1. Review of Meadowbank Water License Application: Public Hearing
Presentation to NWB
by Department of Environment Government of Nunavut (GN-DOE)
S 1. Introduction
Mr. Chairman, my name is Helen Yeh, Acting Manager for Land Use & Environmental Assessment with the Government of Nunavut, Department of Environment or GN-DOE.
I will be presenting on behalf of GN-DOE for our review on the Meadowbank Gold Mine Water License Application, submitted by Agnico Eagle Mines Limited or AEM.
Prior to this Public Hearing, GN-DOE undertook a technical review of this water license application in line with our mandate and legislation.
April 15 – 17, Baker Lake

2. GN-DOE Legislated Role
Environment Protection Act
The Environmental Protection Act provides GN-DOE with the authority to regulate the discharge of contaminants and their impact on the environment.
Wildlife Act
This Act requires GN-DOE to ensure mitigation and regulation of land-use activities having significant impacts on wildlife and wildlife habitat.
Most issues continue to be dealt with through NIRB project certificate requirements not the water license.
CCME: Canada-Wide Standards (CWS)
S 2. GN-DOE Role in the Environmental Review Process :
Before I proceed with our review, I would like to describe to the board our legislation related to this project. These are the Environmental Protection Act, and the Wildlife Act.
The Environmental Protection Act:
The Environmental Protection Act creates the GN-DOE authority to regulate the discharge of contaminants and their impact on the environment. Within the Act, contaminant is defined as any noise, heat, vibration or substance as the Minister may prescribe. A number of regulations and guidelines have been developed and enacted under this act.
The Wildlife Act:
The Wildlife Act creates the GN-DOE authority for the management of human activities that impact wildlife. This Act requires GN-DOE to ensure mitigation and regulation of land-use activities having significant impacts on wildlife and wildlife habitat.
Most wildlife issues related to the Meadowbank project have been addressed during the Nunavut Impact Review Board (NIRB) environmental assessment process, and these issues will continue to be dealt with through NIRB project certificate requirements, not the water license.
CCME: Canada-Wide Standards (CWS) : other responsibilities
Finally, GN-DOE also has a responsibility under the Canadian Council of Ministers of the Environment or CCME – Canada Wide Standards as the Government of Nunavut is a a signatory to these Standards. The Canada-wide Standards are related to environment quality and human health, and are required to be complied with across Canada.

3. Issue Topics: Water Management & Water Quality Waste Management
Geochemistry
Contingency Planning
Monitoring
Closure & Reclamation
S 3. Topics of Concerns:
Our review and concerns or recommendations related to the Meadowbank water license application fall under the following 6 topics:
Water Management & Water Quality
Waste Management
Geochemistry
Contingency Planning
Monitoring
Closure & Reclamation

4. Issue # 1: Water Quality
Discharge standards to the environment from Portage Diffuser & Wally Lake Diffuser.
Recommendation:
AEM is committed to meet MMER standards at Wally Lake & Third Portage Lake diffuser discharge points.
AEM is also committed to meet CCME – Fresh Water Aquatic Life guidelines within a 30 m radius of the two diffusers or site specific discharge criteria.
Commitments above are recommended to form a term of the water license if issued.
S Issue # 1: Water Quality : Discharge standards to the environment from Portage Diffuser & Wally Lake Diffuser.
During years 4 to 8 of mine operation, discharge to the environment in the Vault area is planned from the Vault Attenuation Pond through a diffuser into the Wally Lake. In the Portage area, from years 1 to 5, discharge during operation to the environment will be from the Portage Attenuation Pond into the Third Portage Lake. GN-DOE were previously unclear about the discharge standards.
AEM indicated that discharges would comply with the Metal Mining Effluent Regulations or MMER at the diffuser discharge points. AEM further indicated in their Mar. 7 response document and at the Technical Meetings, that they will ensure water quality meets either the CCME – Fresh Water Aquatic Life guidelines within a 30 meter radius of the two diffusers or site-specific criteria approved by Environment Canada.
GN-DOE is satisfied with AEM’s commitments, and recommends the commitments form a term of the water license if issued.

5. Issue # 2: Water Management
Refining and updating of water quality predictions and water management plans.
Recommendation:
AEM is committed to refine and update water quality predictions and management plans including treatment needs based on operational monitoring data; these updates should be provided to NWB for review.
Commitment above is recommended to form a term of the water license if issued.
S Issue # 2: Water Management: Refining and updating of water quality predictions and water management plans.
AEM proposes water management and mitigation measures that would control and minimize discharges to the environment for water in contact with mine site components. AEM also proposes treatment methods to address concentrations of total suspended solids, metals and cyanide species.
It is identified by AEM that during years 6 to closure, there are possible exceedances of cyanide and copper in the Portage area. There is also a concern of potential arsenic exceedances. AEM is committed to implement the treatment if required to address these concerns.
In the GN-DOE Feb. 13, 2008 technical submission, we commented that even the best models can not compare with the evaluation of operational monitoring data that allows for refined water quality predictions and management plans, including treatment needs. GN-DOE therefore recommended that AEM refined water quality predictions and management plans based on monitoring data during operation. AEM concurred with our recommendation.
AEM’s commitment to refine and update water quality predictions and management plans based on updated monitoring data, is recommended to form a term of the license if issued.

6. Issue # 3: Sewage Treatment & Management
Treated sewage discharge standard & restoration of the storm water management pond (Tear Drop Lake).
Recommendation:
AEM has committed to meet the Guidelines for the Discharge of Treated Municipal Wastewater in the Northwest Territories for treated sewage discharge, and to monitor the quality of the discharge. This is advised to form a term of the water license if issued.
AEM should restore water quality in Tear Drop Lake to appropriate standards. This is advised to form a condition of the water license if issued.
S Issue # 3: Sewage Treatment & Management: Sewage discharge standard & restoration of the storm water management pond (Tear Drop Lake).
1. During mine construction, treated sewage will be discharged to a fishless lake, namely the Tear Drop Lake. The Lake will be built up in depth with installation of impervious walls to serve as a storm water management pond. AEM has stated that a Rotating Biological Contacting or RBC sewage treatment system will be installed, and that the effluent discharge will meet the Guidelines for the Discharge of Treated Municipal Wastewater in the Northwest Territories. AEM also is committed to monitor the quality of the treated sewage effluent prior to the discharge.
This commitment is recommended to form a term of the water license if issued.
2. However, upon mine closure, it is unclear whether or not AEM plans to restore the water quality of the Tear Drop Lake to appropriate standards. GN-DOE recommends AEM restores the lake water to appropriate standards, such as the CCME: Fresh Water Aquatic Life guidelines, upon closure.
This recommendation is recommended to form a term of the water license if issued.

7. Issue # 4: Landfill and Landfarm
Design / Construction / As-Built Drawings
Submission and review of these drawings.
Recommendation:
AEM has committed to submit, construction drawings for the landfill #1 and the landfarm prior to construction.
AEM should also provide both final design and construction drawings for Landfill#2.
As-built drawings should be submitted for both the two landfills and the landfarm.
Above should form a term of the water license if issued.
S Issue # 4: Landfill and Landfarm Design / Construction / As-Built Drawings : Submission and review of these drawings.
There are 2 landfills and a landfarm proposed for the Meadowbank project. AEM indicated final construction drawings for these facilities will be based on final design drawings, stamped by professional engineers.
To date, AEM has submitted final design drawings stamped by professional engineers registered in the Northwest Territories for the landfill #1 and the landfarm. AEM further commits to provide construction drawings for review prior to construction.
For the landfill #2, as it will be built upon a structure to be built during mine operation, AEM proposed that the final design drawing to be submitted prior to commissioning the landfill. GN-DOE further recommends the construction drawing for the landfill #2 be submitted prior to construction.
Finally, we recommend as-built drawings for both 2 landfill and the landfarm are submitted.
These commitments and recommendations discussed above are recommended to form a term of the water license if issued.

8. Issue # 5: Landfill Management
Landfill management and relevant government guidelines.
Recommendation:
AEM’s commitment to comply with relevant government guidelines or policies in the context of landfilling asbestos, equipment containing ozone-depleting substances, and fluorescent lamp tubes, should form a term of the water license if issued.
S 8. Issue # 5: Landfill Management : Landfill management and relevant government guidelines.
AEM has outlined a list of materials to be landfilled including asbestos, white goods (i.e., refrigerators), and light bulbs (i.e., fluorescent lamp tubes); however, AEM did not provide detailed landfilling procedures for these items. This concern was raised by GN-DOE on Feb. 13, 2008.
In response to GN-DOE concern, AEM responded on Mar. 7, 2008 with a commitment to handle, segregate and manage these above mentioned wastes according to relevant federal and territorial guidelines.
GN-DOE is satisfied with this commitment, and recommends this commitment forms a term of the water license if issued.

9. Issue # 6: Remediation Guidelines for Hydrocarbon Contaminated Soil
Recommendation:
AME is also committed to meet appropriate remediation standards:
Canada-Wide Standards for Petroleum Hydrocarbons (PHC) in Soil
GN-DOE Guideline for Contaminated Site Remediation
For remediation of hydrocarbon contaminated soil, AEM is committed to measure appropriate parameters:
hydrocarbon Fraction 1, Fraction 2, total petroleum hydrocarbon (TPH), and BTEX (benzene, toluene, ethylbenzene and xylene).
Above commitments should form a term of the license if issued.
S Issue # 6: Remediation Guidelines for Hydrocarbon Contaminated Soil
For remediation of hydrocarbon contaminated soil, AEM has committed in their Mar. 7, 2008 response document that they will comply with appropriate guidelines.
Specifically, AEM is committed to comply with both the CCME Canada-Wide Standards, and the relevant GN-DOE Guideline. Additionally, AEM is committed to measure hydrocarbon Fraction 1, Fraction 2, total petroleum hydrocarbon (TPH), and BTEX (benzene, toluene, ethylbenzene and xylene) during the remediation process.
GN-DOE is satisfied with AEM’s commitments discussed above, and recommends these commitments form a term of the water license if issued.

10. Issue # 7: Acid Rock Drainage (ARD) and Metal Leaching (ML)
Re-evaluation of ARD/ML potential.
Recommendation:
AEM’s commitment to re-evaluate ARD/ML potential and to confirm that rock characterization and waste rock volume calculations are still valid, is recommended to form a term of the water license if issued.
AEM’s commitment to survey rock quality and drainage water chemistry at quarry sites along the all-weather road, to address ARD/ML concerns, and to finalize quarry closure plans, is recommended to form a term of the water license if issued.
S Issue # 7: Acid Rock Drainage and Metal Leaching (ARD and ML) : Re-evaluation of ARD/ML potential.
AEM has developed sampling and management plans for potentially acid generating (PAG) materials to mitigate the potential for acid rock drainage (ARD) and metal leaching. Additionally, AEM developed a Water Quality and Flow Monitoring Plan to track changes in drainage chemistry.
In the GN-DOE Feb. 13, 2008 submission, we raised a concern about how changing ARD test methods during re-evaluation of ARD and ML may affect rock characterization and volume calculations of waste rock. The difference in test results may affect overall plans for management of waste rock. AEM indicated in their Mar. 7, 2008 response document that all additional test results collected in the future will be used to verify the current information.
Additionally, in the GN-DOE Feb. 13, 2008 submission, we identified a concern about insufficient testing for ARD and metal leaching potential for materials along the all-weather road (i.e., quarry sites). AEM responded on Mar. 7, 2008 that they will be “surveying rock quality and drainage water chemistry at each quarry site over the summer of 2008 in order to finalize quarry closure plans.”
GN-DOE recommends these commitments discussed above, form a term of the water license if issued.

11. Issue # 8: Metal Leaching
Lack of correlation between total metal concentration and metal leaching rate for waste rock.
Recommendation:
AEM is committed to re-evaluate metal leaching potential by establishing correlations between total metal concentration and metal leach rates for NPAG (Non-Potentially Acid Generating) materials.
This is recommended to form a term of the license.
S Issue # 8: Metal Leaching : Lack of correlation between total metal concentration and metal leaching rate for waste rock.
In the GN-DOE Feb. 13, 2008 submission, we identified the lack of correlation between total metal concentration and metal leaching rate for waste rock. Without this correlation, it is difficult to understand metal leaching potential of NPAG materials, which are to be used for construction and capping materials.
AEM responded in their Mar. 7, 2008 response document that they will continue to conduct total metal analysis and Shake Flask Extraction tests. AEM is also committed to continue operating humidity cells and large field cells to better understand metal leaching potential and leaching rate for both NPAG and PAG materials.
GN-DOE recommends this commitment forms a term of the water license if issued.

12. Issue # 9: Landfarm Management & Contingency Planning
Landfarm capacity and contingency planning to handle large spills.
Recommendation:
AEM should provide contingency planning details for large spills where the landfarm can not accommodate contaminated materials; This is recommended to form a term of the water license if issued.
S 12. Issue # 9: Landfarm Management & Contingency Planning : Landfarm capacity and contingency planning to handle large spills.
Soil contaminated by spills is to be treated in an on-site landfarm and remediated to the CCME Canada-Wide Standards, and the GN-DOE guidelines. In the case when there are large spills and the tank farm can not accommodate, AEM will temporarily store the contaminated spill materials at the tank farm bermed area or construct a second landfarm to meet the needs. However, details related to these contingency measures have not provided for review.
Details such as the following should be provided. For example, how long will contaminated materials be stored at the tank farm, considering that the tank farm bermed area will have reduced capacity in the event of a spill? What is the implication of this storage on the liner within the tank farm? Will the liner be degraded?
Furthermore, AEM should provide more planning details regarding potential construction of a second landfarm. Details such as location, size, and design are important. Additionally, AEM needs to consider the construction needs of the facility such as manpower and materials, to ensure that they are able to build the facility rapidly in an emergency situation.
Consequently, GN-DOE recommends more details related to these contingency measures for handling of large spills are provided for review. This is recommended to form a term of the water license if issued.

13. Issue # 10: Spill Contingency Planning Recommendation:
AEM’s commitment to revise the Spill Contingency Plan as needed (yearly as a minimum), is recommended to form a term of the water license if issued.
The revision of the Spill Contingency Plan should incorporate GN-DOE’s detailed comments submitted on Feb. 13, This recommendation is advised to form a term of the water license if issued.
S Issue # 10: Spill Contingency Planning
GN-DOE believes the Spill Contingency Plan submitted by AEM is generally satisfactory. AEM is committed to revise their spill plan, yearly as a minimum and as needed. This commitment is recommended to form a term of the water license if issued.
However, in the GN-DOE Feb. 13, 2008 submission, we noted some areas in the spill plan that could be improved. AEM in the Technical Meetings in Baker Lake indicated their willingness to incorporate our comments and improve the plan; however, this commitment has not been noted in the AEM’s Mar. 7, 2008 response document.
GN-DOE therefore recommends AEM incorporate GN-DOE’s comments when they revise the spill contingency plan. This is recommended to form a term of the water license if issued.

14. Issue # 11: Thermal Monitoring & Tailings Storage Facility (TSF)
Uncertainty about post-closure thermal monitoring period for the TSF.
Recommendation:
AEM is committed to conduct thermal monitoring (a minimum of 15 years) to ensure the TSF core post closure will be frozen in perpetuity, and does not present environmental risk; a license requirement.
Annual reporting of thermal monitoring results, is recommended to form a term of the water license if issued.
S 14. Issue # 11: Thermal Monitoring & Tailings Storage Facility (TSF)
AEM predicted that frozen conditions within the Tailing Storage Facility (TSF) will take 10 to 15 years. Once frozen conditions are established, the ability of the tailings to produce acid and leach metals will be minimized. However, we previously were unclear about the period of the thermal monitoring proposed.
In AEM’s Mar. 7, 2008 response document, AEM indicated that they will monitor thermal condition within the TSF through the final decommissioning phase and the post-closure time period until “it can be clearly demonstrated that the underlying tailings mass has fully frozen and no longer presents an environmental risk to the surrounding environment. For the purposes of estimating reclamation liability it has been assumed that this will require a minimum post closure time period for this monitoring of 15 years.”
GN-DOE is satisfied with AEM’s commitment to conduct thermal monitoring of the TSF until the TSF does not present an environmental risk. We further recommend the thermal monitoring result be reported annually. These commitment and reporting requirement are recommended to form a term of the water license if issued.

15. Issue # 12: Thermal Monitoring & Rock Storage Facilities (RSF)
Recommendation:
AEM is committed to monitor thermal conditions and chemical/ physical stability in the Portage RSF and the Vault RSF.
AEM also commits to implement mitigation measures if these stable conditions are not present.
These commitments should form a term of the water license if issued
S Issue # 12: Monitoring & Rock Storage Facilities (RSF)
Waste rock from mining operations will be disposed of in two waste rock storage facilities (RSFs); these are the Portage and Vault RSFs. The establishment of frozen conditions within these facilities will minimize the likelihood of acid rock drainage and metal leaching.
AEM indicates in their Mar. 7, 2008 response document that they “intend to monitor thermal conditions and chemical drainage conditions in both RSFs to verify physical and chemical stability. Mitigative measures will be employed if monitoring indicates that chemical and physical stability are not present.”
GN-DOE is satisfied with this commitment, and recommends this forms a term of the water license if issued.

16. Issue # 13: Dikes Breaching & Water Quality
Water quality in pit lakes prior to breaching of dikes.
Recommendation:
AEM’s proposal to meet CCME-Fresh Water Aquatic Life guidelines, or site specific criteria in pit lakes prior to dike breaching.
The site specific criteria above should be approved by Environment Canada.
These commitment and recommendation above are recommended to form a term of the license if issued.
S 16. Issue # 13: Dikes Breaching & Water Quality : Water quality in pit lakes prior to breaching of dikes.
Dikes separating the flooded open pits from nearby lakes will eventually be breached, and the water in the pit lakes may contain elevated levels of metals and other undesired substances. In the GN-DOE Feb. 13, 2008 submission, we raised a concern about the water quality in the pit lakes at the point where the dikes are breached. Inadequate water quality within the pit lakes will affect the surrounding lake water quality when the dikes are breached.
In response to our concern, AEM in their Mar. 7, 2008 response document states that they “propose to breach the dikes only where water quality within the pit lakes meets CCME Aquatic Life Guidelines (CCME, 2006), background lake concentrations, or other risk based assessment criteria as determined through aquatic effects studies and/or an approvals process initiated through the Nunavut Water Board and KIA.”
GN-DOE supports AEM’s proposal to meet CCME Fresh Water Aquatic Life guidelines, or site specific criteria, within pit lakes prior to dike breaching. The site specific criteria should be approved by Environment Canada. These commitment and recommendation are recommended to form a term of the water license if issued.

17. Issue # 14: Closure Plans for Tailings Storage Facility
(TSF) & Rock Storage Facilities (RSF)
Updating closure plans for TSF and RSFs.
Recommendation:
AEM should revise closure plans for the TSF and the two RSFs as operational information and management plans are revised. This is recommended to form a term of the water license if issued.
S 17. Issue # 14: Closure Plans for Tailings Storage Facility (TSF) & Rock Storage Facilities (RSF) : Updating closure plans for TSF and RSFs.
As indicated in the previous slides, AEM is proposed to have one Tailings Storage Facility (TSF), and two Rock Storage Facilities (RSFs); namely Vault and Portage RSF. In the GN-DOE Feb. 13, 2008 submission, we indicated that closure success of the TSF and RSFs is based on assumptions such as correct rock characterization, and establishment of frozen condition within the cores of the TSF and the RSFs. However, there are underlying field realities that may affect these assumptions during mine operation. GN-DOE therefore recommended that AEM revises closure plans for the TSF and the two RSFs as operational information and management plans are revised.
AEM, in their Mar. 7, 2008 response document, indicated that they will update their closure plan for the Vault RSF based on additional rock characterization information; however, it is unclear to GN-DOE if this commitment to update closure plans will also be applied to the TSF and the Portage RSF.
Therefore, GN-DOE recommends AEM revises closure plans for the TSF and the two RSFs as operational information and management plans are revised. This is recommended to form a term of the water license if issued.

18. Issue # 15: Re-vegetation & Reclamation
Concerns for short monitoring period for re-vegetation.
Recommendation:
AEM’s commitment to monitor vegetation recovery on the disturbed mine site until the success of re-vegetation, is recommended to form a term of the water license if issued.
S Issue # 15: Re-vegetation & Reclamation : Concerns for short monitoring period for re-vegetation
Re-vegetation during and post closure is an important step for successful restoration of a disturbed site. In the GN-DOE Feb. 13, 2008 submission, we were concerned about the short monitoring period for re-vegetation post closure, considering re-vegetation can take decades. AEM previously proposed that they would monitor re-vegetation until year 11 post closure.
In response to GN-DOE concern, AEM in their Mar. 7, 2008 response document stated that “AEM will continue to monitor the conditions at the reclaimed Meadowbank site, including the success of revegetation measures until the landowner (the KIA) and the NWB are satisfied that the site is chemically and physically stable and that the ongoing risk of release of contaminants to the surrounding environment has been adequately addressed.”
GN-DOE is satisfied with AEM’s commitment, and recommends this commitment forms a term of the water license if issued.

19. Summary This Water License Application, and its supplemental
information submitted by AEM describe measures to
mitigate and manage potential impacts resulting from the
Meadwobank project. The Application generally provides
satisfactory mitigation and management procedures for all
waste streams and hazardous materials.
We GN-DOE thanks the Nunavut Water Board for the
opportunity to comment on this license application.
S 19. Summary
To sum up, this Water License Application submitted by AEM describe measures to mitigate and manage potential impacts resulting from the Meadwobank project. The Application generally provides satisfactory mitigation and management procedures for all waste streams and hazardous materials. GN-DOE supports this license application moving forward if the concerns and recommendations discussed above are addressed.
We GN-DOE thanks the Nunavut Water Board for the opportunity to comment on this license application.

20. Nakurmik! Thank you! Any comments or Questions?
Nakurmik! Qujannamik! Thank you.
Any questions or comments?