June 2013 June 2013 Environmental Update Environmental Update

for SLEMA Boardfor SLEMA BoardZhong LiuZhong Liu

June 30, 2013June 30, 2013

OutlineOutline1.1. Mine UpdateMine Update

2.2. Inspection UpdateInspection Update

3.3. Regulators’ UpdateRegulators’ Update

4.4. Aboriginal UpdateAboriginal Update

5.5. Stakeholders’ UpdateStakeholders’ Update

6.6. Agency’s ActivitiesAgency’s Activities

7.7. SLEMA ReviewsSLEMA Reviews

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

(previous INAC – India and Northern Affairs Canada)(previous INAC – India and Northern Affairs Canada) AEMP – Aquatic Effects Monitoring ProgramAEMP – Aquatic Effects Monitoring Program ARD – Acid Rock DrainageARD – Acid Rock Drainage DFO – Fisheries and Oceans CanadaDFO – Fisheries and Oceans Canada EC – Environment CanadaEC – Environment Canada ENR – Department of Environment and Natural Resources, GNWTENR – Department of Environment and Natural Resources, GNWT GNWT – Government of the Northwest TerritoriesGNWT – Government of the Northwest Territories MVLWB – Mackenzie Valley Land and Water BoardMVLWB – Mackenzie Valley Land and Water Board PK – Processed KimberlitePK – Processed Kimberlite SLEMA – Snap Lake Environmental Monitoring AgencySLEMA – Snap Lake Environmental Monitoring Agency SNP – Surveillance Network ProgramSNP – Surveillance Network Program TDS – Total Dissolved SolidsTDS – Total Dissolved Solids WEMP – Wildlife Effects Monitoring ProgramWEMP – Wildlife Effects Monitoring Program WTP – Water Treatment PlantWTP – Water Treatment Plant WMP – Water Management PondWMP – Water Management Pond

1.1 Mine Update – May 20131.1 Mine Update – May 2013 Production rate: Production rate: 100.4 100.4 % of its capacity (% of its capacity (98,003 98,003 tonnes tonnes

of kimberlite processed)of kimberlite processed) 3,293 3,293 mm33 of water withdrawn from Snap Lake of water withdrawn from Snap Lake 1,046,774 1,046,774 mm33 of treated water discharged into Snap Lake of treated water discharged into Snap Lake 84,327 84,327 tonnes of coarse reject andtonnes of coarse reject and 65,465 65,465 m m33 of slimes of slimes

deposited in the North Piledeposited in the North Pile 6 6 spills (3 reportable)spills (3 reportable) Water sampled in Water sampled in 1515 monitoring stations monitoring stations

The monthly average for all parameters met complianceThe monthly average for all parameters met compliance

1.2 1.2 SNP 02-17B and SNP 02-20 in SNP 02-17B and SNP 02-20 in May 2013May 2013

Parameter SNP 02-20 (d) SNP 02-20 (e)

SNP 02-20 (f) WQO

TDS, mg/L 297 293 299 350

Chloride, mg/L 132 132 134 120

Fluoride, mg/L 0.16 0.16 0.03 0.12

Monthly average concentration of Chloride in SNP 02-17B (treated effluent) in May 2013 is 254 mg/L, lower than that in April (303 mg/L) and the Water Licence limit (310 mg/L)

Chloride levels at the end of the mixing zone (SNP 02-20) are still above the Water Quality Objective (CCME Guideline – 120 mg/L)

1.3 Starter Cell Raise1.3 Starter Cell Raise

Dated June 3, 2013Dated June 3, 2013 Titled “North Pile Starter Cell Phase IV Titled “North Pile Starter Cell Phase IV

Embankments Design Report”Embankments Design Report”• De Beers plans to raise the height of the Starter De Beers plans to raise the height of the Starter

Cell by 3.5 metersCell by 3.5 meters• During the Environmental Assessment De Beers During the Environmental Assessment De Beers

committed to the North Pile facility to be no higher committed to the North Pile facility to be no higher than the hills in the surrounding landscape (within than the hills in the surrounding landscape (within the the Zone of InfluenceZone of Influence) and this commitment will ) and this commitment will be upheldbe upheld

1.4 Summary of Difference between 1.4 Summary of Difference between Water Licence MV2011L2-0004 and Water Licence MV2011L2-0004 and

the 2013 AEMP Design Planthe 2013 AEMP Design Plan Dated June 4, 2013Dated June 4, 2013

There are differences between the 2013 There are differences between the 2013 approved AEMP Design Plan and the Water approved AEMP Design Plan and the Water Licence. As such, there is potential for non-Licence. As such, there is potential for non-compliance with the Water Licence as some compliance with the Water Licence as some of the Water Licence requirements were of the Water Licence requirements were based on the 2005 AEMP designbased on the 2005 AEMP design

1.5 Strontium Response Plan 1.5 Strontium Response Plan RequirementRequirement

Request submitted on June 10, 2013Request submitted on June 10, 2013 The MVLWB to remove the Strontium The MVLWB to remove the Strontium

Response Plan require under the Water Response Plan require under the Water Licence, to be replaced by a suggested Licence, to be replaced by a suggested Benchmark to be monitored under the AEMPBenchmark to be monitored under the AEMP• 14,130 µg/L for the chronic effects benchmark 14,130 µg/L for the chronic effects benchmark

(CEB)(CEB) Attached a report titled Development of Attached a report titled Development of

Strontium Benchmark for Aquatic Life for the Strontium Benchmark for Aquatic Life for the Snap Lake MineSnap Lake Mine

1.6 Follow-up AEMP Technical 1.6 Follow-up AEMP Technical Meeting with SLEMAMeeting with SLEMA

Dated June 13, 2013Dated June 13, 2013 De Beers staff, Golder Associates Ltd. staff, De Beers staff, Golder Associates Ltd. staff,

SLEMA staff SLEMA staff • SLEMA Science Panel (Barry Zajdlik), and DFO SLEMA Science Panel (Barry Zajdlik), and DFO

consultant (Maggie Squires) via teleconferenceconsultant (Maggie Squires) via teleconference Discussion was focused on SLEMA/DFO’s Discussion was focused on SLEMA/DFO’s

recommendation on food web modelrecommendation on food web model

1.7 Contribution to ENR’s 1.7 Contribution to ENR’s Caribou ResearchCaribou Research

E-mail dated June 19, 2013E-mail dated June 19, 2013 De Beers is looking to contribute $70k to the De Beers is looking to contribute $70k to the

GNWT/ENR for caribou research in lieu of the GNWT/ENR for caribou research in lieu of the aerial survey done annuallyaerial survey done annually• In response to ENR’s request on May 4, 2013 – “if In response to ENR’s request on May 4, 2013 – “if

De Beers would like to contribute to any of these De Beers would like to contribute to any of these project as part of their 2013/14 wildlife effects project as part of their 2013/14 wildlife effects monitoring program for barren-ground caribou at monitoring program for barren-ground caribou at the Snap Lake and proposed Gahcho Kue mine the Snap Lake and proposed Gahcho Kue mine sites”sites”

1.8 Lake Discharge and Lake Elevation 1.8 Lake Discharge and Lake Elevation Monitoring Program 2012 Annual ReportMonitoring Program 2012 Annual Report

Submitted June 24, 2013Submitted June 24, 2013 Required by the Environmental Agreement for Required by the Environmental Agreement for

hydrology monitoringhydrology monitoring

1.9 Vegetation Monitoring Program 2012 Annual Report

Submitted on June 26, 2013 Required by the Environmental Agreement To provide support for the closure and

reclamation requirements as outlined in the Water Licence

2. Inspection Update 2. Inspection Update

AANDC Inspector – Patrick KramersAANDC Inspector – Patrick Kramers No Inspection reports received in June No Inspection reports received in June

20132013

2.1 Letter of Warning in relation to 2.1 Letter of Warning in relation to NWT Spills 11-391 and 11-398NWT Spills 11-391 and 11-398

Issued by Jason Brennan on April 16, Issued by Jason Brennan on April 16, 20132013 The AANDC Investigation into the noted The AANDC Investigation into the noted

seepage events has concluded and is now seepage events has concluded and is now closed closed

The AANDC Inspector presently assigned to The AANDC Inspector presently assigned to the Snap Lake file will be monitoring progress the Snap Lake file will be monitoring progress on the Implementation Plan for repairs to be on the Implementation Plan for repairs to be completed at Perimeter Sump #3 (PS3) over completed at Perimeter Sump #3 (PS3) over the summer of 2013the summer of 2013

Spills 11-391 and 11-398Spills 11-391 and 11-398

The release of mine water the receiving The release of mine water the receiving environment violated several conditions of environment violated several conditions of Water Licence MV2001L2-0002Water Licence MV2001L2-0002 3,625,500 litres of mine water entered Snap Lake from 3,625,500 litres of mine water entered Snap Lake from

the North Pilethe North Pile Subsequent water sampling conducted by AANDC Subsequent water sampling conducted by AANDC

Inspectors revealed that Water Licence criteria for Inspectors revealed that Water Licence criteria for Nitrate, as well as four additional water quality Nitrate, as well as four additional water quality parameters were exceeded during these spill events parameters were exceeded during these spill events (TSS, Zinc, Copper and Nitrite)(TSS, Zinc, Copper and Nitrite)

A resulting temporary algae bloom was also observed A resulting temporary algae bloom was also observed along a section of the Snap Lake shorelinealong a section of the Snap Lake shoreline

Investigation of Spills 11-391 Investigation of Spills 11-391 and 11-398 (I)and 11-398 (I)

The inadequate water management practises The inadequate water management practises observed during the course of the investigation observed during the course of the investigation signify serious environmental management signify serious environmental management problems, unacceptable risk management problems, unacceptable risk management practices, poor internal communications and practices, poor internal communications and lack of role accountability in some cases at the lack of role accountability in some cases at the Snap Lake mine siteSnap Lake mine site East Cell perimeter sumps were not being monitored East Cell perimeter sumps were not being monitored

properlyproperly Perimeter Sump #4 was not being operated as per Perimeter Sump #4 was not being operated as per

design specificationsdesign specifications

Investigation of Spills 11-391 Investigation of Spills 11-391 and 11-398 (II)and 11-398 (II)

Four root causes of the water management crisisFour root causes of the water management crisis A higher volume or rate of mine water inflow reportedly A higher volume or rate of mine water inflow reportedly

entering the underground mine workings during the given entering the underground mine workings during the given periodperiod

Insufficient reserve storage capacity available at surface Insufficient reserve storage capacity available at surface in the Water Management Pondin the Water Management Pond

Improper use of East Cell perimeter sumps as mine water Improper use of East Cell perimeter sumps as mine water storage structuresstorage structures

The inability of the Water Treatment Plant to treat for The inability of the Water Treatment Plant to treat for nitrate which has led to the need to rely on dilution as a nitrate which has led to the need to rely on dilution as a means to meet Effluent Quality Criteria for this specific means to meet Effluent Quality Criteria for this specific parameterparameter

Investigation of Spills 11-391 Investigation of Spills 11-391 and 11-398 (III)and 11-398 (III)

It also became evident that De Beers Canada did not It also became evident that De Beers Canada did not initially opt to implement their approved contingencyinitially opt to implement their approved contingency Temporarily drawing down the Water Management Pond Temporarily drawing down the Water Management Pond

and flooding underground workings as an emergency and flooding underground workings as an emergency measure to redirect excess surface mine water to the measure to redirect excess surface mine water to the underground during a water balance upset emergency underground during a water balance upset emergency situationsituation

Hesitation by De Beers Canada to not implement this Hesitation by De Beers Canada to not implement this approved contingency until well after the second mine approved contingency until well after the second mine water seepage event improperly put day to day water seepage event improperly put day to day operational business priorities ahead of protecting the operational business priorities ahead of protecting the environmental integrity of Snap Lake itselfenvironmental integrity of Snap Lake itself

Official WarningOfficial Warning

““Aboriginal Affairs and Northern Development Canada Aboriginal Affairs and Northern Development Canada does not intend to proceed with legal action does not intend to proceed with legal action against De against De Beers Canada Inc. regarding the release of mine water Beers Canada Inc. regarding the release of mine water from the North Pile East Cell at the Snap Lake Diamond from the North Pile East Cell at the Snap Lake Diamond Mine that occurred on or prior to October 2nd & 11th, Mine that occurred on or prior to October 2nd & 11th, 2011. De Beers Canada Inc., however, is hereby given 2011. De Beers Canada Inc., however, is hereby given official warningofficial warning that any further action or lack of that any further action or lack of appropriate action that results in future violations of the appropriate action that results in future violations of the Water Licence or other statutory obligations may result in Water Licence or other statutory obligations may result in legal recourse pursuant to the legal recourse pursuant to the Northwest Territories Northwest Territories Waters Act or other acts as appropriate”Waters Act or other acts as appropriate”

CBC Radio News on June 24, CBC Radio News on June 24, 20132013

Titled Titled De Beers to be Charged if Another De Beers to be Charged if Another Spill at Snap LakeSpill at Snap Lake ““The federal government has put De Beers on The federal government has put De Beers on

notice that the company will be charged if it notice that the company will be charged if it has another spill at the Snap Lake Diamond has another spill at the Snap Lake Diamond Mine. Federal inspectors investigated after Mine. Federal inspectors investigated after 3.6 million litres seeped into Snap Lake two 3.6 million litres seeped into Snap Lake two years ago, but the company says it’s made years ago, but the company says it’s made major changes since then.”major changes since then.”

3. Regulators’ Update3. Regulators’ Update – – MVLWB (I)MVLWB (I) Distributed De Beers request for Starter Cell Raise for Distributed De Beers request for Starter Cell Raise for

review on June 6, 2013review on June 6, 2013• The deadline for reviewers to submit comments is Jun 26The deadline for reviewers to submit comments is Jun 26

• The deadline for the proponent to submit responses is The deadline for the proponent to submit responses is Jul 03Jul 03

Requested via e-mail on June 7 that De Beers provide Requested via e-mail on June 7 that De Beers provide update on stability, thermal and seepage analyses, update on stability, thermal and seepage analyses, and future plans for the North Pile (i.e. deposition and and future plans for the North Pile (i.e. deposition and slurry/paste status)slurry/paste status)

• De Beers responded on June 10 that no updates were De Beers responded on June 10 that no updates were done on thermal and seepage analysesdone on thermal and seepage analyses

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

Board staff responded on June 24, 2013 to SLEMA request dated April 26

SLEMA requested the Board “require De Beers to conduct chronic toxicity tests (cladoceran crustacean Ceridaphnia dubia and alga Pseudokirchneriella subcapitata) for SNP02-20 in the following month after a chloride exceedence.”

The Board requires further clarification before considering the request

• “Can SLEMA detail the benefit of increased chronic toxicity testing at SNP02-20, considering that quarterly acute and chronic studies are currently required for full effluent (SNP02-17B)?”

4. Aboriginal Update4. Aboriginal Update

The NSMA Commented AEMP Design The NSMA Commented AEMP Design Plan – Chapters 6 and 7 on May 31, 2013Plan – Chapters 6 and 7 on May 31, 2013

YKDFN commented on Starter Cell Raise YKDFN commented on Starter Cell Raise on June 26on June 26

4.1 NSMA Comments on AEMP 4.1 NSMA Comments on AEMP Design Plan – Chapters 6 and 7 (I)Design Plan – Chapters 6 and 7 (I)

Strengthen the language for significance Strengthen the language for significance threshold definitions. Take the definitions a threshold definitions. Take the definitions a step backwards. Definitions should include step backwards. Definitions should include some of the following: (n)% changes, some of the following: (n)% changes, temporal scale (i.e., reference to closure), temporal scale (i.e., reference to closure), spatial scale, or in the least, spatial scale, or in the least, supplementary information to provide supplementary information to provide justification and rationalejustification and rationale

The NSMA’s concern The NSMA’s concern with how its members with how its members

will perceive the will perceive the significance threshold significance threshold

The NSMA’s perception The NSMA’s perception of how the Proponent of how the Proponent

perceives the perceives the significance threshold significance threshold

Significance threshold for water: Once the whole Significance threshold for water: Once the whole lake becomes undrinkablelake becomes undrinkable

this will be perceived as a catastrophethis will be perceived as a catastrophe

4.1 NSMA Comments on AEMP 4.1 NSMA Comments on AEMP Design Plan – Chapters 6 and 7 (II)Design Plan – Chapters 6 and 7 (II) Implement aesthetics objectives for Implement aesthetics objectives for

drinking water within the response drinking water within the response frameworkframework

Implement an independent framework for Implement an independent framework for traditional knowledge. Discuss how this traditional knowledge. Discuss how this framework will be complementary to the framework will be complementary to the WOE frameworkWOE framework

How the NSMA How the NSMA perceives the current perceives the current

WOE processWOE process

How the NSMA would How the NSMA would like to see the process like to see the process

4.2 YKDFN Comments on Starter 4.2 YKDFN Comments on Starter Cell Raise (I)Cell Raise (I)

At the current time, YKDFN cannot support the request as there seems to be a lack of clarity surrounding the issue

From the YKDFN perspective, there is confusion between the final elevation (ASL) for the pile as envisioned in both the EA and the recent closure documents

Similarly, there seems to be a lack of clarity with regards to the local height of the waste pile. The preferred closure option seems to include heights of both 34 and 39m

If this does move beyond the EA predictions or if closure options are compromised, this is information which should form part of a considered decision rather than occurring as a consequence of a mid-life operational choice based on short term need

4.2 YKDFN Comments on Starter 4.2 YKDFN Comments on Starter Cell Raise (II)Cell Raise (II)

YKDFN encourages the Developer to engage SLEMA on their recommendation and address conflicting information as stated above. Should the proposed changes be found to contradict EA predictions or alter closure options, YKDFN hopes a considered discussion be held to consider the potential options and residual impacts

5. Stakeholders’ Update5. Stakeholders’ Update

Comments on Comments on Starter Cell Raise Starter Cell Raise byby AANDC Inspector on June 26, 2013AANDC Inspector on June 26, 2013 AANDC Water Resources on June 26AANDC Water Resources on June 26

5.1 AANDC Inspector Comments 5.1 AANDC Inspector Comments on Starter Cell Raise (I)on Starter Cell Raise (I)

De Beers to provide reasonable assurances that the added weight and volume of the additional slurry/water has been considered and that the existing infrastructure will be able to handle any additional seepage

De Beers to provide reasonable assurances that the added weight and volume of the additional slurry has been considered in relation to water quality and the water treatment plants ability to treat the already higher than predicted mine flows

5.1 AANDC Inspector Comments 5.1 AANDC Inspector Comments on Starter Cell Raise (II)on Starter Cell Raise (II)

Can De Beers verify that the completion of as-built drawings will in fact be submitted to the board upon completion of the raise (if approved)?

Can De Beers describe what led to the omission of an update for the deposition plan?  Will a plan on deposition post raise (if approved) be forthcoming?

This information should be included in the updated mine plan regarding future containment intentions on site

Information relating to stability, thermal and seepage analyses that may be relevant to the proposed raise should be presented (or committed to be presented) prior to authorization

5.2 AANDC Water Resources 5.2 AANDC Water Resources Comments on Starter Cell Raise (I)Comments on Starter Cell Raise (I) AANDC recommends the Board confirm

whether or not the new proposed height conforms to any commitments made during the EAR regarding the height of the North Pile and visibility on the landscape. If not, rationale for any deviations should be explained

5.2 AANDC Water Resources 5.2 AANDC Water Resources Comments on Starter Cell Raise (II)Comments on Starter Cell Raise (II)

AANDC recommends the Board require DeBeers to provide an update on the progress of the paste trials and describe any revisions to the overall design and operation of the North Pile in the event that paste cannot or will not be successfully generated

5.2 AANDC Water Resources 5.2 AANDC Water Resources Comments on Starter Cell Raise (III)Comments on Starter Cell Raise (III)

AANDC recommends the Board confirm the height of the Starter Cell after completing the Phase IV raise

AANDC recommends the Board require DeBeers to provide additional information on the operational conditions and requirements that have led to the need for the raise, as well as any alternatives to a raises that may exist

5.2 AANDC Water Resources 5.2 AANDC Water Resources Comments on Starter Cell Raise (IV)Comments on Starter Cell Raise (IV)

AANDC recommends the Board retain the requirement for a 4m cover over PAG material unless DeBeers is able to provide suitable justification for requiring only 3m

AANDC recommends that the Board request updated infiltration and seepage quality/quantity analyses. The Board should consider request the company evaluate a scenario where the entire North Pile is filled with PK slurry

6. Agency’s Activities6. Agency’s Activities

Liaison Meeting held in the SLEMA office Liaison Meeting held in the SLEMA office on June 3, 2013on June 3, 2013

Mine Site Visit by Environmental Analyst Mine Site Visit by Environmental Analyst on June 10 and 11on June 10 and 11

SLEMA Wildlife Workshop held on June SLEMA Wildlife Workshop held on June 18 and 1918 and 19

SLEMA Core Group Meeting held on June SLEMA Core Group Meeting held on June 2020

6.1 Liaison Meeting (I)6.1 Liaison Meeting (I) Held on June 3, 2013Held on June 3, 2013 ParticipantsParticipants

Lionel Marcinkoski and Paul Green from AANDC; Bruce Lionel Marcinkoski and Paul Green from AANDC; Bruce Hanna from DFO; Marc Cacas from the MVLWB ; Patrick Hanna from DFO; Marc Cacas from the MVLWB ; Patrick Clancy from GNWT/ENRClancy from GNWT/ENR

Patrick Kramers, AANDC InspectorPatrick Kramers, AANDC Inspector• Provided an update on inspections in the past monthsProvided an update on inspections in the past months

Tom Bradbury from De BeersTom Bradbury from De Beers• Provided an update of the mine site environmental managementProvided an update of the mine site environmental management

Dave White and Zhong Liu from SLEMADave White and Zhong Liu from SLEMA• Provided an update on Chloride (exceedances of CCME guideline and Provided an update on Chloride (exceedances of CCME guideline and

higher monthly concentration close to effluent discharge criterion in higher monthly concentration close to effluent discharge criterion in April)April)

6.1 Liaison Meeting (II)6.1 Liaison Meeting (II)

The discussion focused on Site water The discussion focused on Site water management, paste deposition issue, etc.management, paste deposition issue, etc.

RecommendationsRecommendations De Beers to send senior people to the Liaison De Beers to send senior people to the Liaison

MeetingMeeting A site tour to be scheduled in September for A site tour to be scheduled in September for

Liaison MeetingLiaison Meeting

6.2 Environmental Analyst Site 6.2 Environmental Analyst Site VisitVisit

Conducted on June 10 and 11, 2013Conducted on June 10 and 11, 2013 Details seen in the following linkDetails seen in the following link

http://www.slema.ca/wp-content/uploads/2013/02/20130610-Site-Visit

4.pdf

7. SLEMA Reviews7. SLEMA Reviews

Starter Cell Raise North Pile Starter Cell Phase IV Embankments

Design Report

Quarterly Toxicity Results for SNP 02-17 in May 2013

7.1 Starter Cell Raise 7.1 Starter Cell Raise

Paste trials continue within the North Pile Paste trials continue within the North Pile Starter Cell, but the Starter Cell Phase III Starter Cell, but the Starter Cell Phase III embankments reached a final elevation of embankments reached a final elevation of 486 meters above sea level (MASL)486 meters above sea level (MASL)

Construction of the East Cell is ongoing, Construction of the East Cell is ongoing, but is not at design to receive continuous but is not at design to receive continuous paste or slurrypaste or slurry

De Beers Rationale for the 3.5 De Beers Rationale for the 3.5 meter Raisemeter Raise

In order to continue active deposition and In order to continue active deposition and processing at the Snap Lake Mine, the Starter processing at the Snap Lake Mine, the Starter Cell will be raised. By raising the Starter Cell Cell will be raised. By raising the Starter Cell to the revised height of 489.5 MASL the to the revised height of 489.5 MASL the Starter Cell and North Pile will remain at Starter Cell and North Pile will remain at permitted heights (503.654 MASL) as permitted heights (503.654 MASL) as referenced by the Zone of Influence (ZOI) referenced by the Zone of Influence (ZOI) which will provide further capacity for which will provide further capacity for deposition and will not expand the land deposition and will not expand the land footprint of the North Pilefootprint of the North Pile

Layout PlanLayout Plan

489.47 MASL

473.65 MASL

PK Deposition – Slurry, Paste and GritsPK Deposition – Slurry, Paste and Grits

The storage capacity of the Starter Cell The storage capacity of the Starter Cell Phase IV embankments is about 761,000 Phase IV embankments is about 761,000 mm33

The deposition should be completed in The deposition should be completed in about a yearabout a year

Water Management and Water Management and Surface DrainageSurface Drainage

The Starter Cell is designed to promote surface water The Starter Cell is designed to promote surface water drainage from the deposited materials towards the drainage from the deposited materials towards the perimeter water control structures. This will also reduce perimeter water control structures. This will also reduce the potential for ice entrapment within the deposited the potential for ice entrapment within the deposited materialsmaterials

During operations, any ponded water in low-lying areas During operations, any ponded water in low-lying areas or on deposited materials should be removed. Some or on deposited materials should be removed. Some mechanical grading of the deposition surface should be mechanical grading of the deposition surface should be expected during operations to promote surface drainage. expected during operations to promote surface drainage. Provisions for mobile pumping equipment should be Provisions for mobile pumping equipment should be provided to remove any ponded waterprovided to remove any ponded water

Dust ControlDust Control

The surface of the deposited PK dries quickly during The surface of the deposited PK dries quickly during summer conditions and is lower than the perimeter summer conditions and is lower than the perimeter embankment crest. Dust generation should be monitored embankment crest. Dust generation should be monitored during operations and dust control measures be during operations and dust control measures be developed as necessarydeveloped as necessary

During winter conditions, the deposition surface will During winter conditions, the deposition surface will freeze and snow will cover the surface, reducing dust freeze and snow will cover the surface, reducing dust erosion and the need for dust control. Dusting should be erosion and the need for dust control. Dusting should be monitored throughout the year to assess the North Pile monitored throughout the year to assess the North Pile performanceperformance

Dust generation from the North Pile has not been noted Dust generation from the North Pile has not been noted to dateto date

SLEMA Communication with De SLEMA Communication with De BeersBeers

Request for clarification sent via e-mail on Request for clarification sent via e-mail on June 20, 2013June 20, 2013 North Pile maximum elevation of 503.654 North Pile maximum elevation of 503.654

MASL is inconsistent with the number (484 MASL is inconsistent with the number (484 MASL) in the  Environmental Assessment MASL) in the  Environmental Assessment Report (page 3-18). Clarification is requiredReport (page 3-18). Clarification is required

De Beers’ ResponseDe Beers’ Response

De Beers responded on June 24, 2013De Beers responded on June 24, 2013 The higher value is related to the commitment The higher value is related to the commitment

that the pile will be no higher than the that the pile will be no higher than the surrounding hills within the ZOI and surrounding hills within the ZOI and recent recent reviews of actual elevations done by a reviews of actual elevations done by a surveyorsurveyor as opposed to during the EA as opposed to during the EA when it was a when it was a paper exercisepaper exercise

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

In the Environmental Assessment Report In the Environmental Assessment Report (Page 3-18), it is stated that (Page 3-18), it is stated that ““At the end of operation, the north pile will have a At the end of operation, the north pile will have a

maximum height of approximately 34 m (crest maximum height of approximately 34 m (crest elevation 484 m). At this elevation, the pile will be elevation 484 m). At this elevation, the pile will be approximately the same height as the highest point approximately the same height as the highest point of natural ground in the of natural ground in the immediate area of the immediate area of the project siteproject site””

The immediate area of the project site should not The immediate area of the project site should not be referred to the Zone of Influence (with a radius be referred to the Zone of Influence (with a radius of 35 km) of 35 km)

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

It is noted that the wildlife study area is defined by It is noted that the wildlife study area is defined by a circle with a radius of 31 kma circle with a radius of 31 km, centered on the , centered on the Mine siteMine site Two reference lakes (Northeast Lake and Lake 13) and Two reference lakes (Northeast Lake and Lake 13) and

King Lake (KING 01 – downstream water quality King Lake (KING 01 – downstream water quality station) are also within the circlestation) are also within the circle

The highest point within 35 km (defined by De The highest point within 35 km (defined by De Beers for ZOI), based on Golder Associate Beers for ZOI), based on Golder Associate Technical Memorandum dated April 22, 2013, is Technical Memorandum dated April 22, 2013, is located north northwest of the North Pile, and located north northwest of the North Pile, and appears to be outside the wildlife study areaappears to be outside the wildlife study area

Closure Options and Research Workshop Closure Options and Research Workshop on March 13, 2013, Slide #21on March 13, 2013, Slide #21

• Closure options presented in the 2003 and 2006 ICRPs• Size and shape

oShort, large footprintoMedium height, medium footprintoTall, small footprint

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

During the Closure Workshop, De Beers did not During the Closure Workshop, De Beers did not intend to change the chosen closure option #2, intend to change the chosen closure option #2, which is consistent with the Environmental which is consistent with the Environmental Assessment Report commitmentAssessment Report commitment

Two concerns are raisedTwo concerns are raised Planned Starter Cell raise is not consistent with De Planned Starter Cell raise is not consistent with De

Beers commitment during the Environmental Beers commitment during the Environmental AssessmentAssessment

The approach to arguing a Starter Cell raise is not The approach to arguing a Starter Cell raise is not appropriateappropriate

SLEMA Position (I)

SLEMA is disappointed that De Beers is deviating from its original intent to maintain the profile of the North Pile consistent with the surrounding terrain, and is choosing instead to use a prominence, not even visible from Snap Lake as the benchmark elevation. This being said SLEMA prefers an elevation increase to increased footprint and in this regards would like to make the following points.

It has been two years since the last update on paste production, SLEMA would like to see a frank discussion following a new update of the paste production, discussing the reasons why this proposed method is not yet a viable alternative, slowing the deposition to the North Pile.

SLEMA Position (II)

Elders consistently express concern for the increased elevation as a generator of dust. SLEMA acknowledges that De Beers continues to test capping methods and is trying hard to develop a cap that does not have dust generating characteristics. SLEMA encourages De Beers to engage the communities and work hard at educating the stake holders to alleviate these concerns

Further increase in height should not be contemplated without comprehensive consultations with all the stake holders taking place

7.7.22 Quarterly Toxicity Results for SNP Quarterly Toxicity Results for SNP 02-1702-17

Submitted on June 28, 2013 Water Treatment Plant (WTP) effluent samples

taken on May 20 were tested• By HydroQual Laboratories Ltd. (Calgary) during May 2013

Standard biological test methods used 4 analysis reports for each samples submitted

• Algae – inhibitory effects did not occur• Ceriodaphnia – no effect occurred• Trout – no effect occurred• Daphania – no effect occurred

Comments from the Environmental Analyst

No concerns are raised