Water Resources Division

Qimugjuk Building

P.O. Box 2200

Iqaluit, Nunavut
X0A 0H0	Your file - Votre référence

Tel: (867) 975-4548	NWB1BOS9801

Our file - Notre référence

July 17 2001

Andrea Carter

A/Licensing Administrator

Nunavut Water Board

P.O. Box 119

Gjoa Haven, Nunavut

X0B 1J0

Dear Ms. Carter:

Re: Hope Bay Joint Venture - Updated A&R Plan

The Water Resources Division has reviewed the updated Abandonment and Reclamation Plan (the "Plan") submitted by Hope Bay Joint Venture. In general, the Plan lacks sufficient detail and does not address many of the environmental issues at the site. Much of the background information in this evaluation stems from the 1999 Hope Bay Belt Site Assessment that was completed for BHP Diamonds by Rescan.

Sampling conducted during the site assessment identified several areas requiring remediation, the report also includes suggested remedial actions. The environmental issues include: hydrocarbon contaminated soil, areas with tundra burn, and areas containing salt contamination and drilling wastes.

1.	Hydrocarbon Contaminated Soil

a.	Soil samples collected from the area surrounding the Procon Shop exceeded guidelines for total petroleum hydrocarbons (TPH), stained soils near the fuel storage and refuelling area were observed.

b.	Rescan suggested that these soils be fertilized to enhance bioremediation, alternatively the soils can be removed and disposed of appropriately.

c.	These soils must meet CCME guidelines for TPH content prior to site abandonment and the methodology to achieve this should be outlined in the Plan.

2.	Tundra Burn

a.	Soil downslope of the two settling ponds contained high levels of metals, TPH, and salt and the source was attributed to drill cuttings that were disposed of in the unlined pit (although this does not explain the TPH)

b.	Several of the samples obtained from the salt burns in the vicinity of the airstrip contained excessive salt concentrations.

c.	Rescan suggested that the light grey sedimentary material (bentonite) be removed and that fertilizer be applied to the TPH to promote bioremediation.

d.	These soils must meet CCME guidelines for salt (chloride), metals (e.g. arsenic, chromium, copper), and TPH content prior to site abandonment and the methodology to achieve this should be outlined in the Plan.

The Plan does not describe work that was undertaken during 2000-2001 to remediate the above-mentioned sites nor does it provide details as to how these sites will be remediated.

Since the areas are readily accessible and remedial activities would not significantly disrupt other site activities, progressive restoration at the sites would be appropriate. The Plan also lacks sufficient detail in the following areas:

•	remediation the ore stockpiles; the Plan states that the stockpiles will be either recontoured or placed underground (the spreadsheet includes and estimate for covering the stockpile but the Plan does not provide information on the cover material, etc.); the Plan should include mitigative measures for metal leaching or acid rock drainage if these issues arise,

•	remediation of the solid waste disposal area and the three ponds located in the proximity of the ore stockpiles.

DIAND feels that the NWB should request a more comprehensive Plan from the Licensee to ensure the above mentioned work will be completed in an appropriate time frame. Should you have any questions or comments, please do not hesitate to contact me at the number above or by e-mail at johnsonmi@inac.gc.ca.

Sincerely,

Michelle Johnson

Kivalliq/Kitikmeot Regional Coordinator