From the Canadian Environmental Assessment Agency to Treasury Metals Inc. re: Information Requests Related to the Environmental Impact Statement Round 2
Cover letter (PDF – 79 KB)
Canadian Environmental Assessment Agency
Ontario Region
55 York Street,
Sulte 600
Toronto ON M5J 1R7
Agence canadienne d'évaluation environnementale
Region de l'Ontario
55, rue York,
bureau 600
Toronto ON MSJ 1R7
July 06, 2018
Sent by E-mail
Mr. Robert MacDonald
Vice president
Treasury Metals Inc.
130 King Street West, Suite 3680
Toronto, ON M5X 1B1
rmacdonald@treasurymetals.com
Dear Mr. MacDonald,
SUBJECT: Outcome of the Technical Review of the response to Information Request #1 of the Goliath Gold Project Environmental Impact Statement
The Canadian Environmental Assessment Agency (the Agency) has completed the technical review of the response to Information Request #1 of the Goliath Gold Project (the Project) Environmental Impact Statement (EIS) documentation from Treasury Metals Inc. (Treasury) and determined that the information provided is insufficient for the purpose of moving forward with the environmental assessment (EA).
To facilitate moving forward with the EA, the Agency has prepared information requests (IRs), contained in this letter and the attached Annex, in consultation with Environment and Climate Change Canada, Natural Resources Canada, Fisheries and Oceans Canada, and Health Canada. The IRs were also informed by comments from provincial Ministries.
The attached IRs (Annex 1) are categorized and sorted by their links to environmental effects that are to be taken into account under section 5 of the Canadian Environmental Assessment Act, 2012 (CEAA 2012), factors to be considered under section 19 of CEAA 2012, and potential adverse impacts of the project on potential or established Aboriginal and treaty rights protected by Section 35 of the Constitution Act, 1982.
Annex 2 of this letter contains recommendations related to regulatory or permitting preparations and actions that Treasury should consider moving forward. The Agency does not require that Treasury respond to the recommendations contained in Annex 2 as part of their response to IR #2.
Please note that IRs related to the human health risk assessment will follow shortly under separate cover (Annex 3). Furthermore, as Indigenous groups were given additional time to provide comments and questions, the Agency expects to submit additional IRs to Treasury, once the comments are received and reviewed (Annex 4).
This letter and all annexes collectively form the second Information Request (IR #2) and are developed based on technical questions arising from the review of Treasury's response to IR #1. In accordance with subsection 23(2) of CEAA 2012, the Agency requires that Treasury submit complete responses to the requests contained in IR #2.
Registry provisions
In accordance with CEAA 2012, comments received and other documents submitted or generated to inform the EA are part of the project file. Accordingly, information submitted to the Agency that is relevant to the EA of the Project is available to the public upon request and may also be posted on the online public registry under reference number 80019. The Agency will remove information, such as home addresses, telephone numbers, email addresses and signatures prior to public disclosure. Should you provide any documents that contain confidential or sensitive information that you believe should not be made public, please contact me directly.
Next Steps
The timeline is stopped as of July 06, 2018 and will not recommence until the Agency reviews the formal submission of the response to the IR #2 and is satisfied that responses are sufficiently complete to proceed with the EA.
As per the Agency's " Operational Policy Statement: Information Requests and Timelines, February 2016 " (https://www.canada.ca/en/environmental-assessment-agency/news/media-room/media-room-2016/information-requests-timelines.html) the Agency will take up to a maximum of 15 days to complete the conformity review of Treasury's response to IR #2 without the timeline for the EA resuming. If the Agency has not come to a conclusion after 15 days, the timeline will resume.
The Agency is willing to meet with Treasury to discuss the path forward and schedule meetings on specific EA thematic areas with all government reviewers, Treasury and their consultants to clarify expectations for the IR responses.
If you have any further questions, please contact me directly at 437-993-2243 or Goliath@ceaa-acee.gc.ca.
Sincerely,
<Original signed by>
Marcelle Phaneuf
Project Manager
Attachments:
Annex 1 – Second Round of Information Requests for the Goliath Gold Project Environmental Impact Statement (IR #2)
Annex 2 – Regulatory Comments and Supplementary Actions for Consideration by the Proponent
ANNEX 1: Second Round of Information Requests for the Goliath Gold Project Environmental Impact Statement (IR #2)
Annex 1 - Second Round of Information Requests for the Goliath Gold Project Environmental Impact Statement (PDF – 771 KB)
Updated July 10, 2018
IR-2 # |
TMI ID |
IR-1 # |
Project Effects Link to CEAA 2012 |
Reference to EIS guidelines |
Reference to EIS (including appendices) |
Context and Rationale |
Specific Question/ Request for Information |
---|---|---|---|---|---|---|---|
IR-2 #: AA(2)-01 |
TMI ID: 25 |
IR-1 #: AA(1)-06 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat 5(1)(a)(iii) Migratory Birds 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions 5(1)(c)(ii) Aboriginal Physical and Cultural Heritage 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Section 8 |
Reference to EIS: Section 3.6.2; Section 4.3.4 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Include the worst-case scenario of a spill from the carbon-in-leach ore processing area in the Accidents and Malfunctions assessment of cyanide releases. Include the following:
B. Provide information on mitigation measures and follow-up program to be implemented to restrict wildlife and migratory birds' access and use of the event pond. C. Review and revise significance determination for the potential risk to wildlife including migratory birds, species at risk, and wildlife of use to Indigenous use (including consumption of wildlife that could access the event pond). |
IR-2 #: AC(2)-01 |
TMI ID: TMI 357 TMI 603 TMI 661 |
IR-1 #: AC(1)-31 AC(1)-276 AC(1)-334 |
Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions 5(1)(c)(ii) Aboriginal Physical and Cultural Heritage 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes 5(1)(c)(iv) any Structure, Site or Thing of Historical, Archaeological, Paleontological or Architectural Significance |
Reference to EIS guidelines: Part 2 Section 11.1 |
Reference to EIS: Section 6.21.5; Table 6.23-20 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide specific, relevant mitigation measures for the following effects to Aboriginal peoples':
B. Describe how these mitigation measures will counteract the possible effects and impacts to Aboriginal peoples. C. Characterize residual effects, if any, after the mitigation measures have been implemented. D. Update the follow-up program for potential effects of changes to the environmental on Aboriginal peoples, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: AC(2)-02 |
TMI ID: TMI 226 TMI 227 TMI 228 TMI 348 TMI 349 TMI 430 TMI 490 TMI 507 |
IR-1 #: HE(1)-33 HE(1)-34 HE(1)-35 AC(1)-22 AC(1)-23 AC(1)-105 AC(1)-164 AC(1)-181 |
Project Effects Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2 Section 10.1.3 |
Reference to EIS: Section 5.13; Section 6. 17; Table 6.1.3.20-1 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide an assessment for socio-economic effects related to harvesting of foods or materials for subsistence consumption or commercial sale (e.g. wild rice, blueberries, animals, timber). Include the following:
B. Characterize residual effects, if any, after the mitigation measures have been implemented. C. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. D. Consider the effects of changes to the environment on socio-economic conditions as part of the cumulative effects assessment. |
IR-2 #: AC(2)-03 |
TMI ID: TMI 1 TMI 407 TMI 485 TMI 496 TMI 558 TMI 561 TMI 564 TMI 578 TMI 581 TMI 660 TMI 674 |
IR-1 #: EA(1)-01 AC(1)-82 AC(1)-159 AC(1)-170 AC(1)-232 AC(1)-235 AC(1)-238 AC(1)252 AC(1)-255 AC(1)-333 AC(1)-346 |
Project Effects Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions 5(1)(c)(ii) Aboriginal Physical and Cultural Heritage 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes 5(1)(c)(iv) any Structure, Site or Thing of Historical, Archaeological, Paleontological or Architectural Significance |
Reference to EIS guidelines: Sections 2.3, 3.4.2, 7.2.1, 7.2.2, 9.1.1, 10.2, 11.2 |
Reference to EIS: Section 6.1.6 |
Context and Rationale:
|
Specific Question/ Request for Information: Provide a rationale for the use of a pan-Aboriginal/disaggregated approach for both the baseline and effects assessment for the effect of changes to the environment on Indigenous peoples' health and socio-economic conditions, physical and cultural heritage, current use of lands and resources for traditional purposes and any structure site or thing that is of historical, archaeological or paleontological significance including a description of how the approach was undertaken. |
IR-2 #: AC(2)-04 |
TMI ID: TMI 11 TMI 369 TMI 536 TMI554 TMI 607 |
IR-1 #: AC(1)-02 AC(1)-43 AC(1)-210 AC(1)-228 AC(1)-280 |
Project Effects Link to CEAA 2012: Choose an item. |
Reference to EIS guidelines: Sections 12.2, 12.3 |
Reference to EIS: Section 8.9.3 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide an opinion as to whether the project will impact potential or established Aboriginal and Treaty rights including those that have not been fully mitigated. |
IR-2 #: AM(2)-01 |
TMI ID: 243 |
IR-1 #: AM(1)-01 |
Project Effects Link to CEAA 2012: 19(1) Accidents and malfunctions |
Reference to EIS guidelines: Part 2, Section 7.1.2 |
Reference to EIS: Section 4 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Describe the conditions under which clean-up or rehabilitation would be considered necessary in the case of spills and releases on or off-site. Include relevant legislated requirements that may apply. B. Identify the extent to which the affected environment will need to be restored and any specific guidelines that would need to be followed. |
IR-2 #: AM(2)-02 |
TMI ID: 245 |
IR-1 #: AM(1)-03 |
Project Effects Link to CEAA 2012: 19(1) Accidents and malfunctions |
Reference to EIS guidelines: Part 2, Section 7.1.2 |
Reference to EIS: Section 4 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Describe the potential environmental effects from the failure of the tailings or effluent pipeline. |
IR-2 #: AM(2)-03 |
TMI ID: 246 |
IR-1 #: AM(1)-04 |
Project Effects Link to CEAA 2012: 19(1) Accidents and malfunctions |
Reference to EIS guidelines: Part 2, Section 7.1.2 |
Reference to EIS: Section 4 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Describe the effects and their duration if particulate materials remobilize with every heavy rainfall or spring freshet in Blackwater Creek following a failure of the tailings storage facility; B. Describe any additional measures required to avoid or mitigate effects associated with the remobilization of particulate material, if necessary; C. Provide a discussion of the response procedures and contingency measures to avoid or mitigate effects due to a tailings storage facility failure to fish and fish habitat on Christie's Island, at Thunder Creek and in Bonny Bay. |
IR-2 #: CE(2)-01 |
TMI ID: 252 |
IR-1 #: CE(1)-02 |
Project Effects Link to CEAA 2012: 19(1) Cumulative effects |
Reference to EIS guidelines: Part 2, Section 12.1.2 |
Reference to EIS: Sections 7.2.2, 7.3.2; Figures 7.3.2-4, 7.3.2-9 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide a comprehensive list of projects with the potential to interact with the valued components identified, including with ungulates and the current use of lands and resources for traditional purposes. Include clear screening criteria and how they were applied. B. Update the cumulative effects assessment as necessary to reflect the potential effects that would result from the inclusion of any additional projects identified. |
IR-2 #: EA(2)-01 |
TMI ID: 6 |
IR-1 #: EA(1)-06 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat 5(1)(a)(iii) Migratory Birds 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions 5(1)(c)(ii) Aboriginal Physical and Cultural Heritage 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Section 11.4 |
Reference to EIS: Section 13 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Create a Follow-up program that concentrates on areas of uncertainty, including but not limited to the following:
B. Review all responses to IRs to inform the Follow-up Program. Pay particular attention to the following IRs: AA(2)-01; WL(2)-03; RG(2)-01; AE(2)-01 to 03; AE(2)-05; AE(2)-06; SW(2)-02; SW(2)-03; SW(2)-05; SW(2)-07; MW(2)-06; MW(2)-11. C. Develop a preliminary Environmental Monitoring Program (separate from the Follow-up Program) that conforms to the requirements of the EIS Guidelines. This program should provide the following information at a conceptual level:
|
IR-2 #: WL(2)-01 |
TMI ID: 145 147 162 |
IR-1 #: WL(1)-02 WL(1)-04 WL(1)-19 AC(1)-216 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat 5(1)(a)(iii) Migratory Birds 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: Sections 5.9.2.1 - 5.9.2.4, Table 5.9.1; Appendix G; Section 9.1.2, Table 9.5, Figures 9.4 -9.7; Appendix R Executive Summary, Section 2.2 |
Context and Rationale: Ecosites
Habitat Classes The habitat classes provided in Table 1 of TMI_145-WL(1)-02 are too general to be applied to wildlife habitat used by migratory birds, species of interest to Indigenous groups or SAR. Specifically:
|
Specific Question/ Request for Information: A. Revise ecosite mapping to ensure it is complete within the local study area (LSA). B. Provide an updated ecosite summary table that includes the Project footprint, regional study area (RSA) and LSA. Provide both the ecosite codes and names, and summarize using broader habitat classes, such as: Habitat Type Habitat Class Upland -Coniferous -Deciduous -Mixedwood -Shrubland -Grassland -Barren Wetland -Marsh -Swamp -Fen -Bog Open Water Disturbed C. Update IR#1 TMI_145-WL(1)-02_Table 3 to include ecosite codes and names, and all project components (including underground workings, disturbed "interstitial" areas, effluent discharge infrastructure and firebreaks). Include a summary table that presents the project components and habitat classes. D. Revise Figure 2b from IR#1 TMI_145-WL(1)-02 to include the Project footprint. Use the updated habitat classes instead of ecosites, and ensure the colour scheme is distinct. E. Revise Table 1 of TMI_147 WL(1)-05 to include the Project footprint, the ecosite codes and names, and subtotals to summarize the values using the suggested habitat classes. F. Present the baseline wildlife (including breeding birds) and vegetation survey information using the revised habitat classes. Amend the following tables:
G. Using the information presented above, justify how the wildlife and vegetation survey efforts appropriately characterize the direct effects of the project within the Project footprint and the indirect effects of the project within the LSA, relative to the RSA. H. Update wildlife habitat and vegetation summaries where appropriate based on the updated habitat classes. I. Provide estimates of the total number of individuals of each migratory bird that will be affected by the project relative to the LSA and RSA. J. Update all VC effect assessment summaries based on the revised Project footprint and where appropriate on the updated ecosite mapping, habitat classes and number of individuals of each species of migratory bird that will be affected. K. Where appropriate, review and revise the proposed mitigation measures and follow-up program associated with the updated valued component effect assessment. |
IR-2 #: WL(2)-02 |
TMI ID: 88 105 146 |
IR-1 #: WL(1)-03 WL(1)-07 RG(1)-17 AC(1)-368 AC(1)-375 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat 5(1)(a)(iii) Migratory Birds 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: Sections 5.9.2.4, 5.9.3, 6.2.1.13, 6.4.1.13, 9.1.2, 9.2.2.3 Appendix R, Figure 3.1 Appendix S, Figure 2.1 Appendix G Appendix S Section 2.2 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Review and update wetland mapping within the Project Study Area (PSA), Local Study Area (LSA) and Zone of Influence (ZOI). Review satellite imagery in the Project footprint, LSA and ZOI to update desktop mapping for wetlands. B. Based on the results of the revised desktop wetland mapping, revise the field survey summaries to ensure all habitat within the PSA, LSA and RSA are adequately assessed. C. If the revised field survey habitat summaries identify gaps in coverage, additional baseline survey information may be needed to assess the effects of Project activities within the PSA, LSA and ZOI. Compare the location of the historic field surveys with the "new" wetland areas to determine areas where survey coverage is inadequate. Additional field surveys for the following valued components (VCs) may be necessary for:
D. Provide updated figures of (a) all wetlands within the LSA and (b) all wetlands within the PSA. Include the following information in each figure:
E. Provide an updated summary table for all wetlands (including wetlands that were not surveyed) within the LSA. F. Revise the effects assessment and the determination of significance of the residual effects on VCs impacted by the loss of wetland habitat caused by project activities, while taking into account:
Include a reassessment of the following effects:
Updated VCs could include migratory birds, species at risk and species of interest to Indigenous groups with wetland habitat (e.g., rusty blackbird, yellowrail, waterfowl, little brown myotis, northern myotis, snapping turtle, moose, beaver and wild rice). G. As required, review and revise the proposed mitigation measures and follow-up programs associated with updates to the determination of significance. |
IR-2 #: WL(2)-03 |
TMI ID: 148 |
IR-1 #: WL(1)-05 AC(1)-124 |
Project Effects Link to CEAA 2012: 5(1)(a)(iii) Migratory Birds 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: Sections 3.7, 6.12, 6.13, 6.21, 6.23, 10.0, 13.0 |
Context and Rationale:
References
|
Specific Question/ Request for Information: A. Clarify the anticipated water quality concentrations for the TSF. B. Review and revise the potential effects to wildlife including migratory birds, flying species at risk (birds and bats), species of interest to Indigenous groups, and consumption of wildlife by Indigenous communities that could access the TSF taking into consideration the response to Question A and the information in the context. C. Describe additional mitigation measures to prevent adverse effects from water in the TSF on wildlife including migratory birds, flying species at risk (birds and bats), and species of interest to Indigenous groups taking the response from Question B into consideration. D. In the follow-up program, include a specific monitoring activity to identify if migratory birds are accessing the TSF. If monitoring identifies use by migratory birds, contingency measures including additional deterrents such as visual and noise disturbances should be implemented. Include this monitoring activity in the response to EA(2)-01. |
IR-2 #: WL(2)-04 |
TMI ID: 152 |
IR-1 #: WL(1)-09 |
Project Effects Link to CEAA 2012: 5(1)(a)(iii) Migratory Birds 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: Section 10 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide details on the monitoring programs that will be used to assess the effectiveness of the mitigation measures in reducing the effects of effluent discharge on wetlands, and conditions that would trigger the reduction or termination of effluent discharge. Include:
B. Consider additional wetlands that may be identified as a result of revised wetland mapping [WL(2)-03] that may be affected by alterations to the flow of Blackwater Creek. |
IR-2 #: WL(2)-05 |
TMI ID: 153 |
IR-1 #: WL(1)-10 |
Project Effects Link to CEAA 2012: Section 19 |
Reference to EIS guidelines: Part 2, Sections 7.1.1, 9.1.2 |
Reference to EIS: Section 6.1.3.11 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide a figure illustrating potential habitat for snapping turtle and potential habitat loss data summary. B. Provide an effects assessment for snapping turtle. Provide the indicators used to assess potential project effects. Use an impact matrix to describe the potential effects, including species at risk (SAR) habitats, for each project phase. C. Describe the mitigation measures to address the potential effects to snapping turtle, ensuring that the measures are consistent with applicable recovery strategies and management plans. D. Describe the residual effects on snapping turtle and their habitat and the significance of those residual effects, based on the Agency's methodology for assessing significance (including the criteria of magnitude, geographic extent, timing, duration, frequency, reversibility, and ecological and social context). E. Describe the monitoring program for snapping turtle, including objectives and any monitoring measures that will be implemented, to verify presence of snapping turtles, effectiveness of mitigation measures. |
IR-2 #: WL(2)-06 |
TMI ID: 134 |
IR-1 #: FH(1)-13 |
Project Effects Link to CEAA 2012: 5(1)(a)(iii) Migratory Birds |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: Section 6.3 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Describe the measures that will be put in place at closure to restrict access for wildlife, in the event that monitoring data indicates that surface water quality in the pit lake exceeds the PWQO or background conditions if background levels exceed the PWQO. B. In the event that no such measures are put in place, describe the potential adverse effects of exposure to contaminated pit lake water to wildlife, including migratory birds, species at risk and species of use to Indigenous groups (e.g., waterfowl, moose). |
IR-2 #: RG(2)-01 |
TMI ID: 8 |
IR-1 #: EA(1)-08 |
Project Effects Link to CEAA 2012: 5(2) Linked to Regulatory Permits/Authorizations (specify which legislation) |
Reference to EIS guidelines: Part 2, Sections 10.1.2, 10.1.3 |
Reference to EIS: Section 14; Appendix II |
Context and Rationale:
|
Specific Question/ Request for Information: A. Drawing from the accounting conducted in response to FFH(2)-02, provide a map that clearly indicates the watercourses that would be overprinted or reduced through a federal authorization, distinguishing those alterations that would be authorized under Section 35 of the Fisheries Act, or through a Schedule 2 amendment under the Metal Mining Effluent Regulations. In the same map, clearly indicate any new habitat that would be created under these authorizations. If TMI has not selected a preferred conceptual offset plan, offsetting measures proposed under any feasible offset habitat option must be shown in this map. B. Provide a table that describes any activities required to overprint or reduce the watercourses shown in the map provided for Question A, and that describes any activities required to construct and maintain each offsetting measure shown in the same map. For example, identify activities necessary for the creation of a new watercourse, such as the removal of vegetation or a wetland in an area, or the building of a trench. C. Identify changes to the environment that may be caused by each of the activities identified in Question B, other than the ones captured under paragraphs 5(1)(a) and 5(1)(b) of CEAA 2012. For example, identify changes to the environment arising from the creation of a new watercourse, which may include changes to water quality and quantity, changes to air quality from emission of particulate matter, loss of terrestrial habitat for particular flora and fauna such as beaver ponds, or loss of riparian areas and wetlands. D. Identify potential effects related to the changes to the environment identified in Question C, including effects to health and socio-economic conditions (including navigation), physical and cultural heritage, and any structure, site or thing that is of historical, archaeological, paleontological or architectural significance, other than the ones captured under paragraph 5(1)(c) of CEAA 2012. E. Identify valued components from the list in Table 6.1.3.21-1 of the revised EIS, other than those already assessed under subsection 5(1) of CEAA 2012, which may be affected by those changes identified in Questions C and D. Examples of valued components to retain may include wetlands, amphibians and reptiles. It is possible that new valued components that are not included in Table 6.1.3.21-1 may need to be considered to capture all effects under subsection 5(2) of CEAA 2012. F. Given the changes to the environment and potential impacts identified in Questions C and D, describe the potential adverse effects, including effects associated with changes to the environment, to each valued component identified in Question E that are directly linked or necessarily incidental to each federal decision, including those that may not have already been identified in the revised EIS. G. Identify the mitigation measures to avoid, reduce or compensate potential adverse effects identified in Question F. H. Characterize the residual adverse effects identified in Question F after applying mitigation measures identified in Question G. I. Describe a follow-up program, including objectives and any monitoring measures, which will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures in Question G, if required. Include the follow-up measures in the overall Follow-Up Program to be prepared in response to IR# EA(2)-01. |
IR-2 #: AE(2)-01 |
TMI ID: 167 |
IR-1 #: AE(1)-05 |
Project Effects Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2, Sections 10.1.3, 11.1 |
Reference to EIS: Section 6.6.4; Appendix J |
Context and Rationale:
|
Specific Question/ Request for Information: A. Include annual concentrations for NO2 in the air quality assessment, by providing the baseline concentrations in Appendix J-2, Table 1, and the maximum predicted concentrations in Section 6.6.4, Tables 6.6.4.1-2, 6.6.4.2-2 and 6.6.4.3-2 of the revised EIS. B. Describe additional mitigation measures that can be applied to reduce NO2 and SO2 concentrations to the new CAAQS levels, in keeping with CAAQS principles of Keeping Clean Areas Clean and Continuous Improvement. C. Update the HHRA to account for the annual concentrations of NO2 predicted through Question A, the new CAAQS thresholds for NO2 and SO2, and the additional mitigation measures identified in Question B. D. Characterize effects to human health from the updated HHRA in Question C. E. If necessary, update the follow-up program for effects to human health, including objectives and any additional monitoring measures that will be implemented to verify the predictions of concentrations of NO2 and SO2. Add these new measures to the overall Follow-Up Program to be prepared in response to IR# EA(2)-01. |
IR-2 #: AE(2)-02 |
TMI ID: 168 |
IR-1 #: AE(1)-06 |
Project Effects Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2, Section 10.1.3. |
Reference to EIS: Appendix J-5 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Indicate the sources and predicted concentrations of diesel particulate matter (DPM) in air as a result of project activities. B. Update the human health risk assessment by providing a quantitative assessment of incremental cancer risk from DPM using the unit risk and inhalation slope factor available from the California Office of Health Hazard Assessment, CalEPA (2015). https://www.arb.ca.gov/toxics/dieseltac/de-fnds.htm C. Propose and describe additional mitigation measures to reduce incremental cancer risk from emissions of DPM. D. Characterize effects to human health from quantitative assessment developed in Question A. E. If necessary, update the follow-up program for effects to human health, including objectives and any additional monitoring measures that will be implemented to verify the predictions of concentrations of DPM. Add these new measures to the overall Follow-Up Program to be prepared in response to IR# EA(2)-01. |
IR-2 #: AE(2)-03 |
TMI ID: 169 |
IR-1 #: AE(1)-07 |
Project Effects Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2, Section 10.1.3 |
Reference to EIS: Section 6.19.1; Section 6.21.4; Appendix J-5 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Based on the project schedule provided in Section 3.2 of the revised EIS, identify the time periods when access to the operations area would be restricted during each phase. Describe the physical means that TMI would use to restrict access to the operations area during each phase. If access to the operations area is allowed during any phase of the Project for traditional use by Indigenous people, respond to questions B-F below. B. Identify and list any new receptor locations in the operations area, where traditional use will be allowed during any phase of the Project. C. Update the air quality assessment to include any locations identified in question B. Where any contaminants are found to exceed federal or provincial criteria, including the new CAAQS for NO2 and SO2, incorporate this into the frequency analysis (in days or in percentage) found in IR# AE(2)-04 Question B. D. Provide and describe additional mitigation measures to reduce concentrations of contaminants at receptor locations identified in question B. E. Update the human health risk assessment to include any new receptors identified in Question B. F. If necessary, update the follow-up program for effects to human health, including objectives and any additional monitoring measures that will be implemented to verify the predictions of concentrations in locations identified in question B. Add these new measures to the overall Follow-Up Program to be prepared in response to IR# EA(2)-01. |
IR-2 #: AE(2)-04 |
TMI ID: 168, 169 |
IR-1 #: AE(1)-06, AE(1)-07 |
Project Effects Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2, Section 10.1.3 |
Reference to EIS: Section 6.6.4; Appendix J-5 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Review total maximum hourly emission rates for the operations phase (Appendix J-5, Table 9) to provide the correct individual sources and the correct total maximum hourly emission rates. If necessary, redo the dispersion modelling based on the correct emission rates. B. Provide a frequency analysis (in days or in percentage) for any pollutants that are predicted to exceed the standards based on cumulative concentrations shown in Appendix J-5, Tables 11, 12 and 13. Describe how meteorological conditions and the season of the year would affect the likelihood of an exceedance. Ensure that this frequency analysis uses new CAAQS standards for NO2 and SO2, as discussed in IR# AE(2)-01. C. Update the human health risk assessment to reflect any changes to the air quality assessment from the responses to Questions A to D. D. If necessary, update the follow-up program for effects to human health, including objectives and any additional monitoring measures that will be implemented to verify the predictions of concentrations in locations within the operations area where access will be allowed during any phase of the Project. Add these new measures to the overall Follow-Up Program to be prepared in response to IR# EA(2)-01. |
IR-2 #: AE(2)-05 |
TMI ID: 163, 164 |
IR-1 #: AE(1)-01, AE(1)-02 |
Project Effects Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2, Section 16 |
Reference to EIS: Section 13.6.3 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Clarify whether the "continuous air monitoring station" will include real-time monitoring for PM10, PM2.5 and NO2, and describe how it will be used to ensure timely mitigation measures are implemented in case of exceedances. B. Discuss whether airborne metals, specifically the ones shown in Table 1 of the response to IR# TMI_163B (arsenic, chromium, manganese, lead), would be collected and analyzed as a portion of total suspended particulates (TSP) collected at the continuous air monitoring station, or provide a clear rationale for not doing so. C. Provide the locations of the dust fall jars mentioned in Section 13.6.3, and specify whether the metals shown in Table 1 of the response to IR# TMI_163B (arsenic, chromium, manganese, lead) would be analyzed within these samples. D. Provide details of additional mitigation measures that could be applied in case that the predictions in the EA are found to not be met. E.Include the information requested in Questions A to D in theoverall Follow-Up Program and Environmental Monitoring Program to be prepared in response to IR# EA(2)-01. |
IR-2 #: AE(2)-06 |
TMI ID: 184 |
IR-1 #: AE(1)-22 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Section 10.1.2
|
Reference to EIS: Section 6.4 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Identify fish-bearing waterbodies adjacent to the open pit or any other locations expected to have blasting activities. B. Include, in the noise and vibration assessment, sensitive points of reception in any waterbody within 500 metres of blasting activities where fish may be located and fish spawning would be expected to occur. C. Update the noise and vibration assessment to include the locations identified in Question A and B, and compare against Fisheries and Oceans Canada Guidelines for blasting (including peak particle velocity and overpressure). D. Clarify how blasting practices could be adjusted if peak particle velocity and overpressure levels identified in Question C are found to exceed Fisheries and Oceans Canada guidelines. E. Provide an assessment of effects on fish and fish habitat as a result of blasting during the Project. F. Describe mitigation measures that would be used to avoid effects on fish and fish habitat from blasting. G. Characterize residual effects on fish and fish habitat that would occur due to vibration from blasting activities. H. Update the follow-up program designed in response to IR# EA(2)-01 to include blasting noise and vibration for receptors related to fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. Identify any monitoring that would be required by Fisheries and Oceans Canada. If follow-up is not required, provide a rationale. |
IR-2 #: AE(2)-07 |
TMI ID: 185, 193 |
IR-1 #: AE(1)-23, AE(1)-31 |
Project Effects Link to CEAA 2012: 5(1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2, Sections 11.1.2, 11.4 |
Reference to EIS: Section 13.4; Appendix H-2, Section 3.2 |
Context and Rationale:
|
Specific Question/ Request for Information: A. At the nearest receptor around the project footprint, discuss potential mitigation measures to reduce annoyance or increase the quality of experience, and what metrics would be used to determine the application of these measures. B. Describe how Indigenous groups would be involved in the development of the noise management plan, and discuss how complaints from Indigenous people related to noise would be managed.
|
IR-2 #: SW(2)-01 |
TMI ID: TMI_108 TMI_115 TMI_117 |
IR-1 #: SW(1)-22 SW(1)-29 SW(1)-31 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2, 10 |
Reference to EIS: Sections 5.8.1 and 5.8.1.3; Appendix JJ, Section 6.3 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Explain how surface water quality results from the 2010/2011 water quality sampling program were incorporated into the baseline surface water quality assessment. B. Provide an assessment of seasonal variation using the data collected in both the 2010/2011 and 2012/2013 sampling programs; C. Update the water quality assessment, if necessary, taking responses from Questions A and B into consideration. D. Revise the effects on fish and fish habitat, if necessary, based on the response from Question C. E. Describe any additional mitigation measures to prevent adverse effects to fish and fish habitat described in the response to Question D, if necessary. F. Characterize residual effects, if any, after the mitigation measures described in the response to Question E have been implemented. G. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: SW(2)-02 |
TMI ID: TMI_093 |
IR-1 #: SW(1)-07 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: Section 3.8.2; Section 13.8.3, Table 13.8.3-1. |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide the predicted residual hydrocarbon concentration in the effluent. B. Provide the threshold concentration for treatment of effluent with residual hydrocarbons, and describe how this will be monitored to determine when to implement treatment. . C. Describe how the effectiveness of the treatment will be monitored, and describe contingency measures to be implemented should the treatment method be found to be ineffective (for example due to fouling of the reverse osmosis membrane). D. Where treatment is not implemented or determined to be ineffective, update the water quality assessment, if needed, based on the response from Questions A and B. E. Describe the effects on fish and fish habitat, if necessary, based on the response from Question D. F. Describe mitigation measures to prevent adverse effects to fish and fish habitat described in the response to Question E, if necessary. G. Characterize residual effects, if any, after the mitigation measures described in the response to Question F have been implemented. H. Update the follow-up program for potential effects to fish and fish habitat, including a monitoring plan for hydrocarbons in the effluent stream, to verify the predictions of effects and evaluate the effectiveness of the proposed reverse osmosis system for treatment of effluent. |
IR-2 #: SW(2)-03 |
TMI ID: TMI_88 |
IR-1 #: SW(1)-02 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: Section 3.8 |
Context and Rationale:
|
Specific Question/ Request for Information: A1. Clarify erosion control and seepage containment measures within the seepage and collection ditches. A2. Provide a description of how the runoff and seepage collection ditches would be lined. B. Confirm whether all of the runoff and seepage collection ditches would be lined. If not, which collection ditches are not lined, and provide a rationale. C. Identify a follow-up program to verify the effectiveness of the liners. Provide contingency measures to be implemented in case the monitoring indicates failure of the lining. |
IR-2 #: SW(2)-04 |
TMI ID: TMI_105 |
IR-1 #: SW(1)-19 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: Section 3.8.8, Table 3.8.8-1; Section 3.8.9, Table 3.8.9-1; Section 6.4.1.8 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide modelled predicted final effluent concentrations for the point of discharge to Blackwater Creek for all parameters found in Table 3.8.8-1 and compare these against the applicable water quality criteria. B. Clarify whether the water quality parameters of the process effluent discharge presented in Table 3.8.8-1 are used to estimate the water quality of seepage from the TSF. Confirm whether the seepage water quality estimate incorporates the potential for acid rock drainage (See IR# MW(2)-01 to MW(2)-03, and MW(2)-06). C. Provide the modelled predicted influent water quality of the open pit from the TSF during decommissioning and abandonment and provide a comparison of modelled concentrations of parameters against the applicable water quality criteria. D. For Questions A and C, describe the effects on fish and fish habitat for modelled water quality parameters that may exceed the applicable water quality criteria. E. Describe mitigation measures, if necessary, to prevent adverse effects on fish and fish habitat identified in the response to Question D. F. Characterize residual effects, if any, after the mitigation measures identified in the response to Question E have been implemented. G. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: SW(2)-05 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2, 10 |
Reference to EIS: Sections 3.7.5, 3.8.5 and 3.6.6.4. |
Context and Rationale:
|
Specific Question/ Request for Information: A. Clarify what portion of the tailings will be kept under water during the operations phase. B: If some exposure of tailings to the atmosphere is anticipated, describe the changes in water quality from ARD, dust, and metal leaching. C. Describe the effects on fish and fish habitat taking responses from Questions A and B into consideration. D. Describe mitigation measures to prevent adverse effects to fish and fish habitat identified in the response to Question C. E. Characterize residual effects, if any, after the mitigation measures described in the response to Question D have been implemented. F. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures within the TSF that will be implemented to verify that water cover is maintained and ARD is not occurring, and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: SW(2)-06 |
TMI ID: TMI_134 TMI_108 |
IR-1 #: FH(1)-13 SW(1)-22 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Sections 9.1.2, 10 |
Reference to EIS: Section 3.8.6, Figure 3.0-1A |
Context and Rationale:
|
Specific Question/ Request for Information: A. Assess the potential for methylmercury production in the wetlands around Blackwater Creek due to elevated sulphate levels in the pit lake water during abandonment, when the pit lake is connected with Blackwater Creek. B. Assess the potential for methylmercury production in the wetlands around the Blackwater Creek due to elevated sulphate levels in seepage from the TSF and/or WRSA during all phases of the Project. C. Update the water quality in Blackwater Creek taking the responses from Questions A and B into account. D. Revise the effects on fish and fish habitat taking responses from Questions A to C into consideration. E. Describe mitigation measures to prevent adverse effects to fish and fish habitat, if necessary. F. Characterize residual effects, if any, after the mitigation measures have been implemented. G. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: SW(2)-07 |
TMI ID: 103 |
IR-1 #: SW(1)-17 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat 5(1)(a)(iii) Migratory Birds 5(1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10 |
Reference to EIS: Sections 6.8.5, 6.15.4.2, 6.15.4.4, 13.3.2, 13.3.4; Appendix JJ, Table 5-9. |
Context and Rationale: Section 6.8.5 states that "Once the pit lake is fully flooded, it is expected that the monitoring of the water quality in the pit lake will continue for a period of time to determine whether additional batch treatment may be required to ensure the water released from the pit lake meets effluent release limits". The Agency understands that the water quality from the pit lake will be monitored against "PWQO, or background if background levels exceed the PWQO", prior to discharge of water from the pit lake to a tributary of Blackwater Creek (Section 13.3.4). However, the frequency, timing, and duration of pit lake water quality monitoring has not been described in Section 6 or Section 13 of the revised EIS or in the responses to IR#1. Table 5-9 of Appendix JJ identifies some metal concentrations (e.g. iron, lead, zinc) in the open pit water for the Long Term Post-Closure phase, which exceed the Canadian Water Quality Guidelines, Provincial Water Quality Objectives (PWQO) or Metal Mining Effluent Regulations (MMER) limits. The Agency is unclear whether water from the open pit would continue to be treated during abandonment should concentrations of metals or other parameters exceed the water quality criteria. In addition, the note at the bottom of Table 5-9 of Appendix JJ states that "Concentrations for chloride, mercury and phosphorus not included due to incomplete source term data". It is unclear what is meant by "incomplete source term data". In Section 13.3.2, the parameters for pit lake and pit lake discharge monitoring are provided. The Agency notes that total and dissolved metals would be analyzed for the pit lake discharge samples but only dissolved metals would be analyzed for the pit lake samples. Total metals should also be analyzed for pit lake samples so that the results can be compared to the water quality criteria to assess the pit lake water quality for potential effects. An understanding of the water quality in the open pit is necessary to assess the effects of the Project on fish and fish habitat, as the pit lake would be connected with Blackwater Creek at the abandonment phase. The water quality of the pit lake and its connection to Blackwater Creek is also important to assess effects on wildlife, including migratory birds, species at risk and species of use to Indigenous groups. As stated in Section 6.15.4.2, "waterfowl and wildlife are attracted to wetlands for foraging and breeding, concentrations of contaminants could constitute an attractive nuisance to such species." The proponent has proposed in Section 6.15.4.4, "new wetlands will be generated around the pit lake." The Agency assumes the pit lake and rehabilitated wetland areas will be accessed by wildlife during the post-closure phase. |
Specific Question/ Request for Information: A. Provide the frequency, timing and duration of monitoring planned for the open pit when it is filled after the operation phase; B. Once the pit lake is fully flooded, should the results of the monitoring show elevated concentrations of metals or other parameters compared to applicable water quality criteria, confirm whether pit lake water will continue to be treated until the concentrations of parameters meet PWQO or background concentrations if background levels are higher than PWQO; C. Clarify what is meant by "incomplete source of data" in Table 5-9 "Estimated Open Pit Water Quality", and include the concentrations of chloride, mercury and phosphorus in the modeled long-term post-closure open pit water quality; D. Update the monitoring program to include an assessment of both total and dissolved metals in pit lake water quality sampling or provide a rationale; E. Provide information on mitigation measures and follow-up program to be implemented to restrict wildlife access and use of the open pit lake if water quality parameters are exceeded. F. Review and revise assessment and significance determination for the potential adverse effects to wildlife including migratory birds, species at risk, and wildlife of use to Indigenous peoples (for the purpose of consumption) that may access the open pit lake. |
IR-2 #: SW(2)-08 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10 |
Reference to EIS: Appendix JJ, Section 5.3.2 |
Context and Rationale: The Agency notes in Section 5.3.1 of Appendix JJ that the water in the pit lake was assumed to be "completely mixed". According to Ministry of Natural Resources and Forestry (MNRF), there is a possibility that the pit lake will become meromictic, stratifying permanently with higher concentrations of dissolved metals in the bottom layer of the lake. The assumption that the pit lake would be fully mixed may overestimate the concentrations of dissolved metals in overflow surface water, but underestimate concentrations in the bottom layer of the pit lake. This may have implications for the seepage predictions from the pit lake, after it is filled. An estimate of the seepage from the pit lake during abandonment, if the pit lake becomes meromictic, is not provided in the revised EIS. This is important for the Agency to understand as seepage from the pit lake after abandonment phase can leak to the surrounding surface water bodies (e.g. Thunder Lake) and affect fish and fish habitat. |
Specific Question/ Request for Information: A. Discuss the potential for the pit lake to become meromictic and permanently stratify. B. In the event that the pit lake becomes meromictic, provide a revised estimate of the water quality of the seepage that is expected to enter the surrounding waterbodies from the pit lake. C. Describe the changes in water quality of the waterbodies surrounding the pit lake at abandonment, taking the responses from Questions A and B into consideration. D. Revise the effects on fish and fish habitat taking the responses from Questions A to C into consideration. E. Describe additional mitigation measures to prevent adverse effects to fish and fish habitat, if necessary, taking the response to Question D into consideration. F. Characterize residual effects, if any, after the mitigation measures described in the response to Question E have been implemented. G. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: FFH(2)-01 |
TMI ID: TMI_014 TMI_132 |
IR-1 #: PD(1)-01 FH(1)-11 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat 5(1)(a)(iii) Migratory Birds 5(2) Linked to Regulatory Permits/Authorizations (specify which legislation) |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10 |
Reference to EIS: Sections 6.14 and 6.15 Appendix Q, S, II TMI_132-FH(1)-11_Table _1 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Taking responses from SG-WL_2 into consideration, provide an estimate of the loss of fish habitat (in m2) for each fish-bearing wetland that will be affected by the Project. B. Provide updated accounting for fish habitat loss taking into consideration the response to Question A for the proposed Conceptual Fish Offsetting Plan. |
IR-2 #: FFH(2)-02 |
TMI ID: TMI_127 |
IR-1 #: FH(1)-06 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat 5(2) Linked to Regulatory Permits/Authorizations (specify which legislation) |
Reference to EIS guidelines: Part 2, Sections 9.1.2, 10 |
Reference to EIS: Appendix II, Sections 4.2 and 4.3; Table 4.1-1; Section 6.0 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide an accounting of the amount of fish habitat impacted by the Project (in m2) for each watercourse/waterbody, and explain how it was calculated. Include in this assessment, the fish habitat loss accounting conducted for fish-bearing wetlands as requested in FFH(2)-01. B. To offset the amount of habitat identified in response to Question A, provide an estimate of the amount of fish habitat for each offsetting option (in m2), and explain how it was calculated, using appropriate figures and rationale. Clarify whether a single or multiple offsetting options would be chosen for the Fish Habitat Offsetting Plan. . C. For Questions A and B, distinguish between what would be considered under section 35 of the Fisheries Act or Schedule 2 of the Metal Mining Effluent Regulations under the Fisheries Act. |
IR-2 #: FFH(2)-03 |
TMI ID: TMI_128 |
IR-1 #: FH(1)-07 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2, 10 |
Reference to EIS: Section 6.14.4.1, 6.14.5; Section 10, Table 10.0-2 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Describe whether Blackwater Creek Tributary 2 diversion is considered among the offset habitat that would be required under Section 35 of the Fisheries Act, or under the Metal Mining Effluent Regulations. Update the response to IR# FFH(2)-02 accordingly. B. Provide an assessment of changes in water quality of the Blackwater Creek Tributary 2 diversion channel, considering its proximity to the TSF and any runoff and seepage from the TSF that may bypass the contact water collection ditches and enter the diversion channel. C. Explain how flooding or overflowing from contact water collection ditches may affect the water quality of Blackwater Creek Tributary 2 diversion and areas downstream of it. D. Provide an assessment of potential effects to the structural integrity of the TSF from establishing a diversion channel in its vicinity. E. Describe the effects on fish and fish habitat taking responses from Questions B and D into consideration. F. Describe mitigation measures to prevent adverse effects to fish and fish habitat taking into consideration the response to Question E, if necessary. F. Characterize residual effects, if any, after the mitigation measures described in the response to Question F have been implemented. G. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: FFH(2)-04 |
TMI ID: TMI_135 |
IR-1 #: FH(1)-14 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2, 10 |
Reference to EIS: Section 6.14.1; Appendix Q; Appendix II |
Context and Rationale:
|
Specific Question/ Request for Information: A. Describe how changes in water temperature due to lack of well-developed riparian vegetation on the new Blackwater Creek Tributary 2 diversion would be mitigated. B. Describe the magnitude and temporal extent of the effect of changes in water temperature on fish and fish habitat in Blackwater Creek Tributary 2 and downstream. C. Describe any additional mitigation measures to prevent adverse effects to fish and fish habitat identified in the response to Question B, if necessary. D. Characterize residual effects, if any, after the mitigation measures identified in the response to Question C have been implemented. E. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: FFH(2)-05 |
TMI ID: TMI_130 |
IR-1 #: FH(1)-07 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10 |
Reference to EIS: Sections 6.14.4.1 -6.14.4.4 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Provide a prediction of the anticipated loss of fish habitat (in m2) in Blackwater Creek, Little Creek, and Hoffstrom's Bay as a result of flow reductions and/or changes in water levels; B. Assess whether reductions in flow and/or changes to water levels would affect the ability of Blackwater Creek, Little Creek, and Hoffstrom's Bay to support stream-resident and small-bodied fish species, and large-bodied species downstream. C. Assess whether the anticipated reductions in stream-resident and small-bodied fish populations in Blackwater Creek, Little Creek, and Hoffstrom's Bay Tributary will result in impacts to large-bodied species downstream. D. Describe mitigation measures to prevent adverse effects to fish and fish habitat taking responses from Questions A to C into consideration; E. Characterize residual effects, if any, after the mitigation measures have been implemented. F. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
IR-2 #: MW(2)-01 |
TMI ID: TMI_053 |
IR-1 #: MW(1)-15 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10. |
Reference to EIS: Appendix JJ, Sections 1.2.3, 2.0, 5.2; Appendix KK, Sections 1.4.2, 3.4 and 4.2. |
Context and Rationale:
|
Specific Question/ Request for Information: A. For both dry and wet TSF cover options, provide an estimate of the length of time required to consolidate the tailings and implement the cover. Include experiences at other mine sites with similar features and characteristics to support the time estimates. B. Assess the potential for acid rock drainage for the time it would take to consolidate the tailings and emplace the cover on the TSF, as requested in Question A. C. Describe the changes in surface water quality due to seepage from the TSF taking the responses from Questions A and B into consideration; D. Describe the effects on fish and fish habitat taking the responses from Questions A to C into consideration; E. Describe mitigation measures to prevent adverse effects to fish and fish habitat, if necessary; F. Characterize residual effects, if any, after the mitigation measures have been implemented; G. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. H. Incorporate the findings of this IR, if applicable, into the revision of seepage water quality assessment requested in IR# MW(2)-06, and revision of groundwater model requested in IR# GW(2)-01. |
IR-2 #: MW(2)-02 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10. |
Reference to EIS: Section 3.5.3; Section 5.1.4; Appendix JJ; Appendix JJ-1 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Indicate whether the intent of the wet cover on the TSF is to completely prevent any ARD, or to reduce the rate of ARD formation. B. Provide a multi-year water cover modelling analysis to substantiate the viability of the wet cover on the TSF using appropriate climate data. All water inputs (e.g. direct precipitation into the TSF) and outputs (e.g. evaporation, snow sublimation, transpiration, seepage) should be clearly identified, quantified and appropriately modelled; C. Assess the potential effects of climate change on long-term viability of the wet cover on the TSF and factor that into the response to Question B; D. Provide a sensitivity analysis that examines the robustness of the system to maintain the water cover in perpetuity. The sensitivity analysis should also examine what conditions, or combination of conditions, will cause the wet cover to fail; E. Update the water quality assessment, if needed, taking the responses from Questions A to D into consideration; F. Describe the effects on fish and fish habitat, if any, taking the response from Question E into consideration; G. Describe additional mitigation measures, including contingency measures that would be in place to mitigate any effects on fish and fish habitat if the wet cover on the TSF is unsuccessful; H. Characterize residual effects, if any, after the mitigation measures have been implemented; I. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. J. Incorporate the findings of this IR, if applicable, into the revision of seepage water quality assessment requested in IR# MW(2)-06, and revision of groundwater model requested in IR# GW(2)-01. |
IR-2 #: MW(2)-03 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10. |
Reference to EIS: Appendix JJ, Section 3.4.2 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Indicate whether the intent of the dry cover on the TSF is to completely prevent any ARD, or to reduce the rate of ARD formation. B: Provide additional details about the design of the dry cover and its potential for long-term success in preventing ARD, including the composition and thickness of the various layers that would be emplaced over the TSF and whether appropriate cover materials are readily available at the Project site. C. Examine all possible causes that may contribute to the failure of the dry cover over the TSF, including erosion, tree root penetration, settling, slumping, frost heave. Discuss the robustness of the dry cover design to those failure modes. D. Update the water quality assessment, if needed, taking the responses from Questions A to C into consideration; E. Describe the effects on fish and fish habitat, if any, taking the response from Question D into consideration; F. Describe additional mitigation measures, including contingency measures that would be in place to mitigate any effects on fish and fish habitat if the dry cover on the TSF is unsuccessful; G. Characterize residual effects, if any, after the mitigation measures have been implemented; H. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. I. Incorporate the findings of this IR, if applicable, into the revision of seepage water quality assessment requested in IR# MW(2)-06, and revision of groundwater model requested in IR# GW(2)-01. |
IR-2 #: MW(2)-04 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10 |
Reference to EIS: Sections 3.16.5 and 3.7.2. |
Context and Rationale:
|
Specific Question/ Request for Information: A. Clarify whether clay would be used underneath the TSF despite the application of a HDPE liner. B. If a clay layer would be used underneath the TSF, indicate how the suitability of the clay to be used for construction of the base of TSF and other project components would be determined. Include details on considerations such as disturbance of the clay, mixing with sands and silts, compaction of the clay, thickness of the clay layer and target hydraulic conductivity to support the analysis. C. If a clay layer would not be used underneath the TSF, describe the efficacy of the HDPE liner in preventing seepage from the TSF leading into the surrounding waterbodies. Assess the potential for degradation of the liner over time, as requested in MW(2)-05, and the implications on seepage should it occur. D. Update the water quality assessment, if needed, taking the responses from Questions A to C into consideration. E. Revise the effects on fish and fish habitat, if needed, taking the response from Question D into consideration. F. Describe additional mitigation measures to prevent adverse effects to fish and fish habitat, if necessary; G. Characterize residual effects, if any, after the mitigation measures have been implemented; H. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. I. Incorporate the findings of this IR, if applicable, into the revision of seepage water quality assessment requested in IR# MW(2)-06, and revision of groundwater model requested in IR# GW(2)-01. |
IR-2 #: MW(2)-05 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10 |
Reference to EIS: Sections 3.5.3, 3.16.5 and 4.0; Appendix M; Appendix M-2 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Reassess the rate of seepage emanating from the TSF based on the design of the TSF for this project, or based on most conservative assumptions (i.e. highest seepage rates). Include in this assessment, a consideration of:
B. Re-run the models, including the groundwater model and the multi-year water cover model (MW(2)-02), based on the assumptions revised in the response to Question A; C. Update the water quality assessment, if needed, taking the responses from Questions A and B into consideration. D. Provide the effects on fish and fish habitat, if any, taking the response from Question C into consideration. E. Describe mitigation measures to prevent adverse effects to fish and fish habitat, if necessary; F. Characterize residual effects, if any, after the mitigation measures have been implemented; G. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. I. Incorporate the findings of this IR, if applicable, into the revision of seepage water quality assessment requested in IR# MW(2)-06, and revision of groundwater model requested in IR# GW(2)-01. |
IR-2 #: MW(2)-06 |
TMI ID: 53 54 |
IR-1 #: MW(1)-15 MW(1)-16 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10. |
Reference to EIS: Appendix K; Appendix M; Appendix JJ, Section 5 |
Context and Rationale: There are a number of uncertainties with the kinetic and static testing conducted to characterize the geochemistry of mine rock and ore on site. Due to these uncertainties, the Agency has identified a number of concerns related to management of mine rock and tailings on site, including the assumptions made in the revised EIS. The Agency notes that these concerns are also tied with the groundwater modelling (See IR# GW(2)-01, GW(2)- 03 and GW(2)- 04), the TSF base and liner (See IR# MW(2)-04 and MW(2)-05) and cover options for the TSF and the WRSA (See IR# MW(2)-01 to 03 and GW(2)-02). A summary of these uncertainties is presented below and a detailed account of each is presented in the subsequent IRs.
1) Waste rock and ore sampling: It is unclear if the mine rock used for geochemistry tests included parameters required for testing of onset of acidic drainage. Also, there appears to be no ore analysis. Therefore the information provided in the revised EIS is insufficient to determine whether the tailings sample used for modelling is representative of tailings that will be produced during the Project (See IR# MW(2)-07). 2) Humidity Cell Tests: The revised EIS indicates that the onset time of acid drainage in tailings in the Humidity Cell Tests (HCTs) was about 60 weeks. However, HCTs were discontinued earlier and prior to the cells reaching equilibrium. Yet the onset time for ARD was assumed to be two years for the water quality assessment. It is unclear how this assumption was drawn (See IR# MW(2)-08). 3) Sulphur Block Model: The sulphur block model was not provided in the revised EIS and it is unclear how it was used to determine mine rock cut-off criteria and to assess the potential for acid rock drainage (See IR# MW(2)-09). 4) Acid base accounting: It is unclear how the high sulphide zones identified in the acid-base accounting (ABA) analysis were considered in the calculation for ARD onset time (See IR# MW(2)-10). Given the concerns raised above, it was also noted that there is no evidence to suggest that a geochemical characterization program would be used throughout the life of the Project. The purpose of such a program would be to detect changes in geochemical behavior through time in advance, while the mine is still operating, which would allow adjustments to be made in the management of mine rock and tailings, including planning for decommissioning and abandonment. The information requested above is important for the Agency to understand the quality of seepage that will be produced from the mine rock and tailings generated as part of the Project, and understand how they can cause changes to water quality of the surrounding waterbodies, and affect fish and fish habitat. |
Specific Question/ Request for Information: A. Update the geochemical characterizations of mine rock and tailings based on the responses to IRs MW(2)-07 to MW(2)-10 and the four areas of uncertainty raised in the "Context and Rationale" column. As these concerns are addressed, consider how they interplay with other IRs related to groundwater modelling (IR# GW(2)-01, GW(2)- 03 and GW(2)- 04), TSF base and liner (IR# MW(2)-04 and MW(2)-05) and cover options for the TSF and WRSA (IR# MW(2)-01 to 03 and GW(2)-02). B. Provide a reassessment of acid rock drainage, and its onset time, based on the revisions requested in Question A. Any assumptions made in the revised assessments should be conservative and tailored to the characteristics of the Project site conditions. Where uncertainties and assumptions are unavoidable, use worst- case scenario for seepage and runoff. C. Describe the changes in water quality from runoff and seepage from the TSF and WRSA that may include acidic water, taking the responses from Questions A and B into consideration. D. Revise the effects on fish and fish habitat taking the response from Question C into consideration; E. Describe additional mitigation measures to prevent adverse effects to fish and fish habitat, if necessary, taking the response to Question D into consideration. F. Characterize residual effects, if any, after the mitigation measures described in Question E have been implemented; H. Update the follow-up program for potential effects to fish and fish habitat, including conceptual details for any further geochemistry testing programs that are planned throughout the life of the Project to address uncertainties, verify previous results and refine options for management of waste rock and tailings. Also provide any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. I. Provide contingency plans for prevention and treatment of runoff and seepage using worst case scenarios, particularly as it relates to acid rock drainage.
|
IR-2 #: MW(2)-07 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10. |
Reference to EIS: Appendix K, Section 2.2; Table 2.1. |
Context and Rationale: Section 2.2 of Appendix K states that "Various rock types in the geological complex include: Biotite Muscovite Schist (BMS), Biotite Schist (BS), Muscovite Sericite Schist (MSS), and Meta-Sediment (MSED). The composition, expected amount in the mine rock, and relative percentage of the total anticipated mine rock for each rock type is summarized in Table 2.1." Table 2.1 of Appendix K of the revised EIS is incomplete as the columns for estimated amount and percent of mine rock for each of the different rock types state "value req." It is further stated in Appendix K, Section 2.2 that "The selection of additional samples was based on the estimated distribution of major rock units and included a total of 112 samples analyzed, of which 52 were BMS, 16 were BS, 35 were MSS and 9 were MSED. The samples were selected to represent potential mine rock only and no ore containing samples were included." It is unclear why ore containing samples were not included in this assessment as ore characterization is required in order to evaluate the potential composition and variability in composition of the tailings. This information is required by the Agency to understand and validate the geochemical testing conducted for the Project and to evaluate the efficacy of the proposed management options for ore, mine rock and tailings that can potentially affect the water quality of fish-bearing waterbodies. |
Specific Question/ Request for Information: A. Provide the missing information in Table 2.1 of Appendix K. Include in the table, spatial distribution and timing of excavation of different rock types and distribution of sulphides and carbonates that may affect proportional exposure in waste rock fines. B. Explain how the geochemical testing was used to characterize ore in order to understand the composition and variability in the tailings, and determine if the tailings samples are representative of the site conditions. C. Incorporate the findings from Questions A and B into the revision of seepage water quality assessment requested in IR# MW(2)-06. |
IR-2 #: MW(2)-08 |
TMI ID: 53 |
IR-1 #: MW(1)-15 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Sections 9.1.2 and 10. |
Reference to EIS: Appendix K, Sections 2.4.1 and 2.4.3. |
Context and Rationale:
It is stated in response to MW(1)-15 and Section 6.3.2.3 of the revised EIS that "The time to acid on-set for waste rock and pit walls in the model was conservatively assumed to be only two years." It is unclear how the onset time of two years can be considered conservative considering that mine rock used for the Humidity Cell Tests (HCTs) "reached acidic conditions (pH values less than 5.5) after approximately 60 weeks" (Appendix K, Section 4.2). Considering that acid rock drainage (ARD) onset took a shorter time in the HCTs than the assumed two years in the revised EIS, the length of time required to implement the cover options, as described in MW(2)-01, becomes a point of consideration.
Furthermore, according to Natural Resources Canada (NRCan), the HCTs were not designed in a manner appropriate to evaluate the Carbonate-Neutralization Potential (CO3-NP) and Carbonate-Neutralization Potential Ratio (CO3-NPR). These values are of importance with regards to their effect on acid rock drainage onset time.". According to NRCan, the humidity cells were often not at equilibrium when discontinued and approximate time to CO3-NP depletion was also not calculated. The rationale for discontinuation of humidity cells prior to reaching equilibrium was not provided in Appendix K. This information is important for the Agency to validate the predictions made for ARD and ARD onset time, and the management options for mine rock and tailings to prevent adverse changes in water quality of fish-bearing waterbodies. |
Specific Question/ Request for Information: A. Revise the assumption made in the revised EIS for the ARD onset time to match the data collected in kinetic testing; B. Provide a rationale for discontinuation of humidity cell tests prior to equilibrium being reached in the cells; C. Incorporate the findings from Questions A and B into the revision of seepage water quality assessment requested in IR# MW(2)-06, and groundwater model requested in IR# GW(2)-01. |
IR-2 #: MW(2)-09 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10. |
Reference to EIS: Appendix K, Section 2.4.4 |
Context and Rationale: Section 2.4.4 of Appendix K of the revised EIS mentions that a Sulphur Block Model was developed "in order to develop an understanding of the distribution of sulphur within the deposit. All available data from exploration drilling between 2008 and 2014 were used in the sulphur block model" to evaluate the "[…] rock volumes with various sulphur contents for use in assessment of mine rock cut-off criteria and water quality assessment, and to refine mine rock management options". However, the details of this model are not provided in Appendix K of the revised EIS. It is also unclear how this model was used in the assessment of mine rock cut-off criteria, water quality assessment and mine rock management options. This information is important for the Agency to gain confidence in the geochemical studies conducted for the Project, and validate the management options considered for mine rock in order to prevent adverse effects on fish-bearing waterbodies. |
Specific Question/ Request for Information: A. Provide the Sulphur Block Model, and describe how it was used in the revised EIS to determine mine rock cut-off criteria and management plans. B. Incorporate the findings from this IR into the revision of seepage water quality assessment requested in IR# MW(2)-06. |
IR-2 #: MW(2)-10 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10. |
Reference to EIS: Appendix K, section 1.4.2 |
Context and Rationale:
Section 1.4.2 of Appendix K of the revised EIS states that "The Main Zone is composed of well-defined pyritic quartz-sericite schist (MSS) separated by less-altered biotite-feldspar schist (BMS). Sulphide mineralisation and local visible gold occurs mainly within the leucocratic bands but occasionally it is localized in the melanocratic bands enriched with biotite and chlorite. The sulphide (mineral) content of the mineralised zone is generally 3 to 5 % but locally is up to 15 % (by volume)". According to Natural Resources Canada (NRCan), high sulphide zones within the deposit that would be processed and subsequently deposited as tailings could lead to rapid unpredicted onset of acidic weathering conditions, reducing the predicted time of onset of acid drainage. It is unclear whether or how this was factored into the assessment of Acid rock drainage (ARD) onset time. This information is important for the Agency to gain confidence in the geochemical studies conducted for the Project, and validate the management options considered for mine rock in order to prevent adverse effects on fish-bearing waterbodies. |
Specific Question/ Request for Information: A. Describe how the high sulphide zones identified in the acid-base accounting (ABA) analysis were considered in the calculation of ARD onset time. B. Incorporate the findings from this IR into the revision of seepage water quality assessment requested in IR# MW(2)-06. |
IR-2 #: MW(2)-11 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Section 9.1.2 and 10. |
Reference to EIS: Appendix JJ, Section 3.5.3, Tables 6-5 to 6-14. |
Context and Rationale:
|
Specific Question/ Request for Information: A. Confirm that the runoff and seepage collection ditches would remain in place during decommissioning and abandonment. If runoff and seepage collection ditches would continue to exist after filling of the open pit, describe where the water collected in these ditches would report to. B. Describe the water quality criteria in the runoff and seepage collection ditches that are expected to be achieved before the ditches are decommissioned. C. Update the changes in water quality expected from runoff and seepage from the TSF and WRSA during decommissioning and abandonment, if necessary, taking the responses from Questions A and B into account. D. Revise the effects on fish and fish habitat taking responses from Questions A to C into consideration. E. Describe additional mitigation measures to prevent adverse effects to fish and fish habitat, if necessary. F. Characterize residual effects, if any, after the mitigation measures have been implemented. G. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions for water quality during decommissioning and abandonment. In addition, evaluate the effectiveness of the proposed mitigation measures and provide contingency measures, if necessary. If follow-up is not required, provide a rationale. |
IR-2 #: GW(2)-01 |
TMI ID: 72 74 75 83 115 |
IR-1 #: GW(1)-09 GW(1)-11 GW(1)-12 GW(1)-20 SW(1)-29 |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.1 and 9.1.2 |
Reference to EIS: |
Context and Rationale: The groundwater model has a number of deficiencies, listed below, which raise uncertainties with the modelling exercise, the outputs of the model, and the effects assessments that incorporate those model outputs. These concerns are also tied with concerns raised in other IRs related to characterization of geochemistry on the site (see IR# MW(2)-06 to MW(2)-10), cover options for TSF and WRSAs (see IR# MW(2)-01 to MW(2)-03 and GW(2)-02), and TSF base and liner (see IR# MW(2)-04 and -05). 1) Recharge for overburden layers Recharge was based on very limited field observations which were conducted during unusually dry years (Appendix M of the revised EIS, Section 3.2 and Figure 9). Recharge rates have important implications for modelling the quantity of seepage. 2) Recharge for waste rock storage area (WRSA) As discussed in IR# GW(2)-02, low values were used for infiltration though the WRSA. Using these low values for infiltration will cause the groundwater model to output a lower amount of seepage. 3) Hydraulic conductivity measurements The hydraulic conductivity measurements as described in Section 5.6.2.2 of the revised EIS do not allow for proper characterization of the overburden layers or the bedrock. In addition, the number of measurements, particularly in key geologic units such as weathered bedrock and the different types of overburden appear to be limited. Furthermore, the data in Table 5.6.2.2-1 of the same section, presenting the hydraulic conductivity values (K) of the overburden layers, indicates either an error in testing or misinterpretation of units 4) Thickness of the overburden It is stated in Appendix M, Section 5.1.1 of the revised EIS that "Model layer 3 corresponds to the weathered Shallow Bedrock unit. This zone was assumed to have a uniform thickness of 7 m". A rationale for this assumption was not provided in the revised EIS. The thickness of the model layers, particularly the upper layers, will have an effect on seepage flow estimates. These layers are also likely to have the greatest potential for interaction with surface water bodies. 5) Porosity estimates There is uncertainty with the assumed porosity of 1% for shallow bedrock in the groundwater model (See IR# GW(2)-03) 6) Particle tracking A particle tracking for the open pit zone of influence was not provided in the EIS and it is unclear how the clay layers that may exist between the tailings storage facility (TSF) and the pit lake may influence the rate of capture of seepage (See IR# GW(2)-04) 7) Sensitivity analyses A sensitivity analysis for the recharge and infiltration from WRSA is not provided in the revised EIS. A sensitivity analysis for the hydraulic conductivity of key geologic units such as the overburden and weathered bedrock also needs to be factored into the groundwater model. Due to the above deficiencies with the groundwater model, the Agency has uncertainty with the seepage assessment conducted for the Project. The seepage calculations should be based on an updated groundwater model that factors the design of the cover for the TSF and WRSA, TSF base and liner, and concerns raised in other IRs regarding characterization of geochemistry of mine rock and ore. This is important for the Agency to understand as seepage from the Project can lead to contamination of surrounding waterbodies and affect the fish and fish habitat. |
Specific Question/ Request for Information: A. Provide an updated groundwater model that addresses all seven of the concerns raised in the "Context and Rationale" for this IR. Incorporate the findings from the IRs # MW(2)-08 and GW(2)-02 to GW(2)-04 in the revision of the model. B. Provide the potential range in seepage volumes (e.g. based on sensitivity analyses) from the TSF and WRSA. Also provide travel times for this seepage to various receptor locations. Include in this assessment, an explanation of how seepage volumes would be expected to flow through various geologic layers. C. Determine the capture efficiency of the seepage collection system, and assess the efficiency based on different ditch depths, and whether efficiency can be improved through the use of additional mitigation measures such as pump-back wells. D. Reassess the changes in water quality from seepage emanating from the TSF and WRSA and an updated groundwater model, taking the responses from Questions A to C into consideration. E. Revise the effects to fish and fish habitat taking the response from Question D into consideration. F. Describe additional mitigation measures to prevent adverse effects to fish and fish habitat, if necessary, taking into consideration the response to Question E. G. Characterize residual effects, if any, after the mitigation measures describes in Question F have been implemented. H. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. I. Incorporate the findings from this IR into the revision of seepage water quality assessment requested in IR# MW(2)-06. |
IR-2 #: GW(2)-02 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10 |
Reference to EIS: Section 2.5.3.2 Table 3.15-1 Appendix M |
Context and Rationale: Insufficient information is provided to substantiate the effects from the uncapped and capped waste rock storage area (WRSA) options provided in the revised EIS. 1. Uncapped WRSA
2. Capped WRSA
|
Specific Question/ Request for Information: A. Reassess the rate of infiltration assumed for uncapped WRSA scenario with consideration of high porosity of mine rock. B. Substantiate the ability of the cap on WRSA to reduce ARD by providing an analysis of the conceptual design and materials that will be used for construction (see IR# MW(2)-04) C: Provide detailed assumptions and calculations, with supporting data and rationale, regarding the rate of ARD generation, infiltration rates, and the amount of time for the WRSA to become sufficiently saturated such that seepage can begin to flow. Use data and information from similar caps that have been implemented in Canada in areas with similar climate and geography to support the assumptions and conclusions about the performance of the cap. D. Describe how the assessment conducted for ARD has taken into consideration that a greater percentage of the mine rock may be PAG. Provide an updated assessment, if necessary. E. Update the water quality assessment taking the responses from Questions A to D into consideration. F. Describe the effects on fish and fish habitat, if any, taking the response from Question E into consideration. G. Describe mitigation measures to prevent adverse effects to fish and fish habitat, if necessary; H. Characterize residual effects, if any, after the mitigation measures have been implemented; I. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. J. Incorporate the findings of this IR, if applicable, into the revision of seepage water quality assessment requested in IR# MW(2)-06, and revision of groundwater model requested in IR# GW(2)-01. |
IR-2 #: GW(2)-03 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2 and 10. |
Reference to EIS: Appendix M; Appendix M-3. |
Context and Rationale: It is stated in Appendix M-2 of Appendix M of the revised EIS that "The average linear velocity of groundwater in the shallow bedrock may be of the order of 2E-06 m/s (~ 0.2 m/d) assuming a hydraulic conductivity of the shallow bedrock of 1E-06 m/s (Table 8, Appendix M), and a kinematic porosity of 0.01. Travel times from the waste rock storage area (WRSA) to Thunder Lake may be expected to be of the order of fifteen years given a flowpath length of about 1 km." There is uncertainty with the assumed porosity, as 1% porosity cannot be deemed a conservative assumption considering that seepage will flow through weathered upper bedrock and the overburden. Section 5.3 of Appendix M mentions that the runoff and seepage collection ditches are "assumed to be 1m wide and 1m deep" surrounding the tailings storage facility (TSF). In Figure 5a of Appendix M, Cross-section A-A' identifies deep overburden to the southwest of the TSF. This deep overburden will likely make the interception of seepage challenging for the seepage collection ditches; it is unclear whether uncertainties with factors like the kinematic porosity, and weathered upper bedrock and overburden have been considered in the design of the seepage collection system. This is important for the Agency to understand as it has implications for seepage quality, flow and travel times, which can ultimately affect the fish and fish habitat in surrounding surface water features. |
Specific Question/ Request for Information: A. Consider a reasonable range of porosity estimates for bedrock and provide an assessment of seepage behavior and travel time for seepage that travels through shallow bedrock and overburden; B. Assess the efficacy of the proposed 1 m deep and wide runoff and seepage collection ditches in areas of deep overburden around the TSF. Also identify other areas that may pose a challenge for seepage collection and propose additional mitigation measures in these areas to capture seepage; C. Incorporate the findings from Questions A and B into the revision of seepage water quality assessment requested in IR# MW(2)-06, and revision of groundwater model requested in IR# GW(2)-01. |
IR-2 #: GW(2)-04 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.1, 9.1.2, 10 |
Reference to EIS: |
Context and Rationale: It is stated in Section 3.3.2 of the revised EIS that "The zone of influence (water table drawdown) will prevent any seepage from the Operations Area to the surrounding environment". The Agency understands that the zone of influence is expected to capture any seepage that may bypass the seepage collection ditches due to the drawdown induced by open pit dewatering. However, Figure 5.5.2-3 shows clay layers that may exist at depth between the TSF and the pit lake. The presence of this clay aquitard across much of the property can limit the influence of the drawdown on layers above the clay aquitard. Additionally, locally high heads at the tailings storage area (TSF) and waste rock storage area (WRSA) will induce a radial outward flow of seepage from the TSF which may intersect topographic lows and discharge locally, regardless of the drawdown, and draw towards the pit lake. Particle tracking figures were not provided for the dewatered pit scenario, which would have supported the claim that uncaptured seepage will be captured by the open pit drawdown. The Agency requires the particle tracking figures for the dewatered pit scenario to substantiate the claim that uncaptured seepage would be captured by the open pit zone of influence, and not result in effects to fish and fish habitat. |
Specific Question/ Request for Information: A. Provide a particle tracking figure for the dewatered pit scenario, and reconsider the conclusion that all of the seepage bypass during the operation phase would be captured by the open pit drawdown force. B. Incorporate the findings of this IR into the revision of seepage water quality assessment requested in IR# MW(2)-06, and revision of groundwater model requested in IR# GW(2)-01. |
IR-2 #: GW(2)-05 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5(1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: Part 2, Sections 9.1.2, 10 |
Reference to EIS: Section 3.16.5 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Describe the purpose of the finger drain that is proposed to be constructed in the existing creek channel that bisects the TSF. B. Provide an assessment of whether the finger drain has the potential to increase seepage from the TSF. If seepage is expected to increase, update the groundwater model and the corresponding surface water quality assessment. C. Describe the effects on fish and fish habitat taking the responses from Questions A and B into consideration. D. Describe mitigation measures to prevent adverse effects to fish and fish habitat, if necessary. E. Characterize residual effects, if any, after the mitigation measures identified in the response to Question D have been implemented. F. Update the follow-up program for potential effects to fish and fish habitat, including objectives and any monitoring measures that will be implemented to verify the predictions of effects and evaluate the effectiveness of the proposed mitigation measures. If follow-up is not required, provide a rationale. |
ANNEX 2 – Clarifications or Recommendation for the Goliath Gold Project Environmental Impact Statement (IR #2)
Annex 2 - Regulatory Comments and Supplementary Actions for Consideration by the Proponent (PDF – 307 KB)
REC # |
TMI ID |
IR-1 # |
Project Effects Link to CEAA 2012 |
Reference to EIS guidelines |
Reference to EIS (including appendices) |
Context and Rationale |
Clarification or Recommendation |
---|---|---|---|---|---|---|---|
REC # REC-01 |
TMI ID: 145 147 162 |
IR-1 #: WL(1)-02 WL(1)-04 WL(1)-19 AC(1)-216 |
Project Effects Link to CEAA 2012: 5 (1)(a)(i) Fish and Fish Habitat 5 (1)(a)(iii) Migratory Birds 5 (1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Section 9.1.2 |
Reference to EIS: EIS Section 5.9.2.1 - 5.9.2.4, Table 5.9.1; Appendix G Section 9.1.2, Table 9.5, Figures 9.4 -9.7; Appendix R Executive Summary, Section 2.2 |
Context and Rationale:
|
Specific Question/ Request for Information: A. Change the existing footprint of the project to include all project components within the boundary, including but not limited to the following:
B. Update figure 3.1-1A according to the response to Question A. C. Provide a glossary of terms that might be used to refer to the project footprint throughout the revised EIS. |
REC # REC-02 |
TMI ID: 172 |
IR-1 #: AE(1)-10 |
Project Effects Link to CEAA 2012: 5 (1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2, Section 10.1.3 |
Reference to EIS: Section 6.21.4, Appendix J-2 |
Context and Rationale: Appendix J-2, Figures 6 to 19 show contour plots from the operations phase, in areas outside of the Property Line. The response to IR# TMI_169C indicates that "for safety and security reasons, access to the operations area would be restricted throughout the active life of the Project." From Figure 6.21.4-1, it appears that access will be allowed in some areas inside of the Property Line throughout the life of the Project, and access to the operations area itself may be allowed during the construction phase (see IR# MARC-AIR-03). Any locations within the Property Line where access will be allowed for traditional use of lands at any phase of the Project must be included in these contour plots, to understand potential effects to human health from air quality. |
Specific Question/ Request for Information: A. Update Figures 6 to 19 of Appendix J-2 to include any areas within the Property Line where access will be allowed during any phase of the Project. It may be necessary to prepare two sets of figures – one for the construction phase, and one for the operations phase. Ensure that any updates from question D of IR# MARC-AIR-03 are incorporated, if necessary. |
REC # REC-03 |
TMI ID: 168 , 169 |
IR-1 #: AE(1)-06, AE(1)-07 |
Project Effects Link to CEAA 2012: 5 (1)(c)(i) Aboriginal Peoples Health/ socio-economic conditions |
Reference to EIS guidelines: Part 2, Section 10.1.3 |
Reference to EIS: Section 6.6.4; Appendix J-5. |
Context and Rationale: Particulate matter is a non-threshold pollutant and can cause health effects at levels below the applicable standard. Receptors will be exposed to elevated particulate matter levels as a result of the proposed project. Therefore, additional mitigation measures should be used to adequately protect human health. PM2.5, PM10, and NO2 should be reduced to as low as reasonably achievable, as these are non-threshold pollutants. The Canada Wide Standards, advocate "keeping clean areas clean" and "continuous improvement" in air quality. |
Specific Question/ Request for Information: As appropriate, when updating the HHRA, note that Health Canada recommends mitigating negative impacts to air quality where exceedances or near-exceedances of air quality objectives and guidelines are anticipated or where potential human health impacts are predicted. |
REC # REC-04 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5 (1)(c)(iii) Current Use of Lands and Resources for traditional purposes |
Reference to EIS guidelines: Part 2, Section 10.1.2, Section 10.1.3 |
Reference to EIS: Figure 6: .5.4-3 |
Context and Rationale: Figure 6: .5.4-3 of the revised EIS is illegible and does not include a legend. It is unclear what the orange portion in the middle of the operations area conveys. The Agency would like to confirm whether the orange portion represents the area where light trespass is predicted to be above zero, as this would correspond to the comment in Section 6.5.4 of the revised EIS, which states that "based on the modelling, it is highly unlikely that light originating from the Project site would, or could, be measurable beyond the property boundaries." |
Context and Rationale: A. Provide a new figure 6.5.4-3 with a clear legend. B. Clarify whether the orange portion on the map represents the area where light trespass is predicted to be above zero |
REC # REC-05 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5 (1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: 10.1.2 |
Reference to EIS: |
Context and Rationale: The proponent has not provided a detailed effluent plume delineation model. A model of the estimated effluent plume delineation is needed to allow for a complete understanding of the anticipated changes the project may cause to the environment. The effluent plume delineation model is needed to inform the Environmental Effects Monitoring (EEM) program in the Metal and Diamond Mining Effluent Regulations (MDMER). Under the MDMER, the extent of the one percent effluent plume is used to determine if a mine is required under EEM to conduct a fish survey and/or a benthic invertebrate community survey downstream of the Mine's final discharge point. If the one percent effluent plume is less than one percent at 250 metres downstream, then a fish survey is not required under the MDMER. If the one percent effluent plume is less than one percent at 100 metres downstream, then a benthic invertebrate community survey is not required under the MDMER. Modeling the extent of the one percent effluent plume in the EA stage is useful to show the expected extent of the Exposure Area for EEM studies to be conducted under the MDMER. |
Specific Question/ Request for Information: Provide a detailed effluent plume delineation model to estimate the effluent concentration in Blackwater Creek downstream of the final discharge point. Describe the modelled extent of the 1% effluent plume. |
REC # REC-06 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: Choose an item. |
Reference to EIS guidelines: |
Reference to EIS: Appendix Q page13 Appendix II page 6 |
Context and Rationale: Various spots in the EIS and appendices make reference to Wabigoon lake designated as a Specially Designated Water (SDW)in FMZ5. As of recently, SDW have been eliminated. |
Specific Question/ Request for Information: Please remove the references to Wabigoon Lake designated as a Specially Designated Water. |
REC # REC-07 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5 (1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: 9.1.2 Biophysical Environment, Terrestrial Environment-Geology and Geochemistry, Acid Rock Drainage and Metal Leaching |
Reference to EIS: Appendix K: Geochemistry Evaluation Section 1.4.2 P1-4 |
Context and Rationale: The Main Zone is composed of well-defined pyritic quartz-sericite schist (MSS) separated by less-altered biotite-feldspar schist (BMS). Sulphide mineralisation and local visible gold occurs mainly within the leucocratic bands but occasionally it is localized in the melanocratic bands enriched with biotite and chlorite. The sulphide (mineral) content of the mineralised zone is generally 3 to 5 % but locally is up to 15 % (by volume). High sulphide zones within the deposit that will be processed and subsequently deposited as tailings could lead to rapid unpredicted onset of acidic weathering conditions, reducing the predicted time of onset of acid drainage. Additional information is required to understand these potential risks and determine if the proponent's plans to mitigate them will be effective. |
Specific Question/ Request for Information: Given the risk of rapid unpredicted onset of acid weathering conditions, NRCan recommends that the proponent should provide a plan that includes tailings desulphurization of the top layer of the tailings most prone to sulphide oxidation so that acid drainage onset is limited until they can apply a dry cover during closure. If the proponent does not consider this a viable option, the proponent must explain how they intend to ensure that the tailings will not become acid generating prior to emplacement of a dry cover during closure. |
REC # REC-08 |
TMI ID: n/a |
IR-1 #: n/a |
Project Effects Link to CEAA 2012: 5 (1)(a)(i) Fish and Fish Habitat |
Reference to EIS guidelines: EIS Guidelines 5.1 - Water Resources - groundwater |
Reference to EIS: EIS Section 5.6 Page PDF 47 |
Context and Rationale: The proponent does not provide sufficient information about the distribution of the hydrogeological model units. To ensure the model methodology is clear, and in order for NRCan to ensure validity of the model, a number of maps need to be added. This information is important, because it will make it easier to determine the relationships between the units in the model. These relationships between units in the model have an impact on flow and transport, and thus the model results and on understanding the potential environmental effects of the project. |
Specific Question/ Request for Information: NRCan recommends that the proponent should provide the spatial distribution of the thicknesses of the various units of the 3D model on the different maps. The units are Clay, Basal Sand, Sand-Clay/Silt-Sand, Sand and Gravel, Shallow Bedrock, Intermediate Bedrock, and Deep Bedrock. For each of the maps, overlay surface water bodies, private wells and monitoring wells, as well as the mining facilities. |
Document Reference Number: 30