Workshop Summary: Dominion Diamond Ekati …registry.mvlwb.ca/Documents/W2012L2-0001/W2012L2-0001 - Ekati... · - North Slave Metis Alliance (NSMA) - Tlicho Government – Lands Department

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Box 32, Wekweètì, NT X0E 1W0 Tel: 867-713-2500 Fax: 867-713-2502

#1-4905 48th Street, Yellowknife, NT X1A 3S3 Tel: 867-765-4592 Fax: 867-669-9593 www.wlwb.ca

Workshop Summary: Dominion Diamond Ekati Corporation’s

Aquatic Response Framework

The Wek’èezhìi Land and Water Board (WLWB or Board) held a workshop on June 19, 2015 to facilitate a

discussion between affected parties and the proponent about DDEC’s Aquatic Response Framework (ARF).

The focus of the workshop was to discuss the identified remaining uncertainties in DDEC’s ARF, identified

in the Board January 30, 2015 directive. In addition, a discussion was held in response to the Board’s

February 23, 2015 directive, to address the link between dustfall and the aquatic environment, particularly

related to monitoring dustfall to identify impacts to the aquatic receiving environment, at the Lynx

Development.

As requested, the proponent submitted an Information Package in response to the Board’s directives one

week prior to the workshop, June 12, 2015. This information package was distributed to all affected

parties that same day.

Workshop participants (alphabetical):

- Dominion Diamond Ekati Corporation (DDEC)

- Department of Fisheries and Oceans (DFO)

- Environment Canada (EC)

- Environment and Natural Resources Department (ENR), Government of the Northwest Territories

- The Independent Environmental Monitoring Agency (IEMA)

- Lutsel’Ke Dene First Nation (LKDFN)

- North Slave Metis Alliance (NSMA)

- Tlicho Government – Lands Department (TG)

- WLWB Board staff

Topics of Discussion:

1. Significance thresholds;

2. Benchmarks for fish and biology;

3. Fish parameter selection;

4. Low action level for biological community composition;

5. Water quality – evaluation of effects and low action level; and,

6. Dustfall impacts to the aquatic receiving environment.

http://www.mvlwb.ca/Boards/WLWB/Registry/2012/W2012L2-0001/W2012L2-0001%20-%20Ekati%20-%20AEMP%20-%20Response%20Framework%20-%20Version%201.1%20-%20Board%20Directive%20and%20Reasons%20for%20Decision%20-%20Jan%2030_15.pdf

http://www.mvlwb.ca/Boards/WLWB/Registry/2012/W2012L2-0001/W2012L2-0001%20-%20Ekati%20-%20AEMP%20-%20Lynx%20Development%20-%20Board%20Directive%20and%20Reasons%20for%20Decision%20-%20Feb%2023_15.pdf

http://www.mvlwb.ca/Boards/WLWB/Registry/2012/W2012L2-0001/W2012L2-0001%20-%20Ekati%20-%20AEMP%20-%20Response%20Framework%20-%20Workshop%20Information%20Package%20-%20June%2012_15.pdf

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Board staff began the workshop with a short presentation on the Board’s Draft Guidelines for Adaptive

Management – a Response Framework for Aquatic Effects Monitoring. DDEC followed with a presentation

of its approach to its Response Framework. Then, for each discussion topic, DDEC gave a brief explanation

of the information presented in the information package, after which all participants had an opportunity

to provide feedback.

This summary document presents the key points discussed during the workshop on each topic area.

1. Significance thresholds

DDEC presented three significance thresholds (STs) in its June 12, 2015 Information package. The ST for

water quality and for plankton and benthos remained the same as Version 1.1 of its ARF; changes were

presented for its significance threshold for fish.

Plankton and Benthos

IEMA requested clarity regarding the use of the term “sufficient” (sufficient food for fish) in the ST for

plankton and biology, questioning whether consideration had been given to interpretation of

‘significance’ as abundance vs. nutritional value for fish; DDEC confirmed that it is not just abundance but

type of food for fish that is intended by this ST. IEMA recommended that subjective terminology be

explained in Version 1.2.

Board staff identified that the ST for plankton and benthos may be interpreted as circular - do we have to

wait for identification of significant effects before knowing that there is a significant impact to biology?

Board staff acknowledged that it was likely not DDEC’s intention and that the action levels for plankton

and benthos are likely to provide additional clarity, but pointed out that the ST is somewhat confusing in

this regard.

Fish

Considering the ARF as an early warning system, IEMA questioned why small-bodied fish were not

included in the ST, in particular slimy sculpin which has been included in the AEMP as an indicator species

for large-bodied fish. ENR commented that not having a ST for small bodied fish makes it seem as though

there could be a loss of a small bodied fish and it wouldn’t be considered a ST; given their trophic status,

small-bodied fish should be included.

DDEC acknowledged that having a ST for plankton and benthos and not for small bodied fish appears

inconsistent. DDEC brought up the consideration that because plankton and benthos are at the bottom of

the food chain, it may make sense just to have an ST for them and not for the small bodied fish. Amongst

the whole group, it was discussed that having a value statement that protects large-bodied fish is

appropriate, and that inclusion of surrogate (small-bodied) species would be most appropriate as part of

a low action level. DDEC explained that it is currently unclear whether slimy sculpin are an appropriate

surrogate for the large-bodied fish species at Ekati; research will be done this summer to better

understand this relationship. Results will be presented in the 2015 Annual Aquatic Effects Monitoring

Program (AEMP) report.

http://wlwb.ca/sites/default/files/documents/Final-Draft-Response-Framework-for-Aquatic-Effects-Monitoring.pdf

http://wlwb.ca/sites/default/files/documents/Final-Draft-Response-Framework-for-Aquatic-Effects-Monitoring.pdf

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ENR and IEMA requested clarification as to whether the ST is identifying individual species or fish

population at Ekati as a whole; if whitefish increased but trout decreased, would these changes cancel

each other out? DDEC recognized it is not clear and confirmed they are defining STs on a watershed level

and that it is not an overall count, but on a species by species basis.

IEMA questioned whether fish being “unsafe to eat” has been considered for wildlife (not only for human)

consumption. It was recommended that a literature search could be completed most appropriately as

part of a Response Plan for a low action level, should one be exceeded. IEMA cautioned that DDEC identify

the appropriate surrogate livestock species when selecting appropriate guidelines (e.g. sheep was

identified as a better surrogate for caribou than cattle or goats in previous discussions regarding the Long

Lake Containment Facility).

2. Benchmarks for Plankton/Benthos and Fish

During the public review process for Version 1.1, confusion regarding the use of the term benchmark was

identified. A discussion of the semantics of the term when discussing biological change is presented in

DDEC’s information package. ENR agreed that DDEC’s explanation of how it has used the term

‘benchmark’ makes sense, but wonders if it could be avoided when discussing biology and fish? IEMA

agreed that the term benchmark is appropriate for numerical benchmarks (e.g., site specific water quality

objectives, etc.) but is more complicated when discussing non-numerical benchmarks. It was requested

that at a minimum, a clear explanation of how benchmark is defined should be included in Version 1.2.

DDEC was open to consideration of alternative wording. ENR questioned whether “biological change”

could be a possibility. Board staff suggested that instead of using the term benchmark for biology and fish,

the ARF could identify that the low action level is a mine effect, which is outside the normal range, avoiding

the use of the term benchmark altogether in the biological components of the ARF.

DDEC identified that the “trend” component is also important due to the high annual variability and will

be included when defining the low action level for plankton and benthos. IEMA noted a lack of clarity in

the time element used in the benchmarks and low action levels for biology when discussing trends; is it

the three years going forward, or the past three years? DDEC confirmed that a trend analysis will consider

the three most recent years of data when identifying a trend. DDEC committed to evaluating the language

used to improve clarity.

3. Fish Parameter Selection and Low Action Level

In response to January 30, 2015 directive DDEC has now included all fish parameters measured in the

AEMP in its ARF and has updated its low action level for fish to be inclusive of all fish parameters

measured.

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Fish parameters

EC requested clarification of whether the parameters included in the ARF can be re-evaluated should

changes be identified in the receiving environment; i.e., can new parameters be added? DDEC confirmed

that the parameters evaluated for fish are those based on the results of previous AEMPs and that what is

included in the ARF is a starting list. The 2015 Re-evaluation will evaluate which variables need to be added

to the list based on trends, or which can be taken off; the ARF will be updated to reflect this outcome.

Board staff confirmed that the variables included in a RF can be changed based on the outcomes of the

AEMP; it is not a static document.

IEMA asked DDEC how much aboriginal community input had been received in the selection of fish health

parameters. DDEC explained that aboriginal input has definitely driven change in the AEMP, specifically

inclusion of the DELT assessment (deformities, erosions, lesions, tumours), which gives a broader view of

how the fish are doing. IEMA followed up by stating that parasitism in slimy sculpin (tapeworm) in

comparison to reference lakes is the type of parameter that is very good to have in an ARF.

Low Action Level - Fish

A discussion was held on the inclusion of small-bodied fish in the low action level. DDEC has not yet

considered small-bodied fish in defining its low action level. Some reflection was given to ENR’s comments

as whether small bodied fish should only be considered as a surrogate for large-bodied fish, or whether

small-bodied fish abundance should be included an additional parameter; Board staff questioned whether

a low action level for small bodied fish in considering abundance would be appropriate. No conclusions

were reached on this topic but it was noted that the results of slimy sculpin sampling this summer will

provide more insight into the usefulness of slimy sculpin. DDEC will present the results of slimy sculpin

monitoring in the 2015 AEMP Annual Report which will be submitted in the spring of 2016. DDEC said

that it will comment on the utility of including slimy sculpin in the ARF at that time.

DDEC highlighted that there is no time element included in the low action level for fish due to sampling

frequency; therefore, exceedance in any one year would trigger the action level.

4. Low Action Level for Plankton and Benthos Community Composition

DDEC proposed in its Information Package to remove condition #3 in the low action level biological community composition, as presented in Version 1.1;

Condition #3: Uncertainty exists around the meaning, significance or implication of the change triggering condition one (1) and more information is required.

Board staff pointed out that removal of this condition makes the action level more conservative since only

two conditions now need to be met instead of three. IEMA requested assurance that the precautionary

principle would be applied in investigating changes in community composition. IEMA is concerned that a

change in plankton populations would have to be identified as a mine effect to be investigated; should

there be uncertainty as to whether it is a mine effect, IEMA wonders if it would still be investigated if

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condition #3 is removed? During the ensuing discussion, IEMA agreed that the use of the term “suspected”

(a mine effect is detected or suspected) in conditions #1 and 2, addresses this concern.

LKDFN asked why a trend, if suspected to be a mine effect, would have to occur for three years, prior to

further investigation; i.e., will a discussion of an identified change occur annually, not only after being

identified for three years? DDEC confirmed that general interpretation of results, including identification

of a mine effect, additional sampling, and other efforts to investigate a possible trend do happen as a

result of annual AEMP results, not only when a Response Plan is required by the ARF. It was suggested

that it would be helpful to make a statement to this effect in the ARF.

The qualifying statement presented by DDEC was questioned by IEMA; IEMA stated that it agreed in

principle that there is no need to create a separate Response Plan if an existing Response Plan already

addressing the triggered low action level exceedance exists. But, what if the existing RP only addresses

part of the new action level – IEMA questioned whether is it possible to amend or revise the existing

Response Plan to better reflect additional action levels exceeded? DDEC confirmed that this would be

possible. It was recommended that the qualifying statement included in the information package be

clarified.

Board staff explained that the Licence requires the proponent to report all exceedances and submit a

Response Plan for each. This is meant to be flexible however and responses should be based on the

circumstances present at the time. For example, it could be appropriate to submit a document that points

to or extends an existing Response Plan. IEMA questioned the onus of responsibility in determining when

one plan is sufficient – is it the onus of the company to convince the Board that an existing plan is

sufficient? Or, is it the Board’s responsibility to determine that DDEC needs a separate plan?

Board staff explained that the company proposes a course of action; the Board then evaluates that

proposal through a public review process and makes a final determination.

5. Water Quality – Evaluation of Effects and Low action level

Similar to the situation for plankton and benthos, DDEC removed the third condition of the low action

level for water quality presented in Version 1.1; this condition required all exceedances to be compared

to reference lake information to confirm the exceedance; instead DDEC has included a qualifying

statement which is similar to the intent of condition #3. DDEC states that removal of this condition

simplifies the analysis that would need to be conducted to identify an exceedance in water quality,

allowing for quicker identification of an exceedance by the proponent.

DDEC requested clarification from Board: if action level were to be exceeded as a result of something

external to mine operations, is a response plan necessary? Can DDEC just send a letter to that effect?

Board staff responded that the Licence requires a Response Plan to be submitted each time an action level

is exceeded; however, the content of that Response Plan will depend on the circumstances presented to

the Board. So, for example, DDEC could submit a Response Plan that simply says that although the action

level was exceeded, the cause was not due to the mine, supported by appropriate rationale.

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ENR requested confirmation that if a variable in the natural environment is already above the

benchmark/low action level (e.g. mercury), but starts to increase, would this trigger an action level? DDEC

confirmed that this type of scenario would trigger the low action level. It was recommended that the

qualifying statement included in the Information package be further clarified.

6. Dustfall Impacts to the Aquatic Receiving Environment

A discussion of dustfall impacts at the Lynx Development, including identification of the link between air

quality monitoring and the aquatic environment, was included in the workshop discussions; this direction

from the Board resulted from a commitment made by DDEC to adaptively manage its aquatic monitoring

in response to measured dustfall loadings.

DDEC provided a calculation of expected dustfall loadings for the Lynx Development. IEMA identified that

blasting dust and winter dustfall concentrations had not been included in the calculation; therefore, in

IEMA’s opinion, it may not yet be reasonable to conclude that dustfall loadings to the aquatic environment

are going to be “negligible.” IEMA would like to see the monitoring of dust to be discussed prior to Lynx

going into large-scale operations.

The Tlicho Government identified that dustfall loadings have a major impact on the Tlicho way of life; TG

has done their own TK research and would like to be part of these discussions moving forward.

DDEC proposed that it could complete the calculations of dustfall loadings through the AEMP Re-

evaluation, as they relate to the aquatic receiving environment. These calculations could include blasting

information and winter dustfall sources, based on available sources. In addition, DDEC has already

committed to updating its Air Quality Monitoring and Maintenance Plan (AQMMP) prior to

commencement of operations at Lynx, and has noted IEMA’s request to include blasting and winter

dustfall sources in its update. Once this document is completed, further discussion can commence.

IEMA questioned whether the information presented in the Information Package addresses the Board’s

concerns with respect to dustfall trigger levels and the aquatic environment. Board staff commented that

the Board will consider the information presented and discussed in the workshop, and consider future

options.

Final Workshop Comments

IEMA requested more information regarding how lead times are built into the ARF and considered when

setting action levels. How is rate of change being considered when addressing identified exceedances?

IEMA would like action levels to ensure there is enough lead time to assess an exceedance before it

becomes a problem.

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IEMA recommended that the Board consider issuance of a document which identifies “lessons learned”

in developing responses plans for the mines in the Mackenzie Valley and work towards standardization of

the processes for developing response frameworks and addressing adaptive management.

Conclusions

This summary report will be sent to all workshop participants for review; any comments on the

information presented can be sent to Board staff by Monday June 29, 2015. It will be presented to the

Board at the July Board meeting. A directive for the development of Version 1.2 of DDEC’s Aquatic

Response Framework will be issued by the WLWB shortly thereafter.

Submission of Version 1.2 will be determined by the Board, but is anticipated to be in late summer/early

fall; at that time Version 1.2 will be distributed for public review.

Should you have any questions, please contact Elissa Berrill at [email protected] or 867-765-4581. The

WLWB thanks all participants for their time in preparing for and attending this workshop and apologizes

for technical difficulties limiting conference call participation.

Sincerely,

Elissa Berrill Ryan Fequet Regulatory Specialist Executive Director

Attachments

1. WLWB Board staff’s workshop presentation

2. DDEC’s workshop presentation

mailto:[email protected]

Aquatic Response Framework Workshop -

Ekati Diamond Mine

June 19, 2015

Purpose of Workshop

To facilitate a discussion about the remaining uncertainties in Dominion Diamond EkatiCorporation’s Aquatic Response Framework.

This discussion will assist in the development of Version 1.2 of DDEC’s Aquatic Response Framework.

Agenda - MorningTime Topic

9:00 - 9:30 am Introductions and outline of the process

9:30 – 9:45 am WLWB Presentation on Response Frameworks

9:45 – 10:15 am DDEC presentation of its approach to development of its ARF

10:15-10:30 am Break (coffee and snacks provided)

Topics of Discussion(5-10 min presentation by DDEC on each topic, followed by 25-35 min for

discussion)

10:30 – 11:15 am 1. Significance thresholds

11:15 – 12:00 pm 2. Benchmarks for fish and biology

12:00 – 1:30 pm Lunch (not provided)

Agenda - AfternoonTime Topic

1:30 – 2:10 pm 3. Fish parameter selection and the low action level for fish

2:10 – 2:50 pm 4. Low action level for biological communitycomposition

2:50 – 3:00 pm Break (coffee and snacks provided)

3:00 – 3:40 pm5. Dust fall impacts to the aquatic receiving

environment - adaptive management in response to monitoring results

3:40 – 4:20 pm6. Water Quality - evaluation of effects – low action

level for water quality

4:20 – 5:00 pm Summary of discussion, remaining questions, conclusions.

Introductions

Process Summary – to date

• DDEC submitted Version 1.0 on February 15, 2014

• Version 1.0 reviewed and DDEC directed to make some changes (July 4 & Sept 12 Directives).

• DDEC submitted Version 1.1 on November 20, 2014.

• Version 1.1 reviewed and DDEC directed to address some additional items that would be discussed at this workshop January 30, 2015.

• DDEC submitted additional info on June 12, 2015.

Process Summary – going forward• Board staff to makes notes about comments made at

this workshop and distribute a summary sheet to all participants on Tuesday June 23.

• Parties may provide feedback on the summary document prior to end of day, Monday June 29, 2015.

• The Board will issue a directive for DDEC to consider/implement for Version 1.2 in July 2015.

• DDEC to submit Version 1.2 late summer/early fall (TBD).

• Version 1.2 will be subject to review & approval.

Presentation on WLWB’s Response

Framework

Background – Why did the WLWB develop the Response Framework?

Question 1 : How to link the EA to the regulatory process ?

Question 2: How to keep project-related effects within acceptable limits?

Question 3: How to bring “adaptive management” from a concept that is often fuzzy into a regulatory program?

• too fuzzy and general

– learning by doing - “we’ll figure it out if it occurs”

• too prescriptive

– Develop a response to all possible eventualities

Summary of Response Framework

• The Response Framework is a systematic approach to responding to the results of an aquatic effects monitoring program.

• The Framework requires proponents to take some action upon reaching a pre-defined level of environmental change or effect (the “action level”).

• Action levels are, in turn, set such that significant adverse impacts never occur.

How are Action Levels (a.k.a., triggers) developed?

You start by defining the Significance Threshold for the project

Baseline

Range of Potential Environmental Conditions

Unacceptable UnacceptableAcceptable Range

Significance Thresholds

Predicted Project Effects

Tiered action levels

• Fish are safe to eat• Water is drinkable• Ecological integrity

maintained

Increasing Environmental Change (over time)

LowLevel Moderate

Level HighLevel

SignificanceThreshold

• Maximum % change over baseline

• No change from baseline

Trend away from background but below benchmark concentration

No biological effect measured

Low • Investigate trend and implications

• Identify potential mitigation options

• Set Moderate and High Action Levels

Benchmark exceedances or biological effect is imminent or has been measured in the area where effects were predicted in the EA

Moderate • Implement mitigations to stop or slow trend

Benchmark exceedances or biological effects are measured that are above EA predictions but below significance threshold

High • Implement mitigations to reverse trend

• Environmental remediation may be necessary

Monitoring Management Result Action

Action Level Exceeded

Basic premise of Response Framework

If an Action Level is exceeded

Submit a “Response Plan”

Report Annually

Monitor

Proponent proposes appropriate Action (e.g., confirm effect,

propose mitigation etc.)

Board determines then enforces action through directives or

amendments to water licence

Stakeholderreview

Site-Specific Action Levels: where science meets social values

Magnitude is related to:

• exceedances of normal range and/or reference conditions

• guideline values if appropriate (e.g., water quality, sediment, fish tissue)

• Importance of water body to stakeholders

• Traditional knowledge end points (e.g., taste)

Spatial considerations related to:

• Big lake vs small lake vs river

• Importance of water bodies to stakeholders

Temporal

• Trends over time are considered

• Acceptability of changes may vary with project phase (e.g., operations versus closure)

Note that several types of action levels can be set to address one significance threshold

Harm to fish populations

Water Quality

Plankton BenthicsFish

Health

High Level

Moderate LevelModerate Level

Challenges and Advantages

Challenges:

• It is hard to define a limit of acceptable change (significance threshold)

• It will be hard to define moderate and high action levels since these may be based on more complicated stats or metrics

• It is hard to resist the urge to act too fast – for example, often the first “action” is to confirm an effect but many prefer to immediately investigate additional mitigations

Advantages:

• Reduces annual debates over significance of observed changes

• Helps stakeholders relate the monitoring data directly to things that matter to them (e.g., plankton biomass vs maintenance of traditional fishing uses)

• Provides a focus for adaptive management

• Erring on the side of a “false positive” is of low risk because there are several action levels between baseline and significance threshold. Also, each exceedance is evaluated before substantial action taken.

Questions on the general concepts of the Response Framework?

DDEC presentation on the development of an Aquatic Response

Framework for the Ekati Diamond Mine

Ekati Diamond Mine Aquatic Response

Framework

Our Approach:

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www.ddcorp.ca


Objective:

• Satisfy requirements of Water LicenceW2012L2-0001

• Consider ‘Guidelines for Adaptive Management – A Response Framework for Aquatic Effects Monitoring- DRAFT’

• Maximize use of existing monitoring data (as part of the AEMP)

• Provide an early-warning system with defined action levels that are initiated with an adequate timeframe to ensure that a significant adverse environmental impact does not occur

• Protect the uses of the aquatic receiving environment at the Ekati Diamond Mine.


• The Ekati Diamond Mine Aquatic Receiving Environment:– Koala Watershed- downstream of the Long Lake

Containment Facility; historical mine influences

– King-Cujo Watershed- downstream of the King Pond Containment Facility

– Pigeon-Fay and Upper Exeter Watershed-downstream of Pigeon Stream Diversion Channel

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www.ddcorp.ca

Topic 1: Significance Thresholds

Surface Water Flow through AEMP Watersheds


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www.ddcorp.ca

Concordance with W2012L2-0001 and WLWB 2010 Guidance

Criterion Included?

Statement of Objectives

Environmental Interactions and Predictions of Change

Identify Environmental Variables of Concern

Define Significance Thresholds *

Overview of Existing Environmental Monitoring Programs

Assessment of Environmental Change

Environmental Action Levels - abiotic and biotic *

Potential Management Responses

Outline of Response Plan Contents

Timelines for Review and Updating Response Plans

Aquatic Response Framework- A Comparison

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www.ddcorp.ca

Ekati (2015) Diavik (2014) Snap Lake (2013)

Components Water Quality, Plankton, Benthos and Fish

Water Quality, Plankton, Benthos and Fish

Water Quality, Sediment Quality, Plankton, Benthos and Fish

Site Specific Monitoring Area

Near Field – considered for action levels; 1 or 2 lakes downstream of potential mine impact

Watershed – considered for significance threshold

Near Field Mixing ZoneFar Field BFar Field A (reference)

Mixing ZoneMain Basin

Significance Threshold

(1) Water Quality -Narrative (2) Plankton and Benthos -Narrative (3) Fish - Narrative

(1) Water – Numerical(2) Plankton – Numerical(3) Benthos – Numerical(4) Fish – Narrative (5) Eutrophication -Numerical

(1) Water - Narrative (2) Fish - Narrative (3) Sediment quality -Narrative (4) Ecological function -Narrative

Aquatic Response Framework- A Comparison

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www.ddcorp.ca

Ekati (2015) Diavik (2014) Snap Lake (2013)

Action Level

Low, Medium and High

Low is defined for each component; medium and high defined in low action response plan

Water Quality – 9 levelsBiological Effects – 5 levelsEutrophication (Chlorophyll a) – 9 levels

All levels are defined within framework except for #4 biological effects

Negligible, Low, Medium, and High

Negligible and Low is defined; medium and high defined in low action response plan

Effects Threshold Not Applicable

Defined if a WQ variable approaches the effects benchmark

Not Applicable

Benchmark

Water Quality- CCME guidelines, Drinking Water guideline (Nitrate), SSWQO

Biological- narrative specific to monitoring data

‘Effects Benchmark’ –CCME guideline and Drinking Water guideline

Eutrophication – 4.5 µg/L (literature)Biological - undefined

Water Quality- CCMEguidelines and Site specific developed in the EAR

Sediment Quality- CCMEguidelines

Biological- undefined


• Designed to link to the current Aquatic Effects Monitoring Program (AEMP)

• Site Specific

– Significance Threshold

– Benchmark

– Action Level

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www.ddcorp.ca

Topic 1: Significance Thresholds


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www.ddcorp.ca

WLWB Request:

‘Significance thresholds for fish and biology, as those included in Version 1.1 were removed at the request of the proponent’

Rationale:

Removal of the significance thresholds for two of three identified ecosystem components (biology and fish) in Version 1.1 of DDEC’s Response Framework results in non-compliance with Part J, Item, 8 of W2012L2-0001.

Significance Threshold – Water Quality

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www.ddcorp.ca

Version 1.1

“The water quality of the Koala, King-Cujo or Pigeon-Fay and Upper Exeter watershed is unsafe to drink for wildlife and/or humans”

Significance Threshold – Plankton & Benthos

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www.ddcorp.ca

Version 1.1

“The plankton and/or benthos communities of the Koala, King-Cujo or Pigeon-Fay and Upper Exeter watershed have changed in such a way that sufficient food for fish is no longer available”

Significance Threshold – Fish

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www.ddcorp.ca

Version 1.1

“The fish of the Koala, King-Cujoor Pigeon-Fay and Upper Exeter watersheds are unsafe to eat or

the population of an ecologically, recreationally or

culturally important fish species is negatively affected”

Version 1.2

“A large-bodied fish species (i.e., lake trout or round whitefish) of the Koala, King-Cujo, or Pigeon-Fay and Upper Exeter watershed is unsafe to eat; or is unable to survive, grow, or reproduce, or

is permanently lost from a watershed”


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www.ddcorp.ca

Questions?

Topic 2: Benchmarks for Plankton/Benthos and Fish

Benchmarks for Plankton/Benthos & Fish

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www.ddcorp.ca

WLWB Request:

Benchmarks for fish and biology

WLWB Rationale:

Benchmark for fish was requested to be removed and a new benchmark for biology was proposed by the proponent.

Concerns over newly proposed benchmark for biology.

Benchmarks for Plankton/Benthos General Variables (Biomass and Density)

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www.ddcorp.ca

Version 1.1

• Numerical based on reasonable normal ranges

• If an observation (e.g., average 2014 phytoplankton density) is less than the lower benchmark or greater than the upper benchmark, the benchmark is exceeded

Benchmarks for Plankton/Benthos Diversity & Community Composition & Fish

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www.ddcorp.ca

Version 1.1

“mine effect is not observed using the methodology applied in the AEMP – Part 1 Evaluation of Effects”

Benchmarks for Plankton/Benthos General Variables (Biomass and Density)

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www.ddcorp.ca

Wek’èezhìi Land and Water Board DDEC Aquatic Response Framework

Benchmark: “a contaminant concentration that is expected to be protective of aquatic life. This value would be set below the significance threshold for a chemical parameter.”

Benchmark” “the level at which effects can be detected in sensitive organisms”

Water Quality Benchmark: “…encompasses water quality guidelines and SSWQO. Water quality that meets water quality benchmarks is safe for its identified uses.”

Biological Benchmark: “…broad ecosystem and biological indicators. Where biological measures meet their benchmarks, the measure remains similar to reference or baseline conditions”.


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Questions?

Topic 3: Fish Parameter Selection and Low Action Levels for Fish

Fish Parameter Selection and Low Action Levels for Fish

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www.ddcorp.ca

Rationale:

All fish parameters should be included in Response Framework, however, DDEChas included only a subset of variables (those predicted to change or with current mine effects)

WLWB Request:

(a) a description of the limitations that exists within the current AEMP Design that limit the proponent in determining the low action level for fish, and (b) an outline of the statistical analysis that the proponent identifies as necessary in order to determine a meaningful change in fish, for each of the fish parameters identified in Version 1.1 of the Response Framework

Version 1.2

• fish health and fish community parameters

currently assessed in the AEMP for large-bodied

fish species• AEMP “evaluated” fish

tissue metals

Fish Parameter Selection

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Version 1.1

• Parameters predicted to change in 1995 EIS or 2000

EA• Current mine effect

(similar to rationale for including water quality

variables)

Fish Parameter Selection

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Questions?

Version 1.2

Based on AEMP methods for determining mine

effects in fish, a mine effect is concluded for a near-field lake for lake trout or round

whitefish

Based on AEMP methods for determining mine effects for metals in fish muscle or liver

and EROD activity, a mine effect is concluded for a near-field lake for lake trout or round

whitefish muscle or liver metals or EROD activity.

Low Action Levels for Fish

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Version 1.1

Low Action Levels for Fish

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Questions?

Topic 4: Low Action Levels for Plankton/Benthos Community

Composition

Low Action Levels for Plankton/Benthos Community Composition

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WLWB Request:

an updated low action level for biological diversity/community composition with accompanying rationale that addresses the discussion held in the RFD

Rationale:

DDEC proposed three conditions which would trigger a low action level for biological diversity and community composition in Version 1.1. The Board is concerned with the organization of the conditions: requiring conditions (1) and (2) AND (3) to all be satisfied in order to trigger the low action level, could result in confusion as to when an effect would trigger the low action level.

• Remove 3rd condition from Version 1.1

• Add qualifying statement as per WLWB recommendation

1. Based on AEMP methods for determining mine effects a mine effect is detected or suspected at a near-field lake; 2. The mine effect detected or suspected in condition one (1) is based on three years of data including the current AEMP year and the previous two years at any near-field site; and3. Uncertainty exists around the meaning, significance or implication of the change triggering condition one (1) and more information is required.

Low Action Levels for Plankton/Benthos Community Composition

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Version 1.1 Version 1.2

Low Action Levels for Plankton and Benthos Community Composition

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Questions?

Topic 5: Dustfall Contribution to the Aquatic Environment

‘The Board requires DDEC to define a level of dustfall deposition that will trigger a response to address impacts of higher than anticipated dustfall levels.’

Lynx Development - Board Directive and Reasons for Decision- February 23, 2015

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Dustfall Contribution to the Aquatic Environment


Contribution of Dustfallto the Lynx Area Aquatic Environment:

• Similar methods to that completed in 2009 and 2012 Re-evaluation

• Calculate an order of magnitude estimate for potential contribution of dustfall in summer

• Dustfall data from Misery Area stations and WRSA

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• Develop decay functions with distance from mine infrastructure(subtract background)

• Area under the curve = total mass of deposition/day/m2

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• Calculated the dust deposition with a footprint area (Lynx Area)

• Assumed all dust deposited on ground is transported into the aquatic environment

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• From the total dustfalldeposition (kg) calculated the equivalent concentration in the aquatic environment

• Compared to Mossing Stream observed concentrations in 2013 and 2014

Variable

Total Dustfall

Deposition (kg)

Equivalent Concentration

(mg/L)

Average Mossing Stream Concentration (mg/L)

2013 2014

Total Dissolved Solids (TDS)

22.1 0.007 29.13 27.09

Total Suspended Solids (TSS)

449 0.142 < 3.0 < 3.0a

Chloride 2.18 6.92 x 10-4 0.755 0.645

Nitrate as N 0.302 9.59 x 10-5 0.0034 0.0029

Sulphate 0.781 2.47 x 10-4 7.51 6.30

Potassium 4.36 1.38 x 10-3 1.34 1.32

Aluminum 7.32 2.32 x 10-3 0.0418 0.0537

Equivalent concentration of the calculated dustfall contributions are at least two orders of magnitude smaller than the 2013/2014 average

observed Mossing Outflow concentration


Estimate of the total dustfall entering Mossing Lake required to increase the TSS by 50% in Mossing Outflow:

• = 689 kg annually (5.6 kg/summer day and assumes complete mixing)

• Comparison to that observed daily between 2009 to 2014:

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Misery Total Dustfall Deposition (mg/m2/day)

30 m 90 m 300 m 1000 m

Average 9.04 2.75 0.61 0.51

Range 0.97 – 35.90 0.11 - 25.10 0.10 – 2.43 0.14 – 2.04

• Dustfall Contribution to Aquatic Environment mitigation:

– Regular maintenance of equipment will continue at the Ekati mine;

– Dust suppression measures will be applied as appropriate to haulage roads;

– Speed limits are established on all roads to reduce production of dust

• Continued dustfall monitoring on Misery Haul Road

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Questions?


Topic 6: Water Quality – Evaluation of Effects and Appropriate Lead

Times

• [Provide] An example of how to complete the analysis for the water quality action levels, and a presentation of the benefits and limitations, for each of the following:

– comparing average measured monthly concentrations of the water quality variables at any near-field AEMP sampling location to seasonal trends in reference lakes); and,

– comparing average measured monthly concentrations of the water quality variables at any near-field AEMP sampling location to the maximum observed reference lake concentration based on data collected within the same month

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Water Quality - Evaluation of Effects

Board Directive:

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Why not a comparison to Reference Condition Trends?

Example 1-‘Different Linear Trends’:

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Example 2-‘Different Non-linear Trends’:

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Example 3-‘Different Non-Linear Trends Not Related to Current Mine Effects’:

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Version 1.1

1.The average measured monthly concentration of the water quality variable at any near-field AEMP sampling location is greater than 50% of the water quality benchmark; 2. The variable shows an increasing annual trend for all sampling events based on data collected within the same month for which condition one (1) is met; and3. The average measured monthly concentration of the water quality variable at any near-field AEMP sampling location is greater than the maximum observed reference lake concentration based on data collected within the same month for which condition one (1) is met.


• Add qualifying statement as per WLWB recommendation


• Add qualifying statement for water quality variables unclear trends and those that are also known to naturally exceed water quality benchmarks

Version 1.2

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Questions?


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Water Quality – Appropriate Lead Times

WLWB Request:

IEMA raised concern that lead times in action levels are not explicitly defined and that it is necessary to do so to provide enough lead time to actually implement an appropriate response. (IEMA-4).

Rationale:

The low action level is defined in such a way that it provides the lead time needed to address an issue – it is in effect, the lead time. In other words, Low Action Levels are meant to be low enough that there is appropriate time to act on an identified increasing trend long before a benchmark (and certainly a Significance Threshold) is reached. The exceedance of a Low Action Level does not mean ‘take immediate action;’ what it does mean is investigate further and plan how to address the trend identified, should it continue in the same direction

• Low action have been set to ensure that adequate lead times were incorporated

• For example the 50% of the benchmark was selected for water quality variables because based on best professional judgment and to some extent the existing water quality modelling predictions this allowed sufficient time to complete the appropriate low level actions

• Medium and High action levels will be developed to ensure that the variable specific rates of change, ecological implications and other relevant information are captured

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Water Quality - Appropriate Lead Times

DDEC Response (January 6, 2015):

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Questions?

Water Quality - Appropriate Lead Times

Thank -you