De Beers Canada Inc. Snap Lake Diamond Mine Water Licence Renewal - - PowerPoint PPT Presentation
De Beers Canada Inc. Snap Lake Diamond Mine Water Licence Renewal - - PowerPoint PPT Presentation
De Beers Canada Inc. Snap Lake Diamond Mine Water Licence Renewal Fisheries and Oceans Canada Intervention December 13-15, 2011 Yellowknife Overview DFOs Mandate DFOs Recommendations Term of Licence Adaptive
Overview
- DFO’s Mandate
- DFO’s Recommendations
– Term of Licence – Adaptive Management Plan – Best Available Technologies – Incorporation of FA Conditions (TDS and DO) – AEMP – Closure
DFO’s Responsibilities
- Management and protection of fish
and marine mammals and their habitats;
- Developing and implementing
policies and programs in support of Canada’s scientific, ecological, social and economic interests in
- ceans and fresh waters.
Recommendations
- The licence term should
be 5-8 years.
- De Beers has proposed
an 8 year term.
Issue: Term of Licence
Recommendation
- An adaptive management/response
framework plan should continue to be required for the Snap Lake Diamond Mine.
- DBCI
seeks guidance from the MVLWB on how to best accomplish incorporating Adaptive Management / Response Framework into the
- perations of the Snap Lake Diamond
Mine.
Issue: Adaptive Management Plan
Recommendations
- To harmonize the FA and WL, we recommend that the
AEMP include:
– monitoring of TDS concentrations in close proximity to fisheries compensatory habitat sites within Snap Lake. – TDS sampling once per month under ice and at least two times per year during open water conditions – Results of TDS monitoring provided in the water quality chapter
- f the AEMP annually, including a plain language summary.
Issue: TDS limits around Fisheries Compensatory Habitat Sites
Recommendations Cont.
– Results of TDS sampling from SNAP 05, 12, 28 and 29 in the monthly SNP report. – Incorporating the intent of Condition 5.6.5 of the Fisheries Act Authorization SC-00-196, into the water licence under adaptive management, where the 350mg/L limit is an action level.
Issue: TDS limits around Fisheries Compensatory Habitat Sites
Recommendations
- DBCI assess
alternative solutions to reduce the TDS concentrations at the source(s).
Issue: TDS limit
De Beers Response
- DBCI agrees with DFO’s
recommendations regarding TDS.
- DBCI has proposed to incorporate
monthly TDS sampling “four times per year under ice”.
- This is acceptable to DFO; this issue
is resolved.
Issue: TDS limits around Fisheries Compensatory Habitat Sites
Recommendations
- To harmonize the FA and WL, we recommends the AEMP
should include: – Dissolved Oxygen (DO) profiles from deep areas in Snap Lake monthly from February through May, throughout the mine life. – monitoring for changes in the deep water benthic invertebrate community in conjunction with DO monitoring.
- Incorporating the intent of condition 5.7.3 of the Fisheries
Act Authorization SC-00-196, into the renewed water licence, as part of the adaptive management response framework.
Issue: Dissolved Oxygen Monitoring
De Beers Response
Issue: Dissolved Oxygen Monitoring
- DBCI agrees with our recommendations regarding
incorporation of DO monitoring into the WL; this issue is resolved.
Recommendation
- Re-evaluation of Best Available Technologies for the
treatment of the effluent should be required in the renewed water licence.
- DBCI maintains that constantly monitoring developments
in technologies is enough.
- DFO continues to recommend that re-evaluation of BATs
should be maintained within the water licence.
Issue: Best Available Technology
Recommendations (Regarding the Update)
We recommend that the AEMP be reviewed, updated and approved by the MVLWB, at an appropriate frequency (3 years).
Issue: Aquatic Effects Monitoring Program
Recommendations (Annual Report)
The Annual AEMP report should:
- show and describe trends over time.
- incorporate a chapter that analyzes the interactions between the
different components within the aquatic ecosystem.
- report against the adaptive management/response framework
action levels approved by the Board.
- Include a more detailed, rigorous report should be provided every
three years.
- Provision of electronic data for both the annual and three year
report.
Issue: Aquatic Effects Monitoring Program
De Beers Response
- De Beers agrees with DFO
recommends regarding the AEMP just discussed. This issue is resolved.
Issue: Aquatic Effects Monitoring Program
Recommendation (Invertebrates)
DFO agrees with DBCI that invertebrates do not need to be sampled for trace metals, provided that the effluent sampled and sediment quality do not show an increase in trace metals. However, if an increase is detected the need for invertebrate sampling should be re-assessed and a recognized sampling protocol should be followed.
Issue: Aquatic Effects Monitoring Program
De Beers Response
- DBCI is of the opinion that the “need for invertebrate
sampling should be re-assessed only if a substantive increase in trace metals is detected in the effluent sampled and sediment quality.”
- DFO maintains that the need to conduct trace metal
analysis of invertebrates should be re-assessed as part
- f the response management framework.
Issue: Aquatic Effects Monitoring Program
Recommendation (Cyanobacteria)
- Microcystin-LR continue to be monitored at an
appropriate frequency (eg. every two weeks).
- DBCI agrees to continue to monitor microcystin-
LR, and is proposing to conduct the sampling monthly.
- This is acceptable to DFO.
Issue: Aquatic Effects Monitoring Program
Recommendation (Chlorophyll-a)
- Chlorophyll-a continue to be monitored.
- DBCI agrees to continue to monitor
Chlorophyll-a; this issue is resolved. Issue: Aquatic Effects Monitoring Program
Recommendation (Fish Community Monitoring)
- To harmonize the FA and WL, we
recommend that standardized fish community assessment methodology (e.g., nordic or BSM protocols) be required as a component within the AEMP.
- DBCI agrees with this
recommendation; this issue is resolved.
Issue: Aquatic Effects Monitoring Program
Recommendation (Special Studies)
- We recommend that the
plume characterization study be included in the conditions for the AEMP in the renewed water licence.
- DBCI agrees with this
recommendation, this issue is resolved.
Issue: Aquatic Effects Monitoring Program
Recommendation (Closure Reclamation Plan)
- DBCI should be required to have an
updated and board approved closure and reclamation plan at various points during mine life, in preparation for final closure.
Issue: Closure
De Beers Response
- DBCI does not agree with our
recommendation but has submitted that “a condition requiring that the Closure and Reclamation Plan be updated at the request of MVLWB” would be acceptable.
- DFO recommends DBCI follow the
Guidelines for Development of Closures and Reclamation Plans for Advanced Mineral Exploration and Mine Sites in the NWT when finalized.
Issue: Closure
Recommendation (Current Standards and Best Practices)
- DFO recommends that
each iteration of the Closure and Reclamation plan should be in accordance with current standards and best practices.
- DBCI agreed to this
recommendation.
Issue: Closure
Recommendation (Closure & Reclamation Plan Components)
Closure measures required by the MVLWB should continue to include
- alternatives. Alternative Closure
Measures should be required in the new condition DBCI has proposed, Part I#3 Issue: Closure
De Beers Response
- DBCI agrees to include
alternatives in the Closure and Reclamation plan.
Issue: Closure
Summary
- DFO has made 17 Recommendations
- DBCI agrees with most of our recommendations