Blackrod Project Update and Sir 2 Responses Secured

700, 444 – 7th Avenue S.W.
Calgary, AB T2P 0X8

Telephone: 403-215-8313
Fax: 403-262-5123
December 13, 2013
Steve Thomas Claire Classen

Applications Section Leader Alberta Environment and Sustainable
Energy Resources Conservation Board Resource Development
Suite 1000, 250 – 5 Street SW 111, Twin Atria Building
Calgary, Alberta T2P 0R4 4999, 98 Avenue
Edmonton, Alberta T6B 2X3
Dear Sir or Madam:
Re: Blackrod Commercial SAGD Project - Supplemental Information Request (SIR)

EPEA Application No. 001-301778
ERCB Application No. 1728831
Athabasca Oil Sands Area
Supplemental information requests (Round 2) regarding the Blackrod Commercial Project application
were received from the AER and ESRD on October 22, 2013. The attached document (Application for
Approval of the Blackrod Commercial SAGD Project – Supplemental Information Request Round 2
Responses) provides the following in relation to the supplemental information requests received:
• Project Update
• AER SIR 2 Responses
• ESRD SIR 2 Responses
• BlackPearl Errata
If you have any questions with respect to the application please contact Michael Carteri, Project Manager
by e-mail at mike.carteri@pxx.ca or by telephone at (403) 536-4695.
Yours truly,
BLACKPEARL RESOURCES INC.
Chris Hogue
Vice-President, Operations
Attachment: Application for Approval of the Blackrod Commercial SAGD Project – Supplemental
Information Request Round 2 Responses
BlackPearl Resources Inc.
Blackrod Commercial SAGD Project
Project Update & Supplemental
Information Request Responses - Round 2
December 2013
Submitted To:
Alberta Energy Regulator &
Alberta Environment and Sustainable Resource Development
Submitted By:
BlackPearl Resources Inc.
Calgary, Alberta
1.0 Introduction
2.0 Project Upate
Project
Update
1.0 General
2.0 Geology
3.0 Resource Recovery Process
4.0 Hydrogeology
AER SIR 2 5.0

6.0
Air Quality
References
Responses
1.0 General
2.0 Air
3.0 Water
4.0 Terrestrial
5.0 Health
6.0 Approvals
AESRD SIR 2 7.0 Errata
Responses 8.0 References
BlackPearl
Errata
PROJECT UPDATE – SIR ROUND 2
BlackPearl Resources Inc. December 2013
Blackrod Commercial SAGD Project Project Update – SIR Round 2
TABLE OF CONTENTS
Page
1.0 INTRODUCTION.............................................................................................................................. 1
2.0 PROJECT UPDATE ......................................................................................................................... 1
2.1 Revisions to the Project Area .............................................................................................. 1
2.2 Environmental Impact Assessment..................................................................................... 5
2.2.1 Proposed Groundwater Monitoring Wells .............................................................. 5
LIST OF FIGURES
Figure 1.1-1 Project Footprint (December 2013) ..................................................................................... 2
Figure 1.1-2 Comparison of Project Footprints (April 2013 and December 2013) .................................. 3
Figure 1.1-3 Development Area Well Layout .......................................................................................... 4
Figure 2.1-1 Existing and Proposed Groundwater Monitoring Wells ...................................................... 6
Page i
1.0 INTRODUCTION
BlackPearl Resources Inc. (BlackPearl) submitted an Application for Approval of the Blackrod
Commercial SAGD Project (the Project) to Alberta Environment and Sustainable Resource Development
(AESRD) and the Energy and Resources Conservation Board (ERCB) (now the Alberta Energy Regulator
[AER]) in May 2012 (referred to as the Integrated Application). Round 1 Supplemental Information
Requests (SIRs) were received from AESRD and the ERCB in January 2013 and BlackPearl provided
SIR Responses and a Project Update in April 2013. BlackPearl received Round 2 SIRs from AESRD and
AER (formerly ERCB) in October 2013. The Project Update and Round 2 SIR responses are provided in
the following separate sections of this document:
• Project Update – SIR Round 2;
• AER SIR 2 Reponses; and
• AESRD SIR 2 Responses.
Information on the Project Update is provided below and its effect on the environmental assessment
conclusions.
2.0 PROJECT UPDATE

Since the submission of the April 2013 Project Update, updates to the Project include modifications to the
Project Area (also referred to as the Project Footprint) and Development Area.
2.1 Revisions to the Project Area

The revised Project Area is provided in Figure 1.1-1. As a result of further consultation with Laricina
Energy Ltd. (Laricina), well pad 1A has been moved from 13-30-76-17 W4M to 15-26-75-18 W4M in order
to avoid conflict with Laricina’s existing mineral holdings (refer to Round 2 AER SIR 1). The multi-use
corridor associated with this well pad has also been relocated (Figure 1.1-2). The changes result in a
0.8 ha decrease to the Project Area.
The Project Development Area has been revised to include all quarter sections that encompass the
proposed Drainage Patterns (DP) (Round 2 AER SIR 2). The relocation of well pad 1A does not impact
the DP area boundaries. The pad locations from which the DP areas are drilled from have been updated
as follows (Figure 1.1-3):
• DP1 is now drilled from well pad 1E;
• DP2 is now drilled from well pad 1B only; and
• DP 6 is now drilled from the new well pad 1A.
Based on the performance of the second Pilot well pair and as new geologic information is obtained, the
well pads in each Phase will be optimized for maximum recovery. As a result, the well pads associated
with each Phase may change over-time as information is continually obtained over the course of the
Project.
Page 1
Athab a sc a R iver RGE.18 W4M RGE.17 W4M
Riv er
3BHH
22 23 24 19 20
B3B16
21
3BGG
3BDD 3BCC
B3B15
B3B13
TWP.77 3BBB 3BAA 3BFF

15 14 L3B2
13 18 17 16
B3B12
3BU 3BT 3BW 3BEE

3BY 3BZ B3B14
3BX
B3B11
S3B1
3BS 3BR 3BV
10
11 B3B8 12 B3B10
7
Naming
8
Convention 9
3BO 1A 3BAA
3BQ 3BP Well Pad
B3B9 Phase Letter Phase Letter
B3B7
L3A1
Log Deck (L) Log Deck Number
Phase
3BN 3BM
L3B1 3AC S3B1
3 Sump (S) Sump Number
2 1 L3A2 6 5
Phase
4
B3B6
B3A3
3BL
3BK
2A Borrow Pit (B) Borrow Pit Number
Phase
B3A1 B13
3AB 3AA
2B
1D
34
35 36
B3B1 1C 31 32 33
B21 B11
3BB 3BA 2C
1A 1E
B3B3 B121B 2G
3BD 3BC
2D
TWP.76 27
B3B2
26 25 30 29
B22 28
B3B4 S11
3BF 3BE
2F 2E CAMP S12
B3A2 L3A1
3AD CPF
3AF
3BH 3BG 3AG
B3B5 3AE
22 23 B3A3
24 19 20
21
CAMP
3BJ 3BI
3AI 3AH
Project Footprint FIGURE 1.1-1

Phase 1 Borrow Pit Construction Camp Site Existing Blackrod Road
PROJECT FOOTPRINT (DECEMBER 2013)
t6790_Figure01_Project_Footprint_20130703.pdf
Phase 2 Sump Site Permanent Operations Camp Site Waterbody

Phase 3A Log Deck Proposed Blackrod Road PROJECT UPDATE SIR ROUND 2 -
Phase 3B PROPOSED BLACKROD COMMERCIAL SAGD PROJECT
UTM Zone 12N SCALE: 1: 50,000
Project Area: Altus Geomatics 2012 & Feb 8, 2013, modified by TERA Environmental Nov 4, 2013; Meters
Hydrography: AltaLIS.Ltd 2011; Roads: IHS Inc. 2011.
0 500 1,000
December 2013
Although there is no reason to believe that there are any errors associated with the data used to generate this product or in the product itself,
users of these data are advised that errors in the data may be present.
(All Locations Approximate)
Athab a sc a R ive r
RGE.18 W4M RGE.17 W4M
v er
22 23 24 19 20 21
TWP.77
15 14 13 18 17 16
10 11
12 7 8 9
3 2 1 6 5 4
34 35 36 31 32 33
TWP.76 27 26
25 30 29 28
a 22 23 24 19 20 21
t6790_Figure_1_1_2_Comparison_of_Project_Footprints_20132813.mxd
Project Footprint (December 2013) SIR Round 1 Footprint (April 2013) FIGURE 1.1-2
Phase 1 Borrow Pit Construction Camp Site Phase 1 Existing COMPARISON OF PROJECT FOOTPRINTS
Phase 2 Sump Site Permanent Operations Blackrod Road (APRIL 2013 AND DECEMBER 2013)
Phase 3A Log Deck Camp Site
PROJECT UPDATE SIR ROUND 2 - BLACKPEARL RESOURCES INC.
Phase 3B Proposed Blackrod Road PROPOSED BLACKROD COMMERCIAL SAGD PROJECT
UTM Zone 12N
SCALE: 1: 50,000
Project Area: Altus Geomatics 2013; Hydrography: AltaLIS.Ltd 2011; Roads: IHS Inc. 2011. Meters
0 500 1,000
December 2013
users of these data are advised that errors in the data may be present. (All Locations Approximate)

"

"

Athab a s c a Riv er
3BHH

3BGG
"

3BDD 3BCC
3BBB 3BAA 3BFF

3BT 3BW 3BY 3BZ 3BEE

3BU 3BX
3BR 3BV
3BS

3BO
3BQ 3BP

3BN 3BM

3AC

3BL 2A
3BK

3AB 3AA
2B
1D

1C
3BB 3BA 2C

1A 1E

1B 2G
3BD 3BC
2D

3BF 3BE 2F 2E
"

3AD CPF
3AF
3BH 3BG 3AG
3AE

3BJ 3BI
3AI 3AH

t6790_Figure_1_1_3_Development_Area_Well_Layout_20131128
Project Footprint Construction Camp Site Development Area Well

Permanent Operations Drainage Pattern Area
Phase 1 Phase 3B !

"

#
Camp Site Development Area (DA)
Phase 2 BlackPearl Oil

$
Sand Holdings Proposed Blackrod Road Application Resource Area (ARA)

Phase 3A Existing Blackrod Road Waterbody

UTM Zone 12N
Project Footprint: Altus Geomatics 2013;
SCALE: 1: 65,000
Wells and Pads: BlackPearl Resources Inc. 2013; Hydrography: AltaLIS.Ltd 2011; Roads: IHS Inc. 2011; km
Drainage Area: BlackPearl Resources Inc. 2013. 0 0.5 1 1.5
December 2013
2.2 Environmental Impact Assessment

The changes to the Project Area as described in Section 2.0 do not affect the assessment conclusions for
Air Quality, Noise, Hydrogeology, Hydrology, Surface Water Quality, Aquatic Ecology, Vegetation,
Wildlife, Biodiversity, Terrain and Soils, Land Use and Management, Historical Resources, Traditional
Ecological Knowledge and Land Use, the Human Health Risk Assessment or the Socio-Economic Impact
Assessment. The assessments for these components provided in the May 2012 Integrated Application
and as amended in the April 2013 Round 1 SIR Project Update remain unchanged.
2.2.1 Proposed Groundwater Monitoring Wells

The change to the Project Area has resulted in changes to the locations of the proposed groundwater
monitoring wells as previously shown on Figure 2.4-2 in the Round 1 SIR Project Update. The number of
Grand Rapids ‘B’ monitoring wells has been increased from three to four wells as a result of the change
to the Project Area. The revised locations of proposed groundwater monitoring wells are shown on
Figure 2.1-1. These revised locations have no effect on the results of the Hydrogeology Assessment.
Page 5
¯
Riv er
22 23 24 19 20 21
TWP.77
15 14 13 18 17 16
10
11 12 7 8 9
3 2 1 6 5 4
12-36 (Proposed)
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3-36 (Existing - directional)
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TWP.76 27 26 25 30 29 28
(
!
22 23 24 19 20 21
14-24 (Existing)
t6790_Figure_2_Existing_Proposed_Groundwater_Wells_20131118.pdf.mxd
Project Footprint FIGURE 2.1-1

Phase 1 Borrow Pit Construction Camp Site Viking Aquifer Monitoring Well
EXISTING AND PROPOSED
(
!
Phase 2 Sump Site Permanent Operations (
! Grand Rapids 'B' Monitoring Well GROUNDWATER MONITORING WELLS
Phase 3A Log Deck Camp Site Grand Rapids 'B' Observation Well
PROJECT UPDATE SIR ROUND 2 - BLACKPEARL RESOURCES INC.
(
!
Phase 3B Proposed Blackrod Road
PROPOSED BLACKROD COMMERCIAL SAGD PROJECT
Imagery: 2011 SPOT5 © 2013 CNES, Licensed by BlackBridge Geomatics Corp, www.blackbridge.com
Meters
Project Area: Altus Geomatics 2013; Hydrography: AltaLIS.Ltd 2011; Roads: IHS Inc. 2011.
0 500 1,000
December 2013
AER SIR 2 RESPONSES
Blackrod Commercial SAGD Project AER SIR 2 Responses
TABLE OF CONTENTS
Page
1.0 GENERAL ........................................................................................................................................ 1
2.0 GEOLOGY ....................................................................................................................................... 7
3.0 RESOURCE RECOVERY PROCESS ........................................................................................... 16
4.0 HYDROGEOLOGY ........................................................................................................................ 18
5.0 AIR QUALITY ................................................................................................................................. 34
6.0 REFERENCES............................................................................................................................... 43
LIST OF APPENDICES
AER SIR Appendix A Aboriginal Record Of Engagement Log ..............................................................A-1
LIST OF FIGURES
Figure 2-1 Phase 1 Drainage Patterns (with Net Pay) ......................................................................... 6
Figure 4-1 Schematic Structural 100/14-25-076-18W4/00 & 100/10-25-076-18W4/00
Cross-Section Drainage Area DP1 ..................................................................................... 8
Figure 4-2 Schematic Structural 1AA/02-36-076-18W4/00 & 1AA/07-36-076-18W4/00
Cross-Section Drainage Area DP2 ..................................................................................... 9
Figure 4-3 Schematic Structural 100/02-01-077-18W4/00 & 100/08-01-077-18W4/00
Cross-Section Drainage Area DP3 ................................................................................... 10
Figure 4-6 Schematic Structural 1AA/15-26-076-18W4/00 & 102/14-25-076-18W4/00
Figure 4-7 Schematic Structural 1AA/08-01-077-18W4/00 & 102/01-12-077-18W4/00
Figure 4-8 Schematic Structural 1AB/06-01-077-18W4/00 & 1AA/13-01-077-18W4/00
Figure 6-1 Changes in Water Level in 00/03-36-076-18 W4M (MW LGR 3-36) ................................ 19
Figure 6-2 Changes in Water Level in 00/14-25-076-18 W4M (MW LGR 14-25) .............................. 20
Figure 8-1 Stratigraphic Correlation Chart for Northeastern Alberta .................................................. 23
Figure 8-2 Upper Cretaceous Type Log ............................................................................................. 25
Figure 9-1 Grosmont A Disposal Well ................................................................................................ 27
Figure 10-1 Bedrock Monitoring Network Location Cross Section Schematic ..................................... 30
Figure 11-1 Simulated Temperature Contours from Steam Injection................................................... 33
Figure 14-1 Measured Ambient 98th Percentile PM2.5 Concentrations at Wood Buffalo
Environmental Association Ambient Air Monitoring Stations ............................................ 41
Figure 14-2 Summary of Annual Average PM2.5 Concentrations at Wood Buffalo
Environmental Association Ambient Air Monitoring Stations in the Oil Sands
Region ............................................................................................................................... 42
Page i
LIST OF TABLES
Table 1-1 Pre-Open House Media Coverage...................................................................................... 2
Table 1-2 Summary of Open House Issues or Concerns Raised and BlackPearl’s
Response ............................................................................................................................ 2
Table 1-3 Summary of Outstanding Statements of Concern .............................................................. 4
Table 3-1 Original Bitumen in Place (OBIP) and Developable Bitumen in Place (DBIP) ................... 7
Table 12-1 Predicted Hourly NO2 Maximum, 9th Highest and Probability of Exceeding
Adverse Acute Health Effect Levels.................................................................................. 35
Table 12-2 Potential Acute Health Effects Associated with NO2 ........................................................ 35
Table 13-1 Predicted Hourly SO2 Maximum, 9th Highest and Probability of Exceeding
Adverse Acute Health Effect Levels.................................................................................. 37
Table 13-2 Potential Acute Health Effects Associated With SO2 ........................................................ 37
Table 14-1 Predicted Maximum and 98th Percentile Pm2.5 Concentrations at the RSA
MPOI and Probability That PM2.5 Concentrations at the RSA MPOI Will
Exceed the CWS ............................................................................................................... 40
Table 14-2 Predicted Annual Average PM2.5 Concentrations at the RSA MPOI ................................. 41
Page ii
ACRONYM LIST
Definition/Acronym Full Name

AAAQO Alberta Ambient Air Quality Objectives
AER Alberta Energy Regulator
AESRD Alberta Environment and Sustainable Resource Development
ARA Application Resource Area
Cal EPA California Environmental Protection Agency
CAPP Canadian Association of Petroleum Producers
CASA Clear Air Strategic Alliance
CCME Canadian Council of Ministers of the Environment
COPD Chronic Obstructive Pulmonary Disease
CPF Central Processing Facility
CWS Canada Wide Standard
EIA Environmental Impact Assessment
EPEA Environmental Protection and Enhancement Act
ERCB Energy Resources Conservation Board
GLIMPS Geographic Land Information Management Planning System
HHRA Human Health Risk Assessment
LSA Local Study Area
MPOI Maximum Point of Impingement
PDC Planned Development Case
PM Particulate Matter
RSA Regional Study Area
SAGD Steam-assisted Gravity Drainage
SIR Supplemental Information Request
SOC Statement of Concern
SOR Steam to Oil Ratio
TDS Total Dissolved Solids
TEK Traditional Ecological Knowledge
TERA TERA Environmental Consultants
TUS Traditional Use Study
US EPA United States Environmental Protection Agency
WBEA Wood Buffalo Environmental Association
Page iii
1.0 GENERAL
1. Provide an update on the status of stakeholder (public and industry) notification and
consultation associated the proposed project, including a list of all stakeholders with an
outstanding statement of concern respecting the proposed development, a summary of key
issues identified in each statement of concern, and the efforts taken to address and resolve the
concerns.
Response:
Summary
BlackPearl began consultation for the Blackrod Commercial Project in Q3 2010. Information has been
openly provided to stakeholders including the Integrated Application, Project update letters and Round 1
Supplemental Information Request (SIR) Responses. BlackPearl has hosted four Open Houses (Fort
McMurray, Lac La Biche, and Grasslands on two occasions) to allow stakeholders additional opportunity
to discuss the Project directly with BlackPearl representatives. BlackPearl has met with stakeholders
individually who have requested additional information. The company website also provides information
on the Project and a link to the Alberta Environment and Sustainable Resource Development (AESRD)
Summary of Environmental Assessment Activity where current information is posted.
Stakeholder notification and consultation has been conducted in accordance with Alberta Energy
Regulator (AER) (formerly Energy Resources Conservation Board [ERCB]) Directive 023, as well as in
consideration of Directive 056. An overview of the Public Consultation and Aboriginal Engagement
Program up to May 24, 2012 is provided in Section 2.2 and 2.3, respectively, of Volume 1 in the
Integrated Application submitted in May 2012. An update of the public consultation and Aboriginal
Engagement activities from application submission to April 2013 is provided in Section 1.0 of the Round 1
ERCB SIR Responses. Since the filing of Round 1 SIR Responses on April 5, 2013, BlackPearl has
continued to engage interested stakeholders and Aboriginal communities. BlackPearl is committed to
on-going engagement with stakeholders and addressing any concerns with a resolution that will
accommodate all parties involved.
Ongoing Stakeholder Engagement Activities
Project Update Letter

BlackPearl provided identified stakeholders with a Project update letter via mail in May and July, 2013.
The update letter outlined details regarding BlackPearl’s ongoing commitment to consultation, the
application process and the Project Footprint. All previously identified stakeholders were sent the update
letter, with the exception of those who were updated though separate communications (e.g. meetings or
sent a copy of the Round 1 SIR Responses and Project Update) or who are no longer affected by the
Project.
As part of BlackPearl’s ongoing consultation program, a Geographic Land Information Management

Planning System (GLIMPS) search was performed on November 13, 2013. This search identified two new
stakeholders. The stakeholders were mailed a Project information letter and open house notification on
November 29, 2013.
Open House
In order to provide a Project introduction and update to stakeholders as well as an opportunity to ask
questions, BlackPearl held an Open House from 3:00 PM – 7:00 PM on December 11, 2013 at the
Grassland Community Center, in the Hamlet of Grassland, Alberta. Notification regarding the open house
was accomplished through advertisements in local newspapers and radio stations including: Athabasca
Advocate; Lac La Biche Post; Windspeaker Newspaper; The River 94.1 FM Radio Station; and
CFWE-FM Radio.
In addition, stakeholders were notified by letter or email of the open house. The circulation methods and
timing of the above communication methods and information materials are outlined in Table 1-1.
Page 1
TABLE 1-1
PRE-OPEN HOUSE MEDIA COVERAGE
Media Outlet Circulation Area Date Frequency

Windspeaker newspaper National November 22, 2013 Monthly
Athabasca Advocate newspaper Athabasca / Boyle and area November 26, 2013 Weekly
December 3, 2013
December 10, 2013
Lac La Biche Post newspaper Lac La Biche / Wandering River and November 26, 2013 Weekly
area December 3, 2013
December 10, 2013
The River 94.1 FM Radio Station Athabasca / Boyle and area December 9-11, 2013 10 on-air 30 second
advertisements
CFWE Radio, Treaty 6 & Treaty 8 territory, Lac La Throughout Alberta via satellite December 9-11, 2013 15 on-air 30 second
Biche 89.9 FM advertisements
47 people attended the open house. At the open house, attendees were provided with a copy of the
Project Fact Sheet. In addition, the open house featured Project Story Boards throughout the room as
well as copies of: AER Brochure: A Letter from the Chairman of the ERCB (ERCB 2011a), AER Brochure:
Understanding Oil and Gas Development in Alberta (ERCB 2011b), EnerFAQs 7: Proposed Oil and Gas,
Pipelines and Facilities: A Landowner’s Guide (AER 2013a), EnerFAQs 12: Oil Sands (AER 2013b),
EnerFAQs 15: Expressing Your Concerns – How to File a Statement of Concern About an Energy
Resource Project (AER 2013c) and the Canadian Association of Petroleum Producers (CAPP) Upstream
Dialogue, The Facts on: Oil Sands (CAPP 2013). Display materials presented information about the
Project, including the Project footprint, stakeholder engagement, potential environmental and
socio-economic effects and the Environmental Impact Assessment (EIA) process. Representatives from
BlackPearl and TERA Environmental Consultants (TERA) attended the open house to respond to
attendees’ questions.
Comment forms were provided to identify any additional comments, concerns or questions regarding the
Project. Stakeholders were invited to leave the comment forms at the open house or to submit comments
later via email or fax. Response to the Project from open house attendees was generally positive. Most
stakeholders were interested in employment opportunities and the economic benefits associated with the
Project. A few stakeholders expressed concern about the process of water use with the proposed
development. A summary of the open house concerns and questions and BlackPearl’s response is
outlined in Table 1-2.
TABLE 1-2
SUMMARY OF OPEN HOUSE ISSUES OR CONCERNS RAISED AND BLACKPEARL’S RESPONSE
Summary of Comment Project Team’s Response

Access to the Project Area for trappers and Direct access into the Project Area would require a check-in and safety orientation at the security check
recreational users point. BlackPearl will provide information to stakeholders on access requirements (i.e., security check-in and
safety orientation) when the Project becomes operational. BlackPearl will not restrict access to the area.
Concerns regarding water use from the BlackPearl informed stakeholders that no water from the Athabasca River will be used. In addition, no
Athabasca River drinkable water will be used. Only non-drinkable salt water from a deep source will be used in the steam-
assisted gravity drainage (SAGD) process.
How the product will be transferred to the market BlackPearl intends to transfer the final bitumen product to the market via pipeline. There are several
proposed pipeline projects in the vicinity of the proposed development that BlackPearl will consider. No
pipelines from the Project will cross the Athabasca River.
Employment opportunities Stakeholders requested information on employment and contracting opportunities, as well as opportunities
that will benefit the local surrounding communities. BlackPearl is currently collecting information from
individuals that have expressed interest in employment, training and business opportunities on an internal
vendor list. BlackPearl will communicate the types of present and future opportunities to local individuals
and businesses based on their internal vendor list.
Page 2
Aboriginal Engagement Activities
BlackPearl strives to conduct consultation with Aboriginal communities in a meaningful way that supports
the spirit of collaboration and will make all attempts to follow the guidelines and activities as set out in the
First Nation Consultation Guidelines on Land Management and Resource Development. To date, not all
communities have participated in the consultation process. In these instances, such as with Beaver Lake
Cree Nation, BlackPearl has implemented the consultation protocols of the community and provided
funding as per their process, with limited success.
A detailed record of ongoing consultation activities with Aboriginal communities from April 6, 2013 to
December 11, 2013 is provided in AER SIR Appendix A. BlackPearl will continue to consult with
Aboriginal communities.
Objections and Statements of Concern
There are currently no objections filed with the AER (formerly ERCB) regarding this Project. Rae and
Company, representing the Chard Métis Local No. 214 and Chard Métis Dene Inc. (Chard Métis), Fort
McMurray #468 First Nation and Laricina Energy Ltd. (Laricina), provided Statements of Concern (SOC)
to the ERCB (now AER) and AESRD on December 17, 2012, June 7, 2013 and September 11, 2013,
respectively. AESRD did not accept the Chard Metis SOC, stating that their SOC does not demonstrate
that they are directly affected by the Project. Additionally, AESRD did not accept the Laricina SOC,
stating that the issues Laricina raised are outside of AESRD’s mandate and are therefore not part of
AESRD’s Project review process.
BlackPearl will continue to engage with stakeholders who have raised concerns or comments with the
intent of coming to a resolution that will accommodate all parties. Details of consultation with those that
have provided SOCs are provided below.
Chard Métis
On July 25, 2013, AESRD issued a letter to Chard Métis stating AESRD was unable to determine how the
individual members of the First Nation are directly affected by the Project, therefore the Chard Métis will
not be considered as directly affected and their SOC will not be considered a statement of concern.
Following the submission of the Round 1 SIR Responses and the receipt of the above letter, BlackPearl
continued discussions with Chard Métis and met with a legal representative for Chard Métis on
August 14, 2013 to discuss concerns. Additionally, BlackPearl met with the Manager of the Chard Metis
on November 14, 2013 to discuss the Project. During this meeting, it was indicated the Project was
located too far away to have any concerns; however, Chard Metis requested that they be provided the
same opportunities for employment as other stakeholders in the region. BlackPearl is committed to
continue to work directly with Chard Métis to continue to address any issues regarding the Project.
A detailed record of consultation activities with Chard Métis is provided in AER SIR Appendix A.
Fort McMurray #468 First Nation

BlackPearl has reviewed the Fort McMurray #468 First Nation SOC and made several attempts to
coordinate a meeting to discuss the Project and the issues raised within the SOC as well as any
additional concerns. BlackPearl met with Fort McMurray #468 First Nation on November 13, 2013.
BlackPearl provided an overview of the Project and discussed the concern identified in the June 7, 2013
SOC. During this meeting, Fort McMurray #468 First Nation stated that they have not reviewed the
application documentation provided by BlackPearl. BlackPearl requested more information on their
concerns. BlackPearl is currently undergoing a project screening by Fort McMurray #468 First Nation to
determine if a Traditional Ecological Knowledge (TEK)/Traditional Use Study (TUS) will be required. A
summary of the concerns and BlackPearl’s response is summarized in Table 1-3. BlackPearl will continue
to consult with the Fort McMurray #468 First Nation and the community to address any concerns
regarding the Project.
A detailed record of consultation activities with Fort McMurray # 468 First Nation is provided in AER SIR
Appendix A.
Page 3
Laricina Energy Ltd.

Laricina Energy Ltd. (Laricina) provided a SOC to ERCB (now AER) and AESRD on January 18, 2013.
Following the submission of the Round 1 SIR Responses on May 17, 2013, AESRD issued a letter to
Laricina stating that the issues raised on January 18, 2013 regarding the application were outside the
scope of the AESRD application review, and therefore would not be considered a SOC.
On September 11, 2013, Laricina sent a letter to AER (formerly ERCB) and AESRD outlining their
remaining concerns. BlackPearl has relocated well pad 1A in order to avoid conflict with Laricina’s mineral
holdings. A summary of the concerns and BlackPearl’s response is summarized in Table 1-3.
At this time, BlackPearl has completed consultation with Laricina. As requested by Laricina, BlackPearl
has removed the proposed well pads from Sections 19, 30 and 31-76-17 W4M. BlackPearl has
demonstrated to Larcina that the location of the proposed Central Processing Facility (CPF) does not
impact Laricina’s access to its resource from both a surface, subsurface and economic perspective.
BlackPearl will submit a response to the AER regarding Laricina’s SOC in December 2013.
TABLE 1-3
SUMMARY OF OUTSTANDING STATEMENTS OF CONCERN
Stakeholder
Group Issues or Concerns Raised Response Status
Fort McMurray The impact on the drainages and Hydrogeology and Hydrology impact assessments have been completed for the Project Ongoing
#468 First aquifers feeding the Athabasca as part of the Integrated Application and concluded that there would not be impacts to the
Nation River watershed. drainages and aquifers feeding the Athabasca River watershed. BlackPearl informed Fort
McMurray #468 that only non-drinkable salt water from a deep source will be used in the
SAGD process.
The potential cumulative effects of An assessment of potential cumulative effects was completed as part of the Integrated Ongoing
BlackPearl’s application when Application for all environmental and socio-economic components of the Project and was
considered with other similar submitted to ERCB (now AER) and AESRD in May 2012.
pending and future applications.
Laricina Location of the CPF. The location of the CPF will still remain as proposed in the Integrated Application. Ongoing
BlackPearl presented several suitable alternative locations for the Laricina CPF at a
meeting on October 28, 2013. The information presented at this meeting will be included
in BlackPearl’s letter of response to the AER to be submitted in December 2013.
Select well pad locations. BlackPearl has revised their Project Footprint, which includes the removal of well pads Ongoing
and associated infrastructure in Sections 19, 30 and 31-76-17 W4M on Laricina’s
lease-holdings.
Crossing of production lines. The challenges associated with the hydraulics of moving liquids over an existing pipeline Ongoing
can be overcome through appropriate design and engineering by Laricina.
SAGD well off set from lease There is no data (i.e., from other similar wells, or modeling/simulation exercises) that Ongoing
boundary. demonstrates a drainage radius beyond 50 m for a Grand Rapids SAGD well pair.
BlackPearl’s own simulation data has shown a maximum heat progression of 50 m
around a SAGD well pair after 8 years.
Recent industry applications for other projects in the Grand Rapids (e.g., Cenovus,
Cavalier and Laricina) have proposed SAGD well pair spacing from 40 m to 100 m,
suggesting that a 50 m buffer is appropriate.
Page 4
2. ERCB SIR 1 Responses, SIR 3, Response b, Page 13.
An AER-defined Development Area represents the boundary approved for the specified
placement of drainage patterns for the recovery of bitumen. The AER’s current practice is to
limit an approved Development Area to include all quarter sections that encompass approved
drainage patterns. Considering the AER’s current practice and BlackPearl’s plan to use the
results for the initial project drainage patterns to shape future drainage patterns, provide an
updated map outlining the proposed Development Area.
Response:
Please refer to Figure 2-1 for an updated map outlining the proposed Development Area for the Blackrod
SAGD Project. The Development Area includes all quarter sections surrounding the initial drainage
patterns for the Project.
Page 5
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2.0 GEOLOGY
3. ERCB SIR 1 Responses, Table 7-1, Page 19.
BlackPearl provided an estimate of original bitumen in place (OBIP) for each proposed
drainage pattern. The area of the drainage patterns in Table 7-1 appears to be incorrect. Clarify
the area associated with each proposed drainage pattern and resubmit Table 7-1 as
necessary.
Response:
Refer to Table 3-1 below for an updated drainage pattern area. In Round 1 ERCB SIR 7, this table was
submitted with an incorrect column heading. This column heading has been corrected in the Table below
to be “Drainage Pattern Area (103 m2)”.
TABLE 3-1
ORIGINAL BITUMEN IN PLACE (OBIP) AND DEVELOPABLE BITUMEN IN PLACE (DBIP)
Drainage Average Planned

Drainage Pattern Pay Bitumen Average Well Wells per Drainage Potential
Pattern Area Thickness Saturation Porosity Length Drainage Pattern Well OBIP DBIP Recovery
Area (103 m2) (m) (%) (%) (m) Pattern Spacing (m) (106 m3) (106 m3) Factor (%)
DP 1 746 25 63 35 950 8 80 4.1 3.3 55
DP 2 1015 25 63 34 925 10 100 5.4 4.5 55
DP 3 1013 24 62 33 1150 10 80 5.0 3.6 60
DP 4 830 23 61 34 950 8 100 3.9 2.6 55
DP 5 851 23 63 34 950 10 80 4.1 3.3 60
DP 6 945 23 62 35 950 10 80 4.7 3.7 60
DP 7 830 25 56 35 950 8 100 4.0 2.5 55
DP 8 851 25 60 33 950 10 80 4.1 3.0 60
Average 24 61 34 Total 36 27
4. ERCB SIR 1 Responses, Figures 8-1 to 8-8, Page 20 to 27.
The submitted cross sections in Figures 8-1 to 8-8 showing the proposed wellbore trajectories
are not tied to well logs. Update and resubmit Figures 8-1 to 8-8 to include well logs.
Response:
Figures 8-1 to 8-8 have been updated and are provided below as Figures 4-1 to 4-8.
Page 7
A´ PAD # DP1 (G.L. 641.45m) A
December 2013
100/14-25-076-18W4/00 100/10-25-076-18W4/00
400 AF90 (OHMM) AT90 (OHM.M)
0.20 2000.00 0.20 2000.00
395 NPOR_SAN (V/V) AF30 (OHMM) DPHZ (V/V) AT30 (OHM.M)

0.60 0.00 0.20 2000.00 0.60 0.00 0.20 2000.00
390 GR (GAPI) DPHI_SAN (V/V) AF20 (OHMM) GR (GAPI) NPOR (V/V) AT20 (OHM.M) FIGURE 4-1
0.00 150.00 0.60 0.00 0.20 2000.00 0.00 150.00 0.60 0.00 0.20 2000.00
385
Joli Fou
380
SCHEMATIC STRUCTURAL
375 100/14-25-076-18W4/00
Joli Fou Caprock
370 &
365 100/10-25-076-18W4/00
Upper 360
CROSS-SECTION
Grand DRAINAGE AREA DP1
355
Rapids
350
AER SIR 2 RESPONSES -
345
Elevation (mSS)

Upper Grand Rapids
340 PROPOSED BLACKROD
335 COMMERCIAL SAGD PROJECT
330
325
Max Flooding
320 Top
Surface (MFS) L.GR Caprock SAGD
LGR1 315 Reservoir
310
Lower Grand Rapids
305
300 INJECTOR
295 PRODUCER Base
SAGD
LGR2 290
Reservoir
285
1050 m
Drainage Area Length
FACIES C (FC) - Dark grey marine mudstone FACIES A (FA) - Fine to medium-grained coarsening upward sandstone
Mixed sand and shale FACIES B (BA) - Heterolithic sands interbedded with dark grey shales
Although there is no reason to believe that there are any errors
associated with the data used to general this product or in the
product itself, users of these data are advised that errors in the
data may be present
A PAD # DP2 (G.L. 614.57 m) A´
December 2013
1AA/02-36-076-18W4/00 1AA/07-36-076-18W4/00
AT30 (OHMM)
0.20 2000.00
AT30 (OHM.M) 400
0.20 2000.00
NPOR_SAN (V/V)
0.60 0.00 0.20 AT90 (OHMM) 2000.00 DPHI SAN (M3/M3) AT90 (OHM.M) 395
0.60 0.00 0.20 2000.00
0.00
GR (GAPI)
150.00 0.60
DPHI_SAN (V/V)
0.00 0.20
AT20 (OHMM)
2000.00 GR (GAPI) NPOR SAN (M3/M3) AT20 (OHM.M) 390 FIGURE 4-2
0.00 150.00 0.60 0.00 0.20 2000.00
Joli Fou 385
380
375 1AA/02-36-076-18W4/00
Joli Fou Caprock
370 &
Upper 365 1AA/07-36-076-18W4/00
Grand 360
CROSS-SECTION
Rapids DRAINAGE AREA DP2
355
350
345 BLACKPEARL RESOURCES INC.
Upper Grand Rapids
Elevation (mSS)
330
325
Max Flooding
Surface (MFS) 320
LGR1 L.GR Caprock 315
Lower Grand Rapids Top SAGD 310
Reservoir
305
INJECTOR
300
PRODUCER
295
LGR2 290
Base SAGD
Reservoir 285
1025 m
FACIES C (FC) - Dark grey marine mudstone FACIES A (FA) - Fine to medium-grained coarsening upward sandstone DP1

data may be present
A A´
PAD # DP3 (G.L. 604.17m)
100/02-01-077-18W4/00 1AA/08-01-077-18W4/00 December 2013
RSFE (OHMM) AT30 (OHM.M) 400
0.20 2000.00 0.20 2000.00
DPRS_(%) RILM (OHMM) NPOR SAN (M3/M3) AT90 (OHM.M) 395

0.60 0.00 0.20 2000.00 0.60 0.00 0.20 2000.00
GR (GAPI) NPRS (%) RILD (OHMM) GR (GAPI) DPHI SAN (M3/M3) AT20 (OHM.M) 390 FIGURE 4-3
0.00 150.00 0.60 0.00 0.20 2000.00 0.00 150.00 0.60 0.00 0.20 2000.00
385
Joli Fou
380
375
Joli Fou Caprock 100/02-01-077-18W4/00
370 &
365 100/08-01-077-18W4/00
Upper
Grand 360 CROSS-SECTION
Rapids 355 DRAINAGE AREA DP3
350
Elevation (mSS)
345
Upper Grand Rapids BLACKPEARL RESOURCES INC.
330
325
Max Flooding
Surface (MFS) L.GR Caprock 320
LGR1 Top SAGD
Reservoir 315
Lower Grand Rapids 310
305
INJECTOR
300
PRODUCER
295
Base SAGD
LGR2 Reservoir 290
285
1250 m
DP1

data may be present
A A´
PAD # DP4 (G.L. 601.03m) December 2013
1AA/14-36-076-18W4/00 1AA/04-01-077-18W4/00
RSFE (OHMM)
0.20
AT30 (OHM.M)
2000.00
400
0.20 2000.00
DPRS_(%) RILM (OHMM)

0.60
DPHI_SAN (M3/M3)
0.00 0.20
AT90 (OHM.M)
2000.00
395
FIGURE 4-4
0.60 0.00 0.20 2000.00
GR (GAPI) NPRS (%) RILD (OHMM)

0.00
GR (GAPI)
150.00 0.60
NPOR_SAN (M3/M3)
0.00 0.20
AT20 (OHM.M)
2000.00
390
0.00 150.00 0.60 0.00 0.20 2000.00
Joli Fou 385

380 SCHEMATIC STRUCTURAL
375 1AA/14-36-076-18W4/00
Joli Fou Caprock &
370
1AA/04-01-077-18W4/00
365
CROSS-SECTION
Upper 360 DRAINAGE AREA DP4
Grand
355
Rapids
350 AER SIR 2 RESPONSES -
Elevation (mSS)
Upper Grand Rapids PROPOSED BLACKROD
340
COMMERCIAL SAGD PROJECT
335
330
325
Max Flooding 320
Surface (MFS) L.GR Caprock
315
LGR1 Top SAGD Reservoir
305
INJECTOR 300
PRODUCER 295
Base SAGD Reservoir 290

LGR2
285
1050 m
DP1

data may be present
A A´
PAD # DP5 (G.L. 603.05m)
1AA/07-36-076-18W4/00 1AA/16-35-076-18W4/00
1AA/16-35-076-18W4/00 December 2013
AT30 (OHM.M) AHT90 (OHMM)
0.20 2000.00 0.20 2000.00 400
DPHI_SAN (M3/M3) AT90 (OHM.M) DPHI_SAN (V/V) AHT30 (OHMM)
0.60 0.00 0.20 2000.00 0.60 0.00 0.20 2000.00 395
0.00
GR (GAPI)
150.00 0.60
NPOR_SAN (M3/M3)
0.00 0.20
AT20 (OHM.M)
2000.00 0.00
GR (GAPI)
150.00 0.60
TNPH_SAN (V/V)
0.00 0.20
AHT20 (OHMM)
2000.00 390 FIGURE 4-5
385
Joli Fou
380
JoliFou
FouCaprock
Caprock
375 1AA/07-36-076-18W4/00
Joli 370 &
365 1AA/16-35-076-18W4/00
Upper
360
CROSS-SECTION
Rapids 355
Elevation (mSS)
350
UpperGrand
Upper GrandRapids
Rapids
330
325
Max Flooding
Surface (MFS) 320
L.GR Caprock
LGR1 Top SAGD 315
Lower
Lower Grand
Grand Rapids
Rapids Top SAGDReservoir
Reservoir 310
INJECTOR
INJECTOR 305
PRODUCER
PRODUCER 300
295
LGR2 290
Base SAGD Reservoir
285
1050 m
DP1

data may be present
A PAD # DP6 (G.L. 610.0m) A´
1AA/15-26-076-18W4/00 102/14-25-076-18W4/00 December 2013
AT30[1] (OHM.M) SFLR (OHMM) 400
0.20 2000.00 0.20 2000.00
NPOR_SAN[1] (M3/M3) AT90[1] (OHM.M) NPSS (PU) MVR2 (OHMM) 395

0.60 0.00 0.20 2000.00 60.00 0.00 0.20 2000.00
GR[1] (GAPI)
0.00 150.00 0.60
DPHI_SAN[1] (M3/M3)
0.00
AT20[1] (OHM.M)
0.00
GR (API)
150.00 60.00
DPHI (PU)
0.00 0.20
DVR2 (OHMM)
2000.00
390 FIGURE 4-6
0.20 2000.00
385
Joli Fou
380
375 1AA/15-26-076-18W4/00
Joli Fou Caprock
370 &
365 102/14-25-076-18W4/00
Upper 360 CROSS-SECTION
Grand
355
DRAINAGE AREA DP6
Rapids
350
Elevation (mSS)
345
Upper Grand Rapids BLACKPEARL RESOURCES INC.
330
325
Max Flooding
Surface (MFS) 320
L.GR Caprock
LGR1 315
Lower Grand Rapids Top SAGD Reservoir 310
INJECTOR 305
PRODUCER 300
LGR2 295
290
1050 m
DP1
Oil/Water Contact Shale filled tidal channel

data may be present
A PAD # DP7 (G.L. 604.50m) A´
1AA/08-01-077-18W4/00 102/01-12-077-18W4/00
AT30 (OHM.M) AHT90 (OHMM) December 2013
0.20 2000.00 0.20 2000.00
NPOR_SAN (M3/M3) AT90 (OHM.M) NPOR_SAN (V/V) AHT30 (OHMM)

0.60 0.00 0.20 2000.00 0.60 0.00 0.20 2000.00 400
GR (GAPI) DPHI_SAN (M3/M3) AT20 (OHM.M) GR (GAPI) DPHI_SAN (V/V) AHT20 (OHMM)
0.00 150.00 0.60 0.00 0.20 2000.00 0.00 150.00 0.60 0.00 0.20 2000.00 395
Joli Fou 390 FIGURE 4-7

385
Joli Fou Caprock 375 1AA/08-01-077-18W4/00
370 &
Upper 365 102/01-12-077-18W4/00
Grand CROSS-SECTION
Rapids 360
DRAINAGE AREA DP7
355
Elevation (mSS)
350
Upper Grand Rapids
330
Max Flooding
Surface (MFS) 325
LGR1 L.GR Caprock 320
Lower Grand Rapids Top SAGD Reservoir 315
R
INJECTO 310
U C ER
PROD 305
300
LGR2
295
Base SAGD Reservoir
290
285
1050 m
DP1

data may be present
A PAD # DP8 (G.L. 604.5m) A´
1AB/06-01-077-18W4/00 1AA/13-01-077-18W4/00 December 2013
AHT90 (OHMM) AHT90 (OHMM)
0.20 2000.00 0.20 2000.00
NPOR_SAN (V/V) AHT30 (OHMM) DPHI_SAN (V/V) AHT30 (OHMM)

0.60 0.00 0.20 2000.00 0.60 0.00 0.20 2000.00 400
0.00
GR (GAPI)
150.00 0.60
DPHI_SAN (V/V)
0.00 0.20
AHT20 (OHMM)
2000.00 0.00
GR (GAPI)
150.00 0.60
TNPH_SAN (V/V)
0.00 0.20
AHT20 (OHMM)
2000.00 395 FIGURE 4-8
Joli Fou 390
380 1AB/06-01-077-18W4/00
Joli Fou Caprock &
375
1AA/13-01-077-18W4/00
370
CROSS-SECTION
Upper 365
Rapids 360
355 AER SIR 2 RESPONSES -
Elevation (mSS)
350
Upper Grand Rapids 345 PROPOSED BLACKROD
340
335
330
Max Flooding
k 325
Surface (MFS)
aproc
LGR1 L.GR C Top SAGD Reservoir 320
315
INJECTOR 305
PRODUCER 300
LGR2 295
285
1050 m
DP1

data may be present
3.0 RESOURCE RECOVERY PROCESS

5. Volume 1, Section 3.3.2 L.GR 1 Gas Distribution and Section 3.3.3 Transition Zone
Distribution, Page 3-30.
BlackPearl states “The isopach of the lean zone (Figure 3.3-3) reaches a maximum thickness
of approximately 6.5m.” and “This transition zone ranges from 0.3 to 5.8 meter in thickness.
The isopach of the transition zone which is in contact with the Net Pay Zone in shown in
Figure 3.3-4.”
a. Provide a discussion on how the transition zone will impact the performance in terms of
production rate, cumulative steam to oil ratio, and recovery of SAGD well pairs.
Response:
BlackPearl’s proposed production well standoffs (Volume 1, Section 4.6.3 of the Integrated Application
and Round 1 ERCB SIR 13) reduce the risk of bottom water influx and subsequent unsustainable steam
to oil ratios (SOR), which will reduce the targeted ultimate recovery due to economic restrictions. The
information obtained from the learning for the standoff from the Phase 1 wells will be incorporated into
future development.
There are higher risks to the economic performance of SAGD pairs which are placed close to bottom
water, SAGD well pairs which have portions of the producer well in or entire production well in bottom
water, versus higher wells for the following reasons.
• SAGD production wells placed entirely in bottom water or portions of the well that are in the bottom
water have higher SOR’s during initial years of SAGD operations, which reduce the economics of the
Project when it is most critical.
• It is extremely difficult to achieve a uniform steam chamber development over the entire horizontal
section, especially in the early stages of operation. To rely on the principle of slumping of heated oil
into the bottom water to seal the entire horizontal production well, which is the only way a uniform
steam chamber can be achieved, may put the entire Project at economic risk if unsuccessful.
• Should bottom water coning occur on a SAGD pair it will impact the operation of the adjacent pairs in
later stages of development when the steam chambers from adjacent well pairs of coalesced into a
common chamber.
• Lower SAGD well pairs have a greater risk that portions of the producer wells could enter the bottom
water due to drilling accuracies.
As described in Round 1 ERCB SIR 19, BlackPearl will operate SAGD well pairs with a pressure balance
to prevent steam losses to bottom water as well as to prevent water from mobilizing up to the production
well. In areas where a lean zone is present, operational procedures will be in place to minimize steam
loss to the lean zone to maximize recovery of the SAGD well pairs in the area. Steam losses to the lean
zone will have a negative effect on production rates, SOR’s and ultimate recovery. Therefore operational
strategies (described in Part b of this SIR) will be in place to reduce the steam losses to any lean zones to
maximize well performance in these areas.
BlackPearl’s approach to the well placement in Phase 1 is to ensure the initial well pairs can be
economically produced and thus protect the significant investment BlackPearl must make to start
operations of Phase 1. BlackPearl will look to the information obtained from our Pilot and Phase 1, as well
as other projects to maximize the ultimate recovery of the Blackrod SAGD Project.
Page 16
5. b. Describe how BlackPearl will mitigate loss of steam to the transition zone.
Response:
Steam injection pressure management and producer well drawdown pressure are still critical factors in
BlackPearl’s operational strategy to reduce steam loss to the transition zone, prevent water influx and
steam loss to a lean zone where lean zones are present. Also refer to Round 1 ERCB SIR 19 for the
proposed operating procedures and pressures during start-up, circulation and SAGD mode.
Bottom Water Influx Mitigation Strategy/Steam Loss to Transition Zone:

Operating pressure will be controlled through steam injection and emulsion production rates. The
pressure difference between the bottom water and operating pressures will be minimized to limit steam
loss to the transition zone and/or bottom water. Operational pressures will be guided by monitoring the
bottom water pressures, produced water rates and chlorides.
Steam Loss to Lean Zone Mitigation Strategy:

A similar strategy to bottom water influx/steam loss to transition zone will be used to reduce steam loss
into lean zones, where present. The key will be to minimize the pressure difference between the injection
pressures and lean zone to minimize steam loss. The BlackPearl monitoring program includes
temperature monitoring to quantify steam chamber growth at a fixed point in the reservoir. This
temperature data is generally more applicable to SAGD optimization then to determining communication
between a SAGD operations and a lean zone due to the point source nature of the data.
Page 17
4.0 HYDROGEOLOGY
6. Volume 1, Section 4.4.1.2 Groundwater Monitoring, Page 4-4 to 4-5.
BlackPearl notes that there are two observation wells, 00/03-36-076-18W4 and
00/14-25-076-18W4, completed in the bottom water. However, these two wells are shown in
Figure 4.4-3 as being completed in the Lower Grand Rapids Unit 3 (LGR 3).
a. Clarify whether or not the LGR 3 aquifer is considered bottom water for the proposed
project.
Response:
The reference to 00/03-36-076-18W4 and 00/14-25-076-18W4 being completed in the bottom water in
Volume 1, Section 4.4.1 of the Integrated Application was erroneous. The 00/03-36-076-18W4 and 00/14-
25-076-18W4 wells were drilled as part of the Pilot Project to monitor the fully water saturated LG3
aquifer. Volume 1, Section 4.4.1 has been updated to reflect this corrected wording in the Round 2 SIR
BlackPearl Errata section. For additional information regarding the LGR3 monitoring program, refer to the
Blackrod Pilot Application (Approval 11522) and Environmental Protection and Enhancement Act (EPEA)
Application (Approval No. 264736-00-00).
However, the LGR 3 aquifer (also referred to as the Grand Rapids 'B' aquifer) is considered bottom water
for the proposed Project. The LGR 3 is the lower most parasequence that underlies LGR 2 and LGR 1
and is always wet in the Project area.
As shown in Figure 4.4-3, monitoring wells MW LGR 3-36 (00/03-36-076-18W4) and MW LGR 14-25
(00/14-25-076-18W4) at the Pilot Project are completed in the LGR3 aquifer. These two wells are located
to the east of the main occurrence of bottom water of the LGR 1 unit (Volume 1, Figure 3.3-5).
6. b. Clarify differences between the LGR 3 and bottom water mapped in Figure 3.3-5.
Response:
Figure 3.3-5 is showing the distribution of bottom water in the LGR 1 unit only. The LGR 3 unit is always
wet and therefore, it was not included in the mapping illustrated in Figure 3.3-5.
6. c. Confirm whether the above noted LGR 3 monitoring wells responded to BlackPearl’s
LGR 3 pumping at 1F1/14-24-076-18W4.
Response:
Both of the above noted wells, 00/03-36-076-18W4 (MW LGR 3-36) and 00/14-25-076-18W4
(MW LGR 14-25), responded to pumping from 1F1/14-24-076-18W4. Measured water levels over time for
these wells are shown in Figures 6-1 and 6-2, respectively. Following the start of groundwater extraction
from 1F1/14-24-076-18W4, the groundwater levels measured at 00/03-36-076-18W4 and
00/14-25-076-18W4 decreased by 3 m and 5 m, respectively, with the majority of the change occurring in
the first 3 months following the start of pumping.
Page 18
December 2013
150
Gauge depth = 320.1 mKB (TVD)

152 Top of Aquifer = 326.3 mKB (TVD)
= 388.1 mKB (MD)
FIGURE 6-1
154
CHANGES IN WATER LEVEL

156 IN 00/03-36-076-18W4
Depth to Water (mKB)
(MW LGR 3-36)
158
160
PROPOSED BLACKROD
162
164
166
168 Recorded Water Level in MW LGR 3-36

Start of Continuous Pumping at WSW LGR 14-24
170
Dec-10 Mar-11 Jun-11 Sep-11 Dec-11 Mar-12 Jun-12 Sep-12 Dec-12
Date
Figure 6-1
Notes:
Changes in Water Levels
Gaps in data set due to power loss to instrumentation. in 00/03-36-076-18W4
Sudden decreases in water level correspond to purging during sampling events. (MW LGR 3-36)

data may be present
December 2013
130
Gauge depth = 319.0 mKB (TVD)

132
Top of Aquifer = 326.0 mKB (TVD)
= 385.1 mKB (MD) FIGURE 6-2
134
Recorded Water Levels at MW LGR 14-25 CHANGES IN WATER LEVEL
Start of Continuous Pumping at WSW LGR 14-24 IN 00/14-25-076/18W4
136
(MW LGR 14-25)
Depth to Water (mKB)
138
142
144
146
148
150
Dec-10 Mar-11 Jun-11 Sep-11 Dec-11 Mar-12 Jun-12 Sep-12 Dec-12
Date
Figure 6-2
Notes: Changes in Water Level
Gaps in data set due to power loss to instrumentation.
in 00/14-25-076-18W4
Sudden decreases in water level correspond to purging during sampling events. (MW LGR 14-25)

data may be present
6. d. Confirm that there is hydraulic connection between the LGR 3 aquifer and the bottom
water mapped in Figure 3.3-5.
Response:
There is hydraulic connection between the LGR 3 aquifer and the LGR 1 Bottom Water unit mapped in
Figure 3.3-5. Locally, the three parasequences, LGR 1, LGR 2 and LGR 3 are amalgamated and are
preserved as one blocky package. In these cases, where the sands are stacked, it is apparent that the
flooding surfaces separating each parasequence have been eroded by regressive surfaces.
7. Volume 3, Section 1.5.2.6 Model Constraints and Limitations, Page 1-18.
BlackPearl states that an equivalent porous media approach was taken for simulating
groundwater flow in the Grosmont Formation, even though secondary porosity is predicted to
be very important on a local scale. Provide the rationale for not using dual porosity or discrete
fractured network models for simulating groundwater withdrawals in the Grosmont.
Response:
To use either a dual porosity or discrete fracture network model, a detailed understanding of the fracture
network is required. This level of detail was not available on the Grosmont saline aquifer. Layers of
assumptions would have been made to create a model using either of these methods due to their
complexity, creating additional uncertainty and poor confidence in model results. The model created to
simulate flows in the Grosmont saline aquifer was kept simple to reflect the level of scientific information
available.
The use of an equivalent porous medium is conceptually simple, and a commonly used approach to
estimate flow in fractured media, as it avoids the need to characterize the fractures. Flow in a large
enough volume of fractured medium, as with the regional model of the Grosmont saline aquifer, can be
reasonably represented by flow through a porous medium (Singhal and Gupta 2010). Through research,
this approximation had been shown to be most valid when fracture density is high, fracture apertures are
constant, fracture orientations are distributed rather than constant, and the area modelled is large (Long
et al. 1982). Further, it is more applicable if the intent is to simulate volumetric flow, rather than
contaminant transport (Singhal and Gupta 2010). Since the Grosmont saline aquifer is understood to be a
highly fractured system, the modelled area is large, and the intent is to model only volumetric flow, in our
professional opinion, the application of the equivalent porous medium is considered a suitable choice.
8. Volume 1, Section 3.1.1.3 La Biche Formation, Page 3-5.

Since this application was submitted, updated information on the regionally important Colorado
Group aquitard has been released by the Alberta Geological Survey (AGS) in Map 600 and
Open File Report 2012-02. The Blackrod Commercial SAGD Project is located in an area
where several different Colorado Group Formations and the Lea Park Formation subcrop.
Improved stratigraphic interpretation of the Colorado Group and Lea Park Formation will be
useful for resolving wellbore integrity issues associated with long-term thermal in situ oil sands
operations. The absence of regional markers like the Second White Specks and the Base of
Fish Scales can also be useful for identifying deep Quaternary incisions.
a. Based on the nomenclature from AGS Map 600, update Section 3.1.1.3 and
Figure 3.1-2.
Response:
Please refer to Figure 8-1 for the updated stragraphic correlation chart for North Eastern Alberta.
Volume 1, Section 3.1.1.3 of the Integrated Application has been updated below.
Page 21
Colorado Group
The Colorado Group was deposited when the Alberta Basin was subjected to a widespread marine
transgression (Bachu 1999). The Colorado strata consist predominantly of thick shales within which there
are thin sandy units such as the Viking sandstone. The formations comprising the Colorado Group are, in
ascending order, the Joli Fou, Viking, the Base Fish Scales and the Second White Specks.
Joli Fou
The Joli Fou Formation is approximately 20 m to 26 m thick (Figure 3.1-11) in the Application Resource
Area (ARA) and consists of marine shales with minor interbedded fine-and medium grained sandstones,
which overly the Upper Grand Rapids (Glass 1990). In the ARA the Joli Fou Formation gently dips at
approximately 2m/km from +400 mSS in the northeast to 380 mSS in the southeast (Figure 3.1-12).
Viking
The Joli Fou is overlain by the Viking Formation which is comprised of laterally extensive, prograding,
stacked shoreface sands overlain by the Base Fish Scales. The Viking Formation is generally composed
of relatively well-washed and variably shaly, fine- to coarse-grained sandstone (Glass 1990).
Structure and isopach maps of the Viking sandstone are provided in Figures 3.1-13 and 3.1-14. Within
the ARA, the Viking Formation dips to the south east from +420 to +405 mSS. The Viking sandstone is
4 m to 14 m thick with the entire thickness ranging from 20 m to 25 m. The Viking Formation in the ARA is
typically wet.
Base Fish Scales

The Fish Scales Zone contains abundant fish remains (scales and skeletal material) within finely
laminated, generally nonbioturbated sandstone, siltstone and shales (Glass 1990). The Base Fish Scales
is overlain by the Second White Specks and is approximately 30 m to 35 m thick in the ARA, and dips to
the south from +450 to + 435 mSS.
Second White Specks

The Second White Specks consists of dark grey and brown shales associated with calcareous white
speckled shale (Glass 1990). The Lea Park Formation which normally lies above the Second White
Specks was eroded and truncated by the glacial action that created the buried bedrock valleys in the
Quarternary.
Bedrock Topography and Quaternary/Tertiary Deposits

Post Cretaceous deposits over the Blackrod lease consist of gravel, sand deposited at the base of
channels which are considered to be Tertiary (pre-glacial) in age and Quaternary (glacial) aged clay till
with layers and lenses of sand, and sand and gravel. The bedrock surface in the area was shaped by
multiple pre-glacial erosional events and processes that occurred prior to and during glaciations. There is
evidence of a north-south buried valley west of the ARA. These Quaternary/Tertiary deposits average
about 100 m in thickness in the ARA. Sand and gravel deposits likely occur on the floors of all of major
buried valleys. The age of the sand and gravel deposits (Quaternary or Tertiary) has not been determined
but for the purposes of this study, it is assumed the lowermost deposits are Tertiary age (i.e., pre-glacial).
Detailed discussion of the Quaternary/Tertiary deposits is discussed in Volume 3, Appendix 1A, and
Section 1A.4.3 of the Integrated Application.
Page 22
AGE Stratigraphy
Second White Specks

Base Fish Scales
Viking (Pelican Fm)
Joli Fou Fm
CRETACEOUS
Grand Rapids Fm Upper

L. GR 1
Lower L. GR 2
L. GR 3
Mannville Group
Clearwater Fm
Wabiskaw Mbr
McMurray Fm
D C B A
DEVONIAN
Fm
Fm
u
Fm
n
sk
to
m
Ni
Fm
ke
re
tF
rI
La
on
n
pe
to
ng
m
Up
Ire
os
o ki
Gr
Co
FIGURE 8-1
December 2013
STRATIGRAPHIC CORRELATION CHART
FOR NORTH EASTERN ALBERTA
PROPOSED BLACKROD
COMMERICAL SAGD PROJECT
8. b. Provide an Upper Cretaceous type log for the proposed Project Area.
Response:
Please refer to Figure 8-2 for an Upper Cretaceous type log.
Page 24
Second White Specks
Base Fish Scales
Viking
Joli Fou
U.GR
Capping Shale (MFS)

L.GR 1
RSE
L.GR 2
L.GR 3
December 2013 Figure 8-2
Upper Cretaceous Type Log
AESRD SIR 2 Responses – BlackPearl Resources

Inc. Proposed Blackrod Commercial SAGD Project
9. ERCB SIR 1 Responses, SIR 28 Surface Casing for Disposal Wells, Page 6.
BlackPearl indicates it will complete all future disposal wells similar to the Class II pilot disposal
well 00/02-25-76-18W4, which only has surface casing to 103 m. Given that BlackPearl is not
proposing to install surface casing to the base of the Grand Rapids Formation, this implies
BlackPearl will only be applying for Class II disposal for the commercial project. Clarify whether
BlackPearl will be applying for new disposal wells for the proposed project, and if so, what fluid
class.
Response:
BlackPearl will be applying for new Class 1B disposal wells for the Project. Due to the fact that the
100/02-25-076-18W4 well was drilled and completed prior to implementation of the new Draft Directive
051: Injection and Disposal Wells, BlackPearl received Class 1B reclassification for the
100/02-25-076-18W4 Disposal Well from the AER as per Application No. 1735278 and Disposal Scheme
Approval No. 11703A. As discussed with Erin Kempin (AER) during the time Application No. 1735278
was under review, future disposal wells drilled in support of the Commercial Project will be designed to
comply with the Class 1B requirements as stipulated in the new Draft Directive 051: Injection and
Disposal Wells. Please see Figure 9-1 for an illustration of how new disposal wells for the Commercial
Project will be set up.
Page 26
Conductor Hole: 444.5 mm
Conductor: Set @ depth as per Directive 008
Size: 339.7 mm
Surface Hole: 311.0 mm

Surface Casing: Set @ depth covering BGWP as per Directive 051
Size: 244.5 mm
Secondary Hole: 222 mm

Secondary Casing: Set @ depth just above Grosmont A
Size: 177.8 mm thermal grade c/w premium connections
Injection Tubing:
Size: 88.9mm c/w HDPE internal liner
Hydraulic Packer:
Size: 177.8mm x 88.9mm mechanical set, double grip packer
Open Hole Interval: 159.0 mm open hole Grosmont A section
FIGURE 9-1
GROSMONT A DISPOSAL WELL

t6790_AER_SiR2_Figure_9_1_Grosmont_A_Disposal_Well

Although there is no reason to believe that there are any errors associated with the data used to general this product or in the
product itself, users of these data are advised that errors in the data may be present December 2013
10. Volume 3, Figure 1A-4 Cretaceous Type Log, Page 1A-11.
The Upper Grand Rapids shown in this type log shows a thick sandstone near the top of the
unit. Previous sections discussed gas saturated intervals.
a. Discuss whether this sandstone has any water saturated intervals or aquifer intervals
within the local study area.
Response:
The Upper Grand Rapids ‘A’ consists of shale and variable occurrences of sandstone, the pore spaces of
which contain water or gas. The thicknesses and distribution of water-saturated sandstone intervals within
the Grand Rapids ‘A’ in the Hydrogeology Local Study Area (LSA) were illustrated in Figure 1A-36 of the
Integrated Application (Volume 3, Appendix 1A, Figure 1A-36, Page 1A-45 of the Integrated Application).
10. b. Provide the expected water quality of any identified Upper Grand Rapids Aquifers.
Response:
The Grand Rapids 'A' aquifer, where present, is approximately 30 m to 35 m below the Viking aquifer and
55m to 60 m above the Grand Rapids 'B' aquifer (see, for example, the Cretaceous type log in Volume 3,
Appendix 1A, Figure 1A-4, Page 1A-11 of the Integrated Application). Generally, groundwater
mineralization increases with depth. Accordingly, it is expected that water in the Grand Rapids 'A' would
be more saline than the water in the Viking aquifer and less saline than the water in the Grand Rapids 'B'
aquifer. Based on this observation and the available chemistry data for the Viking and Grand Rapids 'B'
aquifers (Volume 3, Appendix 1A, Page 1A-71 of the Integrated Application), the total dissolved solids
(TDS) concentrations of water in the Grand Rapids 'A' aquifer are expected to be roughly 2,000 mg/L.
10. c. Discuss BlackPearl’s plans to monitor pressures and temperatures in the Upper Grand
Rapids Aquifer or gas cap.
Response:
The Grand Rapids 'A' aquifer is not considered to be a groundwater management unit. The
water-saturated sandstones of the Grand Rapids ‘A’ do not constitute a laterally continuous aquifer in the
Project Area (Westwater Environmental Ltd. 2011). Of the 59 well locations in the Hydrogeology LSA
(Volume 3, Appendix 1A, Figure 1A-36, Page 1A-45 of the Integrated Application), 23 (39%) had no
water-saturated sandstone in the Grand Rapids ‘A’. Similar numbers are seen for the Project Area:
water-saturated sandstone in the Grand Rapids ‘A’ was absent in 36% of well location boreholes (Volume
3, Appendix 1A, Figure 1A-36, Page 1A-45 of the Integrated Application). In many cases, the presence of
water-saturated sandstone within the Grand Rapids ‘A’ is not consistent even between adjacent leases.
Voids within the Grand Rapids ‘A’ sandstone commonly contain gas rather than water.
For the Grand Rapids ‘A’ sandstone to be a groundwater management unit, the minimum areal extent
should be such that it is adequate, when coupled with thickness, for the aquifer to supply water for
practical use. The discontinuity of sandstone between boreholes in both the Hydrogeology LSA and
Project Area, coupled with its tendency for gas-saturation, have discounted the Grand Rapids ‘A’
sandstone as a viable groundwater supply and therefore it is not considered a groundwater management
unit. Consequently, pressure and temperature monitoring of the Grand Rapids ‘A’ is not considered to be
warranted. BlackPearl does not have plans for monitoring pressure and temperature within the Upper
Grand Rapids ‘A’.
Page 28
At the Pilot, the 13-25 Toe Observation Well and the 14-25 Heel Observation Well have thermistors in the
Grand Rapids 'A' shale, just above the capping shale (Figure 10-1). These are at the top ends of the
strings of thermistors that monitor pressure and temperature for operational purposes within the capping
shale and Lower Grand Rapids Units 1 and 2.
Page 29
December 2013
FIGURE 10-1
BEDROCK MONITORING NETWORK LOCATION

CROSS SECTION SCHEMATIC

PROPOSED BLACKROD

data may be present
11. Induced Hydraulic Communication from water saturated steam chambers (LGR 1) to the
Lower Grand Rapids B (LGR 3) aquifer.
There may be potential for induced hydraulic communication, after SAGD ceases, from inactive
exploited steam chambers through bottom water or through lean zones or transition zones in
the Lower Grand Rapids B bitumen reservoir to the Grand Rapids B aquifer (i.e., similar to the
vertical induced hydraulic communication described by Barson et al., 2001, but with a lateral
flow component within the LGR 3).
a. Discuss the potential for induced hydraulic communication from steam chambers
(LGR 1) to the Grand Rapids B aquifer (LGR 3) at the proposed project.
Response:
There may be potential for induced hydraulic communication, after SAGD ceases, from inactive exploited
steam chambers through bottom water or through lean zones or transition zones in the Lower Grand
Rapids B bitumen reservoir to the Grand Rapids B aquifer (i.e., similar to the vertical induced hydraulic
communication described by Barson et al., 2001, but with a lateral flow component within the LGR 3).
11. b. In the event that induced hydraulic communication occurs:
i. Discuss how far heat would be transported down gradient of the steam chambers
prior to returning to ambient temperatures.
Response:
Thermal transport modelling was conducted with FEFLOW to account for induced hydraulic
communication from SAGD steaming into the Grand Rapids B aquifer. The heat transport was simulated
for a horizontal steam injection well with the heat boundary applied along top of the aquifer for the entire
length of the well screen. Induced communication was represented by assuming the heat from steaming
directly applied through the bitumen zone directly to the top of the Grand Rapids B aquifer.
FEFLOW is one of the most advanced, comprehensive groundwater models available. It simulates fully
coupled heat and groundwater flow, including adjusting hydraulic head and conductivity according to
changes in groundwater / media temperature. Advective heat transport through the groundwater is
included along with convective heat flow through the groundwater and media within FEFLOW’s numerical
solution. FEFLOW was chosen because of its fully comprehensive approach to representing heat flow
within groundwater systems.
The heat modelling was conducted with FEFLOW applying the following.
• Hydraulic parameters for the Grand Rapids B aquifer as follows.
− Aquifer isopach thickness (Volume 3, Appendix 1A, Figure 1A-30 of the Integrated Application).
-6
− Hydraulic conductivity – 4.2 x 10 m/s.
− Hydraulic gradient – 0.00042.
− Direction of hydraulic gradient – towards the northwest at the Project Area.
• The heat related model parameters applied are as follows.
− Volumetric heat capacity of fluid (water) – 4.2 J/m3/K.
− Heat conductivity of fluid (water) – 0.65 J/m/s/K.
Page 31
− Volumetric heat capacity of sandstone – 2.5 J/m3/K.
− Heat conductivity of sandstone - 3 J/m/s/K.
− Longitudinal dispersivity – 10 m.
− Transverse and vertical dispersivity – 1 m.
− Porosity – 30%.
− Background temperature of water – 15 degrees C.
− A heat boundary of 250 degrees C along the 950 m long steam injection well screen applied at
the top or the Grand Rapids B aquifer.
Steam injection was simulated with a representative injection well located within centre of the Project
Area for a 10 year period. The results of the simulation are shown in Figure 11-1. Heat travels a distance
of 60 m at the end of the simulated steam period. After the end of 10 years of steaming, a 50 year
recovery period was simulated. The maximum distance the heat travels is 160 m as shown. The heat
resulting from steaming travels away from the injection well in a radial type pattern demonstrating the
heat flow is dominated by convective transport forces and not advective transport from groundwater flow.
If heat transport was dominated by advective flow heat transport would be elongated along the direction
of groundwater flow. This is a reasonable result given the low hydraulic gradient and low hydraulic
conductivity within the Grand Rapids B aquifer.
11. b. In the event that induced hydraulic communication occurs:
ii Discuss how far conservative contaminants would be transported down gradient of

the steam chambers prior to returning to background concentrations.
Response:
Applying the hydraulic parameters and porosity presented in the response to 11 (b) (i), a conservative
solute is expected to travel 10 m within the 50 year recovery period. Solutes are not expected to travel far
from the source of steaming given the low hydraulic gradient and conductivity within the Grand Rapids A
aquifer.
Page 32
SAGD Steam
Injection Well 60m
(Max. Temp. 250 C)
UTM Northing (m)
15
A) Simulated Temperature within the Grand Rapids B Aquifer

After 10 Years Of Steam Injection
UTM Easting (m)
SAGD Steam
160m
Injection Well
15
UTM Northing (m)
B) Simulated Temperature within the Grand Rapids B Aquifer

50 Years After End Of Steam Injection
UTM Easting (m)
FIGURE 11-1
SIMULATED TEMPERATURE CONTOURS FROM STEAM INJECTION

t6790_AER_SiR2_Figure_11_1_SIMULATED TEMPERATURE CONTOURS FROM STEAM INJECTION.pdf
Contour Temperature in °C
AER SIR 2 RESPONSES - BLACKPEARL RESOURCES INC.
Although there is no reason to believe that there are any errors associated with the data used to general this product or in the
product itself, users of these data are advised that errors in the data may be present December 2013
5.0 AIR QUALITY

12. April 2013 Project Update, Table B-1 Comparison of 1-Hour (9th Highest) NO2
Concentrations and Table B-2 Comparison of Annual NO2 Concentrations, Page B-6 and
B-12.
Tables B-1 and B-2 show an exceedance of the Alberta Ambient Air Quality Objectives
(AAAQO) for 1-hour and annual NO2 concentrations in the RSA. This is for all four assessment
scenarios, i.e. for existing condition, baseline case, application case, and planned development
case. BlackPearl did not discuss these exceedances in its submission. Provide a discussion of
the above exceedances including causes, potential adverse effects and mitigation.
Response:
The HHRA did not evaluate potential adverse human health effects from predicted air concentrations at
the Regional Study Area (RSA) Maximum Point of Impingement (MPOI) because the Project is predicted
to have negligible impact on air quality outside of the LSA. The air quality LSA was defined by an area of
100 km east to west and by 100 km north to south centered on the Project. Predicted maximum and 9th
highest NO2 concentrations and the probability of predicted hourly concentrations above benchmark
values is presented in Table 12-1 for each assessment case at the RSA MPOI location. Based on the air
quality April 2013 Project Update, the following exceedances were presented at the RSA MPOI.
• 1-hour (9th highest) NO2 concentrations were predicted above the Alberta Ambient Air Quality
Objectives (AAAQO) (300 µg/m³) for the Baseline Case, Application Case and Planned Development
Case (PDC).
• Annual (maximum of 5-years) NO2 concentrations were predicted above AAAQO (45 µg/m³) for the
Baseline Case, Application Case and PDC.
The Human Health Risk Assessment (HHRA) did not use the 1-hour AAAQO because limited information
is provided regarding the rationale of deriving the objective (Volume 5, Section 4.0, Appendix 4A,
Section 4A.55 of the Integrated Application). Instead the HHRA used the 1-hour National Air Standard of
188 µg/m³ derived by the United States Environmental Protection Agency (US EPA) (2010a). The degree
of conservatism incorporated into the NO2 exposure limit used in the HHRA must be considered in the
interpretation of the likelihood of potential adverse health effects with the predicted exceedances at the
RSA MPOI. Review of the scientific literature (Table 12-2) generally indicates that no adverse effects
among healthy individuals are observed for brief periods of exposure to concentrations of nitrogen dioxide
less than 1,900 µg/m³. In addition, a recent meta-analysis of NO2 exposure and airway
hyper-responsiveness in asthmatics suggests that there is no evidence that NO2 causes clinically relevant
effects in asthmatics at concentrations up to 1,100 µg/m³ (Goodman et al. 2009). The probability of
exceeding the US EPA NO2 exposure limit of 188 µg/m³ at the RSA MPOI is 7% and there is a zero
percent probability of exceeding concentrations greater than 490 µg/m³ at the RSA MPOI. Finally, the
maximum hourly concentration of NO2 in the Baseline Case, Application Case and PDC is 450 µg/m³ and
is predicted to occur 35 km north of Fort McMurray near existing oil sand operations or more than 160 km
from the Project.
Adverse impacts from short-term exposures to NO2 at the RSA MPOI are not expected based on the
following:
• the conservatism incorporated in the exposure limit; and
• hourly maximum concentrations (i.e., 450 µg/m³) for each assessment case are below
levels where NO2 causes clinically relevant effects in asthmatics (Table 12-2;
Goodman et al. 2009).
The HHRA did not use the annual AAAQO because is based on vegetation effects (AESRD 2013).
Instead the HHRA used the US EPA (2010a) ambient air quality standard of 53 ppb (100 µg/m³) because
it was health based for sensitive individuals (i.e., children). For all assessment cases the predicted
Page 34
maximum annual average NO2 concentrations (i.e., ranged from 68 to 72 µg/m³) were predicted to be
below the health based ambient air quality standard of 100 µg/m³. The maximum annual average was
predicted to occur at a location similar to the hourly RSA MPOI for NO2, but was about 15 km apart.
Adverse health effects from long-term exposures to predicted NO2 concentrations at the RSA MPOI are
not expected because the predicted concentrations are below the US EPA (2010a) ambient air quality
standard of 100 µg/m³.
Finally, the predicted NO2 concentration values for the Application Case were identical to those predicted
in the Baseline Case, indicating that the Project emissions are expected to have a negligible impact on
predicted health risks at the RSA MPOI.
The predicted concentrations in excess of the AAAQO in the RSA are attributable to emissions from other
oil sands facilities and are predicted to occur at considerable distance from the Project. Additional
mitigation measures for the Project will not reduce the maximum predicted concentrations in the RSA.
The Lower Athabasca Region Air Quality Management Framework was developed by AESRD to clearly
define the management of cumulative effects on development and contribute to the achievement of
desired regional objectives for air quality. The framework establishes triggers and limits for NO2 and uses
monitoring data to determine appropriate management response to increase levels of measured NO2
concentrations to prevent actual exceedances of the AAAQO (AESRD 2012).
TABLE 12-1
PREDICTED HOURLY NO2 MAXIMUM, 9th HIGHEST AND PROBABILITY OF

EXCEEDING ADVERSE ACUTE HEALTH EFFECT LEVELS
Application
Parameter Baseline Case Case PDC
Hourly Maximum [ug/m3] 449 449 453
Hourly 9th Highest [ug/m3] 393 393 395
Probability <190(a) 93% 93% 93%
Probability >190(a) 7% 7% 7%
Note: (a) Based on 5 years of predicted hourly concentrations.
TABLE 12-2
POTENTIAL ACUTE HEALTH EFFECTS ASSOCIATED WITH NO2
Air Concentration Air Concentration

[µg/m3] [ppm] (1) Description of Potential Health Effects References
<190 0.1 No documented reproducible evidence (consistent and Hesterberg et al. (2009);
significant) of adverse health effects among healthy Goodman et al. (2009);
individuals or susceptible individuals following short-term Koenig et al. (1985);
exposure. Study results are variable and can be Hazucha et al. (1983)
indiscernible from background or control groups.
190 to 560 0.1 to 0.3 Increased airways responsiveness, detectable via meta- California Environmental
analysis, among asthmatics. Large variability in both Protection Agency (Cal EPA)
protocols and responses. (2007);
US EPA (2008)
490 0.26 Allergen-induced decrements in lung function and Cal EPA (2007);
increased allergen-induced airways inflammatory US EPA (2008)
response among asthmatics. Most studies used non-
specific airways challenges. No NO2-induced change in
lung function. No documented effects among healthy
individuals.
Page 35
TABLE 12-2 Cont’d

Air Concentration Air Concentration
[µg/m3] [ppm] (1) Description of Potential Health Effects References
560 to 750 0.3 to 0.4 Potential effects on lung function indices, including Gong et al. (2005);
inconsistent changes forced expiratory volume in 1 Morrow et al. (1992);
second and forced vital capacity among patients with Vagaggini et al. (1996)
chronic obstructive pulmonary disease (COPD) during
mild exercise.
1,900 to 3,700 1 to 2 Increased likelihood of inflammatory response and Azadniv et al. (1998);
airway responsiveness among healthy individuals during Blomberg et al. (1997,1999);
intermittent exercise. Symptoms have not been detected Devlin et al. (1999);
by most investigators among healthy individuals. Jorres et al. (1995);
Asthmatics might experience small decrements in forced US EPA (2008)
expiratory volume in 1 second.
≥3,700 >2 Changes in lung function, such as increased airway Beil and Ulmer (1976);
resistance, in healthy individuals. von Nieding et al. (1979, 1980);
von Nieding and Wagner (1977)
Note: (1) ppm NO2 converted to µg/m³ by multiplying by conversion factor of 1,900.
13. April 2013 Project Update, Table B-3 Comparison of 1-Hour (9th Highest) SO2
Concentrations and Table B-4 Comparison of 24-Hour (2nd Highest) SO2
Concentrations, Page B-18 and B-24.
Tables B-3 and B-4 show an exceedance of the AAAQO for 1-hour and 24-hour SO2
concentrations in the RSA. This is for all four assessment scenarios, i.e. for existing condition,
baseline case, application case, and planned development case. BlackPearl did not discuss
these exceedances in its submission. Provide a discussion of the above exceedances including
causes, potential adverse effects, and mitigation.
Response:
the RSA MPOI because the Project is predicted to have negligible impact on air quality outside of the
LSA. The air quality LSA was defined by an area of 100 km east to west and by 100 km north to south
centered on the Project. Predicted maximum and 9th highest SO2 concentrations and the probability of
predicted hourly concentrations above benchmark values is presented in Table 13-1 for each assessment
case at the RSA MPOI location. Based on the air quality April 2013 Project Update, the following
exceedances were presented at the RSA MPOI.
• 1-hour (9th highest) SO2 concentrations were predicted above AAAQO (450 µg/m³) for the Baseline
Case, Application Case and PDC.
• 24-hour (2nd highest) SO2 concentrations were predicted above AAAQO (125 µg/m³) for the Baseline
The HHRA did not use the 1-hour AAAQO because limited information is provided regarding the rationale
of deriving the objective (Volume 5, Section 4.0, Appendix 4A, Section 4A.62 of the Integrated
Application). Instead the HHRA used the 1-hour National Air Standard of 188 µg/m³ derived by the US
EPA (2010). The degree of conservatism incorporated into the SO2 exposure limit must be considered in
the interpretation of the likelihood of potential adverse health effects with the predicted exceedances at
the RSA MPOI. A review of the scientific literature indicates that no adverse effects among healthy
individuals are observed for brief periods of exposure to concentrations of SO2 less than 1,300 µg/m³ (see
Table 13-2). The maximum predicted hourly SO2 concentration at the RSA MPOI (930 µg/m³) in the
Application Case is within the range of air concentrations where increased airway resistance and potential
bronchoconstriction in asthmatic or sensitive individuals is observed when engaged in moderate exercise.
All changes in airway resistance are reversible and shortness of breath or other clinical signs may be
observed depending on severity of the asthmatic condition. The probability of exceeding the
concentration level 530 µg/m³ at the RSA MPOI is less than 0.1%. Finally, the maximum concentration of
Page 36
SO2 in the Baseline Case, Application Case and PDC is predicted to occur 35 km north of Fort McMurray
or more than 160 km from the Project.
Based on the low likelihood of SO2 concentrations exceeding guidelines, the conservatism incorporated in
the exposure limit and the low likelihood that an individual will be present at the MPOI at the exact time
when maximum concentrations are reached, the predicted acute SO2 risks are likely overstated and
adverse impacts from short-term exposures to SO2 at the RSA MPOI are not expected.
Finally the predicted respiratory quotient values for the Application Case were identical to those predicted
in the Baseline Case, indicating that the Project emissions are expected to have a negligible impact on
predicted health risks.
The predicted concentrations in excess of the AAAQO in the RSA are attributable to emissions from other
oil sands facilities and are predicted to occur at considerable distance from the Project. Additional
mitigation measures for the Project will not reduce the maximum predicted concentrations in the RSA.
The Lower Athabasca Region Air Quality Management Framework was developed by AESRD to clearly
define the management of cumulative effects on development and contribute to the achievement of
desired regional objectives for air quality. The framework establishes triggers and limits for SO2 and uses
monitoring data to determine appropriate management response to increase levels of measured SO2
concentrations to prevent actual exceedances of the AAAQO (AESRD 2012).
TABLE 13-1
PREDICTED HOURLY SO2 MAXIMUM, 9th HIGHEST AND PROBABILITY OF

EXCEEDING ADVERSE ACUTE HEALTH EFFECT LEVELS
Parameter Baseline Case Application Case PDC

Hourly Maximum [ug/m ] 3 930 930 941
Hourly 9th Highest [ug/m3] 537 537 542
Probability <190(a) 98.8% 98.8% 98.7%
Probability >190(a) 1.2% 1.2% 1.3%
Probability >250(a) 0.6% 0.6% 0.7%
Probability >530(a) 0.1% 0.1% 0.1%
Probability >1300(a) 0.0% 0.0% 0.0%
Note: (a) Based on 5 years of predicted hourly concentrations.
TABLE 13-2
POTENTIAL ACUTE HEALTH EFFECTS ASSOCIATED WITH SO2
Concentration in Air
ppm µg/m³(1) Description of Potential Health Effects(2)
No documented reproducible evidence of adverse health effects among healthy individuals or
<0.1 <250
susceptible individuals(3) following short-term exposure.
Possible modest, transient changes in lung function indices, detectable by spirometry, among
asthmatics during moderate to strenuous exercise. Changes characterized by increased airway
0.1 to 0.2 250 to 530 resistance and/or reduced air conductance. All changes fully reversible and strictly sub-clinical in nature,
with no evidence of wheezing, shortness of breath or other clinical signs. No documented effects among
healthy individuals.
Increased airway resistance and potential bronchoconstriction in asthmatic or sensitive individuals
0.2 to 0.5 530 to 1,300 engaged in moderate exercise. Bronchoconstriction with or without attendant clinical signs depending
on severity of asthmatic condition. Typically no effects on lung function in normal individuals.
Page 37
TABLE 13-2 Cont'd
Concentration in Air
ppm µg/m³(1) Description of Potential Health Effects(2)
Increased resistance in airways and difficulties breathing may be experienced by normal individuals (in
addition to asthmatics and sensitive individuals). Sore throat and the ability to taste and smell SO2 may
0.5 to 1 1,300 to 2,600
also be apparent. Effects in asthmatics and other sensitive individuals may also include wheezing,
dyspnea, and bronchoconstriction.
Odour is detectable. Increased resistance in airways, decreased lung volume, reduced bronchial
clearance, and evidence of lung irritation (increased macrophages in lung fluid) were observed at this
exposure level. Headache, coughing, throat irritation, nasal congestion, increased salivation may be
1 to 5 2,600 to 13,000
evident, and some symptoms may persist for several days after exposure. Mucociliary transport in the
nasal passages may also be impaired, potentially leading to nasal congestion. Respiratory effects may
be more severe in asthmatics and sensitive individuals.
Increased resistance in airways, decreased respiratory volume, difficulties breathing, and lung irritation
were reported at this exposure level. Nasal, throat, and eye irritation, nosebleeds, coughing, potentially
5 to 10 13,000 to 26,000
accompanied by erythema of trachea and bronchi may occur. Respiratory effects may be more severe
in asthmatics and sensitive individuals.
Symptoms of more severe respiratory irritation may appear, such as burning of nose and throat,
sneezing, severe airway obstruction, choking, and dyspnea. Exposure may result in damage to airway
epithelium that may progress to epithelial hyperplasia, an increased number of secretory goblet cells,
and hypertrophy of the submucosal glands. A condition known as Reactive Airway Dysfunction
10 to 50 26,000 to 130,000
Syndrome may arise in the concentration ranges (as well as above) as a result of bronchial epithelial
damage. Chronic respiratory effects may develop. Eye irritation, watery eyes, and skin eruptions
(rashes) may be evident. Respiratory effects may be more severe in asthmatics and sensitive
individuals.
Symptoms of severe respiratory irritation may occur, such as bronchitis, intolerable irritation of mucous
50 to 100 130,000 to 260,000 membranes in addition to other effects described above, such as decreased lung capacity and breathing
difficulties, runny nose, eye and skin irritation.
Immediately dangerous to life and health. Chemical bronchopneumonia and asphyxia were reported at
>100 >260,000 high levels of exposure. Death may result from severe respiratory depression at concentrations of about
2 600 000 µg/m³.
Sources: Agency for Toxic Substances and Disease Registry 1998, Cal EPA 1999, Hazardous Substances Data Base 2010, National Institute of
Occupational Safety and Health 1974, World Health Organization 1979, 2000
Notes: (1) ppm SO2 converted to µg/m³ by multiplying by conversion factor of 2,600.
(2) Note that the descriptions pertain largely to the types of health effects that might be experienced among normal, healthy individuals
following acute exposure to SO2. Some descriptions refer to the types of symptoms that might occur among individuals with pre-existing
eye and/or breathing disorders, such as asthma, bronchitis or COPD. The exact nature and severity of responses that might occur
among these latter individuals will depend on several factors, including: i) the severity of the person’s condition; ii) the age of the
individual; iii) the level of management of the disorder, including the availability and use of medications; iv) the person’s level of physical
activity; and/or, v) external environmental factors such as temperature and humidity. The symptoms that could be experienced by these
individuals could be more or less severe that those described because of these factors.
(3) Includes individuals suffering from respiratory disorders, such as asthma, bronchitis, and COPD.
14. April 2013 Project Update, Table B-8 Comparison of 24-Hour (2nd Highest) PM2.5
Concentrations, Page B-48.
Table B-8 shows an exceedance of the AAAQO for 24-hour PM2.5 concentration in the RSA.
This is for all four assessment scenarios, i.e. for existing condition, baseline case, application
case and planned development case. BlackPearl provided some context on the higher
emissions predicted for existing conditions. No further discussions were provided about the
three other assessment scenarios. Provide a discussion of the above exceedances including
causes, potential adverse effects, and mitigation.
Response:
the RSA MPOI because the Project is predicted to have negligible impact on air quality outside of the
LSA. The air quality LSA was defined by an area of 100 km east to west and by 100 km north to south
centered on the Project. Based on the air quality April 2013 Project Update, the following exceedances
were presented at the RSA MPOI.
Page 38
• 1-hour (9th highest) PM2.5 concentrations were predicted above AAAQG (80 µg/m³) for the Baseline
• 24-hour (2nd highest) PM2.5 concentrations were predicted above AAAQG (30 µg/m³) for the Baseline
Predicted daily 98th percentile concentrations for PM2.5 were predicted to exceed the Canada Wide
Standard (CWS) (i.e., 30 µg/m3) at the RSA MPOI. The analysis and interpretation of the short-term PM2.5
exceedances considered the following:
• the conservative nature of the air quality assessment;
• short-term verses long-term PM2.5 concentrations predicted at the RSA MPOI;
• potential contributions from the Project and other planned future emission sources; and
• the likelihood of an exceedance at the location associated with the maximum

concentration.
The HHRA did not use the 1-hour and 24-hour AAAQG because the 1-hour value is intended for use in
monitoring and reporting of the Ambient Air Quality Index (Volume 5, Section 4.0, Appendix 4A,
Section 4A.56 of the Integrated Application). In addition, the 24-hour AAAQG was not used because the
CWS was selected over the AAAQG, as the value of 30 µg/m³ is the primary source (Canadian Council of
Ministers of the Environment [CCME] 2000), and the CCME provides more substantive supporting
documentation for the derivation of the guideline (Volume 5, Section 4.0, Appendix 4A, Section 4A.56 of
th
the Integrated Application). The daily 98 percentile PM2.5 at the RSA MPOI was predicted to be 104, 104
and 105 µg/m in the Baseline Case, Application Case and PDC, respectively. Table 14-1 presents the
predicted daily maximum, daily 2nd highest and daily 98th percentile concentrations at the RSA MPOI for
the Baseline Case, Application Case and PDC. In addition, Table 14-1 resents the predicted probability
that daily PM2.5 concentrations would exceed the CWS of 30 µg/m³ at the RSA MPOI. The following
considerations are critical to interpreting the results of the acute inhalation PM2.5 assessment.
• Comparison of measured daily 98th percentile concentrations (Figure 14-1) to the predicted
concentrations demonstrates that the results of the air quality modelling are fairly conservative.
Measured daily PM2.5 98th percentile concentrations for the past decade are typically below 20 µg/m³
at Fort McKay and both Fort McMurray ambient air monitoring stations (i.e., Patricia McInnes and
Athabasca Valley). The only exception is in the year 2011 when Wood Buffalo Environmental
Association (WBEA) ambient air monitoring stations were severely impacted with forest fires during
the months of May and June.
• The predicted daily PM2.5 98th percentile concentration at the RSA MPOI is predicted to occur 35 km
north of Fort McMurray and is predicted to be 168 km from the Project.
• The Project is not predicted to appreciably increase the occurrence of PM2.5 concentrations exceeding
30 µg/m³ at the RSA MPOI.
In the examination of potential human health risks associated with acute inhalation exposures to PM2.5 it is
also important to recognize that particulate matter (PM) health effects are dependent on both exposure
concentrations and length of exposure and that the short-term studies only capture a small amount of the
overall health effects of PM exposure (Pope and Dockery 2006). In a critical review of health effects of
fine particulate air pollution, Pope and Dockery (2006) found that long-term repeated exposures have
larger, more persistent cumulative effects than short-term transient exposures. The adverse health effects
of particulate air pollution are likely dependent on both exposure concentrations and length of exposure;
therefore, it is expected that long-term repeated exposures would have larger, more persistent cumulative
effects than short-term transient exposures (Pope and Dockery 2006). With regard towards long-term PM
exposures and mortality effects, recent focus has been on cohort studies that can control for individual
differences in age, sex, smoking history and other risk factors. The PM-mortality effect estimates from
these prospective cohort studies are substantially larger than those from the daily time series and case
crossover studies (i.e., studies used in the derivation of daily exposure limits). Pope and Dockery (2006)
Page 39
concluded that long-term repeated exposures to pollution may have more broad-based impacts on
long-term health and susceptibility, and suggest that the daily time series studies only capture a small
amount of the overall health effects of long-term repeated exposure to PM. For this reason, results of the
chronic inhalation assessment (i.e., comparison of annual average exposure to chronic exposure limits)
may be considered a better predictor of potential health effects associated with PM2.5 than acute
assessment results. A discussion of the predicted long-term risks to PM2.5 exposures are presented
below.
Predicted annual average PM2.5 concentrations were predicted to exceed the California Air Resource
Board standard of 12 µg/m³ at the RSA MPOI in the Baseline Case, Application Case and PDC. The
predicted PM2.5 concentrations for the Baseline Case and Application Case were identical indicating that
the contributions of the Project with respect to air emissions will have a negligible impact on health at the
RSA MPOI. Adverse effects from chronic exposure to PM2.5 are not expected based on the following
considerations.
• The location of the annual PM2.5 RSA MPOI is within a remote region where chronic exposures are
not likely. The predicted RSA MPOI annual average PM2.5 concentration is located 35 km north of Fort
McMurray and located on the east side of the Athabasca River near existing oil sand operations. The
location of the chronic PM2.5 RSA MPOI is similar to the location of the acute RSA MPOI.
• Conservatism incorporated in the air quality assessment.
• Project emissions are expected to have a negligible impact on predicted health risks.
The Baseline Case, Application Case and PDC PM2.5 annual average concentration was predicted to
range from 29 to 36 µg/m³ at the RSA MPOI. Based on the US EPA (2009, 2010b), annual average
ambient concentrations greater than 20 µg/m³ are associated with 8-10% (i.e, 25th and 75th quartile)
non-accidental premature mortality attributable to PM2.5 exposure. However, the predicted maximum
annual average air concentration at the RSA MPOI is likely overstated based on the concentrations
observed at WBEA ambient air monitoring stations (Figure 14-2). Annual average PM2.5 concentrations at
WBEA stations have consistently remained below 11 µg/m³ for a decade and most stations have been
lower than 7 µg/m³ in the last 10 years.
The predicted PM2.5 concentrations in excess of the AAAQO in the RSA are attributable to emissions from
other oil sands facilities and are predicted to occur at considerable distance from the Project. Additional
mitigation measures for the Project will not reduce the maximum predicted PM2.5 concentrations in the
RSA. The Lower Athabasca Region Air Quality Management Framework was developed by AESRD to
clearly define the management of cumulative effects on development and contribute to the achievement
of desired regional objectives for air quality. The framework establishes triggers and limits for NO2 and
SO2, which are both PM2.5 precursors and uses monitoring data to determine appropriate management
response to increasing levels of measured NO2 and SO2 concentrations (AESRD 2012). The CASA
(Clean Air Strategic Alliance) PM and Ozone Management Framework is another cumulative effect
management tool which requires an annual assessment of PM2.5 and assigns action levels to some areas
of the province which requires development of management plans that aim to prevent exceedances of the
AAAQO for PM2.5 (CASA 2003).
TABLE 14-1
PREDICTED MAXIMUM AND 98TH PERCENTILE PM2.5 CONCENTRATIONS AT THE

RSA MPOI AND PROBABILITY THAT PM2.5 CONCENTRATIONS AT THE
RSA MPOI WILL EXCEED THE CWS
RSA MPOI [Probability

RSA MPOI Daily RSA MPOI Daily 2nd RSA MPOI Daily 98th Daily Concentration >
Assessment Case Maximum [µg/m³] Highest [µg/m³] Percentile [µg/m³] 30 µg/m³]
Baseline 146 112 104 40%
Application 146 112 104 40%
PDC 148 113 105 42%
Page 40
AMS 01 - Fort McKay AMS 06 - Patricia McInnes AMS 07 - Athabasca Valley AMS 08 - Fort Chipewyan
AMS 12 - Millennium AMS 13 - Syncrude UE-1 AMS 15 - CNRL Horizon
200
98th Percentile PM2.5 Concentration [ug/m3]
Note that PM2.5 concentrations are elevated

180 in 2011 due to severe forest fires in May and
June and concentrations are elevated in
160 2012 due to forest fires in June and July.
140
120
100
80
60
40 Canada-Wide Standard, PM2.5 (98th Percentile) = 30 ug/m³
20
0
1998 2000 2002 2004 2006 2008 2010 2012 2014
Year
Figure 14-1 Measured Ambient 98th Percentile PM2.5 Concentrations at Wood Buffalo
Environmental Association Ambient Air Monitoring Stations
TABLE 14-2
PREDICTED ANNUAL AVERAGE PM2.5 CONCENTRATIONS AT THE RSA MPOI
RSA MPOI 5-Year Annual RSA MPOI Range in Annual Average for the 5-Year
Assessment Case Average [µg/m³] Period [µg/m³]
Baseline 31 29 to 35
Application 31 29 to 35
PDC 32 29 to 36
Page 41
AMS 06 - Patricia McInnes

AMS 01 - Fort McKay AMS 07 - Athabasca Valley AMS 08 - Fort Chipewyan
Measured Annual Average of PM2.5 Ambient Air Concentrations
Annual Average PM2.5 Concentration [ug/m3] AMS 12 - Millennium AMS 13 - Syncrude UE-1 AMS 15 - CNRL Horizon
20
19 Note that PM2.5 concentrations are elevated
18 in 2011 due to severe forest fires in May and
June and concentrations are elevated in 2012
17
due to forest fires in June and July.
16
15
14
13
California Air Resource Board’s (CARB) standard of 12 µg/m3 (annual average)
12
11
10
9
8
7
6
5
4
3
2
1
0
1998 2000 2002 2004 2006 2008 2010 2012 2014
Year
Figure 14-2 Summary of Annual Average PM2.5 Concentrations at Wood Buffalo Environmental
Association Ambient Air Monitoring Stations in the Oil Sands Region
Page 42
6.0 REFERENCES
Agency for Toxic Substances and Disease Registry. 1998. Toxicological Profile for Sulphur Dioxide.
United States Department of Health and Human Services.
Alberta Energy Regulator. 2013a. EnerFAQs 7: Proposed Oil and Gas Development: A Landowner’s
Guide. Website: http://www.aer.ca/compliance-and-enforcement/enerfaqs/enerfaqs-07.
Accessed: December 2013.
Alberta Energy Regulator. 2013b. EnerFAQs 12: Oil Sands. Website: http://www.aer.ca/compliance-and-
enforcement/enerfaqs/enerfaqs-12. Accessed: December 2013.
Alberta Energy Regulator. 2013c. EnerFAQs 15: Expressing Your Concerns – How to File a Statement of
Concern About an Energy Resource Project. Website: http://www.aer.ca/applications-and-
notices/statement-of-concern. Accessed: December 2013.
Alberta Environment and Sustainable Resource Development. 2012. Lower Athabasca Region Air Quality
Management Framework. Website:
http://environment.alberta.ca/documents/LARP_Framework_AirQuality_FINAL.pdf. Accessed:
August 2012.
Alberta Environment and Sustainable Resource Development. 2013. Alberta Ambient Air Quality
Objectives and Guidelines. Air Policy Branch. Website:
http://environment.gov.ab.ca/info/library/5726.pdf. Accessed: December 2013.
Azadniv, M., M.J. Utell, P.E. Morrow, F.R. Gibb, J. Nichols, N.J. Jr. Roberts, D.M. Speers, A. Torres, Y.
Tsai, M.K. Abraham, K.Z. Voter and M.W. Frampton. 1998. Effects of nitrogen dioxide exposure
on human host defense. Inhalation Toxicology 10(6):585-601.
Bachu, S. 1999. Flow systems in the Alberta Basin: Patterns, types and driving mechanisms. Bulletin of
Canadian Petroleum Geology 47:455-474.
Beil, M. and W.T. Ulmer. 1976. Wirkung von NO2 im MAK-Bereich auf Atemmechanik und bronchiale
Acetylcholinempfindlichkeit bei Normalpersonen [Effect of NO2 in workroom concentrations on
respiratory mechanics and bronchial susceptibility to acetylcholine in normal persons].
International Archives of Occupational and Environmental Health 38:31-44.
Blomberg, A., M.T. Krishna, V. Bocchino, G.L. Biscione, J.K. Shute, F.J. Kelly, A.J. Frew, S.T. Holgate
and T. Sandstrom. 1997. The inflammatory effects of 2 ppm NO2 on the airways of healthy
subjects. American Journal of Respiratory and Critical Care Medicine 156:418-424.
Blomberg, A., M.T. Krishna, R. Helleday, M. Söderberg, M.C. Ledin, F.J. Kelly, A.J. Frew, S.T. Holgate
and T. Sandström. 1999. Persistent airway inflammation but accommodated antioxidant and lung
function responses after repeated daily exposure to nitrogen dioxide. American Journal of
Respiratory and Critical Care Medicine 159:536-543.
California Environmental Protection Agency. 2007. Review of the California Ambient Air Quality Standard
For Nitrogen Dioxide: Technical Support Document. California Environmental Protection Agency
Air Resources Board and Office of Environmental Health and Hazard Assessment. Website:
http://www.arb.ca.gov/research/aaqs/no2-rs/no2tech.pdf. Accessed: December 2013.
California Environmental Protection Agency. 1999. Determination of Acute Reference Exposure Levels
for Airborne Toxicants. Office of Environmental Health Hazard Assessment.
Canadian Association of Petroleum Producers. 2013. Upstream Dialogue, The Facts on: Oil Sands.
Available at: http://www.capp.ca/UpstreamDialogue/OilSands/Pages/default.aspx. Accessed
December 2013.
Page 43
Clean Air Strategic Alliance. 2003. Particulate Matter and Ozone Management Framework. Website:
http://webcache.googleusercontent.com/search?q=cache:yr_c5lRwKrgJ:www.casahome.org/Proj
ects/ProjectsAdminController.aspx%3FCommand%3DCore_Download%26EntryId%3D636+&cd=
1&hl=en&ct=clnk&gl=ca. Accessed: December 2013.
Canadian Council of Ministers of the Environment. 2000. Canada-Wide Standards for Particulate Matter
(PM) and Ozone. Accepted November 29, 1999, for endorsement in May 2000.
Devlin, R.B., D.P. Horstman, T.R. Gerrity, S. Becker and M.C. Madden. 1999. Inflammatory response in
humans exposed to 2.0 ppm nitrogen dioxide. Inhalation Toxicology 11: 89-109.
Energy Resources Conservation Board. 2011a. AER Brochure: A Letter from the Chairman of the ERCB.
Available at: http://www.ercb.ca/docs/documents/directives/Directive056_ChairmanLetter.pdf.
Accessed December 2013.
Energy Resources Conservation Board. 2011b. AER Brochure: Understanding Oil and Gas Development
in Alberta. Available at: http://www.aer.ca/documents/directives/Directive056_Brochure.pdf.
Accessed December 2013.
Glass, D. J. 1990. Lexicon of Canadian stratigraphy. Volume 4, Western Canada, Including Eastern
British Columbia, Alberta, Saskatchewan and Southern Manitoba. Canadian Society of Petroleum
Geologists, Calgary, Alberta. 772 pp.
Gong, H. Jr., W.S. Linn, K.W. Clark, K.R. Anderson, M.D. Geller and C. Sioutas. 2005. Respiratory
responses to exposures with fine particulates and nitrogen dioxide in the elderly with and without
COPD. Inhalation Toxicology 17:123-132.
Goodman, J.E., J.K. Chandalia, S. Thakali and M. Seeley. 2009. Meta-analysis of nitrogen dioxide
exposure and airway hyper-responsiveness in asthmatics. Critical Reviews in Toxicology
39(9):719-742.
Hazardous Substances Data Bank. 2010. Sulfur Dioxide. Website: http://toxnet.nlm.nih.gov/cgi-

bin/sis/search/a?dbs+hsdb:@term+@DOCNO+228. Accessed: December 2013.
Hazucha, M.L., J.F. Ginsberg, W.F. McDonnell, E.D. Jr. Haak, R.L. Pimmel, S.A. Salaam, D.E. House
and P.A. Bromberg. 1983. Effects of 0.1 ppm nitrogen dioxide on airways of normal and
asthmatic subjects. Journal of Applied Physiology: Respiratory Environment and Exercise
Physiology 54(3):730-739.
Hesterberg T.W., W.B. Bunn, R.O. McClellan, A.K. Hamade, C.M. Long and P.A. Valberg. 2009. Critical
review of the human data on short-term nitrogen dioxide (NO2) exposures: evidence for NO2
no-effect levels. Critical Reviews in Toxicology 39(9):743-781.
Jorres, R., D. Nowak, F. Grimminger, W. Seeger, M. Oldigs and H. Magnussen. 1995. The effect of 1
ppm nitrogen dioxide on bronchoalveolar lavage cells and inflammatory mediators in normal and
asthmatic subjects. European Respiratory Journal 8: 416-424.
Koenig, J.Q., D.S. Covert, M.S. Morgan, M. Horike, N. Horike, S.G. Marshall and W.E. Pierson. 1985.
Acute effects of 0.12 ppm ozone or 0.12 ppm nitrogen dioxide on pulmonary function in healthy
and asthmatic adolescents. American Review of Respiratory Disease 132:648-651.
Long, J.C.S., J.S. Remer, C.R. Wilson and P.A. Witherspoon. 1982. Porous Medium Equivalents for
Networks of Discontinuous Fractures. Water Resources Research 18(3):645-658.
Morrow, P.E., M.J. Utell, M.A. Bauer, A.M. Smeglin, M.W. Frampton, C. Cox, D.M. Speers and F.R. Gibb.
1992. Pulmonary performance of elderly normal subjects and subjects with chronic obstructive
pulmonary disease exposed to 0.3 ppm nitrogen dioxide. American Review of Respiratory
Diseases 145:291-300.
Page 44
National Institute of Occupational Safety and Health. 1974. Criteria for a Recommended Standard -
Occupational Exposure to Sulfur Dioxide. U.S. Department of Health, Education and Welfare.
Pope C.A. and D.W. Dockery. 2006. Health Effects of Fine Particulate Air Pollution: Lines that Connect.
Critical Review. Journal of Air & Waste Management Association 56:709-742.
Singhal, B.B.S. and R.P. Gupta, 2010. Applied Hydrogeology of Fractured Rocks, 2nd Ed., Springer, New
York. 408 pp.
United States Environmental Protection Agency. 2008. Integrated Science Assessment for Oxides of
Nitrogen – Health Criteria. Second External Review Draft. National Center for Environmental
Assessment-RTP Division, Office of Research and Development, U.S. Environmental Protection
Agency. Research Triangle Park, NC, USA. EPA/600/R-07/093aB.
United States Environmental Protection Agency. 2009. Risk Assessment to Support the Review of the PM
Primary National Ambient Air Quality Standards External Review Draft. EPA 452/P-09-006. US
Environmental Protection Agency Office of Air and Radiation Office of Air Quality Planning and
Standards Health and Environmental Impacts Division Ambient Standards Group Research
Triangle Park, North Carolina. September 2009.
United States Environmental Protection Agency. 2010a. 40 CFR Parts 50 and 58. Primary National
Ambient Air Quality Standards for Nitrogen Dioxide. Final Rule.
United States Environmental Protection Agency. 2010b. Quantitative Health Risk Assessment for
Particulate Matter. EPA-452/R-10-005. US Environmental Protection Agency Office of Air and
Radiation Office of Air Quality Planning and Standards Health and Environmental Impacts
Division Ambient Standards Group Research Triangle Park, North Carolina. June 2010.
Vagaggini, B., P.L. Paggiaro, D. Giannini, A. Di Franco, S. Cianchetti, S. Carnevali, M. Taccola, E. Bacci,
L. Bancalari, F.L. Dente and C. Giuntini. 1996. Effect of short-term NO2 exposure on induced
sputum in normal, asthmatic and COPD subjects. European Respiratory Journal 9:1852-1857.
von Nieding, G. and H.M. Wagner. 1977. Experimental studies on the short-term effect of air pollutants on
man: two hour exposure to NO2, O3 and SO2 alone and in combination. In: Proceedings of the
Fourth International Clean Air Conference (Kasuga S, N. Suzuki, T. Yamada, G. Kimura, K.
Inagaki and K. Onoe eds). Tokyo, Japan: Japanese Union of Air Pollution Prevention
Associations, 5-8.
von Nieding, G., H. M. Wagner, H. Kerkeler, H. Lollgin, W. Fries and A. Bentham. 1979. Controlled
studies of human exposure to single and combined action of N02, 03 and S02. International
Archives of Occupational and Environmental Health 43:195-210.
von Nieding, G., H.M. Wagner, H. Casper, A. Beuthan and U. Smidt. 1980. Effect of experimental and
occupational exposure to NO2 in sensitive and normal subjects. In: Lee, S. D. (ed.). Nitrogen
oxides and their effects on health. Ann Arbor, MI: Ann Arbor Science Publishers, Inc. 315-331 pp.
Westwater Environmental Ltd. 2011. Final Proposed Groundwater Management Plan for Blackrod SAGD
Pilot Project. Prepared for BlackPearl Resources Inc. April 2011.
World Health Organization. 2000. Air Quality Standards – Sulphur Dioxide.
World Health Organization. International Program for Chemical Safety – Environmental Health Criteria 8 –
Sulphur Oxides and Suspended Particulate Matter.
Page 45
World Health Organization. 2000. Air Quality Standards – Sulphur Dioxide.
World Health Organization. International Program for Chemical Safety – Environmental Health Criteria 8 –
Sulphur Oxides and Suspended Particulate Matter.
Page 46
AER SIR APPENDIX A
ABORIGINAL RECORD OF ENGAGEMENT LOG

Stakeholder
Group/Agency Method of Date of Commitments/Follow-Up
Name Contact Name Engagement Engagement Activity Reason for Engagement Issues/Concerns Actions/Comments
Beaver Lake Cree Robert Gillis Letter July 19,2013 BlackPearl sent a Project update letter. BlackPearl would like None. BlackPearl will hold an open
Nation to continue discussions with Beaver Lake Cree Nation. In house to continue discussions.
addition, BlackPearl sent digital copies of the Integrated
Application and the SIR 1 responses. BlackPearl provided a
cheque for the payment of the application fee as per the
BLCN consultation protocol and requested the
commencement of consultation as per the BLCN
consultation process.
Buffalo Lake Métis Stan Delorme Letter July 19,2013 BlackPearl sent a Project update letter. BlackPearl would like None. BlackPearl will hold an open
Settlement to continue discussions with Beaver Lake Cree Nation. house to continue discussions.
BlackPearl also provided a copy of the SIR 1 Responses.
Chipewyan Prairie Chris Heavy Shield Letter July 19, 2013 BlackPearl sent a Project update letter. BlackPearl would like None. BlackPearl will hold an open
Dene First Nation to continue discussions regarding TLU/TEK studies with house to continue discussions.
Chipewyan Prairie Dene First Nation. A copy of the SIR 1
Responses was provided within the package.
Chipewyan Prairie Chris Heavy Shield In person October 17, 2013 BlackPearl attempted to meet with C. Heavy Shield at their None.
Dene First Nation office. He was not available to meet.
Page A-1
Chard Métis Local William Landstrom, Letter May 10,2013 Stakeholder acknowledged receipt of letter dated None.
No. 214 and Chard Raoul Montgrand March 25, 2013. Stakeholder provided a copy of the
Métis Dene Inc. Certificate of Incorporation (dated March 12, 2013) of the
(Chard Métis) Chard Metis Society.
Chard Métis Local Raoul Montgrand c/o Letter July 19,2013 BlackPearl sent a Project update letter. BlackPearl would None. BlackPearl will hold an open
No. 214 and Chard William Landstrom like to arrange a meeting with Chard Métis as well as house to continue discussions.
Métis Dene Inc. W. Landstrom of the Métis Nation of Alberta to discuss the
(Chard Métis) concerns of the Chard Métis Local No. 214 and the Chard
Métis Dene Inc. as well as provide an introduction and
overview of the scope of the Project. BlackPearl included a
digital copy of the application.
Chard Métis Local L. Douglas Rae, Yoki Ho Letter August 07,2013 Stakeholder requested a meeting with BlackPearl for August None.
No. 214 and Chard 14, 2013.
Métis Dene Inc.
(Chard Métis)
Chard Métis Local Yoki Ho Email August 13,2013 BlackPearl sent confirmation of attendance at meeting on None.
No. 214 and Chard August 14, 2013. BlackPearl requested a brief agenda for
Métis Dene Inc. this meeting.
(Chard Métis)
Chard Métis Local L. Douglas Rae In person August 14,2013 Mr. Rae represents the Chard Métis. Chard wants to have None.
No. 214 and Chard their members employed and/or services used for
Métis Dene Inc. BlackPearl’s Project. Most of membership have limited
(Chard Métis) education and training would be required stated that it would
be a good thing to have the Chard Métis like BlackPearl
rather than the opposite. Their membership includes Métis
and First Nations that are not Local but do not have an
association with another membership/band.
BlackPearl should expect a package which will contain a co-
operation and benefits agreement. It is up to BlackPearl if
they wish to sign it.
Stakeholder
Chard Métis Local L. Douglas Rae, yoki Ho Email September 13,2013 Email received from legal counsel for Chard Métis containing None.
No. 214 and Chard the draft cooperation and benefits agreement and draft
Métis Dene Inc. appendix. If BlackPearl has any questions regarding the
(Chard Métis) agreement Doug Rae should be contacted.
Chard Métis Local Ian Trewinnard Telephone November 13, 2013 BlackPearl requested to meet with I. Trewinnard to introduce None. Meeting confirmed for November
No. 214 and Chard the Project and discuss any feedback. Discussed briefly 14, 2013.
Métis Dene Inc. BlackPearl’s policy for employment and procurement of
(Chard Métis) services. A meeting was set-up for November 14, 2013.
Chard Métis Local Ian Trewinnard In Person November 14, 2013 BlackPearl met with I. Trewinnard and provided a brief None. Meeting to be held in December
No. 214 and Chard overview of the Project and a consultation binder containing 2013.
Métis Dene Inc. an electronic copy of the EIA application and the SIR 1
(Chard Métis) responses as well as historical air photo mosaics from 1949
to 2011 and a plain language information package. Advised
I. Trewinnard that BlackPearl will be hosting another open
house on December 11, 2013. They discussed holding
another meeting at this time.
Chard Métis Local Ian Trewinnard Telephone December 5, 2013 I. Trewinnard was unable to attend the meeting on None.
No. 214 and Chard December 11, 2013. They discussed the anticipated
Métis Dene Inc. construction date and requested that BlackPearl keep Chard
(Chard Métis) Métis in mind for employment opportunities.
Chipewyan Prairie Chris Heavyshield In person October 17,2013 BlackPearl made a contact attempt to provide Project None.
Dene First Nation update.
Page A-2
Chipewyan Prairie Chris Heavyshield Email December 4, 2013 BlackPearl provided a copy of the open house advertisement
Dene First Nation and requested if they could forward the information to any of
their community who would be interested in attending.
Fort McMurray First W.L. (Bill) McElhanney Email June 07,2013 BlackPearl received a copy of the Statement of Concern. None.
Nation
Fort McMurray First Nicholle Louvelle Letter July 19,2013 BlackPearl sent a Project update letter and thanked the None. BlackPearl will hold an open
Nation stakeholder for their involvement in the Project to date. house to continue discussions.
BlackPearl would like to arrange a meeting with stakeholder
to discuss the Project. A digital copy of the application was
provided. BlackPearl acknowledged they received the
stakeholder's Statement of Concern and would like to meet
to discuss the issues raised in the Statement of Concern.
Fort McMurray First Harry Cheecham Telephone October 15,2013 BlackPearl followed up and requested to continue None.
Nation consultation on the Project. Mr. Cheecham advised they
were undergoing internal restructuring and this required all
consultation activities to stop.
Fort McMurray First Harry Cheecham, In Person October 17,2013 BlackPearl attempted to meet stakeholder at their office. None.
Nation Nicholle Louvelle They were not available to meet.
Fort McMurray First Harry Cheecham Telephone October 30,2013 BlackPearl left a voicemail requesting a phone call back to None.
Nation continue discussions.
Fort McMurray First Harry Cheecham Telephone November 7, 2013 BlackPearl contacted H. Cheecham and requested a
Nation meeting to discuss the Project and discuss items in the
Statement of Concern.
Fort McMurray First Harry Cheecham Telephone November 7, 2013 Discussion regarding an appropriate meeting time. Meeting confirmed for November
Nation 13, 2013.
Fort McMurray First Harry Cheecham, In Person November 13, 2013 BlackPearl met with H. Cheecham to discuss the Project.
Nation Nicholle Louvelle BlackPearl provided an overview of the Project, discussed
the Statement of Concerns and capacity funding. BlackPearl
requested more information on their concerns. BlackPearl
advised that they would be holding another open house on
December 11, 2013.
Stakeholder
Fort McMurray First Harry Cheecham Email November 25, 2013 Email from H. Cheecham requesting G. Currie’s contact None.
Nation information. BlackPearl provided H. Cheecham with the
information.
Fort McMurray First Harry Cheecham, Email November 26, 2013 Discussed beginning the screening process. Fort McMurray None. BlackPearl will compile a
Nation Nicholle Louvelle First Nation contracts Dillion Consultants. They will provide a response to their information
list of the information required to complete the screening. request and should have it to
The list provides proponents with a summary of the them by November29, 2013.
information required by FMFN in order to conduct a TK/TLU
screening.
Fort McMurray First Harry Cheecham Email December 4, 2013 BlackPearl provided a copy of the open house advertisement
Nation and requested if they could forward the information to any of
their community who would be interested in attending.
Heart Lake First John Fleming Letter July 19,2013 BlackPearl sent a Project update letter. BlackPearl would None. BlackPearl will hold an open
Nation like to arrange a meeting to discuss the TEK/TLU studies house to continue discussions.
and continue the consultation process.
Heart Lake First n/a Telephone October 11,2013 BlackPearl contacted the main office and was informed None.
Nation Mr. Fleming no longer was employed by Heart Lake First
Nation.
Heart Lake First Cameron Knutson Telephone October 11,2013 BlackPearl left a voicemail regarding the status of the None.
Nation TEK/TLU report and to continue consultation.
Heart Lake First John Fleming Telephone October 15,2013 BlackPearl left a voicemail regarding the status of the None.
Nation TEK/TLU report and to continue consultation.
Page A-3
Heart Lake First Cameron Knutson, John Telephone October 15,2013 BlackPearl learned John Fleming was transitioning to None.
Nation Fleming another job and wanted to finish up consultation. Heart Lake
First Nation would contact BlackPearl to set up a meeting to
review the TEK/TLU report.
Heart Lake First Cameron Knutson Telephone October 22,2013 BlackPearl left a voicemail requesting the status of the None.
Nation TEK/TUS report and to continue the consultation process.
Heart Lake First John Fleming Telephone October 25,2013 BlackPearl left a voicemail requesting the status of the None.
Nation TEK/TUS report. They expressed interest in reviewing the
report and continuing the consultation process.
Heart Lake First Cameron Knutson Telephone October 29,2013 BlackPearl left a message for Cameron requesting an None.
Nation update on when BlackPearl will receive the TEK/TUS report.
BlackPearl acknowledged Mr. Fleming was leaving his
position at the end of the month and inquired to his
replacement so they could continue consultation.
Heart Lake First John Fleming Telephone October 30,2013 BlackPearl contacted the main office and was unable to None.
Nation leave a voicemail as the mail box was full. A voicemail was
left for John Fleming's cell phone requesting information on
the status of the TEK/TUS report and to continue with
consultation.
Heart Lake First Reception Telephone November 7, 2013 BlackPearl followed up and requested a meeting. The
Nation receptionist said the office was closed until November 12,
2013 and C. Knutson was replacing J. Fleming.
Heart Lake First Cameron Knutson Email November 12, 2013 Discussion regarding an appropriate meeting time and place.
Nation November 12, 2013
November 14, 2013
Heart Lake First Cameron Knutson, John Email November 25, 2013 C. Knutson sent an email and would like to meet in Calgary
Nation Fleming November 26, 2013 on November 29, 2013. BlackPearl confirmed they would be
available to meet at 2 pm at their office.
Heart Lake First Cameron Knutson, John Email November 28, 2013 C. Knutson sent email to cancel meeting as J. Fleming was
Nation Fleming unable to attend.
Stakeholder
Heart Lake First Cameron Knutson Email December 4, 2013 Email sent to HLFN with a copy of the advertisement for the
Nation open house on December 11. Requested if he could inform
any members of the HLFN community that would like to
know more about the Project.
Kikino Métis General Delivery Letter July 19, 2013 BlackPearl mailed out a Project update letter to stakeholder None. BlackPearl will hold an open
Settlement and will be hosting an open house to continue discussions. house to continue discussions.
Métis Local # 1949 Jack Quintal April 10,2013 J. Quintal would like to meet before end of April as he is None.
Owl River going on holidays in early May.
Métis Local # 1949 Paul Clyburn Letter April 30,2013 Letter from Jack Quintal providing overview of telephone None.
Owl River conversation on April 12, 2013. BlackPearl and Métis Local
# 1949 Owl River will be organizing a meeting within the
following weeks to review a draft of the traditional land use
and environmental knowledge study. Métis Local # 1949 Owl
River would like to have as many of their board members
present as possible when reviewing the report. The meeting
can be held in Lac La Biche or Calgary.
Métis Local # 1949 Paul Clyburn Email April 30,2013 BlackPearl acknowledged Mr. Clyburn's previous email and None.
Owl River would look into dates for meeting to discuss the Project.
Métis Local # 1949 Paul Clyburn Telephone April 30,2013 Stakeholder discussed meeting in mid to late May to review None.
Owl River the TEK/TLU report.
Métis Local # 1949 Jack Quintal Letter July 19,2013 BlackPearl mailed out a Project update letter to stakeholder None. BlackPearl will hold an open
Page A-4
Owl River with information on Project modifications, regulatory process house to continue discussions.
and any additional feedback.
Métis Local # 1949 Paul Clyburn Email May 13,2013 Formal request for funding sponsorship for a trapper’s None.
Owl River education course.
Métis Local # 1949 Paul Clyburn Email May 30,2013 Email for Corporate registration for the 3rd annual Métis None.
Owl River Local # 1949 Owl River golf tournament and fundraiser.
Métis Local # 1949 Paul Clyburn Email June 24,2013 Received from Métis Local # 1949 Owl River thanking None.
Owl River sponsors of the annual Métis Local # 1949 Owl River Golf
Tournament and Scholarship fundraiser.
Métis Local # 1949 Jack Quintal, Paul Letter October 06,2013 Bulk letter received from Jack Quintel regarding donation None.
Owl River Clyburn requests for the Metis Local 1949 annual Christmas Gala on
Nov 30, 2013. Requested a monetary donation or donation
of an item for the event.
Métis Local # 1949 Paul Clyburn Email October 15,2013 Stakeholder inquired if BlackPearl had any availability to None.
Owl River meet to discuss the TEK/TLU report.
Métis Local # 1949 Jack Quintal Email October 21,2013 BlackPearl requested a list of available dates to arrange a None.
Owl River meeting in Lac La Biche regarding reviewing the TKUS
report that the stakeholder had prepared for the Project.
Métis Local # 1949 Paul Clyburn Email October 22, 2013 Stakeholder confirmed they were available to meet in Lac La None.
Owl River Biche on October 28, 2013.
Métis Local # 1949 Paul Clyburn Email October 25, 2013 BlackPearl requested alternate dates to meet regarding the None.
Owl River TEK/TLU studies.
Métis Local # 1949 Paul Clyburn Email October 25, 2013 Stakeholder has availability to meet towards the end of None.
Owl River November and would inquire if Mr. Quintal would be able to
meet as well.
Métis Local # 1949 Paul Clyburn Email October 28, 2013 Stakeholder inquired if BlackPearl had any availability to None.
Owl River meet in November and suggested meeting in Lac LA Biche,
Alberta.
Stakeholder
Métis Local # 1949 Paul Clyburn Email November 4, 2013 Discussion regarding an appropriate meeting time. None. Meeting confirmed for November
Owl River Email November 7, 2013 Stakeholder was unable to meet on November 8 or 15 but 14, 2013.
Telephone November 7, 2013 were available to meet on November 14, 2013 and inquired if
Email November 12, 2013 BlackPearl was available.
Métis Local # 1949 Paul Clyburn In Person November 14, 2013 BlackPearl met with P. Clyburn and Jack Quintal. They BlackPearl will send historical air
Owl River Jack Quintal discussed the TLU report and BlackPearl was provided a photo mosaics to assist Métis
copy. P. Clyburn said they did not have any concerns Local # 1949 Owl River with their
regarding the Project impacting any known historical studies
resources, however they inquired if BPR would be flexible if
areas of concern are identified prior to commencement of
construction. BlackPearl will conduct detailed site
assessments for all developments for the Project. This will
assist with determining if any cultural resources and/or land
uses will be impacted. BlackPearl advised that they would be
holding another open house on December 11, 2013.
Métis Local # 1949 Paul Clyburn Email December 4, 2013 BlackPearl provided a copy of the open house advertisement
Owl River Jack Quintal and requested if they could forward the information to any of
their membership who would be interested in attending.
Métis Local #1909 Melina Scoville Letter July 19, 2013 BlackPearl mailed out a Project update letter to stakeholder None.
Lakeland with information on Project modifications, regulatory process
and any additional feedback.
Métis Local #1909 Melina Scoville Email October 02, 2013 Stakeholder sent an email to BlackPearl inquiring about None.
Page A-5
Lakeland meeting to discuss the MTEK report and concerns identified

within the report.
Métis Local #1909 Melina Scoville In person October 18, 2013 BlackPearl met with stakeholder and discussed opportunities None.
Lakeland for employment and concerns regarding the process. They
reviewed the list of concerns outlined in the TEK report.
Métis Local # 1909 Melina Scoville Email December 4, 2013 BlackPearl provided a copy of the open house advertisement
Lakeland and requested if they could forward the information to any of
their membership who would be interested in attending.
Métis Local #2010 Darryl Shott Letter July 19, 2013 BlackPearl mailed out a Project update letter to stakeholder None. BlackPearl will hold an open
Athabasca Landing and will be hosting an open house to continue discussions. house to continue discussions.
Métis Local # 2010 Darrly Shott Email December 4, 2013 Email sent to Métis Local # 2010 informing them as to the
Athabasca Landing Open House on December 11, 2013 and requesting that any
members of the local be provided the information if they
would like to know more about the Project or have
questions/concerns.
Alberta Métis Darryl Shott Email December 8, 2013 Response to an email sent by BlackPearl regarding the open
Federation house on December 11, 2013. Provided an update as to the
MJC proceedings and the current status of the Métis Local
2010. He is planning to attend the Open House as the
Provincial Leader of the Alberta Métis Federation Provincial
Membership.
Alberta Métis Darryl Shott Email December 11, 2013 Provided a copy of the results of the MJC decision regarding
Federation the Métis Local 2010. Stated that he is not the local council
anymore, however that Kenton Klien and his associates are
not either. Also advised that Dianne Scoville has been
suspended from the office of the MNAA Region 1. Darryl
does represent the Alberta Métis Federation.
Alberta Métis Darryl Shott In Person December 11, 2013 D. Shott attended the open house event held by BlackPearl. None.
Federation Discussed the Project with BlackPearl.
Stakeholder
Métis Nation of Diane Scoville Letter July 19, 2013 BlackPearl mailed out a Project update letter to stakeholder None. BlackPearl will hold an open
Alberta Region 1 and will be hosting an open house to continue discussions. house to continue discussions.
Métis Nation of William Landstrom Letter July 19, 2013 BlackPearl mailed out a Project update letter to stakeholder None. BlackPearl will hold an open
Alberta Region 1 and will be hosting an open house to continue discussions. house to continue discussions.
Page A-6
AESRD SIR 2 RESPONSES
Blackrod Commercial SAGD Project AESRD SIR 2 Responses
TABLE OF CONTENTS
Page
1.0 GENERAL ........................................................................................................................................ 1
1.1 Emergency Response Plan ................................................................................................ 1
1.2 Transportation ..................................................................................................................... 3
2.0 AIR ................................................................................................................................................... 9
2.1 Dispersion Modelling ........................................................................................................... 9
3.0 WATER .......................................................................................................................................... 12
3.1 Water Management........................................................................................................... 12
3.2 Hydrogeology .................................................................................................................... 14
3.3 Hydrology .......................................................................................................................... 42
3.4 Surface Water Quality ....................................................................................................... 43
3.5 Aquatics ............................................................................................................................ 45
4.0 TERRESTRIAL .............................................................................................................................. 55
4.1 Conservation and Reclamation ......................................................................................... 55
4.2 Wildlife ............................................................................................................................... 58
5.0 HEALTH ......................................................................................................................................... 75
6.0 APPROVALS ................................................................................................................................. 76
6.1 Environmental Protection and Enhancement Act ............................................................. 76
7.0 ERRATA ....................................................................................................................................... 129
8.0 REFERENCES............................................................................................................................. 131
LIST OF APPENDICES
AESRD SIR Appendix A Updated Conservation And Reclamation Section ............................................A-1
LIST OF FIGURES
Figure 2-1 Existing Water Crossing of LOC 819 .................................................................................. 4
Figure 8-1 MFS Core Locations ......................................................................................................... 16
Figure 8-2 MFS Caprock Core 1AA/07-36-076-18W4/00 .................................................................. 17
Figure 10-1 Drawdown and Residual Drawdown in MW LGR 3-36 ..................................................... 21
Figure 10-2 Drawdown and Residual Drawdown in MW LGR 14-25 ................................................... 22
Figure 11-1 Watercourses with Defined Channel and 100 m Buffer .................................................... 24
Figure 25-1 Area of Potential Pipeline Corridor .................................................................................... 47
Figure 32-1 Soil Stockpile, Aggregate and Borrow Material Source Locations ................................... 56
Figure 36-1 Completed and Conceptual Seismic Programs ................................................................ 60
Figure 36-2 Linear Density within the RSA for Baseline and Application Case ................................... 64
Figure 36-3 Estimated Area of Linear Disturbance .............................................................................. 65
Figure 48-1 Central Processing Facility – Phase 1 Plot Plan ............................................................... 79
Figure 50-1 1-Hour NO2 Concentrations within the RSA (Existing Case) ............................................ 84
Figure 50-2 Annual NO2 Concentrations within the RSA (Existing Case) ............................................ 85
Figure 50-3 1-Hour SO2 Concentrations within the RSA (Existing Case) ............................................ 86
Figure 50-4 24-Hour SO2 Concentrations within the RSA (Existing Case) .......................................... 87
Figure 50-5 Annual SO2 Concentrations within the RSA (Existing Case) ............................................ 88
Figure 50-6 1-Hour PM2.5 Concentrations within the RSA (Existing Case) .......................................... 89
Figure 50-7 24-Hour PM2.5 Concentrations within the RSA (Existing Case) ........................................ 90
Figure 50-8 Annual PM2.5 Concentrations within the RSA (Existing Case) .......................................... 91
Figure 50-9 1-Hour NO2 Concentrations within the RSA (Base Case) ................................................ 92
Figure 50-10 Annual NO2 Concentrations within the RSA (Base Case) ................................................ 93
Figure 50-11 1-Hour SO2 Concentrations within the RSA (Base Case) ................................................ 94
Figure 50-12 24-Hour SO2 Concentrations within the RSA (Base Case) .............................................. 95
Page i
Figure 50-13 Annual SO2 Concentrations within the RSA (Base Case) ................................................ 96
Figure 50-14 1-Hour PM2.5 Concentrations within the RSA (Base Case) .............................................. 97
Figure 50-15 24-Hour PM2.5 Concentrations within the RSA (Base Case) ............................................ 98
Figure 50-16 Annual PM2.5 Concentrations within the RSA (Base Case) .............................................. 99
Figure 50-17 1-Hour NO2 Concentrations within the RSA (Application Case) ..................................... 100
Figure 50-18 Annual NO2 Concentrations within the RSA (Application Case) ..................................... 101
Figure 50-19 1-Hour SO2 Concentrations within the RSA (Application Case) ..................................... 102
Figure 50-20 24-Hour SO2 Concentrations within the RSA (Application Case) ................................... 103
Figure 50-21 Annual SO2 Concentrations within the RSA (Application Case) ..................................... 104
Figure 50-22 1-Hour PM2.5 Concentrations within the RSA (Application Case) ................................... 105
Figure 50-23 24-Hour PM2.5 Concentrations within the RSA (Application Case) ................................. 106
Figure 50-24 Annual PM2.5 Concentrations within the RSA (Application Case) ................................... 107
Figure 50-25 1-Hour NO2 Concentrations within the RSA (Future Case) ............................................ 108
Figure 50-26 Annual NO2 Concentrations within the RSA (Future Case) ............................................ 109
Figure 50-27 1-Hour SO2 Concentrations within the RSA (Future Case) ............................................ 110
Figure 50-28 24-Hour SO2 Concentrations within the RSA (Future Case) .......................................... 111
Figure 50-29 Annual SO2 Concentrations within the RSA (Future Case) ............................................ 112
Figure 50-30 1-Hour PM2.5 Concentrations within the RSA (Future Case) .......................................... 113
Figure 50-31 24-Hour PM2.5 Concentrations within the RSA (Future Case) ........................................ 114
Figure 50-32 Annual PM2.5 Concentrations within the RSA (Future Case) .......................................... 115
Figure 50-33 1-Hour NO2 Concentrations within the RSA (Project Case) ........................................... 116
Figure 50-34 Annual NO2 Concentrations within the RSA (Project Case) ........................................... 117
Figure 50-35 1-Hour SO2 Concentrations within the RSA (Project Case) ........................................... 118
Figure 50-36 24-Hour SO2 Concentrations within the RSA (Project Case) ......................................... 119
Figure 50-37 Annual SO2 Concentrations within the RSA (Project Case) ........................................... 120
Figure 50-38 1-Hour PM2.5 Concentrations within the RSA (Project Case) ......................................... 121
Figure 50-39 24-Hour PM2.5 Concentrations within the RSA (Project Case) ....................................... 122
Figure 50-40 Annual PM2.5 Concentrations within the RSA (Project Case) ......................................... 123
Figure 50-41 30-Day SO2 Concentrations within the RSA (Existing Case) ......................................... 124
Figure 50-42 30-Day SO2 Concentrations within the RSA (Base Case) .............................................. 125
Figure 50-43 30-Day SO2 Concentrations within the RSA (Application Case) .................................... 126
Figure 50-44 30-Day SO2 Concentrations within the RSA (Future Case) ............................................ 127
Figure 50-45 30-Day SO2 Concentrations within the RSA (Project Case) ........................................... 128
LIST OF TABLES
Table 2-1 Summary of Watercourse Crossings Along the Existing Blackpearl LOC 819 ................... 6
Table 7-1 Estimated Maximum Dust Control Water Demand for Summer (June to
September) Construction and Operation .......................................................................... 12
Table 7-2 Assumed Water Volumes for Dust Control ....................................................................... 13
Table 10-1 Estimates of Hydraulic Parameters for the Grand Rapids ‘B’ Aquifer .............................. 20
Table 12-1 Measured Ground Heave at SAGD Sites in Alberta ......................................................... 26
Table 20-1 Groundwater Level ............................................................................................................ 39
Table 21-1 Estimates of Hydraulic Conductivity for Shallow Surficial Deposits at the Pilot
CPF ................................................................................................................................... 41
Table 36-1 Estimated Change in Area of Exploration (Seismic) Disturbance .................................... 61
Table 36-2 Estimated Change in Linear Disturbance Density With Conceptual Future
Seismic .............................................................................................................................. 62
Table 49-1 Assumed Gas Composition for the Project (Mole Percent) .............................................. 81
Table 49-2 Gas Composition (Mole Fraction) From the Flash Separator at the Blackpearl
Blackrod Pilot Plant From September 2011 to November 2012 ....................................... 82
st
Table 51-1 Comparison of 30-Day (1 Highest) SO2 Concentrations ............................................... 129
Page ii
ACRONYM LIST
Definition/Acronym Full Name

AAAQO Alberta Ambient Air Quality Objectives
AENV Alberta Environment
AER Alberta Energy Regulator
AESRD Alberta Environment and Sustainable Resource Development
ARA Application Resource Area
BlackPearl BlackPearl Resources Incorporated
COSEWIC Committee on the Status of Endangered Wildlife in Canada
CPF Central Processing Facility
DFO Department of Fisheries and Oceans
EIA Environmental Impact Assessment
EPEA Environmental Protection and Enhancement Act
ERCB Energy Resources Conservation Board
LSA Local Study Area
MEM Millennium EMS Solutions Limited
MFS Maximum Flooding Shale
PDA Pre-development site assessment
PDC Planned Development Case
PM Particulate Matter
RAP Restricted activity period
RSA Regional Study Area
SAGD Steam-assisted Gravity Drainage
SAOS Southern Athabasca Oil Sands
SIR Supplemental Information Request
Page iii
1.0 GENERAL
1.1 Emergency Response Plan
1. ESRD SIR 1 Responses, Section 1.2, SIR 3, Response b, Page 5
BlackPearl indicates a wellhead failure on a producer site would require, due to the pressures
of the wellbore, between 2-3 days to depressurize the wellbore before control measures can
[sic] be implemented. BlackPearl indicates further that Design features of the wellpad and the
utilization of spill response equipment would mitigate and control the release of hydrocarbon off
site…
a. Given the pressurized nature of the wellbore, discuss whether such a release is likely
to extend beyond the boundaries of the well pad.
Response:
A release at a steam injection wellhead would have the potential to extend beyond the boundaries of the
well pad since steam flows through the wellhead at high pressures. Any release beyond the boundaries of
the well pad would only occur during the initial release of pressure from the wellbore and is anticipated to
consist of boiler grade steam. Due to the nature of the fluid (boiler grade steam) it is anticipated that once
the initial pressure is released from the wellbore and the feed source is isolated, the steam within the
wellbore would condense into a liquid state. Without a source of pressure, the remaining fluid within the
wellbore would remain isolated within the wellbore.
A release at the production wellhead is not anticipated to extend beyond the designed containment
measures on the well pad. The production well’s subsurface pumps supply the pressure needed to move
fluid to surface. It is unlikely the pumping pressures would be sufficient to result in a release of fluid that
would extend beyond the well pad boundaries.
1. b. If not, describe why the release would be unlikely to extend beyond the boundaries of
the well pad.
Response:
Refer to the response for Round 2 Alberta Environment and Sustainable Resource Development
[AESRD] Supplemental Information Request [SIR] 1a above. Additionally, the current design of the well
pads incorporates the construction of a minimum 2 m berm around the perimeter of the production pad. In
addition to the berm, a dyke is to be constructed on the well pad for the management of surface water.
This dyke system would also assist with the containment of any potential release of emulsion from the
producer wellbore in the event of an equipment failure.
1. c. If so, provide further details on how such a release would be managed.
Response:
In the event of a release of this nature the following processes would be implemented to manage the
incident:
1. Immediate isolation of the feed lines into the wellbore to shut off the source of pressurized
steam.
Page 1
2. Evacuation of the pad site and implementation of BlackPearl’s Emergency Response Plan and
spill containment measures. Notifications will be made to all relevant regulatory bodies as well
as spill response services (Area Spill Co-op).
3. Mobilize equipment to the site to assist with the containment of any surface fluids at the site.
Vacuum trucks will be onsite to remove any free fluids on surface on both the well pad and
adjacent impacted lands.
4. Once the initial pressure release from the injector well has decreased sufficiently to allow for
the safety of personnel, a service rig will be mobilized to commence with assessment and
repairs to the subject wellbore.
5. Delineate the areal extent of the land impacted by the initial release of steam from the wellbore
and commence with assessment, remedial measures and monitoring activities.
1. d. Describe mitigation measures to be put in place to limit the areal extent of such a
release as the wellbore is being depressurized.
Response:
For a steam injection wellhead, the design of the injector wellbore and feed steam lines will incorporate
sufficient isolation valves that would be engaged immediately upon discovery of an issue with the
wellbore. The isolation of the feed steam lines into the injector well would shut off the source of pressure
and feed steam into the wellbore; therefore the initial release from the injector wellbore would consist of a
short-term release of steam and vapour. As the residual pressure and temperature within the wellbore
declines any released fluid from the wellbore would consist of water, which would be contained within the
boundaries of the well pad.
In the event of a production wellhead release, the subsurface pumps would be automatically shut down,
thereby limiting the ability of the release to extend beyond the containment boundary.
Also, as noted in Round 2 AESRD SIR 1b above, well pads will be bermed and diked to limit the aerial
extent of a release.
1. e. Describe a conceptual monitoring plan to be initiated in the event of such a release to

monitor and track mitigation and spill management effectiveness. Ensure both
terrestrial and aquatic monitoring and mitigation are considered.
Response:
In the event of a release extending beyond the boundaries of a well pad, BlackPearl would report and
manage the incident, as required, in a timely manner. A monitoring and remediation program would be
created to delineate the extent of the release, as well as monitor the effectiveness of the remedial actions.
The monitoring program will consist of site inspections to collect information and samples as required.
Data collected may include, but not be limited to soil samples, review of vegetation health and water
quality, depending on the location and extent of the release.
The monitoring plan that is prepared will be aligned with provincial standards and discussed prior to
implementation with the appropriate regulatory agency. The plan will vary depending on type of release,
volume, location and area affected. The plan will include a detailed sampling design (study plots/control
plots), methods, sampling and reporting schedule, and QA/QC protocols.
Soils will be sampled and analyzed to confirm any potential soil quality issues. Analytical parameters
might include: texture and structure; soil reaction (pH); electrical conductivity (EC); sodium adsorption
ratio (SAR); and macronutrient concentrations.
Page 2
Vegetation will be assessed and parameters might include: vegetation species; quantity; health; and
vigour.
Water quality will be sampled, and if required, habitat assessments related to fish will be completed.
Remedial measures will be implemented as required, and ongoing monitoring will be conducted to
measure the effectiveness of the remedial measures.
BlackPearl’s incident investigation process will be implemented and identify the root causes of the
incident to assist with the identification of corrective measures to mitigate the recurrence of a similar
release. The corrective measures identified through the incident investigation process will be documented
and implemented at sites where similar conditions may exist as a preventative measure.
1.2 Transportation
2. ESRD SIR 1 Responses, Section 1.4, SIR 8, Page 12
BlackPearl indicates, with respect to upgrading LOC 819 to accommodate Project traffic, that
existing culverts will be re-assessed and replaced as required.
a. Identify and map any LOC 819 culvert crossings currently located on fish-bearing or
potentially fish-bearing watercourses.
Response:
Existing watercourse and drainage crossings located along LOC 819 are presented in Figure 2-1.
Page 3
20 21 22 23 24 19 20 21 22 23 24 19 20 21 22
19
17 16 15 14 13 18 17 16 15 14 13 18 17 16 15
18
T 77
T 77
7 8 9 10 11 12 7 8 9 10 11 12 7 8 9 10
6 5 4 3 2 1 6 5 4 3 2 1 6 5 4 3
31 32 33 34 35 36 31 32 33 34 35 36 31 32 33 34
D28 D27 D24
30 26 25 30 29 28 27 26 25 30 29 28 27
29 28 27
D26 D25 D23
WC17
19 20 21 22 23 24 19 20 21 22 23 24 19 20 21 22
T 76
T 76
D22
18 17 16 15 14 13 18 17 16 15 14 13 18 17 16 15
D21
D20
WC16
T 76
7 8 9 10 11 12 7 8 9 10 11 12 7 8 9 10
WC15
D19
D18
3 2 1 6 5
WC14 4 3 2 1 6 5 4 3
6 5 4
WC13
T 75 T 76
D17
WC12
D16
31 32 33 34 35 36 31 32 33 34 35 36 31 32 33 34
D15
WC11
T 75
D14 WC10
30 29 28 27 26 25 30 29 28 27
30 29 28 27 26 25
T 75
WC9
D13 D12
19 20 21 22 23 24 19 20 21 22 23 24 19 20 21 22
WC8
T 75
16 15 14 13 18 17 16 15 14 13 18 17 16 15
18 17
D11
T 75
7 8 9 10 11 12 7 8 9 10 11 12 7 8 9 10
WC6
WC7
WC5
3 2 1 6 5 4 3 2 1 6 5 4 3
6 5 4
D10
36 31 32 33 34 35 36 31 32 33 34 35 36 31 32 33
D9
25 30 29 28 27 26 25 30 29 28 27 26 25 30 29 28
D8
WC4
24 19 20 21 22 23 24 19 20 21 22 D7 23 24 19 20 21
D5 63
T 74
T 74
63
D6
13 18 17 16 15 14 13 18 17 16 15 14 13 18 63 17 16
WC3
WC2
D4 63
WC1 63
12 7 8 9 10 11 12 7 8 9 10 11 12 7 8 9
D3
D2
D1
1 6 5 4 3 2 1 6 5 4 3 2 1 6 5 4
R 19 W4M R 17 W4M
Project Footprint Phase 3B Construction Camp Site 63 Highway

FIGURE 2-1
Phase 1 Borrow Pit Permanent Operations Existing LOC 819
Camp Site EXISTING WATER CROSSINGS OF LOC 819
AESRD SIR 2 RESPONSES -
Phase 2 Sump Site Watercourse Crossing Watercourse BLACKPEARL RESOURCES INC.
PROPOSED BLACKROD
Phase 3A Log Deck Drainage Crossing Waterbody
t8344_Fig21_CEAA_SIRs_Rev01.mxd
UTM Zone 12N: SCALE: 1:100,000

Date of Imagery: July 2012 SPOT5 ©2013 CNES, Licensed by BlackBridge Geomatics Corp, www.blackbridge.com km
Project Area: Altus Geomatics 2012; Hydrography: AltaLIS 2011c.; Road: IHS Inc., 2011c.
0 0.5 1 1.5 2
DECEMBER 2013
Although there is no reason to believe that there are any errors associated with the data used to generate this product
or in the product itself, users of these data are advised that errors in the data may be present.
2. b. Summarize existing fisheries and aquatics data associated with these crossing sites/
watersheds.
Response:
A total of 17 watercourses and 28 drainages (i.e., no defined bed and bank) are crossed by LOC 819
(Figure 2-1). LOC 819 is located within the Athabasca River Basin and includes crossings on Duncan
Creek, twelve of its unnamed tributaries as well as four unnamed direct tributaries to the Athabasca River
(Figure 2-1).
Duncan Creek is a tributary of the Athabasca River, flowing generally south from its headwaters for
approximately 50 km where it joins the Athabasca River. An existing bridge is present at the Duncan
Creek crossing. Brook stickleback are the only fish species previously documented within the Duncan
Creek watershed. Within the unnamed tributaries to the Athabasca River, brook stickleback have also
been previously documented in the vicinity of LOC 819. Longnose sucker have been previously
documented in one of the unnamed tributaries to the Athabasca River, approximately 10 km downstream
from the LOC 819 crossing. No fish species listed by the Committee on the Status of Endangered Wildlife
in Canada (COSEWIC) are known to occur at or near the existing crossings along LOC 819
(COSEWIC 2013).
Class and restricted activity periods (RAP) for all watercourses crossed by LOC 819 were determined as
specified in the Code of Practice for Watercourse Crossings (Alberta Government 2013). All watercourses
crossed by LOC 819 are Class C watercourses with a RAP from April 16 to July 15.
Reconnaissance of all existing access crossing locations present along LOC 819 was conducted by a
Qualified Aquatics Environmental Specialist in the fall 2010 or spring 2012 to verify flow regime, channel
morphology, water quality characteristics, fish habitat potential and existing crossing structures. A
summary of site-specific fisheries and aquatics data for watercourse crossings identified along LOC 819
is presented in Table 2-1.
Page 5
BlackPearl Resources Inc December 2013
TABLE 2-1
SUMMARY OF WATERCOURSE CROSSINGS ALONG THE EXISTING BLACKPEARL LOC 819
Substrate Fish Species Captured or Beaver

Legal Location (W4M), Watercourse Class Composition Observed During Open Water Activity
UTM Co-ordinates and Restricted Activity Mean Channel Water Quality (Dominant / Assessment Present
Site No.1 Name (NAD 83, Zone 12 U) Period (RAP)2 Morphology (m)3 Parameters Subdominant) Flow Regime Riparian Composition (Previously Documented)4 (Yes/No) Comments
WC 1 Unnamed tributary to Duncan 4-7-74-16 Unmapped Class C Bankfull Width: 25.4 m Temperature: 6°C Fine / n/a Beaver Dam Width: > 50 m Brook stickleback captured (No fish Yes Crossing located within a series of beaver dams.
Creek E: 407111 (April 16 – July 15) Bankfull Depth: 0.9 m pH: n /r Complex Vegetation: grasses and previously documented)
N: 6139320 Wetted Width: 40.9 m DO: 7.1 mg/L shrubs
Water Depth: 0.8 m Conductivity: 195
Stream Gradient: 0-1% Turbidity: clear
Sinuosity: 1
WC 2 Unnamed tributary to Duncan 11-12-74-17 Unmapped Class C Bankfull Width: 3.4 m Temperature: 7.5°C Organic / n/a Beaver Dam Width: > 50 m Brook stickleback captured (No fish Yes Crossing located within a series of beaver dams.
Creek E: 406125 (April 16 – July 15) Bankfull Depth: 0.3 m pH: 6.5 Complex Vegetation: grasses and previously documented)
Water Depth: 0.5 m Conductivity: 86.9
Stream Gradient: 0-1% Turbidity: clear
Sinuosity: 1
WC 3 Unnamed tributary to Duncan 8-14-74-17 Mapped Class C Bankfull Width: 4.5 m Temperature: 6.7°C Fine / n/a Perennial Width: 20 - 30 m Brook stickleback captured (No fish Yes Crossing located on a meander bend.
Creek E: 405113 (April 16 – July 15) Bankfull Depth: 1.0 m pH: 7.1 Watercourse Vegetation: grasses and previously documented)
Stream Gradient: 1% Turbidity: stained
Sinuosity: 2.1
WC 4 Unnamed tributary to Duncan 4-26-74-17 Unmapped Class C Bankfull Width: 1.0 m Temperature: 3.7°C Fine / Organic Intermittent Width: 20 - 30 m No fish captured (No fish previously No Defined bed and banks upstream from road crossing - not
Creek E: 404019 (April 16 – July 15) Bankfull Depth: 0.2 m pH: 7.5 Watercourse/ No Vegetation: shrubs documented) defined at road crossing. Low lying wet area
N: 6144264 Wetted Width: 0.7 m DO: 12.4 mg/L Defined Channel
Stream Gradient: 0.5-1% Turbidity: stained
Sinuosity: 1.05
WC 5 Unnamed tributary to Duncan 4-2-75-17 Unmapped Class C Bankfull Width: 1.1 m Temperature: 2.5°C Fine / Cobble Intermittent Width: 20 - 30 m No fish captured (No fish previously No Shallow and narrow with debris barriers throughout
Creek E: 402940 (April 16 – July 15) Bankfull Depth: 0.3 m pH: 7.4 Watercourse Vegetation: shrubs documented)
N: 6147564 Wetted Width: 0.8 m DO: 11.3 mg/L
Stream Gradient: 1% Turbidity: n /r
Sinuosity: 1.1
WC 6 Unnamed tributary to Duncan 12-2-75-17 Unmapped Class C Bankfull Width: 0.8 m Temperature: 6.1°C Fine / n/a Intermittent Width: 30 - 40 m No fish captured (No fish previously Yes Shallow and narrow with debris and log barriers throughout
Creek E: 402646 (April 16 – July 15) Bankfull Depth: 0.3 m pH: 7.5 Watercourse Vegetation: shrubs documented)
Sinuosity: 1.2
WC 7 Duncan Creek 16-3-75-17 Mapped Class C Bankfull Width: 5.5 m Temperature: 6.7°C Fine / Small Perennial Width: n/r Brook stickleback captured (brook No
E: 402275 (April 16 – July 15) Bankfull Depth: 0.4 m pH: 7.0 Gravel Watercourse Vegetation: n/r stickleback documented)
Stream Gradient: 1.5% Turbidity: stained
Sinuosity: 2.5
WC 8 Unnamed tributary to Duncan 15-15-75-17 Unmapped Class C Bankfull Width: 1.4 m Temperature: 3.9°C Fine / n/a Beaver Dam Width: 20 - 30 m No fish captured (No fish previously Yes
Creek E: 402100 (April 16 – July 15) Bankfull Depth: 0.4 m pH: 5.5 Complex Vegetation: shrubs documented)
Sinuosity: 1.1
WC 9 Unnamed tributary to Duncan 13-22-75-17 Unmapped Class C Bankfull Width: 1.1 m Temperature: 4.7°C Fine / n/a Perennial Width: 10 - 20 m No fish captured (No fish previously No Shallow and narrow with subsurface flow and debris barriers
Creek E: 401476 (April 16 – July 15) Bankfull Depth: 0.4 m pH: 6.8 Watercourse Vegetation: shrubs documented) throughout
Stream Gradient: 0-1% Turbidity: n/r
Sinuosity: 1.4
Page 6
BlackPearl Resources Inc December 2013
TABLE 2-1 Cont'd

Substrate Fish Species Captured or Beaver
Legal Location (W4M), Watercourse Class Composition Observed During Open Water Activity
UTM Co-ordinates and Restricted Activity Mean Channel Water Quality (Dominant / Assessment Present
Site No.1 Name (NAD 83, Zone 12 U) Period (RAP)2 Morphology (m)3 Parameters Subdominant) Flow Regime Riparian Composition (Previously Documented)4 (Yes/No) Comments
WC 10 Unnamed tributary to Duncan 9-28-75-17 Unmapped Class C Bankfull Width: 1.4 m Temperature: 3.9°C Fine / Small Perennial Width: 20 - 30 m Brook stickleback captured (No fish Yes Shallow and narrow with debris and log barriers throughout.
Creek E: 400816 (April 16 – July 15) Bankfull Depth: 0.4 m pH: 7.0 Gravel Watercourse Vegetation: grasses and previously documented) Beaver dam at 100 m downstream
Sinuosity: 1.14
WC 11 Unnamed tributary to Duncan 7-33-75-17 Unmapped Class C Bankfull Width: 1.0 m Temperature: 7.5°C Fine / Organic Perennial Width: 20 - 30 m No fish captured (No fish previously Yes Very narrow channel with debris and log barriers throughout
Creek E: 400608 (April 16 – July 15) Bankfull Depth: 0.6 m pH: 6.8 Watercourse Vegetation: grasses and documented)
Stream Gradient: 1% Turbidity: n/r
Sinuosity: 1.2
WC 12 Unnamed tributary to Duncan 10-33-75-17 Unmapped Class C Bankfull Width: 1.0 m Temperature: 8.6°C Organic / Fine Intermittent Width: 10 - 20 m No fish captured (brook stickleback No Defined bed and banks upstream from road crossing - not
Creek E: 400582 (April 16 – July 15) Bankfull Depth: 0.3 m pH: 6.7 Watercourse/ No Vegetation: shrubs previously documented) defined at road crossing.
Sinuosity: 1.2
WC 13 Unnamed tributary to Duncan 2-4-76-17 Unmapped Class C Bankfull Width: 0.9 m Temperature: 9.0°C Organic / n/a Intermittent Width: 20 - 30 m No fish captured (No fish previously No Upstream predominately undefined channel, downstream
Creek E: 400519 (April 16 – July 15) Bankfull Depth: 0.1 m pH: 7.2 Watercourse/ No Vegetation: shrubs documented) defined channel.
Stream Gradient: 2% Turbidity: lightly
Sinuosity: 1.1 turbid
WC 14 Unnamed tributary to Athabasca 10-4-76-17 Unmapped Class C Bankfull Width: 0.6 m Temperature: 7.1°C Fine / Organic Perennial Width: 5 - 10 m No fish captured (No fish previously No Subsurface flow and debris barriers throughout.
River E: 400544 (April 16 – June 30) Bankfull Depth: 0.2 m pH: 5.9 Watercourse Vegetation: shrubs documented)
Sinuosity: 1.1
WC 15 Unnamed tributary to Athabasca 15-4-76-17 Unmapped Class C Bankfull Width: 2.1 m Temperature: 7.5°C Fine / Cobble Perennial Width: 20 - 30 m Brook stickleback captured (No fish Yes Beaver dam complex located upstream.
River E: 400519 (April 16 – June 30) Bankfull Depth: 0.7 m pH: n /r Watercourse Vegetation: shrubs previously documented)
Sinuosity: 1.25
WC 16 Unnamed tributary to Athabasca 7-9-76-17 Unmapped Class C Bankfull Width: 0.8 m Temperature: 6.0°C Organic / Fine Perennial Width: 20 - 30 m No fish captured (No fish previously No Subsurface flow and debris barriers throughout.
River E: 400455 (April 16 – June 30) Bankfull Depth: 0.2 m pH: 6.1 Watercourse Vegetation: n/r documented)
Stream Gradient: 1.5% Turbidity: clear
Sinuosity: 1.2
WC 17 Unnamed tributary to Athabasca 7-20-76-17 Unmapped Class C Bankfull Width: 3.7 m Temperature: 7.3°C Organic / n/a Beaver Dam Width: 0 - 5 m No fish captured (No fish previously No
River E: 399137 (April 16 – July 15) Bankfull Depth: 1.0 m pH: 5.3 Complex Vegetation: mixed woods documented)
Stream Gradient: 0-1% Turbidity: stained
Sinuosity: 1.2
Notes: 1 Watercourses as defined under the Alberta Code of Practice for Pipelines and Telecommunication Lines Crossing a Waterbody (GOA 2013).
2 Determined from the Code of Practice Management Area Map for Lac La Biche (AENV 2006).
3 Some depth measurements from Beaverdam complexes were estimated.
4 Results from FWMIS (2013).
n/a (not applicable), n/r (not recorded).
Page 7
2. a. Identify what additional data will be collected to augment this and describe the criteria
to be used to determine crossing structure design.
Response:
Reconnaissance of all existing access crossing locations present along LOC 819 was conducted by a
Qualified Aquatics Environmental Specialist (QAES) in the fall 2010 or spring 2012 to verify flow regime,
channel morphology, water quality characteristics, fish habitat potential and existing crossing structures,
and has been summarized above (Table 2-1). No additional data is anticipated to be collected at this
time; however, if eventual upgrading, replacement or maintenance of existing watercourse crossings on
LOC 819 is required to support traffic and equipment associated with an operational steam-assisted
gravity drainage (SAGD) facility (as described in Round 1 AESRD SIR 8a), site-specific fish and fish
habitat assessments will be conducted where required to ensure adherence to the Code of Practice for
Watercourse Crossings (Alberta Government 2013).
Any replacement or upgrade of existing watercourse crossing structures along LOC 819 will be designed
and installed in adherence to the Code of Practice for Watercourse Crossings (Alberta Government 2013)
and will be selected based on the QAES recommendation as discussed in Volume 3, Section 4.7.2 of the
Integrated Application and Round 1 AESRD SIRs 64c and 64e, and will be based on sensitivity of the
watercourse, including habitat characteristics, fish species present, RAPs, hydrological specifications and
regulatory requirement, in addition to construction schedule, and technical and economic feasibility.
2. b. Outline how avoidance of aquatic fragmentation will be considered in the design

criteria.
Response:
As discussed in Volume 3, Section 4.7.4 of the Integrated Application and Round 1 AESRD SIRs 64e and
68b, avoidance of aquatic habitat fragmentation will be considered in the design, installation and
monitoring of existing watercourse crossings that are determined to need replacement through adherence
to the installation protocols and regulations outlined in the Alberta Transportation Fish Habitat Manual
(Alberta Transportation 2001), Government of Alberta (GOA) Roadway Watercourse Crossing Inspection
Manual (GOA 2012) and the Government of Alberta Code of Practice for Watercourse Crossings (Alberta
Government 2013). Black Pearl has also committed to regular inspections and maintenance. (Volume 3,
Section 4.7.4 of the Integrated Application and Round 2 AESRD SIR 26).
2. c. Confirm these crossings will be monitored using Government of Alberta Roadway

Watercourse Crossing Inspection Manual (September 21, 2012) and describe a
conceptual monitoring plan clearly identifying the frequency of monitoring proposed,
reporting and remediation timing for any issues identified.
Response:
BlackPearl has committed to post-construction monitoring of road watercourse crossings using the
guidelines in the Roadway Watercourse Crossing Inspection Manual (GOA 2012) as discussed in
Round 1 AESRD SIRs 64f and 64g. Watercourse crossings will be monitored annually, at a minimum,
and if deficiencies are found they will be reported to the construction supervisor and documented as a
part of BlackPearl’s monitoring program. Remedial measures will be taken as soon as possible, however
the timeline for remedial action will vary depending on a number of factors such as severity of the issue,
ground condition, volume of water flow and measures required to rectify the issue as was discussed in
Round 1 AESRD SIR 68a.
Page 8
2.0 AIR
2.1 Dispersion Modelling
3. ESRD SIR 1 Responses, Section 2.2, SIR 16, Table 16-1, Page 20
Table 16-1 indicates that the value for BIAS used in CALMET model option group 5 parameters
has been set to +1, which reduces the weighting of the surface stations to zero, with the note
that a value of -1 reduces the weight of the unused upper stations by 100% to zero.
a. Confirm that the value used is correct and that BIAS is set to reduce the weighting of
the needed stations by the correct amount.
Response:
Based upon how the CALMET model was employed for the BlackPearl assessment, the BIAS switch is
inactive and is not considered by the CALMET model.
The diagnostic wind field component of the CALMET model uses a two-step approach to creating a three
dimensionally varying wind field. In the first step, an initial-guess field is created. The CALMET model
then adjusts the initial guess field for kinematic effects of terrain, slope flows and terrain blocking effects
to produce a step 1 wind field. Lastly, CALMET uses an objective analysis procedure to introduce
observational data into the step 1 wind field.
The BIAS switch is only used when CALMET is configured to create an initial guess field by interpolating
between twice-daily upper air observation and surface station observation. The BIAS switch allows the
user to provide more or less weighting to upper air station data.
The CALMET model was run using only the AESRD supplied MM5 mesoscale meteorological dataset as
the initial guess field which means that CALMET does not use BIAS values in the model run.
Table 16-1 indicates a value of 5 was selected for the number of stations used in data
interpolation for the reduction of smoothing effects applied to the data.
a. Explain how using this specification results in an appropriate usage of the

meteorological data.
Response:
CALMET uses an inverse distance method to introduce observational surface station wind data into the
step 1 wind field. This interpolation scheme allows observational data to be heavily weighted at grid
locations near the observational station and less weighted further away. The surface weighting parameter
R1 specifies the distance at which surface observational data and the step 1 wind field are equally
weighted. The BlackPearl assessment used a value of 8 km for R1. At CALMET grid locations less than
8 km, the surface station wind data most heavily influences the final wind field. At CALMET grid points
located greater than 8 km from a surface station, the AESRD supplied MM5 data most heavily influences
the final wind field.
The NINTR2 parameter specifies the maximum number of meteorological stations used for interpolation
of data at each CALMET grid point. For the BlackPearl assessment, CALMET was set to limit the number
of stations considered in the inverse distance method interpolation to a maximum of 5 stations for
computational efficiency. This parameter was set to 5 with consideration given to the number of, location
of and density of actual surface stations in the domain relative to the radius of influence parameter (R1).
As the density of surface stations is sparse, there are no locations within the CALMET domain where
Page 9
more than 5 stations are located within sufficient proximity to potentially influence the objective analysis
step of CALMET. Limiting NINTR2 to a maximum of 5 stations is an appropriate choice for this Project.
Table 16-2 shows that two grid cells were used as the maximum search radius for averaging,
and that it corresponds to a distance of 8 km.
a. Confirm that the ESRD MM5 data set, which has a grid spacing of 12 km per grid cell,
was used.
Response:
Yes, the AESRD MM5 data is used; however, the switch MNMDAV, which controls the maximum search
radius for mixing height averaging, is unrelated to whether or not the AESRD MM5 data is used or the
MM5 grid spacing.
CALMET predicts mixing heights as the maximum of convective and mechanical mixing height values for
each grid cell for each hour of the 5 year time period. To prevent unreasonably large cell-to-cell variation
in mixing heights, CALMET employs a smoothing scheme to account for important advection effect on
mixing height depths. CALMET employs an upwind averaging that allows CALMET to smooth the
predicted mixing height for a given grid cell with the mixing heights of upwind grid cell to account for the
influence of air moving across different grid cells, hour-to-hour.
The parameter MNMDAV specifies the maximum search distance in CALMET grid cells to consider in the
spatial smoothing calculation. The value was set to two CALMET grid cells, equal to 8 km which is
appropriate for considering upwind influences on grid cell mixing heights.
Table 16-7 indicates that NSPLIT has been set to a value of 2, less than the default of 3 for the
purpose of making the model run faster.
a. Explain how this is a reasonable and justifiable approach considering this could reduce
the model precision.
Response:
The CALPUFF model contains an optional puff splitting algorithm that allows for more realistic simulation
of vertical wind shear effects, or how wind speed and direction vary with height. While puff splitting is
noted as a non-default option, it was employed for the BlackPearl assessment based upon
recommendation by the model developer. The model developer, in the Frequently Asked Questions
section of the CALPUFF user website states that puff splitting is an important option to include when
running the CALPUFF model using large study areas with long transport distances with high probability of
tracking puffs for more than 12 hours (The Atmospheric Studies Group 2008). The CALPUFF domain
used for the BlackPearl assessment is a large study area.
Puff splitting allows the model to account for variation of the horizontal wind as a function of height, which
is most prevalent at night. The CALPUFF model was run to allow 1 puff to split into 2 puffs by setting
NSPLIT=2, once per day near sunset. The default recommended value for NSPLIT is suggested as 3 but
was reduced to 2 to reduce the number of puffs. The CALPUFF model contains a limit of the maximum
number of puffs that can be simulated (MXPUFF). If the number of puffs tracked exceed this limit, the
model will crash.
Page 10
The choice to reduce NSPLIT from 3 to 2 is consistent with guidance on the CALPUFF model developer
Frequently Asked Questions website. The guidance states that a user may need to consider reducing the
number of puffs to a lower value than 3 for each puff split event to avoid creating too many puffs that
exceed the maximum number of tracked puffs for the CALPUFF model.
The use of less aggressive puff splitting by selecting NSPLIT=2 instead of 3 is expected to result in
decreased dispersion of the puffs which would slightly increase predicted concentrations. The use of
NSPLIT=2 instead of 3 is expected to result in slightly more conservative concentration predictions.
Page 11
3.0 WATER
3.1 Water Management
7. ESRD SIR 1 Responses, Section 3.1, SIR 20, Page 26.
BlackPearl indicates A dust control problem is unlikely [to be] required for the BlackRod
project… noting, further, that a dust control program was not required for the pilot. However,
BlackPearl does indicate that it will monitor the construction process and evaluate the need for
dust control.
a. Most operators of similar projects identify a water requirement for dust control. How
does the BlackRod project differ from these?
Response:
Dust control is required for oilsands project operations that are accompanied by heavy trucking traffic for
transportation of bitumen. As the Blackrod Project will use pipelines to convey bitumen, operation traffic in
the Project area will be minimal; therefore, a dust control program is unlikely to be required. Dust control
has not been required during our Pilot operation. Nevertheless, since dust control may be required for
summer construction in dry years, BlackPearl has estimated water demand for dust control for both
construction and operation phases. The estimated water volumes for dust control are shown in Table 7-1.
3
The estimate is based on the assumption that 3.5 m of water is required for each application on every
kilometre of road that is dust controlled. The water demand calculations are based on the road lengths
from the Central Processing Facility (CPF) to the well pads for all phases and that the corners are dust
controlled on LOC 819 (approximately 32 km) from Highway 63 to the CPF. BlackPearl will monitor the
process and adjust the dust control program accordingly.
TABLE 7-1
ESTIMATED MAXIMUM DUST CONTROL WATER DEMAND FOR SUMMER

(JUNE TO SEPTEMBER) CONSTRUCTION AND OPERATION
Water Demand
3
Year (m )
2014 2,700
2015 2,700
2016 2,700
2017 3,900
2018 3,900
2019 5,300
2020 6,100
2021 7,600
2022 7,700
2023 7,700
2024 8,500
2025 9,200
2026 9,700
2027 10,800
2028 10,900
2029 10,900
2030 11,700
2031 11,700
2032 11,700
2033 11,700
2034 11,700
Page 12
TABLE 7-1 Cont'd
Water Demand
3
Year (m )
2035 11,700
2036 11,700
2037 11,700
2038 11,700
2039 11,700
2040 11,700
2041 11,700
2042 11,700
2043 8,000
2044 6,000
2045 5,000
2046 4,000
2047 3,000
7. b. In the event dust control is needed, from where will BlackPearl source the water
required?
Response:
BlackPearl plans to source its dust control water from the CPF storm water pond. Please refer to the
response to Round 2 AESRD SIR 48b for the CPF storm water pond size. BlackPearl will apply for a
Water Act License to source dust control water from the CPF storm water pond.
The estimated water volumes (Table 7-1) represent up to 8% of the average annual runoff volume from
the CPF plant site. This consumption will not have adverse impacts to surface water in the regional study
area (RSA); instead, it will reduce the runoff volume increase due to the development of the CPF. The
current pond design allows for provision of dedicated storage for dust control use. We propose to allocate
3
a volume of 9,000 m for this purpose, which represents 18.7% of the pond volume. Water collected in
this supply storage zone will only be used for dust control. As described below, the HSPF model was
used to confirm that this plan would provide sufficient water for the dust control program.
As described in the Integrated Application (Volume 3, Section 2.0), the HSPF model was developed to
simulate runoff processes for the period from 1961 through 2010. The model is used herein to simulate
the CPF storm water pond operation with dust control under the Application Case. In accordance with the
current CPF plant site plan, the storm water pond in the model has a surface area of 2.0 ha. The first
3
0.45 m depth is defined as the water supply zone, which provides a storage capacity of 9,000 m . Water
in this zone is only discharged to supply for dust control use. Through the entire simulation period, annual
3
water consumption for dust control is assumed as 11,700 m - the maximum of the estimated annual
water demand (Table 7-1) – with monthly variation shown in Table 7-2.
TABLE 7-2
ASSUMED WATER VOLUMES FOR DUST CONTROL

3
Month Volume (m )
June 1,400
July 3,100
August 3,100
September 4,100
Total 11,700
Page 13
Based on the simulation results, the pond would never empty due to water consumption for dust control: a
minimum pond depth of 0.08 m would have occurred in 2007 and the second lowest minimum depth of
0.12 m would have occurred in 2004. Therefore, it is believed that the proposed pond operation plan will
provide the required water volumes for dust control.
Additional details regarding the CPF pond size are provided in the response to Round 2 AESRD SIR 48b.
7. c. If the source is not a surface water source, provide a comparison of water quality
between the source water and local surface water and discuss any potential loading
issues to soils, and/or terrestrial, wetland, and aquatic habitat.
Response:
BlackPearl will only source dust control water from a surface source (i.e., CPF storm water pond).
7. d. If there are potential loading issues, identify how they will be monitored and managed.
Response:
As stated in Round 2 AESRD SIR 7c above, BlackPearl will only use a surface water source. There will
be no loading issues.
3.2 Hydrogeology
8. ESRD SIR 1 Responses, Section 3.2, SIR 21, Pages 30-31
SIR 21 was meant to obtain clarifications on the MFS caprock formation for hydrogeological
evaluation purposes. In response to SIR 21f, which specifically requests hydraulic properties of
the capping shale obtained within the Application Resource Area (ARA), BlackPearl states that
Direct measurements of the hydraulic properties … of a shale deposit typically cannot be made
due to the very low permeability of the shale. BlackPearl further provides hydraulic
conductivities estimated from a groundwater flow model for the overlying Joli Fou shales.
Although it is recognized that groundwater inflow in shale formations is low, groundwater

monitoring wells are regularly drilled in aquitards for the purpose of characterizing their
hydraulic conductivities and the level of connectivity with surrounding formations. The caprock
is an important formation for SAGD operations and, therefore, should be hydraulically
characterized at a micro and macro-scale within the ARA.
In response to SIR 21a regarding the possible presence of a near wellbore fracture based on
mini-frac test data obtained by Schlumberger, BlackPearl states that Based on the additional
core evaluation work that BlackPearl has conducted, the near-wellbore fracture observed by
Schlumberger is likely a drilling disturbance and not a natural occurrence.
a. Provide the above mentioned additional core evaluation data conducted by BlackPearl
to show that there are no fractures within the MFS caprock.
Page 14
Response:
The additional core evaluation work that BlackPearl has conducted to show that there are no naturally
occurring fractures consists of visually inspecting and describing 28 maximum flooding shale (MFS)
caprock intervals in cores recovered from within the Application Resource Area (Figure 8-1). The shale
representing the MFS caprock interval, in all 28 sampled cores, is typically a medium to dark grey well
indurated, non-calcareous, slightly fissile marine shale that is free of vertical fractures (Figure 8-2).
Occasional traces of pyrite were also observed in some samples. The MFS caprock in
1AA/07-36-076-18W4/00 is representative of the caprock throughout the Project Area. The shale is
parted along the horizontal bedding planes due to desiccation of the core in storage. Under original
overburden in situ conditions the separated horizontal laminations would be sealed. This shale is
considered to be a competent caprock due to lack of vertical fractures, continuous lateral extent, and
consistent isopach thickness as shown in Figure 3.2-2 of Volume 1, Section 3.0 of the Integrated
Application.
Page 15
¯

!

!


!

!

+ MFS Core Locations Application Resource Area (ARA)

t6790_Figure_8-1_MFS core locations20131114
Existing Well Waterbody

"
BlackPearl Oil Sand Holdings

Hydrography: AltaLIS.Ltd 2011; Wells: BlackPearl Resources Inc. 2013;
km
Drainage Area: BlackPearl Resources Inc. 2013.
0 0.5 1 1.5
December 2013
MFS
Caprock
Figure 8-2
December 2013
MFS Caprock Core
1AA/07-36-076-18W4/00
AESRD SIR 2 Responses – BlackPearl Resources

Inc. Proposed Blackrod Commercial SAGD Project
8. b. Provide groundwater information obtained at different locations within the ARA,

including pumping or slug test data, hydraulic conductivities, water elevations, to
characterize the hydraulic properties of the capping shale measured within the ARA.
Response:
Literature data for the hydraulic properties of the MFS caprock in the Application Resource Area [ARA]
are not available, which is not unexpected given the remote location of the Project Area. However,
hydraulic conductivity values for two overlying capping shales (Grand Rapids 'A' shale and Joli Fou
Formation shale) were provided previously (Round 1 AESRD SIR 21f response).
As stated in the response for Round 1 AESRD SIR 21f, the MFS caprock in the ARA is directly overlain
by the Grand Rapids 'A' shale. Horizontal and vertical hydraulic conductivities estimated for the Grand
-10
Rapids 'A' shale from the steady-state calibration of a groundwater flow model were 1.0 x 10 and
-11
1.0 x 10 m/s (Cenovus 2011). The model was developed for the Cenovus Pelican Lake Grand Rapids
Project and the model domain included the Blackrod ARA.
Horizontal and vertical hydraulic conductivities estimated for the Joli Fou Formation shale from the
-8 -11
steady-state calibration of a groundwater flow model were 1.2 x 10 and 1.5 x 10 m/s (Worley
Parsons 2010). The model was developed for the Southern Athabasca Oil Sands (SAOS) region and the
model domain included the Blackrod ARA.
Based on these values, a reasonable estimate of the horizontal hydraulic conductivity of the MFS caprock
-10 -8
in the ARA is in the range of 1.0 x 10 to 1.2 x 10 m/s, and a reasonable estimate of the vertical
-11 -11
hydraulic conductivity is in the range of 1.0 x 10 to 1.5 x 10 m/s.
BlackPearl does not agree with the statement in the preamble that groundwater monitoring wells are
regularly drilled in aquitards for the purpose of characterizing their hydraulic conductivities. To clarify the
response for Round 1 AESRD SIR 21f, direct measurement of the hydraulic properties of a shale deposit
using monitoring wells is impractical and typically cannot be made due to the very low permeability of the
shale. In hydrogeology studies, the hydraulic properties of aquitards on a regional scale are commonly
estimated from the steady-state calibration of a groundwater flow model. The hydraulic properties of the
shale aquitards in the Cenovus Pelican Lake model domain and the SAOS region model domain, noted
above, were estimated from steady-state calibrations of groundwater flow models. Groundwater
monitoring wells had not been drilled in aquitards within either model domain. The BlackPearl
hydrogeology team is not aware of any shale monitoring wells in the oil sands areas of northeast Alberta.
Page 18
Volume 3, Appendix 1A, Figures 1A-4 and 1A-36, Pages 1A-11 and 1A-45
In response to SIR 23b requesting the list and data on non saline groundwater formations,
BlackPearl states that The water-saturated sandstones of the Upper Grand Rapids (i.e., the
Grand Rapids 'A' aquifer) are thin or absent in the Project Area and the Hydrogeology LSA
(Volume 3, Appendix 1A, Figure 1A-36, Page 1A-45 of the Integrated Application).
Consequently, the Grand Rapids 'A' aquifer is not a groundwater management unit.
On the type log 100/07-35-076-18W4 provided in EIA Volume 3, Appendix 1A, Figure 1A-4,
Page 1A-11, the Grand Rapids A is shown as a continuous sandstone over 20 m thick. The
isopach map provided in EIA Volume 3, Appendix 1A, Figure 1A-36, Page 1A-45 suggests
thicknesses of the Grand Rapids 'A' sandstone ranging between 0 and 11 m within the
southern portion of the Project Area.
a. Update the isopach map shown on Figure 1A-36 to reflect correctly the 20+m thickness
observed for Grand Rapid 'A' on Figure 1A-11.
Response:
The Grand Rapids ‘A’ interval on type log 100/07-35-076-18W4/00 (Volume 3, Appendix 1A, Figure 1A-4
of the Integrated Application) shows an overall thickness of 21 m; however, the total thickness of the
water-saturated sandstone (i.e. aquifer) is only 11 m. This is over two intervals, one 8 m thick and the
other 3 m. Thus, Figure 1A-36 correctly shows this as “11(2)”. The 7 m of gas saturated sandstone, and
the 3 m of shale are not considered part of the aquifer and were therefore excluded. The following is a
breakdown of the Grand Rapids ‘A’ sequence from this type log:
• 243 to 250 m: gas-saturated sandstone;
• 250 to 258 m: water-saturated sandstone (8 m aquifer interval);
• 258 to 261 m: shale; and
• 261 to 264 m: water-saturated sandstone (3 m aquifer interval).
9. b. Explain what formation thickness is classified as "thin" by BlackPearl, with regards to

the Grand Rapids 'A' sandstone. Explain what BackPearl considers as the minimum
thickness and areal extent for the Grand Rapids 'A' Formation within the ARA, to be a
groundwater management unit.
Response:
One metre is considered the minimum thickness. Water-saturated sandstone thicknesses shown on
Figure 1A-36 were rounded to the nearest metre; thus, a thickness of 1 m shown on this isopach is
considered an indication of water-saturated sandstone being present within the Grand Rapids ‘A’.
The water-saturated sandstones of the Grand Rapids ‘A’ do not constitute a laterally continuous aquifer in
the Project Area (Westwater Environmental Ltd [Westwater] 2011). Of the 59 well locations in the
Hydrogeology local study area (LSA) (Volume 3, Appendix 1A, Figure 1A-36 of the Integrated
Application), 23 (39%) had no water-saturated sandstone in the Grand Rapids ‘A’. Similar numbers are
seen for the Project Area: water-saturated sandstone in the Grand Rapids ‘A’ was absent in 36% of well
location boreholes (Volume 3, Appendix 1A, Figure 1A-36 of the Integrated Application). In many cases,
the presence of water-saturated sandstone within the Grand Rapids ‘A’ is not consistent even between
adjacent leases. As noted above in the response for Round 2 AESRD SIR 9a, voids within the Grand
Rapids ‘A’ sandstone commonly contain gas rather than water.
Page 19
For the Grand Rapids ‘A’ sandstone to be a groundwater management unit, the minimum areal extent
should be such that it is adequate, when coupled with thickness, for the aquifer to supply water for
practical use. The discontinuity of sandstone between boreholes in both the Hydrogeology LSA and
Project Area, coupled with its tendency for gas-saturation, have discounted the Grand Rapids ‘A’
sandstone as a viable groundwater supply and therefore it is not considered to be a groundwater
management unit.
10. ESRD SIR 1 Responses, Section 3.2, SIR 23, Response d, Page 34
In response to SIR 23d requesting hydraulic data collected from the two wells drilled to monitor
the bottom water zone in the Lower Grand Rapids formation at 03-36-76-18W4 and 14-25-76-
18W4, BlackPearl provided water level and temperature data. However, BlackPearl indicated
that transmissivity and hydraulic conductivity values were not available.
a. Provide pumping test or slug test data obtained on the above mentioned wells, along
with corresponding transmissivity and hydraulic conductivity values. If not, indicate the
reasons why the tests were not conducted or why data cannot be provided and provide
a plan to acquire this data.
Response:
The monitoring wells at 03-36-76-18 W4M (MW LGR 3-36) and 14-25-76-18 W4M (MW LGR 14-25) are
completed in the LGR 3 aquifer, also referred to as the Grand Rapids ‘B’ aquifer. MW LGR 3-36 and MW
LGR 14-25 were installed for the purpose of groundwater sample collection in addition to water level and
temperature monitoring; therefore, formal hydraulic testing was not completed.
To provide estimates of transmissivity and hydraulic conductivity for the Grand Rapids ‘B’ aquifer,
drawdown and recovery data obtained during the May 2013 sampling event were analysed. Graphs of the
drawdown and residual drawdown versus time are shown in Figures 10-1 and 10-2. Data were analysed
using the Theis solution. Resulting estimates of transmissivity and hydraulic conductivity are shown in
Table 10-1.
TABLE 10-1
ESTIMATES OF HYDRAULIC PARAMETERS FOR THE GRAND RAPIDS ‘B’ AQUIFER
Drawdown Residual Drawdown

Hydraulic Hydraulic
Pumping Rate Transmissivity Conductivity Transmissivity Conductivity
3 2 2
Well Name (m /day) (m /day) (m/s) (m /day) (m/s)
-6 -6
MW LGR 3-36 50 6 6 x 10 4 3 x 10
-6
MW LGR 14-25 40 n/a n/a 4 4 x 10
To compare with regional estimates, hydraulic conductivity values for the Grand Rapids ‘B’ in the
-7 -5 -6
Hydrogeology RSA ranged from 8.2 x 10 m/s to 1.5 x 10 m/s, with a geometric mean of 4.2 x 10 m/s
(Volume 3, Appendix 1A, Section 1A.5.1.7 of the Integrated Application). Locally, hydraulic test results
from the water source well located within the BlackPearl leases at 14-24-76-18 W4M indicate a
2 -6
transmissivity of 2 m /d with a corresponding hydraulic conductivity of 1.5 x 10 m/s.
Page 20
December 2013
Time elapsed since pump start (minutes)
0 20 40 60 80 100 120 140 160 180 200 220 240 260 280
0
FIGURE 10-1
2 Q = 50 m3/day
4 DRAWDOWN AND RESIDUAL
DRAWDOWN IN MW LGR 3-36
6 Data used in analysis
8 AESRD SIR 2 RESPONSES -

T = 4 m2/day BLACKPEARL RESOURCES INC.
K = 3 x 10-6 m/s PROPOSED BLACKROD
10
Drawdown (m)
12
T = 6 m2/day
14 K = 6 x 10-6 m/s
16 Data Used in Analysis
18
20
22
24
26
LEGEND:
Drawdown and Residual Drawdown

in MW LGR 3-36

data may be present
December 2013
Time elapsed since pump start (min)
0 20 40 60 80 100 120 140 160 180 200 220 240 260 280 300
0
4 Q = 40 m3/day FIGURE 10-2
6
Data used in analysis DRAWDOWN AND RESIDUAL
8 DRAWDOWN IN MW LGR 14-25
T = 4m2/day
10 K = 4 x 10-6 m/s
12
Drawdown (m)

16
18
20
22
24
26
28
30
32
LEGEND:
Drawdown and Residual Drawdown

at MW LGR 14-25

data may be present
ESRD SIR 1 Responses, Section 3.5, SIR 62, Page 94
BlackPearl was requested to map a 100 metre setback from the edge of the disturbance to the
top of the watercourse escarpment. BlackPearl provided Figure 62-1, and identified in the text
that it depicts a 100m buffer on watercourses with defined bed and banks. BlackPearl was
requested to use the top of the escarpment as the measurement endpoint to provide clarity as
to whether infrastructure will encroach upon watercourse valleys.
a. It is unclear whether the figure depicts the setback as measured from the edge of the
disturbance to the high water mark, or the top of the escarpment. Confirm that the
setback presented is measured from the top of the escarpment. If it is not, re-present
the figure with this measurement endpoint as requested.
Response:
Current provincial guidance documents do not provide a definition of ‘top of escarpment’. Upon further
consultation with AESRD, ‘top of escarpment’ was clarified as being generally commensurate with valley
break, as defined in the Enhanced Approval Process Integrated Standards and Guidelines (GOA 2013).
Figure 11-1 depicts the 100 m setback as measured from the top of the escarpment (i.e., valley break).
Escarpment breaks were derived based on professional interpretation of LiDAR imagery (acquired
February 6, 2012), topographic maps and aerial imagery (acquired July 4, 2011). As noted in Round 2
AESRD SIR 30 below, watercourses identified using NTS 1:50,000 maps, DEM data, and additional
hydrography obtained from 1:20,000 scale Alberta SDW maps will be ground-truthed prior to finalization
of infrastructure locations.
Page 23

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11. b. In ESRD SIR 62b, BlackPearl was requested for a rationale for the location of all
infrastructure located within the 100 metre setback as measured from the top of the
escarpment. BlackPearl explains in the response to SIR 62c, that the proposed access
road paralleling the watercourse in 18-77-17-W4M is existing infrastructure, and the
CPF will be designed to maintain the riparian setback around the headwaters of the
local drainage. For all other infrastructure that is proposed within the setback, as
measured from the top of the escarpment to the edge of disturbance, provide a
rationale for its location and discuss the implications of relocation outside the setback.
For each case, identify why it is ‘not possible to maintain a 100 metre setback’,
describing what criteria were considered in the decision and how they were weighted.
Response:
As previously described in the response to Round 1 AESRD SIR 63b and shown in Figure 11-1, other
infrastructure located within the 100 m setback as measured from the top of the escarpment based on a
desktop review includes: three well pads, in NE 35-76-18 W4M, SE 35-76-18 W4M and
NW 24-76-18 W4M; and one borrow pit located in 24-76-18 W4M. The well pads in 35-76-18 W4M are
part of Phase 2 and will not be constructed until 2017, pending regulatory approval. The borrow pit and
well pad in 24-76-18 W4M are part of Phase 3 with an anticipated construction start date of 2019,
pending regulatory approval.
As previously indicated, pre-development site assessments (PDAs) will be completed prior to final well
pad and borrow pit siting, clearing and construction to confirm the location of the watercourse and
associated escarpment breaks. Setbacks will be measured from the top of the escarpment of
watercourses with defined bed and banks to the edge of the disturbance. In the absence of a clear
escarpment break, the setback will be measured from the normal high water mark of watercourses with
defined bed and banks. Based on the results of the PDA, BlackPearl will review those locations that are
located within 100 m and discuss with AESRD. It is likely that modifications can be made to
accommodate a 100 m setback, however, more in-depth information from field conditions are warranted.
12. Project Update and ERCB SIR 1 Responses, Section 3.0, SIR 23, Page 50
ESRD SIR 1 Responses, Section 3.2, SIR 25, Pages 39-40
BlackPearl’s response to the request for additional information around BlackPearl’s conclusions
related to ground heave and surface subsidence makes a number of statements that seem
contradictory.
Heave occurs as a normal part of operations at SAGD projects within Alberta.
a. This statement appears in the response to SIR 25a and is repeated in the response to
SIR 25f. The statement suggests that there are, in fact, sufficient data from other
operators to characterize surface heave as a normal part of operations. Describe how
BlackPearl determined ground heave to be a normal part of operations.
Response:
As stated in response to Round 1 AESRD SIR 25, BlackPearl recognizes that surface heave could occur
and, if it occurs, BlackPearl considers it to be normal part of operations at SAGD projects within Alberta
as heave has occurred at existing SAGD operations. Since heave was identified as an industry issue,
SAGD operators have implemented monitoring programs to quantify heave and the rate or deformation.
Mean annual displacement rates observed at existing SAGD projects are 2.4 cm to 3.5 cm per year
(Millennium EMS Solutions Ltd. [MEMS] 2012, Suncor 2013, Cenovus 2012).
Maximum measured ground heave at several SAGD projects roughly analogous to Blackrod are
presented below (Table 12-1).
Page 25
TABLE 12-1
MEASURED GROUND HEAVE AT SAGD SITES IN ALBERTA
Company and Average SAGD Fm Operating Pressure Maximum Heave

Project Depth (m) (kPa) Measured (cm)
Connacher
480 2000-2500 14
Algar/Great Divide
Suncor
300 2660 24.5
Firebag
Cenovus
330-400 2500 20-40
Christina Lake
Cenovus
350-400 3000-4000 20-40
Foster Creek
12. a. Describe potential effects associated with subsidence.
If heave occurs, it is a result of normal SAGD operations and cannot be mitigated because the
only mitigation measure would be to stop steam injection.
Response:
Measured subsidence at Cenovus’ Christina Lake SAGD project has been between 0.2 cm and 1.5 cm
per year (Cenovus 2013). Measured subsidence at Suncor Firebag has been 2 cm and preliminary
findings at Nexen’s Long Lake operations show subsidence of 5 cm (MEMS 2012). No environmental
effects have been reported as a result of measured subsidence. Given the magnitude of the measured
subsidence at other SAGD projects and the lack of reported effects as a result of that subsidence,
discussion of potential effects from subsidence is considered speculative.
12. b. Characterize the potential environmental effects associated with the potential for
surface heave and subsidence, providing data, models, studies, and/or peer-reviewed
literature to support the conclusions presented.
Response:
As noted in Round 2 AESRD SIR 12a and 12b, there are very few data on measured heave and
subsidence as a result of SAGD operations. Collins (2005) presented his findings on the geomechanical
effects of the SAGD process in 2005, and noted that ground heave quickly lessens with distance from the
injection site. Based on the typical rates of surface heave (2.4 to 3.5 cm per year; Round 2 AESRD
SIR 12a), up to 28 cm of heave may occur at Blackrod over the 8 to 10 year lifespan of a well pad.
BlackPearl is not aware of any SAGD operators in Alberta having reported hydrologic or aquatic impacts
resulting from heave or subsidence. Discussion of environmental effects therefore remains speculative
and cannot be discussed using published information, as requested. BlackPearl has committed to
monitoring for ground deformation during Phase 1. These data will be used in review of the processes
and operations used during bitumen recovery in subsequent stages of the Project.
Page 26
Volume 1, Section 7.7, Table 7.7-1, Page 7-6
Volume 3, Section 1.1, Page 1-1
BlackPearl states that The planned wastewater disposal zone is the Lower 'A' and 'B' units of
the Grosmont Formation (Volume 3, Page 1-1). BlackPearl states that Table 7.7-1 is provided
to illustrate the composition of the project fluid streams that are sent to underground disposal
as well as the water composition from the underground source. The tables illustrate that any
fluid that is disposed is of similar quality to the subsurface formation fluid that it is being
pumped into.
In response to SIR 26a which requests information on the fluid composition of the Grosmont 'A'
and 'B', BlackPearl states that Water chemistry data are not available for Grosmont 'A' and 'B'
units. However, it is expected the chemistry of those two Grosmont units will be similar to the
chemistry of the Grosmont 'D' unit as shown in Table 7.7-1 in Volume 1, Section 7.0 of the
Integrated Application. However, a comparison between the water stream to Grosmont 'A' and
the simulated water stream from Grosmont 'D' (Table 7.7-1) shows major chemistry differences
between the project fluid streams sent for disposal and the receiving formation (e.g., chloride
concentrations are measured at 27,497 mg/L in the water stream to Grosmont 'A', and 4,692
mg/L in Grosmont 'D' which is assumed by BlackPearl to have composition as Grosmont 'A').
a. Provide data obtained within the ARA to characterize the Lower 'A' and 'B' units of the
Grosmont Formation which are intended to be the wastewater disposal zone, including
fluid chemistry, chemical compatibility, containment potential, injection capacity,
hydrodynamic flow regime, and water quality assessments (ToR 3.2.1.vii).
Response:
Fluid Chemistry
As noted in the preamble, water chemistry data are not available for the Grosmont 'A'/'B' units. However,
it is BlackPearl's expectation that the chemistry of those two units is similar to the chemistry of the
Grosmont 'D' unit. The basis for that expectation is as follows.
The chemical composition of groundwater is primarily determined by the rock types (i.e., mineralogy) of
the aquifer material. The Grosmont Formation consists of grey and brown fossiliferous limestones and
dolomites (Volume 3, Appendix 1A, Page 1A-15 of the Integrated Application). There is no information
available for the Hydrogeology RSA that would suggest the rock types of the Grosmont 'A’/'B' units are
different from those for the Grosmont 'D' unit. Without any notable differences in rock type, it is
considered very likely that the chemistry of the Grosmont 'A'/'B' groundwater is similar to the chemistry of
the Grosmont 'D' groundwater.
Chemical Compatibility
Operational experience at the Pilot Project demonstrates the wastewater is chemically compatible with
the groundwater in the Grosmont 'A'/'B' disposal zone. Wastewater produced at the Pilot Project is
disposed of into the disposal well located at 2-25-76-18 W4M (DW GROS 2-25). Disposal into DW GROS
3
2-25 began in October 2011 and since that date, a total of 192,000 m of wastewater has been disposed.
During this period, the disposal well has been "on vacuum" which demonstrates that clogging of the well
due to the build-up of precipitates as a result of chemical incompatibility is not occurring. From this
operational experience, BlackPearl has concluded that the two fluids (wastewater and Grosmont 'A'/'B'
groundwater) are of similar quality.
Containment Potential
Containment potential is discussed in Volume 3, Section 1.6.1.2 of the Integrated Application. As stated,
two regionally extensive shale layers designated as Shale 1 and Shale 2 occur in the Grosmont
Page 27
Formation. Shale 1 occurs at the base of Grosmont 'C' and Shale 2 occurs at the base of Grosmont 'B'.
These shale layers range in thickness from 2 m to 8 m and act as barriers to flow (BlackPearl 2011). Due
to the presence of Shale 1 and Shale 2, the Grosmont 'A'/'B' disposal zone is separated (i.e., hydraulically
isolated) from the Grosmont 'D' water source aquifer. Furthermore, in consideration of the aquitards that
overlie the Grosmont 'D' aquifer, principally the Clearwater Formation, the Grosmont 'A'/'B' disposal zone
is hydraulically isolated from the overlying non-saline aquifers and the surface resources such as surface
water.
Injection Capacity
Injection capacity is addressed in Volume 3, Section 1.6.1.2 of the Integrated Application. As stated, a
step injection test was performed on DW GROS 2-25 as per Alberta Energy Regulator (AER)
Directive 051 (Energy Resources Conservation Board [ERCB] 1994) requirements. A maximum pressure
3
of 7,000 kPa was reached at an injection rate of 2,300 m /d without any indication of formation fracturing.
In accordance with Directive 051, the maximum wellhead injection pressure assigned to the well by the
ERCB (AER) as per Class II Disposal Scheme No. 11703 was 6,300 kPa.
3
The maximum rate of wastewater production for the Project is estimated to be 4,742 m /d (Round 1
3
AESRD SIR 7, Figure 7-1). Based on the injection test rate of 2,300 m /d, it is expected that DW
GROS 2-25 and only one additional disposal well will be needed for the Project. BlackPearl is proposing a
total of three disposal wells for the Project to account for events where a disposal well is out of service for
well maintenance. Therefore, it is concluded that the injection capacity of the Grosmont 'A'/'B' disposal
zone will meet the requirements of the Project.
Hydrodynamic Flow Regime
The hydrodynamic flow regime of the Grosmont Formation is discussed in Volume 3, Appendix 1A, Pages
1A-62 and 1A-63 of the Integrated Application. In summary, the Grosmont Formation is a prominent
regional aquifer in northern Alberta. Information on regional groundwater flow in the Grosmont in a study
area centred in the Stony Mountain Uplands is presented in Barson et al. (2001). The Stony Mountain
Upland is a southwest-northeast oriented upland with the southwest part situated just east of the
Hydrogeology LSA. To the west and southwest of Fort McMurray, the Grosmont aquifer is considered to
be highly permeable due to dissolution cavities, collapse breccia, sinkholes and fractures. It is believed it
intercepts water seeping down from the overlying Mannville strata at the basin scale. Groundwater in the
Grosmont flows to the northwest (Bachu et al. 1993; Anfort et al. 2001). The Grosmont aquifer likely
discharges in the Peace River valley to the northwest of the Birch Mountains where the Grosmont
Formation crops out at an elevation of approximately 240 masl (Bachu et al. 1993).
The distribution of hydraulic heads for the undifferentiated Grosmont Formation in the Hydrogeology RSA
is shown on Figure 1A-46 (Volume 3, Section 1.0, Appendix 1A) in the Integrated Application. The
hydraulic heads are highest (greater than 360 masl) in the subcrop area in the eastern part of the
Hydrogeology RSA. Elsewhere, heads are generally in the range of 350 masl to 360 masl. This hydraulic
head distribution is similar to the distribution presented in Bachu et al. (1993) which shows the
potentiometric surface is relatively flat within the Hydrogeology RSA with head values in the range of
350 masl to 375 masl.
Water Quality Assessment
Refer to the above statements under Fluid Chemistry and Chemical Compatibility.
Concluding Comments
The use of the disposal well (DW GROS 2-25) at the Pilot Project was licensed by AER as per Class II
Disposal Scheme No. 11703. The two additional disposal wells to be drilled for the Project will have the
same design as DW GROS 2-25 and will be tested in accordance with AER Directive 051 requirements
(Volume 3, Section 1.6.1.2 of the Integrated Application). Any other requirements that may be specified
by AER will be met. Therefore, the use of the Grosmont 'A'/'B' disposal zone will meet all regulatory
requirements.
Page 28
13. b. Show how the fluid chemistry data obtained for the Lower 'A' and 'B' units of the
Grosmont Formation compare with the project fluid stream to be disposed in that
formation.
Response:
Although the chemistry data for the Grosmont ‘A’ and ‘B’ unit is not available, as stated in Round 2
AESRD SIR 13a, the chemical composition of the Grosmont ‘D’ can be used to infer what the chemistry of
the Grosmont ‘A’/‘B’ unit will be. Table 7.7-1 in Volume 1 of the Integrated Application shows that the
chemical makeup of the disposal stream is the same as the Grosmont ‘A’ and ‘B’, the concentrations are
what differ.
The reason for the higher concentrations of substances in the fluid streams sent for disposal than in the
source water is the design of the water recycling process at SAGD projects. The produced and make-up
water are treated to improve the water quality for steam generation (boiler feed water).
13. c. Indicate what BlackPearl is planning to do in case of significant differences between

the project fluid stream to be disposed of and the receiving formation fluid.
Response:
BlackPearl intends to dispose of the waste water stream shown in Table 7.7-1 in Volume 1 of the
Integrated Application, into the Grosmont ‘A’/’B’ and has no plans to alter the waste water steam
composition to more closely match the composition of the receiving formation fluid. Altering the waste
water stream is not a realistic or required option for the following reasons:
• BlackPearl has already received AER Directive 51 approval to disposal of the waste water from
our Pilot operations into the Grosmont ‘A’/‘B’ formation at the 100/02-25-076-18W4 well
(License # 0429413). The Grosmont ‘A’/‘B’ is the only suitable waste water disposal formation for
the commercial Project and will therefore continue to be used as our disposal formation. AER
Directive 51 (ERCB 1994) defines the criteria in which a waste water stream is suitable for
deepwell disposal. Based on the simulated composition of our disposal stream we will meet all
the disposal criteria for deepwell disposal;
• The reason for the concentrated levels is the design of the water recycling process at SAGD
projects. Whether it is a hot lime system like we have at Blackrod or an evaporator system, the
water treatment system treats the produced and make-up water to a boiler feed water
specification. In order to create this cleaned boiler feedwater stream there is a resulting waste
stream. The composition of the waste water disposal stream is a concentrated stream of the
components which are removed from the produced water and water makeup stream to achieve
boiler feed water quality required.
• Although we are not able to get an actual representative sample of the Grosmont ‘A’/‘B’ formation
water, as stated in Round 2 AESRD SIR 13a it is reasonable to assume that the composition will
be similar to the Grosmont ‘D’ formation, refer to Table 7.7-1 in Volume 1 of the Integrated
Application for compositions of these streams. As shown in Table 7.7-1, the waste water disposal
stream contains concentrated levels of the components that make up the receiving fluid
formation.
• The Blackrod waste water disposal stream contains no hydrocarbons.
The chemical makeup of the disposal stream is an approved AER deepwater disposal stream and the
disposal stream does not introduce any hydrocarbons into the receiving fluid formation, there is no need
to alter the waste water stream from its current form. With disposal streams there is always a risk of scale
precipitate therefore to maintain disposal well uptime, BlackPearl will monitor and manage scale
precipitate.
Page 29
13. d. Update the water management/disposal plan to reflect new data obtained from Lower
Grosmont 'A' and 'B' units.
Response:
Disposal of waste streams by deep well injection into saline aquifers in Alberta is managed by AER.
BlackPearl’s water management/disposal plan meets the criteria outlined for deep well disposal in AER’s
Directives 51 and 81 (ERCB 1994, AER 2012), which govern deep well disposal. Thus, the water
management/disposal plan has not changed. We have optimized our water management strategy,
including water source, treatment and disposal to comply with the Directive 81 guidelines.
14. ESRD SIR 1 Responses, Section 3.2, SIR 31, Pages 45 - 46
SIR 31 requests information on the groundwater model calibration. As part of the response to
the SIR, BlackPearl states that A steady-state calibration could not be performed due to the
lack of specific calibration targets in the model domain. The main issue for the model
calibration is the lack of target data in the Grosmont 'D' aquifer which is being simulated, with
only one head data point within the RSA. The request for additional data in the Grosmont
aquifer was not addressed and, therefore, SIR 31 was not addressed due to lack of data. The
SIR is restated.
Calibration is one of the most complex parts of applying groundwater models. Model
Calibration (Steady State and Transient State) is the most important component of groundwater
modelling protocol, especially when the model is used for predictive purposes. Basically, the
model must first be calibrated before it can be used to generate groundwater head
forecasts/predictions. That is, model parameters are adjusted until the simulation is consistent
with the analyst’s understanding of the groundwater system and all available data; computed
hydraulic head values should closely match measured values at selected points (observations
wells) in the aquifer. This means that a set of historical data is used to compare with the
generated groundwater heads derived by simulation. Analysis of the difference between
measured and computed heads gives an indication as to where adjustment of output
parameters may be necessary in order to minimize this difference. Therefore, the model needs
to be calibrated for both static (steady-state) and stressed (transient state) aquifer conditions.
The stressed condition will provide good determination of K, since model drawdown will not
match unless K is correct. This portion (calibration) of modeling protocol was not performed.
a. Provide steady state and transient state calibrations using data collected from the
Project area.
Response:
There is currently one water source well completed in the Grosmont ‘D’ saline aquifer (GROS 15-25).
Seven additional Grosmont ‘D’ wells are planned and all seven will be drilled within the Project Area
(Volume 3, Section 1.6.1.1 and Figure 1.6-1 of the Integrated Application).
A minimum of five observation points (wells) are needed for model calibration; therefore, model
calibration could not be completed at this time. Steady-state and transient calibrations will be undertaken
after the Grosmont ‘D’ well network has been expanded and the needed data have been collected. The
one existing Grosmont ‘D’ water source well has been licensed by AER and the additional wells will be
licensed by AER. The calibration results will be provided to AER if requested.
Page 30
14. b. Provide calibration results (scatterplots, calibration histograms, maps, contour patterns,
and assessment of input aquifer properties and boundary conditions).
Response:
The calibration results will be provided to AER if requested once sufficient data have been collected to
perform the calibration of the model as discussed in the response for Round 2 ERSD SIR 14a. Analysis
of the simulated hydraulic heads as compared to observed hydraulic heads will be performed at that time,
which will include residual head scatter plots, histograms of the residual heads, and simulated head
contour maps. A sensitivity assessment of model input parameters will be provided at that time.
14. c. Provide a thorough discussion describing the worst-case and best-case predictions.
Response:
The principal purpose of the groundwater model was to predict the extent of drawdown in the
Grosmont ‘D’ saline aquifer and any overlying groundwater aquifers as a result of groundwater
production.
To account for the uncertainty in the predictions, drawdown was simulated by applying two cases: the
“expected-case” and the “worst-case”. The expected-case, is sometimes described as the “best-case”.
Hydraulic conductivity and storage were the parameters that affected simulated drawdown in the model;
other model parameters did not have a significant effect on drawdown predictions. Hydraulic conductivity
was the parameter adjusted to create the best-case and worst-case scenarios. Storage was not adjusted
in the two cases since less information was available for Grosmont storage, therefore the worst-case
value was applied to both.
For the ‘best-case’ scenario, an expected value was used for the regional hydraulic conductivity of the
-5
Grosmont aquifer, 7.0 x 10 m/s, based on values presented in Worley Parsons (2011) (Volume 3,
Section 1.5.2.3 of the Integrated Application). For the worst-case scenario, a hydraulic conductivity value
-5
of 2.0 x 10 m/s was applied. This is half an order of magnitude lower than what was used in the ‘best-
case’ scenario. Applying a lower hydraulic conductivity value to the Grosmont aquifer increased the
predicted magnitude of drawdown.
Low specific storage values increase the rate at which drawdown impacts propagate from a source well.
-6 -1
For both modelled cases, a specific storage value of 5 x 10 m was used. This value was taken from a
regional model by WorleyParsons (2010), which encompassed the BlackPearl Project Area. Use of this
value is a conservative approach as it was the lowest published value found for the region, and is in the
-7 -1 -4 -1
low end of the range for typical values of aquifer specific storage in rock (10 m to 10 m ; Singhal and
Gupta 2010).
Applying conservative conductivity and storage values increased drawdown beyond what is expected,
providing a conservative assumption. The worst-case scenario increased drawdown by 3 times over the
expected-case (Volume 3, Sections 1.5.2.5 and 1.6.1.1 of the Integrated Application); thus demonstrating
that the worst-case scenario is more conservative than the expected-case. In our professional opinion,
the worst-case parameters applied are sufficient to account for parameter uncertainty and thus provide
conservative drawdown predictions that will exceed the expected values.
14. d. Discuss different assumptions made, and the impact of errors that may result from
these assumptions; provide a map showing areas that are most sensitive to these
errors and where aquifer parameter adjustment was required.
Response:
Page 31
Model calibration could not be completed at this time and, as a result, an assumption/error assessment
cannot be undertaken. This assessment will be performed once the calibration has been done (see
response to Round 2 AESRD SIR 14a). The results of the assessment will be provided to AER if
requested.
14. e. Provide a thorough discussion on the level of confidence BlackPearl has in the
assessment of impacts to groundwater given the lack of field data from the local study
area.
Response:
We are confident the model results provide a suitable, conservative prediction of potential groundwater
impacts due to groundwater source production from the Grosmont saline aquifer. As noted in the
response to Round 2 AESRD SIR 14c, it is our professional opinion that predicted drawdown impacts,
especially those from the worst-case model simulation, are greater than what is expected to occur from
actual pumping.
Drawdown predictions are most affected by the values of hydraulic conductivity and storage; therefore,
values of these parameters were the most important considerations for the model. Lower values for each
of these parameters will increase the predicted effects from groundwater extraction.
We expect that observed drawdown from actual groundwater extraction will be less than predicted by the
worst-case model scenario, since the hydraulic conductivity value used in the worst-case simulation was
lower than the regional estimates presented by Worley Parsons (2010). Specifically, the hydraulic
-5
conductivity applied to the Grosmont aquifer in the worst-case scenario was 2.0 x 10 m/s. This is a
-5
conservative value, as groundwater units with hydraulic conductivity values less than 2.0 x 10 m/s do not
readily transmit groundwater under typical hydraulic gradients, and therefore typically are not considered
aquifers. We are confident the model predictions account for reasonable model parameter uncertainty
and the lack of local data. The model predictions include conservative assumptions and are expected to
over-predict actual drawdown.
In addition to the model discussed above, a one-dimensional analysis was conducted to estimate the
propagation of drawdown effects to overlying hydrogeologic units. This model demonstrated no impacts
from Grosmont drawdown on overlying aquifers and surface features. We are confident this prediction
suitably simulates expected effects because situated between the Grosmost aquifer and non-saline
groundwater and surface water resources is the Clearwater Shale, which is a very low-permeability,
competent aquitard of considerably thickness (70 m to 80 m). Drawdown impacts to units and features
above the Clearwater are considered unlikely.
One objective of the modelling work was to assess the potential impact of Grosmont ‘D’ aquifer pumping
on shallower non-saline aquifers and surface resources (e.g., surface water) as a result of any increased
downward leakage to the Grosmont ‘D’ aquifer through the overlying aquitards. The simulations with the
3D model assessed the potential areal extent of any increased leakage (i.e., area of potential impact).
The simulation with the 1D model assessed the potential maximum magnitude of any increased
downward leakage (Volume 3, Section 1.6.1.1 of the Integrated Application). The results of the 1D
simulation showed that drawdown effects to the water table and surface features would be less than the
tolerance of the model (0.1 mm), which is lower than what could possibly be measured, and, therefore,
there would be no effects on the surface resources. These results were as expected considering the
characteristics of the aquitards that overlie the Grosmont ‘D’ aquifer (Volume 3, Section 1.6.1.1 of the
Integrated Application). In view of these characteristics, groundwater withdrawal from the Grosmont ‘D’
aquifer should not affect the Grand Rapids 'B' aquifer. Any pressure effects on the Grand Rapids 'B'
aquifer should be too small to measure and induced downward leakage would be negligible (Volume 3,
Section 1.6.1.1 of the Integrated Application). The shallower aquifers and surface resources are
hydraulically isolated from the Grosmont ‘D’ aquifer. Therefore, groundwater withdrawal from the
Page 32
Grosmont ‘D’ aquifer would not affect shallower aquifers or watercourses, fish/fish habitat, wetlands,
terrestrial or riparian vegetation and wildlife (Volume 3, Section 1.6.1.1 of the Integrated Application).
In summary, BlackPearl has a high level of confidence in the above impact assessments. Furthermore,
BlackPearl is confident that steady-state and transient calibration work will not change the results of the
assessment with respect to shallower non-saline aquifers and surface resources. Monitoring of the Grand
Rapids 'B' aquifer is currently underway for the Pilot Project and the monitoring program will be expanded
for the Project. The monitoring results will be reviewed to identify, among other things, the potential
effects of groundwater withdrawal from the Grosmont ‘D’ aquifer (Volume 3, Section 1.6.1.1 of the
Integrated Application).
15. ESRD SIR 1 Responses, Section 3.2, SIR 32, Pages 46 and 47
SIR 32 requests data on sensitivity analysis. As part of the response, BlackPearl states that
Without calibration target points, a sensitivity analysis would not produce meaningful results.
SIR 32 was not addressed due to lack of data. The SIR is restated.
Sensitivity analysis is a standard procedure for scientific evaluation and assessment of the
model’s response to parameter inputs. Typically a model after calibration and used to draw
conclusions about a physical hydrogeologic system, a sensitivity analysis must be performed to
identify which model inputs have the most impact on the degree of calibration and on the
conclusions of the modeling analysis. This portion (sensitivity analysis) of modeling protocol
was not performed.
a. Provide a sensitivity analysis of the calibrated model.
Response:
Model calibration could not be completed at this time and, as a result, a sensitivity analysis cannot be
performed. A sensitivity analysis will be provided to AER if requested once the calibration has been
completed (see response for Round 2 AESRD SIR 14a).
15. b. Provide an assessment on the impact of parameter uncertainty on model predictions,

and describe the percentage of variance contributed by each parameter in the
predictions for simulated cases.
Response:
The impact of parameter uncertainty was assessed for hydraulic conductivity (Volume 3, Section 1.5.2.5
of the Integrated Application). One hydraulic conductivity value was available for the Grosmont ‘D’ saline
-5
aquifer, which was 7 x 10 m/s. The uncertainty impact of conductivity was assessed by reducing its
value by half an order of magnitude, which is considered a conservative approach as drawdown impacts
will increase as a result. Reducing conductivity by this amount resulted in drawdown increasing from
8.3 m to 24.1 m, thus demonstrating that reduced conductivity is a conservative assumption for pumping
predictions (Volume 3, Section 1.6.1.1 of the Integrated Application). A more-detailed assessment of
parameter uncertainty will be provided to AER if requested once the calibration has been completed (see
response for Round 2 AESRD SIR 14a).
15. c. Explain an evaluation of used values since many reasonable combinations can history
match the observed data.
Response:
Page 33
Currently, only one observed water level and one hydraulic conductivity estimate exist for the
Grosmont ‘D’ saline aquifer. As no calibration and no sensitivity analysis can be performed at this time
(see responses to Round 2 AESRD SIR 14a and SIR 15a), there are no combinations of parameter
values to assess. However, a worst-case scenario was applied as discussed in the response for Round 2
AESRD SIR 14c. An evaluation of reasonable combinations of parameter values will be provided to AER
if requested once additional water level data and hydraulic conductivity estimates have been obtained
from the additional wells to be drilled for the Project (see response for Round 2 AESRD SIR 14a).
16. ESRD SIR 1 Responses, Section 3.2, SIR 33, Pages 47 and 48
SIR 33 requests additional information on the model grid spacing. As part of the response,
BlackPearl states that The model grid spacing represents the overall resolution of the surface
interpretations of the geology and groundwater flow. Therefore, the grid spacing does not
impact the drawdown predictions.
BlackPearl also states that During model development, grid spacing was tested and further
refinement did not result in improved drawdown predictions. It is noted that actual drawdown
data in the vicinity of the pumping wells are not available.
Proper grid spacing is important when modelling pumping/injection wells. Away from the wells,
coarse and fine grid will likely show identical drawdown but the drawdown will be quite different
close to the well (Reilly and Harbaugh 2004). Thus, local grid refinement around wells is
important. In general, regions of large variations in hydraulic gradient occurring over relatively
small spatial scales require refined-difference grid spacing for accurate simulations (Mehl et al.
2006).
Refinement is needed around the pumping wells for calibration as well as to predict accurate
drawdown for different scenarios. The actual model is not calibrated and therefore, not suitable
for predictive purposes (i.e., predictive drawdown).
a. Explain how the grid spacing was tested during the model development.
Response:
The model grid for the initial model set-up was 500 x 500 m as stated in Volume 3, Section 1.5.2.3 of the
Integrated Application. Since there were no pumping stresses applied, grid refinement was not
necessary.
The model grid was refined for the Baseline Case and Application Case predictive scenarios (Volume 3,
Section 1.6.1.1 of the Integrated Application) since pumping stresses were applied. This gave a more-
detailed representation of the drawdown gradients that occurred in the vicinity of the pumping stresses.
The grid spacing was refined to 200 x 200 m within the Project Area and further refined to 100 x 100 m at
the proposed water source wells. Further refinement beyond this would not result in a better depiction of
drawdown.
Page 34
16. b. Discuss how the impact of grid spacing on drawdown predictions was evaluated, since
the actual drawdown data in the vicinity of the pumping wells are not available.
Response:
See response to Round 2 AESRD SIR 16a.
Volume 3, Section 1.5.2.3, Page 1-14
Volume 3, Sections 1.5.2.4. and 1.5.2.6, Page 1-18
Volume 3, Section 1.5.2.4, Figure 1.5-3, Page 1-19
SIR 34 is related to the extension of the size of the model to the whole Grosmont 'D' aquifer,
which renders the results too general for any use within the RSA or the project area. The SIR
was not addressed properly due to lack of data for the model calibration within the RSA and the
Project Area and is, therefore, restated.
The layer which was modeled is the Grosmont aquifer D which is intended to be the water
source for the project. In this case, it was extended to the whole Grosmont mapping available
from the literature (Walker and Harrison 1985), which is over 4 times the size of the
hydrogeology RSA. The extension of the model to such a large area minimizes considerably
the prediction accuracy to a point that it becomes almost irrelevant within the RSA, the LSA
and the Project Area. The results of simulated head distribution shown on Figure 1.5-3 are too
general for any use within the RSA or the Project Area. Furthermore, data used for the model is
mainly obtained outside the RSA, and only one data point is available from the Project Area.
a. The active model domain should not be too broad to lack specific information relevant
to the RSA, LSA and Project Area. Review the model and its size to only reflect
specific information relevant to the RSA, LSA and Project Area.
Response:
The size of the model was intentionally designed so that model boundary conditions could be placed far
from the Project Area to avoid model boundaries biasing the model predictions. The predicted drawdown
in the Grosmont ‘D’ aquifer due to groundwater extraction extends beyond the RSA. Limiting the model
size to the RSA would cause the boundaries to affect the predicted drawdown, both in areal extent and
magnitude, because a static head value (groundwater level) must be specified at the model boundaries.
Therefore, placing specified head boundaries too close to pumping wells will artificially reduce drawdown
impacts, which is important to avoid.
Computer processing capacity is such that model size can be expanded beyond what was possible in the
past. Models covering a large area are no longer limited to a widely-spaced grid in order to save
computing time. As noted in the response to Round 2 AESRD SIR 16a, the model grid was refined
(i.e. close spacing) in the Project Area giving sufficient representation of the drawdown gradients that
occur in the vicinity of the pumping stresses. The model size and scale are appropriate for the
simulations.
The Hydrogeology RSA, LSA and Project Area are located in a remote part of northeast Alberta.
Currently, only one observed water level and one hydraulic conductivity estimate exist for the
Grosmont ‘D’ saline aquifer in the Hydrogeology RSA.
Page 35
17. b. Provide sufficient site specific data within the Project Area for accurate predictions in
the Project Area, the LSA and the RSA.
Response:
As noted in the response to Round 2 AESRD SIR 14a, there is currently one water source well completed
in the Grosmont ‘D’ saline aquifer within the Project Area. Additional site-specific data within the Project
Area will be obtained as the Grosmont ‘D’ well network is expanded.
17. c. Discuss the significance of the model results provided in Section 1.5.2.4 to the Project
Area, given the limitations and constraints connected with lack of data and the
extension of the model to the whole Grosmont aquifer.
Response:
See responses for Round 2 AESRD SIR 14e and SIR 17a.
Volume 3, Section 1.5.2.4, Page 1-18
In response to SIR 35 requesting additional information on the water balance for the model,
BlackPearl states that The water balance for the model (Volume 3, Section 1.5.2.4, Page 1-18
of the Integrated Application) did not vary significantly between model simulations for the two
scenarios.
a. Provide a detailed water balance for the transient model and discuss the results
(steady state versus transient state).
Response:
The flow budget of the model was presented in Volume 3, Section 1.5.2.4 of the Integrated Application.
Prior to pumping (i.e., steady-state), the flow budget was as follows:
Inflow:
3
• 21,700 m /d from the recharge boundary (top boundary);
3
• 40,200 m /d from the general head boundaries on the south side of the model; and
3
• 3,900 m /d from the general head boundary on the east edge of the model.
Outflow:
3
• 65,800 m /d leaves the model through the general head boundaries on the north side
of the model.
For the transient simulation for Baseline Case pumping, the flow budget of the model throughout the
simulation was as follows:
Inflow:
3
Page 36
3
• 40,200 m /d from the general head boundaries on the south side of the model;
3
• 3,900 m /d from the general head boundary on the east edge of the model; and
3
• Storage rates vary. Over the entire simulation, 298,500 m comes from storage,
matching pumping outflow (Volume 3, Figure 1.5-4 of the Integrated Application).
Outflow:
3
• 65,800 m /d leaves the model through the general head boundaries on the north side
of the model; and
3
• Pumping rates vary. Over the entire simulation, 298,500 m leaves through pumping
(Volume 3, Figure 1.5-4 of the Integrated Application).
For the transient simulation for Application Case pumping, the flow budget of the model throughout the
simulation was as follows:
Inflow:
3
3
• 40,200 m /d from the general head boundaries on the south side of the model;
3
• 3,900 m /d from the general head boundary on the east edge of the model; and
3
• Storage rates vary. Over the entire simulation, 26.2 x 106 m comes from storage
matching pumping outflow (Volume 3, Figure 1.6-2 of the Integrated Application).
Outflow:
3
• 65,800 m /d leaves the model through the general head boundary on the north side of
the model; and
3
• Pumping rates vary. Over the entire simulation, 26.2 x 106 m leaves through pumping
(Volume 3, Figure 1.6-2 of the Integrated Application).
Recharge is fixed and did not vary throughout the simulations. The inflow and outflow at the boundaries
located at the model edges do not vary throughout the Baseline and Application Case transient
simulations since drawdown impacts do not reach the boundaries during simulated time.
In response to SIR 36 requesting clarifications on parameter uncertainty and interpolations

between distant observation wells, BlackPearl states that Observation wells are not present in
the Hydrogeology RSA and, therefore, interpolations between distant observation wells were
not made. The SIR was not addressed and is, therefore, restated.
a. Given the uncertainty associated with the model input baseline data, explain measures
that will be taken to reduce this uncertainty.
Response:
Refer to the responses to Round 2 AESRD SIR 14a and SIR 15b. The additional wells in the Grosmont
‘D’ saline aquifer will be drilled sequentially as the Project expands through the three phases. The model
will be updated after each well is drilled and tested. In addition, each model update will include any data
Page 37
available for any other Grosmont ‘D’ wells drilled in the Hydrogeology RSA. These measures will reduce
parameter uncertainty.
19. b. Describe the level of parameter uncertainty and discuss the methods used for
evaluating uncertainty and the plans to resolve uncertainty due to data limitations.
Response:
As described in the response for Round 2 AESRD SIR 15b, an uncertainty assessment was performed
with the hydraulic conductivity parameter value that was available for the Grosmont ‘D’ saline aquifer.
This analysis resulted in a conservative prediction of drawdown impacts. After Project approval and once
more data are collected, parameter uncertainty will be further reduced (see response for Round 2 AESRD
SIR 19a).
19. c. Compare the importance of the variability in parameters and distribution to each input
parameter in the model and identify the critical inputs that introduce the greatest
uncertainty in performance predictions obtained with the model.
Response:
Assessing parameter uncertainty is important in order to obtain conservative predictions (i.e., predictions
tending towards a “worst-case” scenario based on the available data). Hydraulic conductivity was found to
have an impact on the drawdown predictions. As discussed in response to Round 2 AESRD SIR 15b, the
parameter assessment of hydraulic conductivity provides conservative predictions. Note that aquifer
parameters are uniform throughout the model domain (e.g., one hydraulic conductivity for the
Grosmont ‘D’ saline aquifer for the entire model domain). Since parameter values do not vary spatially at
this time, there was no distribution variability to be assessed. After Project approval, more data will be
collected and the uncertainty assessment (including a sensitivity assessment of the critical inputs) will be
revisited (see responses for Round 2 AESRD SIRs 15a and 15b).
20. ESRD SIR 1 Responses, Sections 3.2 and 3.3, SIR 42 and 50, Table 42-1, Pages 64, 65
and 79
In response to SIR 50b regarding water that may collect in the borrow pits, BlackPearl indicates
that the borrow pits will receive direct precipitation only. However, data provided in Table 42-1
indicates that the water levels in Quaternary formations are shallow, suggesting potential
groundwater water inflow from these formations into the borrow pit. This component was not
included in the discussion presented for SIR 50b.
a. Discuss the impact of potential groundwater inflow into the borrow pits, in addition to
direct precipitation, with regards to the hydraulic conductivities obtained from
monitoring wells installed in Quaternary formations at the current CPF location.
Response:
As described in response to Round 2 AESRD SIR 21, water table in the Project Area is located within the
-9 -9
clay till layer where hydraulic conductivity ranges from 1 x 10 m/s to 6 x 10 m/s and the estimated
average linear groundwater flow velocity is 6 cm per year. Therefore, groundwater contribution to borrow
pits is believed to be negligible.
Page 38
Even if groundwater does contribute to borrow pits, groundwater inflow collected in the borrow pits will not
be higher than the water table. As shown in Table 20-1, the observed depths to the water table (Depth to
Water in m below ground surface) range from greater than 8.2 m to 0.77 m with the shallowest recorded
at the monitoring well GMW-6 on August 9, 2011. The average annual precipitation is 0.46 m and the
historical maximum was about 0.68 m. Since the average annual evaporation is 0.58 m, the direct
precipitation will evaporate from the borrow pits in most years. Therefore, the borrow pits will have
sufficient storage to receive direct precipitation and will not spill.
TABLE 20-1
GROUNDWATER LEVEL
Depth Depth
to Ground Casing to
Water Elevation Stick-up Water
Location Date m bTOC m asl m ags m bgs
GMW-1 19-May-11 9.15 616.25 0.95 >8.2
GMW-1 02-Jun-11 9.15 616.25 0.95 >8.2
GMW-1 09-Aug-11 6.46 616.25 0.95 5.51
GMW-1 29-Nov-11 4.14 616.25 0.95 3.19
GMW-1 27-Feb-12 4.67 616.25 0.95 3.72
GMW-1 06-May-12 5.21 616.25 0.95 4.26
GMW-1 15-Nov-12 3.69 616.25 0.95 2.74
GMW-2 19-May-11 5.13 616.66 0.75 4.38
GMW-2 02-Jun-11 3.71 616.66 0.75 2.96
GMW-2 09-Aug-11 1.79 616.66 0.75 1.04
GMW-2 30-Nov-11 2.09 616.66 0.75 1.34
GMW-2 27-Feb-12 2.53 616.66 0.75 1.78
GMW-2 07-May-12 2.65 616.66 0.75 1.9
GMW-2 14-Nov-12 1.95 616.66 0.75 1.2
GMW-3 19-May-11 5.73 616.71 0.71 5.02
GMW-3 02-Jun-11 4.15 616.71 0.71 3.44
GMW-3 09-Aug-11 1.55 616.71 0.71 0.84
GMW-3 30-Nov-11 1.97 616.71 0.71 1.26
GMW-3 27-Feb-12 2.40 616.71 0.71 1.69
GMW-3 07-May-12 2.74 616.71 0.71 2.03
GMW-3 14-Nov-12 2.05 616.71 0.71 1.34
GMW-4 19-May-11 4.88 616.56 0.94 3.94
GMW-4 02-Jun-11 3.56 616.56 0.94 2.62
GMW-4 09-Aug-11 2.83 616.56 0.94 1.89
GMW-4 29-Nov-11 2.74 616.56 0.94 1.8
GMW-4 28-Feb-12 3.01 616.56 0.94 2.07
GMW-4 06-May-12 3.31 616.56 0.94 2.37
GMW-4 15-Nov-12 2.70 616.56 0.94 1.76
GMW-5 19-May-11 5.21 616.6 0.88 4.33
GMW-5 02-Jun-11 3.65 616.6 0.88 2.77
GMW-5 03-Jun-11 - 616.6 0.88 -
GMW-5 09-Aug-11 1.93 616.6 0.88 1.05
GMW-5 30-Nov-11 1.67 616.6 0.88 0.79
GMW-5 06-May-12 Frozen 616.6 0.88 Frozen
GMW-5 14-Jun-12 nm 616.6 0.88 nm
GMW-5 15-Nov-12 1.75 616.6 0.88 0.87
GMW-6 19-May-11 3.23 616.31 0.84 2.39
GMW-6 02-Jun-11 Frozen 616.31 0.84 Frozen
GMW-6 09-Aug-11 1.61 616.31 0.84 0.77
Page 39
TABLE 20-1 Cont'd
Depth Depth
to Ground Casing to
Water Elevation Stick-up Water
Location Date m bTOC m asl m ags m bgs
GMW-1 19-May-11 9.15 616.25 0.95 >8.2
GMW-6 29-Nov-11 1.67 616.31 0.84 0.83
GMW-6 28-Feb-12 1.75 616.31 0.84 0.91
GMW-6 06-May-12 2.21 616.31 0.84 1.37
GMW-6 15-Nov-12 1.85 616.31 0.84 1.01
GMW-7 19-May-11 5.39 616.24 0.7 4.69
GMW-7 02-Jun-11 3.89 616.24 0.7 3.19
GMW-7 09-Aug-11 2.96 616.24 0.7 2.26
GMW-7 29-Nov-11 2.30 616.24 0.7 1.6
GMW-7 27-Feb-12 2.52 616.24 0.7 1.82
GMW-7 07-May-12 2.74 616.24 0.7 2.04
GMW-7 14-Nov-12 2.20 616.24 0.7 1.5
GMW-8 19-May-11 >6.28 613.59 0.79 >5.49
GMW-8 02-Jun-11 6.19 613.59 0.79 5.4
GMW-8 10-Aug-11 3.84 613.59 0.79 3.05
GMW-8 29-Nov-11 2.32 613.59 0.79 1.53
GMW-8 27-Feb-12 3.00 613.59 0.79 2.21
GMW-8 06-May-12 3.45 613.59 0.79 2.66
GMW-8 14-Nov-12 2.11 613.59 0.79 1.32
GMW-9 19-May-11 >6.5 614.86 0.91 >5.59
GMW-9 02-Jun-11 >6.5 614.86 0.91 >5.59
GMW-9 10-Aug-11 2.82 614.86 0.91 1.91
GMW-9 29-Nov-11 3.31 614.86 0.91 2.4
GMW-9 27-Feb-12 3.60 614.86 0.91 2.69
GMW-9 06-May-12 3.96 614.86 0.91 3.05
GMW-9 14-Nov-12 3.18 614.86 0.91 2.27
GMW-10 19-May-11 >6.38 612.44 0.89 >5.49
GMW-10 02-Jun-11 6.21 612.44 0.89 5.32
GMW-10 10-Aug-11 4.03 612.44 0.89 3.14
GMW-10 29-Nov-11 3.29 612.44 0.89 2.4
GMW-10 27-Feb-12 3.53 612.44 0.89 2.64
GMW-10 06-May-12 3.33 612.44 0.89 2.44
GMW-10 14-Nov-12 2.79 612.44 0.89 1.9
Notes: - nm = not measured.
- bTOC = below top of casing.
- ags = above ground surface.
- bgs = below ground surface.
- Only water levels were measured during May 2011, following well installation.
- At GMW-5, water levels were measured on June 2, 2011, while other parameters were measured on
June 3, 2011.
Page 40
ESRD acknowledges the data provided for SIR 42 with regards to the wells completed in
Quaternary formations at the Pilot Project CPF. However, hydraulic conductivities obtained
from those wells were not provided. The request for additional monitoring wells in Quaternary
formations to cover other parts of the Project Area was not addressed by the response to SIR
42b.
a. Provide slug test data, hydraulic conductivities, hydraulic gradients and flow velocities
obtained in Quaternary formations from the wells installed at the CPF area.
Response:
It is assumed that the CPF referred to in the request is that for the Pilot Project. Hydraulic conductivity,
-9 -9
estimated at each of the shallow monitoring wells, ranges from 1 x 10 m/s to 6 x 10 m/s (Table 21-1),
which is typical of clay. For a conservative estimate of average linear groundwater flow velocity, the
highest observed gradient from monitoring that occurred November 2012 (Round 1 AESRD SIR 42,
Figure 42-2), 0.06 m/m, was used along with the maximum estimate of hydraulic conductivity and an
effective porosity of 20%. The resulting conservative estimate of average linear groundwater flow velocity
is 6 cm per year.
TABLE 21-1
ESTIMATES OF HYDRAULIC CONDUCTIVITY FOR SHALLOW

SURFICIAL DEPOSITS AT THE PILOT CPF
Estimate of
Depth to Base Hydraulic
of Screen Conductivity
Monitoring Well (mbgs) (m/s)
-9
GMW-1 8.20 1 x 10
-9
GMW-2 5.35 4 x 10
-9
GMW-3 5.17 2 x 10
-9
GMW-4 5.56 6 x 10
-9
GMW-5 5.55 3 x 10
-9
GMW-6 4.53 4 x 10
-9
GMW-7 5.54 4 x 10
-9
GMW-8 5.49 1 x 10
-9
GMW-9 5.59 4 x 10
-9
GMW-10 5.49 4 x 10
Note: mbgs – metres below ground surface
For the Commercial Project CPF, the construction phase will be two years from clearing/grubbing to CPF
commissioning. All Quaternary monitoring wells will be installed prior to commissioning. Once installed,
further baseline data including groundwater chemistry data, hydraulic conductivities, hydraulic gradients
and flow velocities will be obtained.
Page 41
3.3 Hydrology
BlackPearl was requested for further clarification on monitoring to ensure hydrological

connectivity was maintained, given BlackPearl’s stated mitigation approach of culvert
installation every 400 metres. BlackPearl’s responses focus on the monitoring and
maintenance of the culverts themselves, and response 45c circles back to why the original
question was generated, stating BlackPearl expects that its drainage plan will provide adequate
hydrologic connectivity. Roads, pads and other infrastructure can interrupt the surface and
shallow sub-surface flow resulting in changes to wetlands, upland habitat and headwater flow
to watercourses.
a. How will BlackPearl monitor to confirm that hydrologic connectivity is maintained and
that the stated mitigation approach is sufficient to ensure wetlands, uplands and
headwater drainage habitat function potentially interrupted by facilities is retained?
Response:
Culvert installation every 400 metres on access roads is a general guideline. A drainage plan has been
developed and included in the Integrated Application (Volume 3, Appendix 2A, Figure 2.9-2) and updated
in the Round 1 SIR Project Update (Figure 2.5-2). The plan shows key locations of culvert installation in
order to maintain hydrological connectivity and post-development flow paths which is generally consistent
with the existing drainage pattern.
The monitoring plan to be implemented by BlackPearl is described as follows:
1. Visual inspection will be undertaken during the spring runoff of each year.
2. Observations to be made and documented shall confirm that:
a) the ditches flow in the direction as designed;
b) the ditches are not likely to be overtopped (the ditch sizes are adequate);
c) the ditches are not eroded or blocked;
d) the culverts flow in the direction as designed;
e) the culvert sizes are adequate (water is not ponded on upstream of the culvert);
f) no severe erosion occurs upstream or downstream of the culverts; and
g) the culverts are not blocked or damaged.
3. Observed problems will be reported to the Project engineer for further assessment. A remediation
plan will be developed and implemented, as required.
4. If observed problems are related to carrying capacity of culverts/ditches or insufficient erosion

protection design, further investigation will be carried out by qualified professionals and a
remediation plan will be developed and implemented, as required.
Page 42
22. b. Provide a conceptual plan describing what will be monitored, when, how frequently,
and how the results will be assessed and reported.
Response:
See response to Round 2 AESRD SIR 22a.
22. c. Describe any additional mitigation that might be implemented in the event that culvert
placement every 400 metres is insufficient to retain hydrologic connectivity.
Response:
Although unlikely, in the event that culvert placement every 400 m is deemed insufficient, the mitigation
and monitoring plan identified in Round 2 AESRD SIR 22a would not change.
3.4 Surface Water Quality

In the original question, reference was made to BlackPearl’s discussion of surface water quality
and vegetation monitoring. BlackPearl provides a response related to water quality monitoring;
but, doesn’t discuss vegetation monitoring. Refer to the original question and provide this.
Response:
The original question reads: “In a discussion of surface water quality and vegetation monitoring,
BlackPearl indicates If substantial negative impacts are detected, remedial measures will be
implemented.
a. Provide the criteria and decision points BlackPearl will use to determine whether negative
impacts are ‘substantial’, and whether to implement remedial measures.”
The criteria for a substantial negative effect to vegetation will vary depending on if the effect relates to the
effectiveness of progressive revegetation efforts, wetland reclamation, weed control or effectiveness of
rare plant and rare ecological community mitigation.
The focus of revegetation efforts will be the restoration of equivalent capability. Under the Environmental
Protection and Enhancement Act, it is required that the target post-reclamation land capability and the
proportions of the different capability classes within the Project Area be equivalent to that of pre-
development conditions. Re-established vegetation must be in compliance with the most current
reclamation criteria (at the time of reclamation). At the decommissioning and reclamation phases, site-
specific reclamation targets will be defined and revegetation activities to achieve these targets will be
implemented to complement natural colonization of vegetation. During the closure phase, BlackPearl will
monitor vegetation establishment, composition, abundance and structure within the reclaimed sites post-
reclamation until it can be determined that successional trajectories have been established. Therefore,
the criteria for revegetation are that vegetation must meet the criteria of equivalent capability, current
reclamation criteria must be met as well as successional trajectories. If these criteria are not being met
remedial measures will be recommended to address these impacts.
For locations where the target end land use is wetland, BlackPearl will monitor water quality, hydrology
(e.g., impedance and/or drainage due to construction and restored connectivity between wetland
complexes) and vegetation within the reclaimed wetlands post-reclamation until it can be determined that
successional trajectories towards no-maintenance self-sustaining wetland vegetation communities have
Page 43
been established and hydrological regimes that can support the appropriate wetland processes are
retained. The criteria that need to be met in regards to surface water quality were described in Round 1
AESRD SIR 51. For each class of wetland present within the LSA, BlackPearl will select benchmark
wetlands that were not directly affected by the Project and refer to site-specific baseline information to
compare with the monitoring results. The goal is for reclaimed wetlands to naturally revegetate to a
wetland vegetation community comparable to baseline condition and benchmark wetlands of the same
class. Restoring hydrological function is the most important environmental factor in controlling plant
community structure (Graf 2009). If monitoring results indicate that localized surface water hydrology has
been impacted, or that hydrology has been altered (visible as excessive surface water ponding or
stressed vegetation) remedial measures will be implemented to correct this impact. If target vegetation
does not naturally recolonize the reclaimed wetland, plants may be introduced by a variety of means. The
key criteria for wetland reclamation with respect to vegetation are the restoration of hydrological function,
the replacement of the preserved seedbank and the natural regeneration of wetland plants. If these
criteria are not being met then remedial measures will be recommended to address these impacts.
Weed control efforts will focus on weeds which are designated as Prohibited Noxious or Noxious under
the Weed Control Act. However, other invasive species, where they are abundant, may also require
management. BlackPearl is committed to undertaking weed and invasive species management and
control throughout the life of the Project in accordance with the Alberta Weed Control Act and ASRD’s
Weed Management in Forestry Operations (ASRD 2001). According to the Alberta Weed Control Act,
Prohibited Noxious weeds are those that must be destroyed and Noxious weeds are those that must be
controlled. Disturbed areas will be monitored during all phases of the Project for areas of prolific weed
growth. Measures to control weeds at identified locations will be conducted. Any weeds listed as
Prohibited Noxious or Noxious or by the municipality will be controlled in a timely manner to prevent the
spread of the weed. Therefore, the criteria used to determine if remedial weed control measures will be
implemented are the presence of Prohibited Noxious or Noxious species as well as areas of prolific weed
growth.
Post-construction monitoring may be recommended for some rare ecological communities or rare plant
populations, depending on the type of mitigation recommended. For example, any populations or
communities which are avoided by the Project will not be recommended for monitoring. Applied mitigation
measures will be considered successfully resolved when the affected population or community is
observed. Applied mitigation measures will be considered unsuccessfully resolved when the population
was expected to be present based on the size of the original occurrence and the timing of monitoring
(seasonal timing as well as number of years following construction), yet was not observed. During post-
construction monitoring if issues related to rare ecological communities or rare plants remain unresolved,
additional monitoring may be recommended since population viability and mitigation success may be
difficult to determine in the short-term (particularly due to annual climatic fluctuations). If threats to the
population are identified, then site-specific remedial measures may be recommended. These remedial
measures could include repair of flagging/fencing, spot weed control, erosion control, adjustments to
surrounding areas to ensure that existing drainage patterns and moisture regimen are maintained or
additional plant propagation/transplanting. The criteria used to determine if remedial measures to address
unresolved impacts to rare ecological communities or rare plants are that the population or community is
on a trend of decreasing viability which is related to a detectable causal relationship. For example, if
erosion, prolific weeds or changes to site moisture conditions are affecting the ability of the species or
community to persist at the site then remedial measures will be recommended. If the causal relationship
is not detectable then further monitoring will be recommended.
Page 44
24. ESRD SIR 1 Responses, Section 3.4, SIR 55, Response a, Page 86
BlackPearl’s response states that According to Figure 2 of the Alberta Acid Deposition
Management Framework (AENV 2008), the Project Area is located within a “high” receptor
sensitivity area. Therefore, the Project Area is assumed to be subject to the Potential Acid Input
(PAI) monitoring load level of 0.17 keq H+/ha/yr for sensitive grid cells.
In Volume 3, Appendix 3A, Section 3A.5.3, Page 3A-17, BlackPearl states, The baseline data
suggests that the surface waters in the LSA and RSA have a high capacity for neutralizing
acidifying compounds and will not be significantly impacted by acid deposition as a result of the
Project.
a. Describe the source of the buffering capacity of the surface waters in the LSA and RSA
given that the project area is within a high receptor sensitivity area.
Response:
BlackPearl has confirmed that the site is located within a “high” receptor sensitivity area and will apply
management for a high receptor sensitivity level as per Figure 2 of the Alberta Acid Deposition
Management Framework (Alberta Environment [AENV] 2008).
BlackPearl recognizes that although the site is located within a ‘high’ sensitivity area, baseline water
chemistry data within the LSA and RSA indicate that surface waters may have a high capacity for
buffering. Sensitivity of Alberta Lakes to acidifying deposition: an update of sensitivity maps with
emphasis on 109 Northern Lakes (Government of Alberta 1996) provides a refined representation of the
sensitivity of Alberta Lakes, compiles data and documents and evaluates the chemical analysis used in
determining sensitivity. One of the chemical analyses the report evaluates is the total alkalinity of surface
waters. The report states that highly sensitive water would have alkalinities between 0 and 10 mg/L as
CaCO3. Moderately sensitive would have alkalinities between 11 and 20 mg/L, and low sensitivity would
have alkalinities between 21 and 40 mg/L. Baseline data for the site shows an alkalinity range of 16 to
310 mg/L as CaCO3, with an average of 67 mg/L. This would indicate that the surface waters within the
site would have a moderate to high buffering capacity (medium to low receptor sensitivity).
BlackPearl will take a conservative approach to the management of acid deposition and will apply
management practices for a high receptor sensitivity area as indicated in the Alberta Acid Deposition
Management Framework.
3.5 Aquatics
BlackPearl was requested for a map of proposed pipeline routes for the natural gas and
bitumen-diluent pipelines. BlackPearl’s response indicates that several options are being
considered and a map was not provided. Provide a map of the proposed options.
Response:
At this time, BlackPearl does not have enough detail on the proposed pipeline route options to provide a
figure showing route alignments or tie-in points. Instead, the general region in which the pipelines may
occur is presented in Figure 25-1. The fuel gas, diluent-bitumen and diluent pipelines will not cross the
Athabasca River. All proposed pipelines will be routed to the east of the Project Area. The fuel gas
pipeline is anticipated to be approximately 30 km in length and the diluent-bitumen and diluent pipelines
could range from 30 km to 100 km in length, depending on the company selected to construct the
pipelines. Ongoing expansion of other pipeline and SAGD developments in the region mean that potential
pipeline route alignments and tie-in location options are continually evolving and will be closely evaluated
by BlackPearl at an appropriate time in the future.
Page 45
The fuel gas supply for the Project will be from a pipeline connected to the TransCanada gas system
located in the vicinity of the Highway 63 corridor. The exact route for the fuel gas pipeline has not been
determined, however it is not anticipated to cross any named watercourses. Dependant on the proposed
alignment of the diluent and diluent-bitumen pipelines, these pipelines may cross 4 named watercourses,
including House River, May River, Sunday Creek and Logan River.
All recommendations and mitigation measures for watercourse crossings that may be encountered along
potential pipeline routes will be developed in accordance with all current and applicable industry
standards and best management practices, including but not limited to, the construction standards
rd
outlined in the guide for Pipeline Associated Watercourse Crossings, 3 Edition (Canadian Association of
Petroleum Producers et al. 2005), any applicable Department of Fisheries and Oceans (DFO) best
practices and/or mitigation measures outlined in the Measures to Avoid Causing Harm to Fish and Fish
Habitat (DFO 2013) and the Code of Practice for Pipelines and Telecommunication Lines Crossing a
Water Body (AENV 2000a) and Code of Practice for Watercourse Crossings (Alberta Government 2013).
Potential mitigation measures for watercourse crossings may also include those relevant mitigation
measures that are listed in Volume 3.0, Section 4.7.1 of the Integrated Application.
Page 46
19 18 17 16 15 14 13 12 11 85 9 8 7 6
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Hamlet Road
Area of Potential
Indian Reserve FIGURE 25-1
Pipeline Corridor
Lac la Biche AREA OF POTENTIAL PIPELINE CORRIDOR
Existing Pipelines Watercourse Project Area Waterbody
Ward Lake Missawawi Lake
AESRD SIR 2 RESPONSES - BLACKPEARL RESOURCES INC.
Railway Military Boundaries PROPOSED BLACKROD COMMERCIAL SAGD PROJECT
UTM Zone 12N
Pipelines: IHS Inc. 2013; Roads: Natural Resources Canada 2013; Railways: US National Imagery and Mapping Agency 2000;
SCALE: 1: 750,000
km
Hydrography: US National Imagery and Mapping Agency 2000 & ESRI 2005; Settlements: AltaLIS 2013;
Municipalities: AltaLIS 2013; Indian Reserves: Gov. of Canada 2013; 0 5 10 15 20
December 2013
t6790_Figure_25_1_Area_of_Potential_Pipeline_Corridor_0823.mxd
26. ESRD SIR 1 Responses, Section 3.5, SIR 64, Response f, Page 102
ESRD SIR 1 Responses, Section 3.5, SIR 68, Response c, Page 107
BlackPearl indicates with respect to crossing monitoring and mitigation, …at a minimum, the
crossing site will be inspected annually during the snow free season and more frequently on
culvert crossings located in areas of high beaver activity or until permanent erosion control
measures are established.
a. Confirm whether all crossings will be monitored, at a minimum, annually for the life of
the project.
Response:
BlackPearl has committed to inspecting watercourse crossings on an annual basis, at a minimum, for the
life of the Project.
27. ESRD SIR 70, Page 108.
BlackPearl was asked to identify when it would not be practical to embed a culvert, in response
to the statement in Volume 3, Section 4.7.1, Page 4-19: If practical, embed the culvert in the
waterbody bottom so that the culvert bottom is covered with natural substrate. BlackPearl
indicates it would not be practical when bedrock is present.
a. Discuss if bedrock is present at the BlackPearl BlackRod site, and map any places
where culverts might be installed on bedrock.
Response:
Volume 3, Appendix 1A, Section 1A.4.3 of the Integrated Application indicates the depth to bedrock
(based on the thicknesses of clay till) at OSE wells drilled in and around the Project Area ranges from
35 m to 70 m (see also Volume 3, Appendix 1A, Figures 1A-5 and 1A-6 of the Integrated Application).
Bedrock is not present at any proposed watercourse crossings (Volume 4, Appendix 4A,
Section 4A.3.1.4, Figure 4A-5 of the Integrated Application).
27. b. Clarify whether all culverts will be embedded. Describe which culverts would not be
embedded and why.
Response:
All culverts will be embedded, as stated in Volume 3, Section 4.7.1 of the Integrated Application.
Page 48
28. ESRD SIR 1 Responses, Section 3.5, SIR 71, Page 108 – 109
BlackPearl describes the precautionary approach taken in the EIA to assume all watercourses
and waterbodies were fish bearing. Yet, this precautionary approach has not been extended to
watercourse crossings since culverts are proposed for fish-bearing waters. Watershed
fragmentation associated with culverts use has been well documented. BlackPearl indicates it
will follow guidelines, measures and BMPs for aquatic and biological assessments stated in the
Codes of Practice for watercourse crossings, pipelines, and telecommunication lines.
BlackPearl indicates it will request a case-specific review by DFO for the proposed crossings
where fish habitat is present. BlackPearl also indicates additional sampling will be undertaken
by a QAES at proposed watercourse crossings to determine fish presence and fish habitat
potential.
a. Describe any conversations BlackPearl has had with the local fish biologist regarding
watercourse crossings and identify how any advice provided has been considered.
Response:
Black Pearl has engaged AESRD biologists at various planning stages throughout the Project
development, including a Project overview meeting with senior AESRD staff on January 31, 2012. Project
location, overview and preliminary aquatics and fisheries baseline data was discussed. There were no
specific concerns raised by the AESRD biologists regarding the existing access road and watercourse
crossings at this meeting. Black Pearl has been in contact with local AESRD fish biologists since this
meeting regarding various aquatics topics (i.e., historical fisheries information and distribution,
commercial, recreation and aboriginal fisheries use; and classification and restricted activity periods of
watercourses); however, watercourse crossings have not been specifically discussed to-date. Where new
crossing structures are required, Black Pearl will conduct appropriate correspondence with the local
AESRD fisheries biologist.
28. b. How have current peer-reviewed aquatic fragmentation conclusions been considered in
BlackPearl’s decision to use culverts as a watercourse crossing method in fish-bearing
waters?
Response:
A discussion of peer-reviewed literature on aquatic fragmentation can be found in Volume 3,

Section 4.7.4 of the Integrated Application. This information, in conjunction with the fish and fish habitat
information described in Volume 3, Section 4.6.1 of the Integrated Application and the parameters
detailed in Round 1 AESRD SIRs 64e and 68b, was incorporated into the decision making process for
watercourse crossings. Design, installation and monitoring components as described in Volume 3,
Section 4.7.1 of the Integrated Application, Alberta Transportation Fish Habitat Manual (Alberta
Transportation 2001), Government of Alberta Roadway Watercourse Crossing Inspection Manual
(GOA 2012) and the Government of Alberta Code of Practice for Watercourse Crossings (Alberta
Government 2013) were also incorporated.
Page 49
28. c. BlackPearl states several times that a DFO case-specific review will be requested in
the event fish habitat is present. This is interpreted as meaning that where fish habitat
is determined to be absent, BlackPearl will not request a DFO case-specific review.
BlackPearl was asked for a clear description of what data will be collected and how a
watercourse will be determined to be non-fish-bearing prior to undertaking crossing
construction. BlackPearl‘s response identified presence of fish habitat will be
determined by a number of physical channel characteristics, including water quality
parameters, condition of the channel (e.g. dry channel), stream gradient, substrate size
and type, channel geomorphic units, and potential barriers to fish passage. Fish
inventories will also be conducted to assist in determining which species are present.
Watercourses in the northern Alberta are often used episodically by local fish
depending on local hydrologic and water quality conditions. The response indicated
data types to be collected; but, did not describe how a watercourse will be determined
to be non-fish-bearing. Provide the criteria to be used (e.g. statistical absence,
downstream barrier such as a waterfall – note that beaver dams are not considered
complete or permanent barriers to fish) to determine a watercourse is non-fish bearing.
Describe how these criteria would be used to determine a watercourse is non-fish-
bearing.
Response:
DFO has initiated measures to streamline its review process by releasing a self-assessment tool for
proponents to determine if DFO requires review of projects near water. The self-assessment tool outlines
types of waterbodies and project activities and criteria where DFO review is not required. If a project
meets the criteria of the self-assessment, no further review by DFO or notification to DFO is required.
However, proponents are still required to comply with the Fisheries Act by following the best practices
and mitigation measures outlined in the Measures to Avoid Causing Harm to Fish and Fish Habitat (DFO
2013). The self-assessment tool replaces all “Operational Statements” and notification to DFO under the
Operational Statements.
As discussed in Round 1 AESRD SIR 71 and the methodology described in Volume 3, Section 4A.6.3 of
the Integrated Application, all watercourses were considered fish-bearing and ratings of fish habitat
potential were used to classify tributaries within the LSA as high or low quality habitat as shown in
Volume 3, Section 4.7.1, Figure 4A-3 of the Integrated Application. For clarity, where a proposed
watercourse and/or crossing type is not a listed project activities or waterbody type where DFO review is
not required, a DFO case-specific review of the proposed crossing method will be requested. The
appropriate approval will be obtained and fisheries assessments will be completed at each proposed
watercourse crossing. The relevant regulatory authorities will be consulted, as needed, to determine the
appropriate watercourse crossing method in consideration that watercourses in the Project Area may be
used episodically by local fish.
29. ESRD SIR 1 Responses, Section 3.5, SIR 76, Page 111 - 113
In the question pre-amble, specific reference is made to the predicted cumulative population
and its likely influence on regional angling pressure and potential impacts to fisheries
resources. Although BlackPearl describes the existing fishing pressure at a broader scope, it
limits the assessment to the incremental impact of the project.
a. Characterize the expected increased regional fishing pressure and potential impacts to
fisheries resources.
Response:
The expected increase in regional fishing pressure in Round 1 AESRD SIR 76 was calculated based on
the projected less than 1% population increase within the Socio-economic RSA that could be attributed to
Page 50
the Project (i.e., direct, indirect and induced workers; see Volume 5, Sections 5.5.1 and 5.6.2 of the
Integrated Application) as well as known future developments. To address cumulative impacts to fishing
pressure at an even broader scope, BlackPearl has taken a greater conservative approach and
considered the total expected population increase for the Socio-economic RSA (as depicted in Volume 5,
Section 5.0, Figure 5.2-1 of the Integrated Application), estimated to 2050. Using expected population
increase projections and census data from 2011 as presented in Volume 5, Section 5.4.4 of the
Integrated Application, the total population increase within the Socio-economic RSA was calculated to be
approximately 26%. Given the provincial angling rates in each watershed unit, as discussed in Round 1
AESRD SIR 76, the projected 26% total population increase may lead to an increase of fishing pressure
of 0.598-0.936% in PP2, 0.0962-0.1508% in NB1 and 0.0234-0.0364% in NB4.
As discussed in Volume 3, Section 4.7 of the Integrated Application, the potential residual effects of
increased fishing pressures in the vicinity of the Project are long-term in duration since the effects from
increased access (i.e., increased off-road vehicle access) and angling by Project operation personnel will
be experienced during Project operation. With the application of the mitigation strategies aimed at
deterring Project personnel from fishing (Volume 3, Section 4.7.1 of the Integrated Application), the
residual effect of increased fishing pressures is anticipated to be reversible and of low magnitude.
Consequently, the potential residual effect of increased fishing pressure on fish mortality or injury as a
result of the Project and existing activities is not significant for the Application Case (Volume 3, Section
4.7, Table 4.7-2, point [3c] of the Integrated Application). However, as per the Introduction and
Assessment Methodology Section (Volume 2, Section 1.0 of the Integrated Application), a planned
development case (PDC) assessment is only completed for an indicator when the Application Case
assessment indicates the effect is likely to occur. Given that the potential residual effects associated with
increased fishing pressures is of low probability (i.e., unlikely to occur) for the Application Case, a PDC
assessment for these potential residual effects on aquatic resources is not warranted. In the unlikely
event that the potential residual effect associated with increased fishing pressure occurs, the effect is
expected to be long-term in duration (longer than 10 years), occasional in frequency, reversible and
negligible (not detectable) to low (well within environmental, social and/or regulatory standards) in
magnitude at the PDC assessment level. Since the residual effect of increased fishing pressure
associated with the Project, future developments and estimated future regional population increases (as
discussed above) is expected not to threaten the integrity of fishing resources and be within manageable
levels, it is considered not significant.
29. b. BlackPearl states on page 112, With the projected population increase of less than 1%
due to project development, it is anticipated that the effects on the present angling
statistics and target species will be considerable. Please clarify.
Response:
The sentence on page 112 as described above is erroneous. The sentence should read With the
projected population increase of less than 1% due to project development, it is anticipated that the effects
on the present angling statistics and target species will not be considerable.
Page 51
30. ESRD SIR 1 Responses, Section 3.5, SIR 77, Page 113.
BlackPearl indicates that watercourses were determined to have a defined or undefined

channel based on NTS 1:50,000 maps, DEM data, and additional hydrography obtained from
1:20,000 scale Alberta SDW maps.
a. Confirm whether this assessment will be ground-truthed prior to the finalization of

project infrastructure locations.
Response:
Watercourses and waterbodies identified using NTS 1:50,000 maps, DEM data, and additional
hydrography obtained from 1:20,000 scale Alberta SDW maps will be ground-truthed prior to finalization
of infrastructure locations.
30. b. Identify whether infrastructure locations will be revised using ground-truthing to ensure
a 100 metre setback is maintained from all defined channels as measured from the top
of the escarpment to the edge of disturbance.
Response:
See response to Round 2 AESRD SIR 11b.The locations of infrastructure may be modified as necessary
based on the results of a more in-depth ground-truthing. In the absence of a clear escarpment break, the
setback will be measured from the normal high water mark.
BlackPearl was requested to revise the RSA to better describe regional influences on aquatic
resources.
a. Revise the RSA, considering the extent of any potential drawdown effects, the
migration distances/full life history requirements of local fish species and the broader
watershed boundary/boundaries associated with these migration distances/full life
history requirements.
Response:
The Aquatic Ecology RSA was selected as the area where the direct and indirect influence of other land
uses and activities could overlap with Project-specific effects and cause cumulative effects on aquatic
habitat and resources, as discussed in Volume 3, Section 4.3.2 of the Integrated Application and Round 1
AESRD SIRs 78 and 82. The Aquatic Ecology RSA encompasses the LSA as well as those portions of
the Athabasca River immediately downstream from the drainage basins located within the LSA (see
Volume 4, Appendix 4A, Section 4A.3.1 of the Integrated Application). The LSA boundary was based on
the area where Project-specific effects are most likely to occur, and then extended beyond the anticipated
zone of influence (ZOI) to the boundary of all drainages where individual effects of multiple Project
crossings and acid deposition could combine. As such, the LSA is delineated to address both local and
regional scale effects on aquatic resources in order to capture the combined effects of multiple crossings
and acid deposition.
The shared boundary of the Aquatic Ecology LSA and RSA delineates the full outer extent of Drainages A
through E, which are entirely encompassed within the LSA and RSA. There is no direct connectivity
Page 52
between these drainages and the Duncan Creek, House River or Agnes Creek drainages beyond the
extent of the LSA and RSA. Therefore, there is no potential for the Project to interact with other activities
in those drainages or beyond and contribute to cumulative effects on aquatic resources. As such, it is not
appropriate to expand the spatial boundary for the Aquatic Ecology RSA, since doing so would not
provide additional information relevant to the assessment of Project effects or contribution to cumulative
effects on aquatic resources, and would result in dilution of predicted effects and assessment
conclusions.
The Aquatic Ecology RSA as delineated in Volume 3, Section 4.3.2 of the Integrated Application provides
the appropriate spatial boundary to understand the potential effects of the Project and cumulative
interactions with other activities on regional aquatic ecosystems. Further rationale is provided below to
specifically address the SIR comments regarding drawdown effects and migration/life history
requirements of fish.
Consideration of Drawdown Effects in the Delineation of the Aquatic Ecology RSA

The potential for drawdown effects were considered as part of the rationale for the Hydrogeology RSA, as
depicted in Volume 1, Figure 1.3.1 of the Integrated Application, and were assessed in the Hydrogeology
assessment (Volume 3.0, Section 1.0 of the Integrated Application). The Hydrogeology assessment
concluded that, ‘groundwater withdrawal would not affect shallower aquifers or watercourses, open water,
wetlands, terrestrial or riparian vegetation and wildlife’ (Volume 3.0, Section 1.6.1.1, Page 1-28 of the
Integrated Application). Modeling of drawdown, as described in Volume 3.0, Section 1.6.1.1 of the
Integrated Application, indicated that ‘drawdown at the water table and at the surface water features
would be less than 0.0001 m’. Considering the conclusions of the Hydrogeology assessment related to
potential drawdown effects, revision of the Aquatic Ecology RSA based on the potential for drawdown
effects is not warranted.
Consideration of Extended Migratory Movements in the Delineation of the Aquatic Ecology RSA
High quality fish habitat potential within the Aquatic Ecology RSA is limited to the lower and mid-reaches
of A1 (i.e., approximately 10 km upstream from its confluence with the Athabasca River), the lower
reaches of A2 and D1, and the Athabasca River (Volume 4, Section 4.6.1 and Appendix 4A of the
Integrated Application). Considering the fish habitat potential identified within the Aquatic Ecology RSA
and the life history requirements of the fish species known to occur within the RSA (see Volume 4,
Table 4A-2 of the Integrated Application), fish dispersal within the study area extending beyond localized
migration are expected to be limited to the Athabasca River, Drainage Basin A and Drainage Basin D. As
mentioned above, Drainage Basin A and Drainage Basin D are fully encompassed within the Aquatic
Ecology RSA and no instream construction activity resulting in temporary or permanent blockage of fish
movement is anticipated within high quality fish habitat (Volume 3, Section 4.7, Table 4.7-1
[Watercourse 1] of the Integrated Application) as a result of the Project. Instream construction activity will
be limited to the low quality fish habitat (Volume 3, Section 4.7, Table 4.7-1 [Watercourses 2-4, Drainages
5-7] of the Integrated Application). Therefore, there is no basis for expanding the Aquatic Ecology RSA
beyond these basins to address upstream fish movement.
The Aquatic Ecology RSA was delineated to include approximately 30 km of the Athabasca River
(Volume 3, Appendix 4A, Section 4A.3.1, Page 4A-4 of the Integrated Application). Although much of the
specific information regarding fish species distribution in the Athabasca River has been concentrated in
the lower reaches downstream of the city of Fort McMurray (i.e., Alberta Oil Sands Environmental
Research Program, Northern River Basins Study, and Regional Aquatics Monitoring Program), several of
the fish species documented in the Athabasca River, including Arctic grayling, lake whitefish, mountain
whitefish and burbot, are known to have migratory movements ranging from 10 km to 280 km (see Berry
1998; Hubert et al 1985; Northcote 1993; Alberta Sustainable Resource Development 2005; Tripp and
Tsui 1980; West et al. 1992; McPhail and Troffe 1998; Applied Aquatics Research 2009). Specific
information regarding the movement patterns of migratory fish species in the Athabasca River upstream
of Fort McMurray in the Project’s vicinity is limited, and the impact of naturally occurring cascade features
(e.g., Grand Rapids) on upstream migration and fish distribution is not well documented. Other fish
species previously documented within the LSA are non-migratory fish species (i.e., brook stickleback and
pearl dace). Therefore, their life history stages are likely completely contained within the current RSA
boundary.
Page 53
Some migratory fish species may have movements beyond the delineated Aquatic Ecology RSA
boundary on the Athabasca River; however, it is anticipated that the currently defined RSA is sufficient for
the assessment of the potential impacts of the Project on fish species movement and habitat utilization
between the Athabasca River and the drainages included in the RSA. Extending the RSA further
downstream and/or upstream the Athabasca River is not warranted since instream Project work will be
confined to low quality habitat within the LSA and will not lead to temporary blockage of fish movement in
the Athabasca River. The potential direct effects of the Project and the Project’s contribution to the
cumulative effects in regards to fish habitat and movements are not anticipated to extend beyond the
currently delineated RSA boundary.
Summary
The potential drawdown effects have been considered in the establishment of the Aquatic Ecology RSA
and, since they are negligible at the water table and surface water features, extension of the RSA on the
basis of drawdown effects is not warranted. Drainage connectivity as well as available information on fish
life history and movement patterns in the Athabasca River have been considered in the establishment of
the Aquatic Ecology RSA. Since the instream construction activities of the Project will be limited to low
quality fish habitat and will not lead to blockage of fish movement in the Athabasca River, extending the
RSA boundary is not warranted.
Page 54
4.0 TERRESTRIAL
4.1 Conservation and Reclamation
32. ESRD SIR 1 Responses, Section 4.2, SIR 97, Figure 97-1, Pages 137 to 138
BlackPearl was asked in SIR1 to update the Conservation and Reclamation (C&R) Section to
include figures which present the sources of aggregate resources, borrow material and other
construction material and locations of any stockpiles that will be developed. BlackPearl stated
that they provided a diagram identifying sources of aggregate, borrow and other construction
material as well as locations of any soil stockpile locations in Figure 97-1. It is unclear where
the proposed topsoil locations are, and the soil material stockpile host site (green hatched
area) on Figure 97-1 is also unclear.
a. Provide an undated figure with the proposed soil stockpile locations.
Response:
The proposed soil stockpile locations are provided in Figure 32-1 (previously Round 1 AESRD SIR
Figure 97-1).
Page 55
Riv er
22 23 24 19 20 21
TWP.77
15 14 13 18 17 16
10 11 12 7 8 9
3 2 1 6 5 4
34 35 36 31 32 33
TWP.76 27 26 25 30 29 28
22 23 24 19 20 21
Note: Soil stockpile locations are approximate and not to scale.

Project Footprint Construction Camp Site Potential Aggregate Source FIGURE 32-1
t6790_Figure 32-1s_Soil_Stockpile_Locations_20131113.pdf
Phase 1 Borrow Pit Permanent Operations (Rickard Excavation Ltd. -

Camp Site Surface Material Exploration) SOIL STOCKPILE, AGGREGATE AND BORROW
Phase 2 Sump Site MATERIAL SOURCE LOCATIONS
Proposed Blackrod Road Soil Material Stockpile Host Site
Phase 3A Log Deck Existing Blackrod Road AESRD SIR 2 RESPONSES -
(Pilot Location - Miscellaneous\ BLACKPEARL RESOURCES INC.
Phase 3B Soil Stockpile Location Mineral Surface Lease) PROPOSED BLACKROD COMMERCIAL SAGD PROJECT
UTM Zone 12N
Project Area: Altus Geomatics 2012 & Feb 19, 2013, modified by TERA Environmental Feb 19, 2013;
SCALE: 1: 50,000
Stockpile Locations: AltaLIS. 2013. Alberta Digital Integrated Dispositions; Meters
Hydrography: AltaLIS.Ltd 2011; Roads: IHS Inc. 2011. 0 500 1,000
32. b. Clarify what material is being stored on the soil material stockpile host site (pilot
location – miscellaneous/mineral surface lease).
Response:
Salvaged organic soils from shallow and deep peat areas and access roads will be stored at the soil
material stockpile host site at the current Pilot location.
32. c. Confirm that the proposed soil materials from the EIA are being discussed and not the
Pilot project.
Response:
BlackPearl confirms that the soil materials from the Environmental Impact Assessment (EIA) are being
discussed and not the Pilot Project.
33. ESRD SIR 1 Responses, Section 4.2, SIR 101, Figure 101-6, Pages 146 to 153
BlackPearl was asked to provide the missing conceptual construction and reclamation of
various scenarios present in their operations. The conceptual access road construction and
reclamation: deep peat environment (Figure 101-6) presented two options for reclamation;
however, it was unclear.
In Reclaimed A, the replaced peat was covering the geotextile and fill material. The geotextile
and fill was not removed in the diagram and does not correlate with the text in the figure. The
notes state:
1. Removed gravel, fill material and remove culverts;

2. Replace salvaged peat in excavated area;
3. Revegetate reclaimed area.
In Reclaimed B, only the replaced peat was present. The notes state:
1. Removed gravel, fill material and culverts;

2. Replace peat in excavated area; and
3. Revegetate reclaimed area.
BlackPearl must remove all gravel, fill and geotextile material; therefore, Reclaimed Option A
as depicted in the diagram is not acceptable.
a. Confirm that BlackPearl will remove all gravel, fill, culverts and geotextile material from
all access roads constructed in deep peat environments.
Response:
BlackPearl will remove all gravel, fill, culverts and geotextile material from all access roads constructed in
deep peat environments.
Page 57
34. ESRD SIR 1 Responses, Section 4.2, SIR 103, Pages 155 to 166
BlackPearl provided adequate responses to parts a to e of the question. SIR 103 f (page 166)
stated Update the C&R Plan accordingly.
BlackPearl responded that they will update the Conservation and Reclamation (C&R) Plan and
will provide to ESRD upon completion of the SIR process.
a. Provide the updated C&R Plan prior to completion of the SIR process.
Response:
An updated C&R plan is provided in AESRD SIR Appendix A for review.
4.2 Wildlife
BlackPearl states that Areas around the kitchen facilities will have additional fencing and
securement.
a. Will this fencing surround the waste containers only, or will it encompass the entire
kitchen facility in order to protect those transferring waste from the kitchen to the
facility?
Response:
The fencing will encompass the entire kitchen facility to protect any personnel transferring kitchen waste.
36. ESRD SIR 1 Responses, Section 4.1, SIR 94, Pages 133-135
BlackPearl states that Future exploration and seismic activities were not known as of February
2012 and, therefore, an assessment of the potential impacts of these activities on wildlife and
wildlife habitat is not required as part of the integrated application. Although it is reasonable
that the precise location of seismic is unknown at this time, it is unreasonable to assume that
the project could be carried out in full without the use of seismic and, therefore, the full impacts
of the project cannot be assessed. ESRD expects that 4D or monitoring seismic development
for the BlackPearl - Blackrod Project will be similar to that for other projects in the near vicinity.
a. Provide estimates of future seismic.
Response:
BlackPearl has no immediate plans for future seismic programs for the Blackrod Project. However,
BlackPearl has derived estimates of future seismic based on existing seismic programs in the region for
similar developments. The existing seismic disturbance completed for the Blackrod Project was projected
to cover the area of the proposed Phases 3A and 3B for the Project. This conceptual future seismic
disturbance is shown on Figure 36-1, along with the existing 3D seismic program completed for the
Project during winter 2010/2011. Although future seismic is speculative, it was used to estimate the length
(provided below) and area (provided in response to Round 2 AESRD SIR 36b) of future 3D seismic lines
that may be required over the life of the Project.
The length of the 3D seismic program conducted in 2011/2012 is approximately 555 km. The conceptual
3D seismic program, based on the projected lines shown in Figure 36-1, would add approximately 980 km
Page 58
of low-impact seismic lines, for a total of 1,535 km of 3D seismic lines. These lengths do not account for
overlap with other disturbance features. BlackPearl anticipates that any future 4D seismic program would
be limited to the footprint of the existing 3D seismic program (shown in red on Figure 36-1). No additional
seismic length will result from a future 4D seismic program.
Page 59
Athabasca River
Riv er
22 23 24 19 20 21
TWP.77
15 14 13 18 17 16
10 11 12 7 8 9
3 2 1 6 5 4
34 35 36 31 32 33
TWP.76 27 26 25 30 29 28
22 23 24 19 20 21
Completed 3D Seismic Program Revised Footprint Existing FIGURE 36-1

and future 4D Seismic Program Phase 1 Borrow Pit Blackrod Road
COMPLETED AND CONCEPTUAL SEISMIC PROGRAMS
Conceptual 3D Seismic Program Phase 2 Sump Site Proposed
Phase 3A Construction Camp Site Blackrod Road AESRD SIR 2 RESPONSES -
Phase 3A - 186.79 km
Phase 3B Permanent Operations BLACKPEARL RESOURCES INC. PROPOSED BLACKROD
Phase 3B - 793.60 km Log Deck Camp Site COMMERCIAL SAGD PROJECT
UTM Zone 12N
SCALE: 1: 50,000
Project Area: Altus Geomatics 2012 & Feb 8, 2013, modified by TERA Environmental Aug, 2013; M
0 500 1,000
December 2013
36. b. For each section (defined by legal land description), provide estimates of the
exploration footprint in terms of total area (ha), and density of linear disturbance
2
(km/km ) for the baseline, application and planned development cases. Describe how
these estimates were derived.
Response:
Area of Exploration Disturbance

The change in area of seismic disturbance was determined following the method used in the EIA,
whereby disturbances were categorized according to a hierarchy, and overlapping disturbances were
dissolved using GIS to avoid repeatedly counting disturbance that overlaps spatially. Area metrics
assume a typical low-impact seismic footprint of 2.75 m wide source lines and 1.75 m wide receiver lines.
The estimated area of seismic disturbance by section is summarized in Table 36-1.
Results indicate that the incremental change in area of seismic disturbance decreases from Baseline to
Application Case in some sections. This is a function of the Project Footprint overlapping the existing 3D
seismic grid. In sections where future 3D seismic lines were projected, the results indicate an increase in
the area of seismic disturbance. Overall, there is an estimated increase of approximately 69 ha of seismic
disturbance from Baseline to Application Case.
TABLE 36-1
ESTIMATED CHANGE IN AREA OF EXPLORATION (SEISMIC) DISTURBANCE
Area of Seismic Disturbance (ha)

Section (W4M) Baseline Case Application Case Incremental Change (ha)
36-76-18 19.7 14.7 -5.0
35-76-18 17.5 15.5 -2.0
34-76-18 1.5 17.0 15.5
31-76-17 3.9 1.5 -2.4
30-76-17 7.9 1.2 -6.7
27-76-18 3.4 16.4 13.0
26-76-18 22.3 15.9 -6.4
25-76-18 22.3 13.4 -8.9
24-76-18 5.5 15.2 9.7
23-76-18 3.2 17.2 14.0
22-76-18 3.2 16.9 13.7
19-76-17 2.0 7.9 5.9
20-77-17 4.8 8.0 3.2
19-77-17 8.8 0.2 -8.7
18-77-17 3.0 14.5 11.6
17-77-17 5.4 15.9 10.5
14-77-18 6.3 9.0 2.7
13-77-18 4.3 7.4 3.1
12-77-18 14.1 13.4 -0.7
11-77-18 4.4 17.4 13.0
8-77-17 5.9 0.1 -5.9
7-77-17 5.9 1.4 -4.5
6-77-17 4.4 1.4 -3.0
2-77-18 6.2 18.7 12.5
1-77-18 20.2 15.0 -5.2
Overall 206.1 275.1 69.0
Note: Results incorporate existing (Baseline) and Project disturbances such that overlapping disturbance is
not repeatedly counted. The Baseline seismic area includes existing 2D and 3D seismic disturbance.
Page 61
Linear Disturbance Density

Baseline Case estimates of linear disturbance density include the existing 3D seismic disturbance, as well
as other existing linear disturbances used in the quantitative analyses for the EIA. Overlapping and
contiguous linear features were counted as a single linear corridor. Results are presented in Table 36-2
by section.
The linear disturbance density for the Application Case includes the existing (i.e., Baseline Case) linear
disturbance, the conceptual future 3D seismic program (described in Round 2 AESRD SIR 36a), and
linear components of the Project Footprint. Results are presented in Table 36-2 by section. BlackPearl
anticipates that a future 4D seismic program would overlap the existing 3D seismic lines included in the
Baseline Case; therefore, no additional disturbance is included for 4D seismic in the Application Case
results.
There are no known future developments that are linear in nature or that would interact with the baseline
disturbances and the Project to change the estimated linear density from Application Case to Planned
Development Case. Therefore, the linear density for the Planned Development Case does not change
from the Application Case.
Linear density was estimated using a moving window analysis. The moving window approach calculates
the density of linear features in the neighbourhood (‘window’) of each output raster cell (‘pixel’) in the
middle of the window (ESRI 2012). Linear density (km/km²) was computed using a moving window
2
analysis in ArcGIS with a 500 m circular window radius (i.e., a 1 km window) and 30 m pixels.
As expected, the results indicate that in sections where the baseline mean linear density is low, the mean
linear density for Application Case with the conceptual 3D seismic lines is substantially higher compared
to Baseline Case (Table 36-2).
TABLE 36-2
ESTIMATED CHANGE IN LINEAR DISTURBANCE DENSITY WITH CONCEPTUAL FUTURE SEISMIC
Mean Linear Density ± Standard Deviation (km/km²) Incremental

Section (W4M) Baseline Case Application Case Change (km/km²)
36-76-18 30.4 ± 3.1 30.5 ± 3.1 0.1
35-76-18 22.7 ± 9.9 32.0 ± 0.6 9.3
34-76-18 2.8 ± 2.1 29.4 ± 4.6 26.6
31-76-17 5.5 ± 5.4 5.6 ± 5.3 0.0
30-76-17 6.5 ± 5.4 6.8 ± 5.4 0.3
27-76-18 5.6 ± 6.7 30.7 ± 4.0 25.1
26-76-18 30.8 ± 2.6 32.0 ± 0.7 1.3
25-76-18 29.9 ± 3.1 30.7 ± 2.8 0.8
24-76-18 7.4 ± 6.0 29.0 ± 4.9 21.6
23-76-18 6.2 ± 6.5 30.6 ± 4.0 24.4
22-76-18 2.9 ± 2.2 29.1 ± 5.0 26.2
19-76-17 5.0 ± 2.8 6.5 ± 4.5 1.5
20-77-17 1.2 ± 0.8 15.6 ± 12.2 14.4
19-77-17 2.4 ± 0.8 16.6 ± 11.7 14.1
18-77-17 2.6 ± 1.2 29.5 ± 4.1 26.8
17-77-17 2.9 ± 1.3 28.7 ± 5.2 25.7
14-77-18 3.8 ± 1.1 18.2 ± 11.0 14.4
13-77-18 2.4 ± 0.9 19.0 ± 11.7 16.6
12-77-18 19.1 ± 11.3 31.2 ± 2.2 12.1
11-77-18 5.7 ± 5.5 31.2 ± 3.7 25.4
8-77-17 3.8 ± 0.9 5.8 ± 3.9 2.0
7-77-17 5.4 ± 4.2 8.4 ± 5.9 3.0
Page 62
TABLE 36-2 Cont'd
36-76-18 30.4 ± 3.1 30.5 ± 3.1 0.1

6-77-17 5.3 ± 5.7 5.3 ± 5.7 0.0
2-77-18 8.4 ± 8.3 31.0 ± 3.5 22.7
1-77-18 30.7 ± 2.5 31.4 ± 2.5 0.7
Note: Results incorporate existing (Baseline) and Project disturbances, such that overlapping and
contiguous linear disturbances are counted as a single linear corridor.
36. c. Provide figures to illustrate the total area affected (ha), including average 4D or
monitoring seismic for an equivalent project, and the density of linear disturbance
2
(km/km ) by section for the baseline, application and planned development cases.
Response:
The results of the moving window analysis for linear feature density described in Round 2 AESRD SIR
36b are illustrated on Figure 36-2. The estimated area of linear disturbance described in Round 2 AESRD
SIR 36b is shown on Figure 36-3.
Page 63
Baseline Case
RGE.18 W4M RGE.17 W4M RGE.16 W4M RGE.18 W4M RGE.17 W4M RGE.16 W4M
Ag
Pe
Ag Application Case With Future 3D Seismic
nes
ne s
lic
n
R
C re
Cre
a
iv
Agnes er Agnes
ek
ek
TWP.79 TWP.79 December 2013
Lake Lake
Crow Crow FIGURE 36-2

Lake Lake
LINEAR DENSITY WITHIN THE RSA FOR
k
ek
Ho
ee
H
el lC ou BASELINE AND APPLICATION CASE
re
Cr
us
ll e Ri le se R
TWP.78 Par a ver TWP.78 P a r a l i v er
PROPOSED BLACKROD COMMERCIAL
SAGD PROJECT
er
a Ri v R iver
sc ca Section Grid
a 63 as 63
ab 19 20 19 20
ab
Existing Blackrod Road
Ath
A th
TWP.77 14 13 18 17
TWP.77 14 13 18 17
11 12 7 8 11 12 7 8 61
Road
2 1 6 2 1 6
Wildlife Regional Study Area

34 35 36 31 34 35 36 31
27 26 25 30 27 26 25 30 Watercourse
22 23 24 19 22 23 24 19
Waterbody
TWP.76 TWP.76
Linear Density (km/km²)

0
0 - 0.60
0.6 -1.2
TWP.75 TWP.75
1.2 - 2.4
>2.4
McMillan McMillan
Lake Lake
TWP.74 TWP.74
ek ek
Cre
Cre
E ric
E ric
t6790_Seismic_Figure_01_Baseline_vs_Application_00.mxd
UTM Zone 12N

k
Project Area: Altus Geomatics 2012;

ree
r ee
Hydrography: AltaLIS.Ltd 2011c;

n n d eri n g Ri v n n d eri n g R iv
nca n ca
Roads: IHS Inc. 2011c.
C
Du er Du er
TWP.73 TWP.73
a
a
W
W
associated with the data used to generate this product or in the product itself,
SCALE: 1: 250,000
km
0 2.5 5 7.5 10 12.5

Athabasca River RGE.18 W4M RGE.18 W4M
Athabasca River
December 2013
FIGURE 36-3
19 20 19 20
APPLICATION BASELINE
LINEAR DISTURBANCE BY SECTION FOR
APPLICATION CASE WITH PROJECT ROW

PROPOSED BLACKROD
6790
14 13 18 17 14 13 18 17
TWP. 77 Existing Linear Disturbance
TWP.77
Proposed Linear Disturbance
No Linear Disturbance
Section Grid
11 12 7 8 11 12 7 8
Waterbody
2 1 6 2 1 6
34 35 36 31 34 35 36 31
27
27 26 25 30 26 25 30
TWP.76
TWP. 76
SCALE: 1:50,000
km
0 1 2
22 23 24 19 22 23 24 19
t6790_Figure_36_3_Linear_Disturbance_Combined_131212.mxd
UTM Zone 12N

Linear Density created by TERA Environmental Nov 23, 2013;
Hydrography: AltaLIS.Ltd 2011;
Although there is no reason to believe that there are

any errors associated with the data used to generate
this product or in the product itself, users of these data
are advised that errors in the data may be present.
Mapped By: WL Checked By: DD

36. d. Update the wildlife assessment to include the average 4D or monitoring seismic
required for an equivalent project of this size.
Response:
Updated assessments for wildlife habitat and wildlife indicators are provided below, which addresses
conceptual 4D seismic and 3D seismic programs that may be conducted for the Project. The assessment
conclusions provided in the Integrated Application remain unchanged.
Habitat
BlackPearl anticipates that any future 4D seismic program would be limited to the footprint of the existing
3D seismic program (shown in red on Figure 36-1). Changes in habitat as a result of 4D seismic would be
limited to clearing of regenerating vegetation, if warranted, and sensory disturbance during seismic
activities.
When the proposed Project Footprint is considered (i.e., overlapping disturbance is removed from the
quantification), the conceptual 3D seismic program would result in approximately 69 ha of disturbance
(Round 2 AESRD SIR 36b). Potential future 3D seismic lines will be cleared using low-impact methods
(refer to Round 1 AESRD SIR 161c response). Low-impact seismic lines have minor changes to overstory
structure and cover, and are too narrow to result in changes in understory vegetation characteristics that
would substantially alter habitat suitability for most wildlife species to a degree that would affect habitat
use at the home range/territory scale, or distribution of individuals. Recent studies have found that
narrow, low-impact seismic lines are less likely to affect habitat use relative to conventional seismic lines
(Bayne et al. 2005, Tigner 2012).
BlackPearl is committed to low impact methods for conducting any future seismic programs that may be
warranted for the Project. In addition, BlackPearl is committed to mitigating the effects of seismic
programs by implementing the measures outlined in the response to Round 1 AESRD SIR 94a. With
implementation of these measures, the residual effects of potential future seismic disturbance on wildlife
and wildlife habitat will be reduced.
As described in the Project Update submitted with Round 1 SIR responses, BlackPearl has made an
effort to modify the Project Area to reduce the total area of disturbance and length of linear development.
The reduction in the area of disturbance from the originally proposed Project Area to the currently
proposed reduced Project Area is 109.4 ha. The additional disturbance from conceptual seismic lines is
approximately 69.0 ha. The estimated Project disturbance with conceptual seismic is smaller than the
Project Area assessed in the EIA.
The assessment conclusions provided in the Integrated Application remain valid.
Beaver
Changes in habitat as a result of 4D seismic would be limited to clearing of regenerating vegetation, if
warranted, and sensory disturbance during seismic activities. Disturbance associated with the conceptual
future 3D seismic activities is anticipated to reduce habitat suitability for beaver by a minimal amount. The
measures described in Round 1 AESRD SIR 94a, and in particular measures designed to avoid or reduce
disturbance within riparian areas, are expected to effectively mitigate the potential residual effect of
potential future seismic on beaver habitat, movement and mortality risk. The assessment conclusions
provided in the Integrated Application for beaver remain valid.
Black Bear
warranted, and sensory disturbance during seismic activities. Low-impact seismic lines for the conceptual
3D seismic program are unlikely to substantially alter habitat suitability for black bear. Foraging habitat
suitability for black bear may increase to some degree following clearing of seismic lines, as herbaceous
vegetation regenerates. The minimum disturbance techniques used for 3D seismic are expected to
facilitate rapid regeneration of native vegetation. Low-impact seismic lines are narrow and meandering,
often avoiding large trees or environmental features (e.g., riparian areas). Nonetheless, clearing of
Page 66
understory vegetation has potential to create easier travel routes for bears in the initial growing seasons
following clearing or mulching of the lines, relative to adjacent forest communities, particularly for open
seismic lines that are≥ 2 m wide (Tigner 2012). As the lines regenerate to natural vegetation, they will
become less conducive to easy travel through the forest. Seismic lines will not create a barrier to black
bear movement.
Linear features have been found to contribute to black bear mortality both directly (i.e., road kill) and
indirectly (i.e., legal and illegal hunting). Seismic lines are expected to have no effect on the potential for
direct mortality to black bears, since direct mortality is associated with linear features that support
vehicular traffic. The implementation of mitigation measures such as prohibiting employees and
contractors from carrying firearms on site or from hunting in proximity to the Project Area, and monitoring
public access on multi-use corridors, is expected to reduce the potential effect of seismic lines
contributing to access within the LSA, and indirectly to black bear mortality risk.
The assessment conclusions provided in the Integrated Application for black bear remain valid.
Fisher
warranted, and sensory disturbance during seismic activities. Low-impact seismic lines are expected to
have a minimal reduction in habitat suitability and effectiveness for fisher in the LSA, as a result of
sensory disturbance during 3D and 4D seismic activities, and from vegetation clearing. Changes in
habitat will be reduced with minimal disturbance techniques used for low-impact seismic programs. The
meandering lines typically avoid large trees wherever feasible, and avoid disturbance within riparian
areas. Tigner (2012) found that marten avoided open seismic lines that are≥ 3 m wide, but did not use
open lines that were≤ 2 m wide or wider lines with at least partial recovery of woody vegetation. Similar
response can be expected by fisher. The narrow, meandering low-impact seismic lines for a potential
exploration program would likely have some effect on fisher habitat effectiveness and movement. Seismic
lines will not create a barrier to fisher movement. The minimum disturbance techniques used for low-
impact seismic programs are expected to facilitate rapid regeneration of native vegetation, which will
mitigate effects of the seismic lines on fisher habitat.
Seismic programs in the region are typically conducted during winter to facilitate access (i.e., frozen
conditions). The winter timing avoids natal and maternal denning periods for fisher. Mitigation measures
proposed to address access within the Project Area are expected to be effective.
The assessment conclusions provided in the Integrated Application for fisher remain valid.
Lynx/Snowshoe Hare
have a minimal reduction in habitat suitability and effectiveness for Canada lynx and snowshoe hare in
the LSA, as a result of sensory disturbance during 3D and 4D seismic activities, and from vegetation
clearing. Low-impact seismic lines are expected to have minimal effects on movement and mortality risk
for lynx and snowshoe hare. Lynx are relatively tolerant of human disturbance, and studies conducted at
an in-situ project in the Conklin area suggested lynx exhibited no avoidance of active 3D seismic
exploration (Kansas and Charlebois 2003, cited in Devon NEC Corporation [Devon] 2010).
The assessment conclusions provided in the Integrated Application for Canada lynx and snowshoe hare
remain valid.
Moose
have a minimal reduction in moose winter foraging and thermal/security habitat suitability in the LSA, as a
result of sensory disturbance during 3D and 4D seismic activities, and from vegetation clearing. Devon
monitored moose habitat use in the Jackfish SAGD project area during and following seismic exploration
activities. Results indicated that moose initially spent substantially less time within both active and
Page 67
inactive seismic areas than outside of seismic areas. Follow-up winter tracking in the Jackfish area found
that moose returned to use 3D exploration areas following active exploration (Devon 2010). Changes in
habitat will be reduced with minimal disturbance techniques used for low-impact seismic programs. The
meandering lines typically avoid large trees wherever feasible, and avoid disturbance within riparian
areas. The minimum disturbance techniques used for low-impact seismic programs are expected to
facilitate rapid regeneration of native vegetation, which will mitigate effects of the seismic lines on moose.
Low-impact seismic lines are narrow and meandering, often avoiding large trees or environmental
features (e.g., riparian areas), which limits line-of-sight and ease of travel for predators such as wolves.
Nonetheless, clearing of understory vegetation has potential to create easier travel routes for wolves in
the initial growing seasons following clearing or mulching of the lines, relative to adjacent forest
communities, and wolves have been documented travelling along low-impact seismic lines where they
are encountered (Latham et al. 2011). As the lines regenerate to natural vegetation, they will become less
conducive to predator travel. Seismic lines will not create a barrier to moose movement.
The assessment conclusions provided in the Integrated Application for moose remain valid.
Northern Goshawk and Old-forest Birds

Low-impact seismic lines create small openings in the forest canopy and reduced understory vegetation,
which are unlikely to substantially reduce habitat suitability, movement or mortality risk for northern
goshawk. The narrow, meandering lines typically avoid large trees wherever practical. Canopy openings
from low-impact seismic are expected to be too narrow to be perceived as edges for most avian species.
Small canopy openings can create flyways that are a valuable component to goshawk habitat, provided
large trees suitable for nesting are retained. Desrochers and Hannon (1997) found that forest gaps less
than 30 m wide had little effect on bird movements. In addition, Bayne et al. (2005) found that ovenbirds
incorporated low-impact seismic lines within their territories. Potential seismic programs would be
scheduled during winter, outside of the breeding period for northern goshawk (March 15 to August 31)
and migratory birds (Environment Canada recommends a migratory bird restricted activity period [RAP] of
May 7 to August 20. Wetlands attractive to migratory birds should not be cleared/disturbed from April 20
to August 25). Clearing of future seismic lines is not anticipated to have an effect on northern goshawk or
old-forest bird movement or mortality risk within the LSA.
The assessment conclusions provided in the Integrated Application for northern goshawk and old-forest
birds remain valid.
Sandhill Crane
Low-impact seismic lines are not expected to have a substantial effect on sandhill crane habitat suitability,
movement or mortality risk. Where low-impact seismic lines are cleared in forested habitats, the openings
will be too narrow to alter understory vegetation to a degree that would create suitable foraging habitat for
cranes. Where seismic lines occur in openings with herbaceous vegetation, conducting activities during
winter will avoid surface disturbance and therefore, changes in vegetation the following spring season are
expected to be negligible.
Potential seismic programs would be scheduled during winter, outside of the breeding period for sandhill
crane (Environment Canada recommends a migratory RAP of May 7 to August 20. Wetlands attractive to
migratory birds should not be cleared/disturbed from April 20 to August 25). Clearing of future seismic
lines is not anticipated to have an effect on sandhill crane movement or mortality risk within the LSA.
The assessment conclusions provided in the Integrated Application for sandhill crane remain valid.
Western Toad
Breeding habitat for western toad is unlikely to be affected by low-impact seismic lines, which generally
avoid open standing water and riparian areas. The minimum disturbance techniques used for low-impact
seismic lines are expected to facilitate rapid regeneration of native vegetation, which will mitigate effects
of the seismic lines on western toad habitat, movement and mortality risk.
The assessment conclusions provided in the Integrated Application for western toad remain valid.
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Woodland Caribou
Potential effects of low-impact seismic activities on woodland caribou are associated with sensory
disturbance during sensitive winter periods and indirect effects associated with primary prey and predator
response to disturbance. Effects of low-impact seismic associated with habitat alteration that could alter
primary prey (i.e., moose) habitat use or abundance are expected to be of minor extent (refer to moose
discussion above). Low-impact seismic lines are narrow and meandering, often avoiding large trees or
environmental features (e.g., riparian areas), which limits line-of-sight and ease of travel for predators
such as wolves. Nonetheless, clearing of understory vegetation has potential to create easier travel
routes for wolves in the initial growing seasons following clearing or mulching of the lines, relative to
adjacent forest communities, and wolves have been documented travelling along low-impact seismic lines
where they are encountered (Latham et al. 2011). As the lines regenerate to natural vegetation, they will
become less conducive to predator travel. The minimum disturbance techniques used for low-impact
seismic programs are expected to facilitate rapid regeneration of native vegetation, which will mitigate
effects of the seismic lines on predator travel. The conceptual seismic grids are located outside of
provincially identified caribou range.
The mitigation measures provided in Volume 4, Section 2.6.1 of the Integrated Application, and in
response to Round 1 AESRD SIRs 148b and 151a, and Round 2 AESRD SIR 38, are expected to
effectively mitigate the potential effects of any future seismic programs for the Project.
The assessment conclusions provided in the Integrated Application for woodland caribou remain valid.
37. ESRD SIR 1 Responses, Section 4.1, SIR 94, Responses c and d, Pages 135-136
BlackPearl states that BlackPearl has no exploration activities planned for winter 2012/2013 for
the Blackrod Project and that BlackPearl completed an exploration program (oil sands
exploration wells) in winter 2012/2013.
a. Clarify.
Response:
The sentence on page 135 as described above is erroneous. The statement should read: BlackPearl
completed an exploration program (oil sands exploration wells) in winter 2011/2012.
BlackPearl states that Additional pullouts will be constructed at various points along the road
during the Project construction phase to allow safe passing of vehicles. These pullouts are
expected to comprise minor widening of short segments at intermittent intervals along the
existing road. BlackPearl will continue to maintain the existing access road (e.g., grading,
adding additional gravel, plowing) as necessary to maintain a safe driving surface during all
phases of the Project. Refer to the response to ESRD SIR 8 for additional information.
a. What caribou mitigation measures will be implemented during the construction of these
pullouts?
Response:
The following caribou mitigation measures will be implemented during the construction of pullouts along
the existing BlackPearl access road (LOC 819):
Page 69
• AESRD recommends a timing restriction of February 15 to July 15 within caribou range to reduce
impacts to pregnant cows and their calves. Exceptions include site preparation/construction that is
initiated prior to February 15 and activities within 100 m of an all-weather road. Work can continue
until adverse conditions are encountered (GOA 2013). BlackPearl will endeavour to schedule site
preparation and construction activities along the existing BlackPearl access road outside of the
recommended timing restriction of February 15 to July 15, whenever practical.
• BlackPearl will consult with AESRD in regards to activity that may occur in caribou range during the
period of February 15 to July 15.
• BlackPearl will contact AESRD if there are circumstances that lead to delays with the construction
schedule.
• Low speed limits will be posted to reduce potential for vehicle-wildlife collisions, and vehicles will yield
to all wildlife crossing roads. BlackPearl’s environmental education program for all site personnel and
contractors will include expectations that speed limits be adhered to, and for all drivers to be aware
and yield to wildlife crossing roads.
• If caribou are encountered, stop vehicles/equipment and allow the caribou to move through the area
undisturbed. Advise others working nearby of the presence of caribou in the area.
• When plowing snow, create breaks in snow berms by placing berms on alternate sides of the road at
approximately 100 m intervals, where practical.
• BlackPearl will monitor access on the existing access road. Hunting, poaching, disturbance to wildlife,
and the creation of packed snowmobile trails in winter will be reduced by operational practices
employed by BlackPearl, including, but not limited to the following:
− recreational use of snowmobiles and ATVs by employees and contractors will be prohibited in the
vicinity of the existing access road;
− a zero tolerance policy on the feeding and harassment of wildlife by employees and contractors
will be enforced, and the presence of employee-owned dogs will be prohibited; and
− employees and contractors will be strictly prohibited from carrying firearms on the Project site and
existing access road, and from hunting in proximity to the Project Area and existing access road
while working on site or staying in camp.
• Continuously collect and dispose of all construction garbage at an approved facility to avoid attracting
animals. Waste containers shall accompany each working unit. No waste material shall be disposed
of on the construction site or adjacent lands at any time.
• Any incidents with wildlife or collisions with wildlife will be reported to the AESRD Fish and Wildlife
Division.
• BlackPearl will develop a Wildlife Monitoring Program in collaboration with AESRD, regional working
groups and stakeholders. Adaptive management will be implemented, if warranted, to mitigate
negative effects on wildlife.
38. b. Provide BlackPearl’s commitment to avoiding road construction in caribou range during
the Caribou Restricted Activity Period (February 15 – July 15).
Response:
AESRD recommends a timing restriction of February 15 to July 15 within caribou range to reduce impacts
to pregnant cows and their calves. Exceptions include site preparation/construction that is initiated prior to
February 15 and activities within 100 m of an all-weather road. Work can continue until adverse
Page 70
conditions are encountered (GOA 2013). BlackPearl will endeavour to schedule site preparation and
construction activities along the existing BlackPearl access road outside of the recommended timing
restriction of February 15 to July 15, whenever practical.
39. ESRD SIR 1 Responses, Section 4.5, SIR 139, Response e, Page 292
BlackPearl states that The increased use of the road was considered in the assessment of
effects on caribou (Volume 4, Sections 2.3.4.4 and 2.6.3.10). With the posting of low traffic
speeds, signage and education of construction and operation contractors and employees, risk
of caribou injury or mortality associated with traffic on the access road is not expected to
increase measurably as a result of the Project. Increased traffic on the road could directly affect
caribou in terms of injury or mortality, as well as habitat use and permeability.
a. Provide an update analysis of the impacts of increased road use in caribou range,
including all factors that may affect caribou.
Response:
Research in boreal caribou range in northeast Alberta has demonstrated that roads create barriers to
caribou movement, likely through the impact of traffic levels, aversion to the physical barrier created by
the forest opening along roads and human predation (Dyer et al. 2001). Changes in movement patterns
(i.e., reduced permeability across the road, avoidance of habitat adjacent to the road) in the vicinity of the
existing access road during construction and operation of the Project may occur as a result of increased
sensory disturbance from elevated traffic volumes. Dyer et al. (2001) demonstrated that caribou showed
avoidance of distances of up to 250 m from linear features (seismic lines and roads), particularly during
late winter and calving seasons when human activity was higher.
The existing BlackPearl access road has been present and active for several decades and, as such, is
likely already affecting caribou movement and habitat value within 250 m of the road. Telemetry data
were obtained from the Alberta Caribou Committee to inform the assessment of potential Project effects
on caribou. Telemetry points were collected between 2006 and 2011 within the Wandering caribou range
south of the LSA. There were no telemetry points recorded within 250 m of the existing road, and only
one telemetry point recorded within 2 km of the road. The number and proportion of individuals in the
herd with collars at the time of sampling are unknown. The available data suggest that caribou use habitat
near the road infrequently.
Increased traffic on the existing road associated with the Project has potential to affect caribou
movement, cause sensory disturbance and habitat avoidance within several hundred meters of the road.
Given the road is an existing high-grade gravel road that facilitates traffic for existing industrial operations
(oil and gas, forestry) and resource use (trapping, guided hunting), and available data suggest that
caribou do not frequently use habitat in proximity to the road, the incremental effect of the Project traffic is
unlikely to have a substantial effect on caribou movement, sensory disturbance, habitat effectiveness and
displacement. Implementing the mitigation measures described in Round 2 AESRD SIR 38 and Round 1
AESRD SIR 151, including scheduling of road upgrading activities outside of the recommended timing
restriction of February 15 to July 15, whenever practical, posting of low speed limits, creating breaks in
snow berms, and development of a Wildlife Monitoring Program, are expected to reduce the adverse
effects of increased traffic on the existing road on caribou and caribou habitat.
The proposed measures described in the response to Round 1 AESRD SIR 139e and Round 2 AESRD
SIR 38 are expected to effectively mitigate the potential effects of the Project on caribou mortality risk.
The assessment conclusions provided in the Integrated Application for woodland caribou remain valid.
Page 71
Table 2.3-4 (Volume 4, Section 2.3.6.1, Page 2-16) summarizes Habitat Change Thresholds for
Wildlife Indicators. In this table, a threshold of 30% disturbance is identified for beaver, black
bear, fisher, lynx/snowshoe hare/northern goshawk, old-forest bird community, moose, sandhill
crane. A 20% threshold is identified for western toad, and a 35% threshold is identified for
caribou.
a. Provide the specific sources used to determine these species-specific thresholds.
Response:
Few thresholds or standards for habitat change are explicitly identified by regulators or the scientific
community as accepted or established. In lieu of this, BlackPearl used a precautionary approach to define
thresholds that could be used to inform the characterization of the magnitude of residual adverse Project
effects on wildlife habitat. Multiple sources were considered to determine thresholds, including published
scientific literature, cumulative effects guidance documents, and previous environmental assessments
reviewed and approved under provincial and federal environmental regulatory processes. In consideration
of the available scientific literature related to critical thresholds for many wildlife species, the thresholds
defined in the assessment were designed as conservative (i.e., precautionary) estimations of levels of
acceptable change from baseline conditions. Examples of assessments completed for in-situ projects that
adopted similar methods (i.e., identified thresholds of habitat change to inform the characterization of the
magnitude of effects) include the wildlife assessments for the Laricina Energy Limited Germain Project
Expansion, EnCana FCCL Ltd. Christina Lake Thermal Expansion Project Phases 1E, 1F and 1G,
Cenovus FCCL Ltd. Narrows Lake Project, Canadian Natural Resources Limited Kirby In Situ Oil Sands
Expansion Project, and the Dover Operating Corporation Dover Commercial Project. The following
documents were consulted to inform the development of thresholds of habitat change used in the
assessment of Project effects on wildlife indicators.
Alberta Environment, Alberta Energy and Utilities Board and Alberta Natural Resources Conservation
Board. 2010. Cumulative Effects Assessment in Environmental Impact Assessment Reports
under the Alberta Environmental Protection and Enhancement Act. Website:
http://environment.alberta.ca/03040.html. Accessed: February 2012.
Alberta Sustainable Resource Development. 2008a. Alberta Grizzly Bear Recovery Plan 2008-2013.
Alberta Species at Risk Recovery Plan No. 15. 68 pp.
Andrén, H. 1994. Effects of habitat fragmentation on birds and mammals in landscapes with different
proportions of suitable habitat: a review. - Oikos 71: 355-366.
Antoniuk, T. 2000. Cumulative effects assessment of pipeline projects. In Cumulative Environmental

Effects Management Tools and Approaches, Alan J. Kennedy (ed). Papers from a symposium
held by the Alberta Society of Professional Biologists. Pp. 143-161. Calgary, Alberta.
Antoniuk, T. 2002. Cumulative effects assessment and linear corridors: the representative areas
approach. Environmental Concerns in Rights-of-Way Management: Seventh International
Symposium. J.W. Goodrich-Mahoney, D.F. Mutrie and C.A. Guild (editors). Elsevier Science Ltd.
pp. 209-218.
Antoniuk, T., and B. Ainslie. 2003. Cumulative effects: Sources, indicators, and thresholds. Appendix 1 in
Volume 2, Cumulative Effects Indicators, Thresholds, and Case Studies of the Cumulative Effects
Assessment and Management for Northeast British Columbia project. Prepared for Oil and Gas
Science Commission Science and Community Knowledge Fund and Muskwa-Kechika
Management Area by Salmo Consulting Inc.
Athabasca Oil Sands Corporation. 2009. MacKay River Commercial Project, Environmental Impact
Assessment. December 2009.
Page 72
Canadian Natural Resources Limited. 2012. Grouse In Situ Oil Sands Project, Volume 5, Section 13:
Wildlife. February 2012. vi + 134 pp. + appendices.
Connacher Oil and Gas Limited. 2010. Great Divide Steam Assisted Gravity Drainage Expansion Project
Application and Environmental Impact Assessment. May 2010.
Cunningham, M.A. and D.H. Johnson. 2011. Seeking parsimony in landscape metrics. Journal of Wildlife
Management 73(3): 692-701.
Devon NEC Corporation. 2010. Devon Jackfish 3 Project, Volume 2 – Environmental Impact Assessment.
August 2010.
Environment Canada. 2011. Scientific assessment to inform the identification of critical habitat for
woodland caribou (Rangifer tarandus caribou), boreal population, in Canada: 2011 update.
Ottawa, Ontario, Canada. xiv + 102 pp.
Fahrig, L. 1997. Relative effects of habitat loss and fragmentation on population extinction. Journal of
Wildlife Management 61: 603-610.
Flather, C.H., and M. Bevers. 2002. Patchy reaction-diffusion and population abundance: The relative
importance of habitat amount and arrangement. The American Naturalist. 159(1):40-56.
Golder Associates Ltd. 2009. Environmental Impact Assessment for the EnCana Foster Creek and
Christina Lakes Ltd. Christina Lake Thermal Expansion Project, Phases 1E, 1F and 1G. Volume
2 (Introduction to the Environmental Impact Assessment) and Volume 5 (Terrestrial Resources
Assessment). October 2009.
Golder Associates Ltd. 2010. Environmental Impact Assessment for the Cenovus Foster Creek and
Christina Lakes Ltd. Narrows Lake Project. Volume 2 (Introduction to the Environmental Impact
Assessment) and Volume 5 (Terrestrial Resources Assessment). June 2010.
Golder Associates Ltd. 2010. Environmental Impact Assessment for the Dover Operating Corporation
Dover Commercial Project. Volume 3 (Introduction to the Environmental Impact Assessment) and
Volume 5 (Terrestrial Resources Assessment). December 2010.
Golder Associates Ltd. 2011. Environmental Impact Assessment for the Cenovus Energy Inc. Pelican
Lake Grand Rapids Project. Volume 3 (Introduction to the Environmental Impact Assessment)
and Volume 5 (Terrestrial Resources Assessment). December 2011.
Golder Associates Ltd. 2011. Environmental Impact Assessment for the Canadian Natural Resources
Limited Kirby In Situ Oil Sands Expansion Project. Volume 2 (Introduction to the Environmental
Impact Assessment) and Volume 5 (Terrestrial Resources Assessment). December 2011.
Government of Alberta. 2011. Draft Lower Athabasca Integrated Regional Plan 2011-2021. Government
of Alberta, Edmonton. 94 pp.
Hegmann, G., C. Cocklin, R. Creasey, S. Dupuis, A. Kennedy, L. Kingsley, W. Ross, H. Spaling and D.
Stalker. 1999. Cumulative Effects Assessment Practitioners Guide. Prepared by AXYS
Environmental Consulting Ltd. and the CEA Working Group for the Canadian Environmental
Assessment Agency. Hull, Quebec. Website: http://www.ceaa.gc.ca/013/0001/0004/index_e.htm.
Jalkotzy, M.G., P.I. Ross, and M.D. Nasserden. 1997. The Effects of Linear Developments on Wildlife: A
Review of Selected Scientific Literature. Prep. for Canadian Association of Petroleum Producers.
Arc Wildlife Services Ltd., Calgary. 115 pp.
Japan Canada Oil Sands Limited. 2010. Hangingstone Expansion Project, Environmental Impact
Assessment. April 2010.
Mönkkönen, M. and P. Reunanen. 1999. On critical thresholds in landscape connectivity: A management

perspective. Oikos: 84(2): 302-305.
Page 73
Osum Oil Sands Corp. 2009. Application for Approval of the Taiga Project. Volume 4, Section 12 Wildlife.
Rompré, G., Y. Boucher, L. Bélanger, S. Côté and W.D. Robinson. 2010. Conserving biodiversity in
managed forest landscapes: The use of critical thresholds for habitat. The Forestry Chronicle
85(5): 589-596.
Shell Canada Limited. 2009. Application for Approval of Peace River Oil Sands Carmon Creek Project.
Volume II- Environmental Impact Assessment. November 2009.
Sorensen, T., P. McLoughlin, D. Hervieux, E. Dzus, J. Nolan and S. Boutin. 2007. Determining
Sustainable Levels of Cumulative Effects for Boreal Caribou. Journal of Wildlife Management 72:
900-905.
Stantec Consulting Limited. 2011. Wildlife Assessment Report Laricina Energy Ltd. Germain Project
Expansion Final Report. Prepared for Millenium EMS Solutions Ltd. November 2011.
Swift, T.L. and S.J. Hannon. 2010. Critical thresholds associated with habitat loss: a review of the
concepts, evidence, and applications. Biological Reviews 85: 35-53.
41. ESRD SIR 1 Responses, Section 4.5, SIR 156, Figure 156-1, Page 315
The Draft Above-ground Pipelines Wildlife Crossings Design Standards describe an approach
and egress slope of 6:1, rather than BlackPearl's 5:1 slope in Figure 156-1. As well, there does
not seem to be a mention of the width (not length) of the crossing design.
a. Confirm that BlackPearl will meet, at the minimum, the accepted Above-Ground
Pipelines Wildlife Crossing Design Standards.
Response:
BlackPearl will meet or exceed the accepted Above-Ground Pipelines Wildlife Crossing Design
Standards. An approach and egress slope of 6:1 will be implemented where this slope will not result in
additional clearing of habitat. In areas where this slope would require additional habitat clearing, a greater
slope (e.g., 1:5) will be implemented. Under this circumstance, slope of over-pipe crossings will not
exceed 1:3, as specified in the AGP design standards. In accordance with the AGP design standards, the
surface of the crossing structure will be 8 m wide, at a minimum, excluding side slopes.
Page 74
5.0 HEALTH
42. ESRD SIR 1 Responses, Section 5, Pages 340 - 367
The conclusions of the HHRA are dependent on the predicted air dispersion modelling results.
Through the SIR process, additional air modelling may be required for the air quality portions of
the application thus generating new predicted air concentration data.
a. In the event that new or additional air dispersion data is generated for selected COPC,
compare the results to health based Toxicity Reference Values (TRVs) and discuss the
potential health impact or provide justification for not completing these steps.
Response:
New air data was presented in Round 1 AESRD SIR 170 and Appendix B in the Round 1 SIR Project
Update. There is no new air quality data that was generated as part the second round of SIRs.
Therefore, all new air quality data has been included and assessed as part of the SIR process.
Page 75
6.0 APPROVALS
The responses to questions in Section 6, Marine Mammals will not be considered as part of the EIA
completeness decision made by Alberta Environment and Sustainable Resource Development.
6.1 Environmental Protection and Enhancement Act

BlackPearl states, Sizing the pond for a 1:10 year storm should be adequate in terms of
protecting downstream water quality. If the pond spills during a more severe rainfall storm
event, the overflow would be significantly diluted by ambient runoff and consequently
contaminants carried by the overflow, if any, would become undetectable in the downstream
area. BlackPearl should be managing the amount of runoff collected in the stormwater pond in
order to minimize this event from happening.
a. Does BlackPearl have measures in place in order to minimize this from occurring?
Response:
Water collected in the live storage zone (please refer to the response to Round 2 AESRD SIR 48b) of the
pond will be discharged as soon as the ambient runoff has ceased and water quality meets the standards.
If the water quality does not meet the standards, the water will be trucked out to maintain the live storage
capacity.
BlackPearl indicates there will be no salvage of mineral subsoil horizons for the Steepbank and
Ells River soil units. A maximum of 30 cm of subsoil salvage is required for shallow organics as
per EPEA Approval clauses or Director Authorization must be sought prior to construction.
a. Clarify what BlackPearl’s plans are for subsoil in shallow organics.
Response:
BlackPearl’s response to Round 1 AESRD SIR 103 was specific to topsoil salvage. Topsoil will be
salvaged separately from the upper subsoil of shallow Organic soils; there will be no admixing of peat and
mineral subsoil. As provided in the response to Round 1 AESRD SIR 106, Table 106-1 BlackPearl
intends to salvage a maximum thickness of 30 cm for all upland and shallow Organic soils within the CPF,
well pads and borrow areas.
45. ESRD SIR 1 Responses, Section 4.2, SIR 103, Response f, Page 166
Response to SIR 103 f states that BlackPearl will update the C&R Plan and will provide it to
ESRD upon completion of the SIR process. A C&R plan is needed to be reviewed prior to
EPEA Authorization.
Response:
An updated C&R plan is provided in AESRD SIR Appendix A for review.
Page 76
To clarify, ESRD finds it suitable to windrow topsoil along the road edge, not in the ditch area
where it would be more susceptible to road salt contamination and erosion and not along the
pipeline side of the right-of-way. BlackPearl states in the response that soils salvaged from the
Project multi-use corridors in wetland environments will be stored at the designated soil
stockpile facility at the existing pilot site.
a. If BlackPearl is going to store soil at another location other than in windrows along the
right-of-way, confirm soil will be tracked and labeled and will not be lost among other
soil piles.
Response:
Soils salvaged from Project multi-use corridors in wetland environments will be tracked and labelled at the
host stockpile location. Adequate signage will be placed at each soil stockpile identifying the material type
and source location. The soil source and stockpile locations will be mapped and referenced prior to the
commencement of all reclamation activities to mitigate the loss of reclamation materials.
47. Project Update, Page 74
BlackPearl states, The previously disturbed access roads and active well pads (18.5 ha) falling
inside the Project Area will remain disturbed. And, Except the previously disturbed access
roads and active well pads (18.5 ha), the existing disturbance (previously disturbed lands)
within the Project Area will be reclaimed.
a. Explain why BlackPearl will not be reclaiming the 18.5 ha of disturbance for the
previously disturbed access roads and active well pads.
Response:
The 18.5 ha of disturbance that will not be reclaimed by BlackPearl are primarily attributed to existing
access roads (and to a lesser extent, existing well pads) either crossing or falling partially within
BlackPearl’s multi-use corridors. All previously existing disturbances falling within BlackPearl’s proposed
well pads, CPF and borrow areas will be reclaimed by BlackPearl. BlackPearl does not intend to reclaim
access roads required by other operators to access leases.
47. b. Clarify what previously disturbed areas will be reclaimed and a discussion on if
reclamation material is required for these areas and how it will be obtained.
Response:
Previously disturbed areas falling within BlackPearl’s proposed well pads, CPF and borrow areas will be
reclaimed by BlackPearl. The material required for these areas has already been accounted for in the
material balance. During the Pre-disturbance assessment, topsoil or subsoil associated with the existing
disturbances identified in the field will be marked/signed and recorded for future reference. If materials
are suitable, they may be used during reclamation activities.
Page 77
48. Project Update, Appendix A, Page A-2
ESRD SIR 1 Responses, Section 6.1.2, SIR 187, Page 370
The new CPF Plot plan appears to have certain areas blacked out and not labelled.
a. SIR 1 Response 187 indicates that the Phase 3 pond is included in the plot plan. There
are three ponds not labelled. Identify which pond is the stormwater pond and which
one is the Phase 1 process ponds.
Response:
The CPF plot plan provided below (Figure 48-1) includes the proper labelling for the storm water pond
and process ponds.
Page 78
48. b. Due to the change on the CPF layout, did the size of the stormwater pond change? If
so, update the runoff calculation and dimensions of the pond.
Response:
The runoff calculation and minimum pond size requirement presented in the Project Update were based
on the updated CPF layout. The pond size will remain the same as that described in Integrated
3
Application (Volume 1, Section 6.0) – 48,200 m ; however, operations of the pond has been adjusted in
accordance with the current CPF layout and water supply for potential dust control needs.
3
As described in response to Round 2 AESRD SIR 7, a supply storage volume of 9,000 m of the pond will
be dedicated to the dust control program. This volume will be maintained and only be discharged for dust
3
control use. The remaining 39,200 m of the pond volume will be the live storage to manage excessive
runoff from the CPF plant site. Water collected in this live storage zone will be discharged as soon as the
ambient runoff has ceased and water quality meets the standards. As described in Section 2.5 of the
Round 1 SIR Project Update, the catchment area for the CPF storm water pond is 82.3 ha (the CPF plant
site excluding the fire buffer) and the runoff volume due to the 24-hour 10-year design rainfall is estimated
3
as 31,900 m . Therefore, the live storage capacity of the pond is adequate to accommodate the runoff for
the 24-hour 10-year design rainfall.
The assessment for the dust control water supply is presented in the response to Round 2 AESRD SIR 7.
48. c. What are the two blacked out area beside the subsoil and topsoil stockpile?
Response:
The updated labels on the CPF plot plan (Figure 48-1) do not show any blacked out areas beside the
subsoil and topsoil stock pile.
48. d. Provide the most up to date CPF Plot Plan that is complete with labels and previous
changes taken out.
Response:
Please refer to Figure 48-1 for the most up to date CPF plot plan with updated labelling.
49. Project Update, Appendix B, Section B7.1, Page B-53
ESRD SIR 1 Responses, Section 6.1.2, SIR 188, Page 370
There were 4 upset scenarios and the air dispersion results presented in this section.
a. Provide the produced gas rate, gas composition, SO2 emission rate and flaring stack
parameters for the flaring scenarios.
Response:
The Section B7.1 of the Round 1 SIR Project Update states that the intermittent flare scenarios are
unchanged from the scenarios presented and evaluated in the Integrated Application. The gas
composition, flare gas flow rate, SO2 emission rate and flare stack pseudo parameters for each scenario
are provided in Volume 2, Appendix 3A, Tables 3A-29, 3A-30 and 3A-31 of the Integrated Application for
Page 80
all of the intermittent flare scenario. The flare scenarios cover a range of upset and abnormal operating
conditions. One of those scenarios involves flaring a mixture of produced gas and natural gas.
The natural gas, produced gas and mixed gas compositions assumed for the Project were presented in
the Volume 2, Appendix 3A, Table 3A-23 of the Integrated Application. The gas composition is presented
again in Table 49-1. The produced gas flow rate and produced gas H2S content associated with full
3
Project capacity of 80,000 bblpd was assumed to be 114,530 sm /d and 0.16% (mole percent),
respectively for purpose of estimating SO2 emissions for the air quality modelling. This produced gas flow
rate is equivalent to a gas to oil ratio of 9.0 and is consistent with the Project SO2 emission rate of 0.502
t/d. Refer to Round 1 AESRD SIR 188 for clarification regarding the gas to oil ratio value.
TABLE 49-1
ASSUMED GAS COMPOSITION FOR THE PROJECT (MOLE PERCENT)
Composition Natural Gas Produced Gas Mixed Fuel Gas

Helium 0.0200 0.00 0.0187
Hydrogen 0.0200 1.59 0.0489
Nitrogen 2.26 0.850 2.16
CO2 1.45 53.5 2.29
a
H2S 0.00230 0.160 0.00545
Methane 96.2 43.8 94.7
Ethane 0.0300 0.0200 0.0311
Propane 0.0200 0.0100 0.0192
i-Butane 0.0400 0.00 0.0908
n-Butane 0.00 0.00 0.0936
i-Pentane 0.00 0.00 0.00
n-Heptane 0.00 0.0700 0.566
Total 100 100 100
Note: 1 Assumes M-Mercaptan was added to H2S.
49. b. How does the gas composition provided in (a) compare to what is existing at the
Blackrod Pilot Plant.
Response:
As a condition of the Environmental Protection and Enhancement Act (EPEA) approval for the Pilot
Project, BlackPearl has contracted MAXXAM Analytics Inc. to analyze the gas from the well casing and
the flash separator at the Pilot plant. Table 49-2 presents a summary of monthly average gas
compositions from the flash separator from the September 2011 to November 2012 period. Overall, for
the average H2S content of all samples was 0.58%. The highest monthly average H2S concentration was
1.28% in September 2012.
The H2S content of produced gas assumed for the Integrated Application is 0.16% (mole percent).
Page 81
TABLE 49-2
GAS COMPOSITION (MOLE FRACTION) FROM THE FLASH SEPARATOR AT THE BLACKPEARL BLACKROD PILOT PLANT
FROM SEPTEMBER 2011 TO NOVEMBER 2012
Compound Sep-11 Dec-11 Feb-12 Apr-12 May-12 Jul-12 Aug-12 Sep-12 Oct-12
H2 0.0156 0.0115 0.0081 0.0041 0.0078 0.0048 0.0038 0.0032 0.0027
He 0.00005 0.0000 0.0000 0.0001 0.0000 0.0000 0.0000 0.0000 0.0000
N2 0.0091 0.0028 0.0021 0.0131 0.0311 0.0090 0.0179 0.0041 0.0081
CO2 0.5445 0.5911 0.6348 0.6488 0.4385 0.6887 0.7274 0.6964 0.7058
H2S 0.0019 0.0040 0.0047 0.0060 0.0027 0.0022 0.0058 0.0128 0.0122
CH4 0.4284 0.3896 0.3493 0.3235 0.5185 0.2876 0.2386 0.2740 0.2632
C2H6 0.0002 0.0003 0.0000 0.0003 0.0005 0.0011 0.0011 0.0014 0.0017
C3H8 0.0001 0.0002 0.0003 0.0006 0.0005 0.0010 0.0013 0.0016 0.0018
i-C4H10 0.00005 0.0001 0.0001 0.0002 0.0000 0.0001 0.0002 0.0002 0.0003
n-C4H10 0.00005 0.0001 0.0001 0.0002 0.0002 0.0004 0.0006 0.0006 0.0007
i-C5H12 0.00005 0.0000 0.0000 0.0001 0.0000 0.0001 0.0002 0.0003 0.0003
n-C5H12 0.00005 0.0001 0.0001 0.0002 0.0001 0.0003 0.0004 0.0004 0.0005
n-C6H14 0.00005 0.0001 0.0001 0.0004 0.0000 0.0008 0.0010 0.0012 0.0011
Page 82
C7 H16 0.00002 0.0001 0.0001 0.0004 0.0001 0.0010 0.0008 0.0009 0.0007
C8 H18 0.0000 0.0000 0.0001 0.0007 0.0000 0.0016 0.0007 0.0012 0.0006
C9 H20 0.0000 0.0000 0.0001 0.0006 0.0000 0.0009 0.0002 0.0010 0.0002
+
C10 0.0000 0.0000 0.0000 0.0007 0.0000 0.0004 0.0000 0.0007 0.0001
Total 1.0001 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000 1.0000
Notes: Gas Analyses were provided by MAXXAM Analytics.
Only the months that the gas analyses from the Flash Separator that were successfully sampled are reported. For monthly reports either the gas analyses
from the well casing or the previous month’s gas analyses were used.
49. c. In relation to the above, the SO2 emission rate of 0.504t/d appears to be extremely low
for a project of this size. Discuss the rationale behind the predicted sulphur emissions.
Response:
The Project SO2 emission rate of 0.504 t/d was estimated based upon the best estimate of the produced
gas rate and H2S content of the produced gas at the time of the application. A gas to oil of 9 and an H2S
concentration of 0.16% (mole percent) was used as the basis to calculate the Project SO2 emission rate.
BlackPearl has operated the Blackrod Pilot Project since 2011 allowing for the measurement of actual
produced gas volumes and actual H2S concentrations in the produced gas. Measurements to date
indicate that the produced gas volumes and H2S concentrations can vary considerably from month-to-
month. In general, measurements collected at the Pilot Project indicate actual SO2 emission rates are
expected to be larger than the SO2 emission rate presented in the Application; however, due to the limited
period of operation of the Pilot Project and limited production data collected to date, it isn’t possible to
definitively determine Project SO2 emissions at this time. BlackPearl continues to operate the Pilot Project
to gather produced gas volume, H2S concentration and production data. The gathered data will be used
to finalize design of Phase 1 of the Project. In November 2013 BlackPearl started warming up the second
SAGD well pair at the Blackrod Pilot, this well better represents the commercial well pair design in terms
of well length, completion and placement in the reservoir. Therefore BlackPearl believes that data from
this well should also be included in determining the sulphur limits for the Blackrod Project.
BlackPearl understands that sulphur recovery is required for projects emitting more than 1 t/d sulphur as
described in AER Interim Directive ID 2001-3 (ERCB 2001). BlackPearl has allowed for flexibility to
incorporate sulphur recovery in the Project design and Project layout. Once additional produced gas
volume, H2S concentration and production data is available from the Pilot Project to further advance
Project design, BlackPearl will provide an updated estimate of Project SO2 emission rates. The update
will include a determination if sulphur recovery is required for Phase 1 and subsequent phases of the
Project and, if sulphur recovery is necessary, a description of the sulphur recovery process, estimated
sulphur removal efficiency and updated Project SO2 emission rates. If it is determined that sulphur
recovery is required, BlackPearl is committed to installing these facilities as part of the construction of the
Phase 1 plant facilities. If Project SO2 emission rates increase from the 0.504 t/d value presented in the
application, updated SO2 dispersion modelling will also be provided with the update to demonstrate that
SO2 emissions are acceptable relative to the Alberta Ambient Air Quality Objectives for SO2.
50. ESRD SIR 1 Responses, Section 6.1.2, SIR 189, Page 371
As requested in the previous round of SIRs, please provide the isopleths for the RSA.
Response:
Isopleths of maximum predicted SO2, NO2 and Particulate Matter (PM)2.5 concentrations for the RSA for
all assessment cases are attached as Figures 50-1 to 50-45.
Page 83
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
70
150
0
15
100
6300000
6300000
50
70
40 1 00
6280000
6280000
100
50
50
70
40
6260000
6260000
Willow
Lake
40
70
50
50
6240000
6240000
50
70
50
40
70
50 50
50 63
40
6220000
6220000
70
70
NorthLake
Wabasca 40
50
50
50
50
Wabasca-Desmarais
50
50
6200000
6200000
50 South Wabasca 40
40
Lake
40
50
40
50
Sandy
Lake
40
Sandy Lake
Pelican 40
40
40
6180000
6180000
40
Lake
50
50
40
40
50
70
Conklin
40
40
6160000
6160000
40
50
50
40
40
50
40
70
McMillan
40
Lake 40
50
6140000
6140000
50
40
40
40
40
40
50
40
Calling
Lake
6120000
6120000
Moose Portage Calling Lake
Wandering River
50
40
40
Breynat
Ranch 40 50
40
Calling River
6100000
6100000
40
50 40
40
Avenir Heart
Lake 40
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
45
6
10
6 45
20
8
6
6
20
20
6
6300000
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8
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6
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6
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6 63
6220000
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5 6
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Wabasca
6
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6
6
6
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6200000
6
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Wabasca
5
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Lake 6
5 Lake
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Pelican 6
6180000
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6
5
6 5
6
5
6
Conklin
5
6
6160000
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5
5
5 McMillan
Lake 6
6140000
6140000
5
5
5 6
5
5
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Lake 5 5
5
6120000
6120000
Moose Portage Calling Lake 6
Wandering River
5
Breynat
Ranch 5
5
Calling River 5
6
6100000
6100000
5
Avenir Heart
Lake
5
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
20
45
0
30
20 20
0
25 30
6300000
6300000
100
100
30
6280000
6280000
30
45
30
45
30
6260000
6260000
Willow
Lake
45
30
6240000
6240000
30
45
45
63
30
6220000
6220000
25
20
NorthLake
Wabasca
20
Wabasca-Desmarais 30
45
20
30
20
6200000
6200000
30
SouthLake
Wabasca
20 30
Sandy
Lake
Sandy Lake 30
25
Pelican
30
6180000
6180000
Lake
25
25
25
30
30
25
30
30
Conklin
25
6160000
6160000
20
30
25
20
McMillan
Lake
6140000
6140000
30
30
20
25
25
25
25
Calling
Lake
6120000
6120000
20 Wandering River
25
Breynat
25
20
Ranch
20
Calling River 20
20
6100000
6100000
20 Avenir Heart
Lake 25
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
12.5 50
100
10
25
50
50
12.5
25
6300000
6300000
25 25
25
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.5
12
6280000
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12.5
5
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6260000
6260000
10
Willow
Lake
10
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6240000
10
12.5
.5 63
12
.5
12
6220000
6220000
12.5
10
10
NorthLake
Wabasca
12.
5
6200000
6200000
12.
SouthLake
Wabasca
5
Sandy
Lake
Sandy Lake
12.5
10
Pelican
7
6180000
6180000
Lake
10
10 10
10
12.5
10
12.5
Conklin
6160000
6160000
.5
12
.5
7 12
10 12.5
12.5
McMillan
10
Lake
6140000
6140000
12
.5
10
10
7
Calling
Lake
6120000
6120000
Wandering River
Breynat
Ranch 10
7
Calling River
6100000
6100000
Avenir Heart
7
7
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
1.5
10
1 10
1.4 5
5
2 3
6300000
6300000
3
5
1.
3
6280000
6280000
1.2
3
3
1.4
6260000
6260000
1.5 Willow
Lake
2
1.5
6240000
6240000
1.5
1.2
1.5
63
6220000
6220000
1.4
3
2
1.4
NorthLake
Wabasca
Wabasca-Desmarais
1.5
2
6200000
6200000
1.2
1 Wabasca
SouthLake
1.4
1.2
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
1.2
Conklin
2
6160000
6160000
1.
1.
1
1.4
1.2 5
4
McMillan
Lake
6140000
6140000
1.
2
1
Calling
Lake
6120000
6120000
Wandering River
1.5
Breynat 1.4
1.2
Ranch 1
Calling River
1.5
1
6100000
6100000
Avenir 2
1. Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
100 80
50
17
30
80
19
25
22
0
10
6300000
6300000
80
25 50
22 30
19 50
30
17
80
6280000
6280000
30
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6260000
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Willow
Lake
30
25
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17
22
6240000
6240000
19
30
22
63
22
19
6220000
6220000
NorthLake
Wabasca
25
19
22
6200000
6200000
22
SouthLake
Wabasca
19
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Lake
17 Sandy Lake
Pelican 19 17
6180000
6180000
Lake
19
17
17
17 Conklin
6160000
6160000
17
17
17
McMillan
Lake
6140000
6140000
17
17
Calling
Lake
6120000
6120000
Wandering River
Breynat
Ranch
17
17
Calling River
6100000
6100000
17
Avenir
17
Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
50
50
13
20
15
14
50
30
6300000
6300000
20
13
20
14
13 15
6280000
6280000
30
20
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Willow
Lake
13
14
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6240000
15
13
13
14 63
6220000
6220000
NorthLake
Wabasca
13
Wabasca-Desmarais
6200000
6200000
13
15
SouthLake
Wabasca
12
13
Sandy
Lake
14
Sandy Lake
12
Pelican
6180000
6180000
Lake
12
12
.5
11
Conklin
6160000
6160000
12
14
12
.5
11
13
12
11
.5
.5
McMillan
11
Lake
6140000
6140000
11.5
Calling
12
Lake
6120000
6120000
Wandering River
Breynat
11.5
11
.5
Ranch
12
12
11
.5
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
1 5
3.
3.1
10
3 .2
3.3
5
10
3.5
4
5
5
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10
6300000
6300000
5
3.15
4
5
4
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6280000
4
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5
4
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6260000
6260000
3.1
Willow
Lake
3.
5
3.5
6240000
6240000
3.15
3.05
63
3.3
3.
2
6220000
6220000
3.3
NorthLake
Wabasca
3.1
3.2
Wabasca-Desmarais 3.3
3.
3.3
1
3.1
6200000
6200000
3.2
SouthLake
Wabasca 3.1
5
3.0 Sandy
5 Lake
Sandy Lake
Pelican 3.2
6180000
6180000
Lake
3.15
3.1
Conklin
6160000
6160000
3.05
3.1
McMillan
Lake
6140000
6140000
3.
15
Calling
Lake
6120000
6120000
Wandering River
3.05
1
Breynat 3.
3.1
Ranch
3.05 Calling River
6100000
6100000
1
Avenir 3.
Heart
3.05 Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
0
20
50 15
0
200
150
6300000
6300000
70
100
0
10
6280000
6280000
50
6260000
6260000
Willow
Lake
70
70
6240000
6240000
70
70
63
6220000
6220000
70
70
70
NorthLake
Wabasca
50
Wabasca-Desmarais
70
6200000
6200000
SouthLake
Wabasca
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
50
50
50
50
50 50 70
50 Conklin
50
6160000
6160000
50
50
50
50
70
McMillan
50
Lake
6140000
6140000
50
50
50
70
50
40
40
50
Calling
50
Lake
6120000
6120000
Wandering River
50
40
Breynat
Ranch 50
40
40
40
Calling River
6100000
6100000
40
50 Avenir
40 Heart
Lake 5
0
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
45
45
20
5
6 20
45
6300000
6300000
20
10
8
6280000
6280000
10
6
10
6260000
6260000
Willow
Lake
6
8
6240000
6240000
8
63
6220000
6220000
NorthLake
Wabasca
6 6
Wabasca-Desmarais
8
6
6200000
6200000
6
8
SouthLake
Wabasca
6
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
6
6
6
6 Conklin
6
6160000
6160000
5
6
6
6
McMillan
Lake
6140000
6140000
6
5
6
5
5
5
Calling
Lake
6120000
6120000
Wandering River
5
5 Breynat
Ranch
6
6 5
5
Calling River
6100000
6100000
6
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
400
200
30
20 45 0
30
10
0
25
10
0
6300000
6300000
30
25
0
10
45
25
6280000
6280000
30 45
45
45
30
6260000
6260000
Willow
Lake
45
6240000
6240000
30
25
45
63
45
6220000
6220000
25
NorthLake
Wabasca
30
Wabasca-Desmarais
30
6200000
6200000
30
SouthLake
Wabasca
25
Sandy
30
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
25
25
30
30
25
Conklin
6160000
6160000
30
30
25
20
25
25 30
25
25
McMillan
Lake
25
6140000
6140000
20
30
20
25
Calling
Lake 20
6120000
6120000
Moose Portage
20
Calling Lake
Wandering River
20
Breynat
Ranch
20
Calling River 20
20
25
6100000
6100000
20 20
Avenir Heart 25
20 Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
12. 50
100
5
50
50
25
10 10
10 12.5
6300000
6300000
25
10
25
12.5
6280000
6280000
10
12
.5
25
10
6260000
6260000
5
12. Willow
.5
10
Lake
12
25
6240000
6240000
10
12.5
10
63
6220000
6220000
NorthLake
Wabasca
10
Wabasca-Desmarais
12.5
6200000
6200000
12.5
10
SouthLake
Wabasca
Sandy
Lake
.5
5
Sandy Lake 12
12.
Pelican 10
6180000
6180000
Lake
10
10
10
12.5
Conklin
10
6160000
6160000
7
7
10
10
10
McMillan
Lake
6140000
6140000
Calling
Lake
6120000
6120000
12.5
Wandering River
Breynat
12.5
Ranch
10
7
7
Calling River
12.5
7
6100000
6100000
Avenir
7
Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
5
5
4 10
1.
1.
1 .2
10
5
2
5
6300000
6300000
3
3
1.2
1.4
2
6280000
6280000
3
3
5 3
1.
6260000
6260000
2
Willow
Lake
1.5
3
1.4
6240000
6240000
1.
2
3
63
6220000
6220000
2
3
NorthLake
Wabasca
1.
5
Wabasca-Desmarais
1.
1.2
4
6200000
6200000
SouthLake
Wabasca
1 .4
1.5
1.
Sandy 2
Lake
Sandy Lake
2
Pelican
6180000
6180000
Lake
1.2
2
1
Conklin
6160000
6160000
1.5 2
1.
2
1.4
McMillan
Lake 1 .2
6140000
6140000
1
Calling
Lake
6120000
6120000
Wandering River
1.4
Breynat
Ranch 1. 1.5
1 2
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
22
25
1 00
15
50
80
30
200
100
22
6300000
6300000
30
0
10
80
25
50
50
50
80
6280000
6280000
22
30
6260000
6260000
Willow
Lake
25
6240000
6240000
63
6220000
6220000
30
NorthLake
Wabasca 30
30
25
Wabasca-Desmarais
30
25
25
6200000
6200000
SouthLake
Wabasca
22 25
25
Sandy 25
Lake
22 Sandy Lake
Pelican
6180000
6180000
Lake
22
22
22 Conklin
6160000
6160000
22
McMillan
Lake
6140000
6140000
19
19
Calling
Lake
6120000
6120000
Wandering River
19
Breynat
Ranch 19
Calling River
6100000
6100000
19
Avenir
19 Heart
Lake 19
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
80
50
18
18
6300000
6300000
50
30
30
30
6280000
6280000
20
6260000
6260000
18 Willow
Lake
18
6240000
6240000
20 63
6220000
6220000
NorthLake
Wabasca 18
18
Wabasca-Desmarais
6200000
6200000
20
SouthLake
Wabasca
15
Sandy
Lake
18
Sandy Lake
Pelican 15
6180000
6180000
Lake 14
15
15
Conklin
6160000
6160000
14
14
McMillan
Lake
6140000
6140000
13 15
15
Calling
Lake
6120000
6120000
Wandering River
Breynat
Ranch
14
13
Calling River
14
14
14
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
20
10
10
6300000
6300000
10
5
3.2
6280000
6280000
5
3.5
3.3
6260000
6260000
Willow
Lake
4
6240000
6240000
4
63
3.5
6220000
6220000
NorthLake
Wabasca 3 .3
3.3
Wabasca-Desmarais
3.3
3.5
6200000
6200000
SouthLake
Wabasca
Sandy
Lake 3.5
Sandy Lake 3.3
Pelican
6180000
6180000
Lake
3. 2
3.
3
Conklin
6160000
6160000
3.1
3.2
3.1
5
McMillan
Lake
6140000
6140000
Calling
Lake 3.3
6120000
6120000
Wandering River
3.05
Breynat
3.1
3.1
Ranch 3.
2
5
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
70
20
150
0
50 150 15
20
0
0
100
70
200
150
6300000
6300000
50
70
100
0
10
6280000
6280000
70
50
6260000
6260000
Willow
Lake
50
70
70
6240000
6240000
70
70
70
63
50
6220000
6220000
70
70 70
70
NorthLake
Wabasca
Wabasca-Desmarais
70
6200000
6200000
SouthLake
Wabasca
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
50
50
50
50
50
70
70 Conklin
50 50
6160000
6160000
50
50
50
50
50
70
70 50
50
70
McMillan
Lake
6140000
6140000
50
70
50
40
50
40
50
Calling
50
Lake
6120000
6120000
Wandering River
50
50
40
Breynat
Ranch 50
40
40
Calling River
70
6100000
6100000
40
Avenir Heart
Lake 50
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
20
45
45
6
45
10
20
45
6
6300000
6300000
20
10
6280000
6280000
10
10
6
8
6260000
6260000
Willow
Lake
6240000
6240000
8
6
63
6220000
6220000
8
NorthLake
Wabasca
6
Wabasca-Desmarais
8
6
6
6200000
6200000
8
SouthLake
Wabasca
6
Sandy
Lake
Sandy Lake
Pelican 6
6180000
6180000
Lake
6
6
6
6
5
6
10
Conklin
6
6160000
6160000
8
6
6
6
6
McMillan
Lake
6140000
6140000
6
5
6
6
5
Calling
Lake
6120000
6120000
5
Wandering River
5
Breynat
Ranch 5
5
6
Calling River
6100000
6100000
5
5
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
200
45
300
30
10 0
25
10
0
6300000
6300000
30 100
0
10
45
6280000
6280000
45
30
45
45
30
6260000
6260000
Willow
Lake
45
30
6240000
6240000
30
25
45
63
45
30
6220000
6220000
25
45
NorthLake
Wabasca
30
Wabasca-Desmarais
30
6200000
6200000
30
SouthLake
Wabasca
25
Sandy
30
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
25
25
30 30
30
25
Conklin
6160000
6160000
30
25
30
25
20
20 30 25 30
25
25
25
McMillan
Lake
25
6140000
6140000
20
30
20
25
Calling
Lake 20
6120000
6120000
Moose Portage
20
Calling Lake
Wandering River
20
20
Breynat
Ranch
20
Calling River 20
25
20
6100000
6100000
20 20 Avenir 20
Heart
Lake 25
20
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
12.
1 00
5 50
50
50
12. 12
5
10
.5
25
10 10
12.5 25
10
6300000
6300000
10
25
25
10
12.5 25
6280000
6280000
.5
12
25
10
10
6260000
6260000
5
12. Willow
.5
Lake
12
25
10
6240000
6240000
12.5
10
63
6220000
6220000
NorthLake
Wabasca
10
.5
12
Wabasca-Desmarais
12.5
6200000
6200000
12.5
SouthLake
Wabasca
10
Sandy
Lake
.5
5
Sandy Lake 12
12.
Pelican 10
6180000
6180000
Lake
10
10
10
12.5
Conklin
6160000
6160000
7
7
10
10
10
McMillan
Lake
6140000
6140000
Calling
Lake
6120000
6120000
12.5
Wandering River
Breynat
Ranch
10
7
Calling River 7
7
12.5
12.5
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
5
10
10
3
1.5
1.
4
5
5
6300000
6300000
3
1.2
2
6280000
6280000
3
3
3
1.4
6260000
6260000
2
Willow
Lake
1 .5
1 .5
3
6240000
6240000
1.
2
3
63
1.
4
6220000
6220000
2
3
NorthLake
Wabasca
1.5
Wabasca-Desmarais
6200000
6200000
1.4
SouthLake
Wabasca 1.5
Sandy
Lake 1.
2
Sandy Lake
2
Pelican
6180000
6180000
Lake
1.2
1.4
1
Conklin
6160000
6160000
2
1.5
1.4
McMillan
Lake 1.2
6140000
6140000
1
Calling
Lake
6120000
6120000
Wandering River
1.4
Breynat
Ranch 1. 1.5
1 2
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
22
25
100
80
25
25
50
15
30
150
200
0
100
22
6300000
6300000
0
10
50
80
50
25
50
6280000
6280000
80
30
6260000
6260000
Willow
Lake
25
6240000
6240000
63
30
30
6220000
6220000
NorthLake
Wabasca
30
30
25
Wabasca-Desmarais
30
6200000
6200000
SouthLake
Wabasca
25
25
Sandy 25
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
22
25
22
Conklin
6160000
6160000
22
22
McMillan
Lake
6140000
6140000
19
Calling
Lake
6120000
6120000
Wandering River
Breynat
Ranch
Calling River
6100000
6100000
Avenir Heart
Lake 19
19
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
50
80
30
50
18
6300000
6300000
50
18
30
30
30
30
6280000
6280000
20
6260000
6260000
18 Willow
Lake
18
6240000
6240000
20 63
18
6220000
6220000
NorthLake
Wabasca 18
18
Wabasca-Desmarais
6200000
6200000
20
SouthLake
Wabasca
15
Sandy
Lake
18
Sandy Lake
Pelican
14
6180000
6180000
Lake 15
15
15
Conklin
6160000
6160000
14
14
14 McMillan
Lake
6140000
6140000
15
15
Calling
Lake
6120000
6120000
Wandering River
Breynat
Ranch 13
14
14
Calling River
14
14
14
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
20
10
20
3.2
10
6300000
6300000
10
5
6280000
6280000
5
3.5
3.3
6260000
6260000
Willow
Lake
4
6240000
6240000
4
63
3.5
6220000
6220000
NorthLake
Wabasca 3 .3
3.3
Wabasca-Desmarais
3.5
6200000
6200000
3.3
SouthLake
Wabasca
3. 2
Sandy
Lake
Sandy Lake 3 .5
3 .1 Pelican 3.
3
6180000
6180000
5 Lake
3.
2
Conklin
6160000
6160000
3
3.3 .5
3.
1
3.05
3 .1
5
3.2
McMillan
3.3
Lake
6140000
6140000
Calling
Lake
6120000
6120000
3.3
Wandering River
3 .1
5
3.05
Breynat
3.
3.1
Ranch 2
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
200
20
150
0
20
0
70 150
100
200
150
6300000
6300000
100
70
6280000
6280000
10
0
6260000
6260000
Willow
Lake
70
6240000
6240000
70
70
63
70
6220000
6220000
NorthLake
Wabasca 70 70
70
Wabasca-Desmarais
70
6200000
6200000
70
70
SouthLake
Wabasca 70
70
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
70
Conklin
6160000
6160000
70
70
70
50
70
McMillan
50
Lake
6140000
6140000
50
50
70
50
50
70
50
50
50
Calling
50
Lake
6120000
6120000
50

50
Wandering River
50
50 Breynat
50
Ranch
50
50
Calling River
50
6100000
6100000
50
50
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
45
45
20
8
10
6
45
6300000
6300000
20
8
6280000
6280000
20
10
10
6260000
6260000
10 Willow
Lake
8
6
10
8
6240000
6240000
10
8
63
6220000
6220000
8
Wabasca 6
NorthLake
8
8
Wabasca-Desmarais
8
6200000
6200000
SouthLake
Wabasca
6
8
6
Sandy
Lake
8
Sandy Lake
6
Pelican
6180000
6180000
Lake
6
6
6
6
Conklin
6 10
6160000
6160000
8
8
6
6
McMillan
Lake
6140000
6140000
6
8
5
6
6
6 6
Calling
5 Lake
6120000
6120000
Wandering River
6
Breynat
6
Ranch 6
6
5
Calling River
6
6
6100000
6100000
5
6
Avenir Heart
5 Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
200
45
30
25
20
100
0
6300000
6300000
30 45
30 100
100
6280000
6280000
45
30
45
6260000
6260000
Willow
Lake
45
45
45
6240000
6240000
30
63
45
6220000
6220000
45
NorthLake
Wabasca
Wabasca-Desmarais
30
6200000
6200000
SouthLake
Wabasca
30
Sandy
Lake
25
30
30
Sandy Lake
Pelican
6180000
6180000
Lake
30
30
25 30
25
45
30 Conklin
6160000
6160000
25
30
20 30
20
30
25
McMillan
Lake
6140000
6140000
30
30
25
25
25
Calling
Lake
6120000
6120000
Wandering River
20
Breynat
20
25
Ranch 25
Calling River
6100000
6100000
25
20
Avenir
20
Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
50
50
10
50
25
6300000
6300000
.5
12 25
6280000
6280000
25
25
25
12.5
6260000
6260000
Willow
Lake
25
.5
12
6240000
6240000
25
12 63
.5
6220000
6220000
10
NorthLake
Wabasca
Wabasca-Desmarais
12
.5
12.5
6200000
6200000
.5
12
SouthLake
Wabasca
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
10
1 2.
5
12.5
Conklin
5
6160000
6160000
12.
10 10
12.5
McMillan
Lake
6140000
6140000
12.5
10
10
7
10
Calling
Lake
6120000
6120000
Wandering River
Breynat
12.
10
Ranch7
5
Calling River
6100000
6100000
12.5
10
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
10
1.4
10
2
1.
1 .5
5
6300000
6300000
2
1.4
5
1.
5
6280000
6280000
5
1.5
3
2
6260000
6260000
Willow
Lake
2
1.
3 2
4
2 5
6240000
6240000
2
63
1.5
6220000
6220000
3
NorthLake
Wabasca
1 .4 2
1. 2
Wabasca-Desmarais
6200000
6200000
3
SouthLake
Wabasca
1.5
Sandy
Lake
1.5
Sandy Lake
Pelican 1.4
6180000
6180000
Lake
1.4
1.5
1.2
3
Conklin
6160000
6160000
2
1.
1.5
1.2
1 .4
1.2
1.
5
1 McMillan
Lake
6140000
6140000
1.2
1.2
Calling
Lake
2
6120000
6120000
Wandering River
Breynat
1.4
1.5
Ranch 1.2
1
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
25
15
50
0
100
200
30
80 0
15
6300000
6300000
25
0
10
50
80
100
6280000
6280000
80
30
50
6260000
6260000
Willow
Lake
6240000
6240000
30
63
6220000
6220000
NorthLake
Wabasca
30
30
Wabasca-Desmarais
6200000
6200000
SouthLake
Wabasca
30
25 Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
25
30
22 25
25 Conklin
6160000
6160000
25
McMillan
Lake
6140000
6140000
22
22
22
22
Calling
Lake
6120000
6120000
Wandering River
22
22
22
Breynat 22
Ranch
22
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
80
30
50
20
80
6300000
6300000
50
20
30
50
50
6280000
6280000
18
20
30
30
6260000
6260000
Willow
Lake
20
18
6240000
6240000
20
18
63
6220000
6220000
NorthLake
Wabasca
20
18
6200000
6200000
SouthLake
Wabasca
Sandy 18
Lake
Sandy Lake
Pelican
18
6180000
6180000
Lake
18
20
Conklin
6160000
6160000
15 McMillan
18
Lake
6140000
6140000
15
15
Calling
Lake
6120000
6120000
Wandering River
Breynat
Ranch
15
15
14
Calling River
6100000
6100000
Avenir
15
Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
20
10
3.3
20
10
6300000
6300000
10
5
6280000
6280000
5
5
4
3.5
6260000
6260000
Willow
Lake
6240000
6240000
4
63
4
6220000
6220000
3.5
3.3
NorthLake
Wabasca
3. 5
Wabasca-Desmarais
6200000
6200000
SouthLake
Wabasca
3.5
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
3.3
3.2
3.5
Conklin
3.1
6160000
6160000
5
3.
2
3. McMillan
3 Lake
6140000
6140000
3.3
3.1
3.5
Calling
Lake
6120000
6120000
Wandering River
3.1
Breynat
3 .1
3.2
Ranch
3.
5
Calling River
6100000
6100000
Avenir
3.1 Heart
5 Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
6300000
6300000
6280000
6280000
2
2
2
6260000
6260000
Willow
Lake
2
2
6240000
6240000
3
63 2
6220000
6220000
NorthLake
Wabasca
3
Wabasca-Desmarais 2
2
6200000
6200000
3
5
SouthLake
Wabasca 3
Sandy
5
Lake
Sandy Lake
5
Pelican
6180000
6180000
Lake
2
5
10
2
3
3
10
3
5
30 Conklin
6160000
6160000
30
5
3
3
2
10
3
McMillan
Lake
6140000
6140000
2
Calling
Lake 2
6120000
6120000
3 Wandering River
3
2
2
Breynat
Ranch
2 3
Calling River
6100000
6100000
2
Avenir Heart
Lake 2
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
6300000
6300000
6280000
6280000
6260000
6260000
Willow
Lake
6240000
6240000
05
0.
0.
05
63
6220000
6220000
NorthLake
Wabasca
Wabasca-Desmarais
0.05
0.1
6200000
6200000
SouthLake
Wabasca
0 .0
5
0.1
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
0.25
0.
05
0.25
0.05
Conklin
6160000
6160000
1
0.5
0.1
0.25
McMillan
Lake
6140000
6140000
0.
05
Calling 0.1
5
Lake
0.0
6120000
6120000
Wandering River
Breynat
0.0
Ranch
5
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
6300000
6300000
6280000
6280000
0.
2
0.2
0.2
6260000
6260000
Willow
Lake
0.2
0.2
6240000
6240000
63
2
0.
6220000
6220000
NorthLake
Wabasca
Wabasca-Desmarais
0. 2
0.5
0.2
6200000
6200000
SouthLake
Wabasca
Sandy
Lake
Sandy Lake
0.5
Pelican
6180000
6180000
Lake
1
0.2
0.2
0 .5
5
0. Conklin
6160000
6160000
1
2.5
0.
2
0.5
McMillan
Lake 1
6140000
6140000
0.5
0.2
0.2
Calling
Lake 2
0.
6120000
6120000
Wandering River
Breynat
Ranch
0.2
0.2
0.2
Calling River
0.2
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
6300000
6300000
6280000
6280000
6260000
6260000
Willow
Lake
0 .0
8
6240000
6240000
0.08
63
0. 0
6220000
6220000
8
NorthLake
Wabasca
Wabasca-Desmarais
08
0.
0.15
6200000
6200000
08
0.
SouthLake
Wabasca
Sandy
Lake 08
5 0.
Sandy Lake 0 .1
0.25
Pelican
6180000
6180000
Lake
0 .1
5
8
0 .0
0.25
0.08 Conklin
0.2
6160000
6160000
0.15 1
0.15 5
1
0.0
8
5
0.1 0.5
0.08
McMillan
Lake
6140000
6140000
0.08 0.
25
0.15
0.
15
08
Calling
Lake 0.
6120000
6120000
0.08
Wandering River 0.0

8
Breynat 0.08
Ranch
Calling River
6100000
6100000
Avenir Heart
Lake 0.08
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
6300000
6300000
6280000
6280000
6260000
6260000
Willow
Lake
0.005
6240000
6240000
63
6220000
6220000
0.00
0. 0
NorthLake
Wabasca
07
5
5
Wabasca-Desmarais
0.00
0.01
6200000
6200000
5
0.
0. 0
SouthLake
Wabasca 00
5
07
5
Sandy
Lake
Sandy Lake
Pelican
0.0
6180000
6180000
Lake
1
0.0075
0.025
0.01
5
0.00 5
07 0.
0.0 00
0.
75 Conklin
05
6160000
6160000
0 .1
0.0
0.
5
00
75
0 .0
0.02
5
05
McMillan
0.0075
Lake
6140000
6140000
0.
00
0.0
1
75
Calling
Lake
6120000
6120000
Moose Portage
5
Calling Lake
00
0.
Wandering River
0.0
Breynat
Ranch
05
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
0.5
0.5
6300000
6300000
0.5
0.5
6280000
6280000
5
0.
0.5
6260000
6260000
Willow
Lake
5
0.
0.5
5
0.
6240000
6240000
63
6220000
6220000
0 .5
0.5
NorthLake
Wabasca
0.5
Wabasca-Desmarais
1
6200000
6200000
SouthLake
Wabasca
Sandy
1
Lake 1
Sandy Lake
Pelican
6180000
6180000
Lake
2
0.5
0.5
1 Conklin
6160000
6160000
4
2
1
0.5 McMillan
Lake
6140000
6140000
1
0.
5
Calling
Lake
6120000
6120000
0.5
Wandering River
Breynat
0.5
Ranch 0.
5
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
0 .2
5
0.2
0.
6300000
6300000
2
0.2
0.2
6280000
6280000
5
0.2
0.2
6260000
6260000
0.2 Willow
Lake
0.2
6240000
6240000
0.25
0.2
63
2
0.
6220000
6220000
25
0.2
0.
NorthLake
Wabasca
Wabasca-Desmarais
6200000
6200000
0.2
SouthLake
Wabasca
0 .2
25
0. Sandy 0.2
0.
2 Lake
0.25
Sandy Lake
0.5
Pelican
6180000
6180000
Lake
0.25
0.5
Conklin
0.
0.5
2
6160000
6160000
1
0 .5
0 .2
5
0.2
0.5
0.2 0.25 McMillan

Lake 5
6140000
6140000
2
0.
2
0.
Calling
0.2
Lake
6120000
6120000
Wandering River 0 .2
5
0.2
Breynat
0.2
Ranch
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
6300000
6300000
6280000
6280000
6260000
6260000
Willow
Lake
0.
01
6240000
6240000
63
6220000
6220000
0.
01
NorthLake
Wabasca
0.01
Wabasca-Desmarais
0.015
6200000
6200000
0.01
5
SouthLake
Wabasca
0. 0
1
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
0.025
0.
01
5
0.01 0.
05
0.025
0.
1
Conklin
6160000
6160000
0.1
0.0
5
0.
0 15
0 .0
1
McMillan
Lake
6140000
6140000
0.025
Calling
Lake
6120000
6120000
1

0 .0
Wandering River
0.
Breynat 01
5
0.0
Ranch
1
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
10
2.
10
3. 5
6300000
6300000
4
5
5
5
6280000
6280000
3.5
5
4
6260000
6260000
5
4
Willow
Lake
5
6240000
6240000
3.5
4
63
5
3.5
6220000
6220000
3
NorthLake
Wabasca
Wabasca-Desmarais
5
5
4
6200000
6200000
SouthLake
Wabasca
3
3.5
Sandy
Lake
2. 4
8 Sandy Lake
Pelican
6180000
6180000
Lake
3
4 Conklin
6160000
6160000
4
2.
8
4
3
McMillan
3.5
Lake
6140000
6140000
3
Calling
Lake
6120000
6120000
4
Wandering River
2.8
Breynat
3.5
Ranch
3
Calling River
4
3.5
6100000
6100000
5
3.
Avenir Heart
3 Lake 4
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
10
30
3
10
10
6300000
6300000
10
5
4
5
6280000
6280000
3.5
5
5
6260000
6260000
Willow
Lake
4
4
4
4
6240000
6240000
4
3 .5
5
63
4
6220000
6220000
3
NorthLake
Wabasca
Wabasca-Desmarais
5
3.5
6200000
6200000
2South Wabasca
.8 Lake
4
5
Sandy
Lake
3
3.5
Sandy Lake
Pelican
6180000
6180000
Lake
2.8
3 Conklin
6160000
6160000
3
5
4
3.
5
2.
8
McMillan
Lake
6140000
6140000
5
Calling
Lake
6120000
6120000
Wandering River
Breynat
3.5
2.8
Ranch
3
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
10
10
5
4
10
6300000
6300000
5
4
5
6280000
6280000
3.5
5
5
5
6260000
6260000
Willow
Lake
4
4
4
4
6240000
6240000
3. 5
5
63
4
6220000
6220000
3
NorthLake
Wabasca
Wabasca-Desmarais
5
3.5
6200000
6200000
SouthLake
Wabasca
4 5
3.5
Sandy
Lake
3
Sandy Lake
2 .8 Pelican
6180000
6180000
Lake
3.5
3 Conklin
6160000
6160000
3
5
2.8
3.
5
McMillan
Lake
6140000
6140000
5
3
Calling
Lake
6120000
6120000
Wandering River
Breynat
3.5
2.8
Ranch
3
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
30
10
10
5
3.
10
4
10
5
6300000
6300000
10
6280000
6280000
5
4
5
4
6260000
6260000
Willow
Lake
5
5
6240000
6240000
10
63
3.5
6220000
6220000
4
NorthLake
Wabasca 5
Wabasca-Desmarais
4
6200000
6200000
SouthLake
Wabasca
Sandy
Lake
Sandy Lake
4
3. 5
Pelican
6180000
6180000
Lake
3.5
5
4
5
Conklin
6160000
6160000
2.8
3.
5
3
4
McMillan
Lake
6140000
6140000
Calling
Lake
5
6120000
6120000
Wandering River
3.5
Breynat
2.8
Ranch
4
3
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
6300000
6300000
6280000
6280000
6260000
6260000
Willow
Lake
0.0
51
6240000
6240000
63
6220000
6220000
0.015
NorthLake
Wabasca
0.015
Wabasca-Desmarais
5
01
0.
6200000
6200000
SouthLake
Wabasca
0.015
0.03
Sandy
Lake
Sandy Lake
Pelican
6180000
6180000
Lake
3
0.0
0.05
0.
0.
03
01
5
Conklin
15
0.0
6160000
6160000
0.03
0.2
15
0.1 0.0
0.015
McMillan 0 .0
Lake 5
6140000
6140000
0.
03
0.015
Calling
0. 0
Lake
6120000
6120000
15
Wandering River
Breynat 0.0
Ranch 15
Calling River
6100000
6100000
Avenir Heart
Lake
320000 340000 360000 380000 400000 420000 440000 460000 480000 500000
7.0 ERRATA
51. Project Update, Table B-5, Page B-30
3
Table B-5 indicates that the Alberta Ambient Air Quality Objective is 125 μg/m . This value
3
should be 30 μg/m for a 30-day concentration. Additionally, the header on Table B-5 indicates
24-hour concentrations, while the table title indicated 30-day concentrations. Correct
inconsistencies and resubmit the table.
Response:
Updated Table B-5 (provided herein as Table 51-1) with corrected label and corrected Alberta Ambient
Air Quality Objective value is provided below.
TABLE 51-1
ST
COMPARISON OF 30-DAY (1 HIGHEST) SO2 CONCENTRATIONS
30-day (1st highest) SO2 Concentration

Existing Baseline
Condition Case Application Case PDC
Location Year (µg/m3) (µg/m3) (µg/m3) (% Change) (µg/m3) (% Change)
2002 3.21 3.19 5.67 78 5.85 83
2003 3.19 3.19 5.28 66 5.65 77
Inside 2004 2.80 2.97 4.76 60 4.96 67
Project CPF
Fence line 2005 2.91 3.01 5.19 72 5.26 75
2006 2.79 2.93 5.01 71 5.07 73
Maximum 3.21 3.19 5.67 78 5.85 83
2002 3.21 3.19 4.98 56 5.37 68
2003 3.19 3.19 4.95 55 5.32 67
On Project 2004 2.79 2.96 4.70 59 4.90 65
CPF Fence
line 2005 2.90 3.01 4.86 61 4.93 64
2006 2.79 2.93 5.06 73 5.12 75
Maximum 3.21 3.19 5.06 59 5.37 68
2002 3.21 3.30 4.93 50 5.32 61
Outside
Project CPF 2003 3.19 3.28 4.81 47 5.14 57
Fence line 2004 2.79 2.98 4.66 56 4.86 63
and Inside 2005 2.89 3.08 4.75 54 4.82 57
Well Pad 2006 2.79 2.93 4.98 70 5.04 72
Area
Maximum 3.21 3.30 4.98 51 5.32 61
2002 4.23 4.62 4.66 1 5.52 19
Outside 2003 5.11 5.10 5.10 0 5.90 16
Well Pad 2004 3.88 4.86 4.87 0 5.74 18
Area and 2005 3.79 3.69 4.32 17 4.44 20
Inside LSA 2006 3.32 3.59 4.47 25 4.53 26
Maximum 5.11 5.10 5.10 0.12 5.90 16
2002 36.8 36.8 36.8 0.001 38.1 3.4
2003 30.7 32.0 32.0 0.004 33.0 3.3
Outside 2004 26.6 25.7 25.7 0.01 26.5 3.2
LSA and
Inside RSA 2005 51.7 53.4 53.4 0.002 54.2 1.5
2006 36.1 35.1 35.1 0.001 35.8 2.1
Maximum 51.7 53.4 53.4 0.002 54.2 1.5
AAAQO 30 30 30 - 30 -
Notes: The % change is with respect to the Baseline Case.
Alberta Ambient Air Quality Objectives (AAAQO) are not applicable within an industrial fence line.
Page 129
52. Project Update, Table B-5, Page B-30
Table B-5 is incorrectly labeled as “24-hour (2nd highest) SO2 Concentration” within the table
3
and the AAAQO used for comparison is incorrectly labeled as 125 μg/m .
Response:
See response to Round 2 AESRD SIR 51.
Page 130
8.0 REFERENCES
Alberta Energy Regulator. 2012. Directive 081: Water Disposal Limits and Reporting Requirements for
Thermal In Situ Oil Sands Schemes. November 21, 2012. 24 pp.
Alberta Environment. 2000a. Code of Practice for Pipelines and Telecommunication Lines Crossing a
Water Body. Includes Amendments to February 2007. 26 pp. Government of Alberta.
Alberta Environment. 2000b. Guide to the Code of Practice for Watercourse Crossings. Revised April
2001. Website: http://environment.alberta.ca/documents/WatercourseGuide.pdf. Accessed:
March 2013.
Alberta Environment. 2008. Alberta Acid Deposition Management Framework. Air Policy Branch.
Edmonton, Alberta, Canada.
Alberta Government. 2013. Code of Practice for Watercourse Crossings. Edmonton, AB. 44 pp.
Alberta Sustainable Resource Development. 2001. Weed Management in Forestry Operations (Directive
No. 2001-6). Land and Forest Division, Alberta Sustainable Resource Development, Edmonton,
AB. 5 pp.
Alberta Sustainable Resource Development. 2005. Status of Arctic grayling (Thymallus arcticus) in
Alberta. Alberta Sustainable Resource Development, Fish and Wildlife Division and the Alberta
Conservation Association, Wildlife Status Report No. 57. 41 pp. Edmonton, Alberta.
Alberta Transportation. 2001. Fish Habitat Manual: Guidelines and Procedures for Watercourse
Crossings in Alberta. Revised August 2009. Government of Alberta. Website:
http://www.transportation.alberta.ca/Content/docType245/Production/Complete_Fish_Habitiat_M
anual.pdf. Accessed: December 2013.
Anfort, S.J., S. Bachu and L.R. Bentley. 2001. Regional-Scale Hydrogeology of the Upper Devonian -
Lower Cretaceous Sedimentary Succession, South-Central Alberta Basin, Canada. American
Association of Petroleum Geologists Bulletin 85(4):637-660.
Applied Aquatics Research Ltd. 2009. Report on Movement and Habitat Use of Fishes in the Lower
Athabasca River From 2008 – 2009 – CEMA Contract #2007-0045. Prepared for Instream Flow
Needs Technical Task Group, Surface Water Working Group and Cumulative Environmental
Management Association. Calgary, Alberta.
Bachu, S., J.R. Underschultz, B. Hitchon and D. Cotterill. 1993. Regional-Scale Subsurface Hydrogeology
in Northeast Alberta. Bulletin No. 61. Alberta Geological Survey, Alberta Research Council.
Barson, D., S. Bachu and P. Esslinger. 2001. Flow Systems in the Mannville Group in the East-Central
Athabasca Area and Implications for Steam-assisted Gravity Drainage (SAGD) Operations for In
Situ Bitumen Production. Bulletin of Canadian Petroleum Geology 49(3):376-392.
Bayne, E. M., S. Boutin, B. Tracz and K. Charest. 2005. Functional and numerical responses of ovenbirds
(Seiurus aurocapilla) to changing seismic exploration practices in Alberta’s boreal forest.
Ecoscience 12:216-222.
Berry, D.K. 1998. Alberta’s Arctic Grayling Management and Recovery Plan. Alberta Environmental
Protection, Natural Resources Service, Fisheries Management Division, 27 pp. Edmonton,
Alberta.
BlackPearl Resources Inc. 2011. Letter to Steve Thomas and Nicole Jones, Energy Resources
Conservation Board regarding Application No. 1691283, 02-25-076-18W4 Proposed Disposal
Well Location, Response to Supplemental Information Request. August 23, 2011.
Page 131
Canadian Association of Petroleum Producers, Canadian Energy Pipeline Association and Canadian Gas
Association. 2005. Pipeline Associated Watercourse Crossings, Third Edition. Prepared by TERA
Environmental Consultants and Salmo Consulting Inc. Calgary Alberta.
Cenovus Energy Inc. 2011. Application for Approval of the Pelican Lake Grand Rapids Project.
Application submitted to Energy Resources Conservation Board and Alberta Environment.
December 19, 2011.
Cenovus Energy Inc. 2012. Cenovus Christina Lake In-Situ Oil Scheme 2011-2012 Update. Presentation
to ERCB, June 20, 2012. Website: http://www.aer.ca/data-and-publications/activity-and-data/in-
situ-performance-presentations.
Cenovus Energy Inc. 2013. Christina Lake Thermal Project – Phase H and Eastern Expansion.
Application for Approval to ESRD and ERCB.
Collins, P.A. 2005. SPE/PS-CIM/CHOA 97905, Geomechanical Effects on the SAGD Process. 2005
SPE/PS-SIM/CHOA International Thermal Operations and Heave Oil Symposium, Calgary,
Alberta, Canada.
Committee on the Status of Endangered Wildlife in Canada. 2013. Wildlife Species Search. Database of
Wildlife Species Assessed by COSEWIC. Website:
http://www.cosewic.gc.ca/eng/sct1/index_e.cfm. Accessed: December 2013.
Desrochers, A. and S. Hannon. 1997. Gap crossing decisions by forest songbirds during the post-fledging
period. Conservation Biology 11(5):1204-1210.
Devon NEC Corporation. 2010. Devon Jackfish 3 Project, Volume 2 – Environmental Impact Assessment.
August 2010.
Dyer, S.J., J.P. O’Neill, S.M. Wasel and S. Boutin. 2001. Avoidance of industrial development by
woodland caribou. Journal of Wildlife Management 65:531-542.
Energy Resources Conservation Board. 1994. Directive 051: Injection and Disposal Wells – Well
Classifications, Completions, Logging, and Testing Requirements. Energy Resources
Conservation Board. 44 pp. Website: http://www.aer.ca/documents/directives/Directive051.pdf.
Energy Resources Conservation Board. 2001. Directive ID 2001-3 Sulphur Recovery Guidelines for the
Province of Alberta. 24 pp. Website: http://www.aer.ca/documents/ids/pdf/id2001-03.pdf.
ESRI. 2012. ArcGIS resources: how line density works. Website:

http://resources.arcgis.com/en/help/main/10.1/index.html#/How_Line_Density_works/009z000000
12000000/. Accessed: October 2013
Fisheries and Oceans Canada. 2013. Measures to Avoid Causing Harm to Fish and Fish Habitat.
Website: http://www.dfo-mpo.gc.ca/pnw-ppe/measures-mesures/index-eng.html. Accessed:
December 2013.
Government of Alberta. 1996. Sensitivity of Alberta lakes to acidifying deposition: an update of sensitivity
maps with emphasis on 109 northern lakes.
Government of Alberta. 2012. Roadway Watercourse Crossing Inspection Manual. Website:

http://srd.alberta.ca/LandsForests/LandManagement/documents/RoadwayWatercourseCrossingI
nspManual-Sep20-2012.pdf. Accessed: December 2013.
Government of Alberta. 2013. Integrated Standards and Guidelines: Enhanced Approval Process.
March 23, 2013. 85 pp.
Page 132
Graf, M. D. 2009. Literature Review on the Restoration of Alberta’s Boreal Wetlands Affected by Oil, Gas
and In Situ Oil Sands Development. Prepared for Ducks Unlimited Canada.
Hubert, W.A., R.S. Helzner, L.A. Lee and P.C. Nelson. 1985. Habitat suitability index models and
instream flow suitability curves: Arctic grayling riverine populations. U.S. Fish and Wildlife
Service, Biological Report 82 (10.110), 34 pp.
Kansas, J. and M. Charlebois. 2003. Responses of ungulates and mid-sized carnivores to oil and gas
activity and development in the Christina Lake area of northeast Alberta. Prep. for Devon Canada
Corporation by URSUS Ecosystem Management Ltd., Calgary, Alberta.
Latham, A.D.M., M.C. Latham, M.S. Boyce and S. Boutin. 2011. Movement responses by wolves to
industrial linear features and their effect on woodland caribou in northeast Alberta. Ecological
Applications 21:2854-2865.
McPhail, J.D. and P.M. Troffe. 1998. The mountain whitefish (Prosopium williamsoni): a potential indicator
species for the Fraser System. Prepared for Environment Canada, Environmental Conservation
Branch, Aquatic and Atmospheric Sciences Division. Vancouver, British Columbia.
Mehl, S., M. C. Hill and S.A. Leak. 2006. Comparison of Local Grid Refinement Methods for MODFLOW.
Ground Water 44(6):792-796.
Millennium EMS Solutions Ltd. 2012. Advanced TriStar Project Baseline Soil Survey and Impact
Assessment. Prepared for Value Creation Inc. Proj. No. 10-033NE.
Northcote, T. G. 1993. A Review of Management and Enhancement Options for the Arctic Grayling
(Thymallus arcticus) with special reference to the Williston Reservior Watershed in British
Columbia. Prepared for Peace/Williston Fish and Wildlife Compensation Program, Report No. 78,
69 pp.
Reilly, T.E. and A. W. Harbaugh. 2004. Guidelines for Evaluating Ground-Water Flow Models. U.S.
Geological Survey. Scientific Investigation Report 2004-5038.
Singhal, B.B.S and R.P.Gupta. 2010 . Applied Hydrogeology of Fractured Rocks: Second Edition.
Springer Dordrecht Heidelberg, London, New York.
Suncor Energy Limited. 2013. Annual ERCB Progress Presentation. Suncor Firebag, 2013 ERCB
Performance Presentation. May 1-2, 2013. Website: http://www.aer.ca/data-and-
publications/activity-and-data/in-situ-performance-presentations.
The Atmospheric Studies Group. 2008. CALPUFF FAQs Answers. Website:

http://www.src.com/calpuff/FAQ-answers.htm#3.3.3. Accessed: September 2013.
Tigner, D.J. 2012. Measuring wildlife response to seismic lines to inform land use planning decisions in
northwest Canada. M.Sc. Thesis, University of Alberta, Department of Biological Sciences,
Edmonton, AB.
Tripp D.B. and P.T.P. Tsui. 1980. Fisheries and Habitat investigations of tributary streams in the southern
portion of the AOSERP study area. Alberta Oil Sands Environmental Research Program, Report
No. 92.
Walker, D. and R.S. Harrison. 1985. Grosmont Formation maps accompanying Open File Report 1986-02
(Walker 1986).
West, R.L., M.W. Smith, W.E. Barber, J.B. Reynolds and H. Hop. 1992. Autumn Migration and
Overwintering of Arctic Grayling in Coastal Streams of the Arctic National Wildlife Refuge, Alaska.
Transactions of the American Fisheries Society 121:709-715.
Westwater Environmental Ltd. 2011. Final proposed groundwater management plan for Blackrod SAGD
Pilot Project. Prepared for BlackPearl Resources Inc.
Page 133
WorleyParsons Canada Ltd. 2010. Groundwater Flow Model for the Athabasca Oil Sands (In Situ) Area
South of Fort McMurray, Phase 2. Draft report prepared for Alberta Environment. November 26,
2010.
WorleyParsons Canada Ltd. 2011 Volume 3, Section 1.5.2.3 of the Integrated Application.
Page 134
WorleyParsons Canada Ltd. 2010. Groundwater Flow Model for the Athabasca Oil Sands (In Situ) Area
South of Fort McMurray, Phase 2. Draft report prepared for Alberta Environment. November 26,
2010.
WorleyParsons Canada Ltd. 2011 Volume 3, Section 1.5.2.3 of the Integrated Application.
Page 134
AESRD SIR APPENDIX A
UPDATED CONSERVATION AND RECLAMATION SECTION
Page A-1
CONSERVATION AND RECLAMATION
BlackPearl Resources Inc. Conservation and Reclamation
Blackrod Commercial SAGD Project Volume 1 - Section 11.0
TABLE OF CONTENTS
Page
11.0 CONSERVATION AND RECLAMATION PLAN .............................................................................. 1
11.1 Introduction ......................................................................................................................... 1
11.2 Existing Biophysical Environment ....................................................................................... 2
11.2.1 Terrestrial Mapping Approach................................................................................ 2
11.3 Life of Facility Reclamation Plan ......................................................................................... 5
11.3.1 Objectives and Key Activities ................................................................................. 5
11.3.2 Siting and Route Selection................................................................................... 10
11.3.3 Pre-Construction Contamination Assessment ..................................................... 10
11.3.4 Restoration of Equivalent Capability .................................................................... 11
11.4 Conceptual Conservation and Reclamation Plan ............................................................. 15
11.4.1 Facility Construction ............................................................................................. 16
11.4.2 Facility Operation ................................................................................................. 55
11.4.3 Facility Decommissioning and Reclamation ........................................................ 59
11.4.4 Soil Replacement Plan ......................................................................................... 66
11.4.5 Revegetation Plan ................................................................................................ 67
11.4.6 Waste Management and Contingency Plans....................................................... 74
11.4.7 Conceptual Conservation and Reclamation Plan Uncertainties .......................... 75
11.5 Conservation and Reclamation Monitoring ....................................................................... 76
11.5.1 Wildlife Monitoring ................................................................................................ 76
11.5.2 Construction and Operations Monitoring ............................................................. 77
11.5.3 Post-Reclamation Monitoring and Reporting ....................................................... 77
11.5.4 Terrain and Drainage ........................................................................................... 78
11.5.5 Soils ..................................................................................................................... 78
11.5.6 Vegetation ............................................................................................................ 78
11.6 Reclamation Certificate ..................................................................................................... 79
11.7 References ........................................................................................................................ 80
LIST OF FIGURES
Figure 11.2-1 Baseline Soils...................................................................................................................... 3
Figure 11.2-2 Baseline Ecological Land Classification.............................................................................. 4
Figure 11.4-1 Conceptual Well Pad Construction & Reclamation: Upland Mineral Soil ......................... 24
Figure 11.4-2 Conceptual Access Road Construction and Reclamation: Upland
Environment ...................................................................................................................... 25
Figure 11.4-3 Conceptual Well Pad Construction & Reclamation: Upland & Wetland Soils................... 26
Figure 11.4-4 Conceptual Well Pad Construction & Reclamation: Deep Peat ....................................... 27
Figure 11.4-5 Soil Stockpile and Aggregate and Borrow Material Sources and Stockpile
Locations ........................................................................................................................... 28
Figure 11.4-6 Conceptual Borrow Pit Construction and Reclamation: Upland Self Draining
Borrow Pit.......................................................................................................................... 29
Figure 11.4-7 Conceptual Borrow Pit Construction and Reclamation: Internally Draining
Borrow Pit and Upland Environment ................................................................................. 30
Figure 11.4-8 Conceptual Borrow Pit Construction and Reclamation: Upland and Wetland
Soils Borrow Pit ................................................................................................................. 31
Figure 11.4-9 Conceptual Access Road Construction and Reclamation: Wetland
Environment and Shallow Peat (<40 cm) ......................................................................... 32
Figure 11.4-10 Conceptual CPF Construction & Reclamation .................................................................. 33
Figure 11.4-11 Conceptual Well Pad Construction and Reclamation: Floating Pad Design –
Deep Peat ......................................................................................................................... 34
Figure 11.4-12 Conceptual Closure Scenario ELC for the LSA ................................................................ 69
Page 11-i
LIST OF TABLES
Table 11.1-1 Terms of Reference ............................................................................................................ 1
Table 11.3-1 Relevant Guidelines and Regulatory Criteria ...................................................................... 6
Table 11.3-2 Project Components and Associated Disturbance ............................................................. 6
Table 11.3-3 Facility Construction and Reclamation Schedule ............................................................... 8
Table 11.3-4 Conceptual Initial Well Pad Development ......................................................................... 10
Table 11.3-5 Changes to Land Capability Classification in the LSA ...................................................... 12
Table 11.3-6 Changes to Forested Land from Baseline Case to Application Case at
Closure Phase in the LSA ................................................................................................. 13
Table 11.3-7 Summary of Reclamation Suitability Classes for Disturbed Soils in the LSA ................... 13
Table 11.4-1 Estimated Total Merchantable Timber Volume within the LSA ........................................ 17
Table 11.4-2 Mineral Soil and Organic Peat Topsoil Salvage Guidelines for
Project Developments within the LSA ............................................................................... 20
Table 11.4-3 Subsoil Salvage Guidelines for Project Developments within the LSA ............................ 21
Table 11.4-4 Estimates of Borrow Pit Overburden Material ................................................................... 35
Table 11.4-5 Topsoil Balance for the Project ......................................................................................... 37
Table 11.4-6 Subsoil Balance for the Project ......................................................................................... 46
Table 11.4-7 Native Grass Seed Mix Example for a Moist Rich Site Type ............................................ 54
Table 11.4-8 Project Facilities in Upland and Lowland with
Corresponding Proposed Reclamation Type .................................................................... 61
Table 11.4-9 Planting Prescriptions ....................................................................................................... 70
Table 11.4-10 Change from Baseline to Application Case at Closure Phase ELC in the LSA ................ 72
Page 11-ii
11.0 CONSERVATION AND RECLAMATION PLAN

11.1 Introduction
The Conservation and Reclamation (C&R) Plan describes the general conservation, mitigation and
reclamation measures to be implemented throughout the life span of the proposed BlackPearl Resources
Inc. Blackrod Commercial SAGD Project (the Project). The life span of the Project includes the
construction, operation, decommissioning, reclamation and closure phases. Construction is scheduled to
commence in 2014, and operations in 2016. The expected life of the Project (i.e., operation phase) is 30
years. Based on this scenario, the operational phase of the Project would extend from 2016 to 2046 and
final reclamation would be completed in 2050. The closure phase extends beyond the completion of
reclamation activities in 2050 (after all facilities and infrastructure have been decommissioned and
removed). The closure phase assumes all reclamation activities have been completed and successional
trajectories have been established that will return sites to pre-disturbance ecosite phases or prescribed
reclamation conditions (target end land use).The intent is to limit the potential environmental effects that
are identified within the Environmental Impact Assessment (EIA) and to achieve equivalent land capability
after the reclamation of the Project.
The C&R Plan outlined in this Section was developed specifically for the Blackrod Commercial SAGD
Project. The purpose of the C&R is to provide the appropriate tools to reclaim the Project Area to an
equivalent land capability upon decommissioning of the Project.
Baseline environmental surveys have been completed to support the EIA for the Blackrod Project.
Information obtained through these baseline environmental surveys was used in the development of this
conceptual C&R Plan. Additionally, BlackPearl has incorporated the Terms of Reference (TOR) issued by
Alberta Environment and Water (AEW 2012) into the design for the C&R Plan (Table 11.1-1)
All future conservation and reclamation activities will adhere to the general outline and practices
described within the C&R Plan. BlackPearl will submit to AESRD a summary of the reclamation activities
that were undertaken each calendar year within the Blackrod C&R Annual Report. This Annual Report will
include a description of the work performed and reclamation plans proposed for the following calendar
year. Forward planning of reclamation projects will incorporate adaptive management and updates to
applicable regulations when required.
TABLE 11.1-1
TERMS OF REFERENCE
2.8 Conservation and Reclamation Plan

[A] Provide a conceptual conservation and reclamation plan for the Project. Describe and map as applicable:
(a) Current land use and capability and proposed post-development land use capability;
(b) Anticipated timeframes for completion of reclamation stages and release of lands back to the Crown including an outline of the key milestone dates
for reclamation and how progress to achieve these targets will be measured;
(c) Constraints to reclamation such as timing of activities, availability of reclamation materials and influence of natural processes and cycles including
natural disturbance regimes;
(d) A revegetation plan for the disturbed terrestrial and riparian and wetland areas;
(e) Reclamation material salvage, storage areas and handling procedures; and
(f) Existing and final reclaimed site drainage plans.
[B] Discuss, from an ecological perspective, the expected timelines for establishment and recovery of vegetative communities and wildlife habitat, the expected
success of establishment and recovery, and the expected differences in the resulting communities.
[C] Describe how the Proponent considered the use of progressive reclamation in project design and reclamation planning.
[D] Discuss the Proponent’s involvement in any in-situ reclamation initiatives or reclamation working groups.
[E] Discuss uncertainties related to the conceptual reclamation plan.
Page 11-1
11.2 Existing Biophysical Environment

Information pertaining to the existing biophysical environment and the potential environmental effects
related to the Blackrod Project are located within the following sections of the EIA.
• Volume 2: Air Quality and Noise.
• Volume 3: Hydrogeology, Hydrology, Surface Water Quality, Aquatic Ecology.
• Volume 4: Vegetation, Wildlife, Biodiversity, Terrain and Soils.
• Volume 5: Human Health.
The C&R was developed with information provided from the terrestrial resources studies (Volume 4 of this
EIA).
11.2.1 Terrestrial Mapping Approach

Soils and vegetation data was collected in 2010 and 2011 for the Project. The Terrain and Soils and
Vegetation sections in Volume 4 provide detailed descriptions of the methodologies and results gathered.
The spatial boundary of the Local Study Area (LSA) used for the purpose of the C&R Plan is consistent
with the LSA used for the assessments of vegetation, and terrain and soils. (i.e., a 450 m buffer extended
from the Project Area for an area of approximately 6,136 ha). The approach towards assessing the
Baseline Case and post-reclamation (Closure Phase) were different in that:
• the Baseline Case describes the existing soils, vegetation, wildlife habitat and
biodiversity that could be mapped based on existing available data; while
• the post-reclamation (Closure Phase) is conceptual and assumed that the Project Area
will be returned to an equivalent land capability with target vegetation types similar to
adjacent ecosite phases. The scenario describes the anticipated ecosystem
approximately 30 years post-reclamation (2080).
Baseline Case for soil map units and ecological land classification within the Project LSA are presented in
Figures 11.2-1 and 11.2-2, respectively.
The characteristics of the terrestrial ecosystem in the future will be dependent on many factors, therefore
there will be a degree of uncertainty regarding future soils, vegetation, wildlife habitat and biodiversity. To
accommodate this uncertainty, closure phase mapping provided within the C&R provides conceptual
target vegetation communities for the Project Area that will correspond with adjacent vegetation types
based on current knowledge of the area. The target vegetation communities for the Project Area will be
updated at the time of reclamation based on the results of site-specific Pre-disturbance Assessments
(PDAs), monitoring and adjacent vegetation communities at the time of reclamation. The adoption of this
approach allows for site specific adaptation of the reclamation plan in response to variations in vegetation
succession as site factors change over time.
Page 11-2
Twp 77 Rge 17 W4M
Twp 77 Rge 18 W4M
Athabasca River
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Legend
ELS HLYzz LVK MRN STPpt Hydrography

FIGURE 11.2-1
ELSpt HRR MLD MUS STPzz Water
BASELINE SOILS
FIRxt HZMaa MLDxt RB Disturbed Land Soils Local SCALE: 1: 45,000
Study Area km BLACKPEARL RESOURCES INC.
HLY HZMaapt MLDzz STP Pilot Plant 0 0.5 1 PROPOSED BLACKROD
UTM Zone 12N

AltaLIS Ltd. (2011), Altus Geomatics (2012), Blackbridge Geomatics (2010), Paragon (2012), TERA Environmental Consultants (2012)
Although there is no reason to believe that there are any errors associated with the data used to generate this product or in the product itself, users of these data are advised that errors in the data may be present. May 2012
27 26
¯
25 30 29
RGE. 18 W4M RGE. 17 W4M
28
21 22 23 24 19 20 21
TWP. 77
16 15 14 13 18 17 16
9 10 11 12 7 8 9
4 3 2 1 6 5 4 3
Ecological Land Classification
Anthropogenic
Disturbance
b3 - blueberry Aw-Sw
Cutblock (logged within
last 10 years or no trees
regenerating)
c1 - Labrador
33 34 35 tea-mesic Pj-Sb
36 31 32 33 d1 - low-bush 34
cranberry Aw
d2 - low-bush
cranberry Aw-Sw
d3 - low-bush
cranberry Sw
e1 - dogwood Pb-Aw
e2 - dogwood Pb-Sw
28
e3 - dogwood Sw
27 26 25 30 29 f1 - horsetail Pb-Aw
28 27
f2 - horsetail Pb-Sw
f3 - horsetail Sw
g1 - Labrador
tea-subhygric Sb-Pj
h1 - Labrador
TWP. 76 tea/horsetail Sw-Sb
i1 - treed bog
21 22 i2 - shrubby bog
23 24 19 20 j1 - treed poor fen
21 22
j2 - shrubby poor fen
k1 - treed rich fen
k2 - shrubby rich fen
k3 - graminoid rich fen
l1 - marsh
Meadow (upland with
<6% tree cover and
16 15 <25% shrub cover)
14 13 18 17 Regenerating Burn
16
(wildfire within last 15
30 years)
Regenerating Cutblock
(logged within last 30 years
but older than 10 years)
Shrubby Wetland
FIGURE 11.2-2
Project Area Existing Blackrod Road
Vegetation Local BASELINE ECOLOGICAL LAND CLASSIFICATION
Watercourse
Study Area (450 m) BLACKPEARL RESOURCES INC.
Waterbody PROPOSED BLACKROD
UTM Zone 12N: SCALE: 1: 60,000
Project Area: Altus Geomatics 2012; Ecological Land Classification: TERA Environmental Consultants 2012c;
km
Hydrography: AltaLIS 2011c.; Road: IHS Inc., 2011c.
0 0.5 1 1.5
t6790_C&R_Fig11.2-2_Baseline_ELC.mxd
11.3 Life of Facility Reclamation Plan

11.3.1 Objectives and Key Activities
The C&R Plan applies to the Project Area and was developed to provide a detailed description of how the
Project Area would be reclaimed to an equivalent land capability upon the conclusion of the operational
life of the Project.
The objective of reclamation is to return disturbed areas to a forest capability and wildlife habitat
capability equivalent to the pre-disturbance conditions. Conservation and Reclamation practices to
achieve equivalent land capability involve:
• consideration of cumulative effects management and differences in end land use

objective amongst user groups;
• conserving existing resources as much as feasible during development planning (i.e.,

use of common corridors and existing disturbances for facilities);
• use of regeneration prescriptions for commercial forests species and other land uses for
the post-reclamation landscape; and
• use of adaptive management to incorporate new techniques for construction, design

and reclamation strategies, to meet future thresholds and targets throughout all stages
of the Project.
BlackPearl’s reclamation objectives for the disturbances associated with the Project include:
• remediation and disposal of contaminants on all disturbed sites to meet AESRD

requirements;
• reclamation of Project facilities to achieve compatibility with the surrounding terrain and
target end-land uses;
• ensure that the drainage patterns upon completion of re-contouring provide proper
drainage and that adequate erosion control is installed;
• progressive reclamation to minimize the immediate and cumulative total developed

areas in use;
• providing a land capability equivalent (at minimum) to pre-disturbance conditions and

the conditions of the existing land base at the time of reclamation;
• establish maintenance–free, self-sustaining vegetation communities that achieve target

end-land uses and ecosite phases that correspond with adjacent vegetation
communities; and
• satisfy the applicable reclamation criteria and obtain a certificate of reclamation.
The intent of designing and implementing environmental protection measures is to address identified
effects from the Project. As such, general project-specific measures are outlined in this C&R Plan and will
be implemented during the Project to minimize the effects that were identified though the EIA process.
The use of progressive reclamation also enhances the re-establishment of suitable wildlife habitat. The
final reclamation of the Project Area will be completed once the individual facilities are decommissioned
and infrastructure removed.
BlackPearl has had ongoing discussions with AESRD pertaining to the Project and will continue
consultation for the duration of the Project. Additionally, BlackPearl will maintain an active stakeholder
consultation and engagement program to facilitate open discussions on the Project development, project
reclamation, and reclamation strategies, regularly throughout the life span of the project. Refer to the
Page 11-5
Public Consultation and Aboriginal Engagement Program (Volume 1, Section 2.0) for details on
consultation.
BlackPearl will comply will all relevant guidelines and regulatory criteria including, but not limited to, those
summarized in Table 11.3-1. As guidelines change, BlackPearl shall adapt its reclamation plans and
follow the most current guidelines and criteria available at the time of reclamation.
TABLE 11.3-1
RELEVANT GUIDELINES AND REGULATORY CRITERIA
Guidelines or Documents Reference

Alberta Tier 1 and Tier 2 Soil and Groundwater Remediation Guidelines AENV 2010a,b
Guidelines for Wetland Establishment on Reclaimed Oil Sands Leases (2007) Revised AENV 2008
Code of Practice for Watercourse Crossings AENV 20013aa
Code of Practice for Pipelines and Telecommunication Lines Crossing a Waterbody AENV 2013b
Sites Reclaimed Using Natural Recovery Methods AENV 2003
Environmental Protection Guidelines for Oil Production Sites (C&R/IL/02-1) AENV 2002
Environmental Protection Guidelines for Roadways AENV 2000
Environmental Protection and Enhancement Act Conservation and Reclamation Regulation (AR 115/93, as amended) GOA 2013
Environmental Protection Guidelines for Electric Transmission Lines (R&R/11-03) AENV 2011a
A Guide to “Surface Material” Resource Extraction on Public Land ASRD 2008
Debris Management Standards for Timber Harvest Operations ASRD 2010
Weed Management in Forestry Operations (Directive 2001-06) ASRD 2001
Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region AENV 2010
Guideline for Monitoring and Management of Soil Contamination Under EPEA Approvals AENV 1996
Drilling Waste Management (ERCB Directive 050) ERCBB 2012
Storage Requirements for the Upstream Petroleum Industry (ERCB Directive 055) ERCB 2001
Code of Practice for Pits AENV 2004
Well Abandonment Guide (ERCB Directive 020) ERCB 2010
Oilfield Waste Management Requirements for the Upstream Petroleum Industry (ERCB Directive 058) ERCB 2006
Management of Wood Chips on Public Land (Directive SD 2009-01) ASRD 2009
2010 Reclamation Criteria for Wellsites and Associated Facilities for Forested Lands (updated July 2013) ESRD 2013
Code of Practice for Exploration Operations AENV 2005
Land Capability Classification for Forest Ecosystems in the Oil Sands Region, 3rd Edition CEMA 2006
11.3.1.1 Project Area

The Project Area includes all lands that are subject to direct disturbance by the Project activities. The
Project components and their associated disturbance are outlined in Table 11.3-2.
TABLE 11.3-2
PROJECT COMPONENTS AND ASSOCIATED DISTURBANCE
Soil Disturbed (ha) Vegetation Disturbed (ha)

CPF 122.9 122.9
CPF Access Road 0.8 0.8
Well Pads (1) 232.2 232.2
Multi-Use Corridor (1) 313.1 313.1
Borrow Pits 151.4 151.4
Log Decks n/a 3.8
Sumps 13.3 13.3
Camps 18.7 18.7
Total 852.5 856.3
Notes: 1. Based on assumption that facilities will be built to maximum dimensions.
2. Totals may not add due to rounding.
Page 11-6
Detailed descriptions of the Project design and components are provided in Volume 1, Section 4.7 and
Volume 1, Section 6.0. The Project will include a construction camp, permanent operations camp, central
processing facility (CPF), CPF access road, production well pads, borrow pits, drilling sumps, log decks
and multi-use corridors, pipelines and powerlines to connect the well pads to the CPF. BlackPearl has
made all efforts to minimize the Project Area through incorporation of both environmental and engineering
factors including the use of existing disturbances (linear and non-linear) to limit the use of new
disturbance, and avoidance of environmentally sensitive areas.
11.3.1.2 Well Pad Sequence

The Project is expected to be developed in three phases over an estimated 30 year period with the initial
phase producing 20,000 barrels per day (bbl/d) of crude bitumen and the subsequent phases producing
30,000 bbl/d each, for a final production capacity of 80,000 bbl/d. Up to 54 well pads are expected over
the life of the Project.
The sequence of drilling the multi-well pads will be determined based on a detailed analysis of the
reservoir. A typical multi-well SAGD pad is envisioned to have a dimension up to 4.0 ha, for further details
on pad dimensions refer to Volume 1, Section 4.7. The locations of the well pads are based on
BlackPearl’s current understanding of the reservoir and the surface locations may shift more detailed
information on the reservoir is collected. However, each individual well pad location plus associated
surface disturbances will be applied for through the appropriate regulatory bodies for approval prior to
licensing of any of the well pairs and subsequent surface disturbance.
11.3.1.3 Development Timeline and Reclamation

The Project will be developed in three phases:
Phase 1
Involves the clearing, site preparation and construction of the CPF, well pads, access roads and
associated Project infrastructure to reach a bitumen production of 20,000 bbl/d.
Phase 2
Includes the installation of additional production equipment at the CPF, construction of additional well
pads, access roads and associated Project infrastructure to increase the bitumen production by
30,000 bbl/d to 50,000 bbl/d.
Phase 3
Involves the expansion of bitumen production capability at the CPF, construction of additional well pads,
access roads and associated Project infrastructure to increase the bitumen production by 30,000 bbl/d to
80,000 bbl/d.
Pending regulatory review and favourable market conditions, construction of the Project is anticipated to
commence in 2014 with commissioning/start-up projected for 2016. Table 11.3-3 outlines the anticipated
timeline for the Project activities. Final reclamation is anticipated to be completed by 2050. The
reclamation timeline is subject to modification due to changes in regulatory approvals, site conditions, and
business considerations. Table 11.3-4 outlines the initial forecast development for the SAGD Project.
Page 11-7
TABLE 11.3-3
FACILITY CONSTRUCTION AND RECLAMATION SCHEDULE
Year of Development
Development Number 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051
CPF CPF
1A
1B
1C
1D
Phase 1 B11
B12
B13
S11
S12
1E
Page 11-8
2A
2B
2C
Phase 2 2D
2E
2F
B21
B22
3AA
3AB
3AC
3AD
3AE
3AF
3AG
Phase 3A
3AH
3AI
B3A1
B3A2
B3A3
L3A1
L3A2
3BA
3BB
3BC
3BD
3BE
3BF
3BG
Phase 3B 3BH
3BI
3BJ
3BK
3BL
3BM
3BN
3BO
TABLE 11.3-3 Cont’d
Year of Development
Development Number 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051
CPF CPF
Phase 3B 3BP
(cont’d) 3BQ
3BR
3BT
3BU
3BV
3BW
3BX
3BY
3BZ
3BAA
Page 11-9
3BBB
3BCC
3BDD
3BEE
3BFF
3BGG
3BHH
B3B1
B3B2
B3B3
B3B4
B3B5
B3B6
B3B7
B3B8
B3B9
B3B10
B3B11
B3B12
B3B13
B3B14
B3B15
B3B16
S3B1
L3B2
Notes: 1. Red indicates construction commencement year. Green indicates reclamation commencement year.
TABLE 11.3-4
CONCEPTUAL INITIAL WELL PAD DEVELOPMENT
Year Well Pads Per Phase

2014-2015 (Phase 1) 5
2018-2019 (Phase 2) 6
2020-2021 (Phase 3A) 9
2023-2034 (Phase 3B - 4 pads per year) 34
Total Pads 54
Progressive reclamation shall be conducted on disturbed areas, such as abandoned well pads, access
roads and associated disturbances, throughout the lifespan of the Project as facilities are abandoned and
decommissioned. The operational life of a well pad is anticipated to be between 10-12 years.
Reclamation of these disturbances are further discussed in Volume 1, Section 11.4. Further details
regarding the Project scheduling, is provided in Volume 1, Section 1.0.
11.3.2 Siting and Route Selection

Engineering and environmental factors have been considered in all aspects of the planning and design of
the Project. The environmental considerations utilized for locating routing and siting of the Project include
the following.
• Topography: maximize the utilization of high, dry and stable ground and minimization of watercourse
crossings plus interference with natural drainage patterns, where ever feasible. Site selection shall
avoid steep slope areas and maximize the positioning of power lines, roads and pipelines on existing
linear disturbances, where practical.
• Soils: Siting of facility locations on upland mineral soils would be preferred (well pads, CPF). Some
facilities (well pads) were located in shallow or deep peatland since placement in only upland soils
was impractical given the location of the targeted bitumen source, horizontal well recovery technology
limitations, and the extent of peatlands within the LSA.
• Sensitive Habitat and Vegetation: Wherever feasible, avoid rare ecological communities, rare
plants, sensitive site-specific wildlife habitat features, and adjust site locations wherever feasible to
avoid direct impacts.
• Surface Water/Aquatics: Select sites for borrow pits, well pads and the CPF that are a minimum of
100 m from watercourse with defined bed and banks, where feasible.
• Historical Resources: Conduct an assessment of the potential effects on historical resources

resulting from construction and operations prior to the commencement of construction
11.3.3 Pre-Construction Contamination Assessment

A Phase I Environmental Site Assessment (ESA) will be conducted on all previously disturbed sites within
the Project Area that has the potential for the presence of contamination. The ESA will be conducted prior
to the commencement of construction activities and will adhere to AENV’s Phase I Environmental Site
Assessment Guideline for Upstream Oil and Gas Sites (AENV 2001), and the current 2010 Reclamation
Criteria for Wellsites and Associated Facilities Application Guidelines (AENV 2011b).
Additionally, BlackPearl will conduct a baseline monitoring program as per the requirements of the Soil
Monitoring Directive (Government of Alberta 2009) to identify potential sources of soil contamination prior
to the commencement of construction operations. In the event that any contamination is identified it will
be managed through the development of a site-specific Soil Management Plan. Additional details on soil
monitoring programs are provided in Volume 4, Section 4.8.
Page 11-10
11.3.4 Restoration of Equivalent Capability

BlackPearl is committed to restoring equivalent land capability for the reclaimed Project Area, as per
regulatory requirements. A comparison between the anticipated changes between the pre-disturbance
and post-reclamation land capability for soil, vegetation, wildlife and biodiversity are provided in the
following sections.
Landforms and vegetation may not be identical to pre-disturbance conditions upon completion of
reclamation. However, the reclaimed land capability will not be diminished from the pre-development
capability. Under the Environmental Protection and Enhancement Act (EPEA) (GOA 2006), it is required
that the target post-reclamation land capability and the proportions of the different capability classes
within the Project Area be equivalent to that of pre-development conditions.
BlackPearl will consider multiple end-land uses through reclamation, based on results from on-site
monitoring, BlackPearl’s regional and industry initiatives and consultation with regulators and
stakeholders throughout the life of the Project.
BlackPearl is dedicated to investigating and pursuing opportunities to address regional environmental

issues associated with the Project through collaborative efforts with other regional stakeholders.
Involvement in such efforts has the potential to provide many benefits including:
• providing forums for the discussion of issues and challenges shared among BlackPearl and other
parties;
• increasing the technical and intellectual capacity required to oversee and direct studies;
• sharing costs to ease financial constraints of undertaking potentially costly studies;
• facilitating the sharing of data which can increase the quality of study conclusions; and
• establishing holistic focus to environmental studies and initiatives and land management.
BlackPearl is responsible for addressing the environmental issues related to the Project through
mitigation, monitoring, research and additional initiatives. BlackPearl will utilize the following factors to
evaluate whether participation in a regional initiative is appropriate.
• The initiative assists BlackPearl with meeting the requirements of approval conditions and other
commitments.
• Participation in the initiative will result in the sharing of information and experience with all parties
involved.
• Participation in the initiative achieves BlackPearl’s objectives for better management and reduction of
cumulative environmental impacts.
BlackPearl currently is in discussions to determine its level of participation with the following working
groups and initiatives.
• Oil Sands Developers Group.
• Alberta Caribou Committee.
• Alberta Biodiversity Monitoring Institute.
• Ecological Monitoring Committee of the Lower Athabasca.
• Cumulative Environmental Management Association.
• Portage College Forestry and Natural Resources Technician Program.
Page 11-11
11.3.4.1 Land Capability for Forest Ecosystems

The predicted changes in land capability pertaining to forestry resulting from the Project are discussed in
Volume 5.0. A summary of changes to land capability classification from baseline case to reclamation
phase of the Application Case is provided in Table 11.3-5.
TABLE 11.3-5
CHANGES TO LAND CAPABILITY CLASSIFICATION IN THE LSA
Conditions at Conditions During Construction Conditions Following Decommissioning

Baseline and Operations and Reclamation
Change in % Change in %
Area of Area Change Area Change
Land Land Relative to Relative Area of Land Relative to Relative
Capability Capability % of Baseline to Capability % of Baseline to
Class Area (ha) % of LSA Class (ha) LSA (ha) Baseline Class (ha) LSA (ha) Baseline
2 2,397.4 39.1 2,129.2 34.7 -259.5 -4.2 2,452.7 40.0 55.3 0.9
3 1,425.5 23.2 1,181.1 19.2 -244.4 -4.0 1,556.3 25.4 130.8 2.1
4 92.4 1.5 69.1 1.1 -23.3 -0.4 69.1 1.1 -23.3 -0.4
5 (Undisturbed 1,985.0 32.3 1,700.7 27.7 -291.7 -4.8 1,835.5 29.9 -149.5 -2.4
soil)
5 (Disturbed 167.2 2.7 988.6 16.1 821.6 3 13.4 153.8 2.5 -13.4 -0.2
Land)
Water (not 6.5 0.1 6.5 0.1 0.0 0.0 6.5 0.1 0.0 0.0
rated)
Rough Broken 62.5 1.0 61.3 1.0 -1.2 < -0.1 62.5 1.0 0.0 0.0
(not rated)
Total4 6,136.4 100 6,136.4 100 0 0 6,136.4 100 0 0
Notes:
1 The change in area considers that 31.9 ha of previously disturbed land occur within the Project Area.
2 Disturbed land remaining in the LSA includes previously disturbed areas outside of the Project Area (not attributed to the Project), as well as
previously disturbed access roads falling inside the Project Area which will not be reclaimed.
3 The area of direct disturbance is 852.5 ha
4 Totals may not add due to rounding
11.3.4.2 Closure Phase and Land Capabilities

Project developments on mineral soils, such as the CPF, well pads and multi-use corridors, are planned
to be reclaimed to an equivalent Land Capability Classification as the Baseline Case and adjacent
undisturbed uplands (LCCS classes 2 through 4). The predicted changes in Land Capability for forest
ecosystems within the LSA are presented in Table 11.3-5.
The expected LCCS classes at closure for reclaimed well pad areas in deep peatlands are expected to
have a rating of LCCS class 2, 3 and 5 as follows.
• Transitional Shallow Peat wetland areas established on reclaimed well pads on peat are anticipated
to have a LCCS rating of Class 3 due to the target soil moisture regime;
• The upland area of an access road or well pad within deep peatlands is anticipated to have an LCCS
rating of Class 2 (conditionally productive); and
• A portion of each well pad will have the fill and geotextile removed; it is anticipated that these areas
will return to wetland soils with a LCC rating of Class 5;
• A reduction in the area for LCCS classes 4 and 5 within the LSA is anticipated due to the reclamation
of portions of the well pads and access pads within areas of deep peat to upland ecosites.
Page 11-12
Changes in the extent of forested land based on timber productivity ratings (TPR) between the Baseline
Case and closure phase is summarized in Table 11.3-6. A more detailed discussion of the Project related
effects on forest resources is provided in the Land Use and Management Assessment (Volume 5,
Section 1.0).
TABLE 11.3-6
CHANGES TO FORESTED LAND FROM BASELINE CASE TO APPLICATION

CASE AT CLOSURE PHASE IN THE LSA
Timber Productivity Area at the Baseline Area at Reclamation Change from Baseline Case to Reclamation Phase
Rating Case (ha) Phase (ha) Area (ha) % Difference
Good 1925 1925 0 0
Moderate 2552.3 2552.3 0 0
Fair 714.3 714.3 0 0
Unproductive 901.8 901.8 0 0
Not Classified 43.4 43.4 0 0
Total 6136.7 6136.7 0 0
11.3.4.3 Reclamation Suitability

Volume 4, Section 4.0, contains the results of the soil suitability assessment for reclamation. The physical
and chemical properties of the soil in this assessment assist in the determination of soil limitations and
special handling requirements for reclamation plan development. A summary of the reclamation suitability
for the soils within the Project Area is provided in Table 11.3-7
TABLE 11.3-7
SUMMARY OF RECLAMATION SUITABILITY CLASSES FOR DISTURBED SOILS IN THE LSA
Upper Lift - Topsoil Lower Lift - Subsoil

Reclamation Suitability Class Area (ha) % of LSA Area (ha) % of LSA
Good 400.4 6.5 39.9 0.6
Good-Fair 2015.8 32.8 9.2 0.1
Fair 1446.5 23.6 1167.5 19.0
Fair-Poor -- -- 2646.1 43.1
Organic (not rated) 2037.4 33.2 2037.4 33.2
Water (not rated) 6.6 0.1 6.6 0.1
Rough Broken (not rated) 62.5 1.0 62.5 1.0
Disturbed Land (not rated) 167.2 2.7 167.2 2.7
total 6136.4 100 6136.4 100
11.3.4.4 Biodiversity
A detailed discussion of the Baseline Case, Application Case and Planned Development Case for
biodiversity is provided in Volume 4, Section 3.0.
Although not all portions of the Project Area will be returned to pre-disturbance soil units and vegetation
communities, efforts will be made to maintain landscape diversity and biodiversity comparable to Baseline
Case conditions. Landscape diversity will be maintained through reclamation activities that strive to
replace the structural and chemical properties, organic matter and nutrient content of the salvaged soil.
These properties are integral to the establishment of soil biota, which in turn drive ecological functions
within the soil that support plant and animal communities. The biophysical features of the reclaimed
developments are expected to follow a successional pattern similar to the natural landscape.
Alteration of terrain types and topography are anticipated as a result of the construction activities within
the Project Area. Diverse terrain types tend to support a diversity of soil types and vegetation
Page 11-13
communities. Pre-disturbance terrain types will be replaced by reclaimed terrain upon completion of
reclamation. Landscape function and drainage patterns will be restored, however the spatial arrangement
of pre-disturbance terrain types will not.
Site-specific revegetation plans will include planting prescriptions to support regeneration of characteristic
woody species for target Ecosite Phases. By implementing site-specific planting prescriptions,
successional trajectories will be established that will facilitate re-establishment of plant and animal
communities and, therefore, biodiversity. Planting prescription details are provided in Section 11.4.5 and
a detailed assessment of the interaction of the Project with biodiversity is provided in Volume 4,
Section 3.0.
11.3.4.5 Wildlife Habitat Management

BlackPearl anticipates that re-established ecosystems on disturbed lands will become self-sustaining and
capable of maturing naturally over the long term. These ecosystems will provide suitable habitat for
resident and migratory wildlife species. The aim of the C&R Plan is to establish upland wildlife habitats
compatible with equivalent areas in the surrounding landscape. BlackPearl shall implement strategies to
minimize the potential effects of the Project to wildlife such as:
• schedule clearing to occur outside the migratory bird restricted activity period (RAP)
(May 7 to August 20; April 20 to August 25 for wetlands attractive to migratory birds),
and limit late winter clearing to reduce disturbance of wildlife during sensitive late winter
periods; conduct pre-clearing nest surveys if clearing is scheduled to occur during the
migratory bird nesting period and consult with AESRD/Environment Canada regarding
recommended mitigation measures should occupied nests be discovered;
• allow for regeneration of native deciduous vegetation and replanting of coniferous

species in prescriptions comparable with the surrounding vegetation communities;
• reclaim corridors as soon as practical after they are no longer required for Project
operation;
• implement progressive reclamation on the Project Area no longer required for

operations; and
• implement measures to control sight-lines and access, where feasible.
A description of the wildlife resources and a more comprehensive list of mitigation measures are provided
in the Wildlife (Volume 4, Section 2.0).
11.3.4.6 Traditional Land Use

The Project is situated within the traditional areas of the Chipewyan Prairie Dene First Nation, Fort
McMurray First Nation, Heart Lake First Nation, and Beaver Lake Cree Nation, as well as Metis from
Kikino, Buffalo Lake, Metis Local # 1949 Owl River, Metis Local # 2010 Athabasca Landing, and Metis
Local # 1909 Lakeland.
BlackPearl is working with with Chipewyan Prairie Dene First Nation, Fort McMurray # 468 First Nation
and Heart Lake First Nation, the Kikino Metis and Buffalo Lake, and the Metis Locals 1909, 1949 and
2010, as part of Traditional Land Use studies (TLU). TLU studies have been completed by the Metis
Locals 1909, 1949 and 2010. Heart Lake First Nation has completed the TUS study, however, the final
report has not yet been received by BlackPearl. Additionally, BlackPearl is attempting to consult with
Beaver Lake Cree Nation and the Kikino and Buffalo Metis Settlements. The information obtained through
the TLU/TEK studies will be utilized to assist BlackPearl with determination of potential effects of the
Project within the TLU regional study area and Project planning. Refer to Volume 1, Section 2.0 for
further details on consultation.
Page 11-14
11.4 Conceptual Conservation and Reclamation Plan

The implementation of the C&R Plan is an integral part of pre-construction planning. The use of the C&R
Plan provides a means of ensuring that conservation and reclamation procedures are utilized during
construction, operation, decommissioning and reclamation of the Project. BlackPearl’s planning process
will take into consideration guidelines from multi-stakeholder committees as well as recommendations
from regulatory bodies and, where feasible, interested stakeholders. Prior to the commencement of
reclamation activities for any development associated with the Project, BlackPearl shall consult with
AESRD reclamation officers and directly affected stakeholders to make certain that the appropriate site-
specific reclamation plans are utilized.
This C&R Plan is organized according to the four stages of activities to be undertaken, which includes:
Facility Construction
• Timber Salvage;
• Vegetation Clearing; and
• Soil Salvage:
− Upland Mineral;
− Subsoil;
− Shallow Peat; and
− Deep Peat.
• Borrow Pit Construction;
• Soils Material Balance; and
• Soil Stockpiling.
Facility Operation
• Progressive Reclamation;
• Erosion Control;
• Weed Management; and
• Water Management.
Decommissioning and Reclamation

• Soil Replacement; and
• Re-vegetation.
Closure Phase
• Post-Reclamation Monitoring.
Page 11-15
11.4.1 Facility Construction

11.4.1.1 Timber Salvage Plan
The PDA’s and adjacent vegetation communities will be considered when creating site-specific planting
prescriptions at the time of reclamation. BlackPearl will participate and develop an Integrated Land
Management Plan with Alberta-Pacific Forest Industries (Al-Pac) and Millar Western. Volume 5,
Section 1.6 outlines BlackPearl’s commitments towards involvement in regional land management plans
and mitigation of conflicts between the Project and current land use planning.
All applicable regulatory requirements shall be followed for the harvesting of merchantable timber within
the Project Area. Measures include the following.
• All merchantable timber salvage and woody debris disposal shall be conducted as per direction by
AESRD.
• Salvage and brushing will be avoided during migratory bird nesting seasons unless authorized.
• If salvage and brushing programs are authorized during migratory bird nesting season, BlackPearl
shall conduct nest sweeps on the applicable developments prior to clearing and consult with
AESRD/Environment Canada regarding recommended mitigation measures should occupied nests
be discovered. The results of the assessment shall be documented and provided in the Annual C&R
report.
• Tree salvage and brush clearing will be performed as early as possible during late fall/winter salvage
operations in accordance to the Enhanced Approval Process Integrated Standards and Guidelines
(ESRD 2013b).
• Construction activities will continue at the CPF, well pads and other areas cleared prior to restricted
activity periods unless otherwise notified by AESRD.
Vegetation surveys will be conducted as part of the PDA to record site specific vegetation resources
present prior to disturbance. Vegetation communities will be classified to ecosite phase using the
ecological land classification as in the field guide to Ecosites of Northern Alberta (Beckingham and
Archibald 1996). The abundance of characteristic species will be recorded for each ecosite phase. The
abundance and distribution of non-native and invasive plant species will be recorded and site specific
weed management practices will be developed. Rare plant and rare ecological community surveys will
also be conducted during PDA’s.
Merchantable Timber
BlackPearl will co-ordinate with Millar Western and Al-Pac to ensure that all merchantable timber within
the Project Area is salvaged prior to commencement of construction activities. Merchantable timber will
be defined as follows.
Merchantable Coniferous Tree:
• tree species will be considered merchantable when it has a minimum 15 cm diameter,

at 30 cm above ground level, and a usable length of 3.66 m with a top diameter of
11 cm.
Merchantable Deciduous Tree:
• tree species will be considered merchantable when it has a minimum 15 cm diameter,

at 30 cm above ground level, and a usable length of 3.66 m with a top of 10 cm.
Timber salvage activities shall, at minimum, follow the following requirements:
• reforested cutblocks will not be utilized for decking sites;
Page 11-16
• preference for decking site placement will be in existing cleared areas. In the event that
no existing clearings are present within proximity of the timber salvage activity, the use
of non-merchantable timber stands or merchantable stands shall be considered upon
consultation with AESRD;
• salvaged logs shall be limbed flush and topped to specifications;
• log decks shall be orientated to facilitate removal and loading on trucks; and
• salvaged timber shall be removed from Project developments prior to the

commencement of reclamation.
Details on the estimated volumes of merchantable timber to within the LSA are summarized in
Table 11.4-1.
TABLE 11.4-1
ESTIMATED TOTAL MERCHANTABLE TIMBER VOLUME WITHIN THE LSA
Volume (m3)
Dominant Forest Cover Coniferous Deciduous
Type Yield Class TPR (G) TPR (M) TPR (F) TPR (G) TPR (M) TPR (F) Total
Coniferous
Sb-C-FM 0 37528.2 6048.3 0 2778.2 1388.6 47753.4
Sb-C-G 9154.8 0 0 1459.8 0 0 10614.5
Sb-O 6298.5 32907.6 16706.4 514.8 1984.4 1126.7 59538.4
Sw-C-FM 0 11550 255.7 0 3083.1 82.1 14970.8
Sw-C-G 19015.7 0 0 3133.4 0 0 22149.1
Sw-O 18034.4 52726 1172.3 2806.6 9716.3 297 84752.7
Coniferous-Deciduous
SAw-S 10827.5 14911.2 899 9948.8 9850.3 1117.9 47554.7
Deciduous-Coniferous
AwS-S 4576.7 6812.1 14121.7 4563.4 7932.9 16475.7 54752.6
Deciduous
Aw-Comp 1036.5 2206.1 343.9 16248.4 29246.7 4319.7 53401.3
Aw-S-C-S 1736.8 2638.1 2376.2 8858 8442.8 9584.7 33616.7
Aw-S-O 0 829.6 561.1 3138.6 5906.8 5132.3 15568.4
Non-Merchantable Timber
3
Project developments which contain merchantable timber density less than 50 m /ha, shall be treated as
non-merchantable and a waiver from AESRD obtained.
Upland sites with less than 40 cm of surface peat containing non-merchantable timber will be cut using a
feller buncher and skidder and cleared with a bulldozer equipped with a brush rake. Woody stems will be
broken so that they lie flat on the ground surface. The woody debris disposal shall be via on-site burning,
or removed to a borrow location for future disposal. A portion of woody material may be retained for future
reclamation material or erosion control.
Developments with surface peat deeper than 40 cm will be mulched. BlackPearl will strip the mulch and
utilize it as a base layer on undisturbed peat, no thicker than 5 cm, within the stockpile area. The salvage
peat shall be placed on top of this base layer.
Page 11-17
11.4.1.2 Vegetation Clearing

BlackPearl shall conduct vegetation clearing to the extent that will allow for the completion and operation
of the Project’s various developments while establishing appropriate setbacks between the facilities and
watercourses/riparian areas. Riparian vegetation will not be controlled during the operations phase of the
Project. Volume 3, Section 4.7.1 (Aquatic Ecology Assessment) discusses minimum setbacks and buffers
for riparian areas. Where feasible, areas previously cleared for well pads, access roads and pipeline right-
of-ways shall be used. Project developments will be cleared according to the Forest and Prairie
Protection Act, the Timber Management Regulations, and any associated regulations applying to site
clearing, disposal of debris and on-site firefighting equipment.
Volume 3, Section 1.6.1 describes the mitigation measures towards the direct loss of native vegetation,
which include.
• The Project Area will be minimized to the extent practical. Existing linear corridors will be used for
access and installation of new infrastructure, where feasible. Project developments will be integrated
with other proposed land use activities to reduce the area of disturbance and new clearings.
BlackPearl will use existing cutlines that are starting to regenerate only when other reasonable
options do not exist. The use of directional drilling (i.e., multi-well pads) will reduce the number of well
pads required.
• Proposed facilities will be located on elevated, relatively level, non-organic, well-drained areas, where
feasible. Facilities will be located in areas that will reduce requirements for grading and modification
to drainage, where feasible.
• Final Project siting will consider reducing disturbance of mature and old-growth forest as much as
practical.
• PDAs will be conducted to identify site-specific vegetation issues including rare plant populations,
rare ecological communities and baseline abundance and distribution of weedy species.
• Construction will be scheduled to occur during frozen ground conditions.
• All construction activities and construction traffic will utilize the approved, surveyed access roads,
facility boundaries and approved temporary workspace.
• Grubbing will be minimized in order to limit the area of disturbance and potential damage to adjacent
trees. Small trees and shrubs will be mowed or cut to ground level rather than grubbing or wholly
removing, if feasible, to facilitate regeneration following construction.
BlackPearl will implement the following mitigation measures to avoid or reduce Project effects on wetland
vegetation resources (Volume 4, Section 1.6.1).
• PDAs will be conducted prior to construction to confirm the location of Project disturbances with
respect to wetlands. Where possible, facilities should be sited in non-wetland locations, particularly
deep peatland or open water wetlands.
• Clearing and site preparation activities will be scheduled to avoid periods of high water (i.e., spring
and wet weather).
• Drainages will be staked during the fall or prior to heavy snowfall, if feasible, to assist in locating gaps
in the trench crown (for buried pipelines) and topsoil windrow, as well as locating and aligning culverts
(for access roads). This will reduce the alteration of drainage and avoid flooding or erosion problems
during spring break-up.
• Grading will be minimized as much as practical. If necessary and to the extent practical, grading will
be conducted away from any open water to reduce the risk of sedimentation. Wetland soils will be
stored separate from upland soils.
Page 11-18
Vegetation clearing shall be avoided whenever feasible from May 7 to August 20 (April 20 to August 25 in
wetlands attractive to migratory birds) to avoid the nesting and fledging period for migratory birds. In the
event that clearing will be required during this period, BlackPearl shall perform a pre-construction nest
survey and consult with AESRD/Environment Canada regarding recommended mitigation measures
should occupied nests be discovered. Mitigative measures for rare plant populations generally fall into
categories of avoidance, reducing disturbance and alternative reclamation techniques. Where rare plants
populations are encountered, avoidance shall be the primary mitigation tool. If realignment of the Project
Area is not feasible to avoid or reduce disturbance to an identified rare plant or rare ecological
community, BlackPearl shall assess the use of the mitigation outlined in the Rare Ecological Community
and Rare Plant Populations Discovery Contingency Plan (Volume 4, Appendix 1B) in consultation with
vegetation specialists, and where appropriate, the land authority. The agreed-upon mitigation measures
will be implemented to protect rare vegetation resources.
11.4.1.3 Soil Salvage

Conservation and mitigation measures for soils specific to facility type and site conditions are integral to
the success of reclamation. Eighteen soil units were identified within the Project LSA. The Project LSA
contains mineral soils with varying combinations of Luvisolic and Brunisolic soils, Gleysolic and Organic
soils. A description of the soil series, the surface soil and subsoil characteristics are provided in Volume
4, Section 4.0. Section 11.4.1.9 provides a summary of the soil balances for the Project.
Mitigation strategies designed to limit the effects of the Project on soil quality during facility construction
include:
• minimization of the amount of soil disturbance, where possible;
• avoiding construction when soils are wet;
• avoiding grubbing following merchantable timber harvest to preserve surface

organic material and topsoil; and
• use of an environmental monitor during construction, soil salvage and stockpiling

operations to ensure that topsoil and subsoils are salvaged and stockpiled in
accordance to approval conditions.
Soil will be excavated and stockpiled at the nearest suitable facility. Soils will be stockpiled and the
source location recorded for use during the reclamation of the project development. The double handling
of soil material will be prevented through the following procedures:
• Completion of a Pre-Development Assessment (PDA) of the development to be

constructed. The PDA will provide data on the soil types and volumes within the
site to assist with the salvage and stockpiling operations.
• Pre-planning of soil stockpile sites to ensure that adequate area is available for
proper stockpiling of the salvaged material. Preference will be to place salvaged
soil material at the development site. In instances where organic soils or peat is
present, the soil material will be stockpiled at a designated soil stockpile facility.
• Adequate design of the stockpiles to avoid soil movement due to slope instability or
erosion.
• Soils will be salvaged and transported directly to the allocated soil storage area.
Soils will not be stockpiled at an interim site prior to final storage
Page 11-19
11.4.1.4 Upland Mineral Soil Salvage

Topsoil is an important determinant for land capability. Surface soil salvage on Project development will
consist of the surface duff layer (LFH), organic peat (Of/Om) plus mineral (Ah/Ae/AB) horizons. Topsoil
salvaged will occur on all upland sites of the Project Area, with the exception of log decks. General
mineral soil salvage guidelines are provided in Table 11.4-2. Additionally, the following measures will be
followed for upland mineral soil salvage to conserve the quality and quantity of the available soil:
• a PDA shall be conducted on each development prior to the commencement of construction to

develop site-specific soil handling guidelines;
• soil salvage and handling shall not occur during wet conditions or high wind velocities that may result
in the degradation and/or loss of topsoil;
• surface ripping may be conducted where winter soil salvage is required to reduce the potential for
admixing the topsoil and subsoil;
• all mineral soils will be salvaged and handled separately from upper subsoil material. The salvaged
topsoil will be stockpiled separately from the subsoil on site or at a designated stockpile site. LFH or
shallow peat material will be salvaged and stockpiled with the “A” horizon material; and
• the stockpiled soil shall be identified at the storage site through the use of signage and documented
for future reclamation activities.
A conceptual illustration showing the construction of a well pad requiring cut and fill within upland mineral
soil is provided in Figure 11.4-1. Soils salvaged from Project multi-use corridors (i.e., rights-of-way) in
upland environments will be stockpiled along the boundary of the multi-use corridor furthest from the
road. Salvaged soils will not be windrowed or replaced along the access road edge. Soils salvaged from
Project corridors in wetland environments will be stored at the designated soil stockpile facility at the
existing Pilot site. Figure 11.4-2 illustrates the conceptual access road construction and reclamation in an
upland environment.
TABLE 11.4-2
MINERAL SOIL AND ORGANIC PEAT TOPSOIL SALVAGE GUIDELINES FOR PROJECT
DEVELOPMENTS WITHIN THE LSA
Topsoil Thickness Peat Thickness Average

Soil Series Parent Material General Topsoil Salvage Average (Range) (cm) (Range) (cm)
Horse River Glacial Till Salvage all topsoil material 20 (10-44) N/A
Hazelmere Glacial Till (LFH/Shallow Peat plus all “A” 21 (10-39) N/A
horizon soil)
Hazelmere-pt Glacial Till 32 (22-49) N/A
Livock Glaciofluvial overlying 21 (18-25) N/A
Glacial Till
Ells River Glacial Till Salvage surface LFH, peat and 16 (5-31) N/A
Steepbank Glacial Till the underlying “A” horizon 12 (4-26) N/A
(where present)
Steepbank-zz Glacial Till 18 (9-25) N/A
Ells River-pt Glacial Till Salvage topsoil only (Of/Om/Oh 30 (15-55) N/A
Steepbank-pt Glacial Till and A, if present). No salvage 26 (15-50) N/A
of mineral subsoil horizons.
Firebag-xt Glaciofluvial overlying Salvage all topsoil material 24 (13-33) N/A
Glacial Till (LFH/Shallow peat plus all “A”
horizon soil)
Hartley Organic/Glacial Till Salvage 40 cm of peat N/A 51 (40-70)
Hartley-zz Organic/Glacial Till N/A 82 (41-190)
McLelland Organic N/A 238 (160-390)
McLelland-xt Organic/Glacial Till N/A 86 (42-150)
McLelland-zz Organic N/A 209 (165-330)
Mariana Organic/Glacial Till N/A 82 (43-150)
Muskeg Organic N/A 222 (160-320)
Page 11-20
11.4.1.5 Subsoil Salvage

Subsoil shall be salvaged from upland soils to a maximum thickness of 30 cm. BlackPearl will salvage the
subsoil from access rights-of-way when encountered. Subsoil is not a suitable material for construction of
road beds, therefore, it will be salvaged and stockpiled along the road edge or the nearest suitable facility.
Subsoil will be replaced upon reclamation. The general subsoil salvage and average subsoil thickness by
soil series is provided in Table 11.4-3.
TABLE 11.4-3
SUBSOIL SALVAGE GUIDELINES FOR PROJECT DEVELOPMENTS WITHIN THE LSA
Subsoil Thickness
Soil Series Parent Material General Subsoil Salvage Average (Range) (cm)
Horse River Glacial Till Salvage a maximum thickness 34 (18-61)
Hazelmere Glacial Till of 30 cm within the CPF, Well 35 (9-66)
Pads and Borrow Areas.
Hazelmere-pt Glacial Till 33 (17-50)
Subsoil salvage not required
Livock Glaciofluvial overlying elsewhere. 44 (33-63)
Glacial Till
Ells River Glacial Till 7 (0-48)
Steepbank Glacial Till 31 (10-60)
Steepbank-zz Glacial Till 32 (16-50)
Ells River-pt Glacial Till 10 (0-70)
Steepbank-pt Glacial Till 34 (7-85)
Firebag-xt Glaciofluvial overlying 32 (15-40)
Glacial Till
Hartley Organic/Glacial Till No Subsoil Salvage N/A
Hartley-zz Organic/Glacial Till N/A
McLelland Organic N/A
McLelland-xt Organic/Glacial Till N/A
McLelland-zz Organic N/A
Mariana Organic/Glacial Till N/A
Muskeg Organic N/A
11.4.1.6 Shallow Peat

Peat material will be salvaged on Project developments (well pads, access roads and associated
infrastructure) within shallow peat to a maximum depth of 40 cm. Shallow peat sites are commonly found
in the transitional areas between upland and deep peatland (greater than 40 cm); they are characterized
by Gleysolic soils. Topsoil will be salvaged separately from the upper subsoil of shallow organic soils.
There will be no admixing of peat and mineral subsoil.
The salvaged peat material shall be stored on site in designated storage areas or at a designated
stockpile area within an existing clearing. Salvaged peat material will not be stored in wetland areas. The
material will be stockpiled at the nearest upland environment. If there is insufficient upland area within the
lease pad, the salvaged material will be stockpiled at the nearest suitable facility (e.g., well pad). Soil
surveys will be conducted as part of the PDA to develop site specific soil handling measures. A
conceptual illustration showing the construction of a well pad requiring cut and fill within both upland and
shallow peat is provided in Figure 11.4-3.
11.4.1.7 Deep Peat

Construction of well pads on regions of deep peat will involve the salvage of a maximum of 40 cm of peat
which will be stockpiled in the designated storage area. Peat material salvaged from wetland areas will
not be stored in wetland areas and will be stockpiled at the nearest suitable facility. Subsoil shall not be
salvaged on deep peat sites due to excessive moisture. Geotextile fabric shall be installed and overlain
with geogrid. Fill material will be imported to the site and deposited in layers and compacted until the
appropriate height is achieved. The conceptual illustration of well pad construction within deep peat
environments is provided in Figure 11.4-4.
Page 11-21
Access roads construction on regions of deep peat will be consistent with the construction of well pads.
The upper 40 cm of peat will be salvaged and stockpiled in a designated storage area; geotextile or
geogrid will be installed at the base of the access road pad prior to the importing of borrow material to
build up the access road. Construction material for the padded access road will be obtained from
designated borrow pits.
Water movement is essential to maintaining the biological integrity of peatlands. BlackPearl will follow
best management practices for facilities constructed in regions of deep peat to mitigate the potential
changes to surface water flow rates. The following measures will be applied for the construction of
facilities in wetland areas:
• culverts on access roads will be installed approximately every 400 m to maintain hydrological
connectivity; and
• ditches shall be constructed to direct the flow of surface water away from the facility.
11.4.1.8 Borrow Pit Construction

Borrow pit material will be required for the construction of facilities. Potential borrow areas have been
located primarily on upland mineral soils derived from glacial till parent material.
The actual excavated areas within the borrow sites will be chosen based on:
• minimization of the overall impact; and
• maximization of the use of borrow material.
Borrow areas excavation shall only occur to the extent that the material is required for the facilities. Prior
to the commencement of construction activities for each phase of the Project, the associated borrow sites
will be confirmed following the completion of geotechnical investigations. PDAs will be conducted prior to
construction to confirm if proposed borrow pits are located within deep or shallow peat wetlands. If a
proposed borrow pit is confirmed to be within a deep peat wetland the location will be moved to a more
suitable location. To extend the life of the borrow areas BlackPearl shall re-use materials (gravel, clay fill)
from well pads and roads where practical. A diagram identifying sources of borrow, aggregate and other
sources of construction material is provided in Figure 11.4-5.
The following measures will be implemented to ensure the conservation of the quality and quantity of
salvageable soils within the borrow areas:
• prior to commencement of construction activities at the borrow site(s) BlackPearl shall conduct a PDA
to develop site-specific soil handling guidelines;
• surface soil salvage on Project development will consist of the surface duff layer (LFH), organic peat
(Of/Om) plus mineral (Ah/Ae/AB) horizons. All available surface soil shall be salvaged;
• salvaged surface soil shall be stockpiled separately from subsoil;
• an environmental monitor shall be present during the soil salvage to ensure the minimization of soil
loss through admixing or insufficient removal;
• when shallow peat is encountered (up to 40 cm), the peat materials will be over-stripped with equal
amounts of underlying subsoil. The salvaged shallow peat shall be stockpiled separately from
salvaged mineral soils and subsoil; and
• a maximum of 30 cm of subsoil will be salvaged from upper mineral and transition soils (when
present).
Soil handling measures will follow the methods outlined in Volume 1, Section 11.4.1.3 and Volume 4,
Section 4. BlackPearl will re-use borrow material as much as feasible as a means to reduce the size and
Page 11-22
number of borrow pits required. Borrow areas will be constructed as landscape borrows when feasible
and reclaimed to regulatory specifications.
All slopes of the exhausted borrow areas within one vertical meter above and below the full supply level
will be recontoured to a minimum of 5:1 slope. Slopes less than 1 m below the full supply level will be re-
contoured to a minimum of 3:1 slope. Poor construction material and subsoil stockpiled during the
development of the borrow pit will be utilized for re-contouring of the exhausted borrow pits. During the
operational lifespan of the borrow pit, all non-specified spoil material will be stockpiled within the borrow
area. Figures 11.4-6, 11.4-7 and 11.4-8 provides conceptual diagrams of borrow site construction and
reclamation. All non-specified materials (lower subsoil, sand, aggregate) will be stockpiled separately in
the non-operational area of the borrow pit during the excavation phase (Figures 11.4-6, 11.4-7 and
11.4-8). Upon reclamation of the borrow area the material will be utilized to recontour the slopes of the
excavated area to achieve the desired slope ratio. An estimate of the volume of non-specified materials
anticipated at the borrow pit locations is provided in Table 11.4-4.
Page 11-23
Original Landscape
(Cross Section)
c1
Upper Subsoil
Topsoil
Parent Material (C Horizon)
Constructed Pad
(Cross Section)
Sub-soil Topsoil
c1 Storage Well Pad Storage c1
Berm and Original External Ditch
Ditch Ground Where Required
Surface

Rows of Wells
1. Salvage topsoil and upper subsoil and stockpile separately in the storage area. 2. Construct well pad with imported borrow material, or cut
and fill if required (external ditches constructed where required). 3. Cover pad with gravel.
Reclaimed Pad
(Cross Section)
Target Ecosite Phase c1
Replaced Replaced
Topsoil Upper Subsoil

Abandoned Wells
1. Abandon well with > 2.0m cover. 2. Decompact and recontour any borrow material and subsoil material. 3. Replace upper subsoil and topsoil.
4. Revegetate as per C & R Plan.
Note: c1 = Labrador tea - mesic - jackpine - black spruce.
Legend FIGURE 11.4-1
CONCEPTUAL WELL PAD CONSTRUCTION &

Borrow Material RECLAMATION: UPLAND MINERAL SOIL
Black Spruce (Sb)
Topsoil (A Horizon) PROPOSED BLACKROD
Former Constructed Pad COMMERICAL SADG PROJECT
Upper Subsoil (B Horizon)

Original Ground Surface Jack Pine (Pj)
Cross Sections FIGURE 11.4-2
Pre-Development CONCEPTUAL ACCESS ROAD CONSTRUCTION AND
RECLAMATION: UPLAND ENVIRONMENT

PROPOSED BLACKROD
Topsoil
Subsoil
Parent Material “C” Overhead View - Constructed
A A1
Constructed
Power Pole
Pipeline Rack
Topsoil
Wetland
Subsoil Stockpile Stockpile
Culverts
Topsoil Access Road

Subsoil
C Horizon
Topsoil Stockpile
Access Road
A A1
1. Topsoil salvaged from the access will be stockpiled along one side of the right-of-way where the transmission line will be placed.
2. Breaks will be constructed to allow wildlife access across the corridor. 3. Topsoil salvaged from wetlands shall be stockpiled at an upland site.
Reclaimed
Replaced Topsoil
Topsoil Stockpile
A A1
Topsoil
Subsoil
Replaced Subsoil
C Horizon
A 1. Remove gravel from access and recycle for use on other developments. 2. Remove any culverts and recontour the access road to restore the A1
drainage patterns. 3. Recompact the road area. 4. Replace the stockpiled subsoil and topsoil over the recontoured road. Pipelines Power Poles
Original Landscape
c1 Existing Wetland Vegetation (g1, STNN)
Organic
Parent Material (C Horizon) Material
(Peat
< 40cm)
Soil Salvage & Storage
Existing
Mineral Soil Peat Mineral Wetland
Stockpile Working Area Stockpile Vegetation
Woody Debris
Original Ground or Mulch
(5cm Thick)
Surface
Peat
1. Remove 40cm peat, plus equal amounts of under lying mineral soil. 1:1 ratio. 2. Stockpile peat mineral soil in storage area.
3. Salvage topsoil and subsoil, stockpile separately.
Construction Pad Peat Mineral

Stockpile
Mineral Soil Existing

Peat Mineral Wetland
Stockpile
Working Area Stockpile Vegetation
Woody Debris
or Mulch
Berm
(5cm Thick)
Berm
Cut & Fill
Material
Peat

Rows of Wells
1. Construct well pad with cut and fill material (import borrow material where required). 2. Cover working area with gravel.
Reclaimed Pad Existing

Wetland
Target Ecosite Phase (c1) Target Ecosite Phase (g1) Vegetation Reclaimed Pad
Mineral/Peat Replaced Mineral/
Mix Peat Mix
g1 Target
Ecosite Phase
c1 Target
Ecosite Phase
Replaced Upper
Subsoil Replaced Topsoil
Transitional Wetland
Parent Material (C Horizon) Abandoned Wells
1. Remove gravel and borrow material where applicable. 2. Decompact and recontour subsoil material. 3. Replace uppper subsoil
and topsoil in c1 area. 4. Place surface peat and clay mix on g1 area. 5. Replace salvaged organic material. 6. Revegetate as per C&R Plan
Note: c1 = Labrador tea - mesic - jack pine - black spruce. g1 = Labrador tea - subhygric black spruce - jack pine
FIGURE 11.4-3
Legend Upper Subsoil (B Horizon) Woody Debris or Mulch CONCEPTUAL WELL PAD CONSTRUCTION &
RECLAMATION: UPLAND & WETLAND SOILS
Mineral / Peat Mix
Former Constructed Pad BLACKPEARL RESOURCES INC.
Peat Black Spruce (Sb) PROPOSED BLACKROD
COMMERICAL SADG PROJECT
Parent Material Original Ground Surface

(C Horizon)
Replaced Salvaged Peat Jack Pine (Pj)
Topsoil (A Horizon) (Fill & Geotextile Removed)
Original Landscape
Existing Wetland Vegetation (j1)
Organic
Material
(Peat)
Organic Material
(Peat >40cm)
Peat
Peat Salvage & Storage

Existing Wetland Existing
Vegetation Peat Wetland
Woody Debris
Original Ground or Mulch
Surface
Peat
1. Mulch well pad. 2. Remove 40cm of surface peat and stockpile in storage area.
Constructed Pad
Existing Wetland Existing
Vegetation Peat Wetland
Borrow Berm
Berm Material and Woody Debris
and Original Ground Geotextile
Rows of Wells Ditch or Mulch
Ditch Surface and Geogrid
Peat
1. Install geotextile and geogrid and construct well pad with imported borrow material. 2. Cover with gravel.
Reclaimed Pad
Existing Deep Peat Transitional Existing
Wetland Wetland Wetland Transitional Wetland
Vegetation (j1) (h1; STNN) Target Ecosite Phase (h1) Wetland Vegetation
Reclaimed Pad
Replaced Peat and/or Replaced Salvaged Peat
Replaced Salvaged Peat
Peat Mineral Mix (fill and geotextile removed)
(Fill & Geotextile Removed) Borrow Material Transitional
Wetland
h1 Target
Ecosite Phase
Peat
Parent Material (C Horizon) Abandoned Wells
1. Remove gravel and portion of clay pad where applicable. 2. Decompact and recontour. 3. Cover well > 2.0m cover.
4. Replace salvaged peat. 5. Revegetate as per C&R Plan.
Note: j1 = treed fen, STNN = treed swamp, h1 = Labrador tea - subhygric black spruce - jack pine
Legend Former Constructed Pad

FIGURE 11.4-4
CONCEPTUAL WELL PAD CONSTRUCTION &

Well Pad Material RECLAMATION: DEEP PEAT
Geotextile & Geogrid Black Spruce (Sb)
Peat PROPOSED BLACKROD
Original Ground Surface COMMERICAL SADG PROJECT
Parent Material Tamarack (Lt)
(C Horizon) Replaced Salvaged Peat
(Fill & Geotextile Removed)
Peat Material
Woody Debris or Mulch
Riv er
22 23 24 19 20 21
TWP.77
15 14 13 18 17 16
10 11 12 7 8 9
3 2 1 6 5 4
34 35 36 31 32 33
TWP.76 27 26 25 30 29 28
22 23 24 19 20 21
Note: Soil stockpile locations are approximate and not to scale.

Project Footprint Construction Camp Site Potential Aggregate Source
t6790_Figure 32-1s_Soil_Stockpile_Locations_20131113.pdf
FIGURE 11.4-5
Phase 1 Borrow Pit Permanent Operations (Rickard Excavation Ltd. -
Camp Site Surface Material Exploration) SOIL STOCKPILE, AGGREGATE AND BORROW
Phase 2 Sump Site MATERIAL SOURCE LOCATIONS
Proposed Blackrod Road Soil Material Stockpile Host Site
Phase 3A Log Deck Existing Blackrod Road (Pilot Location - Miscellaneous\ BLACKPEARL RESOURCES INC.
Phase 3B Soil Stockpile Location Mineral Surface Lease) PROPOSED BLACKROD COMMERCIAL SAGD PROJECT
UTM Zone 12N
Project Area: Altus Geomatics 2012 & Feb 19, 2013, modified by TERA Environmental Feb 19, 2013;
SCALE: 1: 50,000
Stockpile Locations: AltaLIS. 2013. Alberta Digital Integrated Dispositions; Meters
Hydrography: AltaLIS.Ltd 2011; Roads: IHS Inc. 2011. 0 500 1,000
CONCEPTUAL BORROW PIT CONSTRUCTION AND

Pre-Development RECLAMATION: UPLAND SELF DRAINING BORROW PIT

PROPOSED BLACKROD
Topsoil
Subsoil
Overhead View
Pre-Development
A A1
Constructed A A1
Subsoil Topsoil
Topsoil
Subsoil
Overburden
Constructed Extent of Excavation
Undisturbed Buffer
A A1
1. Salvage topsoil and subsoil and stockpile along pit boundaries.
Overburden
2. Excavate borrow material and stockpile overburden materials in the non-operating area of the pit. A A1
Reclaimed
Extent of Excavation
Reclaimed
5:1
Recontoured Topsoil
Slope Subsoil
A A1
Replaced
Extent of Overburden
Excavation
A A1
1. Recontour borrow pit area using the stockpiled overburden material to restore connectivity with adjacent drainage.
2. Replace salvaged subsoil and topsoil over the recontoured pit area. 3. Revegetate the borrow area.
Pre-Development CONCEPTUAL BORROW PIT CONSTRUCTION AND

RECLAMATION: INTERNALLY DRAINING BORROW PIT UPLAND ENVIRONMENT

PROPOSED BLACKROD
Topsoil
Subsoil
Overhead View
Parent Material ‘C’ Pre-Development
A A1
Constructed A A1
Topsoil
Subsoil
Topsoil
Subsoil
Overburden
Constructed
Undisturbed Buffer
Parent Material ‘C’

Extent of
A 1. Salvage topsoil and subsoil and stockpile along pit boundaries. A1 Excavation
2. Excavate borrow material and stockpile overburden materials in the non-operating area of the pit.
A A1
Overburden
Reclaimed
5:1 Topsoil Reclaimed

Recontoured Subsoil Extent of
Slope Excavation
Water
Extent of A A1
Excavation Replaced
Parent Material ‘C’ Overburden Water
A 1. Recontour the borrow area using the stockpiled overburden material. A1

2. Replace salvaged subsoil and topsoil over the recontoured pit. Salvaged subsoil and topsoil will not be replaced where the pit
will be reclaimed to open water.
CONCEPTUAL BORROW PIT CONSTRUCTION AND

Pre-Development RECLAMATION: UPLAND AND WETLAND SOILS BORROW PIT

PROPOSED BLACKROD
Topsoil
Subsoil
Peat
< 40cm
C Horizon
Overhead View
A A1
Pre-Development
A A1
Topsoil
Constructed Subsoil
Overburden
Constructed Extent of Excavation
Peat Undisturbed Buffer

< 40cm
C Horizon
A A1
1. Salvage topsoil and peat and stockpile in upland area of pit. Topsoil and peat will be segregated. 2. Salvage and stockpile subsoil in upland area of pit.
A A1
3. Excavate borrow material and stockpile all overburden material in the non-operating area of the pit.
Overburden
Reclaimed
5:1 Reclaimed
Recontoured
Slope Topsoil
Replaced Subsoil
Peat
Water
Peat
< 40cm Replaced A A1
Overburden
C Horizon Water
A A1
1. Recontour the borrow pit area using the stockpiled overburden material.
2. Replace salvaged topsoil, subsoil, and peat over pit area. Salvaged soils will not be replaced where the pit will be reclaimed to open water.
Cross Sections FIGURE 11.4 - 9
Pre-Development CONCEPTUAL ACCESS ROAD CONSTRUCTION AND
RECLAMATION: WETLAND ENVIRONMENT AND SHALLOW PEAT ( < 40cm)

PROPOSED BLACKROD
Organic Soil (Peat) < 40cm Peat

Subsoil
Parent Material “C” Overhead View - Constructed
B B1
Constructed
Power Pole
Pipeline Rack
Culvert
Wetland
B B1
Culverts
Organic Soil (Peat)

Subsoil
Borrow material Geofabric

Parent Material “C” (and gravel)
B B1
Topsoil Stockpile
Access Road
1. Excavate topsoil and subsoil separately from road pad area and stockpile at the stockpile area. 2. Install geotextile at the base of the excavated road bed.
3. Construct road with borrow fill material. 4. Install culverts. 5. Cap with gravel.
Reclaimed
Replaced Topsoil
Organic Soil (Peat)
Topsoil Stockpile
Subsoil
Replaced Subsoil
Parent Material “C”
B B1
1. Remove gravel from access road and recycle for use on other developments. 2. Remove clay fill material, culverts and geotextile. 3. Replace stockpiled subsoil
and topsoil. 4. Revegetate reclaimed area.
Pipelines Power Poles

CONCEPTUAL CPF CONSTRUCTION & RECLAMATION

Pre-Development
PROPOSED BLACKROD
Overhead View
Topsoil Pre-Development
Subsoil
A A1
A A1
Constructed
Salvage Soil Storage
Salvage Soil Storage
Cut & Fill CPF Padsite

Topsoil
Constructed
Clay Stockpile
A A1 Subsoil Subsoil
CPF Facility
1. Salvage topsoil and subsoil, stockpile at designated locations on-site. 2. Cut & fill site to create level area. Stockpile excess clay material at designated location
on-site. Material may be considered for use as borrow material for well pads or access roads.
A A1
Topsoil Topsoil
Reclaimed
Reclaimed
Topsoil
Subsoil
A A1
A A1
1. Remove gravel pad and facilities. 2. Remediate contaminated materials if present. 3. Decompact operating area of site. 4. Recontour to restore drainage patterns.
5. Replace salvaged topsoil and subsoil. 5. Revegetate the reclaimed area.
FIGURE 11.4 - 11
Cross Sections
CONCEPTUAL WELL PAD CONSTRUCTION AND
RECLAMATION: FLOATING PAD DESIGN - DEEP PEAT
Pre-Development
AESRD SIR 1 RESPONSES
PROPOSED BLACKROD
April 2013
Peat > 40cm Overhead View
Pre-Development
C Horizon
A A1
A A1
Constructed
Fill/Borrow Material
Geotextile
Constructed
Peat > 40cm
Pad
A A1
C Horizon
A 1. Install geotextile over intact peat. 2. Construct pad with borrow fill material. 3. Cap with gravel. A1
Reclaimed
Reclaimed
Decompacted Peat
Compaction of original
Peat > 40cm peat surface
Wetland
A A1
C Horizon
A 1. Remove gravel. 2. Remove fill and geotextile. 3. Decompaction of peat. 4. Revegetation based on prescription based on site by site assessment. A1
TABLE 11.4-4
ESTIMATES OF BORROW PIT OVERBURDEN MATERIAL

Borrow Pit Sum of Area (m3) Overburden Material (m3)
B11 22,805 22,805
B12 64,639 64,639
B13 67,631 67,631
B21 45,209 45,209
B22 69,589 69,589
B3A1 58,616 58,616
B3A2 127,597 127,597
B3A3 63,823 63,823
B3B1 66,847 66,847
B3B10 27,326 27,326
B3B11 46,030 46,030
B3B12 47,821 47,821
B3B13 80,119 80,119
B3B14 70,998 70,998
B3B15 83,084 83,084
B3B16 46,250 46,250
B3B2 75,319 75,319
B3B3 103,637 103,637
B3B4 33,246 33,246
B3B5 52,230 52,230
B3B6 60,332 60,332
B3B7 56,680 56,680
B3B8 71,858 71,858
B3B9 45,712 45,712
Notes: 1 Assumed 1 m of material to be unsuitable for construction purposes and will be retained for reclamation of the
borrow pit.
Borrow pits within upland environments will be reclaimed to encourage the development into upland
ecosite phases similar to adjacent lands. It is expected that a portion of the borrow pits will have an area
that will initially fill with water and be reclaimed to as a wetland end land use. BlackPearl will employ the
best available methods to facilitate the establishment of natural wetland vegetation community
composition and water quality characteristics towards achieving a successional trajectory to a natural
wetland community. Further details on the reclamation are provided in Section 11.4.5, Volume 4,
Section 2.6 (Wildlife) and Volume 4, Section 1.6 (Vegetation).
For the wetland portions of reclaimed borrow pits, considerations will be given to providing wildlife habitat
for species such as waterbirds and amphibians (western toad). Varying water depths, areas for
nesting/loafing and suitable vegetation cover (aquatic and riparian) are examples that will be factored into
borrow pit reclamation. For those portions of the borrow pit that are reclaimed to upland, considerations
include planting a vegetative cover that matches the surrounding landscape (i.e., compatible with the
surrounding ecosites), as well as avoiding plants that are highly palatable to species such as deer and
black bear. The sloping criteria referenced in The Guide to the Code of Practice for Pits (AENV 2004) will
also be considered in the reclamation design.
The techniques utilized to reclaim borrow pits to promote connectivity to adjacent ecosites and habitats
will vary on a site-by-site basis based on the location of the exhausted borrow pit. BlackPearl will strive to
provide connectivity to surrounding natural drainage patterns to provide water inflow and outflow from the
reclaimed borrow pits. The ability to create surface water connectivity will largely be dictated by the
landform where the borrow pit is situated within and the adjacent terrain. For example:
• Borrow pits isolated by upland features and landforms are not favourable to the establishment of
surface water in-flow and out-flow. Borrow pits within upland environments will be reclaimed to
encourage the development into upland ecosite phases similar to adjacent lands. It is expected that
the deepest portion of the borrow pits will have an area that will have a hydric soil moisture regime,
resulting in a marsh vegetation community establishing. The recontoured gentle slopes of the borrow
pits will have a gradient of soil moisture regimes that will trend from this marsh vegetation community
through a transitional treed swamp vegetation community to an upland vegetation community similar
Page 11-35
to adjacent lands. The techniques utilized to reclaim borrow pits to promote connectivity to adjacent
ecosites and habitats will vary on a site-by-site basis based on the location of the exhausted borrow
pit;
• Borrow pits constructed adjacent to landforms favourable to the establishment of surface water inflow
and outflow, such as pits located in uplands adjacent to transitional soils or nearly level peat lands,
will be constructed to enable connectivity.
Soil handling measures outlined in Section 11.4.1.3 will be adhered to minimize the potential for
sedimentation of nearby surface water and wetland environments. Once a borrow pit has been
completely re-contoured, soil replacement will proceed. Salvaged mineral soils and organic soils shall be
replaced over the re-contoured surfaces of the borrow pit. It is anticipated that there will be a reduction in
replacement area due to the formation of a wetland within the depressional low. Approximately 5% of the
borrow areas shall be returned to open water with the exception of where a self-draining pit can be
constructed. The portion of the borrow area to be returned to open water shall not have topsoil or subsoil
replaced; however, excess peat material may be used in this area if practical. BlackPearl will consider the
use of this excess soil in reclamation developments where fill material is left in place or to supplement
placement thickness of reclamation material if required.
11.4.1.9 Soils Materials Balance

The soils material balance for the Project is summarized in Tables 11.4-5 (surface soils) and 11.4-6
(subsoils). Topsoil, as defined by EPEA, includes:
1. All organic horizons (L,F,H and O) and A horizons as defined in the Canadian System of Soil
Classification (Third Edition), Agriculture and Agri-Food Canada Publication 1646, 1988, as
amended
2. A-Horizons as defined in The Canadian System of Soil Classification (Third Edition), Agriculture
and Agri-Food Canada Publication 1646, 1988, as amended and rated as Good, Fair or Poor as
described in the Soil Quality Criteria Relative to Disturbance and Reclamation, Alberta
Agriculture, 1987, as amended
3. The replaced topsoil layer in a reclaimed soil.
The material balance will assist BlackPearl in development and reclamation planning to provide estimated
volumes of materials to be salvaged and available for reclamation upon decommissioning of the Project
developments. BlackPearl anticipates that sufficient reclamation materials will be available upon
decommissioning of the Project developments.
Page 11-36
TABLE 11.4-5
TOPSOIL BALANCE FOR THE PROJECT
Average Topsoil Soil Material

Project Project LFH/Shallow O Average A Average Topsoil/Peat Volume Required for Soil
Component Component Area Horizon Depth Horizon Peat Salvage Depth Available a Reclamation Replacement Balance
Type Soil Series (ha) (m) Depth (m) Depth (m) (m) (m3) b,c,d (m3) Depth (m) (+/- m3)
Borrow Pits Totalf 151.4 - - - - 405,000 384,750 - 20,250
Totalf 2.3 - - - - 9,000 8,550 - 450
HZMaa 0.1 0.10 0.11 - 0.21 0 - 0.21 0
B11
MRN 2.2 - - 0.82 0.40 9,000 8,550 0.4 450
STPzz 0.0 0.10 0.08 - 0.18 0 - 0.18 0
Totalf 6.5 - - - - 13,000 12,350 - 650
B12 DL 0.4 - - - 0.00 0 - - 0
HZMaa 6.1 0.10 0.11 - 0.21 13,000 12,350 0.21 650
Totalf 6.8 - - - - 14,000 13,300 - 700
DL 1.3 - - - 0.00 0 - - 0
B13 HZMaa 0.4 0.10 0.11 - 0.21 1,000 950 0.21 50
MRN 2.4 - - 0.82 0.40 10,000 9,500 0.4 500
STP 2.7 0.09 0.03 - 0.12 3,000 2,850 0.12 150
Page 11-37
Totalf 4.5 - - - - 18,000 17,100 - 900

B21 DL 0.0 - - - 0.00 0 - - 0
MLD 4.5 - - 2.38 0.40 18,000 17,100 0.4 900
Totalf 7.0 23,000 21,850 - 1,150
DL 0.7 - - - 0.00 0 - - 0
B22
HZMaa 0.9 0.10 0.11 - 0.21 2,000 1,900 0.21 100
Borrow Pit
MLD 5.3 - - 2.38 0.40 21,000 19,950 0.4 1,050
Totalf 5.9 - - - - 12,000 11,400 - 600
DL 0.1 - - - 0.00 0 - - 0
B3A1
HZMaa 5.5 0.10 0.11 - 0.21 12,000 11,400 0.21 600
MLDxt 0.2 - - 0.85 0.40 1,000 950 0.4 50
Totalf 12.8 - - - - 49,000 46,550 - 2,450
HLY 11.4 - - 0.51 0.40 45,000 42,750 0.4 2,250
B3A2
HZMaa 0.0 0.10 0.11 - 0.21 0 - 0.21 0
STPpt 1.4 0.23 0.03 - 0.26 4,000 3,800 0.26 200
Totalf 6.4 - - - - 20,000 19,000 - 1,000
B3A3 HZMaapt 6.0 0.22 0.10 - 0.32 19,000 18,050 0.32 950
STPpt 0.4 0.23 0.03 - 0.26 1,000 950 0.26 50
Totalf 6.7 - - - - 14,000 13,300 - 700
DL 0.1 - - - 0.00 0 - - 0
B3B1
HZMaa 6.6 0.10 0.11 - 0.21 14,000 13,300 0.21 700
STPpt 0.0 0.23 0.03 - 0.26 0 - - 0
Totalf 2.7 - - - - 6,000 5,700 - 300
B3B10 DL 0.0 - - - 0.00 0 - - 0
HZMaa 1.2 0.10 0.11 - 0.21 3,000 2,850 0.21 150
Borrow Pits STPpt 1.5 0.23 0.03 - 0.26 4,000 3,800 0.26 200
Totalf 4.6 - - - - 11,000 10,450 - 550
B3B11 HZMaa 1.0 0.10 0.11 - 0.21 2,000 1,900 0.21 100
STPpt 3.6 0.23 0.03 - 0.26 9,000 8,550 0.26 450
Totalf 7.5 - - - - 30,000 28,500 - 1,500
B3B12
MUS 7.5 - - 2.22 0.40 30,000 28,500 0.4 1,500
Totalf 8.0 - - - - 17,000 16,150 - 850
B3B13 HZMaa 7.9 0.10 0.11 - 0.21 17,000 16,150 0.21 850
MRN 0.2 - - 0.82 0.40 1,000 950 0.4 50
Totalf 7.1 - - - - 10,000 9,500 - 500
B3B14 MLDxt 0.5 - - 0.85 0.40 2,000 1,900 0.4 100
STP 6.6 0.09 0.03 - 0.12 8,000 7,600 0.12 400
Totalf 8.3 - - - - 17,000 16,150 - 850
B3B15
HZMaa 8.3 0.10 0.11 - 0.21 17,000 16,150 0.21 850
Page 11-38
Totalf 4.6 - - - - 12,000 11,400 - 600

B3B16 ELSpt 2.5 0.27 0.03 - 0.30 7,000 6,650 0.3 350
HZMaa 2.2 0.10 0.11 - 0.21 5,000 4,750 0.21 250
Totalf 7.5 - - - - 14,000 13,300 - 700
DL 0.2 - - - 0.00 0 - - 0
Borrow Pit
B3B2 MLDxt 1.7 - - 0.85 0.40 7,000 6,650 0.4 350
(cont’d)
MLDzz 0.1 - - 2.09 0.40 0 - - 0
STP 5.5 0.09 0.03 - 0.12 7,000 6,650 0.12 350
Total 10.4 - - - - 19,000 18,050 - 950
B3B3 MLDxt 0.0 - - 0.85 0.40 0 - - 0
STPzz 10.3 0.10 0.08 - 0.18 19,000 18,050 0.18 950
Totalf 3.3 - - - - 13,000 12,350 - 650
B3B4
MLDxt 3.3 - - 0.85 0.40 13,000 12,350 0.4 650
Totalf 5.2 - - - - 10,000 9,500 - 500
B3B5 MLDxt 1.3 - - 0.85 0.40 5,000 4,750 0.4 250
STP 3.9 0.09 0.03 - 0.12 5,000 4,750 0.12 250
Totalf 6.0 - - - - 24,000 22,800 - 1,200
B3B6
MLD 6.0 - - 2.38 0.40 24,000 22,800 0.4 1,200
Totalf 5.7 - - - - 22,000 20,900 - 1,100
B3B7 DL 0.2 - - - 0.00 0 - - 0
MLD 5.5 - - 2.38 0.40 22,000 20,900 0.4 1,100
Totalf 7.2 - - - - 19,000 18,050 - 950
DL 0.0 - - - 0.00 0 - - 0
B3B8
MLD 0.5 - - 2.38 0.40 2,000 1,900 0.4 100
STPpt 6.7 0.23 0.03 - 0.26 17,000 16,150 0.26 850
Totalf 4.6 - - - - 8,000 7,600 - 400
Borrow Pit
B3B9 DL 0.7 - - - 0.00 0 - - 0
(cont’d)
HZMaa 3.8 0.10 0.11 - 0.21 8,000 7,600 0.21 400
Totalf 8.4 - - - - 16,000 16,000 - 0
Construction Construction HRR 7.5 0.10 0.10 - 0.20 15,000 15,000 0.2 0
Camp Camp HZMaa 0.5 0.10 0.11 - 0.21 1,000 1,000 0.2 0
STP 0.4 0.09 0.03 - 0.12 0 - - 0
Totalf 122.9 253,000 253,000 - 0
DL 1.2 - - - 0.00 0 - - 0
Central HRR 66.6 0.10 0.10 - 0.20 133,000 133,000 0.2 0
Processing CPF
Facility HZMaa 20.3 0.10 0.11 - 0.21 43,000 43,000 0.2 0
HZMaapt 18.0 0.22 0.10 - 0.32 57,000 57,000 0.32 0
STP 16.9 0.09 0.03 - 0.12 20,000 20,000 0.12 0
Totalf 0.8 - - - - 1,000 1,000 - 0
Page 11-39
CPF Access CPF Access DL 0.4 - - - 0.00 0 - - 0

Road Road HRR 0.2 0.10 0.10 - 0.20 0 - - 0
HZMaapt 0.3 0.22 0.10 - 0.32 1,000 1,000 0.32 0
Log Deckse Totalf 3.8 - - - - 0 - - 0
Totalf 2.0 - - - - 0 - - 0
HLY 0.7 - - 0.51 0.00 0 - - 0
L3A1
HZMaa 1.3 0.10 0.11 - 0.00 0 - - 0
STPpt 0.0 0.23 0.03 - 0.00 0 - - 0
Totalf 0.7 - - - - 0 - - 0
DL 0.0 - - - 0.00 0 - - 0
L3A2
Log Decks MLD 0.7 - - 2.38 0.00 0 - - 0
STPpt 0.0 0.23 0.03 - 0.00 0 - - 0
Totalf 0.5 - - - - 0 - - 0
L3B1
MLD 0.5 - - 2.38 0.00 0 - - 0
Totalf 0.6 - - - - 0 - - 0
DL 0.0 - - - 0.00 0 - - 0
L3B2
HZMaa 0.5 0.10 0.11 - 0.00 0 - - 0
MRN 0.1 - - 0.82 0.00 0 - - 0
Totalf 10.3 - - - - 30,000 30,000 - 0
Operations HRR 2.1 0.10 0.10 - 0.20 4,000 4,000 0.2 0
Operations Camp
Camp HZMaapt 7.4 0.22 0.10 - 0.32 24,000 24,000 0.32 0
STPpt 0.8 0.23 0.03 - 0.26 2,000 2,000 0.26 0
Phase 1 - Pads Totalf 22.2 - - - - 70,000 70,000 - 0
Totalf 4.0 16,000 16,000 - 0
1A
MLD 4.0 - - 2.38 0.4 16,000 16,000 -0.4 0
Totalf 6.3 - - - - 13,000 13,000 - 0
1B 2G DL 0.1 - - - 0.00 - - 0
HZMaa 6.2 0.10 0.11 - 0.21 13,000 13,000 0.21 0
Totalf 4.0 - - - - 11,000 11,000 - 0
Phase 1 - Pads 1C MRN 1.7 - - 0.82 0.40 7,000 7,000 0.4 0
STPzz 2.3 0.10 0.08 - 0.18 4,000 4,000 0.18 0
Totalf 4.0 - - - - 13,000 13,000 - 0
MLD 2.4 - - 2.38 0.40 10,000 10,000 0.4 0
1D
MUS 0.7 - - 2.22 0.40 3,000 3,000 0.4 0
STP 0.9 0.09 0.03 - 0.12 1,000 1,000 0.12 0
Totalf 4.0 - - - - 16,000 16,000 - 0
1E
Page 11-40
MLD 4.0 - - 2.38 0.40 16,000 16,000 0.4 0

Totalf 43.6 - - - - 83,000 83,000 - 0
DL 10.1 - - - 0.00 - - 0
HRR 4.1 0.10 0.10 - 0.20 8,000 8,000 0.2 0
HZMaa 16.2 0.10 0.11 - 0.21 34,000 34,000 0.21 0
MLD 5.2 - - 2.38 0.40 21,000 21,000 0.4 0
Phase 1 - RoW Phase 1 - RoW
MRN 0.1 - - 0.82 0.40 0 - - 0
MUS 2.1 - - 2.22 0.40 8,000 8,000 0.4 0
STP 1.3 0.09 0.03 - 0.12 2,000 2,000 0.12 0
STPpt 1.5 0.23 0.03 - 0.26 4,000 4,000 0.26 0
STPzz 3.0 0.10 0.08 - 0.18 5,000 5,000 0.18 0
Phase 2 - Pads Totalf 26.0 - - - - 84,000 84,000 - 0
Totalf 6.0 - - - - 10,000 10,000 - 0
HZMaa 0.3 0.10 0.11 - 0.21 1,000 1,000 0.21 0
2A
STP 4.2 0.09 0.03 - 0.12 5,000 5,000 0.12 0
STPpt 1.6 0.23 0.03 - 0.26 4,000 4,000 0.26 0
Totalf 4.0 - - - - 15,000 15,000 - 0
DL 0.2 - - - 0.00 - - 0
Phase 2 - Pads 2B
MLD 0.9 - - 2.38 0.40 3,000 3,000 0.4 0
MUS 2.9 - - 2.22 0.40 12,000 12,000 0.4 0
Totalf 4.0 - - - - 16,000 16,000 - 0
2C MLD 2.4 - - 2.38 0.40 10,000 10,000 0.4 0
MRN 1.6 - - 0.82 0.40 6,000 6,000 0.4 0
Totalf 4.0 - - - - 16,000 16,000 - 0
2D
MLD 4.0 - - 2.38 0.40 16,000 16,000 0.4 0
Totalf 4.0 - - - - 12,000 12,000 - 0
DL 0.3 - - - 0.00 - - 0
2E HLY 1.7 - - 0.51 0.40 7,000 7,000 0.4 0
HZMaa 1.4 0.10 0.11 - 0.21 3,000 3,000 0.21 0
Phase 2 – Pads
MLD 0.6 - - 2.38 0.40 2,000 2,000 0.4 0
(cont’d)
Totalf 4.0 - - - - 15,000 15,000 - 0
DL 0.3 - - - 0.00 - - 0
2F
MLD 0.4 - - 2.38 0.40 2,000 2,000 0.4 0
MLDzz 3.3 - - 2.09 0.40 13,000 13,000 0.4 0
Totalf 32.3 - - - - 110,000 110,000 - 0
DL 1.6 - - - 0.00 0 - - 0
HLY 0.3 - - 0.51 0.40 1,000 1,000 0.4 0
HZMaa 4.6 0.10 0.11 - 0.21 10,000 10,000 0.21 0
MLD 19.6 - - 2.38 0.40 79,000 79,000 0.4 0
Phase 2 - RoW Phase 2 - RoW
Page 11-41
MLDxt 0.5 - - 0.85 0.40 2,000 2,000 0.4 0

MLDzz 2.4 - - 2.09 0.40 9,000 9,000 0.4 0
MUS 1.3 - - 2.22 0.40 5,000 5,000 0.4 0
STP 0.1 0.09 0.03 - 0.12 0 - - 0
STPzz 1.9 0.10 0.08 - 0.18 3,000 3,000 0.18 0
Phase 3A - Pads Totalf 38.0 - - - - 128,000 128,000 - 0
Totalf 4.0 - - - - 10,000 10,000 - 0
3AA HZMaa 0.8 0.10 0.11 - 0.21 2,000 2,000 0.21 0
STPpt 3.2 0.23 0.03 - 0.26 8,000 8,000 0.26 0
Totalf 4.0 - - - - 14,000 14,000 - 0
3AB HZMaa 0.8 0.10 0.11 - 0.21 2,000 2,000 0.21 0
MLDxt 3.2 - - 0.85 0.40 13,000 13,000 0.4 0
Totalf 6.0 - - - - 20,000 20,000 - 0
DL 0.2 - - - 0.00 0 - - 0
3AC
MLD 3.8 - - 2.38 0.40 15,000 15,000 0.4 0
Phase 3A - Pads
STPpt 2.1 0.23 0.03 - 0.26 5,000 5,000 0.26 0
Totalf 4.0 - - - - 11,000 11,000 - 0
DL 0.0 - - - 0.00 0 - - 0
3AD HLY 0.4 - - 0.51 0.40 2,000 2,000 0.4 0
HZMaa 0.0 0.10 0.11 - 0.21 0 - - 0
STPpt 3.6 0.23 0.03 - 0.26 9,000 9,000 0.26 0
Totalf 4.0 - - - - 11,000 11,000 - 0
DL 0.2 - - - 0.00 0 - - 0
3AE
HZMaapt 2.2 0.22 0.10 - 0.32 7,000 7,000 0.32 0
STPpt 1.6 0.23 0.03 - 0.26 4,000 4,000 0.26 0
Totalf 4.0 - - - - 16,000 16,000 - 0
MLD 2.8 - - 2.38 0.40 11,000 11,000 0.4 0
3AF
MLDzz 1.2 - - 2.09 0.40 5,000 5,000 0.4 0
STPpt 0.0 0.23 0.03 - 0.26 0 - - 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3AG
Phase 3A – Pads MLD 4.0 - - 2.38 0.40 16,000 16,000 0.4 0
(cont’d) Totalf 4.0 - - - - 13,000 13,000 - 0
ELS 1.2 0.09 0.07 - 0.16 2,000 2,000 0.16 0
3AH
HZMaapt 0.1 0.22 0.10 - 0.32 0 - - 0
MLD 2.7 - - 2.38 0.40 11,000 11,000 0.4 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3AI
MLDzz 4.0 - - 2.09 0.40 16,000 16,000 0.4 0
Totalf 50.6 - - - - 143,000 143,000 - 0
DL 4.2 - - - 0.00 0 - - 0
Page 11-42
ELS 0.5 0.09 0.07 - 0.16 1,000 1,000 0.16 0

HLY 2.5 - - 0.51 0.40 10,000 10,000 0.4 0
HZMaa 5.7 0.10 0.11 - 0.21 12,000 12,000 0.21 0
Phase 3A - RoW Phase 3A - RoW HZMaapt 4.1 0.22 0.10 - 0.32 13,000 13,000 0.32 0
MLD 11.4 - - 2.38 0.40 46,000 46,000 0.4 0
MLDxt 1.5 - - 0.85 0.40 6,000 6,000 0.4 0
MLDzz 5.7 - - 2.09 0.40 23,000 23,000 0.4 0
STP 4.8 0.09 0.03 - 0.12 6,000 6,000 0.12 0
STPpt 10.0 0.23 0.03 - 0.26 26,000 26,000 0.26 0
Phase 3B - Pads Totalf 146.0 - - - - 422,000 422,000 - 0
Totalf 4.0 - - - - 13,000 13,000 - 0
3BA HZMaa 1.5 0.10 0.11 - 0.21 3,000 3,000 0.21 0
MLDxt 2.5 - - 0.85 0.40 10,000 10,000 0.4 0
Totalf 4.0 - - - - 8,000 8,000 - 0
3BAA
HZMaa 4.0 0.10 0.11 - 0.21 8,000 8,000 0.21 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BB
MLDxt 4.0 - - 0.85 0.40 16,000 16,000 0.4 0
Phase 3B - Pads
Totalf 4.0 - - - - 8,000 8,000 - 0
3BBB
HZMaa 4.0 0.10 0.11 - 0.21 8,000 8,000 0.21 0
Totalf 4.0 - - - - 5,000 5,000 - 0
3BC
STP 4.0 0.09 0.03 - 0.12 5,000 5,000 0.12 0
Totalf 4.0 - - - - 8,000 8,000 - 0
3BCC
HZMaa 4.0 0.10 0.11 - 0.21 8,000 8,000 0.21 0
Totalf 4.0 - - - - 9,000 9,000 - 0
3BD
MLDxt 1.0 - - 0.85 0.40 4,000 4,000 0.4 0
STPzz 3.0 0.10 0.08 - 0.18 5,000 5,000 0.18 0
Totalf 4.0 - - - - 8,000 8,000 - 0
3BDD
HZMaa 4.0 0.10 0.11 - 0.21 8,000 8,000 0.21 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BE MLDxt 3.8 - - 0.85 0.40 15,000 15,000 0.4 0
MLDzz 0.2 - - 2.09 0.40 1,000 1,000 0.4 0
Totalf 6.0 - - - - 20,000 20,000 - 0
MLDxt 1.7 - - 0.85 0.40 7,000 7,000 0.4 0
3BEE MRN 1.7 - - 0.82 0.40 7,000 7,000 0.4 0
STP 0.5 0.09 0.03 - 0.12 1,000 1,000 0.12 0
STPpt 2.1 0.23 0.03 - 0.26 5,000 5,000 0.26 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BF
MLDxt 4.0 - - 0.85 0.40 16,000 16,000 0.4 0
Totalf 6.0 - - - - 18,000 18,000 - 0
Page 11-43
3BFF HZMaa 3.1 0.10 0.11 - 0.21 7,000 7,000 0.21 0

MRN 2.9 - - 0.82 0.40 11,000 11,000 0.4 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BG
MLDzz 4.0 - - 2.09 0.40 16,000 16,000 0.4 0
Totalf 6.0 - - - - 13,000 13,000 - 0
Phase 3B – Pads
DL 0.5 - - - 0.00 0 - - 0
(cont’d) 3BGG
ELSpt 1.2 0.27 0.03 - 0.30 4,000 4,000 0.3 0
HZMaa 4.3 0.10 0.11 - 0.21 9,000 9,000 0.21 0
Totalf 4.0 - - - - 9,000 9,000 - 0
3BH MLDxt 1.4 - - 0.85 0.40 5,000 5,000 0.4 0
STP 2.6 0.09 0.03 - 0.12 3,000 3,000 0.12 0
Totalf 4.0 - - - - 9,000 9,000 - 0
3BHH ELSpt 0.3 0.27 0.03 - 0.30 1,000 1,000 0.3 0
HZMaa 3.7 0.10 0.11 - 0.21 8,000 8,000 0.21 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BI MLDxt 1.4 - - 0.85 0.40 6,000 6,000 0.4 0
MLDzz 2.6 - - 2.09 0.40 10,000 10,000 0.4 0
Totalf 4.0 - - - - 7,000 7,000 - 0
3BJ
STPzz 4.0 0.10 0.08 - 0.18 7,000 7,000 0.18 0
Totalf 4.0 - - - - 14,000 14,000 - 0
3BK DL 0.5 - - - 0.00 0 - - 0
MUS 3.5 - - 2.22 0.40 14,000 14,000 0.4 0
Totalf 4.0 - - - - 11,000 11,000 - 0
3BL DL 1.2 - - - 0.00 0 - - 0
MLD 2.8 - - 2.38 0.40 11,000 11,000 0.4 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BM MLD 4.0 - - 2.38 0.40 16,000 16,000 0.4 0
MLDxt 0.0 - - 0.85 0.40 0 - - 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BN MLD 2.2 - - 2.38 0.40 9,000 9,000 0.4 0
MLDxt 1.8 - - 0.85 0.40 7,000 7,000 0.4 0
Totalf 6.0 - - - - 16,000 16,000 - 0
3BO HZMaa 0.0 0.10 0.11 - 0.21 0 - - 0
STPpt 6.0 0.23 0.03 - 0.26 16,000 16,000 0.26 0
Totalf 4.0 - - - - 15,000 15,000 - 0
HZMaa 0.2 0.10 0.11 - 0.21 1,000 1,000 0.21 0
3BP
MLD 3.5 - - 2.38 0.40 14,000 14,000 0.4 0
STPpt 0.3 0.23 0.03 - 0.26 1,000 1,000 0.26 0
Totalf 4.0 - - - - 13,000 13,000 - 0
Page 11-44
3BQ DL 0.8 - - - 0.00 0 - - 0

MLD 3.2 - - 2.38 0.40 13,000 13,000 0.4 0
Totalf 4.0 - - - - 13,000 13,000 - 0
MLDxt 1.2 - - 0.85 0.40 5,000 5,000 0.4 0
3BR
MUS 0.3 - - 2.22 0.40 1,000 1,000 0.4 0
Phase 3B – Pads
STPpt 2.5 0.23 0.03 - 0.26 6,000 6,000 0.26 0
(cont’d)
Totalf 4.0 - - - - 13,000 13,000 - 0
HZMaa 1.0 0.10 0.11 - 0.21 2,000 2,000 0.21 0
3BS
MLDxt 2.1 - - 0.85 0.40 8,000 8,000 0.4 0
STPpt 0.9 0.23 0.03 - 0.26 2,000 2,000 0.26 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BT
MUS 4.0 - - 2.22 0.40 16,000 16,000 0.4 0
Totalf 4.0 - - - - 16,000 16,000 - 0
3BU MRN 3.7 - - 0.82 0.40 15,000 15,000 0.4 0
MUS 0.3 - - 2.22 0.40 1,000 1,000 0.4 0
Totalf 6.0 - - - - 13,000 13,000 - 0
3BV DL 0.0 - - - 0.00 0 - - 0
HZMaa 6.0 0.10 0.11 - 0.21 13,000 13,000 0.21 0
Totalf 4.0 - - - - 9,000 9,000 - 0
3BW HZMaa 3.0 0.10 0.11 - 0.21 6,000 6,000 0.21 0
STPpt 1.0 0.23 0.03 - 0.26 2,000 2,000 0.26 0
Totalf 4.0 - - - - 8,000 8,000 - 0
3BX
HZMaa 4.0 0.10 0.11 - 0.21 8,000 8,000 0.21 0
Totalf 4.0 - - - - 9,000 9,000 - 0
3BY
HZMaa 3.2 0.10 0.11 - 0.21 7,000 7,000 0.21 0
STPpt 0.8 0.23 0.03 - 0.26 2,000 2,000 0.26 0
Phase 3B – Pads Totalf 4.0 - - - - 9,000 9,000 - 0
(cont’d) 3BZ HZMaa 3.5 0.10 0.11 - 0.21 7,000 7,000 0.21 0
STPpt 0.5 0.23 0.03 - 0.26 1,000 1,000 0.26 0
Totalf 186.3 - - - - 546,000 546,000 - 0
DL 6.4 - - - 0.00 0 - - 0
ELSpt 3.0 0.27 0.03 - 0.30 9,000 9,000 0.3 0
HZMaa 65.6 0.10 0.11 - 0.21 138,000 138,000 0.21 0
MLD 24.1 - - 2.38 0.40 97,000 97,000 0.4 0
MLDxt 45.2 - - 0.85 0.40 181,000 181,000 0.4 0
Phase 3B - RoW Phase 3B - RoW MLDzz 1.5 - - 2.09 0.40 6,000 6,000 0.4 0
MRN 4.4 - - 0.82 0.40 18,000 18,000 0.4 0
MUS 11.3 - - 2.22 0.40 45,000 45,000 0.4 0
RB 1.2 - - - 0.00 0 - - 0
Page 11-45
STP 5.5 0.09 0.03 - 0.12 7,000 7,000 0.12 0

STPpt 18.1 0.23 0.03 - 0.26 47,000 47,000 0.26 0
STPzz 0.2 0.10 0.08 - 0.18 0 - - 0
Sumps Totalf 13.3 - - - - 27,000 27,000 - 0
Totalf 2.9 - - - - 6,000 6,000 - 0
DL 0.2 - - - 0.00 0 - - 0
S11
HZMaa 1.6 0.10 0.11 - 0.21 3,000 3,000 0.21 0
STPpt 1.1 0.23 0.03 - 0.26 3,000 3,000 0.26 0
Sumps Totalf 5.9 - - - - 12,000 12,000 - 0
S12 HRR 5.7 0.10 0.10 - 0.20 11,000 11,000 0.2 0
STP 0.2 0.09 0.03 - 0.12 0 - - 0
Totalf 4.5 - - - - 10,000 10,000 - 0
S3B1 HZMaa 4.0 0.10 0.11 - 0.21 8,000 8,000 0.21 0
STPpt 0.5 0.23 0.03 - 0.26 1,000 1,000 0.26 0
Grand Totalf 856.0 - - - - 2,318,000 2,297,750 - 20,250
Notes: (a) Available volumes rounded to the nearest 1000 m3
(b) Replacement depths of upland mineral topsoill will be equivalent to the salvage depths encountered on each component of the Project.
(c) The return of a portion of borrow areas to open water will result in excess topsoil. Approximately 95% of topsoil salvaged will be replaced, with the remaining 5% returning to open water. Excess peat material may be
used in this area, if practicable. Excess soil will be considered for use in reclamation of developments where fill material is left in place or to supplement placement thicknesses of reclamation material if required.
(d) The entire volume of peat salvaged from well pads and road beds in deep peat areas is assumed to be replaced in these areas. Due to peat compaction (increase in bulk density) and decomposition over time, the final
replacement depth is anticipated to range between 20 - 40 cm
(e) No soil disturbance expected on log decks; no topsoil salvage.
(f) Individual values may not add to totals due to rounding.
TABLE 11.4-6
SUBSOIL BALANCE FOR THE PROJECT
Subsoil
Subsoil Subsoil Required for Subsoil
Project Project Salvage Depth Volume Reclamation b,c Replacement Balance (+/-
Component Type Component Soil Series Area (ha) (m) Available (m3)a (m3) Depth (m) m3)
Borrow Pits Totald 151.4 - 281,000 266,950 - 14,050
B11 Totald 2.3 - 0 0 - 0
HZMaa 0.1 0.30 0 0 0.30 0
MRN 2.2 - 0 0 - 0
STPzz 0.0 0.30 0 0 0.30 0
B12 Totald 6.5 - 18,000 17,100 - 900
DL 0.4 - 0 0 - 0
HZMaa 6.1 0.30 18,000 17,100 0.30 900
B13 Totald 6.8 - 9,000 8,550 - 450
DL 1.3 - 0 0 - 0
HZMaa 0.4 0.30 1,000 950 0.30 50
MRN 2.4 - 0 0 - 0
STP 2.7 0.30 8,000 7,600 0.30 400
Page 11-46
B21 Totald 4.5 - 0 0 - 0

DL 0.0 - 0 0 - 0
MLD 4.5 - 0 0 - 0
B22 Totald 7.0 - 3,000 2,850 - 150
DL 0.7 - 0 0 - 0
HZMaa 0.9 0.30 3,000 2,850 0.30 150
Borrow Pit
MLD 5.3 - 0 0 - 0
B3A1 Totald 5.9 - 17,000 16,150 - 850
DL 0.1 - 0 0 - 0
HZMaa 5.5 0.30 17,000 16,150 0.30 850
MLDxt 0.2 - 0 0 - 0
B3A2 Totald 12.8 - 4,000 3,800 - 200
HLY 11.4 - 0 0 - 0
HZMaa 0.0 0.30 0 0 0.3 0
STPpt 1.4 0.30 4,000 3,800 0.3 200
B3A3 Totald 6.4 - 19,000 18,050 - 950
HZMaapt 6.0 0.30 18,000 17,100 0.30 900
STPpt 0.4 0.30 1,000 950 0.30 50
B3B1 Totald 6.7 - 20,000 19,000 - 1,000
DL 0.1 - 0 0 - 0
HZMaa 6.6 0.30 20,000 19,000 0.30 1,000
STPpt 0.0 0.30 0 0 0.30 0
B3B10 Totald 2.7 - 8,000 7,600 - 400
DL 0.0 - 0 0 - 0
HZMaa 1.2 0.30 4,000 3,800 0.30 200
Subsoil
Borrow Pits STPpt 1.5 0.30 4,000 3,800 0.30 200
B3B11 Totald 4.6 - 14,000 13,300 - 700
HZMaa 1.0 0.30 3,000 2,850 0.30 150
STPpt 3.6 0.30 11,000 10,450 0.30 550
B3B12 Totald 7.5 - 0 0 - 0
MUS 7.5 - 0 0 - 0
B3B13 Totald 8.0 - 24,000 22,800 - 1,200
HZMaa 7.9 0.30 24,000 22,800 0.30 1,200
MRN 0.2 - 0 0 - 0
B3B14 Totald 7.1 - 20,000 19,000 - 1,000
MLDxt 0.5 - 0 0 - 0
STP 6.6 0.30 20,000 19,000 0.30 1,000
B3B15 Totald 8.3 - 25,000 23,750 - 1,250
HZMaa 8.3 0.30 25,000 23,750 0.30 1,250
Page 11-47
B3B16 Totald 4.6 - 9,000 8,550 - 450

ELSpt 2.5 0.10 2,000 1,900 0.10 100
HZMaa 2.2 0.30 6,000 5,700 0.30 300
B3B2 Totald 7.5 - 17,000 16,150 - 850
DL 0.2 - 0 0 - 0
Borrow Pit
MLDxt 1.7 - 0 0 - 0
(cont’d)
MLDzz 0.1 - 0 0 - 0
STP 5.5 0.30 17,000 16,150 0.30 850
B3B3 Totald 10.4 - 31,000 29,450 - 1,550
MLDxt 0.0 - 0 0 - 0
STPzz 10.3 0.30 31,000 29,450 0.30 1,550
B3B4 Totald 3.3 - 0 0 - 0
MLDxt 3.3 - 0 0 - 0
B3B5 Totald 5.2 - 12,000 11,400 - 600
MLDxt 1.3 - 0 0 - 0
STP 3.9 0.30 12,000 11,400 0.30 600
B3B6 Totald 6.0 - 0 0 - 0
MLD 6.0 - 0 0 - 0
B3B7 Totald 5.7 - 0 0 - 0
DL 0.2 - 0 0 - 0
MLD 5.5 - 0 0 - 0
B3B8 Totald 7.2 - 20,000 19,000 - 1,000
DL 0.0 - 0 0 - 0
MLD 0.5 - 0 0 - 0
STPpt 6.7 0.30 20,000 19,000 0.30 1,000
Subsoil
B3B9 Totald 4.6 - 11,000 10,450 - 550
Borrow Pit
DL 0.7 - 0 0 - 0
(cont’d)
HZMaa 3.8 0.30 11,000 10,450 0.30 550
CPF Totald 122.9 - 365,000 365,000 - 0
DL 1.2 - 0 0 - 0
Central HRR 66.6 0.30 200,000 200,000 0.30 0
Processing
Facility HZMaa 20.3 0.30 61,000 61,000 0.30 0
HZMaapt 18.0 0.30 54,000 54,000 0.30 0
STP 16.9 0.30 51,000 51,000 0.30 0
Central CPF Access Totald 0.8 - 1,000 1,000 - 0
Processing Road DL 0.4 0 0 0 - 0
Facility – Access HRR 0.2 0.3 1,000 1,000 0.30 0
Road HZMaapt 0.3 0.3 1,000 1,000 0.30 0
Phase 1 - Pads Totald 22.2 - 28,000 28,000 - 0
Page 11-48
1A Totald 4.0 - 0 0 - 0
MLD 4.0 - 0 0 0 0
1B 2G Total 6.3 - 18,000 18,000 - 0
DL 0.1 - 0 0 - 0
HZMaa 6.2 0.30 18,000 18,000 0.30 0
1C Totald 4.0 - 7,000 7,000 - 0
Phase 1 - Pads MRN 1.7 - 0 0 - 0
STPzz 2.3 0.30 7,000 7,000 0.30 0
1D Totald 4.0 - 3,000 3,000 - 0
MLD 2.4 - 0 0 - 0
MUS 0.7 - 0 0 - 0
STP 0.9 0.30 3,000 3,000 0.30 0
1E Totald 4.0 - 0 0 - 0
MLD 4.0 - 0 0 - 0
Phase 2 - Pads Totald 26.0 - 22,000 22,000 - 0
2A Totald 6.0 - 18,000 18,000 - 0
HZMaa 0.3 0.30 1,000 1,000 0.30 0
STP 4.2 0.30 12,000 12,000 0.30 0
STPpt 1.6 0.30 5,000 5,000 0.30 0
Phase 2 - Pads 2B Totald 4.0 - 0 0 - 0
DL 0.2 - 0 0 - 0
MLD 0.9 - 0 0 - 0
MUS 2.9 - 0 0 - 0
2C Totald 4.0 - 0 0 - 0
MLD 2.4 - 0 0 - 0
Subsoil
MRN 1.6 - 0 0 - 0
2D Totald 4.0 - 0 0 - 0
MLD 4.0 - 0 0 - 0
2E Totald 4.0 - 4,000 4,000 - 0
DL 0.3 - 0 0 - 0
Phase 2 – Pads HLY 1.7 - 0 0 - 0
(cont’d) HZMaa 1.4 0.30 4,000 4,000 0.30 0
MLD 0.6 - 0 0 - 0
2F Totald 4.0 - 0 0 - 0
DL 0.3 - 0 0 - 0
MLD 0.4 - 0 0 - 0
MLDzz 3.3 - 0 0 - 0
Phase 3A -
Totald 38.0 - 44,000 44,000 - 0
Pads
Page 11-49
3AA Totald 4.0 - 12,000 12,000 - 0

HZMaa 0.8 0.30 2,000 2,000 0.30 0
STPpt 3.2 0.30 10,000 10,000 0.30 0
3AB Totald 4.0 - 2,000 2,000 - 0
HZMaa 0.8 0.30 2,000 2,000 0.30 0
MLDxt 3.2 - 0 0 - 0
3AC Totald 6.0 - 6,000 6,000 - 0
DL 0.2 - 0 0 - 0
MLD 3.8 - 0 0 - 0
STPpt 2.1 0.30 6,000 6,000 0.30 0
3AD Totald 4.0 - 11,000 11,000 - 0
Phase 3A - Pads DL 0.0 - 0 0 - 0
HLY 0.4 - 0 0 - 0
HZMaa 0.0 0.30 0 0 0.30 0
STPpt 3.6 0.30 11,000 11,000 0.30 0
3AE Totald 4.0 - 11,000 11,000 - 0
DL 0.2 - 0 0 - 0
HZMaapt 2.2 0.30 6,000 6,000 0.30 0
STPpt 1.6 0.30 5,000 5,000 0.30 0
3AF Totald 4.0 - 0 0 - 0
MLD 2.8 - 0 0 - 0
MLDzz 1.2 - 0 0 - 0
STPpt 0.0 0.30 0 0 0.30 0
3AG Totald 4.0 - 0 0 - 0
MLD 4.0 - 0 0 - 0
Subsoil
3AH Totald 4.0 - 1,000 1,000 - 0
ELS 1.2 0.07 1,000 1,000 0.07 0
Phase 3A – Pads HZMaapt 0.1 0.30 0 0 0.30 0
(cont’d) MLD 2.7 - 0 0 - 0
3AI Totald 4.0 - 0 0 - 0
MLDzz 4.0 - 0 0 - 0
Phase 3B -
Totald 146.0 - 234,000 234,000 - 0
Pads
3BA Totald 4.0 - 4,000 4,000 - 0
HZMaa 1.5 0.30 4,000 4,000 0.30 0
MLDxt 2.5 - 0 0 - 0
3BAA Totald 4.0 - 12,000 12,000 - 0
HZMaa 4.0 0.30 12,000 12,000 0.30 0
3BB Totald 4.0 - 0 0 - 0
Page 11-50
MLDxt 4.0 - 0 0 - 0
3BBB Totald 4.0 - 12,000 12,000 - 0
HZMaa 4.0 0.30 12,000 12,000 0.30 0
3BC Totald 4.0 - 12,000 12,000 - 0
STP 4.0 0.30 12,000 12,000 0.30 0
3BCC Totald 4.0 0.30 12,000 12,000 0.30 0
HZMaa 4.0 0.30 12,000 12,000 0.30 0
3BD Totald 4.0 - 9,000 9,000 - 0
Phase 3B - Pads MLDxt 1.0 - 0 0 - 0
STPzz 3.0 0.30 9,000 9,000 0.30 0
3BDD Totald 4.0 - 12,000 12,000 - 0
HZMaa 4.0 0.30 12,000 12,000 0.30 0
3BE Totald 4.0 - 0 0 - 0
MLDxt 3.8 - 0 0 - 0
MLDzz 0.2 - 0 0 - 0
3BEE Totald 6.0 - 8,000 8,000 - 0
MLDxt 1.7 - 0 0 - 0
MRN 1.7 - 0 0 - 0
STP 0.5 0.30 1,000 1,000 0.30 0
STPpt 2.1 0.30 6,000 6,000 0.30 0
3BF Totald 4.0 - 0 0 - 0
MLDxt 4.0 - 0 0 - 0
3BFF Totald 6.0 - 9,000 9,000 - 0
HZMaa 3.1 0.30 9,000 9,000 0.30 0
MRN 2.9 - 0 0 - 0
Subsoil
3BG Totald 4.0 - 0 0 - 0
MLDzz 4.0 - 0 0 - 0
3BGG Totald 6.0 - 14,000 14,000 - 0
DL 0.5 - 0 0 - 0
ELSpt 1.2 0.10 1,000 1,000 0.10 0
HZMaa 4.3 0.30 13,000 13,000 0.30 0
3BH Totald 4.0 - 8,000 8,000 - 0
MLDxt 1.4 - 0 0 - 0
STP 2.6 0.30 8,000 8,000 0.30 0
3BHH Totald 4.0 - 11,000 11,000 - 0
ELSpt 0.3 0.10 0 0 0.10 0
HZMaa 3.7 0.30 11,000 11,000 0.30 0
3BI Totald 4.0 - 0 0 - 0
MLDxt 1.4 - 0 0 - 0
Page 11-51
MLDzz 2.6 - 0 0 - 0
3BJ Totald 4.0 - 12,000 12,000 - 0
STPzz 4.0 0.30 12,000 12,000 0.30 0
3BK Totald 4.0 - 0 0 - 0
DL 0.5 - 0 0 - 0
Phase 3B – Pads
MUS 3.5 - 0 0 - 0
(cont’d)
3BL Totald 4.0 - 0 0 - 0
DL 1.2 - 0 0 - 0
MLD 2.8 - 0 0 - 0
3BM Totald 4.0 - 0 0 - 0
MLD 4.0 - 0 0 - 0
MLDxt 0.0 - 0 0 - 0
3BN Totald 4.0 - 0 0 - 0
MLD 2.2 - 0 0 - 0
MLDxt 1.8 - 0 0 - 0
3BO Totald 6.0 - 18,000 18,000 - 0
HZMaa 0.0 0.30 0 0 0.30 0
STPpt 6.0 0.30 18,000 18,000 0.30 0
3BP Totald 4.0 - 2,000 2,000 - 0
HZMaa 0.2 0.30 1,000 1,000 0.30 0
MLD 3.5 - 0 0 - 0
STPpt 0.3 0.30 1,000 1,000 0.30 0
3BQ Totald 4.0 - 0 0 - 0
DL 0.8 - 0 0 - 0
MLD 3.2 - 0 0 - 0
Subsoil
3BR Totald 4.0 - 7,000 7,000 - 0
MLDxt 1.2 - 0 0 - 0
MUS 0.3 - 0 0 - 0
STPpt 2.5 0.30 7,000 7,000 0.30 0
3BS Totald 4.0 - 6,000 6,000 - 0
HZMaa 1.0 0.30 3,000 3,000 0.30 0
MLDxt 2.1 - 0 0 - 0
STPpt 0.9 0.30 3,000 3,000 0.30 0
3BT Totald 4.0 - 0 0 - 0
MUS 4.0 - 0 0 - 0
3BU Totald 4.0 - 0 0 - 0
MRN 3.7 - 0 0 - 0
MUS 0.3 - 0 0 - 0
Phase 3B – Pads
3BV Totald 6.0 - 18,000 18,000 - 0
(cont’d)
Page 11-52
DL 0.0 - 0 0 - 0
HZMaa 6.0 0.30 18,000 18,000 0.30 0
3BW Totald 4.0 - 12,000 12,000 - 0
HZMaa 3.0 0.30 9,000 9,000 0.30 0
STPpt 1.0 0.30 3,000 3,000 0.30 0
3BX Totald 4.0 - 12,000 12,000 - 0
HZMaa 4.0 0.30 12,000 12,000 0.30 0
3BY Totald 4.0 - 12,000 12,000 - 0
HZMaa 3.2 0.30 10,000 10,000 0.30 0
STPpt 0.8 0.30 2,000 2,000 0.30 0
3BZ Total 4.0 - 12,000 12,000 - 0
HZMaa 3.5 0.30 10,000 10,000 0.30 0
STPpt 0.5 0.30 2,000 2,000 0.30 0
Phase 1 - ROW Totald 43.6 - 78,000 78,000 0
DL 10.1 0 - 0 - 0
HRR 4.1 0.3 12,000 12,000 0.30 0
HZMaa 16.2 0.3 49,000 49,000 0.30 0
Phase 1 – Multi- MLD 5.2 0 o 0 - 0
Use Corridor MRN 0.1 0 o 0 - 0
MUS 2.1 0 o 0 - 0
STP 1.3 0.3 4,000 4,000 0.30 0
STPpt 1.5 0.3 4,000 4,000 0.30 0
STPzz 3.0 0.3 9,000 9,000 0.30 0
Subsoil
Phase 2 - ROW Totald 32.3 - 20,000 20,000 0
DL 1.6 0 o 0 - 0
HLY 0.3 0 o 0 - 0
HZMaa 4.6 0.3 14,000 14,000 0.30 0
Phase 2 – Multi- MLD 19.6 0 o 0 - 0
Use Corridor MLDxt 0.5 0 o 0 - 0
MLDzz 2.4 0 o 0 - 0
MUS 1.3 0 o 0 - 0
STP 0.1 0.3 o 0 0.30 0
STPzz 1.9 0.3 6,000 6,000 0.30 0
Phase 3A - Totald 50.6 - 74,000 74,000 0
ROW DL 4.2 0 o 0 - 0
ELS 0.5 0.07 o 0 - 0
HLY 2.5 0 o 0 - 0
HZMaa 5.7 0.3 17,000 17,000 0.30 0
Page 11-53
Phase 3A -
HZMaapt 4.1 0.3 12,000 12,000 0.30 0
Corridor
MLD 11.4 0 o 0 - 0
MLDxt 1.5 0 o 0 - 0
MLDzz 5.7 0 o 0 - 0
STP 4.8 0.3 14,000 14,000 0.30 0
STPpt 10.0 0.3 30,000 30,000 0.30 0
Phase 3B - Totald 186.3 - 271,000 271,000 0
ROW DL 6.4 0 o 0 - 0
ELSpt 3.0 0.1 3,000 3,000 0.10 0
HZMaa 65.6 0.3 197,000 197,000 0.30 0
MLD 24.1 0 o 0 - 0
MLDxt 45.2 0 o 0 - 0
Phase 3B -
MLDzz 1.5 0 o 0 - 0
Corridor
MRN 4.4 0 o 0 - 0
MUS 11.3 0 o 0 - 0
RB 1.2 0 o 0 - 0
STP 5.5 0.3 16,000 16,000 0.30 0
STPpt 18.1 0.3 54,000 54,000 0.30 0
STPzz 0.2 0.3 o 0 - 0
Grand Totald 820.2 - 1,419,000 1,403,950 15,050
Notes: (a) Available volumes rounded to the nearest 1000 m3
(b) Replacement depths of upland mineral subsoil will be equivalent to the salvage depths encountered on each component of the Project.
(c) The return of a portion of borrow areas to open water will result in excess subsoil. Approximately 95% of soil salvaged will be replaced, with the remaining 5% returning to open water. Excess soil will be considered for
use in reclamation of developments where fill material is left in place or to supplement placement thicknesses of reclamation material if required.
(d) Individual values may not add to totals due to rounding.
11.4.1.10 Soil Stockpiling

BlackPearl will strive to stockpile salvaged soil at the site of origin. All stockpile locations and volumes will
be in as-builts. Long term stockpiled materials will be placed in the designated stockpiles as follows.
• Topsoil and subsoil materials salvaged from well pads will be stockpiled separately on like materials
with a minimum 1 m separation between the toe of each stockpile.
• Soil material salvaged from borrow pit areas shall be stockpiled at the borrow site or at a designated
stockpile location until required for reclamation.
• Topsoil and subsoil materials salvaged from the CPF will be stored on the edge of the CPF site in
stockpiles until required for reclamation.
• Stockpiled material will be placed on a stable surface out of the way of surface water flow.
• Stockpiled material will include signage that indicates the type of reclamation material.
• Average height of stockpiled material will vary between 3-5 m with minimum slopes of 3:1.
• Where space is available the stockpiles will be placed in wide shallow configurations to assist with
providing more aerobic conditions.
• A 5 m setback will be in place between standing timber and the base of the soil pile.
• Piles will be stabilized through active seeding to control soil loss due to water or wind erosion, and
encourage organic matter build-up and nutrient cycling. A certified weed-free seed mixture will be
developed in consultation with AESRD for use on long-term soil piles.
• BlackPearl shall follow the weed management practices when considering options for stability control
on soil stockpiles.
• Where windrowing is not an option, BlackPearl will utilize existing nearby disturbances to store the
reclamation material.
Long term stockpiled materials will be stabilized and seeded for erosion control. Site specific seed mixes
will be developed for different soil types based on the results of the PDAs. An example seed mix is
provided in Table 11.4-7 and reseeding methodology is described in Section 11.4.5.3.
Materials salvaged from access road/utility corridors in upland/transitional soils will be temporarily stored
along the edge of the right of way and replaced within the ditches once construction is complete. All long
term soil piles will be documented in the Annual C&R Report submitted annually to AESRD. The
stockpiled reclamation material will not be utilized for any construction activities. A diagram identifying soil
stockpile locations is provided in Figure 11.4-5.
TABLE 11.4-7
NATIVE GRASS SEED MIX EXAMPLE FOR A MOIST RICH SITE TYPE
Common Name Percentage of Mix

Canada wild rye 30
fringed brome 20
Rocky Mountain fescue 15
June grass 15
hairy wild rye 10
tufted hair grass 10
fowl bluegrass 5
Notes: Broadcast seed 20-25 kg/ha
Page 11-54
11.4.2 Facility Operation

11.4.2.1 Progressive Reclamation
The goal of progressive reclamation of facilities is to minimize the amount of active surface disturbance
whenever a component of the facilities is no longer required.
Examples of progressive reclamation measures are:
• temporary water crossings will be removed;
• pipeline ditches will be closed for buried water pipelines as soon as practical to maintain
propagule viability;
• natural woody vegetation will be allowed to grow back along the edge of cleared multi-
use corridors during the operation phase to the extent practical;
• reclamation of disturbed sites will be initiated as soon as the work areas are no longer
required and will be carried out progressively over the lifespan of the Project.
Progressive reclamation will be conducted throughout the Project phases, including
actively revegetating multi-use corridors as early in the Project as feasible;
• a selection of traditionally used species (Volume 4, Appendix 1A) will be utilized for the
revegetation of disturbed sites, as indicated in the planting prescriptions contained
within the C&R for the Project (Section 11.4.5);
• wetlands will be allowed to naturally regenerate following construction. Wetlands will not
be seeded;
• monitoring of disturbed sites will be initiated progressively depending on the Project

phase at which reclamation begins for each component. Monitoring will address the
effectiveness of progressive revegetation efforts, weed control efforts, and rare plant
and rare ecological community mitigation. Remedial work will be recommended, if
warranted, to address any issues identified during the Vegetation Monitoring Program
(VMP) (Volume 4, Section 1.6.1);
• the site will be monitored post-construction, during operation to document and, if

warranted, implement mitigation to ensure that existing drainage patterns are
maintained (altered hydrology is visible as excessive surface water ponding or stressed
vegetation);
• water quality and vegetation adjacent to the Project Area within wetlands will be
monitored post-construction during operation. Remedial measures will be implemented,
where warranted;
• all roads damaged by construction vehicles will be repaired to preconstruction

conditions. Shoo-flies will be reclaimed as part of interim reclamation;
• travel will take place on designated access roads to prevent unnecessary damage to
surrounding vegetation and surface soil layers. Off-road detours around mudholes will
be avoided;
• low speed limits will be posted on Project roads and the main access road, and will
reduce dust deposition;
• the use of refined oil for dust control on roads during maintenance activities will be
prohibited. Solutions consisting of organic/non-toxic ingredients or water will be used to
control dust on roadways. Dust control activities will be conducted in accordance with
applicable provincial and municipal regulations and guidelines; and
Page 11-55
• where maximum vegetation height limits must be maintained adjacent to the facilities,
brushcutters, brushhogs or other equipment will be used which will result in minimal
terrain disturbance during nonfrozen conditions to clear tall brush and small trees.
All disturbances associated with construction and interim reclamation activities will be documented within
the Annual C&R Report submitted to AESRD.
11.4.2.2 Erosion and Sediment Control

The risk of soil erosion to surface soils is greatest during the soil salvage, soil storage and soil
replacement stages of construction. At minimum, BlackPearl will minimize soil erosion risk during soil
handling, stockpiling and reclamation activities through the following methods:
• limiting the time between surface soil salvage and placement within the designated
stockpile areas;
• suspending soil handling during periods of high winds and wet ground conditions;
• strategically placing soil stockpiles to minimize exposure to wind or water;
• ensuring stockpiles will have slopes less than or equal to 3:1;
• for landscapes with a high probability for erosion, such as steep side slopes, utilizing
measures such as soil stabilizers, tackifiers, silt fencing, sediment traps or wind
barriers;
• construction of continuous berms or earth dyke barriers;
• seeding topsoil stockpiles, as soon as possible, with an approved seed mix;
• establishing vegetative cover in disturbed non-gravelled areas to prevent erosion, runoff

and sedimentation from the Project Area into adjacent wetland areas, as soon as
feasible following construction. Seeding or otherwise stabilizing stockpiles and disturbed
areas that will not be gravelled with an appropriate seed mix. Adding a cover crop
where erosion is a concern; and
• monitoring of the reclaimed areas and stockpiles to ensure the effectiveness of the
mitigation measures implemented.
Whenever possible, soil disturbances shall be allowed to re-vegetate naturally. In the event that natural
regeneration methods are insufficient or ineffective in the control or prevention of soil erosion, BlackPearl
will utilize erosion control measures such as:
• installation of silt fencing;
• hydro-seeding or hydro-mulching;
• use of salvaged coarse woody debris;
• installation of coconut matting following soil replacement;
• slope texturing; and
• creation of adequate drainage.
11.4.2.3 Weed Management

BlackPearl is committed to undertaking weed and invasive species management and control throughout
the life of the Project in accordance with the Alberta Weed Control Act and ASRD’s Weed Management in
Forestry Operations (ASRD 2001). According to the Alberta Weed Control Act, Prohibited Noxious weeds
Page 11-56
are those that must be destroyed, and Noxious weeds are those that must be controlled. Vegetation and
weed management practices on Project facilities are described in Volume 4, Section 1.6.1. Vegetation
management conducted by mechanical means (i.e., cutting or mowing) will be favored; if vegetation
management by chemical means is the only feasible method it will be conducted with equipment that
ensures the specificity of the application. Additional vegetation and weed management practices include:
• recommendations made in the PDAs to limit the risk of transporting weed seeds from
weed-infested areas will be followed. Areas identified as having Prohibited Noxious or
Noxious weed infestations will be flagged prior to construction activities.
• construction equipment will be cleaned prior to its arrival on site to minimize the risk of
weed introduction. Any equipment that arrives in a dirty condition shall not be allowed
on the Project Area until it has been cleaned off at a suitable location. Stickers will be
applied to equipment that has been verified as being cleaned of soil potentially holding
weed seeds. A log will be kept of all equipment that has been cleaned. This log will be
provided to the Environmental Inspector for record keeping.
• seed mixes used to revegetate disturbed areas will be free of Prohibited Noxious and
Noxious weed seed. The best available seed will be used and the analysis certificate(s)
will be retained.
• disturbed areas will be monitored during all phases of the Project for areas of prolific
weed growth. Measures to control weeds at identified locations will be conducted. Any
weeds listed as Prohibited Noxious or Noxious under the Weed Control Act or by the
municipality will be controlled in a timely manner to prevent the spread of the weed.
Records of weed control activities will be kept and detailed in the Annual C&R Report;
• training of operation personnel and contractors on weed identification and reporting

requirements;
• agronomic species will be avoided for re-vegetation of reclaimed areas;
• clean fill material will be used to ensure that Prohibited Noxious and Noxious weed
species are not present; and
• erosion control products shall not contain agronomic species.
11.4.2.4 Water Management

BlackPearl will conduct monitoring of surface water quality and vegetation adjacent to facilities located
within wetlands Quarterly groundwater quality monitoring reports will also be reviewed prior to conducting
wetland monitoring. If substantial negative impacts are detected, remedial measures will be implemented
to correct these impacts. When determining remedial measures to be taken industry peer
initiatives/learnings and new reclamation techniques will be considered, The results of the monitoring
program and remedial measures implemented will be provided in the Annual C&R Report.
Temporary alterations to surface run-off are anticipated during the construction and operational phases of
the Project. In cases where facility placement may affect surface water flows, water flows will be directed
around the facility to maintain drainage patterns in a manner that minimizes changes to existing hydrology
and protects surface water quality. Mitigation measures to be utilized throughout the Project to reduce the
potential impacts on shallow groundwater quality from construction activities and run-off from well pads,
CPF, roads and multi-use corridors are discussed in Volume 3, Section 1.0.
These include, but are not limited to:
• selection of routes for multi-use corridors to maximize the use of existing linear
disturbances, minimizing habitat disruption and minimization of watercourse crossings
while minimizing the overall Project Area;
Page 11-57
• strive to utilize common corridors for access roads and pipelines as much as possible;
• utilization of a 100 m buffer zone to watercourses for well pads and facilities;
• use of existing disturbances for project facilities, wherever possible;
• adhere to AENV’s Code of Practice for Pipelines and Telecommunications Line

Crossing a Water Body and Code of Practice for Watercourse Crossings under the
Water Act;
• monitoring of water quality during instream construction where required by applicable

regulatory approvals;
• installation and maintenance of appropriate sediment control techniques during

construction of roads, drainage ditches and multi-use corridors to minimize
sedimentation;
• utilization of appropriate soil stabilization techniques for soil stockpiling to minimize

deposition from water and wind erosion; and
• disposal of drilling waste in accordance to AER Directive 058 and Directive 050.
These measures will reduce the potential for spills to reach watercourses and waterbodies and include
industry-standard operating practices such as the use of secondary containment for above ground
storage tanks (ASTs), spill preparedness and BlackPearl’s Health Safety and Environment Program.
Mitigation measures will be in place during the operation phase of the Project developments to reduce
surface run-off from well pads and access roads that have the potential to directly affect surface waters
through the introduction of sediment. The measures to be implemented include:
• well pads shall be constructed with a 1 m high berm and contoured to facilitate lease
run-off to naturally drain to one corner;
• contaminated run-off from the well pads will be taken to the CPF for recycling or
disposal;
• installation of appropriate watercourse crossings at drainage lows, wetlands and

watercourses;
• installation of appropriate sediment control techniques on access roads and drainage

ditches to minimize the introduction of sediment; and
• culvert ends will be flagged. Culverts will be checked periodically for blockages to flow
and monitored for erosion at the culvert ends after installation.
Water collected in the down gradient corner of the well pad will be sampled and released upon
compliance with the following criteria:
• Chloride content below 500 mg/L;
• pH 6.0 to 9.5;
• testing indicates no other chemical contamination ;
• consent of AESRD;
• water will be released onto an adjacent upland environment. The release area will have
sufficient buffers to any watercourses (river or creek), or waterbodies; and
Page 11-58
• each water release shall be documented including testing results, date of release and
volumes released.
All water pumped off lease will be discharged without causing erosion and will be filtered (e.g., through
geotextile membranes). Silt in the pumped water can reduce water quality if introduced into waterbodies
and can alter the nutrient content of peat. Accumulated water that does meet regulatory requirements
shall be taken to the CPF for recycling or disposal.
Potential effects and mitigation measures towards receiving surface waterbodies are further discussed in
the Hydrology Assessment (Volume 3, Section 2.0), the Surface Water Quality Assessment (Volume 3,
Section 3.0) and the Aquatic Ecology Assessment (Volume 3, Section 4.7). Key mitigation measures
include:
• storage of all liquid and solid materials have a minimum setback of 100 m from any
watercourse;
• stations for washing, maintaining and fueling equipment shall have a minimum setback
of 100 m from any watercourse;
• well pads shall have a 100 m setback from watercourses;
• spills shall be cleaned up immediately in accordance to BlackPearl’s emergency

response procedures;
• during construction activities in or near aquatic habitats, a Qualified Aquatic

Environmental Specialist (QAES) will be on-site to supervise the implementation of
mitigation measures and compliance with regulatory requirements; and
• BlackPearl will implement a surface water quality monitoring program at selected

surface water sites in the LSA and RSA.
A shallow groundwater monitoring program shall be carried out throughout the operational life of the CPF
facility to provide early detection of effects from accidental spills or leaks. The program is discussed in
more detail in Volume 3, Section 1.8 and involves the installation of groundwater monitoring wells, the
monitoring of water levels within the wells and the collection and analysis of groundwater samples for
predetermined parameters. Reporting of the results from the monitoring program will be submitted to
AESRD on an annual basis.
11.4.3 Facility Decommissioning and Reclamation

Reclamation of individual facilities and Project developments will be ongoing throughout the life span of
the Project. A breakdown of the Project facilities in upland and lowland environments with the
corresponding proposed reclamation type is provided in Table 11.4-8. At minimum, general reclamation
procedures will include:
• review of the environmental history of the facility and additional assessments

performed, if required. Sites will be assessed in accordance to the Phase I
Environmental Site Assessments Guideline for Upstream Oil and Gas Sites
(AENV 2001) as amended and the 2010 Reclamation Criteria for Wellsite and
Associated Facilities Application (AENV 2011b). Based on the results of the Phase I
ESA a Phase II environmental assessment may be conducted;
• all above ground infrastructure and equipment will be removed;
• all wells will be abandoned in accordance to AER Directive 020 (ERCB 2007). The well
casings will be cut 2 m below the final contour elevation and capped with a welded steel
plate;
Page 11-59
• all debris and garbage will be removed from the facility prior to the commencement of
reclamation;
• any areas requiring remedial activities, such as a substance release, will be reassessed
upon completion of the remedial activities to confirm achievement of the remedial goals;
and
• areas to be reclaimed will be re-contoured and soils replaced.
Reclamation activities shall be suspended during wet soil conditions and high winds to maintain soil
quality and minimize soil loss. Reclamation of a well pad within upland environments is illustrated in
Figure 11.4-1.
BlackPearl intends to conduct progressive reclamation of well pads and associated facilities (access
roads, pipelines and transmission lines, borrow pits) that are not required for operations upon completion
of abandonment and decommissioning. Reclamation of the well pads and associated facilities within the
first 10-12 years of the Project should overlap with the construction of well pads in later phases.
BlackPearl will strive to re-use salvageable material (clean fill and gravel) for the coinciding new facility
construction, wherever reasonable.
Knowledge gained from the progressive reclamation and subsequent monitoring of the initial facilities will
be used to improve future reclamation and monitoring programs and procedures as part of BlackPearl’s
adaptive management strategy. Research is required to further develop a successful reclamation practice
for the reclamation of wetlands. BlackPearl recognizes the benefits of the multi-stakeholder groups that
are in place to ensure good stewardship within the oilsands and is investigating alternative procedures
that can be adopted to enhance the proposed reclamation measures for the Project. BlackPearl is
currently a member or the Cumulative Effects Management Association (CEMA) and will participate in
research studies where applicable, such as the Boreal Forest Research Centre operated by the Northern
Alberta Institute of Technology (NAIT).
Page 11-60
TABLE 11.4-8
PROJECT FACILITIES IN UPLAND AND LOWLAND WITH CORRESPONDING PROPOSED RECLAMATION TYPE
Reclamation Type on Upland Reclamation Type on Lowland

Full fill Partial fill No fill Geotextile Full fill Partial fill No fill Geotextile
Quantity Upland Upland Lowland Lowland removal removal removal removal removal removal removal removal
Project Facility (unit) Area (ha) (unit) (ha) (Unit) (ha) (unit) (unit) (unit) (ha) (unit) (unit) (unit) (ha)
Central Processing 1 122.9 1 122.9 0 0 0 0 1 0 0 0 0 0
Facility
CPF Access Road 1 0.8 1 0.8 0 0 0 0 1 0 0 0 0 0
Camps 1 18.7 1 18.7 0 0 0 0 1 0 0 0 0 0
Well Pads 54 232.2 20 118.8 34 113.4 0 0 20 0 0 34 0 58.7
Sumps 3 13.34 3 13.34 0 0 0 0 3 0 0 0 0 0
Borrow Pits 24 151.4 18 0 6 0 0 0 18 0 0 0 6 0
Multi-use Corridors n/a 313.1 n/a 173.7 n/a 139.1 0 0 173.7 ha 0 139.1 ha 0 0 139.1
Area of Direct Soil Disturbance 852.5
Notes: 1. Approximately 56% of each well pad located in deep peat areas will be reclaimed to wetland type reclaimed soils.
Approximately 44% will be reclaimed to transitional soils.
Approximately 27% will be reclaimed to upland mineral soils.
Page 11-61
11.4.3.1 Reclamation of Upland Sites

CPF, Access Roads/Utility Corridors and Well Pads
The objectives for reclamation of Project developments within upland areas will include returning soil,
landform and drainage conditions that are consistent with adjacent lands, and restoration of habitat to an
equivalent land capability.
Reclamation of the Project Area on uplands will be completed under dry, non-frozen conditions where
feasible. Reclamation plans will be site-specific and developed based on results of PDA, site-specific
monitoring, adjacent vegetation communities, and consultation with AESRD and relevant stakeholders at
the time of reclamation. Generally, reclamation steps will include:
• removal of salvageable surface gravel for re-use on existing or new Project facilities,
where feasible;
• decompaction of the subsoil underlying facilities through disking, ripping or both prior to
commencement of recontouring activities;
• recontouring of facilities to be compatible with the surrounding landforms and natural

drainage patterns;
• linear disturbances will be recontoured with the creation of irregular patterns of

undulating terrain with low areas utilized to restore natural drainage patterns.
Recontouring of the linear disturbances will be compatible with the surrounding
landscape;
• replacement of the salvaged subsoil to an average depth of 30 cm and disc or harrow

the replaced subsoil material to lessen compaction prior to surface soil or peat
replacement;
• replace salvaged topsoil, leaving the surface textured to provide microsites for moisture
retention and plant species establishment. Topsoil replacement will consist of
replacement of the stockpiled material to an equivalent depth of pre-construction
conditions;
• ensure uplands with native vegetation are seeded with an appropriate native seed mix
or left to naturally regenerate. Seed riparian and erosion prone areas with an approved
seed mix and cover crop;
• seed mixes used to revegetate disturbed areas will be free of Prohibited Noxious and
Noxious weed seed. The best available seed will be used and the analysis certificate(s)
will be retained; and
• restrict vehicle access over newly seeded areas.
Prior to the commencement of reclamation activities on access corridors, equipment will be removed from
the Right-Of-Way (ROW) and the gravel removed from the road for use on other developments
associated with the Project. Power supply lines and poles will be removed. The base structures that
support the power poles and/or guy wires will be removed to a depth of 1.2 meters, covered with subsoil
and reclamation material (peat or mineral topsoil) compatible with the surrounding area. For wellpads in
upland areas, fill material is generally not required as the material underlying the subsoil is typically
suitable for construction. Where grading is required on a well pad within upland areas (i.e., cut and fill),
the material underlying the salvaged subsoil can be used for construction. During reclamation, the well
pad will be re-contoured to re-establish drainage and tie the reclaimed site into the surrounding
undisturbed area.
Road reclamation within upland environments will involve the removal of culverts and watercourse
crossings. Fill material and geotextile will be removed from the crossings and will be redistributed along
Page 11-62
the recontoured road area. Decompaction measures, where required will be performed during dry
conditions to ensure the effectiveness of ripping and to minimize soil restrictions that would negatively
affect vegetation growth. Topsoil and subsoil stockpiled along the ROW will be replaced within the
recontoured access road. Figures 11.4-6 and 11.4-7 illustrate typical reclamation of access roads within
upland and shallow wetland environments.
The CPF site is situated within an upland area and will be reclaimed in a consistent approach as per an
upland well pad site. A conceptual diagram of the reclamation approach is illustrated in Figure 11.4-8.
Borrow Pits
Borrow pits within upland environments will be reclaimed to encourage the development into upland
ecosites similar to adjacent lands. It is expected that a portion of the borrow pits will have an area that will
have a hydric soil moisture regime, resulting in a marsh vegetation community establishing. The
recontoured gentle slopes of the borrow pits will have a gradient of soil moisture regimes that will trend
from this marsh vegetation community through a transitional treed swamp vegetation community to an
upland vegetation community similar to adjacent lands. The techniques utilized to reclaim borrow pits to
promote connectivity to adjacent vegetation communities and habitats will vary on a site-by-site basis.
The reclamation approach for borrow pits are illustrated in Figures 11.4-9, 11.4-10 and 11.4-11.
11.4.3.2 Reclamation of Deep Peat Sites

The approach to reclamation of well pads within regions of deep peat will be to reclaim the central portion
of the pad site to an upland environment, with the outer portions of the pad area to be reclaimed to a
shallow peat wetland leading into the surrounding undisturbed deep peat wetland. The reclamation
approach for well pads within regions of deep peat is illustrated in Figure 11.4-3.
The creation of transitional upland islands as the preferred method for reclaiming well pads and facilities
within deep peat environments has many advantages over current reclamation practices. The current
practice of leaving the mineral cap in place will not restore the structure or the ecological function of the
peatland to pre-disturbance equivalence (Graf 2009). The reclamation approach is designed to restore an
underlying physical structure, within a gradient that can support the same dominant wetland vegetation
species assemblages. This is a modified pit and mound approach as developed and used in reforestation.
It resembles topography throughout the boreal, including moats, ridges, hollows, hummocks, as well as
flat lawns at or near the water table. The primary consideration is water, at or near the soil surface, which
creates soil conditions suitable for the species assemblages found on the adjacent reference locations.
The natural community type for most northern bogs is dominated by blackspruce (Lavoie, et al. 2005).
The present day vegetation groupings has not changed in centuries, and are in fact and excellent
reference point for what constitutes successful reclamation (i.e., the adjacent adjoining undisturbed
ecosite). Successful reclamation does not imply an identical replicate of what was there prior to the
disturbance activity, but it would mean recreating the physical conditions to support those vegetation
groupings which are naturally part of the ecosite.
The currently proposed reclamation plan (the creation of transitional upland islands within deep peat
areas) is based on modified “pit and mound technology” techniques commonly used in reforestation. The
methods proposed for the reclamation of access roads and well pads within deep peat wetlands will:
1. Preserve natural hydrology through the creation of cross drainages on access roads to maintain
natural and subsurface flows. This is achieved by the partial removal of pad material in deep
peats combined with the removal of all pad material at pre-selected locations along the access
road as well as the total removal of pad material within shallow peat environments and
replacement of salvaged pet material within the excavated areas. The hydrology would provide
for subhydric to hydric soils near the water table which in turn supports the same species
assemblages as the surrounding ecosite.
2. Restore the topography to baseline conditions wherever possible. The square linear edges of the
well pad and access road would be recontoured into irregular outlines, combined with low ridges,
as can be found in mature forested swamp systems.
3. Restore, at minimum, 56% of the pad area to deep peat.
Page 11-63
4. Utilize natural vegetation through the salvage of the upper 40 cm of peat augmented with plantin ,
where required.
Pit and mound topography involves creating “pits” where the fill is completely removed and mounds
where the fill is re-contoured to transitional and upland areas. These mounds are predicted to be hygric
and support ecosystems such as a g or h, as normally seen along the edges of deep peat wetland
systems.
The reclamation steps for Project facilities in deep peatlands will include:
• removal of salvageable surface gravel for use on existing or new Project facilities,
where feasible;
• decompaction of the facilities through disking, ripping or both prior to commencement of

recontouring activities;
• excavation of pad material from the peat replacement area to leave a poorly drained
lowland area;
• excavated material shall be placed at the central area of the pad or used for
construction activities;
• the central area will be contoured to become a slightly domed upland with slopes less
than 25% gradient. Erosion prevention measures will be utilized where required;
• salvaged peat will be replaced over the contoured mineral soil to a thickness of 20 cm
and mixed into the mineral soil within the central area;
• salvaged peat will be replaced over the shallow peat wetland area to a thickness of
20 cm to encourage the establishment of a transitional wetland vegetation community;
and
• salvaged peat shall be replaced into the outer pad area with undulations consistent with
the adjacent landscape and with similar hydrology.
The geotextile will be removed from all areas where the fill material is intended to be excavated as well as
around the edges of the well pads and associated facilities to create an irregular outline. BlackPearl will
be removing sufficient geotextile and well pad to achieve a minimum of 56% return to deep peat.
Remaining edges create a gradually sloped transition zone, again with geotextile removed around the
perimeter of the landforms so as not to interfere with root growth of trees or other vegetation. The width of
the geotextile to be removed around the perimeter of the recontoured land will be determined on a case
by case basis and will be approximately 44m. Geotextile will remain in place in areas with more than
75 cm of fill material on deep peat to avoid additional unnecessary disturbance. All species used for
reclamation planting in these areas, including tamarack and black spruce are shallow rooted species,
where roots spread laterally. The planted species would not be limited by the geotextile at depth or
adequate water source (Riley 1989).
In addition to being a common and currently permitted practice, BlackPearl prefers leaving portions of the
fill in place to complete fill removal for the following reasons.
• The total removal of fill material from well pads located in deep peat will likely create a depressional
area which will fill with water and be much more difficult to revegetate.
• The water filled area may prevent the dominant species (i.e. black spruce) from establishing. The
depressional area will likely become dominated by sedges and emergent aquatics since soil moisture
regimes and conditions are wetter than pre-disturbance conditions. Such change will not yield the
same ecosite as present in the pre-disturbance state.
Page 11-64
The proposed reclamation approach has no anticipated significant adverse effects to the surface
hydrology, as there are no changes in water inputs or withdrawals to the ecosites, nor are there changes
in water flows or obstructions. There is no change in flux. In addition, the well pads are relatively small in
comparison to the adjacent undisturbed lands and do not affect the overall ecosite or hydrology of the
surrounding ecosite (Price, et al. 2003).
Reclamation strategy for access road within deep peat will involve the complete removal of the pad
material and geotextile. All salvageable gravel, culverts and minerals soils as well as the geotextile
surrounding the culverts will be removed. Salvaged peat will be replaced within these areas. BlackPearl
will decompact the underlying peat in an effort to “fluff” the compacted peat to provide sufficient elevation
to meet the adjacent ground.
Further research into methods for reclaiming wetlands through partial removal of the well pad could be
beneficial. Various pad removal depths/water depth/peat replacement depth trails on well pads
decommissioned earlier in the Project life-cycle will be conducted. The outcome from these trials will be
used as part of adaptive management when developing and reclaiming the next phase of well pads on
the Blackrod Project.
A potential design for a reclamation trial to determine the optimal or at the very least, suitable, conditions
for peat creation and wetland re-establishment, portions of the well pad can be removed in a wedge
shape. At the bottom of the wedge, the entire pad is removed while at the top of the wedge, the entire
thickness of the pad remains. A water depth gradient is now present on which to study various peat
replacement depths. An additional factor to consider for this trial is whether or not newly salvaged peat
would perform better than older stockpiled peat. This would be included as part of the trial. The results of
the trial should provide some evidence as whether deeper peat replacement depths work any better than
thinner replacement depth and whether or not newly salvaged peat establishes better than stockpiled
peat or a combinations of each.
Alternate Reclamation Approaches

Currently, the preferred reclamation approach is a viable and beneficial strategy, although BlackPearl
recognizes that it is not necessary to use the preferred method on each site. Some sites could in fact be
completely excavated, using the normal best management practices. There are several additional
approaches besides the preferred reclamation strategy for the reclamation of well sites within deep peat
wetlands that may be applicable:
1. Full removal of fill material and geotextile and decompaction of compacted peat: The “fluffing of the
peat to expose and decompact the peat layer that would be compressed under the clay pad is
intended to add volume to the surface peat. The removal of the entire well pad and geotextile would
effectively remove any barriers to hydrological function of the reclaimed area. However, there are
limitations to the use of this technique in that it is not very effective in areas with shallow underlying
peat and the fluffing of the peat may not be sufficient to meet the adjacent ground surface elevation,
thus establishing regions of open water. This conceptual reclamation strategy is illustrated in
Figure 11.4-4. Even with the addition of donor peat, the depressional area would be saturated and the
peat would be unconsolidated. Additionally the removal of the fill would create a contour that was not
there previously and is not viewed as desirable in terms of creating an optimal environment for
vegetation establishment. The feasibility of this approach is still to be determined through studies
being performed through NAIT’s Boreal Research Institute peatland restoration research trials.
2. Complete pad removal and peat inversion: The peat inversion approach has been successfully
demonstrated, and vegetation establishment has been successful on mined peatlands, which have
far more problems with hydrological and structural impacts than oil sands SAGD operations due to
being previously drained. So in addition to the customary approach which excavates the entire
amount of fill, using the best management practices, this approach as well as the inversion approach
represent other viable options for the reclamation of deep peat sites. These are simply different
designs, where the species assemblage on the adjacent reference communities can be successfully
established, and that the previous function and capabilities are restored or improved as a result.
3. Partial Pad removal and peat inversion: A variation of the complete pad removal and peat inversion
involves the removal of the upper portion of the clay pad leaving the lower 20-30 cm on site. The
Page 11-65
remaining pad material, geotextile and underlying peat in inverted. Initial trials of this process
indicated difficulties in avoidance of mixing clay with the peat material during removal of the geotextile
material. This option, however, is the most viable option of the three alternate approaches to the
reclamation of a well pad within a deep peat environment.
Research is ongoing to determine a cost-effective reclamation method to achieve the restoration of

peatlands. That said, BlackPearl will continue to investigate alternative methods to achieve the restoration
of wetlands and participate in the Wetland Reclamation Trial Program, as required. The efficacy and cost
effectiveness of complete or partial removal of fill from well pads located in deep peat has not be proven
thus far, but should advances be made prior to reclamation, BlackPearl will adapt our reclamation
methodologies to meet the reclamation requirements of the day.
11.4.3.3 Reclamation of Transitional Sites

Developments with portions of the sites within upland and wetland environments will be reclaimed
through the following methods.
• Removal of salvageable surface gravel for re-use on existing or new Project development, where
feasible.
• De-compaction of the well pad/access road through disking, ripping or both prior to commencement
of re-contouring activities.
• Re-contouring the site to allow for open surface drainage connected to the surrounding drainage
systems. In the event that pad material will be required, recycling of the material will be considered for
ongoing construction activities, where feasible.
• Stockpiled peat/mineral material will be replaced within the transitional area with undulations
consistent with the surrounding landscape.
• Replacement of stockpiled subsoil and topsoil over the upland area of the development.
Reclamation of a well pad with both upland and wetland environments is illustrated in Figure 11.4-2.
Access roads situated within shallow wetland areas will involve the removal of gravel and culverts as well
as the removal of the padded fill material Figure 11.4-7. The area will be ripped, as required, to alleviate
compaction prior to the placement of topsoil or peat. The removal of fill material and culverts will allow for
the natural flow of surface and subsurface water.
11.4.4 Soil Replacement Plan

BlackPearl’s intent is to rebuild soils that have an equivalent land capability in comparison to the pre-
development conditions. Generally the process of surface soil replacement for Project developments will
be as follows.
• Upon completion of construction activities, stockpiled subsoil will be replaced over disturbed upland
sites to a depth of 30 cm. To minimize soil loss or degradation, replacement will not occur during
periods of excessively wet ground conditions or high winds.
• Preference will be to replace stockpiled subsoil at the location from which it was salvaged.
• For Project developments constructed on mineral soils, soil replacement will consist of the
replacement of the mineral surface soil (LFH/Om plus A horizons from the stockpile to a comparable
depth with pre-development conditions.
• Terrain will be recontoured to blend with the surrounding topography and natural surface drainage
patterns restored.
Page 11-66
The desired result of properly managed soil replacement is to provide suitable moisture and nutrient
supply to establish a soil profile which enables the establishment of an initial vegetation cover, initiation of
natural soil processes, the subsequent natural recovery of the plant community and ultimately and
equivalent forested land capability.
11.4.5 Revegetation Plan

Site-specific end land use and ecosite phase targets will be developed considering the following current
legislation and guidelines, or equivalents at time of reclamation.
• Public Lands Act.
• Weed Control Act.
• Native Plant Revegetation Guidelines (Native Plant Working Group [NPWG] 2000).
• Guideline for Wetland Establishment on Reclaimed Oil Sands Leases (2nd edition: AENV 2008).
• Guideline to Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (AENV 2010c).
• Reforestation Standard of Alberta (ASRD 2011).
BlackPearl has initiated development of an Integrated Land Management Plan (ILMP) with the primary
timber harvest company (Millar Western) and Forest Management Agreement (FMA) holder (Al-Pac).The
FMA holder’s FMA Area Forest Management Plan (Al-Pac 2007) will inform the ILMP for cooperative
reforestation and reclamation efforts. Any updates to applicable legislation, guidelines and the FMA Area
Forest Management Plan will be incorporated into the post-reclamation goals and re-vegetation plan
initiated at reclamation.
The objective of the re-vegetation plan is to develop site conditions that will support a variety of
vegetation communities on the Project Area that are comparable with adjacent vegetation communities of
similar ecosite phase. These reclaimed vegetation communities will be self-sustaining ecosystems that
provide:
• watershed protection;
• wildlife habitat;
• traditional land uses; and
• commercial forestry land uses.
End land uses will also be determined, were appropriate, in co-operation with relevant stakeholders such
as:
• FMA Holders;
• Traditional land users;
• Recreational and commercial users; and
• AESRD.
11.4.5.1 Revegetation Practices

Site-specific re-vegetation plans will be developed considering the results of PDAs, the VMP, adjacent
vegetation communities, current regulations and guidelines and advancements in reclamation practices.
The length of time salvaged soil is stockpiled will have an impact on the success of natural regeneration
of vegetation. Soils that have been in stockpile for greater than 12 months will have reductions in viable
Page 11-67
seed or propagules (root material) remaining (AENV 2010c). Salvage and direct placement of soils onto
reclamation sites typically requires less re-vegetation effort to establish vegetation communities.
Opportunities for direct placement of soils will be limited to ditches along access corridors and pipelines.
The re-vegetation practices to be utilized within the reclamation program are discussed in terms of level
of disturbance.
Low Level Disturbance Sites (Above Ground Pipelines and Power Lines)
Natural regeneration of vegetation is expected throughout operation phase resulting in early successional
vegetation communities by the reclamation phase. Additional revegetation activities to achieve end land
use and ecosite phase targets will be implemented to complement natural regeneration of vegetation if
deemed warranted based upon the results of the VMP.
Moderate Level Disturbance Sites (Borrow Pits and Buried Pipelines)

The combination of surface soil and LFH layer is termed “LFH amendment” (AENV 2010c). LFH
amendments on these sites are expected to be stockpiled for a relatively short period of time (less than
12 months). Sites that receive LFH amendments will receive modified planting prescription densities as
per the Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region (AENV
2010c), or equivalent at time of reclamation, based upon salvage, storage and placement techniques
used at the site. Borrow pits will be constructed in conjunction with the construction of the lease pads and
associated access roads requiring borrow material and is anticipated to require 12 months. Upon
completion of construction of the facilities, BlackPearl will commence with interim reclamation of these
disturbances as well as the recontouring and soils replacement within the borrow pits. Table 11.3-3
provides a breakdown of the Project facility construction and reclamation schedule.
High Level Disturbance Sites (CPF, Well Pads, Campsites and Access Roads)
Site-specific reclamation targets will be defined and revegetation activities to achieve these targets will be
implemented to complement natural colonization of vegetation. Upland areas will be planted with tree and
shrub seedlings based on site-specific planting prescriptions to achieve target end land use and ecosite
phase. Natural ingress of locally native herbaceous plants, shrubs and trees is expected to occur as site
conditions become more suitable.
11.4.5.2 Re-vegetation Species

BlackPearl will use an adaptive management approach in the determination of the suitable planting rates
for understory shrub species. The planting rates will be determined during the development of the site-
specific reclamation plan. BlackPearl will take into consideration results of PDA’s, monitoring data,
adjacent vegetation communities, academic or industry peer research towards the development of re-
vegetation prescriptions. The conceptual closure phase ecosite phases for the Project are illustrated in
Figure 11.4-12. The target ecosite phases for the Project Area will be updated at the time of reclamation
based on the results of site-specific Pre-disturbance Assessments (PDAs), monitoring and adjacent
Ecosite Phases at the time of reclamation.
Trees and shrubs will be sourced from local seed stock whenever possible and BlackPearl will follow the
guidance of the following documents, or current equivalent at time of reclamation, for sourcing of plant
material.
• Standards for Tree Improvement in Alberta (ASRD 2005).
• Native Plant Revegetation Guidelines for Alberta (NPWG, 2000).
Page 11-68
RGE. 18 W4M RGE. 17 W4M
¯
28 27 25 30 29 27
Athabasca River
21 22 23 24 19 20 21 22
TWP. 77
16 15 14 13 18 17 16 15
9 10 11 12 7 8 9 10
4 3 2 1 6 5 4 3
LC
33 34 35 36 31 32 33 34
Ecological Land Classification
b3 - blueberry Aw-Sw
c1 - Labrador
tea-mesic Pj-Sb
d1 - low-bush
cranberry Aw
d2 - low-bush
cranberry Aw-Sw
28 27 26 25 30 29 28 d3 - low-bush 27
cranberry Sw
e1 - dogwood Pb-Aw
e2 - dogwood Pb-Sw
e3 - dogwood Sw
f1 - horsetail Pb-Aw
f2 - horsetail Pb-Sw
TWP. 76 f3 - horsetail Sw
g1 - Labrador
21 22 23 24 19 20 21 tea-subhygric Sb-Pj 22
h1 - Labrador
tea/horsetail Sw-Sb
i1 - treed bog
i2 - shrubby bog
j1 - treed poor fen
j2 - shrubby poor fen
k1 - treed rich fen
k2 - shrubby rich fen
16 15 14 13 18 17 16 15
k3 - graminoid rich fen
l1 - marsh
Meadow (upland with
<6% tree cover and
<25% shrub cover)
Shrubby Wetland
FIGURE 11.4-12
Vegetation Local
Watercourse
Study Area (450 m) CONCEPTUAL CLOSURE SCENARIO ELC FOR THE LSA
Waterbody
t6790_VEG_Fig_11_4_12_Conceptual_Closure ELC
Existing Blackrod Road Anthropogenic Disturbance

UTM Zone 12N: SCALE: 1: 60,000
Ecological Land Classification: TERA Environmental Consultants 2013c;
km
Hydrography: AltaLIS 2011c.; Road: IHS Inc. 2011c.
0 0.5 1 1.5
11.4.5.3 Seeding
BlackPearl will design native seed mixes appropriate for various site-types and purposes in consultation
with ASRD prior to the commencement of reclamation activities. There will likely be a suite of seed mixes
developed dependent upon site-specific condition. Weed free certified seed will be utilized and will only
be utilized in disturbed areas where:
• a high potential for erosion is likely to occur on soil stockpiles;
• the potential of invasive species infestation is present;
• a cover crop is required to minimize invasive species and reduce the erosion of soils in
areas where natural regeneration is anticipated to proceed slowly; and
• monitoring of revegetation progress indicates that additional revegetation measures are

required.
Seed mixtures will be designed based on the expected moisture regimes and the end land-use objective.
In order to prevent stockpile erosion and to control potential sediment movement, the following methods
will be employed.
• The surface of the stockpiles will be left rough to encourage infiltration and reduce surface runoff
velocity (free-dumping or rough texturing are suitable methods for ensuring a rough surface).
• Soil stockpiles will be seeded with a perennial native grass mix (broadcast 20-25 kg/ha) as soon as
practicable in order to minimize erosion and weed infestation.
• Hydromulch with tackifiers may be used if erosion is noted.
• Stockpiling operations will be discontinued during windy conditions.
• Silt fencing will be used where required.
• Stockpiles will be labelled as topsoil or subsoil.
11.4.5.4 Trees and Shrubs in Upland Areas

Tree and shrub species to be utilized for the re-vegetation of moderate to high disturbance sites within
upland and transitional areas are summarized in Table 11.4-9. The planting prescriptions to achieve the
end land use and ecosite phase targets include tree species minimum planting densities. The species
composition may be adjusted on a site-specific basis to be more compatible with the adjacent ecosite
phases.
TABLE 11.4-9
PLANTING PRESCRIPTIONS
Non-Commercial Forest End

Commercial Forest End Land Use1 Land Use3 Tree Species and Shrub Species5 (Minimum
Tree Species and Minimum Planting Minimum Planting Densities2 Density of 500 to 700
Site Type Ecosite Phase Densities2 (stems/ha) (stems/ha) stems/ha)6
Moist Poor c1 – Labrador tea- Jack pine (1,000) Jack pine (700) common Labrador tea;
mesic Pj-Sb black spruce (400) black spruce (300) common blueberry;
bog cranberry7;
twinflower7
Page 11-70

Non-Commercial Forest End
Commercial Forest End Land Use1 Land Use3 Tree Species and Shrub Species5 (Minimum
Tree Species and Minimum Planting Minimum Planting Densities2 Density of 500 to 700
Site Type Ecosite Phase Densities2 (stems/ha) (stems/ha) stems/ha)6
Moist Rich d1 – low-bush Allow for natural re-vegetation through Allow for natural re-vegetation northern gooseberry;
cranberry Aw suckering of aspen4 through suckering of aspen4 prickly rose;
d2 – low-bush white spruce (1,000) white spruce (350) low-bush cranberry;
cranberry Aw-Sw Allow for natural re-vegetation through balsam fir (100) twinflower7
suckering of aspen4 Allow for natural re-vegetation
through suckering of aspen4
d3 – low-bush white spruce (1,400) white spruce (400)
cranberry Sw Allow for natural re-vegetation through balsam fir (100)
suckering of aspen4 Allow for natural re-vegetation
through suckering of aspen4
e1 – dogwood Pb-Aw Allow for natural re-vegetation through Allow for natural re-vegetation wild red currant;
suckering of aspen and white birch4 through suckering of aspen and wild red raspberry;
white birch4 northern gooseberry;
e2 – dogwood Pb-Sw white spruce (1,000) white spruce (350) river alder;
Allow for natural revegetation through balsam fir (100) green alder;
suckering of aspen and white birch4 Allow for natural revegetation prickly rose;
through suckering of aspen and bracted honeysuckle;
white birch4 low-bush cranberry;
twinflower7
e3 – dogwood Sw white spruce (1,400) white spruce (400)
Allow for natural revegetation through balsam fir (100)
suckering of aspen and white birch4 Allow for natural revegetation
through suckering of aspen and
white birch4
Wet Rich f1 – horsetail Pb-Aw Allow for natural revegetation through Allow for natural revegetation wild red currant;
suckering of aspen and white birch4 through suckering of aspen and river alder;
white birch4 bracted honeysuckle;
f2 – horsetail Pb-Sw white spruce (1,000) white spruce (350) northern gooseberry;
Allow for natural revegetation through balsam fir (100) wild red raspberry;
suckering of aspen and white birch4 Allow for natural revegetation common wild rose;
through suckering of aspen and bog cranberry7;
white birch4 twinflower7
f3 – horsetail Sw white spruce (1,400) white spruce (400)
Allow for natural revegetation through balsam fir (100)
suckering of aspen and white birch4 Allow for natural revegetation
through suckering of aspen and
white birch4
g1 – Labrador tea - black spruce (1,400) black spruce (700) common Labrador tea;
subhygric Sb-Pj bog cranberry7
h1 – Labrador white spruce (600) white spruce (250) common Labrador tea:
tea/horsetail Sw-Sb black spruce (800) black spruce (350) river alder;
northern black currant;
bog cranberry7;
twinflower7
Notes: 1. Crown closure classes D and C.
2. Tree planting densities are to be determined using site type and end land-use as per Tables 4-5 to 4-14 in the
Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region, 2nd Edition (AENV 2010c), or
current equivalent at time of reclamation. See Note 4 for exceptions.
3. Crown closure classes A and B.
4. As per the FMA Area Forest Management Plan (Al-Pac 2007), or current equivalent at time of reclamation. If
deciduous stem density is less than the targets set out in the Guidelines for Reclamation to Forest Vegetation in the
Athabasca Oil Sands Region, 2nd Edition (AENV 2010c) at year 8 of monitoring, planting may be warranted.
5. The shrub species listed in this table are the observed characteristic species (i.e., present in a minimum of 70% of
the vegetation baseline sample plots for a given ecosite or have a prominence value of 20 or greater). Additional
shrub species can be planted based on observed non-characteristic species and the Guidelines for Reclamation to
Forest Vegetation in the Athabasca Oil Sands Region, 2nd Edition (AENV 2010c), or current equivalent at time of
reclamation. These species may be established by a variety of means, including (but not limited to) bareroot and
container seedling planting, application of LFH amendment and potentially through direct seeding.
6. Site specific considerations will be taken into account in addition to the 500-700 stems per hectare minimum
recommended when establishing planting species and densities at time of reclamation. Understory planting
Page 11-71
prescriptions will be developed with reference to the minimum target numbers of characteristic species for the target
ecosite phase as per the Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands Region, 2nd
Edition (AENV 2010c), or current equivalent at time of reclamation.
7. Dwarf shrubs are treated as shrubs in the Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil
Sands Region, 2nd Edition (AENV 2010c) while they have been treated as part of the forb strata within the
Vegetation Baseline (Volume 4, Appendix 1A).
11.4.5.5 Wetlands and Transitional Areas

Planting or seeding prescriptions are not planned for deep organic soils, however if monitoring results
indicate that natural regeneration is ineffective, additional re-vegetation efforts will be utilized. Restoring
hydrological functioning is the most important environmental factor in controlling plant community
structure (Graf 2009). The results of the surface hydrology assessment (Volume 3, Section 3.0) indicate
that no perceptible effects on surface hydrology are expected as a result of the Project. If monitoring
results indicate that localized surface water hydrology has been impacted, remedial measures will be
implemented to correct this impact. If target vegetation does not naturally recolonize the reclaimed
wetland, plants may be introduced by a variety of means, including (but not limited to) bareroot and
container seedling planting, application of donor live peat (with viable seed bank), soil amendment and
potentially through direct seeding. Additional remedial measures for the restoration of wetlands will be
implemented if deemed warranted based on monitoring results.
11.4.5.6 Seismic Lines and Buried Pipeline Right of Ways

Linear disturbances with minimal soil disturbance will not be disturbed upon decommissioning and
removal of infrastructure. The use of rollback and planting of woody species will be considered on
reclaimed access and utility corridors to limit access by vehicles in consultation with ASRD and relevant
stakeholders. Replanting of seismic lines and buried pipeline rights of way will be determined in
consultation with Millar Western and Al-Pac as part of an Integrated Land Management Plan (ILMP)
between BlackPearl and the commercial forestry stakeholders. Replanting of seismic lines will be limited
to intersections as the linear disturbances are narrow, thus it is anticipated that natural regrowth and
encroachment would occur relatively quickly. The replanting of the seismic line and buried pipeline right-
of-ways would also assist with limiting line of site issues for wildlife. Discussions on the reclamation of
linear disturbances and vegetation establishment are provided in Volume 4, Section 2.6.
11.4.5.7 Conceptual Closure Phase Ecosite Phases

A comparison between the Baseline Case and predicted Application Case closure phase ecological land
classifications (ELCs) within the vegetation LSA is provided in Table 11.4-10. The closure phase ELC
distribution is illustrated in Figure 11.4-12. Refer to the vegetation assessment report (Volume 4,
Section 1.4) for the methods and assumptions used to predict closure phase ELC. Descriptions of ELC
are provided in the vegetation baseline report (Volume 4, Appendix 1A).
TABLE 11.4-10
CHANGE FROM BASELINE TO APPLICATION CASE AT CLOSURE PHASE ELC IN THE LSA
Baseline Case Application Case Closure Phase

Total Area in LSA Total Area in LSA
ELC (ha)1 % Cover in LSA2 (ha)1 % Cover in LSA2 %Change3
b3 - blueberry Aw-Sw 4.2 0.1 4.2 0.1 0.0
c1 - Labrador tea- 3.9 0.1 0.1 2.6
mesic Pj-Sb 4
d1 - low-bush cranberry 527.8 8.6 9.5 10.5
Aw 583.3
Aw-Sw 606.6
Sw 437.0
e1 - dogwood Pb-Aw 183.2 3.0 185.0 3.0 1.0
e2 - dogwood Pb-Sw 265.2 4.3 762.2 12.4 187.4
e3 - dogwood Sw 224.9 3.7 305.7 5.0 35.9
Page 11-72
TABLE 11.4-10 Cont'd

Baseline Case Application Case Closure Phase
Total Area in LSA Total Area in LSA
ELC (ha)1 % Cover in LSA2 (ha)1 % Cover in LSA2 %Change3
b3 - blueberry Aw-Sw 4.2 0.1 4.2 0.1 0.0
f1 - horsetail Pb-Aw 27.5 0.4 74.9 1.2 172.4
f2 - horsetail Pb-Sw 38.7 0.6 168.3 2.7 334.9
f3 - horsetail Sw 117.1 1.9 285.2 4.6 143.6
g1 - Labrador tea- 365.0 5.9 6.8 13.8
subhygric Sb-Pj 415.4
h1 - Labrador 391.0 6.4 9.0 41.7
tea/horsetail Sw-Sb 554.0
i1 - treed bog 345.9 5.6 303.6 4.9 -12.2
i2 - shrubby bog 66.2 1.1 188.0 3.1 184.0
j1 - treed poor fen 465.9 7.6 410.4 6.7 -11.9
j2 - shrubby poor fen 19.8 0.3 77.8 1.3 292.9
k1 - treed rich fen 206.6 3.4 186.6 3.0 -9.7
k2 - shrubby rich fen 16.6 0.3 33.3 0.5 100.6
k3 - graminoid rich fen 39.3 0.6 41.9 0.7 6.6
l1 – marsh 12.1 0.2 17.0 0.3 40.5
Shrubby Wetland* 236.0 3.8 248.5 4.0 5.3
Meadow* 2.0 0.0 2.2 <0.1 10.0
Regenerating Burn* 123.4 2.0 0.0 0.0 -100.0
Regenerating 1,086.9 17.7 0.0 0.0 -100.0
Cutblock*
Cutblock* 634.7 10.3 0.0 0.0 -100.0
Anthropogenic* 445.6 7.3 241.4 3.9 -45.8
Total1 6,136.2 100.0 6,136.4 100.0 ---
Notes: 1. Sum of total area may not add up to 6,136.4 ha due to rounding error.
2. Percent cover may not add up to 100% due to rounding error.
3. Percent change is proportional to the vegetation community.
* Additional classifications were created where the Field Guide to Ecosites of Northern Alberta (Beckingham and Archibald 1996) did not outline
an equivalent vegetation community.
11.4.5.8 Reclamation Completion Timeline

Progressive reclamation is expected to be ongoing throughout the operational life span of the Project
from 2015 to 2050.
BlackPearl will assess partial reclamation, re-vegetation, erosion control, surface drainage and any weed
problem areas on the Project Area following construction as well as during regularly scheduled operations
and maintenance activities over the lifetime of the Project. Following abandonment and reclamation,
BlackPearl will assess reclamation, re-vegetation, erosion control, surface drainage and any weed
problem areas on the Project Area. At locations with a target end land use of commercial forestry, the
monitoring practices of the FMA holder will be implemented. These monitoring practices include
assessing the survival of tree species at year 5 or 6 and year 13 or 14 post-reclamation (Al-Pac 2007), as
well as additional measures of reforestation success as detailed in the Reforestation Standard of Alberta
(ASRD 2011). For locations where the target end land use is wetland, BlackPearl will monitor water
quality and vegetation within the reclaimed wetlands post-reclamation until it can be determined that
successional trajectories towards no-maintenance self-sustaining wetland vegetation communities have
been established. For each class of wetland present within the vegetation LSA, BlackPearl will select
benchmark wetlands that were not directly affected by the Project to compare monitoring results to. The
goal is for reclaimed wetlands to naturally revegetate to a wetland vegetation community comparable to
benchmark wetlands of the same class. Refer to Volume 4, Section 1.0 and Volume 1, Section 11.5 for a
discussion on monitoring measures for re-vegetation.
Page 11-73
Additional mitigation measures will be applied as warranted based upon the recorded findings of
reclamation specialists, BlackPearl operations and maintenance staff and qualified timber management
field surveyors during post-reclamation monitoring.
Delays in the reclamation activities may occur due to environmental constraints such as extreme dry
weather and extended wet periods resulting from precipitation events.
The timelines for vegetation establishment is difficult to predict, however, BlackPearl anticipates the
approximate time-frame for regeneration of reclaimed areas to a young forest structural stage, where a
natural successional trajectory is established, to be 30 years. Project facilities such as well pads and
access roads are expected to be ready for the initiation of application for reclamation certificates before
achieving a mature forest structural stage, and BlackPearl will monitor vegetation establishment,
composition, abundance and structure within the reclaimed sites post-reclamation until it can be
determined that successional trajectories have been established. BlackPearl anticipates these
developments to be ready for reclamation certification 15-30 years post-reclamation once the monitoring
results indicate that the area is on a successional trajectory to meet the end land-use and ecosite phase
targets.
11.4.6 Waste Management and Contingency Plans

The generation of wastes and potential for accidental releases will exist throughout the lifespan of the
Project. BlackPearl will minimize waste generation whenever possible. Over the life of the Project, waste
management may be reviewed to scope changes to comply with the relevant government regulations and
best management practices of industry. Waste Management Plan will be developed for the handling,
storage and disposal of wastes will adhere to BlackPearl’s Environmental Management Plans described
in Volume 1, Section 9.5.
11.4.6.1 Oilfield Waste, Drilling Waste and Solid Disposal

Drilling waste disposal will be managed in adherence to AER Directive 050: Drilling Waste Management
(ERCB 2012). BlackPearl will utilize several different options for the disposal of drilling wastes for the
Project, including both offsite and onsite disposal techniques; offsite disposal options may be preferred in
the event that soil conditions are determined to be unfavorable for onsite options.
Onsite options for the disposal of drilling wastes include mix-bury-cover (MBC), whereby the drilling
wastes are stabilized using subsoils below the rooting zone and above the water table. The drilling waste
is mixed with the clay subsoil at ratios determined upon analysis of the waste. A second onsite disposal
option is above ground landspreading, where wastes are dried and incorporated into the surface pad of
the wellsite.
Offsite disposal options include pump off of clear fluids, which is the application of clear fluids to the
ground surface at pre-determined application rates, and disposal at a licensed disposal facility.
All remote sumps and above ground storage areas will adhere to the requirements outlined within the
AER Directive 070 Drilling Waste Disposal Inspection Manual (ERCB 2002) and AERt Directive 050:
Drilling Waste Management (ERCB 2012) including signage and perimeter security to minimize
unauthorized entry and wildlife interaction with disposal operations. Above ground storage pits will be
utilized for the management of drilling solids only.
A description of the oilfield wastes anticipated and the corresponding disposal methods are provided in
Volume 1, Section 9.5. BlackPearl proposes to dispose of wastewater into deep saline aquifers. A
detailed discussion of wastewater disposal is provided in Volume 1, Sections 6.3.4, 6.3.5 and 7.7. Oilfield
wastes will be handled in accordance with the requirements outlined within AER Directive 058: Oilfield
Waste Management Requirements for the Upstream Petroleum Industry (EUB 2006), as updated.
Spill prevention, response and mitigation measures are provided in BlackPearl’s Waste Management
Plan and Emergency response Plan. Measures provided in these contingency plans are designed to
alleviate any potential effects on:
Page 11-74
• wildlife health and mortality risks associated with exposure to contaminants;
• water quality in waterbodies and wetlands;
• shallow groundwater quality;
• surface soils and vegetation; and
• human health.
11.4.6.2 Non-Oilfield Waste Disposal

Wastes not suitable for disposal in BlackPearl’s disposal wells or class II landfill will be removed off site to
an appropriate disposal facility. Details for non-oilfield waste disposal are provided in Volume 1,
Section 9.5. Additionally BlackPearl will develop the Waste Management Plan to minimize the attraction
of bears and other predatory wildlife within the Project Area through implementation of the measures
outlined within the Bear-Human Conflict Management Plan for Camps (Government of Alberta 2011a)
and the Alberta BearSmart Program Manual (Government of Alberta 2011b).
11.4.7 Conceptual Conservation and Reclamation Plan Uncertainties

The uncertainties related to the proposed C&R plan for the Project are provided within Table 11.4-11.
TABLE 11.4-11
CONSERVATION AND RECLAMATION PLAN UNCERTAINTIES
Subject Uncertainties Description

Soil Salvage Available topsoil for salvage The topsoil thicknesses are based on data collected during the
SIL2 soil survey. Soil salvage thickness will be refined upon
completion of a PDA (very detailed soil survey).
Borrow Pit Construction Volume of overburden The volume of overburden cannot be accurately determined prior
to a geotechnical assessment for each proposed borrow area. It is
assumed that lower subsoil material (overburden) will be present
at all borrow areas and shall be separated and stockpiled within
the borrow area for use during recontouring of the pit upon
decommissioning and reclamation.
Dewatering Dewatering of the borrow pits will be required during the
construction phase. The volume of water that will be required to
be removed from the active borrow pits cannot be determined and
will vary based on regional weather conditions and season of
construction.
Soil Material Balance Available topsoil and subsoil for reclamation The soil material balances provided for subsoil and topsoil are
based on average depths derived from the baseline soils
assessment (SIL1).
Soil Stockpiling Stockpile storage The long term storage of peat and topsoil material will have an
impact on the availability of live propagules within the stockpiled
reclamation material. The results of research studies are expected
to become available during the life of the Project.
Progressive Timelines for progressive reclamation BlackPearl will progressively reclaim disturbances that are no
Reclamation longer in use during the lifespan of the Project. The timelines for
the reclamation of wellpads can only be considered a conceptual
based on current engineering and operational practices.
Improvements to operational procedures resulting in increases in
the operational lifespan of producing wellpads will result in
alterations of the proposed reclamation timelines.
Erosion and Sediment Success of current control methodologies An adaptive management process will be utilized for responding to
Control erosion and sedimentation issues. The measures proposed within
the C&R may require adaptation or use of a combination of control
methods depending on several factors such as: damage (human,
wildlife, weather conditions and severe weather events).
Page 11-75

Subject Uncertainties Description
Weed Management Control of weeds introduced by other land users BlackPearl will introduce a weed management program for all of
its disturbances, however, an uncertainty exists on the
management of weeds encroached from adjacent disturbances
such as cut blocks. BlackPearl cannot control weed infestations in
these areas.
Water Management Dust control volumes Weather variability will affect the volume of water required for dust
control on BlackPearl facilities.
Availability of source water within existing surface Weather extremes cannot be predicted, therefore the amount of
disturbances water available within existing and future borrow pits cannot be
accurately determined.
Alternate reclamation strategy successes Research on reclamation in Boreal peatland is underway for
alternate reclamation methods. The results of these research
projects are expected to become available during the life of the
Project. The long term effectiveness of the alternate
methodologies such as clay pad removal and peat inversion have
not been determined to date. Current reclamation criteria allows
for the utilization of BlackPearl’s preferred method of reclamation
of deep peat sites, however, future changes to reclamation
requirements cannot be predicted.
Reclamation: Shallow
and Deep Organic Sites Viability of long term stockpiled peat material for There is uncertainty regarding the effects of long term storage of
reclamation peat material and the availability of live propagules within the
stockpiled material. It is assumed that a small percentage of live
propagules will be present within the material upon utilization for
reclamation. BlackPearl will monitor the results of industry
research on the long term stockpiling of peat material and
incorporate the results for reclamation once available. Peat
material salvaged from Phase 3 deep peat padsites will be utilized
for the reclamation programs of Phase 1 deep peat sites; this
would likely solve the issue of live propagule availability.
Reclamation: Borrow A site specific reclamation plan for each identified borrow area
Facilities cannot be developed until an PDA and geotechnical assessment
is performed. Therefore the percentage of the reclaimed borrow
areas returned to open water and wetland can only be estimated.
Reclamation: Road Reclamation timeline The reclamation scheduling for the access roads will be based
Facilities upon the operational lifespans of the producing wellpads. The long
term storage of topsoil along the ROW.
11.5 Conservation and Reclamation Monitoring

Monitoring for impacts that could affect the land capability of a disturbed area will be conducted at all
stages of the Project. The objectives of the monitoring programs are to evaluate the success of the
Conservation and Reclamation activities and implement any modifications that are required using an
adaptive management approach to achieve the reclamation objectives and a certificate of reclamation.
The achievement of the reclamation objectives will be obtained through site inspections conducted by an
Environmental Monitor(s) of the Project Area, additional reclamation measures where required, and
evaluation of the results of monitoring programs on reclaimed areas. The Environmental Monitor(s) will
ensure that mitigation measures are implemented during all phases of the Project. When a deficiency or
concern is identified by the Environmental Monitor, or BlackPearl operations personnel, the
Environmental Monitor will be responsible for co-ordinating the mitigation measures with BlackPearl’s
project managers. BlackPearl will track the deficiencies observed by the Environmental Monitor(s) as well
as the effectiveness of the mitigation measures. The results of the monitoring activities, the effectiveness
of the mitigation measures as well as any adaptive measures implemented will be included in the annual
C&R report provided to regulators.
11.5.1 Wildlife Monitoring

Conservation and Reclamation monitoring programs shall include wildlife mitigation and monitoring. The
monitoring program for wildlife will include both disturbed and un-disturbed areas of the LSA and will
provide data on the progress of re-establishment of wildlife habitat. The data obtained through the
Page 11-76
monitoring program will provide BlackPearl with measurement whereby an assessment of the success of
the mitigation measures can be based.
It is anticipated that wildlife use will increase once the herbaceous vegetation has established and
advances through successional stages. BlackPearl will develop a wildlife monitoring program in
collaboration with AESRD, regional working groups and stakeholders. Monitoring the use of reclaimed
areas by wildlife species is discussed in Volume 4, Section 2.0.
11.5.2 Construction and Operations Monitoring

Environmental monitoring activities to be conducted during the Project construction and operation stages
include:
• Environmental Monitors on-site to monitor the construction of Project facilities to ensure

that the environmental protection measures provided in the C&R as well as the EIA are
followed;
• post-construction monitoring of waterbodies and crossings and implementation of

preventative and remedial measures to mitigate any potential sedimentation or
blockage issues;
• monitoring areas where weed control measures are applied to assess the effectiveness
and modify the program as required;
• monitoring programs for soil, vegetation, water and wildlife protection; and
• mitigation of deficiencies identified during the monitoring programs in a timely manner to

achieve environmental objectives.
11.5.3 Post-Reclamation Monitoring and Reporting

Environmental monitoring will be performed during and after reclamation programs to mitigate any issues
and to monitor the reclamation success. Post-reclamation monitoring scheduling will be determined
based on the identified issues, reclamation work required to correct deficiencies and the progress of
vegetation re-establishment. The objectives of reclamation monitoring include the assessment of the
following parameters.
• Soil and Terrain to determine if the reclamation criteria are met and that equivalent land capability is
achieved.
• Landscape (Drainage, erosion, soil stability and debris).
• Quality and quantity of replaced soil.
• Vegetation to determine if additional measures are required to re-establish vegetation communities.

Determine if the re-established vegetation is in compliance with the most current reclamation criteria.
All reclamation activities will be in compliance with the terms and conditions of the EPEA approval, and all
ongoing surface land disturbance and reclamation activities shall be documented and provided within the
Annual C&R Report. The Annual C&R Report will summarize the following activities from the previous
year:
• completed Project development activities;
• completed reclamation activities;
• construction, Operation and Reclamation monitoring summaries;
• wildlife Mitigation monitoring programs;
Page 11-77
• planned activities for the upcoming year; and
• PDAs for Project developments to be constructed during the following year.
11.5.4 Terrain and Drainage

Visual inspections will be performed to ensure that drainage is consistent with pre-disturbance conditions.
BlackPearl’s Environmental Monitor would be performed to confirm if there are any hydrological effects
associated with the Project are within their anticipated ranges. Indicators identified include runoff volumes
and stream flows, water levels and surface areas and channel morphology and sediment concentrations.
Additionally, the environmental monitor will be assessing the following:
• visual indicators of erosion or slumping;
• the reclaimed contours of the Project development blend with the surrounding
landscape;
• presence of gravel and rocks are not in excess of reclamation criteria; and
• excess woody debris is within criteria and not negatively impacting drainage.
11.5.5 Soils
Post reclamation monitoring will be conducted to measure and track the reclamation success and will be
performed in conjunction to the vegetation assessment scheduling described in Section 11.5 and
Volume 4, Section 1.0.
Soil monitoring will involve the collection of composite subsoil and topsoil samples and the assessment of
the following parameters:
• soil replacement depths are consistent with the current reclamation criteria;
• presence of compaction or restrictive layers; and
• physical and chemical properties in addition to parameters outlined in the reclamation

criteria for wellsites within the Green Zone, including:
− soil texture;
− soil structure;
− pH, salinity and cation exchange capacity;
− macronutrient levels, soluble ions and organic carbon; and
− saturation percentage.
This monitoring data will be compared to baseline and adjacent areas upon which the monitoring data will
be used for evaluation of the reclamation techniques utilized to achieve target end land use objectives.
Mitigative measures will be undertaken if the results of the soil assessments deem necessary.
11.5.6 Vegetation
At the decommissioning and reclamation phases, site-specific reclamation targets will be defined and
revegetation activities to achieve these targets will be implemented to complement natural colonization of
vegetation. During the closure phase, BlackPearl will monitor vegetation establishment, composition,
abundance and structure within the reclaimed sites post-reclamation until it can be determined that
successional trajectories have been established.
Page 11-78
At locations with a target end land use of commercial forestry, the monitoring practices of the FMA holder
will be implemented. These monitoring practices include assessing the survival of tree species at year 5
or 6 and year 13 or 14 post-reclamation (Al-Pac 2007), as well as additional measures of reforestation
success as detailed in the Reforestation Standard of Alberta (ASRD 2011).
For locations where the target end land use is wetland, BlackPearl will monitor water quality and
vegetation within the reclaimed wetlands post-reclamation until it can be determined that successional
trajectories towards no-maintenance self-sustaining wetland vegetation communities have been
established. For each class of wetland present within the LSA, BlackPearl will select benchmark wetlands
that were not directly affected by the Project to compare monitoring results to. The goal is for reclaimed
wetlands to naturally revegetate to a wetland vegetation community comparable to benchmark wetlands
of the same class. Restoring hydrological functioning is the most important environmental factor in
controlling plant community structure (Graf 2009). The results of the surface hydrology assessment
(Volume 3, Section 3.0) indicate that no perceptible effects on surface hydrology are expected as a result
of the Project. If the results of the vegetation monitoring results indicate that localized surface water
hydrology has been impacted, remedial measures will be implemented to correct this impact. If target
vegetation does not naturally recolonize the reclaimed wetland, plants may be introduced by a variety of
means, including (but not limited to) bareroot and container seedling planting, application of donor live
peat (with viable seed bank), soil amendment and potentially through direct seeding. Additional remedial
measures for the restoration of wetlands will be implemented if deemed warranted based on monitoring
results.
BlackPearl will prepare and submit to AESRD an Annual C&R Report summarizing the previous year’s
activities, including completed reclamation activities, reclamation and results of monitoring, as well as
planned adaptive remedial measures.
11.6 Reclamation Certificate

Final reclamation assessments will be conducted to evaluate the parameters required by the 2010
Reclamation Criteria for Well sites and Associated Facilities for Forested Lands (ESRD 2013a) and its
updates. Soil, landscape, vegetation and any other required parameters will be assessed and
documented. Once reclaimed Project developments meet the current reclamation criteria and have met
the target end land use and ecosite phase, the assessment reports will be submitted with the relevant
applications for reclamation certificates.
Page 11-79
11.7 References
Alberta Environment. 1995. Environmental Protection Guidelines for Electric Transmission Lines (C&R/IL
95-1). Alberta Environment, Edmonton, AB. 5pp.
Alberta Environment. 1996. Guideline for Monitoring and Management of Soil Contamination under EPEA
Approvals. Chemicals Assessment and Management Division, Alberta Environment.
Edmonton, AB. 7pp.
Alberta Environment. 2000. Environmental Protection Guidelines for Roadways. (C&R/IL/00-5). Alberta
Environment. Edmonton, AB. 5pp.
Alberta Environment. 2001. Phase I Environmental Site Assessments Guideline for Upstream Oil and
Gas Sites (Report #ESD/LM/01-1, Publication No: T/573).Alberta Environment, Edmonton, AB.
16pp.
Alberta Environment. 2002. Environmental Protection Guidelines for Oil Production Sites: revised
January 2002 (C&R/IL/02-1). Alberta Environment. Edmonton, AB. 5pp.
Alberta Environment. 2003. Sites Reclaimed Using Natural Recovery Methods: Guidance on Site
Assessment (R&R/03-6). Edmonton, AB. Submitted September 2003. 8pp.
Alberta Environment. 2004. A Guide to the Code of Practice for Pits (Publication No: T/763). Alberta
Environment. Edmonton, AB. 84pp.
Alberta Environment. 2005. Code of Practice for Exploration Operations (made under the Environmental
Protection and Enhancement Act, RSA 2000, c.E-12, as amended and Conservation and
Reclamation Regulation (AR 115/93), as amended). Alberta Environment. Edmonton, AB. 20pp.
Alberta Environment. 2008. Guideline for wetland establishment on reclaimed oil sands leases (2nd
edition). Prepared by Harris, M.L. of Lorax Environmental for the Wetlands and Aquatics
Subgroup of the Reclamation Working Group of the Cumulative Environmental Management
Association, Fort McMurray, AB. December 2007.
Alberta Environment. 2010a. Alberta Tier 1 Soil and Groundwater Remediation Guidelines. Alberta
Environment. Edmonton, AB. 62 pp + appendices.
Alberta Environment. 2010b. Alberta Tier 2 Soil and Groundwater Remediation Guidelines. Alberta
Environment., Edmonton, AB. 77pp + appendices.
Alberta Environment. 2010c. Guidelines for Reclamation to Forest Vegetation in the Athabasca Oil Sands
nd
Region, 2 Edition. Prepared by the Terrestrial Subgroup of the Reclamation Working Group of
the Cumulative Environmental Management Association, Fort McMurray, AB. X + 332 pp.
Alberta Environment. 2010d. A Guide to Remediation Certificates for Upstream Oil and Gas Sites. Alberta
Environment. Edmonton, AB. Ii + 25 pp.
Alberta Environment. 2011a. Environmental Protection Guidelines for Transmission Lines (R&R/11-03).
Alberta Environment. Edmonton, AB. 5 pp.
Alberta Environment. 2011b. 2010 Reclamation Criteria for Wellsites and Associated Facilities Application
Guidelines. Alberta Environment. Edmonton, AB. 52pp.
Alberta Environment. 2013a. Code of Practice for Watercourse Crossings (made under the Water Act and
Water Ministerial Regulation). Alberta Environment. Edmonton, AB. 38pp.
Alberta Environment. 2013b. Code of Practice for Pipelines and Telecommunication Lines Crossing a
Waterbody (made under the Water Act and Water Ministerial Regulation). Alberta Environment.
Edmonton, AB. 31pp.
Page 11-80
Alberta Environment and Water. 2012. Final Terms of Reference for BlackPearl Resources Inc.’s
Proposed Blackrod Commercial SAGD Project. Issued by Alberta Environment and Water
February 2, 2012. Edmonton, AB. 19 pp.
Alberta Energy Resources Conservation Board. 2001. Directive 055: Storage Requirements for the
Upstream Petroleum Industry. Calgary, AB. Available online at:
http://www.aer.ca/documents/directives/directive 055.pdf.
Alberta Energy Resources Conservation Board. 2002. Directive 070: Drilling Waste Disposal Inspection
Manual. Calgary, AB. Available online at:
http://www.aer.ca/documents/directives/directive070.pdf.
Alberta Energy Resources Conservation Board. 2006. Directive 058: Oilfield Waste Management
Requirements for the Upstream Petroleum Industry. Calgary, AB. Available online at:
http//www.aer.ca/documents/directives/directive058.pdf.
Alberta Energy Resources Conservation Board. 2007. Directive 020: Well Abandonment Guide. Calgary,
AB. Available online at: http://www.aer.ca/documents/directives/directive020.pdf.
Alberta Energy Resources Conservation Board. 2008. Directive 058: Oilfield Waste Management
Approvals – Notification and Amendment Procedures (Addendum 2008-12-23). Calgary, AB.
Available online at: http://www.aer.ca/documents/directives/directive058_addendum.pdf.
Alberta Energy Resources Conservation Board. 2010. Directive 020: Well Abandonment. Calgary, AB.
Available online at: http://www.aer.ca/documents/directives/directive020.pdf.
Alberta Energy Resources Conservation Board. 2011b. Interim Requirements for Aboveground
Synthetically-Lined Storage Systems, Updates to Linear Requirements , and Optional Diking
Requirements for Single-Walled Aboveground Storage Tanks (Addendum 2011-10-11). Calgary,
AB. Available online at: http://www.aer.ca/documents/directives/directive055_addendum.pdf.
Alberta Energy Resources Conservation Board. 2012. Directive 050: Drilling Waste Management.
Calgary, AB. Available online at: http://www.aer.ca/documents/directives/directive050.pdf.
Alberta-Pacific Forest Industries. 2007. Albeta-Pacific FMA Area Forest Management Plan (Revised).
Boyle, AB. 48 pp + appendices.
Alberta Sustainable Resource Development. 2001. Weed Management in Forestry Operations (Directive
No. 2001-6). Land and Forest Division, Alberta Sustainable Resource Development, Edmonton,
AB. 5 pp.
Alberta Sustainable Resource Development. 2005. Standards for Tree Improvement in Alberta. Land and
Forest Division, Alberta Sustainable Resource Development, Edmonton, AB. vi + 116 pp.
Alberta Sustainable Resource Development. 2008. Guidelines for Acquiring Materials Dispositions on
Public Land (2008 Edition). Land Management Branch, Alberta Sustainable Resource
Development, Edmonton, AB. vi + 142 pp.
Alberta Sustainable Resource Development. 2009. Management of Wood Chips on Public Land (External
Directive, Industry Directive Number ID 2009-1). Land Management Branch, Alberta Sustainable
Resource Development, Edmonton, AB. 3 pp.
Alberta Sustainable Resource Development. 2010. Debris Management Standards for Timber Harvest
Operations. Wildfire Management Branch, Alberta Sustainable Resource Development,
Edmonton, AB. Available on-line at:
http://www.srd.alberta.ca/FormsOnlineServices/Directives/documents/2007-02-
DebrisManagementStandards-TimberHarvestOperations-Mar2010.pdf.
Alberta Sustainable Resource Development. 2011. Reforestation Standard of Alberta. Government of

Alberta, Department of Sustainable Resource Development, Edmonton, AB. 231 pp.
Page 11-81
Beckingham, J.D. and J.H Archibald. 1996. Field Guide to Ecosites of Northern Alberta (Northern Forestry
Centre Special Report 5). Natural Resources Canada, Canadian Forest Service, Northwest
Negion, Edmonton, AB.
Cummulative Environmental Management Association. 2006. Land Capability Classification System for
rd
Forest Ecosystems in the Oil Sands, 3 Edition; Volume 1: Field Manual for Land Capability
Determination. Prepared for Alberta Environment by the Cummulative Environmental
Management Association, Fort McMurray, AB. 53 pp + appendices.
Environment and Sustainable Resource Development. 2013a. 2010 Reclamation Criteria for Wellsites
and Associated Facilities for Forested Lands (Updated July 2013). Alberta Environment.
Edmonton, AB. 81 pp.
Environment and Sustainable Resource Development. 2013b. EAP Integrated Standards and Guidelines.
Government of Alberta. 2011a. Bear-Human Conflict Management Plan for Camps. Alberta Sustainable
Resource Development. Edmonton, Alberta. 4pp.
Government of Alberta. 2011b. Alberta BearSmart Program Manual. Alberta Sustainable resource
Development. Edmonton, AB. Available online at:
http://www.srd.alberta.ca/recreationpublicuse/AlbertaBearSmart/documents/AlbertaBearSmart-
ProgramManual-May2011.pdf
Graf, M.D. 2009. Literature review on the restoration of Alberta’s Boreal Wetlands Affected by Oil, Gas
and In-situ Oil Sands Development. Report prepared for Ducks Unlimited Canada. vii + 52 pp.
Lavoie, M., D. Pare, N. Fenton, D. Groot, K. Taylor. 2005. Paludification and management of forested
peatlands in Canada. Literature Review. Env. Rev. 13: 21-50.
Native Plant Working Group. 2000. Native Plant Revegetation Guidelines for Alberta. H. Sinton-Gerling
(ed.), Alberta Agriculture, Food and Rural Development and Alberta Environment. Edmonton,
Alberta. vii + 58 pp.
Price, J.S., A.L. Heathwaite, A. Baird. 2003. Hydrological processes in abandoned and restored
peatlands. Wetlands and Ecol. Mgt. 11:65-83.
Riley, J.L., 1989. Southern Ontario bogs and fens on the Canadian shield. Wetlands: Inertia or
Momentum. 355-367.
Page 11-82
BLACKPEARL ERRATA
Blackrod Commercial SAGD Project BlackPearl Errata – SIR Round 2
1. Integrated Application, Volume 1, Section 4.4.1 Pilot Monitoring, Page 4-4.
In Section 4.4.1, the references to monitoring the bottom water are erroneous. The section should refer to
monitoring of the LGR3 aquifer.
4.4.1 Pilot Monitoring

The pilot project has an extensive monitoring program in place to monitor ground water, well performance
and to ensure that the project remains within the ERCB approved operational pressure limits.
4.4.1.1 SAGD Well Performance Monitoring

To monitor the operations of the pilot the SAGD production well has been equipped with 5 thermo
couples along the length of the horizontal and heel and toe pressure monitoring bubble tubes. In addition
to this, two observation wells, monitoring pressure and temperature, have been drilled offsetting the heel
and toe of the SAGD well pair.
Pilot observation wells:
• 102/14-25-076-18W4 (heel observation well) is drilled 17.7 south of the SAGD well pair. The well
is setup to monitor temperature above, below and within the net pay as well monitoring the
pressure and temperature of the LGR3 aquifer.
• 103/13-25-076-18W4 (toe observation well) is drilled 8.5m North of the SAGD well pair. The well
is setup to monitor the temperature above, below and within the net pay.
4.4.1.2 Ground Water Monitoring

As part of the ERCB and AEW approval conditions for the pilot project, three wells have been drilled to
monitor ground water conditions. Prior to pilot operations commencing, all non-saline ground water
formations were tested to obtain the baseline water composition. SAGD operational procedures are in
place to prevent contamination of non-saline water sources. The potential effects associated with ongoing
SAGD operations will be monitored by way of semi-annual sampling events for the remaining life of the
pilot well pair. 100/03-36-076-18W4: first of two wells drilled to monitor the LGR3 aquifer as per AEW
requirements. The well is equipped with a pressure and temperature sensor in the Lower Grand Rapids
LGR3 aquifer.
• 100/14-25-076-18W4: second of two wells used to monitor the bottom water zone. The well is
completed similarly to the 100/03-36-076-18W4 well and has the same monitoring capabilities
and sampling schedule.
• 100/15-25-076-18W4: the well was drilled to the monitor the Viking aquifer above the bitumen
zone. The well is equipped with pressure and temperature sensors in the Viking. The
100/15-25-076-18W4 Viking well has the same monitoring capabilities and sampling schedule.
Refer to Figure 4.4-3 for a diagram of the pilot monitoring program.
2. Integrated Application, Volume 1, Section 6.3.9 Sulphur Recovery Facility, Page 6-18.
The H2S value in the sentence on page 6-18 is erroneous. It was incorrectly stated that the gas analysis
at the pilot operations has the H2S at 16 ppm. The sentence should have read: Produced gas analysis
data from the pilot operations have the H2S at 1600 ppm. All calculations in Volume 1, Table 6.3-3 were
calculated using 1600 ppm.
Page 1
Blackrod Commercial SAGD Project BlackPearl Errata – SIR Round 2
3. ESRD SIR 1 Responses, Section 3.5, SIR 76, Page 111 - 113
BlackPearl states on page 112, With the projected population increase of less than 1% due to
project development, it is anticipated that the effects on the present angling statistics and target
species will be considerable.
The sentence on page 112 as described above is erroneous. The sentence should read: With the
projected population increase of less than 1% due to project development, it is anticipated that the effects
on the present angling statistics and target species will not be considerable.
4. ESRD SIR 1 Responses, Section 4.1, SIR 94, Responses c and d, Pages 135-136
BlackPearl states that BlackPearl has no exploration activities planned for winter 2012/2013 for
the Blackrod Project and that BlackPearl completed an exploration program (oil sands
exploration wells) in winter 2012/2013.
The sentence on page 135 as described above is erroneous. The statement should read: BlackPearl
completed an exploration program (oil sands exploration wells) in winter 2011/2012.
The values provided in Table 109-1 were erroneous. Table 109-1 has been revised according to the
updated Project Footprint (December 2013) and is provided below.
Page 2
TABLE 109-1
PROJECT FACILITIES IN UPLAND AND LOWLAND WITH

CORRESPONDING PROPOSED RECLAMATION TYPE
Reclamation Type on Upland Reclamation Type on Lowland

Full fill Partial fill No fill Geotextile Full fill Partial fill No fill Geotextile
Quantity Upland Upland Lowland Lowland removal removal removal removal removal removal removal removal
Project Facility (unit) Area (ha) (unit) (ha) (Unit) (ha) (unit) (unit) (unit) (ha) (unit) (unit) (unit) (ha)
Central Processing 1 122.9 1 122.9 0 0 0 0 1 0 0 0 0 0
Facility
CPF Access Road 1 0.8 1 0.8 0 0 0 0 1 0 0 0 0 0
Camps 1 18.7 1 18.7 0 0 0 0 1 0 0 0 0 0
Well Pads 54 232.2 20 118.8 34 113.4 0 0 20 0 0 34 0 58.7
Sumps 3 13.34 3 13.34 0 0 0 0 3 0 0 0 0 0
Borrow Pits 24 151.4 18 0 6 0 0 0 18 0 0 0 6 0
Multi-use Corridors n/a 313.1 n/a 173.7 n/a 139.1 0 0 173.7 ha 0 139.1 ha 0 0 139.1
Area of Direct Soil Disturbance 852.5
Notes: 1. Approximately 56% of each well pad located in deep peat areas will be reclaimed to wetland type reclaimed soils.
Approximately 44% will be reclaimed to transitional soils.
Approximately 27% will be reclaimed to upland mineral soils.
Page 3

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700, 444 – 7th Avenue S.W.

Calgary, AB T2P 0X8

December 13, 2013

Steve Thomas Claire Classen

Dear Sir or Madam:

Re: Blackrod Commercial SAGD Project - Supplemental Information Request (SIR)

BLACKPEARL RESOURCES INC.

AER SIR 2 5.0

• Project Update – SIR Round 2;

• AER SIR 2 Reponses; and

• AESRD SIR 2 Responses.

2.0 PROJECT UPDATE

2.1 Revisions to the Project Area

• DP1 is now drilled from well pad 1E;

• DP2 is now drilled from well pad 1B only; and

• DP 6 is now drilled from the new well pad 1A.

TWP.77 3BBB 3BAA 3BFF

3BU 3BT 3BW 3BEE

3BS 3BR 3BV

Project Footprint FIGURE 1.1-1

Phase 2 Sump Site Permanent Operations Camp Site Waterbody

RGE.18 W4M RGE.17 W4M

3BBB 3BAA 3BFF

3BT 3BW 3BY 3BZ 3BEE

Project Footprint Construction Camp Site Development Area Well 

2.2 Environmental Impact Assessment

2.2.1 Proposed Groundwater Monitoring Wells

12-36 (Proposed) 9-36 (Proposed)

3-36 (Existing - directional)

Project Footprint FIGURE 2.1-1

Definition/Acronym Full Name

Ongoing Stakeholder Engagement Activities

Project Update Letter

As part of BlackPearl’s ongoing consultation program, a Geographic Land Information Management

PRE-OPEN HOUSE MEDIA COVERAGE

Media Outlet Circulation Area Date Frequency

SUMMARY OF OPEN HOUSE ISSUES OR CONCERNS RAISED AND BLACKPEARL’S RESPONSE

Summary of Comment Project Team’s Response

Aboriginal Engagement Activities

Objections and Statements of Concern

Fort McMurray #468 First Nation

Laricina Energy Ltd.

SUMMARY OF OUTSTANDING STATEMENTS OF CONCERN

2. ERCB SIR 1 Responses, SIR 3, Response b, Page 13.

ORIGINAL BITUMEN IN PLACE (OBIP) AND DEVELOPABLE BITUMEN IN PLACE (DBIP)

Drainage Average Planned

4. ERCB SIR 1 Responses, Figures 8-1 to 8-8, Page 20 to 27.

395 NPOR_SAN (V/V) AF30 (OHMM) DPHZ (V/V) AT30 (OHM.M)

BLACKPEARL RESOURCES INC.

Although there is no reason to believe that there are any errors

DPRS_(%) RILM (OHMM) NPOR SAN (M3/M3) AT90 (OHM.M) 395

Although there is no reason to believe that there are any errors

DPRS_(%) RILM (OHMM)

GR (GAPI) NPRS (%) RILD (OHMM)

Joli Fou 385

Base SAGD Reservoir 290

Although there is no reason to believe that there are any errors

Although there is no reason to believe that there are any errors

Project Footprint Construction Camp Site Development Area Well