august 2017 environmental update...2017/08/01 · 1.1mineupdate1.1 mine update –july2017july 2017...

August 2017August 2017ggEnvironmental Update Environmental Update

f SLEMA B df SLEMA B dfor SLEMA Boardfor SLEMA BoardZhong LiuZhong LiuZhong LiuZhong Liu

August 31, 2017August 31, 2017

OutlineOutlineOutlineOutline1.1. Mine UpdateMine Update2.2. Inspection UpdateInspection Update3.3. Regulators’ UpdateRegulators’ Update3.3. Regulators UpdateRegulators Update4.4. Aboriginal UpdateAboriginal Update55 Stakeholders’ UpdateStakeholders’ Update5.5. Stakeholders’ UpdateStakeholders’ Update6.6. Agency’s ActivitiesAgency’s Activities7.7. SLEMA ReviewsSLEMA Reviews

AcronymsAcronyms AEMPAEMP Aquatic Effects Monitoring ProgramAquatic Effects Monitoring Program AEMP AEMP –– Aquatic Effects Monitoring ProgramAquatic Effects Monitoring Program ARD ARD –– Acid Rock DrainageAcid Rock Drainage DFO DFO –– Fisheries and Oceans CanadaFisheries and Oceans Canada ECCCECCC –– Environment and Climate Change CanadaEnvironment and Climate Change Canada ECCC ECCC Environment and Climate Change CanadaEnvironment and Climate Change Canada ECM ECM –– Extended Care and MaintenanceExtended Care and Maintenance ENR ENR –– Department of Environment and Natural Resources, GNWTDepartment of Environment and Natural Resources, GNWT EQC EQC –– Effluent Quality CriterionEffluent Quality Criterionyy GNWT GNWT –– Government of the Northwest TerritoriesGovernment of the Northwest Territories INAC INAC –– Indigenous and Northern Affairs Canada (formerly Indigenous and Northern Affairs Canada (formerly

Aboriginal Affairs and Northern Development Canada [AANDC]) Aboriginal Affairs and Northern Development Canada [AANDC]) MVEIRBMVEIRB M k i V ll E i t l I t R i B dM k i V ll E i t l I t R i B d MVEIRB MVEIRB –– Mackenzie Valley Environmental Impact Review BoardMackenzie Valley Environmental Impact Review Board MVLWB MVLWB –– Mackenzie Valley Land and Water BoardMackenzie Valley Land and Water Board PK PK –– Processed Processed KimberliteKimberlite SLEMASLEMA –– Snap Lake Environmental Monitoring AgencySnap Lake Environmental Monitoring Agency SLEMA SLEMA –– Snap Lake Environmental Monitoring AgencySnap Lake Environmental Monitoring Agency SNP SNP –– Surveillance Network ProgramSurveillance Network Program SSWQO SSWQO –– SiteSite--Specific Water Quality ObjectiveSpecific Water Quality Objective TDSTDS –– Total Dissolved SolidsTotal Dissolved Solids TDS TDS Total Dissolved SolidsTotal Dissolved Solids WEMP WEMP –– Wildlife Effects Monitoring ProgramWildlife Effects Monitoring Program WTP WTP –– Water Treatment PlantWater Treatment Plant WMP WMP –– Water Management PondWater Management Pond

1.1 Mine Update1.1 Mine Update –– July 2017July 20171.1 Mine Update 1.1 Mine Update July 2017July 2017 The Snap Lake Mine remained in suspended The Snap Lake Mine remained in suspended

operations (Extended Care and Maintenance)operations (Extended Care and Maintenance) 1,819 m1,819 m33 of water withdrawn from Snap Lakeof water withdrawn from Snap Lake

N t t d t di h d i t S L kN t t d t di h d i t S L k No treated water discharged into Snap LakeNo treated water discharged into Snap Lake No reportable spillsNo reportable spills W t l d i 4 it i t tiW t l d i 4 it i t ti Water sampled in 4 monitoring stations Water sampled in 4 monitoring stations

No compliance issuesNo compliance issues

1.2 2017 Geotechnical Site Inspection 1.2 2017 Geotechnical Site Inspection of the North Pile Facility and Waterof the North Pile Facility and Waterof the North Pile Facility and Water of the North Pile Facility and Water

Management Pond DamsManagement Pond Dams Submitted on August 15 2017Submitted on August 15 2017 Submitted on August 15, 2017Submitted on August 15, 2017

De Beers retained De Beers retained GolderGolder Associates Ltd. Associates Ltd. ((GloderGloder) to perform a geotechnical inspection) to perform a geotechnical inspection((GloderGloder) to perform a geotechnical inspection ) to perform a geotechnical inspection of the North Pile facility and Water of the North Pile facility and Water Management Pond (WMP) damsManagement Pond (WMP) damsg ( )g ( )

The geotechnical site inspection was carried The geotechnical site inspection was carried out between 5 and 8 June 2017out between 5 and 8 June 2017

•• No major items of concern were observed for the No major items of concern were observed for the North Pile and WMP, and the facilities are being North Pile and WMP, and the facilities are being maintained and monitored and are in keeping withmaintained and monitored and are in keeping withmaintained and monitored and are in keeping with maintained and monitored and are in keeping with the designthe design

1.3 Air Quality Update for Care 1.3 Air Quality Update for Care and Maintenance (I)and Maintenance (I)

Submitted on August 23 2017Submitted on August 23 2017 Submitted on August 23, 2017Submitted on August 23, 2017 It will be impractical to provide alternative It will be impractical to provide alternative

power options to the current SHARP Monitorspower options to the current SHARP Monitorspower options to the current SHARP Monitors power options to the current SHARP Monitors between the months of October to April when between the months of October to April when personnel are not at the Minepersonnel are not at the Minepp

•• The SHARP Monitors provide continuous The SHARP Monitors provide continuous measurement of PMmeasurement of PM2.52.5, particulate matter less than , particulate matter less than 2 5 microns in diameter2 5 microns in diameter2.5 microns in diameter2.5 microns in diameter

1.3 Air Quality Update for Care 1.3 Air Quality Update for Care and Maintenance (II)and Maintenance (II)

A change to the SHARP Monitor operationsA change to the SHARP Monitor operations A change to the SHARP Monitor operations A change to the SHARP Monitor operations was proposedwas proposed

•• Option 1: SHARP Monitors will operate at their Option 1: SHARP Monitors will operate at their p pp pcurrent locations for the months of May to current locations for the months of May to September, but not between the months of September, but not between the months of October and AprilOctober and AprilOctober and AprilOctober and April

•• Option 2: SHARP Monitor located near the airstrip Option 2: SHARP Monitor located near the airstrip will not operate between the months of October will not operate between the months of October and April, but will operate for the months of May to and April, but will operate for the months of May to September; SHARP Monitor located near the September; SHARP Monitor located near the emulsion plant will be relocated to near theemulsion plant will be relocated to near theemulsion plant will be relocated to near the emulsion plant will be relocated to near the communications shack and operate year roundcommunications shack and operate year round

1.4 Summary Report for the 1.4 Summary Report for the E Di h M 21 2017E Di h M 21 2017Emergency Discharge on May 21, 2017Emergency Discharge on May 21, 2017 Dated on August 24 2017Dated on August 24 2017 Dated on August 24, 2017Dated on August 24, 2017

The Inspector issued an Emergency Discharge of The Inspector issued an Emergency Discharge of Mine Water Authorization on May 21, 2017 under Part Mine Water Authorization on May 21, 2017 under Part F section 12 of the Water License. Discharge began F section 12 of the Water License. Discharge began on May 25, 2017 by way of the Modular Water on May 25, 2017 by way of the Modular Water Treatment Plant to the existing diffuser in Snap Lake.Treatment Plant to the existing diffuser in Snap Lake.Treatment Plant to the existing diffuser in Snap Lake. Treatment Plant to the existing diffuser in Snap Lake. Discharge finished on June 29, 2017 Discharge finished on June 29, 2017

Daily and cumulative discharge volumes, tabulated Daily and cumulative discharge volumes, tabulated l b t lt d ti t d l di fl b t lt d ti t d l di flaboratory results and estimated mass loading of laboratory results and estimated mass loading of exceeded effluent criteria (EQC) constituents are exceeded effluent criteria (EQC) constituents are presented in the Summary Reportpresented in the Summary Reportp y pp y p

1.5 Renewal Request for Land Use 1.5 Renewal Request for Land Use P it MV2010P it MV2010 D0053/MV2014D0053/MV2014 D0010D0010Permit MV2010Permit MV2010--D0053/MV2014D0053/MV2014--D0010D0010 Submitted on August 25 2017Submitted on August 25 2017 Submitted on August 25, 2017Submitted on August 25, 2017

Current LUPs will be expired on February 15, Current LUPs will be expired on February 15, 2018201820182018

Application package include the Application Application package include the Application Form and supporting documentsForm and supporting documentsForm and supporting documentsForm and supporting documents

2 Inspection Update2 Inspection Update2. Inspection Update 2. Inspection Update

Inspector Inspector –– Andrew Andrew HowtonHowton / Tracy Covey/ Tracy Coveypp y yy yNo inspection reports for Water No inspection reports for Water LicenceLicence or or

Land Use Permits received in August 2017Land Use Permits received in August 2017Land Use Permits received in August 2017 Land Use Permits received in August 2017

3 Regulators’ Update3 Regulators’ Update3. Regulators Update3. Regulators Update

No decisions made in August 2017No decisions made in August 2017No decisions made in August 2017No decisions made in August 2017

4 Aboriginal Update4 Aboriginal Update4. Aboriginal Update4. Aboriginal Update

No comments received in August 2017No comments received in August 2017No comments received in August 2017No comments received in August 2017

5 Stakeholders’ Update5 Stakeholders’ Update5. Stakeholders Update5. Stakeholders Update

ECCC and ENR commented on the 2017 ECCC and ENR commented on the 2017 Downstream Watercourses Special Study Report on August 17 2017Report on August 17, 2017

5.1 ECCC Comments on the 2017 5.1 ECCC Comments on the 2017 Downstream Watercourses Special StudyDownstream Watercourses Special StudyDownstream Watercourses Special Study Downstream Watercourses Special Study

Report (I)Report (I) The Downstream Watercourses SpecialThe Downstream Watercourses Special The Downstream Watercourses Special The Downstream Watercourses Special

Study Report presents a reasonable Study Report presents a reasonable approach to evaluating compliance withapproach to evaluating compliance withapproach to evaluating compliance with approach to evaluating compliance with the Environmental Assessment Measure the Environmental Assessment Measure 1(d) and has done a credible assessment1(d) and has done a credible assessment1(d) and has done a credible assessment 1(d) and has done a credible assessment of the range of natural variability for Node of the range of natural variability for Node 22 in MacKay Lake22 in MacKay Lake22 in MacKay Lake22 in MacKay Lake


Report (II)Report (II) The Conformity (Figure 5The Conformity (Figure 5--28) and Action Level28) and Action Level The Conformity (Figure 5The Conformity (Figure 5 28) and Action Level 28) and Action Level

(Figure 5(Figure 5--29) Decision Trees present an 29) Decision Trees present an acceptable stepwise approach to determining acceptable stepwise approach to determining p p pp gp p pp gwhen action will be triggered. However, Figure when action will be triggered. However, Figure 55--28 ends the action sequence with reporting 28 ends the action sequence with reporting

lt t th I t f d t i ti flt t th I t f d t i ti fresults to the Inspector for determination of results to the Inspector for determination of conformity with Measure 1(d). Further actions conformity with Measure 1(d). Further actions that would be taken if nonthat would be taken if non conformity is identifiedconformity is identifiedthat would be taken if nonthat would be taken if non--conformity is identified conformity is identified was not discussedwas not discussed ECCC recommends De Beers (the Proponent)ECCC recommends De Beers (the Proponent)ECCC recommends De Beers (the Proponent) ECCC recommends De Beers (the Proponent)

provide a discussion of any measures that could be provide a discussion of any measures that could be applied in the case of a situation of nonapplied in the case of a situation of non--conformityconformity


Report (III)Report (III) Concentration shown for Total Phosphorus (TP)Concentration shown for Total Phosphorus (TP) Concentration shown for Total Phosphorus (TP) Concentration shown for Total Phosphorus (TP)

are lower than several of the other phosphorus are lower than several of the other phosphorus species reported in the "Off the flow path / Ice species reported in the "Off the flow path / Ice p p pp p pCovered / Max" data. Total phosphorus should Covered / Max" data. Total phosphorus should encompass all the other forms which were encompass all the other forms which were

l dl d f th i h ld bf th i h ld banalysedanalysed for, so the maximums shown would be for, so the maximums shown would be expected to be higherexpected to be higher

ECCC recommends the Proponent clarify why TPECCC recommends the Proponent clarify why TP ECCC recommends the Proponent clarify why TP ECCC recommends the Proponent clarify why TP maximums are lower than some of the other forms maximums are lower than some of the other forms reported (e.g. total organic phosphorus, dissolved P, reported (e.g. total organic phosphorus, dissolved P, total dissolved P) for the results in the "Off the flow total dissolved P) for the results in the "Off the flow path Ice Covered Max" datapath Ice Covered Max" data

5.2 ENR Comments on the 2017 5.2 ENR Comments on the 2017 Downstream Watercourses Special StudyDownstream Watercourses Special StudyDownstream Watercourses Special Study Downstream Watercourses Special Study

Report (I)Report (I) ENR retained the services of Zajdlik andENR retained the services of Zajdlik and ENR retained the services of Zajdlik and ENR retained the services of Zajdlik and

Associates Inc. to review and provide Associates Inc. to review and provide recommendations on the Report preparedrecommendations on the Report preparedrecommendations on the Report, prepared recommendations on the Report, prepared by by GolderGolder Associates, on behalf of De Associates, on behalf of De BeersBeersBeersBeers Zajdlik and Associates review memo provides Zajdlik and Associates review memo provides

additional context and analysis supportingadditional context and analysis supportingadditional context and analysis supporting additional context and analysis supporting ENR’s comments and recommendations ENR’s comments and recommendations


Report (II)Report (II) Table 5 4 indicates that Node 22 and the LacTable 5 4 indicates that Node 22 and the Lac Table 5.4 indicates that Node 22 and the Lac Table 5.4 indicates that Node 22 and the Lac

CapotCapot Blanc (LCB) outlets will be sampled Blanc (LCB) outlets will be sampled annually for assessing conformity and action annually for assessing conformity and action y g yy g ylevels. The following bullet list on Page 65 levels. The following bullet list on Page 65 identifies that Node 22 will be sampled twice per identifies that Node 22 will be sampled twice per

(i d d t ) d th LCB(i d d t ) d th LCByear (ice covered and open water) and the LCB year (ice covered and open water) and the LCB Outlets will be sampled three times per year (ice Outlets will be sampled three times per year (ice covered open water and fall)covered open water and fall)covered, open water and fall)covered, open water and fall) ENR recommends that more frequent sampling than ENR recommends that more frequent sampling than

that proposed in the bullet list on Page 65 is required that proposed in the bullet list on Page 65 is required p p g qp p g qin order to assess conformity with the EA Measure in order to assess conformity with the EA Measure and action levelsand action levels


Report (III)Report (III) De Beers uses calculated TDS instead of measured TDSDe Beers uses calculated TDS instead of measured TDS De Beers uses calculated TDS instead of measured TDS De Beers uses calculated TDS instead of measured TDS

when determining TDS concentrations in Snap Lake and when determining TDS concentrations in Snap Lake and downstream water bodies. ENR’s review of the downstream water bodies. ENR’s review of the measured vs calculated TDS has identified somemeasured vs calculated TDS has identified somemeasured vs. calculated TDS has identified some measured vs. calculated TDS has identified some concerns with the calculated TDS concentrations when concerns with the calculated TDS concentrations when compared to the measured TDS concentrations compared to the measured TDS concentrations ENR recommends that De Beers provide a thorough rationale for ENR recommends that De Beers provide a thorough rationale for

using calculated TDS and review their rationale for using using calculated TDS and review their rationale for using calculated TDS instead of measured TDS, given the results of calculated TDS instead of measured TDS, given the results of the data collected thus far as part of this monitoring program. the data collected thus far as part of this monitoring program. This analysis should be provided for review and approval by the This analysis should be provided for review and approval by the Board and include rationale and reasoning for either TDS Board and include rationale and reasoning for either TDS measurement selected (measured or calculated)measurement selected (measured or calculated)measurement selected (measured or calculated)measurement selected (measured or calculated)


Report (IV)Report (IV) None of the TDS concentrations provided byNone of the TDS concentrations provided by GolderGolder None of the TDS concentrations provided by None of the TDS concentrations provided by GolderGolder

(2017) are presented as censored, despite censoring in (2017) are presented as censored, despite censoring in some of the constituent ions used in the calculation some of the constituent ions used in the calculation ((GolderGolder 2017 Equation 42017 Equation 4 1)1) GolderGolder (2017) does not(2017) does not((GolderGolder, 2017, Equation 4, 2017, Equation 4--1). 1). GolderGolder (2017) does not (2017) does not provide a discussion regarding how censored data are provide a discussion regarding how censored data are incorporated into the calculated TDS value, or any incorporated into the calculated TDS value, or any implications of using censored data when assessing implications of using censored data when assessing conformity with the EA measure. As such, ENR is conformity with the EA measure. As such, ENR is concerned with using calculated TDS results to assess ifconcerned with using calculated TDS results to assess ifconcerned with using calculated TDS results to assess if concerned with using calculated TDS results to assess if TDS is increasing in MacKay LakeTDS is increasing in MacKay Lake ENR recommends that De Beers provide a discussion regarding ENR recommends that De Beers provide a discussion regarding

the use of censored data when calculating TDS concentrationsthe use of censored data when calculating TDS concentrationsthe use of censored data when calculating TDS concentrationsthe use of censored data when calculating TDS concentrations


Report (V)Report (V) ENR recommends that the Board requireENR recommends that the Board require ENR recommends that the Board require ENR recommends that the Board require

that the existing sampling program be that the existing sampling program be retained and that De Beers resume dataretained and that De Beers resume dataretained and that De Beers resume data retained and that De Beers resume data collection during freshet and early spring collection during freshet and early spring until such time as sufficient data isuntil such time as sufficient data isuntil such time as sufficient data is until such time as sufficient data is available to statistically confirm that the available to statistically confirm that the data sets are the samedata sets are the samedata sets are the samedata sets are the same


Report (VI)Report (VI) A nonA non--exhaustive or preliminary analysis of the data exhaustive or preliminary analysis of the data

available has identified a number of potential QA/QC available has identified a number of potential QA/QC concerns. Namely, quality assurance results show that concerns. Namely, quality assurance results show that sample contamination and/or excessive hold times lead sample contamination and/or excessive hold times lead ppto poor quality nutrient data (dissolved organic to poor quality nutrient data (dissolved organic phosphorus, calculated nitrate as N, calculated phosphorus, calculated nitrate as N, calculated nitrate/nitrite as N nitrite as Nnitrate/nitrite as N nitrite as N orthoortho phosphate as Pphosphate as Pnitrate/nitrite as N, nitrite as N nitrate/nitrite as N, nitrite as N orthoortho--phosphate as P, phosphate as P, total dissolved P, calculated total N and total P) and total dissolved P, calculated total N and total P) and conventional parameters data (laboratory pH, calculated conventional parameters data (laboratory pH, calculated TDS and turbidity). ENR notes that Aluminum, Boron, TDS and turbidity). ENR notes that Aluminum, Boron, Antimony and Manganese sample contamination was Antimony and Manganese sample contamination was noted in 100% of samplesnoted in 100% of samplespp ENR recommends that De Beers take all the necessary steps to ENR recommends that De Beers take all the necessary steps to

improve data quality (QA/QC) and reduce hold times to ensure improve data quality (QA/QC) and reduce hold times to ensure all lab hold times are metall lab hold times are met


Report (VII)Report (VII) ENR has several concerns with theENR has several concerns with the ENR has several concerns with the ENR has several concerns with the

compliance assessment method proposed compliance assessment method proposed by De Beersby De Beersby De Beersby De Beers ENR recommends that additional discussion, ENR recommends that additional discussion,

review and rationale regarding the method forreview and rationale regarding the method forreview and rationale regarding the method for review and rationale regarding the method for assessing compliance with Measure 1 (d) assessing compliance with Measure 1 (d) should occur prior to approvalshould occur prior to approvalp ppp pp


Report (VIII)Report (VIII) ENR recommends that quality controlENR recommends that quality control ENR recommends that quality control ENR recommends that quality control

methods should be assessed for all methods should be assessed for all evaluations of conformance with Measureevaluations of conformance with Measureevaluations of conformance with Measure evaluations of conformance with Measure 1 (d) and the Action Levels (for both 1 (d) and the Action Levels (for both conformity results and nonconformity results and non--conformityconformityconformity results and nonconformity results and non--conformity conformity results)results)

ENR recommends that De Beers provide aENR recommends that De Beers provide a ENR recommends that De Beers provide a ENR recommends that De Beers provide a discussion regarding how quickly the data discussion regarding how quickly the data assessment would occur and how quicklyassessment would occur and how quicklyassessment would occur and how quickly assessment would occur and how quickly follow up samples could be collectedfollow up samples could be collected

6 Agency’s Activities6 Agency’s Activities6. Agency s Activities6. Agency s Activities

SLEMA sent a comment letter on the 2017SLEMA sent a comment letter on the 2017 SLEMA sent a comment letter on the 2017 SLEMA sent a comment letter on the 2017 Downstream Watercourses Special Study Downstream Watercourses Special Study Report on August 17, 2017Report on August 17, 2017p gp g

7 SLEMA Reviews7 SLEMA Reviews7. SLEMA Reviews7. SLEMA Reviews 2017 Downstream Watercourses Special 2017 Downstream Watercourses Special

Study Report Study Report Air Quality Update for Care and Air Quality Update for Care and yy

MaintenanceMaintenance

7.1 2017 Downstream Watercourses 7.1 2017 Downstream Watercourses S i l St d R tS i l St d R tSpecial Study Report Special Study Report

Submitted in July 2017Submitted in July 2017 Submitted in July 2017Submitted in July 2017 The purpose of the Study was to collect water The purpose of the Study was to collect water

quality and hydrological data to provide aquality and hydrological data to provide aquality and hydrological data to provide a quality and hydrological data to provide a basis for basis for defining natural variability defining natural variability downstream of Snap Lake including MacKay downstream of Snap Lake including MacKay p g yp g yLake and regionally, and for updating the Lake and regionally, and for updating the water quality model downstream of Snap water quality model downstream of Snap Lake up to and including MacKay LakeLake up to and including MacKay Lake

BackgroundBackgroundBackground Background During the Environmental Assessment EA1314During the Environmental Assessment EA1314--0202 During the Environmental Assessment EA1314During the Environmental Assessment EA1314 02 02

regulatory process, traditional users of MacKay Lake regulatory process, traditional users of MacKay Lake expressed concerns that increasing the allowable treated expressed concerns that increasing the allowable treated effluent discharge concentration of TDS would result ineffluent discharge concentration of TDS would result ineffluent discharge concentration of TDS would result in effluent discharge concentration of TDS would result in treated effluent from Snap Lake affecting culturally treated effluent from Snap Lake affecting culturally important areas. Accordingly, as part of its decision to important areas. Accordingly, as part of its decision to allow the increased Water allow the increased Water LicenceLicence limit for TDS, the limit for TDS, the MVEIRB recommended that the MVLWB set numerical MVEIRB recommended that the MVLWB set numerical endend--ofof--pipe limits such that, perpipe limits such that, per Measure 1(d)Measure 1(d) “No Total“No Totalendend ofof pipe limits such that, per pipe limits such that, per Measure 1(d) Measure 1(d) No Total No Total Dissolved Solids or its constituent ions from Snap Lake Dissolved Solids or its constituent ions from Snap Lake Mine effluent will be detectable, relative to the range of Mine effluent will be detectable, relative to the range of natural variability at the inlet to MacKay Lake 44 kmnatural variability at the inlet to MacKay Lake 44 kmnatural variability, at the inlet to MacKay Lake, 44 km natural variability, at the inlet to MacKay Lake, 44 km downstream of Snap Lake”downstream of Snap Lake”

Mackay Lake and Lockhart Mackay Lake and Lockhart River WatershedsRiver Watersheds

Monitoring StationsMonitoring StationsMonitoring StationsMonitoring Stations

Conformity t ti (istation (i.e.,

Node 22)

Total Dissolved Solids Concentrations Total Dissolved Solids Concentrations D t f S L k ith DSL2 O tl tD t f S L k ith DSL2 O tl tDownstream of Snap Lake, with DSL2 OutletDownstream of Snap Lake, with DSL2 Outlet

Total Dissolved Solids Concentrations Total Dissolved Solids Concentrations D t f S L k ith t DSL2 O tl tD t f S L k ith t DSL2 O tl tDownstream of Snap Lake, without DSL2 OutletDownstream of Snap Lake, without DSL2 Outlet

Results (I)Results (I)Results (I)Results (I)

In summary, based on the spatial downstream gradients of TDS, In summary, based on the spatial downstream gradients of TDS, y p gy p gcalcium, chloride and sodium concentrations, treated effluent from calcium, chloride and sodium concentrations, treated effluent from Snap Lake can be detected downstream of Snap Lake from LCB to Snap Lake can be detected downstream of Snap Lake from LCB to MCKYMCKY--IN, but not within MacKay Lake. During the Care and IN, but not within MacKay Lake. During the Care and Maintenance period, concentrations of parameters related to treated Maintenance period, concentrations of parameters related to treated effluent are predicted to decrease in Snap Lakeeffluent are predicted to decrease in Snap Lake

Seasonal variability between late iceSeasonal variability between late ice--covered and opencovered and open--water water conditions was evident in TDS concentrations and in most of the conditions was evident in TDS concentrations and in most of the constituent parameters concentrations downstream of Snap Lakeconstituent parameters concentrations downstream of Snap Lake TDS and constituent parameters concentrations were typically higher TDS and constituent parameters concentrations were typically higher

d i l t id i l t i d diti d td diti d t t ditit ditiduring late iceduring late ice--covered conditions compared to opencovered conditions compared to open--water conditionswater conditions

Extent of Treated Effluent Plume in Snap Extent of Treated Effluent Plume in Snap L k d D t L k i 2015L k d D t L k i 2015Lake and Downstream Lakes in 2015Lake and Downstream Lakes in 2015

Extent of Treated Effluent Plume in Snap Extent of Treated Effluent Plume in Snap L k d D t L k i 2016L k d D t L k i 2016Lake and Downstream Lakes in 2016Lake and Downstream Lakes in 2016

Results (II)Results (II)Results (II)Results (II) Conductivity measurements were used as a tracer forConductivity measurements were used as a tracer for Conductivity measurements were used as a tracer for Conductivity measurements were used as a tracer for

the treated effluent downstream of Snap Lakethe treated effluent downstream of Snap Lake Conductivity values decreased with distance Conductivity values decreased with distance

d t f S L k f DSL2 O tl t t N d 22d t f S L k f DSL2 O tl t t N d 22downstream of Snap Lake, from DSL2 Outlet to Node 22downstream of Snap Lake, from DSL2 Outlet to Node 22 Conductivity measurements at the outlets of LCB have Conductivity measurements at the outlets of LCB have

increased over time as predictedincreased over time as predictedincreased over time as predictedincreased over time as predicted Conductivity values at KING01 and MCKYConductivity values at KING01 and MCKY--IN remained IN remained

similar between 2015 and 2016similar between 2015 and 2016 The treated effluent plume from Snap Lake is evident at The treated effluent plume from Snap Lake is evident at

DSL2 Outlet, after which substantial dilution of the DSL2 Outlet, after which substantial dilution of the treated effluent occurs within a short distance of enteringtreated effluent occurs within a short distance of enteringtreated effluent occurs within a short distance of entering treated effluent occurs within a short distance of entering LCBLCB

Total Dissolved Solids Natural Variability Total Dissolved Solids Natural Variability R f M K L kR f M K L kRanges for MacKay LakeRanges for MacKay Lake

Results (III)Results (III)Results (III)Results (III)

The natural variability ranges for TDSThe natural variability ranges for TDS The natural variability ranges for TDS The natural variability ranges for TDS concentrations were calculated for yearconcentrations were calculated for year--round, round, iceice--covered, and opencovered, and open--water conditions using water conditions using pp ggthe off the flow path data the off the flow path data The natural variability range for TDS without The natural variability range for TDS without

ti f lit (i i d t fti f lit (i i d t faccounting for seasonality (i.e., using data from yearaccounting for seasonality (i.e., using data from year--round) was 5.0 to 15.8 mg/Lround) was 5.0 to 15.8 mg/L

The natural variability range for TDS concentrationsThe natural variability range for TDS concentrations The natural variability range for TDS concentrations The natural variability range for TDS concentrations for icefor ice--covered conditions (4.4 to 16.4 mg/L)covered conditions (4.4 to 16.4 mg/L) and and openopen--water conditions (i.e., 6.0 to 14.3 mg/L) were water conditions (i.e., 6.0 to 14.3 mg/L) were similar to the range estimated for data from bothsimilar to the range estimated for data from bothsimilar to the range estimated for data from both similar to the range estimated for data from both seasons combinedseasons combined

Evaluation of Conformity with Measure 1(d)Evaluation of Conformity with Measure 1(d)Evaluation of Conformity with Measure 1(d)Evaluation of Conformity with Measure 1(d)

The Acceptable Limit (i e TDS conformityThe Acceptable Limit (i e TDS conformity The Acceptable Limit (i.e., TDS conformity The Acceptable Limit (i.e., TDS conformity concentration) for iceconcentration) for ice--covered conditions covered conditions was 19 1 mg/L and 16 7 mg/L for openwas 19 1 mg/L and 16 7 mg/L for open--was 19.1 mg/L, and 16.7 mg/L for openwas 19.1 mg/L, and 16.7 mg/L for open--water conditionswater conditions

A mean TDS concentration of five samplesA mean TDS concentration of five samples A mean TDS concentration of five samples A mean TDS concentration of five samples collected annually collected annually at Node 22at Node 22 during iceduring ice--covered conditions less than or equal to 19.1covered conditions less than or equal to 19.1covered conditions less than or equal to 19.1 covered conditions less than or equal to 19.1 mg/L would be in conformity with Measure mg/L would be in conformity with Measure 1(d)1(d)

Low Action Level for the Protection of Low Action Level for the Protection of T diti l L d UT diti l L d UTraditional Land UseTraditional Land Use

Low Action Levels would be assessed at the outlets ofLow Action Levels would be assessed at the outlets of Low Action Levels would be assessed at the outlets of Low Action Levels would be assessed at the outlets of LCB, as an earlyLCB, as an early--warning upstream location, and at warning upstream location, and at Node 22Node 22

Th t ti t th LCB tl t i b thTh t ti t th LCB tl t i b th The average concentration at the LCB outlets is above the The average concentration at the LCB outlets is above the current Interim Low Action Level, which is based on water quality current Interim Low Action Level, which is based on water quality modellingmodelling through 2020through 2020At N d 22 TDS t ti ithi th A t bl Li itAt N d 22 TDS t ti ithi th A t bl Li it At Node 22 TDS concentrations are within the Acceptable Limit At Node 22 TDS concentrations are within the Acceptable Limit but may exceed the range of natural variabilitybut may exceed the range of natural variability

If either of the two Low Action Levels were triggered, an If either of the two Low Action Levels were triggered, an appropriate response plan would be prepared and appropriate response plan would be prepared and submitted to the MVLWBsubmitted to the MVLWB

Evaluation of conformity with Measure 1(d) and the LowEvaluation of conformity with Measure 1(d) and the Low Evaluation of conformity with Measure 1(d) and the Low Evaluation of conformity with Measure 1(d) and the Low Action Levels will be included in the next update of the Action Levels will be included in the next update of the AEMP Design PlanAEMP Design Plan

Proposed Monitoring Sampling Locations Downstream of Snap Proposed Monitoring Sampling Locations Downstream of Snap L k f E l ti C f it d A i A ti L lL k f E l ti C f it d A i A ti L lLake for Evaluating Conformity and Assessing Action LevelsLake for Evaluating Conformity and Assessing Action Levels

TDS Concentrations, ModelTDS Concentrations, ModelPredictions at the outlets of Predictions at the outlets of LCB, KING01, and Node 22LCB, KING01, and Node 22

Updating Downstream Lakes ModelUpdating Downstream Lakes ModelUpdating Downstream Lakes ModelUpdating Downstream Lakes Model

The downstream water quality model is currentlyThe downstream water quality model is currently The downstream water quality model is currently The downstream water quality model is currently predicting TDS concentrations that are similar to or predicting TDS concentrations that are similar to or above monitored TDS concentrations; based on the above monitored TDS concentrations; based on the current bias of the model concentrations are expected tocurrent bias of the model concentrations are expected tocurrent bias of the model, concentrations are expected to current bias of the model, concentrations are expected to remain below the range of natural variability at Node 22. remain below the range of natural variability at Node 22. Therefore, the water quality model downstream of Snap Therefore, the water quality model downstream of Snap Lake should be updated at the same time and frequency Lake should be updated at the same time and frequency as the other models for the Mine (i.e., the Site model and as the other models for the Mine (i.e., the Site model and the Snap Lake model)the Snap Lake model)the Snap Lake model)the Snap Lake model)

Comments from the Comments from the Environmental Analyst (I)Environmental Analyst (I)

The study is well designed and the results andThe study is well designed and the results and The study is well designed and the results and The study is well designed and the results and conclusions are reasonably made. It is conclusions are reasonably made. It is recommended that the MVLWB approve the recommended that the MVLWB approve the ppppsubmissionsubmission

No concerns are raised but No concerns are raised but Table 5Table 5--2 in page 38 indicates that the water surface 2 in page 38 indicates that the water surface

elevation in LCB outlet is 423.xx m, which is higher elevation in LCB outlet is 423.xx m, which is higher than that inthan that in upstreamupstream DSL 2 Outlet (421 xx m) andDSL 2 Outlet (421 xx m) andthan that in than that in upstreamupstream DSL 2 Outlet (421.xx m), and DSL 2 Outlet (421.xx m), and the water surface elevation in MacKay Lake outlet is the water surface elevation in MacKay Lake outlet is 405.xx m, which is higher than that in 405.xx m, which is higher than that in upstreamupstream King King L k O l (400 ) D fL k O l (400 ) D fLake Outlet (400.xx m). Downstream water surface Lake Outlet (400.xx m). Downstream water surface elevation higher than upstream is not justifiable, and elevation higher than upstream is not justifiable, and clarification is requestedclarification is requested

De Beers’ Response to Water De Beers’ Response to Water S f El i i T blS f El i i T bl 22Surface Elevations in Table 5Surface Elevations in Table 5--22

Request for clarification was sent onRequest for clarification was sent onRequest for clarification was sent on Request for clarification was sent on August 15, and De Beers responded in the August 15, and De Beers responded in the same daysame daysame daysame day ““Elevations presented are incorrectly reported Elevations presented are incorrectly reported

as “geodetic” and should be reported asas “geodetic” and should be reported asas geodetic and should be reported as as geodetic and should be reported as “local” as these were tied to local benchmarks “local” as these were tied to local benchmarks near each lake outlet with arbitrary near each lake outlet with arbitrary datumsdatums. . yyHence, elevations presented should be Hence, elevations presented should be interpreted as relative elevations for each lake interpreted as relative elevations for each lake

d b l l i Thi dd b l l i Thi das opposed to absolute elevations. This does as opposed to absolute elevations. This does not change any conclusions of the report.not change any conclusions of the report.””

Comments from the Comments from the Environmental Analyst (II)Environmental Analyst (II)

Explanation is acceptable howeverExplanation is acceptable however Explanation is acceptable, however, Explanation is acceptable, however, correction is still neededcorrection is still needed

7.2 Air Quality Update for Care 7.2 Air Quality Update for Care and Maintenanceand Maintenance

Prepared byPrepared by ArktisArktis Solutions on behalf ofSolutions on behalf of Prepared by Prepared by ArktisArktis Solutions on behalf of Solutions on behalf of De Beers in August 2017De Beers in August 2017

As a result of the changes of siteAs a result of the changes of site As a result of the changes of site As a result of the changes of site infrastructure during care and maintenance infrastructure during care and maintenance (C&M), power will no longer be supplied to the(C&M), power will no longer be supplied to the(C&M), power will no longer be supplied to the (C&M), power will no longer be supplied to the Thermo Scientific 5030 SHARP Monitors at Thermo Scientific 5030 SHARP Monitors at their current locationstheir current locations

•• Thus, a change to the SHARP Monitor operations Thus, a change to the SHARP Monitor operations is necessary during C&Mis necessary during C&M

Background (I)Background (I)Background (I) Background (I)

During care and maintenance siteDuring care and maintenance siteDuring care and maintenance, site During care and maintenance, site infrastructure will be managed to ensure infrastructure will be managed to ensure environmental stability and minimizeenvironmental stability and minimizeenvironmental stability and minimize environmental stability and minimize operating footprint, which involves, but not operating footprint, which involves, but not limited to:limited to:limited to: limited to: reduction in powerreduction in power and heating requirements;and heating requirements;

reduction of onreduction of on site personnelsite personnel requirements;requirements; reduction of onreduction of on--site personnelsite personnel requirements; requirements; and and reconfiguration of power requirements toreconfiguration of power requirements to reconfiguration of power requirements to reconfiguration of power requirements to maximize efficiencymaximize efficiency

Background (II)Background (II)Background (II) Background (II)

The SHARP Monitors provide continuousThe SHARP Monitors provide continuous The SHARP Monitors provide continuous The SHARP Monitors provide continuous measurement of PMmeasurement of PM2.52.5, particulate matter less , particulate matter less than 2.5 microns in diameterthan 2.5 microns in diameter The current locations for the 5030 SHARP PMThe current locations for the 5030 SHARP PM2.52.5

Monitors were selected to represent estimates of Monitors were selected to represent estimates of particulate concentrations away from high intensityparticulate concentrations away from high intensityparticulate concentrations away from high intensity particulate concentrations away from high intensity mining activities, as informed by 2007 dispersion mining activities, as informed by 2007 dispersion modeling predictionsmodeling predictions

•• Installed in November 2014Installed in November 2014 to replace Dichotomous to replace Dichotomous PMPM1010/PM/PM2.52.5 PartisolPartisol

•• The availability of electrical power was also a keyThe availability of electrical power was also a key•• The availability of electrical power was also a key The availability of electrical power was also a key consideration for these locationsconsideration for these locations

Current locations for the SHARP Monitors Current locations for the SHARP Monitors Approximate location of proposed SHARP monitorApproximate location of proposed SHARP monitorpp p ppp p p

Background (III)Background (III)Background (III) Background (III)

Suspended particulate matter emissions may beSuspended particulate matter emissions may be Suspended particulate matter emissions may be Suspended particulate matter emissions may be generated by generated by wind erosion wind erosion of local landscapes, of local landscapes, movement of movement of vehicles/equipmentvehicles/equipment, , airstripairstripq pq p ppactivities, activities, constructionconstruction activities, the activities, the combustioncombustionof diesel fuel and solid waste incinerationof diesel fuel and solid waste incineration

Based on air dispersion modeling, it is Based on air dispersion modeling, it is suggested that fugitive dust emission sources suggested that fugitive dust emission sources ( d d t) lik l ibl f( d d t) lik l ibl f(e.g., road dust) are likely responsible for (e.g., road dust) are likely responsible for elevated total suspended particulates within the elevated total suspended particulates within the active Mine area compared to combustionactive Mine area compared to combustionactive Mine area, compared to combustion active Mine area, compared to combustion sources, for the operating Minesources, for the operating Mine

Proposed Change to the Air Proposed Change to the Air Quality Monitoring ProgramQuality Monitoring Program

Option 1: SHARP Monitors will operate at their currentOption 1: SHARP Monitors will operate at their current Option 1: SHARP Monitors will operate at their current Option 1: SHARP Monitors will operate at their current locations for the months of May to September, locations for the months of May to September, but not but not between the months of October and Aprilbetween the months of October and AprilO ti 2 SHARP M it l t d th i t i illO ti 2 SHARP M it l t d th i t i ill Option 2: SHARP Monitor located near the airstrip will Option 2: SHARP Monitor located near the airstrip will not operate between the months of October and April, not operate between the months of October and April, but will operate for the months of May to September; but will operate for the months of May to September; p y pp y pSHARP Monitor located near the emulsion plant will be SHARP Monitor located near the emulsion plant will be relocated to near the communications shack and operate relocated to near the communications shack and operate year roundyear roundyear roundyear round

No changes are proposed to the passive monitoring of No changes are proposed to the passive monitoring of SO2 and NO2 at the MineSO2 and NO2 at the Mine

RationaleRationaleRationale Rationale Lower generation of particulate matter from the Lower generation of particulate matter from the

following sources because of a reduction in sitefollowing sources because of a reduction in sitefollowing sources because of a reduction in site following sources because of a reduction in site activities: movement of vehicles/equipment, activities: movement of vehicles/equipment, airstrip activities, construction activities, airstrip activities, construction activities, ppcombustion sourcescombustion sources

Wind erosion of local landscapes will remain a Wind erosion of local landscapes will remain a source for the generation of particulate matter in source for the generation of particulate matter in C&MC&M

Wind erosion of local landscapes is reduced in Wind erosion of local landscapes is reduced in the winter, due to frozen ground conditions the winter, due to frozen ground conditions and/or wet/snow covered ground compared toand/or wet/snow covered ground compared toand/or wet/snow covered ground, compared to and/or wet/snow covered ground, compared to the warmer seasonsthe warmer seasons

Comments from the Comments from the Environmental Analyst (I)Environmental Analyst (I)

The Air Quality Meteorological Monitoring andThe Air Quality Meteorological Monitoring and The Air Quality Meteorological Monitoring and The Air Quality Meteorological Monitoring and Emissions Reporting 2016 Annual Report (2016 Emissions Reporting 2016 Annual Report (2016 Air Quality Report) indicates that Air Quality Report) indicates that y p )y p ) Particulate matter concentrations (Total Suspended Particulate matter concentrations (Total Suspended

Particulate and PMParticulate and PM2.52.5) could be ) could be elevated in both elevated in both summer and wintersummer and wintersummer and wintersummer and winter

In total, five In total, five exceedancesexceedances of the 24of the 24--hour PMhour PM2.52.5standard were recorded at the emulsion plant, and standard were recorded at the emulsion plant, and p ,p ,seven seven exceedancesexceedances were also recorded at the were also recorded at the airstrip, in 2016airstrip, in 2016Action Level I was triggered for PMAction Level I was triggered for PM Action Level IAction Level I Action Level I was triggered for PMAction Level I was triggered for PM2.52.5. Action Level I . Action Level I indicates that indicates that monitoring should continue and no monitoring should continue and no mitigation is necessarymitigation is necessary

2015 Total Suspended Particulate 2015 Total Suspended Particulate Concentrations at Three TSP StationsConcentrations at Three TSP StationsConcentrations at Three TSP Stations Concentrations at Three TSP Stations

(Table 18 of the 2016 Air Quality Report) (Table 18 of the 2016 Air Quality Report)

2016 PM2016 PM2.52.5 Concentrations at Airstrip Station Concentrations at Airstrip Station (T bl 20 f th 2016 Ai Q lit R t)(T bl 20 f th 2016 Ai Q lit R t)(Table 20 of the 2016 Air Quality Report)(Table 20 of the 2016 Air Quality Report)

2016 PM2016 PM2.52.5 Concentrations at Emulsion Plant Concentrations at Emulsion Plant St ti (T bl 21 f th 2016 Ai Q lit R t)St ti (T bl 21 f th 2016 Ai Q lit R t)Station (Table 21 of the 2016 Air Quality Report)Station (Table 21 of the 2016 Air Quality Report)

Comments from the Comments from the Environmental Analyst (II)Environmental Analyst (II)

Option 1 is not consistent with the requirementsOption 1 is not consistent with the requirements Option 1 is not consistent with the requirements Option 1 is not consistent with the requirements of the Environmental Agreement, thus not of the Environmental Agreement, thus not acceptableacceptablepp Data loss of PMData loss of PM2.52.5 will be seven months per year, and will be seven months per year, and

there will be not compliance record for the period of there will be not compliance record for the period of October to next AprilOctober to next AprilOctober to next AprilOctober to next April

Option 2 is barely acceptable, considering the Option 2 is barely acceptable, considering the limited capability during C&Mlimited capability during C&Mlimited capability during C&Mlimited capability during C&M Partially fulfill the continuity of particulate monitoring Partially fulfill the continuity of particulate monitoring The memo provides some explanations but not The memo provides some explanations but not e e o p o des so e e p a a o s bu oe e o p o des so e e p a a o s bu o

enough for the justification of SHARP monitor enough for the justification of SHARP monitor relocation and compliance recordrelocation and compliance record

Comments from the Comments from the Environmental Analyst (III)Environmental Analyst (III)

It is stated in Option 2 (page 3 of the Memo) that It is stated in Option 2 (page 3 of the Memo) that demonstration of compliance with ambient air quality demonstration of compliance with ambient air quality benchmarks at the new location can reasonably be benchmarks at the new location can reasonably be extrapolated to represent compliance at offextrapolated to represent compliance at off--site locationssite locationsp p pp p p

However, air dispersion modeling for the C&M period However, air dispersion modeling for the C&M period has not been completed. The previous modeling was has not been completed. The previous modeling was d i 2007d i 2007done in 2007done in 2007

It is requested that De Beers update the Air Modeling to It is requested that De Beers update the Air Modeling to Reflect the current status of care and maintenance and provideReflect the current status of care and maintenance and provide Reflect the current status of care and maintenance and provide Reflect the current status of care and maintenance and provide

guidance for the air quality trend in the future under various guidance for the air quality trend in the future under various scenarios (reopen, extended care and maintenance, and scenarios (reopen, extended care and maintenance, and permanent closure) permanent closure) p )p )

Analyze the impacts of the relocation of SHARP monitor at the Analyze the impacts of the relocation of SHARP monitor at the emulsion plant and demonstrate the compliance at offemulsion plant and demonstrate the compliance at off--site site locations through extrapolation locations through extrapolation

august 2017 environmental update...2017/08/01 · 1.1mineupdate1.1 mine update –july2017july 2017...

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