Environment Canada’s Intervention on the Doris North Gold Project Water Licence Application...

Environment Canada’s Intervention on theDoris North Gold Project Water Licence Application

Savanna Levenson/Dave Fox / Anne WilsonEnvironmental Protection Operations Division

August 13 – 15, 2007

Overview

Environment Canada’s presentation will cover the following areas:

• Mandate of Environment Canada (EC)

• Comments and recommendations regarding:– Discharge criteria – Aquatic Effects Monitoring Program (AEMP) – Monitoring of Seepage– Waste Management & Incineration issues

EC’s Mandate

• Department of the Environment Act• Fisheries Act – Pollution Prevention

Provisions• Canadian Environmental Protection Act• Canada-Wide Standards for Mercury

Emissions• Canada-Wide Standards for Dioxins and

Furans

Water Quality

Water QualityDischarge Criteria – Tail Lake and Doris Creek

• Miramar Hope Bay Ltd. (MHBL) predicts that by managing effluent discharge volumes with flows in Doris Creek, water quality below the waterfall can be maintained at or below the Canadian Council of Ministers for the Environment (CCME) Guidelines for the Protection of Freshwater Aquatic Life.

• Two compliance points are proposed:– MMER limits will be met at the end of pipe for Tail Lake;– CCME guidelines will be met at the waterfall in Doris Creek.


• MHBL has proposed to meet criteria for the parameters shown in Table 5.2 of the Revised Monitoring and Follow-up Plan, and to monitor supporting variables shown in Table 3.10 of the Revised Water Licence Application Support Document.

• There are a number of major ion parameters of potential concern which do not have CCME guideline values yet.

• Many of the baseline values for Table 5.2 parameters are considerably lower than CCME levels.


Recommendations:

Doris Creek

• EC recommends that compliance criteria in Doris Creek be set for a slightly broader range of parameters than shown in Table 5.2, with receiving environment targets which are more site-specific.

• In the case of parameters which have baseline concentrations which are substantially below CCME guideline values, (i.e. ammonia, nitrate, nitrite, arsenic, iron, lead, mercury, molybdenum, nickel, silver, thallium and zinc), management objectives should be to maintain those parameters at the lowest possible concentrations in the receiving environment.


Recommendations Cont’d:

• For parameters which do not have CCME guidelines (such as chloride and TDS) it is recommended that MHBL set management targets which will maintain ambient conditions within a reasonable range, to ensure concentrations in the downstream aquatic environment will be protective of aquatic life.

• EC has reconsidered setting a TSS limit in Doris Creek, as the end-of-pipe limit is considered as protective.


Recommendations cont’d:

Tail Lake

• A limit for ammonia in the Tail Lake effluent outflow should be set, and EC recommends this be set at 6 mg/L NH3-N for the Maximum Average Concentration. This value is intended to be consistent with effluent concentrations which will not result in bioassay failure.

• EC also supports the monthly testing for BOD5 and Fecal Coliforms and suggests limits of 15 mg/L BOD5 and 100 CFU/dL for FC

Water QualityAquatic Effects Monitoring Program (AEMP)

• The AEMP has been designed to comply with the MMER Environmental Effects Monitoring (EEM) requirements, but a more comprehensive program is needed to provide enough information to allow adaptive management to be used.

• The timescale outlined in the EEM program and proposed for this project is not suitable for a short 2 year mine life.

• The 2003 monitoring plan which was submitted with the water licence application is also outdated; EC recommends that submission of an updated AEMP be required as a licence condition.


Recommendations:

• EC recommends that the proponent design an AEMP which monitors water quality, sediments, benthic invertebrates, productivity, and fish on an appropriate frequency, with annual reporting of results.

• The program should be designed to capture the extent of seasonal and spatial variability in the aquatic ecosystems, and should utilize appropriate reference sites.

• In addition to meeting the objectives outlined in Section 1.3 of the Monitoring and Follow-Up Plan the AEMP should be sufficiently comprehensive to detect effects which may not have been predicted.


Monitoring Parameter Location Frequency AEMP MMER

Water quality* 1,2,3,4,5 Freshet, mid-summer, fall

2008

2009

2010

Sediment quality** 1,3,5 Every 3 years 2010

Benthic Invertebrates*** 1,2,3,4 Every 2 years 2008 2010

Fish**** 1,2,3,4 Every 3 years 2010

*includes field measurements, physicals, major ions, total metals, nutrients, CN & chl a

**total metals, TN,TP, TC, TOC, PSA

***MMER EEM Guidance, as proposed in Golder 2003 Study Design report

****MMER EEM Guidance, as proposed in Golder 2003 Study Design report

1. Little Roberts Lake

2. Little Roberts Stream

3. Reference Lakes A&B

4. Reference Stream A

5. Roberts Bay

Water QualitySeepage Monitoring

• MHBL proposes annual freshet surveys along areas where blast rock has been used, utilizing field and lab measurements, as appropriate.

• EC supports the tiered approach to monitoring, however a subset of the field measurements should be backed up with laboratory analysis of a seepage sample for the parameters of concern (e.g. ammonia, sulphate, iron, aluminum).

• Given the variability in natural tundra pH values, it would be advisable to add reference sites to the routine surveys.

Water QualityIssue: Seepage Monitoring

Recommendations:

• The annual seepage surveys should include periodic analysis of a limited subset of seepage samples, and routine field monitoring of several reference points which are not subject to mine influences.

Miscellaneous Points

• Under the Surveillance Network Program (SNP) there appears to be duplication between the toxicity and water quality testing proposed at the reclaim pump and at the end of pipe. This should be reviewed and eliminated if appropriate.

• Erosion prevention is an important mitigative measure for all discharges during construction, for example from collection ponds and the sewage outfall. Discharge must be to suitable substrates, and ponding must be prevented, as that can lead to thermal erosion.

Waste Management

Waste Disposal -- Incineration

• Incineration is a waste disposal option at remote facilities

• Reduction in volume of waste through combustion

• Incineration can produce emissions of many toxic contaminants including dioxins and furans

Incineration – Not an AQ Issue

• Incineration is not an Air Quality Issue

• Dominant exposure pathways for incineration contaminants are:

▪ Sediments;▪ Water column; ▪ Vegetation; and▪ Soil.

Dioxins and Furans

• Product of incomplete combustion– Organic matter + chlorine

• Incineration of MSW is the largest source

• Persistent in the environment

• Bioaccumulate

• Toxic

Environmental Fate -- Terrestrial

Air

Vegetation

Animals

Dry Deposition

Ingestion

Environmental Fate -- Aquatic

Air

SoilWater

Sediments

Benthics

Fish

Wet/DryDeposition

Runoff/Erosion

Sedimentation

Ingestion/filtering of contaminated particles

Ingestion

Environmental Fate – Food Chain

CCME Canada-wide Standards

• Canada-wide Standards for Dioxins and Furans• Canada-wide Standards for Mercury Emissions

• CWS focus on:– Emission limits for incineration – Demonstration through:

▪ Determined efforts▪ Stack testing

Determined Efforts for Incineration

IncinerationW

aste

Man

agem

ent

Tec

hnol

ogy

Ope

ratio

n

Waste Management

• Reduce the amount of waste to be incinerated.

• Only food and food contaminated waste should be incinerated.

• Divert non-incineration waste to more appropriate disposal options.

Incineration Technology

• Incinerator must achieve the 3 T’s– Temperature (>1000C)– Time residency (1 to 2 sec)– Turbulence

• Best Available Technology – Dual chamber– Controlled air– Wet Scrubber

Incinerator Operation

• Operator Training– Temperature, types and amount of waste

• Maintenance

• Record keeping

Incineration Management Plan

• Recycling/segregation waste program

• Selection of incineration technology

• Waste audit -- amount and types of waste incinerated

• Operational and maintenance records

• Operator training

• Emission measurements

• Incinerator ash disposal

• Annual Report

Proponent’s commitments

• Compliance with Canada-wide Standards– Annual stack testing

• Waste segregation program

• Operator training

Incineration Recommendations

• Develop an Incineration Management Plan in consultation with EC

• Incinerator ash should be tested to determine appropriate disposal option

• Waste oil should tested for contaminants and only burned in an approve oil burner

Open burning

• Only paper products and untreated wood are suitable for open burning.

• Cyanide contaminated wood should not be burn in an open pit.

Closure

EC thanks the Board for this opportunity EC thanks the Board for this opportunity to present our submission, and would to present our submission, and would

be happy to take any questions.be happy to take any questions.

Environment Canada’s Intervention on the Doris North Gold Project Water Licence Application...

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