The Government of the Northwest Territories Department of - PowerPoint PPT Presentation

The Government of the Northwest Territories Department of Environment and Natural Resources (ENR) Public Hearing Presentation Fortune Minerals Ltd. Water Licence Application W2008L2-0004 Behchokǫ̀ , NT February 25 and 26, 2014

Presentation Overview • Conceptual Management Plans • Waste Management and Incineration Management Plans • Waste Management: Petroleum Hydrocarbons (Water and Soil) • Spill Contingency Plan • Information Request #6 - ETF Performance Evaluation • Closing

Conceptual Management Plans • The proponent has provided conceptual management/mitigation plans because the mine design has not been finalized. • Management plans are key to minimizing impacts to the environment.

Conceptual Management Plans - ENR Recommendations 1) The proponent submit for approval all management plans on a milestone basis. Each plan should be submitted prior to the activity, construction and operation

Conceptual Management Plans - ENR Recommendations 2) The Waste Management and Incineration Management Plan (WMIP) and the Spill Contingency Plan (SCP) be updated within 30 days after the issuance of a LUP/WL. In addition, as the mine design is finalized, any major changes (i.e. additional fuel storage, fundamental process changes etc.) to the WMIP and SCP must be submitted 60 days prior to the alteration for review and approval by the Board.

Conceptual Management Plans - ENR Recommendations 3) For all other management plans, the submission should correspond to major milestone events (discharge of mine effluent, explosive magazine construction etc.) as the mine design is finalized. All management plans be submitted a minimum of 60 days prior to the activity or after substantial alteration, as is consistent with other mine sites regulated by the WLWB.

Waste Management and Incineration Management Plans • ENR met with proponent on January 21, 2014 to further discuss outstanding issued identified during the technical sessions held by the WLWB. • The proponent committed to looking into alternative options for waste management, however no written commitments have been provided at the time of this intervention. • It is anticipated that updates will be incorporated into the final WMIP.

Waste Management and Incineration Management Plans - ENR Recommendations 1) The proponent provide an updated management plan that addresses the concerns raised in ENRs written intervention and throughout the process.

Waste Management and Incineration Management Plans - ENR Recommendations 2) The WLWB include a testing requirement for waste oil and residual ash, including analytical criteria, in the WL for the management of potentially hazardous waste.

Waste Management: Petroleum Hydrocarbons (Water and Soil) • ENR met with proponent on January 21, 2014 to further discuss outstanding issued identified during the technical sessions held by the WLWB. ENR has concerns with respect to the petroleum hydrocarbon management, in water and soil, at the NICO site. • No commitments have been provided in a finalized plan, though it is anticipated that updates will be incorporated at a later date.

Waste Management: Petroleum Hydrocarbons (Water and Soil) • ENR notes that the treatment of petroleum hydrocarbon contaminated water may be necessary once underground sumps are established for the NICO Site. • Because all water will be directed to a central location (surge pond), the current Effluent Treatment Facility (ETF) may not be able to remove hydrocarbon contaminants from water.

Waste Management: Petroleum Hydrocarbons – ENR Recommendations 1) The proponent provide a Landfarm Management Plan (LMP) a minimum of 60 days prior to its construction. 2) LMP should include engineered drawings and details of its design, operation and waste segregation methods.

Waste Management: Petroleum Hydrocarbons – ENR Recommendations 2) Landfarm design should specify details on a soil cell and a separate cell for hydrocarbon-impacted snow/water. Design must include a method for water treatment of petroleum hydrocarbon-impacted water.

Waste Management: Petroleum Hydrocarbons – ENR Recommendations 3) The WLWB should include both soil and water treatment criteria for petroleum hydrocarbons in the WL. • Potential Licence Criteria for soil, if it is to be used for cover at closure, should be based on the GNWT Contaminated Site Remediation Guidelines agricultural criteria and/or Canadian Council of the Ministers of the Environment Canada-Wide Standard for Petroleum Hydrocarbons agricultural/wildland criteria be adopted for the remedial targets.

Waste Management: Petroleum Hydrocarbons – ENR Recommendations • Potential licence criteria of hydrocarbon- impacted water could be based on the Alberta Tier 1 Soil and Groundwater Remediation Guidelines for benzene, toluene, ethyl benzene and xylene and fraction 1 and 2 petroleum hydrocarbons (PHC).

Waste Management: Petroleum Hydrocarbons – ENR Recommendations 5) The proponent should provide an updated plan that includes the treatment of PHC impacted water. Specifically the proponent should indicate if the ETF will be designed with the ability to treat hydrocarbon- impacted water from the surge pond and landfarm. Alternatively provide secondary options for treatment or a contingency for complete removal of impacted water from site in its waste management plan.

Spill Contingency Plan • ENR met with proponent on January 21, 2014 to further discuss outstanding issued identified during the technical sessions held by the WLWB. • The proponent has committed to addressing the deficiencies in the SCP, however no written commitments have been provided at the time of this intervention.

Spill Contingency Plan – ENR Recommendation 1) The proponent submit for Board approval an updated SCP within 30 days of the issuance of a LUP/WL. Additionally, if there are significant alterations to the SCP that it be re-submitted to the Board a minimum of 60 days prior to the alteration for approval.

Information Request #6 ETF Performance Evaluation - Proponent’s Conclusion • ENR commends the proponent for agreeing to conduct bench scale study on simulated effluent prior to the end of construction and prior to discharge. ENR notes that bench scale testing may affect the calculations required for the Effluent Quality Criteria (EQC) and may alter the WL criteria.

ENR Review • Bench scale studies are imperative for the protection of down-stream aquatic ecosystems and for establishment the EQCs. • This information is required to develop the maximum and average daily discharge limits and is critical prior to discharge from site.

Closing