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From the Impact Assessment Agency of Canada to Galaxy Lithium (Canada) Inc. re: Responses to Information Requests Round 1 on the Environmental Impact Assessment

BY EMAIL

November 12, 2019, Québec City

Gail Amyot
Galaxy Lithium (Canada) Inc.
2000 Peel Street, Suite 720
Montréal, QC  H3A 2W5

SUBJECT: James Bay Lithium Mine Project—Response to the June 27, 2019, information request

Dear Ms. Amyot:

On October 10, 2019, the Joint Assessment Committee (the Committee) received the response to its June 27, 2019, information request concerning the project in question. The responses are in the following document:

WSP, 2019. James Bay Lithium Mine. Answers to Questions and Comments Received from CEAA as Part of the Environmental Impact Study Review. Report prepared for Galaxy Lithium (Canada) Inc. 223 pages, maps and appendices.

Following a review of the response document, the Committee, in cooperation with the departments that have environmental assessment expertise, has determined that the following information must be provided so that they can continue with the Environmental Impact Statement (EIS) review.

No further information beyond what is specified in the final Guidelines for the preparation of an Environmental Impact Statement of February 2018 and in the correspondence of June 27, 2019, is requested in this letter. The proponent may refer to the correspondence of June 27, 2019, for details and context concerning each question.

Question CEAA-6

Alternative analysis methodology—category weighting

The proponent must explain how the various considerations and weight assigned to each indicator in a category were determined.

Question CEAA-11

Project Description—mine layout

The proponent must provide the location of the concrete batch plant. If the location is unknown, the proponent must provide the various location scenarios.

Question CEAA-12

Project Description—quarries and borrow pits

A) and B) The proponent must describe the various options considered for operating potential quarries and borrow pits situated outside the project's footprint, including, for each potential quarry and borrow pit, its area, the location of access roads, water management and a description of its operation in general. The proponent must integrate these options into the environmental impact analysis, indicate the mitigation measures necessary to reduce these impacts and, where applicable, integrate them into the analysis of the project's cumulative effects.

Question CEAA-14

Project Description—wells and drinking water treatment station

B) The proponent must provide the various scenarios considered for the required work on the drinking water treatment station in the operating phase.

C) The proponent must provide the various scenarios considered for the location of the pipe associated with the drinking water treatment station in the operating phase.

Question CEAA-17

Project Description—infrastructure and activities related to explosives

A) The proponent must provide a description (location, role, activities) of the infrastructure related to the manufacture and use of explosives.

Question CEAA-19

Project Description—management of residual materials and hazardous waste

A) The proponent must provide a layout diagram of the storage areas for the different categories of hazardous waste listed in Tables 4–23 and 4–24 of the EIS.

B) The proponent must specify the mode, duration and capacity of on-site storage for each category of residual materials and hazardous waste.

C) The proponent must indicate how it plans to ensure the sealing of the storage areas and the safety of the premises.

Question CEAA-31

Surface water and groundwater—overall impact of the project on the quality of surface water and groundwater during the different phases of the project

A) The proponent must provide results on the project's impacts on the surface water and groundwater quality of the receiving environment caused by leaching and the risk of acid mine drainage from the ore and overburden stockpiles.

B) The proponent must include the results of the kinetic tests on the ore, the tests on the waste rock/tailings mix and the CTEU-9 test on the overburden in its analysis of the quality of surface water and groundwater, and compare them with the Canadian Water Quality Guideline of the Canadian Council of Ministers of the Environment for the protection of aquatic life for the different phases of the project, as well as the standards in the Metal and Diamond Mining Effluent Regulations to which the mine is subject.

C) The proponent must provide all of the analytical results for the overburden and the ore that show the probability of some of the apprehended impacts, including the results of the long-term kinetic tests to determine, as applicable, the time necessary to trigger mine drainage (acid and/or neutral) or leaching of metals.

D) The proponent must provide a complete study of the mobility of leachable metals and metalloids in order to predict their mobility by runoff from the waste rock stockpiles to their availability in the surface water and their ecotoxicity.

Question CEAA-32

Surface water and groundwater—breaches created in the stockpiles in the rehabilitation phase

The proponent must provide the location or the various location scenarios considered for the spillways and breaches, and their dimensions.

Question CEAA-34

Surface water and groundwater—water management during the construction phase

A) The proponent must provide details (location, methods, schedules) for the construction of the infrastructure associated with watercourse diversion and dewatering activities.

B) The proponent must provide the water quality objectives for the permanent and temporary infrastructure or systems.

Questions CEAA-35 A) and CEAA-38 A) and B)

Surface water and groundwater—mapping illustrating the evolution of the infrastructure during the construction phase and detailed mapping of the route of the water for all phases of the project

A) and B) The proponent must map all water trajectories, including those from each pump to the main retention pond.

Question CEAA-36

Surface water and groundwater—effluent treatment systems during the construction and operating phases

A) The proponent must describe the treatment systems for all construction phase effluents and their capacity to treat the different types of contaminants in the water. In particular, the proponent must describe what happens to runoff from construction activities.

Question CEAA-37

Surface water and groundwater—information concerning the sealing measures at the bottom of the piles and contact water ditches

The proponent must provide a map of the location of the sanitary effluent. The proponent may also provide the various scenarios considered for the location of that effluent if the location is unknown at this time.

Question CEAA-39

Surface water and groundwater—description of the flow of mine water north of the waste rock pile and the main sedimentation pond

A) The proponent must provide a description of the flow (direction of flow, route and end point) of the sedimentation pond water in the operating phase.

C) The proponent must provide a map showing the complete flow of water in the industrial zone, including the pump for the sedimentation pond for that area, the connection (pipe) between that sedimentation pond and the rainwater and runoff system, and the actual trajectory of the water between that pump and the main sedimentation pond.

Question CEAA-41

Surface water and groundwater—mine water

The proponent must provide details of the complete path of the mine water, including the trajectory and infrastructure (pipe) between the pit and the water retention pond.

Question CEAA-42

Surface water and groundwater—information concerning the sealing measures at the bottom of the piles and contact water ditches

The proponent must provide information concerning the sealing measures at the bottom of the ore pile, including the presence of a geomembrane.

Question CEAA-44

Surface water and groundwater—service roads

A) The proponent must provide information about the means to ensure the sealing of the ditches along the service roads, since leaching of metals is expected from the construction equipment coming from the quarry or the waste rock.

Question CEAA-50

Soils and sediments—construction materials and mapping of lithology types

A) The proponent must provide a map showing the lithology types related to the construction materials (quarries and borrow pits). The proponent may also provide a map showing the various options considered for the choice of quarries and borrow pits to be operated.

B) The proponent must provide a description of all the environmental water quality changes caused by the use of the borrow pits and quarries.

C) The proponent must provide all results of geochemical characterization and/or any other relevant characterization of the materials that will be extracted from the quarries and borrow pits in order to determine their acid drainage and/or leaching potential.

Question CEAA-52

Soils and sediments—geochemical characterization of overburden and ore

A) The proponent must provide the results of the CTEU-9 leaching tests required by the COMEX for the overburden.

Questions CEAA-60 and CEAA-104 A)

Air and greenhouse gases—adjustment of atmospheric modelling of contaminants / toxicological risk assessment—baseline data and identification of contaminants of potential concern

A) The proponent must include emissions from generators (including their number and location), the concrete batch plant and the transportation of concentrate between the mine and Matagami in its modelling of the atmospheric dispersion of contaminants. The proponent may make these estimates on the basis of the maximum emissions from these types of equipment, infrastructure and transportation or on the basis of the worst-case scenario.

B) On the basis of the emissions estimated in A), the proponent must estimate the contribution of those components to total atmospheric emissions.

Question CEAA-78

Avian fauna—results of avian fauna inventories

D) The proponent must prove that the avian fauna inventories were adapted for each migratory species at risk present and potentially present in the study area, and that the inventory methodology (habitat types inventoried, period, number of stations according to the habitat availability area, etc.) was adapted to each of these species. To do so, the proponent may provide the protocol used for each species. The proponent must also prove that their potential habitats were covered sufficiently by the inventories to allow production of a representative picture of the study area.

Questions CEAA-83 and CEAA-90

Species at risk—cumulative effects assessment

A) The proponent must assess the cumulative impacts for each species at risk that could frequent the study area, including the caribou (boreal population), the wolverine and other non-avian species at risk, such as Chiroptera (bats).

B) The proponent must assess the environmental impacts for the species assessed by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) that are not yet listed in Schedule 1 of the Species at Risk Act and that could frequent the study area, including the caribou, eastern migratory population.

C) Not having assessed the cumulative impacts for species at risk for which there are recovery strategies, the proponent has not described the consequences of those impacts for the population and distribution objectives identified in those strategies, as requested. The proponent must provide that information.

Questions CEAA-88 D) and CEAA-91 A)

Species at risk—caribou monitoring program

The proponent must provide the general outline (e.g., objectives, follow-up frequency and methodology) of a caribou monitoring program.

Question CEAA-96

Indigenous peoples—consultations with Indigenous communities

B) The proponent must incorporate a portion of the north shore of Eastmain River into the human environment study area.

C) Following the inclusion of a portion of the north shore of Eastmain River in the human environment study area, the proponent must identify and locate the camps and other traditional activities of VC33 and VC35 tallymen on Map 6-22 of the EIS.

Question CEAA-99

Indigenous issues—land and resource use (black bear)

B) The proponent must propose mitigation measures related to the modification of black bear behaviour.

Question CEAA-100

Indigenous issues—land and resource use (caribou)

B) The proponent must document Cree knowledge regarding the fragmentation of the woodland and migratory caribou habitat in the area with relation to recent land development.

C) The proponent must propose mitigation measures, defined jointly with the Cree communities of Eastmain and Waskaganish, to decrease the project's potential impacts on the woodland and migratory caribou harvest for current future land users.

Question CEAA-102

Indigenous issues—land and resource use

A) The proponent must present the RE2 tallyman's concerns and recommendations regarding the mine rehabilitation plan to encourage the resumption of traditional activities by future generations on the mining territory.

Question CEAA-104

Toxicological risk assessment—baseline data and identification of contaminants of potential concern

B) The proponent must consider the water discharges and anticipate the substances that could be in the effluent(s), runoff and filtration water, including mercury. The proponent must identify the substances of potential concern based on the ore composition and the kinetic tests.

Question CEAA-106

Toxicological risk assessment—contaminant monitoring

The proponent must provide the general outline (e.g., objectives, monitoring frequency, methodology, contaminants to be monitored, standards and criteria to be applied to protect human health, and types of sampling) of an environmental monitoring and follow-up program for relevant contaminants in the various media (e.g., drinking water, air, soil and traditional food) based on human health protection criteria. This monitoring would, in particular, confirm the hypotheses and findings in the toxicological risk assessment.

Question CEAA-108

Traditional food—baseline data

The proponent must perform a chemical analysis of other resources harvested by the First Nations as traditional food in collaboration with them. This collaboration could help identify any species that should be monitored.

This analysis is very important, as the First Nations have expressed concern about the potential contamination of traditional food. It would help ensure that the First Nations people do not avoid the area on the presumption that the project's activities may contaminate traditional food, which is a very important source of nutrients. Compliance with environmental regulations (e.g., water and air regulations) in itself may not be enough to provide an acceptable measure of health protection.

Question CEAA-109

Traditional food—quality monitoring

The proponent must provide the general outline (e.g., objectives, follow-up frequency, methodology, contaminants to be monitored, species to be sampled, standards and criteria to be applied to protect human health, and types of sampling) of a human health protection program for monitoring the quality of traditional food in collaboration with Cree land users. If the proponent decides to implement the monitoring program only for plant species, it must provide a rationale for that decision. Monitoring of traditional food would ensure better communications with the First Nations regarding the risks (or lack thereof).

Question CEAA-110

Human environment—drinking water quality

A) The proponent must specify the mitigation measures included in the contingency plan to mitigate the impacts of potential spills/accidents on sources of drinking water in the study area.

Question CEAA-116

Indigenous issues—inequity of impacts

G) The proponent must assess the project's positive and negative effects on the various subgroups of the Eastmain and Waskaganish Cree communities, including women, youth and seniors, and propose appropriate mitigation measures for the assessment and for these subgroups.

Question CEAA-124

Accident risk management—potential impacts of a spill on migratory birds and species at risk

The proponent must assess the potential effects of an accidental spill of hazardous materials on migratory birds and species at risk and discuss the potential consequences of a spill for these species and their habitats.

Question CEAA-133

Monitoring and follow-up programs—monitoring program

A) The proponent must provide the general outline of the environmental monitoring program.

B) The proponent must indicate, for the elements requiring monitoring specified in the program mentioned in A), the measures and means considered for carrying out such monitoring.

Next steps

In the near future, the Committee will coordinate a meeting with the proponent and the expert departments concerned with the above-mentioned questions to discuss the information that must be provided so that the Committee and the departments can continue their EIS review. If necessary, explanations can be provided to clarify what is expected. The federal environmental assessment timeline will restart when the Committee receives all of the requested information. Please note that the Committee plans to submit another information request later to clarify certain responses.

If you need further information, please contact Véronique Lalande at 418-455-4116 or veronique.lalande@canada.ca

Yours truly,

<Original signed by>

John Paul Murdoch
Co-Chair, Joint Assessment Committee
Government of the Cree Nation
Anne-Marie Gaudet
Co-Chair, Joint Assessment Committee
Impact Assessment Agency of Canada

c.c.: [by email]: Brian Craik, Government of the Cree Nation
Véronique Lalande, Impact Assessment Agency of Canada
Elisabeth Gill, Impact Assessment Agency of Canada
Isabelle Vézina, Health Canada
Marie-Eve Lenghan, Natural Resources Canada
Annaïg Kervella, Fisheries and Oceans Canada
Sylvain Martin, Environment and Climate Change Canada
Catherine Gaudette, Transport Canada

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