EC Technical comments on Mary River FEIS
Reference: Volume 7, Table 7-3.8, p. 108
A threshold value is included in the Table for beryllium which references the hardness-dependent
equation for deriving a site-specific water quality guideline for cadmium. Please clarify how the
beryllium threshold value was calculated.
No threshold value was provided for cobalt in Table 7-3.8. EC requests that the Proponent clarify
what thresholds will be suggested for cobalt.
The equation provided in the footnote for the derivation of the site-specific Canadian Water
Quality Guideline (CWQG) for nickel is incorrect. The footnote currently references the hardnessdependent equation for determining a site-specific CWQG for lead instead of nickel. EC requests
the Proponent confirm the correct equation was used when determining the site-specific CWQG
for nickel.
Reference: Type A Water Licence application, Explosives Management Plan
Section 2.6.1, p. 6
This section indicates solid ammonium nitrate prills will be stored in 1 tonne FIBC containers
approved for storage of this material. EC recommends that the acronym FIBC be defined in the
next iteration of the Plan.
Reference: Type A Water Licence application, Surface Water and Aquatic Ecosystems
Management Plan, Appendix 10D-2
Table 6.2, p. 19
This Table lists the facilities at the mine site which includes a facility identified as “Ore crushing
facilities and conveyor systems for the Milne Port trucking operation.” Given that shipping ore
from Milne Inlet has been removed from the project please clarify whether this facility is still part
of the mine site plan
Tables 6.1, 6.2, 6.3, 6.4, p. 17-25
These tables provide a list of all the facilities at each project area. An incinerator is absent from
each table even though each camp is expected to be supplied with one. In addition, the
temporary storage for sewage sludge is also not itemized in the list of temporary facilities for the
rail camps. EC recommends the next iteration of the Plan be revised to include the incinerators
and sewage sludge storage.
Section 6.3.2, p. 20, Section 6.5.3, p. 27
This section indicates that treated soil from the landfarm that meets appropriate criteria will be
used as landfill cover material or other acceptable purposes. EC requests that the Proponent
clarify what criteria will used to determine if treated soil from the landfarm is suitable for use as
landfill cover material or other purposes.
Section 6.4.4, p. 23
The following acronym, AREMA, is mentioned in the section but not defined. Please define this
term in the next iteration of this Plan.
Figure 5.3, p. 55
Figure contains a label for “proposed hydroelectric site”. Please clarify if the Proponent is
investigating development of hydroelectric power in the local study area.
Reference: Type A Water Licence application, Fresh Water Supply, Sewage, and
Wastewater Management Plan, Appendix 10D-3
General Comments
There are numerous undefined acronyms used in the Plan. EC recommends that acronyms such
as RBC, PLC, HMI, TOG be defined to make the plan more accessible to the public.
Table 5-2, p. 11
Table 5-2 lists the treated sewage discharge limits for the Milne Inlet and Mine sites as per Type
B water licence 2BB-MRY1114. EC notes that the faecal coliform limits cited in the Table have
been reversed for Milne Inlet and Mary River. Accordingly, the Milne Inlet limit should be <10,000
counts/100 mL and Mary River should be < 1000 counts/100 mL.
Section 5.4.1, p.13
Section 5.4.1 indicates that during the winter sewage waste at Milne Inlet is captured in latrines
and this waste is subsequently collected and incinerated. In addition, sections 5.4.1, 5.4.2 and
5.4.3 indicate that dewatered sludge will be incinerated. Please clarify whether the incinerators
proposed for sewage incineration were designed for this purpose.
Sections 5.4.4, 5.4.5, p. 16-17
Sections 5.4.4 and 5.4.5 indicate that sewage will be stored at the Mid-rail, Ravn River and
Cockburn North sites for much of the first year before roads are constructed. In addition, the
sewage storage capacity will be sized for one-week storage at the Cockburn South rail camp.
Please clarify the capacity of the sewage storage containers at each of the rail camps. Given the
inclement weather, as a contingency, EC recommends the Cockburn South sewage storage be
increased to accommodate more than 1 week storage in the event of road closures due to white
out conditions.
Table 6-1, p. 19; Section 9.2.2, p. 31
Table 6-1 of the Plan lists the Guidelines for Industrial Waste Discharges in Nunavut (GIWDN)
and Metal Mining Effluent Regulations (MMER) wastewater effluent discharge limits for a number
of parameters. However there are no units listed in this Table. EC notes that a similar Table is
presented on p. 31 and that the GIWDN thresholds are stated in mg/L. Assuming the GIWDN
limits are in mg/L, many of the GIWDN thresholds are 1-3 orders of magnitude higher than their
respective generic CCME water quality guidelines (e.g. Al, As, Cd, Cr, Cu, CN, Fl, Pb, Ag).
Please clarify what units were provided for the GIWDN. If these thresholds are presented in
mg/L, EC does not support their use as treated oily water discharge criteria.
Section 6.2.2, p.21
Under section 6.2.2, EC noted the Proponent plans to use DL-10 and calcium chloride as dust
suppressants on roads at the mine and Steensby sites in accordance with the Government of
Nunavut’s Environmental Guideline for Dust Suppression. This Guideline endorses the use of
Bunker C, calcium chloride and DL 10. EC does not recommend that DL-10 or calcium chloride
be applied within 30 m of water bodies intersecting or adjacent to the tote road or railway access
road, and that application rates be maintained such that product does not migrate from the
roadway. EC requests that the Proponent clarify if consideration has been given to the use of
water for dust suppression.
Section 6.2.1, p. 20
This section provides no information regarding the fate of treated oily water at Milne Inlet. It is
unclear if it is discharged into an overland outfall and then drained by gravity to the ocean?
Please clarify the fate of treated oily water at Milne Inlet.
Section 6.2.2, p. 21
The Plan indicates treated effluent from the oily water treatment plants in Mary River and
Steensby will be discharged, or recycled and reused as washdown water at the maintenance
shops. This section indicates the treated effluent will be ‘pumped to discharge’. Please clarify
where the treated effluent will be discharged.
Section 6.2.2, p.21
This section indicates that “run-off from the tank fuel storage areas will have to be treated by a
local oily water separator system that will be used as needed. The resulting water will be
discharged directly to the receiving body (Mine Site - Mary River, Steensby – Ocean). The water
will be periodically tested such that if any parameter is out of compliance the water will be
removed by vacuum truck and treated in the vehicle maintenance shop wastewater treatment
plant.” EC requests that the Proponent clarify where the treated effluent from the maintenance
shop wastewater treatment plant will be discharged?
Section 6.2.2, p.21
The Plan indicates “the emulsion plant shall be supplied with its own wastewater treatment plant
which utilizes an evaporation system to evaporate the water leaving solid residue and oil. This
residue will be tested for toxicity and if necessary taken off-site for disposal in a licensed facility
otherwise the waste will be land filled.” EC requests clarification on how toxicity will be tested and
what will constitute a pass/fail for the toxicity test. Also, if the residue is determined to be toxic,
EC requests a description of how it would be encapsulated in the landfill, and, suggests an
evaluation of landfarm disposal be considered.
Section 7.2.1.1, p. 24
The Plan states that “the monitoring plan is subject to relevant Federal and Provincial laws” and
“the frequency of sampling and testing will be determined by the ministry and outlined by the
certificate of approval”. EC recommends this section be updated to reflect the Nunavut context.
Sections 9.2 and 9.3, p. 30-31
These sections describe the location for sampling sewage effluent and treated oily water effluent
however the latitude and longitude for the sample points for each effluent type are the same for
all 3 sites (Milne, mine and Steensby). EC request that the Proponent clarify if the sampling
points are the same for each effluent type.
Reference: Type A Water Licence, Waste Management Plan for Construction, Operation
and Closure, Appendix 10D-4
Section 1.3, p. 4
The Petroleum Refining Liquid Effluent Regulations is referenced as one of the regulations that
might relate to the Mary River Project in terms of waste management. EC notes that the
aforementioned regulation applies to petroleum refineries and given that there are no plans to
establish refining facilities at the Mary River Project, EC requests that the Proponent clarify on the
relevance of this regulation for the Mary River Project.
Table 4.1, p. 10
This table indicates that, in addition to incineration, one of the disposal methods suggested for
biological sludge is landfilling. In contrast, the wastewater management plan does not make
reference to landfilling as a possible disposal alternative for dewatered sludge. EC requests that
the Proponent clarify if landfilling is to be used as a disposal method for dewatered sludge.
Section 4.3.3, p. 15
This section indicates that temporary waste management facilities will be constructed at all sites
(Mary River, Steensby Port, Milne Port, Ravn River Rail Camp, Mid Rail Rail Camp and South
Cockburn Lake Rail Camp), however the North Cockburn camp was not mentioned in the Plan.
EC requests that the Proponent clarify if a temporary waste management facility will also be
established at the North Cockburn rail camp.
Section 4.4.1, p. 18
This section indicates that “non-salvageable timber along with shrubs and other small woody
plants shall be chipped and mixed in with the grubbed material to be used on an ongoing basis as
soil cover and to stabilize disturbed slopes.” to aid with revegetation of disturbed areas during and
following construction. EC recommends this that section be updated to reflect vegetation
characteristic of the local study area. Given that the LSA is north of the treeline, non-salvageable
timber is not anticipated.
Section 4.4.3, p. 19
This section suggests that the Proponent and/or its contractors will be undertaking or
encouraging recycling practices where possible as follows:
With respect to construction waste, “it is anticipated that some of the contractors generating this
waste will carry out their own salvage of economically worthwhile recyclables, particularly ferrous
metals and copper, where a ready market exists. Typically tires, where the casings are sound,
are retreaded for ongoing use, reducing the materials requiring final disposal.
Polyethylene film - Film is used in large quantities to wrap and hence protect equipment. It is
anticipated that substantial amounts will be generated by unpacking equipment. Opportunities for
recycling this material will be explored and if practical the film will be baled and shipped for reuse.
Recyclable materials shall be placed in appropriate recycling bins or on pads by site personnel.
Containers shall be clearly marked and have signage reminding all workers of what is recyclable
and what is not. Recycling bins shall be placed alongside garbage bins to promote recycling
habits.”
EC requests that Baffinland clarify what commitments they will make with respect to recycling
practices.
Section 4.5.3, p. 24
This section suggests the Proponent will employ modified burn barrels to burn, among other
things, food waste and food packaging. The section states that “unburned materials from
modified burn barrels used to burn paper, paperboard packing, untreated wood, food waste, food
packaging and natural fibre textiles is suitable for burial in a designated pit or municipal landfill.”
EC requests that the Proponent clarify if modified burn barrels will be used for burning waste.
Section 4.5.3, p. 24
This section makes reference to a Toxicity Characteristic Leaching Procedure (TCLP) analysis
that is employed to verify bottom ash from the incinerator is suitable for landfill disposal. EC
requests the Proponent provide a copy of this protocol. EC also requests that the Proponent
clarify how frequently the TCLP analysis will be conducted on bottom ash. For example, will a set
of samples be taken for every burn cycle or will subsamples be taken per specified quantity of
accumulated ash?
Section 4.5.4, p. 24
This section indicates continuous monitoring will be used at all permanent incinerator units.
Further, each process and in‐stack monitor will be equipped with visible and audible alarms to
warn operators of poor incinerator operation. EC requests that the Proponent clarify which
parameters will be continuously monitored; what triggers a visible/audible alarm during
incineration operation and how a visible alarm manifests itself on the incinerator.
Section 4.6, p. 25
EC notes that the last sentence of the first paragraph is incomplete and Annex 5 has erroneously
been cited as the location to find the landfill design and closure details. These details are
provided in Annex 4. EC recommends these sections be revised in the next iteration of the Plan
Section 4.8, p. 28
This section indicates special bacteria may be introduced to ameliorate biodegradation of
hydrocarbon-contaminated soil in the landfarm. If effective remediation is not possible, the
Proponent will consider sourcing an off-site landfarm for disposal. EC requests more information
on the special bacteria that might be employed to assist with biodegradation of hydrocarboncontaminated soils. EC also requests that the Proponent clarify the feasibility of sending the soils
to an off-site landfarm. EC also recommends the Nunavut guidelines which outline landfarm
remediation objectives be properly referenced in the next iteration of this Plan.
Section 5, Roles and Responsibilities p. 29-33
It’s not clear what the reporting relationships are between the positions identified in Table 5.1 (i.e.
Construction Manager, HSE Manager, Environmental Lead) and Table 5.2. Further, the reporting
relationships for the management team identified in Table 5.2 are also not clear. Table 5.2
identifies one site coordinator but the text that follows references on-site coordinators. Under 5.1,
a reference to Site Managers is also made but these are not defined in Tables 5.1 or 5.2. In
addition, another position, Vice President of Sustainability, is also mentioned under section 5.2.
Lastly, a Maintenance and Warehouse HSE Manager is also mentioned under Section 5.5. It’s
not clear if this HSE Manager is the same Manager identified in Table 5.1.
EC requests a concise organization chart be provided that clearly delineates reporting structure
and roles and responsibilities for each of the senior staff responsible for ensuring waste
management practices are implemented at Mary River. In its current form, the Plan lacks
accountability. To that end, EC notes no one was identified as being responsible for maintaining
and updating the Environmental Protection Plans, which embody the mine’s operational
procedures and ensure the practices outlined in the waste management plan are implemented by
all staff.
Section 9, p.36
This section indicates that camp incinerators are installed at each of the camps associated with
the Mary River Project, namely Milne Port, Mine Site, Mid-Rail and Steensby. EC seeks
clarification whether incinerators will be installed at all rail camps.
Reference: Type A Water Licence, Waste Management Plan for Construction, Operation
and Closure, Annex 4, Mary River Landfill Operation Manual
Part A I(1), p. 3
This section identifies a Site Manager. This position was not identified in the Roles and
Responsibilities of the overall Waste Management Plan. For transparency and accountability, EC
recommends the landfill Site Manager be included in the organization chart related to waste
management for the Waste Management Plan.
Part A I(3), p. 4
As a minor edit, steps 3e and 3f of this procedure appear to be incomplete.
Appendix A, p. 17
Under Section 2, steel and pallets are identified as materials that can be recycled or reused. EC
seeks clarification from Baffinland if they are committed to recycling steel and pallets.
Reference: Type A Water Licence, Waste Management Plan for Construction, Operation
and Closure, Annex 5, Landfarm Operation Information
General
EC notes that this plan refers to outdated Type B water license, 2BB-MRY0710. This license was
re-issued as 2BB-MRY1114 on April 15, 2011 with an expiry date of April 15, 2014. EC
recommends the next iteration of this Plan be updated to refer to the correct water licence.
Section 3.1, p.2
This plan indicates the fuel bladder farm containment area is contaminated with 8000 L of Jet A
fuel. EC requests that the Proponent clarify what volume of soil is contaminated and an estimate
of how long the company anticipates it will take to remediate the contaminated soil via
landfarming.
Section 3.2, p. 3
This section indicates the less-impacted materials from the bladder farm may be re-used as
protective layer in the newly constructed landfarm facility. EC requests that the Proponent clarify
how the determination of “less-impacted soil” will be made. Specifically, EC requests that the
Proponent clarify if the soils will need to be below specified contaminant thresholds before they
can be used as the protective layer of the landfarm and if so, what will these thresholds be?
Section 4.2, p. 4
This section lists the chemical criteria that soil must meet before being disposed of at the
landfarm, however it is unclear how the Proponent will ensure the soils meet the specified criteria.
To that end, EC requests the Proponent indicate how frequent analysis will be conducted on soil
destined for the landfarm and how many samples will be taken per volume of soil?
Section 5.2, p. 6
This section indicates that water from the sewage lagoon polishing cell or sewage sludge could
be recycled and used to meet soil moisture requirements for the landfarm, thereby reducing
freshwater consumption. EC seeks clarification on whether Baffinland is committed to
institutionalizing this practice.
Section 6, p. 6
As a minor note, this section erroneously makes reference to the 2010 Government of Nunavut
Environmental Guideline for Contaminated Site Remediation. In the next iteration of the Plan,
this should be revised to 2009.
Section 7.2, p. 7
This section indicates contact water will be tested for F1 and F2 hydrocarbons. According to
section 3.1, Jet A fuel is anticipated to require treatment for F2 and F3 fractions. Given the
constituents of Jet A fuel, EC seeks clarification why contact water will not also be tested for the
F3 fraction.
Reference: Type A Water Licence application, Environmental Monitoring Plan, Appendix
10D-12
Table 2-3, p. 9
This section indicates annual stack testing will not be required for the incinerators located at the
mine site and Steensby Port since they will be equipped with CEMS. For transparency, EC
recommends CEMS be defined in the next iteration of this Plan.
Section 4, p. 24-28
The Plan identifies the various discharges that will be monitored for water quality during the life of
the project, including contact water from bulk fuel storage and landfarm facilities and effluents
from the sewage treatment plants and vehicle maintenance shop. EC notes that the Wastewater
Plan indicates that the emulsion plant will be equipped with its own wastewater treatment plant.
EC requests that the Proponent clarify what level of monitoring will be undertaken, including the
frequency and parameters to be tested in the discharges originating from the emulsion plant.
Section 4.3, p.26
The Plan indicates that “sampling and monitoring of the wastewater treatment systems will
include the following: 5. Permitted discharge volumes of treated effluent and their discharge
locations are presented in Table 2-20.”
Table 4-5 indicates that no water quality sampling will be undertaken while acute toxicity testing
will be done once a year. However, the narrative indicates that water quality monitoring will be
undertaken once before discharge and every four weeks thereafter. EC was unable to locate
Table 2-20 in this Plan and therefore recommends the next iteration be updated to reference the
correct Table. Further EC also recommends that Table 4-5 be updated in the next iteration of the
Plan to reflect the level of water quality sampling undertaken for discharges from each sewage
treatment plant.
Table 4-7, p.28
This table lists the discharge water quality criteria for the vehicle maintenance shop wastewater
treatment facility. As noted in comments above related to the Wastewater Management Plan, the
thresholds identified in the Guidelines for Industrial Waste Discharges in Nunavut (GIWDN) are 13 orders of magnitude higher than their respective generic CCME water quality guidelines (e.g.
Al, As, Cd, Cr, Cu, CN, Fl, Pb, Ag). As noted above EC seeks clarity regarding the units provided
for the GIWDN. If these thresholds are confirmed to be in mg/L, EC does not support their use as
water discharge criteria for the vehicle maintenance shop wastewater treatment plant. EC
recommends all site discharges meet criteria which will be protective of the aquatic receiving
environment.
Table 4-9, p. 30
EC questions the defensibility of the mine Reference sites suggested in the Table. EC
recommends the Proponent revisit reference site selection and provide justification that reference
sites are outside the mine’s zone of influence. As per recent discussions with Baffinland, EC
recommends this Plan be updated with revised reference sites once these sites have been
selected.
Table 4-11, p. 32
EC notes that no SNP station has been established for discharges from the emulsion plant
wastewater treatment plant. EC requests the Proponent clarify the fate and water quality
monitoring of discharges from the emulsion wastewater plant.
Section 10, p. 40
In the Reference section, Appendix 10D-14 has been identified as the Aquatic Effects Monitoring
Plan (AEMP). The correct name for this Appendix is the MMER Environmental Effects Monitoring
Study Design Framework. For clarification, the MMER EEM Framework is not equivalent to the
AEMP. The next iteration of the Plan should be updated to reflect the correct name of Appendix
10D-14.
Reference: Volume 10, Biophysical Environmental Effects Monitoring Framework,
Appendix 10D-13
Section 1.0, p. 9
As a minor edit, EC notes that the first bullet following the 3rd paragraph of this Plan makes
reference to CEAA. EC recommends this Plan be updated to reflect the Nunavut context.
Table 10-1, p. 6
EC recommends that the acronym CPUE be defined in the Table as this is its first occurrence in
the Plan.
Also, the Table could be updated to reflect the fact that analysis of mercury concentrations in fish
tissue is only required if the effluent characterization yields mercury concentrations greater than
0.10 ug/L.
Reference: Volume 3, Appendix 3B, Attachment 4 - Site Specific Documents - Mary River Waste Rock Design Criteria - Section 3.6; and Attachment 5 - Waste Rock Management
Plan
Attachment #4
Section 3.0- Option 2 states that “Placement of the waste rock in a single stockpile with
segregation of the PAG and non-PAG material. The PAG material would be encapsulated within
the confine of the non-PAG material”. Table 3-1 - Preliminary Schedule of Waste Rock
Production, suggests that there is at the least 3:1 of non-PAG to PAG, which could result in
insufficient non-PAG rock to encapsulate the PAG. EC requests that the Proponent clarify if there
is sufficient non PAG rock for encapsulation and to prevent the ultimate release of acid rock
drainage once the non-PAG has been used up. EC requests that the Proponent clarify if
consideration has been given to “blending” the non-PAG & PAG before encapsulation?
Reference: Volume 3, Appendix 3B, Attachment 5 - Waste Rock Management Plan, Sec
3.7.1
EC requests that the Proponent provide some details regarding the volume of sedimentation
expected.
Reference: Volume 10, Section 7.2.4.1;
Volume 3, Appendix 3B, Attachment 5 - Waste Rock Management Plan
Baffinland states that “The majority of the waste rock will be placed while the ground is frozen
allowing the level of permafrost to rise in elevation by conduction. It is expected that a
permanently frozen impermeable core will form in the waste rock storage area within the first few
years after placement. The technical memorandum on the development of permafrost in waste
rock stockpiles is included in Annex 2.” EC notes that the Proponent assumes that climate
change will not affect the development or stability of permafrost in the pile. EC requests that the
Proponent clarify if the potential impacts of climate change on permafrost in the waste rock pile
have been considered and what mitigations will be in place to prevent seepage, subsurface flow
or flows that could undermine the berms as well as acid rock drainage /metal leaching.