Jacqueline Ho, Mackenzie Valley Land and Water Board

Transcription

1 To: From: cc: Subject: Jacqueline Ho, Mackenzie Valley Land and Water Board Judy Dudley John Key, Julian Morse, Tim Smith, Jeff Hussey MVLWB May 15, 2018 Information Request for MV2018L2-003 Pine Point Mining Limited (PPML) has prepared the following responses to the Information Request (IR) sent to us by your agency on May 15, Introduction The PPML team has submitted an application that is as innocuous as we could make it and still complete the required work in the timeframe needed. PPML has worked hard to build relationships with Affected Parties; agreements are in place that provide greater benefits when the drill program can expand under this new permit. Support for our application from the most highly affected parties is evident by comments posted on the MVLWB Online Review System. For every hole drilled, this project will provide economic benefits to the South Slave region. Money that must be spent on costly SNPs and long water hauls will reduce the number of holes we drill and will reduce the economic benefits to the local communities. It should be noted that the drill cuttings and water that are collected at the collar of the drill holes is nothing more than dolomite and limestone (calcite), both excellent buffers, that will keep the ph high and prevent the leaching of any base metals into the water. Furthermore, limestone and dolomite form the rock substrate in the entire area. A limestone-based slurry, similar to our drill cuttings, is being used to treat the runoff at Cominco s tailings management system north of this project area. PPML is not aware of any study that documented the regional water supply or water quality was negatively impacted by the 18,000 holes that Cominco drilled in their exploration program. GNWT is sending a negative message to prospective explorers by requesting unnecessary monitoring programs and unreasonable security on simple exploration programs. Item a. Quality and Location of Water Sources PPML is convinced that using water from the nearest abandoned pit site or drainage canal is the most sustainable alternative for project operations. Site selection in a confirmation drilling program is an iterative process. A drill target is chosen only after:

2 #1) statistical analysis has indicated more data is required for a particular deposit; #2) old Cominco drill collars at that deposit can be located and surveyed; and #3) PPML can confirm that all of the equipment and personnel are available to proceed. If those factors are in place, then PPML sends drill target information to the Inspector and Board. Barring objections, that drill target is then added to the schedule for drilling. PPML typically identifies the best source of water to use for a particular target based upon which sources might be frozen, proximity to target, access issues, etc. This IR implies that PPML needs to commit to use of only very specific water sources over the life of the permit when we don t know where we will be drilling over the entire life of the permit. If that should become a firm requirement, the Board needs to understand that unnecessary expense associated with water haulage costs will be imposed on PPML. This will also result in higher fuel consumption and generation of greenhouse gases and other vehicle emissions. Based on results, follow-up drill targets are developed or cancelled. PPML has identified the pits shown on Figures 1 3 as the most likely sources of water to be used in the confirmation drilling program. Figure 1. Possible Sources of Water for the Confirmation Drilling Program Central Zone Pits. (PPML Lease Boundary in Purple, Areas Most Likely to be Drilled in Red) 2

3 Water quality results are available for pits K-62 and J-69. Those data are provided below in Table 1. PPML believes the results support our position that pit water is suitable for use in this program. Table 1. Water Quality Data for Mine Pits J-69 and K-62. Sample ID Units Pit J-69 Pit K-62 Sample Type Mine Pit Mine Pit Sample Date 10/24/ /24/2017 Northing / Latitude Easting / Longitude True Colour CU < 5.0 < 5.0 Conductivity us/cm ,930 Hardness CaCO3 1, ph TDS 1,450 1,620 Turbidity NTU Alkalinity CaCO Ammonia < Bromide < < Chloride Fluoride Nitrate < < Nitrite < < TKN Sulfate Aluminum 0.04 < Antimony < < Arsenic < < Barium Beryllium < < Bismuth <0.005 <0.005 Boron <0.25 <0.25 Cadmium < < Calcium Chromium <0.005 <0.005 Cobalt <0.001 <0.001 Copper < < Iron <0.05 <0.05 Lead <0.001 <

4 Sample ID Units Pit J-69 Pit K-62 Lithium Magnesium Manganese <0.005 <0.005 Mercury < < Molybdenum <0.005 <0.005 Nickel <0.005 <0.005 Potassium Selenium < < Silicon Silver < < Sodium Strontium Thallium Tin <0.025 <0.025 Titanium <0.025 <0.025 Uranium Vanadium <0.025 <0.025 Zinc <0.025 Zirconium < < Figure 2. Possible Sources of Water for Summer 2018 Confirmation Drilling Program East Zone Pits 4

5 Water quality results are available for pits J-44 and O-42. Those data are provided below in Table 2. PPML believes the results support our position that pit water is suitable for use in this program. Table 2. Water Quality Data for Mine Pits J-44 and O-42 (samples collected by Knight Piesold for Avalon Advanced Metals) Sample ID Units SW5; Pit J- SW5; Pit J- SW5; Pit J- SW7; Pit O- SW7; Pit O Sample Type Mine Pit Mine Pit Mine Pit Mine Pit Mine Pit Sample Date 28-Feb-11 9-Aug Apr Mar Aug-11 Northing / Latitude Easting / Longitude True Colour CU 6 9 <2 Conductivity us/cm Hardness CaCO ph TSS <3.0 < <3.0 <3.0 TDS Turbidity NTU Acidity as CaCO3 <5 <5 <5 Alkalinity CaCO Bromide <DL <DL <DL <DL <DL Chloride <DL Nitrate <DL <DL <DL <DL Nitrite <DL <DL <DL <DL <DL Dissolved ortho- Phosphate <DL <DL Phosphorus <DL <DL <DL Sulfate Aluminum <DL <DL 1.52 <DL Antimony <DL <DL <DL <DL <DL Arsenic <DL <DL <DL Barium Beryllium <DL <DL <DL <DL <DL Boron <DL Cadmium <DL <DL <DL Calcium Chromium <DL <DL <DL <DL <DL 5

6 Sample ID Units SW5; Pit J- SW5; Pit J- SW5; Pit J- SW7; Pit O- SW7; Pit O Cobalt <DL <DL <DL <DL <DL Copper <DL <DL <DL <DL Iron < <0.01 Lead < <0.005 Lithium <DL Magnesium Manganese <DL <DL Mercury <DL <DL Molybdenum <DL <DL <DL <DL <DL Nickel <DL Potassium Selenium <DL <DL <DL <DL <DL Silver <DL <DL <DL <DL <DL Sodium < Strontium Thallium <DL <DL <DL Tin <DL <DL <DL <DL <DL Titanium <DL <DL <DL <DL Uranium Vanadium <DL <DL <DL <DL Zinc

7 Figure 3. Possible Sources of Water for the Confirmation Drilling Program North Trend Pits. (PPML Lease Boundary in Purple, Areas Most Likely to be Drilled in Red) Water quality results are available for pits A-70. Those data are provided below in Table 3. PPML believes the results support our position that pit water is suitable for use in this program. Table 3. Water Quality Data for Mine Pit A-70 Sample ID Units Pit A-70 Sample Type Mine Pit Sample Date 10/24/2017 Northing / Latitude Easting / Longitude True Colour CU < 5.0 Conductivity us/cm 2,780 Hardness CaCO3 1,760 ph 8.2 TDS 2,570 Turbidity NTU 0.33 Alkalinity CaCO3 204 Ammonia 0.04 Bromide <

8 Sample ID Units Pit A-70 Chloride 55 Fluoride 1.2 Nitrate < Nitrite < TKN Sulfate 1550 Aluminum < Antimony < Arsenic < Barium Beryllium < Bismuth <0.005 Boron Cadmium < Calcium 408 Chromium <0.005 Cobalt <0.001 Copper < Iron <0.05 Lead <0.001 Lithium Magnesium 179 Manganese Mercury < Molybdenum <0.005 Nickel <0.005 Potassium 3.70 Selenium < Silicon 4.58 Silver < Sodium 43.6 Strontium 9.61 Thallium < Tin <0.025 Titanium <0.025 Uranium 0.00 Vanadium <0.025 Zinc <

9 Item b. Water Balance Anticipated water use compared to estimated volume of water in mine pits at the site in summarized on Figures 1 3. The estimated volumes of water for the pits in those figures was calculated and assumed depths of 10 m for pits in the East Zone and 20 m in the Central Zone and North Trend. Water use was estimated using the conservative estimate that each hole requires 1.5 days of drilling. So, for example, if there were 9 drills in continuous operation over a 90 day period the total water use would be 6750 m 3 for the 180 holes drilled, with an average water use of 225 m 3 per day. The water balance for a typical drill hole is presented in Figure 4. As noted in the application, comment responses, and in this figure, most of the water will be returned to the aquifer down the hole. To put this into perspective, PPML s winter 2018 exploration program drilled 129 holes for a projected water use of 4,838 m 3, of which it is estimated that 4740 m 3 were returned to the aquifer down the drill hole and 98 m 3 were returned into the overburden layer (total) over the course of 3 months. Compare that to Cominco s water use of 227 m 3 of water every minute during operations in 1984 (Ryan Silke, 2009, The Operational History of Mines in the Northwest Territories, Canada, p. 386). Figure 4. Water Balance for typical diamond drill operation at PPML Project Site. The conservative estimate provided by PPML in the WL application is that with the maximum number of drills in simultaneous operation this program would use ~243 m 3 of water per day. To put this volume into perspective, consider how that level of water use 9

10 might affect volume in a mine pit that was hypothetically disconnected from the aquifer and atmosphere and had no recharge or precipitation inputs. Dimensions of Cominco s mine pits have been reported (Ryan Silke, p. 383). A small, cylindrically shaped pit at the site would have a diameter of 152 m and a depth of 30.5 m for a hypothetical volume of 556,000 m 3 of water. It would take PPML more than 6 years to empty that pit if 9 drills were in operation every day (which won t happen) and drilling occurred 365 days per year (which won t happen) and the pit did not receive any additional water from precipitation or recharge (which it won t). In other words, the total amount of water to be used under this water license is substantially less than the total volume of water in one of the smaller sized mine pits at the site. Item c. Groundwater Quality and Hydrology The most current summary available to describe the hydrology at Pine Point was published in 2017 (NI Preliminary Economic Assessment Technical Report on the Pine Point Zinc Project, Northwest Territories, Canada; prepared by JDS Energy & Mining Inc.; prepared for Darnley Bay Resources Limited; June 1, 2017). As reported in that document, groundwater flows toward Great Slave Lake (see Figure 5). As further stated in the PEA, the aquifer storativity is high and flow velocity is relatively low at < 1 m/day (PEA p ). 10

11 Figure 5. Groundwater Gradient from Pine Point Area, blue arrows = groundwater flow direction, blue lines = groundwater contours (Source: JDS, 2017) Results from groundwater sampling conducted by Knight Piesold in 2011/12 in the Pine Point area are presented in Tables 4 and 5. The location of these sampling sites are shown in Figure 6 in relation to the area where PPML may locate one of the cuttings disposal areas, per inspector s approval. 11

12 Figure 6. Location of 2011 Groundwater Study Sites (green dots) in Relation to PPML's Primary Cuttings Disposal Site PPML insists the small volume of water removed from the aquifer by this program will not affect regional water supply or quality. It was estimated that Cominco removed more than one billion m 3 of groundwater from the aquifer from and still had struggles with groundwater infiltration into their mine pits (JDS, 2017, p ). If PPML drilled all 2500 holes over the 27-month life of this permit, a total of 1250 m 3 of water would be removed from the aquifer and deposited into the well-buffered cuttings disposal areas. Any of that water that percolates rather than evaporates would be immediately diluted by the large volume of native groundwater. The comparisons noted here are intended to put the drill program in context and help the Board make a relatively simple decision which would keep the drilling program on schedule for the early June start-up of the summer drilling program. Winter drilling is more expensive, leading to less exploration drilling footage. 12

13 Table 4. Groundwater Quality at Pine Point, 2011 (from Knight-Piesold study done for Avalon Advanced Metals). Sample ID Units DH DH S DH S DH D DH D DH DH DH Sample Date 4-Mar Feb-11 9-Aug Feb-11 9-Aug Feb-11 9-Aug-11 9-Aug-11 Northing m Easting m True Colour CU Conductivity us/cm Hardness CaCO3 ph TSS TDS Turbidity NTU Acidity as CaCO < Alkalinity CaCO3 Bromide <1.0 <1.0 <0.1 <1.0 <0.1 <1.0 <1.0 <1.0 Chloride Fluoride Ammonia <0.05 <0.05 <0.05 <0.05 <0.05 Nitrate <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Nitrite <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Kjeldahl Nitrogen Nitrogen Dissolved ortho- Phosphate Phosphorus <0.2 <0.2 <0.2 <0.2 <0.21 <0.21 <0.21 <0.21 <0.01 <0.01 <0.01 < <0.02 <0.02 <0.02 <0.02 < <0.02 Sulfate

14 Sample ID Units DH DH S DH S DH D DH D DH DH DH Cyanide <0.002 <0.002 <0.005 <0.002 <0.005 <0.002 <0.005 <0.005 Aluminum Antimony < < < < < < < < Arsenic Barium Beryllium <0.001 <0.001 <0.002 <0.001 <0.002 <0.001 <0.002 <0.002 Boron <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Cadmium < <0.001 < <0.001 < <0.001 <0.001 Calcium Chromium <0.005 < <0.005 <0.005 < <0.005 Cobalt <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 Copper < <0.001 Iron Lead <0.005 Lithium <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Magnesium Manganese Mercury < < < < Molybdenum <0.005 <0.005 < < < Nickel Potassium Selenium < < < < < < < < Silver < < <0.005 < <0.005 < <0.005 <0.005 Sodium Strontium Thallium < < <0.05 < < <0.05 <0.05 Tin <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <

15 Sample ID Units DH DH S DH S DH D DH D DH DH DH Titanium Uranium Vanadium <0.001 <0.001 < <0.001 Zinc Table 5. Groundwater Quality at Pine Point, 2011 & 2012 (from Knight-Piesold study done for Avalon Advanced Metals). Sample ID Units DH DH DH DH DH GT-PP11-08 PP11-01 PP11-02 PP11-03 PP11-04 PP11-05 Sample Date 4-Mar Feb-11 9-Aug Apr Apr Apr Apr Apr Apr Apr Apr- 12 Mineral Trend Main Main Main Main Main Main Main Main Main Main Main Northing m Easting m True Colour CU Conductivity us/cm Hardness CaCO3 ph TSS TDS Turbidity NTU Acidity as CaCO3 <5.0 <5.0 <5.0 < <5.0 <5.0 <5.0 <5.0 Alkalinity CaCO Bicarbonate Bromide <1.0 <0.1 <0.1 <1.0 <0.1 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 Chloride 1.21 <0.5 < < Ammonia <0.05 <0.05 <0.05 <0.05 < <

16 Sample ID Units DH DH DH DH DH GT-PP11-08 PP11-01 PP11-02 PP11-03 PP11-04 PP11-05 Nitrate < <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Nitrite <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Kjeldahl Nitrogen Nitrogen Dissolved ortho- Phosphate Phosphorus < <0.2 < <0.2 <0.2 < <0.21 < <0.21 <0.21 <0.01 < <0.01 < < <0.02 < Sulfate Cyanide Aluminum Antimony Arsenic Barium Beryllium Boron Cadmium Calcium Chromium Cobalt Copper Iron Lead <0.002 <0.002 <0.005 <0.002 <0.002 <0.002 <0.002 <0.2 <0.002 <0.002 < < < < < < < < < < < < < <0.001 <0.001 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.002 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 < <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 <0.001 < <0.005 < <0.005 < <0.005 <0.005 <0.005 < <0.002 < <0.002 < <0.002 <0.002 < < < < <

17 Sample ID Units DH DH DH DH DH GT-PP11-08 PP11-01 PP11-02 PP11-03 PP11-04 PP11-05 Lithium Magnesium Manganese Mercury Molybdenum Nickel Potassium Selenium <0.01 < <0.01 <0.01 <0.01 < < < < <0.005 < < <0.005 < < < < < < < < < < < Silver < < <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 <0.005 Sodium Strontium Thallium Tin Titanium Uranium Vanadium Zinc < <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 < < < <0.001 <