Risk Assessment of Solvent

Injection Processes

December 2018
Alberta Energy Regulator
Risk Assessment of Solvent Injection Processes

December 2018

Published by
Alberta Energy Regulator
Suite 1000, 250 – 5 Street SW
Calgary, Alberta
T2P 0R4

Telephone: 403-297-8311
Inquiries (toll free): 1-855-297-8311
Email: [email protected]
Website: www.aer.ca
 Alberta Energy Regulator

Contents
Preface .......................................................................................................................................................... iii

Executive Summary ...................................................................................................................................... v

1 Introduction ............................................................................................................................................. 1

1.1 Background ................................................................................................................................... 1

1.2 Scope ............................................................................................................................................ 2

1.3 Objectives ..................................................................................................................................... 3

1.4 Context and Stakeholders ............................................................................................................ 4

1.4.1 Internal Context ............................................................................................................... 4

1.4.2 External Stakeholders...................................................................................................... 4

2 Limitations and Assumptions .................................................................................................................. 4

3 Risk Assessment .................................................................................................................................... 5

3.1 Risk Identification .......................................................................................................................... 5

3.1.1 Contaminant of Potential Concern (CoPC) ..................................................................... 5

3.1.2 Potential Subsurface Failure/Release Scenarios ............................................................ 5

3.1.3 Potential Surface Failure/Release Scenarios .................................................................. 8

3.1.4 Potential Transport Pathways .......................................................................................... 9

3.1.5 Potential Exposure Routes ............................................................................................ 12

3.2 Risk Analysis and Evaluation ..................................................................................................... 12

4 Key Findings ......................................................................................................................................... 15

Appendix 1 Glossary and Abbreviations ................................................................................................ 17

Appendix 2 Examples of Substances Potentially Used in Activities at Solvent Injection Facilities........ 18

Appendix 3 Risk Assessment Results .................................................................................................... 19

Report: Risk Assessment for Solvent Injection Processes i

 Alberta Energy Regulator

Preface

This report describes an option in providing regulatory assurance at the Alberta Energy Regulator (AER)
in the face of rapid technological advances being adopted in Alberta’s petroleum industry. It addresses a
new innovative practice for regulatory review and should be regarded as a prototype for a more rapid,
evidence-based and science-informed regulatory response to new technology when that is proposed for
development of Alberta’s energy resources.

This preface is meant to provide context to this option, whereas the contents of the report stand on their
own merit. I recommend their conclusions be accepted by the AER for information and guidance without
prejudice to any regulatory application under current or future review.

This particular work concerns new technology for underground, or in situ, development of oil sands. The
goal of the Province of Alberta has always been to develop its immense in situ oil sands resources in a
way that provides economic benefits to all Albertans. The role of the AER is to assure Albertans that this
development is done in a way that is safe, efficient, orderly, and environmentally responsible.

The history of oil sands development in Alberta has been one of responsible resource stewardship, intense
regulatory oversight, and made-in Alberta commercial innovation. A historical review is partly captured
in the peer-reviewed paper by AER Chief Geologists (past) Dr. F.J. Hein and (present) Dr. K.P. Parks,
published in 2016 by the Canadian Society of Petroleum Geologists 1. In the past decade, Albertans’
concerns have included growing calls for more environmental protection, stakeholder engagement,
respect for indigenous and traditional rights, and response to climate change in the in situ oil sands sector.
In response, government leaders and policy-makers are focusing their attention on these issues, and
regulators need to respond accordingly. A real challenge for regulators like the AER is to adapt to these
tectonic shifts in social concerns and government direction using regulatory instruments already in force,
while going through the process to create new ones.

Regulatory development is a detailed process involving stakeholder consultation, risk assessment, policy
alignment, legal review, and possibly legislative changes. As such, it can move relatively slowly. In
contrast, technological innovation driven by economic forces, moves relatively quickly. These dynamics
put the regulatory system under tension to allow industry to capture immediate value through innovation
while respecting the process needed for quality regulatory changes that balance society’s goals and
values.

1
Hein, F.J., and K.P. Parks, 2016. Public geoscience in regulating Alberta’s oil sands development: A Historical Retrospective

1960–2010. Bulletin of Canadian Petroleum Geology, 64(2), pp.362-383.

Risk Assessment of Solvent Injection Processes iii

This document represents an innovative approach inside the AER to better respond to that tension. The
specific challenge is around the use of solvent-assisted Steam-Assisted Gravity Drainage (SAGD)
technology to recover oil sands in northeast Alberta, but it could be applied equally to a number of other
areas of energy development in Alberta.

Over the past decade, the in situ oil sands industry in Alberta has invested in innovation to reduce water
use in SAGD in situ oil sands-recovery processes in order to reduce costs and decrease environmental
impacts. As well, conservation of water and minimization of waste is a prime mandate for the AER and
thus AER has been requiring industry to reduce its use of water in SAGD. One opportunity to reduce the
water footprint of SAGD is to deploy new technologies that actually replace the use of water in the
development of in situ oil sands, but does not introduce unacceptable or unmanageable new risk to public
safety or the environment. Solvent-assisted SAGD is one of these technologies.

Solvent-assisted SAGD, while not new in concept or pilot stage application, is relatively new in
commercial-scale application in Alberta. As the practice evolves and matures, the AER will need to apply
its existing regulatory instruments to evaluate and control risks, recognizing that the regulatory
instruments that were developed in other oilfield contexts have general applicability to solvent-assisted
SAGD projects. The economic interests of Albertans will be hurt if industry is not allowed to proceed
with its safe use in the field at pilot and commercial scales.

This document summarizes the work of staff at the AER, which provides information to the AER
leadership. The intent of this work was to provide an assessment of the AER’s regulatory requirements
and their effectiveness in regards to the application of solvent technology for in situ development of oil
sands. This document concludes that the existing regulatory instruments will be sufficient to meet the
goals of public safety and environmental protection demanded by Albertans, while allowing commercial
development to proceed in an orderly, efficient, and environmentally responsible manner, during which
time fit-for-purpose regulations can be developed to suit both the specific nature of this technology and
the site-specific contexts of oil sands areas where it will be deployed.

This work benefited from the contributions of AER subject-matter experts in many fields, including the
AER Risk Assessment Team. Thanks go to H. Deng, M. Dumanski, K. Hale, J. Du, F. Chiang, S.
Harbidge, L. Kopf, C. Dickinson, H. Huang, E. Giry, G. Boyer, T. Hussain, A. Panwar, C. Filewich, B.
Hathway, T. Hauck, K. Haug, T. Arciszewski, and C. Evans.

Dr. Kevin Parks, P. Geo.

AER Chief Geologist
July 2018, Calgary

iv Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Executive Summary

Solvent injection processes, assessed in this report, are bitumen recovery technologies that involve
injecting solvents (such as propane, diluent or other hydrocarbons) or co-injecting solvents with steam
into a reservoir to produce bitumen reserves.

A risk assessment was conducted by AER staff to assess the effectiveness of existing regulatory controls
in this context. The objective of this risk assessment is to understand the effectiveness of existing AER
controls that could reduce the chance and magnitude of potential risks occurring given a generic
understanding of a solvent-assisted SAGD project. This includes consideration of risk factors that could
be associated with this technology including:

• general types of Contaminate(s) of Potential Concern (CoPC) potentially used in typical activities
at solvent injection facilities;
• potential failure/release scenarios and transport pathways by which substances could enter the
environment (e.g., groundwater, surface water, air, and soil);
• potential exposure routes (e.g., breathing, eating, or drinking) by which people could come into
contact with CoPCs released into the environment.

This assessment is not intended to complete, amend, substitute for, or agree or disagree with any
particular site-specific application of this technology under consideration, application, review, or other
regulatory process. Rather this is an inward directed assessment of the regulatory instruments that will be
applied to reviews of this technology at AER. The intent of this assessment is to provide the AER
assurance that its own instruments are complete and sufficient with regard to controlling risk and to
identify areas where improvements may be needed.

The risk assessment identified four key findings that can be used in risk-informed decision making and
discussions for solvent injection processes:

1. A total of 20 potential failure/release scenarios that could result in the release of CoPCs from
solvent injection processes were identified. This list can inform future application reviews for
completeness.
2. 16 out of the total 20 potential failure/release scenarios with associated potential transport
pathways and exposure routes were identified as lower band risk scenarios, for which the
probability of exposure is very low or the potential magnitude of exposure is negligible given our
knowledge of the technology and subsurface conditions in Alberta where this technology is likely
to be applied. These risk scenarios are broadly tolerable; and they can be managed by existing
risk reduction measures and no additional risk reduction measures are needed. To prevent these
failure events and ensure their impacts are negligible, it is critical for operators to fully comply
with AER’s regulatory requirements.

Risk Assessment of Solvent Injection Processes v

 3. 4 out of the total 20 potential failure/release scenarios have potential transport pathways and
exposure routes ranked as middle band risk scenarios with the consideration of AER’s existing
regulatory controls. These risk scenarios warrant a thorough consideration of individual
applications or operations to determine the necessity of employing practicable risk reduction
measures (e.g., carry out additional review and surveillance - such as monitoring, inspections and
audit; enhanced ongoing stakeholder engagement). These middle band risk scenarios include:

• Caprock fracture (e.g., slow release of fluid to the surface) and caprock and overlying
formation fracture (e.g., Total Joslyn incident) – if these failure event occurred, the
magnitude of exposure would not be negligible. Existing regulatory instruments that could
prevent or mitigate these failure events include AER Directive 086 Reservoir Containment
Application Requirements for Steam-Assisted Gravity Drainage Projects in the Shallow Oil
Sands Area.

• Loss of containment from pipeline transportation – among the 20 potential failure/release

events, pipeline spills/leaks are the most likely ones to occur off lease. Existing regulatory
instruments that could prevent or mitigate these failure events include Pipeline Act; Directive
077 Pipelines – Requirements and Reference Tools; Water Act; Manual 001 Facility and Well
Site Inspections; Manual 005 Pipeline Inspections; and requirements under Alberta Boilers
Safety Association (ABSA).

4. Potential CoPCs at solvent injection facilities are not limited only to hydrocarbons. Collecting
data on CoPCs associated with solvent injection process and assessing risks to people and
environment could provide a technical rationale for developing monitoring programs for selected
CoPCs, and deploy adaptive management strategies to mitigate these risks when they are
identified. Having a comprehensive and responsive monitoring program based on trigger-warning
systems allows identification of a chronic problem before it reaches critical levels or exceeds an
exposure limit.

The risk assessment conducted here is limited by a number of factors. Interpretation of the key findings
and future discussions should reflect these limitations and assumptions.

vi Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

1 Introduction

1.1 Background

Solvent injection processes, assessed in this report, are bitumen recovery technologies that involve:

1. injecting solvents into a reservoir (see Figure 1 below)

Similar to steam-assisted gravity drainage (SAGD), this technology uses horizontal well pairs to
access bitumen reservoirs that are uneconomic to mine. However, instead of injecting steam, a
clean condensable solvent (such as propane) is injected into the reservoir.

2. co-injecting solvents with steam into a reservoir (see Figure 2 below)

This technology is a modification of SAGD or cyclic steam stimulation (CSS), which involves
injecting a mixture of solvent and steam into the reservoir.

The injected steam and/or solvent (such as propane, diluent or other hydrocarbons) decrease the bitumen
viscosity allowing it to flow more freely to the surface (producing well). While these technologies vary in
name, solvent formulation, and operating conditions, all are intended to increase bitumen production rate,
reduce water use and greenhouse gas emissions, and ensure economic viability while producing bitumen
reserve. Comparison of processes injecting clean condensable solvents with the ones co-injecting solvents
with steam were summarized in Table 1.

2
Figure 1: Illustration of in situ bitumen recovery technologies involving injecting solvent

2
Source: www.nsolv.ca

Risk Assessment of Solvent Injection Processes 1

 3
Figure 2: Illustration of in situ bitumen recovery technologies involving co-injecting solvent with steam

Table 1: Comparing processes of injecting clean condensable solvents with the ones co-injecting solvents
with steam

Injecting solvents Co-injecting solvents with steam

• Improve bitumen recovery

• Reduce water use and greenhouse gas emissions
• Substances used in both processes include:
Similarities
- Hydrocarbon chemicals used to enhance recovery
- Non-hydrocarbon chemicals used to enhance recovery
- Common additives for well maintenance

• Use only solvent, not steam • Use a mixture of solvent (< 20% by
• Use less energy and emit less volume) and steam
Differences
greenhouse gas comparing with co- • First commercial scale
injecting solvent with steam

1.2 Scope
This assessment was conducted on risks related to both surface and subsurface activities at solvent
injection facilities. Table 2 below summarizes activities and associated substances considered in this risk
assessment.

3
Source: Oil Sands Magazine

2 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Table 2: Potential Interaction of solvent injection processes with the Environment

Activities Associated Substances

Subsurface activities

Solvent injection process - Solvent, additives, steam, bitumen, produced water,

subsurface activities and salts

Solvent, residual hydrocarbons, produced water, and

Disposal
salts

Surface activities

Chemical storage Solvent, chemical additives

Flaring Solvent, flowback fluid (solvent, formation product)
Ground transportation Solvent, chemical additives, disposal fluid/solids
Pipeline transportation Steam, solvent, dilbit, disposal fluid
Produced water, solvent, bitumen, dilbit, water
Processing facility
treatment chemicals
Flue stacks PM2.5, NOx, VOCs, SOx
Produced gas (hydrocarbon, VOCs, RSCs, blanket gas)
Other venting
and water vapour

1.3 Objectives
The objective of this risk assessment is to understand:

• General types of Contaminants of Potential Concern (CoPCs) that could be used in typical activities
at solvent injection facilities, including
- solvent injection process
- well and plant process, and
- emission sources.

• Potential failure/release scenarios and transport pathways by which substances can enter the
environment at solvent injection facilities, including
- unplanned releases that occur over a short or intermittent duration, e.g., accident, emergency or
upset release; and
- controlled continuous releases, e.g., emission sources.

• Potential exposure routes (e.g., breathing, eating, or drinking) by which people could come into
contact with CoPCs released into the environment.

• Effectiveness of existing AER’s regulatory controls which could reduce the chance and/or
magnitude of potential risks occurring.

Risk Assessment of Solvent Injection Processes 3

1.4 Context and Stakeholders

1.4.1 Internal Context

This study is conducted to ensure the following AER strategic outcomes are achieved:

• The environment is protected,

• The public is safe from harm, and,
• Citizens are confident about how energy is developed within the province.

1.4.2 External Stakeholders

The main external stakeholder or indigenous community for this study is Fort MacKay First Nation. Their
concerns are related to commercial scale solvent injection processes in Fort Mackay’s traditional territory
and are detailed in the two letters to the AER dated October 13, 2016 and March 9, 2017. Results of this
work may be used to engage the external stakeholder or indigenous community at a future potential
Solvent Forum.

2 Limitations and Assumptions

The risk assessment conducted here is limited by a number of factors. Interpretation of the results and
future discussions should reflect these limitations and assumptions.

1. Risk analysis was based on AER staff’s knowledge and experiences, and generic information
gathered from publically available applications, approvals, and correspondence.

2. The effectiveness assessment of AER’s regulatory controls was based on the assumption that
operators fully comply with these requirements. The AER follows its Integrated Compliance
Assurance Framework to ensure operators comply with these requirements.

3. Risks to environmental receptors require site-specific information, therefore it was not conducted.
However, ecological health assessment could be done in the future if it is determined as needed.

4. Exposure assessment to human receptors requires site-specific data (e.g., quantity and
composition of used substances, location of human receptor), therefore it was not conducted.
However, it could be done in the future if it is determined as needed.

4 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

3 Risk Assessment
The following risk assessment was conducted by members of AER’s Environmental Science Group,
Industry Operations - In Situ group, and Enterprise Risk Management team.

This risk assessment is to identify the risk associated with solvent injection process and to assess the
effectiveness of regulatory controls, to ensure AER strategic outcomes are achieved. It started with
identifying scenarios that have potential to release CoPCs to the environment, and various exposure
pathways through which people could be in contact with contaminated soil, water and air. It also
evaluated the likelihood of potential failure scenarios and exposure pathways based on the effectiveness
of existing regulatory controls that could reduce the chance and/or consequence of potential failures
occurring.

3.1 Risk Identification

The purpose of risk identification is to identify contaminant sources, subsurface failure/release scenarios,
surface failure/release scenarios, transport pathways, and exposure routes.

3.1.1 Contaminant of Potential Concern (CoPC)

CoPCs potentially used at solvent injection facilities generally fall into four categories and the usage rates
vary depending on the operational scheme:

1. Hydrocarbons to enhance recovery

2. Non-hydrocarbon chemicals to enhance recovery

3. Additives for well and plant processes

4. Chemicals in disposal wells

While currently companies are not required to disclose the detailed compositions of substances used in
solvent injection process, some examples of potentially used substances were obtained from In Situ
Performance Presentations submitted to the AER. See Appendix 2 for details.

3.1.2 Potential Subsurface Failure/Release Scenarios

Potential subsurface failure/release scenarios for solvent injection process can be categorized by
geological leakage or engineering failures. Nine potential scenarios were identified (see Figure 3) with
associated activities that may lead to the release of the substance(s). Table 3 below provides detailed
descriptions of these scenarios.

Risk Assessment of Solvent Injection Processes 5

Figure 3: Illustration of potential subsurface failure/release scenarios

Table 3: Detailed description of potential subsurface failure/release scenarios identified in Figure 3

Potential subsurface
Potential Source
failure/release scenarios
Existing regulatory instruments that could
No. Expected
Potential prevent or mitigate the failure scenario
Activity Description release
substances
duration 4

Solvent,
AER directives related to drilling, completions,
Solvent injection additives, Production/injection
recompletions, repair, and abandonment (Dir 08, 09,
process - steam, casing failures with
1 Short 10, 13, 20, and 51); ID2003-01, Industry
subsurface bitumen, surface casing
Recommended Practices (IRPs) 03, 25, and 26
activities produced failure
(future);
water, salts

4
Potential failure/release types were characterized as short (i.e., an unplanned release or emergency that occurs over
a short duration, such as immediate, hours, or days), intermittent (frequently intermittent event, such as weeks), or
continuous (i.e., a continuous for months or continuous year-around)

6 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Potential subsurface
Potential Source
failure/release scenarios
Existing regulatory instruments that could
No. Expected
Potential prevent or mitigate the failure scenario
Activity Description release
substances
duration 4

Solvent,
AER directives related to drilling, completions,
Solvent injection additives,
recompletions, repair, and abandonment (Dir 08, 09,
process - steam, Cement, casing, or Short or
2 10, 13, 20, and 51); ID2003-01, Industry
subsurface bitumen, wellhead failure intermittent
Recommended Practices (IRPs) 03, 25, and 26
activities produced
(future)
water, salts
Solvent injection Solvent,
Caprock fracture
process - bitumen, AER Directive 086 for shallow Athabasca Oil Sands
3 (e.g., slow release of Short or
subsurface produced Area
fluid to the surface) intermittent
activities water, salts
AER Directive 086 for shallow Athabasca Oil Sands
Solvent injection Solvent, Caprock and
Area
process - bitumen, overlying formation
4 Short AER Directive 023 for non-shallow area (e.g.,
subsurface produced fracture (e.g., Total
application review process, SIRs, approval conditions,
activities water, salts Joslyn incident)
and caprock monitoring)
Solvent injection Solvent, Lateral loss of
process - bitumen, solvent to highly Short or AER Directive 023 application information related to
5
subsurface produced mobile water in the intermittent geology and reservoir quality
activities water. salts reservoir
Solvent,
Disposal / Strat. AER Directive 023 Applications and Scheme Approval
bitumen, Loss of disposal Short or
6 testing / legacy Conditions, Directive 065, and Directive 054
produced zone containment 5 intermittent
wells monitoring related to Devonian disposal operations
water, salts
Enters stratigraphic AER directives related to drilling, completions,
Solvent,
Disposal / Strat. testing, disposal, or recompletions, repair, and abandonment (Dir 08, 09,
bitumen, Short or
7 testing / legacy legacy wells with 10, 13, 20, and 5); ID2003-01, Industry
produced Intermittent
wells poor cement and/or Recommended Practices (IRPs) 03, 25, and 26
water, salts
casing (future)
AER directives related to drilling, completions,
Solvent, Enters stratigraphic
Disposal / Strat. recompletions, repair, and abandonment (Dir 08, 09,
bitumen, testing, disposal, or Short or
8 testing / legacy 10, 13, 20, and 51); ID2003-01, Industry
produced legacy wells with intermittent
wells Recommended Practices (IRPs) 03, 25, and 26
water, salts open flow wellbore
(future)

Solvent injection Solvent, Short,

Lateral loss of
process - bitumen, intermittent AER Directive 023 (e.g., application review process,
9 solvent to adjacent
subsurface produced or SIRs, approval condition, and caprock monitoring)
or underlying zones
activities water, salts continuous

5
Fort McKay First Nation raised their concern on this failure scenario in their letter to the AER on March 9, 2017.

Risk Assessment of Solvent Injection Processes 7

3.1.3 Potential Surface Failure/Release Scenarios
Potential surface failure/release scenarios were identified for typical infrastructures used in solvent
injection process, including on site storage, ground and pipeline transportation, processing facility, and
emission sources. Table 4 summarizes the potential surface failure/release scenarios.
Table 4: Potential Surface Failure/Release Scenarios

Potential surface
Potential Source
failure/release scenarios
Existing regulatory instruments that could prevent or
No. Expected
Potential mitigate the failure scenario
Activity Description release
substances
duration

Loss of
Chemical Solvent, containment AER Directive 055 Storage Requirements for Upstream
10 Short
storage additives (reportable spill or Petroleum Industry
leak)
Loss of
Chemical Solvent, containment (non- Short or AER Directive 055 Storage Requirements for Upstream
11
storage additives reportable spill or intermittent Petroleum Industry
leak)

Solvent, Loss of
A spill or leak on lease would be regulated by AER through
Ground additives, containment on
12 Short EPEA.
transportation disposal lease (reportable
If it is off lease it is out of the AER’s jurisdiction.
fluid/solids spill or leak)

Loss of
Solvent,
containment on
Ground additives, Short or A spill or leak on lease would be regulated by AER through
13 lease (non-
transportation disposal intermittent EPEA. If it is off lease it is out of the AER’s jurisdiction.
reportable spill or
fluid/solids
leak)

Steam, Loss of
Pipeline solvent, containment Pipeline Act, Directive 077, Water Act,
14 Short
transportation dilbit, (reportable spill or Manuals 1 and 5; ABSA
disposal fluid leak)

Steam, Loss of
Pipeline solvent, containment (non- Short or Pipeline Act, Directive 077, Water Act,
15
transportation dilbit, reportable spill or intermittent Manuals 1 and 5; ABSA
disposal fluid leak)

Produced
water,
Loss of
solvent,
Processing containment
16 bitumen, Short Facility Application Review (D023 & D078), EPEA, D055
facility (reportable
dilbit, water
incident)
treatment
chemical

Produced
water,
Loss of
solvent,
Processing containment (non- Short or
17 bitumen, Facility Application Review (D023 & D078), EPEA, D055
facility reportable spill or intermittent
dilbit, water
leak)
treatment
chemical

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 Alberta Energy Regulator

Potential surface
Potential Source
failure/release scenarios
Existing regulatory instruments that could prevent or
No. Expected
Potential mitigate the failure scenario
Activity Description release
substances
duration

Solvent,
flowback
AER Directive 060 Upstream Petroleum Industry Flaring,
18 Flaring fluid (solvent, Upset condition Short
Incinerating, and Venting; EPEA
formation
product)

PM2.5, NOx,
19 Flue stacks Emission source Continuous EPEA, ID 2001-03
VOCs, SOx

Produced
gas
(hydrocarbon AER Directive 060 Upstream Petroleum Industry Flaring,
20 Venting Upset condition Short
, VOCs, Incinerating, and Venting; EPEA; ID 2001-03
RSCs,
blanket gas)

3.1.4 Potential Transport Pathways

Transport pathways are how substances move into environmental media (air, surface water, sediment,
groundwater, and soil) and diet items (wildlife, fish, and plants). Sections 3.1.2 and 3.1.3 illustrates the
potential failure/release scenarios at solvent injection facilities. These scenarios with associated potential
transport pathways are described in Table 5 below.

Table 5: Potential Failure/Release Scenarios and Potential Transport Pathways

Potential failure/release
Potential Source
scenarios
NO. Expected Potential transport pathway
Potential
Activity Description release
substances
duration
Solvent Production /
Release to groundwater
Injection injection casing
Solvent, additives,
1 Process – failures with Short
salts Release to surface water via
subsurface surface casing
activities failure groundwater interaction

Solvent Release to surface water

Injection
Solvent, additives, Cement, casing or Short or
2 Process –
salts wellhead failure intermittent
subsurface Release to soil
activities

Solvent Release to groundwater

Caprock fracture
Injection Solvent, bitumen,
(e.g., slow release Short or
3 Process – produced water,
of fluid to the intermittent Release to surface water via
subsurface salts
surface) groundwater interaction
activities

Solvent Solvent, bitumen, Caprock and

4 Short Release to groundwater
Injection produced water, Overlying

Risk Assessment of Solvent Injection Processes 9

 Potential failure/release
Potential Source
scenarios
NO. Expected Potential transport pathway
Potential
Activity Description release
substances
duration
Process – salts Formation
subsurface Fracture (e.g., Release to surface water via
activities Total Joslyn groundwater interaction
incident)

Direct release to surface water

Direct release to air

Solvent Release to groundwater

Lateral loss of Short,
Injection Solvent, additives,
solvent to highly intermittent
5 Process – bitumen, produced
mobile water in or
subsurface Water, salts Release to surface water via
the reservoir continuous
activities groundwater interaction

Diluent, residual
hydrocarbons, Loss of disposal Short or Indirect release to surface water
6 Disposal
produced water, zone containment intermittent (long migration pathway)
salts

enters
Release to groundwater
Diluent, residual stratigraphic
hydrocarbons, testing, disposal, Short or
7 Disposal
produced water, or legacy wells intermittent
salts with poor cement Release to surface water via
or casing groundwater interaction

enters Release to surface water

Diluent, residual stratigraphic
hydrocarbons, testing, disposal, Short or
8 Disposal
produced water, or legacy wells intermittent
salts with open flow
wellbore Direct release to soil

Solvent Release to groundwater

Lateral loss of Short,
Injection Solvent, additives,
solvent to intermittent
9 Process – bitumen, produced
adjacent or or
subsurface Water, salts Release to surface water via
underlying zones continuous
activities groundwater interaction
Release to surface water (direct
or in-direct)
Loss of
Chemical containment Direct release to soil
10 Additives, solvent Short
storage (reportable spill or
leak) Direct release to air

Release to groundwater

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 Alberta Energy Regulator

Potential failure/release
Potential Source
scenarios
NO. Expected Potential transport pathway
Potential
Activity Description release
substances
duration

Release to surface water (direct

or in-direct)
Loss of
Chemical containment (non- Short or Direct release to soil
11 Additives, solvent
storage reportable spill or intermittent
leak) Direct release to air

Release to groundwater

Release to surface water (direct

or in-direct)

Loss of
Ground Additives, diluent, containment on Direct release to soil
12 Short
transportation disposal fluid/solid lease (reportable
spill or leak)
Direct release to air

Release to groundwater

Release to surface water (direct

or in-direct)

Loss of
Direct release to soil
containment on
Ground Additives, diluent, Short or
13 lease (non-
transportation disposal fluid/solid intermittent
reportable spill or Direct release to air
leak)

Release to groundwater

Release to surface water (direct

or in-direct)
Loss of
Steam, diluent,
Pipeline containment Direct release to soil
14 dilbit, disposal Short
transportation (reportable spills
fluid Direct release to Air
or leaks)

Release to groundwater

Release to surface water (direct

or in-direct)

Loss of Direct release to soil

Steam, diluent,
Pipeline containment (non- Short or
15 dilbit, disposal
transportation reportable spills intermittent
fluid
and leaks) Direct release to air

Release to groundwater

Risk Assessment of Solvent Injection Processes 11

 Potential failure/release
Potential Source
scenarios
NO. Expected Potential transport pathway
Potential
Activity Description release
substances
duration

Release to surface water (direct

or in-direct)
Produced water,
Loss of
diluent, bitumen, Direct release to soil
Processing containment
16 dilbit, water Short
facility (reportable
treatment Direct release to air
incident)
chemical
Release to groundwater

Release to surface water (direct

Produced water, or in-direct)
diluent, bitumen, Loss of
Processing Short or Direct release to soil
17 dilbit, water containment (non-
facility intermittent
treatment reportable spill) Direct release to air
chemical
Release to groundwater

Solvent, flowback
(diluent, formation
18 Flaring Upset condition Short Direct release to air
products,
additives)

PM2.5, NOx,
19 Flue stacks Emission source Continuous Direct release to air
VOC, SOx

Produced gas -
hydrocarbon,
20 Venting Upset condition Short Direct release to air
VOCs, RSCs;
blanket gas

3.1.5 Potential Exposure Routes

Exposure routes are the ways people could come into contact with a CoPC. The potential exposure routes
considered for this risk assessment were:

• Humans
- Ingestion of groundwater
- Ingestion of surface water
- Dermal contact with surface water
- Inhalation

3.2 Risk Analysis and Evaluation

Risk analysis involves developing an understanding of the risk. It provides an input to risk evaluation and
to decisions on whether additional risk reduction measures are needed (e.g., new AER regulatory
controls).

12 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

In general, risk can be expressed as:

RISK = LIKELIHOOD × CONSEQUENCE

In this risk assessment, risk was expressed as:

RISK = EXPOSURE × HAZARD

Where, “exposure” is equivalent to likelihood of exposure and considers potential CoPCs associated with
activity (factor 1), potential failure pathway for CoPCs release to the environment (factor 2), potential
transport mechanism for CoPCs movement in environmental media (factor 3), and potential receptor
exposure route (factor 4); while “hazard” considers the potential magnitude of exposure (factor 5).

A semi-quantitative risk analysis was conducted through assigning binary values to the above five factors
(i.e., 0 and 1 for factors 1 to 4; 1 or 2 for factor 5):

RISK = {EXPOSURE (factor 1 + factor 2 + factor 3 + factor 4) × HAZARD (factor 5)}

The risk assessment team ranked the 20 potential failure/release scenarios with associated transport
pathways and exposure route (see Section 3.1) using the criteria described in Table 6. The effectiveness
of existing AER regulatory control was considered when determining the level of risk. The risk scores for
all scenarios are listed in Appendix 2.

Based on the risk score, each potential failure/release scenario was classified as one of the following
categories:

• Lower band (risk score = 0, 1, or 2) – for which the probability of exposure is low or the potential
magnitude of exposure is negligible, indicate the level of risk is broadly tolerable; and they can be
managed by existing risk reduction measures and no additional risk reduction measures are
needed.

• Middle band (risk score = 3, or 4) – indicate the level of risk is tolerable only if all reasonably
practicable risk reduction measures have been implemented; further detailed risk assessment and
cost-benefit analysis may need to determine whether all reasonably practicable risk reduction
measures have been implemented or not.

• Upper band (risk score = 6, or 8) – indicates the level of risk is regarded as intolerable whatever
benefits the activity may bring, and risk reduction measure is essential at any cost if activity is to
continue.

Risk Assessment of Solvent Injection Processes 13

Table 6: Semi-Quantitative Risk Analysis Criteria Used in this Risk Assessment

Likelihood of Exposure Hazard

Factor 1: Factor 2: Factor 3: Factor 4: Factor 5:

Potential Potential failure Potential transport Potential receptor Potential magnitude
Factors CoPCs pathway for mechanism for exposure route of exposure
associated COPCs release COPCs movement
with activity to the in environmental
environment media

- Do the - Is the release - Is there any - Is receptor - What is the

substances mechanism a effective control present? concentration of
used in the normal of monitoring - Is the release CoPCs in
activity have operation, CoPCs in the on-site or off- environmental
the potential upset condition, environmental site? media?
to contain or failure media? - What is the
- Is there any
Parameter CoPCs? event?
effective release rate and
- Is there any - Is there any measure can duration from
effective effective control prevent the source
control to to prevent the presence of emissions?
prevent using failure event? receptor? - Is the release
CoPCs? acute or chronic?

0 - very low 0 - very low 0 - very low 0 - very low 1 - negligible

Value
1 – uncertain* 1 – uncertain* 1 – uncertain* 1 – uncertain* 2 – uncertain*

Risk score
𝑹𝑹𝑹𝑹𝑹𝑹𝑹𝑹 = { 𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬 (𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 1 + 𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 2 + 𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 3 + 𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 4) × 𝑯𝑯𝑯𝑯𝑯𝑯𝑯𝑯𝑯𝑯𝑯𝑯 (𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓𝑓 5) }
calculation

Risk = 0, 1 or 2: lower band risk

Criteria Risk = 3 or 4: middle band risk

Risk = 6 or 8: upper band risk

* “uncertain” means: depends on specific solvent injection operation (e.g., specific nature of the
technology, site-specific subsurface condition), the likelihood or magnitude of exposure could be very low
or higher.

14 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

4 Key Findings
The risk assessment identified four key findings that can be used in risk-informed decision making and
discussions at solvent injection facilities.

1. We identified a total of 20 potential failure/release scenarios (see Table 5) that could result in
release of CoPCs from solvent injection facilities.

2. 16 out of the total 20 potential failure/release scenarios with associated potential transport pathways
and exposure routes were identified as lower band risk scenarios, for which the probability of
exposure is low or the potential magnitude of exposure is negligible given our knowledge of the
technology and subsurface conditions in Alberta where this technology is likely to be applied.
These risk scenarios are broadly tolerable; and they can be managed by existing risk reduction
measures and no additional risk reduction measures are needed. To prevent these failure events and
ensure their impacts are negligible, it is critical for operators to comply with AER’s requirements
listed in Table 3 and Table 4.

3. 4 out of the total 20 potential failure/release scenarios have potential transport pathways and
exposure routes ranked as middle band risk scenarios with the consideration of AER’s existing
regulatory controls. These risk scenarios warrant a thorough consideration of individual
applications or operations to determine the necessity of employing practicable risk reduction
measures (e.g., carry out additional review and surveillance - such as monitoring, inspections and
audit; enhanced ongoing stakeholder engagement). These middle band risk scenarios include:

• Caprock fracture (e.g., slow release of fluid to the surface) and caprock and overlying
formation fracture (e.g., Total Joslyn incident) – if these failure event occurred, the magnitude
of exposure would not be negligible. Existing regulatory instruments that could prevent or
mitigate these failure events include AER Directive 086 Reservoir Containment Application
Requirements for Steam-Assisted Gravity Drainage Projects in the Shallow Oil Sands Area.

• Loss of containment from pipeline transportation – among the 20 potential failure/release

scenarios, pipeline spills/leaks are the most likely ones to occur off lease. Existing regulatory
instruments that could prevent or mitigate these failure events include Pipeline Act; Directive
077 Pipelines – Requirements and Reference Tools; Water Act; Manual 001 Facility and Well
Site Inspections; Manual 005 Pipeline Inspections; and requirements under Alberta Boilers
Safety Association (ABSA).

4. Potential CoPCs at solvent injection facilities are not limited only to hydrocarbons. Collecting data
on CoPCs associated with the substances identified in Table 5 and assessing risks to people and
environment could provide a technical rationale for developing monitoring program for selected
CoPCs and adaptive management strategies to mitigate these risks when they are identified.

Risk Assessment of Solvent Injection Processes 15

 Having a comprehensive and responsive monitoring programs based on trigger-warning systems
allows identification of a chronic problem before it reaches critical levels or exceeds an exposure
limit.

16 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Appendix 1 Glossary and Abbreviations

Glossary

adverse effect impairment of or damage to the environment, human health or safety or

property (source: Environmental Protection and Enhancement Act).

contaminant of any substance that is identified as potentially present on, in or under the site
potential concern and surrounding area that, if released, has the potential for adverse effect
(CoPC) (source: Alberta Environmental Site Assessment Act).

CO2 carbon dioxide

exposure route the ways people could come into contact with a CoPC

H2S hydrogen sulfide

NOx a generic term for the mono-nitrogen oxides

PM2.5 atmospheric particulate matter that have a diameter of less than 2.5
micrometers

RSCs reduced sulphur compounds

transport pathways how substances move into environmental media (air, surface water, sediment,
groundwater, and soil) and diet items (wildlife, fish, and plants).

SOx sulfur oxide

VOCs volatile organic compound

Abbreviations

AER Alberta Energy Regulator

ABSA Alberta Boilers Safety Association

CSS Cyclic Steam Stimulation

SAGD Steam-Assisted Gravity Drainage

Risk Assessment of Solvent Injection Processes 17

Appendix 2 Examples of Substances Potentially Used in Activities at Solvent Injection Facilities

Table A1:Example: hydrocarbons used to enhance recovery (based on Table A2: Example: non-hydrocarbon chemicals used to enhance Table A3: Example: chemicals used in well and plant process
typical composition of diluent) recovery
Additives
Component Carbon Number Non-hydrocarbon chemicals
used to enhance recovery Hydrochloric acid
i-Butane i-C4 Urea Nitrogen
n-Butane n-C4 Brine Solution Phosphoric hydrofluoric acid
i-Pentane i-C5 Ammonia Bleach (sodium hypochlorite)
n-Pentane n-C5 Surfactant (soap) Other Biocide
Hexanes C6 Alkali Clay Stabilizer (3% potassium
Heptanes C7 CO2 chloride water, nutra clay)
Octanes C8 Aromatic solvent (Xylene)
Nonanes C9 Scale inhibitor
Decanes C10 Oxygen scavenger
Undecanes C11 H2S scavenger
Dodecanes C12 CO2 scavenger
Tridecanes C13 Antifoam agent
Benzene C6H6 Sulphur scrubbers
Toluene C7H8 Flocculants
Ethylbenzene, P + m-Xylene C8H10 Corrosion inhibitors (amines)
o-Xylene C8H10 Surfactants
1, 2, 4 Trimethylbenzene C9H12 Ashphaltene dispersants
Cyclopentane C5H10 Fuels
Methylcyclopentane C6H12
Degreasers and cleaners
Cyclohexane C6H12

Methylcyclohexane C7H12

18 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Appendix 3 Risk Assessment Results

Table B1: Risk Assessment Results – Risk Score without Considering AER’s Existing Regulatory Controls

Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #3:
Factor #2: Risk Score
Factor #1: Potential
Potential failure Factor #4: Factor #5: without
Potential transport
pathway for Potential Potential considering
Potential Transport Potential COPCs mechanism for
NO. Expected COPCs release receptor magnitude of AER's
Potential Pathway Exposure route associated COPCs movement
Activity Description Release Human to the exposure route exposure existing
Substances with activity in environmental
Duration environment regulatory
media
0 - very low 1 - negligible controls
0 - very low
0 - very low 1 - uncertain 2 - uncertain
1 - uncertain 0 - very low
1 - uncertain
1 - uncertain
Release to groundwater Ingestion X 1 1 1 1 2 8
Solvent
Solvent, additives, Production/injecti Ingestion X 1 0 1 1 2 6
injection
steam, bitumen, on casing failure
1 process -
produced water, with surface
Short Release to surface water
subsurface via groundwater direct contact X 1 0 1 1 2 6
salts casing failure interaction
activities
Inhalation X 1 0 1 1 2 6

Ingestion X 1 0 1 1 2 6
Release to surface water
direct contact X 1 0 1 1 2 6
Solvent
Solvent, additives,
injection Cement, casing, Ingestion X 1 1 1 1 1 4
steam, bitumen, Short or
2 process -
produced water,
or wellhead
intermittent
subsurface failure Direct release to soil direct contact X 1 1 1 1 1 4
salts
activities
Inhalation X 1 1 1 1 1 4

Direct release to air Inhalation X 1 1 1 1 1 4

Solvent Release to groundwater Ingestion X 1 1 1 1 2 8

Solvent, additives, Caprock fracture
injection Ingestion X 1 1 1 1 2 8
steam, bitumen, (e.g., slow Short or
3 process -
produced water, release of fluid to intermittent
Release to surface water
subsurface via groundwater direct contact X 1 1 1 1 2 8
salts the surface) interaction
activities Inhalation X 1 1 1 1 2 8
Release to groundwater Ingestion X 1 1 1 1 1 4
Ingestion X 1 1 1 1 1 4
Release to surface water
via groundwater direct contact X 1 1 1 1 1 4
Caprock and interaction
Solvent Inhalation X 1 1 1 1 1 4
Solvent, additives, Overlying
injection
steam, bitumen, Formation Ingestion X 1 1 1 1 1 4
4 process -
produced water, Fracture (e.g.,
Short
Direct release to surface
subsurface direct contact X 1 1 1 1 1 4
salts Total Joslyn water
activities
incident) Inhalation X 1 1 1 1 1 4
Inhalation X 1 0 1 1 2 6
Direct release to air
Deposition to soil X 1 0 1 1 2 6

Solvent Release to Groundwater Ingestion X 1 1 1 1 1 4

Solvent, additives, Lateral loss of Short,
injection Ingestion X 1 1 1 1 1 4
steam, bitumen, solvent to highly intermittent,
5 process -
produced water, mobile water in or
Release to Surface water
subsurface via Groundwater direct contact X 1 1 1 1 1 4
salts the reservoir continuous interaction
activities Inhalation X 1 1 1 1 1 4
Disposal / Solvent, residual Loss of disposal Short or Indirect release to surface
6 Strat. Testing / hydrocarbons, zone intermittent water (long migration
Ingestion X 1 1 1 1 2 8

Risk Assessment of Solvent Injection Processes 19

 Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #3:
Factor #2: Risk Score
Factor #1: Potential
Potential failure Factor #4: Factor #5: without
Potential transport
pathway for Potential Potential considering
Potential Transport Potential COPCs mechanism for
NO. Expected COPCs release receptor magnitude of AER's
Potential Pathway Exposure route associated COPCs movement
Activity Description Release Human to the exposure route exposure existing
Substances with activity in environmental
Duration environment regulatory
media
0 - very low 1 - negligible controls
0 - very low
0 - very low 1 - uncertain 2 - uncertain
1 - uncertain 0 - very low
1 - uncertain
1 - uncertain
legacy wells produced Water, containment pathway)
salts direct contact X 1 1 1 1 2 8

enters Release to groundwater Ingestion X 1 1 1 1 1 4

Solvent, residual stratigraphic
Disposal / Ingestion X 1 1 1 1 1 4
hydrocarbons, testing, disposal, Short or
7 Strat. Testing /
produced Water, or legacy wells intermittent
Release to surface water
legacy wells via groundwater direct contact X 1 1 1 1 1 4
salts with poor cement
interaction
and/or casing
Inhalation X 1 1 1 1 1 4

Ingestion X 1 1 1 1 1 4
Release to surface water
enters direct contact X 1 1 1 1 1 4
Solvent, residual stratigraphic
Disposal /
hydrocarbons, testing, disposal, Short or
8 Strat. Testing /
produced Water, or legacy wells intermittent
Ingestion X 1 1 1 1 1 4
legacy wells
salts with open flow Direct release to soil direct contact X 1 1 1 1 1 4
wellbore
Inhalation X 1 1 1 1 1 4

Solvent Release to Groundwater Ingestion X 1 1 1 1 1 4

Solvent, additives, Lateral loss of Short,
injection
steam, bitumen, solvent to intermittent, Ingestion X 1 1 1 1 1 4
9 process -
produced water, adjacent or or Release to Surface water
subsurface via Groundwater direct contact X 1 1 1 1 1 4
salts underlying zones continuous
activities interaction
Inhalation X 1 1 1 1 1 4

Release to Surface water Ingestion X 1 1 1 1 2 8

(direct or in-direct) direct contact X 1 1 1 1 2 8
Loss of Ingestion X 1 1 1 1 2 8
Chemical containment
10 storage
Additives, solvent
(reportable spill
Short Direct Release to soil direct contact X 1 1 1 1 2 8
or leak) Inhalation X 1 1 1 1 2 8
Direct Release to Air Inhalation X 1 1 1 1 2 8
Release to Groundwater Ingestion X 1 1 1 1 2 8

Release to Surface water Ingestion X 1 1 1 1 2 8

(direct or in-direct) direct contact X 1 1 1 1 2 8
Loss of Ingestion X 1 1 1 1 2 8
Chemical containment Short or
11 storage
Additives, solvent
(non-reportable intermittent
Direct release to soil direct contact X 1 1 1 1 2 8
spill or leak) Inhalation X 1 1 1 1 2 8
Direct release to air Inhalation X 1 1 1 1 2 8
Release to groundwater Ingestion X 1 1 1 1 2 8

Release to surface water Ingestion X 1 1 1 1 2 8

Loss of (direct or in-direct) direct contact X 1 1 1 1 2 8
Ground Additives, diluent, containment on
12 transportation disposal fluid/solid lease (reportable
Short Ingestion X 1 1 1 1 2 8
spill or leak) Direct release to soil direct contact X 1 1 1 1 2 8
Inhalation X 1 1 1 1 2 8

20 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #3:
Factor #2: Risk Score
Factor #1: Potential
Potential failure Factor #4: Factor #5: without
Potential transport
pathway for Potential Potential considering
Potential Transport Potential COPCs mechanism for
NO. Expected COPCs release receptor magnitude of AER's
Potential Pathway Exposure route associated COPCs movement
Activity Description Release Human to the exposure route exposure existing
Substances with activity in environmental
Duration environment regulatory
media
0 - very low 1 - negligible controls
0 - very low
0 - very low 1 - uncertain 2 - uncertain
1 - uncertain 0 - very low
1 - uncertain
1 - uncertain
Direct release to air Inhalation X 1 1 1 1 2 8
Release to groundwater Ingestion X 1 1 1 1 2 8

Release to surface water Ingestion X 1 1 1 1 1 4

(direct or in-direct) direct contact X 1 1 1 1 1 4
Loss of
Ingestion X 1 1 1 1 1 4
containment on
Ground Additives, diluent, Short or
13 transportation disposal fluid/solid
lease (non-
intermittent
Direct release to soil direct contact X 1 1 1 1 1 4
reportable spill or
Inhalation X 1 1 1 1 1 4
leak)
Direct release to air Inhalation X 1 1 1 1 1 4
Release to groundwater Ingestion X 1 1 1 1 1 4

Release to surface water Ingestion X 1 1 1 1 2 8

(direct or in-direct) direct contact X 1 1 1 1 2 8
Loss of Ingestion X 1 1 1 1 2 8
Pipeline Steam, diluent, containment
14 transportation dilbit, disposal fluid (reportable spills
Short Direct release to soil direct contact X 1 1 1 1 2 8
or leaks) Inhalation X 1 1 1 1 2 8
Direct release to air Inhalation X 1 1 1 1 2 8
Release to groundwater Ingestion X 1 1 1 1 2 8

Release to surface water Ingestion X 1 1 1 1 2 8

(direct or in-direct) direct contact X 1 1 1 1 2 8
Loss of Ingestion X 1 1 1 1 2 8
Pipeline Steam, diluent, containment Short or
15 transportation dilbit, disposal fluid (non-reportable intermittent Direct release to soil direct contact X 1 1 1 1 2 8
spills and leaks) Inhalation X 1 1 1 1 2 8
Direct release to air Inhalation X 1 1 1 1 2 8
Release to groundwater Ingestion X 1 1 1 1 2 8

Release to Surface water Ingestion X 1 1 1 1 2 8

(direct or in-direct) direct contact X 1 1 1 1 2 8
Produced water, Loss of Ingestion X 1 1 1 1 2 8
Processing diluent, bitumen, containment
16 facility dilbit, water (reportable
Short Direct release to soil direct contact X 1 1 1 1 2 8
treatment chemical incident) Inhalation X 1 1 1 1 2 8
Direct release to air Inhalation X 1 1 1 1 2 8
Release to groundwater Ingestion X 1 1 1 1 2 8

Release to surface water Ingestion X 1 1 1 1 2 8

(direct or in-direct) direct contact X 1 1 1 1 2 8
Produced water, Loss of
Processing diluent, bitumen, containment Short or Ingestion X 1 1 1 1 2 8
17 facility dilbit, water (non-reportable intermittent Direct release to soil direct contact X 1 1 1 1 2 8
treatment chemical spill)
Inhalation X 1 1 1 1 2 8
Direct release to air Inhalation X 1 1 1 1 2 8

Risk Assessment of Solvent Injection Processes 21

 Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #3:
Factor #2: Risk Score
Factor #1: Potential
Potential failure Factor #4: Factor #5: without
Potential transport
pathway for Potential Potential considering
Potential Transport Potential COPCs mechanism for
NO. Expected COPCs release receptor magnitude of AER's
Potential Pathway Exposure route associated COPCs movement
Activity Description Release Human to the exposure route exposure existing
Substances with activity in environmental
Duration environment regulatory
media
0 - very low 1 - negligible controls
0 - very low
0 - very low 1 - uncertain 2 - uncertain
1 - uncertain 0 - very low
1 - uncertain
1 - uncertain
Release to Groundwater Ingestion X 1 1 1 1 2 8

Solvent, flowback
18 Flaring (diluent, formation Upset condition Short Direct release to air Inhalation X 1 1 1 1 2 8
products, additives)

PM2.5, NOx, VOC,

19 Flue stacks
SOx
Emission source Continuous Direct release to air Inhalation X 1 1 1 1 2 8

Produced gas -
hydrocarbon,
20 Venting
VOCs, RSCs;
Upset condition Short Direct release to air Inhalation X 1 1 1 1 2 8
blanket gas

22 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Table B2: Risk Assessment Results – Risk Score Considering AER’s Existing Regulatory Controls

Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #1: Factor #2: Factor #3: Factor #4: Factor #5:
Potential Potential Potential Potential Potential Risk Score
COPCs failure transport receptor magnitude considering
Potential Explanation on the
Potential Transport associated pathway for mechanism for exposure of Exposure AER’s
NO. Expected Exposure effectiveness of AER
Potential Pathway with activity COPCs COPCs route existing
Activity Description Release route Human regulatory instrument
Substances 0 - very low release to the movement in 0 - very low 1 - negligible regulatory
Duration
1 - uncertain environment environmental 1 - uncertain 2 - uncertain controls
0 - very low media
1 - uncertain 0 - very low
1 - uncertain
No groundwater well used
Release to by public; therefore,
Ingestion X 1 1 0 0 1 2
groundwater magnitude of exposure
Solvent, considered as negligible.
Solvent Production
additives,
injection /injection There are setback distances
steam,
1 process -
bitumen,
casing failure Short Ingestion X 1 0 0 0 2 2
between wells and surface
subsurface with surface Release to surface
produced water; therefore, the
activities casing failure water via
water, salts direct contact X 1 0 0 0 2 2 likelihood of release to
groundwater
surface water via
interaction
groundwater interaction is
Inhalation X 1 0 0 0 2 2 considered as very low.

There are setback distances

Ingestion X 1 0 0 0 2 2 between wells and surface
water. Liquid phase solvent
Release to surface are not as likely as methane
water to migrate to surface water.
direct contact X 1 0 0 0 2 2 Therefore, the likelihood of
release to surface water is
very low.
The release would be on
Solvent, Ingestion X 1 1 0 0 1 2 lease and operators own the
Solvent
additives, Cement, lease. Liquid phase solvent
injection
steam, casing, or Short or
2 process -
bitumen, wellhead intermittent Direct release to soil direct contact X 1 1 0 0 1 2 are not as likely as methane
subsurface to migrate to surface water.
produced failure Therefore, the magnitude of
activities
water, salts exposure at off-lease is
Inhalation X 1 1 0 0 1 2
considered as very low.
The release could go off-
lease. However, liquid phase
solvent are not as likely as
Direct release to air Inhalation X 1 1 0 0 1 2 methane to migrate to air.
Therefore, the magnitude of
exposure at off-lease is
considered as very low.
When operators comply with
Release to AER's existing requirements
Ingestion X 1 0 1 0 2 4 (e.g., Directive 86), the
groundwater
likelihood of caprock fracture
is very low. The AER is
Solvent,
Solvent Caprock confident about this control.
additives, Ingestion X 1 0 1 0 2 4
injection fracture (e.g., The likelihood of release to
steam, Short or
3 process -
bitumen,
slow release of
intermittent
groundwater depends on
subsurface fluid to the Release to surface site-specific features. If the
produced water via
activities surface) direct contact X 1 0 1 0 2 4 failure occurred, slow
water, salts groundwater releases of fluid to surface
interaction would be on-lease. Also,
depends on the type of fluid,
Inhalation X 1 0 0 0 1 1 some may not migrate far in
the groundwater.

Risk Assessment of Solvent Injection Processes 23

 Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #1: Factor #2: Factor #3: Factor #4: Factor #5:
Potential Potential Potential Potential Potential Risk Score
COPCs failure transport receptor magnitude considering
Potential Explanation on the
Potential Transport associated pathway for mechanism for exposure of Exposure AER’s
NO. Expected Exposure effectiveness of AER
Potential Pathway with activity COPCs COPCs route existing
Activity Description Release route Human regulatory instrument
Substances 0 - very low release to the movement in 0 - very low 1 - negligible regulatory
Duration
1 - uncertain environment environmental 1 - uncertain 2 - uncertain controls
0 - very low media
1 - uncertain 0 - very low
1 - uncertain
Release to
Ingestion X 1 0 0 0 1 1
groundwater If blow-out occurred,
Release to surface Ingestion X 1 0 1 0 1 2 sediment would be removed.
water via Most of solvent and steam
groundwater direct contact X 1 0 1 0 1 2 would be released to air
interaction Inhalation X 1 0 1 0 1 2 instead of groundwater or
Ingestion X 1 0 1 0 1 2 surface water. Therefore,
Direct release to the magnitude of exposure
direct contact X 1 0 1 0 1 2 is considered as very low.
surface water
Inhalation X 1 0 1 0 1 2
Solvent, Caprock and
Solvent
additives, Overlying If a blow-out occurred,
injection
steam, Formation
4 process -
bitumen, Fracture (e.g.,
Short sediment would be removed.
subsurface Most of solvent and steam
produced Total Joslyn Inhalation X 1 0 1 0 2 4 would be released to air.
activities
water, salts incident) However, the likelihood of a
blow-out is considered as
very low if operators fully
Direct release to air
comply with AER's
requirements (Directive 086
for shallow area and
Deposition to Directive 023 for non-
X 1 0 1 0 2 4 shallow area). The AER is
soil
confident about these
controls.

Release to Fluid could escape into non-

Ingestion X 1 0 0 0 1 1 saline groundwater if
Groundwater
reservoir is directly
connected to a non-saline
Solvent, aquifer. However, the
Solvent Lateral loss of Short Ingestion X 1 0 0 0 1 1
additives, likelihood of reservoir is
injection solvent to
steam, directly connected to a non-
5 process -
bitumen,
highly mobile Intermittent
saline aquifer is considered
subsurface water in the Release to Surface
produced water via as very low if operators fully
activities reservoir continuous direct contact X 1 0 0 0 1 1
water, salts Groundwater comply with AER’s
interaction requirements (Directive
023). The magnitude of
exposure is also considered
Inhalation X 1 0 0 0 1 1
as very low.

First, AER will only allow

certain type of substances
Ingestion X 1 0 0 0 1 1 be disposed. Second,
Solvent,
operators are required to
Disposal / residual Loss of Indirect release to
Short or monitor the pathway to
6 Strat. Testing / hydrocarbons disposal zone intermittent
surface water (long
ensure there is no loss of
legacy wells , Produced containment migration pathway)
disposal zone containment.
Water, salts
direct contact X 1 0 0 0 1 1 Therefore, the likelihood and
magnitude of exposure at
off-lease are very low.

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 Alberta Energy Regulator

Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #1: Factor #2: Factor #3: Factor #4: Factor #5:
Potential Potential Potential Potential Potential Risk Score
COPCs failure transport receptor magnitude considering
Potential Explanation on the
Potential Transport associated pathway for mechanism for exposure of Exposure AER’s
NO. Expected Exposure effectiveness of AER
Potential Pathway with activity COPCs COPCs route existing
Activity Description Release route Human regulatory instrument
Substances 0 - very low release to the movement in 0 - very low 1 - negligible regulatory
Duration
1 - uncertain environment environmental 1 - uncertain 2 - uncertain controls
0 - very low media
1 - uncertain 0 - very low
1 - uncertain
Release to First, operators are required
enters Ingestion X 1 0 0 0 1 1
groundwater to check other wells in the
stratigraphic
Solvent, area. Second, the AER
testing,
Disposal / residual Ingestion X 1 0 0 0 1 1 requires setback from legacy
disposal, or Short or
7 strat. testing / hydrocarbons
legacy wells intermittent
Release to surface well. Third, pressure drops
legacy wells , produced water via significantly in other wells.
with poor direct contact X 1 0 0 0 1 1
water, salts groundwater Therefore, the likelihood and
cement and/or
interaction magnitude of exposure is
casing Inhalation X 1 0 0 0 1 1 very low.

Ingestion X 1 0 1 0 1 2 First, operators are required

Release to surface
enters to check other wells in the
water direct contact X 1 0 1 0 1 2
Solvent, stratigraphic area. Second, the AER
Disposal / residual testing, requires setback from legacy
Short or Ingestion X 1 0 0 0 1 1
8 strat. testing / hydrocarbons disposal, or
intermittent
well. Third, pressure drops
legacy wells , produced legacy wells direct contact X 1 0 0 0 1 1 significantly in other wells.
water, salts with open flow Direct release to soil Therefore, the likelihood and
wellbore magnitude of exposure is
Inhalation X 1 0 0 0 1 1
very low.

Release to Fluid could escape into non-

Ingestion X 1 0 0 0 1 1 saline groundwater if
Groundwater
reservoir is directly
connected to a non-saline
Solvent, Ingestion X 1 0 0 0 1 1 aquifer. However, the
Solvent Lateral loss of
additives, Short, likelihood the likelihood of
injection solvent to
steam, intermittent reservoir is directly
9 process -
bitumen,
adjacent or
, or Release to Surface connected to a non-saline
subsurface underlying water via direct contact X 1 0 0 0 1 1
produced continuous aquifer is considered very
activities zones Groundwater
water, salts low if operators fully comply
interaction with AER’s requirements
(Directive 023). The
Inhalation X 1 0 0 0 1 1 magnitude of exposure is
also considered as very low.

Release to Surface Ingestion X 1 1 0 0 1 2

water (direct or in- Spill/leak would be on lease.
direct) direct contact X 1 1 0 0 1 2 Sites are required to have
100 meters setback from
Ingestion X 1 1 0 0 1 2 surface water. For
Loss of
reportable spills/releases,
Chemical Additives, containment Direct Release to soil direct contact X 1 1 0 0 1 2
10 storage solvent (reportable
Short EPEA requires operators to
Inhalation X 1 1 0 0 1 2 report, monitor, and clean
spill or leak)
them up. Therefore, the
Direct Release to Air Inhalation X 1 1 0 0 1 2 magnitude of exposure at
off-lease is considered as
Release to negligible.
Ingestion X 1 1 0 0 1 2
Groundwater
Loss of Spill/leak would be on lease;
Ingestion X 1 1 0 0 1 2
containment Release to Surface and very small volume and
Chemical Additives, Short or
11 storage solvent
(non-
intermittent
water (direct or in- substance. Sites are
reportable spill direct) direct contact X 1 1 0 0 1 2 required to have 100 meters
or leak) setback from surface water.

Risk Assessment of Solvent Injection Processes 25

 Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #1: Factor #2: Factor #3: Factor #4: Factor #5:
Potential Potential Potential Potential Potential Risk Score
COPCs failure transport receptor magnitude considering
Potential Explanation on the
Potential Transport associated pathway for mechanism for exposure of Exposure AER’s
NO. Expected Exposure effectiveness of AER
Potential Pathway with activity COPCs COPCs route existing
Activity Description Release route Human regulatory instrument
Substances 0 - very low release to the movement in 0 - very low 1 - negligible regulatory
Duration
1 - uncertain environment environmental 1 - uncertain 2 - uncertain controls
0 - very low media
1 - uncertain 0 - very low
1 - uncertain
EPEA requires them to
Ingestion X 1 1 0 0 1 2 monitor any release on site
to ensure it is not going off-
Direct release to soil direct contact X 1 1 0 0 1 2 lease. Therefore, the
magnitude of exposure at
off-lease is considered as
Inhalation X 1 1 0 0 1 2 negligible.

It is most likely dispersed to

insignificant concentration.
Direct release to air Inhalation X 1 1 0 0 1 2 Therefore. The magnitude of
exposure at off-lease is
considered as negligible.
No groundwater well used
Release to by public; therefore,
Ingestion X 1 1 0 0 1 2
groundwater magnitude of exposure
considered as negligible.
A spill or leak on lease
Release to surface Ingestion X 1 1 0 0 1 2 would be regulated by AER
water (direct or in- through EPEA. If it is off
direct) lease it is dealt with
direct contact X 1 1 0 0 1 2
provincially. Transportation
containment itself is dealt
Ingestion X 1 1 0 0 1 2 with federally and/or
provincially.
Loss of
Additives, Direct release to soil direct contact X 1 1 0 0 1 2
containment Spill/leak would be on lease;
Ground diluent,
12 transportation disposal
on lease Short and very small volume and
(reportable substance. Sites are
fluid/solid Inhalation X 1 1 0 0 1 2
spill or leak) required to have 100 meters
setback from surface water.
Direct release to air Inhalation X 1 1 0 0 1 2 EPEA requires them to
monitor any release on site
to ensure it is not going off-
lease. Therefore, the
Release to magnitude of exposure at
Ingestion X 1 1 0 0 1 2
groundwater off-lease is considered as
negligible.
A spill or leak on lease
Ingestion X 1 1 0 0 1 2 would be regulated by AER
Release to surface
water (direct or in- through EPEA. If it is off
direct) lease it is dealt with
direct contact X 1 1 0 0 1 2 provincially. Transportation
Loss of containment itself is dealt
Additives,
containment with federally and/or
Ground diluent, Short or
13 transportation disposal
on lease (non-
Intermittent
provincially.
reportable spill Ingestion X 1 1 0 0 1 2
fluid/solid
or leak) Spill/leak would be on lease;
Direct release to soil and very small volume and
substance. Sites are
required to have 100 meters
direct contact X 1 1 0 0 1 2 setback from surface water.
EPEA requires them to

26 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #1: Factor #2: Factor #3: Factor #4: Factor #5:
Potential Potential Potential Potential Potential Risk Score
COPCs failure transport receptor magnitude considering
Potential Explanation on the
Potential Transport associated pathway for mechanism for exposure of Exposure AER’s
NO. Expected Exposure effectiveness of AER
Potential Pathway with activity COPCs COPCs route existing
Activity Description Release route Human regulatory instrument
Substances 0 - very low release to the movement in 0 - very low 1 - negligible regulatory
Duration
1 - uncertain environment environmental 1 - uncertain 2 - uncertain controls
0 - very low media
1 - uncertain 0 - very low
1 - uncertain
monitor any release on site
to ensure it is not going off-
lease. Therefore, the
Inhalation X 1 1 0 0 1 2
magnitude of exposure at
off-lease is considered as
negligible.

It is most likely dispersed to

insignificant concentration.
Direct release to air Inhalation X 1 1 0 0 1 2 Therefore. The magnitude of
exposure at off-lease is
considered as negligible.

No groundwater well used

Release to by public; therefore,
Ingestion X 1 1 0 0 1 2
groundwater magnitude of exposure
considered as negligible.

Ingestion X 1 0 0 1 2 4
Release to surface Pipeline transportation is
water (direct or in- regulated under Directive
direct) 077, Pipeline Act, Water Act,
direct contact X 1 0 0 1 2 4
and other provincial
regulations such as ABSA.

Ingestion X 1 0 0 1 2 4 Although the frequency of

Loss of reportable pipeline spill/leak
Steam,
Pipeline containment is very low, it could release
14 transportation
diluent, dilbit,
(reportable
Short
Direct release to soil direct contact X 1 0 0 1 2 4 large volume of substances
disposal fluid
spills or leaks) if the failure is not detected
and stopped quickly enough.
Inhalation X 1 0 0 1 2 4 Comparing with other failure
events, pipeline spills are
more likely to occur off site.
Direct release to air Inhalation X 1 0 0 1 2 4 Therefore, the magnitude of
exposure is not considered
as negligible.
Release to
Ingestion X 1 0 0 1 2 4
groundwater
Pipeline transportation is
Release to surface Ingestion X 1 1 0 1 1 3 regulated under Directive
water (direct or in- 077, Pipeline Act, Water Act,
direct) and other provincial
direct contact X 1 1 0 1 1 3
Loss of regulations such as ABSA.
containment
Steam,
Pipeline (non- Short or Although the frequency of
15 transportation
diluent, dilbit,
reportable intermittent
Ingestion X 1 1 0 1 1 3
non-reportable pipeline
disposal fluid
spills and spill/leak is higher than
leaks) Direct release to soil reportable spill/leak, the
direct contact X 1 1 0 1 1 3
release volume is most likely
very small. Therefore, the
Inhalation X 1 1 0 1 1 3 magnitude of exposure is
not considered as negligible.

Risk Assessment of Solvent Injection Processes 27

 Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #1: Factor #2: Factor #3: Factor #4: Factor #5:
Potential Potential Potential Potential Potential Risk Score
COPCs failure transport receptor magnitude considering
Potential Explanation on the
Potential Transport associated pathway for mechanism for exposure of Exposure AER’s
NO. Expected Exposure effectiveness of AER
Potential Pathway with activity COPCs COPCs route existing
Activity Description Release route Human regulatory instrument
Substances 0 - very low release to the movement in 0 - very low 1 - negligible regulatory
Duration
1 - uncertain environment environmental 1 - uncertain 2 - uncertain controls
0 - very low media
1 - uncertain 0 - very low
1 - uncertain

Direct release to air Inhalation X 1 1 0 1 1 3

Release to
Ingestion X 1 1 0 1 1 3
groundwater

Release to Surface Ingestion X 1 1 0 0 1 2

water (direct or in-
direct) direct contact X 1 1 0 0 1 2 Spill/leak would be on lease;
and very small volume and
substance. Sites are
Produced Ingestion X 1 1 0 0 1 2 required to have 100 meters
water, diluent, Loss of setback from surface water.
Processing bitumen, containment EPEA requires them to
16 facility dilbit, water (reportable
Short Direct release to soil
direct contact X 1 1 0 0 1 2 monitor any release on site
treatment incident) to ensure it is not going off-
chemical Inhalation X 1 1 0 0 1 2 lease. Therefore, the
magnitude of exposure at
off-lease is considered as
Direct release to air Inhalation X 1 1 0 0 1 2 negligible.

Release to
Ingestion X 1 1 0 0 1 2
groundwater

Ingestion X 1 1 0 0 1 2
Release to surface
water (direct or in- Spill/leak would be on lease;
direct) and very small volume and
direct contact X 1 1 0 0 1 2 substance. Sites are
required to have 100 meters
setback from surface water.
EPEA requires them to
Ingestion X 1 1 0 0 1 2 monitor any release on site
Produced to ensure it is not going off-
Loss of lease. Therefore, the
water, diluent,
containment magnitude of exposure at
Processing bitumen, Short or Direct release to soil
17 facility dilbit, water
(non-
intermittent
direct contact X 1 1 0 0 1 2
off-lease is considered as
reportable negligible.
treatment
spill)
chemical
Inhalation X 1 1 0 0 1 2

It is most likely dispersed to

insignificant concentration.
Direct release to air Inhalation X 1 1 0 0 1 2 Therefore. The magnitude of
exposure is considered as
negligible.

28 Risk Assessment for Solvent Injection Processes

 Alberta Energy Regulator

Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #1: Factor #2: Factor #3: Factor #4: Factor #5:
Potential Potential Potential Potential Potential Risk Score
COPCs failure transport receptor magnitude considering
Potential Explanation on the
Potential Transport associated pathway for mechanism for exposure of Exposure AER’s
NO. Expected Exposure effectiveness of AER
Potential Pathway with activity COPCs COPCs route existing
Activity Description Release route Human regulatory instrument
Substances 0 - very low release to the movement in 0 - very low 1 - negligible regulatory
Duration
1 - uncertain environment environmental 1 - uncertain 2 - uncertain controls
0 - very low media
1 - uncertain 0 - very low
1 - uncertain

No groundwater well used

Release to by public; therefore,
Ingestion X 1 1 0 0 1 2
Groundwater magnitude of exposure
considered as negligible.

The purpose of flaring is to

reduce emissions during
upset condition. These
flaring stacks are designed
and engineered for very high
combustion efficiency.
Operators also conduct
Solvent, dispersion modeling, which
flowback considering all emission
(diluent, Upset sources in the area to
18 Flaring
formation condition
Short Direct release to air Inhalation X 1 1 0 0 1 2
ensure the emission will not
products, exceed Alberta Ambient Air
additives) Quality Objectives, Under
Directive 060, operators are
required to report flaring
over certain time and
conditions. Therefore, the
magnitude of exposure at
off-lease is considered as
negligible.

These flue stacks are

designed and engineered for
very high combustion
efficiency. Operators also
conduct dispersion
modeling, which considering
all emission sources in the
area to ensure the emission
PM2.5, NOx, Emission
19 Flue stacks
VOC, SOx source
Continuous Direct release to air Inhalation X 1 1 0 0 1 2 will not exceed Alberta
Ambient Air Quality
Objectives. EPEA has
requirement on the
concentration and regular
monitoring. Therefore, the
magnitude of exposure at
off-lease is considered as
negligible.

Risk Assessment of Solvent Injection Processes 29

 Potential Failure/Release
Potential Source Receptor Likelihood of Exposure Hazard
Scenarios
Factor #1: Factor #2: Factor #3: Factor #4: Factor #5:
Potential Potential Potential Potential Potential Risk Score
COPCs failure transport receptor magnitude considering
Potential Explanation on the
Potential Transport associated pathway for mechanism for exposure of Exposure AER’s
NO. Expected Exposure effectiveness of AER
Potential Pathway with activity COPCs COPCs route existing
Activity Description Release route Human regulatory instrument
Substances 0 - very low release to the movement in 0 - very low 1 - negligible regulatory
Duration
1 - uncertain environment environmental 1 - uncertain 2 - uncertain controls
0 - very low media
1 - uncertain 0 - very low
1 - uncertain

For high pressure line,

operators are required to
flare the produced gas as
per EPEA. For low pressure
line, produced gas may be
Produced gas vented. However, mass
- majority of all produced gas
Upset
20 Venting hydrocarbon,
condition
Short Direct release to air Inhalation X 1 1 0 0 1 2 will be captured and used
VOCs, RSCs; on-site. Under Directive 060,
blanket gas operators are required to
report venting over certain
time and conditions.
Therefore, the magnitude of
exposure at off-site is
considered as negligible.

30 Risk Assessment for Solvent Injection Processes