Message

----- Original Message -----

Sent: Friday, July 22, 2005 11:24 AM

Subject: RE: Licence renewal NWB2SNN0305

Environment Canada and DFO are currently working on providing some additional guidance on the use of the interim on-ice drilling guidelines. We're in the process of drafting up a letter to both the NWB and the NIRB regarding when it is and isn't appropriate to reference them. Hopefully we'll have it ready to send out in a week or two...it's difficult to get things together with everyone's summer holiday schedules, so please bear with us for a little longer on this issue!

In regards to the land-based drilling comment - EC would prefer to leave in the recommendation that land-based drilling not occur within 30 m of the high water mark. The reason that we make this recommendation in order to protect the productive littoral areas surrounding waterbodies from the risks of surface erosion and fuel spills. Surface erosion can be associated with dragging the drill onto site as well as drilling the hole, and movement of heavy equipment. This recommendation applies both within the ice-free season as well as during the winter. The recommendation against drilling within 30 m of a waterbody also helps address concerns regarding infiltration or seepage into the water body from drill additives/wastes due to decreased permafrost depths adjacent to lakes. As you are aware, we have other specific recommendations that make to protect water quality from drill additives and return water for on-ice drilling.

I hope this clarifies the issue for you and please feel free to contact me if you have any other questions. I'll be on holidays next week (July 25-29), but I'll be back in the office on August 2.

Environmental Assessment / Contaminated Sites Specialist

Environmental Protection Branch

Email: colette.spagnuolo@ec.gc.ca

just clearing off some of the files that Jim had bee working on an had a question for you on the comments you had submitted on 28Feb05.

Bullet 4 mentions that on-ice drilling was not indicated in the main application, however Q18 of the questionnaire has indicated on-ice drilling. It is not really discussed anywhere else as you mention in your comments. My question is, I noticed that Env. Can has not refered to the Interim Guidelines for on-ice drilling. I had heard rumors a month or so ago that DFO had held a workshop in YK for industry where they had indicated to those present that the guidelines had been dropped by DFO a number of years ago as it was determined that they did not apply to the small diameter drilling that would be taking place with any of the mineral exploration drilling that is currently done. DFO has apparently adopted guidelines developed recently that may have implications for all the mineral exploration currently on-going in NWT and NUnavut. Had you heard anything on this? The NWB currently refers to the Interim Guidelines in their exploration licenses but we're not really sure if there is any basis to that anymore?

My second question has to do with your bullet 5, and drilling within the 30m of a high water mark of any water body. Can you explain to me the basis behind that request as I know we've included it in every licence that has been issued in the last couple years and earlier. The reason I ask is that this Licence was amended less than a month after it was issued to allow drilling within the 30m at specified drill targets with the condition that all waste be deposited within a sump located greater than 30m above the high water mark of any water body. Would it be adequate, and meet the requirements of EC if the condition to deposit waste greater than 30m above the high water mark of any water body was included in the licences, leaving out the prohibition of drilling within that 30 metre zone. On-ice drilling is within that 30m zone and allowed with conditions, so I was wondering what the rationale was behind not allowing it within the 30m on land?

Thanks in advance for your help in clarifying this for me.

If you have any questions, please call.

____________________________________
David Hohnstein, C.E.T.
Technical Advisor Mining
Nunavut Water Board
P.O. Box 119
Gjoa Haven, NU X0B 1J0

Tel : 867.360.6338
Fax: 867.360.6369
email: tech2@nwb.nunavut.ca

Office Phone: 780.443.4406
Office Fax: 780.443.4080