PU PUBL BLIC IC HEARING EARING SNAP AP LAKE KE MINE NE Snap - - PowerPoint PPT Presentation

Snap Lake Mine Closure, Water Licence Renewal (MV2019L2-0004) and Land Use Permit Amendment (MV2017D0032) November 26 and 27, 2019

PU PUBL BLIC IC HEARING EARING SNAP AP LAKE KE MINE NE

PUBLIC LIC PRESEN ENTATION ION

1

• Overview of Application
• Interventions from GNWT and ECCC
• Water Quality Models
• Effluent Quality Criteria, Waste Minimization, Mixing

Zone

• Final Closure and Reclamation Plan
• Monitoring and Management Plans
• Water Licence Conditions
• Security
• Comments from SLEMA
• Summary

OUTL TLINE

OVE VERVIEW VIEW OF OF AP APPLIC PLICATION TION

3

Snap Lake Mine – underground diamond mine, 220 km northeast of Yellowknife

• 2008: Mine opened
• 2015: Mining ceased
• 2016: Extended Care and Maintenance began

(to present)

• 2017: Underground mine flooded
• 2018: Seasonal zero occupancy
• 2019: Submission of water licence renewal

application

REGUL GULATOR ORY HISTOR ORY

4

• Snap Lake Mine is Closing. We need a water licence that

aligns with planned closure re and reclam lamation ation activities ivities

• Water Licence renewal application included:
• Final Closure and Reclamation Plan
• Updated Monitoring and Management Plans
• Updated Security
• Updated Site and Downstream Water Models
• Updated EQC
• Water Licence renewal application ensures:
• Continued monitoring and reporting
• Continued meeting of AEMP benchmarks in Snap Lake and

downstream

• Meeting of the objectives of the Closure plan (Objectives)
• Mechanisms to measure success of closure activities (Criteria)
• Meeting the measures of the EIS
• Ongoing over-site by MVLWB
• Closur

ure e goal: l: To return the site and affected areas around the Mine to technically viable and, where practicable, self- sustaining ecosystems that are compatible with a healthy environment and with human activities.

OVERVIEW EW OF APPLICA CATION TION

TOTAL AL IMAGE GE

North th Pile le Airstrip ip Proc

• cess

ess Plant ant Fuel l Storag rage Water r Mana nageme ment nt Pond nd Camp mp Trea eated ed Water r Disch scharg rge Water r Trea eatme ment nt Plant ant Porta tals ls Emuls lsio ion Plant ant AN Storag rage

7

Tec echnic ical l Sessio sion

• Final Closure and Reclamation Plan based on

MVLWB Guidelines (MVLWB, 2013)

• Closure Objectives: previously approved in the ICRP
• Closure Criteria: refined from previous feedback
• Monitoring will continue in closure and post-closure
• Water management is limited to surface water

~ 2% of the water volumes managed during operations.

• Changes were made in response to review

comments and discussion

• Updated water quantity and quality models
• Updated Effluent Quality Criteria for closure
• Constructed wetlands are not required to meet AEMP

benchmarks.

• Approval of proposed EQC will enable progress of

closure activities and meeting of the closure goal

OVERVIEW EW OF APPLICA CATION TION

8

OVERVIEW EW OF APPLICA CATION TION

2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 Year Sump 3 Sump 5 Post-closure 2 4 6 8 10 12 14 16 18 20 22 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Annual Volume Discharged to Snap Lake (m3) Millions Year

Water Treatment Plant Water Management Pond Underground Mine

Operations Closure ECM

Infor

• rmation

mation Request ests s and d Tec echn hnical ical Worksh shop

• p
• Discharge quantity and quality and protection of the

environment

• Water management has changed substantially

9

Inter erven entio ions

• Proposed Effluent Quality Criteria (EQC) and overall Final Closure Plan aligns with pollution prevention

principle, Fisheries Act

• Measure 1(a) – Fish populations will not be adversely affected with proposed EQC
• Measure 1(d) – Total Dissolved Solids (TDS) in MacKay Lake predicted to remain below acceptable limit
• Capping of the North Pile to meet the requirement of “No active long-term care”

OVERVIEW EW OF APPLICA CATION TION

RESPO ESPONSES NSES TO O INT NTER ERVENT VENTION IONS

WATER TER QU QUAL ALIT ITY Y MO MODELS ELS EF EFFL FLUENT ENT QU QUALIT LITY CRITER RITERIA IA WAS ASTE TE MI MINIMIZA NIMIZATION TION

12 12

• Recommendation GNWT-7
• Site water quality model be updated to include:
• Therma

mal l monitor nitoring ing data

• Sensit

itivit ity analy lyses using SNP 02-02 water quality data in May and June and individual sump water quality data

• De Beers Response
• A thermal

al perform

• rmanc

ance e assessmen ent t report will be part of the geot

• tec

echn hnic ical al inspecti tion

• n report
• The thermal performance assessment report will review and evaluate the thermal condition of the North Pile
• De Beers has used the most repres

esen entat tativ ive e water qualit ality data available for input to the site water quality model

• De Beers does not
• t belie

ieve e that adding ing addit ition ional al conser ervatis atism to the model by assigning SNP 02-02 water quality data to runoff from the North Pile each year in May and June after the North Pile is covered is neces essary

• De Beers expects that interaction of precipitation and processed kimberlite within the North Pile will be limited in May and

June due to freezing of the cover materials and processed kimberlite in contact with the cover

SITE E WATER TER QUALI ALITY MODEL EL: MONITORING ORING DATA

De Beers Intervent entio ion n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.7

13 13

• Recommendation GNWT-10
• The MVLWB set numerical site-spec

pecif ific ic water er qualit lity y objectiv ectives es for total l diss issolv

• lved

ed solid ids and constituent ions of concern for closure and post-closure to ensure compliance with Measure 1 of the Report of EA

• De Beers Response
• De Beers is not proposing an AEMP benchmark for total dissolved solids because:
• De Beers has proposed AEMP bench

chma marks ks for constit ituen uents of total l dissolv

• lved

ed solid lids that are protective of aquatic life (Measure 1a) and drinking water (Measure 1b) and an Acceptable Limit for total dissolved solids at Node 22 to protect traditional uses (Measure 1d)

• Parameter concentrations in Snap Lake are predicted to remain

in below low AEMP bench nchma marks ks and total dissolved solids concentrations at Node 22 in MacKay Lake are predicted to remain below the Acceptable Limit to meet Measure 1d

• The rationale for proposing an AEMP benchmark for total dissolved solids during Operations was that the ionic composition of

water in Snap Lake was expected to remain the same

• During Closure and Post-closure, the ionic

ic compos mposit ition ion of water er in Snap p Lake ke is expec ected to change nge

• Concentrations of total

l dissolv

• lved

ed solid lids in Snap p Lake e are below low the aestheti etic c Canadian ian water er qualit lity y guid ideli eline ne for drinking inking water er

AEMP BENCHMARK CHMARKS: S: TOTAL AL DISSOL SOLVED ED SOLIDS DS

De Beers Intervent entio ion n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.10

14 14

• Recommendation GNWT-8
• The GNWT recommends hardnes

ess-bas ased ed AEMP P benchm hmarks arks be calc lculat lated ed using hardness concentrations in Snap Lake before the Snap Lake Mine began operating and the screening process for parameters of potential concern be updated based on the revised hardness-based AEMP benchmarks

• De Beers Response
• De Beers does not agree with the recommendation from the GNWT for four reasons:
• 1. Hardness adjustment to background is inco

cons nsistent istent with CCME (2007) 7) guid idance nce

• 2. Hardness adjustment to background, as an expression of policy, is inco

cons nsis istent ent with scienc ience

• 3. Uncertainty can be addressed in the model calculations for parameters and their toxicity modifying factors, rather than use of

unrea ealis listic ic hypot

• thetica

ical l scena enarios ios 4.

• 4. Preced

cedent ent in application to other er norther ern n mines es

AEMP BENCHMARK CHMARKS: S: HARDNES ESS S CONCENTRA RATI TIONS

De Beers Intervent entio ion n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.8

15 15

MIXI XING G ZONES ES

De Beers Intervent entio ion n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.6
• Recommendation
• The GNWT recommends (GNWT-6):
• The MVLWB not approve the proposed mixing

ing zones es of 200 metres es for the East and West Influent Storage Ponds. Mixing zone dimensions should be set after plume delineation studies are completed.

• In the interim, the mixing

ing zones es could ld be set at 200 metres es for the existi isting ng dif iffus user er and 100 m for the East and West Influent Storage Ponds

• De Beers Response
• A 200m mixing zone is required.
• De Beers agrees that the size and location of the mixing zone at the diffuser should remain the same (i.e., 200 m)
• De Beers is also proposing 200 m mixing zones for the new discharge locations to the main basin and northwest arm

during Closure and Post-closure

• De Beers does not believe that the assumptions included in the linked models were too conservative

16 16

MIXI XING G ZONES ES

De Beers Intervent entio ion n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.6
• De Beers Response Continued
• The request for 200 m mixing zones for the new discharge locations is in alignment with the guidance from the Mackenzie

Valley Land and Water Board

• The mixing zones are as small as practicable
• The mixing zones will not cause impairment to existing or future uses of Snap Lake
• The mixing zones will not be used as practical pollution prevention practices
• The mixing zones will not impinge on critical habitat or spawning areas
• Conditions within the mixing zones will not cause acute toxicity to aquatic organisms
• The mixing zone will not contain substances that are persistent, or contain concentrations that may result in concerns related to

bioaccumulation, or accumulate toxic substances

• The proposed mixing zones are not expected to restrict the movement or drift of aquatic life in Snap Lake
• Nuisance growths of algae or aquatic weeds will not occur in the mixing zones because Snap Lake has been shown to be a

phosphorus-limited lake

17 17

PARAME AMETER TERS OF POTE TENTIA TIAL CONCERN: ERN: ADDITION TIONAL AL CONSE SERVATI TISM SM

De Beers Intervent entio ion n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.9
• Recommendation GNWT-9
• The screening process to identify parameters of potential concern be updated to include:
• Parameters that do not have

e a toxic icit ity-based ed guid idel eline ine

• Screening agains

inst 75% of AEMP P benchmark k instead of 100% of AEMP benchmarks

• The total petroleum hydrocarbons be retained as a regulated parameter until remediation of the site is complete
• De Beers Response
• Screening process to identify parameters of potential concern has not changed from operations
• The list of AEMP benchmarks has expanded over time
• MVLWB et al. (2017): “Those parameters that are predicted to trend away from background in the receiving environment

and trend toward a Water Quality Objective”

• De Beers removed a level of excessive conservatism from the calculation of EQC. That excessive conservatism had not

been used before (75% AEMP benchmarks) and does not have a scientific justification. De Beers returned to using 100% %

• f the AEMP

MP benchm hmark ark to set EQC as was done during Operations.

• Even with this change, parameter concentrations are predicted to remain

ain below AEMP P benchmarks arks

• Any spill of hydrocarbons would be cleaned up as per De Beers Spill Contingency Plan. Routine, repeated monitoring of

hydrocarbons in effluent discharge is unwarranted.

18 18

PARAME AMETER TERS OF POTE TENTIA TIAL CONCERN: ERN: CLOSURE SURE AND POST-CL CLOSURE OSURE LISTS

De Beers Intervent entio ion n Respons nse e Report

• Appendix C (Response to ECCC), Section 1.2
• Recommendation ECCC-2
• Two separate lists of regulated parameters: one list

t for closure ure and one list for post-clos losur ure

• The list of regulated parameters for closure be the same as the list of regulated parameters in the existing water licence
• De Beers Response
• De Beers has proposed two separate lists of regulated parameters for closure and post-closure
• Closure

ure: total suspended solids, pH, faecal coliforms and nitrate

• Post-closur

losure: e: total suspended solids, pH and nitrate

• De Beers does not
• t agree

ee that t the list of regulat lated ed paramet eter ers for closure ure be the same as the list of regula ulated ed paramet eter ers in the existing ing water r licen ence

• The procedures used to identify parameters of potential concern (i.e., regulated parameters) have not changed
• The difference in the number of parameters of potential concern in closure and post-closure compared to operations is driven by

the much lower volumes of discharge in closure and post-closure

• Parameter concentrations in Snap Lake are predicted to remain below Aquatic Effects Monitoring Program benchmarks
• The regulated parameters must be derived through scientifically sound methods that are appropriate for the activities proposed

19 19

EFFLUENT UENT QUALITY CRI RITERI TERIA: A: UPDATE TE MODELS ELS

De Beers Intervent entio ion n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.10
• Recommendation GNWT-10
• The existing effluent quality criteria remain in the closure and post-closure water licence on an interim basis until the

Proponent has updat ated ed their r models ls and efflue luent nt qualit ality criteria ria report t

• De Beers Response
• Protection of aquatic life and drinking water in Snap Lake will be achieved with the proposed EQC
• Requiring De Beers to meet the existing effluent quality criteria would mean operating the water treatment plant and

reverse osmosis unit until constructed wetlands mature, which is not cost feasible for a closed mine

• The procedur

edures es used to to identify ntify paramet eter ers of pot

• tenti

tial al concern ern and calculat ulate e efflu luen ent t qualit ality criteria eria for the Snap Lake e Mine e have ve not

• t changed

ged from those used and approved throughout operations.

• The difference in the proposed number of parameters of potential concern that require effluent quality criteria in Closure

and Post-closure compared to Operations is driven en by the low

• wer

er vo volum umes es of discha harge rge

20 20

POLLUTI UTION ON PREVENT ENTION ON AND WASTE E MINIMIZA ZATION TION: POLLUTI UTION ON PREVENT ENTION

De Beers Intervent entio ion n Respons nse e Report

• Appendix C (Response to ECCC), Section 1.3
• Recommendation ECCC-3
• Consider treatment options for nitrate during closure to comply with the pollu

luti tion

• n preven

ention ion provisions of the Fisheries Act

• De Beers Response
• The proposed effluent quality criteria for nitrate in closure are complian

liant t with the pollution prevention provisions of the Fisheries Act

• Now that the Mine is entering closure, very little

le, if any new w waste material is being generated

• Loadings of nitrate to Snap Lake are predicted to be lower

er in closure ure and post-clos losure e

• To further minimize nitrate waste, De Beers is suggesting to minimiz

imize e future ure blasting ing activ ivit ity

• Less blasting will be required if the wetlands are not constructed
• The proposed effluent quality criteria for nitrate are below
• w the short-term Canadian water

er qualit lity guid ideline eline

• At the proposed effluent quality criteria for nitrate, nitrate concentrations in Snap Lake are predicted to remain below

low the AEMP P bench chma mark

21 21

POLLUTI UTION ON PREVENT ENTION ON AND WASTE E MINIMIZA ZATION TION: WASTE TE MINIMIZA ZATI TION ON

De Beers Intervent entio ion n Respons nse e Report

• Appendix B (Response to GNWT), Sections 1.5 and 1.10
• Recommendation GNWT-10,5
• The GNWT recommends the MVLWB:
• Minimi

nimize ze the amount unt of waste e that is to be deposited to the receiving environment consistent with the Water and Effluent Quality Management Policy (GNWT-10)

• Consider the cumula

mulativ ive e effec ects of multiple effluent discharge points to Snap Lake before approving multiple effluent discharge points (GNWT-5)

• De Beers Response
• In revising the proposed EQC for nitrate, De Beers has minimized the amount of waste generated on-site by considering:
• The predicted discharge

ge volume mes and conce ncentr ntrations ions to Snap Lake

• The distur

isturbance nce and waste e generated by building constructed wetlands

• The waste

e generated nerated by continuing to operate the water er treatmen ment plant nt and reverse e osmos mosis is unit

• The water quality model results accounted for multiple effluent discharge points to Snap Lake

Closure Design, Goals/Objectives

FINAL NAL CLOSURE OSURE PL PLAN AN

23 23

• Recommendation GNWT-1
• The GNWT recommends the MVLWB require the FCRP and supporting documents be resubmitted for approval post-

issuance of the Water Licence. The MVLWB should ensure e suffic icien ient t revie iew time is available for each of these documents.

• De Beers Response:
• The FCRP was submitted in March of 2019. Comments received have

ve been n addres essed ed throug ugh h the revie iew proces ess.

• The FCRP will be revised and re-submitted to align with this review process.
• Board staff would then comple

lete e a conform

• rmit

ity review prior to approval.

• The entire submission package has undergone substantial review through the water licence renewal process including a

pre-application workshop, a 5 week review period, Technical Sessions and an EQC workshop.

• The core elements of the FCRP have undergo

ergone ne multi tiple le reviews and iterati ation

• ns over the years and are well vetted.

FCRP RP SUBMISS SSION ON: SUFFI FFICIE CIENT REVIEW EW TIME

De Beers Interventio ention n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.1

24 24

• Recommendation GNWT-3
• The GNWT recommends that the following plans are submitted: Final

al Landform

• rm Executi

tion

• n Plan; Tox
• xic

icit ity Testing ing Design ign Plan for the WMP; and, Reclam amati ation

• n Plan

n for the WMP if wetlands are not constructed.

• De Beers Response
• De Beers will include a Final

l Landfor

• rm

m Plan with the revised FCRP.

• A distinct Reclam

lamati ation

• n Plan for the WMP, which is a fairly small component at the mine site, is not necessary. The

reclamation activities for the WMP are best addressed within the FRCP.

• A Tox
• xic

icit ity Testi ting ng Design gn Plan n for the WMP is not necessary. Toxicity testing is included in both the SNP and the AEMP MP. Adding another plan is triplication and adds unwarranted costs on a closure project. Toxicity testing will be conducted at the final point of discharge prior to discharge as is customary in water licence SNP.

FCRP RP SUBMISS SSION ON: SUB UBMISS SSION ON OF ADDIT DITIONAL AL COMPO PONENT ENTS

De Beers Interventio ention n Respons nse e Report

• Appendix B (Response to GNWT), Section 1.2

Water Licence Conditions, Security

MO MONI NITOR ORIN ING G & MA MANA NAGEMEN GEMENT PL PLANS ANS

26 26

• Recommendation from GNWT-11, 12, 13, 14, 18
• retention of existing SNP stations
• the need for Sedimen

entati ation

• n and Erosion

ion Control

• l Plans

ns

• amendment of AEMP

MP to account for underground discharge

• retention of seepage

ge monitoring program throughout closure and assessment of results for post-closure

• Testing of proposed cover material for metals, salts and ARD and approval of results by MVLWB

De Beers Response

• Propos
• sed

ed SNP station

• ns are align

gned ed with the planned activities at site and will ensure robust site water monitoring

• A Sedimen

ent t and Erosion ion Control

• l Plan (SECP)

P) will be incorporated into the North h Pile e Managem gemen ent t Plan n and the Final al Landf dfor

• rm Plan for remainder of site activities.
• De Beers agrees

es to to revise e the AEMP P Design Plan with a characterization of chemistry and volume of water pumped to the underground

• Seepage is collected and monitored in sumps as per the propos
• sed

ed SNP. Continued monitoring of uncontrolled runoff is not warranted based on operational results.

• De Beers will continue sampling construction material to detect potentially AG material, consistent with operational
• approach. Seeking approval by MVLWB prior to placement is not practical.

MONITORI RING G AND MANAGEMEN GEMENT T PLANS

De Beers Interventio ention n Respons nse e Report

• Attachment A ; Section 1.9 , 2.9 Attachment B; Section 1.11; 1.12, 1.13, 1.14, 1.18 Attachment C Section 1.1

27 27

• Recommendation from ECCC-1
• criteria for "stable"

le"/"dec ecreas reasing ing" parameters

• Using a tiered approach for reducing sampling frequency
• Approval of AEMP following approved closure configuration
• De Beers' Response
• Results of trend

d analy lyses es will be provided as part of annual reports and will be based d on statisti tical al analy lysis is appropriate to the data set consistent with the methods used throughout Operations.

• De Beers acknowledges that a tiered approach in monitoring reduction may be appropriate, and that current mechanism

for data analysis and review provide for informed decision making. Further her reduct uction ions in monit itoring

• ring freque

uency ncy may be warranted and will be requested through revised ed monit itoring

• ring and managem

gemen ent t plans.

• The AEMP will be updated and resubmitted following issuance of the water licence.

MONITORI RING G AND MANAGEMEN GEMENT T PLANS: S: AEMP

28 28

• Recommendation: GNWT-3, 4, 15, 16, 17
• Add closure criteria of FCRP as a condition in WL;
• Post–closure site wide physic

ical al stability ility monit itorin

• ring

g plan as condition in WL;

• Add reporting of thermal

l regim ime e to Performance Assessment Report;

• WL condition to ensure construction material is free from contaminants, and approved by MVLWB prior to use and

continued ARD and Geochem hemic ical al Charac acteriz erizati ation

• n
• De Beers' Response
• The water license will include a condition requiring an FCRP. The FCRP adheres

res to to the Guidelines delines (MVLWB, , 2013). This is a strong and clear linkage to ensure requirements are met.

• Physic

ical al Stabili ility ty monitoring

• ring will be in place for the North Pile as well as for other components- with tailored monitoring as

appropriate included in component criteria.

• The North

h Pile e Managem gemen ent Plan n includes ludes monit itoring ring of thermal al regime. This information will be reported as part of a performance assessment report.

• Technical specifications exist for the cover construction material, geochemical testing will be routinely performed prior to

construction use, with quantitative and qualitative results reported annually. MVLWB approval al of sampling ling and testing ng results will result in undue burden on both MVLWB and De Beers and is not feasible operationally. Our method is consis isten ent t with curren ent t approved ed practic ices es.

WATER ER LICENS ENSE E CONDI DITI TIONS

De Beers Interventio ention n Respons nse e Report

• Attachment B Section 1.3, 1.4 and 1.15 to 1.17

29 29

Recommendation GNWT-19 to 24

• The GNWT reviewed the De Beers security estimate and provided recommendations related to addit

ition ional al securit rity for monitoring and care and maintenance, and return of security

De Beers Response

• Security put forward by De Beers is robust and comprehensive
• Security is not expected to change due to minor changes to monitoring programs
• Request conditions in the water licence that enable return of securities based on submission of Reclamation Completion

Reports and/or Performance Assessment Reports

• Duplic

lication ation in security rity should d be avoide voided

• Given the status of reclamation works completed, one year of security for interim care and maintenance is considered
• reasonable. No additional security is warranted.

SECUR URITY

De Beers Interventio ention n Respons nse e Report

• Attachment B (Response to GNWT), Section 1.19 to 1.24

COM OMMENT MENTS S FROM OM SLEMA EMA

31 31

Comments from SLEMA

• SLEMA provided comments and recommendations as part of the public review process. Key topics covered included:
• Incorp
• rporation
• ration of tradit

itio iona nal l knowled

• wledge

ge into the Final Closure and Reclamation Plan

• Design considerations for the North Pile
• Ongoing participation of Indigenous People in the monitoring of the Snap Lake Mine

De Beers Response

• De Beers incorporated Traditional knowledge relevant to closure through the planning process (Appendix C.3 of the FCRP)
• De Beers will continue to include Indigen

genous

• us partic

icip ipants ants in monitoring

• ring programs

rams

• The North Pile has been designed to be physically and chemically stable and protective of the environment
• De Beers will continue to support SLEMA and the TK and science panels and will maintain engagement and consideration
• f Traditional Knowledge into Closure

SLEMA: A: TRADI RADITI TION ONAL AL KNOWLEDGE EDGE, DESIGN, GN, PARTIC RTICIPATI TION ON

De Beers Interventio ention n Respons nse e Report

• Attachment B (Response to GNWT), Section 1.19 to 1.24

SUMM MMAR ARY

33 33

• Snap Lake Mine is moving to the next phase – Closure
• Mining and milling are no longer planned activities
• An FCRP was submitted with:
• Objectives previously approved in the ICRP
• Criteria refined through feedback
• Detailed description of planned activities
• Framework for return of securities
• Key activities for Closure include:
• Cover the North Pile
• Convert the drainage around the pile from active to passive
• Convert sumps/water management pond into influent storage

ponds and passive drainage to Snap Lake

• Demolition of process plant, camp, and all buildings
• Revegetation of roads, pads, and priority infrastructure areas

SUMMAR ARY

34 34

• A Water Licence is needed to:
• Align

ign with planned closure activities and the changes in water management

• Enable

le closure and reclamation activities including capping of the North Pile and demolition of the site

• Allo

low for future adjustments within the framework of monitoring and management plans

• Proposed Effluent Quality Criteria:
• Will not cause acute toxicity
• Are protective of the environment
• Will meet AEMP benchmarks
• Align with Pollution Prevention principles
• Align with the measures of the previous Environmental

Assessments

• Regular monitoring with adaptive management of

the site and environment will continue.

SUMMAR ARY

THANK ANK YOU OU!