1. Environment Canada’s Intervention on the Doris North Gold Project Water Licence Application Savanna Levenson/ Dave Fox / Anne Wilson Environmental Protection Operations Division August 13 – 15, 2007

2. Page 2 Overview Environment Canada’s presentation will cover the following areas: Mandate of Environment Canada (EC) Comments and recommendations regarding: –Discharge criteria –Aquatic Effects Monitoring Program (AEMP) –Monitoring of Seepage –Waste Management & Incineration issues

3. Page 3 EC’s Mandate Department of the Environment Act Fisheries Act – Pollution Prevention Provisions Canadian Environmental Protection Act Canada-Wide Standards for Mercury Emissions Canada-Wide Standards for Dioxins and Furans

4. Page 4 Water Quality

5. Page 5 Water Quality Discharge Criteria – Tail Lake and Doris Creek Miramar Hope Bay Ltd. (MHBL) predicts that by managing effluent discharge volumes with flows in Doris Creek, water quality below the waterfall can be maintained at or below the Canadian Council of Ministers for the Environment (CCME) Guidelines for the Protection of Freshwater Aquatic Life. Two compliance points are proposed: –MMER limits will be met at the end of pipe for Tail Lake; –CCME guidelines will be met at the waterfall in Doris Creek.

6. Page 6 Water Quality Discharge Criteria – Tail Lake and Doris Creek MHBL has proposed to meet criteria for the parameters shown in Table 5.2 of the Revised Monitoring and Follow-up Plan, and to monitor supporting variables shown in Table 3.10 of the Revised Water Licence Application Support Document. There are a number of major ion parameters of potential concern which do not have CCME guideline values yet. Many of the baseline values for Table 5.2 parameters are considerably lower than CCME levels.

7. Page 7 Water Quality Discharge Criteria – Tail Lake and Doris Creek Recommendations: Doris Creek EC recommends that compliance criteria in Doris Creek be set for a slightly broader range of parameters than shown in Table 5.2, with receiving environment targets which are more site-specific. In the case of parameters which have baseline concentrations which are substantially below CCME guideline values, (i.e. ammonia, nitrate, nitrite, arsenic, iron, lead, mercury, molybdenum, nickel, silver, thallium and zinc), management objectives should be to maintain those parameters at the lowest possible concentrations in the receiving environment.

8. Page 8 Water Quality Discharge Criteria – Tail Lake and Doris Creek Recommendations Cont’d: For parameters which do not have CCME guidelines (such as chloride and TDS) it is recommended that MHBL set management targets which will maintain ambient conditions within a reasonable range, to ensure concentrations in the downstream aquatic environment will be protective of aquatic life. EC has reconsidered setting a TSS limit in Doris Creek, as the end-of-pipe limit is considered as protective.

9. Page 9 Water Quality Discharge Criteria – Tail Lake and Doris Creek Recommendations cont’d: Tail Lake A limit for ammonia in the Tail Lake effluent outflow should be set, and EC recommends this be set at 6 mg/L NH 3 -N for the Maximum Average Concentration. This value is intended to be consistent with effluent concentrations which will not result in bioassay failure. EC also supports the monthly testing for BOD 5 and Fecal Coliforms and suggests limits of 15 mg/L BOD 5 and 100 CFU/dL for FC

10. Page 10 Water Quality Aquatic Effects Monitoring Program (AEMP) The AEMP has been designed to comply with the MMER Environmental Effects Monitoring (EEM) requirements, but a more comprehensive program is needed to provide enough information to allow adaptive management to be used. The timescale outlined in the EEM program and proposed for this project is not suitable for a short 2 year mine life. The 2003 monitoring plan which was submitted with the water licence application is also outdated; EC recommends that submission of an updated AEMP be required as a licence condition.

11. Page 11 Water Quality Aquatic Effects Monitoring Program (AEMP) Recommendations: EC recommends that the proponent design an AEMP which monitors water quality, sediments, benthic invertebrates, productivity, and fish on an appropriate frequency, with annual reporting of results. The program should be designed to capture the extent of seasonal and spatial variability in the aquatic ecosystems, and should utilize appropriate reference sites. In addition to meeting the objectives outlined in Section 1.3 of the Monitoring and Follow-Up Plan the AEMP should be sufficiently comprehensive to detect effects which may not have been predicted.

12. Page 12 Water Quality Aquatic Effects Monitoring Program (AEMP) Monitoring ParameterLocationFrequencyAEMPMMER Water quality*1,2,3,4,5Freshet, mid- summer, fall 2008 2009 2010 Sediment quality**1,3,5Every 3 years2010 Benthic Invertebrates***1,2,3,4Every 2 years20082010 Fish****1,2,3,4Every 3 years2010 *includes field measurements, physicals, major ions, total metals, nutrients, CN & chl a **total metals, TN,TP, TC, TOC, PSA ***MMER EEM Guidance, as proposed in Golder 2003 Study Design report ****MMER EEM Guidance, as proposed in Golder 2003 Study Design report 1. Little Roberts Lake 2. Little Roberts Stream 3. Reference Lakes A&B 4. Reference Stream A 5. Roberts Bay

13. Page 13 Water Quality Seepage Monitoring MHBL proposes annual freshet surveys along areas where blast rock has been used, utilizing field and lab measurements, as appropriate. EC supports the tiered approach to monitoring, however a subset of the field measurements should be backed up with laboratory analysis of a seepage sample for the parameters of concern (e.g. ammonia, sulphate, iron, aluminum). Given the variability in natural tundra pH values, it would be advisable to add reference sites to the routine surveys.

14. Page 14 Water Quality Issue: Seepage Monitoring Recommendations: The annual seepage surveys should include periodic analysis of a limited subset of seepage samples, and routine field monitoring of several reference points which are not subject to mine influences.

15. Page 15 Miscellaneous Points Under the Surveillance Network Program (SNP) there appears to be duplication between the toxicity and water quality testing proposed at the reclaim pump and at the end of pipe. This should be reviewed and eliminated if appropriate. Erosion prevention is an important mitigative measure for all discharges during construction, for example from collection ponds and the sewage outfall. Discharge must be to suitable substrates, and ponding must be prevented, as that can lead to thermal erosion.

16. Page 16 Waste Management

17. Page 17 Waste Disposal -- Incineration Incineration is a waste disposal option at remote facilities Reduction in volume of waste through combustion Incineration can produce emissions of many toxic contaminants including dioxins and furans

18. Page 18 Incineration – Not an AQ Issue Incineration is not an Air Quality Issue Dominant exposure pathways for incineration contaminants are: ▪Sediments; ▪Water column; ▪Vegetation; and ▪Soil.

19. Page 19 Dioxins and Furans Product of incomplete combustion –Organic matter + chlorine Incineration of MSW is the largest source Persistent in the environment Bioaccumulate Toxic

20. Page 20 Environmental Fate -- Terrestrial Air Vegetation Animals Dry Deposition Ingestion

21. Page 21 Environmental Fate -- Aquatic Air Soil Water Sediments Benthics Fish Wet/Dry Deposition Runoff/Erosion Sedimentation Ingestion/filtering of contaminated particles Ingestion

22. Page 22 Environmental Fate – Food Chain

23. Page 23 CCME Canada-wide Standards Canada-wide Standards for Dioxins and Furans Canada-wide Standards for Mercury Emissions CWS focus on: –Emission limits for incineration –Demonstration through: ▪Determined efforts ▪Stack testing

24. Page 24 Determined Efforts for Incineration Incineration Waste Management Technology Operation

25. Page 25 Waste Management Reduce the amount of waste to be incinerated. Only food and food contaminated waste should be incinerated. Divert non-incineration waste to more appropriate disposal options.

26. Page 26 Incineration Technology Incinerator must achieve the 3 T’s –Temperature (>1000C) –Time residency (1 to 2 sec) –Turbulence Best Available Technology –Dual chamber –Controlled air –Wet Scrubber

27. Page 27 Incinerator Operation Operator Training –Temperature, types and amount of waste Maintenance Record keeping

28. Page 28 Incineration Management Plan Recycling/segregation waste program Selection of incineration technology Waste audit -- amount and types of waste incinerated Operational and maintenance records Operator training Emission measurements Incinerator ash disposal Annual Report

29. Page 29 Proponent’s commitments Compliance with Canada-wide Standards –Annual stack testing Waste segregation program Operator training

30. Page 30 Incineration Recommendations Develop an Incineration Management Plan in consultation with EC Incinerator ash should be tested to determine appropriate disposal option Waste oil should tested for contaminants and only burned in an approve oil burner

31. Page 31 Open burning Only paper products and untreated wood are suitable for open burning. Cyanide contaminated wood should not be burn in an open pit.

32. Page 32 Closure EC thanks the Board for this opportunity to present our submission, and would be happy to take any questions.