TECHNICAL REVIEW COMMENTS on the Environmental Impact Statement. Karnalyte Resources Inc. Wynyard Carnallite Project

Transcription

1 TECHNICAL REVIEW COMMENTS on the Environmental Impact Statement Karnalyte Resources Inc. Wynyard Carnallite Project Prepared by Saskatchewan Ministry of Environment Environmental Assessment Branch December, 2012

2 TABLE OF CONTENTS Preface Environmental Assessment and Review Process... 2 Introduction... 2 Submission of the Environmental Impact Statement... 2 Technical Review... 3 Public Review... 3 Ministerial Decision Summary of Proposed Project... 4 Alternatives Considered... 5 Biophysical Impacts Considered... 5 Public, First Nations and Métis Engagement Feedback and Response Introduction... 6 Biophysical Impacts... 7 Air Quality and Sensory Disturbance... 7 Groundwater... 8 Surface Water and Aquatic Habitat... 8 Wildlife and Terrestrial Habitat... 9 Social, Cultural and Economic Impacts Heritage Resources Public, First Nations and Métis Engagement Decommissioning, Reclamation and Abandonment Plan Conclusion Invitation to Comment Contact i

3 Preface This document is provided by the Environmental Assessment Branch of Saskatchewan Ministry of Environment as supporting information for the public review of Karnalyte Resources Inc. s (Karnalyte) Environmental Impact Statement for the proposed Wynyard Carnallite Project (the Project). The Project is located 2.5 km southwest of the Town of Wynyard in the Rural Municipality (R.M.) of Big Quill No. 308 in south central Saskatchewan. The proponent is proposing to build and operate a solution potash mine producing 625,000 tonnes of potash per year. This document has four major parts: The first part provides an overview of the provincial environmental assessment and review process. It outlines the events and activities that led to the Environmental Impact Statement being released for public review and describes how the public can provide comments to the Minister of the Environment, through the Ministry of Environment, on the proposed Project. The second part provides a brief summary of the Project. This summary is intended to provide information to assist the reader in deciding whether they are interested in finding out more about the Project. It is not intended to be a full representation of the Project. Interested readers should visit a review centre to read the Environmental Impact Statement for the Project (locations are listed in Section 4). The third Section of the document provides the Ministry of Environment s evaluation of the proponent s conclusions regarding the predicted impacts of the proposed Project, the effectiveness of any identified mitigative measures and any follow-up requirements that may be placed on the proponent by the Minister, should the Project be approved. Section 4 presents the conclusions reached by the Ministry of Environment and invites the public to comment. The Minister of Environment, when making the final decision regarding the environmental acceptability of the proposed Project, considers both the public s comments and. 1

4 1. Environmental Assessment and Review Process Introduction The Environmental Assessment Act (the Act) in Saskatchewan requires the proponents of a development to conduct an Environmental Impact Assessment (EIA). The EIA provides information needed by the Minister responsible for the Act (Minister of Environment) to determine whether, from an environmental perspective, a proposed development should be allowed to proceed and, if so, under what conditions. As part of the environmental assessment process, the proponent is required to prepare an Environmental Impact Statement (EIS) that documents the proponent s assessment and conclusions on the potential environmental effects of the proposed Project. The EIS also describes the measures the proponent plans to take to reduce negative and enhance positive environmental impacts. Once completed, the EIS undergoes both a technical and public review prior to a decision being made by the Minister regarding the Project. The Environmental Assessment Branch review process provides a broad understanding of the potential impacts and ways to minimize the impacts of a Project. The purpose of the environmental assessment and review process is to ensure that adequate environmental safeguards are in place before a development is allowed to proceed and that a development proceeds in a manner understood and broadly accepted by the public. These safeguards may arise out of the actual design and nature of the proposed development or, should the development receive approval under the Act, as a result of ongoing regulatory involvement by government agencies. In addition to the Act, this Project may be subject to the following acts, regulations and guidelines: The Environmental Management and Protection Act, 2002 The Water Regulations, 2002 The Mineral Industry Environmental Protection Regulations, 1996 The Mineral Disposition Regulations, 1986 The Clean Air Act and Regulations, 1989 The Hazardous Substances and Waste Dangerous Goods Regulations, 1989 Other provincial and federal agencies also have legislation and regulations which may be applicable to the Project. Submission of the Environmental Impact Statement Karnalyte chose not to submit a technical project proposal or Terms of Reference for the project. In November 2009, the Environmental Assessment 2

5 Branch (EAB) received a draft EIS for the Project. The Project was officially declared a development under Section 2(d) of the Act and the EIS was sent to provincial agencies and the Government of Canada for technical review. A federal EIA was not required by the Government of Canada. Technical Review Technical review provides the government perspective on the proposed development. Several information gaps were identified and the proponent responded by providing a revised EIS and two addenda in the fall of A revised Commitments Register was also provided as part of the addenda. Upon further review, the September 2012 EIS and two addenda were deemed to contain adequate information to proceed with public review. This document has been prepared pursuant to Section 11 of the Act and is meant to assist the public and government decisionmakers in their review of the EIS. The comments represent a summary evaluation of the proponent s final EIS and related addenda. Karnalyte has also provided a concordance table in the final EIS that summarizes reviewer comments from the second draft EIS review and has provided reviewer comments and Karnalyte s responses from review of the third EIS in the addenda. Comments from the first early draft of the EIS are available upon request. In preparing, the Ministry of Environment focuses on those factors that are considered to be of primary significance with respect to the proposed Project and the environment in the area of the Project. Public Review Public is invited to comment on the Wynyard Carnallite Project EIS for a 30 day period ending Monday, January 28, The EIS, addenda and final are being made available through the Legislative Library in Regina, University of Regina Library, University of Saskatchewan Library, main branches of the Regina and Saskatoon Public Librariesm, the Offices of the Town of Wynyard and the R.M. of Big Quill No. 308, and the EAB office in Regina. Documents can be accessed directly from the Environmental Assessment website at To ensure your comments regarding the EIS are considered, please submit them to the Saskatchewan Ministry of Environment no later than Monday, January 28, 2013 to the following address: Ann Riemer Senior EA Administrator Environmental Assessment Branch Saskatchewan Ministry of Environment 3211 Albert Street 3

6 Regina SK S4S 5W6 Phone: Fax: Ministerial Decision The Minister considers both the public and technical review comments when making a decision. Information generated during the public and technical reviews of the EIS will be submitted to the Minister of the Saskatchewan Ministry of Environment for consideration. The Minister, under Section 15 of the Act, may give Ministerial Approval to proceed with the development, with any terms and conditions that the Minister considers necessary or advisable, or the Minister may refuse to approve the development as proposed and will provide reasons for the decision. 2. Summary of Proposed Project Information in this Section is taken from the Wynyard Carnallite Project EIS and is neither comprehensive nor inclusive of the information contained in that document. Please refer to the Executive Summary, EIS main document and annexes for complete information. The Project will be located on agricultural land within the R.M. of Big Quill No. 308, approximately 175 km east of the City of Saskatoon and 2.5 km south of Wynyard. Wynyard and the Hamlet of Kandahar (approximately 11 km west of the Project) are the nearest communities to the Project site. Karnalyte proposes to use solution mining techniques to extract potash (KCl) from two naturally occurring minerals known as sylvite and carnallite. Sylvite is the mineral form of potash and carnallite is hydrated potassium magnesium chloride. Most existing potash mines focus on the mining of sylvite alone. The final product will be trucked from the processing plant to a rail loadout facility located approximately 3 km from the site. Unlike other potash mines in Saskatchewan, Karnalyte proposes a mining process that will not require the storage of waste on the surface, thereby eliminating the need for construction of tailings piles or tailing ponds. Instead, Karnalyte proposes to dispose of waste solids and brine in depleted (mined-out) caverns and by deep well injection to appropriate locations within the 1,500 metre deep Winnipeg/Deadwood Formation. They also propose to avoid using shallow potable water as process water by extracting brackish groundwater sourced from the Blairmore Aquifer approximately 475 metres below the Project area. Karnalyte s drinking water and start-up boiler feed water would be provided through normal purchase from available supplies in Wynyard. 4

7 Alternatives Considered Alternatives considered for various components of the Project are presented in Section 2.6 of the EIS. Karnalyte chose solution mining over conventional underground mining for a number of reasons, including safety, lower cost and lack of a requirement for a dry tailings storage area. Although existing solution mines in the province do have surface tailings storage facilities, Karnalyte opted to design their process so as to dispose of tailings in spent caverns or through deep well injection, eliminating the need for surface tailings storage. Based on the preferred solution mining method, Karnalyte examined the options of using vertical or deviated boreholes for cavern establishment. Deviated wells on centralized well pads were chosen as preferable for reducing the well field footprint, although vertical boreholes would have been less expensive to construct. Karnalyte also examined buried versus surface pipelines for the well field network and chose to use surface pipelines for ease of leak detection and maintenance. Surface lines will be removed upon decommissioning. The preferred source of process water is the brackish Blairmore Formation. In the event that the Blairmore cannot supply adequate amounts of water, Karnalyte has proposed two alternative sources: the Hatfield Valley Aquifer approximately 19 km from the site and Big Quill Lake approximately 11 km from the site. Several locations for the mine site were assessed and the preferred site was selected based on environmental, community, economic, infrastructure and engineering concerns. Karnalyte provides an analysis of site selection in Addendum I, section Biophysical Impacts Considered Karnalyte has evaluated the possible impact of the Project on the biophysical environment, possible mitigation measures that could be employed to eliminate or mitigate (reduce) the impacts and any residual effects that might remain after the mitigation is in place. In particular, Karnalyte has examined the potential effects of the development on; air quality, noise, soils, terrain, groundwater, surface water environment, terrestrial vegetation (including rare plants), wetlands (including listed species), raptors and waterbirds (including listed species). Analyses for each of these components can be found in the relevant sections of the EIS. In addition, Karnalyte has committed to follow-up and monitoring to verify the predictions made and assess the adequacy of mitigation measures proposed in the EIS. 5

8 Social, Cultural and Economic Impacts Considered The EIS includes an assessment of potential Project impacts to social, cultural and economic factors. A review of existing heritage resource information in the Project area and an additional heritage resource impact assessment were conducted for previously undisturbed areas which will be impacted by the development. Socio-economic considerations included training and employment opportunities, existing land-use and dwellings, linear infrastructure and municipal services. Public, First Nations and Métis Engagement Feedback and Response Section 5.0 of the EIS provides details on Karnalyte s engagement program with government, the public, First Nations and Métis communities initiated in The section also includes a summary of questions and responses arising from engagement activities. Additional details regarding engagement activities by Karnalyte are provided in Appendix 5. All project-specific concerns raised during engagement activities were addressed by Karnalyte during meetings and have been documented in the EIS. Formal opportunities for participation will be provided during the public review of the EIS. 3. Introduction The intent of the technical review phase of the environmental assessment and review process is to give provincial and federal specialists, at a variety of agencies, an opportunity to examine the EIS to: Develop their opinions about how adequately the environmental issues related to the development have been dealt with; and, Determine whether the information provided is sufficiently complete and technically accurate enough to support the public review phase of the process. The technical review of the EIS for the Project identified various issues related to potential environmental impacts and environmental management that required clarification. These issues were addressed with additional data 6

9 collection and analysis and the results were presented in the final EIS submission. Release of the EIS for public review should not be interpreted as absolute agreement with all items within the EIS, but simply that the issues remaining can be handled through ongoing regulatory relationships or terms and conditions that might flow from a decision made pursuant to the Act that would modify the development to make it acceptable to the technical reviewers. Below is a summary of some of the significant provincial comments raised during the technical review of the final EIS and Karnalyte s responses. Karnalyte s responses to the comments on the final EIS can be found in the addenda (I and II) to the final EIS. A listing of technical review comments on an earlier EIS can be found in the Saskatchewan Environmental Assessment Review Panel (SEARP) Comment Concordance Table section. In general, the proponent has addressed or acknowledged the issues raised during review of the earlier EIS submissions and the subsequent revised final EIS. Additional Project details will be developed and provided at the time of licensing and permitting, should the Project advance to that stage. Biophysical Impacts Karnalyte has evaluated the possible impacts of the Project on the biophysical environment, possible mitigation measures that could be employed to eliminate or mitigate (reduce) the impacts and any residual effects that might remain after mitigation is in place. In undertaking the EIS, a number of valued ecosystem components (VECs) were identified to facilitate the assessment and interpretation of potential effects associated with the proposed Project. Section 3 of the EIS provides a description of the existing physical environment, and a list of VECs can be found in Section 6.2. Section 6 of the EIS provides a discussion and screening of environmental effects of the project and measures proposed to mitigate significant effects of the Project. Further assessment of impacts, where residual effects potentially remain after mitigation measures are implemented, are assessed in Section 7 and summarized in Section 9 of the EIS. Air Quality and Sensory Disturbance Karnalyte considered the potential air emissions and total suspended particulate (i.e. dust) that would be produced from solution mining and processing activities and the rail loadout area. The EIS states that the activities are predicted to have a negligible effect on air quality. A number of measures will be taken in order to minimize the amount of fugitive dust from roadways, including enforced speed limits, use of watering trucks, 7

10 covering hauled material and general road maintenance. The proposed haul road will be paved for the operations phase. Karnalyte has committed to developing an air quality monitoring program in consultation with regulators for the construction, operation and decommissioning phases of the project. Groundwater Hydrogeological modeling was conducted as part of the EIS to determine the potential for contamination of groundwater from mine activities and to determine the feasibility of using the brackish Blairmore-Mannville aquifer for process water. Results of the modeling are presented and discussed in various sections throughout the EIS. Based on the design of the Project, and because there will be no surface storage of waste salts, there are no significant concerns regarding the potential for groundwater contamination as a result of the project. Additional modeling that supports the feasibility of using the brackish Blairmore-Mannville aquifer for process water can be found in Addendum I. Karnalyte has also committed to undertake yield testing on the aquifer prior to construction of the mine to verify the results of their modeling. Karnalyte will be implementing a Groundwater Monitoring Program to be designed in consultation with the Ministry of Environment. Surface Water and Aquatic Habitat Karnalyte evaluated the potential effects of the Project on local surface water features, including hydrology, water quality, and fish and fish habitat. Various interactions between the Project and surface water resources will occur as a result of the project. Fish and fish habitat studies did not identify any highly sensitive fish species or habitat and no protected amphibian species were identified. Potential impacts to surface water considered in the EIS included direct loss of wetlands from surface facility construction and the indirect effect of subsidence on surface drainage. No process water will be discharged into any surface waters, although there is a potential for localized accidental releases. Despite mitigation measures, such as avoidance, buffers and the use of clear span bridging proposed as part of the development, certain impacts to surface water bodies may occur. Karnalyte has committed to a monitoring plan for surface waters and will be required to remediate or compensate for any damage to wetlands. 8

11 Wildlife and Terrestrial Habitat The EIS includes discussion of the potential impacts of the Project on the terrestrial environment, including wildlife, wildlife habitat and vegetation. This discussion included consideration of rare plants and wildlife species at risk, raptors, waterbirds, upland birds, ungulates, small mammals and amphibians. The primary effect to VECs will be related to three sensitive plant species (S2 and S3 provincial ranks) that may be impacted at the mine site and loadout facilities. Karnalyte has committed to avoiding these species or to work with experts to develop relocation strategies as necessary. The EIS also included information on upland, aquatic and migratory birds, some of which are listed by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC), indicating that there may be suitable sites for both temporary use and nesting residency within the area. Three COSEWIC-listed bird species were located in the local study area during breeding bird surveys conducted for the EIS. Karnalyte has committed to avoiding key habitat wherever possible and to conducting additional surveys prior to disturbing those areas that cannot be avoided. Vegetation clearing activities will be conducted outside of nesting seasons wherever possible. In addition, Karnalyte will adhere to the Saskatchewan Activity Restriction Guidelines for Sensitive Species in Natural Habitats. The proposed Wynyard Carnallite Project will occur on primarily cultivated land and smaller areas of grassland that has been heavily impacted by invasive species. The preliminary decommissioning and reclamation plan will include removal of infrastructure, recontouring of the disturbed site and return to previous land use. Based on the project description, information collected during baseline studies and the proposed mitigation measures, Karnalyte determined that residual impacts to wildlife and terrestrial habitats from surface development are likely to be not significant. There are no significant concerns related to the terrestrial environment as they were acknowledged or addressed in the EIS. Terrain Karnalyte examined the effect of subsidence on the project area in Sections 2.4.9, 7.2.5, and Appendix 2.4. Subsidence is defined as the lowering of the earth s surface due to movements in the underlying geology. Subsidence is an inevitable consequence of all subsurface mining. Damage caused by the differential settlement that might occur across the boundary of the subsided area, versus the adjacent unaffected area, due to lowering of the earth s surface could potentially change the flow directions of small waterways or damage structures. Subsidence will result in changes to local topography, although the overall effects of ground subsidence are expected to be very gradual and the overall process will take in excess of 100 years. Backfilling of caverns to arrest 9

12 any further dissolution in the depleted cavern reduces the magnitude of subsidence. Reviewers noted that Karnalyte states in section of the EIS that The extended time frame and rate of subsidence indicates that changes in terrain will likely be unnoticeable over shorter time periods and will provide opportunities for infrastructure owners/operators and service providers to monitor existing infrastructure and to apply appropriate mitigative measures as required to prevent significant impacts before they occur. The responsibility to mitigate for the impacts of subsidence resulting from their mining activities clearly rests with the proponent. Karnalyte recognizes this elsewhere in the EIS and commits to work closely with dwelling and infrastructure owners, as well as regulators, to develop and implement appropriate mitigative measures. Additional commitments to mitigate any impacts of subsidence are provided in Addendum II. Karnalyte commits to developing a comprehensive Subsidence Monitoring Plan in consultation with Energy and Resources, Ministry of the Economy and will be required to report regularly as part of their licencing under The Mines Regulations, Reviewers also commented that the analysis of impacts of subsidence on surface water lacked detail with respect to the potential for changes to wetlands and the Wynyard Reservoir. As part of their Environmental, Social, Health and Safety (ESHS) Management System Karnalyte will implement a Water Monitoring Plan, including Surface Water Monitoring, to assess the impact of subsidence over time on surface water in the project area. Karnalyte proposes to implement mitigative actions to address erosion, deposition, or changes to water levels related to their project (sections and ). Karnalyte will be required to submit a copy of this plan to the EAB prior to commencing operations and to report the results of this monitoring to the Branch on an annual basis. This report may also be required by other regulators. Karnalyte determined that residual impacts to terrain from subsurface development (subsidence) are likely to be significant, primarily as they are irreversible. However, the project design, monitoring and mitigation proposed by Karnalyte in the EIS are adequate to safeguard the public and to ensure that, upon decommissioning, the land will support uses similar to those supported prior to the mine s existence. Social, Cultural and Economic Impacts Heritage Resources A heritage resource impact assessment (HRIA) was conducted in the Project area as documented in Sections 3.9 and of the EIS. 10

13 The only heritage resource of significance located in the area was the remnants of an old school ground. A historical marker denotes the property as being the former location of Nordra School, which operated between 1909 and This site was deemed to have local heritage value and as such will be avoided by Project development. Based on the submitted HRIA report, the Heritage Conservation Branch has identified no additional heritage concerns in the area and has indicated there are no further objections with the Project proceeding. Socio-Economic Considerations The EIS examines the socio-economic effects of the proposed development. The Project will generate substantial economic benefits through employment, business opportunities and tax revenues. Karnalyte has committed to supporting local trades and contractors and to providing First Nations and Métis communities and businesses with fair opportunities to participate. Due to the low number of outside workers expected at any one phase and strict behavioral policies, few impacts to community well-being and infrastructure are expected. A work camp near the mine site will be used to house 250 to 300 workers during the busy construction phase, alleviating much of the stress on community infrastructure. Karnalyte has committed to work with local communities, such as the Town of Wynyard, to coordinate efforts where infrastructure may need to be strengthened. Detailed road maintenance and upgrade planning will be undertaken at the detailed design phase. Public, First Nations and Métis Engagement Local residents were notified about the proposed Project during various phases of the EIA, beginning in 2008, and were provided the opportunity to be involved with the environmental assessment process. Section 5.0 of the EIS provides details on Karnalyte s engagement with the public, First Nations and Métis communities and includes a summary of questions and responses arising from engagement activities. Additional details regarding engagement activities by Karnalyte are provided in Appendix 5. Specific concerns raised during the engagement process were documented in the EIS. Common issues raised included mine design; employment opportunities; infrastructure requirements, such as housing; interactions with other neighboring industries; local road maintenance; and dust control. 11

14 All project-specific concerns raised during engagement activities were addressed by Karnalyte during the meetings and have been documented in the EIS. Formal opportunity for participation will be provided during the public review of the EIS. Decommissioning, Reclamation and Abandonment Plan The EIS includes a conceptual decommissioning and reclamation plan for the Project. Major steps include the ongoing decommissioning of spent and backfilled caverns and associated infrastructure and, at the end of all mining, the dismantling of the process plant and loadout facilities. The goal is to return the land to productive agricultural purposes or whatever land use the government and local residents deem appropriate at the time of closure. For a complete summary of the conceptual decommissioning plan see Section 2.5 of the EIS. 4. Conclusion The SEARP (technical reviewers) and Saskatchewan Ministry of Environment conclude that Karnalyte Resources Inc. has undertaken sufficient studies and provided adequate information about the proposed Project such that the EIS can be made available for public review. Invitation to Comment Public is invited to comments on the Wynyard Carnallite Project EIS for a 30 day period ending Monday, January 28, The public is invited to review Karnalyte s EIS and the Technical Review Comments and provide their comments no later than Monday, January 28, Again, the EIS, along with these, are being made available to the public for review at Legislative Library in Regina, University of Regina Library, University of Saskatchewan Library, main branches of the Regina and Saskatoon Public Libraries, the Offices of the Town of Wynyard and the R.M. of Big Quill No. 308, and the EAB office in Regina; or it can be accessed on the internet at: Written comments received during the public review of the EIS, along with the, will be considered by the Minister of Environment when he makes his decision under section 15 of The Environmental Assessment Act to either: (a) give ministerial approval to proceed with the development and impose any terms and conditions that he considers necessary or advisable; or 12

15 (b) refuse to approve the development. Contact For more information, please contact: Ann Riemer Senior EA Administrator Environmental Assessment Branch Saskatchewan Ministry of Environment 3211 Albert Street Regina SK S4S 5W6 Phone: Fax: