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

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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 MIRAMAR MIRAM R NO NORTH RTHERN RN MINING MINING L LTD. CON M MIN INE August 31, 2018 Mackenzie

  1. 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. 17 17

  2. 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 • 18 18

  3. 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/L 1 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 19 19

  4. 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. 20 20

  5. 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 (90,038m 3 ), 2016 (278,153m 3 ), 2017 (238,828m 3 ) 21 21

  6. 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 22 22

  7. 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 on-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. 23 23

  8. 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. 24 24

  9. 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 • Keg Lake July 2015 Meg Lake July 2015 25 25

  10. 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 26 26

  11. 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 of salts entering the M-K-P system. - Note EQC change in 2021 27 27

  12. 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. 28 28

  13. 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 29 29

  14. 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. 30 30

  15. 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 LC 50 (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 31 31

  16. Mean Chloride Concentrations in Treated Effluent and Receiving Water • 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 Proposed annually (maintain flows in Chloride EQC system) • Modelling is calibrated to actuals at SNP 0040-5 • More information is required to further understand the system 32

  17. 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 33 33

  18. 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). 34 34

  19. What is Protected - Mixing Zone Boundary Proposed SSWQO 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 CaCO 3 )  SSWQO = 260 mg/L Cl (rounded to two significant figures) SSD with C. triangulifer Updated hardness-dependent equation: 𝑋𝑅𝑃 = 79.02 𝑦 ln ℎ𝑏𝑠𝑒𝑜𝑓𝑡𝑡 − 138.28 35 35

  20. 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 36 36

  21. 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 lethality 1 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 37 37

  22. 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 38 38

  23. 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. 39 39

  24. Working Group Priority Topic Schedule Start Date Target Deliverable Date Short Term Monitoring Plan for Meg, Keg, Peg Lakes; Review current data and conditions in Spring 2019 Spring 2020 1 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. 2 Closure Objectives and Criteria; Consider approved Objectives and Criteria, consider where Fall 2019 Fall/Winter 2021 necessary objectives and/or criteria for success. Schedule excludes M-K-P and Minewater. Long-Term Monitoring; Review current and future data and provide recommendations, where Spring 2022 Fall/Winter 2025 3 possible, to the MVLWB regarding the long-term monitoring requirements and plan for the project site and receiving environment. 4 Minewater and Groundwater Flooding Criteria; Review available data and documentation on Spring 2026 Fall/Winter 2028 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. Meg – Keg – Peg; Review short and long-term monitoring results to consider potential response to Spring 2027 or Earlier Fall 2031 5 continued discharge. should data allow Subsequent Water Licence; Review and provide recommendations, where necessary and Fall 2030 Fall 2032 6 possible, to the MVLWB as to the type, term, EQCs, and conditions for the subsequent Water Licence Application Package to be submitted Fall 2032. 40 40

  25. 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% over 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 of an on-going effort by both parties to come to a lasting agreement for the Con Mine security following devolution. 41 41

  26. 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 42 42

  27. Thank You 43 43

  28. 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) of 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 200,000 cubic metres (m 3) per year exceeded: March 31, 2008January 30, 2019 Effective date of Licence: 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

  29. PART A: SCOPE AND DEFINITIONS Scope 1. This Licence entitles Miramar Northern Mining Ltd. to use water and dispose of Waste 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”). 2. This Licence continues the approval of the existing plans, programs, studies and 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). 3. 2. This Licence is issued subject to the conditions contained herein with respect to the 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 of 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;

  30. “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 of 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 of 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,

  31. 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 6 th , 1986and associated area to collect

  32. 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.

  33. PART B: GENERAL CONDITIONS 1. The Water Use Fee shall be paid annually in advance of any Water Use. 2. The Licensee shall maintain a security deposit of $7,823,190.008,716,406 and shall maintain further security deposits in accordance with this section: a) Such further or other amounts of security may be required by the Board 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 b) Reductions to the security deposit may be granted by the Board based on 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. 3. The security deposit shall be maintained until such a time as it is fully or partly refunded by the Minister pursuant to section 35 of the Act. 4. All information submitted to the Board, as required by this Licence, shall: a) Be submitted in a form acceptable to the Board; b) Be in accordance with the Board’s March 2012 Document Submission Standards; and c) Include a section within each submission that identifies wherein the pertinent requirements of this Licence are addressed. 5. The Licensee shall operate in accordance with approved plans, programs, studies 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. 6. 4. The Licensee shall file an Annual Report with the Board not later than March 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;

  34. g) a summary of any closure and reclamation work completed and an outline of 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 1 st 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; o) 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. 7. Beginning June 6 th , 2022, and no later than every June 6 th each 3 years thereafter (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] 8. Within 90 days following the submission of the Former Con Mine Status of Environment Report the Licensee shall update the Con Mine Post Closure Monitoring and Maintenance Plan (PCMMP) and its components. 9. 5. The Licensee shall comply with the Surveillance Network Program annexed to 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 . 10. 6. The terms of this Licence, including the Schedules, the Surveillance Network 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.

  35. 11. 7. Meters, devices or other such methods used for measuring the volumes of water used and Waste discharged shall be installed, operated and maintained by the Licensee to the satisfaction of an Inspector. 12. 8. The Licensee shall, within sixty (60) days of the issuance of this Licence, post 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. 13. 9. The Licensee shall replace or repair any monitoring wells that become inoperable to the satisfaction of an Inspector. For greater certainty, a "dry well" is not an inoperable well within the meaning of this licence. 14. 10. The Licensee shall ensure a copy of this Licence is maintained at the site of operation at all times. 15. In conducting its activities under this Licence, the Licensee shall make best efforts to consider and incorporate any scientific and Traditional Knowledge that is made available to the Licensee. PART C: CONDITIONS APPLYING TO WATER USE 1. 1. The annual quantity of water used for all purposes shall not exceed 200,000 cubic metres. 2. The licensee is permitted to construct, operate and maintain, drainage, channels, sumps and dewatering infrastructure as required to collect surface and Minewater. This does not constitute a water use under the licence.

  36. PART D: CONDITIONS APPLYING TO WASTE DISPOSAL 1. The Licensee shall submit to the Board for approval 90 days prior to construction, 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; a) rationale outlining how cover thickness will be determined;Site Water and Mine Flooding Management Plan b) materials to be used for construction;Solid and Hazardous Waste Management Plan c) the purpose of each component of the cover system;Emergency Response and Spill Contingency Plan d) a cost-benefit analysis of the alternatives considered;Vegetation Establishment Monitoring Plan e) details on how the final design will be determined and tested;Surveillance Network Program f) an estimate of how much precipitation is expected to infiltrate through the 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 on 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. 2. An inspection of the hazardous waste disposal site, Tailing Containment Area(s), 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 outlining an implementation plan to respond to the GeotechnicalProfessional Engineer's recommendations. 3. The Licensee shall submit to the Board for approval 90 days prior to construction,

  37. 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 or 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) a Freeboard limit of 1.0 m shall be maintained at all times for the Middle Pud Tailing Containment Area, or as otherwise recommended by a GeotechnicalProfessional Engineer; b) the solid fraction of the mill Tailings within the Middle Pud Tailing 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

  38. sixty (60) days of the inspection, including a covering letter from the Licensee outlining an implementation plan to respond to the Geotechnical Engineer's recommendations.as recommended by a qualified Professional Engineer or an Inspector. 4. 7. All Waste discharged from Middle Pud Tailing Containment Area that does not 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 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.

  39. 5. 8. No Waste discharge, Seepage or other flow from a Tailing Containment 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. 6. 10. The Licensee shall provide at least five (5) days notice to an Inspector prior to the first proposed discharge of Waste from Middle Pud Tailing Containment Areathe water treatment plant during each calendar year. 7. 11. All Waste discharged by the Licensee from a Tailing Containment Area(s), on or before June 1, 2021, including discharge from the water treatment plant, at SNP 0040-1, shall meet the following effluent quality requirements: Parameter Maximum Maximum Average Concentration 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. 8. All Waste discharged by the Licensee from a Tailing Containment Area(s) after June 1, 2021, including discharge from the water treatment plant at SNP 0040-1, shall meet the following effluent quality requirements: Parameter Maximum Maximum Average Concentration 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

  40. Un-ionized ammonia (expressed 0.5 mg/L 1.0 mg/L as nitrogen) 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. 9. If, during the period of this Licence, the concentration of any sample from 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. 10. Minewater shall be managed in accordance with the Site Water and Mine Flooding Management Plan. Any Minewater that reaches the surface as a result of 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. 11. 12. In the event that minewater quality in the shallow mine workings or at the 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. 12. The Licensee shall submit to the Board for approval an updated Solid and 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 or 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: a) updated results from the Mine Flooding Model;A summary of mitigation

  41. measures in place to prevent, reduce, or manage potential environmental impacts; b) measured volumes of water discharged and salinity;A list of all components to be monitored; c) delineation of discharge points and actions taken to control seepage that cannot be channelized to permit monitoring and mitigation if required; andA map and attached table or detailed legend illustrating monitoring and sampling locations; d) consideration of the possible impacts on receiving waters and mitigation options.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. e) A description of monitoring protocols, methodologies, parameters, and frequency specific to each type of monitoring; f) A description of the quality assurance and quality control measures followed for each monitoring type; g) A description, including detailed rationale, of the monitoring endpoints (and Action Levels) for each parameter monitored;

  42. h) A description of response actions (contingency plans) to be carried out if Action Levels are exceeded; and i) Any other item as directed by the Board. PART E: CONDITIONS APPLYING TO MODIFICATIONS 1. The Licensee may, without written approval from the Board, carry out Modifications 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: a) the Licensee has notified the Board in writing of such proposed Modifications at least sixty (60) days prior to beginning the Modifications; b) such Modifications do not place the Licensee in contravention of either the Licence or the Act; c) the Board has not, during the sixty (60) days following notification of the proposed Modifications, informed the Licensee that review of the proposal will require more than sixty (60) days; d) An Inspector has authorized the proposed Modifications and provided a letter of notification to the Board; and e) d) the Board has not rejected the proposed Modifications. 2. Modifications for which all of the conditions referred to in Part E, Item 1 have not been met may be carried out only with written approval from the Board. 3. The Licensee shall provide to the Board as-built plans and drawings of the 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. 1. 2. If, during the period of this Licence, an unauthorized discharge of Waste occurs, or if such a discharge is foreseeable, the Licensee shall: a) employ the appropriate contingency plan; b) report the incident immediately via the 24-Hour NWT Spill Report

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

  44. d) c) submit to an Inspector, a detailed report on each incident not later than thirty (30) days after initially reporting the event. PART G: CONDITIONS APPLYING TO CLOSURE AND RECLAMATION 1. The Licensee shall complete all continued remediation activities as described in the approved Final Closure Plan, in accordance with any design specifications or best industry practices as applicable. 2. 1. The Licensee may apply for a reduction in the amount of security set out in 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. 3. 2. The Licensee shall review the Final Closure Plan, and shall update the plan 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: a) the closure objectives; b) preferred closure option and methods; c) related monitoring; and d) any outstanding reports, research or plans. 4. 3. The Licenseelicensee shall in accordance with Schedule 1 provide to the Board annuallyan annual water licence summary report. 5. The Licensee shall provide to the Board with each submission of the Former 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

  45. applicable discipline. 6. 5. The Board will review the Updated Mine Reclamation Costs and Updated 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. 7. Compliance with the Final Closure Plan specified in this Licence does not limit the legal liability of the Licensee, other than liability arising from provisions of the Act and its Regulations. 8. The Licensee shall provide to the Board annually beby March 31st as-built 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 1. The Licensee shall design and implement an Aquatic Effects Monitoring Program (AEMP) that meets the following objectives: a) To determine the short- and long-term effects of the former Mine on the Receiving Environment; b) To test the predictions made in the Water License Application Package or in other submissions to the Board regarding the impacts of the former Mine on the Receiving Environment; c) To assess the efficacy of mitigation that is used to minimize the effects of the former Mine on the Receiving Environment; and d) To provide an early warning system where the results of the AEMP are used to avoid adverse effects through the Response Framework and/or regular evaluation of the AEMP 2. The Licensee shall implement the Draft AEMP Design Plan submitted in the June 15, 2018 submission to the Board until an updated AEMP Design Plan is approved by the Board. 3. The Licensee shall submit an updated AEMP Design Plan within [XX] months after issuance of the License that reflects directives from the Board.

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

  47. Schedule 1 Attached to Water Licence MV2017L8-0008 Annual Water Licence Summary Report 1. The Annual Water Licence Summary Report referred to in Part B, item 6, may 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) A summary of activities as they relate to Water Use and Waste disposal. b) A summary of the calibration and status of the meters and devices referred to in Part B of this Licence. c) A summary of construction activities, if any, undertaken during the previous year calendar year. d) A summary of Modification activities and major maintenance activities undertaken during the previous calendar year. e) A summary of activities conducted in accordance with the approved Final Closure Plan undertaken during the previous year, including; i. A high level assessment and description of the reclamation status in each of the areas and monitoring plans: (Improving, sustained, deteriorating); ii. A description of any action thresholds or trigger levels that have been reached or exceeded or conditions requiring closer monitoring in the following year; iii. A timeline for the development and submission of any proposed action or response required as a result of monitoring; iv. Follow up report(s) on any actions or responses that were previously flagged as a concern or requiring action; v. A summary of all analytical data collected throughout the year; vi. Monthly and Annual Volumes of all freshwater obtained; vii. Monthly and Annual Volumes of all waste water treated and released; viii. Monthly and annual quantities in cubic metres of water accumulated and stored within the Middle Pud Storage Pond, broken down by source; ix. Annual quantities in cubic metres of all non-hazardous waste placed in the landfill; and

  48. x. A summary of any closure and reclamation work completed. f) A summary of activities conducted in accordance with the approved Spill 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). g) An outline of any spill training and communications exercises carried out during the previous calendar year. h) Tabular summaries of all data and information generated under the 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. i) A summary of actions taken to address concerns, non-conformances, or deficiencies in any reports filed by an Inspector. j) Any other details on Water use or Waste disposal requested by the Board by November 1st of the year being reported.

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

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

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

  52. results of the AEMP; d) Tabular summaries of all data and information generated under the AEMP in an electronic and printed format acceptable to the Board; e) An interpretation of the results, including an evaluation of any identified environmental effects that occurred as a result of the former Mine; f) An analysis that integrates the results of individual monitoring components collected in a calendar year and describes the ecological significance of the results; g) A comparison of monitoring results to Action Levels as set in the AEMP Design Plan; h) An evaluation of the overall effectiveness of the AEMP to date; i) Recommendations, with rationale, for changes to any aspect of the AEMP Design Plan; j) Recommendations for refining the AEMP to improve its effectiveness as required; and k) Any other information specified in the approved AEMP Design Plan or that may be requested by the Board. 4. The Aquatic Effects Re-evaluation Report referred to in Part H , Item 7 shall include, but not be limited to, the following: a) A review and summary of AEMP data collected to date including a description of overall trends in the data and other key findings of the monitoring program; b) An analysis that integrates the results of individual monitoring components (e.g., water quality, sediment, fish health, etc.) to date and describes the overall ecological significance of the results; c) A comparison of measured Mine-related aquatic effects to predictions made during the Water License Application and an evaluation of any differences and lessons learned; d) A plain language summary of the major results of the above analyses and a plain language interpretation of the significance of those results; e) Recommendations, with rationale, for changes to Action Levels; f) Recommendations, with rationale, for changes to any aspect of the Conceptual AEMP Design Plan; and g) Any other information required as requested by the Board. 5. The AEMP Response Plan referred to in Part H, Items 8 and 9 shall contain the

  53. following information for each parameter that has been reported in the AEMP Annual Report to have exceeded an Action Level: a) A description of the parameter, its relation to Significance Thresholds and the ecological implication of the Action Level exceedance; b) A summary of how the Action Level exceedance was determined and confirmed; c) A description of likely causes of the Action Level exceedance and potential mitigation options if appropriate; d) A description of actions to be taken by the Licensee in response to the 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. e) Any other information necessary to assess the response to an Action Level exceedance or that has been requested by the Board.

  54. 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 A. Surveillance Network Program Description and Monitoring Requirements 1. The location of sampling sites and specific monitoring requirements are as follows: Surveillance Network Program (SNP) 0040-1: (active): Treated effluent from the Tailings Containment Area Description: UTM 11V (NAD 83) 635414.00E, 6924774.00N Location: 24-hour composite Once per month Once per year Monthly during Sampling Frequency: sample during during periods of during periods discharge for effluent discharge to effluent discharge of effluent the purpose of the Meg-Keg-Peg to the Meg- discharge to the performing a Lakes System. If the Keg-Peg Lakes Meg- Keg-Peg static “pass/fail” twenty-four System. Lakes System. bioassay for (24) hour sampler both rainbow failsWeekly during trout and periods of effluent Daphnia spp. discharge to the Meg- (per Keg- Peg Lakes Environment system, grab samples Canada’s shall be collected Environmental Sampling pH, Total Dissolved Metals 3 Water Temperature Ammonia,Metals 3 + Dissolved Parameters: Total Ammonia + Total Mercury, Mercury Total Suspended Arsenic (Total and Sulphide Solids, Dissolved), BTEX 4 Total Arsenic, Alkalinity, Total Copper, Major Ions 1 Total Nickel Nutrients 2 Total Lead Total Petroleum Total Zinc Hydrocarbons, Total Cyanide Nitrite and Nitrate, Chloride Total Phosphorous,

  55. 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 Once per month Once per year during Twice each year at Spring Sampling during periods of periods of open Water break-up and before Frequency: open Water , freeze-up in the Fall pH, Dissolved Metals 3 Performing a static “pass/fail” Sampling Total Ammonia, Total Parameters: Total + Dissolved bioassay for both rainbow Cyanide, Total Mercury trout and Daphnia spp. (per Dissolved Solids, Nutrients 2 Environment Canada’s Alkalinity, BTEX4 Environmental Protection Nitrate Series Biological Test Total Petroleum MethodsFor the purpose of Hydrocarbons, Nitrate performing a and Nitrite, Mercury, multi-concentration acute Surveillance Network Program (SNP) 0040-6: (activeinactive) Taylor Road Dam pumping station Description: 635125.00E, 6926037.00N Location: MV2007L8-0025 - Miramar Con Mine Page 17 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  56. Sampling Weekly during periods of flow. Frequency: 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 pH Sampling Total Arsenic , Parameters: Total Copper , Total Cyanide , pH MV2007L8-0025 - Miramar Con Mine Page 18 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  57. Surveillance Network Program (SNP) 0040-9: (active) Drainage pathway between Lower Pud basin and Kam Lake. Description: 634647.00E, 6924444.00N Location: Twice monthly Monthly during periods of flow Sampling Frequency: Sampling pH , Total Suspended Solids , Total Arsenic, Total Copper, Parameters: Total Cyanide Total Metals 3 Surveillance Network Program 0040-10: (active) Drainage from Lower Pud basin before it enters Meg Lake. Description: 635228.00E, 6923536.00N Location: Once per month during periods of open Once per year during periods of open Sampling Water Water Frequency: Sampling pH , Dissolved Metals 3 Conductivity Total and Dissolved Mercury Parameters: Total Ammonia , Total Cyanide, Total Nutrients 2 BTEX4 Dissolved Solids, Alkalinity, Nitrate Total Petroleum Hydrocarbons , Nitrate and Nitrite, Mercury, Arsenic (Total and Dissolved), Conductivity, Total Kjeldahl Surveillance Network Program 0040-12: (active) Description: South end of Rat Lake. Location: 635950.00E, 6926351.00N Sampling and Once per month during periods of open Once per year during periods of open water Water Analysis Sampling pH Dissolved Metals 3 Total Arsenic , pH Parameters: Surveillance Network Program (SNP) Station 0025-7: (active) Surface water sampling station in Kam Lake immediately downstream of 0040-9 Description: Location: Once per month during periods of open Once per year during periods of open Sampling Frequency: water Water pH Dissolved Metals 3 Sampling Field Temperature , pH, Parameters: Total Cyanide Total Suspended Solids , Total Arsenic, Total Copper, Total MV2007L8-0025 - Miramar Con Mine Page 19 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  58. 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 Monthly during discharge at SNP 40-1 Frequency: pH , Sampling Parameters: Total Suspended Solids , Total Arsenic , Total Copper , Total Cyanide Surveillance Network Program 0025-9: (active) Surface water sampling station between Middle Pud TCA and 0025-5 at the Description: Lease Boundary. Location: 634802.00E, 6924468.00N Twice monthly Monthly during discharge at SNP 40-1 flow Sampling Frequency: Sampling pH , Parameters: Total Suspended Solids , Total Arsenic, Total Copper, Total Cyanide Total Metals 3 Surveillance Network Program 0025-10: (active) Surface water sampling station at the lease boundary north of the Upper Pud TCA in Description: the vicinity where the Taylor Road engineered drainage channel is to be engineered. In proximity to 0040-6. Exact location TBD once channel is installed. 634506E, Location: Post installation of the Taylor Road Once per year during periods of flow Sampling Frequency: Sewer/Engineered Drainage Sampling pH Total Cyanide Total Arsenic, Total Copper, Total Parameters: 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: MV2007L8-0025 - Miramar Con Mine Page 20 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  59. Surveillance Network Program 0025-12: (active) Minewater sampling station at Robertson Shaft. Description: Location: Quarterly once minewater levels reach the 150 metre level Twice a year when no Sampling Frequency: dewatering is occurring, monthly during active dewatering Total Ammonia, Mercury, Arsenic (Total and Dissolved), pH Sampling Parameters: 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) Minewater sampling station at C-1 Shaft. Description: Location: Sampling Quarterly once minewater levels reach the 150 metre level Twice a year when no Frequency: dewatering is occurring, monthly during active dewatering Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), pH Parameters: 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: Quarterly once minewater levels reach the 150 metre level Twice a year when no Sampling Frequency: dewatering is occurring, monthly during active dewatering Total Ammonia, Mercury, Arsenic (Total and Dissolved), pH Sampling Parameters: 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 MV2007L8-0025 - Miramar Con Mine Page 21 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  60. Surveillance Network Program 0025-15: (active) Minewater sampling station at 204Q Stope. Description: Location: Sampling Quarterly once minewater levels reach the 150 140 metre Annually Frequency: level and only if seepage is observed Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Turbidity, TSS, pH, Parameters: pH conductivity, major Conductivity, ions 1 , nutrients 2 , Turbidity, CCMS scan 3 (total and Total Kjeldahl Nitrogen, Total Phosphorous, Suspended dissolved), total Solids mercury, total arsenic, Total Cyanide, Total Dissolved Solids, Alkalinity, Total Petroleum Hydrocarbons, Nitrite and Nitrate, pH ICP Metals Scan including but not limited to the 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. 634672.60E, 6925010.00N Location: Monthly Twice a year during periods of groundwater flow Sampling Frequency: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 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). 636123.30E, 6925723.00N Location: Monthly Twice a year during periods of groundwater flow and only if there is sufficient Sampling Frequency: water present to purge the well prior to sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 ICP Metals Scan including but not limited to the following Total and Dissolved MV2007L8-0025 - Miramar Con Mine Page 22 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  61. 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 636456.20E, 6925952.00N Location: Sampling Monthly Twice a year during periods of groundwater flow Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 ICP Metals Scan including but not limited to the following Total and Surveillance Network Program (SNP) Station 0025-19: (active) Groundwater monitoring well to be located downslope from the Dam 2/Dam2 Description: North Location: 634717.90E, 6924948.00N Monthly Twice a year during periods of groundwater flow Sampling Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 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. 635827.00E, 6926163.00N Location: Monthly Twice a year during periods of groundwater flow and only if there is sufficient Sampling Frequency: water present to purge the well prior to sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 ICP Metals Scan including but not limited to the following Total and Surveillance Network Program (SNP) Station 0025-21: (active) Groundwater monitoring well located south of Rat Lake and inside the main mine Description: lease. (Formerly known as MW04-02). MV2007L8-0025 - Miramar Con Mine Page 23 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  62. 635946.00E, 6926121.00N Location: Monthly Twice a year during periods of groundwater flow and only if there is sufficient Sampling Frequency: water present to purge the well prior to sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 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). 636020.00E, 6925736.00N Location: Monthly Twice a year during periods of groundwater flow and only if there is Sampling Frequency: sufficient water present to purge the well prior to sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 Surveillance Network Program (SNP) Station 0025-23: (active) Groundwater monitoring well located in the Negus pond area. (Formerly known as Description: MW04-04). Location: 636221.00E, 6925604.00N Monthly Twice a year during periods of groundwater flow Sampling Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 MV2007L8-0025 - Miramar Con Mine Page 24 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  63. Surveillance Network Program (SNP) Station 0025-24: (active) Groundwater monitoring well located in the Negus pond area. (Formerly known as Description: MW04-05). Location: 636229.00E, 6925500.00N Sampling Monthly Twice a year during periods of groundwater flow Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 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 Monthly Twice a year during periods of groundwater flow Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Parameters: Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 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 Monthly during periods of groundwater flow Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Parameters: Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 MV2007L8-0025 - Miramar Con Mine Page 25 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  64. Surveillance Network Program (SNP) Station 0025-27: (active) Groundwater monitoring well. (Formerly known as MW05-08). Description: 636450.00E, 6925952.00N Location: Monthly Twice a year during periods of groundwater flow Sampling Frequency: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 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 Monthly during periods of groundwater flow Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Parameters: Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-29: (active) Groundwater monitoring well. (Formerly known as MW05-10). Description: 635866.00E, 6925738.00N Location: Sampling Monthly Twice a year during periods of groundwater flow and only if there is sufficient water present to purge the well prior to sampling Frequency: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 MV2007L8-0025 - Miramar Con Mine Page 26 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  65. Surveillance Network Program (SNP) Station 0025-30: (active) Groundwater well Description: 635120.30E, 6926031.00N Location: Monthly Twice a year during periods of groundwater flow Sampling Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Parameters: Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 Surveillance Network Program (SNP) Station 0025-31: (active) Description: Groundwater well Location: 635071.10E, 6924609.00N Sampling Monthly Twice a year during periods of groundwater flow Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Parameters: Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 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 Monthly Twice a year during periods of groundwater flow Frequency: Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Parameters: Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 ICP Metals Scan including but not limited to the following Total and Dissolved MV2007L8-0025 - Miramar Con Mine Page 27 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  66. Surveillance Network Program (SNP) Station 0025-33: (active) Description: Groundwater well Location: 635941.20E, 6925634.00N Monthly Twice a year during periods of groundwater flow and only if there is sufficient Sampling Frequency: water present to purge the well prior to sampling Sampling Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-34: (active) Groundwater well Description: 635871.00E, 6925742.00N Location: Monthly Twice a year during periods of groundwater flow Sampling Frequency: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 ICP Metals Scan including but not limited to the following Total and Dissolved Surveillance Network Program (SNP) Station 0025-35: (active) Groundwater well Description: 635947.80E, 6926113.00N Location: Monthly Twice a year during periods of groundwater flow Sampling Frequency: Total Ammonia, Mercury, Arsenic (Total and Dissolved), Alkalinity, Total Sampling Parameters: Petroleum Hydrocarbons, Total Kjeldahl Nitrogen, Total Phosphorous, Total Cyanide, Conductivity, pH Conductivity Turbidity , BTEX 4 MV2007L8-0025 - Miramar Con Mine Page 28 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  67. 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 634658E, 6925006N Location: Twice a year during periods of groundwater flow Sampling Frequency: pH Sampling Conductivity Parameters: Turbidity Total Cyanide Dissolved Metals 3 Nutrients 2 Major Ions 1 Surveillance Network Program (SNP) Station TBD: (active) Middle Pud Description: 635127.4E, 6924914N Location: Annually during freshet and monthly during treatment Sampling Frequency: pH Sampling Conductivity Parameters: Total Cyanide Total Metals 3 + Total Mercury Major Ions 1 Nutrients 2 Total Petroleum Hydrocarbons Surveillance Network Program (SNP) Station TBD: (inactive) Groundwater well to be located northwest of Middle Pud Tailings Containment Area Description: 634812.5E, 6925313N or alternate suitable location to be determined. Updated Location: coordinates will be provided once installation is complete. Twice a year during periods of groundwater flow Sampling Frequency: Sampling pH Conductivity Parameters: Turbidity Total Cyanide Dissolved Metals 3 Nutrients 2 Major Ions 1 MV2007L8-0025 - Miramar Con Mine Page 29 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  68. Surveillance Network Program (SNP) Station TBD: (inactive) Groundwater well to be located south of Lower Pud Tailings Containment Area Description: 635359.8E, 6924012N Location: or alternate suitable location to be determined. Updated coordinates will be provided once installation is complete. Twice a year during periods of groundwater flow Sampling Frequency: Sampling pH Conductivity Parameters: Turbidity Total Cyanide Dissolved Metals 3 Nutrients 2 Major Ions 1 Surveillance Network Program (SNP) Station TBD: (inactive) Groundwater well to be located east of Crank Lake Tailings Containment Area Description: Location: 636211.2E, 6925813N or alternate suitable location to be determined. Updated coordinates will be provided once installation is complete. Twice a year during periods of groundwater flow Sampling Frequency: pH Sampling Conductivity Parameters: Turbidity Total Cyanide Dissolved Metals 3 Nutrients 2 Major Ions 1 Surveillance Network Program (SNP) Station TBD: (inactive) Groundwater well to be located southeast of SNP 0025-18 Description: 636564.7E, 6925732N or alternate suitable location to be determined. Updated Location: coordinates will be provided once installation is complete. Twice a year during periods of groundwater flow Sampling Frequency: MV2007L8-0025 - Miramar Con Mine Page 30 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  69. Sampling pH Parameters: Conductivity Turbidity Total Cyanide Dissolved Metals 3 Nutrients 2 Major Ions 1 Surveillance Network Program (SNP) Station TBD: (inactive) Groundwater well for reference monitoring - location to be determined Description: Location: 636209.7E, 6926512N, 635485.5E, 6926301N or alternate suitable location to be determined. Updated coordinates will be provided once installation is complete. Sampling Twice a year during periods of groundwater flow Frequency: Sampling pH Parameters: Conductivity Turbidity Total Cyanide Dissolved Metals 3 Nutrients 2 Major Ions 1 Surveillance Network Program (SNP) Station SWMP-1: (active) Description: Surface water in engineered channel Upper Pud Location: 635251E, 6925257N Sampling Annually during freshet Frequency: Sampling pH Total Arsenic and Field Conductivity Parameters: Surveillance Network Program (SNP) Station SWMP-2: (active) Surface water in engineered channel Upstream Hazardous Waste Disposal Site Description: 635735E, 6925652N Location: Annually during freshet Sampling Frequency: pH Sampling Total Arsenic and Field Conductivity Parameters: Water Temperature Surveillance Network Program (SNP) Station SWMP-9: (active) Surface water in engineered channel Negus Pond/Blend Plant Description: Location: 636052E, 6925322N Annually during freshet Sampling Frequency: MV2007L8-0025 - Miramar Con Mine Page 31 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  70. Sampling pH Parameters: Total Arsenic and Field Conductivity Water Temperature MV2007L8-0025 - Miramar Con Mine Page 32 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  71. Surveillance Network Program (SNP) Station SWMP-10: (active) Description: Surface water in engineered channel Crank Lake South Location: 635917E, 6925390N Sampling Annually during freshet Frequency: Sampling pH Total Arsenic and Field Conductivity Parameters: Surveillance Network Program (SNP) Station SWMP-11: (active) Surface water in engineered channel Lower Pud Description: 635387E, 6924702N Location: Sampling Annually during freshet Frequency: pH Sampling Parameters: Total Arsenic and Field Conductivity Water Temperature Surveillance Network Program (SNP) Station SWMP-12: (active) Surface water in engineered channel Crank Lake East Description: Location: 636410E, 6925359N Annually during freshet Sampling Frequency: Sampling pH Total Arsenic and Field Conductivity Parameters: Water Temperature Surveillance Network Program (SNP) Station SWMP-13: (active) Description: Surface water in engineered channel Negus Tailings Containment Area Location: 636193E, 6925064N Sampling Annually during freshet Frequency: Sampling pH Total Arsenic and Field Conductivity Parameters: Surveillance Network Program (SNP) Station SWMP-14: (active) Description: Surface water in engineered channel Neil Lake Tailings Containment Area Location: 635543E, 6924699N Sampling Annually during freshet Frequency: Sampling pH Total Arsenic and Field Conductivity Parameters: Water Temperature MV2007L8-0025 - Miramar Con Mine Page 33 of 24 Current to: May 10, 2018 29603.119892.MTK.15624284.1

  72. Surveillance Network Program (SNP) Station SWMP-16: (active) Surface water in engineered channel downstream Hazardous Waste Disposal Site Description: 635576E, 6925307N Location: Annually during freshet Sampling Frequency: pH Sampling Total Arsenic and Field Conductivity Parameters: Water Temperature Surveillance Network Program (SNP) Station SWMP-17: (active) Description: Surface water in Garden Draw Location: 636661E, 6925830N Sampling Annually during freshet Frequency: Sampling pH Total Arsenic and Field Conductivity Parameters: Water Temperature 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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.

  73. 2. The location of sampling sites is subject to approval of the Inspector. 3. More frequent sample collection may be required at the request of an Inspector. 4. All sampling, sample preservation, and analyses shall be conducted in accordance with 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. 5. All analyses shall be performed in a laboratory accredited by the Canadian Association for 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. 6. 7. The Licensee shall annually review the approved QA/QC Plan and modify the Plan as necessary. Proposed modifications shall be submitted to an Analyst for approval. 7. 8. The QA/QC Plan referred to in SNP Section A, Item 7 shall be implemented as approved by an Analyst. 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), Chloride (Cl), Alkalinity, Hardness, Sulphate (SO 4 ), Sodium (Na), Potassium 2- (K), Total Dissolved Solids (TDS). 2 Nutrients shall include the following parameters: Ammonia (NH 3 ), Nitrite (NO 3 -N), Nitrate (NO 2 - N), Total Kjeldahl Nitrogen (TKN), total Phosphorus (P), dissolved Phosphorous 3- (P), Orthophosphate (PO 4 ), 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. 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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.

  74. 4 BTEX shall include the following parameters: Benzene, Toluene, Ethylene, Xylene B. Flow and Volume Measurements 1. All flow and volume measurements shall be measured and recorded continuously (i.e. using electronic data storage chips or equivalent) during periods of flow or pumping and reported on a monthly basis in cubic metres: a. The monthly and annual quantities of water pumped from Surveillance Network Program Station Numbers 0025-12, 0025-13, 0025-14, 0025-15 shall be measured and recorded in cubic metres; b. The daily quantity of treated effluent discharged from the Tailings 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. C. Other Monitoring Requirements 1. The periods when effluent from the Water Treatment Plant is re-circulated to the 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. D. Reporting Requirements 1. The Licensee shall, within thirty (30) days following the month being reported, 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. 2. The Licensee shall submit a scaled map of all SNP stations, including UTM Coordinates, sixty (60) days after the issuance of the Licence and when revisions 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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.

  75. are made to the surveillance network stations. Mackenzie Valley Land and Water Board Mavis Cli-Michaud, Chair Amanda Gauthier, Witness 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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.

  76. 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 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 Distribution List 3 3.1.1 3.2 MVRMA Part 3 and 4 and Waters Act : Land and Water Regulation 4 General 4 3.2.1 Public Notice 4 3.2.2 Water Use Fees 5 3.2.3 Existing Licences 5 3.2.4 Compensation to Existing Water Uses 5 3.2.5 Water Quality Standards 5 3.2.6 Effluent Quality Standards 5 3.2.7 Financial Responsibility 5 3.2.8 Minimization of Adverse Effects 5 3.2.9 Time Limit 6 3.2.10 Length of Licence Term 6 3.2.11 3.3 MVRMA Part 5 6 Preliminary Screening 6 3.3.1 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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

  77. 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 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 of 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 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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

  78. criteria. On March 15, 2018, the Board approved Work Plan, Version 3 1 , 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 of 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. 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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

  79. 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 organizations; Renewable Resource Boards; heritage regulators; and other interested parties. Table 1 below identifies the Distribution List that the Board used for this regulatory process. 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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

  80. 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 Government of Canada Athabasca Denesuline Council – Prince Albert 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 Salt River First Nations General Public – Kevin O-Reilly Smith Landing First Nation General Public – Steve Robertson 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 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 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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

  81. 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 other 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 of 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 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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

  82. 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 or 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 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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

  83. Preliminary Screening 3.3.1 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: The comments, recommendations, and concerns that arose during the regulatory 1) processes; The evidence and submissions from Reviewers 2) 3 See MVLWB Preliminary Screening and Reasons for Decision, dated September 20, 2007. 1 Major Ions shall include the following parameters: Magnesium (Mg), Fluoride (F), Calcium (Ca), 2- 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 3- 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

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