Review Comment Table

Transcription

1 Review Comment Table Board: Review Item: File(s): Proponent: Document(s): Item For Review Distributed On: Reviewer Comments Due By: Proponent Responses Due By: Item Description: WLWB Ekati - Sable Update - Waste Management Plan Version 3.0 (W2012L2-0001) W2008D0007 W2012L Dominion Diamond Ekati Corporation Waste Management Plan Version 3.0 (3MB) Aug 2 at 16:27 Distribution List Aug 2 at 16:28 Distribution List Aug 19, 2016 Aug 24, 2016 Dominion Diamond Ekati Corporation (DDEC) submitted Version 3.0 of its Waste Management Plan (WMP) to the Wek èezhìi Land and Water Board, on June 23, This Plan has been updated to include the Sable Development and was submitted in accordance with Part C, Item 12 of Land Use Permit W2008D0007. The purpose of this review is to determine whether the Waste Management Plan fulfills the requirements of Part H, Item 1 of Water Licence W2012L2-0001, and to addresses the Board's February 2, 2016 direction. An expedited review process is being carried out to ensure the Board can consider this submission prior to the Construction at Sable development, anticipated to commence September 1, Reviewers are encouraged to submit comments and recommendations on the contents of the Waste Management Plan Version 3.0 prior to the reviewer comment deadline. Contact Information: Meghan Schnurr Sarah Elsasser

2 Comment Summary Dominion Diamond Ekati Corporation (Proponent) ID Topic Reviewer Comment/Recommendation Proponent Response Board Staff Response 1 General File Comment (doc) High resolution PDF version of the Waste Management Decision Tree Recommendation GNWT - ENR: Central GNWT ID Topic Reviewer Comment/Recommendation Proponent Response Board Staff Response 3 General File Comment (doc) ENR Letter with Comments and Recommendations Recommendation 1 Topic 1: Hazardous Waste Management Plan Comment The following comment is in reference to (page 4) Hazardous Waste Definition of the Hazardous Waste Management Plan The Hazardous Waste Management Plan indicates that hazardous waste is defined by the TDGR Act and Regulations. The definition of hazardous waste is defined in the Guideline for the General Management of Hazardous Waste in the NWT and references the TDGR but exempts Class 1 (Explosives) and Class 7 (Radioactives), but also references criteria for industrial waste discharges. In addition to the TDGR, the management of explosives and radioactive material are regulated by different federal agencies. The Guideline for the General Management of Hazardous Waste in the NWT outlines the Aug 23: DDEC adheres to the definition of "hazardous waste" that is presented in the Guideline for the General Management of Hazardous Waste in the NWT, which does not include Class 1 Explosives and Class 7 Radioactive Materials. Class 1 and Class 7 materials are classified according to the Transportation of Dangerous Goods Regulations. DDEC can confirm that the ultimate disposal of hazardous waste is conducted according to the Guideline for the General Management of Hazardous Waste in the NWT. DDEC will provide this clarification and confirmation in the next version of the Hazardous Waste Management Plan.

3 2 Topic 2: Disposal of Class I and Class 7 Radioactive Material roles and responsibilities of generators, carriers and receivers of hazardous waste in the NWT. Ekati Diamond Mine has been registered as a generator of hazardous waste in the NWT as "NTG090" since Recommendation 1) It is recommended DDEC clarify the definition of hazardous waste and confirm that the ultimate disposal of hazardous waste is conducted according to the Guideline for the General Management of Hazardous Waste in the NWT. Comment The Waste Management Plan indicates that it disposes of its hazardous waste at KBL Environmental Ltd. (KBL), including Class I explosives, and Class 7 radioactive material. KBL is a registered receiver of hazardous waste according to the Guideline for the General Management of Hazardous Waste in the NWT; however, KBL is not registered to accept Class 1 and Class 7 radioactive material. Recommendation 1) It is recommended DDEC clarify this section to confirm how and where Class I and Class 7 materials are ultimately being disposed. Aug 23: KBL Environmental Ltd. (KBL) is able to facilitate and coordinate the disposal of Class 1 Explosives and Class 7 Radioactive Materials as long as the materials are manifested direct from Ekati Diamond Mine to an end reciever and remain in transport. Should the Ekati Diamond Mine generate Class 1 or Class 7 waste, KBL will facilitate and coordinate the disposal from site to the end reciever. This clarification will be provided in the next version of the Waste Management Plan.

4 Independent Environmental Monitoring Agency: Marc Casas ID Topic Reviewer Comment/Recommendation Proponent Response Board Staff Response 1 General File Comment (doc) Agency comment letter regarding the Waste Management Plan v. 3.0 Recommendation WLWB: Meghan Schnurr ID Topic Reviewer Comment/Recommendation Proponent Response Board Staff Response 1 Compost - Not a wildlife attractant 2 Compost - Testing of compost Comment The Design Plan for the compost curing pad does not include a fence or other design element to keep wildlife out of the curing pad. DDEC has stated in the Compost Management Plan that Ekati compost has been "proven not to be a wildlife attractant." DDEC has stated in the that in order for compost not to attract wildlife, complete composting of wastes is required. In addition, DDEC has committed to use of wildlife cameras to monitor the curing pad to ensure wildlife are not approaching the composting pad. Recommendation Please provide details regarding how DDEC has proven its compost is not a wildlife attractant. Comment In section 3.5.1, DDEC has outlined its approach to testing compost. DDEC has explained that testing of compost will be completed on representative samples of "mature compost." It is unclear at what stage of the process compost is considered to be Aug 23: DDEC is using wildlife cameras to monitor lined mega bags and plastic totes full of uncured compost, which are currently being staged in the same area the compost curing pad will be constructed. This compost has spent the minimum of 9 days in the in-vessel composter. Data collected from the wildlife cameras is frequently reviewed by Environment Department staff, and no evidence of wildlife attraction has been noted to date. Aug 23: Section 2.3 of the Compost Management Plan outlines DDEC's definition of "mature compost". As per the Canadian Council of Ministers of Environment (CCME) Guidelines for Compost Quality, DDEC will allow the compost generated on site to cure for the

5 3 Waste Management Plan - Waste Decision Tree (figure 5) mature. For example, is it after the 9 days in the composter, or after the compost has completed the curing process? Recommendation Clarify at what stage of the process compost is considered "mature" and will be tested. Comment In review of the Waste Decision Tree presented in Version 2.0 of the Waste Management Plan, some concerns were raised regarding potentially conflicting information between the Decision Tree and sections of the WMP (outlined in the Board's February 2, 2016 Reasons for Decision). DDEC has confirmed it has updated its Waste Decision Tree, but the figure provided is of very low resolution and therefore difficult to read and review. Recommendation Please provide a higher resolution version of the waste decision tree (figure 5) included in Version 3.0 and discuss the feasibility of including a higher resolution figure in future versions. minimum of 21 days. DDEC will send samples of the cured product for testing at an independent laboratory. The laboratory results will confirm if the compost meets the requirements for respiration rate, carbon dioxide evolution rate, or temperature rise as per the CCME Guidelines for Compost Quality. Aug 23: DDEC will provide a higher resolution figure in future versions. DDEC has submitted a high resolution version of this figure with these responses.

6 August 19, 2016 Violet Camsell-Blondin Chair Wekeezhii Land and Water Board # th Street Yellowknife, NT X1A 3S3 Dear Ms. Camsell-Blondin, Re: Domininion Diamond Ekati Corp. (DDEC) Water Licence W2012L Waste Management Plan Version 3 - Sable Update Request for Comment The Department of Environment and Natural Resources (ENR), Government of the Northwest Territories has reviewed the plan at reference based on its mandated responsibilities under the Environmental Protection Act, the Forest Management Act, the Forest Protection Act, the Waters Act and the Wildlife Act and provides the following comments and recommendations for the consideration of the Board. Topic 1: Hazardous Waste Management Plan Comment(s): The following comment is in reference to (page 4) 4.1 Hazardous Waste Definition of the Hazardous Waste Management Plan The Hazardous Waste Management Plan indicates that hazardous waste is defined by the TDGR Act and Regulations. The definition of hazardous waste is defined in the Guideline for the General Management of Hazardous Waste in the NWT and references the TDGR but exempts Class 1 (Explosives) and Class 7 (Radioactives), but also references criteria for industrial waste discharges. In addition to the TDGR, the management of explosives and radioactive material are regulated by different federal agencies. The Guideline for the General Management of Hazardous Waste in the NWT outlines the roles and responsibilities of generators, carriers and receivers of hazardous waste in the NWT. Ekati Diamond Mine has been registered as a generator of hazardous waste in the NWT as NTG090 since

7 Recommendation(s): 1) It is recommended DDEC clarify the definition of hazardous waste and confirm that the ultimate disposal of hazardous waste is conducted according to the Guideline for the General Management of Hazardous Waste in the NWT. Topic 2: Disposal of Class I and Class 7 Radioactive Material Comment(s): The Waste Management Plan indicates that it disposes of its hazardous waste at KBL Environmental Ltd. (KBL), including Class I explosives, and Class 7 radioactive material. KBL is a registered receiver of hazardous waste according to the Guideline for the General Management of Hazardous Waste in the NWT; however, KBL is not registered to accept Class 1 and Class 7 radioactive material. Recommendation(s): 1) It is recommended DDEC clarify this section to confirm how and where Class I and Class 7 materials are ultimately being disposed. Comments and recommendations were provided by ENR technical experts in the Environment Division and the North Slave Region and were coordinated and collated by the Environmental Impact Assessment Section, Conservation, Assessment and Monitoring Division (CAM). Should you have any questions or concerns, please do not hesitate to contact Patrick Clancy, Environmental Regulatory Analyst at (867) Ext: or patrick_clancy@gov.nt.ca. Sincerely, Patrick Clancy Environmental Regulatory Analyst Environmental Impact Assessment Conservation, Assessment and Monitoring Division Department of Environment and Natural Resources Government of the Northwest Territories 2

8 INDEPENDENT ENVIRONMENTAL MONITORING AGENCY P.O. Box 1192, Yellowknife, NT X1A 2N8 Phone (867) Fax (867) Website: August 19, 2016 Violet Camsell-Blondin Chair, Wek eezhii Land and Water Board # th St, Yellowknife, NT X1A 3S3 Dear Ms. Camsell-Blondin, Re: Waste Management Plan Version 3.0 The Independent Environmental Monitoring Agency (Agency) has reviewed Dominion Diamond Ekati Corporation s (DDEC) Waste Management Plan (WMP) Version 3.0 with particular emphasis on past Agency comments and Wek eezhii Land and Water Board (WLWB) directives. The Waste Management Plan has gone through several revisions based on reviewer input and WLWB directives since version 1.0 was submitted in The result is a much improved WMP. DDEC has done a commendable job incorporating and tracking the many changes over the years that have led to the latest version of the WMP. Therefore, the Agency does not have any specific comments or recommendations on the WMP version 3.0. Should you have any questions concerning this letter, the Agency would be pleased to discuss them at your convenience. Sincerely, Jaida Ohokannoak Chairperson Cc: DDEC April Hayward Tlicho Government - Sjoerd van der Wielen Yellowknife Dene First Nation Alex Power Lutsel K e Dene First Nation Lauren King North Slave Metis Alliance Shin Shiga Kitikmeot Inuit Association Jared Ottenhof

9 Government of the Northwest Territories Laurie McGregor Indigenous and Northern Affairs Canada Jennifer O Neil

10 YES INCINERATOR WASTE BINS, OFFICE BINS, or ACCOMMODATIO NS ROOM BINS OR COMPOST BINS FOOD-RELATED, PAPER/CARDBOARD WASTE, or TOBACCO PRODUCT PACKAGING AEROSOLS, BATTERIES, PLASTIC AND METAL DRINK CONTAINERS ALL PLASTICS YES SHARPS, RAZOR BLADES, SYRINGE/ NEEDLES OR MEDICATION VIALS YES RECYCLING BINS LOCATED THROUGHOUT ALL EKATI AND MISERY LIVING QUARTERS AND WORK AREAS OILY RAGS, ABSORBENT PADS, HYDROCARBON IMPACTED PRODUCTS INCLUDING OUTERWEAR AND CARDBOARD YES IS THE PRODUCT OR EMPTY CONTAINER WHMIS CONTROLED AND PROPERLY LABELED AS SUCH YES SOLID, N- RECYCLABLE, INERT, FREE OF WILDLIFE ATTRACTANTS? Examples: Wood Cardboard Steel Rubber Air Filters YES Contact Waste Advisor at 2505 or drop off at the Waste Management Building WASTE MANAGEMENT DECISION TREE YELLOW SHARPS RECEPTACLES in the laundry rooms OILY RAGS BIN IN WORK AREAS AND DRYS OR DROP OFF AT WASTE MANAGEMENT Contact the Waste Advisor at 2505 or drop off at Waste Management Building LANDFILL BIN Note: Individuals delivering waste to the landfill is prohibited, please contact Camp Services at 2012 or Waste Management at 2505