Report on Government Regulation

We searched past and present legislation to find how the various levels of government mandate the regulation of naphthenic acids in the oil sands. This culminated in a report that is summarized below.

The full report, including all references, can be downloaded in PDF format here.

Report Summary

Minimized environmental impact in oil and gas production is an increasingly important goal for both government and industry. This is the result of society’s growing awareness and concern for environmental degradation. Concern continues to increase due to the ever-expanding scale and production rates of oil sands tailings generation and the resulting increased safety risks to humans and the natural environment. Based on this social pressure, government responds by expanding or developing legislation to create further restrictions to push industry to be more responsible and accountable in regards to environmental impact.

In 2008, Alberta Energy Resources Conservation Board’s (ERCB) reported that 0.1 cubic meter (m3) of fine tailings is produced with the processing of one tonne of oil sands. After an initial tailings consolidation period of 3 to 5 years, this volume is further condensed to around 0.05 m3 to 0.06 m3 of mature fine tailings. For an average 100,000 barrel-per-day facility, approximately 195,000 tonnes of oil sands are processed, translating to nearly 20,000 m3 of fine tailings per day as the byproduct.

The current industry standard for the analysis of NAs in tailings samples is performed using Fourier Transform Infrared Spectrometer (FTIR). FTIR involves a filtered acidified sample of tailings that is put into a rotarytumbler apparatus, using hexane to extract NAs. The absorbance of the NAs sample is then compared to commercially available NA mixtures of known concentration. This particular quantification method measures the amount of carboxyl groups in the sample. Since the composition of the commercial mixture is not likely to match that of the sample, there remains some bias in the total NA value of the sample. Lab/analysis companies, such as Maxaam Analytics, charge around $200 per sample. This price may vary based on the amount of business supplied by the client, and so would be less for those companies practicing regular testing/analysis. The standard turnaround time is around 5 business days. Below is a table comparing the current industry standard with the proposed biosensor from the University of calgary's 2011 iGEM team.

Component FTIR Biosensor
Instrumentation Specific, expensive, stationary Non-specific, inexpensive, transportable
Location of Analysis Offsite analytics lab On-site trailer/temporary building
Analyst Training Extensive Minimal
Sample Preparation Significant organic extraction process Little to none
Time Required for Results 5 business days Less than 24 hours
Cost $195/sample To be determined, comparatively inexpensive
Accuracy Very accurate To be determined
Quantified molecular group Carboxylic acid groups To be determined

The Use of Synthetic Biology in the Oil Sands

One of the Canadian Environmental Protection Act of 1999’s guiding principles is based on "precautionary principle". The principle, which states that “where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation". Without implying threat or serious consequences from the use of synthetic organisms, it remains that synthetic biology is a relatively new area of science. In particular, considering that by its very nature, the broad-spectrum technology may be employed for an exhaustive number of very specific applications, it is difficult and still controversial to determine the technology as generally safe. Instead, case-by-case assessment of the safe-use of applications may be more logical. As it remains, the overall technology still requires much time and testing to prove its safe-use, and this is an obstacle that could very well have to be overcome even before individual applications are investigated. Since the Government of Canada operates on the precautionary principle, the use of synthetic biology, in this case Sensomonas nastytoxins, within closed industrial facilities (i.e. not physically released to the environment) may continue simultaneously to its impact assessment, so long as a compelling preliminary assessment and competitive cost can be established.