Gi Giant M Mine R Remediation on Proj oject t Water Licence Intervention – Slater Environmental Consulting
Role o of S f Slater Environmental C Consulti ting Independent Advisor to Giant Mine Working Group (GMWG) Role in Water Licence Process • Terms of Reference: “…provide • “Jointly engaged expert” independent technical expertise • Role options discussed by GMWG in and advice … to the GMWG…” early 2019 • City of Yellowknife letter to Board, • Principles: May 2019 • Independence • “…provide evidence and have • Collaboration that evidence examined…” • Transparency • Independent: not presenting • May 2014 position of the GMWG, or any party on the GMWG Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 2 Working Group
Presenta ntation C Cont ntext • Review comments provided on May 25, 2019: “ Review of Post-EA Information Package Giant Mine Remediation Project ” • Addressing topics raised by GMWG representatives • Participation in July 2019 Technical Session • Review of additional information • Review of discussions at September 2019 Workshop and Technical Session • Written intervention November 14, 2019: “ Licensing Recommendations – Giant Mine Remediation Project ” • Review of December 2, 2019 Response to Interventions Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 3 Working Group
Recomme mmendation 1: Future Land Use Constraints • Not practical to remediate soils across the site to the Yellowknife industrial remediation standard of 340 mg/kg of arsenic • Soils with elevated arsenic concentrations are widespread across the site and beyond • Soils with concentrations as high as at least 3000 mg/kg will be left in place – a permanent exposure source for humans and the environment • Permanent administrative control of future land use activities • Long-term legacy for future generations – challenges for long-term management of human activities Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 4 Working Group
Recomme mmendation 1: Future Land Use Constraints • Human Health Risk Assessment: • Risks are low if human use is limited • Moving through the area – e.g., walking, cycling, running • Casual use for short periods of time Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 5 Working Group
Recomme mmendation 1: Future Land Use Constraints Objectives Criteria • Understanding versus Action • Communication versus Constraints/Action • “Residual risks are identified, and local • Purpose of communication is to create residents have been, and continue to be, appropriate day-to-day action – e.g., not informed of residual hazards” camping in areas with high arsenic concentrations Versus • Criterion should focus on the desired land use • Residual risks are identified and local outcome – that is what we need to measure residents use this information to make and • Land use constraints are also needed implement land use decisions that avoid • What are the rules and how do we make sure unacceptable risks they are permanent? • E.g., no residential development in certain areas • Criterion should focus on whether we have appropriate constraints in place Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 6 Working Group
Recomme mmendation 1: Future Land Use Constraints • Recommendation: • Board should require the co-proponents to establish definitive administrative constraints on future land use in parts of the project area that have soil arsenic concentrations that exceed residential standards but do not include physical barriers • Board should require progress reporting on the establishment of these constraints and monitoring of their effectiveness • Not about what future land use will be – rather what it CANNOT be. • Will require the co-proponents to use broader government authority • Perpetual Care Plan • Areas both inside and outside the lease boundary Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 7 Working Group
Recomme mmendation 2: Potenti tial Ecological Risks • Ecological Risk Assessment: • “…there is the potential for the smaller animals at the site to be affected by arsenic and antimony.” • Response to interventions: • Future Monitoring: • HHERA had sufficient data to draw • Biological studies to examine the conclusions health of vegetation at the site • No significant uncertainties • Collection of insect data to verify • Wildlife and Wildlife Habitat assessment assumptions MMP • Examination of any differences in abundance and diversity of • No components aimed at vegetation and mammals addressing the recommendations from the risk assessment. • Other post-remediation monitoring Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 8 Working Group
Recomme mmendation 3: Proactive Ad Adaptive M Management • Adaptive management in the context of a mining project: • Consistent and transparent framework for responding to deviations in project performance or unforeseen environmental (social, cultural?) conditions • Pre-planned framework for making quick and efficient decisions • Current GMRP proposal: • Contingency measures in management plans: e.g., Tailings Monitoring and Management Plan – Contingency action if water quality exceeds discharge criteria • Response plans in aquatic environment: e.g., in Yellowknife Bay Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 9 Working Group
Recomme mmendation 3: Proactive Ad Adaptive M Management • Identify project aspects with uncertainty that could lead to changing or unexpected performance • Proactive monitoring to detect changing conditions at locations and within timeframes that allow for effective response. • Clear and defensible triggers that will ensure timely implementation of effective responses. • Clear and transparent process for developing appropriate management responses in response to triggers being reached or exceeded. Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 10 Working Group
Recomme mmendation 3: Proactive Ad Adaptive M Management • What should we monitor and where should we monitor if we want to detect and respond to changes quickly? • How do we know when we need to respond? • What responses can we make? • What processes will help us figure out what to do? Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 11 Working Group
Recomme mmendation 3: Proactive Ad Adaptive M Management • Comprehensive Adaptive • Adaptive management Management Plan for Phases 1 components and 2 • Indicators • Monitoring • Key areas of performance • Thresholds/action levels uncertainty, e.g.: • Analysis/interpretation methods • Covers and timing • Loading from pit runoff • Responses • Conditions in remediated Baker • Reporting Creek • Part of environmental • Runoff and seepage from remediated areas management Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 12 Working Group
Recomme mmendation 4: Long-term rm Ad Administration a and F Funding Phase 2 – Closure Implementation Phase 3 – Post-closure • Government project • Will the same mechanisms work? • Government proponents • Report of Environmental • Main Construction Manager Assessment – Measure 6 • Government appropriations • Challenges re: funding for very long- term projects • Investigation of long-term funding options – post-closure maintenance and contingencies • Consider trust fund with multi-year up front funding Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 13 Working Group
Recomme mmendation 4: Long-term rm Ad Administration a and F Funding • Permanent requirements: • Maintenance of water management structures • Pumping and water treatment • Maintenance of freezing system • Administrative delivery mechanisms and funding mechanisms are linked • Additional work is needed to figure out what combination of delivery and funding mechanisms makes sense for the post-closure GMRP Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 14 Working Group
Recomme mmendation 4: Long-term rm Ad Administration a and F Funding • Recommendations: • Limit licence term to Phase 2 • Require additional work to evaluate and select effective long-term administration and funding mechanisms • Engage public and affected parties Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 15 Working Group
Recomme mmendation 5: Pi Pit Backfilling and Covers • Recommendation: Board should require further analysis and design related to pit remediation, including about materials for pit filling and the need for pit covers. • Additional information about materials has been shared, and further work is proposed • Need for pit covers remains uncertain and warrants further discussion Slater Environmental Consulting - Advisor to Giant Mine December 12, 2019 16 Working Group
Recommend
More recommend
