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Document ID ca-bc-tg1emaatreiatar-2014-12 Title Technical Guidance 1 Environmental Management Act Applications TERMS OF REFERENCE Environmental Impact Assessment And Technical Assessment Report URL unknown Jurisdiction /ca/bc Subdomain(s) Wastewater, Industrial water, Mining Language en Status completed Analyzed at 2026-03-15 09:46:44.851976+00:00 Relevance Guidance for effluent discharge permit applications and technical assessments.

Q Qualitative Requirements (50)

Req ID Category Intent Legal Status Name Subdomain(s) Context Conditions Confidence
#Q001administrativereportingmandatoryQualified Professional Sign-off Statementwastewater, otherEach qualified professional signing-off on components of the TAR or EIA is to provide a signed statement, specifying the sections they are responsible for and confirming that all of that respective information required has been provided and that it is true and complete based on their professional knowledge and judgment.When signing-off on components of the TAR or EIA.high
#Q002reportingreportingrecommendedInclusion of Signed Statementswastewater, otherSigned statements should be included as an Appendix in the application and should contain professional association affiliation and membership number.When submitting the application.high
#Q003administrativereportingmandatorySubmission of Application Form and FeeswastewaterIn addition to providing technical information to address these TOR, the proponent must submit an application form for authorization to discharge effluent under EMA and ensure application fees are included.When applying for authorization to discharge effluent.high
#Q004administrativereportingmandatorySubmission of Table of Concordance ChecklistwastewaterTo expedite review of EMA effluent discharge permit applications for new or significantly expanded mines, proponents must submit a completed checklist per Technical Guidance 2 - Table of Concordance as part of the application package to the EPD.When applying for new or significantly expanded mines.high
#Q005monitoringreportingmandatoryBaseline Information Collection Programwastewater, aquatic life, drinking water, agricultural waterA baseline program must collect and assess sufficient physical, chemical and biological information to: describe meteorological and climatic conditions; describe geology, geochemistry and topography; characterize surface water hydrology and groundwater hydrogeology; establish a water balance for the drainage area; document surface and groundwater uses within and downstream of the project area; determine surface water, groundwater and sediment quality prior to disturbance; and describe aquatic ecosystem attributes such as fish and fish habitat, tissue residues, and periphyton and benthic invertebrate communities.Prior to project disturbance or permit application.high
#Q006reportingreportingmandatoryDetailed Description of Baseline MethodologieswastewaterThe application must describe in detail: sampling methods, sample preparation and hold times, analytical methods, analytical detection limits, quality assurance/quality control procedures, data analysis methods, and any assumptions.Within the application baseline summary.high
#Q007reportingoperationalmandatoryDistribution of Draft Baseline-Monitoring ProgramwastewaterIt is essential that a draft of the mine baseline-monitoring program be distributed to the Mine Review Committee (MRC) and the Mine Development Review Committee (MDRC) early in the review process to ensure that the program will meet permitting requirements.Early in the review process.high
#Q008reportingreportingrecommendedProvision of Raw Datawastewater, otherRaw data should be included in appendices, provided on CD, DVD or USB memory stick with the application, and if applicable, uploaded for storage in the Ministry of Environment's EMS (Environmental Monitoring System) database.When submitting the application.high
#Q009monitoringreportingmandatoryCharacterization of Metal Leaching/Acid Rock Drainagewastewater, otherThe geochemistry of all geologic materials to be disturbed or created during mining must be characterized.For materials to be investigated for metal leaching and acid rock drainage potential.high
#Q010reportingreportingrecommendedRemoval of High Turbidity Samplesdrinking water, agricultural water, otherSamples with turbidity values greater than 200 NTU should be removed from the data set prior to analysis;When analyzing groundwater chemistry data.high
#Q011administrativeoperationalmandatoryFisheries Scientific Collection Permitsaquatic lifeProponents must contact regional FLNRO fisheries staff for scientific collection permits and ensure study methods are consistent with regional and provincial protocols.When studying resident fish populations and habitat.high
#Q012reportingreportingmandatoryWaste Treatment and Discharge Information RequirementwastewaterDetailed waste treatment and discharge information must be included in the application for permits under EMA.When submitting an application for permits under EMA.high
#Q013designoperationalrecommendedSelection of Adequate Pollution Control WorkswastewaterENV expects applicants to select works, management practices and/or systems adequate to meet or exceed the statutory requirements and industry standards for preventing or minimizing adverse impacts to the environment and human health.When designing waste treatment and discharge systems.high
#Q014reportingreportingmandatoryAssessment of Residual Environmental Effectsaquatic life, drinking water, wastewaterThe applicant must assess potential residual environmental effects and evaluate the risks of the mine project on human health and water users including aquatic and terrestrial resources.During the preparation of the permit application.high
#Q015monitoringreportingmandatoryRequirement for Monitoring and Reporting Programswastewater, aquatic lifeApplications for EMA permits must include proposed monitoring and reporting programs which enable on- going evaluation of waste management performance, receiving environment condition, and evaluation of impact predictions made during the permit application.When applying for EMA permits.high
#Q016monitoringoperationalmandatoryAquatic Effects Monitoring Programwastewater, aquatic lifethe proponent must develop and implement an Aquatic Effects Monitoring Program (AEMP) to determine the effects of effluent discharges, seepages, and mining related disturbances, separately and cumulatively on the receiving environment.As part of compliance with the EMA permit.high
#Q017monitoringoperationalmandatoryQuality Assurance Protocols Detailwastewater, aquatic lifeThe monitoring programs must be developed by qualified professions and describe in detail the sampling methods, sample preparation and hold times, analytical methods, quality assurance/quality control procedures, and data analysis methods.When developing monitoring programs.high
#Q018monitoringoperationalmandatoryStandard Analytical Methods Requirementwastewater, aquatic lifeAnalyses must be performed using standard analytical methods, as specified in the most recent edition of the British Columbia Environmental Laboratory Manual and supplements to the manual.When performing sample analyses for monitoring.high
#Q019administrativeoperationalmandatoryMeeting for Water Quality Objectives Developmentwastewater, aquatic life, drinking waterIn instances where proponents believe that development of WQOs is technically justified, they must meet with ENV staff to discuss their appropriateness and to determine next steps.When considering the development of site-specific Water Quality Objectives.high
#Q020reportingreportingmandatoryEstablish Risk Likelihood and Consequence Criteriawastewater, otherThe proponent must a priori establish and describe likelihood and consequence criteria to assess risk.When conducting a risk assessment.high
#Q021monitoringoperationalmandatoryCompliance with Baseline Monitoring Guidancewastewater, aquatic lifeIt is essential that applicants also follow the Water and Air Baseline Monitoring Guidance Document for Mine Proponents and Operators.When conducting baseline monitoring for permit applications.high
#Q022reportingreportingmandatoryDemonstration of Meteorological UnderstandingwastewaterThe proponent is expected to demonstrate an understanding of how weather and climate will affect all aspects of the project.Within the EMA permit application.high
#Q023operationaloperationalmandatoryGeochemical Characterization Standardswastewater, otherCharacterization programs must be developed in accordance with: Policy for Metal Leaching and Acid Rock Drainage at British Columbia Mine Sites (1998); Guidelines for Metal Leaching and Acid Rock Drainage at Mine Sites in British Columbia (1998); and Prediction Manual for Drainage Chemistry from Sulphidic Geologic Materials, MEND Report 1.20.1 (December 2009).For all geologic materials to be disturbed or created during mining.high
#Q024reportingreportingmandatoryNaming of Certified Laboratories (Groundwater)drinking water, wastewater, agricultural waterApplications for an EMA permit must: ... name the certified laboratories used to analyze samples;Within the groundwater quality portion of the application.high
#Q025designtreatmentrecommendedInitial Dilution Zone Determinationwastewater, aquatic lifeDescribe in detail all locations of effluent and seepage discharge, and in each case, determine the appropriate initial dilution zone (IDZ) in surface waters.When describing locations of effluent and seepage discharge in an EMA permit application.high
#Q026designtreatmentrecommendedWastewater Treatment Plant Engineering DesignwastewaterProvide detailed engineering designs for any proposed treatment plants including electrical drawings and mechanical information, and document expected treatment effectiveness (based on pilot testing, industry examples, etc.) under variable conditions including flow, temperature, and hydraulic retention times, etc.For any proposed wastewater treatment plants in an EMA application.high
#Q027operationaloperationalrecommendedSafe Discharge Plan Proposalwastewater, aquatic life, drinking waterPropose safe discharge plans for all discharges to surface water or groundwater.As part of the environmental effects assessment for an EMA application.high
#Q028monitoringunknownrecommendedConceptual Ecological Model Developmentaquatic life, otherdevelop or refine conceptual ecological models or frameworks to define and illustrate all exposure pathways or mechanisms linking contaminants or conditions of potential concern to the assessment endpoints (receptors).During environmental effects prediction for EMA applications.high
#Q029reportingreportingrecommendedSite Contamination InventoryotherProvide an inventory of known or suspected site contamination and the potential for further soil or groundwater contamination on or near the site.As part of the Site Contamination section of an EMA permit application.high
#Q030reportingreportingrecommendedSurface Water Quality Baseline Study Requirementsdrinking water, wastewater, agricultural water, aquatic lifeApplications for an EMA permit should: identify downstream water uses (e.g., aquatic life, drinking, irrigation, livestock watering, industrial, etc.) and water licenses; document and describe the rationale for baseline study design including collection methods, parameters analyzed, field instrumentation, sampling frequency and period, site locations, statistical considerations and QA/QC protocols; name the certified laboratories used to analyze samples; provide a summary table listing sample site locations, sample dates, sample size and rationale /purpose of each site; identify which data reflect un-impacted baseline versus conditions affected by former development (e.g. exploration activities, historical mining activities); provide a detailed map showing water quality sampling locations, and proposed or existing discharge locations and areas of disturbance; describe water chemistry and summarize data in tables organized by parameter, site and date. Include detection limits and any QA/QC concerns related to the data; illustrate spatial and temporal variation in key parameters among sites using graphs that show variability in data (e.g., box plots); compare existing water quality conditions to provincial water quality guidelines and/or existing water quality objectives: tabulate and flag water quality values that exceed WQGs or WQOs, clearly document the frequency and magnitude of exceedances; identify critical parameters, locations and time windows or seasonality when baseline surface water quality may exceed water quality guidelines; conduct surface water toxicity tests if required. (This may be needed if WQGs are exceeded due to historic mining or site disturbance and should be discussed with ENV staff.); and identify spatial or temporal gaps in the database.When submitting the surface water quality baseline study in an EMA permit applicationhigh
#Q031reportingreportingrecommendedSediment Quality Baseline Study Requirementsaquatic life, otherApplications for an EMA permit should: document and describe the rationale for baseline study design including parameters analyzed, field instrumentation, sampling frequency and period, site locations, statistical considerations, collection methods and QA/QC protocols; name the certified laboratories used to analyze samples; provide a summary table listing sample site locations, sample dates, sample size and rationale/purpose of each site; identify, which data reflect un-impacted baseline versus conditions affected by former development (e.g. exploration activities, historical mining activities); provide a detailed map of sampling locations, and proposed or existing discharge locations and areas of disturbance; illustrate spatial and temporal variance in key parameters among sites using graphs; compare, tabulate and map existing sediment quality conditions relative to provincial sediment quality guidelines, or Canadian Council of Environment Ministers interim sediment quality guidelines (threshold or probable effect levels); and identify spatial or temporal gaps in the database.When submitting the sediment quality baseline study in an EMA permit applicationhigh
#Q032designoperationalmandatorySpecific Information Requirements for Storage and Effluent Dischargeswastewater, aquatic lifeProvide detailed designs of effective stormwater-drainage collection, conveyance and storage systems that can handle peak climatic and hydrologic events (supported by site hydrology and geotechnical information). Describe the location, quantity and quality (chemistry and toxicity) of contaminated waters and seepages. Describe the methods used to determine the quality and quantity of contaminated waters or seepage (i.e., baseline data including metal leaching and acid rock drainage potential, bench scale tests, pilot plant results, manufacturer's design specifications and performance guarantees, etc.). Describe the timing (i.e., seasonal, continuous, intermittent) of discharges to the environment. Discuss options for contaminant source control, containment or mitigation methods and describe how best management practices and best achievable technology have been applied. Include detailed designs of all proposed discharge works (e.g., outfalls, spillways, channels). Compare proposed discharge quality to known discharge criteria, guidelines or industry practices. This should include an evaluation of end of pipe water quality based effluent limits based on meeting water quality guidelines in the receiving environment during the most sensitive times of the year.Required components for storage and effluent discharge applicationshigh
#Q033operationaloperationalmandatoryWastewater Treatment Plant Operational and Safety DetailswastewaterDescribe and illustrate schematically the tracking of all inputs at each stage in the process through to output. Identify volumes and characteristics of by-product waste produced at each stage of the process (chemicals and reagents used; contaminants liberated or created, etc.). Describe long-term disposal plans for secondary waste/spent substrate that addresses long-term geochemical and physical stability and an assessment of whether the material is deemed hazardous waste, as well as reclamation and closure issues. Assess performance risks for collection and treatment of wastewater (i.e., extreme weather [icing, snow loading, flows, etc.], power outages, wearing of parts, scaling, reagent supply interruption, plugging, by-passing/short circuiting, etc.). Provide time schedule for construction and commissioning, capital and anticipated operating and maintenance costs. Describe operating requirements such as power, pumping, number of people to operate, volumes of materials and reagents, etc. Assess potential public health and safety risks and management plans. Describe maintenance and replacement plans for collection and treatment systems.Required for wastewater treatment plant permit applicationshigh
#Q034corrective_actionoperationalmandatoryEmergency Procedures and Contingency Planningwastewater, aquatic lifeDescribe emergency procedures for pollution control system malfunctions/upsets, and contingency plans (for example, contingency storage for water requiring treatment). Contingency plans for chemical and fuel storage areas should also be included.As part of the safe discharge plans within an EMA applicationhigh
#Q035reportingreportingmandatoryGroundwater Quality Baseline Information Requirementswastewater, drinking waterApplications for an EMA permit must: identify groundwater use downstream of the mine site; document and describe the rationale for baseline study design including parameters analyzed, collection methods, field instrumentation, sampling frequency and period, site locations, statistical considerations and QA/QC protocols; name the certified laboratories used to analyze samples; provide a summary table listing sample site locations, sample dates, sample size and rationale/purpose of each site; identify which data reflect un-impacted baseline versus conditions affected by former development (e.g. exploration activities, historical mining activities); provide a detailed map of groundwater quality sampling locations and proposed or existing discharge points, areas with seepage potential and areas of disturbance; describe groundwater chemistry and summarize data in tables organized by parameter, site and date. Include detection limits and any QA/QC concerns related to the data. Tabulate chemical data and flag values greater than provincial water quality guidelines (WQGs). Samples with turbidity values greater than 200 NTU should be removed from the data set prior to analysis; illustrate spatial and temporal variation in key parameters and among sites using graphs that illustrate data variability; identify critical parameters, locations and time windows or seasonality when baseline groundwater quality may exceed water quality guidelines; and identify spatial or temporal gaps in the database.During application for an EMA permit for groundwater baseline characterizationhigh
#Q036monitoringoperationalmandatoryBiological Monitoring Tool Identificationaquatic lifeAppropriate biological monitoring tools must be identified, and sufficient data must be collected and presented to demonstrate that the program will be able to detect a predetermined change considered to be biologically significant.When developing aquatic life baseline studieshigh
#Q037corrective_actionoperationalmandatorySite Decommissioning and Remedial PlanningotherPropose site decommissioning or planned site remedial activities including information required for the completion of a site profile as described in the Contaminated Sites Regulation.Within the site contamination section of an EMA applicationhigh
#Q038reportingreportingrecommendedCumulative Effects ConsiderationotherThe environmental effects assessment should also consider cumulative effects within the watershed.During environmental effects prediction for EMA applicationhigh
#Q039monitoringoperationalrecommendedContinuous Hydrometric Data Collectionwastewater, aquatic lifeestablish continuous hydrometric data collection for drainages potentially affected by effluent discharge, water diversions, or seepages from waste rock and/or tailings facilities;During baseline information collection for drainages potentially affected by the project.high
#Q040designoperationalrecommendedConceptual Hydrogeologic Model Developmentdrinking water, wastewaterdevelop a conceptual hydrogeologic model (considering seasonal variation) of the mine area with groundwater elevations, flow direction and rate estimates, recharge/discharge boundaries, groundwater divides and impermeable boundaries, and interaction with surface waters;During the groundwater study of the mine property for the Technical Assessment Report.high
#Q041operationalhealthmandatoryGroundwater Use Protectiondrinking water, wastewaterFor groundwater, ensure groundwater use downstream is not compromised and no chronic toxicity occurs in surface waters as surface water recharge occurs.As a component of the safe discharge plan for discharges to groundwater.high
#Q042reportingreportingmandatoryStatistical Power Reportingaquatic lifeProponents are responsible for reporting the a priori statistical power of their sampling plan to provide reviewers with an understanding of the program's strengths and weaknesses;When summarizing periphyton and benthic invertebrate community data in the Technical Assessment Report.high
#Q043monitoringreportingrecommendedGroundwater Baseline Sampling Frequencydrinking water, wastewaterFor groundwater, a minimum of four quarterly samples over one year is recommended before permit application.Before permit application for groundwater characterization.high
#Q044monitoringreportingmandatorySurface Water Baseline Sampling Frequencydrinking water, wastewater, aquatic life, agricultural waterFor surface water a minimum of monthly sampling for a period of one year is necessary, and more is preferred to assess trends and seasonal variation.Baseline study characterization before project development.high
#Q045monitoringreportingmandatoryGuideline Attainment Sampling Protocoldrinking water, wastewater, aquatic life, agricultural waterTo determine water quality guideline or objective attainment, 5 samples in 30 days during critical flows (high and/or low) or biologically relevant periods, are necessary.When determining water quality guideline or objective attainment.high
#Q046monitoringreportingmandatoryMulti-year Data for WQO/SBEB Preparationdrinking water, wastewater, aquatic life, agricultural waterTo assess interannual variation, or to prepare water quality objectives (WQOs) or science-based environmental benchmarks (SBEBs) 16 , multiple years of water quality data is required.When preparing site-specific objectives or benchmarks.high
#Q047monitoringreportingrecommendedSediment Sampling Frequencyaquatic lifeSediment sampling should occur at a minimum of once per year during summer low flow periods.During baseline information collection.high
#Q048administrativereportingmandatoryWater Quality Objective Application Prioritydrinking water, wastewater, aquatic life, agricultural waterWhere water quality objectives exist for a watershed, they are to be used in the place of water quality guidelines in an effects assessment.When water quality objectives exist for a watershed.high
#Q049prohibitiontreatmentrecommendedSBEB Pollution Restrictiondrinking water, wastewater, aquatic life, agricultural waterEstablishment of a SBEB should not result in a situation that causes pollution or increases pollution (if it is an already degraded site).When establishing science-based environmental benchmarks.high
#Q050prohibitionoperationalrecommendedSBEB Protocol 11 Constraintdrinking water, wastewater, aquatic life, agricultural waterFurthermore, a SBEB should not be considered if a threshold value is equivalent to or in excess of the levels set in Protocol 11 for Contaminated Sites which defines a high risk contaminated site 46 ;When considering science-based environmental benchmarks.high

P Quantitative Requirements (12)

Req ID Category Intent Legal Status Name Subdomain(s) Limit Type Limit Value Context Conditions Confidence
#P001operationaloperationalmandatorysampling frequencyotherrequirement5 samples / 30 daysTo determine water quality guideline or objective attainment, 5 samples in 30 days during critical flows (high and/or low) or biologically relevant periods, are necessary.During critical flows (high and/or low) or biologically relevant periodshigh
#P002physicaloperationalrecommendedturbidityotherOG> 200 NTUSamples with turbidity values greater than 200 NTU should be removed from the data set prior to analysisGroundwater chemistry data analysishigh
#P003designtreatmentguidelineInitial dilution zone (IDZ) distancewastewater, aquatic liferequirement<= 100 mInitial dilution zones are normally relatively small (e.g., for municipal effluents they are typically up to 100 m from the point of effluent discharge...)Municipal effluents IDZmedium
#P004designtreatmentguidelineInitial dilution zone (IDZ) widthwastewater, aquatic lifeMAC<= 50 %...but not exceeding 25 to 50% of the width of the waterbodyRelative to waterbody widthhigh
#P005operationalreportingrecommendedsewage dischargeswastewaterrequirement> 100 personsFor sewage discharges greater than 100 persons, or where discharge is to surface waters, registration under the Municipal Wastewater Regulation is desirable.Sewage discharges requiring potential Municipal Wastewater Regulation registrationhigh
#P006operationalreportingrecommendedSurface water hydrology baseline data durationotherrequirement>= 2 yearsA minimum of two years of data is recommended to characterize surface water hydrology.Baseline study for EMA applicationhigh
#P007operationalreportingrecommendedGroundwater hydrogeology baseline data durationotherrequirement>= 1 yearA minimum of one year of quarterly data is recommended to characterize groundwater hydrogeology.Baseline study for EMA applicationhigh
#P008operationalreportingrecommendedBaseline groundwater quality sampling frequencyotherrequirement>= 4 quarterly samples / yearFor groundwater, a minimum of four quarterly samples over one year is recommended before permit application.Groundwater water quality baseline studyhigh
#P009operationalreportingmandatoryBaseline surface water quality sampling frequencyotherrequirement>= 12 monthly samples / yearFor surface water a minimum of monthly sampling for a period of one year is necessary to assess trends and seasonal variation.Surface water quality baseline studyhigh
#P010operationalreportingrecommendedBaseline sediment quality sampling frequencyotherrequirement>= 1 time / yearSediment sampling should occur at a minimum of once per year during summer low flow periods.Sediment quality baseline studyhigh
#P011physicaloperationalrecommendedSediment analysis size fraction (fine)otherrequirement< 63 µmThere may be reason to analyze both the <63 µm and <2mm fraction in a baseline programBaseline sediment quality studyhigh
#P012physicaloperationalrecommendedSediment analysis size fraction (coarse)otherrequirement< 2 mmThere may be reason to analyze both the <63 µm and <2mm fraction in a baseline programBaseline sediment quality studyhigh

D Definitions (35)

Req ID Category Name Context Confidence
#D001AEMPAquatic Effects Monitoring Programhigh
#D002BACIBefore-After-Control-Impacthigh
#D003BATBest Achievable Technologyhigh
#D004CABINCanadian Aquatic Biomonitoring Networkhigh
#D005EIAEnvironmental Impact Assessmenthigh
#D006EMABC Environmental Management Acthigh
#D007ENVMinistry of Environmenthigh
#D008FLNROMinistry of Forests, Lands, and Natural Resource Operationshigh
#D009IDZInitial Dilution Zonehigh
#D010ML/ARDMetal Leaching/Acid Rock Drainagehigh
#D011QA/QCQuality Assurance/Quality Controlhigh
#D012SBEBScience-Based Environmental Benchmarkhigh
#D013WQGWater Quality Guidelineshigh
#D014WQOWater Quality Objectivehigh
#D015TARTechnical Assessment Reporthigh
#D016TORTerms of Referencehigh
#D017IDZThe IDZ is the initial portion of a larger mixing zone applied to a specific effluent discharge.high
#D018Residual effectsResidual effects are those effects remaining after implementation of all mitigation techniques evaluated and proposed in this application.high
#D019B.C. Water Quality Guidelines (WQGs)B.C. Water Quality Guidelines (WQGs) are science-based levels of substances (physical or biological) that are protective of given water uses such as aquatic life, drinking water, recreation, agriculture and industry.high
#D020Water quality objectives (WQOs)Water quality objectives (WQOs) are science-based tools that provide an effective basis for managing aquatic ecosystems and describe conditions that should be met to protect designated uses of freshwater, estuarine, and marine ecosystems.high
#D021SBEBAn SBEB is a quantifiable receiving environment parameter or attribute developed by qualified professionals through a rigorous scientific process with the intent to guide management decisions and mitigative actions for a regulated activity at a specific location.high
#D022EPDEnvironmental Protection Divisionhigh
#D023MAMines Acthigh
#D024MRCMine Review Committeehigh
#D025MDRCMine Development Review Committeehigh
#D026EMSEnvironmental Monitoring Systemhigh
#D027EEMEnvironmental Effects Monitoringhigh
#D028ROBRegional Operations Branchhigh
#D029ContextThe ability of the environment to accept change.high
#D030MagnitudeThe expected size or severity of the effect.high
#D031ExtentThe spatial scale over which the effect is expected.high
#D032DurationThe length of time the effect is expected to persist.high
#D033FrequencyHow often the residual effect occurs.high
#D034ReversibilityWhether an effect can be reversed once the physical work or activity causing the disturbance ceases.high
#D035Working water quality guidelinesThe Province has adopted working water quality guidelines for some of these substances to indicate safe levels in the environment.high