De Beers Canada Inc. Snap Lake Diamond Mine Water Licence Renewal Fisheries and Oceans Canada Intervention December 13-15, 2011 Yellowknife
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 oceans and fresh waters.
Issue: Term of Licence Recommendations • The licence term should be 5-8 years. • De Beers has proposed an 8 year term.
Issue: Adaptive Management Plan 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 operations of the Snap Lake Diamond Mine.
Issue: TDS limits around Fisheries Compensatory Habitat Sites 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 of 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 limit Recommendations • DBCI assess alternative solutions to reduce the TDS concentrations at the source(s).
Issue: TDS limits around Fisheries Compensatory Habitat Sites 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: Dissolved Oxygen Monitoring 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 •DBCI agrees with our recommendations regarding incorporation of DO monitoring into the WL; this issue is resolved.
Issue: Best Available Technology 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: Aquatic Effects Monitoring Program 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 of 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: Closure 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.
DBCI agrees with most of our recommendations Summary DFO has made 17 Recommendations • •
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