energy Regulator to determine the cause of the overflow. 

Does the release pose any danger to humans or wildlife in the area?

• There is no indication of any impact to wildlife. All released fluids have frozen and therefore do not pose any risk to humans or wildlife in the area. All impacted surface ice and snow in the area has now been removed and safely disposed.  

How will Imperial prevent a similar issue in the future?

• Imperial’s top priority is to ensure the appropriate completion of our cleanup efforts in line with the requirements outlined in the environmental protection order. We will make every effort to learn from this incident and apply preventative steps that are identified.
• Since Kearl was first being developed 15 years ago, this is the first time the facility has been issued an environmental protection order. We regret that this incident occurred and are taking steps to prevent it from happening again.

Seepage Interception System

What happened?

• During routine water sampling in May 2022, an orange discolouration was observed in pooled surface water in four areas in close proximity to the Kearl lease boundary. The Alberta Energy Regulator was notified immediately, and Imperial has been working collaboratively with the regulator to determine the cause of the seepage and implement a solution.
• Upon inspection, the seepage is primarily natural groundwater and precipitation, with a small amount of industrial wastewater.

Who was informed of the situation?

• Per company policy, the Alberta Energy Regulator and local Indigenous communities were notified of the situation.
• We have remained in contact with communities and shared our plans for mitigation. We will continue to provide updated and information as it becomes available.

What is the source of the seepage?

• Based on the ongoing investigation conducted in full cooperation with the AER, we have determined that the seepage occurred in shallower ground layers not protected by the system. In compliance with regulations, the Kearl facility has an advanced seepage interception system for its tailings area, which is a customary design feature for operations such as Kearl. This system is designed to capture any seepage in deep groundwater levels. However, in this instance we believe that the seepage occurred in shallower layers not protected by the system.

Does the seepage pose any danger to humans or wildlife in the area?

• Extensive and ongoing water monitoring has confirmed that seepage has not entered local waterways. As such, there have been no impacts to local drinking water sources. There is no indication of impact to wildlife. 

What is being done to mitigate the seepage?

• Under the guidance of the Alberta Energy Regulator, Imperial is     undertaking several immediate actions to rectify this issue:
  • Ongoing extensive monitoring of local waterways;
  • Installation of additional monitoring and collection wells to expand the site’s existing seepage interception system to better protect against seepage events at all levels;
  • Construction of additional drainage collection structures; and
  • Adding additional surface pumps to ensure water is returned to collection areas.
• Additional fencing is being planned to avoid potential access to the affected area by local wildlife. As an added precaution, Imperial is planning to collect the fish from an on-lease waterbody and install a fish barrier to prevent future migration into the facility. There have been no impacts to baseline water quality in the waterbody.