July 2014July 2014July 2014July 2014Environmental Update Environmental Update pp

for SLEMA Boardfor SLEMA BoardZh LiZh LiZhong LiuZhong Liu

July 31, 2014July 31, 2014

HighlightsHighlightsHighlights Highlights

De Beers reported a Monthly AverageDe Beers reported a Monthly AverageDe Beers reported a Monthly Average De Beers reported a Monthly Average Chloride Chloride ExceedanceExceedance at SNP 02at SNP 02--17B 17B (Water Treatment Plant Effluent) on July(Water Treatment Plant Effluent) on July(Water Treatment Plant Effluent) on July (Water Treatment Plant Effluent) on July 31, 201431, 2014

The thirdThe third exceedanceexceedance of monthly averageof monthly average The third The third exceedanceexceedance of monthly average of monthly average Chloride concentration at SNP 02Chloride concentration at SNP 02--17B within 17B within one year periodone year periodone year periodone year period

700Chloride Data Analysis

600

L

400

500

atio

n, m

g/L

Exceedance at SNP 02-17B

300

400

Con

cent

ra

200

Chl

orid

e

Grab Sample

100

Rolling Average

EQC - Grab

EQC A0

18-Oct-12 26-Jan-13 6-May-13 14-Aug-13 22-Nov-13 2-Mar-14 10-Jun-14 18-Sep-14Date

EQC - Average

Comments from the Comments from the Environmental AnalystEnvironmental Analyst

De Beers has a clear record of nonDe Beers has a clear record of non--compliancecompliance De Beers has a clear record of nonDe Beers has a clear record of non compliance compliance now now –– 4 4 exceedanceexceedance events within one year periodevents within one year period 3 3 exceedancesexceedances of monthly average Chloride of monthly average Chloride y gy g

concentration (310 mg/L) at SNP 02concentration (310 mg/L) at SNP 02--17B17B•• September 13, 19 and 25, and October 7, 2013September 13, 19 and 25, and October 7, 2013•• April 23 and 29 and May 5 2014April 23 and 29 and May 5 2014•• April 23 and 29, and May 5, 2014April 23 and 29, and May 5, 2014•• July 10 and 16, 2014July 10 and 16, 2014

1 1 exceedanceexceedance of whole lake average TDS concentration of whole lake average TDS concentration (350 mg/L) at SNP 02(350 mg/L) at SNP 02--1818

•• May 6, 2014May 6, 2014

De Beers shall take effective actions to stop theDe Beers shall take effective actions to stop the De Beers shall take effective actions to stop the De Beers shall take effective actions to stop the trendtrend

OutlineOutlineOutlineOutline1.1. Mine UpdateMine Update2.2. Inspection UpdateInspection Update3.3. Regulators’ UpdateRegulators’ Update3.3. Regulators UpdateRegulators Update4.4. Aboriginal UpdateAboriginal Update55 Stakeholders’ UpdateStakeholders’ Update5.5. Stakeholders’ UpdateStakeholders’ Update6.6. Agency’s ActivitiesAgency’s Activities7.7. SLEMA ReviewsSLEMA Reviews8.8. WaterWater LicenceLicence Amendment ApplicationAmendment Application8.8. Water Water LicenceLicence Amendment Application Amendment Application

AcronymsAcronymsAcronymsAcronyms AANDC AANDC –– Aboriginal Affairs and Northern Development Canada Aboriginal Affairs and Northern Development Canada

(previous INAC(previous INAC –– India and Northern Affairs Canada)India and Northern Affairs Canada)(previous INAC (previous INAC India and Northern Affairs Canada)India and Northern Affairs Canada) AEMP AEMP –– Aquatic Effects Monitoring ProgramAquatic Effects Monitoring Program ARD ARD –– Acid Rock DrainageAcid Rock Drainage DFO DFO –– Fisheries and Oceans CanadaFisheries and Oceans Canada EC EC –– Environment CanadaEnvironment Canada ENR ENR –– Department of Environment and Natural Resources, GNWTDepartment of Environment and Natural Resources, GNWT GNWT GNWT –– Government of the Northwest TerritoriesGovernment of the Northwest Territories

MVLWBMVLWB M k i V ll L d d W t B dM k i V ll L d d W t B d MVLWB MVLWB –– Mackenzie Valley Land and Water BoardMackenzie Valley Land and Water Board PK PK –– Processed Processed KimberliteKimberlite SLEMA SLEMA –– Snap Lake Environmental Monitoring AgencySnap Lake Environmental Monitoring Agency SNPSNP Surveillance Network ProgramSurveillance Network Program SNP SNP –– Surveillance Network ProgramSurveillance Network Program TDS TDS –– Total Dissolved SolidsTotal Dissolved Solids WEMP WEMP –– Wildlife Effects Monitoring ProgramWildlife Effects Monitoring Program WTPWTP –– Water Treatment PlantWater Treatment Plant WTP WTP Water Treatment PlantWater Treatment Plant WMP WMP –– Water Management PondWater Management Pond

1.1 Mine Update1.1 Mine Update –– June 2014June 20141.1 Mine Update 1.1 Mine Update June 2014June 2014 Production rateProduction rate: : 107.0% 107.0% of its capacity (102,162 of its capacity (102,162 tonnestonnes

of of kimberlitekimberlite processed)processed)2 8412 841 33 f t ithd f S L kf t ithd f S L k 2,841 m2,841 m33 of water withdrawn from Snap Lake of water withdrawn from Snap Lake

1,328,779 m1,328,779 m33 of treated water discharged into Snap of treated water discharged into Snap LakeLake

91,446 91,446 tonnestonnes of coarse reject and 54,446 mof coarse reject and 54,446 m33 of slimes of slimes deposited in the North Piledeposited in the North Pile

4 surface spills (1 reportable)4 surface spills (1 reportable) 4 surface spills (1 reportable)4 surface spills (1 reportable) 184 underground hydrocarbon spills (7,778 L)184 underground hydrocarbon spills (7,778 L)

Water sampled in 15 monitoring stations Water sampled in 15 monitoring stations The monthly average for all parameters met complianceThe monthly average for all parameters met compliance

1 2 Spill Reporting1 2 Spill Reporting in Julyin July 201420141.2 Spill Reporting 1.2 Spill Reporting in July in July 20142014Date Location Waste

SpilledAmount (L) Cause

July 5 Northwest arm of Snap Lake

oil 0.3 Boat leg struck a shoal

1 3 Submissions in July 20141 3 Submissions in July 20141.3 Submissions in July 20141.3 Submissions in July 2014

Water Management Plan with Revisions Water Management Plan with Revisions Submitted on July 2, 2014

2013 Hydrology Report 2013 Hydrology Report Submitted on July 3, 2014

2014 North Pile Life-of-Mine Plan 2014 North Pile Life of Mine Plan Submitted on July 8, 2014

1.4 ELS Testing 1.4 ELS Testing –– Chronic Chronic Toxicity TestToxicity Test

Date July 8 2014Date July 8 2014Date July 8, 2014Date July 8, 2014 Additional evidence provided for not Additional evidence provided for not

conducting 30conducting 30--d ELS testingd ELS testingconducting 30conducting 30--d ELS testingd ELS testing “De Beers urges the Board to consider the 7 “De Beers urges the Board to consider the 7

day Fathead Minnow Test which requiresday Fathead Minnow Test which requiresday Fathead Minnow Test which requires day Fathead Minnow Test which requires smaller sample volumes to be collected and smaller sample volumes to be collected and shipped as well as using test organisms that shipped as well as using test organisms that are readily available and of reliable quality as are readily available and of reliable quality as well as more widely performed by commercial well as more widely performed by commercial C di t ti l b t i ”C di t ti l b t i ”Canadian testing laboratories”Canadian testing laboratories”

1.5 1.5 ExceedanceExceedance of AEMP Action Levels of AEMP Action Levels f C i d Th llif C i d Th lli U d tU d tfor Cesium and Thallium for Cesium and Thallium –– Update Update

Dated July 15 2014Dated July 15 2014Dated July 15, 2014Dated July 15, 2014 Provided the proposed Table of Contents Provided the proposed Table of Contents

((ToCToC) of the Cesium and Thallium Response) of the Cesium and Thallium Response((ToCToC) of the Cesium and Thallium Response ) of the Cesium and Thallium Response PlanPlan

•• Both Cesium and Thallium triggered the low action Both Cesium and Thallium triggered the low action gggglevel in fish tissue in 2013level in fish tissue in 2013

Comments from the Comments from the Environmental AnalystEnvironmental Analyst

No concerns are raisedNo concerns are raisedNo concerns are raisedNo concerns are raised

1.6 TDS 1.6 TDS Whole Lake AverageWhole Lake AverageResult on June 25, 2014Result on June 25, 2014

May 6May 6 exceedanceexceedance at SNP 02at SNP 02--18 reported on18 reported on May 6 May 6 exceedanceexceedance at SNP 02at SNP 02 18 reported on 18 reported on June 24June 24

Supplemental TDS testing on June 25 confirmedSupplemental TDS testing on June 25 confirmed Supplemental TDS testing on June 25 confirmed Supplemental TDS testing on June 25 confirmed whole lake average TDS level was lower than whole lake average TDS level was lower than Water Water LinceceLincece limit following melting of the lake limit following melting of the lake iceice

1.7 Monthly Average Chloride 1.7 Monthly Average Chloride ExceedanceExceedance at SNP 02at SNP 02--17B (Water17B (WaterExceedanceExceedance at SNP 02at SNP 02 17B (Water 17B (Water

Treatment Plant Effluent)Treatment Plant Effluent)Reported on July 31 2014Reported on July 31 2014Reported on July 31, 2014Reported on July 31, 2014

Date Grab (mg/L) Average MonthlyAverage (mg/L)

Average MonthlyAverage Limit (mg/L)g ( g ) g ( g )

16 June 2014 295 286 31022 June 2014 312 289 31028 June 2014 350 301 31028 June 2014 350 301 310July 4 2014 334 307 310July 10 2014 319 318 310July 16 2014 270 313 310July 22 2014 271 309 310

2 Inspection Update2 Inspection Update2. Inspection Update 2. Inspection Update

AANDC Inspector AANDC Inspector –– Marty Sanderson Marty Sanderson pp yy Legal sampling programLegal sampling program

Took samples on June 25 2014 afterTook samples on June 25 2014 after Took samples on June 25, 2014 after Took samples on June 25, 2014 after receiving De Beers letter on receiving De Beers letter on exceedanceexceedance of of TDS Whole Lake Average (SNP 02TDS Whole Lake Average (SNP 02--18) on 18) on g (g ( ))June 24 June 24

Water Water LicenceLicence InspectionInspectionpp July 14 and 15, 2014July 14 and 15, 2014

Land Use Permit InspectionLand Use Permit Inspection Land Use Permit InspectionLand Use Permit Inspection July 14, 2014July 14, 2014

2.1 Summary of Findings for Chloride 2.1 Summary of Findings for Chloride E dE d R t d M 5 2014R t d M 5 2014ExceedanceExceedance Reported on May 5, 2014Reported on May 5, 2014

Date July 7 2014Date July 7 2014Date July 7, 2014Date July 7, 2014 Initiated a legal sampling program starting on Initiated a legal sampling program starting on

May 11 and concluding June 10 to determineMay 11 and concluding June 10 to determineMay 11 and concluding June 10 to determine May 11 and concluding June 10 to determine the duration and magnitude of nonthe duration and magnitude of non--compliancecompliancepp

“The 6 samples taken at SNP 02“The 6 samples taken at SNP 02--17B proved 17B proved to the Inspector that the Snap Lake Mine is to the Inspector that the Snap Lake Mine is now in compliance with water now in compliance with water licencelicenceMV2011L2MV2011L2--0004”0004”

Enforcement action is not being contemplated Enforcement action is not being contemplated at this time for this at this time for this exceedanceexceedance eventevent

Summary of Chloride Compliance (SNP02Summary of Chloride Compliance (SNP02--17B) V ifi ti S l R lt17B) V ifi ti S l R lt17B) Verification Sample Results17B) Verification Sample Results

Sample Date Primary Result,mg/L

Duplicate Result, mg/L

May 11, 2014 280 282May 17, 2014 276 278May 23, 2014 271 290May 29, 2014 290 288May 29, 2014 290 288June 4, 2014 256 250June 10, 2014 307 307A 280 282 5Average 280 282.5

2. 2 Summary of Findings for TDS 2. 2 Summary of Findings for TDS E dE d R t d J 24 2014R t d J 24 2014ExceedanceExceedance Reported on June 24, 2014Reported on June 24, 2014 Dated July 19, 2014Dated July 19, 2014 Dated July 19, 2014Dated July 19, 2014

The Inspector was notified on June 24The Inspector was notified on June 24thth 2014 that the whole2014 that the whole--lake lake average of total dissolved solids (TDS) at Surveillance Network average of total dissolved solids (TDS) at Surveillance Network Program (SNP) station 02Program (SNP) station 02--18 was exceeded on May 6, 201418 was exceeded on May 6, 2014Program (SNP) station 02Program (SNP) station 02 18 was exceeded on May 6, 201418 was exceeded on May 6, 2014

In response to the In response to the exceedenceexceedence the Inspector initiated a legal the Inspector initiated a legal sampling program on June 25, 2014 to determine the duration sampling program on June 25, 2014 to determine the duration and magnitude of nonand magnitude of non--compliance. The sampling program wascompliance. The sampling program wasand magnitude of nonand magnitude of non compliance. The sampling program was compliance. The sampling program was conducted under ice free conditionsconducted under ice free conditions

“The 10 samples taken at SNP 02“The 10 samples taken at SNP 02--18 verified to the Inspector 18 verified to the Inspector that the Snap Lake Mine is in compliance with waterthat the Snap Lake Mine is in compliance with water licencelicencethat the Snap Lake Mine is in compliance with water that the Snap Lake Mine is in compliance with water licencelicenceMV2011L2MV2011L2--0004”0004”

Enforcement action is not being contemplated at this time for this Enforcement action is not being contemplated at this time for this exceedanceexceedance eventeventexceedanceexceedance eventevent

Summary of TDS Compliance (SNP02Summary of TDS Compliance (SNP02--18) 18) V ifi ti S l R lt J 25 2014V ifi ti S l R lt J 25 2014Verification Sample Results on June 25, 2014Verification Sample Results on June 25, 2014

SNP 02 18 C l l t d TDSSNP 02-18 Stations

Calculated TDS, mg/L

SNAP 03 250.87SNAP 05 245.32SNAP 08 231.06SNAP 09 276.21SNAP 11A 274.83SNAP 06 279.79SNP 02 20d 248 71SNP 02-20d 248.71SNP 02-20e 352.48SNP 02-20f 253.45SNP 02-20g 256.27Average 266.90

2 3 Water2 3 Water LicenceLicence InspectionInspection2.3 Water 2.3 Water LicenceLicence InspectionInspection Dated July 14 and 15, 2014Dated July 14 and 15, 2014

I t d t tI t d t t l dl d Inspected waste management Inspected waste management laydownlaydown area, area, landfill, tank farms and fuel farm unloading landfill, tank farms and fuel farm unloading modules North Pile sumps and undergroundmodules North Pile sumps and undergroundmodules, North Pile, sumps, and undergroundmodules, North Pile, sumps, and underground A few small spills identified during the A few small spills identified during the inspecitoninspeciton All concerns but small spills in the Truck Shop from the All concerns but small spills in the Truck Shop from the co ce s but s a sp s t e uc S op o t eco ce s but s a sp s t e uc S op o t e

May 29, 2014 Inspection Report were addressedMay 29, 2014 Inspection Report were addressed

Tank farm water has been removed from the Tank farm water has been removed from the bermberm and has been disposed of to anand has been disposed of to anbermberm and has been disposed of to an and has been disposed of to an

approved facilityapproved facility

Several small hydrocarbon spills were identified in Several small hydrocarbon spills were identified in front of the Truck Shop during May 29, 2014 front of the Truck Shop during May 29, 2014

I ti Th ill h t b l dI ti Th ill h t b l dInspection. These spills have not been cleaned up Inspection. These spills have not been cleaned up and disposed of to dateand disposed of to date

Due to extremely dry conditions and high winds Due to extremely dry conditions and high winds De Beers will not ignite the pile of the Burn PitDe Beers will not ignite the pile of the Burn PitDe Beers will not ignite the pile of the Burn Pit De Beers will not ignite the pile of the Burn Pit

until fire hazard conditions are favorableuntil fire hazard conditions are favorable

The Incinerators were being stack The Incinerators were being stack t t d d i th i tit t d d i th i titested during the inspectiontested during the inspection

Temporary Sump 4 was inspected and the Temporary Sump 4 was inspected and the Inspector noted that there was less than ½Inspector noted that there was less than ½Inspector noted that there was less than ½ Inspector noted that there was less than ½

meter of water at this locationmeter of water at this location

Spill pads were located under all units Spill pads were located under all units that could potentially leak at thethat could potentially leak at thethat could potentially leak at the that could potentially leak at the Underground Refueling StationUnderground Refueling Station

The Inspector noted that no drip trays were in place under the The Inspector noted that no drip trays were in place under the underground refueling hose/vehicle. The Inspector highly underground refueling hose/vehicle. The Inspector highly

recommends drip trays be incorporated into all refueling facilitiesrecommends drip trays be incorporated into all refueling facilitiesrecommends drip trays be incorporated into all refueling facilities recommends drip trays be incorporated into all refueling facilities to capture spills and dripsto capture spills and drips

The Inspector observed a target specific grouting The Inspector observed a target specific grouting program being conducted at the lower levels of the mine. program being conducted at the lower levels of the mine. Th i t t ti ll l d / t k t fTh i t t ti ll l d / t k t fThe program is to potentially slow down/stop pockets of The program is to potentially slow down/stop pockets of

connate water from entering existing mine waterconnate water from entering existing mine water

2 4 LUP Inspection2 4 LUP Inspection2.4 LUP Inspection 2.4 LUP Inspection

Dated July 14 2014Dated July 14 2014Dated July 14, 2014Dated July 14, 2014 Land Use Permit Inspection for MV2014DLand Use Permit Inspection for MV2014D--

0010 Bulk Fuel Storage Facility0010 Bulk Fuel Storage Facility0010 Bulk Fuel Storage Facility0010 Bulk Fuel Storage Facility Inspected area Inspected area –– initial clearing of initial clearing of

organics/overburden to competent bed rock atorganics/overburden to competent bed rock atorganics/overburden to competent bed rock at organics/overburden to competent bed rock at the new 10 Million Liter Tank Farm locationthe new 10 Million Liter Tank Farm locationNo concerns were identified during theNo concerns were identified during the No concerns were identified during the No concerns were identified during the inspectioninspection

Drilling and blasting is still under way to Drilling and blasting is still under way to b d t t t b d kb d t t t b d kremove overburden to competent bed rockremove overburden to competent bed rock

The clean organic material has been segregated and will be The clean organic material has been segregated and will be deposited into the organics stock pile for future reclamation deposited into the organics stock pile for future reclamation

work as per the Interim Closure and Reclamation Planwork as per the Interim Closure and Reclamation Plan

3 Regulators’ Update3 Regulators’ Update –– MVLWB (I)MVLWB (I)3. Regulators Update 3. Regulators Update MVLWB (I)MVLWB (I) Approved the 2013 Annual Aquatic Effects Approved the 2013 Annual Aquatic Effects

M it i Pl R t J l 17 2014M it i Pl R t J l 17 2014Monitoring Plan Report on July 17, 2014Monitoring Plan Report on July 17, 2014Changed the Surveillance Network Changed the Surveillance Network

Program on July 17 and requested De Program on July 17 and requested De Beers to conduct both 7 day tests for Beers to conduct both 7 day tests for Rainbow Trout and Fathead Minnow for a Rainbow Trout and Fathead Minnow for a minimum one year periodminimum one year period “Following the one year period, De Beers “Following the one year period, De Beers

could request to eliminate one of the tests if could request to eliminate one of the tests if th h id t t th t”th h id t t th t”they have evidence to support the request” they have evidence to support the request”

3 Regulators’ Update3 Regulators’ Update –– MVLWB (II)MVLWB (II)3. Regulators Update 3. Regulators Update MVLWB (II)MVLWB (II)

Accepted the 2013 Water License AnnualAccepted the 2013 Water License Annual Accepted the 2013 Water License Annual Accepted the 2013 Water License Annual Report and the 2013 Annual Closure and Report and the 2013 Annual Closure and Reclamation Plan Progress Report asReclamation Plan Progress Report asReclamation Plan Progress Report as Reclamation Plan Progress Report as submitted on July 17, 2014 and directed submitted on July 17, 2014 and directed De Beers to adhere to the commitmentsDe Beers to adhere to the commitmentsDe Beers to adhere to the commitments De Beers to adhere to the commitments De Beers made as part of their responses De Beers made as part of their responses to the reviewer Comment Tablesto the reviewer Comment Tablesto the reviewer Comment Tables to the reviewer Comment Tables

4 Aboriginal Update4 Aboriginal Update4. Aboriginal Update4. Aboriginal Update

No comments received from AboriginalNo comments received from AboriginalNo comments received from Aboriginal No comments received from Aboriginal parties in July 2014parties in July 2014

5 Stakeholders’ Update5 Stakeholders’ Update5. Stakeholders Update5. Stakeholders Update

Environment and Natural ResourcesEnvironment and Natural Resources Environment and Natural Resources Environment and Natural Resources (ENR) Commented on Air Quality (ENR) Commented on Air Quality Monitoring during Forest Fire Season onMonitoring during Forest Fire Season onMonitoring during Forest Fire Season on Monitoring during Forest Fire Season on July 16, 2014July 16, 2014

EC and ENR Commented on the NorthEC and ENR Commented on the North EC and ENR Commented on the North EC and ENR Commented on the North Pile Management Plan on July 22Pile Management Plan on July 22

C CC C EC and ENR Commented on the EC and ENR Commented on the Acid/Alkaline Rock Drainage (ARD) and Acid/Alkaline Rock Drainage (ARD) and G CG CGeochemical Characterization Plan on Geochemical Characterization Plan on July 24July 24

5.1 ENR 5.1 ENR Comments on Air Quality Comments on Air Quality M it i d i F t Fi SM it i d i F t Fi SMonitoring during Forest Fire SeasonMonitoring during Forest Fire Season

De Beers requested on July 9 2014 howDe Beers requested on July 9 2014 howDe Beers requested, on July 9, 2014 how De Beers requested, on July 9, 2014 how to differentiate the anthropogenic and to differentiate the anthropogenic and natural sources of particulate matter at thenatural sources of particulate matter at thenatural sources of particulate matter at the natural sources of particulate matter at the mine during forest fire seasonmine during forest fire season

ENR responded with three suggestions onENR responded with three suggestions on ENR responded with three suggestions on ENR responded with three suggestions on July 16July 16

ENR SuggestionsENR SuggestionsENR SuggestionsENR Suggestions “Make sure you keep a good record of days when forest “Make sure you keep a good record of days when forest

fire smoke is present and you are seeing elevated levels fire smoke is present and you are seeing elevated levels p y gp y gof particulate matter (TSP, PM10 & PM2.5).of particulate matter (TSP, PM10 & PM2.5).

In the annual AQ report, make reference to the days In the annual AQ report, make reference to the days forest fire smoke was observed in the area whenforest fire smoke was observed in the area whenforest fire smoke was observed in the area when forest fire smoke was observed in the area when elevated levels of PM were observed.elevated levels of PM were observed.

Remove the PM data points that are elevated as a result Remove the PM data points that are elevated as a result ppof forest fire smoke from the analysis, when you are of forest fire smoke from the analysis, when you are comparing to the relevant standards as well as the year comparing to the relevant standards as well as the year to year changes for TSP PM10 & PM2 5 This wayto year changes for TSP PM10 & PM2 5 This wayto year changes for TSP, PM10 & PM2.5. This way to year changes for TSP, PM10 & PM2.5. This way action levels will not be triggered as a result of forest fire action levels will not be triggered as a result of forest fire activity. It is important that the AQ report clearly explains activity. It is important that the AQ report clearly explains

h th l t d PM di h b d fh th l t d PM di h b d fwhy the elevated PM readings have been removed from why the elevated PM readings have been removed from the analysis”the analysis”

5.2 EC Comments on the North 5.2 EC Comments on the North Pile Management Plan (I)Pile Management Plan (I)

The Proponent states that “Based on the kinetic testThe Proponent states that “Based on the kinetic test The Proponent states that Based on the kinetic test The Proponent states that Based on the kinetic test results and the availability of lowresults and the availability of low--sulphursulphur granite in the granite in the vicinity of the mine site, a maximum vicinity of the mine site, a maximum sulphidesulphide content content cutcut off value of 0 17%off value of 0 17% sulphidesulphide by mass is used toby mass is used tocutcut--off value of 0.17% off value of 0.17% sulphidesulphide by mass is used to by mass is used to determine if rock is suitable for construction. Granite determine if rock is suitable for construction. Granite located away from the located away from the metavolcanicmetavolcanic unit contains very unit contains very low amounts of low amounts of sulphidesulphide minerals and is considered to minerals and is considered to be suitable for construction." It is common practice to be suitable for construction." It is common practice to use more than just theuse more than just the sulphidesulphide content to determinecontent to determineuse more than just the use more than just the sulphidesulphide content to determine content to determine Potentially Acid Generating (PAG) and nonPotentially Acid Generating (PAG) and non--PAG rock. PAG rock. Where there is no or little neutralization potential, even Where there is no or little neutralization potential, even lowlow sulphursulphur content in a rock may still generate acidcontent in a rock may still generate acidlow low sulphursulphur content in a rock may still generate acidcontent in a rock may still generate acid

5.2 EC Comments on the North 5.2 EC Comments on the North Pile Management Plan (II)Pile Management Plan (II)

EC recommends that the proponentEC recommends that the proponent EC recommends that the proponent EC recommends that the proponent include other characterization methods include other characterization methods besides percentage ofbesides percentage of sulphursulphur content tocontent tobesides percentage of besides percentage of sulphursulphur content to content to confirm or deny acid potential (AP)confirm or deny acid potential (AP)

5.3 ENR Comments on the 5.3 ENR Comments on the North Pile Management Plan (I)North Pile Management Plan (I) Based upon the currently permitted NorthBased upon the currently permitted North Based upon the currently permitted North Based upon the currently permitted North

Pile (without amendments), the proponent Pile (without amendments), the proponent has not identified the length of remaininghas not identified the length of remaininghas not identified the length of remaining has not identified the length of remaining mine life that can be achieved if there are mine life that can be achieved if there are no changes to the current mining practicesno changes to the current mining practicesno changes to the current mining practicesno changes to the current mining practices The proponent identify the life of mine The proponent identify the life of mine

remaining in the North Pile if no changes orremaining in the North Pile if no changes orremaining in the North Pile if no changes or remaining in the North Pile if no changes or amendments are approved for the facilityamendments are approved for the facility

5.3 ENR Comments on the 5.3 ENR Comments on the North Pile Management Plan (II)North Pile Management Plan (II) ENR notes that the proponent has notENR notes that the proponent has not ENR notes that the proponent has not ENR notes that the proponent has not

identified the type and quantity of identified the type and quantity of flocculants that are used in the treatmentflocculants that are used in the treatmentflocculants that are used in the treatment flocculants that are used in the treatment processprocess

ENR requests that the proponent identify theENR requests that the proponent identify the ENR requests that the proponent identify the ENR requests that the proponent identify the flocculent and its chemical composition, as it flocculent and its chemical composition, as it can have an impact on water qualitycan have an impact on water qualitycan have an impact on water qualitycan have an impact on water quality

ENR requests that the proponent identify the ENR requests that the proponent identify the total volume of flocculent used in the processtotal volume of flocculent used in the processpp

5.3 ENR Comments on the North 5.3 ENR Comments on the North Pil M Pl (III)Pil M Pl (III)Pile Management Plan (III)Pile Management Plan (III)

The proponent has identified particularThe proponent has identified particular The proponent has identified particular The proponent has identified particular contaminants (Nitrates, Ammonia, pH) with contaminants (Nitrates, Ammonia, pH) with definitive criteria that may indicate the need to definitive criteria that may indicate the need to yyincrease the level of concern. ENR appreciates increase the level of concern. ENR appreciates the approach of identifying specific threshold the approach of identifying specific threshold

l h th t h ld idl h th t h ld idvalues; however, the proponent should consider values; however, the proponent should consider coupling this to a statistical trend analysis which coupling this to a statistical trend analysis which may trigger low level action earlier reducingmay trigger low level action earlier reducingmay trigger low level action earlier reducing may trigger low level action earlier reducing overall impacts. • The proponent has not overall impacts. • The proponent has not identified specific criteria of metals in the SNP identified specific criteria of metals in the SNP ppnetwork which may indicate elevated metal network which may indicate elevated metal leachateleachate being generated by the North Pilebeing generated by the North Pile

5.3 ENR Comments on the North 5.3 ENR Comments on the North Pil M Pl (IV)Pil M Pl (IV)Pile Management Plan (IV)Pile Management Plan (IV)

ENR recommends that De Beers provideENR recommends that De Beers provide ENR recommends that De Beers provide ENR recommends that De Beers provide additional information regarding the additional information regarding the predicted mine rates noted in the planpredicted mine rates noted in the planpredicted mine rates noted in the planpredicted mine rates noted in the plan

ENR recommends that De Beers provide ENR recommends that De Beers provide clarification of predicted amounts of pasteclarification of predicted amounts of pasteclarification of predicted amounts of paste clarification of predicted amounts of paste by year to be deposited to the by year to be deposited to the underground De Beers must be clear onunderground De Beers must be clear onunderground. De Beers must be clear on underground. De Beers must be clear on whether paste will or will not be placed in whether paste will or will not be placed in the underground This discussion hasthe underground This discussion hasthe underground. This discussion has the underground. This discussion has been ongoing for several yearsbeen ongoing for several years

5.3 ENR Comments on the North 5.3 ENR Comments on the North Pil M Pl (V)Pil M Pl (V)Pile Management Plan (V)Pile Management Plan (V)

ENR recommends that De Beers clarify whether options described ENR recommends that De Beers clarify whether options described y py ppreviously in the Plan are included in the work schedule. If options previously in the Plan are included in the work schedule. If options have already been selected with associated timelines, ENR have already been selected with associated timelines, ENR requests additional clarity on the selected heights of raises and their requests additional clarity on the selected heights of raises and their design standard (e.g. water retaining)design standard (e.g. water retaining)

ENR requests clarification on the target level vs. operational ENR requests clarification on the target level vs. operational objective within the Water Management Pond. De Beers should objective within the Water Management Pond. De Beers should provide contingency measures for seepage from Dam 1 if volumes provide contingency measures for seepage from Dam 1 if volumes within the WMP exceed 71,055 m3within the WMP exceed 71,055 m3

ENR recommends that De Beers provide rationale for the thresholds ENR recommends that De Beers provide rationale for the thresholds selected (Table 5) within the Adaptive Management portion of the selected (Table 5) within the Adaptive Management portion of the plan. A description of the increased risk based on less than 0.5m plan. A description of the increased risk based on less than 0.5m increases in depth/width should be described in a geotechnical increases in depth/width should be described in a geotechnical mannermannermannermanner

5.4 ENR Comments on the ARD 5.4 ENR Comments on the ARD Plan (I)Plan (I)

The proponent did not provide any explanationThe proponent did not provide any explanation The proponent did not provide any explanation The proponent did not provide any explanation why why KimberliteKimberlite was blended with was blended with metavolcanicmetavolcanicrock for the long term leach test. It is not clear rock for the long term leach test. It is not clear ggwhy this decision was made given that the why this decision was made given that the blending may reduce/mask the Acid Potential blending may reduce/mask the Acid Potential (AP) th t ld h b t i th(AP) th t ld h b t i th(AP) that would have been present in the (AP) that would have been present in the metavolcanicmetavolcanic rockrock

EC recommends separate characterization of theEC recommends separate characterization of the EC recommends separate characterization of the EC recommends separate characterization of the individual identifiable rock unitsindividual identifiable rock units

5.4 ENR Comments on the ARD 5.4 ENR Comments on the ARD Plan (II)Plan (II)

It is EC’s opinion thatIt is EC’s opinion that metavolcanicsmetavolcanics should notshould not It is EC s opinion that It is EC s opinion that metavolcanicsmetavolcanics should not should not be included in the rock materials that will be be included in the rock materials that will be used for construction. As highlighted in Section used for construction. As highlighted in Section g gg g4.2, 4.2, metavolcanicmetavolcanic rock contain rock contain sulphidesulphide and has and has a low neutralization potential. Using a low neutralization potential. Using

t l it l i th t h b d t i d tth t h b d t i d tmetavolcanicmetavolcanic that has been determined to that has been determined to possess acid potential in construction may possess acid potential in construction may become problematic later and could eitherbecome problematic later and could eitherbecome problematic later and could either become problematic later and could either generate acid or leach metalsgenerate acid or leach metals

5.4 ENR Comments on the ARD 5.4 ENR Comments on the ARD Plan (III)Plan (III)

The proponent states that “it is not expected that minorThe proponent states that “it is not expected that minor The proponent states that it is not expected that minor The proponent states that it is not expected that minor amounts of dilution rock included within granite used for amounts of dilution rock included within granite used for site construction will materially influence the overall site site construction will materially influence the overall site water quality observed” As has been stated above evenwater quality observed” As has been stated above evenwater quality observed . As has been stated above, even water quality observed . As has been stated above, even with a small weight percentage of with a small weight percentage of sulphursulphur SulphideSulphide as as low as 0.17% it may still generate acid if there is low as 0.17% it may still generate acid if there is absence of neutralizing materialsabsence of neutralizing materials EC recommends the proponent define what is meant by “minor EC recommends the proponent define what is meant by “minor

amounts”. In addition, recommends that amounts”. In addition, recommends that metavolcanicsmetavolcanics not be not be mixed with granite rocks intended to be used for constructionmixed with granite rocks intended to be used for construction

5.4 ENR Comments on the ARD 5.4 ENR Comments on the ARD Plan Plan (IV)(IV)

EC recommends that the proponent stateEC recommends that the proponent state EC recommends that the proponent state EC recommends that the proponent state exactly the magnitude above the exactly the magnitude above the background level at which point a remedialbackground level at which point a remedialbackground level at which point a remedial background level at which point a remedial action will be taken, when mitigation will action will be taken, when mitigation will be implemented and what that mitigationbe implemented and what that mitigationbe implemented and what that mitigation be implemented and what that mitigation will be. Thresholds could be a percentage will be. Thresholds could be a percentage or a specific number above backgroundor a specific number above backgroundor a specific number above backgroundor a specific number above background

5.5 ENR Comments on the ARD 5.5 ENR Comments on the ARD PlanPlan

No comments or recommendations at thisNo comments or recommendations at thisNo comments or recommendations at this No comments or recommendations at this timetime

66 Agency’s ActivitiesAgency’s Activities6. 6. Agency s ActivitiesAgency s Activities

SLEMA staff had a meeting with De BeersSLEMA staff had a meeting with De Beers SLEMA staff had a meeting with De Beers SLEMA staff had a meeting with De Beers staff about the coming site visit of SLEMA staff about the coming site visit of SLEMA Core Group Meeting on July 9 2014Core Group Meeting on July 9 2014Core Group Meeting on July 9, 2014Core Group Meeting on July 9, 2014 Scheduled on September 16, after fish tasting Scheduled on September 16, after fish tasting

on September 10 an d11on September 10 an d11on September 10 an d11on September 10 an d11 SLEMA sent out two comment letters to SLEMA sent out two comment letters to

the MVLWB on July 22the MVLWB on July 22the MVLWB on July 22the MVLWB on July 22

7 SLEMA Reviews7 SLEMA Reviews7. SLEMA Reviews7. SLEMA Reviews

North Pile Management PlanNorth Pile Management Plan North Pile Management Plan North Pile Management Plan Acid/Alkaline Rock Drainage (ARD) and Acid/Alkaline Rock Drainage (ARD) and

Geochemical Characterization PlanGeochemical Characterization PlanGeochemical Characterization PlanGeochemical Characterization Plan Water Management Plan with RevisionsWater Management Plan with Revisions 2013 Hydrology Report2013 Hydrology Report 2013 Hydrology Report2013 Hydrology Report 2014 North Pile Life2014 North Pile Life--ofof--Mine PlanMine Plan

7.1 North Pile Management 7.1 North Pile Management PlanPlan

MAIN CONTENTSMAIN CONTENTSWASTE STREAMS OF THE NORTH PILE FACILITYWASTE STREAMS OF THE NORTH PILE FACILITY WASTE STREAMS OF THE NORTH PILE FACILITY WASTE STREAMS OF THE NORTH PILE FACILITY

ESTIMATED ORE, PROCESSED KIMBERLITE AND WASTE ESTIMATED ORE, PROCESSED KIMBERLITE AND WASTE ROCK ROCK

OPERATIONAL PROCEDURES AND GEOMETRIC OPERATIONAL PROCEDURES AND GEOMETRIC SEQUENCING SEQUENCING

PROPOSED KIMBERLITE ORE STOCKPILE PROPOSED KIMBERLITE ORE STOCKPILE GEOCHEMICAL CRITERIA FOR MANAGEMENT AND GEOCHEMICAL CRITERIA FOR MANAGEMENT AND

PLACEMENT OF PAG PLACEMENT OF PAG OPERATIONAL PROCEDURES FOR DEPOSITION OPERATIONAL PROCEDURES FOR DEPOSITION WATER MANAGEMENT WATER MANAGEMENT THE NORTH PILE FACILITY INFRASTRUCTURE AND THE NORTH PILE FACILITY INFRASTRUCTURE AND

PERFORMANCEPERFORMANCEPERFORMANCE PERFORMANCE RESPONSE FRAMEWORK AND ACTION LEVELS RESPONSE FRAMEWORK AND ACTION LEVELS

Starter Cell, East Cell, Ditches Starter Cell, East Cell, Ditches d Sd Sand Sumpsand Sumps

North Pile DevelopmentNorth Pile DevelopmentNorth Pile DevelopmentNorth Pile Development The North Pile is being developed in three cells in theThe North Pile is being developed in three cells in the The North Pile is being developed in three cells in the The North Pile is being developed in three cells in the

following order: following order: 1. Starter Cell (construction in 2005, PK deposition from 2007 to 1. Starter Cell (construction in 2005, PK deposition from 2007 to

2014)2014)2014) 2014) 2. East Cell (construction in 2010, PK deposition from 2014 to 2. East Cell (construction in 2010, PK deposition from 2014 to

2016)2016)3 W t C ll ( t ti i 2014 PK d iti f 2016 t3 W t C ll ( t ti i 2014 PK d iti f 2016 t3. West Cell (construction in 2014, PK deposition from 2016 to 3. West Cell (construction in 2014, PK deposition from 2016 to

2016)2016)

Each of these cells is considered a separate phase of Each of these cells is considered a separate phase of the North Pile developmentthe North Pile development

It is planned that the West Cell construction application It is planned that the West Cell construction application package will be submitted in August 2014package will be submitted in August 2014package will be submitted in August 2014package will be submitted in August 2014

Options for the North Pile Options for the North Pile ExpansionExpansion

Expansion of the West Cell to the westExpansion of the West Cell to the west within the minewithin the mine Expansion of the West Cell to the westExpansion of the West Cell to the west within the mine within the mine property boundary and into currently unpermitted areas. property boundary and into currently unpermitted areas.

Increase of the elevation of the West Cell above Increase of the elevation of the West Cell above tl itt d l titl itt d l ticurrently permitted elevation. currently permitted elevation.

Increase the heightIncrease the height of the Starter Cell from its currently of the Starter Cell from its currently permitted elevation by increasing perimeter slopepermitted elevation by increasing perimeter slopepermitted elevation by increasing perimeter slope permitted elevation by increasing perimeter slope inclination. inclination.

Increase the height of the East Cell from its currently Increase the height of the East Cell from its currently permitted elevation by increasing the perimeter slope permitted elevation by increasing the perimeter slope inclination. inclination.

Construct anConstruct an additional cell to the eastadditional cell to the east of the easternof the eastern Construct an Construct an additional cell to the eastadditional cell to the east of the eastern of the eastern perimeter of the Starter and East Cell perimeter of the Starter and East Cell

Comments from the Comments from the Environmental Analyst (I) Environmental Analyst (I)

““Raise North Pile Facility by Up to 501mRaise North Pile Facility by Up to 501m” is” is Raise North Pile Facility by Up to 501mRaise North Pile Facility by Up to 501m is is stated that in Figure 3. However, that is not stated that in Figure 3. However, that is not approved by the MVLWB. The MVLWB only approved by the MVLWB. The MVLWB only pp y ypp y yapproved the Phase IV Raise of the Starter Cell approved the Phase IV Raise of the Starter Cell up to 489.5m (plus 4m of nonup to 489.5m (plus 4m of non--acid generating acid generating

t i l) S t b 25 2013t i l) S t b 25 2013cover material) on September 25, 2013cover material) on September 25, 2013 Clarification is requested. Further raise of the North Clarification is requested. Further raise of the North

Pile must be reviewed by stakeholders WithoutPile must be reviewed by stakeholders WithoutPile must be reviewed by stakeholders. Without Pile must be reviewed by stakeholders. Without proper consultation and public review, it is not proper consultation and public review, it is not appropriate to approve the maximum height of 501m appropriate to approve the maximum height of 501m D B d i thi PlD B d i thi PlDe Beers proposed in this PlanDe Beers proposed in this Plan

Comments from the Comments from the Environmental Analyst (II) Environmental Analyst (II)

It is stated in page 15 that "(I)t is expected that theIt is stated in page 15 that "(I)t is expected that the It is stated in page 15 that (I)t is expected that the It is stated in page 15 that (I)t is expected that the embankments of the East Cell will be constructed using embankments of the East Cell will be constructed using paste and rock fill". However, during the SLWG on May paste and rock fill". However, during the SLWG on May 28 2014 Peter Mooney claimed that "(W)e have paste28 2014 Peter Mooney claimed that "(W)e have paste28, 2014, Peter Mooney claimed that (W)e have paste 28, 2014, Peter Mooney claimed that (W)e have paste on the NP, but we can’t get the strength required to build on the NP, but we can’t get the strength required to build with it" (page 4 of the Meeting Minutes). It is also stated with it" (page 4 of the Meeting Minutes). It is also stated in Section 2.6 (page 20) that "(T)o date it has not been in Section 2.6 (page 20) that "(T)o date it has not been practical to make a paste of the PK that is suitable for practical to make a paste of the PK that is suitable for embankment construction. There are no longer plans toembankment construction. There are no longer plans toembankment construction. There are no longer plans to embankment construction. There are no longer plans to use paste to construct any cells that comprise the North use paste to construct any cells that comprise the North Pile and there are no near term plans for paste Pile and there are no near term plans for paste deposition on surface however paste will continue to bedeposition on surface however paste will continue to bedeposition on surface, however, paste will continue to be deposition on surface, however, paste will continue to be investigated“investigated“ Consistency is requestedConsistency is requested

Comments from the Comments from the Environmental Analyst (III) Environmental Analyst (III)

The angles for the embankment are 1:1 5The angles for the embankment are 1:1 5 The angles for the embankment are 1:1.5 The angles for the embankment are 1:1.5 for both upstream and downstream (page for both upstream and downstream (page 16) which is not consistent with the16) which is not consistent with the16), which is not consistent with the 16), which is not consistent with the statements provided by Peter Mooney statements provided by Peter Mooney during the SLWG on May 28 he statedduring the SLWG on May 28 he statedduring the SLWG on May 28. he stated during the SLWG on May 28. he stated that upstream would remain 1:2 and that upstream would remain 1:2 and downstream would change from 1:3 to 1:2downstream would change from 1:3 to 1:2downstream would change from 1:3 to 1:2 downstream would change from 1:3 to 1:2 (Slide 9 and 26 of his presentation and (Slide 9 and 26 of his presentation and page 6 of the Meeting Minutes)page 6 of the Meeting Minutes)page 6 of the Meeting Minutes)page 6 of the Meeting Minutes) Clarification is requestedClarification is requested

Comments from the Comments from the Environmental Analyst (IV) Environmental Analyst (IV)

There are other inconsistencies orThere are other inconsistencies or There are other inconsistencies or There are other inconsistencies or inaccuracies in the Plan, revision of the inaccuracies in the Plan, revision of the Plan is requestedPlan is requestedPlan is requestedPlan is requested

7.2 Acid/Alkaline Rock Drainage (ARD) 7.2 Acid/Alkaline Rock Drainage (ARD) and Geochemical Characterization Planand Geochemical Characterization Planand Geochemical Characterization Plan and Geochemical Characterization Plan

(June 2014) (June 2014)

Updated Plan from the January 2013 versionUpdated Plan from the January 2013 version Changes Changes gg

Simplified geochemical classification criteria for Simplified geochemical classification criteria for granitegranite

Addition of a few figures explaining the Addition of a few figures explaining the rocktypesrocktypes, , TDS loading rate, ore and waste flowsTDS loading rate, ore and waste flows

Simplified Geochemical Classification Simplified Geochemical Classification C it i f G itC it i f G itCriteria for GraniteCriteria for Granite

Granite diluted with minor amounts ofGranite diluted with minor amounts of kimberlitekimberlite Granite diluted with minor amounts of Granite diluted with minor amounts of kimberlitekimberlite, , PK, or PK, or metavolcanicmetavolcanic rock may be used for rock may be used for general site construction if material is nongeneral site construction if material is non--AG AG gg(<0.17% S), otherwise should be placed (<0.17% S), otherwise should be placed underground or internal structure construction in underground or internal structure construction in N th Pil bN th Pil bNorth Pile, becauseNorth Pile, because Based on the test results, small amounts of Based on the test results, small amounts of

kimberlitekimberlite//metavolcanicmetavolcanic rock within other rock are notrock within other rock are notkimberlitekimberlite//metavolcanicmetavolcanic rock within other rock are not rock within other rock are not expected to materially change the expected to materially change the leachateleachatecharacteristics or acid generation potential of those characteristics or acid generation potential of those

t i lt i lmaterialsmaterials

RocktypesRocktypes at Snap Lake Mineat Snap Lake MineRocktypesRocktypes at Snap Lake Mineat Snap Lake Mine

Geological Map of the Country Rock at the Geological Map of the Country Rock at the KimberliteKimberlite Dyke Boundary with the Mine WorkingsDyke Boundary with the Mine Workingsy y gy y g

Updated Loading Rate, Updated Loading Rate, D b 31 2013D b 31 2013December 31, 2013December 31, 2013

Ore FlowOre FlowOre FlowOre Flow

Waste FlowWaste FlowWaste FlowWaste Flow

Comments from the Comments from the Environmental Analyst (I)Environmental Analyst (I)

The simplified geochemical classification criteriaThe simplified geochemical classification criteria The simplified geochemical classification criteria The simplified geochemical classification criteria for granite will simplify the mine rock for granite will simplify the mine rock management, however, granite diluted with management, however, granite diluted with g gg gminor amounts of minor amounts of kimberlitekimberlite, PK, or , PK, or metavolcanicmetavolcanic rock used for general site rock used for general site

t ti h t ti l idt ti h t ti l id l h tl h tconstruction may have potential acid construction may have potential acid leachateleachateissues. Instead of for general site construction, issues. Instead of for general site construction, diluted granite is preferred for the North Pilediluted granite is preferred for the North Pilediluted granite is preferred for the North Pile diluted granite is preferred for the North Pile constructionconstruction

Comments from the Comments from the Environmental Analyst (II)Environmental Analyst (II)

Added figures (Figures 2Added figures (Figures 2--2 22 2--3 63 6--2 72 7--1)1) Added figures (Figures 2Added figures (Figures 2--2, 22, 2--3, 63, 6--2, 72, 7--1) 1) and updated Figure 5and updated Figure 5--1 are helpful for 1 are helpful for reviewers to better understand the minereviewers to better understand the minereviewers to better understand the mine reviewers to better understand the mine rock management, and the efforts are rock management, and the efforts are appreciatedappreciatedappreciatedappreciated

The List of Figures (page ii) is not updatedThe List of Figures (page ii) is not updatedAdd d fi i i i th Li tAdd d fi i i i th Li t Added figures are missing in the ListAdded figures are missing in the List

Figure 5Figure 5--2 is removed in Section 5 but still in 2 is removed in Section 5 but still in th Li tth Li tthe Listthe List

7.3 7.3 Water Management Plan Water Management Plan with Revisionswith Revisions

Updated from the October 2013 versionUpdated from the October 2013 versionUpdated from the October 2013 versionUpdated from the October 2013 version Some of SLEMA comments dated January Some of SLEMA comments dated January

23 2014 appear not to be addressed23 2014 appear not to be addressed23, 2014 appear not to be addressed23, 2014 appear not to be addressed A few editing issues are identifiedA few editing issues are identified

7 47 4 2013 Hydrology Report2013 Hydrology Report7.4 7.4 2013 Hydrology Report2013 Hydrology Report The Snap Lake outflow was measured and flow dataThe Snap Lake outflow was measured and flow data The Snap Lake outflow was measured and flow data The Snap Lake outflow was measured and flow data

summarized. The total mean outflow during the open summarized. The total mean outflow during the open water period in 2013 over which measurements were water period in 2013 over which measurements were recorded was 0 205 m3/s The total mean outflow forrecorded was 0 205 m3/s The total mean outflow forrecorded was 0.205 m3/s. The total mean outflow for recorded was 0.205 m3/s. The total mean outflow for 2013 is higher than the 2012 measured value, which was 2013 is higher than the 2012 measured value, which was recorded as 0.150 m3/srecorded as 0.150 m3/s

Snap Lake surface water elevations were also Snap Lake surface water elevations were also measured. Results indicated that a surface water measured. Results indicated that a surface water elevation was lower in 2013 than in 2012 The resultselevation was lower in 2013 than in 2012 The resultselevation was lower in 2013 than in 2012. The results elevation was lower in 2013 than in 2012. The results also suggest that the 2013 water elevation is highest in also suggest that the 2013 water elevation is highest in June and is consistent with previous yearsJune and is consistent with previous years

Surveyed Water Elevations for Selected Surveyed Water Elevations for Selected L k th S L k Mi R l tiL k th S L k Mi R l tiLakes near the Snap Lake Mine RelativeLakes near the Snap Lake Mine Relative

Comments from the Comments from the Environmental AnalystEnvironmental Analyst

No concerns are raisedNo concerns are raisedNo concerns are raisedNo concerns are raised

7.5 7.5 2014 North Pile Life-of-Mine Plan

The objective of the plan is to describeThe objective of the plan is to describe The objective of the plan is to describe The objective of the plan is to describe current and future options and conceptual current and future options and conceptual plans for design construction operationplans for design construction operationplans for design, construction, operation, plans for design, construction, operation, and closure of the North Pileand closure of the North Pile

The document is intended for informationThe document is intended for information The document is intended for information The document is intended for information purposes for stakeholders only, not for review purposes for stakeholders only, not for review and approvaland approvaland approvaland approval

Layout of the MineLayout of the MineLayout of the MineLayout of the Mine

Cross section of the Starter Cell perimeter Cross section of the Starter Cell perimeter embankment. In the initial phase of construction embankment. In the initial phase of construction

the embankment was raised by downstream the embankment was raised by downstream methods. This figure show the small methods. This figure show the small bermberm

t t d t i th h i ht f tht t d t i th h i ht f thconstructed to increase the height of the constructed to increase the height of the embankment to enable continued depositionembankment to enable continued deposition

The current configuration of the Starter Cell as of April 7, The current configuration of the Starter Cell as of April 7, 2014 (highest elevation in Phase IV: 487.65m)2014 (highest elevation in Phase IV: 487.65m)

Expansion Scenarios for the Expansion Scenarios for the Starter CellStarter Cell

Scenario 2a would provide an additionalScenario 2a would provide an additional Scenario 2a would provide an additional Scenario 2a would provide an additional approximately 1.5 million mapproximately 1.5 million m33 of capacity and 4.2 of capacity and 4.2 years operational lifeyears operational lifey py p It would involve steepening the outer slope to 2H:1V It would involve steepening the outer slope to 2H:1V

and raising the elevation of the southand raising the elevation of the south--west corner to west corner to 496 m and the elevation of the north496 m and the elevation of the north east corner toeast corner to496 m and the elevation of the north496 m and the elevation of the north--east corner to east corner to approximately 480 m approximately 480 m

Scenario 4a would provide an additionalScenario 4a would provide an additional Scenario 4a would provide an additional Scenario 4a would provide an additional approximately 1 Mm3 capacity and an additional approximately 1 Mm3 capacity and an additional approximately three years of operational lifeapproximately three years of operational life A new cell would be constructed to the east of the A new cell would be constructed to the east of the

current Starter Cell and the East Cellcurrent Starter Cell and the East Cell

Scenario 2a for raising the Starter Cell and Scenario 2a for raising the Starter Cell and t l l i th f ht l l i th f hat closure sloping the surface as shownat closure sloping the surface as shown

Cross sections through the Scenario 2a raised Cross sections through the Scenario 2a raised Starter Cell. Note this would involveStarter Cell. Note this would involveStarter Cell. Note this would involveStarter Cell. Note this would involve

steepening the outer slopessteepening the outer slopes

Scenario 4a for expanding the capacity of the Starter Cell. Scenario 4a for expanding the capacity of the Starter Cell. A new cell would be constructed to the east of the current A new cell would be constructed to the east of the current

Starter Cell and the East CellStarter Cell and the East Cell

Expansion Scenario for the Expansion Scenario for the Starter CellStarter Cell

The expansion would provide an additionalThe expansion would provide an additional The expansion would provide an additional The expansion would provide an additional approximately 2.4 Mm3 of capacity and approximately 2.4 Mm3 of capacity and 5 3 years operational life5 3 years operational life5.3 years operational life5.3 years operational life It would involve steepening the outer slope to It would involve steepening the outer slope to

2H:1V and raising the elevation of the2H:1V and raising the elevation of the2H:1V and raising the elevation of the 2H:1V and raising the elevation of the southwest corner to, on about 496 m at the southwest corner to, on about 496 m at the west side and about 488 m at the east side of west side and about 488 m at the east side of the expanded East Cellthe expanded East Cell

Scenario 2 for expanding the Scenario 2 for expanding the capacity of the East Cellcapacity of the East Cell

General area of the General area of the West CellWest Cell. Note: the pink shading is the . Note: the pink shading is the previously proposed cell footprint; the light blue shading is previously proposed cell footprint; the light blue shading is

additional area that may be required for cell development for life of additional area that may be required for cell development for life of add t o a a ea t at ay be equ ed o ce de e op e t o e oadd t o a a ea t at ay be equ ed o ce de e op e t o e omine; the dark blue shading denotes lakes that may be affected mine; the dark blue shading denotes lakes that may be affected

by cell development; and the green shading denotes existing by cell development; and the green shading denotes existing infrastructure to be affected by cell developmentinfrastructure to be affected by cell developmentinfrastructure to be affected by cell developmentinfrastructure to be affected by cell development

The ultimate layout of the The ultimate layout of the largest possible West Celllargest possible West Celllargest possible West Celllargest possible West Cell

Closure Scenario 1 LayoutClosure Scenario 1 LayoutClosure Scenario 1 LayoutClosure Scenario 1 Layout

Closure Scenario 2 LayoutClosure Scenario 2 LayoutClosure Scenario 2 LayoutClosure Scenario 2 Layout

Comments from the Comments from the Environmental AnalystEnvironmental Analyst

The document is helpful for stakeholdersThe document is helpful for stakeholders The document is helpful for stakeholders The document is helpful for stakeholders to understand the current design and to understand the current design and operation of the North Pile and theoperation of the North Pile and theoperation of the North Pile, and the operation of the North Pile, and the alternatives for construction of a new West alternatives for construction of a new West Cell expansion of the Starter and EastCell expansion of the Starter and EastCell, expansion of the Starter and East Cell, expansion of the Starter and East Cells, and scenarios for closure of the Cells, and scenarios for closure of the North PileNorth PileNorth PileNorth Pile

8. Water 8. Water LicenceLicence Amendment Amendment Application Application –– EA StageEA Stage

Closing CommentsClosing CommentsClosing CommentsClosing Comments

8 1 Closing Comments8 1 Closing Comments8.1 Closing Comments8.1 Closing Comments

DKFN submitted on July 3 2014DKFN submitted on July 3 2014DKFN submitted on July 3, 2014DKFN submitted on July 3, 2014 LKDFN submitted on July 4, 2014LKDFN submitted on July 4, 2014 EC submitted on July 4, 2014 EC submitted on July 4, 2014 GNWT submitted on July 7, 2014GNWT submitted on July 7, 2014De Beers submitted on July 8, 2014De Beers submitted on July 8, 2014

8.1.1 DKFN’s Closing 8.1.1 DKFN’s Closing Comments Comments

“We continue to be disappointed that over a“We continue to be disappointed that over a We continue to be disappointed that over a We continue to be disappointed that over a decade of monitoring has been conducted at decade of monitoring has been conducted at Snap Lake and the issues of increased levels of Snap Lake and the issues of increased levels of ppTDS continues to be forefront. De Beers has had TDS continues to be forefront. De Beers has had multiple opportunities to demonstrate effective multiple opportunities to demonstrate effective

i t l t d hi b t h f il d t di t l t d hi b t h f il d t denvironmental stewardship but has failed to do environmental stewardship but has failed to do so. We are concerned that based on the current so. We are concerned that based on the current actions and commitments by De Beers that thisactions and commitments by De Beers that thisactions and commitments by De Beers that this actions and commitments by De Beers that this issues will continue for the life of the mine”issues will continue for the life of the mine”

8.1.2 LKDFN’s Closing 8.1.2 LKDFN’s Closing Comments Comments

“In general we hope the Board enforces“In general we hope the Board enforces In general we hope the Board enforces In general we hope the Board enforces mitigation and treatment measures on the mitigation and treatment measures on the company instead of the alternative of increasing company instead of the alternative of increasing p y gp y gdischarge limits into the lake. This is discharge limits into the lake. This is precautionary practice mentality and the proper precautionary practice mentality and the proper

t h t ti f th l d dt h t ti f th l d dway to approach protection of the land and way to approach protection of the land and water. The way that is proposed water. The way that is proposed -- set a limit and set a limit and fill the lake with effluent up to that limitfill the lake with effluent up to that limit is not ais not afill the lake with effluent up to that limit fill the lake with effluent up to that limit –– is not a is not a suitable approach for this environment, and not suitable approach for this environment, and not one that is supported by the one that is supported by the LutselLutsel K’eK’e DeneDenepp ypp yFirst Nation”First Nation”

8 1 3 EC’s Closing Comments8 1 3 EC’s Closing Comments8.1.3 EC s Closing Comments 8.1.3 EC s Closing Comments

“EC’s comments and recommendations are in“EC’s comments and recommendations are in EC s comments and recommendations are in EC s comments and recommendations are in no way to be interpreted as any type of no way to be interpreted as any type of acknowledge, compliance, permission, approval, acknowledge, compliance, permission, approval, g p p ppg p p ppauthorization, or release of liability related to any authorization, or release of liability related to any requirements to comply with federal or territorial requirements to comply with federal or territorial t t t d l ti R ibilit ft t t d l ti R ibilit fstatutes and regulations. Responsibility for statutes and regulations. Responsibility for

achieving regulatory compliance and cost achieving regulatory compliance and cost effective risk and liability reduction lies solelyeffective risk and liability reduction lies solelyeffective risk and liability reduction lies solely effective risk and liability reduction lies solely with the project proponent”with the project proponent”

EC Made further clarifications regarding theEC Made further clarifications regarding the EC Made further clarifications regarding the EC Made further clarifications regarding the additional toxicity test data supporting the additional toxicity test data supporting the proposed SSWQO of 684 mg/L proposed SSWQO of 684 mg/L

8.1.4 GNWT’s Closing 8.1.4 GNWT’s Closing Comments (I)Comments (I)

“GNWT has recommended and continues to“GNWT has recommended and continues to GNWT has recommended and continues to GNWT has recommended and continues to recommend that the Review Board determine recommend that the Review Board determine significance, and recommend measures, significance, and recommend measures, ggaccording to a traditional use standardaccording to a traditional use standard””

“The GNWT emphasizes that the developer has “The GNWT emphasizes that the developer has not made clear in its evidence to the Review not made clear in its evidence to the Review Board how it will achieve any levels short of the Board how it will achieve any levels short of the

iti t d i d th t th d liti t d i d th t th d lunmitigated scenario, and that the developer unmitigated scenario, and that the developer has not committed has not committed titi any specific mitigation”any specific mitigation”

8.1.4 GNWT’s Closing 8.1.4 GNWT’s Closing Comments (II)Comments (II)

“To be clear recent guidelines were specially“To be clear recent guidelines were specially To be clear, recent guidelines were specially To be clear, recent guidelines were specially developed to ensure that all forms of aquatic life developed to ensure that all forms of aquatic life cycles, including the most sensitive life stage of cycles, including the most sensitive life stage of y g gy g gthe most sensitive species over the long term re the most sensitive species over the long term re protected”protected”

“Where the GNWT agrees with De Beers that “Where the GNWT agrees with De Beers that water in Snap Lake needs to be safe to drink water in Snap Lake needs to be safe to drink

d th fi h f t t dditi l t ti id th fi h f t t dditi l t ti iand the fish safe to eat, additional protection is and the fish safe to eat, additional protection is also necessaryalso necessary To respect and protect the traditional uses of SnapTo respect and protect the traditional uses of Snap To respect and protect the traditional uses of Snap To respect and protect the traditional uses of Snap

Lake and downstream watersLake and downstream waters

8.1.4 GNWT’s Closing 8.1.4 GNWT’s Closing Comments (III)Comments (III)

A significant amount of uncertainty exists regarding theA significant amount of uncertainty exists regarding the A significant amount of uncertainty exists regarding the A significant amount of uncertainty exists regarding the ameliorating effects of hardness and the behavior of ameliorating effects of hardness and the behavior of hardness and other parameters posthardness and other parameters post--closureclosureA f t f t f 1 0 d t id dditi t tiA f t f t f 1 0 d t id dditi t ti A safety factor of 1.0 does not provide additive protectionA safety factor of 1.0 does not provide additive protection

There are discrepancies between De Beers and the There are discrepancies between De Beers and the GNWT in the baseline and the predicted spatial extent ofGNWT in the baseline and the predicted spatial extent ofGNWT in the baseline and the predicted spatial extent of GNWT in the baseline and the predicted spatial extent of impact. The GNWT will continue to work with DE Beers impact. The GNWT will continue to work with DE Beers in this area as required to ensure baseline values are in this area as required to ensure baseline values are both adequate and appropriate for the detection ofboth adequate and appropriate for the detection ofboth adequate and appropriate for the detection of both adequate and appropriate for the detection of change and impacts from the Snap Lake developmentchange and impacts from the Snap Lake development

8.1.5 De Beers’ Closing 8.1.5 De Beers’ Closing Statements (I)Statements (I)

De Beers’ evidence demonstrates thatDe Beers’ evidence demonstrates thatDe Beers evidence demonstrates that De Beers evidence demonstrates that there will not be significant adverse there will not be significant adverse impacts to the environment at TDSimpacts to the environment at TDSimpacts to the environment at TDS impacts to the environment at TDS concentrations in Snap Lake of at least concentrations in Snap Lake of at least 684 mg/L and likely as high as 1 000684 mg/L and likely as high as 1 000684 mg/L, and likely as high as 1,000 684 mg/L, and likely as high as 1,000 mg/L. The water will remain safe to drink, mg/L. The water will remain safe to drink, the fish will be safe to eat and thethe fish will be safe to eat and thethe fish will be safe to eat, and the the fish will be safe to eat, and the ecosystem function of Snap Lake will be ecosystem function of Snap Lake will be maintainedmaintainedmaintainedmaintained

8.1.5 De Beers’ Closing 8.1.5 De Beers’ Closing Statements (II)Statements (II)

The Proposed SSWQOs are ConservativeThe Proposed SSWQOs are Conservative The Proposed SSWQOs are Conservative The Proposed SSWQOs are Conservative and Technically Defensibleand Technically Defensible

De Beers could apply the necessaryDe Beers could apply the necessaryDe Beers could apply the necessary De Beers could apply the necessary treatment at the water intake (SNP 02treatment at the water intake (SNP 02--15) 15) to mitigate potential aesthetic (taste)to mitigate potential aesthetic (taste)to mitigate potential aesthetic (taste) to mitigate potential aesthetic (taste) concerns, but such mitigation is not concerns, but such mitigation is not necessary for Snap Lake as a whole Thenecessary for Snap Lake as a whole Thenecessary for Snap Lake as a whole. The necessary for Snap Lake as a whole. The water is, and will remain, safe to drinkwater is, and will remain, safe to drink

8.1.5 De Beers’ Closing 8.1.5 De Beers’ Closing Statements (III)Statements (III)

De Beers has committed to implementing mitigation toDe Beers has committed to implementing mitigation to De Beers has committed to implementing mitigation to De Beers has committed to implementing mitigation to reduce TDS loadings to Snap Lake. De Beers is actively reduce TDS loadings to Snap Lake. De Beers is actively evaluating technologies, including focused grouting and evaluating technologies, including focused grouting and potential treatment technologies that could be employedpotential treatment technologies that could be employedpotential treatment technologies that could be employed potential treatment technologies that could be employed to meet a SSWQO that is protective of the environmentto meet a SSWQO that is protective of the environment

De Beers has committed to implementing additional De Beers has committed to implementing additional p gp gmonitoring at the inlet to Mackay Lake, as part of the monitoring at the inlet to Mackay Lake, as part of the AEMP, in order to verify predictions that changes to AEMP, in order to verify predictions that changes to water quality due to Snap Lake Mine discharge of TDSwater quality due to Snap Lake Mine discharge of TDSwater quality due to Snap Lake Mine discharge of TDS water quality due to Snap Lake Mine discharge of TDS will not be measurable beyond 44 km downstream of will not be measurable beyond 44 km downstream of Snap LakeSnap Lake

8.1.5 De Beers’ Closing 8.1.5 De Beers’ Closing Statements (IV)Statements (IV)Statements (IV)Statements (IV)

De Beers suggests that recommendations arising out of this De Beers suggests that recommendations arising out of this i t l t ld b f lli t l t ld b f llenvironmental assessment could be as follows: environmental assessment could be as follows:

To prevent significant adverse impacts to the environment from ongoing To prevent significant adverse impacts to the environment from ongoing discharge of TDS and its constituent ions chloride, discharge of TDS and its constituent ions chloride, sulphatesulphate, fluoride, and , fluoride, and it t f S L k Mi t th i i i t th MVLWBit t f S L k Mi t th i i i t th MVLWBnitrate from Snap Lake Mine to the receiving environment, the MVLWB nitrate from Snap Lake Mine to the receiving environment, the MVLWB

will establish appropriately protective and reasonably achievable sitewill establish appropriately protective and reasonably achievable site--specific water quality objective(s) for these parameters that are based on specific water quality objective(s) for these parameters that are based on toxicity studies completed by De Beers and other relevant evidencetoxicity studies completed by De Beers and other relevant evidencetoxicity studies completed by De Beers, and other relevant evidence toxicity studies completed by De Beers, and other relevant evidence provided by parties to this environmental assessment and the provided by parties to this environmental assessment and the subsequent water subsequent water licencelicence amendment process. amendment process. De Beers will present the results of a preliminary evaluation of bestDe Beers will present the results of a preliminary evaluation of best De Beers will present the results of a preliminary evaluation of best De Beers will present the results of a preliminary evaluation of best applicable technologies that are economically achievable for Snap Lake applicable technologies that are economically achievable for Snap Lake Mine for consideration by the MVLWB, regulators, and communities, in Mine for consideration by the MVLWB, regulators, and communities, in the establishment of appropriate SSWQOs and EQC for TDSthe establishment of appropriate SSWQOs and EQC for TDSthe establishment of appropriate SSWQOs and EQC for TDSthe establishment of appropriate SSWQOs and EQC for TDS