Revised Final Environmental Study Report (24 MB) - Gold Canyon ...
Revised Final Environmental Study Report (24 MB) - Gold Canyon ... Revised Final Environmental Study Report (24 MB) - Gold Canyon ...
Page 32 1. With the exception of one sample at one sampling event that exceeded cadmium when concentrations were compared to PWQO, no heavy metals, or metals in general, exceeded PWQO values in Springpole Lake. Mercury exceedances were observed in three samples; one sample from Birch Lake and two samples taken during two different sampling periods in Seagrave Lake. Iron concentrations were found to be elevated at one sampling location in the unnamed pond located west of the project camp and at one sampling location located in Seagrave Lake. Evidence of heavy metals would be found routinely in Springpole Lake if drilling were indeed releasing heavy metals onto surface water. Drilling activities in Springpole Lake cannot affect an up-gradient Lake, as metal movement through a water system does not flow up-gradient. Birch Lake is located up-gradient from Springpole Lake. Given the size of Springpole Lake and the distance between the location of the drilling activities and the location where the sample with high mercury was collected, a gradient of mercury concentrations should be observed and not just one sample located a very long distance from the drilling activities. 2. Results for the toxicity testing at Springpole Lake are not required for the road corridor activities. The collection of water samples for toxicity testing was to gather a baseline result that can be then used as a benchmark for mine activities under the metal mining effluent regulations (MMER). It should also be noted that a pass/fail is the first step in environmental sciences to determine if water has potential for toxicity. Springpole Lake is considered a pristine Lake, and therefore it was expected that conditions at this lake are capable of supporting a healthy aquatic ecosystem. The aquatics report should be read in conjunction with the fisheries report that shows that Springpole Lake has a healthy population of fish, with walleye capable of living up to 18 years and reaching lengths of 58 cm. Toxicity testing for the purposes of industrial effluents or receiving waters need to follow methodology approved by Environment Canada (http://www.ec.gc.ca/faunescience-wildlifescience/default.asp?lang=En&n=0BB80E7B- 1). Moreover, the toxicity testing suggested by TFTO are used for testing of individual chemicals for human use or for human exposure. These studies are usually conducted by: 1) the study and observation of people during normal use of a substance or from accidental exposure, 2) experimentally, by exposing animals to specific compounds and 3) experimentally using cell cultures, that could be human, animal or plant derived. For fish and invertebrates there are no approved methodology that can be used to evaluate toxicity in their environment, unless there is a clear chemical of concern. The results of the water sampling at Springpole Lake shows that one sample in the whole lake had an exceedance in cadmium. For this element to be considered for further toxicity testing, cadmium concentrations should be demonstrate to be high in more than just on sample and at one time point. 3. As mentioned in the response for Page 32, Comment 2, the results of the limited toxicity testing will be used as a benchmark result to compare toxicity data collected once mining activities result in the production and release of effluent. Effluent as well as the receiving waters will be Gold Canyon Resources Inc. Response to TFTO Submission for Springpole Access Corridor Final ESR April 2013 Schedule 2/- 35-
assessed through toxicity testing as defined in the metal mining effluent regulations (MMER). Moreover, there is sufficient evidence in the fish studies showing that the fish living in Springpole Lake are healthy and that the lake is capable of supporting a healthy fish population. 4. It is not clear what TFTO means with this comment. The Aquatics Baseline Report shows the surface water and sediment quality, as well as the benthic invertebrate community composition. The baseline report pointed out exceedances in water quality that are above PWQO, and recommends further study of water quality to determine trends in chemical composition, that would point to specific characteristic of that body of water. Baseline studies usually gather multi-year information as one year may not reflect the normal chemistry of a body of water. The 2011 Aquatics report shows water characteristics in one year and therefore assumptions into water quality need to be considered carefully, understanding that to gain an in depth knowledge of water quality more data is needed. TFTO’s criticism of the methodologies is unwarranted. The methodology used for the collection of samples (water, sediment and benthics) are those approved by government agencies. The second cycle of surface water, sediment and benthics data has occurred, and preparations into the collection of a third cycle are underway. Taken together these three cycles of sampling will provided a much better overview of the water quality characteristics at Springpole Lake. 5. The Aquatics Baseline report does not deal with or intend to give any information pertaining to the ESR. Gold Canyon Resources Inc. Response to TFTO Submission for Springpole Access Corridor Final ESR April 2013 Schedule 2/- 36-
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- Page 361 and 362: GCU has hired qualified, independen
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- Page 373 and 374: Page 10 1. Detailed comments on the
- Page 375 and 376: Page 13 1. GCU is proposing to clea
- Page 377 and 378: Page 15 1. GCU is open to developin
- Page 379 and 380: Page 17 1. The economic information
- Page 381 and 382: Page 18 1. This is not a requiremen
- Page 383 and 384: (which were not intended to describ
- Page 385 and 386: Page 21 1. Note that the OLT develo
- Page 387 and 388: Page 22 1. The statement that carib
- Page 389 and 390: Page 24 1. General comment on 5.3.2
- Page 391 and 392: Page 26 1. The background database
- Page 393 and 394: Page 29 1. Comments on Table 3: The
- Page 395 and 396: Page 31 1. Water quality at Springp
- Page 397: 9. The aquatics baseline report doe
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- Page 403 and 404: Page 36 1. These recommendations ar
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- Page 407 and 408: Page 39 1. This means simply that G
- Page 409 and 410: Page 42 1. The recommendations from
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Page 32<br />
1. With the exception of one sample at one sampling event that exceeded cadmium when<br />
concentrations were compared to PWQO, no heavy metals, or metals in general, exceeded<br />
PWQO values in Springpole Lake. Mercury exceedances were observed in three samples; one<br />
sample from Birch Lake and two samples taken during two different sampling periods in<br />
Seagrave Lake. Iron concentrations were found to be elevated at one sampling location in the<br />
unnamed pond located west of the project camp and at one sampling location located in<br />
Seagrave Lake. Evidence of heavy metals would be found routinely in Springpole Lake if drilling<br />
were indeed releasing heavy metals onto surface water. Drilling activities in Springpole Lake<br />
cannot affect an up-gradient Lake, as metal movement through a water system does not flow<br />
up-gradient. Birch Lake is located up-gradient from Springpole Lake. Given the size of<br />
Springpole Lake and the distance between the location of the drilling activities and the location<br />
where the sample with high mercury was collected, a gradient of mercury concentrations should<br />
be observed and not just one sample located a very long distance from the drilling activities.<br />
2. Results for the toxicity testing at Springpole Lake are not required for the road corridor<br />
activities. The collection of water samples for toxicity testing was to gather a baseline result<br />
that can be then used as a benchmark for mine activities under the metal mining effluent<br />
regulations (MMER). It should also be noted that a pass/fail is the first step in environmental<br />
sciences to determine if water has potential for toxicity. Springpole Lake is considered a pristine<br />
Lake, and therefore it was expected that conditions at this lake are capable of supporting a<br />
healthy aquatic ecosystem. The aquatics report should be read in conjunction with the fisheries<br />
report that shows that Springpole Lake has a healthy population of fish, with walleye capable of<br />
living up to 18 years and reaching lengths of 58 cm. Toxicity testing for the purposes of<br />
industrial effluents or receiving waters need to follow methodology approved by Environment<br />
Canada (http://www.ec.gc.ca/faunescience-wildlifescience/default.asp?lang=En&n=0BB80E7B-<br />
1). Moreover, the toxicity testing suggested by TFTO are used for testing of individual chemicals<br />
for human use or for human exposure. These studies are usually conducted by: 1) the study and<br />
observation of people during normal use of a substance or from accidental exposure, 2)<br />
experimentally, by exposing animals to specific compounds and 3) experimentally using cell<br />
cultures, that could be human, animal or plant derived. For fish and invertebrates there are no<br />
approved methodology that can be used to evaluate toxicity in their environment, unless there<br />
is a clear chemical of concern. The results of the water sampling at Springpole Lake shows that<br />
one sample in the whole lake had an exceedance in cadmium. For this element to be considered<br />
for further toxicity testing, cadmium concentrations should be demonstrate to be high in more<br />
than just on sample and at one time point.<br />
3. As mentioned in the response for Page 32, Comment 2, the results of the limited toxicity testing<br />
will be used as a benchmark result to compare toxicity data collected once mining activities<br />
result in the production and release of effluent. Effluent as well as the receiving waters will be<br />
<strong>Gold</strong> <strong>Canyon</strong> Resources Inc.<br />
Response to TFTO Submission for Springpole Access Corridor <strong>Final</strong> ESR<br />
April 2013 Schedule 2/- 35-