James Bay Lithium Mine Project
Quebec City, April 14, 2022
Gail Amyot
Galaxy Lithium (Canada) Inc.
2000 Peel Street, Suite 720
Montreal, Quebec H3A 2W5
<email address removed>
SUBJECT: James Bay Lithium Mine Project — Analysis of the Responses to the Fourth Information Request
Gail Amyot:
On April 1st, 2022, the Joint Assessment Committee (the Committee) received additional responses from Galaxy Lithium (Canada) Inc. to the fourth information request for the above-named project. These responses are presented in the following document:
WSP, 2022. James Bay Lithium Mine Project. Alternative Solution for Road Construction. Technical Note prepared for Galaxy Lithium (Canada) Inc. 15 pages and appendices.
After reviewing the document, the Committee, in collaboration with the federal authorities involved in the environmental assessment, has determined that the responses provided were incomplete. Certain responses are not described in sufficient detail for the Committee and federal authorities to adequately assess them. The additional information requested by the Committee is included in Appendix A.
Next steps
The federal environmental assessment timeline remains suspended. The schedule will resume once the information provided allows the Committee, in cooperation with federal authorities, to proceed with the environmental assessment or prepare the environmental assessment report.
If you need further information, please contact the project manager Guillaume Clément-Mathieu, by phone at <contact information removed>or by email at <email address removed>.
Best regards,
<Original signed by>
Benoît Dubreuil
Co-chair, Joint Assessment Committee
Impact Assessment Agency of Canada
<Original signed by>
John Paul Murdoch
Co-chair, Joint Assessment Committee
Cree Nation Government
Attachment: A – Non-matching Responses to Questions from the Fourth Information Request
c.c. [by email] Kelly LeBlanc, Cree Nation Government
Erica Guth, Cree Nation Government
Elisabeth Gill, Impact Assessment Agency of Canada
Guillaume Clément-Mathieu, Impact Assessment Agency of Canada
Isabelle Vézina, Health Canada
Marie-Ève Lenghan, Natural Resources Canada
Annaïg Kervella, Fisheries and Oceans Canada
Sylvain Martin, Environment and Climate Change Canada
Catherine Gaudette, Transport Canada
Annex A. Non-matching Responses to Questions from the Fourth Information Request
The Committee concludes that the responses submitted by the proponent are not described in sufficient detail to allow their analysis. The proponent must provide the information requested below:
Efficiency, durability and sustainability of roads according to the suggested design
Non-matching response to the following question:
The proponent must demonstrate that the addition of a geomembrane to the unpaved road design will effectively prevent groundwater contamination for the duration of the project. The proponent must consider, without limitation, the impact of the following on the effectiveness, integrity and lifespan of the roads and geomembrane:
- the repeated passage of heavy trucks;
- environmental effects such as sustained rain events, water accumulation, freeze-thaw cycles and others;
- prolonged use of dust suppressants and de-icing products.
The proponent must document the state of practice, viability, effectiveness and sustainability of the proposed alternative through concrete examples typical of the climatic and logistical conditions at the James Bay Lithium Mine Project site. The Committee also recommends that the proponent relies on expert opinion and scientific literature.
Explanation:
Based on the information submitted, the Committee cannot conclude that the proposed haul road design would be effective, durable and sustainable. Although the references cited and the cases mentioned by the proponent are pertinent, they do not include concrete examples of roads with geomembrane in the context of a mining site in a northern territory. In the absence of such examples, the Committee is of the opinion that there is uncertainty about the capacity of this unproven alternative to effectively prevent groundwater contamination for the entire duration of the project. This uncertainty stems in part from questions about maintaining the integrity of the geomembrane over the long term and the durability of the haul road structure.
Therefore, the Committee requests that the proponent provide expertise in geomembranes, road construction and mining engineering to confirm the feasibility and efficacy of the suggested design. The technical advice must address the issues raised in the title question.
In addition, the technical advice must address, without limitation:
- the presence of various loose deposits, including peat deposits, over a large part of the area associated with the proposed roads, and their impact on road stability;
- geomembrane integrity monitoring at ditch and road level.
Where appropriate, the technical advice must include amendments to the proposed measures or recommend any other measures deemed essential (quality assurance and control program, maintenance, monitoring, follow-up) to avoid or mitigate potential adverse environmental effects.
Monitoring wells
Non-matching response to the following question:
The proponent must document the choice of location for the monitoring wells and justify the choice not to install them on certain sections.
Explanation:
Map 2 of the technical note presents three additional wells, i.e. PO-28-2021, PO-29-2021 and PO-30-2021. However, the proponent has still not justified the amount and locations of the observation wells.
According to Environment and Climate Change Canada (ECCC), the proponent must also explain how it would be possible to capture all contaminated water and whether pumping from the proposed wells would be sufficient to eliminate potential groundwater contamination.
Actions to be taken in case of exceedance
Comment:
The proponent states that "[groundwater sampling for developments at risk (Map 2) will be done as required by Section 2.3 of Directive 019 and compared to the resurgence criteria]. However, according to Directive 019, the frequency of well sampling for developments at risk must be done "[twice a year, generally in the spring and summer, to represent periods of high and low water]".
The proponent should, if possible, go beyond these recommendations, as a bi-annual monitoring may not be sufficient for leak detection. ECCC is of the opinion that a biannual monitoring is not adequate because of the possible risk of eventually finding arsenic in the waters surrounding the mining project. The sampling strategy, including its frequency, must be rigorous, take into account site conditions and meet the monitoring objectives, i.e. the prevention of water contamination. To this end, the proponent should also refer to available guides such as the Guide technique de suivi de la qualité des eaux souterraines of the ministère de l'Environnement et de Lutte contre les changements climatiques.
Document reference number: 47