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NIRB Final Hearing Rankin Inlet, Nunavut Michael I. Mohammed

Environment Canada Presentation to Nunavut Impact Review Board Regarding Agnico Eagle Mines Ltd.’s Meliadine Gold Project. NIRB Final Hearing Rankin Inlet, Nunavut Michael I. Mohammed Senior Environmental Assessment Coordinator Anne Wilson Head, Water Quality August, 2014.

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NIRB Final Hearing Rankin Inlet, Nunavut Michael I. Mohammed

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  1. Environment Canada Presentation to Nunavut Impact Review Board Regarding Agnico Eagle Mines Ltd.’s Meliadine Gold Project NIRB Final Hearing Rankin Inlet, Nunavut Michael I. Mohammed Senior Environmental Assessment Coordinator Anne Wilson Head, Water Quality August, 2014

  2. EC’s Mandate • Department of the Environment Act • General responsibility for environmental management and protection. • Preserve and enhance water, air and soil quality. • Conserve Canada's renewable resources. • Migratory birds, species at risk, flora and fauna. • Conserve and protect Canada's water resources. • Provide meteorological information. • Coordinate environmental policies and programs.

  3. How EC Fulfills its Mandate Relevant acts and regulations: • Department of the Environment Act • Canadian Environmental Protection Act • Air quality • Spill contingency planning • Waste management • Fisheries Act – Pollution prevention provisions • Water quality • Metal Mining Effluent Regulations (MMER) • Migratory Birds Convention Act • Species at Risk Act (SARA)

  4. Fisheries ActMetal Mining Effluent Regulations • Applies to a mine, mine under development, new mine or re-opened mine, that: • Exceeds effluent flow rate of 50 m3/day based on cumulative discharges from each final discharge point • Deposits a deleterious substance into waters frequented by fish as per s.36(3) MMER set standards for the quality of all effluent discharged: • pH of effluent and concentrations of arsenic, copper, cyanide, lead, nickel, zinc, radium-226 and suspended solids • concentration does not exceed authorized limits for these substances as identified in Schedule 4 • prohibit discharge of effluent which is acutely lethal to fish • MMER include provisions to authorize the disposal of waste rock or tailings into natural, fish-frequented water bodies (Schedule 2)

  5. MMER Schedule 2Tailings Impoundment Areas (TIA) • A water body can only be added to Schedule 2 of the MMER, designating it as a TIA, by amending the Regulations. • Project proponent would need to assess alternatives for mine waste disposal • EC has guidelines for undertaking such assessments • Effluent from the TIA must meet MMER Schedule 4 criteria • Approval for an amendment to the Regulations must come from Governor in Council • Project proponent must also develop and implement a fish habitat compensation plan to offset the loss of fish habitat • Section 27.1 of the MMER requires fish habitat compensation to offset losses of fish habitat associated with the deposit of a deleterious substance into water body(ies) that are added to Schedule 2.

  6. EC’s Role in Nunavut • Reviews development (and remediation) proposals for environmental impacts falling within its mandate. • Provides recommendations and expert advice to the Nunavut Impact Review Board and Nunavut Water Board. • Enforces compliance with legislation that falls within EC’s mandate.

  7. EC’s Concerns with the Meliadine Gold Project EC raised concerns relate to: • Air quality; • Water quality; • Environmental emergency planning and response capacity; and • Migratory birds and species at risk.

  8. Recommendations Related to Air Quality • Provide details such as information on emission factors, assumptions used in calculations, and information on emissions from support vessels for shipping emission estimates. • Regarding the incineration of sewage sludge.

  9. Recommendations Related to Water Quality - Contaminants • EC recommends that AEM monitor all the sources of cyanide, ammonia, and nitrate , and use real data to update predictions over time. This could flag concerns early enough for mitigation to be used.

  10. Recommendations Related to Water Quality - Effluent • EC recommends that AEM monitor water quality for all source waters that go to AP-01 and use data for total metals to periodically re-run the water quality model, or otherwise update predictions.

  11. Recommendations Related to Water Quality - Effluent • EC recommends that Table 7.4-A24 be updated with an additional column showing predicted effluent quality for each parameter (minimum, maximum and median) over life of mine. This will be useful for developing effluent quality criteria and further refinement of edge of mixing zone concentration targets. • EC recommends that thresholds be identified that would trigger further treatment for AP-01 discharges, and included in an adaptive management plan.

  12. Recommendations Related to Water Quality – Brine Disposal • EC recommends that disposal of treatment brine residuals be done such that there are no impacts to fish-bearing waters. If the ocean discharge option is considered, a full assessment would be needed.

  13. Recommendations Related to Water Quality - Lake B4 • EC recommends that salinity in Lake B4 and its effects on permafrost stability be considered.

  14. Recommendations Related to Water Quality – Monitoring • EC recommends a more comprehensive approach to selecting parameters that will be monitored for operational purposes; and that a working group be set up to further develop the AEMP in advance of construction.

  15. Recommendations Related to Environmental Emergencies • Regarding environmental sensitivity mapping. • Develop spill scenarios that may better represent a worst-case incident presenting potential impacts to receiving water bodies, which may better help to “identify potential risk areas” such as marine shorelines, rivers or waterway crossings.

  16. Recommendations Related to Environmental Emergencies • Undertake hydrologic trajectory modeling for potential spilled diesel for the fuel transfer area in Melvin Bay, the access passage area, and the area surrounding Panorama Island. • As a best practice, pre-deploy containment boom for all fuel transfers at Itivia Harbour. Alternatively, develop criteria for the pre-deployment of containment boom for ship-to-shore fuel transfer.

  17. Recommendations Related to Migratory Birds and Species at Risk • The setback distances for Marine Bird nests should be included in the Shipping Management Plan. • Include the Mary River Project when assessing cumulative effects on Marine Birds in Hudson Strait, including annual reporting. • Regarding monitoring of marine bird/Project vessel interactions along the shipping route.

  18. Recommendations Related to Migratory Birds and Species at Risk • Monitoring of spills should include reporting of the presence of oily sheens on the water near vessels at the port site and mitigation measures be implemented to reduce these discharges; • Identification of the steps that would be taken to protect wildlife (including marine birds) in the event of a spill, and incorporate those steps into the Meliadine Gold Project Spill Contingency Plan;

  19. Recommendations Related to Migratory Birds and Species at Risk • Regarding potential marine bird collisions with Project vessels along the shipping route. • Ship speed be reduced sufficiently to ensure that wakes are equal or less than the mean natural seasonal wave height to prevent wake action from negatively impacting migratory bird nests in low lying shoreline habitat. • Regarding migratory birds and species at risk along the shipping route. • Regarding avoiding the disturbance and destruction of nests and eggs of migratory birds.

  20. Recommendations related to Migratory Birds and Species at Risk • Regarding water management ponds, lake dewatering, and migratory birds. • Regarding communications towers and mitigation of migratory bird collisions. • Reduce aircraft disturbance to migratory birds, subject to pilot discretion regarding safety. • Regarding potential increase in predation on migratory birds through attraction of predators to operations.

  21. Recommendations related to Migratory Birds and Species at Risk • When dewatering water bodies, mitigation measures should be implemented, such as dewatering outside of periods when there is high migratory bird use of these ponds (i.e., nesting, brood rearing and/or migration periods). In addition, EC recommends mitigation measures be provided in the fish salvage plan, and implemented during field activities. • Errors with regards to shorebird species classification be corrected in forthcoming reports and management plans.

  22. Conclusions • The conclusions drawn in the FEIS are generally supported by the analysis. • Requested monitoring will ensure project-related impacts can be detected and will support better adaptive management decision-making. • The Proponent has generally followed EC’s Guidelines for the Assessment of Alternatives for Mine Waste Disposal (EC, 2012). • EC is generally pleased by the Proponent’s response to EC’s Technical Review (July, 2014) of the FEIS. EC looks forward to continuing to work with the Proponent.

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