JAMES BAY LITHIUM MINE MELCC QUESTIONS AND COMMENTS RECEIVED AS PART OF THE ENVIRONMENTAL IMPACT STUDY REVIEW de GALAXY LITHIUM (CANADA) INC. As part of the review of the Environmental Impact Assessment for the James Re Bayronnel Project (EIA) et de la Lutte contre les Changements climatiques (MELCC) submitted a request for an extension.
PROJECT RATIONALE (SECTION 2.3)
The project operator claims that the demand for lithium is steadily increasing, which ensures the profitability and optimization of the project. Total demand for lithium chemicals was approximately 270,000 tons of lithium carbonate equivalent (“LCE”) in 2018, representing 35% growth in the two years since 2016.
WASTE ROCK, TAILINGS AND OVERBURDEN
After several years of operation, if the drilling work shows that the pits can be removed from the water, the subsequent stages of stockpile construction will be replaced by accumulation in one or several pits. For the comparative analysis of the waste rock and tailings reserve options, it is mentioned that the optimization of reserve design in the engineering phase has compensated for the lack in volume of Option 2.
POWER SUPPLY AT THE MINE SITE (SECTION 3.4)
The Proponent of the Project mentions that "the possibility of powering some mobile generators with solar panels with batteries will be assessed". The project proponent will submit this estimate. These solutions will increase the capital costs of the project, without having a significant positive impact on the environment.
POWER SUPPLY FOR MOBILE EQUIPMENT
The Project Proponent will describe the efforts made in this regard as part of the James Bay lithium mine project. It will be in Galaxy's best interest to implement these new technologies when they become available as it is an inherent part of the company's values.
INDUSTRIAL AND ADMINISTRATIVE AREA GENERAL
PREPARATORY WORK (SECTION 4.4)
Sandboxes are usually under non-exclusive licenses and their restoration method is part of the operating permit. Each sandbox or part of sandbox used will be closed in accordance with the requirements of the permits issued.
GEOCHEMICAL CHARACTERIZATION (SECTION 4.7)
Materials that do not meet any of the criteria cannot be evaluated according to the Guide de Valorization. According to the requirements of the Guide de Valorization, these waste rocks cannot be valorized in any way.
STOCKPILES (SECTION 4.8)
On pages 4-46 it is mentioned that a hydrogeological model is currently being developed to assess the environmental impacts of the development of the storage facility. Modeling together with the results of geochemical testing will allow the design of the structure to be finalised.
WATER MANAGEMENT (SECTION 4.9)
Hydrographically, the tailings reserves will be isolated from the rest of the mine area (Figure 35-1). On page 4-54, the Project Proponent mentions that "if unconformities are measured at the outlet of the sedimentation basin, the water will be redirected to the main water retention basin." The Project Proponent shall demonstrate that the main water retention basin will be able to collect the water coming from the tailings storage basin and specify the retention time.
EMISSIONS, DISCHARGES AND WASTE MANAGEMENT
Hazardous waste would be managed by one of the contractors servicing the region (Véolia, Sanivac, Amnor and Groupe Gilbert). Procedures will be established (most likely through a scrap material management program) for the proper handling of hazardous and non-hazardous scrap materials.
OTHER INFRASTRUCTURE (SECTION 4.11)
A - 63: The project footprint presented in the EIA includes the encroachment area of the site roads. The Project Proponent will indicate how it plans to ensure that the fuel storage and distribution facilities comply with the provisions of the Building Code.
CONCENTRATE TRANSPORT TO MATAGAMI
A fiber optic cable is planned to be installed between the 381 km truck stop and the project site. A - 70: The fiber optic cable between the truck stop km 381 and the project site will be buried.
MINE REHABILITATION (SECTION 4.13)
As required under Section 101 of the Mining Act, a full rehabilitation and restoration plan will be drawn up at a later stage. The plan will comply with the requirements of the Guidelines for the Preparation of Mine Closure Plans in Quebec (MERN, 2017) and the expert will be consulted.
OPPORTUNITIES FOR PROJECT OPTIMIZATION
The Project Proponent will also specify the measures to be implemented to prevent issues related to alcohol and drug consumption or prostitution. The Project Proponent will specify the expected reduction thanks to the installation of the system and provide further details about the technology.
SUSTAINABLE DEVELOPMENT PRINCIPLES APPLIED
The project proponent indicates how he intends to take this factor into account when implementing the project. One participant in a focus group meeting with Eastmain elders as part of the project consultations mentioned that.
PHYSICAL ENVIRONMENT (SECTION 6.2)
The initial characterization of the receiving environment will be supplemented by a characterization of mercury in fish. Where τ is an independent factor of the confidence interval (1 - α = 95%), the desired percentile (P) and number of data (n).
BIOLOGICAL ENVIRONMENT (SECTION 6.3)
Therefore, forest fires cannot necessarily have caused the rock mouse to disappear from the area. Also, no fish were caught in creek CE4 upstream of James Bay Road. The observation of the species in the study area is unusual, but not impossible, although it was made almost 80 km from the coast;.
SOCIAL ENVIRONMENT (SECTION 6.4)
An archaeologist provided with such data is better equipped to assess the archaeological potential of the soil. The reference status of the natural and cultural heritage remains the same as that proposed in the archaeological. However, the study does not present any traditional indigenous knowledge that could prove valuable in assessing the archaeological potential of the study area.
IMPACT ASSESSMENT METHOD (SECTION 7.1)
PERCEPTION OF THE PHYSICAL AND NATURAL ENVIRONMENTS
The significance of the impact on the perception of the physical environment during the construction phase is thus assessed to be minor. Application of the preventive measures will minimize the impact on the risk of disturbances in the rehabilitation phase. The significance of the impact of the territory's use in the rehabilitation phase is assessed to be minor.
IMPACTS ON THE PHYSICAL ENVIRONMENT
The potential effects on the perception of the physical environment during the post-rehabilitation phase are negative. A - 117: During the first part of the post-rehabilitation phase, the pit will gradually fill through natural precipitation. Several results of the leaching tests (SPLP, TCLP, CTEU-9) on the four lithologies comprising the waste rocks, tailings and ore samples exceed the criteria for resurgence in surface water (résurgence dans les eaux de Surface) for several metals.
IMPACTS ON THE BIOLOGICAL ENVIRONMENT
The developer must demonstrate how ditch design, including berm construction, will help limit wetland drainage. The project developer will specify how the restoration of ecological functions has been taken into account in the development of the proposed restoration measures. A - 132: The different phases of the wetland restoration methodology will be indicated when submitting the restoration plan.
IMPACT ON THE SOCIAL ENVIRONMENT (SECTION 7.4)
Thus, the significance of the impact on the land use during the construction phase is considered to be minor. The intensity of the impact of transport caused by the project on the traditional uses along the James Bay Road is considered to be minor. The Project Proponent will ensure the participation of the relevant enumerator, or as agreed with the monitoring committee(s) established.
IDENTIFICATION OF VALUED COMPONENTS
In addition, the analysis of cumulative effects on this VC covers the entire territory visited by the Eastmain Cree. This trap is located northeast of the project, on the north bank of the Eastmain River. The cumulative effect of the project on Cree use of land for traditional purposes is therefore insignificant.
PROJECTS, ACTIVITIES OR EVENTS LINKED TO
However, this does not modify the assessment regarding the significance of the project's cumulative effect on Chiroptera (considered minor in the EIA). The changes/improvements made to Sections 8.5.4.1 and 8.6.1.4 of the EIA are highlighted in the text below. The proposed Waskaganish Biodiversity Reserve is located approximately 40 km east of the Waskaganish Cree Village.
ANALYSIS OF CUMULATIVE EFFECTS (SECTION 8.6)
The Project Proponent will characterize the leak and spill detection systems of the petroleum products storage tanks and control facilities. The detailed program will be proposed to MELCC during the concentrator authorization certificate application and will be adjusted as necessary. The collected data will be used to inventory the impacts of the project on the hydrological regime within the study area.
AIR DISPERSION MODELLING STUDY
A - 171: Section 7.2.2 of the modeling report addresses the uncertainties and limitations of the emission rates used for modeling. However, the results of the study are presented for informational purposes to put the modeling results into perspective. However, the results of the study by Pace are presented for informational purposes to put the modeling results into perspective and to emphasize their conservative nature.
SOIL BACKGROUND CONCENTRATION TECHNICAL
Conservatism et limitation of the modeling report is intended for information purposes to put the modeling results into perspective, without, however, having adapted the modeling method in relation to the arguments presented. The reduction ratios mentioned in this paragraph were not taken into account in the modeling (see answer to QC-171). This study assesses the reduction of particulate matter transported via phenomena that have not been taken into account in the modelling.
HYDROGEOLOGICAL TECHNICAL STUDY
The Project Proponent will justify why the modeled area does not include all watersheds and explain why two small areas of the left boundary of watershed 5 and the northern section of watershed 1 are excluded. Potential recharge lies within the range shown. in Section 4.2.2 of the Hydrogeological Technical Study (WSP, 2018). According to the values presented in table 8 of the hydrogeological technical study, the average rainfall is 683.9 mm/year.
TERRESTRIAL VEGETATION BASELINE STUDY
Le promoteur devra décrire les efforts déployés à cet égard dans le cadre du projet de mine de lithium Baie James. Le proposant devra démontrer comment la conception et les mesures de sécurité du bassin permettront le respect des exigences de la directive 019. Le proposant devra indiquer si une partie de ces boues devra être évacuée des bassins pendant la phase d'exploitation.
Le proposant doit expliquer pourquoi le débit d'eaux usées présenté dans cette figure (19 630 m3/j) ne correspond pas à celui du tableau 4-18 pour la même période (19 197 m3/j). Le promoteur doit assurer le rejet direct dans le flux CE3 des eaux sanitaires traitées.
