GIANT MINE REMEDIATION PROJECT - Spill Contingency Plan Version 2.1 - March 2021
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GIANT MINE REMEDIATION PROJECT Spill Contingency Plan Version 2.1 March 2021 376-Management Plans-74-RPT-0004_Rev2_20210325 (Spill CP Rev 2.1)
Spill Contingency Plan LAND ACKNOWLEDGMENT The Giant Mine Remediation Project acknowledges the Indigenous Peoples and the importance of the land in and around the Giant Mine Site, which is located in Chief Drygeese Territory. From time immemorial, it has been and is the traditional land of the Yellowknives Dene First Nation. We acknowledge that the Giant Mine site is also within the homeland of the North Slave Métis Alliance and the Tłichǫ Mǫwhì Gogha Dè Nı̨ ı̨ tłèè boundary. The Giant Mine Remediation Project respects the histories, languages, and cultures of First Nations, Métis, Inuit, and all First Peoples of Canada, whose presence continues to enrich our vibrant community. Version 2.1 i March 2021
Spill Contingency Plan PLAIN LANGUAGE SUMMARY This is a Giant Mine Remediation Project (GMRP or the Project) Spill Contingency Plan that explains how spills are managed on Site. The focus of this version of the Spill Contingency Plan (the Plan) is on the care and maintenance and remediation activities that will take place at the site. This Plan will be updated as necessary as remediation progresses. This Spill Contingency Plan has been developed to meet spill contingency plan guidelines, and applicable Water Licence and Land Use Permit conditions. The approach of the Spill Contingency Plan is to promote safe handling of hazardous materials to help prevent spills and provide a response system that can be implemented quickly in case of a spill. This Plan identifies potential sources of spills during remediation and the best ways to manage spills that may occur. The Plan also provides the roles and responsibilities of staff on-site, spill reporting protocols, and training provided for staff. This Plan gives the Site personnel guidance on how to contain spills depending on size (small or large) and location of spills (e.g., on open water, ice, snow, or land). It provides spill containment procedures to minimize the extent of contamination following a spill. For spills, the priority is to minimize any direct threat to human health or the natural environment. In accordance with the Annual Water Licence reporting requirements, the GMRP will submit a summary of activities conducted in accordance with the Spill Contingency Plan during the previous calendar year. The GMRP will conduct an annual review of this Plan and make any revisions necessary to reflect changes in operations, contact information, or other details. Version 2.1 ii March 2021
Spill Contingency Plan VERSION HISTORY Date Issued/ Version Description of Version Effective Date 1.0 April 1, 2019 Submitted with Water Licence Application to Mackenzie Valley Land and Water Board Submitted to the Mackenzie Valley Land and Water Board as per Water Licence MV2007L8-0031, Part H, Condition 1. Changes to this Plan include an update to address 2.0 December 16, 2020 the Board Directives included in the Water Licence, commitments made during the water licencing process and for consistency in format with other site wide management plans. Submitted to the MVLWB to address MVLWB direction dated February 12, 2021. A 2.1 March 25, 2021 summary of changes was appended to the cover letter submitted with this version. Version 2.1 iii March 2021
Spill Contingency Plan TABLE OF CONTENTS 1 INTRODUCTION ...........................................................................................................................................1-1 1.1 Plan Objectives and Linkages.........................................................................................................1-1 1.2 Project Team ...................................................................................................................................1-6 1.3 Environment, Health and Safety, and Community Policy ...............................................................1-7 1.4 Regulatory Framework ....................................................................................................................1-7 1.5 Engagement ....................................................................................................................................1-9 1.6 Traditional and Community Knowledge ..........................................................................................1-9 1.7 Project Activities Relevant to the Plan ............................................................................................1-9 1.8 Training and Personnel Safety........................................................................................................1-9 2 HAZARDOUS MATERIALS MANAGEMENT.............................................................................................2-1 2.1 Handling Hazardous Materials ........................................................................................................2-1 2.2 Hazardous Materials Inventory .......................................................................................................2-1 2.2.1 Oils and Greases .......................................................................................................................2-2 2.2.2 Fuels (Diesel and Gasoline) ......................................................................................................2-2 2.2.3 Propane .....................................................................................................................................2-2 2.2.4 Reagents....................................................................................................................................2-3 2.2.5 Solvents .....................................................................................................................................2-3 2.2.6 Sewage and Greywater .............................................................................................................2-3 2.2.7 Arsenic Impacted Wastes ..........................................................................................................2-3 2.2.8 Explosives ..................................................................................................................................2-4 2.2.9 Co-Polymers ..............................................................................................................................2-4 2.2.10 Chemical (Dynalene HC, Carbon Dioxide (CO2) and Nitrogen) ...............................................2-4 3 SPILLS MANAGEMENT ..............................................................................................................................3-1 3.1 Roles and Responsibilities ..............................................................................................................3-1 3.1.1 First Responder .........................................................................................................................3-2 3.1.2 Mine Manager and/or Incident Commander (or designate).......................................................3-2 3.1.3 Emergency Management Team ................................................................................................3-3 3.1.4 Environmental Manager (or their designate) .............................................................................3-3 3.1.5 Technical Specialists .................................................................................................................3-4 3.2 Spill Resources ...............................................................................................................................3-5 3.2.1 Access to the Plan .....................................................................................................................3-5 3.2.2 On-Site Communication.............................................................................................................3-5 3.2.3 Spill Kits and Personal Protective Equipment ...........................................................................3-5 3.2.4 Spill Kit Contents .......................................................................................................................3-5 3.2.5 Spill Kit Locations ......................................................................................................................3-6 3.2.6 Spill Equipment Inventory ..........................................................................................................3-9 3.2.7 Off-site Spill Response Resources ............................................................................................3-9 3.3 Spill Response Procedures...........................................................................................................3-10 3.3.1 Incident Action Plans ...............................................................................................................3-11 3.3.2 Continued Action Until Help Arrives ........................................................................................3-11 3.4 Spill Containment Measures .........................................................................................................3-12 Version 2.1 iv March 2021
Spill Contingency Plan 3.4.1 Containment on Open Water ...................................................................................................3-13 3.4.2 Containment on Ice ..................................................................................................................3-13 3.4.3 Containment on Snow .............................................................................................................3-13 3.4.4 Containment on Land ..............................................................................................................3-14 3.4.5 Fire or Explosion Hazard .........................................................................................................3-14 3.4.6 Disposal of Contaminated Materials ........................................................................................3-14 4 PREVENTION OF SYSTEM FAILURE .......................................................................................................4-1 4.1 Monitoring .......................................................................................................................................4-1 4.1.1 Minewater Pipeline Monitoring...................................................................................................4-1 4.1.2 Tailings Dam Structural Monitoring ...........................................................................................4-1 4.1.3 Petroleum Products Monitoring .................................................................................................4-2 4.1.4 Propane Tank Inspection ...........................................................................................................4-3 4.1.5 Arsenic Trioxide Storage ...........................................................................................................4-3 5 REPORTING AND PLAN REVIEW .............................................................................................................5-1 5.1.1 Emergency Spill Reporting ........................................................................................................5-1 5.1.2 Annual Reporting .......................................................................................................................5-2 5.1.3 Plan Review ...............................................................................................................................5-2 6 REFERENCES ..............................................................................................................................................6-1 LIST OF TABLES Table 1.2-1: Giant Mine Remediation Project Site Contacts...................................................................1-6 Table 1.4-1: Relevant Spill Contingency Legislation and Guidelines .....................................................1-8 Table 2.2-1: Hazardous Materials Storage Volumes ..............................................................................2-2 Table 3.2-1: Spill Kit Locations at Giant Mine Site ..................................................................................3-6 Table 3.2-2: Spill Kit in Trucks at Giant Mine Site ...................................................................................3-7 Table 3.2-3: Spill Containment Equipment Inventory ..............................................................................3-9 LIST OF FIGURES Figure 1.1-1: Giant Mine Site Layout ........................................................................................................1-2 Figure 1.1-2: Linkages Between Management and Monitoring Plans for Giant Mine ..............................1-4 Figure 1.1-3: Linkages Between Environmental Management and Monitoring Plans, Construction and Design Plans for Giant Mine ........................................................................................1-5 Figure 3.2-1: Locations of Spill Resources on Site ..................................................................................3-8 Version 2.1 v March 2021
Spill Contingency Plan LIST OF APPENDICES APPENDIX A Conformity Table APPENDIX B Government of The Northwest Territories - Reportable Spill Quantities APPENDIX C List of Approved Chemicals and Safety Data Sheets APPENDIX D Incident Action Plans APPENDIX E Government of the Northwest Territories - Spill Response Form APPENDIX F Emergency Response Communications Flowchart APPENDIX G Emergency Response Communications Flowchart Locations Version 2.1 vi March 2021
Spill Contingency Plan TABLE OF ACRONYM DEFINITIONS Acronym Definition CALA Canadian Association of Laboratory Accreditation CIRNAC Crown-Indigenous Relations and Northern Affairs Canada CRP Closure and Reclamation Plan E2 ECCC Environmental Emergencies Regulations ECCC Environment and Climate Change Canada EHSC Environment, Health & Safety, and Community EMT Emergency Management Team ENR Environment and Natural Resources EPA Environmental Protection Act ETP Effluent Treatment Plant FOS Freeze Optimization Study GMRP Giant Mine Remediation Project GN Government of Nunavut GNWT Government of the Northwest Territories ICS Incident Command System ICT Incident Command Team INAC Indigenous and Northern Affairs Canada MCM Main Construction Manager MEG Mobile Equipment Garage MMP Management and Monitoring Plan MSA Materials Storage Area MVLWB Mackenzie Valley Land and Water Board PCB Polychlorinated Biphynels PPE Personal Protective Equipment PSHEP Project Safety, Health, and Environment Plan PSPC Public Services and Procurement Canada SDS Safety Data Sheet(s) SOP Standard Operating Procedure TCA Tailing Containment Areas TDG Transportation of Dangerous Goods TDGR Transport of Dangerous Goods Regulations the Project Giant Mine Remediation Project the Site Giant Mine WHMIS Workplace Hazardous Materials Information System Version 2.1 vii March 2021
Spill Contingency Plan 1 INTRODUCTION The Giant Mine (Site) is located within the City of Yellowknife boundary, approximately 1.5 kilometres (km) from the community of Ndilǫ and 9 km from the community of Dettah. The Site is situated on Commissioner’s Land administered by the Government of the Northwest Territories (GNWT); Reserves (R622T and 85 J/8-257-2) have been established to allow for the implementation of the remediation of the Site. Ongoing care, maintenance and remediation of the Site is known as the Giant Mine Remediation Project (GMRP or the Project). Subsurface mineral rights are under federal jurisdiction and were withdrawn by Order in Council SI/2005-55 on 15 June 2005. For a history of the Giant Mine and planned remediation activities, please refer to the Closure and Reclamation Plan (CRP). The Site consists of eight abandoned open pits; an underground mine with arsenic trioxide storage areas; Tailings Containment Areas (TCAs) with associated rock fill dams; mine waste rock that buttresses Dams 11, 21B and 21D; a tailings re-treatment plant (out of service since 1990); an Effluent Treatment Plant (ETP); a Mill Complex; several warehouses; and a townsite. Baker Creek flows through the Site seasonally with one ponded area. The Site features are outlined in Figure 1.1-1. 1.1 Plan Objectives and Linkages Plan Objective This Spill Contingency Plan (the Plan) addresses protocol for safe handling of hazardous materials and wastes, and emergency response measures to be implemented in the case of a spill during existing conditions, during active remediation of the Site, and moving into post-closure monitoring of the GMRP. In addition, the Plan also provides the roles and responsibilities of staff on-site, communication protocols, and training provided for staff responsible for enacting the Plan. This Plan is to be used by all personnel at the Site. This plan is intended to provide guidance on spills of all sizes. The objectives of this Plan are to present proactive and safe strategies for handling hazardous materials and to provide easily understood and reasonably comprehensive information to deal with a spill, while minimizing health and safety hazards, environmental damage, and clean-up costs. This Plan is designed to: a) promote safe handling of hazardous materials and help to minimize the occurrence of spill incidents b) outline a formal, practical response system that can be implemented rapidly in the event of a spill of materials resulting from activities performed at the Site that may be hazardous to human health or the environment This Spill Contingency Plan has been developed to satisfy the spill contingency plan guidelines, and applicable conditions set forth in Water Licence MV2007L8-0031 (Appendix A) and Land Use Permit MV2019X0007. Updates to the Spill Contingency Plan will be ongoing through the life of the GMRP to provide more details on future management, as remediation moves forward. Version 2.1 1-1 March 2021
PATH: I:\CLIENTS\GOVERNMENT_OF_CANADA\GIANT_MINE\20137939\Mapping\Products\TA74_74000A_WaterManagementPlan\02-74-0599-R-376-Rev0.mxd PRINTED ON: 2021-03-18 AT: 5:05:29 PM 634000 636000 638000 6936000 6936000 Shot Lake Trapper Lake DAM 22B NORTHWEST POND NON-HAZARDOUS DAM 22A WASTE DISPOSAL SITE r ive fe R ni NORTHWEST POND wk HAZARDOUS lo Gar Yel Lake WASTE AREA NORTHWEST POND DAM 21D SOLIDS RETENTION DYKE Trapper C (SPLITTER DYKE) CONTAINMENT BERM EFFLUENT ree DAM 21A TREATMENT k DAM 21C PLANT (ETP) DAM 21B DAM 3C B4 DAM 3 PIT SETTLING POND Bak DAM 1 POLISHING DAM 3D 6934000 6934000 er C ree POND DAM 2 k B3 NORTH M&M DAM PIT POND TAILING Pocket REPROCESSING DAM 6 Lake Ã Ä Baker PLANT 4 Pond DAM 10 (REMOVED) DAM 4 CENTRAL POND DAM 9 STORAGE CALCINE POND DOME MATERIAL B1 STORAGE B2 DAM PIT AREA DAM 8 B2 PIT DAM 5 (UBC) DAM 12 BROCK FORMER SOUTH PIT ROASTER POND AND STACK MILL POND MILL DAM 11 C1 CLAY C SHAFT DAM 7 BORROW DAM k ree C1 rC PIT ke Ba FORESHORE TAILINGS AREA 6932000 6932000 A SHAFT Yellowknife Bay Handle Lake A1 PIT TOWNSITE IF THIS MEASUREMENT DOES NOT MATCH WHAT IS SHOWN, THE SHEET SIZE HAS BEEN MODIFIED FROM: ANSI B DWC DAM MARINA A2 PIT 634000 636000 638000 LEGEND BUILDING GIANT MINE PROJECT BOUNDARY HIGHWAY INDUSTRIAL WATERCOURSE 0 500 1,000 REFERENCE(S) INFRASTRUCTURE HYDROLOGY AND TRANSPORTATION DATA OBTAINED FROM GEOGRATIS, © DEPARTMENT OF NATURAL RESOURCES CANADA. 2018 ORTHOPHOTO PROVIDED BY AECOM. ROAD 1:20,000 METRES DATUM: NAD 83 PROJECTION: UTM ZONE 11 SPLITTER DYKE PROPONENT PROJECT SURFACE WATER MANAGEMENT DAM/DYKE 25mm TAILINGS OR SLUDGE RETENTION DAM WATERCOURSE YYYY-MM-DD 2021-03-18 TITLE INDUSTRIAL WATERBODY DESIGNED J. LACRAMPE GIANT MINE SITE LAYOUT PIT BOUNDARY PREPARED A. AUCOIN WATERBODY REVIEWED T. HALL PROJECT NO. CONTROL REV. FIGURE APPROVED T. HALL 20137939 02-74-0599 0 1.1-1 0
Spill Contingency Plan Linkage to Other Plans There are other GMRP management and monitoring plans that are related to the Spill Contingency Plan (Figure 1.1-2). An overview of site-wide monitoring during Active Remediation and Adaptive Management (Phase 2) and during Post-Closure (Phase 3) is illustrated in Figure 1.1-3. The Spill Contingency Plan specifically informs and is informed by: • Waste Management and Monitoring Plan • Water Management and Monitoring Plan • Surveillance Network Program The environmental Management and Monitoring Plans (MMPs) for the GMRP have been developed to complement each other while reducing repetition and overlap between plans. As a result, the environmental MMPs are cross-referenced within other plans to indicate where more information can be found. The linkages figures assist with the understanding of how these plans work together to manage and monitor site activities; these are high-level figures representing overall relationships. Figure 1.1-2 is reflective of the current scope of the plans (i.e., the first few years), but includes all major activities anticipated over the life of the Water Licence. As such, the existing post-construction plans (Arsenic Trioxide Frozen Shell and Tailings MMPs) are identified in the diagram which do not apply within the current scope but do provide an understanding of how they fit within the project as a whole. The Spill Contingency Plan also forms Appendix G of the overall GMRP - Emergency Management and Response Plan maintained by the Main Construction Manager (MCM) for the site. The Emergency Management and Response Plan is prepared to protect the public, workers, environment and property through emergency prevention and prepared and coordinated response and recover in the event of an emergency. Other relevant sections of the GMRP - Emergency Management and Response Plan that inform this Spill Contingency Plan include: • Emergency Contact Information in Appendix A • Site-Specific Emergency Response Plan for Arsenic in Appendix E • Site-Specific Emergency Response Plan for Propane in Appendix F Version 2.1 1-3 March 2021
Spill Contingency Plan Figure 1.1-2: Linkages Between Management and Monitoring Plans for Giant Mine Note: there is also an operational maintenance surveillance (OMS) manual for the existing tailings containment area and dam management relevant to the Canadian Dam Association guidelines; it is not for MVLWB approval but is available here for interested parties: https://giantminerp.ca/glance-giant-mine-remediation-project Version 2.1 1-4 March 2021
Spill Contingency Plan Figure 1.1-3: Linkages Between Environmental Management and Monitoring Plans, Construction and Design Plans for Giant Mine Version 2.1 1-5 March 2021
Spill Contingency Plan 1.2 Project Team The GMRP is led by Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) with the Government of the Northwest Territories acting as co-proponents. Public Services and Procurement Canada (PSPC) provides contracting services, contract management, and technical support services to CIRNAC. PSPC has awarded the MCM contract to Parsons Incorporated. This contract will be used to complete implementation activities for the GMRP. The MCM is responsible for overall Site management including emerging risks on Site and supporting planning efforts for closure and reclamation. For this Spill Contingency Plan, the MCM will be responsible for verifying required spill contingency controls are in place and working properly. The MCM and their procured subcontractors will be required to adhere to the details. The MCM will oversee the implementation of the CRP and associated activities. Refer to Table 1.2-1 for staff responsible for management for the GMRP; refer to Appendix B of the GMRP – Emergency Management and Response Plan, for the list of contacts in the event of an emergency or spill. Table 1.2-1: Giant Mine Remediation Project Site Contacts Company Contact Role Information Phone: 867-669-2823 Natalie Plato Deputy Director Email: natalie.plato@canada.ca Phone: 867-444-9783 CIRNAC Candace DeCoste Regulatory Manager Email: candace.decoste@canada.ca Phone: 867-444-9400 Curtis Duffy Senior Engineer Email: curtis.duffy@canada.ca Phone: 780-918-6277 PSPC Brad Thompson Senior Project Manager Email: brad.thompson@pwgsc-tpsgc.gc.ca Phone: 867-669-3715 Doug Hayes Mine Manager Email: doug.hayes@parsons.com Phone: 867-669-3725 Parsons Norlito Cezar Environment Manager Email: Norlito.cezar@parsons.com Senior Safety Specialist Phone: 867-669-3719 Lex Lovatt Security Email: lex.lovatt@parsons.com CIRNAC = Crown-Indigenous Relations and Northern Affairs Canada; PSPC = Public Services and Procurement Canada. Version 2.1 1-6 March 2021
Spill Contingency Plan 1.3 Environment, Health and Safety, and Community Policy Within the GMRP, the health and safety of employees and protection of the environment are an over-riding priority. Management is committed to doing everything possible to prevent injuries and to maintain a healthy environment. The overall goals of the GMRP are: • minimize public and worker health and safety risks • minimize the release of contaminants from the Site into the environment • remediate the Site in a way that inspires public trust • implement an approach that is cost-effective and robust over the long term In keeping with these overall goals for the Project, the specific objectives of this policy are: • protecting the environment and the health and safety of its employees, contractors, and the general public • engaging meaningfully with stakeholders and rights holders • recognizing the important contributions of Elders and community members, and incorporating Traditional Knowledge and community knowledge across the Project • delivering local social and economic benefits • recognizing the Project is an opportunity to advance reconciliation • continuing to look for opportunities to further reduce greenhouse gas emissions and ensure climate change adaptation is incorporated into the Project • being a recognized leader in Environment, Health & Safety, and Community (EHSC) management among public environmental remediation projects The full GMRP EHSC Policy is available upon request. 1.4 Regulatory Framework This plan was developed in consideration of regulatory requirements including legislation, guidance documents, Water Licence requirements, and GMRP commitments and conditions. A full list of requirements/commitments relevant to this plan can be found in Appendix A. Relevant federal and territorial legislation and permits/licences that apply to the Site include: • Mackenzie Valley Resource Management Act (Government of Canada 1998) • Government of Northwest Territories Mine Health and Safety Act (GNWT 1994) and Regulations (GNWT 2003) • Type A Water Licence (MV2007L8-0031) • Land Use Permit (MV2019X0007) Version 2.1 1-7 March 2021
Spill Contingency Plan The following guidance/policy documents were used to support the Spill Contingency Plan: • Guidelines for Spill Contingency Planning developed by Indigenous and Northern Affairs Canada (INAC), April 2007 (INAC 2007) • GNWT Spill Contingency Planning and Reporting Regulation, March 2011 (GNWT 2011) The GNWT regulates reporting requirements (based on reportable spill quantities, Appendix B) under the Environmental Protection Act. The Mackenzie Valley Land and Water Board (MVLWB) further reinforces those requirements through conditions placed in the Water Licence MV2007L8-0031 and Land Use Permit (MV2019X0007). Further, in adherence to the GMRP Environment, Health and Safety and Community Policy, GMRP will comply with relevant federal and territorial legislation and guidelines when dealing with specific issues related to spill management and the environment. A summary of Acts, regulations, and guidelines used to support this Spill Contingency Plan are included in Table 1.4-1. Table 1.4-1: Relevant Spill Contingency Legislation and Guidelines Acts and Regulations Guidelines • Waters Act (GNWT 2014) • Fisheries Act (Government of Canada 1985) • Migratory Birds Convention Act (Government of Canada 1994) • Transportation of Dangerous Goods Act (Government of Canada 1992) • Northwest Territories-Nunavut Spills Working Agreement • NWT Environmental Protection Act (GNWT 1988) (Government of Canada, GNWT, Inuvialuit Land • Canadian Environmental Protection Act (Government of Administration, GN 2014) Canada 1999) • Guidelines for Spill Contingency Planning (INAC 2007) • Spill Contingency Planning and Reporting Regulations • Guidelines for the Closure and Reclamation of Advanced R-068-93 (GNWT 2011) Mineral Exploration and Mine Sites in the Northwest • Used Oil and Waste Fuel Management Regulations Territories prepared by the Mackenzie Valley Land and R-064-2003 Water Board (November 2013) • Canada Occupational Health and Safety Regulations • Standard Outline for Management Plans (MVLWB 2013); (SOR/86-304) and • ECCC Environmental Emergencies Regulations (E2) • Northern Contaminated Sites Program Environment, (SOR/2019-51; Government of Canada 2019) Health and Safety Policy draft (CIRNAC 2020). • Metal and Diamond Mining Effluent Regulations (SOR/2002-222) • Storage Tank Systems for Petroleum Products and Allied Petroleum Regulations (SOR/2008-197) • Northwest Territories Safety Act (2015) Version 2.1 1-8 March 2021
Spill Contingency Plan 1.5 Engagement Version 1.0 of this Spill Contingency Plan was provided to the Mackenzie Valley Land and Water Board (MVLWB) for review and feedback in 2019 and was given interim approval by the MVLWB on September 18, 2020. The GMRP has reached an agreement with City of Yellowknife to provide funding for specialized training for the Yellowknife Fire Division in the event that they need to respond to an emergency situation at the Giant Mine Site. Further details are included in Section 3.2.7. For further detail on the engagement that has occurred for the GMRP please refer to the CRP and the Engagement Plan. 1.6 Traditional and Community Knowledge The consideration of Traditional and Community Knowledge has been integrated into project planning and activities through the consultation and engagement processes the GMRP undertakes with rights holders on various project works. The GMRP Team is committed to continuing to incorporate Traditional and Community Knowledge into the implementation strategy as part of site remediation. The GMRP does not have any specific commitments relevant to the Spill Contingency Plan from the Traditional and Community Knowledge heard to date but will continue to evaluate this throughout the life of the Project. The Engagement Plan, specifically Appendix C, summarizes the Traditional and Community Knowledge provided to date. 1.7 Project Activities Relevant to the Plan This Spill Contingency Plan is focused on activities including continued care and maintenance of the site, demolition of old buildings, blasting, development of quarries, construction of the landfill, excavating contaminated material, storage and management of surface water, surface remediation and clearing of vegetation to support remediation. Remediation will take over ten years to complete. After that time, ‘adaptive management’ will commence to determine if the completed activities are performing as designed. Once closure activities are complete, the GMRP will enter the post-closure phase; it is understood that post-closure activities are not in scope in this water licence. 1.8 Training and Personnel Safety The effectiveness of this Spill Contingency Plan is dependent upon the training and knowledge of staff implementing the Plan. All personnel will receive an orientation related to spill contingency and emergency response on-site as part of the general safety orientation for employees and contractors. The GMRP - Project Safety, Health and Environmental Plan, more specifically the GMRRP - Emergency Management and Response Plan outline the training requirements including those specific to emergency response. Specific to the Spill Contingency Plan, supervisors will review the Plan with each employee on site: • during the employee’s initial site orientation • following an employee’s absence from site of six months or more • when the employee’s responsibilities under the plan change • when the plan is updated Version 2.1 1-9 March 2021
Spill Contingency Plan 2 HAZARDOUS MATERIALS MANAGEMENT Heath, safety, and the prevention of spills are primary considerations when planning for the use, storage, handling, transportation, and disposal of hazardous materials. Workplace Hazardous Materials Information System (WHMIS) has been adopted for employee training and safe storage and handling of controlled products at the Site. Storage, handling, and transportation procedures will comply with Transport of Dangerous Goods Regulations (TDGR) and WHMIS. Most of the chemical and petroleum-based products that will be present at the Site are those used in support of remediation work; however, chemical and petroleum-based products used in past gold mining activities remain. A hazardous waste inventory was completed in 2017 (AECOM 2018) and identifies the locations and nature of the remaining hazardous products, which will be handled and disposed of according to the Waste Management and Monitoring Plan (MMP). In addition to ‘consumable’ products, hazardous by-products of the historical mining activities such as untreated minewater and tailings are present and addressed in the Water Management and Monitoring Plan and the Operation, Maintenance, and Surveillance Manual. 2.1 Handling Hazardous Materials Hazardous materials are classified according to TDGR and any future updates. Substances that fall under these regulations will be labelled to inform personnel of their contents and to comply with governmental regulations. There is a centralized Safety Data Sheets (SDS) binder located at the Safety Office C-Dry wicket, which contains information on hazardous products used on Site. Access to information on chemicals is available 24-hours a day through the Security Officer on duty. SDS binders are also kept in the location of where the hazardous material is stored, and at specific projects on an as-needed basis. The list of approved SDS chemicals is included in Appendix C. The SDS binders are maintained by the Health and Safety Manager and updated regularly. Additionally, contractors working at the site are required to submit copies of SDS documents for hazardous materials required to support the remediation activities they are working on to the MCM Health and Safety Manager prior to or accompanying shipments to the Site. SDS binders should be kept with this plan in locations where the plan is available on site. This plan will be updated for chemicals added to the SDS binder that are not covered by the procedures contained within this plan. Site personnel will be trained on the use of Personal Protective Equipment (PPE) for all applicable tasks on-site. PPE for workers is available from MCM managers. 2.2 Hazardous Materials Inventory Chemicals and petroleum-based products are stored following applicable regulations, codes and best practices (refer to the Waste MMP for additional storage details of the Waste Management Area and Hazardous Waste Transfer Area), based on the product composition and WHMIS classification. The most recent inventory of on-site chemicals and petroleum-based products is available in the Environmental office on site. Additional details on the inventory can be found in the Waste MMP. The following sections outline the hazardous materials that are currently stored at the Giant Mine site. Storage volumes of these materials are provided in Table 2.2-1. Version 2.1 2-1 March 2021
Spill Contingency Plan Table 2.2-1: Hazardous Materials Storage Volumes Item Maximum Storage Capacity Maximum Allowable Storage Volume Diesel1 100,000 L 80,000 L Gasoline 2,500 L 1,250 L Propane1 100,000 L 80,000 L Solvents 205 L 205 L Lime2 37.5 metric tonnes 30 metric tonnes Magnafloc/Vanfloc3 22,000 L 12,800 L Ferric Sulphate2 131 metric tonnes 126 metric tonnes Notes: 1 Based on the ECCC-registered tanks and propane tank and 80% fill capacity requirement. 2 Based on the ETP 2011 Binder maximum inventory datasets. Ferric sulphate tank had 126 MT at 96% capacity. 3 Based on the approximate tank dimension of 4.5 m height and 2.4 m diameter, with a maximum allowable level at 2.7 m. The maximum (allowable) level is based on ETP 2011 Binder maximum inventory datasets. 2.2.1 Oils and Greases Equipment used at the Site requires moderate amounts of hydraulic and lubricating oils and greases which are delivered from local suppliers in drums, pails and cases. These products can be found in the warehouse, and in the various shops around site. Oils and greases will be stored in secondary containment. 2.2.2 Fuels (Diesel and Gasoline) Boilers and heavy equipment, as well as the majority of light vehicles, pumps and generators on site are fueled by automotive grade diesel. Smaller generators and pumps require unleaded gasoline. A diesel and gasoline fueling station (100,000 L diesel tank, 22,000 L diesel tank, 25,000 L diesel tank and 2,500 L mobile gasoline tank) was installed near the C-Dry and has been in service since the summer/fall of 2011. Bulk deliveries of fuels are made to this location on a regular basis. Tanks are double walled and are maintained in compliance with the Storage Tank Systems for Petroleum Products and Allied Petroleum Regulations (Government of Canada, 2007), and other applicable legislation. Fueling is undertaken within the designated Project Transfer Area and in accordance with the Product Transfer Standard Operating Procedure (SOP). 2.2.3 Propane A 30,000 gal (US) propane tank is located next to the B-Shaft Ventilation Plant. Propane from this tank is used to heat air supplied to the underground during the winter months. The tank is owned and maintained by Superior Propane. The tank is registered to the MCM under the E2 Regulations, as per Environment and Climate Change Canada (ECCC) instructions. In addition to the large propane tank located at B-Shaft Ventilation Plant, propane and MAPP cylinders are also stored at the Mobile Equipment Garage (MEG) and they are commonly used to fuel torches. Additional smaller propane tanks can be found on-site (i.e., ETP office trailers (100-420 lbs)) for heating. The MCM will contact Superior Propane in the event of emergencies involving propane. On-site personnel will not attempt to deal with any spill/leak involving propane other than to provide site security and/or remove possible sources of ignition. The Site-specific Environmental Emergency Plan for Propane is provided in Appendix E of the GMRP - Emergency Management and Response Plan. Version 2.1 2-2 March 2021
Spill Contingency Plan 2.2.4 Reagents The following reagents are currently used to treat water at the ETP: • Ferric Sulphate (found in liquid form on-site) is used to co-precipitate arsenic and is stored in three tanks; one outside the ETP building; and two inside. The main tank receives deliveries via tanker truck while the inside tanks are used as storage tanks when the outside tank is full (See Appendix D-4 for the associated incident response plan). • Hydrated lime, a white powder, is added to the water to raise the pH, reducing reaction time. Lime is stored in a single silo within the ETP building (See Appendix D-7 for the associated incident response plan). • Magnafloc or Vanfloc, in solid granular particles is added to the stream before the treated water is released into the Settling Pond to flocculate the solids into larger particles. The flocculant is stored in 25 kg bags in the ETP building and added to the holding tank as required for treatment operations. 2.2.5 Solvents Solvents such as Varsol are used to remove grease and oil from engine components and other machinery. Waste solvents are a contaminant under the Environmental Protection Act (EPA) of the NWT. Waste solvents are stored as per the product label instructions and the Hazmat Compatibility Chart. Solvents are kept in their original container wherever possible or in an approved waste solvent container. 2.2.6 Sewage and Greywater The lunchroom and administrative offices in the C-Dry building include restrooms and a kitchen area, which require the use of potable water. As described in the Water MMP, potable water is trucked to site to support domestic use. In addition to potable water use at the C-Dry, portable toilets are located at various locations around site during spring, summer and fall, in support of activities. The definitions of sewage and greywater, including additional details on how they are managed are provided in both the Waste and Water MMP. • Sewage is defined as all toilet wastes but does not include greywater. • Greywater is defined as all liquid wastes from showers, baths, sinks, kitchens, and domestic washing facilities but not including toilet wastes. Sewage and greywater will be managed differently on Site. Sewage from C-Dry is currently conveyed to the underground. A system will be installed to collect it for treatment off-site through the City of Yellowknife’s sewage treatment plant. Sewage from portable toilets and trailers are collected for off-site treatment. Greywater is conveyed to the Site’s effluent treatment facilities through the underground mine pool. 2.2.7 Arsenic Impacted Wastes As described in the Waste MMP, heavily arsenic-impacted wastes currently stored in shipping containers will be removed and placed in a frozen zone during remediation (Chamber 15 or B1 pit). Older heavily arsenic-impacted wastes buried in the tailings will remain in place. Arsenic trioxide dust and any other hazardous waste items Version 2.1 2-3 March 2021
Spill Contingency Plan impacted with arsenic above the leachable standard, including arsenic impacted double bagged asbestos wastes, will be placed in Transportation of Dangerous Goods (TDG) approved containers and clearly labeled. These will be containerized according to TDG Regulations for eventual disposal underground for freezing in Chamber 15 or B1 Pit as per the CRP. Any spills of arsenic impacted wastes should follow procedures outlined in Appendix D-1. 2.2.8 Explosives As noted in the Borrow Materials and Explosives MMP, explosives will need to be properly managed before, during, and after blasting activities. All packaged explosives and accessories will be supplied by a licensed explosive contractor and transported to site. There will be no magazines for explosive storage on-site. The Drill and Blast Sub-contractor will arrange to have the explosives transported to site from an off-site explosive magazine. Any unused explosives will be returned to the supplier’s off-site magazine. Information about the type of explosives, handling and transporting is provided in the Borrow Materials and Explosives MMP. When handling, transporting or storing explosives, care will be taken to avoid spillage 2.2.9 Co-Polymers Co-polymers may be used for dust suppression on site roads and tailings to mitigate fugitive dust. While co-polymers are generally non-toxic, the SDS for specific co-polymers should be reviewed. Any uncontrolled release of a co-polymer should be dealt with immediately and care should be taken to limit the spread. The SDS for the co-polymer should be reviewed for PPE requirements and other recommendations while utilizing the product or when responding to a release. 2.2.10 Chemical (Dynalene HC, Carbon Dioxide (CO2) and Nitrogen) The Freeze Optimization Study (FOS) cooling plant was constructed just west of the C-Dry between 2009 and 2011. The purpose of the FOS project was to explore options regarding the freezing of the arsenic trioxide in place underground. To date, freezing has taken place in the #10 chamber in the AR2 East area of the site and involves Dynalene HC, nitrogen, CO2 charged thermosyphons. The FOS will be decommissioned and disassembled in the short-term. Chemicals/products being used as part of the FOS are as follows: • Dynalene HC: A heat transfer fluid used in the active freeze holes • CO2: Used as a heat transfer agent in the thermosyphons • Nitrogen: FOS is charged with N2 to prevent rusting of its components Version 2.1 2-4 March 2021
Spill Contingency Plan 3 SPILLS MANAGEMENT 3.1 Roles and Responsibilities The emergency response organization structure for the Site is based on the Incident Command System (ICS). The ICS is a comprehensive, practical emergency management system used for effectively organizing and using the resources available for any type or size of operation. Common terminology has been developed to identify major functions, personnel, and responsibilities. The ICS outlines a series of supervisory levels available for implementation. The assignment of these responsibilities is based on the nature of the incident and the scale and complexity of response activities required. The ICS includes the Incident Command Team (ICT). The ICT chain of command is not the same as the chain of command for regular working activities. The ICT chain of command only applies in the case of an incident or emergency. The ICT made up of the Incident Commander, First Responder, Deputy Incident Commander and the Emergency Management Team (EMT). The ICT is the first line of defense in case of an incident or emergency occurring on the Project. It consists of on- site employees and works out of the incident command center, located in C-Dry. From this location, the ICT can manage on-site duties related to the incident as well as the overall incident and initial communication, sheltering, or evacuation activities. The EMT is responsible for the continued Site response and follow-up actions. The EMT may work out of the emergency operations center located in C-Dry but based on the incident type and location, the EMT may operate from remote locations off-site. The emergency operations center is the blanket term applied to the Site and off-site members of the project team. Both teams can be modified by those in charge (that is, the Incident Commander and Emergency Manager) to effectively manage any incident by adding to, deleting from, or combining positions as the needs of the incident change. However, both the Incident Commander and Emergency Manager should clearly identify the parameters of an assignment when deviating from the standard ICS assignments. Personnel on the ICT and the EMT are responsible for accomplishing assigned duties relating to incidents and for the safety and health of the support personnel reporting to them in an emergency. The Incident Commander should maintain a constant awareness of the position and function of emergency response personnel during an incident. This awareness is the basic means of accountability required to ensure incident response safety. In an emergency, the Main Construction Manager (MCM) is responsible for activating the sequence of the MCM Emergency Response Communications Flowchart (Appendix F). As indicated in the flowchart upon discovery of an emergency the incident commander should be contacted immediately. Individuals named in the Emergency Response Communications Flowchart (Appendix F) are responsible for designating a suitably trained replacement to assume their role in the plan before a planned extended absence from the workplace. Version 2.1 3-1 March 2021
Spill Contingency Plan 3.1.1 First Responder 1. As soon as the spill release is noticed, if applicable, stop work. Ensure that all personnel/bystanders are out of harm’s way and that the cause of the spill has been identified and isolated before initiating spill response. 2. Assess the hazard, including an initial estimate of quantity if possible. Safety and protection of human health take precedence over environmental protection. If there is a threat to personnel safety, evacuate the area immediately to the location determined by the Incident Commander. In the event of a propane or arsenic release, go immediately to Step 4. When assessing the hazards, one should refer to any applicable SDS and must have the applicable personal protective equipment (PPE) available. The first responder should also take note of the nearest windsock on-site or radio the Incident Commander or site security for the wind direction. There are currently two windsocks; one is located at the Propane Tank and the second is located adjacent to the C-Dry. 3. Stop, contain, or minimize the effects of the spill, provided it is safe to do so. Turn off any valves, pumps, vacuums, or other delivery equipment if possible and applicable. 4. Report the spill to the Mine Manager (or designate) to initiate the response. If possible, identify the spilled product, including the amount spilled and the extent of release. 3.1.2 Mine Manager and/or Incident Commander (or designate) In the event of a Spill, the Mine Manager must immediately contact: • The Environmental Manager (by phone or by radio), or their designate, and advise them of the nature and status of the spill. • The Health and Safety Manager (by phone or by radio), or their designate, and advise them of the nature and status of the spill. • The Surface Care and Maintenance Manager (by phone or by radio) who will in turn notify site personnel working on surface. • The Underground Supervisor (by phone or by radio), who will in turn notify site personnel working underground (e.g., using stench gas which is manually dropped at the B vent). • The Inspector, Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC), Public Services and Procurement Canada (PSPC), and the MCM contacts as outlined in the Emergency Response Communications Flowchart (Appendix F). The Incident Commander, who in most cases will be the Mine Manager, will then coordinate the following on-scene response: • Assesses the requirements for staff resources, equipment, materials and tools to contain the spilled material. In conjunction with the Deputy Incident Commander (or Security if the Deputy Incident Commander is not reached by the First Responder), arrange for necessary equipment to be brought to the spill location. Version 2.1 3-2 March 2021
Spill Contingency Plan • Develops the overall plan of action for containment and clean-up of the spill and designates the Emergency Management Team, including the Incident Response Team Leader who will be responsible for implementing the plan. • Ensures that assigned responsibilities are carried out and that proper coordination exists between supervisors and other individuals responding to the spill. • Maintains constant communication with the Environmental Manager or their designate with respect to all aspects of the cleanup. 3.1.3 Emergency Management Team The Emergency Management Team facilitates a coordinated response and recovery process by management and staff to any incident or set of circumstances that has the potential to significantly damage the organization and its employees, operations, financial condition, or reputation. Its function is to assess both the short- and long-term impacts. This team’s areas of responsibilities and contact information are found in the GMRP – Emergency Management and Response Plan, and include: • support the ICT and Incident Commander • manage potential impacts, and consequences of the incident • notify and provide ongoing communication as required 3.1.4 Environmental Manager (or their designate) For all reportable spill quantities (Appendix B): Reports the spill immediately by using the NU-NT Spill Report Form by one of the following methods: i. Northwest Territories 24-hour spill line Telephone: (867) 920-8130 ii. Northwest Territories 24-hour spill line Fax: (867) 873-6924 iii. Northwest Territories 24-hour spill line E-mail: spills@gov.nt.ca iv. Online: Spill Reporting and Tracking Database Within 24 hours, notifies the Board and an Inspector; and within 30 days of initially reporting the incident, submit a detailed report to the Board and an Inspector, including descriptions of causes, response actions, and any changes to procedures to prevent similar occurrences in the future. Written notification shall be provided to the Board and an Inspector if any changes occur. • CIRNAC Inspector Telephone: (867) 669-2442 • CIRNAC Inspector E-mail: Tim.Morton@canada.ca • Mackenzie Valley Land and Water Board (MVLWB) Telephone: (867) 766-7465 • MVLWB Email: sallerston@mvlwb.com Version 2.1 3-3 March 2021
Spill Contingency Plan The Environmental Manager, who in most cases will be the Incident Response Team Leader for secondary spill response, will then coordinate the clean-up. The Environmental Manager is also responsible for the following: • Provides technical advice on anticipated environmental impacts of the spill. • Estimates the effectiveness of various containment, recovery, and disposal options, suggesting the most appropriate approach. Works with the Incident Commander or their designate to determine the plan of action for remediation and cleanup of the spill. • Directs the collection and analysis of water samples to identify and monitor possible contaminant levels is carried out. • Directs a program of sampling natural water courses deemed as directly or potentially impacted by the spill, as well as upstream and downstream of the spill site, is carried out. The program should be designed to assess the potential for damage to the natural environment as a result of the incident. Initial samples should be taken as soon as possible after the spill has occurred, followed by repeated sampling at regular intervals during the subsequent clean up and restoration activities. Sampling time intervals will be determined on a case by case basis and should be developed in consultation with the appropriate regulatory officials whenever possible. • Directs the collection and analysis of soil/sediment samples to identify and monitor possible contaminant levels is carried out. The sampling program will be determined on a case by case basis as necessary and will likely include grid sampling of the affected area. Samples will be submitted to a CALA certified lab for analysis. • Directs air quality monitoring to be conducted if necessary, to adequately protect the health and safety of the responders. • Follows-up at the spill site after the initial response to monitor the effectiveness of the cleanup operation and recommends further remediation work, if necessary. • Follows-up and maintains close communication with the Inspector until the spill-reporting activities are closed. • Gathers relevant information and submits a detailed spill report to the applicable regulatory agencies, within the timeframe determined by the regulatory agencies. • In conjunction with the Health and Safety Manager, ensures that personnel that may be expected to respond to a spill receive adequate training in responding of the various types of spills that may be anticipated throughout the Project (see Section 1.8). 3.1.5 Technical Specialists Technical specialists may be members of either the Incident Response Team or Emergency Management Team, depending on their location (on-site or off-site) and level within the corporation. The roles and location of the different team members are outlined in the GMRP – Emergency Management and Response Plan. Version 2.1 3-4 March 2021
Spill Contingency Plan 3.2 Spill Resources 3.2.1 Access to the Plan The Spill Contingency Plan is posted in the C-Dry Lobby where all site personnel can reference it as needed. Additional copies of the Plan can also be found at this location. The Spill Contingency Plan is also available in the C-Dry second floor conference room, both the Mine Manager and Environmental Manager have copies, and a copy is provided to all subcontractors. Incident Action Plans (Appendix D) are posted at all storage areas (e.g., the ETP, Gatehouse, C-Dry, Machine Shop, Electrical Shop, and Carpenter Shop). More specifically, the incident action plans for Ferric Sulphate (Appendix D-4), Lime (Appendix D-7), Minewater (Appendix D-8) and Tailings spills (Appendix D-8 and D-10) are available at the ETP. 3.2.2 On-Site Communication The Emergency Response Communications Flowchart found in Appendix F as well as in the GMRP – Emergency Management and Response Plan, contains MCM and other key Stakeholders (regulators, authorities, etc.) landline and 24/7 cell phone numbers in case of emergencies. The Security Officers also have site wide radio communication. The locations of the Emergency Response Communication Flowchart are described in Appendix G. The protocols for the use of radios during emergency response is outlined within the GMRP - Project Safety, Health, and Environment Plan (PSHEP). 3.2.3 Spill Kits and Personal Protective Equipment Both Universal and Oil kits are present on site. The kits are contained in polypropylene over pack with threaded lids, snap clip lids or spring top lid barrels. These containers meet the TDGR for salvage drums suitable for use as shipping containers. Contents of spill kits may vary from place-to-place depending on the type of spill that is anticipated. 3.2.4 Spill Kit Contents Universal spill kits are equipped with the following supplies: • Nitrile/Sol-vex gloves • safety goggles • disposable coveralls • universal absorbent pads • universal absorbent pillows • universal absorbent socks • universal booms • portable (insta) berms • disposable plastic bags • tie straps • caution tape Version 2.1 3-5 March 2021
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