372 Bay Street
Suite 901
Toronto, Ontario
M5H 2W9
416-628-0216
October 31, 2014
Kelli Gillard
Technical Advisor
Nunavut Impact Review Board
P.O. Box 1360
Cambridge Bay, NU X0B 0C0
kgillard@nirb.ca
Re: NIRB 05MN047: Comments Received Regarding TMAC Resources Inc.'s 2013 Annual
Report for the Doris North Project NIRB Certificate No.003
Dear Kelli;
In response to the request by NIRB for interested parties to comment on or before June 27, 2014
on TMAC Resources Inc.’s 2013 Annual Report for the Doris North Project, comments were
received from AANDC, EC, GN (revised), KIA and TC. These comments were forwarded by NIRB
to TMAC September 9, 2014. AANDC and TC had no comments to address, and both confirmed
TMAC’s project activities complied with requirements within their regulatory jurisdiction.
Responses to comments from EC, GN and KIA are provided in the table below, and further
explanations will be provided in a Memorandum (currently under review and to be submitted early
in the week of Nov 3) outlining the history of the Hope Bay Wildlife Monitoring Program as it
pertains to Caribou, Grizzly Bear, Muskoxen and Wolverine.
We hope this additional information will provide clarity and rationale for the present program and
the context for any changes or improvements to future monitoring activities.
1
TOPIC
PARTY COMMENT
PARTY REQUEST
Environment Canada June 23/14
Effects Monitoring
In the Hope Bay Seepage Monitoring Program section of Clarify this statement.
the Report, the statement “The majority of this seepage
is captured in the water management system
implemented at Hope Bay” (Page 36) should be clarified
to indicate whether proper treatment of the seepage has
occurred before it escapes into the environment.
The Report provides a 3 page summary of the Aquatic
Effects Monitoring Program (AEMP) results, and no
information on methods nor how conclusions were
reached (i.e. no data). This makes it difficult to evaluate
whether the conclusions reached are valid, and to see
whether there are areas warranting further study or
changes to the program. In 2013 a fairly comprehensive
AEMP report was produced for 2012 monitoring which
included methods, data, rationale and interpretation, so
EC is disappointed by the lack of a 2013 AEMP.
TMAC RESPONSE
This comment is in reference to seepage from the Doris North mine
waste rock pile. Seepage from the waste rock pile at Doris North
is managed in accordance with the NWB-approved Waste Rock
and Ore Management Plan (2010) and the Doris North Project
Interim Water Management Plan (2012). Seepage from the waste
rock pile reports to the Pollution Control Pond and from there is
directed to the Tailings Impoundment Area.
The information provided in the 2013 NIRB Annual Report is the
executive summary of the 2013 annual AEMP. The full text and
supporting data of the 2013 AEMP can be found on the NWB ftp
site here:
ftp://nunavutwaterboard.org/1%20PRUC%20PUBLIC%20REGIS
TRY/2%20MINING%20MILLING/2A/2AM%20%20Mining/2AMDOH1323%20TMAC/3%20TECH/9%20MONITORING%20%28
J%29%28K%29/K10%20Aquatic%20Effects%20Monitoring/140
508%202AM-DOH1323%20%202013%20AEMP-IAAM.pdf
Given the proposed changes to the Project (e.g. marine EC requests that the Proponent provide
discharge, extended footprint) it would have been a comprehensive AEMP along with the
reasonable to focus more on the new marine discharge annual report for the Project in 2014.
area. Some of that might have been done, but it cannot
be ascertained from the summary provided.
No inspections of the Project were completed by EC during the 2013 calendar year, and no non-compliance
with the Fisheries Act or with the Canadian
Environmental Protection Act, 1999 were identified by
information from other sources such as complaints or the
NT/NU Spill Line.
Government of Nunavut June 27/14 - Environment and Human Health Assessment Committee (EHHAC)
Appendix A: Doris North Project Certificate Compliance Summary for 2013
2
A revised AEMP will be proposed in the 2AM-DOH1323 NWB
Licence Amendment. It is intended this program be developed in
consultation with EC during the Amendment review period.
Baseline data collection for Roberts Bay will also be included in the
application.
Acknowledged.
Term
and The GN would like to note that no new design or Condition
implementation plan has been submitted for grizzly bear
22.
and wolverine. Discussions are underway to finalize a
memorandum of understanding with TMAC for caribou
monitoring; however, an agreement for grizzly bear and
wolverine monitoring has not been initiated.
The 2013 WMMP plan includes monitoring for grizzly bear and
wolverine in three ways:
1) on-site monitoring for problem wildlife attracted to site;
2) regional camera monitoring for grizzly bear; and
3) regional camera monitoring for wolverine.
Following results of the 2013 and 2014 field seasons, and as
discussed in the attached memorandum, the plan going forward will
be as follows:
1) continue on-site monitoring for potential problem wildlife
attracted to site;
2) discontinue regional-scale camera monitoring for grizzly bear;
and
3) discontinue regional-scale camera monitoring for wolverine.
No further DNA mark-recapture population surveys are proposed
(see memorandum for further discussion).
2013 Wildlife Monitoring Compliance Report
Section 1.2
Study Area
The 2013 study area was the same as in 2012, which The GN requests further explanation on
represents a reduced size from previous years. The the rationale for reducing the study area.
current study area poses limitations on the location of
control sites. For example, bird surveys were completed
at both treatment and control sites. Treatment sites
included coastal habitat; whereas, control sites were
located inland. A larger study area would allow for better
selection of control sites for wildlife monitoring.
The initial study area allowed for both compliance monitoring for
the Doris North WMMP (the north portion of the study area) as well
as baseline data collection for a Phase II project (the south portion
of the study area, surrounding the Boston site). In the 2012 WMMP
plan, the study area was reduced to the north portion of the
previous study area to more accurately reflect monitoring for the
Doris North WMMP during care and maintenance and to exclude
the baseline study areas associated with the Boston area.
Section 2.2.1
Wildlife
Sighting Log
The Proponent has indicated that 50 incidental
observations of muskoxen were made in 2013. One of
these sightings included a group of 27 muskoxen.
Although the Proponent did not conduct aerial surveys
from 2011 to 2013, incidental observations of muskoxen
continued to be recorded in the study area. During this
time, incidental observations of muskoxen were as high
as those of caribou in the study area (Table 2.2-2). These
Muskox were not included as a VEC in the 2005 Doris North
FEIS. Historically, muskox were monitored through incidental
observations during the caribou aerial surveys, which were
discontinued after 2010. No further aerial surveys are planned.
Results from remote camera studies suggest that muskox occur
at insufficient densities for effective regional monitoring using
cameras (e.g., no muskox were observed in the first 12 months of
3
the camera program). Cameras will continue to be used to
monitor local-scale interactions with infrastructure and incidental
muskox sightings will continue to be reported in the annual
WMMP report.
findings suggest that muskoxen are found in the study
area in numbers that warrant further monitoring.
It should be noted that the camp reports that there is a herd/group
of muskox who use the area near camp and are frequently
observed, leading to multiple observations of the same animals,
rather than a large absolute number of muskox in the area.
Section
2.2.2.1
Remote
Camera
Deployment
(paraphrased – see June 27/14 GN Corr.
“RE: Comment Request for TMAC’s 2013 Annual Report
for Doris North Gold Mine Project Certificate NIRB No.
003” for full comments). As described in the 2013 Wildlife
Compliance Monitoring Report, remote cameras do not
provide a suitable method for monitoring wildlife. At best,
cameras can provide incidental observations of wildlife.
The Proponent acknowledges in this report that
incidental observations are not suitable for monitoring
changes in population densities (Section 2.2.1).
Additional discussion is included in the attached memorandum.
The GN requests the Proponent review This response has 3 parts, for 1) caribou, 2) grizzly bear and 3)
its wildlife monitoring activities to reflect wolverine.
the above statements, and the GN
requests the Proponent adopt more 1) Caribou
appropriate measures to evaluate The 2011 and 2013 WMMP plan indicates that future monitoring of
species abundance.
caribou in the region surrounding Hope Bay will be conducted
through partnering with the GN-DOE to contribute to herd-level
monitoring activities.
The plan states that no future aerial surveys will be conducted for
caribou, largely because aerial surveys conducted between 1996
and 2010 did not produce sufficient sample size to determine and
monitor a zone of effect around the project. The Project is in the
process of negotiating a Memorandum of Understanding (MOU)
with the GN DOE to contribute to collaborative monitoring
programs.
In addition to contributing to herd-level, collaborative programs, the
possible use of remote cameras for caribou monitoring has been
investigated in the Hope Bay area. The camera studies being
conducted provide a variety of data about caribou, including the
following:
4
a) identification of important caribou habitats such as river and lake
crossing points, travel corridors and high-use locations identified by
Inuit Qaujimajatuqangit;
b) the time of year when caribou are present in the study area –
which can indicate which herd is observed and direct management
and mitigation activities; and
c) interactions with roads and infrastructure.
Additional details on the purpose and objectives of the camera
study for caribou at Hope Bay is provided in the memorandum.
Absolute changes in population density of caribou in the study area
will not be monitored going forward with cameras.
2) Grizzly Bear:
A DNA mark-recapture study was conducted for grizzly bears in the
study area in 2010 and 2011 following discussions with GN
between 2007 and 2010. The 2005 Doris North FEIS project
commitments do not include a requirement to conduct ongoing
population-level monitoring for grizzly bears using DNA markrecapture after that initial population estimate. In 2010, Hope Bay
discussed evaluating the efficacy of the method to evaluate Projectrelated effects, and if appropriate, conduct ongoing, periodic
monitoring using DNA mark-recapture techniques. Hope Bay sent
representatives to technical meetings in March 2013 to discuss
DNA methods. One of the results from discussions at this meeting
was that DNA mark-recapture studies do a poor job of measuring
a zone of influence (ZOI) and thus Project-specific effects on bears.
Consequently, no population-level monitoring using DNA markrecapture is planned at this time, as described in the 2013 WMMP
Plan.
Monitoring of camp infrastructure will continue using remote
cameras. Remote cameras are located at a variety of camp
infrastructure, including the boulder garden/fish fence, waste
facilities and other camp buildings. Observations of bears at these
5
locations are monitored to inform management activities. Incidental
observations will also be reported.
Additional details on the purpose, objectives, and history of grizzly
bear monitoring programs at Hope Bay are provided in the
memorandum.
3) Wolverine:
A DNA mark-recapture study was conducted for wolverine in 2010
and 2011 following discussions with GN between 2007 and 2010.
Sample sizes and recapture rates were too small to conduct any
population-level analyses. Thus, no further DNA mark-recapture
studies are proposed for the Project.
As with grizzly bear, wolverine will be monitored for potential
interactions with project infrastructure using cameras to guide
management activities. Incidental observations will also be
reported.
Section
2.2.2.1
Remote
Camera
Deployment
Also, the GN has concerns that the arbitrary 1 km
treatment vs control remote camera placement limit does
not appropriately reflect the extent of Project activity
impacts on wildlife.
Section
The Proponent states that the frequency of wildlife
2.2.2.4
sightings was similar between control and treatment
Wildlife
sites. The remote cameras returned on average 5 wildlife
Sightings by events per camera for the treatment sites and 6 events
Remote
per camera for the control sites. These represent small
Camera
sample sizes from which no conclusion of treatment
effect can be drawn. The Proponent suggests that
population abundance for many species was too low to
Additional details on the purpose, objectives, and history of
wolverine monitoring programs at Hope Bay are provided in the
memorandum.
The GN requests further clarification on With the Project in care and maintenance, the objective was to test
the data used in comparing control and whether a small Zone of Influence (ZOI) occurred as an initial
treatment cameras.
assessment. A small predicted potential ZOI of 1 km was used to
drive experimental design, which ensured sufficient cameras were
present within 1 km of Project infrastructure to capture a
hypothetical small ZOI if present.
TMAC intends to continue to work on a MOU with the GN wherein
TMAC will collaborate with the GN on herd-level monitoring, in lieu
of regional monitoring using cameras. Further discussion is
provided in the attached memorandum.
6
Section 4.1
Caribou
Introduction
Section
4.4.1.2
Remote
Camera
Monitoring
permit comparison of control and treatment cameras.
These results do not indicate that populations are low.
Instead, this confirms that remote cameras constitute a
poor method for detecting wildlife and providing an
estimate of species abundance.
The Proponent states that the Beverly barren-ground
caribou herd has joined the Ahiak herd to form a
combined herd which the GN refers to as the Beverly
herd. The Beverly herd has undergone a shift in calving
distribution over many years; however, the GN
recognizes the Beverly and Ahiak as separate herds.
The Proponent has indicated that some remote cameras The rationale for this decision is unclear
were excluded from the comparison of treatment and and warrants further detail.
control capture rates. Eight control cameras, located at
the far south end of the study area, were omitted from
this analysis. It was indicated that these cameras had no
corresponding treatment equivalents in the general area.
The reference to the Beverly and Ahiak herds in the report followed
Nagy et al.’s (2012) analysis of herd distribution (Beverly and
Queen Maude Gulf herds). Future reports will refer to the Beverly
herd as per Nagy’s analysis of herd distribution.
The cameras were located in the wildlife Regional Study Area,
which is used by two caribou herds, the Dolphin and Union caribou,
which use the Project area during winter and occur on the mainland
up to approximately 100 km south of the coastline, and the
Beverly/Ahiak caribou which occur in the RSA during late summer
to the south of the project location. The Beverly/Ahiak herd,
however, do not use the Project location itself. Hence, the analysis
of treatment vs. control was focused on the Dolphin and Union
caribou herd, which occurs in both the treatment (adjacent to the
Project location) and control (distal from the project footprint) areas.
Eight cameras at the extreme southern end of the RSA, up to 30
km south of the Boston site) recorded observations of the
Beverly/Ahiak caribou because this herd(s) uses the tundra to the
south of the Project area. These cameras were excluded from the
ZOI analysis on the Dolphin and Union caribou because their
inclusion would incorrectly inflate the number of control
observations of this herd.
7
Section
4.4.1.2
Remote
Camera
Monitoring
Section 4.5
Caribou
Discussion
Comparisons of treatment and control camera results The GN requests further clarification on The study area will not be separated in the 2014 WMMP report;
were made for three groups based on their location in the the rationale for these groupings.
instead, the study area relevant to the Doris North Project will be
study area: north, middle, and south. These groupings
referred to as the Doris North Caribou Regional Study Area.
seem arbitrary and do not reflect important factors such
as habitat type.
The GN acknowledges discussions are underway with
TMAC intends to continue to work on a MOU with the GN wherein
the Proponent to develop a MOU for caribou monitoring.
TMAC will collaborate with the GN on herd-level monitoring, in lieu
However, the GN does not consider appropriate the
of regional monitoring using cameras. It must also be noted that the
Proponent’s adopted intermediary means of wildlife
Project is in care and maintenance, with limited staffing,
monitoring through remote camera surveys.
disturbance, and potential effects on wildlife. Consequently, a large
program to monitor effects is not justified at this time.
With aerial surveys producing insufficient data for the determination
of a ZOI, there is a limited set of options for continued monitoring
of caribou in the study area. Objective and constructive criticism
aimed at improving the remote camera monitoring program – which
was being used as part of the Phase II baseline study and which
was being explored as a tool for caribou monitoring at Hope Bay –
has been appreciated. Aside from local-scale caribou monitoring
described elsewhere, the caribou camera monitoring program will
be discontinued going forward. These changes will be reflected in
the 2015 WMMP Plan.
Section 5.4
The Proponent has indicated that sampling effort greatly
Grizzly Bear differed between control and treatment cameras. It is
Results
unclear why such a difference would exist for grizzly bear
data, and the same issue was not noted for caribou data.
The data for these two species was collected from the
same remote cameras. The Proponent noted that only
one camera was excluded from the grizzly bear data
analysis.
As discussed in the above sections, the GN considers
remote camera surveys inappropriate for conducting
wildlife monitoring.
Please see attached memorandum for further discussion.
The GN requests further clarification on The sampling effort differed between treatment and control areas
this discrepancy [pertaining to sampling for the entire camera study: There were fewer cameras near
effort].
infrastructure than further away. This imbalanced study design
does not affect the outcome of the monitoring study, because
The GN requests the Proponent observations of wildlife are evaluated as a rate per camera-day.
reconsider its grizzly bear monitoring Statistical methods are robust to an unbalanced design as long as
program to better evaluate Project the number of observations are not summed by treatment and
related impacts on this species.
control group, which would bias the results.
Different numbers of cameras were censored (removed) from the
analysis based on the species in question. For caribou, eight
cameras were censored because they occur in the extreme south
8
of the study area in the range of the Beverly/Ahiak caribou herd,
while the rest of the study area (including both treatment cameras
around infrastructure and control cameras) are in the range of the
Dolphin and Union herd. Hence, including these eight cameras
would bias the results of the analysis to inflate the number of
animals observed in control areas and they were censored.
Grizzly bears occur in essentially a continuous population across
the tundra and so there is no division into herds as with
caribou. One camera was removed from the grizzly bear analysis
of ZOI at the Roberts Creek boulder garden/fish fence because
there is a strong likelihood that bears were being attracted to the
fish in the boulder garden. These data would have biased the
results of the analysis by inflating the number of bears observed
in the control group and this camera was therefore censored from
the analysis. Note that the results from this camera were used in
the management of safety protocols at the fish fence area, and
was therefore a valuable addition to the monitoring program,
albeit with a different objective.
The Project will continue to use cameras to monitor is the potential
for attracting bears to camps and/or infrastructure, which is the
primary potential effect of Arctic projects such as the Doris North
Project, on grizzly bears. Cameras have been placed at a variety
of locations that may attract bears, such as the waste management
facilities and camp buildings. Cameras are also located at natural
high-use sites, such as Roberts Creek (where
the fish fence is now located). On-site cameras record workers
using the site, but have not recorded any bears to date, indicating
that management activities have been successful at properly
managing wastes, reducing the attractiveness of the site, and
thereby mitigating bear interactions with the Project.
In 2010 and 2011, the Project conducted a DNA mark-recapture
program to estimate the grizzly bear population in the Hope Bay
9
area, thus satisfying certificate commitments. Further DNA markrecapture programs are not proposed, because the technique has
a poor ability to evaluate ZOI. As discussed at the recent grizzly
bear monitoring workshops in Yellowknife (March 2013) markrecapture techniques have a poor resolution to pick up avoidance
by bears because their grid size is 10X10 km cells.
Section 6.5
Wolverine
Discussion
The Proponent has noted that remote camera surveys Given this poor success and the GN’s
for wolverines have not produced sufficient data to concerns with the use of remote
compare treatment and control sites.
cameras for wildlife monitoring, the GN
requests alternate plans be made for
wolverine monitoring.
Further discussion is provided in the attached memorandum.
As with grizzly bears, the primary potential effect of developments
on wolverine in the Arctic is the potential for attracting wolverines
to camps, waste facilities and other infrastructure leading to the
possible injury or a requirement to dispatch a problem animal.
Remote cameras are a good method for monitoring these camp
facilities and guide the management of camps and camp wastes to
avoid the attraction of wolverines.
Hope Bay has been experimenting with the use of remote cameras
to monitor the relative density of wolverine near the project. Given
that DNA-based methods provide poor data to determine ZOI and
snow track surveys, likewise, record few wolverine, the use of
cameras was explored as an alternative. Aside from local-scale
wolverine monitoring described elsewhere, the wolverine camera
monitoring program will be discontinued at this time.
KIA June 27/14
Monitoring Compliance Report
Section 5.4
Grizzly Bear
It has been noticed that some things of interest on the
maintenance inspection report cards at the end of the
report (Appendix C) that didn't get incorporated into the
WMMP or weren't addressed in the summary: (See first
5 Bullets for full text of comments).
1) There are some care and maintenance
inspection forms in Appendix C that were filled
out with no area labeled.
2) On one of those forms, with no area fields filled
in, there is a note stating “wolverine could be
denning in waste rock pile". I didn't see this
1) – Forms not completed
TMAC will review data collection and recording practises and toe
the extent practicable modify as necessary to accomplish the
2) If something like this is noted, it comments offered.
should be looked into to prevent the
crushing of a den, if waste rock is added
to the pile.
3) If the inspectors are unable to identify
them to species or just to general wildlife
order, having them take a photo of the
footprint with a ruler beside it could help
10
Section 5.4
Grizzly Bear
integrated into an adaptive monitoring or a wildlife biologist to determine which
adaptive management plan, and saw no mention species (or at least order) of wildlife
of it anywhere else
these statements are referring to.
3) Many of the forms mention "wildlife tracks" or "old
wildlife tracks".
4) It would be ideal to distinguish
4) There is an inspection report that notes that there between these two, as one implies
was a forced entry at the Orbit Shop (Roberts attractants that are affecting grizzly
Bay), but there is not distinction on the forms to behaviour, and the other implies human
tell whether the entry is by wildlife (grizzly) or break and enter.
humans.
5) One of the inspection reports mentions fox tracks 5) Since foxes sometimes den
at the portal of the white weatherhaven south of underneath weatherhavens, it would be
the portal.
nice to include more details on the
location of the tracks in such situations,
and whether it looks like they are going
to and from the structure, or just passing
by.
In the WMMP summary sections, in the bulleted list, Please present this information as it
there is a statement that says: "The number of grizzly was presented for short-eared owls 2
bear events recorded at treatment sites did not differ bullets below the grizzly bullet (i.e.,
from the number recorded at control sites, suggesting present as the number of recorded
that grizzly bears were not avoiding areas within 1 km of events per camera days).
Project infrastructure in 2013.
When adjusted for sampling effort (i.e., 1,993 camera days in
treatment areas and 3,510 camera days in control areas) the
frequency of grizzly bear camera events between June and
September 2013 was similar between treatment and control
cameras with 1 camera event every 50 camera days in treatment
areas and 1 camera every 43 days in control areas.
2013 Hydrology Compliance Report
The data presented was obtained within the framework established by the Water Licence No. 2AM-DOH0713
Type A. It is our understanding that this licence was valid
until September 30, 2013, hence now it is expired, unless
it has been renewed, but that detailed [sic] is not
explained in the monitoring report.
NWB Type A Licence was renewed/revised August 16, 2013 and
is valid through August 16, 2023. The licence number was changed
in 2013 from 2AM-DOH0713 to 2AM-DOH1323.
11
When the 2012 (Rescan, 2012) and 2013 (ERM Rescan,
2014) monitoring reports are compared, one can notice
that the introduction section of the 2012 report lists more
complying points than the 2013. The points listed in the
2012 report and not listed in the 2013 report are:



The report should include a brief
explanation if this constitutes a change
in scope of the work and hence, a
change in compliance requirements.
Part F, Item 1a of the renewed licence has been revised and no
longer references continuous monitoring of Doris Lake. Continuous
monitoring of Doris Lake water levels and outflows will continue
under the hydrologic baseline characterization. These data will be
used to calibrate the existing water balance and quality model.
The reference to Part G, Item 29 with regard to maintaining Tail
Lake water levels is now found at Part G, Item 31 and includes the
amended verbiage, “following the deposition of tailings”. As
disposition of tailings has not yet occurred, this clause is not
currently applicable.
Part F, Item 1a: The water management plan should
include a requirement to continuously monitor Doris
Lake levels and outflow during the two years of
mining and beyond to confirm water balance and
model predictions.
Part G, Item 29: The licensee shall ensure that water
within the Tailings Impoundment Area is maintained
at an elevation of at least 28.3 m above sea level
such that a minimum of 4 m of water cover is
maintained over the tailings at all times.
Doris North Project Certificate (NIRB No 3,
September 15, 2006): "Hope Bay Mining Limited
[sic] will monitor stage and discharge in Doris
Outflow
both upstream and downstream of the decant
discharge point to provide
information that can be used in assessing the
accuracy of the impact
predictions relating to fish habitat downstream".
Stage and Discharge measurements continue up and downstream
of the decant discharge point during TIA dewatering as per the
Doris North Project Certificate (NIRB No 3). This will be clarified in
subsequent reports.
The facts these aforementioned points are not listed in
the 2013 reports makes the reviewer question if they
have been properly addressed or due to proposed
changes in the project design, these requirements have
been revised.
12
The scope of the report is not specific enough to address
the fact that not all water related aspects of the
requirements or stations stated by the Water Licence are
presented in the report. This point was already
mentioned in the review of the 2012 report. For example,
total water quantities used (potable and process),
hydrotechnical conditions of water courses (erosion),
water quality, etc., are not provided.
It may be the case that these other
aspects are not to be included in the
hydrology report, but if this is the case,
the scope of work should be more clearly
stated, including an explanation of what
is not included in the current report. If the
aspect under concern is not applicable
due to the situation of the mining project
(care and maintenance), it should be
also clearly stated. This analysis could
be shown in a table format for easy
visualization and understanding.
13
ERM Rescan monitors and reports, on behalf of TMAC, on the
following elements of Water Licence Compliance in the annual
Hydrology Compliance Report: Open water season volumetric
discharge from Doris Creek, Roberts Lake, and Windy Lake; water
level variation at Doris Lake and TIA. These items correspond to
the following elements of the water licence (2AM-DOH1323) and
Project Certificate (NIRB No. 003):
Water Licence
 Part F. Item 1a: Provide additional detail on the
requirements [of the Doris North Project Interim Water
Management Plan, dated February 2012], including
frequency, for on-going monitoring and calibration of the
water quality model.
 Part G. Item 31. The Licensee shall, following the deposition
of tailings, maintain water within the Tailings Impoundment
Area at an elevation of least 28.3 metres above sea level
such that a minimum of four (4) metres of water cover is
maintained over the tailings at all times.
 Part G. Item 32. The Licensee shall ensure that the flow
from the Tailings Impoundment Area into Doris Creek at
monitoring station TL-4 does not exceed 10% of the
background flow in Doris Creek, as measured at monitoring
station TL-2 at the time of discharge.
 Part J. Item 2: The Licensee shall install appropriate
instrumentation in Doris Creek at Monitoring Station TL-2,
to monitor flow when ice conditions allow for such
measurements to be taken, on a real time and continuous
basis for any year where discharges from the Tailings
Impoundment Area are planned.
 Part J. Item 3. The Licensee shall undertake the Water
Monitoring Program detailed in the tables of Schedule J
[see Table 6.1-2 below; sites TL-2 and TL-3]
Project Certificate
 Appendix C: Final Hearing Report Appendix B, Additional
Comments, DFO, Item 2: HBML will monitor stage and
discharge in Doris Outflow both upstream and downstream
of the decant discharge point to provide information that can
be used in assessing the accuracy of the impact predictions
relating to fish habitat downstream.
The report is lacking a conclusions section, since it only It is recommended that a section that
presents a summary section.
discusses the conclusions of the report
is incorporated. Such a section should
include clear statements addressing the
following aspects:
o Annual hydrological conditions and if
they have been normal or abnormal in
comparison
with
local
weather
conditions or past observed data.
o Summary of the specific fulfillment of
regulatory requirements and how where
they accomplished. If all requirements
have not been fulfilled, an explanation of
why they have not been done so and the
following plan of action should be
included. It is recommended this is
shown in a table format for clear
visualization and understanding.
14
All other aspects (e.g., water use and recycling, pumping volumes,
etc.) are monitored by TMAC under the Surveillance Network
Program and reported monthly and annually to the NWB in
accordance with the relevant clauses of Licence 2AM-DOH1323.
The 2014 report will include the following:
 a discussion and observations section,
 discussion of hydrological data in the context of local
weather,
 a tabular summary of regulatory requirements and whether
they have been accomplished in the reporting year and if
not, an explanation of why.
The hydrology report presents the data in a factual way, It is recommended that this sort of
without incorporating any interpretation of the data interpretation is incorporated into the
collected.
report in order to give the reader a better
understanding of the study area and the
relevance of the collected data; i.e. to
the revision of water balance design
criteria, for example. If such an
interpretation is not in the agreed scope
of work, the introduction should clearly
state it.
Although the report presents information about water This should be clearly stated in the
levels at Tail Lake, it is not clearly stated if it complies conclusion section and its compliance
with the requirement of 4 m of water cover as a minimum. results table.
There is no description of the 2013 meteorological
conditions that exist in the area, especially air
temperature. The hydrology of an area underlain by
permafrost is controlled by air temperatures.
Related to the previous point, it is recommended that
hydro graphs show air temperature, as well as
precipitation. In this way, it is easier for the reader to
correlate and understand the existence of peak stream
flows like the freshet related one. On a related matter, is
the reported precipitation total precipitation or only
liquid? How is it measured? This should be clearly
explained. Additionally, the correlation of air
temperature,
precipitation
and
field
observed
hydrological parameters is important for the reader
because it gives background on understanding the
natural processes that govern the area, these versus
anthropogenic driven changes.
The 2014 report will include:
 a description of the purpose of the data collection,
 linkages to the regulatory requirements,
 the scope of work for the program and
 relevant observations regarding the data and its collection
for the year.
Refer to earlier comment re: Part G, Item 29 with regard to the
revision of Licence clause number to Item 31, and to the
applicability of maintaining Tail Lake water levels prior to deposition
of tailings into the facility.
As such, a brief description of the local Meteorological conditions are reported in the annual Meteorology
meteorological conditions gives some Compliance Report, which will be referenced in future reporting.
context to understand the general
hydrology of the area and within the
particular year being reported; e.g., the
occurrence of freshet events. It is
therefore recommended to include some
brief weather related explanations.
It is recommended that hydro graphs Hydrographs will include air temperature and precipitation in the
show air temperature, as well as future. Liquid precipitation was shown on the hydrographs in 2013.
precipitation.
In 2014, hydrographs will include air temperature as well. Methods
for measuring precipitation are included in the annual Meteorology
Cleary explain whether reported Compliance Report.
precipitation is total precipitation or only
liquid, and how it is measured.
15
How are demobilization dates decided for the flow
gauging stations? This is important since the report
states that the basal flow is estimated to be the low flow
observed close to the date of demobilization of stations.
Data gathering stops when the station is taken down and
as such, it is not known if the basal flow is actually less
than the values noted. It is suggested to compare the
basal flow estimates with the results of a theoretical
separation of the annual hydro graph and evaluate how
different they may be. In fact, base flow is defined by
Singh (1992) as "the ground water contribution to
streamflow". It continues on saying that "most baseflows
originate from the water table". Then it states that "the
water table is the water saturated sediment whose
surface is in communication with the atmosphere
through the pore openings between sediment grains and
is therefore under atmospheric pressure". However, on
permafrost underlain grounds, where the active layer
freezes in winter, it is very difficult to state that the lower
flows observed by the end of the field recording season
correspond to baseflows.
The generation of the hydro graphs follows a standard
procedure. However, the 24 hour averaging of the 10 min
discharge data in the arctic may result in a nonrepresentative value due to the high daily variations in
flow. The comment is not intended to change the
procedure, but this context should be noted and perhaps
an estimation of the variance of the data presented so it
gives the reader a measure of how representative is the
calculated average Additionally to the previous point,
some sections of the hydrographs were estimated and
shown in dotted lines.
It is recommended that reference to Demobilization of the hydrometric stations is planned each year for
baseflows be deleted; just mention the late September, prior to ice formation in the channels in order to
low flow values recorded at the end of protect the monitoring equipment from freezing.
the field season.
References to baseflows will be deleted in favour of references to
low flow conditions at the end of the field season.
It is recommended to state how these Estimation of the variance of will be presented in subsequent
data were interpolated.
reporting.
Methods for estimating sections of the hydrographs are presented
in Section 2.6: “Standard logarithmic growth and linear decay
functions were used to estimate daily discharge beyond the period
of record for all stations.”
16
The report mentions that the section on station Doris TL- 2 changed due to slumping, which is a possible indication
of degrading permafrost. When did this occur? It is
understandable that a new rating curve is needed.
However, this bears the question as to causative
mechanism and if any mitigation measures are required
for this slumping stream section.
The 2013 report does not mention the Roberts Bay lake If the Roberts Bay lake monitoring
monitoring station as the 2012 report did.
station is no longer being included, it is
recommended that the 2013 reports
gives a brief explanation regarding its
deletion.
There are some occurrences where a water flow value is Any values quoted must have a proper
given, but it is not specifically stated if it corresponds to adjective type (e.g. daily, weekly,
daily average, hourly peak, or what type of observation annually, etc.).
is in terms of its time frame.
This review identified some areas with respect to the The following additional information is
Hydrology Compliance Report 2013, where additional recommended:
information is recommended.
 Clearly identify the scope of work of
the report and state what aspects of
the regulatory requirements have
been addressed and which ones
have not been included, or will be
included elsewhere. This could be
shown in a table format for easy
visualization and understanding.
 Include a conclusions section where
it is clearly pointed out how the
regulatory requirements have been
addressed if properly done so,
along with any relevant
interpretation of the data collected.
Similarly to the previous point, this
could be summarized in a table
format.
17
Gradual slumping has been noted at this location since at least
2011. No abrupt changes were recorded until Spring 2013. The
likely cause of changes to the channel’s hydraulic geometry is the
seasonal formation and subsequent breakup of ice within the
channel. However, geomorphic investigations were not within the
scope of hydrometric monitoring program under 2AM-DOH1323.
The Roberts Bay tidal gauge station was excluded from the 2013
Hydrology Compliance Report because it was not required under
the Fisheries authorization (NU-02-117) in 2013. The tidal gauge
is required during bathymetric surveys, which were not conducted
in 2013.
Acknowledged.
The 2014 report will include:
 a description of the purpose of the data collection,
 linkages to the regulatory requirements,
 the scope of work for the program and
 relevant observations regarding the data and its collection
for the year.

Expand in the context description of
the study area and its hydrological
behaviour.
It
should be noted that the
aforementioned points were noted in the
review of the 2012 report (BGC, 2013)
and they have not yet been addressed in
this year's report.
Windy Lake Shoal Monitoring Report
Pg 2-1
The text on page 2-1 states that monitoring sites were
established in 2012.
Pg 2-6
Pg 3-1
Monitoring details from 2012 are not available for
review and therefore, the consistency of methods and
appropriateness of statistical testing cannot be verified
among years.
Pg 3-7
It should be made clear in the results that the
periphyton and benthic invertebrate data should be
interpreted with the understanding that the use of
artificial substrates does not directly measure the
biological indices between the habitat types, but rather
measures the rate of establishment between the habitat
areas. A true measurement of the difference in
biological communities would be measured from the
existing or newly added substrate.
Pg 3-1
Please clarify the year of establishment The monitoring sites were selected in 2011 and were first sampled
as other records indicate 2011.
in 2012. This will be clarified in the 2014 monitoring report.
Is four plates per site for periphyton
consistent with previous years?
We would recommend that future
reporting contain a brief year-to-year
comparison of methods and results.
The methods for periphyton sampling have been consistent across
the three years of data collection (2012, 2013, and 2014).
Methods were identical across all years unless comments were
made to identify differences (e.g., the addition of gill nets and
Hester Dendy traps in 2013). Moving forward, a record of any
changes in methods and results across sampling years will be
included in the report.
The three habitat types have differing substrates: compensation
shoals are composed of shot-rock 150-300 mm in diameter; natural
shoals are a heterogeneous mix of substrate types; fine sites are
dominated by fine sediment. These differences – along with the
depth of the sampling sites – preclude the use of many standard
sampling methods including grab and Surber samplers. For these
reasons, sampling methods that measure the colonization potential
of the sites have been used as a surrogate for direct measurement.
This distinction will be clarified in the 2014 report.
Are the established shoals at the The compensation shoals are at appropriate depths; they occupy
appropriate depths? This information depths from 1 to 4 m below the lake surface. This will be clarified
was not identified in the reports.
in the 2014 report.
18
Rescan
2010a.
Pg 6-3
It was indicated that underwater videography would be
incorporated to assess fish populations on the
compensation shoals.
Roberts Lake and Outflow Fish Compliance Report
Pg 3-1
Three pass depletion methods were used but it is unclear
how the method was employed to estimate population
density per species.
Pg 3-5
CPUE was used to determine densities. More details are
required to understand the data analysis methods
employed.
Pg 3-5
Pg 3-8
Pg 3-11
It appears as though sample sizes may be quite low
(n=2-4), in which case the ability to detect statistical
differences will be hindered and any results from these
tests may be misleading. With restricting sample sizes,
an emphasis on qualitative results would be more
beneficial for the reader.
Descriptive statistics for all biological and CPUE data
outlined in the methods were not located in the results
section.
Monitoring of the Roberts Lake outflow changed in 2013
to an automated Vaki Riverwatcher System due to safety
risks. Understandably, encounters with dangerous
wildlife in the study area required a fast transition in
surveying methods and thus there are no years where
the two methods were compared
Was
this
methodology
ever The No Net Loss Plan proposed underwater videography as a
implemented? If not, a discussion as to method to count juvenile fish, but limited visibility in Windy Lake
why would be helpful.
would greatly limit the effective range of video. Consequently, this
method has not been employed. This will be clarified in the 2014
monitoring report.
-
Population density per species was not estimated. Instead, CPUE
was compared among sites. This will be clarified in the 2014
monitoring report.
Please provide a detailed breakdown of CPUE was calculated for each site in each year by combining catch
data analysis methods, including the and effort for all passes at that site in that year. As sampling events
sample sizes for each level, the number were typically completed on the same day and the length of creek
and origin of replicate data, the sampled was consistent (25m), this method was appropriate.
avoidance of pseudo replication (e.g.,
were
all
samples/replicates The statistical approach to Stream E09 enhancement program
independent?), and the method for monitoring will be reviewed for the 2014 report. These comments
calculating CPUE (e.g. were all passes will be considered in that process.
summed?)
-
This will be rectified in the 2014 monitoring report.
. A discussion on the potential biases
between the two field methods would be
helpful for assessing future monitoring
results. For example, is the Vaki
Riverwatcher camera system as
effective at identifying individual fish
which migrate past the fence multiple
times? Or is the new technology more
effective at identifying the number of
migrating fish?
States that CPUE will be calculated per fence per 24 h, Please add CPUE to results or remove
however CPUE does not appear to be available in the this from methods section.
results.
19
A comparative discussion was included in the 2013 report
(Appendix 3.2-3 Supplementary Notes on the Operation of the Vaki
Riverwatcher, Doris North Project, 2013).
This will be rectified in the 2014 monitoring report.
Pg 3-14
Pg 3-14
Pg 4-1
Pg 4-1
Pg 4-1
Pg 4-1
Pg 4-7
Descriptive statistics do not appear to be available for
CPUE data.
Survival rate was not standardized to the number of days
the fence was operating in a given year, which varied
from 23 days in 2003 to 48 days in 2010 (Table 4.2-1
P.4-7).
Please revise for consistency between
methods and results.
For comparison purposes, survival
should be standardized by using a
period common to all years or any other
justifiable method which reduces the
potential effect of sampling period
variability.
This will be rectified in the 2014 monitoring report.
Standardising for the length of the sample period would not affect
survival rate calculations.
With respect to differences in the timing of the sampling period that
have occurred through the years, standardizing for a sampling
period that is common to all years would result in the exclusion of
most of the data, so the entire sampling periods were retained for
the analysis in 2013.
Data from pre-enhancement years (2010-2012) are not We would recommend that future This will be addressed in the 2014 monitoring report.
available for review. Thus, the consistency of methods reporting contain a brief year-to-year
and appropriateness of statistical testing cannot be comparison of methods and results.
verified among years.
Given that no fish were caught in any year at the A review of the statistical approach will be conducted for the 2014
enhancement site, the use of a mixed model anova to
report.
compare with sites where fish were caught is invalid as
the difference in samples violates parametric test
assumptions (all samples must be normally distributed
with equal variances).
How was CPUE data pooled within E09 Both catch and effort (seconds) were first summed for all sites in
for comparison with stream E14?
Stream E09. CPUE was then calculated using the same formula
used for E14 (i.e., fish/100 s).
There is an unequal number of years sampled for the two Was a correction incorporated in the No correction was applied to account for the unequal number of
streams, although it seems as though 2010 data was still analysis? Is it possible that 2010 years. A review of the statistical approach will be conducted for the
included in analyses. There does not appear to be any sampling at one site only may influence next report.
correction for an unbalanced study design in the the results? Are the results different if
methods.
2010 is omitted?
Statistical testing of survival should also be standardized Statistical testing of survival should also Standardising for the length of the sample period would not affect
for sampling period.
be standardized for sampling period.
% survival calculations.
With respect to differences in the timing of the sampling period that
have occurred through the years, excluding baseline data collected
outside of the 2013 sampling period would substantially reduce the
amount of data available for before-after comparisons. However,
while the timing of the run may correlate with season, survival
20
Pg 4-7
Rescan
2010a.
Pg 6-2
Rescan
2010a.
Pg 6-3
Text on page 4-7 states that" ... survival in 2013 was
always higher (by a minimum of 24%) than preenhancement years." This statement is unclear as postenhancement survival is only 14% greater than 2010,
and 16% greater than 2003.
The criteria for success is stated as a 25% increase in
the mean number of Arctic charr smolts that go to sea in
a single open-water season compared to the mean
number that went to sea during the pre-improvement
monitoring period. Is the 25% being adopted for the
mean number of returning Arctic charr adults to reflect
the program changes?
through the boulder garden is primarily affected by flow, which
varies each year depending on climatic conditions. Thus, the entire
sampling periods were retained in the analyses.
Survival in 2010 is 14 percentage points higher than baseline (79%
to 93%), but this represents an increase of 18% (93% is 18%
greater than 79%). The report should have read “by a
minimum of 18%”.
-
If so, please provide a summary The 2014 report will provide a discussion of this matter.
evaluation of this criterion using results
from the first year of monitoring. Please
also provide commentary regarding
whether the second criterion of success
(the elimination of stranding of adults
spawners in the boulder garden) was
met in 2013.
The criteria for success outlined for Roberts Lake stream TMAC is in agreement.
E09 were not met. The criteria were: newly created
rearing habitat supports greater densities of rearing fish
than adjacent natural sections of the stream. As
indicated in the monitoring report (Rescan 2014b ), this
was only the first year of data collection after stream
enhancement and additional seasoning of the habitat is
required before drawing firm conclusions as to the
efficacy of the compensation for increasing juvenile
Arctic charr density. Furthermore, the time delay in
increased fish density here should not be considered a
critical issue as the success of the Roberts.
21
2013 Aquatic Effects Monitoring Program Report
All substances were assessed using the required detection limits outlined by the MMER. HESL notes that
TSS measurements in the Marine Environment
occasionally were assessed using a higher than
specified detection limit- 3 mg/L as opposed to the
required 2 mg/L. We do not feel this would have altered
conclusions regarding the Projects impact on the aquatic
environment which will be discussed in our review of the
Results. HESL notes that Radium-226 was assessed in
all samples. This may be reduced in the future given
MMER section 13(2) as Doris North will not be operated
as a uranium mine. Section 13 (2) reads:
13(2): "Despite section 12 and subject to subsection
(3), the owner or operator
of a mine, other than an uranium mine, may reduce the
frequency of testing for
Radium-226 set out as item 8 of Schedule 4 to not less
than once in each calendar quarter if that substance's
concentration in the effluent is less than 0.037 Bq/L in
10 consecutive tests conducted under section 12."
HESL agrees with the use of the BACI analysis for evaluating Project effects. A note of contention was
TMAC's use of a reduced level of significance. A
threshold of significance for evaluation P values was set
at 0.01 to address multiple comparisons. HESL therefore
evaluated project effects in the 2013 AEMP at a more
conservative level of significance threshold of 0.05, using
the statistics provided by TMAC, to recognize the need
for environmental protection. Unless otherwise noted,
the more conservative statistical test did not alter the
conclusions made by TMAC.
TMAC should continue monitoring
hardness at the Doris Lake South site as
it will be proximal to the proposed
effluent discharge from the Tailings
22
In 2013, the analytical detection limit for one marine water quality
sample was raised to 3.0 mg/L rather than 2.0 mg/L by the
analytical laboratory. TMAC agrees that this would not have altered
conclusions regarding Project impact on the aquatic environment.
TMAC notes the KIA’s comment on Radium-226 analyses and will
consider this change during the next update to the Doris North
Aquatic Effects Monitoring Plan (Rescan 2010).
A reduced significance level (p=0.01) was used to control for the
potential of Type I error associated with running many multiple
comparisons for various environmental components (e.g., water
and sediment quality). Environmental parameters where
significance levels approach 0.05 or fall between 0.05 and 0.01 are
always considered as a potential early warning signal (i.e., they are
not immediately dismissed).
Hardness is included in the list of water quality variables evaluated
in the Doris North AEMP (Rescan 2010) and will, therefore,
continue to be examined for potential Project effects in 2014.
Impoundment
Area.
While
the
statistically significant change may have
been a result of project activities, there
is currently little risk to the aquatic
environment.
Cadmium concentrations should be
monitored closely in future years to
ensure
concentrations
are
not
increasing.
Recommendation: The frequency with which cadmium
was below the detection limit at Doris Lake North
suggests that the one sample detected above the
method detection limit is not likely to pose a significant
risk to aquatic life. Given that the next sample collected
from that site was below the detection limit, HESL has
reached the conclusion that the duration which aquatic
life may have been exposed to elevated cadmium is
temporally limited.
HESL agrees with TMACs conclusion that project Cadmium and copper concentrations
activities have not had a significant impact on the water should be closely monitored seasonally
quality of fresh water lakes on site.
to ensure no increasing trend
concentrations is emerging at Doris
Lake North.
Note that Doris Lake is located upstream of proposed effluent
discharge from the Tailings Impoundment Area (TIA). The Doris
Lake Outflow sampling location is located downstream of the TIA.
Cadmium is included in the list of water quality variables assessed
in the Doris North AEMP (Rescan 2010) and will therefore continue
to be examined for potential Project effects in 2014.
Cadmium, copper and iron are included in the list of water quality
variables assessed in the Doris North AEMP (Rescan 2010) and
will therefore continue to be examined for potential Project effects
in 2014.
Iron concentrations should be monitored
in the reference lakes to ensure they are
still comparable to exposure lakes.
HESL agrees with TMAC's assessment that project
activities likely had no impact on the aquatic
environment. Changes in particle size likely represent
natural heterogeneity in the environment as do the
variations in sediment chemistry.
TMAC may need to consider a new
reference site if this is not the case.
Particle size and sediment chemistry Particle size and sediment chemistry will continue to be monitored
should continue to be monitored to in 2014 as per the Doris North AEMP (Rescan 2010).
better understand the heterogeneity
occurring at the sites within the project
assessment area.
23
HESL agrees that some of the change observed at
Roberts Bay West was a result of the changing sediment
composition but is concerned that project activities at the
jetty may also be implicated.
TMAC should closely monitor copper TMAC will continue to monitor sediment chemistry, including
concentrations at the Roberts Bay West copper concentrations, and particle size composition in the marine
and reference sites to ensure environment as per the Doris North AEMP (Rescan 2010).
construction activity has not had a
lasting impact on the sediment
HESL feels that project activities may have impacted composition.
sediment quality in the marine environment but
detrimental impacts to aquatic life cannot be determined TMAC should continue to monitor
at this time.
sediment chemistry and composition in
the marine environment to determine if
changes are more closely correlated
with particle size or project activities. If
the latter is the case steps should be
taken to ensure project activities do not
degrade the environment. This will need
to be addressed during the permitting
phase, specifically in the water
management plans. Reports should be
submitted to the KIA to allow for critical
peer review of sediment quality data.
HESL agrees that it is unlikely the project has impacted Changes in the community should be Primary producers will continue to be monitored in conjunction with
the primary producer community in the marine monitored in conjunction with water and water and sediment quality for potential changes related to the
environment due to the similarity in changes observed sediment quality to ensure the weight of Project in 2014, as per the Doris North AEMP (2010).
between the exposure and reference sites.
evidence does not suggest an impact to
aquatic life from project activities.
HESL feels that the benthic community results do not Non-parallel observations of the benthic Benthic invertebrates will continue to be monitored at both Doris
indicate a significant impact to the aquatic environment community at Doris North and South North and Doris South in 2014, as per the Doris North AEMP
from project activities.
should be closely monitored in the future (Rescan 2010).
to ensure that observed changes are
due to natural variability rather than
Project impacts.
24
HESL feels that the erosion of the jetty and subsequent
construction activities had influenced the benthic
community in the marine environment. HESL notes that
the repair work underway on the jetty constitutes a
mitigation measure.
TMAC should endeavour to reconstruct
the jetty during repair operations in such
a way as to decrease the possibility of
significant future erosion.
25
The jetty was repaired and strengthened during the winter of 201314, under a work plan authorized by DFO. This work was
accomplished when the Arctic Ocean was frozen to the bottom near
the jetty. Ice was excavated from the area adjacent to the jetty and
new large rocks were placed on the sea bottom at that
location. Working in the dry in this fashion ensured that the rocks
were placed individually in a way that would decrease the erosion
of the structure. This was then topped with crushed material and
brought up to grade. By doing the work in the winter the fill material
could be placed in the optimum fashion and reduce the potential for
erosion and deposition near the jetty.
Bibliography:
Nagy, J., M. Campbell and A. Kelly (2012) Herd structure, movements, calving grounds, activity
periods, home range similarity, and behaviours of migratory and tundra-wintering barren-ground
caribou on mainland Nunavut and eastern mainland Northwest Territories, Canada. Technical
Report Series 2012 – No. 01-12, Nunavut Department of Environment, Wildlife Research
Section
Rescan (2010) Doris North Gold Mine Project: Aquatic Effects Monitoring Plan. Prepared by
Rescan Environmental Services Lts. for Hope Bay Mining Ltd. Vancouver, B.C.
Should you have any questions regarding our responses, please contact me at
john.roberts@tmacresources.com.
Yours sincerely,
M. John Roberts
Vice President, Environmental Affairs
Hope Bay Project
(416) 628-0216
26