Schedule A

KSM PROJECT

CERTIFIED PROJECT DESCRIPTION

 TABLE OF CONTENTS
Table of Contents ............................................................................................................. i
List of Figures ....................................................................................................... iv

1 Project Location .................................................................................................... 1

2 Mine Plan ............................................................................................................. 4

3 Mine Site Facilities................................................................................................ 4

3.1 Mitchell Pit and Underground Mine ............................................................ 4
3.2 Sulphurets Pit ............................................................................................ 4
3.3 Kerr Pit ....................................................................................................... 4
3.4 Iron Cap Underground Mine ...................................................................... 4
3.5 Mitchell and McTagg Rock Storage Facilities ............................................ 4
3.6 Mitchell Ore Preparation Complex ............................................................. 4
3.7 Explosives Manufacturing Facility .............................................................. 5
3.8 Mitchell Diversion Tunnels ......................................................................... 5
3.9 McTagg Twinned Diversion Tunnels .......................................................... 5
3.10 Mitchell-Treaty Twinned Tunnels ............................................................... 5
3.11 Mitchell Pit Pipeline .................................................................................... 5
3.12 Kerr Pit Pipeline ......................................................................................... 5
3.13 Iron Cap Pipeline ....................................................................................... 5
3.14 Sulphurets Pit Pipeline ............................................................................... 5
3.15 Water Storage Facility................................................................................ 6
3.16 Water Treatment Plant ............................................................................... 6
3.17 Selenium Treatment Plant ......................................................................... 6
3.18 Ore Stockpiles ........................................................................................... 6
3.19 Substation 2 ............................................................................................... 7
3.20 Small-Scale Hydroelectric Power Facilities ................................................ 7
3.21 Sludge Storage .......................................................................................... 7
3.22 Other Mine Site Facilities ........................................................................... 7

4 Processing and Tailing Management Area Facilities ............................................ 8

4.1 Treaty Ore Preparation Complex ............................................................... 8
4.2 Tailing Management Facility ...................................................................... 8
4.3 Non-contact Water Diversions ................................................................... 9
4.4 Small-Scale Hydroelectric Power Facilities ................................................ 9
4.5 Other Process and Tailing Management Area Facilities ............................ 9

KSM PROJECT CERTIFIED PROJECT DESCRIPTION i

5 Access Roads....................................................................................................... 9
5.1.1 Coulter Creek Access Road (CCAR) ..................................................... 9
5.1.2 Treaty Creek Access Road (TCAR) ....................................................... 9
5.1.3 Other Roads ........................................................................................ 10
5.1.4 Temporary Frank Mackie Glacier Access Route .................................. 10

6 Electrical Power Supply and Distribution ............................................................ 10

7 Project Construction ........................................................................................... 10

8 Project Operation................................................................................................ 11
8.1 Water Management ................................................................................. 11
8.2 Transportation .......................................................................................... 11
8.2.1 Concentrate ......................................................................................... 11

9 Closure and Post-Closure .................................................................................. 12

9.1 Mitchell Pit and Underground Mine .......................................................... 12
9.2 Sulphurets Pit .......................................................................................... 12
9.3 Kerr Pit ..................................................................................................... 12
9.4 Iron Cap Underground Mine .................................................................... 12
9.5 Mitchell and McTagg Rock Storage Facilities .......................................... 12
9.6 Water Storage Facility and Water Treatment Plant .................................. 12
9.7 Mitchell-Treaty Twinned Tunnel ............................................................... 13
9.8 Tailing Management Facility .................................................................... 13
9.9 Coulter Creek Access Road..................................................................... 13
9.10 Treaty Creek Access Road ...................................................................... 13
9.11 Small-Scale Hydroelectric Power Stations ............................................... 13

10 Environmental Management Plan Frameworks .................................................. 14

10.1 Wildlife Effects Monitoring Plan ............................................................... 14
10.1.1 Plan Objectives .......................................................................... 14
10.1.2 Monitoring Locations and Sampling Methods and
Frequency .................................................................................. 15
10.1.3 Management Response ............................................................. 15
10.1.4 Reporting .................................................................................... 16
10.2 Aquatic Effects Monitoring Plan ............................................................... 16
10.2.1 Plan Objectives .......................................................................... 16
10.2.2 Plan Components ....................................................................... 17
10.2.3 Adaptive Management Program Design, Sampling
Methods, and Analysis ............................................................... 17
10.2.4 Management Response ............................................................. 18
10.2.5 Reporting Summary.................................................................... 18

KSM PROJECT CERTIFIED PROJECT DESCRIPTION ii

 10.3 Salmon Monitoring Plan ........................................................................... 18
10.3.1 Plan Objectives .......................................................................... 19
10.3.2 Plan Components ....................................................................... 19
10.3.3 Program Design, Sampling Methods, and Analysis .................... 19
10.3.4 Management Response ............................................................. 20
10.3.5 Reporting Summary.................................................................... 20
10.4 Selenium Management Plan .................................................................... 20
10.4.1 Plan Objectives .......................................................................... 20
10.4.2 Plan Components ....................................................................... 21
10.4.3 Monitoring Program Design, Sampling Methods, and
Analysis ...................................................................................... 21
10.4.4 Management Response ............................................................. 21
10.4.5 Reporting Summary.................................................................... 22
10.5 Groundwater Monitoring and Management Plan ..................................... 22
10.5.1 Plan Objectives .......................................................................... 22
10.5.2 Plan Components ....................................................................... 22
10.5.3 Monitoring Program Design, Sampling Methods, and
Analysis ...................................................................................... 23
10.5.4 Management Response ............................................................. 23
10.5.5 Reporting Summary.................................................................... 23
10.6 Traffic and Access Management Plan ..................................................... 23
10.6.1 Plan Objectives .......................................................................... 23
10.6.2 Plan Components ....................................................................... 23
10.6.3 Monitoring................................................................................... 24
10.6.4 Management Response ............................................................. 24
10.6.5 Reporting Summary.................................................................... 24
10.7 Wetlands Management Plan .................................................................... 24
10.7.1 Plan Objectives .......................................................................... 24
10.7.2 Plan Components ....................................................................... 24
10.7.3 Monitoring................................................................................... 24
10.7.4 Management Response ............................................................. 25
10.7.5 Reporting Summary.................................................................... 25
10.8 Water Management Plan ......................................................................... 25
10.8.1 Plan Objectives .......................................................................... 25
10.8.2 Plan Components ....................................................................... 25
10.8.3 Monitoring................................................................................... 26
10.8.4 Management Response ............................................................. 26
10.8.5 Reporting .................................................................................... 26
10.9 Spill Prevention and Emergency Response Plan ..................................... 26
10.9.1 Plan Objectives and Components .............................................. 26
10.9.2 Management Response ............................................................. 27
10.9.3 Reporting .................................................................................... 27
10.10 Human Health Monitoring Plan ................................................................ 27

KSM PROJECT CERTIFIED PROJECT DESCRIPTION iii

 10.10.1 Plan Objectives .......................................................................... 27
10.10.2 Plan Components ....................................................................... 27
10.10.3 Monitoring................................................................................... 27
10.10.4 Management Response ............................................................. 28
10.10.5 Reporting .................................................................................... 28
10.11 Terrestrial Ecosystems Management and Monitoring Plan ...................... 28
10.11.1 Plan Objectives and Components ...............................................28
10.11.2 Monitoring ........................................................................................... 29
10.11.3 Management Response....................................................................... 29
10.11.4 Reporting ............................................................................................. 29
10.12 Reclamation and Closure Plan ................................................................ 29

LIST OF FIGURES

Figure Page

Figure 1. Location of the KSM Project ............................................................................. 2

Figure 2. KSM Project Layout ......................................................................................... 3

KSM PROJECT CERTIFIED PROJECT DESCRIPTION iv

ACRONYMS, ABBREVIATIONS AND DEFINITIONS

Application Seabridge Gold Inc.’s Application for an Environmental

Assessment Certificate
AEMP Aquatic Effects Monitoring Plan
BC British Columbia
CCAR Coulter Creek access road
CCME Canadian Council of Ministers of the Environment
CIL Carbon-in-leach
Closure The decommissioning and reclamation of Project components that
are no longer required
Construction Tree clearing or ground disturbance related to the building of new
Project components
COPC Contaminents/ chemicals of Potential Concern
EAC Environmental Assessment Certificate
EAC Holder The owner of the KSM Project
EPA Environmental Protection Agency
FLNR Ministry of Forests, Lands and Natural Resource Operations
GMMP Groundwater Monitoring and Mitigation Plan
HDS High Density Sludge
HHMP Human Health Monitoring Plan
km Kilometre(s)
m3 Cubic metre
m3/s Cubic metre per second
MDT Mitchell Diversion Tunnels
MEM Ministry of Energy and Mines
MOE Ministry of Environment
MTDT McTagg Twinned Diversion Tunnels
MTT Mitchell-Treaty Twinned Tunnels
OPC Ore Preparation Complex

KSM PROJECT CERTIFIED PROJECT DESCRIPTION -v-

Operation Mining and processing of ore to produce concentrate for sale
Post-closure The shutdown of the Project
Project The KSM Project
PTMA Processing and Tailing Management Area
QA/QC Quality Assurance/ Quality Control
RSF Rock Storage Facility
Se Selenium
SeMP Selenium Management Plan
SMP Salmon Monitoring Plan
TCAR Treaty Creek Access Road
TMF Tailings Management Facility
VC Valued Component
WEMP Wildlife Effects Monitoring Plan
WMP Water Management Plan
WSD Water Storage Dam
WSF Water Storage Facility
WTP Mine Site Water Treatment Plant

KSM PROJECT CERTIFIED PROJECT DESCRIPTION vi

1 Project Location
The Project is located 65 kilometres (km) northwest of Stewart, BC, and 30 km
northeast of the BC/Alaska border (Figure 1), at 56.52 degrees north latitude and
130.25 degrees west longitude.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 1

Figure 1. Location of the KSM Project

KSM-16-072

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 2

Figure 2. KSM Project Layout

KSM-0028-020

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 3

2 Mine Plan
The Project is a gold/copper/silver/molybdenum mine. The Project will produce up to
130,000 tonnes of ore per day over a mine life of no more than 52 years.

The mine site is located in the Sulphurets watershed and the Processing and Tailing
Management Area (PTMA) is located in the Treaty and Teigen creek watersheds. A
maximum of four deposits will be mined: Mitchell, Sulphurets, Kerr and Iron Cap. Ore
will be crushed at the mine site and conveyed through the Mitchell-Treaty Twinned
Tunnels (MTT) to the PTMA for processing.

Figure 2 shows the layout of the Project.

3 Mine Site Facilities

3.1 Mitchell Pit and Underground Mine
The Mitchell Pit will be located in the Mitchell Creek Valley, downstream of the
Mitchell Glacier. The Mitchell deposit will be mined by open pit and underground block
cave mining methods.

3.2 Sulphurets Pit

The Sulphurets Pit will be located between the Mitchell and Sulphurets Creek valleys.
The Sulphurets Pit will be mined by open pit methods.

3.3 Kerr Pit

The Kerr Pit will be located south of Sulphurets Lake and west of Sulphurets Glacier.
The Kerr deposit will be mined by open pit methods.

3.4 Iron Cap Underground Mine

The Iron Cap deposit will be located north of the Mitchell Pit. The Iron Cap deposit will
be mined using underground block cave mining methods.

3.5 Mitchell and McTagg Rock Storage Facilities

Waste rock that is generated from mining the Mitchell, Sulphurets and Iron Cap deposits
will be stored in the Mitchell and McTagg rock storage facilities (RSF). Waste rock from
the Kerr Pit will be backfilled into the mined-out Sulphurets Pit.

3.6 Mitchell Ore Preparation Complex

The Mitchell Ore Preparation Complex (OPC) will include facilities for rock crushing,
coarse ore storage, fuel storage, as well as an electrical substation (Substation 2) and
distribution network and support infrastructure. The portals of the Mitchell Treaty

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 4

Twinned Tunnels (MTT) and Mitchell underground access and conveyor adits will also
be located at the OPC.

3.7 Explosives Manufacturing Facility

The explosives manufacturing facility will be located in the Ted Morris Creek Valley.

3.8 Mitchell Diversion Tunnels

The Mitchell Diversion Tunnels (MDT) and related inlet structures will divert non-contact
flows from the Mitchell Glacier and surrounding areas located upstream of the Mitchell Pit
and underground mine to the Sulphurets Creek drainage.

3.9 McTagg Twinned Diversion Tunnels

The McTagg Twinned Diversion Tunnels (MTDT) will divert non-contact water from the
McTagg Creek Valley away from the McTagg RSF and other mine site facilities.

3.10 Mitchell-Treaty Twinned Tunnels

The MTT will consist of two parallel interconnected tunnels. The tunnels will be used to
convey crushed ore, distribute power from the Treaty OPC (Substation 1) to the mine
site (Substation 2), house communications infrastructure and transport fuel, bulk
materials and personnel.

The MTT will slope downwards from the Treaty portal to the Mitchell portal, to allow
tunnel seepage water to drain to the mine site.

3.11 Mitchell Pit Pipeline

Mitchell Pit drainage (water piped from dewatering wells, water pumped from the base
of the pit and water routed off the benches of the pit) reports to the portal of the
Mitchell Valley Drainage Tunnel located on the western rim of Mitchell Pit. Drainage
from this tunnel reports directly to the Water Storage Facility (WSF).

3.12 Kerr Pit Pipeline

The Kerr Pit dewatering pipeline will be installed to convey the pit drainage from the
Kerr Pit to the WSF or Selenium Treatment Plant. The Kerr Pit pipeline will have a leak
detection system.

3.13 Iron Cap Pipeline

Drainage from Iron Cap will report via raise bores, to a series of tunnels and short
connecting pipelines and ultimately discharges to the WSF.

3.14 Sulphurets Pit Pipeline

Initially Sulphurets Pit dewatering will be via pipeline to the Sulphurets ditch and WSF.
When backfilling commences, drainage will be routed via pipeline to the Selenium

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 5

Treatment Plant. The Sulphurets Pit pipeline and ditch will have a leak detection
system.

3.15 Water Storage Facility

The WSF will store the mine site contact water to attenuate seasonal flows and regulate
the flow of water to the Water Treatment Plant (WTP) prior to release.

Non-contact runoff from the northwest valley slope above the WSF will be intercepted
by the WSF bypass buried pipeline. Runoff from the southeast valley slope will be
intercepted by the southeast WSF diversion. Both diversions will discharge to
Mitchell Creek below the Water Storage Dam (WSD).

The WSD will be designed to resist the maximum credible earthquake and will include a
freeboard allowance to manage any wave action caused by avalanches without
overtopping. Seepage from the WSD will be collected by seepage interception tunnels
and in a seepage recovery pond, impounded by a seepage dam located downstream of
the WSD.

During the Project’s operation, closure and post-closure phases, the WSF will store for
treatment in the WTP all contact water received from upstream mine site facilities,
including the RSFs, the ore stockpiles, the open pit and underground mine workings
and the drainage from the MTT. The WSF will continue collecting contact water during
the closure and post-closure phases.

3.16 Water Treatment Plant

The WTP will treat contact water discharged from the WSF, using a high density sludge
(HDS) lime water treatment process. Contact water from both the dewatering of the
Mitchell underground block cave mine and the WSD seepage pond will also be treated
at the WTP. The WTP will be designed with the capacity to treat up to 7.5 m 3/second.

3.17 Selenium Treatment Plant

Concentrated seepage from the Mitchell and McTagg RSFs will be collected and
pumped to the Selenium Treatment Plant. Runoff from Kerr Pit waste rock that has
been backfilled into the Sulphurets Pit, and drainage from the Kerr Pit, if elevated with
selenium, will also be treated. Effluent from the Selenium Treatment Plant will report to
the WSF for final treatment through the HDS WTP.

3.18 Ore Stockpiles

A temporary ore stockpile will be located between the Mitchell Pit and the Mitchell OPC
to receive run-of-mine Mitchell Pit ore and a long-term run-of-mine ore stockpile will be
located along the northern margin of the Mitchell RSF.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 6

3.19 Substation 2
Substation 2, located at the Mitchell OPC, will be supplied with power from cables
routed through the MTT from Substation 1 (located at the PTMA). At Substation 2,
power will be stepped down for local distribution to mine site facilities.

3.20 Small-Scale Hydroelectric Power Facilities

Up to three small-scale hydroelectric projects will generate supplementary power for the
Project via diversion of water through the MDT, the MTDT, and discharge of water from
the WSF to the WTP.

3.21 Sludge Storage

During construction, sludge will be stored in a secure sludge landfill area and a winter
sludge storage building during construction. During the operation phase, sludge from the
mine site WTP will be dewatered, trucked to the Mitchell OPC, and transported via the
MTT to the Process Plant, and eventually stored in the Tailing Management Facility
(TMF). At closure, the sludge will be stored in a secure landfill facility located on top of the
McTagg and Mitchell RSFs.

3.22 Other Mine Site Facilities

Permanent avalanche mitigation structures will be constructed in locations around the
mine site to protect infrastructure as detailed in the Avalanche Management Plan. There
will also be areas for snow storage. Borrow areas and quarries for construction materials
at the mine site will be located within the WSF footprint, adjacent to the WSD. Stockpiled
soils for future reclamation purposes will be maintained south of Sulphurets Creek and
east of Ted Morris Creek.

A landfarm/landfill complex will be located adjacent to the Mitchell Operating Camp east
of the Truck Shop to manage non-hazardous waste at the mine site. The landfarm will
accept contaminated soils from spill clean-ups and leaks, while the landfill will be used to
dispose of inert, dry industrial, and forestry waste. The landfarm will also include an area
for storage of contaminated snow from mine site winter snow removal activities. Non-
contact water will be diverted around the landfill site. Runoff from the landfill will be
managed with other contact water.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 7

4 Processing and Tailing Management Area
Facilities
4.1 Treaty Ore Preparation Complex
The Treaty OPC will process mill feed at an annual average production rate of
130,000 tonnes per day.

Water supply for the Treaty OPC will be provided by a fresh water system, a process
water reclaim system for grinding/flotation circuits, and a process water system for
carbon-in-leach (CIL)/gold recovery circuits. Fresh and potable water for the Treaty
OPC will be supplied from nearby wells and local drainage runoff areas to an elevated
storage tank. Water for the grinding/flotation circuits and the CIL leaching/gold recovery
will be sourced from water reclaimed primarily from flotation.

4.2 Tailing Management Facility

The TMF will be designed to store 2.3 billion tonnes of tailing.

The TMF water management system will include three tailing cells and four containment
dams, as well as seepage dams and ponds and surrounding non-contact water
diversions, reclaim water barge and pipeline, and excess water pipeline to
Treaty Creek. The TMF tailing cells and containment dams are described below:

 the initial North Cell will be contained by the North and Splitter dams;
 the CIL Residue Cell (also known as the Centre Cell) will be contained by the
Splitter and Saddle dams; and
 the South Cell will be contained by the Saddle and Southeast dams.

The North and South cells will store desulphurdized or not potentially acid-generating
rougher flotation tailing. The Centre Cell will store treated sulphide-rich cleaner or
potentially acid generating tailing, and will be lined with a geomembrane liner.

During operation, the cleaner tailing in the Centre Cell will be kept flooded with
supernatant to prevent oxidation of sulphide minerals. Surplus water from the Centre
Cell will be routed through the Treaty OPC prior to discharge into either the North or
South Cell. Management of surplus water during operation of both the North and South
cells will use a combination of storage and pumped discharge via a pipeline to
Treaty Creek. The TMF discharge to Treaty Creek will be staged to mimic stream flows
in Treaty Creek in order to meet condition 8. The in stream discharge will be released
through a diffuser.

The TMF cells will be designed with enough freeboard to store all water inputs during
the Probable Maximum Flood as defined in the Application without discharge to the
receiving environment. Seepage and runoff water from the tailing dams that does not

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 8

meet Environmental Management Act permit discharge requirements will be collected
by downstream seepage collection dams and pumped back to the TMF. The seepage
ponds located upstream of the main seepage collection dam will be used as sumps
during the construction of the TMF such that turbid water is directed to these facilities
and allowed to settle prior to discharge to the environment. Water discharge from these
sumps must meet the Ministry of Environment (MOE) requirements for turbidity.

4.3 Non-contact Water Diversions

The Northeast Diversion and the South Diversion channels will be constructed around
the TMF North Cell to channel non-contact runoff from surrounding valley slopes to
South Teigen Creek.

Once the South Cell is in operation, non-contact water from TMF valley slopes will be
diverted by the Southeast Diversion Channel, which will route non-contact flows around
the east side of the South Cell to Treaty Creek.

Two diversion inlet dams will be installed in the East Catchment to divert flows into
South Teigen Creek.

4.4 Small-Scale Hydroelectric Power Facilities

Electrical energy will be generated from the tailing flow from the Process Plant to the
North Cell and/or South Cell.

4.5 Other Process and Tailing Management Area Facilities

A second landfarm/landfill complex will be located at the PTMA. The landfarm will
accept contaminated soils and materials from the Project. Rock quarries to source
construction material may also be located in the vicinity of the PTMA.

5 Access Roads
5.1.1 Coulter Creek Access Road (CCAR)
The mine site will be accessed by a new resource road, the CCAR, which will extend
from the existing Eskay Creek Mine Road southwards to the mine site. The CCAR will
commence at kilometre 55 of the Eskay Creek Mine Road.

5.1.2 Treaty Creek Access Road (TCAR)

The PTMA will be accessed by a new resource road, the TCAR. The TCAR will leave
Highway 37, cross over the Bell Irving River and will run along the Treaty Creek Valley
to the PTMA.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 9

5.1.3 Other Roads
The North Treaty lower and upper roads will be built to the same standards as the
TCAR. The Southwest Diversion maintenance, Treaty Saddle and Treaty Spur roads
will be single-lane roads.

5.1.4 Temporary Frank Mackie Glacier Access Route

During construction, the Frank Mackie Glacier access route will provide temporary,
winter-only access to the mine site. The route will run northwards from a point close to
the abandoned Granduc Mine mill site, access the Frank Mackie Glacier from the
Berendon Glacier, and then proceed up and over into the Ted Morris Creek Valley. The
route will be decommissioned by the end of the construction phase.

6 Electrical Power Supply and Distribution

The main supply of power for the Project will come from a switching station located near
the junction of the TCAR and Highway 37. The switching station would be constructed,
owned and operated by BC Hydro. A 28.5 km transmission line will parallel the TCAR
from the switching station to the PTMA.

Power cables routed through the MTT from the PTMA will provide power to the mine
site.

Until the transmission line along the TCAR is operational, mobile diesel generators will
supply construction power for tunnel driving and other construction activities.

7 Project Construction
Early construction activities will focus on the CCAR, TCAR, MTT and water
management, as well as prestripping of the Mitchell and Sulphurets pits, and
establishing waste rock and ore storage areas.

Early construction water management activities at the mine site will include construction
of the WSD, WTP (first phase), and related sludge management facilities, temporary
water treatment facilities at tunnel portals and other key locations, fresh and contact
water diversions, and the MDT and MTDT. Diversion structures will be constructed
around the Treaty OPC and key TMF construction areas. Once diversions are in place,
the Mitchell and Teigen starter dams would be established and tailing distribution and
reclaim water pipelines would be installed.

Avalanche control systems will be established early during construction and will operate
as required for the life of the Project.

Work on the PTMA will include construction of the Treaty Process Plant and related
support infrastructure, including but not limited to administration buildings, camp and

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 10

fuel storage. Once diversions are in place, the starter dams for the North, Saddle, and
Splitter dams will commence. Seepage control dams will be established and tailing
distribution and reclaim water pipelines will be installed.

8 Project Operation
8.1 Water Management
Water management facilities will be constructed and maintained at the mine site
throughout the life of the Project to divert fresh (non-contact) water around and away
from disturbed areas, and to collect water that has been in contact with disturbed areas
(contact water) for treatment (where required by the Environmental Management Act
permit) prior to release into the receiving environment (as described in section 10.8,
Water Management Plan).

Non-contact water management infrastructure will include:

 diversions around TMF;

 East Creek Diversion;
 Mitchell-McTagg RSF diversions;
 MDT;
 MDTD;
 Mitchell Pit diversions and dewatering adits; and
 Sulphurets Pit diversions.

Contact water management infrastructure will include:

 discharge pipeline from TMF to Treaty Creek;

 discharge pipeline from the WSF WTP to Sulphurets Creek;
 seepage collection dams for North and South cells;
 WSF and seepage collection dam;
 Sulphurets backfill collection sumps, pipelines and ditches;
 Kerr pit pipeline; and
 Iron Cap collection sump.

8.2 Transportation
8.2.1 Concentrate
Copper-gold concentrate will be covered and trucked to the Stewart Bulk Terminals port
facility in Stewart, BC and molybdenum concentrate will be covered and trucked to the
Prince Rupert port. Transportation will be carried out using highway-approved trucks,
operating up to 24 hours per day. Trucks will be capable of carrying 30 to 50 tonne
loads or as otherwise regulated by the Ministry of Transportation and Infrastructure.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 11

9 Closure and Post-Closure
9.1 Mitchell Pit and Underground Mine
When Mitchell underground mining ceases, the closure dam will be completed on the
west side of the pit to allow for controlled pit lake discharge. The crest of the closure
dam will be constructed with sufficient freeboard allowance to manage wave action
caused by avalanches.

9.2 Sulphurets Pit

Following completion of Sulphurets Pit mining, the mined out Sulphurets Pit will be
backfilled with waste rock from the Kerr Pit. The backfill will be constructed from the
bottom up with the outer edge of each bench lined with a synthetic liner to provide a
barrier to downward movement of water within the backfill once the backfilling operation
is complete. All drainage in contact with the Kerr Pit waste rock will be collected and
routed via a pipeline to the Selenium Treatment Plant and WTP.

9.3 Kerr Pit

Water management infrastructure for the Kerr Pit will be sized to accommodate and
route the 200 year flood event from the initiation of mining at the Kerr Pit.

9.4 Iron Cap Underground Mine

Drainage from surface inflow and the Iron Cap underground works will drain into the
Mitchell Pit north wall dewatering adit. This water will flow to the Mitchell Valley
Drainage Tunnel and into the WSF.

9.5 Mitchell and McTagg Rock Storage Facilities

The tops of the Mitchell and McTagg RSFs will be used to construct secure landfills to
store sludge from the WTP.

9.6 Water Storage Facility and Water Treatment Plant

The WSF and the WTP will remain in service after mine closure to continue collecting
and treating contact water during the post-closure phase.

During the closure and post-closure phases, the sludge generated by water treatment
will be placed (during the summer months) on the top of the Mitchell and McTagg RSFs
in a secured engineered landfill. During winter, the sludge will be temporarily stored in a
sludge storage building located near the WTP until it can be placed in the permanent
secure landfill during the following summer. A run-off collection channel will collect and
route contact water from the landfills to the WSF.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 12

9.7 Mitchell-Treaty Twinned Tunnel
During the closure and post-closure phases, the MTT will remain in operation to provide
access to the mine site. All supplies for monitoring, and the maintenance and operation
of the WTP (including lime) will be transported from the PTMA through the MTT to the
mine site.

9.8 Tailing Management Facility

Once mining ceases, tailing in the Centre Cell will be sealed by a cover of rougher
flotation tailing and flooded and remain flooded at all times thereafter. The TMF will be
reclaimed to provide wildlife and wetland habitat as per the Closure and Reclamation
Plan (section 10.12).

9.9 Coulter Creek Access Road

The CCAR will be decommissioned post-closure in accordance with applicable law
and/or provincial guidelines in effect at the time of decommissioning.

9.10 Treaty Creek Access Road

The TCAR will remain gated and access will be limited to personnel involved in post-
closure activities or where approved under the Traffic and Access Management Plan
(section 10.6).

9.11 Small-Scale Hydroelectric Power Stations

With the exception of the energy recovery stations installed in the tailing lines at the
TMF, the small-scale hydro-electric power stations will continue to supply electricity to
the Project site during the closure and post-closure stages.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 13

10 Environmental Management Plan
Frameworks
The Project’s Environmental Management System will include Environmental
Management Plans, environmental monitoring and follow-up programs. Unless stated
otherwise, all Environmental Management Plans described in section 10 will be
developed to the satisfaction of the Environmental Assessment Office and listed
provincial government agencies, and will be submitted before the start of Project
construction or operation as required.

Environmental Management Plans, environmental monitoring and follow-up programs

will be based on the principles of prevention and adaptive management whereby
monitoring and corrective action will occur to address concerns or issues that emerge in
the course of construction, operation, closure, and post-closure activities.

10.1 Wildlife Effects Monitoring Plan

The Environmental Assessment Certificate (EAC) Holder must develop a Wildlife
Effects Monitoring Plan (WEMP) which will investigate and detect potential
environmental effects on wildlife Valued Components (VC) due to Project activities. The
WEMP will describe monitoring related to the following wildlife VC species: moose,
mountain goats, grizzly and black bears, furbearers, marmots, bats, birds, and western
toads.

The WEMP will include, at a minimum:

 a species monitoring program which will describe monitoring plans for VC wildlife
species (e.g., moose, mountain goat, grizzly bear, furbearer, and marmots) in
order to determine Project related effects and evaluate the health of the regional
population;
 a Project infrastructure monitoring program which will evaluate the efficacy of
mitigation activities and allow for adaptive management (e.g., camp waste
management);
 a standard operating procedure to address potential impacts to wildlife from the
use of Highway 37 by company-owned vehicles and subcontractors managed by
the EAC Holder; and
 a standard operating procedure for monitoring and reporting wildlife collisions
and mortalities with company-owned vehicles and subcontractors managed by
the EAC Holder along provincial Highways 37 and 37A.

10.1.1 Plan Objectives

The objectives of the species monitoring program under the WEMP will be to:

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 14

  monitor for changes in wildlife VC species distribution and behaviour, and
manage adaptively; and
 monitor habitat loss to track the as-built size of the Project footprint and compare
this to the area identified in the Application.

The objectives of the Project infrastructure monitoring program under the WEMP will be
to:

 verify the predictions of the environmental effects assessment as described in

the Application;
 address uncertainties, and determine if mitigation measures are working as
intended;
 monitor interactions of VCs with Project infrastructure (e.g., TMF) and the
effectiveness of mitigation measures (e.g., tunnels, building skirting); and
 provide information to guide adaptive management (e.g., deterrents).

10.1.2 Monitoring Locations and Sampling Methods and Frequency

The WEMP Adaptive Management Program design will include, at a minimum:

 species monitoring will occur by surveying treatment and control sites;

 a selection of the sites and survey units used during baseline studies for the
environmental assessment will continue to be monitored;
 pre-development and reference sites will be included in the monitoring program
to allow for “before-after-control-impact” design of monitoring programs in relation
to the effects assessment;
 monitoring locations will be specific to Project components in the case of Project
infrastructure monitoring (e.g., pits, TMF, access roads, buildings). Sampling
methodologies will be described in the WEMP and will be consistent with the
current version of the BC Resource Inventory Standards Committee. Statistical
analyses methods and power analyses will also be described in the WEMP;
 Project infrastructure monitoring will occur once per year; and
 monitoring of moose, grizzly bear, mountain goats, furbearers and marmots will
occur every five years, commencing with construction and ceasing with the
commencement of closure. Where a survey for moose, mountain goat, grizzly
bear, furbearer, or marmots to be carried out by a person other than the EAC
Holder has been approved by the Ministry of Forests, Lands and Natural Resource
Operations (FLNR) and such survey meets some or all of the objectives of this
WEMP to the satisfaction of FLNR, the EAC Holder will be relieved of the
requirement to meet the terms of the WEMP that the survey satisfied.

10.1.3 Management Response

An adaptive management approach will be implemented under the WEMP. If long term
monitoring reveals important new information then adaptive management actions would
be implemented to mitigate site-specific risks. The WEMP will identify management
and/or monitoring strategies.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 15

10.1.4 Reporting
A summary of the data collected under the WEMP will be provided in a report. The
report will summarize:

 wildlife encounters and identify any adaptive management strategies that were
employed to address wildlife issues;
 analysis of the results with comparisons to findings from earlier years (i.e.,
baseline and previous monitoring years); and
 recommendations (if any) for changes to wildlife monitoring and management
practices.

The report will also detail reporting requirements, including:

 reporting frequency; and

 report distribution.

Reporting frequency will vary between the species and infrastructure monitoring
programs. Baseline data collected during the pre-construction phases (e.g., historical
data, baseline data, and pre-construction monitoring) will be summarized in the WEMP
to establish the foundation for comparison of future monitoring data to baseline
conditions. Reports will be provided to the Nisga’a Lisims Government,
Gitanyow Nation, Tahltan Nation, and wilp Skii km Lax Ha.

10.2 Aquatic Effects Monitoring Plan

The EAC Holder must develop an Aquatic Effects Monitoring Plan (AEMP), in
consultation with the Ministry of Environment (MOE), to satisfy Environmental
Management Act permit requirements. The primary goal of the AEMP is to investigate
and detect potential environmental effects in the aquatic receiving environment due to
Project activities. The monitoring program will be designed to take into account
discharge points and proximity to Project infrastructure to allow both local and regional
scale effects to be identified. Monitoring to meet both federal and provincial legislative
requirements will be integrated into the AEMP.

10.2.1 Plan Objectives

The objectives of the AEMP are to:

 verify the predictions of the environmental effects assessment presented in the

Application, address uncertainties, and determine if mitigation measures are
working as intended;
 detect any unforeseen effects or emerging environmental trends as measured
against baseline conditions;
 assist in identifying the potential cause-effect relationship between Project
activities and any environmental effects;
 provide data for the development of adaptive management and mitigation
strategies if effects are detected; and

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 16

  ensure regulatory compliance with respect to discharge and receiving
environment criteria and permitting conditions to be established at the permitting
stage.

10.2.2 Plan Components

The AEMP will include a conceptual site model to aid in the identification of potential
sources, environmental fate or exposure pathways, and potential receptors for
Contaminants of Potential Concern (COPC) in the aquatic receiving environment.

The AEMP will contain, at a minimum:

 a summary of the effects to fish and aquatic habitat that were identified in the
environmental assessment for the Project; and
 a summary of mitigation measures that were identified to avoid or reduce the
effects identified in the environmental assessment for the Project.

The AEMP will describe monitoring related to:

 surface water quantity;

 surface water chemistry;
 water toxicity;
 sediment chemistry;
 primary producers;
 benthic invertebrates (secondary producers);
 fish; and
 water temperature (Teigen and Treaty creeks).

10.2.3 Adaptive Management Program Design, Sampling Methods, and

Analysis
Monitoring locations will be selected in consultation with MOE, Environment Canada,
Fisheries and Oceans Canada and Nisga’a Lisims Government. The AEMP will contain
at a minimum the following information:

 adaptive management program design, including:

– identification of specific monitoring locations on Sulphurets Creek,

Unuk River, Treaty Creek, and Teigen Creek;
– sampling frequency;
– list of parameters or variables to be measured;
– laboratory analytical methods; and
– acceptable detection limits for laboratory analyses;
 sampling methodologies (including equipment, sample collection, handling, and
transport), and Quality Assurance/Quality Control (QA/QC) methods, consistent
with the current version of the:
– British Columbia Field Sampling Manual;

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 17

 – BC Water and Air Baseline Monitoring Guidance Document for Mine
Proponents;
– Environmental Data Quality Assurance Regulation (BC Reg. 301/90);
– Metal Mining Technical Guidance for Environmental Effects Monitoring; or
– other equivalent guidance documents, as acceptable to MOE or
Environment Canada;
 statistical analysis to be used (e.g., before-after-control-impact, trend analysis);
and
 identification of triggers for additional mitigative action.

10.2.4 Management Response

An adaptive management approach will be implemented under the AEMP. This will
facilitate the implementation of early mitigation strategies before concentrations in the
aquatic receiving environment approach levels where potential effects may occur. The
AEMP will identify monitoring or management strategies, and will be informed by the
following documents, as updated periodically:
 BC Ambient Water Quality Guidelines (approved and working guidelines);
 Guideline for the Derivation and Application of Water Quality Objectives in
British Columbia (2013);
 Canadian Council of Ministers of the Environment (CCME) Water Quality
Guidelines for the Protection of Aquatic Life (1987); or
 other equivalent guidance documents as acceptable to MOE or
Environment Canada.

10.2.5 Reporting Summary

Baseline data collected during the pre-construction phases (e.g., historical data, data to
support environmental assessment, and ongoing pre-construction monitoring) will be
summarized into the AEMP to establish the foundation for comparison of future
monitoring data to baseline conditions. Raw baseline data will be provided in
appendices of the AEMP.
The AEMP will detail reporting and notification requirements, including a description of
report contents, recommendations, reporting frequency, and report distribution. Reports
will be provided to the Nisga’a Lisims Government, Gitanyow Nation, Tahltan Nation,
and wilp Skii km Lax Ha.

10.3 Salmon Monitoring Plan

The EAC Holder must develop a Salmon Monitoring Plan (SMP) in consultation with
FLNR, MOE and Fisheries and Oceans Canada. The scope of the SMP includes Teigen
and Treaty creeks. The purpose of the SMP is to monitor salmon and their habitat in
relation to Project related effects and implement mitigation to avoid or reduce these
effects.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 18

10.3.1 Plan Objectives
The objectives of the SMP are to:
 verify the predictions of the environmental effects assessment presented in the
Application, address uncertainties, and determine if mitigation measures are
working as intended;
 detect any unforeseen effects or emerging environmental trends as measured
against baseline conditions;
 assist in identifying the potential cause-effect relationship between Project
activities and environmental effects;
 provide data for the development of adaptive management and mitigation
strategies if effects are detected;
 support the AEMP and Selenium Management Plan; and
 incorporate information from Aboriginal salmon monitoring programs on the
Nass River.

10.3.2 Plan Components

The SMP will contain, at a minimum:
 a summary of the effects to salmon and salmon habitat that were identified in the
environmental assessment for the Project; and
 a summary of mitigation measures that were identified to avoid or reduce the
effects identified in the environmental assessment for the Project.

The SMP will describe monitoring related to:

 surface water quantity;
 surface water temperature;
 salmon habitat; and
 juvenile and adult salmon abundance.

10.3.3 Program Design, Sampling Methods, and Analysis

The SMP will contain the following information, at a minimum:
 program design, including:
– sampling locations, timing and frequency;
– key performance criteria/metrics to be evaluated and monitored;
– target salmon habitats and life history stages to be evaluated and monitored;
and
– list of biological and abiotic parameters or variables to be measured.
 sampling methodologies (including equipment, sample collection and processing)
and QA/QC methods; and
 statistical analysis to be used (e.g., before-after-control-impact, trend analysis).

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 19

10.3.4 Management Response
An adaptive management approach will be implemented under the SMP. This will
facilitate the implementation of early mitigation strategies before any significant effects
were to occur on salmon and their habitat. The results of the SMP will assist in
identifying additional monitoring or management strategies, if required.

10.3.5 Reporting Summary

Baseline data collected during the pre-construction phases (e.g., historical data, data to
support the environmental assessment, and ongoing pre-construction monitoring) will
be summarized into the SMP to establish the foundation for comparison with future
monitoring data to baseline conditions. Raw baseline data will be provided in
appendices of the SMP.

The SMP will detail reporting and notification requirements, including a description of
report contents, recommendations, reporting frequency, and report distribution. Reports
will be provided to relevant government agencies, Nisga’a Lisims Government,
Gitanyow Nation, Tahltan Nation and wilp Skii km Lax Ha.

10.4 Selenium Management Plan

The EAC Holder must develop a Selenium (Se) Management Plan (SeMP), in
conjunction with MOE and the Ministry of Energy and Mines (MEM), to satisfy
Environmental Management Act and Mines Act permit requirements. The primary goal
of the SeMP is to ensure the protection of the aquatic receiving environment. Selenium
monitoring activities and data collection will form a sub-component of the AEMP and the
WMP, and the SeMP will be based on four components (i.e., prediction, prevention,
mitigation, and monitoring). The SeMP will include a conceptual site model to aid in the
identification of potential sources, environmental fate or exposure pathways, and
potential receptors for Se in the aquatic receiving environment.

10.4.1 Plan Objectives

The objectives of the SeMP are to:
 consolidate relevant information for the adaptive management of Se into one
document;
 provide a framework for Se management that meets best practices for
environmental and technical objectives of the Project, in addition to ensuring
regulatory requirements are considered and addressed;
 identify actions that will be taken during various phases of the Project to avoid,
prevent, and mitigate potential effects of Se on the aquatic receiving
environment; and
 define a monitoring program to characterize the potential risks of Se for the
aquatic receiving environment.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 20

10.4.2 Plan Components
The SeMP will describe, at a minimum, monitoring related to selenium concentrations
in:
 surface water;
 sediment;
 primary producers;
 benthic invertebrates (secondary producers);
 fish tissue or eggs; and
 bird eggs.

10.4.3 Monitoring Program Design, Sampling Methods, and Analysis

Monitoring locations will be selected in consultation with MOE and MEM. The SeMP will
contain or describe the following information at a minimum:
 monitoring program design, including:
– types of media or biota to be monitored;
– identification of specific monitoring locations on Sulphurets Creek,
Unuk River, Treaty Creek, and Teigen Creek;
– sampling frequency;
– list of parameters or variables to be measured;
– laboratory analytical methods; and
– acceptable detection limits for laboratory analyses.
 sampling methodologies (including equipment, sample collection, handling, and
transport), and QA/QC methods, consistent with the current version of the:
– British Columbia Field Sampling Manual;
– BC Water and Air Baseline Monitoring Guidance Document for Mine
Proponents;
– Environmental Data Quality Assurance Regulation (BC Reg. 301/90);
– Metal Mining Technical Guidance for Environmental Effects Monitoring; or
– other equivalent guidance documents, as acceptable to MOE or
Environment Canada;
 statistical analysis to be used (e.g., before-after-control-impact, trend analysis);
and
 development of a Se bioaccumulation model.

10.4.4 Management Response

An adaptive management approach will be implemented under the SeMP. This will
facilitate the implementation of early mitigation strategies before concentrations in the
aquatic receiving environment approach levels where potential effects may occur. The
SeMP will identify monitoring or management strategies, and will be informed by the
following documents, as updated periodically:
 BC Ambient Water Quality Guidelines for Selenium (2001);

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 21

  Guideline for the Derivation and Application of Water Quality Objectives in
British Columbia (2013);
 CCME Water Quality Guidelines for the Protection of Aquatic Life (1987);
 State of Alaska Department of Environmental Conservation Water Quality
Standards for Selenium (amended as of April 8, 2012);
 US EPA (Environmental Protection Agency) Guidelines Draft Water Quality
Criteria for Aquatic Life for Selenium (2004); or
 other documents as acceptable to MOE.

10.4.5 Reporting Summary

Baseline data collected during the pre-construction phases (e.g., historical data, data to
support environmental assessment, and ongoing pre-construction monitoring) will be
summarized (e.g., water quality, aquatic resources, fish, etc.) in the SeMP to establish
the foundation for comparison of future monitoring data to baseline conditions. Raw
baseline data will be provided in appendices of the SeMP.

The SeMP will detail reporting and notification requirements, including a description of
the report contents, recommendations, reporting frequency, and report distribution.
Reports will be provided to the Nisga’a Lisims Government, Gitanyow Nation,
Tahltan Nation, and wilp Skii km Lax Ha.

10.5 Groundwater Monitoring and Mitigation Plan

The EAC Holder must develop a Groundwater Monitoring and Mitigation Plan (GMMP),
in conjunction with MOE and MEM. The primary goal of the GMMP is to monitor and
mitigate Project effects on groundwater quality and quantity. Monitoring results from the
GMMP will inform the AEMP.

10.5.1 Plan Objectives

The objectives of the GMMP are to:
 monitor groundwater quality from seepage of contact water from mine
components;
 monitor the changes in groundwater levels arising from mine components; and
 provide data for the development of adaptive management and mitigation
strategies if effects are detected.

10.5.2 Plan Components

The GMMP will include a description of baseline conditions including groundwater flow,
groundwater quality, groundwater recharge and discharge, and groundwater surface
water interaction. The GMMP will describe monitoring related to groundwater quality
from seepage of contact water from mine components. The GMMP will also describe
mine components and activities that could adversely affect groundwater quality and
quantity. The GMMP will also include contingency plans for the interception and
treatment of mine affected groundwater between Sulphurets and Kerr Pits and

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 22

Sulphurets Creek. The GMMP will include triggers for implementing the contingency
plans.

10.5.3 Monitoring Program Design, Sampling Methods, and Analysis

The GMMP will provide the following information, at a minimum:
 groundwater monitoring locations at the mine site and PTMA;
 sample collection methods, QA/QC, sampling frequency, well design and
analysis methods; and
 water quality parameters or variables to be measured.

10.5.4 Management Response

An adaptive management approach will be implemented under the GMMP. This will
facilitate the implementation of early mitigation measures before concentrations in the
aquatic receiving environment approach levels of concern. The GMMP will be informed
by the BC Water Quality Guidelines (BC MOE 2010d), as updated periodically.

10.5.5 Reporting Summary

Groundwater baseline data collected during the pre-construction phase will be
summarized in the GMMP to establish the foundation for comparison of future
monitoring data to baseline conditions. Raw baseline data will be provided in
appendices.

The GMMP will detail reporting and notification requirements, including a description of
the report contents, recommendations, reporting frequency, and report distribution.
Reports will be provided to the Nisga’a Lisims Government, Gitanyow Nation,
Tahltan Nation, and wilp Skii km Lax Ha.

10.6 Traffic and Access Management Plan

The EAC Holder must develop a Traffic and Access Management Plan.

10.6.1 Plan Objectives

The objectives of the Traffic and Access Management Plan are to ensure Project
access roads are:
 designed and maintained in a manner that assures the safety of road users and
minimizes adverse effects on the environment and wildlife; and
 used in a manner that avoids adverse worker and public health and safety effects
and minimizes adverse social and environmental effects.

10.6.2 Plan Components

The Traffic and Access Management Plan will include, at a minimum:
 Coulter Creek access road; and
 Treaty Creek access road.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 23

10.6.3 Monitoring
The Traffic and Access Management Plan will identify monitoring requirements
including:
 observation of ungulate use of access roads during periods of deep snow to
assess the effectiveness of refuge areas and escape routes;
 observation of wildlife use of road verges to assess effectiveness of browse
management and visibility;
 monitoring of sediment release from construction and operation of stream
crossings to identify any additional remedial measures required;
 tracking of unauthorized use of access roads and transmission line corridors;
monitoring of unauthorized fish, wildlife, and plant harvesting by Project
employees and contractors;
 enforcement of access road speed limits;
 tracking of wildlife observations and incidents to identify wildlife sensitive areas;
and
 inspection of access gates for signs of effectiveness or forced entry.

10.6.4 Management Response

An adaptive management approach will be implemented under the Traffic and Access
Management Plan.

10.6.5 Reporting Summary

The Traffic and Access Management Plan will detail reporting requirements, reporting
frequency, and report distribution. Reports will be provided to the Nisga’a Lisims
Government, Gitanyow Nation, Tahltan Nation, and wilp Skii km Lax Ha.

10.7 Wetlands Management Plan

The EAC Holder must develop a Wetlands Management Plan to ensure protection of
wetlands during construction, operation, and monitoring of wetland compensation sites.

10.7.1 Plan Objectives

The objective of the Wetlands Management Plan is to maintain affected wetlands to
levels of functionality similar to baseline conditions.

10.7.2 Plan Components

The Wetlands Management Plan will include, at a minimum, monitoring of wetlands
potentially affected by the construction and operation of the CCAR, TCAR and TMF and
wetland compensation sites.

10.7.3 Monitoring
The Wetlands Management Plan will identify monitoring requirements including, at a
minimum:
 vegetation sampling for biomass and tissue metal concentrations (at select sites);

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 24

  photo point monitoring to evaluate changes in vegetation and site characteristics
(at select sites);
 wetland function; and
 wetland compensation sites to be conducted contemporaneously with fish
compensation sites.

Wetland buffers will be established in accordance with the Riparian Area Management
Guidebook (Ministry of Forest and MOE, 2005).

10.7.4 Management Response

An adaptive management approach will be implemented under the Wetlands
Management Plan.

10.7.5 Reporting Summary

Wetland baseline data collected during the pre-construction phase will be summarized
to establish the foundation for comparison of future monitoring data to baseline
conditions in the Wetlands Management Plan. Raw baseline data will be provided in
appendices of the Wetlands Management Plan.

The Wetlands Management Plan will detail reporting and notification requirements,
including a description of the report contents, recommendations, reporting frequency,
and report distribution. Reports will be provided to the Nisga’a Lisims Government,
Gitanyow Nation, Tahltan Nation, and wilp Skii km Lax Ha.

10.8 Water Management Plan

The EAC Holder must develop a Water Management Plan (WMP) for the mine site and
PTMA, in conjunction with MOE and MEM to satisfy Environmental Management Act
and Mines Act permit requirements. The AEMP will incorporate the water quality and
quantity aspects of the WMP.

10.8.1 Plan Objectives

The objectives of the WMP are to provide a basis for management of surface water at
the mine site and PTMA including:
 diverting non-contact water around the mine site and PTMA; and
 collecting and treating contact water from the mine site to meet discharge
requirements prior to release to the receiving environment.

10.8.2 Plan Components

The WMP will include, at a minimum:
 a description of water management structures at the mine site and PTMA;
 a list of water sources, including a description of water management structures;
 mine site water balance; and

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 25

  monitoring program including sample points downstream from major water
retention structures (e.g., TMF, WSF) and discharge points during operations
(e.g., Treaty Creek and WTP).

10.8.3 Monitoring
The WMP will identify monitoring requirements including:
 sampling stations or areas, including a site map identifying sampling locations;
 sampling frequency, methods and replication protocols;
 analysis including field sampling methods, field and lab QA/QC, variables to be
measured for each sample location, sample collection, handling, preparation and
transport procedures; and
 lab analytical methods.

10.8.4 Management Response

An adaptive management approach will be implemented under the WMP. Surface water
quantity and quality modelling will be updated in the WMP, based on the results of the
monitoring program.

10.8.5 Reporting
The WMP will detail reporting and notification requirements, including a description of
the report contents, recommendations, reporting frequency, and report distribution.
Reports will be provided to the Nisga’a Lisims Government, Gitanyow Nation,
Tahltan Nation, and wilp Skii km Lax Ha.

10.9 Spill Prevention and Emergency Response Plan

The EAC Holder must develop a Spill Prevention and Emergency Response Plan, in
conjunction with MEM and MOE, to respond to un-intentional releases and intentional
emergency releases from Project facilities and along Project infrastructure.

10.9.1 Plan Objectives and Components

The Spill Prevention and Emergency Response Plan objectives are to outline a
pre-determined course of action to:
 implement during an emergency situation related to a spill;
 provide a practical plan on how to safely assess an incident;
 implement actions to minimize incident; and
 complete the follow-up and any corrective action in a safe and effective manner.

The Spill Prevention and Emergency Response Plan will include, at a minimum:
 a strategy for the management of the handling, transportation, and storage of
solid and liquid materials to reduce the risk of spills that might adversely affect
people and the environment; and
 a conceptual plan for the emergency response to such spills.

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 26

10.9.2 Management Response
An adaptive management approach will be implemented under the Spill Prevention and
Emergency Response Plan.

10.9.3 Reporting
The Spill Prevention and Emergency Response Plan will identify reporting
requirements, including report distribution. Reports will be provided to the
Nisga’a Lisims Government, Gitanyow Nation, Tahltan Nation, and wilp Skii km Lax Ha.

10.10 Human Health Monitoring Plan

The EAC Holder must implement a Human Health Monitoring Plan (HHMP) to monitor
ambient air quality and metal levels in soils and plant tissues, in conjunction with MOE
and MEM, to satisfy Environmental Management Act and Mines Act permit
requirements for the mine site.

10.10.1 Plan Objectives

The objectives of the HHMP are to:
 assess data for potential impacts on human health;
 ensure there is an understanding of metals in soils, plants and animals which
have the potential to affect human health;
 establish measures to monitor effects on key valued components during
construction and operation of the Project;
 detect potential soil contaminant accumulations and metal deposition/mobility
patterns during construction and operation of the Project; and
 assess potential changes in terrestrial plant tissue metal concentrations as a
result of Project activities during construction, operation, closure and post-closure
phases.

10.10.2 Plan Components

HHMP components will include, at a minimum:
 modelling predicted concentrations of COPC including, but not limited to dioxins
and furans in airshed and determining the likely paths of such COPCs;
 waste segregation and incineration policies aimed at reducing COPC in the
airshed;
 a contaminated soil prevention strategy;
 a terrestrial plant monitoring strategy; and
 a human health risk assessment framework to identify thresholds. The
assessment will include, but not be limited to, the sampling of small mammal
tissues, metals in fish and wild game (e.g., grouse and moose) consumed, and a
characterization of traditional food quality.

10.10.3 Monitoring
The HHMP will identify monitoring requirements including:

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 27

  locations of sampling points and sites;
 sampling methods including QA/QC, sampling frequency, modelling studies; and
 the parameters or variables to be monitored.

10.10.4 Management Response

An adaptive management approach will be implemented under the HHMP. The HHMP
will identify monitoring or management strategies, and will be informed by the following
documents, as updated periodically:
 Provincial Air Quality Objectives;
 Pollution Control Objectives for the Mining, Smelting and Related Industries of
British Columbia (BC MOE 1979);
 National Ambient Quality Objectives;
 Canadian Ambient Air Quality Standards; and
 CCME Soil Quality Guidelines for the Protection of Environmental and Human
Health.

10.10.5 Reporting
Baseline data collected during the pre-construction phase will be summarized in the
HHMP to establish the foundation for comparison of future monitoring data to baseline
conditions. Ongoing screening level risk assessments will be completed under the
HHMP in order to identify changes in measured concentrations to identify potential
exposures and risks. Raw baseline data will be provided in appendices of the HHMP.
The HHMP will detail reporting requirements, reporting frequency, and report
distribution. Reports will be provided to the Nisga’a Lisims Government,
Gitanyow Nation, Tahltan Nation, and wilp Skii km Lax Ha.

10.11 Terrestrial Ecosystems Management and Monitoring Plan

The EAC Holder must develop a Terrestrial Ecosystems Management and Monitoring
Plan with the overall goal of minimizing effects of the Project on vegetation and
terrestrial ecosystems. The Plan will include, at a minimum, four individual
Environmental Management Plans:
 Vegetation Clearing Management Plan;
 Invasive Plant Management Plan;
 Transmission Line Management Plan; and
 Terrestrial Plant Tissue Metal Concentrations Monitoring Plan.

10.11.1 Plan Objectives and Components

The objectives of the Terrestrial Ecosystems Management and Monitoring Plan are to:
 minimize vegetation loss and disturbance of ecosystems (with emphasis on
identified sensitive ecosystems) resulting from land clearing and vegetation
maintenance activities;
 avoid the introduction and subsequent spread of invasive plant species (with
emphasis on regionally-important plant species); and

KSM PROJECT CERTIFIED PROJECT DESCRIPTION 28

  monitor metal concentrations in terrestrial plant tissues to minimize potential risk
to human and wildlife health.

A site map will be developed under the Terrestrial Ecosystems Management and
Monitoring Plan to identify sensitive ecosystems within the area of proposed
construction, and provided to FLNR and Nisga’a Lisims Government. Reports will be
provided to the Nisga’a Lisims Government, Gitanyow Nation, Tahltan Nation, and
wilp Skii km Lax Ha.

10.11.2 Monitoring
The Terrestrial Ecosystems Management and Monitoring Plan will contain or describe
the following information:
 monitoring program design, including:
- identification of sampling areas, and sampling frequency; and
- sampling methodologies (including equipment, sample collection, handling,
and transport), and QA/QC methods, consistent with guidance documents, as
acceptable to FLNR.

10.11.3 Management Response

An adaptive management approach will be implemented under the Terrestrial
Ecosystems Management and Monitoring Plan. The Terrestrial Ecosystems
Management and Monitoring Plan will identify monitoring or management strategies,
and will be informed by the following documents, as updated periodically:
 British Columbia Timber Sales Windthrow Manual: A Compendium of Information
and Tools for Understanding, Predicting and Managing Windthrow on the BC
Coast;
 Pest Management Plan for Invasive Alien Plants on Provincial Crown Lands in
Central and Northern BC;
 Invasive Alien Plant Program: Reference Guide; and
 Integrated Vegetation Management Plan for Transmission Rights-of-Way.

10.11.4 Reporting
The Terrestrial Ecosystems Management and Monitoring Plan will detail reporting
requirements, reporting frequency, and report distribution. Reports will be provided to
the Nisga’a Lisims Government, Gitanyow Nation, Tahltan Nation, and
wilp Skii km Lax Ha.

10.12 Closure and Reclamation Plan

The EAC Holder must develop a Closure and Reclamation Plan to satisfy Mines Act
permit requirements. The goal of the Closure and Reclamation Plan is to define the
requirements for closure and reclamation of the site, develop approaches to address
these requirements, and incorporate into the mine plan and schedule. The Closure and

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Reclamation Plan will be updated during the life of the mine, and submitted to MEM for
review, in accordance with the Health, Safety and Reclamation Code for Mines in BC.

The Closure and Reclamation Plan will include the following, at a minimum:
 definition of end land use objectives, including a discussion of the proposed
objectives for the site;
 description of the overall reclamation approach as it pertains to the end land use
objectives;
 conceptual plan for implementing the reclamation approach over the life of mine
and into closure based on the most recent Mine Plan;
 identification of growth medium;
 plans for soil salvage, handling, and stockpile treatment;
 plans for soil replacement;
 plans for long-term stability, erosion control, and landform design, including
drainage control and watercourse protection;
 identification of opportunities and plans for progressive reclamation;
 plan for revegetation that includes identification of vegetation species to be used
(with a preference to use of native species), planting methodologies/
prescriptions, and expected fertilization requirements. Maps indicating areas that
will be addressed by different prescriptions to meet site-specific end land use
objectives and/or diverse environmental conditions will be provided;
 plans for reclamation research, including vegetation trials, summary or reference
to previous research and how it is being used to guide future closure and
reclamation;
 outline a proposed program to assess trace element uptake in soils and
vegetation at mine closure, and where possible, during the mine life;
 identification of requirements for disposal of chemicals and reagents;
 outline investigations required as per the BC Contaminated Sites regulations,
and provide anticipated remedial action plans for mitigating potential
contamination;
 outline plans for decommissioning of groundwater wells as per the BC Water Act
and the BC Groundwater Protection Act;
 description of plans for removal of structures and equipment including foundation
materials and identification of disposal locations for non-salvageable materials;
 plans for reclamation of permanent site components including waste rock dump,
open pit, TMF, low grade ore stockpile location and shop areas;
 plan for TMF spillway design;
 water quality monitoring including monitoring stations, frequency, parameters and
a map identifying monitoring locations across the site;
 updates regarding water treatment requirement, including discussion of any
changes to proposed water treatment technologies;
 plans for monitoring reclamation activities to assess the effectiveness of all
reclamation strategies and prescriptions, including revegetation, surface
preparation, soil replacement, erosion control, landform design and drainage
control; and

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  updated reclamation liability cost estimates based on level of disturbance on site
and proposed reclamation activities, and including costs related to water
treatment and long term monitoring and maintenance.

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