CON M MIN INE August 31, 2018 Mackenzie Valley Land and Water - - PDF document

Miramar Northern Mining Ltd. – Con Mine PO Box 2000 Yellowknife, NT X1A 2M1 T 867.766.5317 F 867.873.6357 Dwight.Grabke@Newmont.com

MIRAM MIRAMAR R NO NORTH RTHERN RN MINING MINING L LTD.

CON M MIN INE

August 31, 2018 Mackenzie Valley Land and Water Board P.O. Box 2130 Yellowknife, NT X1A 2P6 Attention: Mavis Cli-Michaud, MVLWB Chair MNML public hearing presentation and revised draft copy of the proposed water licence Dear Ms. Cli-Michaud: In accordance with the schedule in the revised work plan, please find enclosed MNML’s public hearing presentation, and curriculum vitae of technical experts whom will be in attendance and supporting MNML at the public hearing. We are also enclosing a revised draft copy of the proposed water licence. This revision updates the version that was initially submitted with the Water Licence Application on December 15, 2017, and reflects commitments made by MNML throughout the application process to date. A blackline of the draft proposed licence against MNML’s current licence MV 2007L8-0025 is enclosed for the Board’s convenience. We thank the Board for its attention to this matter. Should you require additional information, please contact the writer by telephone at 766-5317, or by e-mail at the following address: Dwight.Grabke@Newmont.com Sincerely, Dwight Grabke, Environmental Manager Miramar Northern Mining Ltd. – Con Mine

1

Miramar Northern Mining Limited - Con Mine Remediation MV2017L8-0008 Public Hearing September 12th and 13th , 2018

2 2

MNML Introduction

• Seeking water licence renewal for Closure and post-Closure of Con Mine
• This will be the third successive licence for closure & reclamation
• NI L2-0040 (2000 – 2008); MV 2007L8-0025 (2008 – 2019)
• Con Mine has complied with licencing since requirements began in 1970s
• No incidents of lack of compliance
• Requested Term is for 15 years
• Allow for the completion of the closure plan
• Transition into post-closure, long-term water treatment and monitoring
• Acquisition of sufficient data to inform long-term decisions
• Rare example of privately funded, successful mine closure in the North

3 3

MNML Introduction

• MNML is committed to the successful reclamation of Con Mine site
• History of environmental compliance
• Board-approved Final Closure Plan is nearing completion
• Forward thinking;
• Bluefish Hydro,
• Autoclave,
• Vegetation Studies,
• Taylor Road Drainage Channel
• BATEA evaluations, including installation of modern water treatment plant (2015)
• Remediation effort 100% funded by MNML/Newmont, utilizing local contractors
• Lasting Positive Legacy

4 4

Newmont Mining Corporation

• Acquired former Con Mine in the acquisition of Miramar Mining Corporation in December 2007
• Never operated Con Mine, committed only to Closure
• Founded in 1921 and publicly traded since 1925, NYSE; NEM market cap. ~ $17B
• Approximately 24,680 employees and contractors, globally
• 2 sites in Canada currently in active / post-closure Con Mine, NT, and Golden Giant Mine, ON

With several other legacy sites in various stages of closure across the globe Our purpose is to create value and improve lives through sustainable and responsible mining. Mission: We transform mineral resources into shared value for our stakeholders and lead the industry in shareholder returns, safety, social responsibility and environmental stewardship. Vision: We will be recognized and respected for exceptional economic, environmental and social performance.

5 5

Project History

1948 1953 1961 1978 1983

1937 Construction

6 6

Negus Mine

• Construction 1938, first Gold in 1939
• Jock McNiven, Mine Manager, first MLA from the North

and First Mayor of Yellowknife

• Tailings deposited into the Negus TCA, Neil Lake, Pud

Lake.

• Underground workings acquired by Con Mine in 1952
• Additional reserves found at depth and mined by Con

Mine

7 7

Con Mine

• Con Claims Staked in 1935
• Construction 1936
• NWT first Gold Bar September 5, 1938
• Tailings originally deposited into Crank Lake, flowed into

Pud Lake

• Last Ore from Con 2003, Con Mining Operations ceased

and underground workings allowed to flood.

• Last Ore from Giant processed through Con Mill in 2004

8 8

Closure

2003 Mining Ceased

2004 Milling ceased 2007 Newmont 2007 Closure & Reclamation Plan Approved 2010 - 2011 Sludge Processed & Autoclave decommissioned 2015 New WTP 2020 CRP Completed On-going Seasonal WTP 50+years

9 9

Con Mine Continued

• Original Abandonment and Restoration Plan submitted in

2003, review deferred to working group (MCARWG) to assess and review section by section.

• 1977 water licence stipulates waste shall be directed towards

Meg Lake

• Dykes constructed to contain mining waste within Pud Lakes,

decant water directed via ditch to Meg Lake

• Arsenic Sludge and Calcines stored in containment ponds on
• surface. Processed through autoclave prior to its

decommissioning in 2010

• Final Closure and Reclamation Plan as agreed upon by the

MCARWG, January 2007, subsequently approved by Board in July 2007.

• In 2003 MCML Sold the Bluefish Hydro Facility for $10M,

funds transferred to a trust for reclamation Security.

10 10

Receiving Environment History

• Treated discharge to the Meg/Keg/Peg Lake water system

beginning in the 1980’s

• In the last 10 years, treated discharge occurred in 2007,

2008, 2010 and then between 2015 and 2018

• The water treatment plant operates seasonally, discharging
• nly during the open-water season, 45days on average
• The location of final discharge is at the southern extremity of

Lower Pud TCA, then drains into a channel that flows into the Meg/Keg/Peg Lake water system

• Enters Great Slave Lake at Jackfish Bay

11 11

Reclamation History

• Mining infrastructure Decommissioned
• All Surface openings capped
• Con dock and lakeside boiler house remediation
• Rat Lake south remediation
• Taylor Road Engineered Drainage Channel
• Surface Grading and Water Management
• Site Wide Engineered Drainage Network
• Approved tailings cover designs
• New Water Treatment Plant Constructed
• Vegetation Establishing site wide
• Minewater reached design pump elevation (67masl)

November 2017, originally estimated to reach the surface (~183masl) in 2014.

12 12

Reclamation Status

• CRP Nearing Completion
• Approved Covers in Place
• Openings to surface capped
• Structural Demolition

Complete

• Engineered Drainage

Channel Network Complete

• Vegetation Establishing
• Minewater Management
• On-going Water Treatment

13 13

Remaining Closure Tasks & Data Requirements

Vegetation

Vegetative Island Construction Maintenance Seed and Fertilizer Assessment, Adaptive Management, and Monitoring Acceptance

Minewater

Install Monitoring System Initiate Active Pumping Monitor Response in 3 shafts Establish Monitoring & Management Controls Long-term predictions and end-points

Middle Pud Storage Pond

On-going Water Treatment Complete Shoreline Stabilization Update Survey Data, Storage Curve, Water Balance, PMF/PMP Synthetic Toxicity analysis study Long-term predictions and end-points for restoring Natural drainage

Receiving Environment Response to Post- Closure Conditions.

Develop monitoring plan Implement monitoring plan yr 1-5 Convene focused working group Review monitoring results Establish realistic expectations for long-term recovered state

14 14

Licence Process to date

Dec 2017

• Water Licence Submission

March 1/2

• First Technical Session
• EQC, modelling, monitoring

March 23

• Discharge Criteria Concept Meeting
• Discussion on how to address stakeholder concerns, focus on

chloride

May 23

• Technical Workshop
• Overview of approach
• No results at that time

June 15

• Second Technical Session
• New limits for chloride
• Proposed delineation of regulatory mixing zone
• Additional monitoring – plume study and AEMP

Peg Lake 2017

15 15

Application Submission

• Adopt Amended MMER, now MDMER
• Maintain Environmental Effects Monitoring Program in lieu of AEMP
• Revised Surveillance Network Program proposed
• Annual summary reporting with Status of Environment Reporting every 5 years
• Supplemental reports in areas of uncertainty submitted with each SOE report
• Working group established in year six of licence

16 16

Technical Session #1

• Stakeholder concerns around water quality and EQC for parameters not

regulated under MDMER (chloride, sulphate, cadmium, nitrite)*

• MNML provided updated predictions and modelling under proposed EQC
• Additional loading through M-K-P and Jackfish Bay
• Treatability and Options Analysis for salt removal

Outcomes:

• Parties agreed that site specific challenges exist for the site and that a creative

solution will be required to balance project and regulatory requirements

• MNML agreed to the formation of a working group earlier than year six. Draft

TOR submitted by MNML

• Stakeholders requested additional time to review supporting documentation

17 17

Criteria Concept Meeting

• MNML and Golder reviewed options for a solution to the EQC concerns
• Proposed that a EQC based on an annual loading limit with some enhanced

downstream monitoring may warrant further consideration. Outcomes:

• As a concept the approach was deemed worthy of additional consideration
• Concern that annual loading could allow for intermittent effluent toxicity.
• Suggestions for receiver monitoring discussed.

18 18

Technical Workshop #1

Effluent Quality Criteria for Chloride

• Lab Study - Site-specific acute lethality threshold for chloride using site-relevant waters
• Desktop Study - Chronic SSWQO for chloride in the downstream receiving waters
• Model chloride concentrations in receiving water for different loading scenarios
• Develop EQC for chloride

Regulatory Mixing Zone

• Propose mixing zone boundary
• Compare predicted concentrations at the mixing zone boundary to chronic CCME

guidelines for the protection of aquatic life Future Monitoring

• Develop Draft AEMP Outline

19 19

Technical Workshop #2

• Maximum Grab Concentration for chloride proposed at 2,500 mg/L, based on the acute

lethality study completed; acutely lethal to Daphnia magna is not expected to occur below 2,500mg/L

• Mixing Zone boundary proposed at 600 m in Jackfish Bay
• SSWQO at mixing zone boundary of 260 mg/L1 chloride provides protection for chronic

effects

• Annual Loading limit of 450,000 kg/year chloride limits the volume of salts entering the M-

K-P system and, during average and wet years, concentrations are predicted to be:

• below the site-specific acute lethality threshold in the mixing zone
• below the chronic SSWQO at the mixing zone boundary most of the time (<75%)

1 – Elphick et al. 2011

20 20

Water Treatment Plant

• Original WTP commissioned in 1987, 2010 last treatment. In-situ treatment began

early 1980’s

• Average accumulated water surface and underground water since closure

180,000m3/yr

• Newmont elected to design and construct the New WTP
• design submitted to MVLWB as required by licence December 2011, plant was

constructed without comment, and commissioned in September 2015.

• WTP effectively removes suspended solids and accumulated metals, using ferric

sulphate co-precipitation

• Discharge through the WTP is estimated to average 45 days/year
• Analysis of available treatment options for other potential pollutants of concern within

the source water predictions, completed in 2017/2018.

21 21

WTP and Source Water

• WTP drafts water from the Middle Pud Storage Pond
• Surface Run-off from Upper & Middle Pud, Negus Pond and Blend Plant
• Surface Run-off from Crank Lake, Negus TCA, Neil Lake and Lower Pud
• SNP 25-9 & 40-9 water management area
• Starting in 2018 Minewater.
• Volumes discharged 2015 (90,038m3), 2016 (278,153m3), 2017 (238,828m3)

22 22

Surface Water

• Surface water quality has not yet achieved steady conditions under closure conditions, due

to continued modification and disturbance of TCA to stabilize the site.

• All surface stabilization effort anticipated to be complete by 2020.
• Surface water quality since closure has been below proposed Chloride EQC

23 23

Minewater

• Minewater elevation and quality at equilibrium are unknown, resulting in the current

management strategy.

• Hydrogeological study to determine static water elevation, originally completed – Golder 2003,

assessed again in 2013 water may exit 204Q, depending on permeability of near surface bedrock.

• Minewater quality is the primary driver of Chloride concern given high concentrations at depth

and unknown mixing characteristics

• Need time to determine volume and quality of water from mine workings which may require
• n-going treatment.
• Propose licence condition that dictates minewater management strategy through Site Water

Management Plan approval, rather than strict elevation to be maintained in the licence.

• Minewater that is discharged as flow to the surface either through treatment or passive flow

will meet EQC.

24 24

Groundwater

• Shallow Groundwater is monitored through SNP
• Elevation and Quality indicating steady state under current conditions
• Proposed SNP suggests sampling spring and fall, due to low variability outside and

between these periods

• Mine workings act as a local groundwater sink
• New wells may be required in locations described in the proposed SNP, should

minewater elevation be permitted to rise under an approved plan.

25 25

Water Levels

• Local climate and precipitation conditions impact:
• source water: volume, contributing ratio and overall quality
• Water elevations and contributing loading through Meg, Keg, and Peg Lakes
• Elevation and wetted parameter of Jackfish Bay

Meg Lake July 2015 Keg Lake July 2015

26 26

Retention Time and Management Response

• Extended retention time adds complication to management response to downstream

monitoring

• Model retention time through Meg, Keg, Peg Lakes exceeds the average annual treatment

period, 100 days in an average year

• Based on estimated flow and average depths

27 27

Proposed EQC

• Proposed EQC achieve SSWQO

and/or guidelines* at mixing zone boundary most of the time

• Maximum Grab Concentration for

Chloride proposed at 2,500 mg/L; expected effluent is not acutely lethal to Daphnia magna

• Annual Loading limit of 450,000

kg/year chloride limits the volume

• f salts entering the M-K-P

system.

• Note EQC change in 2021

28 28

Proposed EQC

• Lowering the Water Licence limits below the proposed discharge limits is not recommended.
• Proposed limits based on MDMER have very recently been studied and lowered, represent

best practice

• MNML recommends adopting MDMER-equivalent discharge limits to allow flexibility to optimize

the treatment of minewater under the predicted range of potential minewater concentrations.

• MNML has consistently treated sitewater so that it meets or, where feasible, has been

substantially lower than, the existing Water Licence Limits and MDMER discharge criteria.

• In the future, MNML will continue to treat the sitewater, not just to those limits, but to the lowest

concentrations technically and economically feasible.

29 29

Why a Chloride EQC

• Study has been completed to correlate acute lethality to Daphnia magna to the proposed

EQC using site relevant waters that considered a range in ionic compositions

• Proposed EQC is predicted to achieve SSWQO at the mixing zone boundary.
• EQC provides an additional measure of compliance at SNP 0040-1
• Provides a management tool for WTP operations and minewater management
• Lethality tests can be susceptible to failure for a variety of reasons, and have the potential to

yield different results under similar conditions

• Delayed results from lethal testing
• In time, chloride can likely either be measured directly at the plant or correlated to TDS or

conductivity

• History has shown that TDS and Chloride in Middle Pud increase throughout open water

season

30 30

Controlling Chloride Peaks

MNML agrees with the objective of controlling the peak concentrations and loading into the MKP system, given that: a) MNML's understanding of the source water is evolving; b) existing conditions in the MKP system are outside of MNML's control; and c) the best currently available and economically feasible technologies are being employed, MNML will continue to evaluate and manage both the source and effluent water quality in an effort to determine if and when peaks occur, and if and how they can be buffered through site water and discharge management.

31 31

Acute Chloride Lethality Study

• Acute lethality threshold should focus on D. magna as the more

sensitive species

• Definition of acute lethality to D. magna should mirror MDMER

For Daphnia magna:

• Study results - 48-hr LC50 (survival & immobility) ranged from 2,894

to 3,086 mg/L

• Threshold response in this study similar to published toxicity results

(2,565 to 3,630 mg/L chloride; Elphick et al. 2011; Mount et al. 1997; Biesinger and Christensen 1972)

• Toxicity results were generally similar across the mixtures
• Acute chloride lethality unlikely to occur under current, or future

predicted conditions at concentrations ≤ 2,500 mg/L

32

Mean Chloride Concentrations in Treated Effluent and Receiving Water

Proposed Chloride EQC

• Direction of flow is left to

right

• Some constituents, such as

chloride, increase through the system

• Due to M-K-P loadings, it

may be better to discharge annually (maintain flows in system)

• Modelling is calibrated to

actuals at SNP 0040-5

• More information is required

to further understand the system

33 33

Proposed Regulatory Mixing Zone

• Meets SSWQO for chloride at 600 m most of

the time (>75% of the time) during average hydrological conditions

• SSWQO determined using new data for

chloride sensitive Mayfly, C. Triangulifer

• Location is accessible by boat for field crew
• Depths at 600 m from the inlet of Jackfish Bay

are expected to be greater than 1 to 1.5 m during average hydrological conditions

34 34

SSWQO & Published Water Quality Objectives

A regulatory mixing zone at 600 m from the inlet of Jackfish Bay was proposed because:

• Based on current monitoring and modeling of the plume, the SSWQO for chloride is expected to be

met at 600 m from the inlet of Jackfish Bay most of the time (greater than 75% of the time) during average hydrological conditions.

• Based on the proposed EQC and range in predicted concentrations in the treated effluent, all other

parameters were predicted to be below chronic generic CCME water quality guidelines for the protection of aquatic life at 600 m from the inlet of Jackfish Bay, with the exception of arsenic (Golder 2018, MNML 2018).

• Background arsenic concentrations are above the chronic CCME water quality guideline in Jackfish

Bay and are predicted to remain within the historical range for the proposed EQC for arsenic (Golder 2018, MNML 2018).

35 35

What is Protected - Mixing Zone Boundary

Elphick et al. (2011) model with Streuwing data incorporated

• Median hardness at all locations in Jackfish

Bay higher than calibrated range

• SSWQO derived from maximum calibrated

hardness (160 mg/L as CaCO3)

• SSWQO = 260 mg/L Cl (rounded to two significant figures)

𝑋𝑅𝑃 = 79.02 𝑦 ln ℎ𝑏𝑠𝑒𝑜𝑓𝑡𝑡 − 138.28 SSD with C. triangulifer Updated hardness-dependent equation:

Proposed SSWQO

36 36

Conditions Linked to Toxicity / Lethality

• MNML agrees, treated effluent discharge as measured at SNP 0040-1 should not be Acutely

Lethal; subject to use of the phrase “acutely lethal” rather than “acutely toxic”.

• MNML’s toxicity testing was done with reference to MDMER standards and MNML is

proposing treated effluent quality that is not acutely lethal, as defined in the MDMER.

• MNML’s proposed EQC of 2,500 mg/L for chloride was based on a concentration that

showed no acute lethality to Daphnia magna in anticipation of the MDMER amendments effective in 2021.

• MNML recommends any reference to acute lethality to Rainbow Trout and Daphnia magna

be subject to the same definition and conditions as MDMER

37 37

Unsupported Conditions

• Given that :
• the SSWQO model conditions are based on the 75% percentile and;
• the Meg, Keg, Peg system and Jackfish Bay are influenced by cumulative effects

that are beyond MNML’s control and not well understood.

• Modelling of the predicted chloride concentrations indicates that acute lethality1 is

possible within the mixing zone under low flow/dry conditions in the absence of treated effluent, and that the addition of treated effluent reduces the potential and/or severity of these conditions during dry periods by reducing chloride concentrations.

• MNML cannot support compliance conditions based on a monitoring result from a

location beyond its influence or control.

1 as a result of predicted chloride concentrations above the site-

specific acute lethality threshold

38 38

Monitoring and Proposed AEMP

• Plume validation
• Effluent
• SNP (WQ, compliance for acute lethality and evaluation of chronic toxicity)
• Chloride loading will be calculated based on weekly analytical analysis, and

flowmeter readings

• Meg, Keg, and Peg lakes monitoring will be determined through the Working Group
• AEMP
• Builds on SNP and EEM monitoring + additional monitoring at the edge of the

regulatory mixing zone boundary

• Response Framework to address potential concerns in the receiving water
• More discussions are required prior to the finalization of the draft AEMP.
• AEMP design plan to be submitted to Board

39 39

First AEMP Design

MNML proposes options for consideration for the deadline of the first AEMP Design Plan, allowing time to incorporate stakeholder input:

• Option 1
• MNML will submit a brief 2019 sampling plan for review prior to the start of the 2019 open-water

field season.

• The review of the AEMP Design Plan will be ongoing through the open-water field season.
• MNML will complete the first field program under a final AEMP in 2020.
• Option 2
• MNML will submit the AEMP Design Plan for review in spring 2019, and commence the 2019 field

program while under review.

• Option 3
• MNML will submit the AEMP Design Plan within 90 days of issuance of the Water Licence and

stakeholders will review the document without consideration of the 2018 data (i.e., base AEMP on 2015 biological data). MNML’s preference is Option 1 or 2.

40 40

Working Group

Priority Topic Schedule Start Date Target Deliverable Date 1 Short Term Monitoring Plan for Meg, Keg, Peg Lakes; Review current data and conditions in the Meg, Keg, Peg lakes and provide recommendations where possible to the MVLWB regarding the short term monitoring plan for Meg, Keg, Peg chain of lakes. Spring 2019 Spring 2020 2 Closure Objectives and Criteria; Consider approved Objectives and Criteria, consider where necessary objectives and/or criteria for success. Schedule excludes M-K-P and Minewater. Fall 2019 Fall/Winter 2021 3 Long-Term Monitoring; Review current and future data and provide recommendations, where possible, to the MVLWB regarding the long-term monitoring requirements and plan for the project site and receiving environment. Spring 2022 Fall/Winter 2025 4 Minewater and Groundwater Flooding Criteria; Review available data and documentation on minewater and groundwater conditions, consider management strategy, and review potential alternative options available. Provide recommendations, where possible, to the MVLWB as to the future minewater management and criteria to increase flooding level and/or to allow passive discharge. Spring 2026 Fall/Winter 2028 5 Meg – Keg –Peg; Review short and long-term monitoring results to consider potential response to continued discharge. Spring 2027 or Earlier should data allow Fall 2031 6 Subsequent Water Licence; Review and provide recommendations, where necessary and possible, to the MVLWB as to the type, term, EQCs, and conditions for the subsequent Water Licence Application Package to be submitted Fall 2032. Fall 2030 Fall 2032

41 41

Reclamation Security

• MNML recommends that the security be maintained at $8,716,406, with updated reclamation

security estimates completed every 3 years, or annually at the request of any party.

• The current security is based on a previously agreed upon and approved discount rate of 3%
• ver a period of 100 years.
• The discount rate for long-term cash flow is not project, nor proponent specific, it is solely

dependent on the GNWT’s anticipated return on investment and inflation projections.

• MNML has engaged the GNWT in the past and in response to this recommendation, as part
• f an on-going effort by both parties to come to a lasting agreement for the Con Mine security

following devolution.

42 42

Closure

• MNML is committed to the success of the project, and achieving a walk away solution

for the site

• All elements of the Board-approved Closure Plan are nearly complete
• Remediation should result in positive impacts and response
• Need time to monitor and collect data to assess the response
• Caution about introducing regulatory controls for previously un-regulated parameters
• Lowering limits on several regulated parameters
• Committed to the development and implementation of an AEMP
• Committed to the formation of a working group to address outstanding items

43 43

Thank You

Mackenzie Valley Land and Water Board Water Licence Pursuant to the Mackenzie Valley Resource Management Act, Waters Act, and Waters Regulations, the Mackenzie Valley Land and Water Board, hereinafter referred to as the Board, hereby grants to:

Miramar Northern Mining Ltd. (Licensee)

• f

Box 2000, Yellowknife, NT XlA 2Ml (Mailing Address) hereinafter called the Licensee, the right to alter, divert, or otherwise use water subject to the restrictions and conditions contained in the Waters Act and Regulations made thereunder and subject to and in accordance with the conditions specified in this Licence. Licence Number: MV20072017L8-00250008 Licence Type: A Water Management Area: Northwest Territories 01 Location: Former Con Mine within the City of Yellowknife, NT (Latitude 62°26'00"” and Longitude 114°23'00"”) Purpose: To use water and dispose of waste and associated uses Description: Closure and ReclamationPost-Closure of the former Con Mine Quantity of Water not to be exceeded: Effective date of Licence: 200,000 cubic metres (m 3) per year March 31, 2008January 30, 2019 Expiry date of Licence: January 29,20192034 This Licence issued and recorded at Yellowknife includes and is subject to the annexed conditions. Mackenzie Valley Land and Water Board Approved by Minister of Environment and Natural Resources

PART A: SCOPE AND DEFINITIONS Scope This Licence entitles Miramar Northern Mining Ltd. to use water and dispose of Waste 1. associated with the Closure and Post Closure and Reclamation of the former Con Mine, located in Yellowknife, Northwest Territories (Latitude 62°26’00” and Longitude 114°23’00”). This Licence continues the approval of the existing plans, programs, studies and 2. manuals approved by the Board under Licence MV2007L8-0025 on their terms, including the Approved Final Closure Plan, titled Updated Closure and Reclamation Plan (UCRP 2014).

• 2. This Licence is issued subject to the conditions contained herein with respect to the

3. taking of water and the depositing of Waste of any type in any Waters or in any place under any conditions where such Waste or any other Waste that results from the deposits of such Waste may enter any Waters. Definitions In this Licence: MV2007L8-0025 “Act” means the Waters Act;2017L8-0008 “Act” means the Waters Act, SNWT 2014, c 18; “Action Level” a predetermined qualitative or quantitative event that, if met, requires the Licensee to take appropriate actions including, but not limited to: further investigations, changes to operations, or enhanced mitigation measures and reporting; “Adaptive Management” a process whereby monitoring results and observations are utilized to inform management decisions through the establishment of Action Levels; “Adaptive Management Phase” the period following the completion of the approved Closure and Reclamation plan, required to monitor the site conditions and perform work as required to ensure long term site stability and regulatory compliance; "Aquatic Effects Monitoring Program" a monitoring program designed to determine the short- and long-term effects in the Receiving Environment resulting from the former Con Mine; to evaluate the accuracy

• f

impact predictions; to assess the effectiveness of planned mitigation; and to identify additional impact mitigation measures to reduce or eliminate environmental effects. “Analyst” means an Analyst designated by the Minister under subsection 65(1) of the Act; “Annual Loading” means the total mass of a substance that is discharged from the water treatment plant to the Receiving Environment as measured by weekly sampling and flow meter readings at SNP 0040-1;

“Average Concentration” means the discreterunning average of up toany four consecutive analytical results collected and submitted to the Board in accordance with the sampling and analysis requirements specified in the Surveillance Network Program, where the parameter is sampled four or more times in a given year; “Board” means the Mackenzie Valley Land and Water Board established under Part 4 of the Mackenzie Valley Resource Management Act, SC 1998, c25; “Contact Water” means any surface water identified on the mine lease which is not directly fed from the previously disturbed area(s), this includes surface flow during freshet and precipitation events that drains through natural topography; “Discharge” the direct or indirect release of any Water or Waste to the Receiving Environment; “Engineered Structure” any structure or facility and the associated area related to Water Use or the deposit of Waste that is designed and approved by a Professional Engineer; “Final Closure Plan” means the Closure and Reclamation Plan for N1L2-0040 approved by the Board on April 23, 2007, as amended from time to time with the approval of the Board;, and includes the 2014 Updated Closure and Reclamation Plan (UCRP 2014), approved by the Board on June 9, 2016; and the 2018 Post Closure Monitoring and Maintenance Plan (PCMMP), pending review and approval by the Board; “Freeboard” means the vertical distance between water line and the lowest elevation of the effective water containment crest on a dam or dyke’s upstream slope; “Geotechnical Engineer” means a professional engineer registered with the Association

• f Professional Engineers, Geologists, and Geophysicists of the Northwest

Territories and whose principal field of specialization is the design and construction of earthworks in a permafrost environment; “Inspector” means an Inspector designated by the Minister under subsection 65(1) of the Act; “Licensee” means the holder of this Licence; “Maximum Concentration” means a concentration of a parameter listed in the Licence that cannot be exceeded in any one (1) sample; “Minewater” means ground water or any water used in mining that is pumped or flows out

• f any underground workings or open pit;

“Minister” means a duly appointed member of the Executive Council who is responsible for the Actor the department responsible for administering that Act; “Modification” means an alteration to a physical work that introduces a new structure or eliminates an existing structure and does not alter the purpose or function of the work,

but does not include an expansion; “Professional Engineer” a person who is registered with the Northwest Territories and Nunavut Association of Professional Engineers and Geoscientists (NAPEG) in accordance with the Engineering and Geoscience Professions Act, S.N.W.T. 2006, c.16, as a Professional Engineer, and whose principal field of specialization is appropriate to address the components of the undertaking at hand; “RECLAIM” means the current version of a computer-based spreadsheet program that is referred to by the Mine Site Reclamation Policy for the Northwest Territories, 2002, used to estimate mine reclamation costs; “Receiving Environment” the aquatic environment that receives any Water or Waste released from the undertaking; “Regulations” means Regulations promulgated pursuant to section 63 of the Act; “Response Framework” is a documented systematic approach for response when the results of a monitoring program indicate that an Action Level has been reached; “Response Plan” is a part of the Response Framework that describes the specific actions to be taken by the Licensee in response to reaching or exceeding an Action Level; “Seepage” includes water that drains, through or escapes from any structure designed to contain, withhold, divert or retain Water or Waste; “Sump” means an excavation at the toe of a dam intended to collect groundwater and Seepage from the Tailings Containment Area(s); “Tailings” means material rejected from the mill after the recoverable valuable minerals have been extracted; “Tailings Containment Area(s)” consists of the Tailings containment basin(s), both historic and recent, and the engineered structures designed to contain Tailings. The engineered structures are described in the 2006 Tailing Dam Summary Record of

• Construction. The historic Tailings include Crank Lake, Lower Pud Lake, Negus Lake,

and Neil Lake; “Updated Mine Reclamation Costs” means the costs of the mine closure and reclamation liability updated annually in accordance with Part G, Item 2; “Waste” means Waste as defined by section 1 of the Act; “Waste Disposal Facilities” means all facilities designated for the disposal of Waste; “Waste Rock” means all unprocessed rock materials, except ore and Tailings, which are produced as a result of mining and milling operations; “Waters” means any Waters as defined by section 1 of the Act; “Water Supply Facilities” compromises the area and associatedthe intake infrastructure as identified in Drawing Number Con 2133, entitled “C1 Rob Shaft Arsenic Plant Lake Water Supply (existing)”, revised June 6th, 1986and associated area to collect

and supply Water for the project; “Water Use” means a use of Water as defined by section 1 of the Act and shall include freshwater from all sources and Minewater, but does not include water collected for the purposes of treatment prior to discharge; and “Water Use Fee” means a fee for the use of Water as required by the regulations made under section 63 of the Act.

PART B: GENERAL CONDITIONS The Water Use Fee shall be paid annually in advance of any Water Use. 1. The Licensee shall maintain a security deposit of $7,823,190.008,716,406 and shall 2. maintain further security deposits in accordance with this section: Such further or other amounts of security may be required by the Board a) based on annual estimates of current mine reclamation liability filed in accordance with Part G, Items 3, 4 and 5 of this Licence or based on such other information as may be available to the Board; and Reductions to the security deposit may be granted by the Board based on b) annual estimates of current liability in accordance with Part G, Item 5 of this Licence or based on other such information as may be available to the Board. The security assessed under this Licence shall be available for closure and reclamation of all liabilities associated with the appurtenant undertaking. The security deposit shall be maintained until such a time as it is fully or partly 3. refunded by the Minister pursuant to section 35 of the Act. All information submitted to the Board, as required by this Licence, shall: 4. Be submitted in a form acceptable to the Board; a) Be in accordance with the Board’s March 2012 Document Submission b) Standards; and Include a section within each submission that identifies wherein the c) pertinent requirements of this Licence are addressed. The Licensee shall operate in accordance with approved plans, programs, studies 5. and manuals referred to in this Licence, including such revisions as may be made pursuant to the conditions of this Licence and as approved by the Board.

• 4. The Licensee shall file an Annual Report with the Board not later than March

6. 31st of the year following the calendar year reported which shall contain the following information:be in accordance with Schedule 1. a) the monthly and annual quantities in cubic metres of fresh water obtained from all sources; b) the monthly and annual quantities in cubic metres of all Waste discharged; c) a summary of Modifications and/or major maintenance work carried out on the Water Supply Facilities and Waste Disposal Facilities, including all associated structures; d) tabular summaries of all data generated under the Surveillance Network Program; e) a list of unauthorized discharges; f) an outline of any spill training and communications exercises carried out;

g) a summary of any closure and reclamation work completed and an outline

• f any work anticipated for the next year;

h) a summary of the monitoring activities and results obtained and any contingencies measures implemented; i) a summary of any studies requested by the Board that relate to Waste disposal, Water Use or reclamation, and a brief description of any future studies planned; j) any other details on Water Use or Waste disposal requested by the Board by November 1st of the year being reported; k) a description of any trenches and Sumps excavated; l) any revisions to the approved Contingency Plans; m) updates to the Solid and Hazardous Waste Management Plan; n) updates to the Mine Flooding Model;

• )

any revisions to the Final Closure Plan, including Updated Mine Reclamation Costs and Updated Reclamation Status Reports; p) a summary of disposal volumes of hazardous and non-hazardous Waste; and q) the amount of Waste treated. Beginning June 6th, 2022, and no later than every June 6th each 3 years thereafter 7. (2025, 2028, 2031), the Licensee shall submit to the Board, a Former Con Mine Status of the Environment Report. The Report shall be in accordance with Schedule 2. [NOTE: Timing to be aligned with AEMP/EEM Final Interpretive Reporting] Within 90 days following the submission of the Former Con Mine Status of 8. Environment Report the Licensee shall update the Con Mine Post Closure Monitoring and Maintenance Plan (PCMMP) and its components.

• 5. The Licensee shall comply with the Surveillance Network Program annexed to

9. this Licence, and any amendment to the said Surveillance Network Program as may be made from time to time, pursuant to the conditions of this Licence.The Licensee shall review the plans, programs, studies and manuals required by this Licence as part of the Post Closure Monitoring and Maintenance Plan, following the submission of each Former Con Mine Status of the Environment Report, [NOTE: Timing to be aligned with AEMP/EEM Final Interpretive Reporting] as required to reflect changes in operations, or as directed by the Board, and make any necessary revisions to reflect changes in operations. Unless otherwise specified by the Board all revised submissions shall be submitted to the Board at least 60 days prior to implementing any proposed updates or changes in the plan, program, study or manual. Any submission shall be accompanied by a brief summary of the changes made. All revised plans, programs, studies, and manuals shall be presented in a format consistent with the Board’s Standard Outline for Management Plans.

• 6. The terms of this Licence, including the Schedules, the Surveillance Network

10. Program, and any compliance dates specified in thethis Licence may be modifiedamended at the discretion of the Board. If any date for any submission falls on a weekend or holiday, the item shall be submitted on the following business day.

• 7. Meters, devices or other such methods used for measuring the volumes of water

11. used and Waste discharged shall be installed, operated and maintained by the Licensee to the satisfaction of an Inspector.

• 8. The Licensee shall, within sixty (60) days of the issuance of this Licence, post

12. the necessary signs, where possible, maintain the signs to identify the stations of the Surveillance Network Program to the satisfaction of an Inspector. All postings shall be located and maintained to the satisfaction of anInspector.

• 9. The Licensee shall replace or repair any monitoring wells that become

13. inoperable to the satisfaction of an Inspector. For greater certainty, a "dry well" is not an inoperable well within the meaning of this licence.

• 10. The Licensee shall ensure a copy of this Licence is maintained at the site of

14.

• peration at all times.

In conducting its activities under this Licence, the Licensee shall make best efforts 15. to consider and incorporate any scientific and Traditional Knowledge that is made available to the Licensee. PART C: CONDITIONS APPLYING TO WATER USE 1. The annual quantity of water used for all purposes shall not exceed 200,000 1. cubic metres. The licensee is permitted to construct, operate and maintain, drainage, channels, 2. sumps and dewatering infrastructure as required to collect surface and Minewater. This does not constitute a water use under the licence.

PART D: CONDITIONS APPLYING TO WASTE DISPOSAL The Licensee shall submit to the Board for approval 90 days prior to construction, 1. a detailed construction design report for the proposed cover to be used for the hazardous waste disposal site, and the former hazardous waste storage site at Con and Negus Ponds. The report will include but not be limited to the following:comply with the approved Final Closure Plan, and its components; rationale outlining how cover thickness will be determined;Site Water and a) Mine Flooding Management Plan materials to be used for construction;Solid and Hazardous Waste b) Management Plan the purpose of each component of the cover system;Emergency Response c) and Spill Contingency Plan a cost-benefit analysis

• f

the alternatives considered;Vegetation d) Establishment Monitoring Plan details on how the final design will be determined and tested;Surveillance e) Network Program an estimate of how much precipitation is expected to infiltrate through the f) cover and include a description of how the testing will be completed to verify how the non- woven geo-textile liner will maintain its anticipated infiltration rate;Standard Operating Procedures for Effluent and Water Quality Monitoring at Con Mine g) a construction quality assurance program; h) slope stability and methods of repair if settlement occurs; i) the designs that will be in place for drainage in these facilities so that water does not collect/pond; j) contingency measures to address unforeseen circumstances during construction; k) contingency measures to address unpredicted infiltration rates; and l) measurable criteria that will be used to assess cover performance, details

• n a monitoring program to ensure that the criteria are being met, and

details on any research that the Licensee needs to undertake to develop measurable performance criteria. An inspection of the hazardous waste disposal site, Tailing Containment Area(s), 2. and the former hazardous waste storage sites at Con and Negus Ponds, shall be carried out annually in June by a qualified GeotechnicalProfessional Engineer. The GeotechnicalProfessional Engineer's inspection report shall be submitted to the Board within sixty (60) days of the inspection, including a covering letter from the Licensee

• utlining

an implementation plan to respond to the GeotechnicalProfessional Engineer's recommendations. The Licensee shall submit to the Board for approval 90 days prior to construction, 3.

a detailed construction design report for the Tailings Containment Area(s). The report will include but is not limited to the following:Middle Pud Tailing Containment Area shall be operated and maintained in accordance with the Final Closure Plan and to engineering standards such that: a) rationale outlining how cover thickness will be determined; b) materials to be used for construction; c) the purpose of each component of the cover system; d) a cost-benefit analysis of the alternatives considered; e) details on how the final design will be determined and tested; f) an estimate of how much precipitation is expected to infiltrate through the cover and how this will be verified; g) criteria that will used to measure cover performance and details on a monitoring program to ensure that the criteria are being met; h) a contingency plan outlining measures to be implemented should the vegetative covers fail; and i) a dust management plan for work occurring on the Tailings Containment Area(s).

• 4. The Licensee shall provide to the Board within 90 days of issuance of the Water

Licence a protocol for determining which materials transferred into the hazardous

• r non- hazardous Waste landfills. The protocol will include but is not limited to

the following: a) estimated volumes of hazardous and non-hazardous Waste to be deposited into the landfills with the removal of each mine component; b) volumes of the hazardous or non-hazardous waste deposited to date including location of the deposit; c) details on how the placement of arsenic contaminated material in the Tailings covers will be avoided; and d) a Quality Assurance/Quality Control plan providing details about how the quality and quantity of the material being placed in the landfills and the quality of the material remaining will be monitored.

• 5. A Tailings Containment Area(s) shall be operated and maintained to engineering

standards such that: a Freeboard limit of 1.0 m shall be maintained at all times for the Middle Pud a) Tailing Containment Area, or as otherwise recommended by a GeotechnicalProfessional Engineer; the solid fraction of the mill Tailings within the Middle Pud Tailing b) Containment Area shall be permanently contained within the Tailing Containment Area(s);c) weekly that Pond; and visual examinations of the dam(s), and Sumps shall be carried out, and records of these examinations shall be kept for review upon the request of an Inspector. More frequentThe frequency of inspections shall be performed at the request of an Inspector.6. An inspection of the Tailing Containment Area(s) shall be carried out annually in June by a qualified Geotechnical Engineer. The Geotechnical Engineer's inspection report shall be submitted to the Board within

sixty (60) days of the inspection, including a covering letter from the Licensee

• utlining an implementation plan to respond to the Geotechnical Engineer's

recommendations.as recommended by a qualified Professional Engineer or an Inspector.

• 7. All Waste discharged from Middle Pud Tailing Containment Area that does not

4. meet the criteria set out in Items 7 and 8 of this Part, as applicable, shall be directed to the water treatment plant and subsequently to the Meg-Keg-Peg Lakes system, as illustrated in Drawing Number 2796, dated June 1986, at the point of discharge at SNP 0040-1, or as otherwise approved by the Board. Waste discharged from Middle Pud Tailing Containment Area that meets the criteria set

• ut in Items 7 and 8 of this Part, as applicable, may be directed without treatment

to the Meg-Keg-Peg Lakes system at the point of discharge at SNP 0040-1, or as

• therwise

approved by the Board.

• 8. No Waste discharge, Seepage or other flow from a Tailing Containment

5. Area(s), or Contact Water that does not meet the criteria set out for Maximum Concentration Grab Sample out in Items 7 and 8 of this Part, as applicable, shall be permitted at any time to enter surrounding water bodies.

• 9. The Licensee shall submit to the Board a Dust Monitoring and Mitigation Plan

prior to the demolition of the Mill complex and Robertson Shaft complex. A summary report of the dust monitoring activities performed during the demolition shall also be submitted.

• 10. The Licensee shall provide at least five (5) days notice to an Inspector prior to

6. the first proposed discharge of Waste from Middle Pud Tailing Containment Areathe water treatment plant during each calendar year.

• 11. All Waste discharged by the Licensee from a Tailing Containment Area(s), on

7.

• r before June 1, 2021, including discharge from the water treatment plant, at

SNP 0040-1, shall meet the following effluent quality requirements: Parameter Maximum Average Concentration Maximum Concentration Grab Sample Total Arsenic 0.50 mg/L 1.0 mg/L Total Copper 0.30 mg/L 0.60 mg/L Total Cyanide 0.80 mg/L 1.60 mg/L Total Lead 0.20 mg/L 0.40 mg/L Total Nickel 0.50 mg/L 1.0 mg/L Total Zinc 0.20 mg/L 0.40 mg/L Total Suspended Solids 15 mg/L 30 mg/L Total Petroleum Hydrocarbons 5.00 mg/L Chloride* 2,500 mg/L Any Waste discharged shall have a pH between 6.0 and 9.5. *Annual loading limit for Chloride of 450,000 kg/year. All Waste discharged by the Licensee from a Tailing Containment Area(s) after 8. June 1, 2021, including discharge from the water treatment plant at SNP 0040-1, shall meet the following effluent quality requirements: Parameter Maximum Average Concentration Maximum Concentration Grab Sample Total Arsenic 0.30 mg/L 0.60 mg/L Total Copper 0.30 mg/L 0.60 mg/L Total Cyanide 0.50 mg/L 1.00 mg/L Total Lead 0.10 mg/L 0.20 mg/L Total Nickel 0.50 mg/L 1.00 mg/L Total Zinc 0.50 mg/L 1.0 mg/L Total Suspended Solids 15 mg/L 30 mg/L Total Petroleum Hydrocarbons 5.00 mg/L

Un-ionized ammonia (expressed as nitrogen) 0.5 mg/L 1.0 mg/L Chloride* 2,500 mg/L Any Waste discharged shall have a pH between 6.0 and 9.5. *Annual loading limit for Chloride of 450,000 kg/year. If, during the period of this Licence, the concentration of any sample from 9. Surveillance Network Program SNP 0040-1 exceeds the requirement specified in Items 7 and 8 of this Part, as applicable, the Licensee shall immediately cease discharge and notify the Board and an Inspector, and shall take the necessary corrective action to mitigate the exceedance to the satisfaction of an Inspector. Minewater shall be managed in accordance with the Site Water and Mine 10. Flooding Management Plan. Any Minewater that reaches the surface as a result

• f the plan and that does not meet the criteria set out in Items 7 and 8 of this

Part, as applicable, shall be directed to the Middle Pud storage pond or directly to the Water Treatment Plant for treatment. Minewater that reaches the surface as a result of the plan and that meets the criteria set out in Items 7 and 8 of this Part, as applicable, may be directed without treatment to the Meg-Keg-Peg Lakes system at the point of discharge at SNP 0040-1, or as otherwise approved by the Board.

• 12. In the event that minewater quality in the shallow mine workings or at the

11. discharge point does not meet the limits outlined in Part D, Item 11, the Licensee shall commence pumping so that the minewater level is maintained at least forty (40) metres below ground surface or at 140 metres above sea level. Pumping shall continue until such time as the quality of the Minewater meets Water Licence effluent discharge quality requirements.Minewater quality does not meet the criteria set out in Items 7 and 8 of this Part, as applicable, the Licensee shall manage the Minewater as specified in the Site Water and Mine Flooding Management Plan. 13. The Licensee shall submit to the Board for approval an updated Solid and 12. Hazardous Waste Management Plan by December 1, 2008. A review of this plan shall be undertaken annually. 14. If not approved by the Board, the plan referenced in Part D, Item 13 shall be revised and resubmitted within six (6) months of receiving notification of the Board’s decision. 15. The Licensee shall submit to the Board for approval a Mine Flooding Plan by December 1, 2008 or before the water level in the mine is within fifty (50) metres from the ground surface whichever occurs first. The plan shall be updated annually as required to and shall include:, for approval, an Adaptive Management Plan for any Contact Water and Seepage from a presently known

• r identified source, demonstrated not to meet the quality criteria outlined in

Items 7 and 8 of this Part, as applicable. The Licensee shall not commence the Adaptive Management Phase until the Board has approved the Plan. This Plan shall include, but not be limited to the following: updated results from the Mine Flooding Model;A summary of mitigation a)

measures in place to prevent, reduce, or manage potential environmental impacts; measured volumes of water discharged and salinity;A list of all components b) to be monitored; delineation of discharge points and actions taken to control seepage that c) cannot be channelized to permit monitoring and mitigation if required; andA map and attached table or detailed legend illustrating monitoring and sampling locations; consideration of the possible impacts on receiving waters and mitigation d)

• ptions.A description, including detailed rationale, of the site-specific

monitoring activities required to identify impacts;

• 16. The Licensee shall provide a report to the Board for approval by December 1,

2008 addressing the stability of Dam 1, Dam 4 and the Taylor Road Dam. The report will be prepared and submitted by a Geotechnical Engineer and will assess long term dam stability in association with potential thawing of the foundation or ice-rich Tailings. Updates shall be included in the Annual Geotechnical Reports. The Annual Geotechnical Reports shall be submitted to the Board within sixty (60) days of the inspection.

• 17. The Licensee shall not remove the autoclave from site until such time as an

Updated Reclamation Status Report that includes the areas previously containing arsenic and calcine sludges has been submitted and approved by the Board. A description of monitoring protocols, methodologies, parameters, and e) frequency specific to each type of monitoring; A description of the quality assurance and quality control measures f) followed for each monitoring type; A description, including detailed rationale, of the monitoring endpoints (and g) Action Levels) for each parameter monitored;

A description of response actions (contingency plans) to be carried out if h) Action Levels are exceeded; and Any other item as directed by the Board. i) PART E: CONDITIONS APPLYING TO MODIFICATIONS The Licensee may, without written approval from the Board, carry out Modifications 1. to the Water Supply Facilities and Waste Disposal Facilities provided that such Modifications are consistent with the terms of this Licence and the following requirements are met: the Licensee has notified the Board in writing of such proposed a) Modifications at least sixty (60) days prior to beginning the Modifications; such Modifications do not place the Licensee in contravention of either the b) Licence or the Act; the Board has not, during the sixty (60) days following notification of the c) proposed Modifications, informed the Licensee that review of the proposal will require more than sixty (60) days; An Inspector has authorized the proposed Modifications and provided a d) letter of notification to the Board; and d) the Board has not rejected the proposed Modifications. e) Modifications for which all of the conditions referred to in Part E, Item 1 have not 2. been met may be carried out only with written approval from the Board. The Licensee shall provide to the Board as-built plans and drawings of the 3. Modifications referred to in this Licence within ninety (90) days of completion of the Modifications. PART F: CONDITIONS APPLYING TO CONTINGENCY PLANNING

• 1. The Licensee shall review the Contingency Plan and update the plan as

necessary to reflect changes in operation and technology. Any proposed updates to the Contingency Plan shall be submitted to the Board for approval.

• 2. If, during the period of this Licence, an unauthorized discharge of Waste occurs,

1.

• r if such a discharge is foreseeable, the Licensee shall:

employ the appropriate contingency plan; a) report the incident immediately via the 24-Hour NWT Spill Report b)

Line.Currently the number is at (867) 920-8130 in accordance with the instructions contained in the Spill Report Form NWT 1752/0593; and Report each spill and Unauthorized Discharge to the Board and an c) Inspector within 24 hours; and

c) submit to an Inspector, a detailed report on each incident not later than d) thirty (30) days after initially reporting the event. PART G: CONDITIONS APPLYING TO CLOSURE AND RECLAMATION The Licensee shall complete all continued remediation activities as described 1. in the approved Final Closure Plan, in accordance with any design specifications or best industry practices as applicable.

• 1. The Licensee may apply for a reduction in the amount of security set out in

2. Part B, Item 2 by filing an Updated Reclamation Status Report prepared in accordance with Part G, Items 4 and 5 for work completed in 2007.the Final Closure Plan.

• 2. The Licensee shall review the Final Closure Plan, and shall update the plan

3. as necessary to reflect directives of the Board, changes in operations, technology, and results of reclamation and/or other studies. Any proposed modifications of the Final Closure Plan shall be submitted to the Board for

• approval. The Licensee, shall submit any update of the Final Closure Plan and

a summary table that lists for each mine component: the closure objectives; a) preferred closure option and methods; b) related monitoring; and c) any outstanding reports, research or plans. d)

• 3. The Licenseelicensee shall in accordance with Schedule 1 provide to the

4. Board annuallyan annual water licence summary report. The Licensee shall provide to the Board with each submission of the Former 5. Con Mine Status of the Environment Report, as described in Schedule 2, item 1; an updated estimate of mine closure and reclamation liability, in accordance with the Final Closure Plan, using RECLAIM, or some other method acceptable to the Board that incorporates site-specific activities and appropriate unit costs used to estimate mine closure and reclamation costs. 4. The Licensee shall provide to the Board on February 28, 2009 and annually each year thereafter an Updated Reclamation Status Report detailing the closure and reclamation work undertaken by or for the Licensee during the previous calendar year(s). The Report will include the costs incurred during the year in undertaking the closure and reclamation work. The Updated Reclamation Status Report will take into account the closure and reclamation work undertaken and be certified by an independent professional engineer(s) registered in the Northwest Territories with recognized expertise in the

applicable discipline.

• 5. The Board will review the Updated Mine Reclamation Costs and Updated

6. Reclamation Status Report and determine the extent to which the reclamation work has reduced the estimated cost of the closure and reclamation work

• remaining. Where the Board is satisfied that the reclamation work undertaken

by the Licensee has reduced the liability associated for the closure and reclamation of the former mine, the Board may reduce the amount of the Security Deposit set out in Part B, Item 2. 6. The Licensee shall submit a Quarry Reclamation Plan to the Board for approval 60 days prior to commencement of any quarry operations. The plan shall include characteristics of the quarried rock to be used. Compliance with the Final Closure Plan specified in this Licence does not limit 7. the legal liability of the Licensee, other than liability arising from provisions of the Act and its Regulations. The Licensee shall provide to the Board annually beby March 31st as-built 8. drawings and closure and reclamation confirmation reports related to closure and reclamation work completed during the year. These reports shall be prepared by a qualified independent engineer(s) registered in the Northwest Territories with recognized expertise in the applicable discipline.Professional Engineer. PART H: CONDITIONS APPLYING TO AQUATIC EFFECTS MONITORING The Licensee shall design and implement an Aquatic Effects Monitoring Program 1. (AEMP) that meets the following objectives: To determine the short- and long-term effects of the former Mine on the a) Receiving Environment; To test the predictions made in the Water License Application Package or in b)

• ther submissions to the Board regarding the impacts of the former Mine on

the Receiving Environment; To assess the efficacy of mitigation that is used to minimize the effects of c) the former Mine on the Receiving Environment; and To provide an early warning system where the results of the AEMP are used d) to avoid adverse effects through the Response Framework and/or regular evaluation of the AEMP The Licensee shall implement the Draft AEMP Design Plan submitted in the June 2. 15, 2018 submission to the Board until an updated AEMP Design Plan is approved by the Board. The Licensee shall submit an updated AEMP Design Plan within [XX] months 3. after issuance of the License that reflects directives from the Board.

The Licensee shall submit a revised AEMP Design Plan to the Board for approval 4.

• n December 31, 2020, then every 3 (three) years thereafter or as directed by the

Board, for the Term of this Licence. The AEMP Design Plan shall satisfy the requirements of Schedule 3, Condition 1. On or before March 31 each year, the Licensee shall submit an Annual Monitoring 5. Report to the Board for approval. This report shall include information relating to data collected in the preceding calendar year, and satisfies the requirements of Schedule 3, Condition 2. On or before June 6, 2022, then every third year thereafter, the Licensee shall 6. submit an AEMP Comprehensive Monitoring Report to the Board for approval. This report shall include information relating to data collected in the preceding 3 (three) calendar years and satisfies the requirements of Schedule 3, Condition 3. The Licensee shall submit an Aquatic Effects Re-evaluation Report for Board 7. approval in September 2023, then every 6 (six) years thereafter. The Licensee shall submit an AEMP Response Plan to the Board for approval, 8. and shall satisfy the requirements of Schedule 3, Condition 5. If any Action Level as defined in the approved AEMP Response Plan is 9. exceeded, the Licensee shall: notify the Board within 60 (sixty) days of when the exceedance is detected; a) and within 90 (ninety) days of when the exceedance is detected, submit a b) Response Plan that satisfies the requirements of Schedule 3, Condition 5 to the Board for approval. The Licensee shall implement the AEMP Response Plan as and when approved 10. by the Board. The Licensee shall submit a revised AEMP Response Plan as directed by the 11. Board. MACKENZIE VALLEY LAND AND WATER BOARD Mavis Cli-Michaud, Chair Amanda Gauthier, Witness

Schedule 1 Attached to Water Licence MV2017L8-0008 Annual Water Licence Summary Report The Annual Water Licence Summary Report referred to in Part B, item 6, may 1. consist of a compilation of previously submitted monthly reports for the reporting period, and shall include, but not be limited to, the following information: A summary of activities as they relate to Water Use and Waste disposal. a) A summary of the calibration and status of the meters and devices referred b) to in Part B of this Licence. A summary of construction activities, if any, undertaken during the previous c) year calendar year. A summary of Modification activities and major maintenance activities d) undertaken during the previous calendar year. A summary of activities conducted in accordance with the approved Final e) Closure Plan undertaken during the previous year, including; A high level assessment and description of the reclamation status in i. each of the areas and monitoring plans: (Improving, sustained, deteriorating); A description of any action thresholds or trigger levels that have ii. been reached or exceeded or conditions requiring closer monitoring in the following year; A timeline for the development and submission of any proposed iii. action or response required as a result of monitoring; Follow up report(s) on any actions or responses that were previously iv. flagged as a concern or requiring action; A summary of all analytical data collected throughout the year; v. Monthly and Annual Volumes of all freshwater obtained; vi. Monthly and Annual Volumes of all waste water treated and vii. released; Monthly and annual quantities in cubic metres of water accumulated viii. and stored within the Middle Pud Storage Pond, broken down by source; Annual quantities in cubic metres of all non-hazardous waste placed ix. in the landfill; and

A summary of any closure and reclamation work completed. x. A summary of activities conducted in accordance with the approved Spill f) Contingency Plan, including a list and description for all unauthorized discharges that occurred during the previous calendar year, including the date, NWT spill number, volume, location, summary of the circumstances and follow-up actions taken, and status (i.e. open or closed). An outline of any spill training and communications exercises carried out g) during the previous calendar year. Tabular summaries of all data and information generated under the h) Surveillance Network Program and graphical summaries of parameters with effluent quality criteria referred to in Part D, at the points of compliance compared to the quality criteria under Part D of this Licence. A summary of actions taken to address concerns, non-conformances, or i) deficiencies in any reports filed by an Inspector. Any other details on Water use or Waste disposal requested by the Board j) by November 1st of the year being reported.

Schedule 2 Attached to Water Licence MV2016L8-0003 Former Con Mine Status of the Environment Report The Former Con Mine Status of the Environment Report referred to in Part B, item 1. 7, shall include, but not be limited to, the following information: The compilation of all summary data from Schedule 1 over the reporting a) period; A detailed analysis of the monitoring data, evaluated against the applicable b) closure criteria and/or monitoring end points, A water quality trend analysis to asses any detectable change over the c) reporting period. A review of any action levels/thresholds, adaptive management triggers for d) the subsequent period, including adjustment as required. A review and update of the Final Closure Plan and associated plans e) for the subsequent period. Any other item as directed by the Board f)

Schedule 3 Attached to Water Licence MV2016L8-0003 Aquatic Effects Monitoring The AEMP Design Plan referred to in Part H, Item 4 describes the monitoring 1. conducted for the AEMP associated with the former Con Mine. The AEMP Design Plan shall include, but not be limited to, the following: A conceptual site model that describes the pathways of potential effects a) from the former Mine to the aquatic ecosystem. The conceptual site model will clearly define testable hypotheses for the AEMP as well as a justification of assessment and measurement endpoints. A description of the types of and need for monitoring conducted under the b) AEMP: Monitoring for the purpose of measuring Mine-related effects on the i. following components in Jackfish Bay: Surface water quality; a) Sediment quality; b) Toxicity testing at the edge of mixing zone; c) Benthic invertebrates; and d) Small-bodied fish health; e) Monitoring for the purpose of assessing mixing of treated mine water ii. in Jackfish Bay Monitoring to verify or characterize changes in contaminants and iii. exposure, potential receiving environment toxicity, and resulting field effects on biological components. A description of the AEMP Design Plan in Part H, Item 4 shall c) include: a description of the area to be monitored including maps showing i. sampling locations as well as the overall predicted zone of influence

• f the former Mine;

the variables, sample media, monitoring protocols, and Quality ii. Assurance/Quality Control (QA/QC) procedures; a description of the sampling program, including a description of iii. sampling frequencies for each component;

a description

• f

procedures to analyze and interpret data iv. collected for each component; the QA/QC procedures to be followed during monitoring and data v. analysis such that continuity, consistency, validity, and applicability of monitoring results will be maintained. a description of how relevant SNP monitoring will be incorporated vi. into the AEMP; A description of the approaches to be used to evaluate and adjust the d) AEMP; and Procedures to minimize the impacts of the AEMP on fish populations and e) fish habitat. A description of an AEMP Response Framework that will include: f) definitions, with rationale, for Action Levels applicable to the aquatic i. Receiving Environment. For each Action Level: A description of the rationale a) A description of how exceedances of Action Levels will be b) assessed; and A general description of what types of actions may be taken if an c) Action Level is exceeded. A description of the Annual AEMP Report format. g) A plain language description of the program objectives, methodology, and h) interpretative framework. The Annual Monitoring Report will referred to in Part H, Item 5 shall include, but 2. will not be limited to, the following: A summary of monitoring activities conducted; and a) Tabular summaries of data and information generated under the b) SNP/AEMP in an electronic and printed format acceptable to the Board. The AEMP Comprehensive Report referred to in Part H, Item 6 shall include, but 3. will not be limited to, the following: A plain language summary of the major results obtained in the preceding a) calendar year and a plain language interpretation of those results; A summary of activities conducted under the AEMP; b) An update of the project development activities and any accidents, c) malfunctions, or spills within the report time frame that could influence the

results of the AEMP; Tabular summaries of all data and information generated under the AEMP d) in an electronic and printed format acceptable to the Board; An interpretation of the results, including an evaluation of any identified e) environmental effects that occurred as a result of the former Mine; An analysis that integrates the results

• f

individual monitoring f) components collected in a calendar year and describes the ecological significance of the results; A comparison of monitoring results to Action Levels as set in the AEMP g) Design Plan; An evaluation of the overall effectiveness of the AEMP to date; h) Recommendations, with rationale, for changes to any aspect of the AEMP i) Design Plan; Recommendations for refining the AEMP to improve its effectiveness as j) required; and Any other information specified in the approved AEMP Design Plan or k) that may be requested by the Board. The Aquatic Effects Re-evaluation Report referred to in Part H , Item 7 shall 4. include, but not be limited to, the following: A review and summary of AEMP data collected to date including a a) description of overall trends in the data and other key findings of the monitoring program; An analysis that integrates the results of individual monitoring components b) (e.g., water quality, sediment, fish health, etc.) to date and describes the

• verall ecological significance of the results;

A comparison of measured Mine-related aquatic effects to predictions c) made during the Water License Application and an evaluation of any differences and lessons learned; A plain language summary of the major results of the above analyses and d) a plain language interpretation of the significance of those results; Recommendations, with rationale, for changes to Action Levels; e) Recommendations, with rationale, for changes to any aspect of the f) Conceptual AEMP Design Plan; and Any other information required as requested by the Board. g) The AEMP Response Plan referred to in Part H, Items 8 and 9 shall contain the 5.

following information for each parameter that has been reported in the AEMP Annual Report to have exceeded an Action Level: A description of the parameter, its relation to Significance Thresholds and a) the ecological implication of the Action Level exceedance; A summary of how the Action Level exceedance was determined and b) confirmed; A description of likely causes of the Action Level exceedance and potential c) mitigation options if appropriate; A description of actions to be taken by the Licensee in response to the d) Action Level exceedance including: i. a justification of the selected action, which may include a cost/benefit analysis; ii. a description of timelines to implement the proposed actions; iii. a projection of the environmental response to the planned actions, if appropriate; iv. a monitoring plan for tracking the response to the actions, if appropriate; and v. A schedule to report on the effectiveness of actions and to update the AEMP Response Plan as required. Any other information necessary to assess the response to an Action e) Level exceedance or that has been requested by the Board.

ANNEX A: SURVEILLANCE NETWORK PROGRAM LICENSEE: Miramar Northern Mining Ltd. LICENCE NUMBER: MV20072017L8-00250008 EFFECTIVE DATE OF LICENCE: March 31, 2008January 30, 2019 EFFECTIVE DATE OF SURVEILLANCE NETWORK PROGRAM (SNP): March 31, 2008January 30, 2019 Updated April 10, 2014 Surveillance Network Program Description and Monitoring Requirements A. The location of sampling sites and specific monitoring requirements are as follows: 1. Surveillance Network Program (SNP) 0040-1: (active): Description: Treated effluent from the Tailings Containment Area Location: UTM 11V (NAD 83) 635414.00E, 6924774.00N Sampling Frequency: 24-hour composite sample during effluent discharge to the Meg-Keg-Peg Lakes System. If the twenty-four (24) hour sampler failsWeekly during periods of effluent discharge to the Meg- Keg- Peg Lakes system, grab samples shall be collected Once per month during periods of effluent discharge to the Meg- Keg-Peg Lakes System. Once per year during periods

• f effluent

discharge to the Meg- Keg-Peg Lakes System. Monthly during discharge for the purpose of performing a static “pass/fail” bioassay for both rainbow trout and Daphnia spp. (per Environment Canada’s Environmental Sampling Parameters: pH, Water Temperature Total Ammonia Total Suspended Solids, Total Arsenic, Total Copper, Total Nickel Total Lead Total Zinc Total Cyanide Chloride Total Ammonia,Metals3 + Total Mercury, Arsenic (Total and Dissolved), Alkalinity, Major Ions1 Nutrients2 Total Petroleum Hydrocarbons, Nitrite and Nitrate, Total Phosphorous, Dissolved Metals3 + Dissolved Mercury Sulphide BTEX4

ICP Metals Scan including but not limited to the following Total and Dissolved elements: Cadmium, Manganese, Iron, Chromium, Nickel, Zinc, Copper, Lead Major Ions including but not limited to the following: Chloride, Hardness, Magnesium, Sodium, Sulphate, Sulphide, Calcium, Potassium

Surveillance Network Program (SNP) 0040-2: (inactive)

Description: Freshwater intake at the Yellowknife Bay Pumphouse. Location: The practice of taking freshwater from Great Slave Lake ceased permanently in 2010. Sampling Frequency: Sampling Parameters: Surveillance Network Program (SNP) 0040-5: (active) Description: Outflow of the Meg-Keg-Peg Lakes System to Great Slave Lake. Location: 634007.00E, 6919277.00N Sampling Frequency: Once per month during periods of

• pen Water,

Once per year during periods of open Water Twice each year at Spring break-up and before freeze-up in the Fall Sampling Parameters: pH, Total Ammonia, Total Cyanide, Total Dissolved Solids, Alkalinity, Nitrate Total Petroleum Hydrocarbons, Nitrate and Nitrite, Mercury, Dissolved Metals3 Total + Dissolved Mercury Nutrients2 BTEX4 Performing a static “pass/fail” bioassay for both rainbow trout and Daphnia spp. (per Environment Canada’s Environmental Protection Series Biological Test MethodsFor the purpose of performing a multi-concentration acute Surveillance Network Program (SNP) 0040-6: (activeinactive) Description: Taylor Road Dam pumping station Location:

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635125.00E, 6926037.00N

Sampling Frequency: Weekly during periods of flow. Prior to installation of the Taylor Road Sewer/Engineered Drainage Channel, water shall be sampled prior to and during pumping of water from the north side of Taylor Road Dam to Kam Lake. When the Taylor Road Sewer/Engineered Drainage Channel is installed, the location of the sampling station will change from 0040-6 to Sampling Parameters: pH Total Arsenic, Total Copper, Total Cyanide, pH

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Surveillance Network Program (SNP) 0040-9: (active) Description: Drainage pathway between Lower Pud basin and Kam Lake. Location: 634647.00E, 6924444.00N Sampling Frequency: Twice monthlyMonthly during periods of flow Sampling Parameters: pH, Total Suspended Solids, Total Arsenic, Total Copper, Total Cyanide Total Metals3 Surveillance Network Program 0040-10: (active) Description: Drainage from Lower Pud basin before it enters Meg Lake. Location: 635228.00E, 6923536.00N Sampling Frequency: Once per month during periods of open Water Once per year during periods of open Water Sampling Parameters: pH, Conductivity Total Ammonia, Total Cyanide, Total Dissolved Solids, Alkalinity, Nitrate Total Petroleum Hydrocarbons, Nitrate and Nitrite, Mercury, Arsenic (Total and Dissolved), Conductivity, Total Kjeldahl Dissolved Metals3 Total and Dissolved Mercury Nutrients2 BTEX4 Surveillance Network Program 0040-12: (active) Description: South end of Rat Lake. Location: 635950.00E, 6926351.00N Sampling and Analysis Once per month during periods of open water Once per year during periods of open Water Sampling Parameters: pH Total Arsenic, pH Dissolved Metals3 Surveillance Network Program (SNP) Station 0025-7: (active) Description: Surface water sampling station in Kam Lake immediately downstream of 0040-9 Location: Sampling Frequency: Once per month during periods of open water Once per year during periods of open Water Sampling Parameters: pH Field Temperature, pH, Total Suspended Solids, Total Arsenic, Total Copper, Total Dissolved Metals3 Total Cyanide

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Surveillance Network Program 0025-8: (activeinactive) Description: Surface water sampling station at or near the outfall of the Water Treatment Plant discharge downstream of the Lower Pud TCA. Location: Sampling Frequency: Monthly during discharge at SNP 40-1 Sampling Parameters: pH, Total Suspended Solids, Total Arsenic, Total Copper, Total Cyanide Surveillance Network Program 0025-9: (active) Description: Surface water sampling station between Middle Pud TCA and 0025-5 at the Lease Boundary. Location: 634802.00E, 6924468.00N Sampling Frequency: Twice monthlyMonthly during discharge at SNP 40-1flow Sampling Parameters: pH, Total Suspended Solids, Total Arsenic, Total Copper, Total Cyanide Total Metals3 Surveillance Network Program 0025-10: (active) Description: Surface water sampling station at the lease boundary north of the Upper Pud TCA in the vicinity where the Taylor Road engineered drainage channel is to be engineered. Location: In proximity to 0040-6. Exact location TBD once channel is installed.634506E, Sampling Frequency: Post installation of the Taylor Road Sewer/Engineered Drainage Once per year during periods of flow Sampling Parameters: pH Total Arsenic, Total Copper, Total Total Cyanide Surveillance Network Program 0025-11: (inactive) Description: Surface water sampling station near the downstream outfall of the culvert under the road at Garden Draw. Location: This station was destroyed during the expansion of the Con Mine trailer park. Sampling Frequency: Sampling Parameters:

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Surveillance Network Program 0025-12: (active) Description: Minewater sampling station at Robertson Shaft. Location: Sampling Frequency: Quarterly once minewater levels reach the 150 metre levelTwice a year when no dewatering is occurring, monthly during active dewatering Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), pH Conductivity, Turbidity, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Total Dissolved Solids, Alkalinity, Total Petroleum Hydrocarbons, Nitrite and Nitrate, pH ICP Metals Scan including but not limited to the following Total and Dissolved elements: Cadmium, Manganese, Iron, Chromium, Nickel, Zinc, Copper, Surveillance Network Program 0025-13: (active) Description: Minewater sampling station at C-1 Shaft. Location: Sampling Frequency: Quarterly once minewater levels reach the 150 metre levelTwice a year when no dewatering is occurring, monthly during active dewatering Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), pH Conductivity, Turbidity, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Total Dissolved Solids, Alkalinity, Total Petroleum Hydrocarbons, Nitrite and Nitrate, pH ICP Metals Scan including but not limited to the following Total and Dissolved elements: Cadmium, Manganese, Iron, Chromium, Nickel, Zinc, Copper, Surveillance Network Program 0025-14: (active) Description: Minewater sampling station at Negus Shaft. Location: Sampling Frequency: Quarterly once minewater levels reach the 150 metre levelTwice a year when no dewatering is occurring, monthly during active dewatering Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), pH Conductivity, Turbidity, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Total Dissolved Solids, Alkalinity, Total Petroleum Hydrocarbons, Nitrite and Nitrate, pH ICP Metals Scan including but not limited to the following Total and Dissolved elements: Cadmium, Manganese, Iron, Chromium, Nickel, Zinc, Copper, Lead

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Surveillance Network Program 0025-15: (active) Description: Minewater sampling station at 204Q Stope. Location: Sampling Frequency: Quarterly once minewater levels reach the 150140 metre level and only if seepage is observed Annually Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), pH Conductivity, Turbidity, Total Kjeldahl Nitrogen, Total Phosphorous, Suspended Solids Total Cyanide, Total Dissolved Solids, Alkalinity, Total Petroleum Hydrocarbons, Nitrite and Nitrate, pH ICP Metals Scan including but not limited to the Turbidity, TSS, pH, conductivity, major ions1, nutrients2, CCMS scan3 (total and dissolved), total mercury, total arsenic, Surveillance Network Program (SNP) 0025-16: (active) Description: Groundwater monitoring well to be(deep) located at the lease boundary near the former SNP 40-8 and between the Middle Pud and Kam Lake. Location: 634672.60E, 6925010.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) 0025-17: (active) Description: Groundwater monitoring well to be located at east limit of Crank Lake (near the gatehouse). Location: 636123.30E, 6925723.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow and only if there is sufficient water present to purge the well prior to sampling Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved

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Surveillance Network Program (SNP) Station 0025-18: (active) Description: Groundwater monitoring well to be located at Garden Draw, downstream of the well at the gatehouse Location: 636456.20E, 6925952.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Surveillance Network Program (SNP) Station 0025-19: (active) Description: Groundwater monitoring well to be located downslope from the Dam 2/Dam2 North Location: 634717.90E, 6924948.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-20: (active): Description: Groundwater monitoring well located south of Rat Lake and inside the main mine lease. Location: 635827.00E, 6926163.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow and only if there is sufficient water present to purge the well prior to sampling Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Surveillance Network Program (SNP) Station 0025-21: (active) Description:

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Groundwater monitoring well located south of Rat Lake and inside the main mine

• lease. (Formerly known as MW04-02).

Location: 635946.00E, 6926121.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow and only if there is sufficient water present to purge the well prior to sampling Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-22: (active) Description: Groundwater monitoring well located in the Historic Crank Lake TCA area. (Formerly known as MW04-03). Location: 636020.00E, 6925736.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow and only if there is sufficient water present to purge the well prior to sampling Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 Surveillance Network Program (SNP) Station 0025-23: (active) Description: Groundwater monitoring well located in the Negus pond area. (Formerly known as MW04-04). Location: 636221.00E, 6925604.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4

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Surveillance Network Program (SNP) Station 0025-24: (active) Description: Groundwater monitoring well located in the Negus pond area. (Formerly known as MW04-05). Location: 636229.00E, 6925500.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 Surveillance Network Program (SNP) Station 0025-25: (active) Description: Groundwater monitoring well located in the Historic Crank Lake TCA area. (Formerly known as MW04-06). Location: 635935.00E, 6925636.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 Surveillance Network Program (SNP) Station 0025-26: (inactive) Description: Groundwater monitoring well. (Formerly known as MW05-07). Location: This station was destroyed during Con Mine trailer park expansion. Sampling Frequency: Monthly during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4

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Surveillance Network Program (SNP) Station 0025-27: (active) Description: Groundwater monitoring well. (Formerly known as MW05-08). Location: 636450.00E, 6925952.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-28: (activeinactive) Description: Groundwater monitoring well. (Formerly known as MW05-09). Location: 635864.00E, 6925730.00N, This well is damaged and can no longer be sampled. Sampling Frequency: Monthly during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-29: (active) Description: Groundwater monitoring well. (Formerly known as MW05-10). Location: 635866.00E, 6925738.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow and only if there is sufficient water present to purge the well prior to sampling Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4

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Surveillance Network Program (SNP) Station 0025-30: (active) Description: Groundwater well Location: 635120.30E, 6926031.00N Sampling MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 Surveillance Network Program (SNP) Station 0025-31: (active) Description: Groundwater well Location: 635071.10E, 6924609.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-32: (active) Description: Groundwater well Location: 636430.70E, 6925032.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved

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Surveillance Network Program (SNP) Station 0025-33: (active) Description: Groundwater well Location: 635941.20E, 6925634.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow and only if there is sufficient water present to purge the well prior to sampling Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-34: (active) Description: Groundwater well Location: 635871.00E, 6925742.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-35: (active) Description: Groundwater well Location: 635947.80E, 6926113.00N Sampling Frequency: MonthlyTwice a year during periods of groundwater flow Sampling Parameters: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity, BTEX4

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Surveillance Network Program (SNP) Station 0025-16A: (active) Description: Groundwater well located at the lease boundary near the former SNP 40-8 and between Middle Pud and Kam Lake Location: 634658E, 6925006N Sampling Frequency: Twice a year during periods of groundwater flow Sampling Parameters: pH Conductivity Turbidity Total Cyanide Dissolved Metals3 Nutrients2 Major Ions1 Surveillance Network Program (SNP) Station TBD: (active) Description: Middle Pud Location: 635127.4E, 6924914N Sampling Frequency: Annually during freshet and monthly during treatment Sampling Parameters: pH Conductivity Total Cyanide Total Metals3 + Total Mercury Major Ions1 Nutrients2 Total Petroleum Hydrocarbons Surveillance Network Program (SNP) Station TBD: (inactive) Description: Groundwater well to be located northwest of Middle Pud Tailings Containment Area Location: 634812.5E, 6925313N or alternate suitable location to be determined. Updated coordinates will be provided once installation is complete. Sampling Frequency: Twice a year during periods of groundwater flow Sampling Parameters: pH Conductivity Turbidity Total Cyanide Dissolved Metals3 Nutrients2 Major Ions1

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Surveillance Network Program (SNP) Station TBD: (inactive) Description: Groundwater well to be located south of Lower Pud Tailings Containment Area Location: 635359.8E, 6924012N

• r alternate suitable location to be determined. Updated coordinates will be provided
• nce installation is complete.

Sampling Frequency: Twice a year during periods of groundwater flow Sampling Parameters: pH Conductivity Turbidity Total Cyanide Dissolved Metals3 Nutrients2 Major Ions1 Surveillance Network Program (SNP) Station TBD: (inactive) Description: Groundwater well to be located east of Crank Lake Tailings Containment Area Location: 636211.2E, 6925813N or alternate suitable location to be determined. Updated coordinates will be provided once installation is complete. Sampling Frequency: Twice a year during periods of groundwater flow Sampling Parameters: pH Conductivity Turbidity Total Cyanide Dissolved Metals3 Nutrients2 Major Ions1 Surveillance Network Program (SNP) Station TBD: (inactive) Description: Groundwater well to be located southeast of SNP 0025-18 Location: 636564.7E, 6925732N or alternate suitable location to be determined. Updated coordinates will be provided once installation is complete. Sampling Frequency:

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Twice a year during periods of groundwater flow

Sampling Parameters: pH Conductivity Turbidity Total Cyanide Dissolved Metals3 Nutrients2 Major Ions1 Surveillance Network Program (SNP) Station TBD: (inactive) Description: Groundwater well for reference monitoring - location to be determined Location: 636209.7E, 6926512N, 635485.5E, 6926301N or alternate suitable location to be

• determined. Updated coordinates will be provided once installation is complete.

Sampling Frequency: Twice a year during periods of groundwater flow Sampling Parameters: pH Conductivity Turbidity Total Cyanide Dissolved Metals3 Nutrients2 Major Ions1 Surveillance Network Program (SNP) Station SWMP-1: (active) Description: Surface water in engineered channel Upper Pud Location: 635251E, 6925257N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Surveillance Network Program (SNP) Station SWMP-2: (active) Description: Surface water in engineered channel Upstream Hazardous Waste Disposal Site Location: 635735E, 6925652N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Water Temperature Surveillance Network Program (SNP) Station SWMP-9: (active) Description: Surface water in engineered channel Negus Pond/Blend Plant Location: 636052E, 6925322N Sampling Frequency: Annually during freshet

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Sampling Parameters: pH Total Arsenic and Field Conductivity Water Temperature

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Surveillance Network Program (SNP) Station SWMP-10: (active) Description: Surface water in engineered channel Crank Lake South Location: 635917E, 6925390N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Surveillance Network Program (SNP) Station SWMP-11: (active) Description: Surface water in engineered channel Lower Pud Location: 635387E, 6924702N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Water Temperature Surveillance Network Program (SNP) Station SWMP-12: (active) Description: Surface water in engineered channel Crank Lake East Location: 636410E, 6925359N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Water Temperature Surveillance Network Program (SNP) Station SWMP-13: (active) Description: Surface water in engineered channel Negus Tailings Containment Area Location: 636193E, 6925064N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Surveillance Network Program (SNP) Station SWMP-14: (active) Description: Surface water in engineered channel Neil Lake Tailings Containment Area Location: 635543E, 6924699N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Water Temperature

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Surveillance Network Program (SNP) Station SWMP-16: (active) Description: Surface water in engineered channel downstream Hazardous Waste Disposal Site Location: 635576E, 6925307N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Water Temperature Surveillance Network Program (SNP) Station SWMP-17: (active) Description: Surface water in Garden Draw Location: 636661E, 6925830N Sampling Frequency: Annually during freshet Sampling Parameters: pH Total Arsenic and Field Conductivity Water Temperature

2- 3-

1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test Method: Reference for Determining Acute Lethality of Effluents to Daphnia magna.

2- 3-

The location of sampling sites is subject to approval of the Inspector. 2. More frequent sample collection may be required at the request of an Inspector. 3. All sampling, sample preservation, and analyses shall be conducted in accordance with 4. methods prescribed in the current edition of "“Standard Methods for the Examination of Water and Wastewater"” at the time of analysis, or by such other methods approved by an Analyst. All analyses shall be performed in a laboratory accredited by the Canadian Association for 5. Laboratory Accreditation (CALA) or equivalent for the specific analyses to be performed or as approved by an Analyst.6. A quality assurance/quality control (QA/QC Plan) plan which includes both field and laboratory requirements shall be submitted to an Analyst for approval not less than 60 days in advance of any sampling conducted.

• 7. The Licensee shall annually review the approved QA/QC Plan and modify the Plan as

6.

• necessary. Proposed modifications shall be submitted to an Analyst for approval.
• 8. The QA/QC Plan referred to in SNP Section A, Item 7 shall be implemented as

7. approved by an Analyst.

1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F),

Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS).

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test Method: Reference for Determining Acute Lethality of Effluents to Daphnia magna.

2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate

(NO2- N), Total Kjeldahl Nitrogen (TKN), total Phosphorus (P), dissolved Phosphorous (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Collision Cell Inductively Coupled Plasma Mass Spectrometry (CCMS) shall include at a

minimum, the following parameters: Aluminum (Al), Antimony (Sb), Arsenic (As), Barium (Ba), Beryllium (Be), Cadmium (Cd), Cobalt (Co), Copper (Cu), Chromium (Cr), Cesium (Cs), Iron (Fe), Lead (Pb), Lithium (Li), Manganese (Mn), Molybdenum (Mo), Nickel (Ni), Rubidium (Rb), Selenium (Se), Strontium (Sr), Titanium (Ti), Thallium (Tl), Uranium (U), Vanadium (V), Zinc (Zn). Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter.

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test Method: Reference for Determining Acute Lethality of Effluents to Daphnia magna.

4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene

Flow and Volume Measurements B. All flow and volume measurements shall be measured and recorded continuously

1.

(i.e. using electronic data storage chips or equivalent) during periods of flow or pumping and reported on a monthly basis in cubic metres: The monthly and annual quantities of water pumped from Surveillance a. Network Program Station Numbers 0025-12, 0025-13, 0025-14, 0025-15 shall be measured and recorded in cubic metres; The daily quantity of treated effluent discharged from the Tailings b. Containment Area shall be measured and recorded in cubic metres. c. The daily and annual quantities of water pumped from Surveillance Network Program Station Numbers 0040-6 shall be measured and recorded in cubic metres. Other Monitoring Requirements C. The periods when effluent from the Water Treatment Plant is re-circulated to the 1. Tailings Containment Area(s) shall be recorded.

• 2. Prior to pumping of water from Station Number 0040-6, results of the analyses

showing that effluent quality limits in Part D, Item 11 of the Licence are being met shall be provided to an Inspector. Reporting Requirements D. The Licensee shall, within thirty (30) days following the month being reported, 1. submit to the Board and Inspector, in electronic and printed formats acceptable to the Board, all data and information required by the Surveillance Network Program, including the results of the approved QA/QC program and any interpretive comments and calculations. The Licensee shall submit a scaled map of all SNP stations, including UTM 2. Coordinates, sixty (60) days after the issuance of the Licence and when revisions

are made to the surveillance network stations. Mackenzie Valley Land and Water Board Mavis Cli-Michaud, Chair Amanda Gauthier, Witness

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test Method: Reference for Determining Acute Lethality of Effluents to Daphnia magna.

Reasons for Decision Issued pursuant to section 72.25 of the Mackenzie Valley Resource Management Act and Section 54 of the Waters Act Water Preliminary Screener MVLWB File Number MV2007L8-0025 Company Miramar Northern Mining Limited Project Con Mine Remediation, Yellowknife, NT Date of Decision May 10, 2018

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test Table of Contents 1.0 List of Abbreviations 2 2.0 Regulatory Process 2

3.0 Legislative Requirements 3 3.1 MVRMA: The Board’s Duty to Consult 3 3.1.1 Distribution List 3 3.2 MVRMA Part 3 and 4 and Waters Act: Land and Water Regulation 4 3.2.1 General 4 3.2.2 Public Notice 4 3.2.3 Water Use Fees 5 3.2.4 Existing Licences 5 3.2.5 Compensation to Existing Water Uses 5 3.2.6 Water Quality Standards 5 3.2.7 Effluent Quality Standards 5 3.2.8 Financial Responsibility 5 3.2.9 Minimization of Adverse Effects 5 3.2.10 Time Limit 6 3.2.11 Length of Licence Term 6 3.3 MVRMA Part 5 6 3.3.1 Preliminary Screening 6

4.0 Decision – Water Licence MV2007L8-0025 6 5.0 Conclusion 7

MV2007L8-0025 – Miramar Northern Mining Limited – Con Mine Remediation Renewal (60-day extension) Page 1 of 7

These Reasons for Decision set out the Mackenzie Valley Land and Water Board’s (the MVLWB/Board) regulatory process and decisions on Board renewal of Water Licence (Licence) MV2007L8-0025 for the Con Mine Remediation Project for a period of 60-days. 1.0 List of Abbreviations

Distribution List Refer below to Section 5: Legislative Requirements GNWT Government of the Northwest Territories Licence Water Licence MV2007L8-0025 MVLWB or Board Mackenzie Valley Land and Water Board MVRMA Mackenzie Valley Resource Management Act Project Con Mine Remediation Reviewer As per the Board’s Rules of Procedures

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test 2.0 Regulatory Process On April 2, 2008, Miramar Northern Mining Limited (MNML) was issued a type A Water Licence MV2007L8-0025 for the remediation of the Con Mine site located within the municipal boundary of Yellowknife, NT. On December 5, 2017, MNML applied for a new Type A Water Licence (Licence) MV2017L8-0008 to renew and continue the remediation

• f the Con Mine site. This Renewal Application (MV2017L8-0008) is to replace the current

Licence MV2007L8-0025 which expires November 30, 2018. The Renewal Application (MV2017L8-0008) was deemed complete on December 15, 2017 and distributed for public review of December 18, 2017. At the March 1-2, 2018 technical session for the Renewal Application (MV2017L8-0008), reviewers required additional time to consider MNML’s responses to initial review comments. MNML also required additional time to provide information to support the development of effluent quality

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test criteria. On March 15, 2018, the Board approved Work Plan, Version 31, for the Renewal Application (MV2017L8-0008). This identified the Board may not decide on the Renewal Application (MV2017L8- 0008) prior to the expiry of the current Licence MV2007L8-0025 as reviewers had requested (and were granted) additional time for review of supplemental information for the Renewal process (MV2017L8-0008). As such, the Board chose to renew the current Licence MV2007L8-0008 for a period of 60 days. Subsection 36 (1) of the Waters Act (Act) allows the Board to renew a type A water licence with or without changes to its conditions and states: Subject to subsection (2) and (3), the Board may a) Renew a licence, with or without changes to its conditions, for a term not exceeding 25 years in the case of a type A licence in respect of a prescribed class of undertakings or in the case of a type B licence, or for a term not exceeding the anticipated duration of the undertaking in the case of any other type A licence, (ii) in any other case, where the renewal appears to the Board to be in the public interest. Paragraph 41(3)(b) of the Waters Act (Act) allows the Board to renew a type A water licence for a period of 60 days without having a public hearing and states:

1 See MVLWB – Work Plan v3, dated March 15, 2018

Subsection 41(2) does not apply [requirement for a mandatory public hearing] 41(3)(b) if, in the case of a renewal referred to in paragraph (2)(a) [mandatory public hearing], the licensee has filed with the Board an application for renewal in accordance with the regulations made under paragraph 63(1)(d) and (e) and the term

• f the renewal or renewals granted by the Board does not exceed 60 days in the

aggregate. On March 22, 2018, Board staff distributed the Boards intent to renew the Type A Licence MV2007L8- 0025 for a period of 60 days via the Online Review System. A public notice also appeared in News North during the week of March 26, 2018 to fulfill paragraphs 43(1)(a) and 43(2)(a) of the Waters Act, respectively.2 One public review comment was received by April 12, 2018 from the Government of the Northwest Territories – Environment and Natural Resources (no comment). MNML did not provide a response, as none was required.

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test On May 10, 2018, the Board met to make decisions regarding the intent to renew the Licence for a period of 60-days. 3.0 Legislative Requirements In conducting the review process as described in Sections 2 above, the Board has ensured that all applicable legislative requirements have been satisfied as outlined below. 3.1 MVRMA: The Board’s Duty to Consult In exercising its authority under the MVRMA, generally, the Board must ensure that the concerns of Aboriginal people have been taken into account under paragraph 114(c) of the MVRMA. It must also consider the importance of conservation to the well-being and way of life of Aboriginal peoples of Canada, under paragraph 60.1(a) of the MVRMA, specifically those to whom section 35 of the Constitution Act, 1982 applies and who use an area of the Mackenzie Valley. Accordingly, the Board works with applicants, affected parties (including Aboriginal organizations/governments), and other parties (such as other boards and regulators) to ensure that potential impacts of proposed projects are understood and carefully considered before decisions are made with respect to the issuance of and Licences. 3.1.1 Distribution List Each application and supporting documents are uploaded to the Board’s webpage and then an application package is distributed to parties, including: appropriate federal and territorial government departments and agencies; land owners; affected communities and Aboriginal

• rganizations; Renewable Resource Boards; heritage regulators; and other interested
• parties. Table 1 below identifies the Distribution List that the Board used for this regulatory

process.

2 See Notice of Application in NewsNorth, dated March 26, 2018.

Table 1: Organizations on the Distribution List for Licence MV2007L8-0025

Akaitcho IMA Implementation Office Golder Associates Athabasca Denesuline Council – Prince Albert Government of Canada Bathurst Inlet Development Ltd. Hamlet of Fort Resolution Bathurst Inlet Lodge Hay River Metis Council BNT Gold Resources Ltd. INAC - Contaminants and Remediation Directorate CanNor NWT Region INAC - NWT Inspectors Chamber of Mines NWT & Nunavut Katlodeeche First Nation City of Yellowknife Lutsel K'e Dene First Nation – Chief or Wildlife, Lands and Environment Dene Nation Mackenzie Valley Environmental Impact Review Board Deninu K'ue First Nation Manitoba Denesuline Environment and Climate Change Canada Miramar Northern Mining Ltd. Fisheries and Oceans Canada National Energy Board Fort Resolution Metis Council North Slave Metis Alliance Fort Smith Metis Council Northwest Territory Metis Nation General Public – Kevin O-Reilly Salt River First Nations General Public – Steve Robertson Smith Landing First Nation GNWT - ECE Snap Lake Environmental Monitoring Agency – SLEMA GNWT - ENR Tlicho Government GNWT - Health Town of Fort Smith GNWT - INF Wek' eezhii Renewable Resources Board GNWT - ITI West Point First Nation GNWT - Lands WLWB GNWT - MACA Workers' Safety and Compensation Commission GNWT- OROGO Yellowknives Dene First Nation

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test 3.2 MVRMA Part 3 and 4 and Waters Act: Land and Water Regulation The use of water, and the deposit of waste proposed is of a nature contemplated by the MVRMA and the Waters Act. The Board has jurisdiction to issue this Licence under subsection 60 (1.1) of the MVRMA

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test 3.2.1 General The Board has considered the people and users of the Mackenzie Valley, and any traditional knowledge and scientific information that was made available to it during this regulatory proceeding, under section 60.1 of the MVRMA. 3.2.2 Public Notice Notice of the Boards intent to renew the water licence were given to fulfill sections 63 and 64 of the MVRMA. The Board is satisfied that a reasonable amount of time was given to communities, First Nations, and the public to participate in this regulatory process by making submissions to the Board. 3.2.3 Water Use Fees MNML is required to pay water use fees as per subsection 8(1) of the Waters Regulations, prior to the start of operations. Water use fees must be paid hereafter for the duration of the Licence on or before its annual Anniversary date. 3.2.4 Existing Licences With respect to 26(5)(a) of the Waters Act, the Board is satisfied that the granting of this Licence will not adversely affect, in a significant way, any existing Licensee or any

• ther applicant if compliance with the Licence occurs.

3.2.5 Compensation to Existing Water Uses Paragraph 26(5)(b) of the Waters Act prohibits the issuance of the Licence unless the Board is satisfied that appropriate compensation has been or will be paid by the applicant to persons who would be adversely affected by the use of waters, or deposit

• f waste proposed by the applicant, at the time when the applicant filed its licence

application with the Board. The Board received no claims for compensation either during the time-period stipulated in the Notice of Application or afterwards. Provided compliance with the Licence conditions takes place, the Board finds that there are no water users or persons listed in paragraph 26(5)(b) of the Waters Act who will be adversely affected by the use of waters or the deposit of waste proposed. 3.2.6 Water Quality Standards With regards to 26(5)(c)(i) of the Waters Act, the Board is satisfied that compliance with the

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test Licence conditions will ensure that waste will be collected and disposed of in a manner which will maintain water quality consistent with applicable standards and the Board’s Water and Effluent Quality Management Policy. No changes were made to the Licence relating to the collection and disposal of waste. 3.2.7 Effluent Quality Standards There are no effluent quality standards prescribed in the Waters Regulations. The Effluent Quality Standards were not reevaluated during this process. 3.2.8 Financial Responsibility The Board must satisfy itself of the financial responsibility of Miramar Northern Mining Limited 26(5)(d) of the Waters Act before it can issue the Licence. The Government of the Northwest Territories (GNWT) currently holds a security in the amount of $7,823,190.00. At this time the Board is not reviewing the amount of security held with the GNWT. 3.2.9 Minimization of Adverse Effects With regards to subsection 27(2) of the Waters Act, it is the opinion of the Board that compliance with the Licence will ensure that any potential adverse effects on other water users, which might arise because of the issuance of the Licence, will be minimized. 3.2.10 Time Limit The Board is satisfied it has adhered to 48(1) of the Waters Act, which requires it to make a decision within a period of nine months. 3.2.11 Length of Licence Term Section 36(1) of the Waters Act allows for a Licence term of not more than 25 years

• r the duration of the undertaking. However, paragraph 41(3)(b) of the Waters Act

allows the Board to renew a type A water licence for a period of 60-days without having a public hearing. Therefore, the Board can utilize the Waters Act to ensure that the current Licence MV2007L8- 0025 remains active during the processing of the new Application for Licence MV2017L8-0008. 3.3 MVRMA Part 5

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1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test 3.3.1 Preliminary Screening On September 20, 2007, the Board conducted a preliminary screening on the Application for Licence MV2007L8-0025, to fulfill subsection 124(1) of the MVRMA. The Board determined that the activities associated with the Application would not have a significant adverse impact on the environment and would not be a cause of public concern. The Board’s Preliminary Screening Report includes its reasons for that decision and is available on the Board’s public registry.3 The Board is satisfied the proposed development has been screened pursuant to the MVRMA. In 2014, MNML applied to amend the term of Licence MV2007L8-0025 from 2014 to 2018, to allow for the continuation of reclamation activities. On July 3, 2014, the Board met and confirmed the activities associated with the Application were exempt from preliminary screening based on Part 1, Schedule 1, section 2.1 of the Exemption List Regulations to the MVRMA.4 On May 10, 2018, the Board confirmed that the renewal was exempt from Preliminary Screening under the Exemption List Regulations Schedule 1, Paragraph 2 which states: A development or part thereof, for which renewal of a permit, licence or authorization is requested that (a) has not been modified; and (b) has fulfilled the requirement of the environmental assessment process established by the Mackenzie Valley Resources Management Act, the Canadian Environmental Assessment Act, or the Environmental Assessment Review Process Guidelines Order. 4.0 Decision – Water Licence MV2007L8-0025 In making its decision and preparing these Reasons for Decision, the Board has reviewed and considered: 1) The comments, recommendations, and concerns that arose during the regulatory processes; 2) The evidence and submissions from Reviewers

3 See MVLWB Preliminary Screening and Reasons for Decision, dated September 20, 2007.

4 See MVLWB Exemption from Preliminary Screening, dated July 3, 2014.

3) The Staff Report prepared for the Board; and 4) The purpose, scope and intent of the Board’s statutory responsibilities under the MVRMA and the Waters Act. Having due regard to the facts, circumstances, and the merits of the submissions made to it, the Board has determined that Licence MV2007L8-0025 should be renewed for a term of 60-days. The new expiry date for Water Licence MV2007L8-0025 is January 30, 2019. The Board’s reasons for this decision are set out below; they focus on the major concerns and issues raised including those that were the subject of substantive argument submitted by one or moreReviewers. No changes have been made to the format or content of the Licence, including the attached Schedules and Surveillance Network Program. ANNEX B: Concordance Table of Items Requiring Submission Annexed to Water Licence MV2017L8-0008 5.0 Conclusion Subject to the scope, definitions, conditions, and term set out in the Licence and for the reasons expressed herein, the MVLWB is of the opinion that the land-use activities, water use, and waste disposal associated with the Con Mine Reclamation Project can be completed by Miramar Northern Mining Limited while providing for the conservation, development, and utilization of land and water resources in a manner that will provide the

• ptimum benefit for all Canadians and in particular for residents of the Mackenzie Valley.

This table summarizes the information the Licensee is required to submit as per the Water Licence conditions. Water Licence MV2007L8-0025 contains provisions that the Board deems necessary to ensure and monitor compliance with the MVRMA, Waters Act, and the Regulations made thereunder, and to provide appropriate safeguards in respect of MNML use of the land and water and deposit of waste affected by the Licence. SIGNATURE

Part of Licence Item Date Annex A Monthly SNP Report Within 30 days of reporting end of reporting month

• Annual Water License Summary Report

2- 3-

1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test

March 31st

• Geotechnical Inspection Report

June - September

• Con Mine Status of the Environment Report

June 6th 2022, 2025, 2028, 2031

• Post Closure Monitoring and Maintenance

Plan – Update September 4th, 2022, 2025, 2028, 2031

• Closure objectives and Criteria table -

Update September 4th, 2022, 2025, 2028, 2031

• Site Water and Mine Flooding Management

Plan - Update September 4th, 2022, 2025, 2028, 2031

• Solid and Hazardous Waste Management

Plan - Update September 4th, 2022, 2025, 2028, 2031

• Emergency Response and Spill Contingency

Plan - Update September 4th, 2022, 2025, 2028, 2031

• Vegetation Establishment Monitoring Plan -

Update September 4th, 2022, 2025, 2028, 2031

• Standard Operating Procedures for Effluent

and Water Quality Monitoring at Con Mine - Update September 4th, 2022, 2025, 2028, 2031

2- 3-

1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test Mackenzie Valley Land and

ANNEX C: Table of Revision History Annexed to Water BoardLicence MV2017L8-0008 May 10, 2018 Mavis Cli-Michaud, Chair Date

Date Location of change Description of change

• 2-

3-

1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO4 ), Sodium (Na), Potassium (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH3), Nitrite (NO3-N), Nitrate (NO2- N), Total Kjeldahl Nitrogen (TKN), Total Phosphorus (P), Orthophosphate (PO4 ), Total Organic Carbon (TOC)

3 Metals shall include but not be limited to analysis of the following parameters by inductively

coupled plasma mass spectrometry or equivalent method: Aluminum, Arsenic, Cadmium, Chromium, Cobalt, Copper, Iron, Lead, Manganese, Molybdenum, Nickel, Selenium, Thallium, Uranium, Zinc. Total metals shall be analyzed in an unfiltered sample and dissolved metals shall be analyzed after passing an unpreserved sample through a 0.45 micron filter. 4BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene 5 As described in Reference Method EPS 1/RM/13 – Biological Test Method: Reference method for Determining Acute Lethality of Effluents to Rainbow Trout and EPS 1/RM/14 – Biological Test