Whabouchi Mining Project

Analysis of Nemaska Lithium's Proposed Changes to the Whabouchi Mining Project

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Document reference number: 123

Final Report

July 2026

Table of contents

• 1. Introduction
• 2. Proposed project changes
• 3. Analysis in accordance with the Physical Activities Regulations
• 4. Consultation and engagement
  • 4.1 Proponent engagement with Indigenous groups
  • 4.2 IAAC consultation with Indigenous groups and the public
• 5. Assessment of potential adverse environmental effects
  • 5.1 Fish and fish habitat
  • 5.2 Migratory birds
  • 5.3 Indigenous peoples
• 6. Conclusion
• Annex 1. Description of the Designated Project

List of tables

Table 1. Amendments to the Decision Statement recommended by IAAC

List of figures

Figure 1. Site layout plan for the Project area

Figure 2. Project area

1. Introduction

The Whabouchi Mining Project (the Project), as currently approved, includes the construction, operation, and decommissioning of an open-pit and underground spodumene mine for the purpose of producing lithium. The Project is located 30 kilometres from Nemaska and 280 kilometres north-northwest of Chibougamau, Quebec. The Project includes an open-pit and underground mine, a waste and tailings impoundment area, an ore concentrator, as well as administrative and maintenance buildings. The mine would have a production capacity of approximately 3,000 tonnes per day over an estimated mine life of 26 years.

The Project was assessed under the Canadian Environmental Assessment Act, 2012 (CEAA 2012). On July 29, 2015, the former Minister of Environment and Climate Change issued a Decision Statement for the Project. The Decision Statement was amended on September 19, 2023, to include the operation of two borrow pits, the establishment of a temporary construction camp, and the relocation of the final mine effluent discharge.

On January 15, 2025, the Proponent notified the Impact Assessment Agency of Canada (IAAC) of proposed changes to the Project, in accordance with condition 2.9 of the Decision Statement. This report summarizes the proposed changes and provides an analysis of whether they constitute a new or different designated project under the Physical Activities Regulations. It also assesses whether the changes could result in increased adverse environmental effects within federal jurisdiction compared to those identified in the 2015 environmental assessment. In addition, the report considers whether any modifications to the conditions in the Decision Statement, such as additions or removals, may be necessary to address the proposed changes. The analysis is based on information provided by the Proponent, as well as feedback received from federal authorities and Indigenous groups. This report also supports the exercise of the authority delegated by the Minister to the President of IAAC on July 24, 2026, under subsection 68(1) of the Impact Assessment Act to amend a decision statement where the amendment would not increase the extent to which the effects identified in the impact assessment report are adverse.

The Project is overseen at the provincial level by the Environmental and Social Impact Review Committee (COMEX). The COMEX is an independent body that reports to Quebec's Ministère de l'Environnement, de la Lutte contre les changements climatiques, de la Faune et des Parcs (MELCCFP). Its mandate is to assess and review the environmental and social impacts of projects located south of the 55^th parallel in the territory governed by the James Bay and Northern Quebec Agreement (JBNQA). The Proponent will also be required to obtain the required authorizations from COMEX and MELCCFP for the proposed changes.

2. Proposed project changes

The Proponent proposes to make the following changes to the Project, which are shown in Figure 1 and detailed in the Proponent's Notice of Amendment (Canadian Impact Assessment Registry Reference Number 80021, Document Number 113):

• the construction of a permanent workers' camp, including a drinking water treatment plant and a sanitary wastewater treatment system with surface discharge;
• the operation of a new borrow pit (BB-05) covering 2.9 hectares, located approximately 5 kilometres east of the site;
• the expansion of the pit (from 24 to 42 hectares);
• an increase in total ore production capacity, accompanied by an extension of the Project's mine life from 26 to 34 years;
• the addition of equipment to the crushing circuit and a flotation tank at the concentrator;
• the addition and reconfiguration of stockpiles and storage areas for ore, waste rock, mine tailings, and concentrate;
• changes to the mine wastewater management system, including basin capacity, as well as to the site's water balance;
• an increase in the flow rate of the final mine effluent from 208 m³/h to 458 m³/h; and
• optimization of the layout of associated infrastructure, including roads, power lines, generators, a weather station, explosives storage facilities, and support buildings.

The addition of an overpass and a bypass road, the widening of the Route du Nord, and changes to concentrate transportation logistics are proposed changes that are excluded from this analysis, as they fall outside the scope of the impact assessment.

On another note, the Proponent is requesting the removal of lake sturgeon and longnose sucker from the triennial monitoring of heavy metal concentrations in the flesh and liver of fish, as required under condition 6.3.3 of the Decision Statement. The Proponent justifies this request by indicating that lake sturgeon does not frequent waters in areas likely to be affected by the Project, while longnose sucker is neither a valued species nor one consumed by land users.

Figure 1. Site layout plan for the Project area

3. Analysis in accordance with the Physical Activities Regulations

The Physical Activities Regulations under the Impact Assessment Act (IAA) identify the physical activities that constitute designated projects that may require an impact assessment by IAAC, including paragraph 19(c), which applies to an existing metal mine whose expansion would result in an increase of 50% or more in the area of mining operations and a total ore production capacity of 5,000 tonnes per day or more following the expansion. According to the information provided by the Proponent, the proposed changes to the Project would result in an 8.57-ha or 6.88% increase in the area of mining operations, while total ore production capacity would increase from 3,000 to 5,600 tonnes per day. Consequently, IAAC has determined that the proposed changes do not constitute a new or different designated project and do not require a new impact assessment.

4. Consultation and engagement

4.1 Proponent engagement with Indigenous groups

The relocation of the permanent camp was discussed during meetings between the Proponent and the Implementation Committee (2018–2019), as well as in various forums, including the Environment Committee, conferences and assemblies of the Cree Nation of Nemaska, focus groups, and meetings with the tallyman and his family.

The borrow pit BB-05 was the subject of consultations in 2017 as part of the permitting process. No comments were received during those consultations. Additional discussions were held in 2023 with tallyman R20 regarding the proposed changes to the borrow pits.

In addition, the revised mine plan, mine water management strategy, and the various proposed optimizations were presented to the Environment Committee and during discussion groups held in 2022–2023.

The concerns raised by the Cree Nation of Nemaska regarding the proposed changes to the Project focused primarily on:

• changes to the environment, such as water quality and water levels, as well as their effects on fish and fish habitat;
• changes to air quality, noise, and vibrations, and their effects on traditional activities;
• effects on migratory birds; and
• the economic benefits of the Project.

4.2 IAAC consultation with Indigenous groups and the public

The project is located within the territory governed by the James Bay and Northern Quebec Agreement. As part of IAAC's ongoing dialogue with the Cree Nation Government (CNG) regarding matters of interest to the Cree Nation related to the Project, email exchanges and virtual meetings took place during the analysis of the changes.

IAAC sought expertise from Environment and Climate Change Canada (ECCC), Fisheries and Oceans Canada (DFO), Health Canada (HC), and Natural Resources Canada (NRCan) to support its assessment of the potential adverse effects associated with the proposed changes to the Project, as presented in Section 5.

A public consultation period was held from June 25 to July 15, 2026. No comments were received from the Cree Nation of Nemaska or the public during this period.

5. Assessment of potential adverse environmental effects

5.1 Fish and fish habitat

5.1.1 Proponent's assessment

Permanent camp

The Proponent states that runoff from the permanent camp would be collected and conveyed to the mine water treatment plant. The Proponent further states that sanitary wastewater generated by all facilities would be treated using a membrane bioreactor system, with treated effluent discharged to Lake 31. In addition, the camp would be located more than 100 metres from any waterbody or watercourse. For these reasons, the Proponent is of the view that the construction and operation of the permanent camp would have little to no additional effects on the water quality of the receiving environment, and, consequently, on fish and fish habitat.

Operation of borrow pit BB-05

The Proponent does not anticipate any effects on fish and fish habitat resulting from the operation of borrow pit BB-05, given that it is located more than 75 metres from any stream, river or lake. Extraction at borrow pit BB-05 would be carried out at least one metre above the groundwater table, and no discharge of water to the environment is anticipated.

Revision of the mine plan

According to the Proponent, the increase in the pit area would not encroach on fish habitat but would expand the area in which the water table is lowered by three metres. After 10 to 15 years of operation, this groundwater drawdown zone would extend southwestward, reaching Lake 3, Watercourse C, and the wetland. Between years 15 and 33 of operation, the three-metre drawdown would also affect Watercourses C and D, Lakes 2 and 3, and Lac du Spodumène. The Proponent indicates that the contribution of groundwater to Lake 3, Lac des Montagnes and Watercourses C and D could decrease during the final phase of operation. In this context, the lowering of the water table and the reduction in groundwater discharge could lead to changes in the hydrological conditions of the above-mentioned waterbodies and watercourses, which could in turn affect fish and fish habitat.

The Proponent states that it has implemented a program to monitor hydrological conditions in the waterbodies and watercourses that may be affected by the Project, namely Lakes 2, 3, 27, and 28, Lac du Spodumène, Lac des Montagnes, and Watercourses C and D. In addition, the Proponent states that it has submitted an offsetting plan to DFO for project activities that are likely to result in the death of fish, or the harmful alteration, disruption, or destruction of fish habitat.

Crushing circuit, concentrator and storage areas

The Proponent maintains that changes to the crushing circuit, concentrator, and storage areas would not encroach on fish habitat, as they would take place in previously disturbed lands. The Proponent adds that the new infrastructure and storage areas would be located more than 300 metres from any waterbody or watercourse. According to the Proponent, the new geometry of the co-disposal pile (Phase 1) would reduce the land footprint and would not result in any additional impacts on surface water relative to the original plans. The Proponent further states that the implementation of the mine wastewater management system, including the mine water treatment plant, as well as the setback of infrastructure from waterbodies, would help reduce potential effects on fish and fish habitat. In addition, the Proponent identifies measures such as stabilizing drainage ditches and properly managing runoff to mitigate effects on fish and fish habitat, as well as a groundwater quality follow-up program designed to detect potential contamination and support the implementation of corrective measures, as needed. In summary, the Proponent is of the view that the proposed changes to the crushing circuit, concentrator, and storage areas would result in only minor additional effects on fish and fish habitat, taking into account the mitigation measures and follow-up programs to be implemented.

Mine wastewater management system

The Proponent states that the management and treatment of water on-site prior to its discharge into the environment would ensure compliance with the final effluent discharge requirements of the Metal and Diamond Mine Effluent Regulations, which is expected to result in minor residual effects that are unlikely to affect the integrity and quality of fish habitat.

Final effluent flow

The Proponent notes that an increase in the flow rate of the final mine effluent would reduce the dilution capacity of the discharge in the Nemiscau River. Nevertheless, the Proponent anticipates that this effluent would not be harmful to the downstream environment, as any effluent whose quality is not suitable for discharge to the environment would be redirected to basin BC-01 and retreated until it meets the applicable standards. The Proponent also notes the existence of a mine wastewater management system, several follow-up programs, and an offsetting plan for fish and fish habitat.

Associated infrastructure

The Proponent states that the emulsion preparation station and the explosives and detonators storage facility would be located more than 30 metres from any waterbody or watercourse and would be situated on a gravel-covered platform equipped with a water management system. The Proponent estimates that the potential effects of relocating the garage and modifying the mine roads on fish and fish habitat would be low in intensity. The Proponent does not anticipate that the proposed changes to the associated infrastructure would result in effects significantly different from those identified in 2015.

5.1.2 Views expressed

NRCan notes that the hydrogeological study (WSP, 2023) supporting the proposed changes contains uncertainties related to modelling parameters, which may affect the extent of groundwater drawdown zones. Furthermore, NRCan observes that the study does not consider the potential effects of underground tunnels. Accordingly, NRCan supports the monitoring of waterbodies and watercourses potentially affected by these groundwater drawdown zones, as well as monitoring of groundwater levels and pumping rates. NRCan further recommends reanalyzing the hydrogeological model as monitoring data becomes available.

DFO acknowledges the uncertainties associated with the hydrogeological model identified by NRCan and considers that these uncertainties reduce the reliability of the model's predictions, thereby affecting the ability to adequately assess and monitor the Project's effects on fish and fish habitat. Consequently, DFO is of the opinion that the aforementioned monitoring requirements and reanalysis of the hydrogeological model must be incorporated into the Decision Statement to account for the effects associated with the proposed changes to the Project. DFO states that it will take into consideration the information provided by the Proponent as well as NRCan's comments as part of the ongoing authorization process under the Fisheries Act. In this regard, DFO notes that Lakes 30 and 31, as well as Streams B, E and F, were also included in the fish habitat loss assessment submitted to DFO.

ECCC considers that the proposed changes would have little or no additional effects on water quality in the receiving environment, provided that the Proponent implements the proposed mitigation and monitoring measures, including the stabilization of drainage ditches and proper runoff management. ECCC emphasizes the Proponent's commitments to groundwater quality monitoring and considers this measure essential for detecting any potential contamination.

5.1.3 Analysis and conclusions

IAAC notes that the proposed changes, particularly those related to mining operations and the water management system, could affect hydrological conditions and the quality of surface water and groundwater, with potential effects on fish and fish habitat. For example, the expansion of the pit could alter the extent of groundwater drawdown zones, potentially affecting water levels in nearby waterbodies and watercourses that provide fish habitat.

IAAC notes that the measures proposed by the Proponent and federal authorities to protect surface and groundwater have, for the most part, already been addressed in the 2015 environmental assessment, such as the installation and operation of a mine water treatment plant (condition 3.2). IAAC recommends adding a condition to the Decision Statement regarding erosion and sedimentation, based on ECCC's expert opinion. This condition would require the stabilization of drainage ditches and appropriate runoff management to mitigate the effects of changes to the Project on fish and fish habitat.

In addition, IAAC notes the uncertainties identified by federal authorities regarding the Project's effects, related, among other things, to the pit expansion, on the quality and quantity of surface water and groundwater. Consequently, IAAC recommends incorporating the following elements into the Decision Statement to verify the accuracy of the environmental assessment and evaluate the effectiveness of the mitigation measures:

• a program to monitor hydrological conditions covering the waterbodies and watercourses likely to be affected by mine water management and pit dewatering, thereby justifying the inclusion of the entirety of Stream C, as well as Lakes 2, 27, 28, and Lac des Montagnes;
• a program to monitor groundwater quality and levels.

Taking into account the additions and modifications made to the above-mentioned conditions, IAAC is of the opinion that the proposed changes to the Project should not result in adverse environmental effects on fish and fish habitat that would be likely to alter the conclusions of the 2015 environmental assessment.

5.2 Migratory birds

5.2.1 Proponent's assessment

The Proponent notes that birds use the mine site for migration, nesting and raising young. Certain areas of the mine site may also provide suitable habitat for species at risk, notably Bank Swallows, which could use the borrow pit embankments for nesting. According to the Proponent, the proposed changes could result in the loss of terrestrial habitats, the destruction of nests and eggs, and mortality of the young, while the noise and light could disrupt birds nesting nearby. The Proponent nevertheless considers that these potential adverse effects would be of low intensity and proposes to implement mitigation measures that are generally consistent with those assessed in the 2015 environmental assessment, including conducting clearing outside the breeding period of migratory birds and protecting nests discovered during construction.

5.2.2 Views expressed

ECCC notes that many of the activities that could harm migratory birds, including species at risk, were previously assessed in the 2015 environmental assessment. In ECCC's view, the proposed changes do not change the conclusions or recommendations set out in their final advice provided to IAAC for the Project in 2023. ECCC considers that the adverse environmental effects remain substantially the same and the mitigation and monitoring measures established in the current Decision Statement are adequate to mitigate these effects on migratory birds.

5.2.3 Analysis and conclusions

Taking ECCC's comments into account, IAAC considers that the proposed changes may result in low-intensity adverse effects on migratory birds, including the loss of terrestrial habitats. However, IAAC notes that these anticipated effects are of the same nature as those assessed in the 2015 environmental assessment. Consequently, IAAC is of the opinion that the existing mitigation and monitoring measures, such as conducting clearing outside the breeding season of migratory birds and protecting nests discovered during construction (condition 5.2), would be sufficient to mitigate these potential effects on migratory birds. IAAC does not recommend any additions regarding migratory birds in the Decision Statement.

5.3 Indigenous peoples

5.3.1 Proponent's assessment

The Proponent does not anticipate any effects of the proposed changes on physical and cultural heritage, as no archaeological remains dating prior to the 1950s were identified during archaeological surveys and development work at the mining site. Should any remains be discovered, the Proponent states that it would comply with applicable procedures.

Permanent camp

The Proponent does not expect the permanent camp to have any effects on the current use of land and resources for traditional purposes, as it will be constructed within the existing mine site footprint.

The Proponent believes that the requirements applicable to the discharge of sanitary wastewater into Lake 31 make it unlikely that effects on water quality and, consequently, on the health and socio-economic conditions of Indigenous peoples, will occur. Lake 31, like Lac du Spodumène, is not used as a source of drinking water.

The Proponent adds that potential contamination of the local groundwater could pose a concern for the health conditions of the Cree Nation of Nemaska, but maintains that the treatment technology selected, the applicable sanitary wastewater requirements, the proposed mitigation measures and the groundwater quality follow-up program would ensure water quality, the early detection of exceedances and the implementation of appropriate adaptive measures.

Operation of borrow pit BB-05

The Proponent believes that the operation of borrow pit BB-05, located on trapline R20, could cause wildlife to avoid the area due to the activities that will take place there, which could result in a shift in the hunting areas used by Indigenous peoples. The Proponent considers that this effect would be of low intensity, limited to a small, well-defined area, and overall unlikely to result in a significant impact on the use of land and resources for traditional purposes, given the borrow pit's proximity to the existing mine site.

From a health perspective, the Proponent notes that no drinking water sources are located near the borrow pit. The Proponent recognizes that the operation of heavy machinery could be a non-negligible source of noise and could also result in low-intensity effects on air and water quality, which could in turn affect the health of Indigenous peoples. In this regard, the Proponent reiterates that mitigation measures were established for the operation of borrow pits, including the requirement that material extraction be conducted at least one metre above the water table. The Proponent also notes that an emergency response plan would be implemented in the event of an accident or malfunction.

Revision of the mine plan

The Proponent notes that the increase in activities associated with the revision of the mine plan could cause disturbances likely to affect the traditional activities of land users, notably by modifying water levels in certain waterbodies and watercourses, as well as by altering air and water quality. However, the Proponent considers that the anticipated effects would be low in intensity and would have a limited impact on this valued component. The Proponent points to several measures established in the 2015 environmental assessment to mitigate these effects, including limiting traffic speeds on access roads and using dust suppressants. The Proponent also notes the implementation of follow-up programs to monitor hydrological conditions in waterbodies and watercourses likely to be affected by mine water management and pit dewatering, as well as programs to monitor surface water and groundwater quality.

Regarding Indigenous peoples' health and socio-economic conditions, the Proponent notes that the revision of the mine plan could increase the risks of water contamination, as well as increase noise levels and atmospheric emissions. The Proponent therefore updated the atmospheric dispersion modelling study to reflect the new operating conditions and to assess whether the predicted concentrations meet the standards for sensitive receptors. The results of this modelling indicate that the Canadian Ambient Air Quality Standards (CAAQS) for NO₂ would be exceeded by as much as 30% over a one-hour period at sensitive receptor R2. The Proponent points out that this was the maximum value obtained at all sensitive receptors, attributing these results in part to the use of conservative modelling assumptions (e.g., one blast per day), which tend to overestimate projected concentrations and the frequency of exceedances. No other exceedances were observed for the various Cree camps located near the mine site. Furthermore, the study revealed that infrequent, sporadic exceedances of standards under the provincial Règlement sur l'assainissement de l'atmosphère for total suspended particulate matter (TSP) and fine particulate matter (PM_2.5) could occur along the edge of the mine site. In light of the results obtained, the Proponent proposes to monitor NO₂ during the first year of operation and to permanently integrate this contaminant into the air quality follow-up program in the event that exceedances are confirmed.

Finally, according to the Proponent, the results of the updated noise impact study demonstrate that years of operation characterized by the highest noise levels would comply with current standards and recommendations for operational noise.

Crushing circuit, concentrator and storage areas

The Proponent points out that the proposed changes to the crushing circuit, concentrator, and storage areas would take place within the mine site footprint. The Proponent considers that these changes should have little impact on the quality of the environmental components and on the current use of lands and resources for traditional purposes by Indigenous peoples, given the mitigation and monitoring measures planned to limit the adverse effects of the Project.

With regard to health, the Proponent notes that the proposed changes, such as additions to the crushing circuit and the establishment of storage areas, nevertheless pose a risk of water contamination. The Proponent is of the opinion that these changes could also lead to increased emissions of dust and other contaminants, as well as higher noise levels. In this context, the Proponent highlights the results of the air emissions modelling and the noise impact study, which demonstrate overall compliance with current standards at sensitive receptor locations. The Proponent reiterates the existence of mitigation measures, such as the proper maintenance and storage of heavy machinery and vehicles. In summary, the Proponent expects that these changes should not result in significant effects on the health of Indigenous peoples, compared with those associated with the initial operation.

Mine wastewater management system

The Proponent anticipates little to no effects from changes to mining wastewater management on the use of land and resources for traditional purposes or on the health and socio-economic conditions of Indigenous peoples, as this wastewater would be collected and treated in accordance with current environmental standards. The Proponent also highlights the numerous follow-up programs planned for surface water and groundwater quality.

Final effluent flow

The Proponent anticipates that the increase in the flow rate of the final mine effluent would have little or no impact on the use of lands and resources for traditional purposes or on the health and socio-economic conditions of Indigenous peoples. Indeed, the Proponent states that this water would be collected and treated in accordance with applicable standards. The Proponent also highlights the various follow-up programs planned for surface water and groundwater quality.

Associated infrastructure

According to the Proponent, the reorganization of roads, as well as the resizing and repositioning of associated infrastructure, would have only limited and reversible effects on the health and socio-economic conditions of Indigenous peoples, given the low risk of surface water and groundwater contamination. The Proponent notes that these changes are generally confined to the mine site's safety perimeter, which remains inaccessible to land users. The Proponent therefore does not anticipate any effect on Indigenous peoples' ongoing use of lands and resources for traditional purposes.

5.3.2 Views expressed

Health Canada did not raise any concerns regarding the effects of the proposed changes on the health and socio-economic conditions of Indigenous peoples. Health Canada raised no objections to the Proponent's request to remove lake sturgeon and longnose sucker from the triennial monitoring of heavy metal concentrations in fish flesh and liver, as required by condition 6.3.3 of the Decision Statement. Indeed, the Proponent confirms that lake sturgeon does not inhabit the waters of the affected sites. As for the longnose sucker, it is neither a valued species nor a resource consumed by local populations, and sampling it would be difficult.

5.3.3 Analysis and conclusions

IAAC considers that the changes made to the Project could result in low-intensity effects on the health and socio-economic conditions of Indigenous peoples, particularly due to the risk of surface water and groundwater contamination, as well as increased dust emissions and noise levels. However, IAAC is of the opinion that these effects would not alter the conclusions of the 2015 environmental assessment, given the proposed mitigation measures, including the mine site watering plan, the use of dust suppressants when necessary, compliance with speed limits, and the use of functional mufflers on equipment. IAAC maintains that the groundwater quality follow-up program is necessary to detect any trends toward contamination, thereby facilitating rapid intervention and helping to limit effects on the health of Indigenous peoples. Furthermore, IAAC notes that NO₂, the contaminant for which exceedances were predicted at sensitive receptor R2, is covered by the air quality follow-up program set forth in condition 6.3.1 of the Decision Statement. Finally, IAAC recommends removing lake sturgeon and longnose sucker from the triennial monitoring of heavy metal concentrations in fish flesh and liver required under condition 6.3.3, since these species either do not inhabit the affected waters or are not consumed by local populations.

IAAC considers that the aforementioned measures are also likely to reduce any disturbances that may arise from traditional activities carried out by Indigenous peoples. In this regard, IAAC emphasizes the relevance of the existing follow-up program for the presence of wildlife species of interest at the designated Project site (condition 5.1). IAAC also notes that the accidental discovery of archaeological remains is already adequately addressed through the procedures set forth in condition 7.1 of the Decision Statement. In summary, IAAC is of the opinion that the changes made to the Project should not result in significant effects on the use of lands and resources for traditional purposes or on the physical and cultural heritage of Indigenous peoples.

6. Conclusion

Based on the information provided by the Proponent and the consulted parties, IAAC concludes that the proposed changes to the Project are not likely to result in adverse environmental effects beyond those addressed in the 2015 environmental assessment. This conclusion takes into account the mitigation measures and follow-up programs included in the conditions of the Decision Statement, as well as the proposed amendments to Table 1. These amendments include the following:

• an update to the Description of the Designated Project to reflect the proposed changes to the Project, as well as the addition of a new appendix (Schedule I) to the Decision Statement to consolidate the project description and align it with current practices;
• an update to conditions 1.9 and 1.23 to reference Schedule I in the definitions of the Designated Project and the Project area;
• an amendment to conditions 2.9 and 2.10 to clarify the requirements for submitting the results of consultation with the Cree Nation of Nemaska regarding future proposed changes to the Project, to align these conditions with recent Decision Statements, and to ensure consistency in how proponents report changes to the Project and how IAAC reviews this information;
• the addition of condition 3.4 regarding the implementation of erosion and sediment control measures;
• the addition of condition 3.8.5 to require monitoring of groundwater quality and levels;
• an amendment to condition 3.8.6 to extend the requirements for monitoring surface water quantity to the entirety of Stream C, as well as Lakes 2, 27, 28, and Lac des Montagnes;
• an amendment to condition 6.3.3 to remove lake sturgeon and longnose sucker from the triennial monitoring of heavy metal concentrations;
• administrative amendments to support translation consistency and to address typos.

Annex I. Description of the Designated Project

The Designated Project is the construction, operation and decommissioning of an open-pit and underground spodumene mine for lithium production. The Designated Project would be located 30 kilometres from Nemaska and 280 kilometres north-northwest of Chibougamau, Québec.

The Designated Project has a production capacity of up to approximately 5,600 tonnes of ore per day over a mine life of approximately 34 years. The Project area, shown in Figure 2, covers approximately 1.9 km² and is divided into two sections: the Mining Operation Area and the Tailings Management Facility Area.

Mining Operation Area

The Mine Operation Area includes the following components and associated physical activities:

• open pit;
• ore, overburden, waste rock and tailings storage areas;
• ore processing facilities, including crushing, grinding and concentration systems;
• water management, erosion and sediment control structures, including ditches and basins;
• explosives storage and handling facilities;
• worker accommodation facilities and supporting infrastructure;
• drinking water and sanitary wastewater treatment systems;
• administrative buildings, garages, workshops and warehouses;
• fuel storage and fueling stations;
• laydown areas;
• borrow pits;
• haul and service roads; and
• on-site electrical distribution system.

Tailings Management Facility Area

The Tailings Management Facility Area includes the following components and associated physical activities:

• co-disposal waste rock and tailings storage areas;
• water management, erosion and sediment control structures, including ditches and basins;
• mine wastewater treatment system, including a final effluent discharge pipeline to the Nemiscau River;
• haul and service roads; and
• laydown areas.

Figure 2. Project area