Aboriginal Affairs and Northern Development Canada (AANDC) Public - - PowerPoint PPT Presentation

Aboriginal Affairs and Northern Development Canada (AANDC) Public Hearing Presentation

BHP Billiton Diamonds I ncorporated EKATI Mine Water Licence Renewal

Yellowknife, NWT February 12 and 13, 2013

Presentation Overview

• Water Licence Renewal
• SSWQO – Koala and Misery Watershed
• EQC – Koala and Misery Watershed
• Reclamation Security
• Water Licence Terms and Conditions

Water Licence Renewal

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Expiry of existing water licence

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Trigger for review of Terms and Conditions

• Including a review of Effluent Quality Criteria

(EQC)

• Assessment of overall project mitigation

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Assessment of security provisions

SSWQO – Koala and Misery Watersheds

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BHPB has proposed to increase SSWQOs for contaminants of potential concern.

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BHPB has relied upon toxicity modifying factors and toxicity literature to increase the SSWQOs above previously proposed objectives and natural background conditions in the region.

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Effluent discharge has modified hardness levels in the aquatic receiving environment.

SSWQO – Koala and Misery Watersheds

Canadian Council of Ministers of the Environment (CCME) Guidelines State:

“Where water bodies are considered to be of exceptional value, or where they support valuable biological resources, degradation of the existing water quality should always be avoided. Similarly, modification of guidelines to site-specific objectives should not be made on the basis of degraded aquatic ecosystem characteristics that have arisen as a direct negative result of previous human activities.” (CCME, 2007; pp I-7)

SSWQO – Koala and Misery Watersheds

MVLWB - Water and Effluent Quality Management Policy, March 31, 2011 A Key Objective for regulating effluent discharge:

• The amount of waste to be deposited to the receiving

environment is minimized.

Key Considerations for regulating effluent discharge:



Pollution Prevention

The use of processes, practices, materials, products, or energy that avoid or minimize the creation of pollutants and waste and reduce overall risk to human health and the environment.



Discharge

Discharge or deposit of waste into the environment should be employed only as a last resort and must meet EQC.

SSWQO – Koala and Misery Watersheds

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BHPB updated its water quality prediction model for the Koala and Misery watersheds.

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BHPB predicts increases in many contaminants

• f concern over the remainder of mine life.

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BHPB also provided an assessment of buffering capacity within Leslie Lake (Koala) and Cujo Lake (Misery).

SSWQO – Koala and Misery Watersheds

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AANDC is concerned with the projected levels of contaminants of potential concern in mine effluent and downstream environment, particularly within the LLCF and Leslie Lake.

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AANDC is concerned with the total loadings from the LLCF as BHPB is proposing to discharge much higher concentrations of key contaminants.

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AANDC is concerned that defaulting to higher SSWQOs will allow for increased contaminant loadings that will increase the mine’s zone of influence and further degrade the downstream environment.

SSWQO – Koala and Misery Watersheds

Recommendations

AANDC provided a number of recommendations for the Board’s consideration as part of its written intervention. A few key recommendations include:

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Degradation of water quality should be avoided;

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SSWQOs be set based on fixed hardness levels;

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PeSSWQO be set for determined for Chloride and Nitrate;

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Specific Management Response Plans be developed for Chloride and Nitrate; and,

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Slipper Lake should remain within the range of natural variability.

EQC – Koala and Misery Watersheds

• EQC are derived to ensure that SSWQOs are

met at the edge of the initial dilution zone (IDZ).

• EQC are specified as maximum and average

limits.

• EQC should ensure that conditions in the

receiving environment are consistent with EA impact predictions.

EQC – Koala and Misery Watersheds

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Effluent discharge to the receiving environment cannot be acutely toxic.

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Mixing within Leslie and Cujo Lake is limited such that EQC should be set at appropriate levels to limit long-term chronic toxicity in the receiving environment

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Effluent discharge should be regulated to minimize the IDZ and zone of influence (CCME)

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EQC should be set at levels that are reasonably achievable and incorporate best management practices.

EQC – Koala and Misery Watersheds

Recommendations

AANDC provided a number of recommendations for the Board’s consideration as part of its written intervention. A few key recommendations include:

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Open water discharge only;

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EQC be developed for all contaminants of potential concern;

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Maximum grab concentrations should equal SSWQOs (Koala Watershed);

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Loading limits be set for Leslie Lake (Koala Watershed);

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Frequency of effluent monitoring increased (Misery Watershed); and,

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EQCs set to achieve generic CCME-PAL at IDZ boundary (Misery Watershed).

Reclamation Security

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When preparing its estimates, AANDC uses Guiding Principles outlined in the ‘Mine Site Reclamation Policy for the Northwest Territories’ (2002).

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AANDC understands that BHPB has prepared an estimate using the RECLAIM Model.

Reclamation Security

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AANDC has not completed an assessment of the existing reclamation liability.

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AANDC will work with BHPB and the WLWB to determine the security requirements for the Water Licence, as per the recently approved ICRP.

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AANDC requests that specific security provisions be located within a water licence schedule.

Water Licence Terms and Conditions

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BHPB has requested a 8 year term. AANDC does not object to an 8 year term.

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AEMP requirements should be maintained within the appropriate schedule of the renewed water licence, including requirements for a Management Response Plan.

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CRP requirements should also be included in the renewed licence, particularly in relation to a Final CRP.

Water Licence Terms and Conditions

Recommendations

AANDC recommends that the requirements for the AEMP, as

• utlined in the existing water licence, should remain within

the renewed water licence, as they outline the minimum standard for monitoring of project related effects in the receiving environment. AANDC recommends that the provision for an Adaptive Management Plan (Management Response Plan) should be placed in the renewed water licence within the section pertaining to the AEMP. AANDC recommends that the requirements for a Closure and Reclamation Plan, particular in relation to a Final CRP, be included in the renewed water licence.

Closing Comments

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AANDC would like to thank the WLWB for providing the opportunity to present its technical intervention and associated recommendations.

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AANDC acknowledges BHPB for the amount of work that went into this renewal submission.

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AANDC looks forward to working with BHPB and the Board in updating the reclamation security requirements for the Ekati Mine.

Thank You!

Quest st ions? s?