November 2014November 2014November 2014November 2014Environmental Update Environmental Update pp

for SLEMA Boardfor SLEMA BoardZh LiZh LiZhong LiuZhong Liu

November 30, 2014November 30, 2014

HighlightsHighlightsHighlights Highlights De Beers, on November 12, 2014, filed an AmendmentDe Beers, on November 12, 2014, filed an Amendment De Beers, on November 12, 2014, filed an Amendment De Beers, on November 12, 2014, filed an Amendment

Application for interim limits related to TDSApplication for interim limits related to TDS Interim TDS EQC: 850 mg/L,Interim TDS EQC: 850 mg/L, inclusive of chloride, from January inclusive of chloride, from January

1 to December 31 20151 to December 31 20151 to December 31, 20151 to December 31, 2015 To remove requirement to maintain wholeTo remove requirement to maintain whole--lake average TDS lake average TDS

concentration below 350 mg/L at all timesconcentration below 350 mg/L at all times

Th d d t i t iTh d d t i t i The proposed amendments are necessary as an interim The proposed amendments are necessary as an interim measure to allow continued operations by De Beers at measure to allow continued operations by De Beers at the Snap Lake mine until the conclusion of the separate the Snap Lake mine until the conclusion of the separate p pp pregulatory process that follows Environmental regulatory process that follows Environmental Assessment (EA) 1314Assessment (EA) 1314--02. However, it is impossible to 02. However, it is impossible to allow for a reasonable and fair review process and forallow for a reasonable and fair review process and forallow for a reasonable and fair review process and for allow for a reasonable and fair review process and for the MVLWB to make a decision by December 31, 2014the MVLWB to make a decision by December 31, 2014

De Beers’ Compliance Problems in 2015De Beers’ Compliance Problems in 2015

1200

Water Quality Prediction of Snap Lake

1000

mg/

L

Observed ValueSLEMA ModelWTP Effluent

Water Quality Objective 350

600

800

cent

ratio

n, Water Quality Objective, 350

400

TDS

Con

c

Correlation co-efficient:

0

200 Assumed discharge amount and concentration: 1.4 M m3/month, 650 mg/L

0.990

Jun-

04

Jun-

05

Jun-

06

Jun-

07

Jun-

08

Jun-

09

Jun-

10

Jun-

11

Jun-

12

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13

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14

Jun-

15

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16

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17

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18

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19

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20

Jun-

21

Jun-

22

Jun-

23

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24

Jun-

25

Jun-

26

Jun-

27

Jun-

28

Month

400

TDS Levels in Snap Lake

350

250

300

on, m

g/L

200

once

ntra

tio SNP 02-20

SNP 02-18

100

150Co

0

50

0Sep-02 Jan-04 May-05 Oct-06 Feb-08 Jul-09 Nov-10 Apr-12 Aug-13 Dec-14 May-16

Month

Comments from the Comments from the E i t l A l tE i t l A l tEnvironmental AnalystEnvironmental Analyst

Based the TDS prediction and the TDS Based the TDS prediction and the TDS exceedanceexceedance in in May 2014, the whole lake average of TDS will exceed May 2014, the whole lake average of TDS will exceed the water licence limit (350 mg/L) again in 2015 and in the water licence limit (350 mg/L) again in 2015 and in the icethe ice--cover season of the following yearscover season of the following yearsg yg y

If the TDS If the TDS exceedanceexceedance occurs in January 2015, it will be occurs in January 2015, it will be reoccurring till the end of ice cover season of 2015. That reoccurring till the end of ice cover season of 2015. That

ill b i t th W t Li MV2011L2ill b i t th W t Li MV2011L2 0004 P t0004 P twill be against the Water Licence MV2011L2will be against the Water Licence MV2011L2--0004, Part 0004, Part F, Item 13F, Item 13 The calculated whole lake average of total dissolved solids The calculated whole lake average of total dissolved solids

(TDS), (as described in the Surveillance Network Program) at (TDS), (as described in the Surveillance Network Program) at sampling locations comprising Surveillance Network Program sampling locations comprising Surveillance Network Program Station Number 02Station Number 02--18 shall 18 shall remain below 350 mg/L remain below 350 mg/L at all timesat all times

De Beers is requested to demonstrate its compliance De Beers is requested to demonstrate its compliance with the Water Licence MV2011L2with the Water Licence MV2011L2--0004, Part F, Item 130004, Part F, Item 13

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) AEMPAEMP Aquatic Effects Monitoring ProgramAquatic Effects Monitoring Program AEMP AEMP –– Aquatic Effects Monitoring ProgramAquatic Effects Monitoring Program ARD ARD –– Acid Rock DrainageAcid Rock Drainage CanNorCanNor –– Canadian Northern Economic Development AgencyCanadian Northern Economic Development Agency DFODFO –– Fisheries and Oceans CanadaFisheries and Oceans Canada 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 ITI ITI –– Department of Industry, Tourism and Investment, GNWTDepartment of Industry, Tourism and Investment, GNWT 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 SNP SNP –– Surveillance Network ProgramSurveillance Network Program TDS TDS –– Total Dissolved SolidsTotal Dissolved Solids WEMPWEMP Wildlif Eff t M it i PWildlif Eff t M it i P WEMP WEMP –– Wildlife Effects Monitoring ProgramWildlife Effects Monitoring Program WTP WTP –– Water Treatment PlantWater Treatment Plant WMP WMP –– Water Management PondWater Management Pond

1.1 Mine Update1.1 Mine Update –– October 2014October 20141.1 Mine Update 1.1 Mine Update October 2014October 2014 Production rateProduction rate: : 107.9% 107.9% of its capacity (105,384 of its capacity (105,384 tonnestonnes

of of kimberlitekimberlite processed)processed)26 58826 588 33 f t ithd f S L kf t ithd f S L k 26,588 m26,588 m33 of water withdrawn from Snap Lakeof water withdrawn from Snap Lake Additional water has been withdrawn from Snap Lake since Additional water has been withdrawn from Snap Lake since

September 2014 to test various pump, flow and water treatment September 2014 to test various pump, flow and water treatment configurationsconfigurationsconfigurationsconfigurations

1,492273 m1,492273 m33 of treated water discharged into Snap Lakeof treated water discharged into Snap Lake 83,371 83,371 tonnestonnes of coarse reject and 56,431 mof coarse reject and 56,431 m33 of slimes of slimes

deposited in the North Piledeposited in the North Pile one reportable spillone reportable spill

200 L of slimes was spilled into the North Pile ditch and200 L of slimes was spilled into the North Pile ditch and 200 L of slimes was spilled into the North Pile ditch and 200 L of slimes was spilled into the North Pile ditch and roadwayroadway

Water sampled in 9 monitoring stations Water sampled in 9 monitoring stations The monthly average for all parameters met complianceThe monthly average for all parameters met compliance The monthly average for all parameters met complianceThe monthly average for all parameters met compliance

1.2 Follow1.2 Follow--Up Report Up Report on Spill on Spill R #14R #14 392392Report #14Report #14--392392

On October 26 2014 the line that directsOn October 26 2014 the line that directs On October 26, 2014, the line that directs On October 26, 2014, the line that directs thickened slurry to the North Pile ruptured. thickened slurry to the North Pile ruptured. Approximately 0.20 cubic meters of slimes was Approximately 0.20 cubic meters of slimes was pp ypp yspilled into the ditch and roadwayspilled into the ditch and roadway

The spilled slurry was frozen in place and the The spilled slurry was frozen in place and the operations team were able to scrape the operations team were able to scrape the material from the ditch and surrounding area material from the ditch and surrounding area

d d it t th N th Pild d it t th N th Piland deposit to the North Pile and deposit to the North Pile The corrective action for this incident was to The corrective action for this incident was to

replace the pipe fitting and line replacement forreplace the pipe fitting and line replacement forreplace the pipe fitting and line replacement for replace the pipe fitting and line replacement for the worn section the worn section

1 3 Notice of Construction1 3 Notice of Construction1.3 Notice of Construction 1.3 Notice of Construction

EE--mail dated October 29 2014mail dated October 29 2014 EE--mail dated October 29, 2014mail dated October 29, 2014 Addressed to the Inspector and the MVLWBAddressed to the Inspector and the MVLWB

Provided 48Provided 48 hour prior notification ofhour prior notification of Provided 48Provided 48 hour prior notification of hour prior notification of commencement of construction activities commencement of construction activities associated with the West Cellassociated with the West Cellassociated with the West Cell associated with the West Cell

1.4 2014 Geotechnical Inspection 1.4 2014 Geotechnical Inspection f N h Pil d WMP Df N h Pil d WMP Dof North Pile and WMP Dams of North Pile and WMP Dams

Letter dated November 12 2014Letter dated November 12 2014 Letter dated November 12, 2014Letter dated November 12, 2014De Beers conducted the annual De Beers conducted the annual

Geotechnical field inspection throughGeotechnical field inspection throughGeotechnical field inspection through Geotechnical field inspection through GolderGolder and Associates Ltd. during the and Associates Ltd. during the week of September 8 2014week of September 8 2014week of September 8, 2014week of September 8, 2014 Presented a revision of the findings from 2013 Presented a revision of the findings from 2013

as requested by the MVLWB and a summaryas requested by the MVLWB and a summaryas requested by the MVLWB, and a summary as requested by the MVLWB, and a summary of the 2014 inspection recommendationsof the 2014 inspection recommendations

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

AANDC Inspector AANDC Inspector –– Jamie SteeleJamie SteeleppWater Water LicenceLicence InspectionInspection

October 29 and 30 2014October 29 and 30 2014 October 29 and 30, 2014October 29 and 30, 2014

2 1 Water2 1 Water LicenceLicence InspectionInspection2.1 Water 2.1 Water LicenceLicence InspectionInspection Inspection on October 29 and 30, 2014, and report dated Inspection on October 29 and 30, 2014, and report dated

November 24November 24November 24November 24 Inspected fuel storage, explosive storage, the North Pile, Inspected fuel storage, explosive storage, the North Pile,

water management, and waste managementwater management, and waste management “The primary focus of this inspection was to follow up on “The primary focus of this inspection was to follow up on

items noted in the previous inspection dated September items noted in the previous inspection dated September 10th 2014 where several issues were identified around10th 2014 where several issues were identified around10th 2014 where several issues were identified around 10th 2014 where several issues were identified around fuel management and storage. This inspection has noted fuel management and storage. This inspection has noted significant improvements in these areas, and all concerns significant improvements in these areas, and all concerns noted in the previous inspection have been addressed”noted in the previous inspection have been addressed”noted in the previous inspection have been addressed”noted in the previous inspection have been addressed”

Building 31 Fuel Farm Unloading Module Building 31 Fuel Farm Unloading Module –– New permanent New permanent containment structure has been built to replace the cutoff drums and containment structure has been built to replace the cutoff drums and

plastic pails that were being used for containment at the refuelingplastic pails that were being used for containment at the refuelingplastic pails that were being used for containment at the refueling plastic pails that were being used for containment at the refueling station. The area was clean with no staining or evidence of fuel spillsstation. The area was clean with no staining or evidence of fuel spills

Spill kit in the area was easily Spill kit in the area was easily accessible and fully stockedaccessible and fully stockedaccessible and fully stockedaccessible and fully stocked

300,000L Tank Farm 300,000L Tank Farm –– Calibration tubes have been removed from the Calibration tubes have been removed from the bleeder valve assemblies on all the 300,000L tanks. Drip trays have bleeder valve assemblies on all the 300,000L tanks. Drip trays have been placed under the valves to catch any drips or leaks. The drip been placed under the valves to catch any drips or leaks. The drip

trays did contain some hydrocarbon residue on nearly all the tanks. trays did contain some hydrocarbon residue on nearly all the tanks. There did not appear to be an active leak coming from the valves. The There did not appear to be an active leak coming from the valves. The

drip trays will need to be cleaned out and the valves inspected to drip trays will need to be cleaned out and the valves inspected to ffdetermine if there is a problemdetermine if there is a problem

Burn pile contained inert combustible materialBurn pile contained inert combustible materialBurn pile contained inert combustible materialBurn pile contained inert combustible material

Waste Management Waste Management LaydownLaydown –– The yard was very neat The yard was very neat and organized. Waste was properly labeled and being and organized. Waste was properly labeled and being g p p y gg p p y g

staged for transportation off sitestaged for transportation off site

Location of NTLocation of NT‐‐NU Spill # 14NU Spill # 14‐‐392. A leak in the paste 392. A leak in the paste line to the north pile spilled 200L of Processed line to the north pile spilled 200L of Processed

Ki b litKi b lit Sli Th l k i d d lSli Th l k i d d lKimberliteKimberlite Slimes. The leak was repaired and cleanSlimes. The leak was repaired and clean‐‐up up was complete and verified by the inspectorwas complete and verified by the inspector

North PileNorth Pile –– View of Starter Cell facing southView of Starter Cell facing southNorth Pile North Pile View of Starter Cell facing southView of Starter Cell facing south

North PileNorth Pile –– View of East Cell constructionView of East Cell constructionNorth Pile North Pile View of East Cell constructionView of East Cell construction

North Pile North Pile –– Overview of the location for Overview of the location for th d W t C ll t tith d W t C ll t tithe approved West Cell constructionthe approved West Cell construction

Temporary Sump 4 Temporary Sump 4 –– Water level is low Water level is low ith l t f itith l t f itwith plenty of reserve capacitywith plenty of reserve capacity

The landfill waste was well contained and The landfill waste was well contained and i di t d t b di di t d t b dno misdirected waste was observedno misdirected waste was observed

Water Management Pond Water Management Pond –– Some seepage from the Water Some seepage from the Water Management Pond has been reported. DeBeers Canada has Management Pond has been reported. DeBeers Canada has

installed a network of installed a network of piezometerspiezometers to try and detect the areas that to try and detect the areas that pp yyare seeping. Routine checks of the are seeping. Routine checks of the piezometerspiezometers are not showing are not showing

any water so the location of the seepage remains unknownany water so the location of the seepage remains unknown

Emulsion Plant Emulsion Plant –– Chemicals in the shop area of the Chemicals in the shop area of the Emulsion plant were stored within a containment tray Emulsion plant were stored within a containment tray p yp y

to prevent spills on the shop floorto prevent spills on the shop floor

Emulsion Plant Emulsion Plant –– Shop area within the facility has an evaporator to Shop area within the facility has an evaporator to handle waste from the shop sumps and tanks. Waste water handle waste from the shop sumps and tanks. Waste water

contaminated with Ammonium Nitrate (AN) is sent to the evaporator contaminated with Ammonium Nitrate (AN) is sent to the evaporator where the clean water is evaporated off while the AN concentrate iswhere the clean water is evaporated off while the AN concentrate iswhere the clean water is evaporated off while the AN concentrate is where the clean water is evaporated off while the AN concentrate is collected as waste and shipped off site. This process eliminates the collected as waste and shipped off site. This process eliminates the

waste AN from entering the water management systemwaste AN from entering the water management system

Ammonium Nitrate (AN) Building Ammonium Nitrate (AN) Building –– Bulk AN Bulk AN t i d ith id ft i d ith id fwas contained with ne evidence of seepagewas contained with ne evidence of seepage

Water World Storage Building 53 Water World Storage Building 53 –– FollowFollow up up from previous inspection showed that fuel from previous inspection showed that fuel

ill h d b l d d l kiill h d b l d d l kispills had been cleaned up and leaking spills had been cleaned up and leaking equipment had been removedequipment had been removed

Water World Storage Building 53 Water World Storage Building 53 –– Building is Building is heated with waste oil. This photo shows the wasteheated with waste oil. This photo shows the wasteheated with waste oil. This photo shows the waste heated with waste oil. This photo shows the waste

oil heater connected to a 1 M3 tote of waste oiloil heater connected to a 1 M3 tote of waste oil

3 Regulators’ Update3 Regulators’ Update –– MVLWBMVLWB3. Regulators Update 3. Regulators Update MVLWB MVLWB Approved the Water Management Plan Approved the Water Management Plan

conditionally on November 20 2014conditionally on November 20 2014conditionally on November 20, 2014conditionally on November 20, 2014

4 Aboriginal Update4 Aboriginal Update4. Aboriginal Update4. Aboriginal Update

No comments received in November 2014No comments received in November 2014No comments received in November 2014No comments received in November 2014

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

No comments received in November 2014No comments received in November 2014No comments received in November 2014No comments received in November 2014

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

SLEMA Executive Meeting held on NovemberSLEMA Executive Meeting held on November SLEMA Executive Meeting held on November SLEMA Executive Meeting held on November 17, 201417, 2014

SLEMA, together with two other sister agenciesSLEMA, together with two other sister agencies SLEMA, together with two other sister agencies SLEMA, together with two other sister agencies (IEMA and EMAB), attended the 2014 Geo(IEMA and EMAB), attended the 2014 Geo--Science Forum and presented itself in the Trade Science Forum and presented itself in the Trade Show from November 25 to 27Show from November 25 to 27

Two comment letters sent out on November 27Two comment letters sent out on November 27 To ENR: EAAR 2013To ENR: EAAR 2013 To De Beers: SLEMA Modeling UpdateTo De Beers: SLEMA Modeling Update

2014 Geo2014 Geo--Science ForumScience Forum

7 SLEMA Reviews7 SLEMA Reviews7. SLEMA Reviews7. SLEMA Reviews

2013 Environmental Agreement Annual Report 2013 Environmental Agreement Annual Report 2014 Geotechnical Inspection of North Pile and

WMP DamsWMP Dams

7.1 2013 Environmental Agreement Annual Report

The Annual Report summarizes theThe Annual Report summarizes the The Annual Report summarizes the The Annual Report summarizes the monitoring activities and results for 2013monitoring activities and results for 2013

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

De Beers reported theDe Beers reported the exceedanceexceedance of Chlorideof Chloride De Beers reported the De Beers reported the exceedanceexceedance of Chloride, of Chloride, which occurred in September and October 2013, which occurred in September and October 2013, in Table 2in Table 2--1 (page 7) and Section 4.1.10 (page 1 (page 7) and Section 4.1.10 (page (p g ) (p g(p g ) (p g60), but did not mention it in Section 5 60), but did not mention it in Section 5 (Summary of Compliance), Section 7 (Summary (Summary of Compliance), Section 7 (Summary

ff Miti tiMiti ti M ) d S ti 9M ) d S ti 9of of MitigativeMitigative Measures), and Section 9 Measures), and Section 9 (Summary of Public Concerns)(Summary of Public Concerns)

ThTh dd t it i lili The The exceedanceexceedance event is a nonevent is a non--compliance compliance against the Water against the Water LicenceLicence, Part F Item 9, and , Part F Item 9, and should be reported in detail in Sections 5 7 andshould be reported in detail in Sections 5 7 andshould be reported in detail in Sections 5, 7 and should be reported in detail in Sections 5, 7 and 9 , even if De Beers were able to re9 , even if De Beers were able to re--establish establish compliance in a timely fashioncompliance in a timely fashion

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

There is one statement aboutThere is one statement about MitigativeMitigative There is one statement about There is one statement about MitigativeMitigativeMeasures in the Executive Summary that Measures in the Executive Summary that “The AEMP annual report demonstrates that the Snap “The AEMP annual report demonstrates that the Snap p pp p

Lake Mine’s impact is similar to what was predicted in Lake Mine’s impact is similar to what was predicted in the Environmental Assessment. the Environmental Assessment. This demonstrates This demonstrates that thethat the mitigativemitigative measures being used by De Beersmeasures being used by De Beersthat the that the mitigativemitigative measures being used by De Beers measures being used by De Beers are working effectivelyare working effectively. Two response Framework . Two response Framework levels were triggered in the 2013 AEMP. Response levels were triggered in the 2013 AEMP. Response Pl l b itt d i 2013 f TDS St tiPl l b itt d i 2013 f TDS St tiPlans re also submitted in 2013 for TDS, Strontium Plans re also submitted in 2013 for TDS, Strontium and Nitrogen. and Nitrogen. A Water License Amendment request A Water License Amendment request was submitted in December 2013 to change water was submitted in December 2013 to change water gglicense effluent quality criteria for Total dissolved license effluent quality criteria for Total dissolved solids and its constituent ionssolids and its constituent ions.”.”

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

The two underlined sentences appear toThe two underlined sentences appear to The two underlined sentences appear to The two underlined sentences appear to be conflictingbe conflicting

IfIf mitigativemitigative measures were effective Demeasures were effective De If If mitigativemitigative measures were effective, De measures were effective, De Beers would not have had to request to Beers would not have had to request to amend the wateramend the water licencelicence limits in Decemberlimits in Decemberamend the water amend the water licencelicence limits in December limits in December 20132013

De Beers improved the report presentationDe Beers improved the report presentationDe Beers improved the report presentation De Beers improved the report presentation by adding three photos of the North Pile by adding three photos of the North Pile showing the changes from 2011 to 2013showing the changes from 2011 to 2013showing the changes from 2011 to 2013showing the changes from 2011 to 2013

7.2 2014 Geotechnical Inspection 7.2 2014 Geotechnical Inspection f N h Pil d WMP Df N h Pil d WMP Dof North Pile and WMP Damsof North Pile and WMP Dams

De Beers conducted the annualDe Beers conducted the annualDe Beers conducted the annual De Beers conducted the annual Geotechnical field inspection through Geotechnical field inspection through GolderGolder and Associates Ltd (and Associates Ltd (GolderGolder))GolderGolder and Associates Ltd. (and Associates Ltd. (GolderGolder) ) during the week of September 8, 2014 during the week of September 8, 2014

De Beers responded to GAL’sDe Beers responded to GAL’sDe Beers responded to GAL’s De Beers responded to GAL’s recommendations in 2013 and 2014 on recommendations in 2013 and 2014 on November 12November 12November 12November 12 Addressed 2013 Inspection recommendationsAddressed 2013 Inspection recommendations

Pl d dd 2014 I iPl d dd 2014 I i Planned to address 2014 Inspection Planned to address 2014 Inspection recommendationsrecommendations

2014 Field Geotechnical 2014 Field Geotechnical InspectionInspection

Technical memorandum prepared byTechnical memorandum prepared by Technical memorandum prepared by Technical memorandum prepared by GolderGolder on September 26, 2014on September 26, 2014

Field inspection performed betweenField inspection performed between Field inspection performed between Field inspection performed between September 8 and 11September 8 and 11

Summarized the key issues and observationsSummarized the key issues and observations Summarized the key issues and observationsSummarized the key issues and observations Presented geotechnical recommendationsPresented geotechnical recommendations

Observations (I)Observations (I)Observations (I)Observations (I)

Key AchievementKey Achievement Key AchievementKey Achievement De Beers has fully formed its De Beers has fully formed its geotechnical teamgeotechnical team, ,

which will oversee the North Pile development and which will oversee the North Pile development and WMP dams WMP dams

De Beers water management is in keeping with De Beers water management is in keeping with th d i i t t d ti l i tth d i i t t d ti l i tthe design intent and operational requirements the design intent and operational requirements of the facilitiesof the facilities

All of the active ditches and sumps of the North PileAll of the active ditches and sumps of the North Pile All of the active ditches and sumps of the North Pile All of the active ditches and sumps of the North Pile appeared to be in good condition and operated as per appeared to be in good condition and operated as per the designthe design

WMP water management, and dams 1 and 2 appear WMP water management, and dams 1 and 2 appear to be performing as per the design to be performing as per the design

Observations (II)Observations (II)Observations (II)Observations (II)

In general the North Pile is being developedIn general the North Pile is being developed In general, the North Pile is being developed In general, the North Pile is being developed and operated in general accordance with the and operated in general accordance with the designdesigngg

The survey prism and The survey prism and piezometerpiezometer data are, in data are, in general, collected, managed, and presented general, collected, managed, and presented effectively for geotechnical interpretation; the effectively for geotechnical interpretation; the thermistorthermistor data, however, are not data, however, are not

Recommendations (I)Recommendations (I)Recommendations (I) Recommendations (I) Documentation of the visual inspections of the North PileDocumentation of the visual inspections of the North Pile Documentation of the visual inspections of the North Pile Documentation of the visual inspections of the North Pile

sumps and the WMP should be generated and sumps and the WMP should be generated and maintained on filemaintained on fileF th l i th t l l f P i t S 1F th l i th t l l f P i t S 1 Further lowering the water levels of Perimeter Sump 1 Further lowering the water levels of Perimeter Sump 1 (SP1), SP2, and Temporary Sump 4 (TS) to provide for (SP1), SP2, and Temporary Sump 4 (TS) to provide for additional storage capacity prior to and during the 2015 additional storage capacity prior to and during the 2015 g p y p gg p y p gfreshet, should be consideredfreshet, should be considered

The placement of the erosion protection layer should be The placement of the erosion protection layer should be placed to properly protect the completed embankmentsplaced to properly protect the completed embankmentsplaced to properly protect the completed embankments placed to properly protect the completed embankments and coincidently with embankment construction and coincidently with embankment construction

Recommendations (II)Recommendations (II)Recommendations (II) Recommendations (II) The North Pile operation, maintenance, and surveillanceThe North Pile operation, maintenance, and surveillance The North Pile operation, maintenance, and surveillance The North Pile operation, maintenance, and surveillance

(OMS) manual should be updated immediately and (OMS) manual should be updated immediately and reviewed and, if required, updated annually reviewed and, if required, updated annually D B i ti t t d/ t ti d tD B i ti t t d/ t ti d t De Beers investigate remote and/or automatic data De Beers investigate remote and/or automatic data collection for the collection for the thermistorsthermistors to improve the efficiency to improve the efficiency and accuracy of data collectionand accuracy of data collectionyy

Comments from the Comments from the Environmental AnalystEnvironmental Analyst

No concerns are raisedNo concerns are raisedNo concerns are raisedNo concerns are raised All All GolderGolder recommendations are supportedrecommendations are supported

8. Water 8. Water LicenceLicence Amendment Amendment Application (I)Application (I)

The Minister of Lands responded to NWTMN, The Minister of Lands responded to NWTMN, LKDFN, DKFN about EA1314LKDFN, DKFN about EA1314--02 on November 4, 02 on November 4, 20142014 Full and fair consideration was given to the views Full and fair consideration was given to the views

expressed in their lettersexpressed in their letters De Beers Responded to Submission RequirementDe Beers Responded to Submission Requirement De Beers Responded to Submission Requirement De Beers Responded to Submission Requirement

of Postof Post--EA Package on November 5EA Package on November 5 To submit the requested information byTo submit the requested information by November 28November 28 To submit the requested information by To submit the requested information by November 28November 28

De Beers filed a De Beers filed a separate Water separate Water LicenceLicenceAmendment Application on November 12Amendment Application on November 12pppp

8. Water 8. Water LicenceLicence Amendment Amendment Application (II)Application (II)

MVLWB clarified the three processes currently MVLWB clarified the three processes currently underway for the Snap Lake Mine on November underway for the Snap Lake Mine on November 27, 201427, 2014 Request to change effective dates for effluent limitsRequest to change effective dates for effluent limits November 2014 Amendment Application for interim November 2014 Amendment Application for interim

TDS EQCTDS EQCTDS EQCTDS EQC December 2013 Amendment ApplicationDecember 2013 Amendment Application

De Beers submitted the PostDe Beers submitted the Post--EA Package onEA Package on De Beers submitted the PostDe Beers submitted the Post EA Package on EA Package on November 28November 28

8.1 GNWT’s Position on Developer 8.1 GNWT’s Position on Developer E f d C li (I)E f d C li (I)Enforcement and Compliance (I)Enforcement and Compliance (I)

Stated in the response letter to LKDFN dated NovemberStated in the response letter to LKDFN dated November Stated in the response letter to LKDFN dated November Stated in the response letter to LKDFN dated November 4, 20144, 2014 “The Developer must comply with any terms and conditions of its “The Developer must comply with any terms and conditions of its

licencelicence GNWT staff conduct inspections of the Snap LakeGNWT staff conduct inspections of the Snap Lakelicencelicence, GNWT staff conduct inspections of the Snap Lake , GNWT staff conduct inspections of the Snap Lake Diamond Mine to confirm compliance with water Diamond Mine to confirm compliance with water licencelicence terms terms and conditions. GNWT provides inspection reports to MVLWB and conditions. GNWT provides inspection reports to MVLWB for posting to its public registry. Nonfor posting to its public registry. Non--compliance is an offencecompliance is an offencefor posting to its public registry. Nonfor posting to its public registry. Non compliance is an offence compliance is an offence and subject to penalty. Any offence that continues for more than and subject to penalty. Any offence that continues for more than one day constitutes a separate offence for each day where the one day constitutes a separate offence for each day where the Developer would be liable to fines and punishments. If the Developer would be liable to fines and punishments. If the p pp pDeveloper contravenes a provision of a term or condition of its Developer contravenes a provision of a term or condition of its licencelicence, MVLWB may suspend the , MVLWB may suspend the licencelicence””

8.1 GNWT’s Position on Developer 8.1 GNWT’s Position on Developer E f d C li (II)E f d C li (II)Enforcement and Compliance (II)Enforcement and Compliance (II) “Under the Snap Lake Environmental“Under the Snap Lake Environmental Under the Snap Lake Environmental Under the Snap Lake Environmental

Agreement (the Environmental Agreement), Agreement (the Environmental Agreement), the Developer must also be in compliance the Developer must also be in compliance p pp pwith all its regulatory instruments (including with all its regulatory instruments (including provision of the Environmental Agreement provision of the Environmental Agreement it lf) If th i i t d fi d i thit lf) If th i i t d fi d i thitself). If the minister, as defined in the itself). If the minister, as defined in the Environmental Agreement, determines the Environmental Agreement, determines the Developer is in nonDeveloper is in non compliance they cancompliance they canDeveloper is in nonDeveloper is in non--compliance, they can compliance, they can issue a minister’s report”issue a minister’s report”

8.2 November 2014 Water 8.2 November 2014 Water LicenceLicenceAmendment Application (I)Amendment Application (I)Amendment Application (I)Amendment Application (I)

De Beers submitted an application to amend its water De Beers submitted an application to amend its water licencelicence on November 12, 2014on November 12, 2014

The MVLWB requested De Beers to submit further The MVLWB requested De Beers to submit further following information for the Amendment Application on following information for the Amendment Application on November 13November 13November 13November 13

De Beers provided further Information for the De Beers provided further Information for the Amendment Application on November 14Amendment Application on November 14

The MVLWB commented De Beers November 2014 The MVLWB commented De Beers November 2014 Amendment Application on November 19Amendment Application on November 19

De Beers requested to change effective dates forDe Beers requested to change effective dates for De Beers requested to change effective dates for De Beers requested to change effective dates for effluent limits (Part F; Condition 9a) on November 20effluent limits (Part F; Condition 9a) on November 20

8.2 November 2014 Water 8.2 November 2014 Water LicenceLicenceA d A li i (II)A d A li i (II)Amendment Application (II)Amendment Application (II)

The MVLWB issued out the work plan for the NovemberThe MVLWB issued out the work plan for the November The MVLWB issued out the work plan for the November The MVLWB issued out the work plan for the November 2014 Amendment Application2014 Amendment Application

YKDFN communicated via eYKDFN communicated via e--mail with De Beers for mail with De Beers for l ifi ti f D b 2013 A d t A li til ifi ti f D b 2013 A d t A li ticlarification of December 2013 Amendment Application, clarification of December 2013 Amendment Application,

November 2014 Amendment Application, and Request November 2014 Amendment Application, and Request on compliance date change on compliance date change p gp g

DFO commented the November 2014 Amendment DFO commented the November 2014 Amendment Application on November 27Application on November 27

DFO h tDFO h t DFO has no commentsDFO has no comments

De Beers held a technical meeting on November 28De Beers held a technical meeting on November 28

8.2.1 November 2014 Water 8.2.1 November 2014 Water LicenceLicence Amendment Application Amendment Application The application proposesThe application proposes two limited durationtwo limited duration The application proposes The application proposes two limited duration, two limited duration,

interim amendmentsinterim amendments:: Part F Condition 9a: Remove the chloride effluent Part F Condition 9a: Remove the chloride effluent

limit that comes into effect January 1, 2015 (160 limit that comes into effect January 1, 2015 (160 mg/L) and effectuate a limit for TDS in effluent of 850 mg/L) and effectuate a limit for TDS in effluent of 850 mg/Lmg/L inclusive of chloride until December 31 2015inclusive of chloride until December 31 2015mg/L,mg/L, inclusive of chloride, until December 31, 2015inclusive of chloride, until December 31, 2015

Part F, Condition 13: Remove requirement to Part F, Condition 13: Remove requirement to maintain wholemaintain whole--lake average TDS concentration lake average TDS concentration below 350 mg/L at all timesbelow 350 mg/L at all times

8.2.2 Further Information for the 8.2.2 Further Information for the Amendment ApplicationAmendment Application

Dated November 14 2014Dated November 14 2014Dated November 14, 2014Dated November 14, 2014 In response to the MVLWB’s requests, De In response to the MVLWB’s requests, De

Beers provided the following informationBeers provided the following informationBeers provided the following information Beers provided the following information •• Record of engagement specific to the amendment Record of engagement specific to the amendment

being sought;being sought;•• All evidence relevant to this application; andAll evidence relevant to this application; and•• Evidence to support the removal of the chloride Evidence to support the removal of the chloride

lili li itli itlicencelicence limit.limit.

8.2.3 MVLWB’s Comments on November 8.2.3 MVLWB’s Comments on November 2014 A d t A li ti (I)2014 A d t A li ti (I)2014 Amendment Application (I)2014 Amendment Application (I)

“The Board is concerned that De Beers has proposed a“The Board is concerned that De Beers has proposed a The Board is concerned that De Beers has proposed a The Board is concerned that De Beers has proposed a timeline for the regulatory process in the cover letter timeline for the regulatory process in the cover letter accompanying the November 2014 Amendment accompanying the November 2014 Amendment Application which is inconsistent with mandatoryApplication which is inconsistent with mandatoryApplication which is inconsistent with mandatory Application which is inconsistent with mandatory elements of the water elements of the water licencelicence amendment process set amendment process set out in legislation. Under paragraph 43(2)(a) of the out in legislation. Under paragraph 43(2)(a) of the Waters Act, the Board is required to post an Waters Act, the Board is required to post an advertisement in a newspaper of general distribution advertisement in a newspaper of general distribution announcing the Public Hearing date.announcing the Public Hearing date. The Public HearingThe Public Hearingannouncing the Public Hearing date. announcing the Public Hearing date. The Public Hearing The Public Hearing date must be a minimum of 35 days after the date must be a minimum of 35 days after the announcement in the newspaperannouncement in the newspaper. The Board considered . The Board considered the timeline proposed by De Beers and determined thatthe timeline proposed by De Beers and determined thatthe timeline proposed by De Beers and determined that the timeline proposed by De Beers and determined that it is it is impossibleimpossible to allow for a reasonable and fair review to allow for a reasonable and fair review process and make a decision by December 31, 2014process and make a decision by December 31, 2014

8.2.3 MVLWB’s Comments on November 8.2.3 MVLWB’s Comments on November 2014 A d t A li ti (II)2014 A d t A li ti (II)2014 Amendment Application (II)2014 Amendment Application (II)

“Based on De Beers’ own assessment of effluent quality“Based on De Beers’ own assessment of effluent quality Based on De Beers own assessment of effluent quality Based on De Beers own assessment of effluent quality trends and because the Board cannot legally make a trends and because the Board cannot legally make a decision in response to De Beers’ request by December decision in response to De Beers’ request by December 31 201431 2014 it seems likely that De Beers could be out ofit seems likely that De Beers could be out of31, 2014, 31, 2014, it seems likely that De Beers could be out of it seems likely that De Beers could be out of compliance with the Water compliance with the Water LicenceLicence after that dateafter that date. The . The Board does not want to see De Beers, or any Board does not want to see De Beers, or any licencelicence or or permit holder, out of compliance with a water permit holder, out of compliance with a water licencelicence or or land use permit. However we must ensure that our land use permit. However we must ensure that our proceedings are carried out in a manner that isproceedings are carried out in a manner that isproceedings are carried out in a manner that is proceedings are carried out in a manner that is consistent with the law, and provide reasonable access consistent with the law, and provide reasonable access to the review process by those who may be affected by to the review process by those who may be affected by the decision”the decision”the decisionthe decision

8.2.3 MVLWB’s Comments on November 8.2.3 MVLWB’s Comments on November 2014 A d t A li ti (III)2014 A d t A li ti (III)2014 Amendment Application (III)2014 Amendment Application (III)

“On several occasions over the past several months,“On several occasions over the past several months, On several occasions over the past several months, On several occasions over the past several months, Board staff has advised De Beers that a request to Board staff has advised De Beers that a request to change the compliance date for Effluent Quality Criteria change the compliance date for Effluent Quality Criteria that will come into effect on January 1 2015 could bethat will come into effect on January 1 2015 could bethat will come into effect on January 1, 2015 could be that will come into effect on January 1, 2015 could be processed in a more timely manner than an amendment processed in a more timely manner than an amendment application. application. Board staff continues to be available to Board staff continues to be available to discuss a compliance date change with De Beersdiscuss a compliance date change with De Beers. In the . In the interim, please be assured that Board staff will make all interim, please be assured that Board staff will make all necessary efforts to expedite the review of yournecessary efforts to expedite the review of yournecessary efforts to expedite the review of your necessary efforts to expedite the review of your November 2014 Amendment Application”November 2014 Amendment Application”

8.2.4 De Beers Request to 8.2.4 De Beers Request to Change Compliance DatesChange Compliance Dates

De Beers requested to change effective datesDe Beers requested to change effective dates De Beers requested to change effective dates De Beers requested to change effective dates for effluent limits (Part F; Condition 9a) on for effluent limits (Part F; Condition 9a) on November 20, 2014November 20, 2014 To remove the effective date of January 1, 2015 for To remove the effective date of January 1, 2015 for

EQCs of nitrate, chloride and fluorideEQCs of nitrate, chloride and fluorideT t d th t EQC f it t d hl idT t d th t EQC f it t d hl id To extend the current EQCs of nitrate and chloride To extend the current EQCs of nitrate and chloride until the expiry date of the water until the expiry date of the water licencelicence, namely June , namely June 13, 202013, 2020,,

The request is intended as a means of reducing The request is intended as a means of reducing (but not eliminating) the potential for non(but not eliminating) the potential for non--compliance as of January 1, 2015compliance as of January 1, 2015

8.2.5 Work Plan for November 8.2.5 Work Plan for November 2014 Amendment Application2014 Amendment Application

Call for information requests and interventionsCall for information requests and interventions Call for information requests and interventions Call for information requests and interventions on November 20, 2014on November 20, 2014

Information requests due on December 9, 2014Information requests due on December 9, 2014 Information requests due on December 9, 2014Information requests due on December 9, 2014 PrePre--Hearing Conference on January 6, 2015Hearing Conference on January 6, 2015 Interventions due on January 9 2015Interventions due on January 9 2015 Interventions due on January 9, 2015Interventions due on January 9, 2015 Hearing Presentations Due (Interveners)/Notice Hearing Presentations Due (Interveners)/Notice

of Intent to Appear at Hearing Due on Januaryof Intent to Appear at Hearing Due on Januaryof Intent to Appear at Hearing Due on January of Intent to Appear at Hearing Due on January 16, 201516, 2015

Public Hearing on January 26 and 27, 2015Public Hearing on January 26 and 27, 2015g y ,g y , Board Decision in Early/MidBoard Decision in Early/Mid--March 2015March 2015

8.2.6 Technical Meeting for the Water 8.2.6 Technical Meeting for the Water LiLi A d t A li tiA d t A li tiLicenceLicence Amendment ApplicationAmendment Application

Dated November 28 2014Dated November 28 2014Dated November 28, 2014Dated November 28, 2014 De Beers presented the proposed De Beers presented the proposed

amendment applicationamendment applicationamendment applicationamendment application Participants included staff from the MVLWB, Participants included staff from the MVLWB,

GNWT (Lands ENR ITI) ECGNWT (Lands ENR ITI) EC CanNorCanNorGNWT (Lands, ENR, ITI), EC, GNWT (Lands, ENR, ITI), EC, CanNorCanNor, , TlichoTlicho, NSMA, NWTMN, SLEMA, , NSMA, NWTMN, SLEMA, GolderGolder