Ministry of Environment Mount Polley Sediment Sample Results Questions and Answers August 2014 Q. How do these results compare to other lakes/sediment/lands in the area? A. Currently, the focus is on the impacts to Quesnel Lake and Polley Lake. No other comparisons have been made at this time as each lake system is unique. Long-term monitoring and remediation will continue in the affected areas. Often areas where mines are located have elevated levels of metals, meaning naturally occurring metal concentrations could be much greater in this region than elsewhere in the province. Q. Is it safe to walk on the sediment or drink water from the tested areas? A. Currently, an order is in place to restrict access to Hazeltine Creek as a safety precaution due to the tailings blocking the outlets of Polley Lake into Hazeltine Creek. The sediment results were collected from sediments under water within the restricted access area. The public does not have access to this restricted area. Q. If certain levels of minerals are higher than normal, how do we know that won’t seep into the drinking water? A. Interior Health is the responsible organization for drinking water. However, science tells us that the metals are not likely to readily move from the sediment into the water, and are therefore not likely to present a risk to future water quality. Leachability tests, to be conducted in the next few days, should confirm this. Q. What will the impact be on wildlife (including deer/bears/fish that may ingest, swim in or walk on the sediment)? A. The focus currently is on human health, and that will soon be shifting to wildlife. The company is required under the Pollution Abatement Order to submit a comprehensive Environmental Impact Assessment and Action Plan which will include a fish and wildlife impact assessment and long-term monitoring program for the affected area. A submission was received by the ministry on August 15. The ministry is reviewing the information. Q. What is the effect of elevated copper and iron to fish? A. At this point it has not yet been determined if the copper detected in the sampling is in a form the will affect the various life stages of fish in the lake. Further analysis of the sediment samples, to be conducted as soon as possible, will provide further data to help answer this question. Iron and nickel levels appear to be naturally elevated and as such would not be expected to have negative effects on fish. 1 Ministry of Environment Mount Polley Sediment Sample Results Questions and Answers August 2014 Q. What actions are you taking to reduce the environmental impacts of the contaminated sediment? A. Imperial Metals has submitted an environmental impact assessment and action plan to the ministry. The company is required to report on the implementation of the action plan on a weekly basis. These actions will include monitoring and remediation of the site. Fall, Winter and Spring freshet impacts will also be addressed in the action plan. These reports received from Imperial Metals will be shared on the ministry website after they have been reviewed by ministry staff. Q. Have you ever tested sediment in the exact area before? How do you know what to compare these samples to? A. The ministry does not have any baseline sediment data prior to August 4, 2014 for Quesnel Lake. Samples have been taken from Quesnel Lake in areas that were not impacted by the tailings spill and results will be compared to the impacted area once the data is received. The ministry is aware of data that has been collected by UNBC researchers for samples taken prior to August 4, 2014. The ministry is working collaboratively with the UNBC researchers. All this said, the sediment results are not unexpected, particularly based on the geology of the area and with the mine close by. Q. How can we be so confident since the samples exceed standards and there is no baseline to work from? A. Comparing the recently collected samples to sediment samples taken from areas not impacted by the tailings dam breach helps us to understand the natural background levels of these metals. Q. Are these results what you expected based on what you were told was in the tailings pond? A. Yes, the samples are consistent with the characteristics of the material which was in the tailing pond prior to the breach. Q. Explain specifically why each of the sediment levels that is above normal is not concerning to you. A. These results do concern us. However, the geology in this general area is naturally enriched in metals and this is why there are active mine sites in the region. Therefore, we expect the naturally occurring metal concentrations for some metals to be much greater in this region than elsewhere in the province. Samples exceeding CSR standards points to potential for impacts on the environment. Impacts that we will work quickly to better understand and manage. 2 Ministry of Environment Mount Polley Sediment Sample Results Questions and Answers August 2014 Q. What is the ministry doing in response to these results? A. The ministry will continue to sample sediment to better understand the extent of the contamination. Q. Is this now a contaminated site? A. The ministry has received the results for three samples; two of those samples have copper results which are in excess of the Contaminated Sites sensitive sediment quality standard. Additional sample collection and assessment is needed before this determination can be made. Q. What can be done to rehabilitate the area? A. The responsibility for rehabilitation rests with the company. The company is required under the Pollution Abatement Order to fully recover or otherwise manage the tailings deposited into the environment. There are a variety of methods which could be used for stabilizing and rehabilitating the impacted areas of Hazeltine Creek. Examples include hydroseeding, installation of geotextile covers, planting of shrubs and channel reconfiguration. Q. Who has to pay for that? A. Mount Polley Mine Corporation is responsible to pay for all costs associated with the cleanup of the tailings breach. This is a requirement under the Environmental Management Act’s Spill Reporting Regulation. The polluter pay principle ensures those who are responsible for spills are also responsible for cleaning them up and is designed to keep the cost of response off of taxpayers. Q. If B.C. has a polluter pay model, what will you be asking the company for to get these areas back to their natural state or at least back to what you’d consider normal sediment levels? A. The company has now submitted its comprehensive environmental impact assessment and action plan as of yesterday (August 15). The ministry is reviewing it and our expectation is that it describes their proposed actions to recover or otherwise manage the materials that were spilled, as well as define the site mitigation that will be implemented. Long-term monitoring will determine the extent of the clean-up efforts. Q. Would this be done with their $15m bond that’s held by government? A. Government currently holds $14.5 million in financial security for the Mount Polley mine. These funds would be used for reclamation and closure of the mine site in the event that the company defaulted on its responsibilities. This bond is not for rehabilitation of the area impacted by the spill. 3 Ministry of Environment Mount Polley Sediment Sample Results Questions and Answers August 2014 Under the Environmental Management Act, the company is responsible for all costs associated with the spill. The Environmental Management Act contains spill response provisions built on the Polluter Pay Principle. The polluter pay principle ensures those who are responsible for spills are also responsible for cleaning them up and is designed to keep the cost of response off of taxpayers. The Spill Cost Recovery Regulation under the Environmental Management Act (EMA) outlines the process and parameters for recovering costs for responding to spills. http://www.env.gov.bc.ca/eemp/resources/spillcost.htm#3 Any individual or company responsible for a hazardous material spill must pay for all reasonable costs associated with clean up, including any costs incurred by the province (such as equipment, contractors, staff time, etc). A cost recovery certificate approved by the Minister is a debt due to the government and, is recoverable, by action in the Supreme Court. Q. How were the samples collected? A. A grab sampler – a set of jaws that retain sediment when lowered to the bottom of a lake or creek – was used. Samples were then sent to an independent lab for chemical analysis. Once the laboratory analysis was completed, the ministry compared the metal concentrations to British Columbia guidelines for sediments and Contaminated Sites Regulation standards. These standards are used to determine if sediment at a site is contaminated and if further actions, such as monitoring or clean-up, is required. Q. What is the fine white sandy looking material found on wood debris from Hazeltine Creek? A. Likely residents have reported observing a fine sandy like material on woody debris from Hazeltine Creek. One sample was provided by a resident to ministry staff, and the fine sandy material appears to be very fine tailings material. 4