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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
Page 2
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
Page 3
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
Page 5
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.
Page 6
Water QualityDischarge Criteria – Tail Lake and 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.
Page 7
Water QualityDischarge Criteria – Tail Lake and Doris Creek
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.
Page 8
Water QualityDischarge Criteria – Tail Lake and Doris Creek
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.
Page 9
Water QualityDischarge Criteria – Tail Lake and Doris Creek
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
Page 10
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.
Page 11
Water QualityAquatic Effects Monitoring Program (AEMP)
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.
Page 12
Water QualityAquatic Effects Monitoring Program (AEMP)
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
Page 13
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.
Page 14
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.
Page 15
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.
Page 17
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
Page 18
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.
Page 19
Dioxins and Furans
• Product of incomplete combustion– Organic matter + chlorine
• Incineration of MSW is the largest source
• Persistent in the environment
• Bioaccumulate
• Toxic
Page 21
Environmental Fate -- Aquatic
Air
SoilWater
Sediments
Benthics
Fish
Wet/DryDeposition
Runoff/Erosion
Sedimentation
Ingestion/filtering of contaminated particles
Ingestion
Page 23
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
Page 24
Determined Efforts for Incineration
IncinerationW
aste
Man
agem
ent
Tec
hnol
ogy
Ope
ratio
n
Page 25
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.
Page 26
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
Page 27
Incinerator Operation
• Operator Training– Temperature, types and amount of waste
• Maintenance
• Record keeping
Page 28
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
Page 29
Proponent’s commitments
• Compliance with Canada-wide Standards– Annual stack testing
• Waste segregation program
• Operator training
Page 30
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
Page 31
Open burning
• Only paper products and untreated wood are suitable for open burning.
• Cyanide contaminated wood should not be burn in an open pit.