1. MEADOWBANK WATER LICENSE RENEWAL NWB 2AM MEA0815 January 14-15, 2015, Community of Baker Lake, NU Hutchinson Environmental Sciences Ltd.

2. Overview Our review was comprised of 27 separate information requests (IRs) We have communicated with AEM over the past three months and have resolved the majority of our issues One issue still outstands This presentation accompanies AEM’s submission to the NWB on January 13, 2014: “NWB 2AM MEA0815 Preliminary AEM response to Technical Comments WL Renewal_revised on 01132015”

3. Guiding Principles Our review is guided by Nunavut Water Board’s (NWB) water quality framework o protect, manage and regulate freshwaters in Nunavut in a manner that will provide the optimum benefits for the residents of the territory in particular and Canadians in general The Nunavut Land Claims Agreement, and The Kivalliq Inuit Association’s right to minimized changes to the environment Our presentation accompanies our submission to the NWB: Hutchinson Environmental Sciences Ltd. 2014. Meadowbank Water License Review. Prepared for GeoVector Management Inc. and the Kivalliq Inuit Association.

4. Resolved Issues IR #IssueResolution KIA-IR-01AEM has requested a significant increase in the freshwater limit. We have clarified our concern and requested the NWB authorize a staged water license. We are also concerned how development of the IVR or Phaser Pit would alter AEM’s freshwater needs. Would AEM anticipate the need to amend the Licence? AEM has agreed to a staged water license Stage 1 reflects operations of the mine, permitting up to 2,350,000 m 3 /yr Stage 2 reflects closure and reclamation activities indicated for 2018 onward permitting up to 9,119,652 m 3 /yr The annual report to the NWB will outline annual freshwater usage and anticipate usage for the following year. KIA-IR- 01-B The KIA is concerned additional freshwater withdrawal from Third Portage Lake represents consumptive use of the lakes available freshwater volume as compared with the annual inflow. AEM provided assurance that Third Portage Lake will contain water level necessary to maintain a minimum flow at the outlet of the lakes over the four summer months KIA-IR-02The KIA expressed concern that AEM was not adequately testing the hypothesis “Water License Limits are adequate to protect the environment” as opposed to testing the implications of not meeting license limits. We worried AEM’s initial screening tool for changes to water quality was internal monitoring results and comparisons to the Water License Limits, placing a greater focus on compliance rather than environmental protection. The KIA compared CREMP environmental monitoring results with trends reported at internal monitoring stations; we do not contest AEM’s conclusion. AEM has agreed to include a map in future annual reports showing internal monitoring stations and CREMP environmental monitoring station locations together.

5. Resolved Issues IR #IssueResolution KIA-IR-04AEM has proposed removing the license condition requiring a comparison between predicted and measured water quality and quantity. Discontinuing the comparison will not continue to validate if Meadowbank is operating within the framework presented to the Nunavut Impact Review Board in the environmental impact statement AEM will continue to collect pit sump data, make comparisons of predicted water quality and quantity within the pits to originally predicted water quality data use updated measured water quality and quantity to ensure pit water quality will meet CCME limits to be protective of aquatic biota. KIA-IR-05The KIA is concerned AEM is not adequately characterizing cyanide in the receiving environment down stream of the Portage Attenuation Pond at ST-9 and the vault attenuation pond at ST-10. AEM has agreed to include an adaptive management response to elevated total or free cyanide in the receiving environment which would require free cyanide monitoring at ST-9 and ST-10. KIA-IR-06AEM has amalgamated the monitoring criteria from two subsections but did not include preface text which frames the requirements. AEM agreed to include the proposed introductory text as it relates to secondary containment discharge to land in Baker Lake Bulk Fuel Storage Facility and the Meadowbank Fuel Storage Facility

6. Resolved Issues IR #IssueResolution KIA-IR-07AEM proposed altering the license no longer requiring confirmation of sample site locations with an inspector. AEM has agreed to confirm the stations location with the Inspector in the event that new stations are added. KIA-IR-08Proposed removal of condition requiring photographic records of existing environment prior to new construction. AEM has agreed maintain photographic records should new construction activities be undertaken. KIA-IR-09Several measured parameters exceeded applicable criteria or showed an increasing trend in key parameters at near field sites. AEM responded that “data to date suggest that the observed changes are generally consistent with those predicted in the EIS”. The KIA have performed additional analysis to evaluate this statement. AND Total phosphorus (in addition to a metal scan using low level detection limits), fluoride, cyanide (total and free), cobalt and silver were not included in the 2013 CREMP suite after being modeled in the FEIS

7. Resolved Issues Sites Associated with the diversion ditches with water discharging to Third Portage Lake, The attenuation pond discharging to Third Portage Lake, and Near the Tailing Storage Facility (TSF) eventually discharging to Second Portage Lake Stations which discharged to land. Specific parameters were: TSS, conductivity, calcium, TDS, sulphate, phytoplankton, benthic invertebrates, zinc in sediments

8. Resolved Issues IR #IssueResolution KIA-IR-09Several measured parameters exceeded applicable criteria or showed an increasing trend in key parameters at near field sites. AEM responded that “data to date suggest that the observed changes are generally consistent with those predicted in the EIS”. The KIA have performed additional analysis to evaluate this statement. AND Total phosphorus (in addition to a metal scan using low level detection limits), fluoride, cyanide (total and free), cobalt and silver were not included in the 2013 CREMP suite after being modeled in the FEIS AEM has agreed to compare the list of modelled parameters with those currently monitored and harmonize the two lists in the CREMP. AEM has also indicated they will provide further discussion on their adaptive management responses. We stress the importance of this in light of the highlighted divergences from the FEIS prediction. We were happy to note AEM has added total phosphorus and cyanide (total and free) Schedule 1, Group 2 in the new water license. KIA-IR-10AEM has indicated a reference site for Wally Lake will not be established AEM has provided an evaluation of the advantages of establishing an additional reference site. The KIA is satisfied with the proponents discussion.

9. Resolved Issues IR #IssueResolution KIA-IR-11AEM has used less stringent Data Quality Objectives (DQOs) than those proposed by the USEPA. Analysis of the CREMP dataset using more stringent DQOs was performed. An additional 14 instances where DQOs were not met were identified. The total was still below 5% indicating AEMs DQO was sufficient for the dataset. KIA-IR-12AEM has not established an accredited on site laboratory which has indirectly resulted in violating hold times for several parameters: colour, turbidity, nitrate, nitrite and ortho- phosphate as dissolved P. AEM has provided Multilab in Val D’Or as a viable alternative but has not presented adequate detection limits. AEM has agreed to work with Multilab to meet the required detection limits. Also see KIA-IR-21

10. Resolved Issues IR #IssueResolution KIA-IR-13“Formal application of the trigger for decision- making purposes was to the yearly mean for each sampling area”. Parameter concentrations vary more over the course of a year than in a given month or a season making it difficult to statistically differentiate a yearly mean from a trigger concentration. AND The CREMP appears unable to detect changes over the course of a single year using the BACI approach if sufficient statistical power is only achieved after 5-6 samples; sampling frequency was 2 to 5 for Meadowbank sites and 2 to 3 for Baker Lake sites. AEM provided further clarification during discussions on January 9. KIA accepts AEM’s formal BACI application accounts for seasonal variation. AEM has indicated they will provide additional analysis during the technical hearings of how the current monitoring framework is capable of detecting changes. AEM also provided a good discussion of rational behind the power analysis used in the CREMP design.

11. Resolved Issues IR #IssueResolution KIA-IR-14Water quality parameters were only reported on when at least 10% of the samples exceeded the MDL. This presents a minimum threshold for discussion that may cause significant but acute changes to water quality to be overlooked. AEM has agreed to use the following reporting criteria for future CREMP reports: greater than 10% of the samples are above the MDL, and parameters that are detected less frequently than in 10% of samples but are >5x MDL in some samples where they were detected in nearfield stations. KIA-IR-15Some trigger values were exceeded at impact areas (e.g., copper [WAL], chromium [TPN] and zinc [SP, WAL] but which were within the range of baseline conditions. Zinc was not highlighted as a potential risk to the environment in the CREMP but was highlighted in the summary in the Main Supporting Document. Lead was found at above both the trigger and threshold concentrations in WAL sediment samples in August 2013 but was not highlighted in the text. AEM has agreed to bring forward threshold and trigger exceedances into the annual report textual discussions. The KIA acknowledge the natural 5% exceedance rate for thresholds developed using 95% of baseline. Exceedances for these parameters will be scrutinized for inconsistencies with baseline conditions, potentially proceeding to further assessment. AEM has agreed to provide further discussion of their adaptive management framework.

12. Resolved Issues IR #IssueResolution KIA-IR-16Chromium exceeded the trigger concentration in 2013 TPE sediments as reported in the CREMP. AEM planned a coring study for currently planned for 2014 to confirm the trend. AEM will provide the KIA with results of the coring study for review. The KIA acknowledge resolution of this IR follows from the discussion of KIA-IR-15. KIA-IR-17AEM has proposed to discontinue zooplankton and periphyton sampling. AEM posits zooplankton studies may still be appropriate for more intensive spatial gradient designs as those employed for targeted studies which are coupled with zooplankton-based toxicity testing. Also see KIA-IR-19 The KIA feel zooplankton results are applicable beyond toxicity testing and warrant inclusion in the CREMP. However, we are cognisant of the statistical limitations of zooplankton to discern mine related changes. The KIA agrees with AEM and accepts the removal of zooplankton from inclusion in the yearly CREMP monitoring. AEM has agreed to include zooplankton as a potential component of the adaptive management monitoring framework.

13. Resolved Issues IR #IssueResolution KIA-IR-18Depth samples are only collected when vertical profiling suggests the presence of stratification through, for example, “abnormally high conductivity measurements”. The KIA agrees with AEM that surface samples are adequate if the lake is well mixed but are concerned AEM only cites conductivity as the profile criteria for when depth sampling is required AEM amended instructions for field staff sampling as part of the CREMP: Field teams are to take samples at depth when vertical profiling suggests the presence of stratification (e.g., abnormally high conductivity or low oxygen measurements). KIA-IR-19The KIA agree with AEM’s statement “zooplankton variables are not realistically capable of detecting effects in a given year”. However, we are concerned with AEM’s decision to remove zooplankton from the CREMP. AEM’s response follows from KIA-IR-17 indicating the limitations of zooplankton as part of the standard CREMP. KIA-IR-20Event Monitoring is not clearly discussed in Spill Contingency Plan nor the Emergency Response Plan AEM will clarify event monitoring requirements in the next version of the Spill Contingency Plan which will be implemented along side of the Emergency Response Plan in the event of a spill.

14. Resolved Issues IR #IssueResolution KIA-IR-21AEM has proposed to simplify the number of monitoring groups used at each sample site. This is acceptable to the KIA but we stress adequate detection limits is a common problem when assessing environmental data. AEM proposes to use Multilab in Val-D’or with detection limits presented in Appendix B6. AEM has agreed to work with Multilab and ALS to meet the required detection limits proposed by the KIA. Minimum detection limits reflect the CCME guidelines for the protection of aquatic life. ParameterMultilab DL (mg/L)ALS DL (mg/L) Minimum Required DL (mg/L) Ortho-Phosphate0.010.0010.002 Total Phosphorus0.010.002 Dissolved Phosphorus0.010.002 Total Cyanide0.0050.00500.001 Free Cyanide0.0050.00500.001

15. Resolved Issues IR #IssueResolution KIA-IR-22Seepages have not been considered spills under the spill contingency plan. AEM will update the Spill Contingency Plan to include unanticipated seepages that can occur on the mine site. KIA-IR-23The maximum obtainable freshwater limit was violated in 2013 and in years prior. AEM attributed the 2013 exceedance to “problems associated with the booster pump and the reclaim barge at the North Cell TSF”. We are concerned with the impacts on Third Portage Lake during mine operation resulting from additional fresh water usage. The KIA is also concerned that the TSF storage capacity is sufficient to accommodate unused reclaim water during mine operation. AEM has provided further discussion regarding impacts of additional fresh water usage during mine operation in their response to KIA-IR-01B. AEM will also provide further discussion of conceptual plans to close the TSF during the technical meetings.

16. Resolved Issues IR #IssueResolution KIA-IR-24Modeling results are provided for several parameters including total but not free cyanide. The water quality report outlines potential elevated copper and ammonia concentrations in the pits after reflooding. AEM has agreed to comply with the KIA requests for: modeling results for free cyanide or commit to comparing total cyanide to the free cyanide guideline in all samples. modeling results in the water management report and plan indicating when pit water quality will meet CCME guidelines. AEM specified this information will be submitted in the final reclamation and closure plan one year prior to closure. Table 4.1: Comparison of originally predicted pit water quality vs. SNC(2014) modelled water quality

17. Resolved Issues IR #IssueResolution KIA-IR-26The KIA expressed concern regarding the collection of water quality samples at depth (e.g.: 1 MOB) as part of dike monitoring. AEM has provided additional clarity on monitoring activities sufficient to alleviate the KIA’s concern. KIA-IR-27The KIA are concerned AEM’s response to anomalous thermistor or piezometer stated as “increase monitoring frequency to assess progression of [the] anomaly” may be insufficient. The KIA requested a description of the monitoring frequency associated with AEM’s adaptive response. AEM stated provided further description of the monitoring frequency associated with geotechnical instrumentation sufficient to alleviate the KIA’s concern.

18. Resolved Issues IR #IssueResolution KIA-IR-28 GeoVector Proposed by GeoVector: AEM has proposed to replace the word “petroleum products” with “fuel” in the amalgamation of two license conditions. The KIA prefers use of “petroleum products” along side “fuel” as they are more inclusive (i.e. hydraulic fluid, motor oil, etc.) than the word “fuel”. AEM has agreed to include both terms in the water license. KIA-IR-29 GeoVector AEM has proposed adding the wording “if possible” to tailings revegetation efforts. AEM refers to their response to EC-10. The wording “if practical” will be used. The KIA are satisfied with this wording request the opportunity to review AEM’s assessment of “if Practical”. KIA-IR-30 GeoVector KIA requests that AEM report on and monitor the amount of PAG versus NPAG material in the Vault RSF in order to ensure that, if required, the RSF is capped with an appropriate amount of material to ensure that freezeback of the RSF occurs upon closure. AEM will include the requested information in the annual reports. KIA-IR-31 GeoVector The KIA requests that AEM include fugitive dust as part of closure and post-closure monitoring. AEM agreed to continue monitoring fugitive dust during closure and post-closure.

19. Outstanding Issue IR #IssueNext Steps KIA-IR-25The 2013 seepage at ST-16 into Lake NP2 resulted in elevated cyanide concentrations in the receiving environment. AEM instigated the Freshet Action Plan in 2014 in response. Water quality has improved in Lake NP-2 from 2013 but several key parameters implicated with the seepage from the RSF still exceeded CCME criteria: copper, nickel and cyanide. Further mitigation by AEM is required to improve water quality in Lake NP-2 and protect resident aquatic life in the receiving environment. AEM should provide discussion of what mitigation measures will be carried out in a separate undertaking.