ERA Questions & Teck Responses re: Teck 2019 IPA Adjustment

ERA recently asked Teck the following questions regarding their 2019 Implementation Plan Adjustment (IPA) to the Elk Valley Water Quality Plan (EVWQP). Teck's responses are posted in blue

Please click below to read questions and responses.

  1. We appreciate the clarification that the IPA is not requesting an increase in Se limits, it is requesting an increased length of time. Is the new timeline 38 years? 

     The Implementation Plan Adjustment (IPA) does not request lower targets, but it does result in increased time required to achieve those targets at some locations. The main reasons for this are two-fold:

    o    Shift in timing of treatment - The IPA incorporates the time that was required to develop a solution to the generation of different selenium species at the West Line Creek Active Water Treatment Facility (WLC AWTF). Teck worked through this as quickly as possible, only taking a little over one year to research and pilot a solution, build it at a full scale and connect it to the WLC AWTF. This solution is now operational at WLC AWTF which is treating water at ~7,000 m3/d and continuing to ramp-up to its full design capacity of 7,500 m3/d.

    This shift in the WLC AWTF schedule resulted in a cascading shift to the timing of the next two AWTFs (at Fording River Operations and at Elkview Operations). The remaining treatment facilities are spaced two years apart, consistent with the EVWQP.

    o    Modeled increase in constituent loading (selenium, nitrate and sulphate) due to an updated understanding of release rates and planning for Teck permitted mine plans. The estimated treatment required in the EVWQP (totaling 130,000 m3/d), to meet compliance limits and SPOs, was based on the assumption that all of the waste rock placed up to that point in time was contributing to loadings measured downstream. This assumption was updated for the 2017 Regional Water Quality Model (RWQM) update based on an improved understanding of the lag between the timing of placement of waste rock and the load arrival at the toe of the spoils. Furthermore, the EVWQP treatment plan was developed up to 2037 and the 2019 IPA planning period was inclusive of all permitted mine plans and extends out further in time.    

    • In addition to this, coupled with the successful Saturated Rock Fill (SRF) full scale (10,000m3/d) trial at Elkview Operations and in parallel to implementing the IPA, Teck is advancing the application of SRFs which can be implemented more quickly than tank-based water treatment facilities and can, therefore, have a meaningful positive impact on water quality sooner. This is consistent with Teck’s adaptive management approach of advancing research and development of alternative technologies and using these developed technologies to improve water quality.

  2. Lake Koocanusa monitoring report also says that whole body, muscle and ovary tissue from several fish species have selenium concentrations above BC tissue guidelines – thus illustrating the problem once Se enters a lake or reservoir system.  Have there been any changes in water or fish tissue concentrations since those reported in the 2014-2016 report?

    Teck is committed to continued investigation of selenium in fish species, with ongoing work for Redside shiner and new studies for Northern pikeminnow. This work is focused on understanding selenium toxicity effects benchmarks for these species as monitoring data indicates only they have elevated concentrations of selenium in their ovaries. Based on current science and understanding, we do not know whether these elevated concentrations of selenium are having an effect at an individual or population level. 


  3. How will Teck respond if effects on fish in Koocanusa are observed? 

    We are in active discussions with governments in Canada and the US about how best to monitor fish health throughout the Koocanusa Reservoir and continue to advance the implementation of the Elk Valley Water Quality Plan to reduce concentrations of selenium in the watershed.

  4. Please elaborate on why most treatment plants have been delayed. We know there have been unexpected challenges, especially with Line Creek; and at the same time, this is a concern that has been raised multiple times by community members. By 2031, how many AWTFs are projected to be operational?

    • As noted above, we had some challenges that we faced with the West Line Creek Active Treatment Facility in 2017. We learned that the facility was converting a portion of the residual selenium to a more bioavailable form that was being released to the environment.

    • We took the plant offline while we developed an advanced oxidation process (AOP) to convert the residual selenium back to the original, less bioavailable form, and restarted the plant with the AOP in October 2018. We learned a lot through the process, which we will take forward into the design of our future facilities.

    • The WLC-AWTF is currently operating at ~7,000 m3/d and continuing to be ramped-up to its full design capacity of 7,500 m3/d. Construction on the second facility at Fording River Operations is well underway and expected to be completed in 2020. A third facility is planned for Elkview Operations – we are currently working through discussions with provincial regulators and Ktunaxa Nation Council on a mechanism by which we could proceed with a Saturated Rock Fill Facility for this third water treatment facility – this will enable earlier treatment of water. We expect that this process will result in a decision in the first half of 2019. 

    • Under the current plan, by 2031 there will be a water treatment facility operating at each of our operations, excluding the Coal Mountain Operation, and two operating at the Fording River Operation (for a total of five facilities). Additional water treatment capacity at the Line Creek, Elkview and Fording River operations is also planned through second phases to the established water treatment facilities or separate water treatment facilities at these operations before 2031.

  5. We realize there is a lag time in Se reductions and know Teck has invested a lot both in terms of developing treatment facilities and in new technologies (including the SRFs which we are extremely hopeful about). However, we are wondering:
    • When does Teck expect to see a reduction in Se and how is this lag time being incorporated into planning?
       
      • We are seeing a reduction in selenium immediately downstream of West Line Creek Active Water Treatment Facility and in the outflows from the Elkview Operation F2 Saturated Rock Fill Full-Scale Trial.  A regional decrease is expected when the Fording River South AWTF is fully operational

      • The greatest upcoming incremental reductions in selenium concentrations in the Elk Valley are associated with the operation of the Fording River Operation AWTF South and the increased treatment planned for the Elkview Operation. The Fording River Operation AWTF South will ramp up to full treatment capacity in 2021 and the Elkview Operation water treatment will ramp up in 2022, or earlier depending on the water treatment technology implemented at this operation.

    • What other selenium mitigation and management measures is Teck investigating and what stage have those investigations reached? 

      • We are conducting an extensive research and development (R&D) program with the goal of improving the technologies and practices available to manage water quality. Teck currently has more than 20 R&D projects underway related to water quality in the Elk Valley.

      • Through that program we have developed a new type of water treatment facility, called Saturated Rock Fill, which can help to achieve water quality objectives in the region more quickly and efficiently. Our first full-scale Saturated Rock Fill trial is successfully achieving near-complete removal of selenium and nitrate in up to 10 million litres of water per day. This new form of treatment has the potential to augment our suite of treatment options in the region, and is just one of the many projects underway to improve how we manage and protect water quality in the Elk Valley. For example, we are aggressively pursuing a second phase of this technology that would double the capacity to treat 20 million litres of water per day at the Elkview Operation.

    • Is Teck investigating covering some of the current dumps? 
       
      • Our R&D Program is working to establish whether covers improve chemistry and we are investigating alternate covers.

    • Are their passive treatment measures being investigated in addition to saturated fill?
       
      • Teck continues to advance over 20 R&D projects including investigating the use Gravel Bed Bioreactors. While not strictly passive, as all water treatment technologies including SRFs require operation, monitoring and maintenance, Gravel Bed Bioreactors are custom built, smaller scale, in-situ treatment cells that can be built near to where the treatment is needed.

    • Is Teck confident that water diversions will be able to handle freshet flows? 

      • Our planned diversions in the 2019 IPA will likely be piped diversions and will be designed to handle required flows. Because of the large difference between annual average and freshet flows (up to 15x in certain creeks) we have not (including in the EVWQP) considered designing diversions to be able to divert freshet flows.

    • Is Teck confident that all of the issues associated with active water treatment solved. 

      • As with the application of all new technologies we continue to learn and adjust. An important outcome of the challenges experienced with the West Line Creek Active Water Treatment Facility is that we have significantly improved our operational controls and monitoring to reduce the risk of future issues.

    • According to the model, at what point will Se concentrations begin to decrease?

      • Similar to the response provided to (a) above, Teck sees a reduction in selenium immediately downstream of Line Creek Active Water Treatment Facility and in the outflows of the Elkview Operation F2 Saturated Rock Fill Full-Scale Trial.  A regional decrease is expected when the Fording River South Active Water Treatment Facility is fully operational.

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