ERRATA NOTICE - Canadian Environmental … NOTICE Comments from Ministry of Northern Development and...

ERRATA NOTICE Comments from Ministry of Northern Development and Mines to Stillwater Canada Inc. on the Environmental Impact Statement October 30, 2012 – Please be advised that a correction is required to the document dated October 25, 2012 from the Ministry of Northern Development and Mines to Stillwater Canada Inc.(CEAR Doc 297). In the document, the section titled "Document 23 Economic and Social Impact Assessment, Comments for Consideration By: Jeff Dicaire, NDO. MNDM, Terrace Bay" contained an incorrect version. This section of the document has been updated and a new version of the entire document is attached.

Ministry of Northern Development Ministère du Développement du Nord et

and Mines Mineral Development and Lands Branch B002–435 James Street South Thunder Bay, ON P7E 6S7 Tel.: 807-475-1106 Fax: 807-475-1112

des Mines Direction de l’exploitation des minéraux et de la gestion des terrains miniers Bureau B002 – 435, rue James Sud Thunder Bay, ON P7E 6S7 Tél. : 807-475-1106 Téléc. : 807-475-1112

October 25, 2012 Tabatha LeBlanc Stillwater Canada Inc. 1100 Memorial Ave, Thunder Bay, Ontario P7B 4A3 Via email: Subject: MNDM Comments re Environmental Impact Statement – Marathon Project Further to the Director’s letter sent earlier to the attention of the Joint Review Panel, you will find attached the MNDM comments regarding the EIS submission for the Marathon Project. These comments relate to mine rehabilitation and closure planning, alternatives to address aboriginal concerns, and documentation of aboriginal engagement. Comments regarding land tenure and socio-economic impacts are outlined below. The descriptions of lands required for mine infrastructure are outlined in Section 1.4.2.2 of the EIS. For review purposes, it would be helpful to have the site infrastructure depicted in Figure 1.4-12 superimposed on a mineral tenure sketch as opposed to the dashed outline of the property boundary which includes various types of leases, proposed leases and staked claims. Please note that claim TB1205330, upon which access road infrastructure will be placed, does not have an associated lease request. It is also important to note that claims TB112787 and TB112788 are mining rights only despite the fact that the northwest portion of the MRSA and associated retention dams will occupy these lands. Having considered the definition of "environment" under the Ontario Environmental Assessment Act and the requirements outlined in the EIS Guidelines, it is felt that Stillwater has adequately documented the social and economic effects of the project on the local communities depicted in Figure 5.9-1. Nonetheless, it is advised that further documentation, alternatives and commitments are required in the following areas: updates re local labour pool as a consequence of other major employers, e.g. Aditya Birla

Group mill start up in Terrace Bay, re-evaluation of proposed Williams Mine Open Pit Expansion and the proposed Rentech Inc bio mass plant in White River

SCI participation in community adjustment committees, labour adjustment committees, both pre and post closure, employee training, labour planning, and transition programs

alternatives under consideration with regard to end use of accommodation facilities, i.e. 3 hotels and housing complex and impacts to existing hoteliers

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an accounting of the expected "leakage" of economic spin-offs due to the high proportion of employees that will not be permanent residents, i.e. the typical 3:1 ratio of indirect employment to direct employment will not be the case for this project

the community of Rossport should be identified and discussed in the EIS and the support documents

consideration of how the project compliments the Northern Growth Plan as well as community strategic economic development plans and Official Plans

It is anticipated that the members of the Joint Review Panel, aboriginal groups, stakeholders, and the public will be interested in this additional documentation during the hearings phase of the EA process. If you have any questions in this regard, do not hesitate to contact me. Sincerely,

Mark O’Brien Mineral Exploration and Development Consultant – Northwest Ontario mark.o’[email protected] c Alissa Sugar, MOE Mike Landers, MOE Joe Tyance, MOE Mike Grant, MNDM

Jeff Dicaire, MNDM Rob Purdon, MNDM Steve Reitzel, MNDM Brad Dragan, MNDM Heather Brown, MMAH Andreas Link, MNR Peggy Bluth, MNR

Joint Review Panel Secretariat Amy Liu, CEAA Candace Anderson, CEAA

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MNDM Comments on the EIS - Marathon PGM Copper Project

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MNDM Comments Regarding the Environmental Impact Statement for the Marathon PGM Copper Project Name page

Mark O'Brien, Mineral Exploration and Development Consultant-NW 2

Rob Purdon, Mine Rehabilitation Specialist 3

Steve Reitzel, Mine Project Engineer 8

Brad Dragan, Mine Rehabilitation Compliance Officer 12

Jeff Dicaire, Northern Development Officer 13

Scott Cousineau, Lands Technician 18


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MNDM General and Aboriginal Consultation Comments by Mark O’Brien, July 20, 2012 Codes: R=comment based upon Mining Act, i.e. regulatory requirement C=consideration should be given to comment based upon OWCP A=comment based upon aboriginal coordination perspective page is pdf page number in consolidated report EIS Main Report page section codes comment 37 Summary C 0.07% of additional disturbance to woodland caribou = non-

significant? 128 1.4.3.1 C Figure 1.4-12 depicts staked claims and leases, should depict expected

land tenure 211 3.3.2 C Depiction of MRSA alternatives, why was option 6 not presented

previously 225 4.4.3.1 A Benefits Agreement(s) without documentation of impacts has not been

the norm 226 4.4.3.1 A This is the first documentation of the March 30, 2012 MoU with

OPRFN 249 Appendix

4A-4E A Documentation consistent with MNDM records, except should be

Mark Bowler (not Mark Holden) on p 253 386 5.4.2.2.7 C Fault lines in Fig 5.4-3 – from OGS publication? 501 5.11-3 A This table illustrates potential impacts to Aboriginal and Treaty rights

for OPRFN 725 Fig 6.6-3 C Illustration of Marathon Project schedule related to other area projects 743 7.1.3 C Adaptive management approach is consistent with EnvCan code of

practice 747 Fig 7.2-2 R Outflow from Main Pit when flooding occurs indicates toward MRSA

– that could cause chemical/physical stability issues Draft Closure Plan page section codes comment 8 1.0 C “Should the project proceed to the regulatory phase…the Certified

Closure Plan will include: …” 27 Fig D C Figure D needs to depict site layout relative to leased parcels not staked

claims 50 3.6 C Categorizing Type 1 and Type 2 rock and process solids is a prudent

precautionary measure 8-85 1-13 R Section numbering not consistent with Schedule 2 of Reg 240/00 89 12.4 A MNO only AG not engaged re CCP 99 Table 5 C Most closure costs are consistent with current unit costs, see Steve Reitzel

comment re transfer of PAG material, Monitoring costs based upon 5 years, with pit flooding to take several decades (p63)?

101 Table 7 C Table 7-12, appear complete, just RSMIN and not RSIMN


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From: Purdon, Rob H. (MNDM) Sent: August 9, 2012 9:27 AM To: O'Brien, Mark (MNDM) Subject: Re: Comments on Marathon PMG EIS I don't think my comments are "show stoppers" per se, but the proponent and their consultants have some gaps that will need to be filled - if this evolves through the EA that is fine, but they should be made aware that they have more work to do - I know MOE has some concerns as well. Cheers! Rob

From: Purdon, Rob H. (MNDM) Sent: July 26, 2012 4:03 PM To: O'Brien, Mark (MNDM) Subject: Stillwater - Preliminary comments

Hi Mark, Attached please find 3 email with my preliminary comments. Some general observations: Their hydroG work did not sufficiently explore possible connections between groundwater impacts and surface water impacts. I spoke with Alisdair Brown at MOE and we share concerns regarding the information presented regarding the chemical loading of the PSMF on groundwater and surface water. The impacts to surface waters due to mine dewatering do not seem to consider low flow stream conditions – it is possible that some could go dry during winter or summer drought periods. I don’t think any of these are show stoppers from an EA perspective, but I am concerned regarding their Closure Plan – I am in agreement with and supportive of much of what they are proposing but there is not enough detail to meet the requirements of the Mining Act – we could move forward with the caveat that our concerns will be addressed. There was a LOT of info presented and I was unable to complete a comprehensive and thorough review of all the documents – I would gladly re-visit my comments if more information becomes available or a more detailed review is required. I will be on holidays for two weeks, returning in the AM of August 13 – can we circle back and have a discussion at that time? Cheers! Rob Purdon, M.Sc., P. Geo. Mine Rehabilitation Specialist Ministry of Northern Development and Mines 435 James Street South, Suite B002 Thunder Bay, ON P7E 6S7 807-475-1197 [email protected]

mailto:[email protected]�


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Baseline Water Quality Assessment 1. Section 2.2.4 Sulphate: 2.2.4 Sulphate Sulphate was analyzed in 935 samples from the study area, and was detected and quantified in all of those samples except 27 one or more from each watershed. Mean sulphate concentration ranged from 2.3 mg/L in the Pic River to 4.5 mg/L in the Shack Creek watershed. The maximum measured sulphate concentration ranged from 3.5 mg/L in the Pic River to 9.1 mg/L in the Stream 4 watershed. No PWQO, or any other benchmark, was available for comparison to these concentrations. CCME and other jurisdictions have sulphate benchmarks for protection of surface water quality (albeit these are primarily for agricultural use of surface waters). 2. Section 2.3.6 Chromium The samples taken from the Shack Creek, Stream 4, Stream 5, and Stream 6 watersheds had low chromium concentrations with chromium (III+VI) not detected in all but seven samples. Chromium was not detected in most of the samples from Malpa Lake or the Stream 1, 2, and 3 watersheds. In the Pic River, however, chromium was detected in most of the water samples. As might be expected from this pattern of non-detects, the mean measured total chromium (III+VI) concentration in each watershed is close to the detection limit in the Shack Creek and the Stream 4, 5, and 6 watersheds, higher in Malpa Lake, Stream 1, 2, and 3 watersheds, and higher still in the Pic River. As such, it is recommended that the summary statistics for chromium (III+VI) be used as upper bounds on baseline concentrations, rather than as baseline concentrations themselves. This appears contradictory – if chromium was NOT detected in most of the samples from Malpa Lake or Stream 1, 2 and 3 watersheds, it would be expected that the mean measured chromium in these watersheds would be lower, not higher. 3. It is not clear what is intended by setting “upper bounds” for the baseline conditions for many parameters. Is the implication that the “actual” baseline conditions should be lower than these “upper bounds”? If so, what process should be used to establish baseline conditions? Is more assessment required? How will establishing “upper bounds” assist with determination/assessment of impacts from the proposed mining activities? Draft Closure Plan review I have completed a preliminary review of the “Draft Conceptual Closure Plan – Marathon PGM – Cu Project” and have some concerns regarding compliance with the Part 7 of the Mine Rehabilitation Code of Ontario. This was a first pass through what is a very large and complex document and this email is not intended to provide a formal or final review of the closure plan. Specifically I note the following: 1. Section 3.6 Process Solids Management The ABA results for the type 1 and 2 process solids are summarized in Table 1. The type 2 solids (high sulphur process solids on Table 1) contained about 7% total sulphur and 6% sulphide sulphur and the NP/AP value was less than 1. The type 2 material, representing less than 10% of the total Bulk Process Solids, will be produced in the mill via the sulphur separation process. This produced material will be stored underwater either at the bottom of a pond, pit or below the water table in the process solids management facility, or both to prevent acid generation and metal leaching.


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2. Section 3.7.2.1: 3.7.2.1 Management of Type 2 Mine Rock (Sulphur Content above 0.3% S) The sulphur distribution in the Marathon Project ore has been intensively studied and is well characterized. The distribution of sulphide sulphur is not random but, rather, follows a recognizable pattern that will be positive for management of type 2 mine rock (mine rock with sulphur content above 0.3% S). Sulphur in the Marathon deposit is generally distributed between two dominant minerals; chalcopyrite (CuFeS2), the primary ore mineral for copper and pyrrhotite (Fe1-xS), a noneconomic iron sulphide mineral. The total sulphur content is predominately composed of a combination of chalcopyrite plus pyrrhotite. The distribution of these minerals as a percentage of the total sulphur, however, changes systematically with depth below ground surface. This is shown graphically in Figure N that shows the proportion of chalcopyrite representing the total sulphide content of the rock as a function of depth from ground surface. The total sulphur content of the rock is shown as a function of depth on the same scale for comparison. Together, these plots illustrate that chalcopyrite represents up to 100% of the sulphide sulphur at depths of about 50 m below ground surface while it represents less than 10% of the total sulphide sulphur at depths greater than 120 m. This means that at shallow depths, almost all sulphur occurs as the copper ore mineral with the expectation that this material represents ore that will report to the mill for the extraction of the sulphur for economic value. However, as depth increases, the proportion of sulphur that occurs as chalcopyrite decreases and that in pyrrhotite increases. Therefore, in general, there is less ore mineral content and more waste sulphide, as pyrrhotite, encountered with increasing depth. This trend also infers that higher sulphur contents in mine rock will be encountered at depth, later in the life of mine. This has important implications for managing mine rock with sulphur contents above the cut-off value of 0.3% S. The majority of the type 2 mine rock will be encountered in later stages near the bottom of the main pit. This means that the satellite pits can be mined out prior to encountering the type 2 mine rock in the main pit and will be available for back filling with type 2 rock for permanent storage underwater after the satellite pits have flooded at the end of operations. At the end of the mine operation, all mine rock with high sulphur contents will be stored in the satellite pits, the main pit or the PSMF and will be covered by water and isolated from the atmosphere to prevent oxidation and associated acid generation. Based on the information provided, it appears that a portion of the orebody is characterized by concentrations of the mineral pyrrhotite and that sulphur concentrations make this material potentially acid-generating as waste rock and process solids (tailings). The proponent makes a good case that the material can be identified and separated from low sulphur (e.g. non-acid generating) materials and measures put in place to prevent ARD. That being said, the draft conceptual closure plan falls short of the requirements of Part VII of the Mine Rehabilitation Code:

Testing and Interpretation 58. Testing of the materials sampled pursuant to section 57 of this Schedule and the interpretation of

the data shall be conducted in accordance with the documents listed in subsection 57 (2), and shall be certified by a person who is qualified as a professional geoscientist or agrologist or as a professional engineer having geological and geochemical experience.

59. (1) Where the interpretation indicates that the materials have the potential for ML or ARD, a management plan shall be developed to ensure that these materials do not adversely affect the quality of the environment.

(2) In order to ensure the chemical and physical stability of the ML or ARD generating materials and that the quality of the environment is protected, the management plan shall consider, where appropriate,

(a) the design and construction of covers and diversion works; and

(b) the use of passive and active treatment systems.

(3) In order to meet the objectives of the closure plan, wet and dry covers for materials that have ML or ARD potential shall be designed and constructed in accordance with best engineering practices and be certified by a qualified professional engineer.


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(4) Analytical models shall be used to predict the performance of wet and dry covers for the materials mentioned in subsection (3) and a monitoring program shall be put in place to test the results predicted by the analytical models used.

More detail is required with respect to how materials that may generate ARD will be handled and how they will be capped or covered. The preferred option appears to be to place ARD materials temporarily in the tailings management facility and then relocate them to one (or more) of the “satellite” open pits. These are expected to eventually flood and submerge the materials, thereby ceasing acid generation. I am supportive of this in principle, however I have concerns regarding the length of time the materials could be exposed on surface prior to flooding as, based on the proponent’s hydrogeological modelling, pit filling rates will be relatively slow. Additionally, kinetic testing indicates that high sulphur materials in the process solids and waste rock may oxidize if left exposed to air and that this causes an initial increase in sulphate concentrations. I did not see information presented which spoke to the relative timing for submerging ARD-generating materials in the pits or covering stockpiled material. Is the intent to artificially flood the pits containing ARD materials and/or cover these materials as they are deposited so that they are not exposed to air? In order to meet the requirements of the above-highlighted sections of the Mine Rehabilitation Code, the proponent should:

1. Provide at least conceptual design of a wet and/or dry cover system for both short term and long term management of the potentially ARD generating materials prepared by suitably qualified individuals;

2. Provide an appropriate conceptual model to predict the performance of these covers and,

3. Describe how the proposed monitoring plan will be used to adequately predict the results of the

conceptual model. My last comment is not directly related to compliance with the Mining Act but it does speak to the ultimate rehabilitation/reclamation of the site:

One of the lasting visual legacies of this mine will be the waste rock pile. Has the proponent given any consideration to marketing this material as aggregate? As a point of reference, there is a large scale profitable quarry operating in the Wawa area that ships trap rock to US markets from a port facility on Lake Superior. Given the proximity of the Marathon PGM project to Lake Superior and the presence of docking facilities in Marathon at the former pulp mill and at Heron Bay (Lafarge), there may be some synergies that could be realized.

Hydrogeology Impact Report review Here are some very preliminary thoughts on the Hydrogeology Impact Report for the Stillwater project:

1. The lifespan of the mine is going to be 11 years, however, the approach in the Report seems to step over this interval in time and look at the long term (e.g. post-mining) hydrog impacts to the GW-SW flow system. Granted, it appears that, based on the model outputs presented in the report, drawdown due to dewatering of the pits is anticipated to have a minimal impact on baseflow in the Pic River. However the Report recognizes that pit dewatering will “decrease or eliminate baseflow to creeks and streams in the vicinity of the pits”. These impacts will have to be included in the assessment of impacts to fish habitat, etc. so that appropriate compensation for loss of fish habitat can be considered.

2. Section 4.2.1:


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4.2.1 Mine Rock Storage Area Tracking the particles placed within the MRSA (Figure 14) shows that an east-west groundwater divide is expected to form beneath the mine rock with approximately half of the groundwater flowing in each direction. Almost all of the particles flowing west discharge to the main pit within the 100 year life of the model due to the pit’s close proximity to the MRSA. A few particles originating in the southwest corner of the MRSA discharge to a drain boundary representing a stream south of the main pit and that stream is within the sub-watershed contributing water to the main pit during closure. Particles flowing west generally form longer pathways but end up discharging to the model’s drain boundaries which represent

the Pic River and its tributaries. Is this last sentence a typo? Should it read “particles flowing east”?

3. Section 4.4: 4.4 Groundwater Chemistry Groundwater chemistry downgradient of the MRSA and PSMF will be a function of background groundwater chemistry and the water chemistry within each structure. In general concentrations in downgradient groundwater are not expected to exceed source concentrations due to natural attenuation processes including dilution, dispersion, precipitation and sorption (e.g. Wilkin, 2007) and concentrations will decrease with distance from the structure. The distribution of groundwater whose chemistry has been affected by either the MRSA or PSMF can be approximated by the distribution of particle tracks (Figure 15) although dispersion is not accounted for in these tracks meaning that the potential extent of affected water chemistry will be somewhat greater. As supported by the conceptual model for the site it has been determined that groundwater chemistry is not the primary concern here; the discharge of groundwater and solutes dissolved in groundwater to surface water bodies is the primary concern. As a result the discharge rates provided in this report for the watersheds in the area can be combined with the geochemical data being collected, analyzed and interpreted by others to calculate a conservative loading rate to the various streams and the Pic River in

the vicinity of the MRSA and PSMF. I hope to see this assessment.

4. Section 5.2: 5.2 Annual Monitoring For the purposes of an annual monitoring program, the monitoring wells should be divided into two groups. Wells directly downgradient of the PSMF, MRSA and other infrastructure should be placed in one group and monitored more frequently and the remaining wells should be monitored less frequently. Wells in Group A are listed below in Table B and should be monitored and sampled three times per year for a list of field and analytical parameters consistent with the groundwater sampling done to date. Wells in Group B, should be monitored and sampled once per year for the same list of field and analytical

parameters as Group A.

While I agree that Wells in Group B may not need to be monitored more than once annually, it would be prudent to collect water table elevation data from these wells as part of the regular monitoring program. This will give a broader perspective on the changes to the site hydrogeology and groundwater flow patterns as the mine develops.


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From: Reitzel, Steve (MNDM) Sent: August 9, 2012 8:14 AM To: O'Brien, Mark (MNDM) Cc: Purdon, Rob H. (MNDM); Cooper, Leslie (MNDM); Grant, Mike (MNDM); Dicaire, Jeff (MNDM); Lillie-Paetz, Jennifer (MNDM) Subject: RE: Comments on Marathon PMG EIS

Thanks Mark, None of my comments are critical enough to hold up public review of the EIS. I cannot speak to others. I had thought that MNDM comments (and other regulatory agency comments) would be consolidated and forwarded to Stillwater for a response as part of the review of the EIS process.

Steve Reitzel, P.Eng Mine Project Engineer

Ministry of Northern Development and Mines 933 Ramsey Lake Road, Sudbury, ON P3E 6B5 Ph: 705-670-5731 Fx: 705-670-5803 [email protected]

From: Reitzel, Steve (MNDM) Sent: August 7, 2012 9:28 AM To: Grant, Mike (MNDM); O'Brien, Mark (MNDM) Cc: Purdon, Rob H. (MNDM); Cooper, Leslie (MNDM) Subject: Comments on Marathon PMG EIS Follow Up Flag: Follow up Flag Status: Red Attachments: (12-07-9) Marathon PGM EIS Review Comments (Steve).doc Hi Mike/Mark, Attached are my comments on the Marathon PMG Environmental Impact Statement submitted by Stillwater. I also reviewed the preliminary Closure Plan prepared by True Grit. I had few comments and they are very general. I’ve provided them below. I’ve reviewed the Closure Plan and Tailings Management and Waste Rock water collection programs. In general I have no significant concerns. All of these programs will be reviewed in significantly more detail when Stillwater applies for their permits. General Comments:

1. some of the figures, such as General Site Layout Figure 1.4-12 are too small to read. Larger scale drawings should be made available for downloading as required.

2. Figure 6.6-2 (EIS) – Pairie Lake is shown twice? Figure N (SD-18-CP) the 2nd “construction” should say “Operation”. There are minor typos throughout the documents.

3. Figure 7.2-2 (EIS) Conceptual Closure plan shows pit discharge migrating through the waste rock pile? The discharge path from the flooded pits to the Pic River needs to be clarified.

4. The EIS commits to completing the waste rock dump (MRSA) to a stable slope. Its not clear if waste rock will be placed on top of the deeper overburden deposits along the Pic River. The EIS needs to confirm that the proposed MRSA slopes are sufficient to ensure long term physical stability given its apparent location on the side of the Pic River valley. A few sectional drawings through the MRSA extending to the Pic River would be helpful in assisting the reader to understand the final MRSA topography relative to the surrounding area.



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5. pg.47 (SD-18-CP) - The cutoff Marathon is using for waste rock Potentially Acid Generating (PAG) material is total sulphur (S) >0.3%. Based on ABA testing by Stillwater, 8 of 356 samples tested with S<0.3% were found to be PAG (i.e. about a 2% error rate). If 288M tonnes of waste rock is to be produced, this error rate could result in 6.5M tonnes of PAG waste rock that has a S content of <0.3% and therefore is erroneously identified as non acid generating (NAG) and is placed in the MRSA? Further clarification is required as to how the potential misplacement of PAG material will be addressed, or why this is not a concern is required.

6. pg.67 (SD-18-CP) PMF Cell 1 and 2 (tailings management area) are to contain PAG tailings, which will be capped with NAG tailings. Once full, these cells will be dewatered to re-establish natural drainage paths. Its not clear if the PAG material will remain below the water table once the pond is drained from Cell 1 and 2 upon closure. Further clarification is required as to the location of the final water table in the TMA relative to the final elevation of the PAG tailings.

7. Table 5 (SD-18-CP) Some of the costs provided in the CP Costing Tables provided by Knight Piesold seems unreasonably low. For example a cost of $1.00/m3 is provided to transfer PAG rock to the primary pit ( a $5M total cost). MNDM recently completed similar work in Timmins this spring and paid $12/m3 on a time and materials basis. We can address specifics when the CP is formally submitted to MNDM, however the Proponent should be reminded that closure costs are to be based on 3rd party rates. They cannot assume that mine equipment and staff will be used to close the site.

Regards

Steve Reitzel, P.Eng Mine Project Engineer

Ministry of Northern Development and Mines 933 Ramsey Lake Road, Sudbury, ON P3E 6B5 Ph: 705-670-5731 Fx: 705-670-5803 [email protected]

Review of Marathon PGM Environmental Impact Statement

Main Report – June 2012 by Stillwater Canada Supplemental Document 18 – Closure Plan by True Grit August 7, 2012 Project Summary: Background:

Site is located 10 km north of town of Marathon. Over an 11.5 year mine life, mining at 22,000 tpd, a main pit will be completed approximately 340 m deep

x 79 ha. Several satellite pits 120 – 180 m deep with a total surface area of 45 ha will be completed by year 6.

Milling will include crushing, floatation for platinum group metals (PMG), Cu and possibly Fe. Concentrate will be stored on site, with a moisture content of 8%.

Groundwater flow is predominantly in the shallow bedrock where the fractured surficial rock has an average K 10-6 m/s. There are various lineaments and fault zones that pass through the pit and rock stock pile that may also transmit groundwater. Groundwater gradients were consistently toward the surface water bodies.

Process Solids Management Facility (Tailings MF)

85% to 90% of the 61M m3 of processed solids (tailings) will be type 1 (non acid generating). The remaining waste rock will be type 2 (potentially acid generating). Two cells within the TMA will contain 5



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and 45 million tonnes of Type 1 tailings, the satellite pits will contain an additional 12M tonnes of Type 1 and 2 tailings. Type 2 tailings will be covered with Type 1 tailings and flooded. Additional type 2 tailings will be placed in Cells 1 and 2 and covered by Type 1 tailings (pg 1.77 EIS)

Water from the TMA (Process Solids Management Facility (PSMF) will be treated and discharged to Hare Lake. Ore stockpile drainage will directed to the pits. Pit water will be directed to the PSMF for treatment.

Dams will be raised to 330 to 375 masl and contain an interior HDPE barrier. The dams will have a slop of 2H:1V, a crest width of 8 m and be raised from 33 to 77 m above grade.

Non hazardous solid waste will be co-disposed with the tailings (pg.3.29) Pg.44 (SD-18 CP) pilot test completed to demonstrate that sulphur separation can be used to produce a 94%

NAG tailings stream. Mine Rock Storage Area (Waste Rock)

85% to 90% of the 288M tonnes of mine rock that will be produced will be non acid generating. Type 1 mine rock (NAG) will be directed to the Mine Rock Storage Area (MRSA) for permanent storage. It will also be used for construction of roads, dams, etc. on site. Type 2 (PAG) mine rock will be relocated to the pits once mining is completed and flooded. Approx. 20M tonnes of PAG mine rock will be managed on surface in temporary stock piles on the west side of the pits, prior to being relocated to the open pits. Drainage from these piles will be directed into the pits.

Runoff from the MRSA will be collected via a series of settling ponds located along the toe designed to manage a 24 hour duration 1 in 25 year event. Water from the MRSA will be pumped from the collection ponds, treated and discharged to the Pic River. Discharge is expected during the spring and late fall only.

Satellite pits are projected to be able to hold approx. 12.1M m3 of rock & Tailings (pg1.78 EIS) Operations

Approximately 500,000 L of fuel will be stored on site. Fuel storage will comply with TSSA and NFPA requirements. In addition to bulk storage, temporary “day” tanks will also be located around the site (these locations should be recorded).

Hazmat building will be constructed to store hazardous materials and wastes. Concentrator building will store 6,000 t of concentrate. Building will be a domed structure with concrete

floor. Concentrate will be shipped by rail or truck.

Closure Plan Summary

All infrastructure including buildings, power lines, unnecessary roads, etc. will be removed. PAG (Type II) waste rock still on surface will be relocated to the pits for permanent storage. Preliminary

works suggests that Type II waste rock will take 10 year prior to generating acid. If acid generation occurs earlier, the pits will be proactively flooded to prevent further acid generation (pg.1.72)

Pits that are filled with processed solids and waste rock will be covered with overburden and reclaimed. Drainage from the pits will be directed to the primary pit, with the exception of pit 5 (located furthest south) which will be allowed to flood to create fish habitat and will discharge to the south (sub-watershed 1).

The primary pit will take 40 years to flood and will discharge to the southeast into sub-watershed 2. A bolder or chain-link fence will be used to prevent inadvertent access. Pit over flow level of 258 masl.

The PSMF (tailings area) will be drained, graded, re-vegetated. Drainage channels will be established to direct runoff to sub-watershed 6.

The MRSA (waste rock dump) will be graded to stable slopes. Flat areas will have topsoil added and be re-vegetated. Side slopes average 2.2H:1V, 30 m tall benches with mid slopes of 2H:1V and 10 m wide bench. Final elevation of 360 masl (100 m above pit lake surface).

Physical and chemical monitoring programs will be established. Employee Accommodations in Marathon for 250 people – to be left in place after closure. Possible off-site rail concentrator loading area.

General Comments:


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8. some of the figures, such as General Site Layout Figure 1.4-12 are too small to read. Larger scale drawings should be made available for downloading as required.

9. Figure 6.6-2 (EIS) – Pairie Lake is shown twice? Figure N (SD-18-CP) the 2nd “construction” should say “Operation”. There are minor typos throughout the documents.

10. Figure 7.2-2 (EIS) Conceptual Closure plan shows pit discharge migrating through the waste rock pile? The discharge path from the flooded pits to the Pic River needs to be clarified.

11. The EIS commits to completing the waste rock dump (MRSA) to a stable slope. Its not clear if waste rock will be placed on top of the deeper overburden deposits along the Pic River. The EIS needs to confirm that the proposed MRSA slopes are sufficient to ensure long term physical stability given its apparent location on the side of the Pic River valley. A few sectional drawings through the MRSA extending to the Pic River would be helpful in assisting the reader to understand the final MRSA topography relative to the surrounding area.

12. pg.47 (SD-18-CP) - The cutoff Marathon is using for waste rock Potentially Acid Generating (PAG) material is total sulphur (S) >0.3%. Based on ABA testing by Stillwater, 8 of 356 samples tested with S<0.3% were found to be PAG (i.e. about a 2% error rate). If 288M tonnes of waste rock is to be produced, this error rate could result in 6.5M tonnes of PAG waste rock that has a S content of <0.3% and therefore is erroneously identified as non acid generating (NAG) and is placed in the MRSA? Further clarification is required as to how the potential misplacement of PAG material will be addressed, or why this is not a concern is required.

13. pg.67 (SD-18-CP) PMF Cell 1 and 2 (tailings management area) are to contain PAG tailings, which will be capped with NAG tailings. Once full, these cells will be dewatered to re-establish natural drainage paths. Its not clear if the PAG material will remain below the water table once the pond is drained from Cell 1 and 2 upon closure. Further clarification is required as to the location of the final water table in the TMA relative to the final elevation of the PAG tailings.

14. Table 5 (SD-18-CP) Some of the costs provided in the CP Costing Tables provided by Knight Piesold seems unreasonably low. For example a cost of $1.00/m3 is provided to transfer PAG rock to the primary pit ( a $5M total cost). MNDM recently completed similar work in Timmins this spring and paid $12/m3 on a time and materials basis. We can address specifics when the CP is formally submitted to MNDM, however the Proponent should be reminded that closure costs are to be based on 3rd party rates. They cannot assume that mine equipment and staff will be used to close the site.


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From: O'Brien, Mark (MNDM) Sent: August 10, 2012 11:19 AM To: Dragan, Brad (MNDM) Cc: Cooper, Leslie (MNDM); Reitzel, Steve (MNDM); Purdon, Rob H. (MNDM) Subject: RE: Stillwater Marathon PGM - draft conceptual closure plan comments

Brad, thanks for your comments; I will add to the MNDM response. With regard to nomenclature, Marathon PGM and Stillwater decided to go the route of PSMF and MRSA as tailings and waste have become negative words. The same is true for Type 1 and Type 2 process solids and mine rock. We may see more of this from industry as they are ever more concerned with public relations; I've seen it for so long that I can go either way. Mark O'

From: Dragan, Brad (MNDM) Sent: August 10, 2012 11:00 AM To: O'Brien, Mark (MNDM) Subject: Stillwater Marathon PGM - draft conceptual closure plan comments

Hey Mark, Here are my comments in regards to the closure plan that I reviewed for the Marathon PGM Project. I did not see any glaring issues in the conceptual closure plan, in future versions I would like to see the sections labelled as per schedule 2 so that it is easier to find the section that you are looking for. I agree with Steve’s comments RE: Diagrams could be larger, as I find them difficult to review. Pg. 62 the Figure N Gant chart has the third phase (purple bar) labelled as construction, this should read operation Another suggestion I have is language consistency with typical mining terms. For example, PSMF (Process Solids Management Facility), why not just use the term tailings management facility, the use of this acronym is confusing to the reader. Another example is Type 1 and Type 2 Process Solids (again I suggest using the terms No Acid Generating Potential and Potentially Acid Generating). Regards, Brad Brad Dragan Inspection Officer Ministry of Northern Development and Mines Mine Rehabilitation, Inspection and Compliance (807) 475-1559 [email protected]



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From: Dicaire, Jeff (MNDM) Sent: July 26, 2012 3:52 PM To: O'Brien, Mark (MNDM) Cc: Grant, Mike (MNDM); Guerard, John (MNDM) Subject: RE: Marathon Project - Timing

Mark: I am aware that you had asked to receive comments for the Technical Working Group Review on August 2nd.

I have been repeatedly checked the site and see that the socio-economic impact documents have not been posted. I have reviewed the general overview in the larger main document, and have seen noting that jumps out with the exception of the following:

The only point I would make, involves the consistent messaging that as a result of the forest industry closures, Terrace Bay may provide opportunities for new families to live there and travel to Marathon for employment. While this cannot be discounted, I would be cautious about available workforce or housing availability after the recent announcement that the Superior Court of Justice approved the sale of Terrace Bay Pulp Inc. (TBPI) to Aditya Birla Group (Birla) on July 19, 2012. Aditya Birla Group has agreed to purchase the assets of the idled mill and plans to invest more than $250 million to convert the facility to dissolve wood pulp for rayon fibre. The investment would support more than 275 direct mill jobs, 335 woodland jobs. The new owners are expecting to begin operating the mill and producing paper grade pulp by October 2012, with the full conversion to dissolving pulp over the next 2 years.

The above mentioned development will likely affect many of the statements made in the socio-economic profile that are related to the Terrace Bay area.

As I mentioned to you previously, I will be away on vacation starting tomorrow morning and will return on August 13th.

Jeff Dicaire Northern Development Officer Ministry of Northern Development & Mines Regional Economic Development Branch Thunder Bay Area Team Phone: 807-825-3410 Cell: 807-823-0677 Email: [email protected]



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Stillwater Canada Inc. Marathon PGM-cu Project

Document 22

Baseline Economic and Social Conditions

Comments for Consideration By: Jeff Dicaire, NDO. MNDM, Terrace Bay

Page 13 Daryl Skworchinski is no longer with the municipality. Replaced by Bob

Hancherow on September 10, 2012 Page 29 Superior Slopes Ski Hill is no longer operating. Page 31 In discussing landfill, there is no mention of the town’s efforts to reduce waste

through recycling and by building a transfer station with compacting abilities. Page 44 Terrace Bay-Schreiber Action Centre is closed Page 59 Lake Superior Snowgoers Club no longer operates Page 60 Marathon Airport only has charter service availability. No scheduled flights Page 60 Terrace Bay Pulp’s Deep Water Port is not under construction. Company in

CCAA and Lake Superior Property is for sale. A road was built to site only. No deep sea port construction.

Page 62 Discussion regarding TBPI should reflect new owner AV Terrace Bay Page 65 Vast different real estate landscape as a result of AV Terrace Bay Page 68 Staff has changed in Manitouwadge. Dave Raymond no longer employed by

municipality. Anthony Friedrich is EDO and Community Services position is vacant

Page 86 Community Development position is no longer. Council eliminated this position

and contracted a consultant to perform community development duties 1 day per week. They also hired an intern with NOHFC funding.

Page 86 25% increase in population is likely a result of a census mistake in 2006

according to council members at that time. Page 89 Vacancy rates and motel availability will likely no be available for Stillwater with

the opening of AV Terrace Bay


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Page 99 Real Estate listing would change dramatically if consulted local staff regarding sales listing.

Page 100 Discussion related to Economic Development Committee should reflect they have

not met in more than 1 year and that council eliminated their Community Development Coordinator

Page 101 Discussed feedback to the economic development department. This department

does not exist. Page 138 No mention of the Pic River FN participating in the Local Forest Management

Corporation with Marathon, Manitouwadge, White River and Hornepayne

Stillwater Canada Inc. Marathon PGM-cu Project

Document 23

Economic and Social Impact Assessment

Comments for Consideration By: Jeff Dicaire, NDO. MNDM, Terrace Bay

Page 4 In referring to TBPI Closure, there should be mention of AV Terrace Bay

start-up as this will impact the effect on Stillwater’s operation. Page 12 In discussing communities within 100 kms, Pays Plat First Nation is

included, but not Rossport. This village offers more opportunity for the quality of life for residents in this region as the only community with an active marina and protected harbour on Lake Superior.

Page 16 25% increase population is likely a result of a census mistake in 2006

according to council members at that time in. Table 2.2.2

Terrace Bay and Schreiber numbers will be impacted by AV Terrace Bay start up. Already seeing real estate purchases climb.

Page 29 Again, discussion of TBPI without consideration for effect by purchase

and start-up of AV Terrace Bay. Page 32 Manitouwadge is not serviced by CN. No railway in Manitouwadge. Page 32 Terrace Bay Pulp’s Deep Water Port is not under construction. Company

in CCAA and Lake Superior Property is for sale. A road was built to site only. No deep sea port construction.

Page 37 Again, discussion of TBPI without consideration for effect by purchase

and start-up of AV Terrace Bay. Page 49 Nowhere in section 2.2.2.5 or anywhere in this document is there

reference to Superior North Community Futures Development Corporation. Federal Economic Development agency that covers the entire region.

Page 50 No study is currently underway in Manitouwadge to study the tourism

sector to determine opportunities. (Spoke to EDO to confirm) Page 52 Great Lakes Heritage Coast no longer exists.

Staffing levels never seam to remain constant after an industry closure that

will undoubtedly affect the school’s enrolment. Page 73 All issues discussed seem to be minor according to this section.

Experience with Labour and Community Adjustment processes in other communities would suggest otherwise. Community adjustment not addressed at all considering the closure impacts.

Page 84 No mention of Community Adjustment process at closure to deal with

Socio-economic impact to the community. Page 86 Significance of increased traffic may be more as municipality will be

responsible for road upgrades. Page 87 Demand on emergency services will likely have a higher significance with

the high number of contractors in town during their off-work hours. Additional security may be required??

Page 89 Significance of increased traffic as well as demand on local infrastructure

may be more as municipality will be responsible for road upgrades. Page 90 Demand on emergency services will likely have a higher significance.

Additional security may be required at housing complex which should increase significance??

Page 91 Labour Adjustment at closure should not be a low significance. There is

no mention of Community Adjustment process at closure to deal with Socio-economic impact to the community.

General Comments:

There needs to be more emphasis on the Rentech development in White River and the impacts it will have on available workforce, housing etc…

There needs to be more detail on the impact that will result after the closure, particularly where housing is concerned. Questions like what is the plan for the 3 motels that have been purchased after no longer needed? What will the impact be to the other hoteliers? What will happen with the 252 bed housing complex?


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No, at their request we removed it from their original application. Scott Cousineau Senior Land Technician Ministry of Northern Development and Mines 705-670-5859 1-888-415-9845 ext 5859 [email protected] -----Original Message----- From: O'Brien, Mark (MNDM) Sent: September 25, 2012 1:04 PM To: Laine, Brian (MNDM) Cc: McFarling, Julie (MNDM); Cousineau, Scott (MNDM) Subject: RE: Marathon Project - Stillwater Canada Inc - EIS Review - mining lands So 1205330 is not currently on the list for lease request? Mark O' -----Original Message----- From: Laine, Brian (MNDM) Sent: September 24, 2012 4:57 PM To: Cousineau, Scott (MNDM); O'Brien, Mark (MNDM) Cc: McFarling, Julie (MNDM) Subject: RE: Marathon Project - Stillwater Canada Inc - EIS Review - mining lands Hi Mark, I have a lease application with claims 4204047-48. It originally also included claim 1205330 (first claim on spreadsheet). The client requested it be removed from the application in October 2010. Brian Laine Mining Lands Technician Mineral Development & Lands Branch Ministry of Northern Delopment & Mines Toll Free 1-888-415-9845 Ext. 5804 Direct 1-705-670-5804 Fax: 1-705-670-5863


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-----Original Message----- From: Cousineau, Scott (MNDM) Sent: September-24-12 4:28 PM To: O'Brien, Mark (MNDM) Cc: Laine, Brian (MNDM); McFarling, Julie (MNDM) Subject: RE: Marathon Project - Stillwater Canada Inc - EIS Review - mining lands Mark, The highlighted claims are the ones that we have application for, I have no records indicating the request was sent in for the 4 claims that are not highlighted. Scott Cousineau Senior Land Technician Ministry of Northern Development and Mines 705-670-5859 1-888-415-9845 ext 5859 [email protected] -----Original Message----- From: O'Brien, Mark (MNDM) Sent: September 24, 2012 2:26 PM To: McFarling, Julie (MNDM) Cc: Cousineau, Scott (MNDM) Subject: RE: Marathon Project - Stillwater Canada Inc - EIS Review - mining lands Julie, any word on this? Mark O' -----Original Message----- From: O'Brien, Mark (MNDM) Sent: September 18, 2012 4:39 PM To: Cousineau, Scott (MNDM) Cc: McFarling, Julie (MNDM) Subject: RE: Marathon Project - Stillwater Canada Inc - EIS Review - mining lands


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Super, Mark O' -----Original Message----- From: Cousineau, Scott (MNDM) Sent: September 18, 2012 4:25 PM To: O'Brien, Mark (MNDM) Cc: McFarling, Julie (MNDM) Subject: RE: Marathon Project - Stillwater Canada Inc - EIS Review - mining lands Julie will get back to you tomorrow Scott Cousineau -----Original Message----- From: O'Brien, Mark (MNDM) Sent: September 18, 2012 4:18 PM To: Cousineau, Scott (MNDM) Cc: McFarling, Julie (MNDM) Subject: Marathon Project - Stillwater Canada Inc - EIS Review - mining lands Scott, per my previous emails, I have attached maps and a spreadsheet that depict claims and leases related to the planned infrastructure. I see 1 staked claim that does not adequately cover infrastructure (i.e. 3014935 with regard to the proposed transmission line) and 2 MRO leases (i.e. TB112787 and TB112788 that do not cover the NE portion of the MRSA or waste rock pile with associated catchment basins). Please confirm that this is your understanding and please confirm that the Stillwater list of 22 lease applications are in the system. I know that MNR is concerned with this as well to avoid PLA dispositions, so I would like to report back to them (Peggy Bluth and Gary Davies) and Tabatha at Stillwater ASAP. Any questions, give me a shout, Mark O'

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