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The management of impacts on aquatic resources at new mine developments in British Columbia Winsby, Malcolm Blake 1986

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THE MANAGEMENT OF IMPACTS ON AQUATIC RESOURCES AT NEW MINE DEVELOPMENTS IN BRITISH COLUMBIA by MALCOLM BLAKE WINSBY B.Sc, The University of British Columbia, 1975 THIS THESIS IS SUBMITTED IN PARTIAL FULFILMENT OF THE REQUIREMENTS FOR THE DEGREE OF MASTER OF SCIENCE in THE FACULTY OF GRADUATE STUDIES (School of Community and Regional Planning) We accept this thesis as conforming to the required standard THE UNIVERSITY OF BRITISH COLUMBIA APRIL 1986 © Malcolm Blake Winsby, 1986 In p r e s e n t i n g t h i s t h e s i s i n p a r t i a l f u l f i l m e n t o f the requirements f o r an advanced degree a t the U n i v e r s i t y o f B r i t i s h Columbia, I agree t h a t the L i b r a r y s h a l l make i t f r e e l y a v a i l a b l e f o r r e f e r e n c e and study. I f u r t h e r agree t h a t p e r m i s s i o n f o r e x t e n s i v e copying of t h i s t h e s i s f o r s c h o l a r l y purposes may be granted by the head of my department o r by h i s o r her r e p r e s e n t a t i v e s . I t i s understood t h a t copying or p u b l i c a t i o n o f t h i s t h e s i s f o r f i n a n c i a l g a i n s h a l l not be allowed without my w r i t t e n p e r m i s s i o n . Department of The U n i v e r s i t y o f B r i t i s h Columbia 2075 Wesbrook P l a c e Vancouver, Canada V6T 1W5 Date 7Q ^ i i ABSTRACT This thesis evaluates the a n a l y t i c a l methods and review procedures used for assessing • the impacts on aquatic resources from metal mines i n B r i t i s h Columbia. The s p e c i f i c objectives are to evaluate the effectiveness of pre-development assessment studies for a n t i c i p a t i n g eventual impact management problems, to evaluate a n a l y t i c a l weaknesses i n the pre-development studies; and, to develop recommendations f o r improving the methods and procedures currently used for impact management planning. To evaluate the effectiveness of pre-development studies, impact management problems were reviewed for f i f t e e n mines. Pre-development reports submitted by the mine proponents before mine production began were then reviewed to determine to what extent the problems had been anticipated. Twenty-four problems were i d e n t i f i e d amongst eight mines. Pre-development assessments anticipated 18 of the eventual problems. The r e l a t i v e seriousness of the problems varied considerably. The most serious problems were related to the routine discharge of material (cyanide and metals at gold mines) and to a si t e - r u n o f f problem ( the generation of acid i n waste rock at one sulphide ore mine). However, the most common problems (46%) were associated with equipment and s t r u c t u r a l , f a i l u r e s , mainly t a i l i n g s f a c i l i t i e s ( i . e . l i n e s , pumps, and dams). The pre-development assessments were generally more e f f e c t i v e for i d e n t i f y i n g problems related to routine discharge sources and to general s i t e runoff than to the more common equipment and s t r u c t u r a l f a i l u r e s . To evaluate the a n a l y t i c a l methods used i n the pre-development studies, the following factors were examined: the apparent influence of government guidelines and procedures; the t h e o r e t i c a l weaknesses i n the i i i methods used; and, t h e improvements t o a n a l y t i c a l methods s u g g e s t e d i n r e c e n t government Terms o f R e f e r e n c e (TOR's). I n a d d i t i o n , t h e t y p e s of i n f o r m a t i o n and methods used i n m o n i t o r i n g and f o l l o w - u p s t u d i e s were examined f o r c o m p a r i s o n w i t h t h e pre-development s t u d i e s . The approaches and methods used i n Stage I s t u d i e s have been s t r o n g l y i n f l u e n c e d by t h e 1979 " P r o c e d u r e s " p r e p a r e d by t h e B.C. M i n i s t r y of E n e r g y , M i n e s and P e t r o l e u m R e s o u r c e s . The P r o c e d u r e s recommend a c h e c k l i s t o f t o p i c s t o a d d r e s s but p r o v i d e poor g u i d a n c e on how i m p a c t a n a l y s e s a r e t o be used f o r d e v e l o p i n g i m p a c t management measures. The more r e c e n t s i t e - s p e c i f i c TOR's a r e , i n a s e n s e , p r e - a s s e s s m e n t s o f p o t e n t i a l s o u r c e s of e f f e c t . The TOR's r e q u e s t more d e t a i l e d i n f o r m a t i o n t h a n g e n e r a l l y p r e s e n t e d i n p r e v i o u s r e p o r t s s u b m i t t e d by mine p r o p o n e n t s . The main a n a l y t i c a l weaknesses a r e : t h e u n c l e a r r e l a t i o n s h i p between t h e management p l a n s and m o n i t o r i n g programs and t h e s p e c i f i c r e s o u r c e s a t r i s k ; and, t h e absence o f c r i t i c a l a p p r a i s a l s o f i mpact management measures, i n o r d e r t o d e v e l o p a f a l l - b a c k s t r a t e g y i n t h e e v e n t t h a t t h e chosen measure i s found t o be i n a d e q u a t e . Recommendations i n c l u d e : t h e development o f an e a r l y and e x p l i c i t d e s c r i p t i o n o f t h e l i n k a g e s e x p e c t e d between a p a r t i c u l a r mine and i m p o r t a n t r e s o u r c e s ; t h e p r e p a r a t i o n o f a l t e r n a t e o r " f a l l - b a c k " measures t h a t would be implemented i n t h e e v e n t t h a t t h e chosen methods d i d n o t work; t h e p r e p a r a t i o n by government a g e n c i e s o f t h e t y p e s o f i n f o r m a t i o n r e q u i r e d t o d e v e l o p e f f e c t i v e c o n t i n g e n c y p l a n s ; and, t h e c l e a r s e p a r a t i o n o f i n f o r m a t i o n i n t e n d e d t o d e s c r i b e i m p o r t a n t r e s o u r c e s from t h a t w h i c h i s q u a n t i t a t i v e b a s e l i n e d a t a t o be used d u r i n g f o l l o w - u p m o n i t o r i n g and a s s e s s m e n t s . O p p o r t u n i t i e s a r e i d e n t i f i e d f o r t h e m i n i n g i n d u s t r y t o u n d e r t a k e a s t r o n g e r r o l e i n t h e development o f a n a l y t i c a l s t a n d a r d s f o r i m p a c t a s s e s s m e n t , b o t h t o a b s o r b some o f t h e c o s t s o f d e v e l o p i n g i v assessment procedures and to increase understanding amongst proponents as to the kind of a n a l y t i c a l and impact problems that e x i s t . V TABLE OF CONTENTS Page ABSTRACT i ACKNOWLEDGEMENTS i v TABLE OF CONTENTS v LIST OF TABLES v i i i LIST OF FIGURES x CHAPTER 1.0 INTRODUCTION 1 1.1 Nature of the Problem 2 1.2 Purpose and Objectives 2 1.3 Approach 2 1.4 Scope of the Study 3 CHAPTER 2.0 THE INSTITUTIONAL FRAMEWORK FOR MANAGING IMPACTS FROM METAL MINE DEVELOPMENT 5 2.1 The P r o v i n c i a l Mine Development Review Process 5 2.1.1 The General P r o v i n c i a l Review Process for New Project Development 5 2.1.2 Evolution, Structure and Requirements of the Mine Development Review Process 7 2.1.2.1 Review Stages and Reports 7 2.1.2.2 The Review Committees 9 2.2 Requirements of P r o v i n c i a l Regulatory Agencies 11 2.2.1 Waste Management Permits and Approvals 11 2.2.2 Water Licences and Approvals 12 2.2.3 Reclamation Permits 12 , 2.3 Requirements of Federal Agencies 13 2.4 Summary 14 CHAPTER 3.0 THE THEORETICAL CONCEPTS AND METHODS AVAILABLE FOR IMPACT ASSESSMENT 15 3.1 A n a l y t i c a l Concepts and Methods Described i n the EIA L i t e r a t u r e " 15 3.1.1 The Concept of EIA 3.1.2 Weaknesses i n the T r a d i t i o n a l Approaches to EIA 16 3.1.3 Current Theories for an Improved Approach to EIA 17 3.1.3.1 The Early Conceptualization of Interaction Between a Proposed Project and the Environment 17 3.1.3.2 I d e n t i f i c a t i o n of Important Resources at Risk 18 3.1.3.3 Application of S c i e n t i f i c and E c o l o g i c a l P r i n c i p l e s 19 v i Table of Contents (cont'd) Page 3.1.3.4 Development of Clear C r i t e r i a f o r Interpreting Impact S i g n i f i c a n c e 20 3.1.3.5 The Recognition that Impact Assessment i s an On-going and Adaptive Process 21 3.2 A n a l y t i c a l Features that Could be Included i n Pre-development Studies Undertaken by Mine Proponents 21 CHAPTER 4.0 THE EFFECTIVENESS OF PRE-DEVELOPMENT IMPACT ASSESSMENTS 28 4.1 Study Methods 28 4.1.1 Analysis of Recent Aquatic Resource Impact Management Problems 28 4.1.2 Review of Pre-development (Stage I/Stage II) Impact Assessments 30 4.2 Results 30 4.2.1 Impact Management Problems at 15 Mines 31 4.2.1.1 Stage I mines 31 4.2.1.2 Stage II mines 41 4.2.1.3 Summary 46 4.2.2 Problems Anticipated i n Stage I/Stage II Reports 46 4.2.2.1 Stage I mines 46 4.2.2.2 Stage II mines 50 4.3 Discussion 50 4.3.1 Effectiveness of Pre-development Assessments 53 4.3.1.1 Types of Problem 53 4.3.1.2 Types of Mine having Serious Problems 54 4.3.1.3 Actual E f f e c t s on Aquatic Resources 56 4.3.1.4 Consequences to Mine Operators 58 4.3.2 A n a l y t i c a l Weaknesses rel a t e d to the Occurrence of Serious Problems 58 4.3.3 Adequacy of the Impact Assessment Process 58 4.4 Conclusions 59 CHAPTER 5.0 THE ANALYTICAL METHODS AND PROCEDURES USED FOR STAGE I IMPACT ASSESSMENTS 63 5.1 Study Methods 63 5.1.1 Influence of the P r o v i n c i a l Review Guidelines 65 5.1.2 I d e n t i f i c a t i o n of A n a l y t i c a l Weaknesses i n Pre-development Studies 65 5.2 Results 66 5.2.1 Influence of the P r o v i n c i a l Review Guidelines 66 5.2.1.1 The A n a l y t i c a l Requirements outlined i n the Government Guidelines 66 5.2.1.2 Conformity of the Five Stage I Reports with the 1979 Procedures 67 v i i Table of Contents (cont'd) P a R e 5.2.1.3 Conformity of the Recent Terms of Reference 71 5.2.1.4 Summary 71 5.2.2 I d e n t i f i c a t i o n of A n a l y t i c a l Weaknesses 72 5.2.2.1 Five Pre-development Assessments 73 5.2.2.2 Two Recent Terms of Reference for Pre-development Assessments 90 5.3 Discussion 93 5.3.1 V a r i a b i l i t y Amongst Stage I Reports 93 5.3.2 Influence of the Governmental Review Guidelines 93 5.3.3 A n a l y t i c a l Weaknesses and Improvements 94 5.3.3.1 Conceptualization of Mine-Fisheries Interaction 94 5.3.3.2 I d e n t i f i c a t i o n of Resources at Risk 94 5.3.3.3 I d e n t i f i c a t i o n of Sources of E f f e c t 96 5.3.2.4 Development of M i t i g a t i v e Measures 98 5.4 Conclusions 101 5.4.1 Influence of the Review Guidelines 101 5.4.2 A n a l y t i c a l Weaknesses and Recent Improvements 101 CHAPTER 6.0 RECOMMENDATIONS 105 6.1 A n a l y t i c a l Improvements 105 6.2 Procedural Improvements 108 REFERENCES 109 APPENDICES 113 Appendix I An Overview of the General Sources and Types of Impact from Metal Mines 114 Appendix II Descriptions of Mines Examined 119 Appendix I I I Impact Management Problems at Thirteen Stage I_ Mines and Two Stage II Mines 123 Appendix IV Information Collected During Post-start-up Studies 130 Appendix V General Contents of Five Stage _I Reports and Two Ministry of Environment Terms of Reference. 133 Appendix VI Stage I_ report format recommended i n the 1979  "Procedures for obtaining approval of metal  mine development" 140 v i i i L ist of Tables Page Table 4 .1 Mines for which impact management problems were examined. 29 Table 4 .2 The source or cause of problems at Stage I mines. 32 Table 4 .3 The number of Stage I mines having each type of problem. 33 Table 4 .4 Changes observed in the aquatic environment near Stage I mines. 35 Table 4 .5 The financial costs borne by mining operations in relation to serious impact management problems. 40 Table 4 .6 The source or cause of problems at Stage II mines. 40 Table 4 .7 The number of Stage II mines having each type of problem. 43 Table 4 .8 Changes observed in the aquatic environment near Equity Silver. 44 Table 4 .9 Impact management problems identified in Stage I reports. 48 Table 4 .10 Conclusions drawn for each problem identified in Stage I reports. 49 Table 4 .11 Impact management problems identified in Stage II reports. 51 Table 4 .12 Conclusions drawn for each problem identified in the Equity Silver Stage II report. 52 Table 5 .1 Mines for which Stage I reports and terms of reference were reviewed. 64 Table 5 .2 Fisheries resource features considered in each report. 74 Table 5 .3 Field data obtained to describe fisheries resource features. 76 Table 5 .4 Fisheries resource features referred to in impact analyses. 77 Table 5 .5 Sources of possible effect referred to in each impact analysis. 78 Table 5 .6 The types of possible change to fisheries resource features considered in each impact analysis. 82 Table 5 .7 Sources of effect for which mitigative measures are described in each impact analysis. 84 Table 5.8 Expected changes to fisheries and other aquatic resources. 85 Table 5 .9 Interpretations of impact presented in each Stage I report. 88 XX Page Table II.1 General de s c r i p t i o n and operating status of mines for which impact management problems were reviewed. 120 Table IV.1 Sampling programs prescribed i n Waste Management Permits for eight mines. 131 .X .. LIST OF FIGURES Page Figure 2.1 Flowchart and report requirements of the Mine Development Review Process. Figure 3.1 The basic EIA steps that could be followed by metal mine proponents for EIA. 22 Figure 4.1 The number of Stage I reports (for Stage I mines) submitted to the Mine Development Review Process, 1979-1985. 60 Figure 5.1 Apparent a n a l y t i c a l frameworks i n f i v e Stage I reports. 70 Figure 5.2 The general phases of mining a c t i v i t y i n r e l a t i o n to the stages of mine production. 99 Figure 6.1 An a n a l y t i c a l framework for undertaking impact management planning at new metal mine developments i n B r i t i s h Columbia. 106 x i ACKNOWLEDGEMENTS I would l i k e to si n c e r e l y thank my advisor, Tony Dorcey, f o r h i s encouragement, committment, and thoughtful guidance throughout t h i s study. I would also l i k e to thank Ray Crook, of the Minis t r y of Energy, Mines, and Petroleum Resources, f o r h i s many suggestions and h i s patient explanations of the i n t r i c a c i e s of the p r o v i n c i a l Mine Development Review Process. I would l i k e to thank both Ray Crook and Norm Dale f o r t h e i r thorough reviews and c r i t i c i s m s of the f i n a l d r a f t of the t h e s i s . I would l i k e to extend my appreciation to Keith Ferguson, of the fed e r a l Environmental Protection Service, and to the many i n d i v i d u a l s i n the regional o f f i c e s of the p r o v i n c i a l Ministry of Environment who provided i n i t i a l suggestions and much of the background material f o r t h i s study. In addition, I would l i k e to thank the owners and operators of the mines described i n t h i s t h e s i s , for the time they took to describe t h e i r operations and the problems they have experienced. F i n a l l y , I would l i k e to thank, with fondness, Edna Sakata, who typed and endured the several early d r a f t s of the t h e s i s . 1 CHAPTER 1.0 INTRODUCTION Mining represents a large and diverse natural resource industry in Br i t i sh Columbia. Although the mining industry makes a substantial contribution to the provincial economy, i t also has the potential to cause serious adverse impacts on the natural environment, part icularly to aquatic ecosystems (Clarke 1974; Ripley et a l . 1978; Marshall 1982). The government of Br i t i sh Columbia has responded to the threat of environmental damage from mining operations by inst i tut ing processes by which mine development can be reviewed prior to government approval. Proposals to develop metal hardrock mines and coal mines are reviewed by the Mine Development Review Process (MDRP). Other types of mining act iv i ty , in particular metal mines and coal mines that are in the exploration phase and placer gold and sand/gravel operations, are reviewed by other review processes. Placer gold applications are reviewed by Regional Placer Coordinating Committees. Metal and coal mines in the exploration phase and sand/gravel operations are examined by means of interagency referrals . Applications by metal and coal mines to alter or expand act iv i t i e s once operations begin are examined by interagency re ferra l , i f the changes are relat ively minor, or by the MDRP, i f the changes are major. The MDRP requires the proponents of metal and coal mines to undertake environmental impact assessment (EIA) and to submit reports indicating the results of the EIA studies. The EIA reports are reviewed by various government agencies, and the reports, together with agency comments, are used by the provincial government to determine whether a proposed mine development should be approved, modified or rejected. 2 1.1. Nature of the Problem Recently, a common c r i t i c i s m of review processes f o r environmental impact assessment has been that well-defined i n s t i t u t i o n a l procedures are developed without f u l l y considering the s c i e n t i f i c and a n a l y t i c a l requirements for conducting the assessments (e.g. Munn 1979; Beanlands and Duinker 1983; Rosenberg et a l . 1981). This s i t u a t i o n i s f e l t to be one of the major factors leading to the generally poor q u a l i t y of impact assessment studies. In B.C., impact assessments are now routinely submitted by metal mine proponents, but environmental problems s t i l l occur, p a r t i c u l a r l y i n r e l a t i o n to nearby aquatic resources. A systematic study has not been undertaken to examine the nature of these problems and the reasons why pre-development studies were not e f f e c t i v e for preventing them. 1.2 Purpose and Ob jectives This thesis evaluates the methods and procedures used for assessing the impacts on aquatic resources from metal (hardrock) mines i n B r i t i s h Columbia. The s p e c i f i c objectives are: a) to evaluate the types of impact management problems that have occurred, and the effectiveness of pre-development assessment studies f or a n t i c i p a t i n g them; d) to evaluate the a n a l y t i c a l weaknesses i n the methods and procedures used for pre-development impact assessment studies; and, c) to develop recommendations for improving the methods and procedures currently used for impact management planning. 1.3 Approach The study has been conducted i n four steps. The f i r s t step was a review of the p r o v i n c i a l EIA review process for new metal mine development (Chapter 2.0) and of the t h e o r e t i c a l concepts and methods that can be used for EIA (Chapter 3.0). The review of the p r o v i n c i a l process was undertaken to examine the i n s t i t u t i o n a l framework within which impact management 3 s t r a t e g i e s are developed. The review of EIA concepts and methods was undertaken to determine what a n a l y t i c a l tools are a v a i l a b l e for assessing impacts from new mine developments. The second step was an assessment of the effectiveness of impact management str a t e g i e s presented i n pre-development reports (Chapter 4.0). F i r s t l y , the l i t e r a t u r e describing the impacts of metal mines on aquatic resources was reviewed. Secondly, recent impact management problems at metal mines that have entered the p r o v i n c i a l review process were i d e n t i f i e d . The problems were i d e n t i f i e d through discussions with personnel at the mining companies and i n government agencies. T h i r d l y , the pre-development impact assessments prepared by the mine proponents and submitted to the p r o v i n c i a l government were examined to i d e n t i f y what problems had been an t i c i p a t e d . The t h i r d step was a deta i l e d examination of the a n a l y t i c a l methods that are used i n pre-development studies to develop the impact management stra t e g i e s (Chapter 5.0). Given the evolutionary nature of the B.C. review process and the requirements for doing impact assessments, three factors were considered during t h i s step. The f i r s t was the influence of government guidelines and procedures; the second was the possible weaknesses i n methods used by the analysts working f o r the mine proponent; and, the t h i r d was the improvements evident i n s i t e s p e c i f i c terms of reference that are now prepared by p r o v i n c i a l review agencies. The fourth step was the development of recommendations (Chapter 6.0), based on the r e s u l t s obtained during the e a r l i e r steps, f or improving the a n a l y t i c a l methods and review procedures used to develop impact management plans. 1.4 Scope of the Study The study has been l i m i t e d to analysis of impacts and impact 4 assessment methods as applied to aquatic resources and i n p a r t i c u l a r , f i s h e r i e s resources. Aquatic resources have been chosen for s p e c i f i c study: a) so that a s i n g l e component of reports submitted by mine proponents can be used as a consistent and manageable focus for analyzing a large number of proponent reports; and, b) because, i n terms of environmental damage generally a t t r i b u t e d to the mining industry, many of the e f f e c t s impinge either d i r e c t l y or i n d i r e c t l y on the aquatic environment (Ripley et a l . 1978). 5 CHAPTER 2.0 THE INSTITUTIONAL FRAMEWORK FOR MANAGING IMPACTS FROM NEW  MINE DEVELOPMENT This chapter provides a review of the nature and evolution of the i n s t i t u t i o n a l framework f or managing impacts from new mine development i n B r i t i s h Columbia. The requirements of agencies responsible f o r managing impacts on aquatic resources are emphasized. The review i s necessary to understand how changes i n i n s t i t u t i o n a l requirements have influenced the a n a l y t i c a l methods used i n pre-development impact assessment studies. Pre-development studies are examined i n d e t a i l i n Chapters 4.0 and 5.0. The p r o v i n c i a l review .process f o r new mine development i s described i n section 2.1, and the requirements of p r o v i n c i a l and fe d e r a l agencies responsible f o r protecting the aquatic environment are described, res p e c t i v e l y , i n subsections 2.2 and 2.3. 2.1 The P r o v i n c i a l Mine Development Review Process The review process f o r the mining industry i n B r i t i s h Columbia has been evolving since the mid 1970's, within the framework of the broader p r o v i n c i a l review process f o r new project development. An overview of the general p r o v i n c i a l review process i s presented below, and i s followed by a de s c r i p t i o n of the evolution, structure and requirements of the Mine Development Review Process (MDRP). 2.1.1 The General P r o v i n c i a l Review Process f o r New Project Development B a s i c a l l y , the government of B r i t i s h Columbia has adopted a "staged, f l e x i b l e assessment process" f o r examining p o t e n t i a l l y s i g n i f i c a n t impacts from new projects (O'Riordan 1981). This process allows the government to appraise the impacts from a proposed project i n stages, as the project evolves from a general project d e s c r i p t i o n to an advanced engineering design. The decision-making framework f o r approving or r e j e c t i n g proposals 6 submitted f o r review i s based on provisions of the Environment and Land Use Act (1971). Under t h i s l e g i s l a t i o n , a committee of selected Cabinet members (the Environment and Land Use Committee) has been established as the decision-making body. The Environment and Land Use Committee (ELUC) i s presently comprised of the ministers of : Environment(Chairman) Ag r i c u l t u r e Industry and Small Business Development Energy, Mines, and Petroleum Resources Forests Lands, Parks and Housing Municipal A f f a i r s Transportation and Highways A second committee, the Environment and Land Use Technical Committee (ELUTC), comprised of deputy ministers from the same m i n i s t r i e s l i s t e d above, reports to ELUC on the p o l i c y implications of technical issues (O'Riordan 1981). The chairman of the ELUTC i s the Deputy Minis t e r of the Mini s t r y of Environment. In addition to the broad environmental impact review process that has been established under the Environment and Land Use Act, environment and land use concerns from proposed projects are also subject to review by i n d i v i d u a l regulatory agencies (eg. the Waste Management Branch of the Mini s t r y of the Environment) responsible f or the issuance of various approvals, permits and l i c e n s e s . The separate review by a regulatory agency i s authorized by the appropriate l e g i s l a t i o n covering that agency (eg. a c t i v i t i e s of the Waste Management Branch are authorized by the Waste Management Act, formerly the P o l l u t i o n Control Act). Generally, reviews by the regulatory agencies incorporate a r e f e r r a l process such that a p p l i c a t i o n s from development proponents are referred f o r comment to other agencies, in c l u d i n g those i n other l e v e l s of government, who might have an i n t e r e s t i n the applicant's proposed a c t i v i t i e s . The intent of the broader review process i s not simply to add a more complex process to the separate regulatory review processes, but i s to 7 provide a mechanism for conducting a comprehensive review of projects that w i l l l i k e l y have a number of possible concerns r e l a t i n g to po t e n t i a l impacts. 2.1.2 Evolution, Structure and Requirements of the Mine Development Review  Process As indicated above, the MDRP has evolved i t s own procedures within the framework of the broader p r o v i n c i a l review process. The evolution of the review procedures has also been influenced by complex i n t e r a c t i o n s amongst interested groups. These include the i n t e r e s t s of p o l i t i c i a n s and technical s t a f f at d i f f e r e n t government l e v e l s ( l o c a l , p r o v i n c i a l , and f e d e r a l ) , representatives of the mining industry, and d i f f e r e n t groups within the general public (R. Crook pers. comm.). I n i t i a l l y , coal mines were reviewed by the Coal Guidelines Review Process and metal mines were reviewed by the Metal Mines Guidelines Review Process. Review requirements were outlined i n the "Guidelines for Coal Development" (ELUC 1976), for coal mine proponents, and i n the "Procedures for obtaining Approval of Metal Mine Development" (Ministry of Energy, Mines and Petroleum Resources 1979), for metal mine proponents. In March 1984 the ELUC outlined a set of p r i n c i p l e s for consolidating the coal and metal mine review processes to form the MDRP. Based on the ELUC p r i n c i p l e s , a new combined procedures manual i s to be produced. An outl i n e of the current review process i s shown i n Figure 2-1. The review stages and report requirements and the composition and a c t i v i t i e s of the government review committees are outlined below. 2.1.2.1 Review Stages and Reports Review of a mine i s comprised of a preliminary stage, whereby the proponent can i n i t i a t e the review by providing a Letter of Intent or a Prospectus, and two or three further stages depending on project complexity. Projects must proceed to Stage I unless they are very small and straightforward (such as small p i l o t - s c a l e a c t i v i t i e s ) and would be 8 Figure 2.1 Flowchart and report requirements of the Mine Development Review Process. (Source: adapted from MacDonald 1984 ; R. Crook pers. comm.) FLOWCHART FOR REVIEW PROCESS: S(mpl« Project — F»»t Trmck P r o i p v c t u * oc L«n«* of Inltrtt R«port Project n*j«ciion AppfQVBl-kt-Prtnc lp l* C o m p i f i PTO(«CI — Ful l R*vl«w St»g« II FWpofi Of St a g * Of Approval* In-Prtnctpl* D«cleloo C o m p l w P>Oj#€t — Full Ftov»«w S t a g . II Raport PrO|«Cl Approva l -In-Principle Pub l i c H««f Ingi Pio|ac l Refact ion COMMITTEE WHICH MAT BC MVOLVED AT EACH STAGE Mln# Owttopfntnt Staffing ComnfetM wing HOSC 1 Ototndt M ELUTC' | tmptt or ELUC MOSC 1 Dtowwft H ELUTC j itmpla or auct Mint D»v«lopm*nt Steering Commm** Pub l i c Hear ing M in ing Op«rstkm» CONTENT OF SUBMISSIONS: —Prospectus: • conceptual mine project description —Stage I report: • preliminary project description • preliminary impact assessment • issue identification —Stage II report (if required due to major Impacts): • detailed project description • detailed assessment of selected impact concerns • impact management —Stage III • applications for individual licences and permits (applications can be submitted prior to Stage III, but permits will only be issued at Stage III) 9 unnecessarily impeded by the larger process (R. Crook pers. comm.). Mine projects f e l t by review committees to have complex issues must go through Stage II of the process. A l l projects must obtain relevant regulatory permits i n Stage I I I . Mine proponents must submit one or two formal reports describing the p o t e n t i a l e f f e c t s of the mine development. A preliminary assessment i s required for Stage I and, i f necessary, a more detai l e d assessment i s required for Stage I I . As shown i n Figure 2-1, a decision i s made at the end of Stage I to approve-in-principle, to r e j e c t , or to defer the a p p r o v a l - i n - p r i n c i p l e decision to the end of Stage I I . The decisions at the end of Stage I are made eit h e r by the Steering Committee (for simple, non-controversial projects) or the ELUC or ELUTC (for complex or co n t r o v e r s i a l p r o j e c t s ) . The ap p r o v a l - i n - p r i n c i p l e i s required before a project can proceed to Stage II and/or Stage I I I . 2.1.2.2 The Review Committees The 1979 "Procedures" i n d i c a t e that the previous review process consisted of a main Steering Committee, and several working committees that examined, as necessary, s p e c i f i c aspects of each mine proposal. The working committees were the Minesite Technical Committee, the Mine Housing Committee, the Environmental Impact Assessment Committee and the Economic Evaluation Committee. However, by 1983 there were only two working committees used i n pr a c t i c e : the Steering Committee and the Socio-economic Coordinating Committee (R. Crook, pers. comm.). The new combined review process i s comprised of a steering committee, the Mine Development Steering Committee (MDSC), and two working committees, the Mining and Environmental Technical Committee (METC) and the Socio -Economic Technical Committee (SETC). The working committees are b a s i c a l l y the former Minesite Technical Committee and Economic Evaluation Committee, r e s p e c t i v e l y . The METC and SETC have not been used for the l a s t two years given the r e l a t i v e l y straightforward nature of recent projects, but 10 nonetheless are a v a i l a b l e to review issues at complex projects should the need a r i s e . M i n i s t r i e s represented i n the MDSC include: Energy, Mines and Petroleum Resources (Chairman) Environment Municipal A f f a i r s Industry and Small Business Development Transportation and Highways Of the two working committees, the METC i s the more concerned with impacts on the aquatic environment. Membership i n the METC i s open to a l l M i n i s t r i e s having a mandate f or protecting biophysical resources and includes the M i n i s t r i e s of: Energy, Mines and Petroleum Resources (Chairman) Environment Lands, Parks and Housing - Parks Branch - Lands Branch Forests Agriculure and Food Transportation and Highways P r o v i n c i a l Secretary and Government Services - Heritage Conservation Branch Depending on the nature and l o c a t i o n of a project, other agencies might be consulted. A f u l l c i r c u l a t i o n of project information f o r review would include 14 p r o v i n c i a l m i n i s t r i e s , four f e d e r a l departments (Environment, F i s h e r i e s and Oceans, Indian and Northern A f f a i r s , and Energy, Mines And Resources), and a l l relevant regional and municipal governments (R. Crook pers. comm.). Since 1984, the Prospectus or Lett e r of Intent supplied by each mine proponent has used by the Steering Committee to develop s i t e - s p e c i f i c terms of reference f o r the Stage I report. The review of p o t e n t i a l e f f e c t s on f i s h e r i e s and other aquatic resources i s undertaken primarily by the Minis t r y of Environment. The Chairman of the Steering Committee might also request comments from the fede r a l Departments of the Environment and F i s h e r i e s and Oceans. Within the Minis t r y of Environment, the Prospectus i s c i r c u l a t e d by a 11 Mines Coordinator ( i n the Planning and Assessment Branch) to appropriate branch o f f i c e s . For assessment of possible impacts on aquatic resources t h i s would include the F i s h e r i e s Branch, Water Management Branch and Waste Management Branch. Using comments received from the head and regional o f f i c e s , the Mines Coordinator forwards review comments to the chairman of the Steering Committee. 2.2 Requirements of P r o v i n c i a l Regulatory Agencies After a mine has passed through Stages I and/or I I , i t must s t i l l obtain permits or l i c e n c e s from regulatory agencies i n Stage I I I . Three of these requirements (Waste Management Permits, Water Licences and Reclamation Permits) are of p a r t i c u l a r importance i n r e l a t i o n to c o n t r o l l i n g e f f e c t s on water resources. These permitting requirements are b r i e f l y described below. 2.2.1 Waste Management Permits and Approvals By means of the Waste Management Act (formerly the P o l l u t i o n Control Act), the p r o v i n c i a l Waste Management Branch (formerly the P o l l u t i o n Control Branch) approves or permits the discharge of e f f l u e n t s . To obtain a permit or approval, an applicant must supply information concerning the type, c h a r a c t e r i s t i c s , and quantity of the e f f l u e n t and other information that the Director, or a regional manager, of the Waste Management Branch might require. A d d itional information might be requested at the time a p p l i c a t i o n i s made or at the end of the review. In order to e s t a b l i s h e f f l u e n t standards f o r the industry as a whole, with respect to permit requirements, and to i d e n t i f y what p o l l u t i o n control measures should be imposed, the p r o v i n c i a l government has held two public i n q u i r i e s . The f i r s t public i n q u i r y was held by the P o l l u t i o n Control Branch i n 1972 to determine what measures should be adopted by the mining, mine-milling and smelting i n d u s t r i e s for the c o n t r o l of discharges to water, land and a i r ( P o l l u t i o n Control Branch 1973). The r e s u l t s of the inquiry were 12 used by the Branch to develop a set of minimum objectives for e f f l u e n t discharge by the industry. The second inquiry was held i n 1978, to review the objectives presented i n 1973, with respect both to experience gained i n the a p p l i c a t i o n of the e a r l i e r objectives and to t e c h n i c a l and environmental information that had evolved over the intervening period. The r e s u l t s of t h i s inquiry were published by the P o l l u t i o n Control Board as a new document, the " P o l l u t i o n Control Objectives for the Mining, Smelting and Related Industries of B r i t i s h Columbia 1979". The 1979 "Objectives" i n d i c a t e that pre-operational studies and long-term monitoring programs might be required p r i o r to issuance of permits: " P r i o r to commencement of new discharges or changes to e x i s t i n g discharges, studies may be required to include a comprehensive examination of s i t e s u i t a b i l i t y , baseline documentation of physical and chemical parameters, a b i o l o g i c a l resource inventory and d e t a i l e d impact p r e d i c t i o n s . Long-term monitoring of parameters s p e c i f i e d i n discharge permits ( l e g a l standards) may be required. R e s p o n s i b i l i t y for compliance and for provision of data supporting compliance r e s t s with the permit holder" 2.2.2 Water Licences and Approvals Water licenc e s are issued by the Comptroller of Water Rights, subject to the terms and regulations of the Water Act. The l i c e n c e s are issued to, amongst others, "an owner of land or a mine". Approvals, without issuance of a l i c e n c e , can be made by the Comptroller for the short-term ( l e s s than 6 months) diversion or use of water. Applications for a water l i c e n c e must contain information on the quantity and purposes of waters to be used and a d e s c r i p t i o n of the land, mine or premises where the water i s to be used. 2.2.3 Reclamation Permits The Mines Act 1980 (formerly the Mines Regulation Act) states that "a program for the protection and reclamation of the surface of the land and watercourses affected by the mine i n a form and containing the information 13 the minister may require before commencing preparatory work for production from a mine" must be f i l e d with the Mini s t r y of Energy Mines and Petroleum Resources. The reclamation permit i s p a r t i c u l a r l y important for regulating non-point sources of p o l l u t i o n , such as general s i t e runoff. 2.3 Requirements of Federal Agencies Although the B r i t i s h North America Act 1967 has placed the ownership of land, including overlying water, i n the r i g h t of the provinces, the Parliament of Canada has l e g i s l a t i v e authority over sea coasts and inland f i s h e r i e s . For the boundary of p r o v i n c i a l - f e d e r a l ownership i n coastal areas, the p r o v i n c i a l crown land extends to the low water mark and federal land extends beyond the low water mark to the seaward t e r r i t o r i a l l i m i t . In B r i t i s h Columbia, the r e s p o n s i b i l i t y f o r protecting f i s h and f i s h habitat i s shared with the p r o v i n c i a l government. The p r o v i n c i a l government i s responsible for the freshwater species (and anadromous trout) and the fede r a l government i s responsible f or the marine and most anadromous species. Therefore, the fed e r a l government has a d i r e c t i n t e r e s t i n the e f f e c t s of waste discharge on both the marine and freshwater environments, p a r t i c u l a r l y i n r e l a t i o n to the manner i n which the waste discharge might a f f e c t the management and protection of f i s h and f i s h habitat. Federal l e g i s l a t i o n concerned with the e f f e c t s of waste discharge on the water environment i n B.C. include, p r i n c i p a l l y , the Canada Water Act, the F i s h e r i e s Act and the Ocean Dumping Control Act. Because the fed e r a l government has a d i r e c t i n t e r e s t i n the p o t e n t i a l impacts of mine development on aquatic resources, f e d e r a l environmental and f i s h e r i e s agencies,such as the Environmental Protection Service (Department of the Environment) and Department of F i s h e r i e s and Oceans, are included i n p r o v i n c i a l permitting procedures, by r e f e r r a l , or, i n the case of Ocean Dumping Permits, can become key review agencies. In the event that a p a r t i c u l a r development a c t i v i t y , including mine development, produces a 14 pollutant i n s u f f i c i e n t quantity to cause serious harm to f i s h or f i s h habitat, the fede r a l F i s h e r i e s Act contains provisions by which l e g a l action can be taken and f i n e s l e v i e d . Just as the Waste Management Branch of the p r o v i n c i a l government has developed e f f l u e n t standards or objectives, f o r discharges from the mining industry, the federal government has also developed standards or objectives. In 1977, the federal Environmental Protection Service (Department of the Environment) published a document e n t i t l e d "Metal Mining Liq u i d E f f l u e n t Regulations and Guidelines". In f a c t , the p u b l i c a t i o n i s a small compendium of extracts from the Canada gazette, augmented with a d d i t i o n a l explanatory notes and a Code of Practice f o r Mines. The extracts from the Canada Gazette are: - Metal Mining Liquid E f f l u e n t Regulations - Guidelines f o r the Control of Liqu i d E f f l u e n t s from E x i s t i n g Metal Mines - Guidelines for the Measurement of Acute L e t h a l i t y i n Liqu i d - E f f l u e n t s from Metal Mines In some cases, such as the marine disposal of t a i l i n g s , the regulations might not be applied. Based on recommendations by the Minister of Environment and Minister of F i s h e r i e s , an Order-in-Council was approved i n 1979 allowing Amax of Canada Ltd. to deposit t a i l i n g s d i r e c t l y i n t o marine waters. A p r o v i n c i a l P o l l u t i o n Control Permit was subsequently issued. 2.4 Summary The government of B r i t i s h Columbia has adopted a staged process for reviewing metal mine developments. E f f e c t s on aquatic resources are assessed i n reports submitted by mine proponents and reviewed by government committees. A preliminary assessment i s required during Stage I and a de t a i l e d assessment i s required i f a mine must enter Stage I I . The Stage I and/or Stage II studies are used by regulatory agencies as the basis for iss u i n g permits and licence s at Stage I I I . 15 CHAPTER 3.0 THE THEORETICAL CONCEPTS AND METHODS AVAILABLE FOR  IMPACT ASSESSMENT This chapter provides a review of the concepts and methods that are a v a i l a b l e f or undertaking pre-development impact assessments. The review i s used as the basis f or developing c r i t e r i a used i n Chapter 5.0 to evaluate a n a l y t i c a l weaknesses i n pre-development impact statements submitted by mine proponents. A review of the a n a l y t i c a l concepts and methods described i n the Environmental Impact Assessment (EIA) l i t e r a t u r e i s presented i n section 3.1. The a n a l y t i c a l features that could be included i n pre-development studies undertaken by mine proponents, within the context of government submission requirements (described i n Chapter 2.0), are outlined i n section 3.2. 3.1 A n a l y t i c a l Concepts and Methods described i n the EIA L i t e r a t u r e In 1969, the United States government passed the National Environmental P o l i c y Act (NEPA), which requires a l l f e d e r a l agencies to assess the environmental impacts of proposed projects. Following the lead of the United States government, other governments, including the fe d e r a l and most of the p r o v i n c i a l governments of Canada, have i n s t i t u t e d s i m i l a r requirements. Consequently, since 1969, a large number of s t r a t e g i e s and methods on how environmental impacts should be assessed have been put forward. The concept of EIA, the weaknesses i n the t r a d i t i o n a l approaches, and the current theories f or improving EIA studies are described below. 3.1.1 The Concept of EIA EIA has been broadly defined as "an a c t i v i t y designed to i d e n t i f y and predict the impact on the biogeophysical environment and on man's health and well-being of l e g i s l a t i v e proposals, p o l i c i e s , programmes, projects and operational procedures, and to i n t e r p r e t and communicate information about 16 the impacts" (Munn 1979). In addition, Munn states that the environmental and re l a t e d s o c i a l aspects of new proposals should be considered early i n the formulation of new proposals and should be included throughout the e n t i r e planning process. This means that to be an e f f e c t i v e component of project planning, EIA must be integrated with engineering and economic assessments, not simply added once the other assessments have been completed. Warner and Preston (1974) state that an EIA must deal with four problem areas: Impact i d e n t i f i c a t i o n Impact measurement Impact i n t e r p r e t a t i o n Impact communication to information users To address these problem areas, Lang and Armour (1977) suggest that an EIA should contain, as a minimum, the following seven components: 1. Project Description 2. Environmental Inventory 3. Environmental E f f e c t s 4. Evaluation of E f f e c t s 5. M i t i g a t i n g Actions 6. A l t e r n a t i v e s 7. Presentation Note that Lang and Armour and other authors (Munn 1979; Dooley 1979) d i s t i n g u i s h between environmental " e f f e c t " and environmental "impact". Environmental e f f e c t i s defined as a man-induced environmental change and environmental impact i s defined as a change i n environmental q u a l i t y , with usage of word "impact" implying that a value judgment has been made on the importance of an environmental e f f e c t or change to people (Munn 1979). 3.1.2 Weaknesses i n the T r a d i t i o n a l Approaches to EIA The q u a l i t y of EIA studies has been r e g u l a r l y c r i t i c i z e d since the s t a r t of the formal EIA review processes. In reference to the general approach used f o r EIA i n Canada, Beanlands and Duinker (1983) state that "the s o - c a l l e d 'shotgun' approach has prevailed, with comprehensive but 17 s u p e r f i c i a l coverage of a l l elements of the environment, regardless of t h e i r relevance to project decisions". Based on a review of more than 30 EIA's from across Canada, Beanlands and Duinker concluded that "predictions were commonly vague, of questionable value both f o r decision-making and for studies to t e s t them". The c r i t i c i s m that EIA reports are excessively lengthy and f i l l e d with i r r e l e v a n t d e t a i l has also been made by other authors (Schindler 1976; Caldwell 1978; Ward 1978; Cole 1979). Rosenberg et a l . (1981) also conducted a d e t a i l e d review of recent EIA studies. In conclusion, they l i s t e d what they f e l t to be the main weaknesses of EIA based on a review of more than 40 documents f o r EIA's conducted around the world (note that a l l but two involve l o c a t i o n s i n North America). These are: "tokenism"; u n r e a l i s t i c time constraints; uncertainty of program or development schedules; d i f f i c u l t access to EIA l i t e r a t u r e ; questionable e t h i c s ; lack of coordination amongst studies; poor research design. 3.1.3 Current Theories for an Improved Approach to EIA The EIA l i t e r a t u r e stresses the need f o r the following features to improve the q u a l i t y of analyses: - the early conceptualization of i n t e r a c t i o n between a project and the environment; - the i d e n t i f i c a t i o n of important resources at r i s k ; - the a p p l i c a t i o n of s c i e n t i f i c and e c o l o g i c a l p r i n c i p l e s ; - the development of c l e a r c r i t e r i a f o r i n t e r p r e t i n g impact s i g n i f i c a n c e ; and, - the recognition that impact assessment i s an on-going and adaptive process. These concepts are b r i e f l y dicussed below. 3.1.3.1 The Early Conceptualization of Interaction Between a_ Proposed Project and the Environment. Preparation of a conceptual framework that shows how the components of a proposed project are expected to i n t e r a c t with components of the surrounding environment has been recommended as an early step i n the design of EIA studies ( H o l l i n g 1978; Munn 1979; Beanlands and Duinker 1983). The 18 exercise can be made simple or complex, depending on the amount of information a v a i l a b l e and on the wishes of the assessor. Regardless of the degree of complexity, at l e a s t some information w i l l be required with respect to both the proposed project and the environment. Beanlands and Duinker (1983) f e e l the early use of such a conceptual framework would have the following advantages for the design of ensuing studies: "a) a separation of the project i n t o manageable parts; b) a focus on the nature and the source of the perturbation; c) the early establishment of time and space boundaries; d) a recognition of the valued ecosystem components within the assessments; e) l o g i c a l progression from physical-chemical components to b i o t i c components; f ) the consideration of f u n c t i o n a l r e l a t i o n s h i p s wherever possible;and g) a recognizable format within which to present the study r e s u l t s . " When s u f f i c i e n t information i s a v a i l a b l e , the conceptual models that are produced can be refin e d so that selected impact scenarios can be analyzed by use of computer simulations ( H o l l i n g 1978; Munn 1979). 3.1.3.2 I d e n t i f i c a t i o n of Important Resources at Risk A given environment consists of a large number of species or components that could be studied, but only a small number of species or components are l i k e l y to be considered of d i r e c t value to society. Dooley (1979) suggests that the extensiveness or scope of assessments w i l l be s p e c i f i e d by regulation or review process, and that the concerns and a t t i t u d e s of s p e c i a l i n t e r e s t groups and the general public might be useful for the eventual i d e n t i f i c a t i o n and i n t e r p r e t a t i o n of impacts. The i d e n t i f i c a t i o n (or " s o c i a l scoping") of s o c i a l l y important components of the environment i s f e l t to be a necessary step early i n the assessment process i n order to focus study e f f o r t (Beanlands and Duinker 1983). Simply stated, information on environmental components that are f e l t to have the greatest s o c i a l value, and whose loss or impairment are of greatest concern to society, w i l l have 19 greater relevance for the decision maker and public-at-large that information on other components (Munn 1979; Beanlands and Duinker 1983). In the United States, "scoping" has become a formal requirement of the NEPA "Regulations for Implementing the Procedural Provisions" (Council on Environmental Quality 1979). Beanlands and Duinker (1983) d i s t i n g u i s h between " s o c i a l " scoping and " e c o l o g i c a l " scoping. Whereas s o c i a l scoping, described above, i d e n t i f i e s those environmental components that are s o c i a l l y valuable and should receive intensive study, e c o l o g i c a l scoping i n d i c a t e s how the components might be best studied. 3.1.3.3 Application of S c i e n t i f i c and E c o l o g i c a l P r i n c i p l e s A major c r i t i c i s m that has been made about the t r a d i t i o n a l approach to EIA i s the poor s c i e n t i f i c q u a l i t y of EIA studies and general absence of a s c i e n t i f i c framework by which to conduct EIA research. In order.to improve the s c i e n t i f i c q u a l i t y and p r e d i c t i v e c a p a b i l i t y of impact assessments, the present approach whereby subjective judgment i s applied to large amounts of d e s c r i p t i v e f i e l d data must be replaced by an approach that uses e x p l i c i t hypotheses to put forward quan t i t a t i v e , testable predictions ( Ward 1978; Beanlands and Duinker 1983). However, H o l l i n g (1978) cautions that a good s c i e n t i f i c study does not necessarily contribute to better decision-making i f the proper variables or processes are not measured. This means that although s c i e n t i f i c p r i n c i p l e s ought to be applied, the research necessary for impact assessment must also r e f l e c t p o l i c y concerns (e.g. the s e l e c t i o n of environmental components of value to society, as discussed above). Also, one might argue that, i n some cases rigorous s c i e n t i f i c methods are not appropriate, because they w i l l impose unnecessary cost and time burdens, for example, on small projects i n environmentally i n s e n s i t i v e areas. In these cases, the professional judgment of one or more s p e c i a l i s t s might s u f f i c e as a means of p r e d i c t i n g the l i k e l y impact. 20 A d i f f i c u l t y with any impact p r e d i c t i o n i s the type and degree of uncertainty which l i m i t s i t s accuracy. Munn (1979) describes four kinds of uncertainty that are generally encountered i n EIA: " l ) t h e natural v a r i a b i l i t y of the environment, p a r t i c u l a r l y the occurrence of rare events such as floods and earthquakes; 2) inadequate understanding of the behaviour of the environment; 3) inadequate data for the region or country being assessed; 4) socio-economic uncertainties (inadequate understanding and inadequate data)" Some of the uncertainty can be removed by f i e l d data c o l l e c t i o n , some can be removed by studies to define the " v a r i a b i l i t y " of the system under study, and some can be removed by studies to i d e n t i f y s t r u c t u r a l and fun c t i o n a l r e l a t i o n s h i p s , but uncertainty cannot be eliminated (Ward 1978; H o l l i n g 1978). Although the uncertainty surrounding predictions can be reduced through the use of hypothesis-testing experiments (Ward 1978), H o l l i n g (1978) suggests that the continued presence of uncertainty should be acknowledged and that the environmental impact assessments should a n t i c i p a t e that unexpected events are i n e v i t a b l e . H o l l i n g (1978) outlines four properties of e c o l o g i c a l systems that influence how impacts on the systems should be assessed and how the kinds of uncertainty outlined i n the preceding subsection might be t r a c t a b l e : "-The parts of an e c o l o g i c a l system are connected to each other i n a s e l e c t i v e way that has implications f or what should be measured. -Events are not uniform over space, which has implications for how intense impacts w i l l be and where they w i l l occur -Sharp s h i f t s i n behaviour are natural f o r many ecosystems. T r a d i t i o n a l methods of assessment can misinterpret these and make them seem unexpected or perverse. - V a r i a b i l i t y , not constancy, i s a feature of e c o l o g i c a l systems that contributes to t h e i r persistence and to t h e i r self-monitoring and s e l f - c o r r e c t i n g c a p a c i t i e s . " 3.1.3.4 The Development of Clear C r i t e r i a f o r Interpreting Impact  Sig n i f i c a n c e Eventually, the predicted changes i n valued ecosystem components caused by a proposed project must be interpreted i n terms of t h e i r s i g n i f i c a n c e or importance. Unambiguous d e f i n i t i o n of the c r i t e r i a to be used f o r 21 determining s i g n i f i c a n c e provides both a focus f o r the operational needs of the EIA study and reduces the l i k e l i h o o d of misunderstanding when impact i n t e r p r e t a t i o n i s presented to the decision-maker and the public (Beanlands and Duinker 1983). General and undefined usage of the term " s i g n i f i c a n c e " can have d i f f e r e n t meaning depending on the background of the audience. 3.1.3.5 The Recognition that Impact Assessment i s an On-going and  Adaptive Process EIA should not be regarded as complete once the formal pre-operation project review has been completed ( H o l l i n g 1978; Munn 1979; Beanlands and Duinker 1983). Although t h i s concept i s rather straightforward, implementation of a s a t i s f a c t o r y monitoring program w i l l depend on the adequacy of pre-operational studies. S p e c i f i c a l l y , the e a r l i e r studies must define the natural v a r i a b i l i t y i n environmental features of concern so that data gathered during the monitoring studies w i l l i n d i c a t e , f i r s t l y , that a change has occurred and, secondly, that the change was induced by the project (Gore et a l . 1979; Skalski and MacKenzie 1982). H o l l i n g (1978) indicates the project proponents should expect the unexpected and should design t h e i r projects so that features can be changed i f problems are evident during the monitoring and on-going assessment program. Therefore, the proponents should a n t i c i p a t e that not only w i l l EIA continue i n t o the operating phase of the project but also that changes i n project design w i l l l i k e l y be required. 3.2 A n a l y t i c a l Features that Could be Included i n Pre-development Studies  Undertaken by Mine Proponents. The a n a l y t i c a l features one might expect i n the Stage I and Stage II reports (described i n Chapter 2.0) prepared by metal mine proponents are summarized i n t h i s section. The basic a n a l y t i c a l steps that could be followed throughout the EIA are l i s t e d i n Figure 3-1. In terms of the ex i s t i n g three-stage metal mine review process, a Stage I report might be 22 Figure 3.1 The basic EIA steps that could be followed by metal mine proponents. I n i t i a l A c t i v i t i e s The mine proponent makes an i n i t i a l determination of the extent and value of the orebody through f i e l d exploration and economic a n a l y s i s , then decides to seek approval for development. STEP 1_ Development of a Preliminary Conceptual Understanding of Interaction Between The Mine and the Surrounding Environment. STEP 2 I d e n t i f i c a t i o n of Important Environmental Resources. STEP 3 I d e n t i f i c a t i o n of Sources of E f f e c t . STEP h_ Development of Preliminary Measures to Protect Important Resources STEP 5_ Development of S c i e n t i f i c Objectives and Implementation of Research Studies, and Assessments of Risk. STEP 6_ Refinement of Predictions of E f f e c t and M i t i g a t i v e Measures (If Necessary) STEP 1_ Implementation of an On-going Assessment Program 23 expected to contain the Steps 1 through 4, though Step 1 would be more appropriate as a preliminary a c t i v i t y p r i o r to commencing Stage I studies. Step 5, to some extent, would be required to define baseline conditions that could be examined during Step 7, whether or not a mine had to proceed to Stage I I . A Stage II study, i f necessary, would be a more thorough undertaking of Step 5 and, i n addition, Step 6. Step 7 corresponds to Stage I I I and would apply to both Stage I and Stage II mines. Re f l e c t i n g the step-by-step sequence described for the " t h e o r e t i c a l " EIA model, the derived c r i t e r i a are l i s t e d below under the appropriate heading for each step. STEP 1: Development of a_ Preliminary Conceptual Understanding of Interaction Between the Mine and the Surrounding Environment 1. A conceptual understanding of mine-environment i n t e r a c t i o n i s presented i n the EIA report as a basis for the EIA study strategy and objectives. 2. The conceptual model i s used to i d e n t i f y the general a c t i v i t i e s associated with each phase of mine development that might have an e f f e c t on the aquatic environment. 3. The conceptual model provides a general i n d i c a t i o n of the basic e c o l o g i c a l structure of the aquatic environment near the minesite and what e c o l o g i c a l features might be affected by the mine. 4. The conceptual model i s used as a basis for i n i t i a l discussion with the Metal Mines Steering Committee, regarding environmental f a c t o r s to be considered, the types of a l t e r n a t i v e s , l o c a t i o n s and design features that should be considered and the o v e r a l l study strategy for the EIA. 5. The conceptual model i s used to i n d i c a t e to engineering design personnel the general types of mine features for which a l t e r n a t i v e s should be examined. STEP 2: I d e n t i f i c a t i o n of Important Environmental Resources 1. STEP 2a: Background preparation a) The background preparation of the EIA study i s based on a general strategy and objectives outlined i n the early stages of the study (whether or not a conceptual model i s presented). 24 b) The background preparation includes: i . a review of environmental l i t e r a t u r e f o r the study area, i i . a review of environmental information obtained through discussion with government resource agencies, i i i . a f i e l d reconnaisance to i d e n t i f y the l o c a t i o n of important resources. 2. STEP 2b: Establishment of study l i m i t s a) Geographical l i m i t s of the study area The l i m i t s of the study area are c l e a r l y indicated i n the report and include d e f i n i t i o n of: the project boundaries ( i n c l u d i n g a l t e r n a t i v e l o c a t i o n s f or some mine-related a c t i v i t i e s such as h y d r o e l e c t r i c r e s e r v o i r s and transmission l i n e s , waste rock disposal s i t e s , e t c . ) ; j u r i s d i c t i o n a l boundaries, i f appropriate; e c o l o g i c a l boundaries; and t e c h n i c a l boundaries f o r EIA a n a l y s i s . b) "Scoping" of environmental f a c t o r s to be_ considered i . The method f o r choosing the valued ecosystem components, for which s p e c i f i c e f f e c t s are to be predicted and impacts interpreted, i s c l e a r l y outlined, i i . For each valued ecosystem component i d e n t i f i e d , the c r i t i c a l times and l o c a t i o n s of important a c t i v i t i e s are s p e c i f i e d . i i i . S i m i l a r l y , the environmental i n d i c a t o r s chosen f o r study i n order to draw conclusions about impacts on valued ecosystem components are c l e a r l y explained, i v . Government agency personnel or members of the public have ass i s t e d i n the "scoping" of environmental components to be studied, or reasons are given to i n d i c a t e why they were not included. 3. STEP 2c: F i e l d studies Based on the weaknesses i d e n t i f i e d i n a v a i l a b l e information, f i e l d studies are conducted to determine the c r i t i c a l l o c a t i o n s and timings of important resource features. STEP 3: I d e n t i f i c a t i o n of Sources of E f f e c t 1. Where information obtained from the background review permits, s t r u c t u r a l and f u n c t i o n a l r e l a t i o n s h i p s are shown i n the conceptual model (both for components of the environment and for mine-environment i n t e r a c t i o n ) . 2. I d e n t i f i c a t i o n of sources and types of impact i s based on methods that: a) are comprehensive, providing a systematic assessment of each mine a c t i v i t y b) consider both d i r e c t and i n d i r e c t e f f e c t s c) consider both short term e f f e c t s and long term e f f e c t s d) consider a l l phases of mining a c t i v i t y (eg. exploration, development, closure) 3. E x p l i c i t c r i t e r i a are developed f o r determining the s i g n i f i c a n c e or importance of predictions that w i l l be made concerning the e f f e c t s of mine development on the important resource features. 25 STEP 4: Development of Preliminary Measures to Protect Important  Resources 1. P r e l i m i n a r l y predictions of e f f e c t s and i n t e r p r e t a t i o n s of impacts a) For each source and type of possible impact that has been i d e n t i f i e d (STEP 3), e i t h e r a p r e d i c t i o n i s put forward or reasons why a p r e d i c t i o n cannot be made i s stated. b) The predictions of e f f e c t i n d i c a t e : i . magnitude i i . p e r i o d i c i t y and duration i i i . geographic extent i v . l i k e l i h o o d of occurrence c) The u n c e r t a i n t i e s r e l a t e d to the predictions of e f f e c t are c l e a r l y stated. d) Where general terms such as small, medium etc. are used to describe e f f e c t s , they are defined. e) Cumulative e f f e c t s are predicted. f ) Predictions d i s t i n g u i s h between expected environmental conditions "with" the project and "without" the project. g) Predictions consider the possible recovery of environmental features once the source of disturbance i s removed. h) The s i g n i f i c a n c e c r i t e r i a developed e a r l i e r are c o n s i s t e n t l y applied to the predicted e f f e c t s f o r i n t e r p r e t i n g impact. i ) The groups i n society that w i l l be a f f e c t e d by the impacts caused by the mine are i d e n t i f i e d . 2. Development of impact management st r a t e g i e s The preliminary impact assessment studies are used to: a) develop preliminary m i t i g a t i v e measures b) o u t l i n e the expected e f f e c t s a f t e r m i t i g a t i o n c) recommend that further studies be conducted to better i d e n t i f y the l o c a t i o n and amount of resources at r i s k d) recommend that further studies be conducted to resolve u n c e r t a i n t i e s about the cause-effect r e l a t i o n s h i p between selected mining a c t i v i t i e s and environmental features e) develop a monitoring and follow-up assessment strategy f ) develop contingency plans to deal with unexpected emergencies g) develop an adaptive or f a l l - b a c k strategy i n case the monitoring and follow-up studies (Step 6) show that the m i t i g a t i v e measures chosen i n i t i a l l y are not working h) draw conclusions about the o v e r a l l environmental a c c e p t a b i l i t y of the mining project. STEP 5: Development of S c i e n t i f i c Objectives and Implementation of Experimental Research Studies, and Assessments of Risk 1. E x p l i c i t s c i e n t i f i c objectives are stated so that the r e s u l t s of baseline and experimental research w i l l y i e l d q uantitative r e s u l t s , that can be tested during studies a f t e r mine production begins. 2. Studies are conducted (where necessary) to i d e n t i f y f u n c t i o n a l 26 r e l a t i o n s h i p s between environmental components and/or the cause-effect r e l a t i o n s h i p s between the proposed mine and selected environmental components. 3. Where sources of serious p o t e n t i a l damage to an environmental component or components has been i d e n t i f i e d , studies are conducted to assess the r i s k or p r o b a b i l i t y of occurrence. 4. Where s c i e n t i f i c objectives are put forward, the methods used to achieve each objective are described ( i e . laboratory studies, f i e l d " i n - s i t u " studies, desk an a l y s i s (eg. systems simulation modelling) and the l i m i t a t i o n s f o r i n t e r p r e t i n g the r e s u l t s c l e a r l y i d e n t i f i e d . STEP 6: Refinement of Pred i c t i o n s of E f f e c t and M i t i g a t i v e Measures  ( I f Necessary) 1. Based on the r e s u l t s of a d d i t i o n a l s c i e n t i f i c studies ( i f necessary), predictions of e f f e c t are stated i n quantitative terms that can be examined f o r correctness once the mine begins operations. 2. Predictions are put forward f o r a l l a l t e r n a t i v e mine-design and mi t i g a t i v e features that are f i n a n c i a l l y and t e c h n i c a l l y p r a c t i c a b l e , and the preferred features ( f o r environmental protection) i d e n t i f i e d . 3. Outstanding unc e r t a i n t i e s are c l e a r l y i d e n t i f i e d . 4. Reasons why the outstanding u n c e r t a i n t i e s are not considered important are stated, or recommendations to elucidate the unc e r t a i n t i e s by further study are given. 5. The r i s k associated with each p r e d i c t i o n i s i d e n t i f i e d i n terms of p r o b a b i l i t y of occurrence, or reasons why q u a n t i f i c a t i o n i s not necessary i s given. 6. The assumption and procedures of a d d i t i o n a l methods of impact a n a l y s i s are c l e a r l y stated. 7. Predictions that are based on professional judgement are c l e a r l y separated from qu a n t i t a t i v e p r e d i c t i o n s . 8. The s i g n i f i c a n c e or importance of predicted e f f e c t s are i d e n t i f i e d using consistent a p p l i c a t i o n of the defined c r i t e r i a (STEP 3). 9. Based on the predictions of e f f e c t and chosen mine design and mi t i g a t i v e measures, a contingency plan and on-going assessment program are put forward. 10. The report i n d i c a t e s what f l e x i b i l i t y , i n terms of mine operating features or mi t i g a t i v e measures, e x i s t s to allow adaptation to a range of possible f i n d i n g s by the on-going assessment program. STEP 7: Implementation of an On-going Assessment Program 27 After the mine begins operation, the e f f e c t s are assessed on an on-going basis and, where e f f e c t s become apparent, alternate operating p r a c t i c e s or m i t i g a t i v e measures developed i n Steps 3 to 6 are implemented. / 28 CHAPTER 4.0 THE EFFECTIVENESS OF PRE-DEVELOPMENT IMPACT ASSESSMENTS The purpose of t h i s chapter i s , f i r s t l y , to examine aquatic resource impact management problems at metal mines for which impact assessment reports were submitted to the p r o v i n c i a l government, and, secondly, to evaluate the effectiveness of the reports f o r a n t i c i p a t i n g the eventual problems. The l i t e r a t u r e describing the e f f e c t s that metal mines can have on aquatic resources was reviewed, to provide background on the general sources and types of problem that can occur. The review i s summarized i n Appendix I. 4.1. Study Methods 4.1.1 Analysis of Recent Aquatic Resource Impact Management Problems. F i f t e e n mines were selected using the following c r i t e r i a : i . the mine proponent submitted a formal Stage I or Stage I I report to the MDRP for review; and, i i . the mine began production a f t e r submitting the Stage I or Stage II reports. The mines were i d e n t i f i e d i n p e r i o d i c l i s t s that are produced by the B.C. M i n i s t r y of Energy, Mines and Petroleum Resources and summarize the status of mines that have entered the Mines Development Review Process (eg. Crook 1984). The mines selected, the year that reports were submitted, the year i n which each mine began operation, and the current (March 1986) operating status of each mine are shown i n Table 4-1. One mine (Equity S i l v e r ) submitted pre-development reports to the p r o v i n c i a l i n 1976, three years before the formal process for reviewing metal mine development was i n place. The authors of the Equity S i l v e r reports used the 1976 "Guidelines for Coal Development" for guidance. The reports for most of the other mines were submitted s h o r t l y a f t e r issuance of the 1979 "Procedures f o r obtaining approval of metal mine development" (Ministry 29 Table 4.1 Mines for which impact management problems were examined. Mine Type Mine Name Reports Submitted Year Prod- Status Type Year uction (March 1986) Began STAGE I Stage II Baker Stage I 1980 1980 closed Banbury Stage I 1982 1983 non-operational, Stage I Addendum 1982 but not closed B r u s s i l o f Stage I 1980 1981 operational Free Gold Stage I 1981 1981 non-operational HB M i l l Stage I 1982 1982 non-operational Ladner Creek Stage I 1979 1982 non-operational Stage I Addendum 1979 Silence Lake Stage I 19 81 1982 closed Skomac Stage I 1980 1981 closed Summit Lake Stage I 1980 1981 closed Table Mtn. Stage I 1980 1980 closed Taurus Stage I 1980 1981 closed Venus Stage I 1980 1981 closed Vollaug Stage I 1980 1981 closed Stage I Supplement 1980 Equity S i l v e r Stage Stage I II 19 76 1976 1980 operational Goldstream Stage I 1979 1983 not operating Stage II Supplement 1979 30 of Energy, Mines and Petroleum Resources 1979). General descriptions and operating status of each mine are summarized i n Appendix I I . For each mine selected for review, the type and severity of impacts and problems associated with f a c i l i t i e s or st r a t e g i e s to c o n t r o l the impacts were discussed with representatives of: i . the mine company; i i . the fe d e r a l Environmental Protection Service and/or i i i . the p r o v i n c i a l Waste Management Branch; and, i v . the federal Department of J u s t i c e . A d d i tional information was obtained from reports prepared by government agencies or by consultants on behalf of mine proponents. Problems were then analyzed i n terms of the sources of problems, the e f f e c t s on the aquatic environment, and the l e g a l and f i n a n c i a l consequences to mine operators. 4.1.2 Review of Pre-development (Stage I/Stage II) Impact Assessments The Stage I/Stage II reports prepared for each mine that encountered an environmental problem were reviewed to determine: i . i f the source or cause of the problem had been i d e n t i f i e d ; and, i f so, i i . i f the p o t e n t i a l e f f e c t s of the problem on the aquatic environment were described; i i i . what miti g a t i v e measures had been proposed to manage the possible consequences of those problems i d e n t i f i e d ; and, i v . what conclusions were drawn concerning the expected impacts of the problem, whether or not mit i g a t i v e measures were to be implemented. 4.2 Results The impact management problems that have occurred at each of the 15 mines are described i n subsection 4.2.1, and the number and types of problem anticipated i n the pre-development reports are described i n subsection 4.2.2. 31 4.2.1 Impact Management Problems at 15 Mines Impact management problems were reported f or eight of the t h i r t e e n Stage I mines and both of the Stage II mines. The problems i d e n t i f i e d at each mine are presented i n Appendix I I I , and are summarized separately below fo r Stage I mines (subsection 4.2.1.1) and Stage II mines (subsection 4.2.1.2). To a s s i s t the a n a l y s i s , problems are categorized according to the general types of mining a c t i v i t y discussed i n Appendix I: On-going Exploration; Mine Development and Operation; M i l l Construction and Operation; and, Other A c t i v i t i e s . 4.2.1.1 Stage I Mines Nineteen problems were reported. Seventeen problems are incidents that occurred during the development or operation of the mine and/or m i l l , and two were requests by regulatory agencies f or construction of a d d i t i o n a l treatment ponds p r i o r to operation (Table Mountain and Venus). The l a t t e r were precautionary measures and are not addressed fu r t h e r . The sources of problems, the e f f e c t s on the aquatic environment, and the l e g a l and f i n a n c i a l consequences to mine operators are summarized below, a) The Sources of Problems The source or cause of each problem i s l i s t e d i n Table 4-2. Most problems (approximately 60%) were i n r e l a t i o n to M i l l Construction and Operation A c t i v i t i e s . No problems occurred i n r e l a t i o n to On-going Exploration A c t i v i t i e s . The types of problem are categorized and the number of mines i n each category are shown i n Table 4-3. These data i n d i c a t e that problems r e l a t i n g to the treatment or containment of t a i l i n g s and process waste-water have been the most common. In f a c t these problems have occurred at l e a s t once at a l l mines or m i l l s that reported a problem. In p a r t i c u l a r , d i f f i c u l t i e s have r e l a t e d to the permitted discharge of cyanide and associated metals, breaks i n t a i l i n g s l i n e s , and the construction and 32 Table 4.2 The source or cause of problems at Stage I mines. Category of Mining A c t i v i t y  Mine Name Mine Development M i l l Construction Other A c t i v i t i e s and Operation and Operation Baker 1. mine drainage 1. discharge from 1. f u e l s p i l l water t a i l i n g s pond at a i r f i e l d 2. break i n t a i l i n g s 2. sewage d i s -l i n e charge Free Gold — 1. leakage from -t a i l i n g s pond HB M i l l 1 - 1. break i n t a i l i n g s — l i n e Ladner Creek 1. general develop- 1. e f f l u e n t discharge -ment a c t i v i t y ^ 2. drainage water in 2. mine water s e t t l i n g m i l l building ponds 3. t a i l i n g pond 3. uncontrolled storage runoff during 4. t a i l i n g s dam operation reconstruction Silence Lake 1. roc k s l i d e at 1. overflow of -mine rock t a i l i n g s berm stockpile Summit Lake - 1. mill-process -discharge Number of Problems : 5 10 2 1 Note that no mining a c t i v i t y occurred at t h i s operation. Changes i n downstream water q u a l i t y and b i o t a were at t r i b u t e d j o i n t l y to mine-water s e t t l i n g ponds and to general s i t e development and construction. Changes were again a t t r i b u t e d to the mine-water s e t t l i n g ponds once production began. 33 Table 4.3 The number of Stage I mines having each type of problem. Category of Mining Type of Problem Number of Mines A c t i v i t y having 1 Problem Mine development and 1. rock/land s l i d e at ore 1 operation stockpile 2. drainage water from mine 1 3. general development a c t i v i t y 1 4. mine-water s e t t l i n g ponds 1 5. uncontrolled runoff during operation 1 M i l l construction and 1. t a i l i n g s / m i l l e f f l u e n t discharge 3 operation 2. drainage from m i l l b u i l d i n g 1 3. breaks i n t a i l i n g s l i n e s 2 4. unexpected overflow or leakage of t a i l i n g s ponds 2 5. t a i l i n g s dam construction 1 6. t a i l i n g s pond storage 1 Other A c t i v i t i e s 1. f u e l s p i l l near a i r s t r i p 1 2. water q u a l i t y and b i o t i c changes from sewage discharge 1 34 overflow or leakage of t a i l i n g s ponds. b) E f f e c t s on the Aquatic Environment Four of the 17 problems (27%) caused no evident change to the aquatic environment. These are: -the f u e l s p i l l at the a i r f i e l d near Baker -the small leakage of the t a i l i n g s pond at Free Gold -the small overflow of the t a i l i n g s berm at Silence Lake -the t a i l i n g s pond storage at Ladner Creek (high runoff to the pond required a shutdown of the m i l l to prevent overflow) In the f i r s t three cases, contaminants were released, but did not reach nearby surface water bodies. Also, the amount of pollutant discharged was described by Waste Management Branch and/or mine personnel as small. In the fourth case, material was not a c t u a l l y discharged. The remaining 13 problems caused s o l i d or dissolved substances to enter the r e c e i v i n g environment. The amount of observed or expected change i n re c e i v i n g water conditions v a r i e s considerably. One problem was detected at the source but was not detected a short distance downstream from the source ( i e . high sulphate l e v e l s i n the mine water at Baker). The observed changes r e s u l t i n g from the other 12 problems are l i s t e d i n Table 4-4. In two cases the problem sources were f e l t by regional M i n i s t r y of Environment personnel to be producing a b e n e f i c i a l change i n the r e c e i v i n g environment. These are the introduction of nitrogen compounds at Baker (from the sewage discharge) and at Ladner Creek (the mine-water s e t t l i n g ponds contained nitrogen compounds from explosives usage). At both lo c a t i o n s the waters were f e l t to be nutrient poor and the nitrogen compounds appeared to be increasing b i o l o g i c a l p r o d u c t i v i t y . In one case (the r o c k s l i d e at Silence Lake), the problem i s f e l t to be minor because the amount of material released was small, the time frame was b r i e f and the release occurred i n an area i n a c c e s s i b l e to f i s h . Ten problems involved the release of p o t e n t i a l l y t o x i c substances and/or r e l a t i v e l y high l e v e l s of suspended s o l i d s . These occurred at four 35 Table 4.4 Changes observed i n the aquatic environment near Stage I mines. Mine Name Problem Source Observed Changes Baker 1. t a i l i n g s pond discharge 2 . break i n t a i l i n g s l i n e 3. sewage discharge high cyanide and copper l e v e l s recorded below t a i l i n g s pond i n both groundwater and surface water patches of sediment observed i n stream; high cyanide l e v e l s recorded i n t a i l i n g s at time of break but no measurements made i n r e c e i v i n g water high l e v e l s of n i t r o g e n and phosphorous recorded i n surface water, downstream; a l g a l mats and changes i n i n v e r t e b r t a t e community observed HB M i l l 1. break i n t a i l i n g s l i n e t a i l i n g s sediment d i s t r i b u t e d a short d i s t a n c e along the stream bottom; no t o x i c substances i n t a i l i n g s a t the time of s p i l l Ladner Creek 1. general minesite development 2 . mine-water s e t t l i n g ponds high l e v e l s of suspended s o l i d s , a l k a l i n i t y , hardness and d i s s o l v e d elements were recorded downstream; a l g a l growth and sedimentation and changes i n i n v e r t e b r a t e community observed high l e v e l s of suspended s o l i d s and n i t r o g e n compounds recorded i n water below m i n e s i t e ; s o l i d s deposited on sub s t r a t e immediately below the minesite but not f u r t h e r downstream where salmonids are found; n i t r o g e n compounds f e l t to be cause of a l g a l growth observed downstream 36 Table 4.4 Cont'd. Mine Name Problem Source Observed Changes 3. uncontrolled runoff during mine operation 4. t a i l i n g s dam reconstruction 5. mill-process discharge 6. m i l l - b u i l d i n g drainage Silence Lake 1. rockslide at ore s t o c k p i l e Summit lake 1. mill-process discharge high l e v e l of suspended s o l i d s recorded high l e v e l s of suspended s o l i d s recorded high cyanide and copper l e v e l s recorded downstream; dead trou t observed down-stream at time of one peak discharge and bioassays suggested l e t h a l l e v e l s immediately below minesite and stress l e v e l s where f i s h are found-*-; macro-invertebrates downstream had high copper l e v e l s i n t i s s u e and showed reduction i n numbers of taxa and i n d i v i d u a l s high cyanide l e v e l s were recorded i n the drainage but the r e l a t i v e c o n t r i b u t i o n to receiving waters i s d i f f i c u l t to i d e n t i f y given the other sources (point 5 above) several boulders and sediment were deposited i n a nearby creek high cyanide and copper l e v e l s recorded i n receiving water; bioassays showed l e t h a l l e v e l s at minesite; p e r i o d i c high l e v e l s recorded downstream could not be a t t r i b u t e d to the mine a c t i v i t y as indicated i n Appendix I I I , the cause of death and the bioassay r e s u l t s have been disputed during l e g a l proceedings. 37 operations (Baker, HB M i l l , Ladner Creek and Summit Lake) and can be grouped i n t o seven problem categories: - cyanide and copper i n m i l l e f f l u e n t - breaks i n t a i l i n g l i n e s - minesite development a c t i v i t y - mine-water s e t t l i n g ponds e f f l u e n t - uncontrolled runoff during mine operation - runoff during t a i l i n g s dam construction - m i l l - b u i l d i n g drainage As shown i n Table 4-4, these problems involved mainly changes i n water q u a l i t y and i n several cases changes i n the stream invertebrate communities. The p o t e n t i a l e f f e c t s of the relevant dissolved and s o l i d substances on f i s h are described i n Appendix IB. The probable e f f e c t s on f i s h e r i e s resources near each mine are discussed separately below. Baker Mine. The discharge of cyanide and dissolved copper do not appear to have had an impact on f i s h e r i e s resources. A study of f i s h resources i n the nearby waters indicated that f i s h are not present i n the watershed near the minesite and f i s h access i s blocked by a w a t e r f a l l located 35 km downstream (Beak 1982). Regional Waste Management personnel do not f e e l t o x i c concentrations of cyanide or copper persisted to that point. A study of aquatic invertebrates conducted over one year a f t e r the high l e v e l s of cyanide and copper were f i r s t recorded, and four months a f t e r the break i n the t a i l i n g s l i n e , did not i n d i c a t e signs of damage below the minesite (IEC Beak 1983). The study suggests that the benthic community showed signs of enhancement r e s u l t i n g from the high nutrient l e v e l s from the sewage discharge and t h i s could have masked negative e f f e c t s from the cyanide and copper discharge. HB M i l l . The s p i l l of t a i l i n g s material from the broken t a i l i n g s are not f e l t by Regional M i n i s t r y of Environment personnel to have had a serious e f f e c t on f i s h i n the affected stream. This i s because f i s h do not u t i l i z e the segment of stream near the s p i l l at the time of year the break occurred, and the amount of material released was small and was not f e l t to contain 38 t o x i c m aterial. Ladner Creek. E f f e c t s on f i s h e r i e s resources might have occurred i n two ways. F i r s t l y , the sedimentation and changes i n the benthic community observed during minesite development occurred i n areas u t i l i z e d by salmonid species. The reported changes could impact salmonids i n d i r e c t l y by a f f e c t i n g both spawning habitat and food production. Secondly, when the high l e v e l s of cyanide and copper were recorded, dead steelhead trout were observed downstream. However, the cause of the m o r t a l i t i e s was disputed during l e g a l proceedings. Steelhead smolts from a hatchery had been placed i n the r i v e r at the time high cyanide and copper l e v e l s were discharged and handling methods during the stocking were f e l t to be a possible cause of death. Although cyanide could not be proven as the cause of death i n these f i s h , trout bioassays conducted s h o r t l y afterward showed that surface water at the minesite was l e t h a l and approximately 8 Km downstream caused s t r e s s . The bioassay procedures were also disputed during l e g a l proceedings. Summit Lake. F i s h bioassays indicated that the mine e f f l u e n t , containing cyanide and metals, was l e t h a l l y t o x i c but f i s h are not normally found i n the lake i n t o which mine e f f l u e n t i s discharged. Below the lake, i n areas where f i s h are found, f i s h m o r t a l i t i e s were not observed and bioassays were not conducted when high cyanide l e v e l s were recorded i n the downstream areas. The downstream l e v e l s are f e l t to have been s u f f i c i e n t to have sublethal e f f e c t s on young salmonids, but the absence of pre-operational water q u a l i t y data at the downstream l o c a t i o n s prevents a t t r i b u t i n g the high cyanide l e v e l s to the mine operation, c) Legal and F i n a n c i a l Consequences Three of the 13 Stage I mines have been convicted under either p r o v i n c i a l or fede r a l l e g i s l a t i o n r e l a t i n g to the protection of aquatic resources. The operators of three Stage I mines have been convicted under 39 the p r o v i n c i a l Waste Management Act (Baker, H B M i l l , Ladner Creek) and one mine operator has been convicted under the fede r a l F i s h e r i e s Act (Ladner Creek). In addition, water samples for l e g a l purposes were taken a f t e r the break i n the t a i l i n g s l i n e at Baker, but charges were not l a i d . The operators of the Ladner Creek mine are appealing t h e i r conviction under the Federal F i s h e r i e s Act, but are also facing a separate c i v i l action by the Steelhead Sociey of B.C. for damages to conservation e f f o r t s along the Coquihalla River. The f i n a n c i a l costs borne by operating companies to deal with the r e l a t i v e l y serious impact management problems are shown i n Table 4-5. In addition to f i n e s , other costs described by mine operators are: - a d d i t i o n a l l e g a l costs, including lawyer's fees, and preparation time for consultants and senior executives; - a d d i t i o n a l p o l l u t i o n c o n t r o l and/or environmental studies; - immediate repair costs to f i x broken equipment; - i n s t a l l a t i o n of a d d i t i o n a l p o l l u t i o n control equipment; - shut-down time causing a l o s s i n production; - increases i n monitoring frequency and/or the number of fa c t o r s monitored. The costs shown i n Table 4-5 must be regarded as approximations; repeatedly, the mining company representatives with whom these costs were discussed, emphasized that exact f i g u r e s could not be quoted. This i s mainly because f i n a n c i a l records did not trea t some factors (such as emergency r e p a i r s , court-appearance costs or the construction of waste treatment f a c i l i t i e s within a larger m i l l complex) as separate expenditures. Therefore many of the costs are simply the educated guesses by the i n d i v i d u a l s with whom the costs were discussed. Nonetheless, the fig u r e s do provide a general i n d i c a t i o n of the r e l a t i v e costs borne by the mining companies to deal with the d i f f e r e n t kinds of problems that developed. The data i n Table 4-5 i n d i c a t e that some mines expended amounts which were approximately 0.3% - 4% of t o t a l pre-production costs, to deal with eventual impact management problems. 40 Table 4.5 The f i n a n c i a l costs borne by mining operations i n r e l a t i o n to serious impact management problems. Problem Mine Name Source Fines and Other Costs($) Involved Pre-Production Costs ($) % of Pre-Production Cost Stage I Mines Baker discharge of cyanide and metals Fine other To t a l 2,000 110,000 112,000 13.5 m i l l i o n 1 0.8 break i n t a i l i n g s l i n e repairs 5,000 to 10,000 HB M i l l break i n t a i l i n g s l i n e Fine Court costs rep a i r s T o t a l 1,500 5,000 85,000 91,500 _2 Ladner Creek discharge of cyanide and metals Fine Fine Other 5,000 135,000 (unable to 50 million-^ estimate) 140,000 plus at l e a s t 0.3 Summit Lake discharge of cyanide and metals Fine Other T o t a l 0 850,OOO4 850,000 19 m i l l i o n 1 4 Stage II Mines Equity S i l v e r a c i d gener-ation i n waste rock Fine 12,000 Other 1,300,000 ( c a p i t a l costs) To t a l 3,000,OOO5 107 m i l l i o n 1 l 3 1 B.C. and Yukon Chamber of Mines 1982 2 Pre-production costs include purchase of m i l l and refurbishing for new production 3 Northern Miner Press Limited 1984 4 Excluding l o s t production during a 3-4 day shutdown a f t e r problem i d e n t i f i e d 5 C a p i t a l costs for i n i t i a l c o l l e c t i o n and treatment f a c i l i t i e s to deal with problem were estimated to be $1.2-1.4 m i l l i o n ; l e g a l costs, on-going studies and treatment measures were expected to bring t o t a l costs to at le a s t $3 m i l l i o n . 41 4.2.1.2 Stage II Mines The sources of problems, the e f f e c t s on the aquatic environment, and the l e g a l and f i n a n c i a l consequences to mine operators are summarized below. a) The Sources of Problems The source or cause of each problem i s l i s t e d i n Table 4-6. Seven impact management problems have occurred. One problem (acid generation i n waste rock) involves more that one source at a minesite (Equity S i l v e r ) because waste rock was used as material f or construction purposes. Five (71%) of the problems were i n r e l a t i o n to M i l l Construction and Operation A c t i v i t i e s . The types of problem are categorized and the number of mines i n each category are shown i n Table 4-7. Note that three problems r e l a t e to the management of t a i l i n g s material ( i e . the break i n the t a i l i n g s l i n e and breakdown of t a i l i n g s and seepage pumps). b) E f f e c t s on the Aquatic Environment One problem ( f a i l u r e of the t a i l i n g s pump at Goldstream) involved the release of t a i l i n g s material, but contaminants did not reach a nearby stream. Two problems (the crushed c u l v e r t at Equity S i l v e r and the broken t a i l i n g s pipe at Goldstream) caused small amounts of material to be released to streams, but the releases were too small and/or too b r i e f to have had an observable e f f e c t on the rec e i v i n g environment. The t a i l i n g s pipe at Goldstream had been drained j u s t p r i o r to the break. The crushed c u l v e r t at Equity S i l v e r caused pooling of low pH drainage water, but the low pH l e v e l s were a r e s u l t of the larger a c i d generation problem. In a d d i t i o n , the overflow from the seepage pond at Equity S i l v e r (because a seepage pump f a i l e d ) had a very low pH, but the overflow took place over a short period and the downstream values were not recorded. The changes observed i n the aquatic environment f o r three remaining problems, a l l at Equity S i l v e r , are summarized i n Table 4-8. Two problems 42 Table 4.6 The source or cause of problems at Stage II mines. Mine Name Category of Mining A c t i v i t y Mine Development and Operation M i l l Construction and Operation Other A c t i v i t i e s Equity S i l v e r 1. acid generation i n waste rock 1 1. accidental s p i l l of a process chemical (sulphuric acid) 2. a c i d generation i n waste rock used for m i l l s i t e c o n s t r u c t i o n 1 3. pump i n t a i l i n g s pond f a i l s 4. high suspended s o l i d s i n m i l l -s i t e runoff 1. acid gen-er a t i o n i n waste rock used f o r access road con-s t r u c t i o n 1 2. crushed c u l v e r t on haul road Goldstream 2. bridge supporting t a i l i n g s l i n e washed out . t a i l i n g s pumps f a i l Number of Problems: 1 waste rock from the mine was used f o r construction of the t a i l i n g s pond, m i l l foundations and access roads. Although the problem i s l i s t e d i n three separate categories, i t i s a c t u a l l y one source and i s therefore counted i n the text once under Mine Development and Ore Extrac t i o n . 43 Table 4.7 The number of Stage II mines having each type of problem. Category of Mining A c t i v i t y Type of Problem Number of Mines having Problem Mine development and ore e x t r a c t i o n 1. acid generation i n waste rock 1 M i l l s i t e construction 1. accidental s p i l l of process and operation chemical (sulphuric acid) 1 2. break i n t a i l i n g s l i n e 1 3. f a i l u r e of tailings/seepage pumps 2 4. m i l l s i t e runoff 1 Other a c t i v i t i e s 1. crushed c u l v e r t on haul road 1 44 Table 4.8 Changes observed i n the aquatic environment near Equity S i l v e r . Problem Source Observed Changes 1. acid generation i n waste rock reduced pH l e v e l s and increased l e v e l s of sulphate and metals (copper, zinc and iron) were recorded downstream; the s i z e of the benthic invertebrate community was reduced 2 . process chemical s p i l l (sulphuric acid) high l e v e l s of suspended s o l i d s were recorded downstream 3. p l a n t s i t e runoff high l e v e l s of suspended s o l i d s were recorded downstream; the s i z e of the benthic invertebrate community was reduced 45 (the a c i d generation i n waste rock and sulphuric acid s p i l l ) involved the release of p o t e n t i a l l y t o x i c substances. In one case (the sulphuric acid s p i l l ) , the problem was accidental and the material was released r a p i d l y ; i n the other case, the problem involved the chronic release of the substance over a l a r g e r geographical area. The suspended s o l i d s produced by the t h i r d problem (runoff from the plant s i t e ) enter the same rec e i v i n g water and a l l three problems l i k e l y contributed to the reported decline i n downstream invertebrate numbers. Waste Management personnel expressed serious concern over the long-term s o l u t i o n of the acid generation problem. The p o t e n t i a l e f f e c t s of these substances on f i s h are discussed i n Appendix IB. Although p o t e n t i a l l y harmful substances were released from the problem-sources at Equity S i l v e r , negative changes i n downstream f i s h populations have not been i d e n t i f i e d . Osborne and Hallam (1982) and H a t f i e l d Consultants Ltd. (1983) reviewed a v a i l a b l e information and concluded that the data suggested downstream f i s h e r i e s resources were not a f f e c t e d . Approximately four kilometers below the mine, the stream i n which water q u a l i t y problems were observed flows i n t o a lower stream (Buck Creek) reported to have a rainbow trout population. The a c i d i c and high metal conditions i n the t r i b u t a r y were not observed a short distance below the junction of the two streams, nor were metals recorded i n f i s h t i s s u e s or bottom sediments. c) The Legal and F i n a n c i a l Consequences to Mine Operators The operators of the one Stage I I mine (Equity S i l v e r ) were convicted under the f e d e r a l F i s h e r i e s Act. The f i n a n c i a l costs borne by the Equity S i l v e r mine to deal with i t s impact management problem i s shown i n Table 4-5. As with the costs for Stage I mines , these costs must be regarded as approximations. The mine expended approximately 3% of i t s t o t a l pre-production costs to correct the acid generation problem. 46 4.2.1.3 Summary Seventeen impact management problems were i d e n t i f i e d at s i x out of 13 Stage I mines. Changes i n the receiving environment were observed i n r e l a t i o n to most (12) of the problems. In two cases the changes appeared to be b e n e f i c i a l and i n 11 cases the changes appeared to be negative (one problem source appears to have produced both p o s i t i v e and negative changes). In 10 cases (approximately 60%) p o t e n t i a l l y serious toxicants or high l e v e l s of suspended s o l i d s were released. These problems occurred at four of the 13 Stage I mines reviewed. Negative changes to a downstream invertebrate community and possibly the f i s h community were recorded at one mine (or 8% of a l l Stage I mines). Three of the Stage I mines were convicted under environmental l e g i s l a t i o n and costs to correct impact management problems were up to 4% of the t o t a l pre-production costs Nine impact management problems were i d e n t i f i e d at two Stage II mines. Changes i n the aquatic r e c e i v i n g environment were observed i n r e l a t i o n to three of the problems. In each case, p o t e n t i a l l y serious toxicants or high l e v e l s of suspended s o l i d s were released. Another problem involved the discharge of low pH e f f l u e n t but a change i n water q u a l i t y was not recorded downstream at the time. Problems producing changes i n receiving waters occurred at 1 of the 2 Stage II mines. Negative changes to the downstream invertebrate community were recorded, but e f f e c t s on f i s h e r i e s resources are not evident. One of the Stage II mines was convicted under environmental l e g i s l a t i o n and costs to correct impact management problems were up to 3% of the t o t a l pre-production costs. 4.2.2 Problems Anticipated i n Stage I/Stage II Reports 4.2.2.1 Stage I Mines The impact management problems i d e n t i f i e d i n Stage I reports are shown 47 i n Table 4-9. Of the 17 problems that occurred,the source or cause of 12 problems were i d e n t i f i e d i n the appropriate Stage I report or Stage I addendum. These include four r e l a t i v e l y major problems discussed i n the previous subsection ( i . e . the problems with cyanide treatment at the Baker, Ladner Creek and Summit Lake mines and the break i n the t a i l i n g s l i n e at HB M i l l ) . Problem sources that were not i d e n t i f i e d are: - the broken t a i l i n g s l i n e at Baker - the f u e l s p i l l at Baker - the mine water s e t t l i n g ponds at Ladner Creek - the leak i n the t a i l i n g s dam at Free Gold - the berm overflow at Silence Lake One problem (the mine water s e t t l i n g pond at Ladner Creek) r e l a t e s mainly to a routine discharge source (though the problem was a t t r i b u t e d to two sources, the other being runoff from general minesite development a c t i v i t y ) , while the other problems r e l a t e mainly to the f a i l u r e of equipment or structures. S p e c i f i c mitigative measures were described for a l l of the i d e n t i f i e d sources of possible impact except the leakage of the t a i l i n g s dam at Free Gold. However, the Free Gold report indicated further studies were to be conducted for designing the t a i l i n g s f a c i l i t y . In cases where problem-sources are i d e n t i f i e d , the reports i n d i c a t e what general aquatic resource features (e.g. water q u a l i t y , f i s h ) might be affected by each problem source or the e f f e c t s can be i n f e r r e d . However, no report attempts to define the amount of change for the resource feature that could occur. Table 4-10 shows what conclusions were drawn i n r e l a t i o n to the problem-sources i d e n t i f i e d . No conclusions were drawn for any of the sources i d e n t i f i e d i n one report (Ladner Creek) and for only some of the sources i d e n t i f i e d i n another (Baker). Otherwise, the conclusions are very e x p l i c i t that problems would not occur. Since i n a l l cases mi t i g a t i v e 48 Table 4.9 Impact management problems i d e n t i f i e d i n Stage I reports. Mine Name Problem that Source/Cause M i t i g a t i v e Further Developed I d e n t i f i e d Measures Studies Proposed Baker 1. discharge of cyanide and metals 2. break i n t a i l i n g s l i n e 3. f u e l s p i l l at a i r -f i e l d 4. acid mine drainage 5. sewage discharge Yes No No Yes Yes Yes Yes Yes No No No Ladner Creek HB M i l l Free Gold Silence Lake 1. run-off during mine development a c t i v i t y 2. mine water s e t t l i n g ponds 3. uncontrolled runoff during operation 4. discharge of cyanide and metals 5. m i l l drainage 6. t a i l i n g s dam construction 7. t a i l i n g s pond storage 1. break i n t a i l i n g s l i n e 1. leak i n t a i l i n g s dam 1. rocks l i d e 2. berm overflow Yes1 No Yes Yes Yes Yes Yes Yes No Yes No Yes Yes x Yes Yes Yes 1 No Yes Yes No Yes No Yes Yes No No Yes No Summit Lake discharge of cyanide and metals Yes Yes No indicated i n the Stage I addendum but not i n the Stage I report. 49 Table 4.10 Conclusions drawn for each problem i d e n t i f i e d i n Stage I reports. Mine Name Problem Source Conclusions Baker 1. discharge of cyanide and metals 2. a c i d mine drainage 3. sewage discharge " T a i l i n g s e f f l u e n t w i l l be non-toxic to f i s h by a properly c o n t r o l l e d a l k a l i n e c h l o r i n a t i o n process." no conclusion presented no conclusion presented HB M i l l 1. broken t a i l i n g s l i n e "A sagging and leaking flume sometimes allowed t a i l i n g s to s p i l l i n t o Sheep Creek during the previous operation. I n s t a l l a t i o n of the p l a s t i c pipe eliminates t h i s problem.' 1. uncontrolled runoff no conclusion presented 2. discharge of cyanide and metals no conclusion presented 3. cyanide i n m i l l drainage no conclusion presented 4. t a i l i n g s dam construction no conclusion presented 1. ro c k s l i d e "No mined or sloughed material w i l l escape i n t o Maxwell Creek." Summit Lake 1. discharge of cyanide and metals "Process water containing cyanide and heavy metis i s to be treated, p r i o r to d i s -charge, by a l k a l i n e c h l o r i n a t i o n , thus e l i m i n a t i n g concern over t o x i c i t y . " "Cyanides and heavy metals w i l l be innocuous due to t h e i r treatment within the m i l l p r i o r to discharge." 50 measures were described, these conclusions imply that mitigation would be absolute. A.2.2.2 Stage II Mines As indicated i n Table 4-11, the source or cause of four of the seven problems was i d e n t i f i e d i n the pre-development reports. The most serious problem (acid-generation at Equity) was amongst those i d e n t i f i e d . Problem-sources that were not i d e n t i f i e d are: - the break i n the t a i l i n g s l i n e at Goldstream - the breakdown of t a i l i n g s pumps at Goldstream - the process chemical s p i l l at Equity S i l v e r General mitigative measures and on-going studies were outlined for the acid generation problem at Equity S i l v e r . S i m i l a r l y , m i t i g a t i v e measures were outlined for the placement of road c u l v e r t s and for drainage from the m i l l s i t e . As with the Stage I reports, the p o t e n t i a l l y affected aquatic resource features were indicated or were evident. However, again, i n most cases the amount of p o t e n t i a l change i n a p a r t i c u l a r resource feature was not indicated. An exception i s a reference i n the Equity S i l v e r report to increased sedimentation r e s u l t i n g from a c t i v i t y i n the m i l l and mine areas. Table 4-12 shows conclusions drawn i n r e l a t i o n to the problem-sources i d e n t i f i e d . The conclusions presented i n the Equity S i l v e r report i n d i c a t e that the acid generation problem was not considered l i k e l y . However, a precautionary monitoring program was outlined because uncertainty existed. 4.3 Discussion The effectiveness of the pre-development assessments i s discussed below ( i n subsection 4.3.1) i n r e l a t i o n to the a n t i c i p a t i o n of d i f f e r e n t types of problem, to the occurrence of problems at d i f f e r e n t mine types, to the r e l a t i v e seriousness of e f f e c t s on aquatic resources, and to the consequences for mine operators. A n a l y t i c a l weaknesses that might have 51 Table 4.11 Impact management problems i d e n t i f i e d i n Stage II reports. Mine Name Problem that Developed Source/Cause M i t i g a t i v e Further P o t e n t i a l I d e n t i f i e d Measures Studies E f f e c t s Proposed Described Equity 1. acid generation i n S i l v e r waste rock Yes process chemical s p i l l (sulphuric acid) No crushed c u l v e r t Yes^ m i l l s i t e runoff Yes breakdown of t a i l i n g s seepage pump Yes 2. 3. 4. 5. Gold- 1. break i n t a i l i n g s stream 4 l i n e No 2. breakdown of t a i l i n g s pump No Yes Yes Yes No Yes' No No No Yes 3 No 1 The impact analysts d i d not s p e c i f i c a l l y r e f e r to "crushed c u l v e r t s " . Nonetheless, these might have been considered, given the wording used. The crushed c u l v e r t occurred at the minesite. Discussion of cul v e r t design and maintenace was i n d i r e c t reference to the mine access road, not roads at the minesite. 2 An on-going monitoring program to detect development of an acid generation problem i s recommended. 3 Increased sediment load i s referred to. 4 Based on preliminary (Stage I) assessment. 52 Table 4.12 Conclusions drawn for each problem i d e n t i f i e d i n the Equity S i l v e r Stage II report. Problem Source Conclusions 1. acid generation i n waste rock "The t e s t s subsequently indicated that the p o t e n t i a l for acid generation does e x i s t . " "After considering the relevant factors which are required for acid mine waters to c o n s t i t u t e a p o l l u t i o n problem, i t i s a n t i c i p a t e d that the impact on the environment w i l l be n e g l i g i b l e provided that the monitoring programme for water seeping from the waste dumps i s c o r r e c t l y implemented." 2. m i l l s i t e runoff "The plant and mine areas could impact the Buck Creek system. However, any incrased sediment load may not impact environmental e f f e c t s beyond Goosly Lake..." 3. crushed c u l v e r t In reference to possible erosion along the mine access road, "However, with c a r e f u l road construction techniques emphasizing road l o c a t i o n , placement and maintenance of c u l v e r t s being employed by the contractor, i t i s an t i c i p a t e d that these p o t e n t i a l negative impacts w i l l be at l e a s t t r a n s i t o r y i f non-existant." 53 contributed to the r e l a t i v e l y serious problems are discussed i n subsection 4.3.2, and the adequacy of the review process i s discussed i n subsection 4.3.3. 4.3.1 Effectiveness of Pre-development Assessments v 4.3.1.1 Types of problem Most problems (60%-70%) at both Stage I and Stage I I mines were i n r e l a t i o n to m i l l construction and operation a c t i v i t i e s ( including t a i l i n g s ponds), as opposed to development and operation of the mine i t s e l f , on-going exploration and other a c t i v i t i e s . The sources of eight of the 24 eventual problems were not i d e n t i f i e d i n pre-development studies. The sources 16 problems were i d e n t i f i e d , but, c l e a r l y , were not prevented. The occurrence of these problems appears to be because e i t h e r inappropriate m i t i g a t i v e measures were chosen or the measures were poorly implemented. Most problems not i d e n t i f i e d were rel a t e d to equipment f a i l u r e and/or operator e r r o r . This i n d i c a t e s that, i n addition to the development of impact management str a t e g i e s before mine operation begins, e f f e c t i v e supervision and enforcement a c t i v i t i e s are required as part of the o v e r a l l management e f f o r t . The absence of more serious e f f e c t s r e l a t e d to several of these problems might be due more to good fortune than good design (eg. draining of the t a i l i n g s l i n e at Goldstream j u s t p r i o r to the break i n the l i n e ) . The sources of problems can be placed i n three general categories. The categories and the numbers and percentages of problems i n each are: routine e f f l u e n t discharge :8(33%) general s i t e runoff :5(21%) equipment or s t r u c t u r a l f a i l u r e s :11(46%) The problems associated with routine e f f l u e n t discharge include m i l l and t a i l i n g s discharges, mine and m i l l s e t t l i n g pond discharge and sewage discharge. The problems associated with general s i t e runoff include runoff from mine and m i l l areas, runoff during t a i l i n g s pond construction and runoff from waste rock material. The problems associated with equipment or 54 structural failure include broken tailings lines and pumps, breaches in tailings dams, a collapsed roadway culvert, s p i l l s of a process chemical s p i l l , a rockslide at an ore stockpile and a fuel s p i l l . In terms of problems that were anticipated in the'associated Stage I and Stage II impact assessments, the number and percentage of problem-sources identified in the different categories are: routine effluent discharge :7(88%) general site runoff :5(100%) equipment or structural failure :6(55%) These data suggest that the pre-development assessments were in general more effective for identifying the sources of potential routine discharge problems and site runoff problems, than for identifying equipment or structural failures. However, these data should be interpreted with caution given the relatively small sample sizes involved. 4.3.1.2 Types of Mine having Serious Problems a) Stage I_ Mines The types and numbers of Stage I mines and mills examined for this thesis are: a) underground gold or gold/silver, producing 30-300 tonnes/day :8 mines b) gold-molybdenum, producing 100 tonnes/day : 1 m i l l c) underground gold/silver plus lead and zinc (mine in Yukon and mil l in B.C.), producing 100 tonnes/day : 1 mine d) underground gold mine producing 1000 tonnes/day : 1 mine e) open pit magnesite (mine in B.C. and m i l l in Alberta) producing 100 tonnes/day : 1 mine f) open pit tungsten producing 100 tonnes/day : 1 mine The three Stage I mines that had relatively serious problems are a l l underground gold mines. Two of the mines are relatively small (Baker and Summit Lake) f a l l i n g in category a) above, and one i s larger (Ladner Creek) and i s the mine shown in category d). The Stage I mil l (the HB Mil l ) that had a relatively serious problem was intended for processing gold and molybdenum (ie. the m i l l identified in category b above), but was processing custom deliveries of lead-zinc-silver when the problem occurred. 55 With respect to gold mines, Ripley et a l . 1978 indicate that there i s a large variation in processing a c t i v i t i e s amongst lode-gold operations but summarize the following effects: " i residual cyanide, from the cyanidation process, in waste waters; i i hydrospheric emissions of arsenic and heavy metals; i i i suspended particulates in waste waters; and iv atmospheric emissions of arsenic, sulphur, and tellerium compounds mainly associated with arsenopyrite ores." In comparison, the sources and types of effect identified in the present study are: i . cyanide and metals in wastewater; i i . suspended solids and dissolved solids from broken tailings lines; tailings dam construction; mine development activity; mine-water settling ponds; and uncontrolled minesite runoff, i i i . nutrients from sewage discharge. Clearly, cyanide, metals and suspended solids are a common impact management problem at gold mines and should not be unexpected. However, these problems have occurred at operations in British Columbia, even those that have prepared an impact assessment and have been subject to governmental review prior to proceeding. For cyanide treatment, the three gold mines i n i t i a l l y used the same treatment method (alkaline chlorination) and converted to a new method (INC0-S02/Air) after cyanide discharge problems developed. b) Stage II Mines The Stage II mines are an open-pit silver, gold, and copper mine producing 5000 tonnes/ day (Equity Silver) and a combined open-pit/underground copper and zinc mine producing 1400 tonnes/day (Goldstream). Both mines are described as sulphide ore mines because the metals are extracted from ores having a high sulphide content. Ripley et a l . 1978 provide the following summary of sources and types of effect from sulphide ore mines: "The emission of heavy metal particulates, sulphur oxide, and acid mine drainage to the hydrosphere cause changes in water chemical composition, sediment, and quality, particularly at the local scale. In addition, water movement, 56 both at the surface and underground, i s a f f e c t e d . " The r e l a t i v e l y serious problems i d e n t i f i e d at the Equity S i l v e r mine are: i . a c i d produced i n and draining from mine waste-rock; i i . a c i d r e s u l t i n g from the s p i l l of a process chemical (sulphuric a c i d ) ; and, i i i . suspended s o l i d s i n minesite runoff. Elevated heavy metal l e v e l s accompanied the a c i d i c conditions. Acid mine drainage i s c l e a r l y i d e n t i f i e d i n the l i t e r a t u r e as a common impact management problem with sulphide ore mines and therefore should not be unexpected. However, acid generation i n the rock material of mines i s a highly complex problem and i s usually the r e s u l t of the combined a c t i v i t y of oxygen, water and a bacterium, T h i o b a c i l l u s ferroxidans (Marshall 1982; Clarke 1974). The impact analysts for the Equity S i l v e r mine concluded that the l i k e l i h o o d of an acid generation problem was low given conditions at the s i t e . 4.3.1.3 Actual E f f e c t s on Aquatic Resources The r e s u l t s i n d i c a t e that changes i n water q u a l i t y and benthic communities were observed at four Stage I mines and one Stage II mine. The r e s u l t s further show that f i s h were observed to be d i r e c t l y affected at only one of the 13 Stage I mines and neither Stage II mine. These data suggest that f i s h e r i e s resources have not been affected at most of the mines examined. Nonetheless, the review of possible e f f e c t s on f i s h e r i e s resources i n Appendix IB i n d i c a t e s that the p o t e n t i a l for more serious e f f e c t s existed at several other mines and were perhaps not detected. C l e a r l y , the a b i l i t y to detect e f f e c t s on f i s h or other resources i s dependent on the types of monitoring and reporting procedures i n place. The p o s s i b i l i t y that a problem occurred but was not detected and the p o s s i b i l i t y that a problem was detected but not reported are discussed b r i e f l y below, a) The p o s s i b i l i t y that a_ problem occurred but was not detected The type of data obtained during monitoring and problem-specific 5 7 s t u d i e s i s d e s c r i b e d i n A ppendix IV. D u r i n g a m o n i t o r i n g program, r o u t i n e s a m p l i n g i s u n d e r t a k e n by t h e mine and, i n a d d i t i o n , b o t h r o u t i n e and i r r e g u l a r v i s i t s a r e c o n d u c t e d by Waste Management B r a n c h p e r s o n n e l o r p e r s o n n e l from o t h e r p r o v i n c i a l o r f e d e r a l r e s o u r c e a g e n c i e s ( e g . E n v i r o n m e n t a l P r o t e c t i o n S e r v i c e ) . I n c a s e s where t h e v i s i t s by government p e r s o n n e l t a k e p l a c e i n f r e q u e n t l y ( e g . once per y e a r ) , g r e a t r e l i a n c e must be p l a c e d on t h e s a m p l i n g and m o n i t o r i n g program u n d e r t a k e n by t h e mine o p e r a t o r . Even r o u t i n e v i s i t s o f once a month might n o t be s u i t a b l e f o r o b s e r v i n g t h e e f f e c t s o f emergency s p i l l s o r o t h e r c a t a s t r o p h i c e v e n t s t h a t c o u l d o c c u r . Based on t h e s a m p l i n g and r e p o r t i n g p r o c e d u r e s t h a t a r e u s ed, problems t h a t r e s u l t i n a c h r o n i c r e l e a s e o f t o x i c a n t s , m e a s u r a b l e o v e r s e v e r a l months, and problems p r o d u c i n g v i s i b l e p h y s i c a l damage a r e more l i k e l y t o be d e t e c t e d . I n c o n t r a s t , problems t h a t r e s u l t i n s p o r a d i c but e x c e s s i v e r e l e a s e s i n t o x i c a n t s and a r e n o t r e l a t e d t o v i s i b l e p h y s i c a l damage appear t o have a low l i k e l i h o o d o f b e i n g d e t e c t e d , b) P o s s i b i l i t y t h a t a_ problem was d e t e c t e d but n o t r e p o r t e d T h i s p o s s i b i l i t y i s d i f f i c u l t t o a s s e s s . R e p o r t i n g o f emergency e v e n t s , s u c h as c h e m i c a l s p i l l s , where p h y s i c a l damage has n o t o c c u r r e d and where t h e p e r i o d o f d e t e c t i o n i s b r i e f , a r e dependent on t h e u n d e r s t a n d i n g and i n t e g r i t y o f t h e mine o p e r a t o r . Where v i s i t s by r e s o u r c e agency p e s o n n e l a r e f r e q u e n t ( e g . l a r g e , a c c e s s i b l e m i n e s ) , t h e s e e v e n t s a r e p r o b a b l y r e p o r t e d w i t h o u t h e s i t a t i o n . However, where v i s i t s by r e s o u r c e agency p e r s o n n e l a r e not f r e q u e n t , ( e g . s m a l l , remote mines) t h e r e i s p erhaps g r e a t e r p o s s i b i l i t y t h e s e e v e n t s a r e n o t r e p o r t e d . The p o s s i b i l i t y t h a t t h e problem w i l l be d e t e c t e d by a second p a r t y , p a r t i c u l a r l y r e s o u r c e agency p e r s o n n e l , m ight i n f l u e n c e t h e d e c i s i o n o f a mine o p e r a t o r t o r e p o r t . N o n e t h e l e s s , f o r t h i s t h e s i s , mine o p e r a t o r s g e n e r a l l y e x h i b i t e d an openness and w i l l i n g n e s s t o i d e n t i f y i m p a c t management d i f f i c u l t i e s t h a t had a r i s e n . 58 4.3.1.4 Consequences to Mine Operators As indicated in the results section (section 4.2), three of the 13 Stage I mines and one Stage II mine had impact management problems that resulted in convictions and/or relatively large financial expenditures. A fourth Stage I mine (Summit Lake) made a large expenditure to deal with a problem, but was not charged. The circumstances of the problems vary greatly and generalizations cannot be made, other than stating that three problems involved the release of cyanide. In one case direct effects on fisheries resources are f e l t to have occurred. In a second but similar case (involving the release of cyanide), direct effects are not f e l t to have occurred yet a conviction resulted because the terms of the discharge permit were not complied with. In a third case, which again involved the release of cyanide, neither direct effects appear to have occurred nor were charges la i d , but, nonetheless, the mine operator incurred a relatively high cost to correct the problem. 4.3.2 Analytical Weaknesses Related to the Occurrence of Serious Problems Where problem sources were referred to in reports, mitigative measures were generally described but the types and amount of potential effects prior to mitigation either were not described or were described very briefly. Consequently, report authors did not attempt to use the amount of possible effect for defining the amount of mitigation to be achieved. In the case of serious problems that developed, the main weaknesses in the impact analyses are: - the unchallenged assumption that a chosen mitigative measure would work ( alkaline chlorination for cyanide removal at Stage I gold mines); and, - the incorrect conclusion about the possible seriousness of an impact problem (acid generation at the Stage II Equity Silver mine), followed by failure to heed statements by the analyst that the conclusion was subject to uncertainty. 4.3.3 Adequacy of the Impact Assessment Process The results indicate that, amongst the mines studied, a Stage I mine 59 entering the MDRP and entering production had a 1 i n 3 l i k e l i h o o d of developing a r e l a t i v e l y serious aquatic resource impact management problem. The mines studied had entered the review process shortly a f t e r i t s adoption i n 1979. In f a c t , high metal prices at that time resulted i n a r e l a t i v e l y large number of report submissions over the 1979-1982 period (shown i n Figure 4-1). Since that period, the review procedures have been modified (as discussed i n Chapter 3.0), and allow closer examination of mines entering the review process. The one Stage II that developed a r e l a t i v e l y serious problem a c t u a l l y submitted pre-development reports to the p r o v i n c i a l government before the formal review process for metal mines was i n place. Other f a c t o r s that must be considered when i n t e r p r e t i n g the numbers of problem that have occurred include: i . the f a c t that three mines (Banbury B r u s s i l o f , and Free Gold) operated at " p i l o t - s c a l e " l e v e l s of production; i i . the Venus mine operated for only two weeks before shutting down; and i i i . f i v e Stage I mines (Silence Lake, Skomac, HB, Table Mountain, Vollaug) and one Stage II mine (Goldstream) operated at a lower l e v e l of production than expected and/or for only one season. This means that of the Stage I mines, four (Baker, Ladner Creek, Summit Lake amd Taurus) operated at near-capacity production l e v e l s for more than one season. Under these operating conditions, 3 out of 4 Stage I mines had r e l a t i v e l y serious impact management problems. Whether t h i s proportion accurately i n d i c a t e s the proportion of mines that would have had problems, had they a l l been at f u l l l e v e l s of production, i s questionable, given the r e l a t i v e l y small number of mines studied. I n t u i t i v e l y , one would expect that, for a p a r t i c u l a r mine, the l i k e l i h o o d of problems developing would increase the longer the mine remained i n operation. 4.4 Conclusions 1. Amount and Occurrence of Problems . Twenty-four problems occurred amongst the 13 Stage I mines and two Stage II mines that submitted pre-development impact assessments to the p r o v i n c i a l government. Six of the 60 Figure 4.1 The number of Stage I reports (for Stage I mines) submitted to the Mine Development Review Process, 1979-1985. 12 11 10 NUMBER OF SUBMISSIONS 1979 1980 1981 1982 1983 1984 1985 YEAR Note that three reports were submitted as dr a f t s i n 1982 and then as f i n a l reports i n 1983. These are counted as 1983 reports only. 61 Stage I mines and b o t h Stage I I mines had a t l e a s t one problem. The s o u r c e s of e i g h t o f t h e e v e n t u a l problems were n o t i d e n t i f i e d i n t h e pre-development a s s e s s m e n t s . F o u r Stage I mines and one Stage I I mine had a r e l a t i v e l y s e r i o u s p r o blem. The p o s s i b i l i t y o f t h e s e problems o c c u r r i n g had been f o r e s e e n i n t h e pre-development s t u d i e s . Some o f t h e mines s t u d i e d had o p e r a t e d a t a r e d u c e d , p i l o t s c a l e and/or v e r y b r i e f l y . I f p i l o t - s c a l e mines and mines t h a t o p e r a t e d f o r l e s s t h a n one season a r e n o t co u n t e d t h e n t h r e e o u t of f o u r S t age I mines had a r e l a t i v e l y s e r i o u s p r oblem. 2 . Types o f P r o b l e m . The most s e r i o u s problems appear t o be t h o s e r e l a t i n g t o t h e d i s c h a r g e o f c y a n i d e and m e t a l s above p e r m i t t e d l e v e l s a t Stage I g o l d mines and t o t h e g e n e r a t i o n o f a c i d i n waste r o c k a t one Stage I I s u l p h i d e o r e mine. The most common problems have been a s s o c i a t e d w i t h equipment and s t r u c t u r a l f a i l u r e s , m a i n l y t a i l i n g s f a c i l i t i e s ( i . e . l i n e s , pumps, and dams). The pre-development a s s e s s m e n t s appear t o have been r e l a t i v e l y more e f f e c t i v e f o r i d e n t i f y i n g r o u t i n e d i s c h a r g e problems and g e n e r a l s i t e r u n o f f p r o b l e m s , t h a n f o r i d e n t i f y i n g problems r e l a t e d t o equipment o r s t r u c t u r a l f a i l u r e s . S i n c e t h e s o u r c e s o f r o u t i n e d i s c h a r g e problems were a n t i c i p a t e d i n t h e pre-development s t u d i e s , t h e r e a s o n t h a t t h e problems o c c u r r e d a p p e a r s r e l a t e d t o t h e c h o i c e and/or i m p l e m e n t a t i o n o f m i t i g a t i v e measures. 3. E f f e c t s on A q u a t i c R e s o u r c e s . E f f e c t s on f i s h e r i e s r e s o u r c e s were o b s e r v e d a t o n l y one Stage I mine and none o f t h e Stage I I mines. However,in g e n e r a l , e f f e c t s on a q u a t i c r e s o u r c e s a r e r e c o r d e d i n terms o f wa t e r q u a l i t y and b e n t h i c i n v e r t e b r a t e s , n ot i n terms o f f i s h p o p u l a t i o n s . The t y p e s o f c h e m i c a l and s o l i d m a t e r i a l r e l e a s e d d u r i n g problems a t most mines i n d i c a t e t h a t t h e p o t e n t i a l f o r more s e r i o u s e f f e c t s e x i s t e d a t o t h e r mines. I t i s p o s s i b l e t h a t t h e e f f e c t s o f some problems were not d e t e c t e d g i v e n t h e 62 monitoring procedures i n use. Although most problems (46%) have been related to the f a i l u r e of equipment or structures, e s p e c i a l l y t a i l i n g s l i n e s , pumps, and dams, environmental e f f e c t s often have not been recorded. The e f f e c t s of mine development on the aquatic environment are not always negative. Nutrients from sewage and explosives appear to have had p o s i t i v e e f f e c t s . 4. Consequences to Mine Operators . The study r e s u l t s suggest that mine operators can expect to spend up to 4% of t h e i r t o t a l pre-production costs to correct a serious problem a f t e r production begins. These costs could be incurred even i f environmental e f f e c t s are not c l e a r l y i d e n t i f i e d and court action does not occur. S i m i l a r l y , serious environmental e f f e c t s do not necessarily have to be shown for a mine operator to be convicted of an offence. 5. Apparent Weaknesses i n the Pre-development Studies. In the case of serious problems that developed, the main weaknesses i n the impact analyses are: - the unchallenged assumption that a chosen mit i g a t i v e measure would work ( i e . a l k a l i n e c h l o r i n a t i o n for cyanide removal) - the i n c o r r e c t conclusion about the possible seriousness of an impact problem ( i e . acid generation), followed by f a i l u r e to heed statements by the impact analyst that the conclusion was subject to uncertainty. 6. Adequacy of the Review Process. The r e s u l t s suggest that a Stage I mine entering the p r o v i n c i a l review process between 1979 and 1982, and operating at f u l l production for more than one operating season, had a 3 i n 4 l i k e l i h o o d of having a r e l a t i v e l y serious impact management problem. Two out of four such mines were convicted under environmental l e g i s l a t i o n and at l e a s t one mine incurred problem-related expenses of up to 4% of the t o t a l mine pre-operational costs. 63 CHAPTER 5.0 ANALYTICAL METHODS AND PROCEDURES USED FOR STAGE I IMPACT  ASSESSMENTS The purpose of t h i s chapter i s to evaluate the a n a l y t i c a l methods used for Stage I assessments, i n order to i d e n t i f y possible weaknesses and opportunities f or improvement. The following factors were examined: the apparent influence of government guidelines and procedures; the t h e o r e t i c a l weaknesses, based on a n a l y t i c a l approaches and methods described i n the l i t e r a t u r e (these are reviewed i n Chapter 3.0); and, the improvements to a n a l y t i c a l methods suggested i n recent government Terms of Reference (TOR's). In addition, the types of information and methods used i n monitoring and follow-up studies were examined for comparison with the pre-development studies. The t h e s i s study methods are described below (subsection 5.1), and the r e s u l t s , discussion, and conclusions are presented i n the subsequent subsections. 5.1 Study Methods Five Stage I reports and two recent s i t e s p e c i f i c TOR's were examined. These are l i s t e d i n Table 5-1. As described i n Chapter 2.0, the review process has been evolving since the early 1970's. Given the evolutionary nature of the review process, reports submitted at d i f f e r e n t times over the 1979-1983 period were examined. One report was submitted i n 1979, two reports were submitted i n 1980, one was submitted i n 1981, and one was submitted i n 1983. The TOR's were produced more recently, i n 1984 and 1985. The Stage I reports include: i . three "Stage I" mines i d e n t i f i e d i n Chapter 4.0 as having r e l a t i v e l y major problems with impact management systems (Baker, Ladner Creek, Summit Lake); i i . one a d d i t i o n a l "Stage I" mine (Free Gold)that was amongst the other "Stage I" mines reviewed i n Chapter 4.0. This mine did not have a major problem. And, 64 Table 5.1 Mines for which Stage I reports and terms of reference were reviewed. Date Report Mine Name Submitted Mine Entered Production R e l a t i v e l y Serious Problem Developed Conviction Resulted STAGE 1 REPORTS Baker March, 1980 Yes Yes Yes Blackdome January, 1983 No - -Free Gold A p r i l , 1981 Yes No No Ladner Creek 1 July, 1979 Yes Yes Yes Summit Lake February, 19 80 Yes Yes No TERMS OF REFERENCE Quesnel Fluorospar ^ - - - -N i c k e l Plate 3 - - - -1 An addendum was submitted i n December, 1979. Prepared i n 1984 Prepared i n 1985 65 i i i . one "Stage I" mine that has not yet entered production ( i e . Blackdome) and was therefore not reviewed i n Chapter 4.0. The Stage I report f or t h i s mine was reviewed as a d r a f t submission i n 1982 and was submitted as a f i n a l report i n 1983. The contents of the reports and TOR's were reviewed, f i r s t l y , to determine to what extent a n a l y t i c a l methods were influenced by goverment review guidelines and, secondly, to i d e n t i f y s p e c i f i c a n a l y t i c a l weaknesses. The general contents of the Stage I reports and TOR's are outlined i n Appendix V. 5.1.1 Influence of P r o v i n c i a l Review Guidelines The procedural guidelines prepared i n 1979 to a s s i s t mine proponents (Ministry of Energy, Mines and Petroleum Resources 1979) were reviewed to i d e n t i f y what a n a l y t i c a l methods are recommended for use i n pre-development studies. A memorandum (MacDonald 1984) issued by the MEMPR i n September, 1984, and describing the revised MDRP, was also reviewed. The contents of each Stage I report and TOR were compared to the top i c s and a n a l y t i c a l methods recommended i n the government guidelines. 5.1.2 I d e n t i f i c a t i o n of A n a l y t i c a l Weaknesses i n Pre-development Studies The information and methods used i n each report described above was examined i n greater d e t a i l and were compared to t h e o r e t i c a l concepts and methods i n the EIA l i t e r a t u r e (reviewed i n Chapter 3.0). The l i t e r a t u r e review was used to i d e n t i f y a n a l y t i c a l features that could be included i n the MDRP Stage I reports. In addition, the types of information and methods used i n studies conducted a f t e r metal mines begin operation were reviewed, and were compared with the types of information and methods used i n the pre-development reports. Monitoring requirements and problem-specific studies f or s i x Stage I mines and two Stage I I mines were reviewed. The Stage I mines include three f o r which Stage I reports were examined ( i e . Baker, Ladner Creek, and Summit Lake). The r e s u l t s of the review are summarized i n Appendix IV. 66 The information requirements outlined i n the two TOR's were compared to the type of information used both i n previous Stage I reports and i n post-start-up studies. These data were used to i d e n t i f y recent improvements to the previous a n a l y t i c a l methods. The contents of the TOR's are summarized i n Appendix VB. 5.2 Results The influence of the p r o v i n c i a l review guidelines i s examined i n subsection 5.2.1, and the weaknesses i n a n a l y t i c a l methods are examined i n subsection 5.2.2. 5.2.1 Influence of the P r o v i n c i a l Review Guidelines The a n a l y t i c a l requirements outlined i n the government guidelines are described i n subsection 5.2.1.1. The conformity of the Stage I reports and TOR's to these requirements are examined, re s p e c t i v e l y , i n subsection 5.2.1.2 and subsection 5.2.1.3. A summary of findings i s presented i n subsection 5.2.1.4. 5.2.1.1 The A n a l y t i c a l Requirements Outlined i n the Government Guidelines The types of information and analyses recommended for use by mine proponents i n the former 1979 "Procedures" and outlined i n the 1984 Memorandum describing the revised review process are summarized separately below. a) The 1979 "Procedures" i . Stage I_ Report "The Stage I report should provide s u f f i c i e n t d e t a i l to inform regulatory and non-regulatory agencies about the current status of the project. The report should contain: - a d e s c r i p t i o n of the e x i s t i n g environmental and s o c i a l conditions that could be affected by the proposed development. - a d e t a i l e d project d e s c r i p t i o n including options that have been considered. - a preliminary environmental and s o c i a l impact assessment. - an outline of proposed further studies." 67 The "Procedures" provide a recommended o u t l i n e f o r the Stage I report, i n which they state that the section on Environmental and S o c i a l Impacts "should address i t s e l f to s i g n i f i c a n t impacts or an i d e n t i f i c a t i o n of environmental concerns which w i l l be assessed i n submissions f o r permit a p p l i c a t i o n s . " The recommended o u t l i n e acts as a c h e c k l i s t of topics to be covered and i s shown i n Appendix VI. No guidance i s provided on how " s i g n i f i c a n t " impacts or concerns should be determined. i i . Stage I I Report "The format of the Stage I I report remains f l e x i b l e to accommodate the s p e c i f i c requirements of each proposed development. The content and format i s l e f t to the d i s c r e t i o n of the proponent and consultant. I t may be i n the proponent's best i n t e r e s t to consider two reports, one covering the minesite and another, housing. Whatever the format, the Stage II report must contain a de s c r i p t i o n of the f i n a l project design i n c l u d i n g : - project d e s c r i p t i o n i n c l u d i n g options considered - proposed housing f o r employees - environmental and s o c i a l impact assessment - management of impacts" Again, no guidance i s provided on how impacts should be analyzed, b) The Revised Procedures The 1984 Memorandum issued by the MEMPR ind i c a t e s that new guidelines are presently being prepared. The guidelines are to contain t e c h n i c a l appendices o u t l i n i n g government information requirements. The memorandum indic a t e s that these might include: b i o p h y s i c a l / t e c h n i c a l information; reclamation guidelines; t a i l i n g s impoundment guidelines; sediment c o n t r o l guidelines; and p o l l u t i o n c o n t r o l objectives. In addi t i o n a c h e c k l i s t of p o t e n t i a l t o p i c s required i n proponent submissions might be included. 5.2.1.2 Conformity of the Five Stage I Reports With the 1979 Procedures The contents of each report are summarized i n Appendix VA. Information contained i n each report i s compared below to the contents and format recommended i n the 1979 "Procedures" (Appendix VI). The information i s examined i n terms of the major topics addressed, the r e l a t i v e emphasis on 68 major t o p i c s , the subtopics addressed, and the apparent a n a l y t i c a l framework. a) Major Topics Addressed Although t i t l e s of major sections vary, a l l reports contain the following major sections: "Introduction"; "Description of E x i s t i n g Environmental and S o c i a l Conditions"; "Project Description"; "Environmental and S o c i a l Impacts". Two reports (Baker and Summit Lake) do not present a section o u t l i n i n g "Proposed Further Studies". Also, discussion of impact management measures d i f f e r s amongst the reports. The Baker, Ladner Creek and Summit Lake reports present separate sections describing " P o t e n t i a l Impacts" and " M i t i g a t i v e Measures". The Free Gold and Blackdome reports do not separate p o t e n t i a l impacts and mit i g a t i o n , but provide a general discussion of both, segregating the discussions under resource categories. A l l reports contain appendices, though the type of information presented varies considerably. b) Relative Emphasis on Major Topics The Blackdome, Ladner Creek and Summit Lake reports are s u b s t a n t i a l l y longer that the 100 page report-length suggested i n the 1979 Procedures. Those reports range from 137 pages f o r the Summit Lake report to 182 pages fo r the Blackdome reports. The proportion of reports used to describe e x i s t i n g environmental and s o c i a l conditions (including relevant appendices, tables and fig u r e s ) i s generally greater than the suggested amounts ( i e . 30%) i n a l l reports. The environmental sections of a l l reports except the Free Gold report contain the r e s u l t s of environmental f i e l d studies. Note that the proponent f o r Ladner Creek was required to submit an addendum describing the t a i l i n g s dam and water management measures. The proportion of reports used f o r the an a l y s i s and d e s c r i p t i o n of impact v a r i e s , but i n three reports (Ladner Creek, Summit Lake and Free 69 Gold) i s l e s s than the amount recommended ( i . e . l e s s than 10% of the t o t a l r e port). S i m i l a r l y , the proportion used to describe further studies i s low or absent i n a l l cases. c) Subtopics Addressed Compared to the subtopics recommended i n the 1979 Procedures for describing e x i s t i n g environmental conditions, a l l reports present information on: "Hydrology", " F i s h e r i e s " , and "Water Quality". Groundwater i s not addressed i n the three reports submitted before 1981 (Baker, Ladner Creek, Summit Lake). Note that the serious problem at Baker (described i n Chapter 4.0) involved the groundwater transport of chemicals from the t a i l i n g s impoundment to a nearby stream. The Baker and Ladner Creek reports include a subtopic (aquatic invertebrates) not suggested i n the 1979 Procedures. With respect to the project d e s c r i p t i o n , the subtopics recommended i n the 1979 Procedures but not included i n some Stage I reports are: drainage control and monitoring and e f f l u e n t c o n t r o l and monitoring. Reports for two out of the three mines (Ladner Creek and Summit Lake) at which major problems developed did not address these subtopics. Drainage c o n t r o l at Ladner Creek was subsequently addressed i n an addendum. A l l reports except the Free Gold report include the r e s u l t s of acid generation t e s t s , though t h i s i s not a recommended topic i n the 1979 Procedures. d) Apparent A n a l y t i c a l Framework The manner i n which information i s presented i n the reports suggests two basic approaches to the impact analyses. These are outlined i n Figure 5-1. The a n a l y t i c a l framework that would be used i f analysts followed the Stage I format suggested i n the 1979 Procedures (Appendix VI) most c l o s e l y resembles that for the two reports submitted i n 1981/1983(Free Gold and Blackdome). Three reports, (Baker, Ladner Creek, Summit Lake) p o s i t i o n the 70 Figure 5.1 Apparent a n a l y t i c a l frameworks i n f i v e Stage I r e p o r t s . PROJECT DESCRIPTION ( A l t e r n a t i v e S i t e s ) ( M i t i g a t i o n ) (Monitoring) IMPORTANT RESOURCES IMPACT ANALYSIS ( I d e n t i f y p o t e n t i a l impacts) IMPORTANT RESOURCES PROJECT DESCRIPTION ( A l t e r n a t i v e S i t e s ) (Mit i g a t i o n ) (Monitoring) IMPACT ANALYSIS (For separate resource c a t e g o r i e s , source of e f f e c t and m i t i g a t i o n discussed) (Mit i g a t i o n ) PROPOSE FURTHER STUDIES (Location and design of t a i l i n g s dam) ADDENDUM NO FURTHER STUDIES FUTURE STUDIES ( l o c a t i o n and design of t a i l i n g s pond) (baseline and on-going water q u a l i t y monitoring water q u a l i t y and q u a n t i t y monitoring 1. LADNER CREEK 1. BAKER 1. FREE GOLD 2. BLACKDOME 2. SUMMIT LAKE "Environmental Description" section behind the "Project Description" section. These reports are for mines that eventually had serious problems. Placing the d e s c r i p t i o n of environmental features section behind the section describing features of the project might simply be "house-keeping" during report preparation, but represents an i n t e r e s t i n g s h i f t i n the flow of l o g i c for analyzing impacts. Since discussion of m i t i g a t i v e measures i s presented i n the project d e s c r i p t i o n section, t h i s sequence implies that m i t i g a t i v e measures are developed p r i o r to and independently from the analyses of e x i s t i n g environmental and s o c i a l conditions. C l e a r l y , such measures would not be developed for s p e c i f i c important resources i d e n t i f i e d downstream and would apply regardless of the mine l o c a t i o n . The 1979 Procedures d i r e c t mine proponents to include m i t i g a t i v e measures i n the "Project Description" Section, but a f t e r preparing a d e s c r i p t i o n of the surrounding environment. 5.2.1.3 Conformity of the Recent Terms of Reference A l i s t of the topics and subtopics contained i n each TOR i s presented i n Appendix VB. B a s i c a l l y , the major aquatic-resource topics are the same as those prescribed i n the 1979 Procedures ( c f . Appendix VI ) and found i n recent Stage I reports ( i . e . Surface Water Quantity and Quality, Groundwater Quantity and Quality and F i s h e r i e s ) . Several subtopics described under the "Waste Management" topic are also indicated i n the 1979 Procedures and are found i n some previous Stage I reports ( i . e . e f f l u e n t discharge, drainage, t a i l i n g s d i s p o s a l ) . Subtopics not prescribed i n the 1979 Procedures, but i d e n t i f i e d i n the TOR's and often addressed i n the previous Stage I reports are acid generation p o t e n t i a l , t o x i c i t y and f i s h habitat assessment. An a n a l y t i c a l framework s i m i l a r to that described above i s not evident i n the TOR's. 5.2.1.4 Summary a) The government guidelines provide guidance on the type of d e s c r i p t i v e 72 information to consider, but not on the methods to be used for impact a n a l y s i s . b) In general, the Stage I reports present the type of d e s c r i p t i v e information suggested i n the 1979 Procedures. c) Later reports address several subtopics recommended i n the 1979 Procedures but not included i n e a r l i e r reports; for example, groundwater and the c o n t r o l and monitoring of e f f l u e n t and drainage. d) The apparent a n a l y t i c a l framework i n the 1979/1980 reports d i f f e r s from the a n a l y t i c a l framework evident i n both the 1979 Procedures and the 1981/1983 reports. e) The Terms of Reference address the same major environmental topics recommended i n the 1979 Procedures but also include some subtopics not previously recommended (eg. acid generation p o t e n t i a l ) . 5.2.2 I d e n t i f i c a t i o n of A n a l y t i c a l Weaknesses Based on the review of a n a l y t i c a l approaches and methods i n Chapter 3.0, the information and methods used i n the Stage I reports and TOR's was examined using the following categories: a) Conceptualization of i n t e r a c t i o n between the mine and f i s h e r i e s resources b) I d e n t i f i c a t i o n and d e s c r i p t i o n of important f i s h e r i e s resources c) I d e n t i f i c a t i o n of sources of e f f e c t d) Development of measures to protect the important f i s h e r i e s resources e) Conclusions and i n t e r p r e t a t i o n s of impact For each t o p i c , the information and methods found i n the reports were compared to t h e o r e t i c a l concepts and methods described i n the EIA l i t e r a t u r e (Chapter 3.0). In addition, the information i n the reports was compared to information used i n post-start-up studies. The types of information c o l l e c t e d i n the post-start-up studies i s summarized i n Appendix IV. 73 The type of information and a n a l y t i c a l methods used i n the f i v e pre-development assessments and i n the two recent Terms of Reference are examined, respectively, i n subsections 5.2.2.1 and 5.2.2.2. 5.2.2.1 Five Pre-development Assessments a) Conceptualization of Mine-fisheries Interaction No report presented a conceptual outline of the type of i n t e r a c t i o n expected between the mine and f i s h e r i e s or other aquatic resources. b) I d e n t i f i c a t i o n and Description of Important F i s h e r i e s Resources i . Factors Considered The f i s h e r i e s resource features considered i n each report are summarized i n Table 5-2. Related aquatic resource features such as hydrology and water q u a l i t y were described i n a l l reports, but i n most cases were treated as separate resource features and were not discussed i n r e l a t i o n to nearby f i s h e r i e s resources. In most reports, the important salmonids known to use the larger r i v e r systems and at le a s t one type of related f i s h e r y (eg. sport) are i d e n t i f i e d and, i n some cases, escapement figures are presented. For three reports (Ladner Creek, Summit Lake and Blackdome), f i e l d studies were conducted i n t r i b u t a r i e s near the minesite to i d e n t i f y what f i s h species were present and to provide d e t a i l s on the physical habitat features of nearby streams (for one report, Baker, aquatic f i e l d studies were conducted but f i s h data were not c o l l e c t e d ) . I n t e r e s t i n g l y , even with t h i s d e t a i l , the locatio n s of c r i t i c a l habitat types (eg. spawning and rearing areas) and timing of f i s h use were generally not s p e c i f i e d . i i . Information Sources and A n a l y t i c a l Methods The sources of information and a n a l y t i c a l methods evident i n the reports are examined i n r e l a t i o n to the a n a l y t i c a l features outlined i n Step 2 of Chapter 3.0 (section 3.2). Four reports (Baker, Ladner Creek, Summit Lake, Blackdome) obtained information from p r o v i n c i a l , federal and/or Table 5.2 F i s h e r i e s resource features considered i n each r e p o r t . Report (Year) •  Ladner Creek (1979) Baker (1980) Summit Lake (1980) Free Gold (1981) Blackdome (1983) F i n l a y R i v e r : - species present Main River Systems Coqu i h a l l a R i v e r : - species present - steelhead importance and t i m i n g - r e c r e a t i o n a l c a p a b i l i t y T r i b u t a r i e s Near M i n e s i t e 1 - p o s s i b i l i t y of - species i d e n t i f i c -a t i o n - l e n g t h , weight and c o n d i t i o n f a c t o r , and general l i f e h i s t o r y information - h a b i t a t types - water q u a l i t y ( p h y s i c a l h a b i t a t ) 2 (aquatic i n v e r t e b r a t e community) 2 f i s h usage (aquatic i n v e r t -ebrate community) 2 Salmon R i v e r : - commercial and sport f i s h e r i e s - anadromous and resident species - nearest expected spawning d e t a i l e d h a b i t a t features and h a b i t a t t y p e s 3 salmon escapements changes i n hydrology 3 water q u a l i t y 3 B u l k l e y R i v e r : - q u a l i t y of r e g i o n a l s t e e l -head f i s h i n g p o s s i b l e salmonid species nearest expected spawning Fraser R i v e r : - anadromous and re s i d e n t species - salmon escapements - nati v e food f i s h e r y - sport f i s h s pecies and s t a t u s - steelhead timing - d e t a i l e d h a b i t a t features - salmon escapements - steelhead s t a t u s - species i d e n t i f i c -a t i o n - water q u a l i t y 1 f i e l d s t u d i e s were conducted at a l l mines except Free Gold 2 t h i s information i s presented i n report but i s not discussed s p e c i f i c a l l y i n r e l a t i o n to f i s h e r i e s resources 3 t h i s information i s presented separately i n an appended subconsultant report 75 i n t e r n a t i o n a l resource agencies and from general or s i t e - s p e c i f i c l i t e r a t u r e . The sources of information discussed i n the Free Gold report are not indicated. As indicated above, f i e l d studies were conducted for four reports. The type of data obtained during these studies i s summarized i n Table 5-3. The f i e l d studies generally included d e t a i l e d habitat descriptions (based on methods used by the Ministry of Environment), f i s h c o l l e c t i o n , and water q u a l i t y sampling. In several cases benthic invertebrates were sampled. In no case i s i t evident that f i e l d studies were undertaken to f i l l s p e c i f i c gaps i n the information already a v a i l a b l e . The scope of environmental f a c t o r s chosen for d e s c r i p t i o n have been strongly influenced by the topics prescribed i n the 1979 "Procedures". The reasons for choosing s p e c i f i c environmental factors (eg. "invertebrates" or "salmonids f i s h e s " i n Aquatic Resource or F i s h e r i e s Resource Sections) are not given i n any report. Presumably, the analysts f e l t that the reasons for the choice of factors would be obvious. The important aquatic resource features a c t u a l l y referred to i n the report sections presenting impact analyses are l i s t e d i n Table 5-4. Compared to the resource features described i n the environmental section of each report, the features a c t u a l l y referred to i n the analyses are very general. In f a c t , the r e l a t i v e l y large sections describing resource features, p a r t i c u l a r l y those incorporating the r e s u l t s of f i e l d studies, do not seem necessary for i d e n t i f y i n g the features considered i n the analyses, c) I d e n t i f i c a t i o n of Sources of E f f e c t i . Sources I d e n t i f i e d The sources of possible e f f e c t i d e n t i f i e d i n the "Impact Assessment" section of each report are summarized i n Table 5-5. In terms of sources related to minesite a c t i v i t y : mine drainage water i s referred to i n three reports; development a c t i v i t i e s , acid generation and waste dumps are Table 5.3 F i e l d data obtained to describe f i s h e r i e s resource features. 1 General Feature Baker (1980) Report (Year) Ladner Creek (1979) Summit Lake 2(1980) Blackdome (1983) Physical Habitat' RAB methodology 3 RAB methodology 3 not stated but evidently RAB methodology Water Quality c o l l e c t i o n s on 2 occasions at 7 s i t e s c o l l e c t i o n s on 3 occasions at 7 s i t e s c o l l e c t i o n s on 1 occasion at 3 s i t e s c o l l e c t i o n s on 4 occasions, but at d i f f e r e n t s i t e s (a t o t a l of 10) and 2 s i t e s were sampled twice Fis h electroshocker surveys: pole seining: species i d e n t i f i c - species i d e n t i f i c -a t ion; length, weight, ation and s i z e condition factor angling: species i d e n t i f i c -ation Aquatic Invertebrates taxonomic groups, r e l a t i v e abundance, and community d i v e r s i t y taxonomic groups and r e l a t i v e abundance; authors indicate that samples retained for future calculations of d i v e r s i t y taxonomic groups 1 f i e l d sampling by the proponent was not undertaken at Free Gold 2 presented i n an appended subconsultant's report 3 RAB = Resource Analysis Branch, B.C. Ministry of Environment Table 5.4 F i s h e r i e s resource features referred to in impact analyses. Reports (Year) Ladner Creek (1979) Baker (1980) Summit lake (1980) Free Gold (1981) Blackdome (198 3) 1. "watercourses 1. "water resources" 1. "water qu a l i t y " 1. "hydrology" 1. "acceptable containing f i s h " 2. "man, animals, 2. "groundwater water q u a l i t y " f i s h " regime" 2. "hydrology of the 3. "Salmon River 3. surface water area f i s h e r y " flows on the 3. " f i s h e r i e s habitat 4. "aquatic habitats " q u a l i t y of creeks located downstream 4. " f i s h resources i n 4. "Fraser River f i s h Canyon Creek" populations Table 5.5 Sources of possible e f f e c t referred to in each impact a n a l y s i s . Category of Mining A c t i v i t y Report (Year) Ladner Creek (1979) Baker (1980) Summit Lake (198 0) Free Gold (1981) Blackdome (198 3) Minesite 1. waste dump1 1. waste dumps 1. mine water 2 1. exploration 1. development 2. mine drainage 2. acid generation a c t i v i t i e s a c t i v i t i e s 3. mine abandon- in waste rock 2. development 2. closure ment 3. mine water 3. waste dump 4. acid generation 4. mine water 5. explosives use M i l l s i t e 1. general runoff 1. t a i l i n g s 1. m i l l d i s - 1. m i l l con- 1. general run-2. t a i l i n g s pond effl u e n t charge 2 s t r u c t i o n off construction, 2. process 2. process 2. m i l l discharge 2. t a i l i n g s pond operation and chemicals chemical s p i l l s 3. t a i l i n g s pond construction, abandonment1 3. t a i l i n g s pond 3. t a i l i n g s d i s - construction discharge/ 3. process runoff/washout charge-^ and abandonment operation and chemical s p i l l s 4. t a i l i n g s 4. t a i l i n g s pond abandonment seepage seepage 3. water use/ 5. t a i l i n g s 5. broken t a i l i n g s storage abandonment l i n e s 4. acid genera-6. water use/ t i o n i n ore storage m a t e r i a l 4 5. m i l l d i s -charge Table 5.5 (Cont'd.) i Category of Report (Year) Mining A c t i v i t y Ladner Creek (1979) Baker (1980) Summit Lake (1980) Free Gold (1981) Blackdome (1983) Other 1. road construction 1. general excavation 2. road construction 3. minesite personnel (fishing) 4. sewage 5. construction material from stream beds 6. fuel, s p i l l s 1. sewage 2 2. f u e l s p i l l s 1. road construction 2. equipment use during con-s t r u c t i o n 1 acid generation tests indicated that ore waste rock and t a i l i n g s material was not acid-producing - t h i s information was not referred to i n the impact analysis, but was presented elsewhere i n the report 2 referred to i n appended subconsultant's report 3 the m i l l was to be constructed within the underground mine 4 discussed i n r e l a t i o n to t a i l i n g s discharge 80 referred to i n two reports; and, exploration a c t i v i t i e s , mine closure ( i . e . due to subsidence), and explosives use are each referred to i n one report. In terms of sources r e l a t e d to m i l l s i t e a c t i v i t y : m i l l and/or t a i l i n g s discharge i s referred to i n a l l reports; t a i l i n g s pond construction and abandonment i s referred to i n three reports; and, general s i t e runoff, process chemical s p i l l s and water use/storage are referred to i n two reports. Note that at the Summit Lake mine the m i l l was constructed within the underground mine. Problem sources i d e n t i f i e d i n only one out of four reports are: - m i l l construction a c t i v i t i e s - t a i l i n g s pond seepage - broken t a i l i n g s l i n e - a c i d generation i n ore material (discussed i n r e l a t i o n to t a i l i n g s discharge) In terms of other a c t i v i t i e s : road construction a c t i v i t i e s are i d e n t i f i e d i n two reports; and, sewage, f u e l s p i l l s and general equipment use during construction are each i d e n t i f i e d i n one report, i i . A n a l y t i c a l Methods Used The a n a l y t i c a l methods evident i n the reports are compared to the methods outlined i n Step 3 of Chapter 3.0. Descriptions of mining a c t i v i t i e s are presented i n the "Project Description" sections of each report. However, inv a r i a b l y i t i s not c l e a r that these have been systematically examined as possible sources of e f f e c t . Consequently, the manner i n which the problem-sources were determined i s not shown and reasons are not given to i n d i c a t e why some mining a c t i v i t i e s are considered more important than others. In a l l cases, the reader i s l e f t with the uncomfortable f e e l i n g that the whole picture has not been considered. The method apparent i n a l l reports can be described as "Ad Hoc", although the opportunity to use a " c h e c k l i s t " approach was a v a i l a b l e (Warner and Preston 1974; Munn 1979). Separate examinations of the phases of mining a c t i v i t y ( i . e . 81 exploration, construction/mine development, abandonment/closure) were presented i n the Blackdome report and to a l e s s e r extent i n the Free Gold report. The phases of t a i l i n g s dam a c t i v i t y were discussed i n several reports (e.g. Ladner Creek). c) Development of Measures to Protect Important F i s h e r i e s Resources As discussed i n subsection 5.2.1 (Influence of the P r o v i n c i a l Review Guidelines), the report sections that describe the types of e f f e c t and m i t i g a t i v e measures are generally small i n r e l a t i o n to other report sections. P o t e n t i a l e f f e c t s and expected e f f e c t s are not c l e a r l y separated i n most reports, and are usually discussed i n general terms with the various sources of e f f e c t and m i t i g a t i v e measures. P o t e n t i a l e f f e c t s , m i t i g a t i v e measures and expected e f f e c t s have been i d e n t i f i e d where possible f o r each report and are discussed b r i e f l y below, i n r e l a t i o n to t h e o r e t i c a l features outlined i n Step 4 of Chapter 3.0. i . Descriptions of P o t e n t i a l E f f e c t s The types of e f f e c t considered i n each report are l i s t e d i n Table 5-6. Usually important resource features were referred to i n general terms ( c f . Table 5-4) and the l i n k between the resource feature affected and p o t e n t i a l e f f e c t described i s l e f t to the judgement of the reader. The p o t e n t i a l to x i c e f f e c t s to aquatic biota were discussed i n four reports (Baker, Summit Lake, Free Gold and Blackdome) although the l e v e l s of d e t a i l varied. In the Blackdome study, actual f i s h bioassays had been conducted and the r e s u l t s were reported. For the Summit Lake report, bioassays had not been conducted but the p o t e n t i a l l e t h a l and sublethal e f f e c t s and e f f e c t s on d i f f e r e n t l i f e h i s t o r y stages were discussed i n an appended subconsultants report. In contrast, the Ladner Creek report referred to "contaminants" and " p o l l u t a n t s " , but made no reference to t o x i c i t y . A v a r i e t y of other f a c t o r s were considered i n discussions of f i s h or f i s h habitat. The d i r e c t removal or impairment of f i s h habitat was Table 5.6 The types of possible change to f i s h e r i e s resource features considered i n each impact a n a l y s i s . General Resource Feature Report i (Year) Ladner Creek ( 1 9 7 9 ) Baker ( 1 9 8 0 ) Summit Lake ( 1 9 8 0 ) Free Gold ( 1 9 8 1 ) Blackdome ( 1 9 8 3 ) Fish - habitat removal - t o x i c i t y to f i s h - t o x i c i t y of - t o x i c i t y - habitat removal - physical and - increased sport process chem- (process - t o x i c i t y of m i l l chemical p o l l - f i s h i n g e f f o r t i c a l s to f i s h : reagents) process water to utants - streambed (l e t h a l vs. - ba r r i e r s to degradation sublethal; l i f e movement history stage 1) - reduction i n - bioaccumulation 1 food - chemicals i n sediments 1 Water Quality - s i l t a t i o n - s i l t a t i o n - suspended - general q u a l i t y - s i l t a t i o n - process chem- - process chem- so l i d s - nitrogen (from i c a l s i c a l s (from - process chem- e x p l o s i v e s ) 1 (from s p i l l s ) s p i l l s ) i c a l s (from - discharged chem-- discharged - fuels s p i l l s ) i c a l s 1 chemicals - discharge chem- - discharged i c a l s chemicals Hydrology - - drainage - - groundwater - changes i n flow - alternative flows regime - surface flows 1 discussed i n appended subconsultant's report. 83 considered i n two reports; the possible e f f e c t s on food resources of f i s h , the possible bioaccumulation of metals and the p o s s i b i l i t y of increased s p o r t - f i s h i n g a c t i v i t y r e s u l t i n g from the mine presence were each discussed i n one report. The importance of i n d i r e c t e f f e c t s was not e x p l i c i t y addressed i n any report. Also, the e f f e c t s of changes i n s p e c i f i c water q u a l i t y features were often not discussed i n r e l a t i o n to f i s h e r i e s resources or human user-groups. For example, a l l reports considered the p o s s i b i l i t y of increased suspended s o l i d s and discharged chemicals but did not i n d i c a t e why t h i s was a concern. Three reports (Baker, Ladner Creek and Summit Lake) considered the p o t e n t i a l for s p i l l s of process chemicals and one report (Blackdome) considered the p o t e n t i a l for nitrogen increases from explosives use. Possible changes i n the amount of surface water flow were considered i n three reports (Baker, Free Gold, Blackdome). i i . M i t i g a t i v e Measures The problem-sources for which mit i g a t i v e measures were developed are shown i n Table 5-7. Except i n the Blackdome report, s p e c i f i c m i t i g a t i v e measures were described only for water q u a l i t y features. In the Blackdome report, measures were also described to minimize e f f e c t s on surface flow regimes. In no case i s mitigation developed to reduce a s p e c i f i e d quantitative p o t e n t i a l e f f e c t . The Ladner Creek report presents a discussion on m i t i g a t i v e "opportunities" that should be considered but does not o u t l i n e those that would be adopted. An addendum to the Ladner Creek report provides more information on t a i l i n g s dam design and s t a b i l i t y and on drainage structures to be constructed to c o n t r o l runoff. i i i . Expected E f f e c t s The expected or predicted changes to aquatic resources are summarized i n Table 5-8. The terms " e f f e c t " and "impact" were loosely applied i n the impact analyses, and i n some cases seemed to i n d i c a t e a possible change 84 Table 5.7 Sources of e f f e c t for which m i t i g a t i v e measures are described i n each impact a n a l y s i s . Ladner Baker Summit Free Blackdome Creek (1980) Lake Gold (1983) (1979) (1980) (1981) Minesite 1. exploration a c t i v i t i e s - 1 2. development a c t i v i t i e s - - - 1 1 3. waste dump runoff 3 1 1 4. mine water - 1 1 1 5. explosives use - - 1 6. mine closure - 1 - - 1 7. acid generation i n waste rock - 3 2 -M i l l s i t e 1. m i l l construction 2. m i l l discharge 3. t a i l i n g s pond: a) construction b) discharge/operation c) abandonment d) seepage e) t a i l i n g s l i n e 4. process chemical s p i l l s 5. general runoff 6. water use/storage Other 1. sewage 2. road construction 3. equipment movement 4. f u e l s p i l l s 5. minesite personnel (fishing) 1 mi t i g a t i v e measures described 2 m i t i g a t i o n stated to be unnecessary 3 i d e n t i f i e d as a source but s p e c i f i c m i t i g a t i v e measures not presented 4 designed for e x f i l t r a t i o n - - 3 1 1 1 3 1 3 - - 3 1 3 1 - - 2 3 1 - 1 1 4 - 1 - - 1 3 1 1 -3 1 - 1 1 - - 3 1 1 3 -1 1 - - 1 1 1 Table 5.8 Expected changes to f i s h e r i e s and other aquatic resources. Report (Year) Baker (1980) Summit Lake (1980) Free Gold (1981) Blackdome (1983) Fish habitat "no need for streambed - - no "adverse degradation" e f f e c t " populations "minor increase i n e f f e c t s "extremely "no impacts on these no "direc t e f f e c t " f i s h i n g pressure" u n l i k e l y " species (16 k i l o - (on Fraser River meters downstream)" populations) "residual p o t e n t i a l for impacts i s minimal" Water Quality s i l t a t i o n "problems are not "small in r e l a t i o n to - "unavoidable expected to develop" natural l e v e l s impacts short-l i v e d " discharged "non-toxic" "innocuous" - no " s i g n i f i c a n t chemicals amounts no "adverse e f f e c t s " no degradation of "receiving waters general - - "minimal e f f e c t s " -Surface Hydrology "drainage a l t e r a t i o n - "minimal e f f e c t s " "minimal adverse w i l l be minor" no e f f e c t on "the e f f e c t s " downstream flow regime" Groundwater " l i t t l e e f f e c t " 86 i n the condition of the environment and i n others to indic a t e the s i g n i f i c a n c e of the change. Descriptions of expected change i n aquatic systems were presented i n a l l reports except the Ladner Creek report. In the Ladner Creek report, areas of concern were i d e n t i f i e d but preliminary predictions were not put forward. For those reports i n which predictions were made, the descriptions were usually b r i e f , general comments on the type of chemical and /or b i o l o g i c a l change that might be expected. In a l l cases no serious changes were expected i n the receiving environment. Quantitative predictions of the magnitude of the possible e f f e c t s were not made, though undefined terms such as " l i t t l e " , "small" and "minimal" were used. Three reports made predictions i n terms of the nearest known or suspected areas u t i l i z e d by f i s h ( i e . Summit Lake, Free Gold, Blackdome). Some statements i n d i c a t e that predictions are based on the l i k e l i h o o d or r i s k of problems occurring, but uncertainty about the type and magnitude of predictions i s not e x p l i c i t l y addressed and used as a basis for further study. However, the Free Gold report i n d i c a t e s that a mine-water sedimentation pond would be constructed i f water q u a l i t y monitoring indicated a need. Note that for the cyanide problems at Baker and Summit Lake (described i n Chapter 4.0), statements i n the respective reports indicated f i r m l y that cyanide would not become a problem a f t e r treatment with a l k a l i n e c h l o r i n a t i o n . In a l l reports, neither cumulative e f f e c t s nor the kind of recovery that impacted factors i n the surrounding environment would display, once the sources of impact were removed, were discussed. S i m i l a r l y , except i n the Summit Lake report, the predictions did not d i s t i n g u i s h what the environment might be l i k e "with " the project from what i t might be l i k e "without" the project. In the Summit Lake report, possible sediment production caused by mining a c t i v i t y i s discussed i n r e l a t i o n to the high l e v e l s of sediment that 87 occur n a t u r a l l y i n downstream waters. However the natural l e v e l s are not defined. The methods or body of knowledge ( i e . professional experience, general l i t e r a t u r e etc.) by which predictions were derived were not described and i n general appear to be the professional judgement of the analysts, i v . Further Studies As indicated e a r l i e r , two reports (Baker and Summit Lake) do not o u t l i n e further studies to be conducted. Two reports (Free Gold and Blackdome) i n d i c a t e that baseline water q u a l i t y conditions are to be the subject of further study and two reports (Free Gold and Ladner Creek) i n d i c a t e further studies would be conducted to locate and design t a i l i n g s ponds. The three reports at which r e l a t i v e l y major problems developed (Baker, Ladner Creek, and Summit Lake) did not propose that water q u a l i t y be the subject of further study. Even those reports that do i n d i c a t e that baseline and on-going water q u a l i t y studies are to be conducted provide no d e t a i l s concerning the substances to be sampled nor the l o c a t i o n and frequency of sampling. e) Conclusions and Interpretations of Impact Conclusions concerning the expected severity of impacts on f i s h e r i e s and general resources are summarized i n Table 5-9. As indicated above, i n most cases i t i s not c l e a r whether analysts are describing changes i n resource features or assessing the value of those changes. However the statements i n Table 5-9 are the only summary conclusions of impact provided i n the respective reports. As with the i d e n t i f i c a t i o n of expected change i n resource features, the determination of the s i g n i f i c a n c e of impacts appears to be l a r g e l y the professional judgment of the analyst and where conclusions about s i g n i f i c a n c e are made c r i t e r i a are not presented. f ) Comparison with Post-start-up Studies Once production begins, the e f f e c t s of mining a c t i v i t y are examined by Table 5.9 Interpretations of impact presented i n each Stage I report. Report (Year) Ladner Creek (1979) Baker (1980) Summit Lake (1980) Free Gold (1981) Blackdome (1983) Fish Resources "extremely un- "there i s a "expected to have l i k e l y that t h i s p o t e n t i a l for no d i r e c t e f f e c t on [Salmon River] impact" the Fraser River could be "no impacts on f i s h populations" affected" these [known downstream] species would be expected" "the residual p o t e n t i a l for impacts i s minimal n General "major environ- - "environmental " i n s i g n i f i c a n t "the impacts on the mental impacts" impacts from the environmental physical and bio-are not expected Scottie mine and damage or land l o g i c a l resources given "due m i l l should be c o n f l i c t w i l l w i l l be minimal" attention to n e g l i g i b l e " a r i s e " mitigation pro-cedures" 89 a routine monitoring and inspection program and, where the need a r i s e s , more intensive f i e l d studies. The types of information obtained during these in v e s t i g a t i o n s i s b r i e f l y described i n Appendix IV. In general, sampling i s more frequent for the monitoring programs, compared to data c o l l e c t e d during pre-development f i e l d studies. For example, sampling frequency for t a i l i n g s ponds and outflow, mine drainage and surface receiving waters varies from once per week to once every three months. As shown i n Table IV-1 of Appendix IV, pre-development sampling i n r e c e i v i n g waters i s highly v a r i a b l e , ranging from no occassions at Free Gold to four occassions at Blackdome, Also, the monitoring programs include types of information usually not obtained during the pre-development studies (eg. bioassays and background l e v e l s of r e s i d u a l s , such as cyanide). Besides the monitoring studies at operating mines, more intensive studies are undertaken when problems are suspected. Information obtained during the intensive studies , but not presented i n pre-development assessments includes: -metallothionein l e v e l s i n f i s h l i v e r s -metal concentrations i n invertebrate t i s s u e -zooplankton (daphnia) bioassays -periphyton studies -metal content i n sediments - p a r t i c l e - s i z e s of suspended s o l i d s A n t i c i p a t i o n of post-start-up data requirements does not appear to improve i n the l a t e r pre-development studies (1979/1983), compared to the e a r l i e r ones, though differences are evident. For example, f i s h bioassays are commonly undertaken i n post-start-up studies. Pre-development bioassays are described i n the Blackdome report but not i n the e a r l i e r reports. In contrast, benthic invertebrate studies are also commonly undertaken i n post-start-up studies and are presented i n the 1979/1980 pre-development studies, but not i n the Blackdome report (or the 1981 Free Gold r e p o r t ) . 90 g) Summary i . Conceptualization of mine-fisheries i n t e r a c t i o n . General conceptualizations of mine-fisheries i n t e r a c t i o n were not presented i n the reports reviewed. i i . I d e n t i f i c a t i o n of important f i s h e r i e s resources and of sources of  e f f e c t . Important f i s h species are usually i d e n t i f i e d but descriptions of c r i t i c a l l ocations are vague. The other types of information and a n a l y t i c a l methods vary considerably amongst the reports. For example, the 1983 Blackdome report includes some f a c t o r s not found i n e a r l i e r reports (e.g. explosives use; separate consideration of the phases of mining a c t i v i t y ) , but does not include other f a c t o r s that are found i n those reports (e.g. s p i l l s of process chemicals and f u e l s ) . i i i . Development of measures to protect important f i s h e r i e s resources. The development of s p e c i f i c impact management str a t e g i e s i s d i f f i c u l t to assess because the sections presenting impact analyses are usually b r i e f and very general. In f a c t , discussions of m i t i g a t i v e measures, expected e f f e c t s , i n t e r p r e t a t i o n s of impact s i g n i f i c a n c e , and further studies were not directed at s p e c i f i c resource features and would apply regardless of the environmental reviews and studies presented i n previous report sections. i v . Comparison with post-start-up studies. The types of data and sampling frequency used i n the post-start-up studies d i f f e r from the data and sampling frequencies evident i n the pre-development reports. 5.2.2.2 Two Recent Terms of Reference for Pre-development Assessments The M i n i s t r y of Environment Terms of Reference (TOR) for the Quesnel Lake Fluorspar Project and the Nickel Plate Gold Project were reviewed. The general objectives and the information and a n a l y t i c a l requirements for managing impacts on f i s h e r i e s resources are outlined i n Appendix VB. Below, the information and a n a l y t i c a l requirements are compared to the a n a l y t i c a l methods evident, f i r s t l y , i n previous Stage I reports and, secondly, i n 91 post-start-up studies. a) Comparison with the Previous Stage I_ Assessments Whereas the Stage I reports (and the 1979 Procedures) emphasize presentation of d e s c r i p t i v e information, the TOR's emphasize "impact management planning". The type of information requested i n the TOR's i s compared below to the information a c t u a l l y presented i n previous pre-development studies. i . Conceptualization of Mine-Fisheries Interaction . As with the Stage I reports, an e x p l i c i t conceptualization of the i n t e r a c t i o n between the mine and f i s h e r i e s or other aquatic resources i s not presented; nor i s one requested. In a sense the TOR's are themselves the conceptualization. i i . I d e n t i f i c a t i o n of Important Resources . Information requested i n the TOR' but usually not presented i n previous Stage I reports includes: - f i s h habitat u t i l i z a t i o n and c a p a b i l i t y - studies of the seasonality of benthic invertebrates - q u a l i t a t i v e and quantitative sampling of the periphyton community - determination of the metal content i n f i s h muscle and of metallothionein l e v e l s i n f i s h l i v e r s - documentation of downstream water uses - groundwater studies i i i . I d e n t i f i c a t i o n of Sources of E f f e c t Information requested i n the TOR's but not evident i n the previous studies includes: - breakdown products of processing reagents - influence of b l a s t i n g agents (except for the 1983 Blackdome report) - mapping of sources of e f f l u e n t and refuse during mine development - p i p e l i n e ruptures - reagent transport - concentrate transport i v . Development of Measures to Protect Important F i s h e r i e s Resources Information requested i n the TOR' but usually not presented i n previous Stage I reports includes: 92 - P o t e n t i a l effects/Supplementary studies. Chemical analyses of p i l o t - s c a l e or laboratory m i l l t a i l i n g s ; bioassays or studies of pond supernatant t o x i c i t y (except the 1983 Blackdome report); quantities of groundwater or leachate, i f q u a l i t y i s poor; minerals i n ore that might a f f e c t cyanide destruction; reagent addition rates and locations; modelling of p a r t i c u l a t e emissions; determination of e f f l u e n t flow rates and q u a l i t y before/after treatment. Also, studies of ore r a d i o a c t i v i t y , concentrate transport across a lake, and the e f f e c t s of lake drawdown; these studies appear s p e c i f i c to the mines under review. - M i t i g a t i v e measures. Presentation of a d r a f t s u r v e i l l a n c e and supervision plan; development of s p i l l contingency plans for chemicals, o i l products and concentrates; storage of runoff and drainage water and contingencies i f storage i s exceeded; long-range, post-operating controls for mine s i t e drainage, t a i l i n g s supernatant and seepage; equipment and methods for the transport of a process chemical ( i . e . cyanide). b) Comparison with Post-start-up Studies Data c o l l e c t e d during post-start-up studies are described i n Appendix IV. Data c o l l e c t e d during post-start-up studies, outlined as pre-development requirements i n the TOR's, and not c o l l e c t e d during previous pre-development studies includes: -metallothionein l e v e l s i n f i s h l i v e r s , and - c h a r a c t e r i s t i c s of the periphyton community. Data not outlined as a pre-development requirement i n the TOR's and not c o l l e c t e d during previous pre-development studies includes: -metal concentrations i n invertebrate t i s s u e -zooplankton (Daphnia) bioassays -metal content of sediment - p a r t i c l e - s i z e s of suspended s o l i d s . c) Summary The TOR's emphasize development of impact management plans. Also, the TOR's appear to represent the government conceptualization of mine-fisheries i n t e r a c t i o n . Compared to information presented i n the previous Stage I reports, the TOR's request more information i n each of the following categories: - i d e n t i f i c a t i o n of important resources; - i d e n t i f i c a t i o n of sources of e f f e c t ; and, -measures to protect important f i s h e r i e s resources. 93 The TOR's do not request, as pre-development data, some types of information obtained during post-start-up studies. 5.3 Discussion The types of v a r i a b i l i t y amongst reports, the apparent influence of the government guidelines and procedures, and the a n a l y t i c a l weaknesses and improvements i n the pre-development studies and TOR's are discussed below. 5.3.1. V a r i a b i l i t y Amongst Stage I Reports The Stage I impact analyses are subject to several types of v a r i a b i l i t y , i n c l u d i n g : - differences i n the mine type and l o c a t i o n - differences i n the c a p a b i l i t i e s of report authors - changes i n the requirements of the review process over time C l e a r l y , the type of mine and i t s l o c a t i o n w i l l influence the s p e c i f i c project and resource features examined at a p a r t i c u l a r s i t e , but should not necessarily influence the basic a n a l y t i c a l approach and methods. In contrast, the Stage I reports were prepared by a va r i e t y of authors and the a n a l y t i c a l c a p a b i l i t i e s of each have l i k e l y influenced the q u a l i t y of the respective impact analyses. The review process imposes no r e s t r i c t i o n on who might undertake the impact analyses and, consequently, must act as a screening process both for s i t e - s p e c i f i c impact issues, and for a n a l y t i c a l q u a l i t y . As described i n Chapter 2.0, the review process has i t s e l f been evolving. Amongst the reports reviewed, one (Ladner Creek) was submitted i n the same year that the MDRP began (1979) and three were submitted shortly afterwards (Baker, Free Gold, and Summit Lake). The Blackdome report was submitted s l i g h t l y l a t e r , i n 1983. 5.3.2. Influence of the Governmental Review Guidelines The 1979 Procedures emphasize presentation of d e s c r i p t i v e information but provide l i t t l e guidance on a n a l y t i c a l requirements. In consequence analysts for Stage I reports have emphasized project and environmental descriptions and not actual analyses of impacts. 94 Since 1982, the p r o v i n c i a l resource agencies have played a more active r o l e undertaking reviews of d r a f t Stage I reports and, more recently, preparing s i t e - s p e c i f i c terms of reference for Stage I assessments (based on the submission of a development Prospectus). The recent Terms of Reference s t i l l request background information but emphasize development of impact management plans. 5.3.3 A n a l y t i c a l Weaknesses and Improvements A n a l y t i c a l weaknesses and improvements are discussed below i n terms of the conceptualization of mine-fisheries i n t e r a c t i o n (subsection 5.3.3.1), the i d e n t i f i c a t i o n of important resources at r i s k (subsection 5.3.3.2), the i d e n t i f i c a t i o n of sources of e f f e c t (subsection 5.3.3.3), and the development of mitigative measures (subsection 5.3.3.4). 5.3.3.1 Conceptualization of Mine-Fisheries Interaction A conceptual framework for examining the type of i n t e r a c t i o n expected between mining a c t i v i t i e s and features of the aquatic environment i s not e x p l i c i t i n either the Stage I reports or the TOR's. In both cases, report authors l i k e l y had t h e i r own image of what the i n t e r a c t i o n was, however these were unclear i n both types of document. As indicated i n subsection 5.2.2.2, the TOR's themselves are a type of conceptualization. However, as such, the TOR's tend to convey a somewhat d i s j o i n t e d picture of p o t e n t i a l i n t e r a c t i o n , because inormation i s categorized under topics which appear to r e f l e c t the separate branches within the M i n i s t r y of Environment ( i e . , F i s h e r i e s , Water Management, and Waste Management). The early and e x p l i c i t development of a conceptual framework for describing the i n t e r a c t i o n between a mine and the nearby aquatic environment would a s s i s t i n guiding the pre-development studies. 5.3.3.2 I d e n t i f i c a t i o n of Resources at Risk a) Defining Important Resource Features The previous Stage I reports i n general place a large emphasis on 95 describing the surrounding environment, i n f a c t , often exceeding the amounts suggested i n the 1979 Procedures. Important f i s h species and general habitat q u a l i t y are usually i d e n t i f i e d . However, the l o c a t i o n s of important habitat types and times of c r i t i c a l f i s h use are generally not presented. The recent MOE information requirements emphasize c o l l e c t i o n of the l a t t e r information and, furthermore, request information on habitat u t i l i z a t i o n and c a p a b i l i t y . However, the information needs for i d e n t i f y i n g important resources and for defining baseline conditions to be measured during follow-up project assessments are not c l e a r l y separated. Some requested information appears superfluous for i d e n t i f y i n g the l o c a t i o n of important resources and for r e f i n i n g impact management s t r a t e g i e s ; but important for monitoring changes a f t e r the mine enters production (e.g. benthic invertebrates), b) Defining Baseline Conditions for Future Assessments The type of information obtained during follow-up assessments has often not been the same as the type of information presented i n the Stage I reports. A l i m i t e d amount of water q u a l i t y information i s presented i n some Stage I reports and water q u a l i t y baseline studies are proposed for further study i n others. However, as indicated i n Appendix IV, water q u a l i t y i s only one of several factors examined during follow-up assessments. Recent MOE Terms of Reference request some information that i s currently obtained during follow-up assessments (e.g. studies of benthic invertebrates, periphyton and the enzyme metallothionein i n f i s h l i v e r ) . However, the intent or purpose of t h i s information i s not distinguished from the intent or purpose of other information, such as that directed at i d e n t i f y i n g and describing the important f i s h populations or habitat. Since the two types of information have, for the most part, d i f f e r e n t purposes t h i s should be indicated and perhaps the information should be 96 presented d i f f e r e n t l y i n the Stage I assessment. A l l information to be measured during follow-up assessments could be segregated and presented as a comprehensive package of baseline information, perhaps e n t i t l e d "Baseline E c o l o g i c a l P r o f i l e for Future Assessment". This subsection of the report would- contain a l l primary sampling information, i . e . those factors to be measured, such as water q u a l i t y , the r e l a t i v e abundance and d i v e r s i t y of benthic invertebrate species, and metal content i n sediments, invertebrates and f i s h t i s s u e etc., plus supplememtary sampling information, i . e . those f a c t o r s that might a f f e c t i n t e r p r e t a t i o n of the primary sampling information, such as stream flow and p r e c i p i t a t i o n at the time of sampling. The baseline p r o f i l e could be presented as part of the Stage I report or the studies for the baseline p r o f i l e could be outlined i n the Stage I report and the data submitted l a t e r as a separate report. In f a c t , perhaps these data should be submitted as a Stage III report, since they are required f o r both Stage I and Stage II mines. 5.3.3.3 I d e n t i f i c a t i o n of Sources of E f f e c t I d e n t i f i c a t i o n and d e s c r i p t i o n of the separate a c t i v i t i e s of a mining project are a common feature i n Stage I reports. The review of general sources of impact presented i n Appendix IA i n d i c a t e s that the types of problem associated with the d i f f e r e n t mining a c t i v i t i e s have been well studied. However, i n the reports reviewed, the use of project d e s c r i p t i o n information as a basis for systematically examining sources of possible e f f e c t i s generally not evident. The l i s t of project topics outlined i n the 1979 "Procedures" provides an opportunity to use a simple c h e c k l i s t approach for examining possible sources of e f f e c t , but t h i s opportunity does not appear to have been used. Although some possible sources (e.g. access roads, sewage, t a i l i n g s l i n e s ) were perhaps f e l t by analysts to be of no further concern, there i s no i n d i c a t i o n i n some Stage I reports that they were even considered. The TOR's act as a preassessment of sources of e f f e c t . 97 Apart from the lack of systematic examinations of possible sources of e f f e c t , the Stage I studies appear weak i n three general areas. These are: the assessment of the l i k e l i h o o d that equipment or structures might f a i l (based on the r e s u l t s obtained i n Chapter 4.0); r e l a t i n g problem-sources d i r e c t l y and i n d i r e c t l y to s p e c i f i c resources at r i s k ; and e x p l i c i t consideration of the d i f f e r e n t phases of mining a c t i v i t y . These topics are b r i e f l y discussed below. a) Assessment of the Likelihood that Equipment or Structures might F a i l Emergency s i t u a t i o n s r e l a t i n g to equipment f a i l u r e and/or human error appear to be common causes of problems ( c f . Chapter 4.0), but are usually not well considered i n pre-development assessments. Recent MOE information requirements emphasize the need for preventative measures and contingency plans f o r some a c t i v i t i e s (e.g. s p i l l s of process chemicals). Nonetheless, a need i s apparent for a systematic a p p r a i s a l of a l l mining a c t i v i t i e s as po t e n t i a l problem sources, including the r i s k of f a i l u r e or breakdown of some features. b) Relating Problem-sources to Resources at Risk This would l i k e l y be improved by developing a conceptual model of the mine-fisheries i n t e r a c t i o n , as discussed above. Two a d d i t i o n a l a n a l y t i c a l techniques could be used. An impact matrix (Munn 1979)could be used to examine possible i n d i r e c t e f f e c t s as long as the matrix i s kept manageable and applied to a s p e c i f i e d resource feature (e.g. salmonid f i s h ) . S i m i l a r l y , "worst-case" scenarios could be developed to assess the possible severity of e f f e c t s on the s p e c i f i e d resource features. c) E x p l i c i t Consideration of D i f f e r e n t Phases of Mining A c t i v i t y In general, the l i t e r a t u r e describing possible e f f e c t s of mining a c t i v i t y on the environment in d i c a t e s that the separate phases of mining a c t i v i t y should be addressed. This has either not been done or done only to a l i m i t e d extent i n the reports reviewed. As described i n Appendix I, the 98 various mining a c t i v i t i e s can be grouped according to the stages of development that w i l l occur for the mine (e.g. Pre-production, Production, Post-production). Ripley et al.1978 divided the a c t i v i t i e s associated with the development of a mine in t o s i x phases: exploration, development, ext r a c t i o n , b e n e f i c i a t i o n ( i . e . m i l l i n g ) further processing ( i . e . smelting and r e f i n i n g ) , and reclamation and abandonment. Ripley et a l . and other authors (e.g. Marshall 1982) usually portray, g r a p h i c a l l y , these phases of mining a c t i v i t y as d i s c r e t e components of a continuous process. Such a portrayal might be appropriate for presenting a d e s c r i p t i o n of ore treatment by a mine, but I f e e l i t i s inappropriate as a conceptual framework for i n t e r p r e t i n g sources of impact. The phases of mining a c t i v i t y are not temporally d i s c r e t e and s u b s t a n t i a l overlap can occur; a more r e a l i s t i c conceptualization i s shown i n Figure 5-2. This i n turn can a f f e c t how one v i s u a l i z e s p o t e n t i a l impacts. For example, "exploration" i s not necessarily discontinued once "development" i s started, and on-going exploration a c t i v i t i e s might not only provide d i r e c t sources of impact but, i f new ore reserves are found, might extend the l i f e of the mine and m i l l i n g operations and thereby a l t e r the time frame of the EIA. In f a c t t h i s conceptualization shows that impact management planning should begin before "exploration" , and not once development has begun. 5.3.3.4 Development of M i t i g a t i v e Measures In most Stage I reports, the actual analysis of impacts was b r i e f and general. The analyses were not used as a focus to i d e n t i f y outstanding un c e r t a i n t i e s that should be addressed through more intensive study. The i d e n t i f i c a t i o n of p o t e n t i a l e f f e c t s , choice of m i t i g a t i v e measures and management of emergencies are b r i e f l y discussed below, a) I d e n t i f i c a t i o n of P o t e n t i a l E f f e c t s For understanding the p o t e n t i a l e f f e c t s and designing appropriate Figure 5.2 The general phases of mining a c t i v i t y in r e l a t i o n to the stages of mine production. Time Axis Stage of Production Phases of Mining A c t i v i t y PRE-PRODUCTION Exploration y» Development (on-going) (removal of unwanted material) Reclamation (on-going) Extraction B e n e f i c i a t i o n Further Processing PRODUCTION POST-PRODUCTION Abandonment KO KO 100 miti g a t i v e measures, recent MOE Terms of Reference emphasize the need to determine acutely t o x i c e f f e c t s to f i s h . These e f f e c t s are generally easier to recognize and i n t e r p r e t than sublethal and chronic e f f e c t s . However, some factors that l i k e l y w i l l be assessed l a t e r during the "follow-up assessments", such as metal content i n f i s h l i v e r s and invertebrates are l i k e l y to i n d i c a t e the sublethal or chronic e f f e c t s (e.g. bioaccumulation of metals). These differences i n e f f e c t and t h e i r importance are not c l e a r l y explained i n the MOE information requirements nor e x p l i c i t l y considered i n previous Stage I reports. As discussed above i n subsection 5.3.3.2 ( I d e n t i f i c a t i o n of Resources at Risk), t h i s information should be c l e a r l y separated from information used to i d e n t i f y important resource features or to enhance predictions of e f f e c t s . b) Choice of M i t i g a t i v e Measures In the three Stage I reports where the impact analysts described a treatment method and assumed that the method would t o t a l l y remove the problem ( i . e . cyanide removal at Baker, Ladner Creek and Summit Lake), t h i s assumption proved to be i n c o r r e c t . I f the analysts had assumed i n i t i a l l y that the chosen method might not work, they possibly would have assessed a l t e r n a t i v e treatment methods or developed an adaptive approach to improving or replacing the treatment method. The use of adaptive s t r a t e g i e s f or EIA i s discussed i n Chapter 3.0. Compared to most Stage I reports examined, an experimental approach to development of mit i g a t i v e measures i s evident i n both a recent Stage I report (Blackdome) and the TOR's. For the Stage I report, m i l l - e f f l u e n t discharge was simulated and the need for further treatment assessed. The 1984 MOE Terms of Reference for the Quesnel Lake mine, in d i c a t e that a s i m i l a r approach be undertaken. c) Management of Emergencies Most impact management e f f o r t s appear directed at the e a s i l y 101 i d e n t i f i a b l e routine or chronic discharge sources. However, as shown by the r e s u l t s i n Section 4.0, greater emphasis must be placed on managing "emergencies" due to s t r u c t u r a l or equipment f a i l u r e . In p a r t i c u l a r , improved designs and/or operating procedures are required f or t a i l i n g s l i n e s and pumps. The TOR's indic a t e a large improvement i n contingency planning, requesting that contingency plans be prepared for possible ruptures i n t a i l i n g s l i n e s , accidents, chemical and f u e l s p i l l s , concentrate s p i l l s during transport, and overflows of stored runoff and drainage water. However the TOR's do not describe what i s expected i n the plans. 5.4 Conclusions 5.4.1 Influence of the Review Guidelines. 1. The a n a l y t i c a l methods used i n Stage I reports have been strongly influenced by the 1979 "Procedures" prepared by the B.C. Mini s t r y of Energy, Mines and Petroleum Resources. However, the Procedures provided poor guidance on how impact analyses were to be used for developing impact management measures. Consequently, the Stage I reports are b a s i c a l l y descriptions of the project a c t i v i t i e s and of the surrounding environment. 2. The review process imposes no r e s t r i c t i o n s on who might undertake the impact analyses and, consequently, must act as a screening process both for s i t e - s p e c i f i c impact issues, and for a n a l y t i c a l q u a l i t y . The review agencies evidently f e e l Stage I reports prepared using the 1979 "Procedures" have not been adequate, and that dr a f t reviews and/or s i t e s p e c i f i c terms of reference are necessary. This d i r e c t p a r t i c i p a t i o n i n the a n a l y t i c a l process suggests a s h i f t i n at l e a s t some of the cost of analyses from the mine proponent to the pu b l i c . 5.4.2 A n a l y t i c a l Weaknesses and Recent Improvements 1. Development of M i t i g a t i v e Measures Stage I_ Reports . Problems at minesites and weaknesses i n Stage I reports have been mainly re l a t e d to the assumption that m i t i g a t i v e measures 102 w i l l work and to the f a i l u r e of equipment or structures. A n a l y t i c a l weaknesses include: - the absence of a c r i t i c a l a p p r a i sal of impact management measures i n order to develop a contingency or f a l l - b a c k strategy; - no assessment of the l i k e l i h o o d that equipment or structures might f a i l and development of contingency plans to deal with these emergencies. Terms of Reference . The TOR's appear to address the problems of equipment and s t r u c t u r a l f a i l u r e , by recommending i n some instances the preparation of contingency plans. However, the TOR's do not i n d i c a t e what fac t o r s should be included i n the coningency plans. Also, the TOR's do not emphasize the basic assumption that m i t i g a t i v e measures might not work, so that f a l l - b a c k m i t i g a t i v e s t r a t e g i e s might be developed i n case the chosen measure i s eventually found to be inadequate. 2. I d e n t i f i c a t i o n of Sources of E f f e c t . Stage I_ reports . The main a n a l y t i c a l weaknesses include: - the absence of a systematic assessment of project a c t i v i t i e s as sources of p o t e n t i a l impact; and, - an apparent bias i n both pre-development and post-start-up studies towards examining routine sources as opposed to emergency sources. Terms of Reference . Systematic appraisals of p o t e n t i a l sources of e f f e c t are not evident i n the TOR's, but the types of sources that should be considered are described. The TOR's i n a sense, act as pre-assessments of such p o t e n t i a l sources. 3. I d e n t i f i c a t i o n of Resources at Risk Stage I_ reports . The main a n a l y t i c a l weaknesses include: - poor i d e n t i f i c a t i o n of s p e c i f i c resources at r i s k and types of e f f e c t expected;and, - no i n d i c a t i o n of the amount of e f f e c t expected without mitigation and with m i t i g a t i o n . Terms of Reference . The TOR's out l i n e information requirements that should better define what resources are at r i s k , compared to information 103 presented i n previous Stage I reports. However, a clear d e s c r i p t i o n of the linkages between the mines and important f i s h e r i e s resources i s presented i n neither the Stage I reports nor the TOR's. Impact management planning i s c l e a r l y the intent of the MOE terms of reference but what impacts are being managed and why are not c l e a r because the management str a t e g i e s are i d e n t i f i e d f or separate but r e l a t e d facets of the aquatic environment ( i e . "Waste","Surface Water Quality", " F i s h " e t c ) . These categories appear to r e f l e c t the i n t e r e s t s of branches within the M i n i s t r y of Environment and perhaps represent a somewhat d i s j o i n t e d approach to managing impacts on the aquatic environment. Like the previous Stage I reports, the TOR's do not suggest defining the amount of e f f e c t that could occur without mitigation ( i . e . the possible worst-case s i t u a t i o n ) . 4. D e f i n i t i o n of Baseline Conditions for Future Studies Stage I reports . A n a l y t i c a l weaknesses include: - poorly defined quantitative information that could be used as a baseline for future monitoring, or d e t a i l s of what information would be c o l l e c t e d as baseline information; and, - the c o l l e c t i o n of information during assessments a f t e r mines began operation that d i f f e r e d from data c o l l e c t e d as baseline during pre-development assessments. Terms of Reference . The TOR's suggest c o l l e c t i o n of more information (compared to previous Stage I reports) that l i k e l y can be used as baseline data for monitoring, and that has been c o l l e c t e d recently during post start-up assessments. However, the TOR's s t i l l do not c l e a r l y state what information i s intended as baseline and what i s intended to simply describe important resource features. 5. Procedural Considerations In general, information requested i n the TOR's appears to be mainly fa c t o r s that would be expected from any mine development and would be more appropriate as a "guidelines" document for d i s t r i b u t i o n beforehand. Some 104 form of procedural guidelines are presently being prepared. 105 CHAPTER 6.0 RECOMMENDATIONS Recommendations are presented below for possible improvements to the methods currently used for impact management planning i n r e l a t i o n to metal mine development. Recommendations are made separately for a n a l y t i c a l and procedural improvements. 6.1 A n a l y t i c a l Improvements An a n a l y t i c a l framework for examining the e f f e c t s of mine development on aquatic resources i s shown i n Figure 6-1. The recommendations made below are for each component shown i n the a n a l y t i c a l framework. 1. Conceptualization of Interaction Between The Mine and The Aquatic  Environment Neither the Stage I reports nor the government terms of reference present c l e a r descriptions of the linkages between mining a c t i v i t i e s and the important aquatic resources that might be a f f e c t e d . An early and e x p l i c i t d e s c r i p t i o n of these linkages would help to f a c i l i t a t e discussions between government te c h n i c a l s t a f f and the mine proponent, and to guide the ensuing studies. 2. I d e n t i f i c a t i o n of Important Resources at Risk a) A n t i c i p a t i o n of Follow-up Studies The TOR's do not c l e a r l y define what impacts are being managed and why because separate management st r a t e g i e s are recommended for the separate but re l a t e d facets of the aquatic environment ( i e . "Waste"."Surface Water Quality", " F i s h " e t c ) . These should be synthesized into a s i n g l e impact management plan, so that the important resources f e l t to be impacted are c l e a r l y i d e n t i f i e d and the planning and monitoring of m i t i g a t i v e measures at the problem-source are linked to the resource at r i s k . b) D e f i n i t i o n of Baseline Conditions Reports submitted by proponents should contain a new section, "Baseline 106 Figure 6.1 An a n a l y t i c a l framework for undertaking impact management planning at new metal mine developments i n B r i t i s h Columbia. PRE-STAGE STAGE I STAGE II STAGE I I I CONCEPTUALIZATION OF INTERACTION IDENTIFICATION OF IMPORTANT RESOURCES IDENTIFICATION OF SOURCES AND TYPES OF EFFECT DEVELOPMENT OF MITIGATIVE MEASURES \1/ (REFINEMENT, IF NECESSARY) DEFINE  BASELINE CONDITIONS IMPLEMENT MEASURES \ 1 / A VERIFY MEASURES  (ADAPT, IF NECESSARY) 107 Conditions", that c l e a r l y defines information that has been or w i l l be c o l l e c t e d f or use during follow-up assessments, or t h i s information should be submitted as a supplement. In f a c t , as shown i n Figure 6 - 1 q u a n t i t a t i v e baseline data could be submitted as a separate Stage III report. 3. I d e n t i f i c a t i o n of Sources of E f f e c t The use of a formal c h e c k l i s t or abbreviated matrices ( i e . directed at s p e c i f i c resource features) would help both the analyst and reviewer determine whether a l l p o t e n t i a l impact sources were examined. 4. Other Improvements to Report Format Stage I reports should emphasize information required to develop management str a t e g i e s and should reduce the amount of d e s c r i p t i v e material. "Project" sections should summarize what sources of e f f e c t have been i d e n t i f i e d and "Environmental" sections should summarize what important resources are at r i s k . 5. Development of M i t i g a t i v e Measures a) Analysis of Alternate Management Strategies As shown i n Figure 6-1, impact management str a t e g i e s might have to be a l t e r e d , i f a problem develops a f t e r production begins. M i t i g a t i v e measures should not be assumed to work and alternate or " f a l l - b a c k " measures should be assessed and put forward i n the event that the chosen methods do not work. The development of "worst-case" scenarios might a s s i s t to i d e n t i f y the type and amount of mitigation necessary. b) Emergency Contingency Planning Based on the r e s u l t s shown i n Chapter 4.0, increased emphasis should be placed on i d e n t i f y i n g and planning for problems r e l a t i n g to equipment and s t r u c t u r a l f a i l u r e , including the development of contingency plans. The government terms of reference request some kinds of contingency planning, but do not describe what i s expected i n such plans. The contents of the contingency plans should be defined. Also, i n some cases, r i s k - o f - f a i l u r e 108 studies and "what-if" scenarios could be used to examine the l i k e l i h o o d and implications of equipment or s t r u c t u r a l f a i l u r e s , p a r t i c u l a r l y t a i l i n g s l i n e s and pumps. 6.2 Procedural Improvements An opportunity i s apparent f o r the mining industry to undertake a stronger r o l e i n the development of a n a l y t i c a l standards for impact assessment, both to absorb some of the costs of developing assessment procedures and to increase understanding amongst proponents as to the kind of a n a l y t i c a l and impact problems that e x i s t . This could perhaps be undertaken by an e x i s t i n g organization such as the Mining Association of B.C. Possible a c t i v i t i e s are: - the development of a screening or c e r t i f i c a t i o n system so that impact analysts are known to have a s p e c i a l i s t c a p a b i l i t y , both i n impact assessment and i n mine development problems; - the undertaking of annual audits of problems so that improvements i n miti g a t i v e measures, p r e d i c t i v e analyses and monitoring methods can be developed; and, - the development of a Code of Good Practice both f o r impact analysis and for use by mine operators during the development and operation of the mine. 109 REFERENCES Beak Consultants Limited. 1976. Sam Goosly Project Stage I I : d e t a i l e d assessment. A report for Equity Mining Corporation. September 1976. 79 pages plus Appendices. Beak Consultants Limited. 1977. An environmental baseline study - 1976. Chappelle Claim. Prepared for Dupont of Canada Exploration Limited. File:J5132. Beak Consultants Limited. 1982. 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A report of the Committee on Water Quality C r i t e r i a , Environmental Studies Board, National Academy of Sciences, National Academy of Engineering, Washington D.C. 594p. Crook, R. personal communication. Secretary, Metal Mines Development Review Process, B r i t i s h Columbia Ministry of Energy, Mines And Petroleum Resources. V i c t o r i a , B r i t i s h Columbia. Crook, R. 1984. Metal mines guidelines review process. Project Status 110 Summary (July,1984). In Mineral P o l i c y and Evaluation Branch, "B.C. Mineral Quarterly S t a t i s t i c s and Information F i r s t Quarter 1984 Vol.8", Province of B r i t i s h Columbia, Ministry of Energy, Mines and Petroleum Resources. Devuyst, E.A., V.A. E t t e l , G.J. Borbely and B.R. Conard. 1982. A new process for the treatment of wastewater containing cyanide and r e l a t e d species. J . Roy Gordon Research Laboratory INCO Ltd. Mississauga, Ontario. Dooley. E. 1979. A framework for environmental impact i d e n t i f i c a t i o n . J . of Environ. Mgmt 1979(9):279-287. E l l i s , D.V. 1982. Marine t a i l i n g s d i s p o s a l . Ann Arbor Science Publishers, Ann Arbor, Michigan. Environment and Land Use Committee. 1976. Guidelines for coal development. B r i t i s h Columbia Environment and Land Use Committee. V i c t o r i a , B.C. March 1976. 33p. Environmental Protection Service. 1977. Metal mining l i q u i d e f f l u e n t regulations and guidelines. F i s h e r i e s and Environmental Protection Service, Water P o l l u t i o n Control Directorate. Report EPS l-wp-77-1. A p r i l 1977. 45p. European Inland F i s h e r i e s Commission. 1965. Working Party on Water qu a l i t y c r i t e r i a for European freshwater f i s h (1965), Report on f i n e l y divided s o l i d s and inland f i s h e r i e s . A i r Water P o l l u t . 9(3): 151-168. Gore, K.L., J.M. Thomas and D.G. Watson. 1979. Quantitative evaluation of environmental impact assessment, based on aquatic monitoring programs at three nuclear power plants. J . of Environ. Mgmt.(1979)8:1-7. Hallam, R.L. 1980. C a r o l i n Mines Ltd. Aurum Mine, Ladner Creek, Hope, B.C. Notes from a review of aquatic environmental information, s i t e inspection and preliminary water q u a l i t y survey conducted September 16, 1980. Department of Environment, Environmental Protection service, P a c i f i c Region. Hallam, R. and Kussat, R.H. 1974. A b i o l o g i c a l survey of the watershed adjacent to a proposed mine s i t e near Houston, B.C. Environmental Protection Service Surveillance Report No. EPS 5-PR-74-4. Hallam, R.L., R.H.Kussat and M.Jones.1975. Environmental impact information of the proposed Equity Mining C a p i t a l Ltd. development near Houston, B r i t i s h Columbia. P o l l u t i o n Abatement Branch, Environmental Protection Service, P a c i f i c Region, Environment Canada, Manuscript Report 75-1. H a t f i e l d Consultants Ltd. 1983. A review of probable e f f e c t s of Equity S i l v e r Mines Ltd. e f f l u e n t on f i s h resources of the Buck Creek system i n c e n t r a l B r i t i s h Columbia. IEC International Environmental Consultants Ltd. 1982. An independent review of the Equity S i l v e r Mine Ltd. operations with I l l recommendations for changes i n the scope of the environmental program. Prepared for Equity S i l v e r Mines Ltd. IEC Beak. 1983. Benthic invertebrate studies i n Galen Creek - 1983. A report prepared for Dupont of Canada Exploration Limited. Vancouver, B.C. H o l l i n g , C.S.(Ed.). 1978. Adaptive environmental assessment and management. International I n s t i t u t e for Applied Systems Analysis, International Series on Applied Systems Analysis No.3. John Wiley and Sons. 377p. Lang, R., and A. Armour. 1977. The process of environmental assessment: making i t work for Canada. In M. Plewes and J.B.R. Whitney (Eds) Environmental Impact Assessment i n Canada: Processes and Approaches Proceedings of a Symposium held at I n s t i t u t e f o r Environmental Studies, February 1977. Pub.No.EE-5. pp.15-30. McDonald, J . 1984. Memorandum, to a l l p a r t i c i p a n t s , Coal Guidelines Review Process and Metal Mines Guidelines Review Process. Re: Revisions to Mine Development Review Process. B.C. Min i s t r y of Energy, Mines and Petroleum Resources. 9p. McNeely, R.N., V.P. Neimanis and L. Dwyer. 1979. Water q u a l i t y sourcebook. A guide to water q u a l i t y parameters. Inland Waters Directorate, Water Quality Branch, Environment Canada. Ottawa. Marshall, I.B. 1982. Mining, land use, and the environment: A Canadian Overview. Lands Directorate, Environment Canada. Ottawa 1982. 280p. Ministry of Energy, Mines and Petroleum Resources. 1979. Procedures for obtaining approval of metal mine development. A p r i l 1979. Province of B r i t i s h Columbia. Min i s t r y of Energy, Mines and Petroleum Resources. 38p Moore, B. 1984. C a r o l i n Mines Ltd. PE-5692. Environmental Impact Assessment 1984. Environmental Section, Region 2 Waste Management. Munn, R.E. (Ed.). 1979. Environmental Impact Assessment. P r i n c i p l e s and Procedures. SCOPE 5 (Second E d i t i o n ) . John Wiley & Sons, Toronto. 190p. Northern Miner Press Limited. 1984. Canadian Mines Handbook 1984-85. Northern Miner Press Limited, Toronto, Ontario. O'Riordan, J . 1981. The B r i t i s h Columbia Experience. In T.O'Riordan and W.R.W. Sewell Project Appraisal and P o l i c y Review. John Wiley & Sons Ltd. pp.95-123. Osborne, V. and B. Hallam. 1982. Summary of environmental information for the Equity S i l v e r Mine. Environmental Protection Branch. Environmental Protection Service, P a c i f i c Region. Poling, G.W. 1977. Treatment of mineral industry e f f l u e n t s i n B r i t i s h Columbia. In J.B. Stephenson (Ed.) The P r a c t i c a l Application of Economic Incentives to the Control of P o l l u t i o n : The Case of B r i t i s h Columbia. Conference on Economic Incentives for A i r and Water 112 P o l l u t i o n Control, V i c t o r i a , 1974. University of B r i t i s h Columbia Press, Vancouver, B.C. pp.47-82. P o l l u t i o n Control Board. 1979. P o l l u t i o n c o n t r o l objectives f o r the mining, smelting, and rela t e d i n d u s t r i e s of B r i t i s h Columbia. Minis t r y of Environment, P o l l u t i o n Control Board. 15p. P o l l u t i o n Control Branch. 1973. Report on P o l l u t i o n c o n t r o l objectives for the mining, mine-milling and smelting i n d u s t r i e s of B r i t i s h Columbia as a r e s u l t of a public inquiry held by the Director of the P o l l u t i o n Control Branch. Province of B r i t i s h Columbia, Department of Lands, Forests, and Water Resources, Water Resources Service, V i c t o r i a , B.C. 25p. Ripley, E.A., R.E. Redmann and J . Maxwell. 1978. Environmental impact of mining i n Canada. Centre for Resource Studies, Queen's Uni v e r s i t y , Kingston, Ontario. 284p. Roots, E.F. 1977. Mining, environment and c o n t r o l . In J.B.Stephpenson (Ed.) The P r a c t i c a l A p p l i c a t i o n of Economic Incentives to the Control of P o l l u t i o n : The Case of B r i t i s h Columbia. Conference on Economic Incentives f or A i r and Water P o l l u t i o n Control, V i c t o r i a 1974. University of B r i t i s h Columbia Press, Vancouver, B.C. pp.83-104. Rosenberg, D.M, V.H.Resh et a l . 1981. Recent trends i n environmental impact assessment. Can. J . F i s h . Aquat. S c i . 38:591-624. Schindler, W. 1976. The impact statement boondoggle. Science 192(4239):509. Scott, J.S., and K. Bragg (Eds). 1975. Mine and m i l l wastewater treatment. By Water P o l l u t i o n Control Directorate s t a f f i n cooperation with the Treatment Working Group of the Mining Regulations Task Force. Environment Canada, Environmental Protection Service, Water P o l l u t i o n Control Directorate. Economic and Technical Review Report EPS 3-WP-75-5. 141p. Skal s k i , J.R., and D.H. McKenzie. 1982. A design for aquatic monitoring programs. J . of Environ. Mgmt 1982(14):pp.237-251. Ward, D.V. 1978. B i o l o g i c a l environmental impact studies: theory and methods. Academic Press, New York. 157p. Warner, M.L. and E.H. Preston. 1974. A review of environmental impact assessment methodologies. O f f i c e of Research and Development, U.S. Enviromental Protection Agency, Washington D.C. Socioeconomic Environmental Studies Series EPA-60015-74-002. 27p. 113 APPENDICES 114 APPENDIX I. An Overview of the General Sources and Types of Impact from Metal Mines This appendix provides a brief description of the general sources and types of impact from metal mine development, particularly in relation to the mines examined in Chapter 4.0.The general sources of impact are reviewed in Section A and the types of effect that can occur in relation to fisheries resources are reviewed in Section B. A. General Sources and Types of Impact from Metal Mines To f a c i l i t a t e a comprehensive examination of the impacts produced by mining operations, Ripley et; al_ 1978 divided mining activity into six sequential phases: " i exploration , which may consist of geochemical or geophysical techniques, followed by the d r i l l i n g of promising targets and delineation of orebodies; i i mine development , or preparing the mine for production by shaft sinking or pit excavation, building of access roads, and construction of surface f a c i l i t i e s ; i i i the ore-removal act i v i t i e s which take place at the minesite i t s e l f ; namely extraction and primary comminution (or crushing); iv that which takes place at a mill usually located not far from the mine site and where a large fraction of the gangue from the ore i s removed; namely, beneficiation or concentration; v further processing , which may be carried out at any distance from the mine and results in the production of the f i n a l desired element or compound. This phase may involve a number of stages and be carried out at a number of locations: for the purpose of this study, only that processing carried out, in Canada, near the mine or mill w i l l be considered; and v i since every orebody i s f i n i t e , the f i n a l phases are those of reclamation and abandonment ." In terms of mine production, exploration and development can be considered pre-production act i v i t i e s ; extraction, beneficiation and further processing (ie. smelting and refining) can be considered production a c t i v i t i e s ; abandonment can be considered post-production a c t i v i t i e s . Reclamation can begin during pre-production a c t i v i t i e s and continue well into abandonment. The general types of impact that can result during the various phases of mining activity are described below for each phase. The descriptions are based mainly on information provided in Ripley e_t a l 1978 and Marshall 1982. Although "Further Processing" of ore during the smelting and refining stages can lead to important pollution problems, i t i s not usually a component of mine development proposals. In most cases, ore concentrates are shipped to established local smelters (eg. the Cominco smelter at T r a i l B.C.) or direct to overseas markets. However, one category of "Further Processing", hydrometallurgy, is briefly discussed because i t often takes place at the minesite and one type of hydrometallurgy (cyanidation) i s used at a number of mines reviewed in Section 3.0 of the text. 115 1.0 Exploration Phase During mineral exploration, the major e f f e c t s on the aquatic environment r e s u l t from the disturbance to land caused by the development and use of access roads. In p a r t i c u l a r , road construction and operation can lead to the production of sediment from the erosion of cleared rights-of-way, stream crossings and borrow p i t s . Once produced, the sediments from these sources might enter nearby lakes and streams. I f s o i l overburden i s removed from underlying bedrock during the exploration phase, sediments might also be produced by the erosion of overburden s t o c k p i l e s . In a d dition, d r i l l i n g operations and the mechanical removal of overburden can produce va r i a b l e amounts of o i l s and greases, suspended s o l i d s , heavy metals, and a c i d i c waste waters. 2.0 Development Phase P r i o r to the extraction of ore, the ore deposit must be exposed, eit h e r by penetrating layers of non-ore rock with shafts and tunnels, i n the case of underground mining, or by the complete removal of non-ore bearing material (both s o i l overburden and non-ore rock) i n the case of surface mining. The amount of disturbance caused by the two kinds of mine development can d i f f e r ; i n general, surface mining disturbs a larger land area and produces much more waste material than underground mining. Regardless of the kind of mine development, the possible sources of disturbance to aquatic systems include the drainage from waste rock stoc k p i l e s ( the chemical composition of the waste rock can a f f e c t the chemistry of drainage water), the s o i l erosion from disturbed land surfaces and the waste material produced both by an increased work force (eg. refuse, sewage) and by the use of heavy equipment (eg. o i l s , greases and hydraulic f l u i d s ) . 3.0 Extraction Phase Once overburden and wasterock have been removed to provide access to ore bodies and the extraction of ore begins, the production of waste rock becomes a continual feature of the extraction process. As during the development phase, the amount of waste rock produced during the extraction phase by surface mining i s generally greater than by underground mining ( i n f a c t , the amount i s approximately 50 times greater; Ripley 1978). B a s i c a l l y , the sources of possible disturbance to aquatic systems are the same as those described f or the development phase, except that during the extraction phase, the removal of drainage water found within the mine i t s e l f becomes a new, on-going source of p o t e n t i a l disturbance. Compared to the development phase, the extraction phase i s of longer duration ( i e . for the l i f e of the mine) and, obviously, the possible e f f e c t s of mining a c t i v i t y w i l l occur over a longer time-frame, l i m i t e d by the length of time the mine remains i n operation. 4.0 B e n e f i c i a t i o n Phase After the metal ore i s extracted i t i s usually treated near the minesite to remove unwanted rock material, and to separate metal types for shipment. During t h i s phase, three general steps are followed: comminution - crushing and/or grinding of the ore to prepare the ore material for further treatment by reducing the siz e of rock p a r t i c l e s concentration - the separation of target metal.types from other metal types and from waste material ( i e . t a i l i n g s ) dewatering - removal of water from the concentrate 116 p r i o r t o shipment I n r e l a t i o n t o p o t e n t i a l i m p a c t s on a q u a t i c e c o s y s t e m s , t h e l a t t e r two s t e p s a r e g e n e r a l l y more i m p o r t a n t t h a n t h e f i r s t . The c r u s h e r s and g r i n d e r s used d u r i n g comminution can produce q u a n t i t i e s o f d u s t but u n l e s s d u s t p r o d u c t i o n i s i n s u f f i c i e n t amounts t o a f f e c t t h e d r a i n a g e s o f nearby w a t e r b o d i e s , t h e p o t e n t i a l damage from d u s t w i l l be s m a l l compared t o e f f e c t s from w a s t e - w a t e r and t h e t a i l i n g s d i s c h a r g e d d u r i n g t h e c o n c e n t r a t i o n and d e w a t e r i n g s t e p s . 4.1 Waste-water D i s c h a r g e The w a t e r d i s c h a r g e d from m i l l i n g o p e r a t i o n s can c o n t a i n a v a r i e t y o f d i s s o l v e d and s o l i d r e s i d u a l s . These can i n c l u d e p r o c e s s i n g r e a g e n t s , t h i o s a l t s ( s u l p h u r based s a l t s o r i g i n a t i n g b o t h from t h e s u l p h i d e - c o n t a i n i n g o r e s t h e m s e l v e s and from r e d u c i n g - s u l p h u r compounds used i n t h e f l o a t a t i o n p r o c e s s ) , suspended s o l i d s and t h e u b i q u i t o u s d i s s o l v e d m e t a l s ( S c o t t and Bragg 1975). A l s o , as w i t h w a t e r d r a i n e d f r o m t h e mine, t h e waste w a t e r from t h e m i l l can be a c i d i c . To remove t h e v a r i o u s c o n t a m i n a n t s b e f o r e e i t h e r r e u s e i n t h e m i l l o r r e l e a s e t o t h e e n v i r o n m e n t , t h e d i s c h a r g e water i s u s u a l l y t r e a t e d i n h o l d i n g ponds w h i c h m i g h t , i n some c a s e s , be t h e t a i l i n g s pond. The amount o f w a t e r r e u s e by t h e m i l l s and t y p e of w a s t e w a t e r t r e a t m e n t system used v a r i e s g r e a t l y between mines, and depends on l o c a l c o n d i t i o n s ( s u c h as a v a i l a b l e w a t e r s u p p l i e s , amount o f p r e c i p i t a t i o n ) and t r e a t m e n t c o s t s . One t y p e o f h y d r o m e t a l l u r g y , t h e c y a n i d a t i o n p r o c e s s , o c c u r s a t most o f t h e g o l d and g o l d / s i l v e r mines r e v i e w e d i n C h a p t e r 4.0 o f t h e t e x t . I n f a c t , t h e c y a n i d a t i o n p r o c e s s i s a s s o c i a t e d w i t h t h r e e o f t h e major impact-management problems i d e n t i f i e d i n t h a t s e c t i o n . G e n e r a l l y , h y d r o m e t a l l u r g y u s e s c h e m i c a l s o l u t i o n s t o " l e a c h " o r s e p a r a t e m e t a l s from t h e o r e c o n c e n t r a t e . I n t h e c y a n i d a t i o n p r o c e s s , sodium o r c a l c i u m c y a n i d e i s used t o d i s s o l v e t h e g o l d o r s i l v e r , w h i c h i s t h e n p r e c i p i t a t e d from t h e s o l u t i o n u s i n g a z i n c o r aluminum d u s t . The p r e c i o u s m e t a l i s t h e n s e p a r a t e d from t h e p r e c i p i t a t e u s i n g h i g h t e m p e r a t u r e s ( i e . p y r o m e t a l l u r g i c a l methods). A f t e r t h e m e t a l has been removed as a p r e c i p i t a t e , t h e o r i g i n a l s o l u t i o n c o n t a i n s q u a n t i t i e s o f c y a n i d e , a p o t e n t i a l l y s e r i o u s t o x i c a n t , t h a t u s u a l l y must be r e d u c e d . The t e c h n o l o g y f o r removing l a r g e q u a n t i t i e s o f c y a n i d e i s s t i l l d e v e l o p i n g . P r e s e n t l y , a l k a l i n e c h l o r i n a t i o n i s t h e most commonly used method, though a new p r o c e s s , d e s c r i b e d as t h e S 0 2 / a i r p r o c e s s a p p e a r s c a p a b l e o f removing l a r g e r q u a n t i t i e s a t l o w e r c o s t ( D e v u y s t e t a l 1982). As shown i n C h a p t e r 4.0 o f t h e t e x t t h e a l k a l i n e c h l o r i n a t i o n p r o c e s s has n o t been adequate a t a number o f g o l d mines i n B.C. The S 0 2 / a i r p r o c e s s i s a new method d e v e l o p e d by I n t e r n a t i o n a l N i c k e l Company ( w h i c h has f i l e d a p p l i c a t i o n s t o p a t e n t t h e p r o c e s s ) . The p r o c e s s uses S02 and a i r t o o x i d i z e t h e c y a n i d e and uses c o p p e r t o c a t a l y z e t h e r e a c t i o n and l i m e t o make t h e r e a c t i o n m i x t u r e s l i g h t l y a l k a l i n e . 4.2 T a i l i n g s D i s p o s a l M i l l t a i l i n g s a r e t h e f i n e r o c k m a t e r i a l t h a t r e m a i n s a f t e r t h e chosen o r e has been removed and c o n c e n t r a t e d . When d i s c h a r g e d from t h e m i l l , t h e t a i l i n g s a r e a s l u r r y o f w a t e r and s m a l l r o c k p a r t i c l e s ( a p p r o x i m a t e l y 0.05-1.0 mm i n d i a m e t e r ) , and u s u a l l y have a low pH ( o r h i g h a c i d i t y ) , r e l a t i v e t o t h e s u r r o u n d i n g w a t e r , and c o n t a i n a v a r i e t y o f m e t a l s . T a i l i n g s a r e d i s p o s e d o f i n one o f two ways, e i t h e r on l a n d o r i n w a t e r , though l a n d d i s p o s a l , u s i n g e a r t h e n dams, i s most common. D i s p o s a l u n d e r w a t e r o c c u r s i n s e v e r a l l o c a t i o n s i n B.C., g e n e r a l l y i n a r e a s h a v i n g h i g h p r e c i p i t a t i o n ( P o l i n g 1 9 7 7 ; E l l i s 1982). I n some c a s e s t h e l a r g e r p a r t i c l e s i z e s i n a t a i l i n g s m i x t u r e a r e s e p a r a t e d f o r use as b a c k f i l l , i n underground mines, o r as c o n s t r u c t i o n m a t e r i a l i n t h e t a i l i n g s dam. 117 4.3 Other Sources of Impact The b e n e f i c i a t i o n phase requires sources of water and energy and a transportation f a c i l i t y for removing the ore concentrate. Local aquatic resources might be affected by the withdrawal of water, depending on the l o c a t i o n of water removal f a c i l i t i e s and on the amounts withdrawn, by the placement of a hy d r o e l e c t r i c dam and/or transmission l i n e s , i f these are used to power the m i l l (and some equipment i n the mine), and by s p i l l a g e of ore concentrate, whether the ore i s shipped by land ( r a i l cars or trucks) or by water (barges or s h i p s ) . 5.0 Abandonment and Reclamation Reclamation of a minesite once extraction has ceased i s usually directed at the r e h a b i l i t a t i o n of disturbed land surfaces, including t a i l i n g s impoundments and waste p i l e s ( i e . wasterock, s o i l overburden). The condition of these land surfaces and the adequacy of r e h a b i l a t i o n e f f o r t s w i l l determine the kind, severity and persistence of e f f e c t s to aquatic systems a f t e r the mine has been abandoned. Roots (1977) has claimed that the e f f e c t s of mine development can be most serious a f t e r the mine ceases operation and i s abandoned, but that i n B r i t i s h Columbia, experiences of t h i s kind are lacking, compared to parts of the world (such as Europe) where the mining industry has been established f o r a much longer time. Ripley ei; a l 1978 i n d i c a t e that, recently, the concept of reclamation has s h i f t e d from a "clean-up" a c t i v i t y once mining a c t i v i t y has ceased, to an a c t i v i t y incorporating an early d e t a i l e d planning stage and an on-going implementation stage (including reclamation a c t i v i t y during the exploration and development phases). Impacts that might occur once reclamation measures have been implemented w i l l depend on both the physical processes (eg. wind and water erosion, mass wasting) and chemical processes (eg.acid generation and leaching of tox i c r e s i d u a l s ) that continue to take place. C l e a r l y , these processes and t h e i r e f f e c t s must be anticipated as early i n the planning stage as possible to prepare appropriate preventative measures. B. E f f e c t s on F i s h e r i e s Resources The e f f e c t s of mine development on aquatic resources at the mines examined i n Chapter 4.0 generally involved changes i n water q u a l i t y and, i n some cases, changes i n the benthic community. In most cases, e f f e c t s on nearby f i s h e r i e s resources were not d i r e c t l y observed and assessment of such e f f e c t s i s based on the i n t e r p r e t a t i o n of changes i n water q u a l i t y and/or the benthic community. The main f a c t o r s that might have affected the f i s h e r i e s resources near each mine are: - cyanides and dissolved metals - suspended s o l i d s and associated materials - nutrients from sewage and explosives - increased a c i d i t y These are b r i e f l y discussed below. 1.0 Cyanide and dissolved metals Discharges of high l e v e l s of cyanide and copper were the cause of major problems i d e n t i f i e d at Baker, Ladner Creek and Summit Lake. Both cyanide and copper can be tox i c to aquatic organisms. However, i n t e r p r e t a t i o n of the d i r e c t and i n d i r e c t e f f e c t s of cyanide and metals i s complex. The chemical form and t o x i c i t y of cyanide i s affected by pH, temperature, dissolved oxygen, s a l i n i t y , dissolved metals and other dissolved substances (Committee on Water Quality C r i t e r i a 1972; Clarke 1974; McNeely et a l 1979). Some chemical forms of cyanide can become more toxi c with exposure to sunlight (Committee on Water Quality C r i t e r i a 1972; Clarke 1974). Metals (eg. copper and zinc) can also occur i n a var i e t y of chemical forms and 118 toxicity i s determined by the chemical species and other factors such as temperature, hardness and turbidity . Cyanide and copper can affect f ish d irect ly , either lethal ly or sublethally, or indirect ly by affecting food organisms such as benthic invertebrates. Also, metals can concentrate in tissues and consequently be passed on through the food chain and accumulate at higher trophic levels . 2.0 Suspended solids and associated material Suspended solids were released from the broken tai l ings l ines at Baker and the HB M i l l , during the development of the Ladner Creek minesite, by a rockslide at Silence Lake and by the runoff from the Equity Silver mi l l s i t e . At the time of the Baker incident high levels of cyanide were recorded in the ta i l ings . Factors affecting interpretation of the effects of cyanide are discussed above. Also, at the time samples were taken at the Ladner Creek minesite elevated levels of other factors (a lkal in i ty , hardness, and 8 dissolved substances) was also recorded. The European Inland Fisheries Commission, EIFAC(1965) cited in the Commission on Water Quality 1972, indicate that suspended solids can be harmful to fisheries by : "- acting direct ly on f ish swimming in water in which solids are suspended either k i l l i n g them or reducing their growth rate and resistance to disease; - preventing the successful development of f ish eggs and larvae; - modifying natural movements and migrations of f i sh; - reducing the food available to f i sh; - affecting efficiency in catching fish" 3.0 Nutrients from sewage and explosives Nitrogen compounds in the aquatic environment are usually produced or altered by a natural process (the Nitrogen Cycle) and include ammonia, nitrate , n i t r i t e and organically-bound nitrogen. Under natural conditions, these compunds do not usually reach toxic levels, but i f additional compounds are introduced, for example from sewage, toxic levels can occur (McNeely ert al_ 1979). Ammonia and n i t r i t e have the greatest toxic potential while organically-bound nitrogen i s not of direct concern (McNeely 1979). Phosphorus i s usually not toxic, but when nitrogen compounds are present can promote the growth of plant material. The overall effect of nutrients at the two mines (Baker, Ladner Creek) where increases were observed appears to have been positive. 4.0 Increased acidity Increased acidity has been observed on a large scale at the Equity Si lver mine. An increase in acidity can be direct ly toxic to aquatic organisms, can increase the toxicity of some substances (eg. zinc and cyanide) and can increase the so lubi l i ty of other, potentially toxic substances such as trace metals (Clarke 1974;Committee on Water Quality 1972). The toxic potential of pH in turn can be influenced by hardness (Clarke 1974). 119 Appendix General description and operating status of mines for which impact management problems were Table II.1 reviewed. (Crook 1984; B.C. and Yukon Chamber of Mines 1982; Northern Miner Press 1984) History/Status Mine Name Operating Company Location Type 1 P r i n c i p l e Capacity Start Notes Metals Production Stage I Mines Baker Banbury B r u s s i l o f Free Gold HB M i l l Dupont of Canada Exploration Ltd. Banbury Gold Mines Ltd. north central u.g. B.C. o.p. gold 100 1981 near Hedley u.g. gold o.p. magnesite BayMag Mines Co. southeast Ltd. B.C. Reako Explorations near Smithers u.g. Ltd./Panther Mines Ltd. David Minerals Ltd. near Salmo (mi l l only) u.g. gold gold, s i l v e r , molybdenum 100-300 1983 10 0 50-100 1000 1981 1981 1982 production in 1982 and 1983; ceased i n l a t e 1983 p i l o t - s c a l e production m i l l i n Alberta; p i l o t - s c a l e 1982 and 1983 p i l o t - s c a l e 1982 and 1983 m i l l obtained from Cominco and re-furbished; no operation 1983 Ladner Creek Carolin Mines near Hope u.g. gold 1500 1982 Ltd. operated 1983 Appendix Table II.1 (Cont'd.) History/Status . Mine Name Operating Company Location Type 1 P r i n c i p l e Capacity Start Notes Metals Production Silence Lake Dumac Resources near Clear- o.p. tungsten Corp. water 100 1981 ceased operation, f a l l 1982 Skomac Robert Mines Ltd. near Green- u.g. gold wood 30 1975 (mine) sporadic prod-1981 ( m i l l ) uction; ceased operation 1983 Summit Lake Scottie Gold Mines Ltd. near Stewart u.g. gold 145 1981 ceased operations l a t e 1984 Table Mountain Cusac Industries Ltd. near Cassiar u.g. gold 30 1981 ceased operations 1982 Taurus Taurus Resources Ltd. near Cassiar u.g. gold 100 1981 ceased operations 1983 Venus United Keno H i l l Mines Ltd. northwest B.C. u.g. gold, s i l v e r , lead, zinc 100 1981 m i l l i n B.C.; mine mine i n Yukon. 2 weeks production only Vollaug (Troutline Creek) Erickson Gold Mines Ltd. (from Plaza Mining Corp.) near Cassiar o.p. u.g. gold 120 1981 mining suspended 1982 Appendix Table II.1 (Cont'd.) History/Status Mine Name Operating Company Location Type 1 P r i n c i p l e Capacity Start Notes Metals Production Stage II Mines Equity S i l v e r Equity Mining near Houston o.p. copper, 4500 1981 s t i l l producing Corp./Placer s i l v e r , gold Development Ltd. Goldstream Noranda Mines near Revel- o.p. copper, zinc 1400 1983 ceased operation Ltd. stoke 1984 u.g. = under ground; o.p. = open p i t 123 APPENDIX I I I . Impact Management Problems I d e n t i f i e d at Thirteen Stage I Mines and Two Stage II Mines A. Stage I_ Mines No impact management problems were i d e n t i f i e d f o r : 1. Banbury Mine 2. B r u s s i l o f Mine 3.Skomac 4. Taurus 5. Vollaug Mine Impact Management Problems were i d e n t i f i e d f o r the following mines: 1. Baker 2. Free Gold 3. H.B. M i l l 4. Ladner Creek 5.Silence Lake 6.Summit Lake 7. Table Mountain 8. Venus The impact management problems i d e n t i f i e d at each mine are summarized below. 1. Baker a) On-going Exploration No problems i d e n t i f i e d b) Mine Development and Operation i . 1982-1983: the mine drainage water contained high sulphate l e v e l s and possible acid drainage was a concern. However, pH l e v e l s remained neutral and elevated sulphate l e v e l s were not evident a short distance downstream. c) M i l l Construction and Operation i . spring 1982 - high cyanide and dissolved copper l e v e l s were recorded i n groundwater and i n a stream below the t a i l i n g s pond. Waste Management Branch charges were l a i d , the mine pleaded g u i l t y and was fined $2000. The mine operators estimated costs to deal with the problem were $112,000 (including court c o s t s ) . i i . May 1983 - the t a i l i n g s l i n e ruptured, s p i l l i n g approximately 280 tonnes of t a i l i n g s i n t o a nearby creek. No charges were l a i d , but l e g a l samples were taken by Waste Management personnel. d)0ther A c t i v i t i e s i . summer 1983 - high l e v e l s of nitrogen and phosporous from domestic sewage were recorded downstream, and resulted i n enhanced production of algae and benthic invertebrates. i i . 1983 - a small s p i l l of h e l i c o p t e r f u e l occurred at an a i r f i e l d b u i l t by the mining company, but no f u e l entered a nearby stream. The f u e l was owned and cleaned-up by a second party. Notes : 1. A pre-operational study of water qu a l i t y and benthic invertebrates was conducted i n 1976 (Beak 1977). 2. A study of f i s h e r i e s resources i n streams near the mine (Beak 1982) concluded that there i s no f i s h l i f e i n the associated watershed u n t i l a point 35 Km downstream. Fi s h access i s prevented by several w a t e r f a l l s at that l o c a t i o n . 3. A study of benthic invertebrates i n streams near the mine (IEC Beak 1983) indicated that the e f f e c t s of sewage discharge had 124 increased b i o l o g i c a l production and l i k e l y masked detrimental e f f e c t s from cyanide and dissolved copper. 4. The o r i g i n a l cyanide removal treatment method ( a l k a l i n e c h l o r i n a t i o n ) was replaced by the INC0-S02/Air method. Sources: 1. regional MOE personnel, Prince George, B.C. 2. management personnel of DuPont Explorations Ltd. 3. Beak Consultants Ltd. 1977; Beak Consultants Ltd. 1982; IEC Beak 1983. 2. Free Gold a) On-going exploration No problems i d e n t i f i e d b) Mine Development and Operation No problems i d e n t i f i e d c) M i l l Construction and Operation 1982 - 1983: a small leak occurred i n the t a i l i n g s pond but the leaked material did not reach nearby waterbodies d) Other A c t i v i t i e s No problems i d e n t i f i e d Sources: 1. regional MOE personnel, Smithers, B.C. 2. management personnel of Reako Explorations Ltd. 3. HB M i l l a) M i l l Construction and Operation January 1982: the t a i l i n g s l i n e froze and an unknown quantity of t a i l i n g s s p i l l e d into Sheep Creek, which flows into the Salmo River. The m i l l had been shut down several days before the break but the t a i l i n g s l i n e had not been flushed. T a i l i n g s were observed along the creek bottom below the t a i l i n g s pipe. Salmonids u t i l i z e the segment of creek where the s p i l l occurred. However, MOE personnel f e l t that given the time and l o c a t i o n , e f f e c t s on f i s h would not be serious. The operators were charged and convicted under the Waste Management Act, and were fined $1500. The problem was a t t r i b u t e d to equipment f a i l u r e and operator e r r o r . The operator estimates costs to repair the t a i l i n g s l i n e were approximately $85,000 (labour plus supply and s e r v i c e s ) . A d d i t ional court and l e g a l costs were approximately $5000. b) Other A c t i v i t i e s No problems i d e n t i f i e d . Sources: 1. regional MOE personnel, Nelson, B.C. 2. management personnel of David Minerals Ltd. 4. Ladner Creek a) On-going Exploration No problems i d e n t i f i e d . b) Mine Development and Operation i . September 1980: increases i n suspended s o l i d s , a l k a l i n i t y , hardness, t u r b i d i t y and some metals (barium, manganese, aluminum, i r o n , s i l i c a , calcium, magnesium and sodium) were recorded below the minesite. The increases were at t r i b u t e d to f i l t r a t i o n from mine water s e t t l i n g ponds and to general minesite development (construction). Increased sediment deposition and a l g a l growth 125 and changes i n the benthic invertebrate community were also i d e n t i f i e d . These e f f e c t s were observed i n downstream areas i n which salmonids are known to occur, i i . 1980 - 1984: the mine s e t t l i n g ponds p e r i o d i c a l l y produced high l e v e l s of suspended s o l i d s and nitrogen compounds, inc l u d i n g ammonia and n i t r i t e . The high l e v e l s of nitrogen species are a t t r i b u t e d to explosives usage. Ammonia and n i t r i t e are apparently converted to n i t r a t e downstream by natural aeration i n the creek. The increased n i t r a t e s have promoted a l g a l growth downstream. i i i . October 1983: increased suspended s o l i d s from uncontrolled runoff, sources c) M i l l Construction and Operation i . September 1980: as for point i ) (Mine Development and Operation) i i . 1982 - 1984: m i l l e f f l u e n t discharge was p e r i o d i c a l l y of poor q u a l i t y , p a r t i c u l a r l y i n r e l a t i o n to the l e v e l s of cyanide and copper discharged: - early spring 1982: high l e v e l s of cyanide and copper were discharged to Ladner Creek. At that time, several hundred dead trout were observed downstream i n the Coquihalla River. Many of these were i d e n t i f i e d as hatchery-produced steelhead smolts placed i n the Coquihalla River over the period of discharge. Trout bioassays suggested that water immediately below minesite was l e t h a l , but the Coquihalla River was not. The mine operators were charged and convicted under both the P o l l u t i o n Control Act and F i s h e r i e s Act. Fines were $5000 for the P o l l u t i o n Control Act conviction and $135,000 for the F i s h e r i e s Act conviction. The mine operators are appealing the F i s h e r i e s Act conviction. In a separate c i v i l a c tion the Steelhead Society of B.C. are suing the operators for damages. At the time, the m i l l shutdown operations for several weeks. - l a t e winter/early spring 1983 : as f u l l recycle operation of the m i l l was achieved, e f f l u e n t q u a l i t y had deteriorated by February 1983. Combined with the rapid f i l l i n g of the t a i l i n g s pond (point i v below) t h i s resulted i n a two-week shutdown of the m i l l . - December 1983: a new cyanide treatment process (INC0/S02 A i r ) was begun, r e s u l t i n g , i n i t i a l l y , i n reduced cyanide and copper. - February 1984 : high cyanide and copper l e v e l s were again recorded downstream. - June 1984 : a change i n m i l l operation related to the amount of gold recovered resulted i n a continuing decline i n e f f l u e n t q u a l i t y causing part of the m i l l i n g process and e f f l u e n t discharge to be shutdown. i i i . October 1982: high cyanide l e v e l s were recorded i n the drain t i l e discharge from the m i l l b u i l d i n g . M i l l clean-up procedures were al t e r e d to correct the problem, i v . early spring 1983: the t a i l i n g s pond f i l l e d r a p i d l y during snowmelt and, combined with a d e t e r i o r a t i o n i n m i l l e f f l u e n t q u a l i t y , resulted i n a two-week shutdown of the m i l l , v. early spring 1983 - f a l l 1984: To allow greater storage the t a i l i n g s dam was r a i s e d . On-going construction a c t i v i t y and surface disturbance contributed to p e r i o d i c a l l y high suspended s o l i d s l e v e l s recorded downstream. d) Related A c t i v i t i e s No problems i d e n t i f i e d . 126 Notes: 1. salmonid f i s h are found i n Ladner Creek approximately 500m below the minesite. 2. from 1982-1984 cyanide and dissolved copper approached l e t h a l l e v e l s to trout on several occasions immediately below the minesite (where trout are not found) and approached stress l e v e l s further downstream where trout are found. 3. copper l e v e l s i n downstream macroinvertebrates was up to 10 times higher than i n upstream macroinvertebrates. The numbers of macroinvertebrates and i n d i v i d u a l s showed a decline over 1982 and 1983, even i n areas where trout normally are found. 4. add i t i v e t o x i c e f f e c t s might have occurred when cyanide, copper and n i t r i t e s were present at the same time. 5. over the 1982-1984 periods suspended s o l i d s appeared to be s e t t l i n g over substrate immediately below the minesite but not further downstream where f i s h are found. 6. nitrogen compounds appeared to be promoting downstream a l g a l growth and was f e l t to be enhancing b i o l o g i c a l p r o d u c t i v i t y . Sources: 1. regional MOE personnel, Surrey, B.C. 2. EPS personnel, P a c i f i c Region, West Vancouver, B.C. 3. Management personnel of C a r o l i n Mines Ltd. 4. Hallam 1980. 5. Moore 1984. 5. Silence Lake a) On-going Exploration No problems i d e n t i f i e d . b) Mine Development and Operation 1. i n 1982 a small amount of erosion of the waste rock dump and a small r o c k s l i d e occurred at the rock storage s i t e causing boulders and a small amount of sediment to enter a nearby stream. Regional Waste Management personnel did not f e e l the incident was serious because the incident was b r i e f and involved a r e l a t i v e l y small amount of material. The l o c a t i o n to the s l i d e i s not accessible to salmonids and Waste Management personnel did not f e e l that f i s h e r i e s resources were af f e c t e d . c) M i l l Construction 1. i n 1982 a small overflow of the t a i l i n g s berm occurred when operations f i r s t began, but e f f l u e n t did not enter a nearby stream. d) 0ther A c t i v i t i e s No problems i d e n t i f i e d . Notes: 1. The mine ceased operation l a t e i n 1982 and the operators were i n receivership. No water q u a l i t y data was forwarded by the mine to the Waste Management Branch and the Waste Management Branch had not c o l l e c t e d t h e i r own. Sources: 1 regional MOE personnel, Kamloops, B.C. 6. Summit Lake a) On-going Exploration No problems i d e n t i f i e d . b) Mine Development and Operation 127 No problems i d e n t i f i e d . c) M i l l Construction and Operation 1981 - 1984: i n October 1981, high l e v e l s of cyanide and copper were recorded i n the discharge to Summit Lake and i n the lake i t s e l f . F i s h k i l l s were observed i n bioassays and the mine operation was required to shutdown for 3-4 days i n July 1982. P e r i o d i c a l l y high l e v e l s of cyanide and copper were recorded below the i c e b a r r i e r forming the lake, but could not be a t t r i b u t e d to the mine. The mine operators were not charged, but incurred expenses of approximately $850,000 improving the e f f l u e n t treatment process. The i n i t i a l a l k a l i n e c h l o r i n a t i o n process was replaced with the INC0-S02/Air process. d) Other A c t i v i t i e s No problems i d e n t i f i e d . Note: The m i l l i s located within the mine (underground) and t a i l i n g s material i s discharged to the bed of Summit Lake. Summit Lake i s formed by an i c e dam that drains when high water l e v e l s cause the i c e dam to r i s e . Sources: 1. regional MOE personnel, Smithers,B.C. 2. management personnel of S c o t t i e Gold Mines 3. EPS personnel, P a c i f i c Region, W.Vancouver, B.C. 7. Table Mountain a) On-going Exploration No problems i d e n t i f i e d . b) Mine Development and Operation No problems i d e n t i f i e d . c) M i l l Construction and Operation An a d d i t i o n a l treatment pond was constructed at the request of the Waste Management Branch d) Other a c t i v i t i e s No problems i d e n t i f i e d . Sources: 1. regional MOE personnel, Smithers, B.C. 2. management personnel of Cusac Industries Ltd. 8. Venus a) On-going Exploration No problems i d e n t i f i e d . b) Mine Development and Operation Two ''large underground holding treatment sumps" constructed at the request of regulatory agencies. c) M i l l Construction and Operation Two a d d i t i o n a l t a i l i n g s ponds constructed at the request of regulatory agencies. d) Other A c t i v i t i e s No problems i d e n t i f i e d . Note: 1. The mine i s located i n the Yukon T e r r i t o r y and the m i l l i s located i n B r i t i s h Columbia. 2. In l a t e 1983, Waste Management Branch personnel had taken samples of seepage waters but r e s u l t s were not a v a i l a b l e . Sources: 1. regional MOE personnel, Smithers, B.C. 128 2. Management personnel of United Keno H i l l Ltd. B. Stage II Mines Two mines were examined and impact management problems were i d e n t i f i e d at both: 1. Equity S i l v e r Mines 2. Goldstream Mine 1. Equity S i l v e r a) On-going Exploration No problems i d e n t i f i e d . b) Mine Development and Operation i . 1980 - 1984: mine drainage water and runoff from mine waste rock were found to be reducing pH l e v e l s and increasing l e v e l s of sulphate and metals (copper, zinc and iron) i n rec e i v i n g waters. Some waste rock was used for a va r i e t y of construction purposes ( i e . t a i l i n g s dam, p l a n t - s i t e , haul road) and consequently low pH problems developed thoughout the minesite. A three phased workplan was developed to c o l l e c t , t r e a t and monitor waste-rock runoff. A company-government Technical Surveillance Committee was formed to deal with the problem. c) M i l l Construction and Operation i . 1980 - 1982: low pH problems from p l a n t s i t e drainage, re l a t e d to acid generation i n waste rock used for p l a n t s i t e construction (as indicated above). i i . 1981: high s i l t l e v e l s occurred p e r i o d i c a l l y i n p l a n t s i t e runoff, i i i . November 1981: approximately 100 tonnes of sulphuric acid s p i l l e d from a storage tank and entered receiving waters. A reduction i n pH was recorded downstream, i v . May 1982: a seepage pond at the foot of a t a i l i n g s dam overflowed while a damaged pump (used to return seepage water to the t a i l i n g s impoundment) was being repaired. An unknown quantity of e f f l u e n t having a low pH(2.8) was released. d) Other A c t i v i t e s i ) 1980 - 1982: low pH problems from roadway drainage, r e l a t e d to acid generation i n waste rock used for road construction (as described above). i i ) February 1982 : cul v e r t crushed on main haulroad, pools of low pH water had to be trucked to t a i l i n g s pond. Notes: 1. a) pre-operational aquatic studies: Beak Consultants Ltd. 1974; Hallam and Kussat 1974; Hallam et a l 1975; Beak Consultants Ltd 1976. b) post-operational studies and reviews: IEC International Environmental Consultants Ltd 1982; Osborne and Hallam 1982; H a t f i e l d Consultants Ltd. 1983; unpublished Waste Management Branch water qu a l i t y and benthos surveys. 2. The mine i s on a watershed divide; the t a i l i n g s s i t e i s i n the Foxy Creek drainage; the minesite, m i l l s i t e and haulroad are i n the Bessemer Creek drainage which i s part of the Buck Creek system. F i s h have not been found i n Bessemer Creek but have been found i n Buck Creek (approximately 3 Km below the minesite). F i s h were not found i n Foxy Creek for approximately 24 Km downstream. 3. Low pH and high metal l e v e l s were recorded i n Bessemer Creek to i t s junction with Buck Creek. The benthic invertebrate population was 129 greatly reduced. Low pH and high heavy metal l e v e l s were recorded at the junction of Bessemer and Buck Creek, but were attenuated 2 Km downstream and increased heavy metals l e v e l s were not evident i n f i s h t i s s u e or bottom sediments. No d i r e c t evidence that f i s h e r i e s resources were af f e c t e d . Trout bioassays indicated that the water was not t o x i c . 4. In 1983 the mine was charged and convicted under the F i s h e r i e s Act. The f i n e was $12,000. The mine began a program to deal with the acid generation problem, inc l u d i n g a c a p i t a l expenditure of $1.1 m i l l i o n to contain, d i v e r t and tr e a t waters. Additional costs include lawyers, consultants and executive fees and t r a v e l costs. T o t a l eventual costs are expected to be approximately $3.0 m i l l i o n . Sources: 1. regional MOE personnel, Smithers B.C. 2. management personnel of Equity S i l v e r Mines Ltd. 3. EPS personnel, P a c i f i c Region, W. Vancouver B.C. 4. Beak Consultants Ltd 1974; Hallam and Kussat 1974; Hallam et a l . 1975; Beak Consultants Ltd, 1976; IEC International Environmental Consultants Ltd. 1982; Osborn and Hallam 1982; H a t f i e l d Consultants Ltd. 1983. 2. Goldstream a) 0n-going Exploration No problems i d e n t i f i e d . b) Mine Development and Operation No problems i d e n t i f i e d . c) M i l l Construction and Operation i . spring 1983: t a i l i n g s pumps did not operate properly; several small s p i l l s occurred, with overflow going onto the ground but not to nearby streams. Afterwards, an a d d i t i o n a l "stand-by" pump was i n s t a l l e d . i i . July 1983 : a bridge supporting the t a i l i n g s l i n e washed out, breaking the t a i l i n g s l i n e , L i t t l e or no t a i l i n g s material entered creek because the t a i l i n g s l i n e had been drained j u s t p r i o r to the mishap. d) Other A c t i v i t i e s No problems i d e n t i f i e d . Sources: 1. regional MOE personnel, Nelson, B.C. 2. management personnel of Noranda Mines Ltd. 130 APPENDIX IV. Information Collected During Post-start-up Studies Once production begins, the e f f e c t s of mining a c t i v i t y are examined by a routine monitoring and inspection program and, where the need a r i s e s , more intensive f i e l d studies. The types of information obtained during these i n v e s t i g a t i o n s i s b r i e f l y described below. a) Routine Inspection and Monitoring i . Inspection by P r o v i n c i a l and Federal Personnel The frequency of routine inspection by Waste Management Branch personnel i s determined i n part by the s i z e of the mine and i n part by the s e n s i t i v i t y of the surrounding environment. Therefore a r e l a t i v e l y small, remote mine such as Baker i s usually v i s i t e d r o u t i n e l y once a year, while a large, accessible mine near a salmon-bearing stream such as Goldstream i s usually v i s i t e d monthly. Irregular v i s i t s by Waste Management Branch personnel or personnel from other p r o v i n c i a l or fe d e r a l resource agencies (eg. Environmental Protection Service) might occur at any time depending on agency resources and p r i o r i t i e s . V i s i t s by government personnel can involve both v i s u a l inspection and c o l l e c t i o n of a d d i t i o n a l samples. i i . Sampling and Monitoring by Mine Operators The sampling programs prescribed i n Waste Management permits for eight mines are summarized i n Table IV-1. In general, sampling i s more frequent for the monitoring programs, compared to data c o l l e c t e d during pre-development f i e l d studies ( c f . Table 5-3). Also, the monitoring programs include information usually not obtained during the pre-development studies (eg. bioassays; background l e v e l s of r e s i d u a l s , such as cyanide). Sampling frequency for t a i l i n g s ponds and outflow, mine drainage and surface re c e i v i n g waters varies from once per week to once every three months. Sampling frequency for groundwater varies from none to once every s i x months and bioassays (for t a i l i n g s water only) varies from none to once every three months. However, apart from the sampling programs for the Summit Lake and Baker mines, the monitoring schedules appear intended to i d e n t i f y problems that might occur with chronic discharges but not with emergency or "catastrophic" problems. In most cases, one to three months w i l l lapse between sample periods. The sample programs for the Summit Lake and Baker mines are based on a more frequent sampling regime with some samples taken on a weekly and even d a i l y basis. (Note that the Baker permit was revised a f t e r serious problems occurred i n 1982 and 1983). These sampling programs are more l i k e l y to i n d i c a t e the occurrence of a catastrophic problem, but, even with weekly sampling, a problem such as a reagent s p i l l might occur and be over before routine samples are c o l l e c t e d . i i i . Requirements for Reporting Reports on the r e s u l t s of the routine sampling are usually required every three months. In addition, the terms of the permits i n s t r u c t mine operators to immediately n o t i f y the Director of the Waste Management Branch i f an emergency condition a r i s e s and to immediately take remedial action. The l a t t e r procedures r e l y on the d i s c r e t i o n of mine operator i n i d e n t i f y i n g , reporting and dealing with an emergency. b) A d d i t i o n a l Intensive Studies The r e s u l t s of intensive studies are included i n the descriptions of impact management problems outlined for four mines i n Appendix I I I (Baker, Ladner Creek, Equity S i l v e r , Summit Lake). The types of study undertaken are summarized below i n r e l a t i o n to the type of aquatic feature examined ( i e . f i s h , invertebrates, vegetation and other features) and are compared to the information presented i n Stage I reports. i . F i s h Studies Studies have included: species presence and d e t a i l e d habitat assessment ( i e . at Baker mine, where pre-production f i s h resource studies were not Table IV.1 Sampling programs prescribed i n Waste Management Permits for eight mines. STAGE I MINES STAGE II MINES Serious Problems Developed Serious Problems did not Develop Equity Goldstream Baker Ladner Creek Summit Lake Silence Lake Skomac United Hearne S i l v e r Date Dec/83 Aug./80 Oct./80 0ct./81 June/81 Sept./81 June/80 Aug./83 Supernatant/ weekly monthly weekly monthly: monthly quarterly quarterly quarterly: Discharge (pH d a i l y ; (residual mine t a i l i n g s & ( t a i l i n g s mine water chlorine, weekly: mine/waste ponds, out- quarterly) cyanide, pH & t a i l i n g s rock flow, t r e a t - 0-R potential monthly: ment source) d a i l y ) outflow Receiving weekly; monthly weekly when quarterly none quarterly monthly monthly; Streams quarterly lake empty; quarterly monthly when lake f u l l ; twice d a i l y when lake emptying Groundwater weekly none monthly quarterly "at a f r e - quarterly none semi-quency and annually at locations to be deter-mined by the Regional Manager" Bioassays none quarterly quarterly none none none none quarterly ( t a i l i n g s ) ( t a i l i n g s ) ( t a i l i n g s ) 132 undertaken); a d d i t i o n a l problem-specific f i s h bioassays; and, c o l l e c t i o n and analysis of f i s h t issues for metal content and of f i s h l i v e r s for the enzyme metallothionein. In the pre-development Stage I assessments, studies of species presence and habitat are r e l a t i v e l y common, and a pre-production bioassay was undertaken for one mine (Blackdome). Metal content i n ti s s u e s and metallothionein studies were not described i n any of the Stage I reports reviewed. F i s h condition f a c t o r s (based on length-weight r e l a t i o n s h i p s ) were reported i n one Stage I report (Ladner Creek), but are not commonly calculated during follow-up assessments. i i . Aquatic invertebrate studies Studies have included: examination of population s i z e s and community structure; metal concentrations i n invertebrate t i s s u e ; and, zooplankton (Daphnia) bioassays. Studies of the benthic invertebrate community were undertaken f or two Stage I reports (Baker and Ladner Creek) and observations of major taxa during assessments of f i s h habitat are presented i n one report (Summit Lake). However, studies of metal concentrations i n invertebrate t i s s u e and zooplankton bioassays were not undertaken. i i i . Aquatic vegetation studies At one mine (Baker) a preliminary study of periphyton growth was undertaken. In addition, f o r most mines unusual a l g a l growth i s usually noted during routine v i s u a l inspections. Periphyton studies were not presented i n any Stage I report. i v . Other Studies Other studies have included the measurement of metal concentrations i n sediments and measurements of p a r t i c l e s i z e s i n suspended s o l i d s . In addition, sediment deposition and suspended s o l i d s l e v e l s are usually noted during routine inspections. In Stage I reports general substrate conditions are occasionally described i n terms of f i s h habitat. However, no report presents information on the metal content i n sediments or analyses of p a r t i c l e sizes of suspended s o l i d s . 133 APPENDIX V. General Contents of Five Stage I Reports and Ministry of Environment Terms of Reference A Stage I_ Reports l.a)Mine: Baker b) Report T i t l e : DuPont of Canada Ltd. Baker Mine. Environmental and Reclamation Report Pursuant to Section 11, Mines Regulation Act. F i l e 1522/1. Author and Date: Ker, Priestman & Associates Ltd. March 1980. c) Report Contents: Topics Summary Introduction and Acknowledgements Project Description E x i s t i n g Environment Present Resource Use Reclamation P o t e n t i a l Environmental Impacts M i t i g a t i v e Measures References Tables Appendix 1 Guidelines f o r Coal and Mineral Exploration Figures Photographs T o t a l Length No. of Pages 2 2 13 18 5 10 2 7 1 2 4 11 3 80 2.a)Mine: Blackdome b) Report T i t l e : Blackdome Explorations Ltd. Blackdome Project Stage I Submission Environmental Impact Assessment Author and date: IEC Beak Consultants Ltd. January 1983. Mine Type, Size and L i f e : g o l d - s i l v e r , underground; 200 tons/day; 4.3 years c) Report evolution: d r a f t Stage I report submitted June 1982, screened i n July 1982; following r e v i s i o n s , f i n a l Stage I report submitted January 1983. d) Report Contents: Topics No. of Pages Executive Summary 2 Acknowledgements 1 Introduction 3 Environmental and Socio-Economic Baseline Conditions 85 Project Description 46 Environmental and S o c i a l Impacts 22 Future Studies 2 Appendices Appendix A. Bioassay Results f o r Simulated T a i l i n g s F i l t r a t e and Acid Generating Test conducted on t a i l i n g s s o l i d s 9 Appendix B. Technical Q u a l i f i c a t i o n s 12 T o t a l Length 182 pages 134 3. a)Mine: Free Gold b) Report T i t l e : Free Gold Project Smithers B.C. Stage One Report Author and Date: Reako Explorations Ltd. Panther Mines Ltd. A p r i l 1981. Mine Type, Size and L i f e : gold and m e t a l l i c sulphides, underground with a portable m i l l ; 50 ton/day: 2 years. c) Report Contents: Topics No. of Pages Summary 2 Introduction 7 Description of E x i s t i n g Environmental and S o c i a l Conditions 30 Project Description 25 Environmental and S o c i a l Impacts 6 Proposed Further Studies 1 Bibliography 2 Appendix A. Report on Phase 1 Geotechnical Investigations for a T a i l i n g s Impoundment Basin near Smithers, B.C. Appendix B. Mineral Inventory Map Sheet 93L 1 To t a l Length: 96 pages 4. a)Mine Name: Ladner Creek b) Report T i t l e : Ladner Creek Development Stage I Report. Project No.1-06-913 Submitted by C a r o l i n Mines Limited. Author and Date: B.C. Research. July 1979. Mine Type, Size and L i f e : gold, underground; 1500 tons/day; 3-10 years Project Summary: Stage I report submitted; addendum requested and submitted December 1979; designated "simple" i n A p r i l 1980; production commenced early 1982. c) Report Contents: Topics No. of Pages Summary 2 Introduction 3 Methods 5 Development Program 20 Environmental Data 25 Environmental Impacts 5 Recommendations for Future Work 1 References 2 Tables 17 Figures 10 Appendices(8) A. Report of Acid Production P o t e n t i a l on four samples from the Ca r o l i n Mine B. S o i l P r o f i l e Descriptions C. Che c k l i s t of Mammals Possibly Occurring i n the Ladner Creek Area D. Checklist of Birds whose Breeding Range coincides with the Ladner Creek Area E. Information Relevant to Land Tenure 135 F. Hydrology for Ker, Priestman & Associates Ltd. G. Guidelines for the Design, Construction, Operation and Abandonment of T a i l i n g s Impoundments. H. Letter from Acting Regional Archaelogist Maps 8 T o t a l Length 156 d)Addendum Report T i t l e : C a r o l i n Mines Ltd. Ladner Creek Project. Addendum to Stage I Report. Author and Date: Ker, Priestman & Associate Ltd. 23p + 2 f i g u r e s Topics No. of Pages Introduction 1 T a i l i n g s Pond Al t e r n a t i v e s Considered 3 S t a b i l i t y of T a i l i n g s Dam 3 Water Management 9 Hydrology 4 Other Agency Concerns 3 Figures 2 5.a)Mine Name: Summit Lake b)Report T i t l e : Stage I Report. S c o t t i e Gold Mines Ltd. Summit Lake, B.C. Author and Date: Ker, Priestman and Associates Ltd. February 1980. Mine Type, Size and L i f e ; gold, underground; 200 tons/day; 3 years or more Project Summary: project designated "simple" i n July 1980; production commenced September 1981. c)Report Contents: Topics No of Pages Summary 3 Introduction 2 Project Description 22 E x i s t i n g Environment 27 Environmental and S o c i a l Impacts 1 Mitigations 3 References 1 Figures 8 Photographs 4 Appendices 66 Appendix I. B.C. Research Report. Acid Production P o t e n t i a l of a Sample from the S c o t t i e Gold Mine 7 Appendix I I . Preliminary Evaluation of P o t e n t i a l Environmental Impacts Associated with Proposed Gold Mining Operations near Stewart, B.C. 56 Appendix V. Letter from Stewart Council (to be provided). — 136 Appendix IV. Golder Associates Ltd, S i t e Evaluation Summit Lake. Appendix I I I . P o l l u t i o n Control Objectives for the Mining, M e t a l l u r g i c a l and Related Industries of B.C. Tota l Length: B. MOE Terms of Reference 1. General Topics a) Mine Name: Quesnel Fluorspar Topics Addressed: A table of contents was not presented. However, the section headings are: 1. Surface Water 1.1 Surface Water Quality 1.1.1 Hydrology 1.1.2 Preliminary Water Management Plan 1.1.3 Water Balance 1.2 Surface Water Quality 1.2.1 Acid Generation Potenial 1.2.2 Abnormal E f f l u e n t Quality 1.2.3 Water Quality Monitoring 1.2.5 Documentation of Water Uses 2. Groundwater 2.1 Groundwater Quantity 2.2 Groundwater Quality 2.2.1 Abnormal Drainage 2.2.2 Groundwater Quality Monitoring 3. Waste Management 3.1 Preliminary Waste Management Plan 3.1.1 Acid Generating P o t e n t i a l 3.1.2 E f f l u e n t Discharges 3.1.3 T a i l i n g s Disposal 3.1.4 P i l o t Plant 3.1.5 Drainage 3.1.6 T a i l i n g s S p i l l s 3.1.7 Emissions and Ambient A i r Quality 3.1.8 C l i m a t o l o g i c a l Information 3.1.9 F a c i l i t i e s 4. F i s h e r i e s 4.1 T o x i c i t y 4.2 F i s h Habitat 5. W i l d l i f e 6. Te r r a i n , Vegetation and S o i l s 7. Recreational Resources b) Mine Name: Nickel Plate Topics Addressed: A table of contents was not presented. However, the section headings are: 1. Surface Water Management 1.1 Mine Water Uses 1.2 Water Management Plan 1.3 Surface Hydrology 2 1 137 pages 137 1.4 Surface Water Quality 2. Groundwater Management 2.1 Suggested Framework for Hydrological Study 2.2 Requested Parameters for Groundwater Quality Assessment 2.3 Mine Drainage 3. Waste Management 3.1 Waste Management Plan 3.2 Acid Generation P o t e n t i a l 3.3 A i r Emissions Management 4. F i s h e r i e s 5. W i l d l i f e 6. T e r r e s t i a l Environment 7. Reclamation 2. Review of the Contents of Two Recent Terms of Reference for  Pre-development Assessments The Ministry of Environment Terms of Reference (TOR)for the Quesnel Lake Fluorspar Project and the Nickel Plate Gold Project were reviewed. The general objectives and the information and a n a l y t i c a l requirements for managing impacts on f i s h e r i e s resources are outlined b r i e f l y below. a) General objectives The Quesnel Lake TOR stresses the development of s t r a t e g i e s or plans "to manage" possible impacts. The objectives of s p e c i f i c information requests are usually "to resolve any t e c h n i c a l or p o l i c y concerns related to" the topic under consideration (eg. surface water q u a l i t y ) . These objectives are not stated i n the Nickel Plate TOR but the development of impact management plans i s emphasized. b) Information and a n a l y t i c a l requirements In the Quesnel Lake TOR, the mine proponent i s directed to consider f i s h e r i e s concerns i d e n t i f i e d i n other TOR sections, Surface Water Quality, Ground Water Quality and Waste Management ( s p e c i f i c a l l y , t o x i c leachates, e f f l u e n t s and acid generation), and to "present a strategy to manage any p o t e n t i a l impacts on water q u a l i t y and f i s h e r i e s due to such sources." Possible accidental s p i l l s of concentrate to be moved across a lake by barge are also to be assessed. In the Nickel Plate TOR, the mine proponent i s not directed to consider the concerns i d e n t i f i e d i n other Sections of the Terms of Reference, but i s i n s t r u c t e d to "present a statement of anticipated impacts, during construction and operation of the project". The type of information requested i n each TOR for f i s h e r i e s , surface water q u a l i t y , groundwater q u a l i t y and waste management i s described b r i e f l y below. i . F i s h e r i e s studies F i e l d information i s requested f o r : i d e n t i f i c a t i o n of species present, d i s t r i b u t i o n and r e l a t i v e abundance; habitat d i s t r i b u t i o n and habitat u t i l i z a t i o n on a seasonal basis. In addition, the Quesnel Lake TOR requests information on present and p o t e n t i a l c a p a b i l i t y of spawning and other habitat. The Nickel Plate TOR also requests: "a d r a f t s u r v e i l l a n c e and supervision plan" to be used during construction and operation; four to f i v e q uantitative benthic invertebrate studies ( p r i o r to development) describing "taxonomy, density ( p r o d u c t i v i t y ) , and seasonality"; "some q u a l i t a t i v e and quantitative sampling of the periphyton community"; determination of the 138 metal content i n f i s h muscle and metallothionein l e v e l i n f i s h l i v e r . For the Nickel Plate project, the mine operators had proposed using a nearby lake for water storage and were therefore instructed to examine the e f f e c t s of storage and drawdown on angling and biomass. i i . Surface Water Quality In the Quesnel Lake TOR, information i s requested f o r : p o t e n t i a l acid generation; bioassays and chemical analyses of p i l o t scale or laboratory m i l l t a i l i n g s ; ore r a d i o a c t i v i t i y ; pre-development water q u a l i t y sampling at four locations (the frequency of pre-development sampling i s not s p e c i f i e d , but a l i s t of factors to be "monitored" indicates monthly sampling of some vari a b l e s , 3-4 samples per year for others and weekly sampling of suspended s o l i d s during freshet conditions); documentation of possible water uses ( i e . drinking water, supply, aquatic l i f e , recreation, i r r i g a t i o n , l i v e s t o c k watering and w i l d l i f e ) including f i s h species present, numbers, importance, and locat i o n s of spawning, rearing and overwintering areas. The request for f i s h e r i e s information i s redundant and has been discussed above. In the Nickel Plate TOR, information i s requested f o r : water use; pre-development sampling at 4 locat i o n s with r e s u l t s from at l e a s t three sampling periods included i n the Stage I report. i i i . Groundwater Quality In the Quesnel Lake TOR, information i s requested f o r : samples from a d i t s , wells or springs and leached mine material; f i s h bioassays and estimated quantities of groundwater or leachate, i f q u a l i t y i s poor; influence of b l a s t i n g agents; q u a l i t y sampling i n spring and l a t e summer; out l i n e of an on-going monitoring program to "be conducted seasonally during the f i r s t year of operation and thereafter at l e a s t annually". In the Nickel Plate TOR, a det a i l e d o u t l i n e of f a c t o r s to be addressed i n a "hydrological study" i s presented. This does not include bioassays. i v . Waste management The Quesnel Lake TOR states: "The Stage I report should describe as completely as possible the nature of a l l anticipated emissions, e f f l u e n t s and refuse during the development and operation of t h i s proposed project. Estimated flow rates, proposed method(s) of treatment, q u a l i t y before and a f t e r treatment and points of discharge should a l l be included. The Stage I Report should o u t l i n e provisions to prevent s p i l l s of any chemicals or o i l products that may be used at the mine, or of concentrate during any part of the transportation system. Contingency plans to manage any s p i l l s that do r e s u l t should also be included. Review of t h i s preliminary waste management plan w i l l greatly f a c i l i t a t e the M i n i s t r y ' s processing of Permit a p p l i c a t i o n s when they are submitted." In addition, information i s requested f o r : acid generation p o t e n t i a l and the mineral composition of rock material; the addition rates for a l l reagents and t h e i r addition locations; modelling of p a r t i c u l a t e emissions; measurement of wind and precipation; the l o c a t i o n of proposed f a c i l i t i e s (eg. chemical storage, work camp). The Nickel Plate TOR emphasizes "long range, post operating controls for mine s i t e drainage, t a i l i n g s supernatant and t a i l i n g s seepage" in c l u d i n g : mapped locatio n s of "the concentrating plant, t a i l i n g s ponds, waste rock p i l e s , etc."; types and q u a n t i t i t e s of a l l processing reagents and t h e i r breakdown products; minerals i n the ore that might a f f e c t cyanide destruction; analysis of chemical constituents i n the m i l l t a i l i n g s pond, supernatant and other discharges; t o x i c i t y of the pond supernatant; treatment and disposal of drainage; explosives use; contingency plans for 139 accidents, s p i l l s or p i p e l i n e ruptures; storage of runoff and drainage water and contingencies i f storage i s exceeded; equipment and methods for the transport of cyanide; acid generation p o t e n t i a l . 140 APPENDIX VI Stage JE Report Format Recommended i n the "Procedures for  Obtaining Approval of Metal Mine Development" 141 OUTLINE OF THE STAGE I REPORT The following outline is suggested. The exact format need not be followed but should serve rather as a check-list. The entire Stage I Report, for most projects, should not exceed 100 pages. TABLE OF CONTENTS SUMMARY ACKNOWLEDGEMENTS (authors and contributors to this report) INTRODUCTION 5 pages History Location Brief project description and schedule of development DESCRIPTION OF EXISTING ENVIRONMENTAL AND SOCIAL CONDITIONS 30 pages Physiography Land tenure Climate Air Quality Surface Water Drainages Water quality Hydrology Fisheries Groundwater Quantity Quality Soils and surficial geology Vegetation Wildlife Land Capability and Use Agriculture, Forestry, Recreation, Trapping, Guiding Historic and Archaeological Sites Existing Social Environment Population Employment Housing Education Commercial services continued: 142 PROJECT DESCRIPTION 30 pages Exploration Description of Deposit Options considered Mine Development ( p i t , underground, waste d i s p o s a l , reclamation, drainage control) M i l l (Process d e s c r i p t i o n , loading,storage, waste d i s p o s a l , water supply, drainage c o n t r o l , reclamation) Transportation Sewage and Garbage disposal U t i l i t i e s Employment Housing Detailed Development Schedule Reclamation o b j e c t i v e s , f a c i l i t i e s and s t a f f Drainage c o n t r o l and monitoring E f f l u e n t c o n t r o l and monitoring ENVIRONMENTAL AND SOCIAL IMPACTS 10 pages - should address i t s e l f to s i g n i f i c a n t impacts or an i d e n t i f i c a t i o n of environmental concerns which w i l l be assessed i n submissions f o r permit a p p l i c t i o n s . PROPOSED FURTHER STUDIES 5 pages 

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