Great Bear Gold Project - IAAC application - Comments on Initial Project Description (IPD)

Great Bear Gold Project – IAAC application – Comments on Initial Project Description (IPD)

Submitted by Catherine Doucet – September 18, 2023

Impact of a flood or wildfire on the mine operations: Overview

Emergency preparedness and response

Accidental events/malfunctions

Potential for climate change related issues in this boreal forest region where the mine is proposed, particularly recent wildfires

Flooding events, specifically at a nearby dam

This application of submitting comments on the Initial Project Description of a Designated Project (IPD) for the Great Bear Gold Project is based primarily on the potential impacts of this project related to emergency preparedness and response and potential resulting malfunctions, both through error or lack of detailed plans. The focus is primarily on these impacts resulting from the increasing risk of climate change.

All potential scenarios should be accounted for including recent boreal forest wildfires and flooding, specifically at the nearby dam. Any dangerous materials that are stored at the mining site could result in perilous results in the event of either wildfires or flooding events.

The Pipeline corridor providing Enbridge natural gas that will be used for this project runs parallel to the project. The increased risk from wildfires must be considered in relation to this natural gas source.

Wildfire risk management plans should be part of the emergency preparedness and response but have not been found in the IPD.

There does not appear to be a section in the IPD on emergency preparedness and response, mitigation strategies and the taking into account of any residual risk as a result of these.

Under the Operations Phase information in the IPD document it seems that this generalized sentence, Development and implementation of environmental protection and monitoring plan(s) for operation  does not provide adequate or detailed information on the plan(s), leaving the impression that they are not yet formulated.

A complete climate change risk assessment should be completed before project approval.

It is not clear what the extent of the plans will be, or what part of the mining operation they include. One must assume that all aspects of the mining project would be included in the yet to be determined  plan(s).

There are a few comments/questions pertaining to the Operation Phase of the IPD document. Bolded text are my comments. Italicized text is derived from IPD document

There is no mention of the potential environmental issues with cyanide.

­ Tailings resulting from the processing of ore will be stored in a surface tailings management facility or used as backfill underground

The comments presented in the IPD do not include concerns about the planned mining process itself. The gold extraction process itself is not indicated/should be indicated.

Although the semi-produced gold doré bars are being exported out, the production of these bars at the Great Bear site would likely include a cyanide process.

-Sized ore will be processed to recover the gold in a processing facility, and produce gold doré bars that will be periodically shipped off site for sale

Based on the description of the capacity of this mine, 15,000 tpd or less, the amount of cyanide can and should be predicted.

-Tailings resulting from the processing of ore will be stored in a surface tailings management facility or used as backfill underground

-Ongoing management of chemicals and wastes, including remediation of incidental spillage if any

­ -As operations continue the underground mines will become progressively deeper and wider below the ground surface

­ -As operations continue the open pit will have a progressively larger surface area and will become deeper

As both the underground mines and the open pit become progressively deeper and wider what will be the amount of cyanide needed?

­ -Ongoing management and treatment of mine water and contact waters for discharge of excess waters that meet regulatory requirements

How will this affect the effluent discharge amounts?

­- Follow up environmental studies

What components will these studies include?