Ajax Project Review Water Contamination and Minesite Drainage

Ajax Project Review Water Contamination and Minesite Drainage

Ajax Project Review Water Contamination and Minesite Drainage Chemistry (also known as Metal Leaching & Acid Rock Drainage (ML-ARD) in British Columbia) Kevin A. Morin, Ph.D., P.Geo., L.Hydrogeo. Minesite Drainage Assessment Group www.MDAG.com Contaminated Water from Minesites (ML-ARD) CANADA USA Contaminated Water from Minesites (ML-ARD) DOMINICAN REPUBLIC PERU

CANADA CANADA Preventing impacts from ML/ARD is the most costly and time consuming environmental issue facing the British Columbia mining industry. It is also one of the most technically challenging. Due to poor historical practices, large remediation costs, technical uncertainty and the potential for negative environmental impacts, ML/ARD is a major issue of public and regulatory concern. In most scientific work, practitioners would be satisfied with a 90 to 95

percent success rate. However, in ML/ ARD prediction and prevention, any failure that results in significant environmental impact is unacceptable. Ajax Project Review on Water Contamination We at the Minesite Drainage Assessment Group (MDAG) were asked to review the Ajax EIS, focussing on water contamination (ML-ARD) and touching on dust contamination. The title of our review is, Ajax Project Review - Review of Predicted Water Contamination, dated March 31, 2016. We thank the following organizations: the Sierra Club of BC, for asking us to review the EIS and the Kamloops Area Preservation Association (KAPA), for sponsoring our report on analytical methods and our presentation in Kamloops

Ajax Project Review on Water Contamination It is very important to understand that KAM has committed the Ajax Project to the Precautionary Principle and Zero Harm in Section 3.2 of the EIS. The strengths of these commitments can be seen in the following quotations from the EIS. The Precautionary Principle stipulates that lack of certainty regarding threats of environmental harm should not be used as an excuse for not taking proactive steps to avert that threat. It also recognizes that delaying action until there is compelling evidence of harm will often mean that it is then too costly or impossible to avert the threat. The use of the Precautionary Principle promotes action to avert risks of serious or irreversible harm to the environment. KAM integrates the application of the Precautionary Principle throughout the design of the Project and forms the basis for project design criteria, the effects assessment, the alternatives assessment and management practices. To this end, the precautionary approach has been used throughout the environmental assessment by applying conservative [safe] factors in design, assessment inputs and modelling, including: ... where there is uncertainty or some plausible risk, implementing conservative approaches, together with a dynamic process of adaptive management. ZERO HARM - We are committed to Zero Harm for our employees, our communities and the environment. . . . KAM believes that protection of the natural environment is

fundamental to the success of operations and projects. . . . [W]e will . . . [p]revent and minimize environmental impacts [and] meet or exceed all environmental laws and regulations. Ajax Project Review on Water Contamination By implementing the Precautionary Principle, KAM would be proposing a proactive and safer mine plan in the face of uncertainties. However, on the issue of water contamination on and leaving the minesite, as reviewed here, the EIS: does not take proactive precautionary steps; does not recognize that delaying action until there is compelling evidence of harm will mean it is then too costly or impossible to avert the threat;

does not promote action to avert risks of serious or irreversible harm to the environment; does not meet the objectives of provincial groundwater legislation; does not apply safe conservative factors in design, assessment inputs and modelling; and does not offer reasonable evidence that zero harm will be done to the environment from water contamination. Ajax Project Review on Water Contamination

We at MDAG were asked to focus on predictions of water contamination that would arise on and downstream of the proposed Ajax minesite. The basic question was: Are the predictions of water contamination contained in the Ajax EIS reasonable, considering the studies in the EIS and the inevitable uncertainties that cannot be known in advance? As our review shows, our answer to the basic question is: No, the predictions are not reasonable, and they significantly underestimate the likely contamination of water on and leaving the proposed minesite. Ajax Project Review on Water Contamination The approach used in this review is based on three steps resulting in impacts, harm, or damage to the environment or nearby humans: contaminant source contaminant pathway receptors In our review, we looked at predictions for the proposed source term of contamination, the Ajax site itself. However, there are several

proposed individual sources on the site, including: waste-rock disposal dumps called mine rock stockpile facilities; the low-grade-ore and medium-grade-ore stockpiles that will not be processed before the end of the operation and may, in effect, become additional waste-rock disposal dumps; the tailings disposal facility called the tailings storage facility or TSF, the waste-rock embankments of the TSF, which will contain a significant percentage of the total waste rock and thus represent additional waste-rock disposal dumps; the open pit, which will fill with water after mining; the overburden stockpile and overburden spread across the proposed site during construction and operation; and several other components that will contain mined material or receive water from the

minesite, including roads and ponds. Ajax Project Review on Water Contamination contaminant source contaminant pathway receptors Our review also looked at one pathway in particular, the Peterson Creek Aquifer generally east and downgradient of the proposed Ajax Minesite. When both the sources and the pathways are underestimated, then the predicted impacts, harm, and damage to the receptors could be much worse than discussed in the Ajax EIS. This could invalidate the predictions of residual effects, because they could be much worse. This would also violate the EIS invocation of the Precautionary Principle and Zero Harm. These points are important, because this is actually what has occurred in the Ajax EIS, as confirmed in our review. The estimated extent and severity of water contamination is much too low in the EIS. Metal levels in the air emissions of dust were also underestimated. Ajax Project - Water Contamination at the Source (Geochemical Source Terms) Looking at predictions of Ajax source contamination, we focussed on the

following issues in Section 4 of our review. 1. Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination 2. What are the metal levels in rock and tailings and blowing dust at the Proposed Ajax Project? 3. Lack of usage of historical geochemical data during operation at the earlier Ajax mining operation 4. Source leaching of metals and other elements, leading to contamination of waters in surface and subsurface pathways 5. How many tonnes of proposed mine rock will be capable of releasing ARD at Ajax? 6. How quickly will rock begin releasing ARD at Ajax (the ARD "lag time")? 7. "Blending" of net-acid-generating ("NPAG") rock with net-acidneutralizing rock to prevent ARD at the proposed Ajax Project 8. ARD mitigation for ore stockpiles Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Ajax Humidity Cells, Columns, and

In-Field Tests Dilute water inflow Full-Scale Reality If Ajax Proceeds Dilute precipitation inflow Each Ajax test was a meter high or less Less dilute water outflow Many meters high

LEGEND Short intervals of rock, tailings, and/or overburden, with each interval releasing a different amount of contamination into the water passing through Water outflow with high concentrations Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Full-Scale Reality for Waste Rock Humidity Cells, Columns, and In-Field Tests

=? Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Full-Scale Reality for Waste Rock Humidity Cells, Columns, and In-Field Tests =? Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Humidity Cells, Columns, and In-Field Tests Full-Scale Reality for Pit Walls

=? Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Full-Scale Reality for Tailings Humidity Cells, Columns, and In-Field Tests =? Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Ajax Humidity Cells, Columns, and In-Field Tests Dilute precipitation

inflow here Full-Scale Reality If Ajax Proceeds Dilute water inflow Each Ajax test was a meter high or less Less dilute water outflow ~80 m high LEGEND Short intervals of rock, tailings,

and/or overburden, with each interval releasing a different amount of contamination into the water passing through The SHORTEST proposed wasterock dump at Ajax is ~80 m high Water outflow here with high concentrations Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Ajax Humidity Cells,

Columns, and In-Field Tests Dilute precipitation inflow here Full-Scale Reality If Ajax Proceeds Dilute water inflow Each Ajax test was a meter high or less Less dilute water outflow PROBLEM #1: Concentrations (mg/L) from these short tests (left

side) were compared directly to relatively higher provincial water-quality guidelines; they were not compared to lower federal CCME guidelines. Alarmingly, even short intervals could create concentrations higher than guidelines, so how much worse could reality be (right side)? Is this precautionary? ~80 m high The SHORTEST proposed wasterock dump at Ajax is ~80 m high LEGEND

Short intervals of rock, tailings, and/or overburden, with each interval releasing a different amount of contamination into the water passing through Water outflow here with high concentrations Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Ajax Humidity Cells, Columns, and In-Field Tests Dilute precipitation inflow here

Full-Scale Reality If Ajax Proceeds Dilute water inflow Each Ajax test was a meter high or less Less dilute water outflow PROBLEM #2: Many maximum concentrations (mg/L) from these short tests (left side) were used to "cap" the maximum predicted concentrations from reality (right side). Maximum concentrations in reality could be much, much higher. Is this precautionary?

~80 m high The SHORTEST proposed wasterock dump at Ajax is ~80 m high LEGEND Short intervals of rock, tailings, and/or overburden, with each interval releasing a different amount of contamination into the water passing through Water outflow here with high

concentrations Weakness of kinetic-testing methods used in the Ajax EIS to predict geochemical source-water contamination Ajax Humidity Cells, Columns, and In-Field Tests Dilute precipitation inflow here Full-Scale Reality If Ajax Proceeds Dilute water inflow Each Ajax test was a meter high or less

Less dilute water outflow PROBLEM #3: Minimum kinetic rates (mg/kg/wk) from these short tests (left side) were used to "scale up" to "average annual" reality. These minimum rates were sometimes 10x to 100x times LESS than the maximum rates that would reflect active mining. This grossly underestimates the amount of water contamination at Ajax. Is this precautionary? ~80 m high The SHORTEST proposed

wasterock dump at Ajax is ~80 m high LEGEND Short intervals of rock, tailings, and/or overburden, with each interval releasing a different amount of contamination into the water passing through Water outflow here with high concentrations What are the metal levels in rock and tailings and blowing dust at the Proposed Ajax Project (A Tale of Two Methods)? It is very important, for many reasons, to know accurately the levels of metals and other potentially toxic elements within Ajax rock, tailings,

overburden, and windblown dust. For example, where pathways exist, windblown dust carries all these solidphase elements off the minesite into the environment and into human/animal lungs and onto the soil. As another example, water contamination by some elements can depend on their solid-phase levels. So what are the levels of metals and other potentially toxic elements in Ajax rock, tailings, overburden, and windblown dust (such as arsenic, mercury, chromium, cadmium, etc.)? We do not know accurately and the company will not tell us. The company claims the environmental analyses in the EIS tell us, but they are wrong. What are the metal levels in rock and tailings and blowing dust at the Proposed Ajax Project (A Tale of Two Methods)? The primary problem lies in the analytical methods for solid-phase elements. Some methods dissolve only part of a sample, and thus analyses using these methods say that levels are relatively low. Other methods dissolve most or all of a sample, and thus analyses using these methods say that levels are relatively high. For exploration work and assay analyses at Ajax, KAM used the strong

four-acid-digestion method. This makes sense, because it reports maximum levels of the economic elements like copper and gold, which makes for the best economics. On the down side, this near-complete digestion also reveals the real levels of unwanted elements like chromium and arsenic, which are then used by smelters to charge monetary penalties for unacceptably high levels. The company has refused to release the assay database, so we do not know the real, high levels of metals and other elements. What are the metal levels in rock and tailings and blowing dust at the Proposed Ajax Project (A Tale of Two Methods)? The company instead refers people to the environmental analyses in the EIS. What method was used for all the environmental samples? The weaker, partial digestion (aqua regia) method was used, which yields only part of the real concentrations. All the environmental samples used this. All risks to humans and the environment in the EIS are based on these partial levels. An important question would be: how much higher are the real assay

levels compared to the lower environmental samples? There is no way to tell reliably, because the company will not release the assay database. Yet, there is a clue. What are the metal levels in rock and tailings and blowing dust at the Proposed Ajax Project (A Tale of Two Methods)? This Figure 11.5-6 from the Ajax EIS is the clue that are serious discrepancies between the less-thorough EIS method (called "static test" in the figure on the horizontal x-axis) and the more-complete Feasibility Study assay method (on the vertical y-axis). What are the metal levels in rock and tailings and blowing dust at the Proposed Ajax Project (A Tale of Two Methods)? It turns out the more-complete assay levels of arsenic can be higher by a factor of 10 times or more. Yet, even knowing this, all predictions of water contamination and risks for windblown dust in the EIS are based on the much lower environmental values. What would these real, much

higher levels of arsenic and other elements, like chromium and mercury, tell us about actual risks to humans and the environment from the Ajax Project? We dont know, because KAM will not release these higher values. Is this precautionary with Zero Harm? Ajax Project - Water Contamination along Pathway: The Peterson Creek Aquifer Looking at predictions of pathway contamination in the Peterson Creek Aquifer, we focussed on the following issues in Section 3 of our review. 1. 2. 3. 4. 5.

6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. Maximum source concentrations were not used as stated RES-2 is not the closest residential well Low flow of contaminated water based on closure conditions after a fully stable cover Elevated baseline concentrations in the Aquifer Natural attenuation into elevated background levels does not persist indefinitely RES-2 is not the only receptor of contaminated water Failure to meet British Columbia's Water Sustainability Act and the Ground Water Protection

Regulation Declaration of the Aquifer as Contaminated, with warnings and limitations on usage Failure of KAM to achieve "Zero Harm" Failure of KAM to meet its corporate Precautionary Principle Warnings from this Reviewer to well owners Reliance by third parties on this preliminary assessment in the EIS Lack of real monitoring of the Aquifer in the EIS Accuracy and reliability of EIS groundwater modelling Recommendation from this Reviewer Summary and underestimation of risk to human health and the environment in the EIS What is the Peterson Creek Aquifer? The Peterson Creek Aquifer is about 18 km2 in lateral area along Peterson Creek (~12 km long and ~1.5 km wide according to Figure 6.6-E-3 in the Ajax EIS). Appendix 6.6-C explains the Aquifer is up to 80 m thick with sand and gravel units . . . interpreted to be glaciofluvial in origin and

interbedded with glaciolacustrine silt and clay lenses. What is the Peterson Creek Aquifer? The Peterson Creek Aquifer is rated by the British Columbia Ministry of Environment as low development, high vulnerability and moderate productivity (Class IIIA) (EIS Appendix 6.6-C). Thus, the Peterson Creek Aquifer has a moderate productivity that is not currently taken advantage of, but is vulnerable to pollution and contamination. This contamination will happen if the Ajax Mine proceeds, as the Ajax modelling itself in the Ajax EIS predicts but underestimates. Failure to meet British Columbia's Water Sustainability Act and the Ground Water Protection Regulation In light of British Columbias Water Sustainability Act, this proposed intentional contamination of the Peterson Creek Aquifer and its

discharges to surface would not be consistent with protecting stream health and aquatic environments, nor with conservation and efficiency of water. The Ajax contaminant groundwater plume will not ensure that water stays healthy and secure for future generations of British Columbians. Failure to meet British Columbia's Water Sustainability Act and the Ground Water Protection Regulation Also, the Ground Water Protection Regulation calls for: ensuring activities related to well water and ground water are undertaken in an environmentally safe manner; securing a safe and healthy ground water resource and reducing risk of degradation of water quality and depletion of aquifers;

increased public confidence in ground water resources; improved integrity and safety of wells and community drinking water supplies (consumer protection); a system of ground water protection that is efficient and accountable, and enhanced protection of aquatic ecosystems dependent on ground water. (http://www.env.gov.bc.ca/wsd/plan_protect_sustain/groundwater/ gw_regulation/backgrounder.html)

Failure to meet British Columbia's Water Sustainability Act and the Ground Water Protection Regulation This proposed intentional release of a contaminant plume into the Peterson Creek Aquifer fails to meet these objectives of British Columbia legislation. This proposed intentional release also fails to meet KAMs Zero Harm policy and Precautionary Principle for the Ajax Project. Lack of real monitoring of the Aquifer in the EIS One may wonder why there are all these uncertainties and underestimations of contamination of an aquifer when it has likely been studied in detail for the Ajax EIS. Surprisingly, the reality is the Peterson Creek Aquifer has not been studied in detail. Table 6.5-1 of the EIS lists only five groundwater monitoring wells near the EMRSF. Of those five, only one, just one, in an aquifer 18 km2 in lateral area and up to 80 m deep, is installed in the Peterson Creek Aquifer.

This one monitor well is more than 1 km away from residential well RES2. Lack of real monitoring of the Aquifer in the EIS Therefore, the Ajax EIS has taken very little information on the Aquifer, and through impressive models and the many resulting detailed diagrams from the models, made it seem like the movements of contamination and groundwater from the proposed Ajax site were reasonably well known. They are not! The movements of contamination and groundwater are not reasonably well known, and there is little information on which to make reliable predictions for the proposed Ajax minesite. Accuracy and reliability of EIS groundwater modelling The accuracy of the Ajax groundwater modelling determines how accurately the groundwater flows, directions, and volumes in the Peterson Creek Aquifer can be predicted for Operation and Closure. Section 6.6.4 of the EIS says that changes (or uncertainties) of a few

meters in groundwater levels cause major changes in groundwater movement in the Peterson Creek Aquifer. So, are the currently existing groundwater levels at the Ajax site well matched by the model, within a few meters? They have to be for any predictions for the Aquifer to be reasonable and likely. Accuracy and reliability of EIS groundwater modelling The currently existing groundwater levels at the Ajax site cannot be matched by the EIS groundwater model to any better than an average of about 6-11 m. Therefore, the EIS models cannot be counted on to simulate reasonably and accurately the Peterson Creek Aquifer, which requires better accuracies than in the EIS. Put simply, no one can reliably predict, with EIS information, where groundwater contamination from the proposed Ajax site will end up. Warnings from this Reviewer (K. Morin) to well owners

As a contaminant hydrogeologist with a Ph.D. in this field, I strongly recommend to people using water from the Peterson Creek Aquifer to have the well water tested (1) very frequently and (2) in perpetuity, now and in the future if the mine is built. Or, to be more cautious, to avoid using the aquifer water. The reason for very frequent testing is that the contaminant plume could leave the minesite quickly and quickly arrive at your well in the Aquifer. Thus, even monthly sampling combined with a typical onemonth time for laboratory analyses means that water from your well could be contaminated for two months before it is known and confirmed. Warnings from this Reviewer (K. Morin) to well owners The reason for in perpetuity testing is due to the longevity of the contaminant sources at the Ajax site. The waste rock and tailings are being placed in storage facilities, which may give the impression of storage for only a limited time. In reality, these facilities are planned as permanent disposal areas like landfills. The rock and tailings as sources of environmental contamination will persist in perpetuity, so

well testing should continue in perpetuity. The contaminant groundwater plume description in the EIS is not sufficient to determine whether your well or any well in the Peterson Creek Aquifer would be safe, and the plume modelling actually underestimates the effect of the contamination. As a result, the estimated effects in the Ajax EIS on human health (not significant (minor)) and water quality have also been underestimated. FINAL CONCLUSION AND SUMMARY Altogether in our review of the Ajax EIS, we have found a cumulative and substantial underestimation of the extent and severity of contamination: 1. at the source, which is the proposed minesite, and 2. in one pathway reviewed here, the Peterson Creek Aquifer. This means that the likely impacts, damage, and harm to human health and environmental quality are significantly underestimated in the Ajax EIS. To emphasize, the significant underestimation of contamination at the source in the Ajax EIS automatically underestimates the amount of

contamination travelling along all pathways in the EIS, including nonaqueous pathways like windblown dust. Additionally, the transport of water contamination through the Peterson Creek Aquifer was underestimated. Therefore, the assessments of risk and residual risks in the Ajax EIS may greatly underestimate the actual risks that would occur if mining is ever approved. THE END

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