GIANT MINE REMEDIATION PROJECT - Spill Contingency Plan Version 2.1 - March 2021

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GIANT MINE REMEDIATION PROJECT - Spill Contingency Plan Version 2.1 - March 2021
GIANT MINE REMEDIATION PROJECT

             Spill Contingency Plan

                    Version 2.1

March 2021

                 376-Management Plans-74-RPT-0004_Rev2_20210325 (Spill CP Rev 2.1)
GIANT MINE REMEDIATION PROJECT - Spill Contingency Plan Version 2.1 - March 2021
Spill Contingency Plan

LAND ACKNOWLEDGMENT
The Giant Mine Remediation Project acknowledges the Indigenous Peoples and the importance of the land in and
around the Giant Mine Site, which is located in Chief Drygeese Territory. From time immemorial, it has been and
is the traditional land of the Yellowknives Dene First Nation. We acknowledge that the Giant Mine site is also within
the homeland of the North Slave Métis Alliance and the Tłichǫ Mǫwhì Gogha Dè Nı̨ ı̨ tłèè boundary. The Giant Mine
Remediation Project respects the histories, languages, and cultures of First Nations, Métis, Inuit, and all First
Peoples of Canada, whose presence continues to enrich our vibrant community.

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GIANT MINE REMEDIATION PROJECT - Spill Contingency Plan Version 2.1 - March 2021
Spill Contingency Plan

PLAIN LANGUAGE SUMMARY
This is a Giant Mine Remediation Project (GMRP or the Project) Spill Contingency Plan that explains how spills
are managed on Site. The focus of this version of the Spill Contingency Plan (the Plan) is on the care and
maintenance and remediation activities that will take place at the site. This Plan will be updated as necessary as
remediation progresses.

This Spill Contingency Plan has been developed to meet spill contingency plan guidelines, and applicable Water
Licence and Land Use Permit conditions. The approach of the Spill Contingency Plan is to promote safe
handling of hazardous materials to help prevent spills and provide a response system that can be implemented
quickly in case of a spill. This Plan identifies potential sources of spills during remediation and the best ways to
manage spills that may occur. The Plan also provides the roles and responsibilities of staff on-site, spill reporting
protocols, and training provided for staff.

This Plan gives the Site personnel guidance on how to contain spills depending on size (small or large) and
location of spills (e.g., on open water, ice, snow, or land). It provides spill containment procedures to minimize
the extent of contamination following a spill. For spills, the priority is to minimize any direct threat to human
health or the natural environment.

In accordance with the Annual Water Licence reporting requirements, the GMRP will submit a summary of
activities conducted in accordance with the Spill Contingency Plan during the previous calendar year. The
GMRP will conduct an annual review of this Plan and make any revisions necessary to reflect changes in
operations, contact information, or other details.

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GIANT MINE REMEDIATION PROJECT - Spill Contingency Plan Version 2.1 - March 2021
Spill Contingency Plan

VERSION HISTORY
             Date Issued/
Version                                                        Description of Version
            Effective Date
  1.0     April 1, 2019       Submitted with Water Licence Application to Mackenzie Valley Land and Water Board
                            Submitted to the Mackenzie Valley Land and Water Board as per Water Licence
                            MV2007L8-0031, Part H, Condition 1. Changes to this Plan include an update to address
  2.0     December 16, 2020
                            the Board Directives included in the Water Licence, commitments made during the water
                            licencing process and for consistency in format with other site wide management plans.
                              Submitted to the MVLWB to address MVLWB direction dated February 12, 2021. A
  2.1     March 25, 2021
                              summary of changes was appended to the cover letter submitted with this version.

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Spill Contingency Plan

                                                             TABLE OF CONTENTS
1       INTRODUCTION ...........................................................................................................................................1-1
    1.1        Plan Objectives and Linkages.........................................................................................................1-1
    1.2        Project Team ...................................................................................................................................1-6
    1.3        Environment, Health and Safety, and Community Policy ...............................................................1-7
    1.4        Regulatory Framework ....................................................................................................................1-7
    1.5        Engagement ....................................................................................................................................1-9
    1.6        Traditional and Community Knowledge ..........................................................................................1-9
    1.7        Project Activities Relevant to the Plan ............................................................................................1-9
    1.8        Training and Personnel Safety........................................................................................................1-9
2       HAZARDOUS MATERIALS MANAGEMENT.............................................................................................2-1
    2.1    Handling Hazardous Materials ........................................................................................................2-1
    2.2    Hazardous Materials Inventory .......................................................................................................2-1
    2.2.1    Oils and Greases .......................................................................................................................2-2
    2.2.2    Fuels (Diesel and Gasoline) ......................................................................................................2-2
    2.2.3    Propane .....................................................................................................................................2-2
    2.2.4    Reagents....................................................................................................................................2-3
    2.2.5    Solvents .....................................................................................................................................2-3
    2.2.6    Sewage and Greywater .............................................................................................................2-3
    2.2.7    Arsenic Impacted Wastes ..........................................................................................................2-3
    2.2.8    Explosives ..................................................................................................................................2-4
    2.2.9    Co-Polymers ..............................................................................................................................2-4
    2.2.10   Chemical (Dynalene HC, Carbon Dioxide (CO2) and Nitrogen) ...............................................2-4
3       SPILLS MANAGEMENT ..............................................................................................................................3-1
    3.1        Roles and Responsibilities ..............................................................................................................3-1
    3.1.1         First Responder .........................................................................................................................3-2
    3.1.2         Mine Manager and/or Incident Commander (or designate).......................................................3-2
    3.1.3         Emergency Management Team ................................................................................................3-3
    3.1.4         Environmental Manager (or their designate) .............................................................................3-3
    3.1.5         Technical Specialists .................................................................................................................3-4
    3.2        Spill Resources ...............................................................................................................................3-5
    3.2.1         Access to the Plan .....................................................................................................................3-5
    3.2.2         On-Site Communication.............................................................................................................3-5
    3.2.3         Spill Kits and Personal Protective Equipment ...........................................................................3-5
    3.2.4         Spill Kit Contents .......................................................................................................................3-5
    3.2.5         Spill Kit Locations ......................................................................................................................3-6
    3.2.6         Spill Equipment Inventory ..........................................................................................................3-9
    3.2.7         Off-site Spill Response Resources ............................................................................................3-9
    3.3        Spill Response Procedures...........................................................................................................3-10
    3.3.1         Incident Action Plans ...............................................................................................................3-11
    3.3.2         Continued Action Until Help Arrives ........................................................................................3-11
    3.4        Spill Containment Measures .........................................................................................................3-12

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     3.4.1          Containment on Open Water ...................................................................................................3-13
     3.4.2          Containment on Ice ..................................................................................................................3-13
     3.4.3          Containment on Snow .............................................................................................................3-13
     3.4.4          Containment on Land ..............................................................................................................3-14
     3.4.5          Fire or Explosion Hazard .........................................................................................................3-14
     3.4.6          Disposal of Contaminated Materials ........................................................................................3-14
4       PREVENTION OF SYSTEM FAILURE .......................................................................................................4-1
     4.1        Monitoring .......................................................................................................................................4-1
     4.1.1        Minewater Pipeline Monitoring...................................................................................................4-1
     4.1.2        Tailings Dam Structural Monitoring ...........................................................................................4-1
     4.1.3        Petroleum Products Monitoring .................................................................................................4-2
     4.1.4        Propane Tank Inspection ...........................................................................................................4-3
     4.1.5        Arsenic Trioxide Storage ...........................................................................................................4-3
5       REPORTING AND PLAN REVIEW .............................................................................................................5-1
     5.1.1          Emergency Spill Reporting ........................................................................................................5-1
     5.1.2          Annual Reporting .......................................................................................................................5-2
     5.1.3          Plan Review ...............................................................................................................................5-2
6       REFERENCES ..............................................................................................................................................6-1

LIST OF TABLES
Table 1.2-1:               Giant Mine Remediation Project Site Contacts...................................................................1-6
Table 1.4-1:               Relevant Spill Contingency Legislation and Guidelines .....................................................1-8
Table 2.2-1:               Hazardous Materials Storage Volumes ..............................................................................2-2
Table 3.2-1:               Spill Kit Locations at Giant Mine Site ..................................................................................3-6
Table 3.2-2:               Spill Kit in Trucks at Giant Mine Site ...................................................................................3-7
Table 3.2-3:               Spill Containment Equipment Inventory ..............................................................................3-9

LIST OF FIGURES
Figure 1.1-1:              Giant Mine Site Layout ........................................................................................................1-2
Figure 1.1-2:              Linkages Between Management and Monitoring Plans for Giant Mine ..............................1-4
Figure 1.1-3:              Linkages Between Environmental Management and Monitoring Plans, Construction
                           and Design Plans for Giant Mine ........................................................................................1-5
Figure 3.2-1:              Locations of Spill Resources on Site ..................................................................................3-8

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LIST OF APPENDICES
APPENDIX A     Conformity Table
APPENDIX B     Government of The Northwest Territories - Reportable Spill Quantities
APPENDIX C     List of Approved Chemicals and Safety Data Sheets
APPENDIX D     Incident Action Plans
APPENDIX E     Government of the Northwest Territories - Spill Response Form
APPENDIX F     Emergency Response Communications Flowchart
APPENDIX G     Emergency Response Communications Flowchart Locations

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TABLE OF ACRONYM DEFINITIONS
       Acronym                                              Definition
CALA             Canadian Association of Laboratory Accreditation
CIRNAC           Crown-Indigenous Relations and Northern Affairs Canada
CRP              Closure and Reclamation Plan
E2               ECCC Environmental Emergencies Regulations
ECCC             Environment and Climate Change Canada
EHSC             Environment, Health & Safety, and Community
EMT              Emergency Management Team
ENR              Environment and Natural Resources
EPA              Environmental Protection Act
ETP              Effluent Treatment Plant
FOS              Freeze Optimization Study
GMRP             Giant Mine Remediation Project
GN               Government of Nunavut
GNWT             Government of the Northwest Territories
ICS              Incident Command System
ICT              Incident Command Team
INAC             Indigenous and Northern Affairs Canada
MCM              Main Construction Manager
MEG              Mobile Equipment Garage
MMP              Management and Monitoring Plan
MSA              Materials Storage Area
MVLWB            Mackenzie Valley Land and Water Board
PCB              Polychlorinated Biphynels
PPE              Personal Protective Equipment
PSHEP            Project Safety, Health, and Environment Plan
PSPC             Public Services and Procurement Canada
SDS              Safety Data Sheet(s)
SOP              Standard Operating Procedure
TCA              Tailing Containment Areas
TDG              Transportation of Dangerous Goods
TDGR             Transport of Dangerous Goods Regulations
the Project      Giant Mine Remediation Project
the Site         Giant Mine
WHMIS            Workplace Hazardous Materials Information System

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Spill Contingency Plan

1       INTRODUCTION
The Giant Mine (Site) is located within the City of Yellowknife boundary, approximately 1.5 kilometres (km) from
the community of Ndilǫ and 9 km from the community of Dettah. The Site is situated on Commissioner’s Land
administered by the Government of the Northwest Territories (GNWT); Reserves (R622T and 85 J/8-257-2)
have been established to allow for the implementation of the remediation of the Site. Ongoing care, maintenance
and remediation of the Site is known as the Giant Mine Remediation Project (GMRP or the Project). Subsurface
mineral rights are under federal jurisdiction and were withdrawn by Order in Council SI/2005-55 on 15 June
2005. For a history of the Giant Mine and planned remediation activities, please refer to the Closure and
Reclamation Plan (CRP).

The Site consists of eight abandoned open pits; an underground mine with arsenic trioxide storage areas;
Tailings Containment Areas (TCAs) with associated rock fill dams; mine waste rock that buttresses Dams 11,
21B and 21D; a tailings re-treatment plant (out of service since 1990); an Effluent Treatment Plant (ETP); a Mill
Complex; several warehouses; and a townsite. Baker Creek flows through the Site seasonally with one ponded
area. The Site features are outlined in Figure 1.1-1.

1.1      Plan Objectives and Linkages
Plan Objective
This Spill Contingency Plan (the Plan) addresses protocol for safe handling of hazardous materials and wastes,
and emergency response measures to be implemented in the case of a spill during existing conditions, during
active remediation of the Site, and moving into post-closure monitoring of the GMRP. In addition, the Plan also
provides the roles and responsibilities of staff on-site, communication protocols, and training provided for staff
responsible for enacting the Plan. This Plan is to be used by all personnel at the Site. This plan is intended to
provide guidance on spills of all sizes.

The objectives of this Plan are to present proactive and safe strategies for handling hazardous materials and to
provide easily understood and reasonably comprehensive information to deal with a spill, while minimizing health
and safety hazards, environmental damage, and clean-up costs. This Plan is designed to:

a) promote safe handling of hazardous materials and help to minimize the occurrence of spill incidents

b) outline a formal, practical response system that can be implemented rapidly in the event of a spill of materials
   resulting from activities performed at the Site that may be hazardous to human health or the environment

This Spill Contingency Plan has been developed to satisfy the spill contingency plan guidelines, and applicable
conditions set forth in Water Licence MV2007L8-0031 (Appendix A) and Land Use Permit MV2019X0007.
Updates to the Spill Contingency Plan will be ongoing through the life of the GMRP to provide more details on
future management, as remediation moves forward.

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                                                                                                                                                                                          STORAGE
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      LEGEND
               BUILDING

               GIANT MINE PROJECT BOUNDARY

               HIGHWAY
               INDUSTRIAL WATERCOURSE                                                                                    0                                500                              1,000                      REFERENCE(S)
               INFRASTRUCTURE                                                                                                                                                                                         HYDROLOGY AND TRANSPORTATION DATA OBTAINED FROM GEOGRATIS, © DEPARTMENT OF
                                                                                                                                                                                                                      NATURAL RESOURCES CANADA. 2018 ORTHOPHOTO PROVIDED BY AECOM.
               ROAD                                                                                                      1:20,000                                                       METRES                        DATUM: NAD 83 PROJECTION: UTM ZONE 11
               SPLITTER DYKE                                                                    PROPONENT                                                                                                             PROJECT

               SURFACE WATER MANAGEMENT DAM/DYKE
                                                                                                                                                                                                                                                                                                                                                                                  25mm

               TAILINGS OR SLUDGE RETENTION DAM
               WATERCOURSE                                                                                                                                      YYYY-MM-DD                 2021-03-18                 TITLE

               INDUSTRIAL WATERBODY                                                                                                                             DESIGNED                   J. LACRAMPE
                                                                                                                                                                                                                      GIANT MINE SITE LAYOUT
               PIT BOUNDARY                                                                                                                                     PREPARED                   A. AUCOIN
               WATERBODY                                                                                                                                        REVIEWED                   T. HALL                    PROJECT NO.            CONTROL                    REV.               FIGURE
                                                                                                                                                                APPROVED                   T. HALL                    20137939               02-74-0599                 0                  1.1-1
                                                                                                                                                                                                                                                                                                                                                                                  0
Spill Contingency Plan

Linkage to Other Plans
There are other GMRP management and monitoring plans that are related to the Spill Contingency Plan
(Figure 1.1-2). An overview of site-wide monitoring during Active Remediation and Adaptive Management
(Phase 2) and during Post-Closure (Phase 3) is illustrated in Figure 1.1-3. The Spill Contingency Plan
specifically informs and is informed by:

•     Waste Management and Monitoring Plan

•     Water Management and Monitoring Plan

•     Surveillance Network Program

The environmental Management and Monitoring Plans (MMPs) for the GMRP have been developed to
complement each other while reducing repetition and overlap between plans. As a result, the environmental
MMPs are cross-referenced within other plans to indicate where more information can be found. The linkages
figures assist with the understanding of how these plans work together to manage and monitor site activities;
these are high-level figures representing overall relationships. Figure 1.1-2 is reflective of the current scope of
the plans (i.e., the first few years), but includes all major activities anticipated over the life of the Water Licence.
As such, the existing post-construction plans (Arsenic Trioxide Frozen Shell and Tailings MMPs) are identified in
the diagram which do not apply within the current scope but do provide an understanding of how they fit within
the project as a whole.

The Spill Contingency Plan also forms Appendix G of the overall GMRP - Emergency Management and
Response Plan maintained by the Main Construction Manager (MCM) for the site. The Emergency Management
and Response Plan is prepared to protect the public, workers, environment and property through emergency
prevention and prepared and coordinated response and recover in the event of an emergency. Other relevant
sections of the GMRP - Emergency Management and Response Plan that inform this Spill Contingency Plan
include:

•     Emergency Contact Information in Appendix A

•     Site-Specific Emergency Response Plan for Arsenic in Appendix E

•     Site-Specific Emergency Response Plan for Propane in Appendix F

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Figure 1.1-2:      Linkages Between Management and Monitoring Plans for Giant Mine

Note: there is also an operational maintenance surveillance (OMS) manual for the existing tailings containment area and dam management relevant to the Canadian Dam Association
guidelines; it is not for MVLWB approval but is available here for interested parties: https://giantminerp.ca/glance-giant-mine-remediation-project

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Figure 1.1-3:   Linkages Between Environmental Management and Monitoring Plans, Construction and Design Plans for Giant Mine

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Spill Contingency Plan

1.2       Project Team
The GMRP is led by Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) with the Government
of the Northwest Territories acting as co-proponents. Public Services and Procurement Canada (PSPC)
provides contracting services, contract management, and technical support services to CIRNAC. PSPC has
awarded the MCM contract to Parsons Incorporated. This contract will be used to complete implementation
activities for the GMRP. The MCM is responsible for overall Site management including emerging risks on Site
and supporting planning efforts for closure and reclamation.

For this Spill Contingency Plan, the MCM will be responsible for verifying required spill contingency controls are
in place and working properly. The MCM and their procured subcontractors will be required to adhere to the
details. The MCM will oversee the implementation of the CRP and associated activities. Refer to Table 1.2-1 for
staff responsible for management for the GMRP; refer to Appendix B of the GMRP – Emergency Management
and Response Plan, for the list of contacts in the event of an emergency or spill.

Table 1.2-1:      Giant Mine Remediation Project Site Contacts
   Company                Contact                         Role                                  Information
                                                                              Phone: 867-669-2823
                  Natalie Plato              Deputy Director
                                                                              Email: natalie.plato@canada.ca
                                                                              Phone: 867-444-9783
CIRNAC            Candace DeCoste            Regulatory Manager
                                                                              Email: candace.decoste@canada.ca
                                                                              Phone: 867-444-9400
                  Curtis Duffy               Senior Engineer
                                                                              Email: curtis.duffy@canada.ca
                                                                              Phone: 780-918-6277
PSPC              Brad Thompson              Senior Project Manager
                                                                              Email: brad.thompson@pwgsc-tpsgc.gc.ca
                                                                              Phone: 867-669-3715
                  Doug Hayes                 Mine Manager
                                                                              Email: doug.hayes@parsons.com
                                                                              Phone: 867-669-3725
Parsons           Norlito Cezar              Environment Manager
                                                                              Email: Norlito.cezar@parsons.com
                                             Senior Safety Specialist         Phone: 867-669-3719
                  Lex Lovatt
                                             Security                         Email: lex.lovatt@parsons.com
CIRNAC = Crown-Indigenous Relations and Northern Affairs Canada; PSPC = Public Services and Procurement Canada.

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1.3       Environment, Health and Safety, and Community Policy
Within the GMRP, the health and safety of employees and protection of the environment are an over-riding
priority. Management is committed to doing everything possible to prevent injuries and to maintain a healthy
environment.

The overall goals of the GMRP are:

•   minimize public and worker health and safety risks

•   minimize the release of contaminants from the Site into the environment

•   remediate the Site in a way that inspires public trust

•   implement an approach that is cost-effective and robust over the long term

In keeping with these overall goals for the Project, the specific objectives of this policy are:

•   protecting the environment and the health and safety of its employees, contractors, and the general public

•   engaging meaningfully with stakeholders and rights holders

•   recognizing the important contributions of Elders and community members, and incorporating Traditional
    Knowledge and community knowledge across the Project

•   delivering local social and economic benefits

•   recognizing the Project is an opportunity to advance reconciliation

•   continuing to look for opportunities to further reduce greenhouse gas emissions and ensure climate change
    adaptation is incorporated into the Project

•   being a recognized leader in Environment, Health & Safety, and Community (EHSC) management among
    public environmental remediation projects

The full GMRP EHSC Policy is available upon request.

1.4       Regulatory Framework
This plan was developed in consideration of regulatory requirements including legislation, guidance documents,
Water Licence requirements, and GMRP commitments and conditions. A full list of requirements/commitments
relevant to this plan can be found in Appendix A. Relevant federal and territorial legislation and permits/licences
that apply to the Site include:

•   Mackenzie Valley Resource Management Act (Government of Canada 1998)

•   Government of Northwest Territories Mine Health and Safety Act (GNWT 1994) and Regulations (GNWT
    2003)

•   Type A Water Licence (MV2007L8-0031)

•   Land Use Permit (MV2019X0007)

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Spill Contingency Plan

The following guidance/policy documents were used to support the Spill Contingency Plan:

•   Guidelines for Spill Contingency Planning developed by Indigenous and Northern Affairs Canada (INAC),
    April 2007 (INAC 2007)

•   GNWT Spill Contingency Planning and Reporting Regulation, March 2011 (GNWT 2011)

The GNWT regulates reporting requirements (based on reportable spill quantities, Appendix B) under the
Environmental Protection Act. The Mackenzie Valley Land and Water Board (MVLWB) further reinforces those
requirements through conditions placed in the Water Licence MV2007L8-0031 and Land Use Permit
(MV2019X0007).

Further, in adherence to the GMRP Environment, Health and Safety and Community Policy, GMRP will comply
with relevant federal and territorial legislation and guidelines when dealing with specific issues related to spill
management and the environment. A summary of Acts, regulations, and guidelines used to support this Spill
Contingency Plan are included in Table 1.4-1.

Table 1.4-1:    Relevant Spill Contingency Legislation and Guidelines
                  Acts and Regulations                                            Guidelines
• Waters Act (GNWT 2014)
• Fisheries Act (Government of Canada 1985)
• Migratory Birds Convention Act (Government of Canada
  1994)
• Transportation of Dangerous Goods Act (Government of
  Canada 1992)                                             • Northwest Territories-Nunavut Spills Working Agreement
• NWT Environmental Protection Act (GNWT 1988)               (Government of Canada, GNWT, Inuvialuit Land
• Canadian Environmental Protection Act (Government of       Administration, GN 2014)
  Canada 1999)                                             • Guidelines for Spill Contingency Planning (INAC 2007)
• Spill Contingency Planning and Reporting Regulations     • Guidelines for the Closure and Reclamation of Advanced
  R-068-93 (GNWT 2011)                                       Mineral Exploration and Mine Sites in the Northwest
• Used Oil and Waste Fuel Management Regulations             Territories prepared by the Mackenzie Valley Land and
  R-064-2003                                                 Water Board (November 2013)
• Canada Occupational Health and Safety Regulations        • Standard Outline for Management Plans (MVLWB 2013);
  (SOR/86-304)                                               and
• ECCC Environmental Emergencies Regulations (E2)          • Northern Contaminated Sites Program Environment,
  (SOR/2019-51; Government of Canada 2019)                   Health and Safety Policy draft (CIRNAC 2020).
• Metal and Diamond Mining Effluent Regulations
  (SOR/2002-222)
• Storage Tank Systems for Petroleum Products and Allied
  Petroleum Regulations (SOR/2008-197)
• Northwest Territories Safety Act (2015)

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1.5      Engagement
Version 1.0 of this Spill Contingency Plan was provided to the Mackenzie Valley Land and Water Board
(MVLWB) for review and feedback in 2019 and was given interim approval by the MVLWB on September 18,
2020. The GMRP has reached an agreement with City of Yellowknife to provide funding for specialized training
for the Yellowknife Fire Division in the event that they need to respond to an emergency situation at the Giant
Mine Site. Further details are included in Section 3.2.7. For further detail on the engagement that has occurred
for the GMRP please refer to the CRP and the Engagement Plan.

1.6      Traditional and Community Knowledge
The consideration of Traditional and Community Knowledge has been integrated into project planning and
activities through the consultation and engagement processes the GMRP undertakes with rights holders on
various project works. The GMRP Team is committed to continuing to incorporate Traditional and Community
Knowledge into the implementation strategy as part of site remediation. The GMRP does not have any specific
commitments relevant to the Spill Contingency Plan from the Traditional and Community Knowledge heard to
date but will continue to evaluate this throughout the life of the Project. The Engagement Plan, specifically
Appendix C, summarizes the Traditional and Community Knowledge provided to date.

1.7      Project Activities Relevant to the Plan
This Spill Contingency Plan is focused on activities including continued care and maintenance of the site,
demolition of old buildings, blasting, development of quarries, construction of the landfill, excavating
contaminated material, storage and management of surface water, surface remediation and clearing of
vegetation to support remediation. Remediation will take over ten years to complete. After that time, ‘adaptive
management’ will commence to determine if the completed activities are performing as designed. Once closure
activities are complete, the GMRP will enter the post-closure phase; it is understood that post-closure activities
are not in scope in this water licence.

1.8      Training and Personnel Safety
The effectiveness of this Spill Contingency Plan is dependent upon the training and knowledge of staff
implementing the Plan. All personnel will receive an orientation related to spill contingency and emergency
response on-site as part of the general safety orientation for employees and contractors. The GMRP - Project
Safety, Health and Environmental Plan, more specifically the GMRRP - Emergency Management and Response
Plan outline the training requirements including those specific to emergency response.

Specific to the Spill Contingency Plan, supervisors will review the Plan with each employee on site:

•   during the employee’s initial site orientation

•   following an employee’s absence from site of six months or more

•   when the employee’s responsibilities under the plan change

•   when the plan is updated

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2       HAZARDOUS MATERIALS MANAGEMENT
Heath, safety, and the prevention of spills are primary considerations when planning for the use, storage,
handling, transportation, and disposal of hazardous materials. Workplace Hazardous Materials Information
System (WHMIS) has been adopted for employee training and safe storage and handling of controlled products
at the Site. Storage, handling, and transportation procedures will comply with Transport of Dangerous Goods
Regulations (TDGR) and WHMIS.

Most of the chemical and petroleum-based products that will be present at the Site are those used in support of
remediation work; however, chemical and petroleum-based products used in past gold mining activities remain.
A hazardous waste inventory was completed in 2017 (AECOM 2018) and identifies the locations and nature of
the remaining hazardous products, which will be handled and disposed of according to the Waste Management
and Monitoring Plan (MMP). In addition to ‘consumable’ products, hazardous by-products of the historical mining
activities such as untreated minewater and tailings are present and addressed in the Water Management and
Monitoring Plan and the Operation, Maintenance, and Surveillance Manual.

2.1      Handling Hazardous Materials
Hazardous materials are classified according to TDGR and any future updates. Substances that fall under these
regulations will be labelled to inform personnel of their contents and to comply with governmental regulations.

There is a centralized Safety Data Sheets (SDS) binder located at the Safety Office C-Dry wicket, which
contains information on hazardous products used on Site. Access to information on chemicals is available
24-hours a day through the Security Officer on duty. SDS binders are also kept in the location of where the
hazardous material is stored, and at specific projects on an as-needed basis. The list of approved SDS
chemicals is included in Appendix C. The SDS binders are maintained by the Health and Safety Manager and
updated regularly. Additionally, contractors working at the site are required to submit copies of SDS documents
for hazardous materials required to support the remediation activities they are working on to the MCM Health
and Safety Manager prior to or accompanying shipments to the Site. SDS binders should be kept with this plan
in locations where the plan is available on site. This plan will be updated for chemicals added to the SDS binder
that are not covered by the procedures contained within this plan.

Site personnel will be trained on the use of Personal Protective Equipment (PPE) for all applicable tasks on-site.
PPE for workers is available from MCM managers.

2.2      Hazardous Materials Inventory
Chemicals and petroleum-based products are stored following applicable regulations, codes and best practices
(refer to the Waste MMP for additional storage details of the Waste Management Area and Hazardous Waste
Transfer Area), based on the product composition and WHMIS classification.

The most recent inventory of on-site chemicals and petroleum-based products is available in the Environmental
office on site. Additional details on the inventory can be found in the Waste MMP. The following sections outline
the hazardous materials that are currently stored at the Giant Mine site. Storage volumes of these materials are
provided in Table 2.2-1.

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Table 2.2-1:          Hazardous Materials Storage Volumes
               Item                       Maximum Storage Capacity                      Maximum Allowable Storage Volume
    Diesel1                                       100,000 L                                         80,000 L
    Gasoline                                        2,500 L                                          1,250 L
    Propane1                                      100,000 L                                         80,000 L
    Solvents                                         205 L                                            205 L
    Lime2                                     37.5 metric tonnes                                30 metric tonnes
    Magnafloc/Vanfloc3                             22,000 L                                         12,800 L
    Ferric Sulphate2                          131 metric tonnes                                126 metric tonnes
Notes:
1
    Based on the ECCC-registered tanks and propane tank and 80% fill capacity requirement.
2
    Based on the ETP 2011 Binder maximum inventory datasets. Ferric sulphate tank had 126 MT at 96% capacity.
3
  Based on the approximate tank dimension of 4.5 m height and 2.4 m diameter, with a maximum allowable level at 2.7 m. The maximum
(allowable) level is based on ETP 2011 Binder maximum inventory datasets.

2.2.1 Oils and Greases
Equipment used at the Site requires moderate amounts of hydraulic and lubricating oils and greases which are
delivered from local suppliers in drums, pails and cases. These products can be found in the warehouse, and in
the various shops around site. Oils and greases will be stored in secondary containment.

2.2.2 Fuels (Diesel and Gasoline)
Boilers and heavy equipment, as well as the majority of light vehicles, pumps and generators on site are fueled
by automotive grade diesel. Smaller generators and pumps require unleaded gasoline. A diesel and gasoline
fueling station (100,000 L diesel tank, 22,000 L diesel tank, 25,000 L diesel tank and 2,500 L mobile gasoline
tank) was installed near the C-Dry and has been in service since the summer/fall of 2011. Bulk deliveries of fuels
are made to this location on a regular basis. Tanks are double walled and are maintained in compliance with the
Storage Tank Systems for Petroleum Products and Allied Petroleum Regulations (Government of Canada,
2007), and other applicable legislation. Fueling is undertaken within the designated Project Transfer Area and in
accordance with the Product Transfer Standard Operating Procedure (SOP).

2.2.3 Propane
A 30,000 gal (US) propane tank is located next to the B-Shaft Ventilation Plant. Propane from this tank is used to
heat air supplied to the underground during the winter months. The tank is owned and maintained by Superior
Propane. The tank is registered to the MCM under the E2 Regulations, as per Environment and Climate Change
Canada (ECCC) instructions.

In addition to the large propane tank located at B-Shaft Ventilation Plant, propane and MAPP cylinders are also
stored at the Mobile Equipment Garage (MEG) and they are commonly used to fuel torches. Additional smaller
propane tanks can be found on-site (i.e., ETP office trailers (100-420 lbs)) for heating.

The MCM will contact Superior Propane in the event of emergencies involving propane. On-site personnel will
not attempt to deal with any spill/leak involving propane other than to provide site security and/or remove
possible sources of ignition. The Site-specific Environmental Emergency Plan for Propane is provided in
Appendix E of the GMRP - Emergency Management and Response Plan.

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2.2.4 Reagents
The following reagents are currently used to treat water at the ETP:

•   Ferric Sulphate (found in liquid form on-site) is used to co-precipitate arsenic and is stored in three tanks;
    one outside the ETP building; and two inside. The main tank receives deliveries via tanker truck while the
    inside tanks are used as storage tanks when the outside tank is full (See Appendix D-4 for the associated
    incident response plan).

•   Hydrated lime, a white powder, is added to the water to raise the pH, reducing reaction time. Lime is stored
    in a single silo within the ETP building (See Appendix D-7 for the associated incident response plan).

•   Magnafloc or Vanfloc, in solid granular particles is added to the stream before the treated water is released
    into the Settling Pond to flocculate the solids into larger particles. The flocculant is stored in 25 kg bags in
    the ETP building and added to the holding tank as required for treatment operations.

2.2.5 Solvents
Solvents such as Varsol are used to remove grease and oil from engine components and other machinery.

Waste solvents are a contaminant under the Environmental Protection Act (EPA) of the NWT. Waste solvents
are stored as per the product label instructions and the Hazmat Compatibility Chart. Solvents are kept in their
original container wherever possible or in an approved waste solvent container.

2.2.6 Sewage and Greywater
The lunchroom and administrative offices in the C-Dry building include restrooms and a kitchen area, which
require the use of potable water. As described in the Water MMP, potable water is trucked to site to support
domestic use. In addition to potable water use at the C-Dry, portable toilets are located at various locations
around site during spring, summer and fall, in support of activities.

The definitions of sewage and greywater, including additional details on how they are managed are provided in
both the Waste and Water MMP.

•   Sewage is defined as all toilet wastes but does not include greywater.

•   Greywater is defined as all liquid wastes from showers, baths, sinks, kitchens, and domestic washing
    facilities but not including toilet wastes.

Sewage and greywater will be managed differently on Site. Sewage from C-Dry is currently conveyed to the
underground. A system will be installed to collect it for treatment off-site through the City of Yellowknife’s sewage
treatment plant. Sewage from portable toilets and trailers are collected for off-site treatment. Greywater is
conveyed to the Site’s effluent treatment facilities through the underground mine pool.

2.2.7 Arsenic Impacted Wastes
As described in the Waste MMP, heavily arsenic-impacted wastes currently stored in shipping containers will be
removed and placed in a frozen zone during remediation (Chamber 15 or B1 pit). Older heavily arsenic-impacted
wastes buried in the tailings will remain in place. Arsenic trioxide dust and any other hazardous waste items

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impacted with arsenic above the leachable standard, including arsenic impacted double bagged asbestos
wastes, will be placed in Transportation of Dangerous Goods (TDG) approved containers and clearly labeled.
These will be containerized according to TDG Regulations for eventual disposal underground for freezing in
Chamber 15 or B1 Pit as per the CRP.

Any spills of arsenic impacted wastes should follow procedures outlined in Appendix D-1.

2.2.8 Explosives
As noted in the Borrow Materials and Explosives MMP, explosives will need to be properly managed before,
during, and after blasting activities. All packaged explosives and accessories will be supplied by a licensed
explosive contractor and transported to site. There will be no magazines for explosive storage on-site. The Drill
and Blast Sub-contractor will arrange to have the explosives transported to site from an off-site explosive
magazine. Any unused explosives will be returned to the supplier’s off-site magazine.

Information about the type of explosives, handling and transporting is provided in the Borrow Materials and
Explosives MMP. When handling, transporting or storing explosives, care will be taken to avoid spillage

2.2.9 Co-Polymers
Co-polymers may be used for dust suppression on site roads and tailings to mitigate fugitive dust. While
co-polymers are generally non-toxic, the SDS for specific co-polymers should be reviewed. Any uncontrolled
release of a co-polymer should be dealt with immediately and care should be taken to limit the spread. The SDS
for the co-polymer should be reviewed for PPE requirements and other recommendations while utilizing the
product or when responding to a release.

2.2.10 Chemical (Dynalene HC, Carbon Dioxide (CO2) and Nitrogen)
The Freeze Optimization Study (FOS) cooling plant was constructed just west of the C-Dry between 2009 and
2011. The purpose of the FOS project was to explore options regarding the freezing of the arsenic trioxide in
place underground. To date, freezing has taken place in the #10 chamber in the AR2 East area of the site and
involves Dynalene HC, nitrogen, CO2 charged thermosyphons. The FOS will be decommissioned and
disassembled in the short-term.

Chemicals/products being used as part of the FOS are as follows:

    •   Dynalene HC: A heat transfer fluid used in the active freeze holes

    •   CO2: Used as a heat transfer agent in the thermosyphons

    •   Nitrogen: FOS is charged with N2 to prevent rusting of its components

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3       SPILLS MANAGEMENT
3.1      Roles and Responsibilities
The emergency response organization structure for the Site is based on the Incident Command System (ICS).
The ICS is a comprehensive, practical emergency management system used for effectively organizing and using
the resources available for any type or size of operation. Common terminology has been developed to identify
major functions, personnel, and responsibilities. The ICS outlines a series of supervisory levels available for
implementation. The assignment of these responsibilities is based on the nature of the incident and the scale
and complexity of response activities required.

The ICS includes the Incident Command Team (ICT). The ICT chain of command is not the same as the chain of
command for regular working activities. The ICT chain of command only applies in the case of an incident or
emergency. The ICT made up of the Incident Commander, First Responder, Deputy Incident Commander and
the Emergency Management Team (EMT).

The ICT is the first line of defense in case of an incident or emergency occurring on the Project. It consists of on-
site employees and works out of the incident command center, located in C-Dry. From this location, the ICT can
manage on-site duties related to the incident as well as the overall incident and initial communication, sheltering,
or evacuation activities. The EMT is responsible for the continued Site response and follow-up actions. The EMT
may work out of the emergency operations center located in C-Dry but based on the incident type and location,
the EMT may operate from remote locations off-site. The emergency operations center is the blanket term
applied to the Site and off-site members of the project team.

Both teams can be modified by those in charge (that is, the Incident Commander and Emergency Manager) to
effectively manage any incident by adding to, deleting from, or combining positions as the needs of the incident
change. However, both the Incident Commander and Emergency Manager should clearly identify the
parameters of an assignment when deviating from the standard ICS assignments.

Personnel on the ICT and the EMT are responsible for accomplishing assigned duties relating to incidents and
for the safety and health of the support personnel reporting to them in an emergency. The Incident Commander
should maintain a constant awareness of the position and function of emergency response personnel during an
incident. This awareness is the basic means of accountability required to ensure incident response safety. In an
emergency, the Main Construction Manager (MCM) is responsible for activating the sequence of the MCM
Emergency Response Communications Flowchart (Appendix F). As indicated in the flowchart upon discovery of
an emergency the incident commander should be contacted immediately.

Individuals named in the Emergency Response Communications Flowchart (Appendix F) are responsible for
designating a suitably trained replacement to assume their role in the plan before a planned extended absence
from the workplace.

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3.1.1 First Responder
1. As soon as the spill release is noticed, if applicable, stop work. Ensure that all personnel/bystanders are out
   of harm’s way and that the cause of the spill has been identified and isolated before initiating spill response.

2. Assess the hazard, including an initial estimate of quantity if possible. Safety and protection of human health
   take precedence over environmental protection. If there is a threat to personnel safety, evacuate the area
   immediately to the location determined by the Incident Commander. In the event of a propane or arsenic
   release, go immediately to Step 4. When assessing the hazards, one should refer to any applicable SDS
   and must have the applicable personal protective equipment (PPE) available. The first responder should
   also take note of the nearest windsock on-site or radio the Incident Commander or site security for the wind
   direction. There are currently two windsocks; one is located at the Propane Tank and the second is located
   adjacent to the C-Dry.

3. Stop, contain, or minimize the effects of the spill, provided it is safe to do so. Turn off any valves, pumps,
   vacuums, or other delivery equipment if possible and applicable.

4. Report the spill to the Mine Manager (or designate) to initiate the response. If possible, identify the spilled
   product, including the amount spilled and the extent of release.

3.1.2 Mine Manager and/or Incident Commander (or designate)
In the event of a Spill, the Mine Manager must immediately contact:

•   The Environmental Manager (by phone or by radio), or their designate, and advise them of the nature and
    status of the spill.

•   The Health and Safety Manager (by phone or by radio), or their designate, and advise them of the nature
    and status of the spill.

•   The Surface Care and Maintenance Manager (by phone or by radio) who will in turn notify site personnel
    working on surface.

•   The Underground Supervisor (by phone or by radio), who will in turn notify site personnel working
    underground (e.g., using stench gas which is manually dropped at the B vent).

•   The Inspector, Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC), Public Services and
    Procurement Canada (PSPC), and the MCM contacts as outlined in the Emergency Response
    Communications Flowchart (Appendix F).

The Incident Commander, who in most cases will be the Mine Manager, will then coordinate the following
on-scene response:

•   Assesses the requirements for staff resources, equipment, materials and tools to contain the spilled
    material. In conjunction with the Deputy Incident Commander (or Security if the Deputy Incident Commander
    is not reached by the First Responder), arrange for necessary equipment to be brought to the spill location.

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•      Develops the overall plan of action for containment and clean-up of the spill and designates the Emergency
       Management Team, including the Incident Response Team Leader who will be responsible for implementing
       the plan.

•      Ensures that assigned responsibilities are carried out and that proper coordination exists between
       supervisors and other individuals responding to the spill.

•      Maintains constant communication with the Environmental Manager or their designate with respect to all
       aspects of the cleanup.

3.1.3 Emergency Management Team
The Emergency Management Team facilitates a coordinated response and recovery process by management
and staff to any incident or set of circumstances that has the potential to significantly damage the organization
and its employees, operations, financial condition, or reputation. Its function is to assess both the short- and
long-term impacts. This team’s areas of responsibilities and contact information are found in the GMRP –
Emergency Management and Response Plan, and include:

•      support the ICT and Incident Commander

•      manage potential impacts, and consequences of the incident

•      notify and provide ongoing communication as required

3.1.4 Environmental Manager (or their designate)
For all reportable spill quantities (Appendix B): Reports the spill immediately by using the NU-NT Spill Report
Form by one of the following methods:

 i.      Northwest Territories 24-hour spill line Telephone: (867) 920-8130

ii.      Northwest Territories 24-hour spill line Fax: (867) 873-6924

iii.     Northwest Territories 24-hour spill line E-mail: spills@gov.nt.ca

iv.      Online: Spill Reporting and Tracking Database

Within 24 hours, notifies the Board and an Inspector; and within 30 days of initially reporting the incident, submit
a detailed report to the Board and an Inspector, including descriptions of causes, response actions, and any
changes to procedures to prevent similar occurrences in the future. Written notification shall be provided to the
Board and an Inspector if any changes occur.

•      CIRNAC Inspector Telephone: (867) 669-2442

•      CIRNAC Inspector E-mail: Tim.Morton@canada.ca

•      Mackenzie Valley Land and Water Board (MVLWB) Telephone: (867) 766-7465

•      MVLWB Email: sallerston@mvlwb.com

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The Environmental Manager, who in most cases will be the Incident Response Team Leader for secondary spill
response, will then coordinate the clean-up. The Environmental Manager is also responsible for the following:

•   Provides technical advice on anticipated environmental impacts of the spill.

•   Estimates the effectiveness of various containment, recovery, and disposal options, suggesting the most
    appropriate approach. Works with the Incident Commander or their designate to determine the plan of action
    for remediation and cleanup of the spill.

•   Directs the collection and analysis of water samples to identify and monitor possible contaminant levels is
    carried out.

•   Directs a program of sampling natural water courses deemed as directly or potentially impacted by the spill,
    as well as upstream and downstream of the spill site, is carried out. The program should be designed to
    assess the potential for damage to the natural environment as a result of the incident. Initial samples should
    be taken as soon as possible after the spill has occurred, followed by repeated sampling at regular intervals
    during the subsequent clean up and restoration activities. Sampling time intervals will be determined on a
    case by case basis and should be developed in consultation with the appropriate regulatory officials
    whenever possible.

•   Directs the collection and analysis of soil/sediment samples to identify and monitor possible contaminant
    levels is carried out. The sampling program will be determined on a case by case basis as necessary and
    will likely include grid sampling of the affected area. Samples will be submitted to a CALA certified lab for
    analysis.

•   Directs air quality monitoring to be conducted if necessary, to adequately protect the health and safety of the
    responders.

•   Follows-up at the spill site after the initial response to monitor the effectiveness of the cleanup operation and
    recommends further remediation work, if necessary.

•   Follows-up and maintains close communication with the Inspector until the spill-reporting activities are
    closed.

•   Gathers relevant information and submits a detailed spill report to the applicable regulatory agencies, within
    the timeframe determined by the regulatory agencies.

•   In conjunction with the Health and Safety Manager, ensures that personnel that may be expected to respond
    to a spill receive adequate training in responding of the various types of spills that may be anticipated
    throughout the Project (see Section 1.8).

3.1.5 Technical Specialists
Technical specialists may be members of either the Incident Response Team or Emergency Management
Team, depending on their location (on-site or off-site) and level within the corporation. The roles and location of
the different team members are outlined in the GMRP – Emergency Management and Response Plan.

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3.2       Spill Resources
3.2.1 Access to the Plan
The Spill Contingency Plan is posted in the C-Dry Lobby where all site personnel can reference it as needed.
Additional copies of the Plan can also be found at this location. The Spill Contingency Plan is also available in
the C-Dry second floor conference room, both the Mine Manager and Environmental Manager have copies, and
a copy is provided to all subcontractors. Incident Action Plans (Appendix D) are posted at all storage areas
(e.g., the ETP, Gatehouse, C-Dry, Machine Shop, Electrical Shop, and Carpenter Shop). More specifically, the
incident action plans for Ferric Sulphate (Appendix D-4), Lime (Appendix D-7), Minewater (Appendix D-8) and
Tailings spills (Appendix D-8 and D-10) are available at the ETP.

3.2.2 On-Site Communication
The Emergency Response Communications Flowchart found in Appendix F as well as in the GMRP –
Emergency Management and Response Plan, contains MCM and other key Stakeholders (regulators,
authorities, etc.) landline and 24/7 cell phone numbers in case of emergencies. The Security Officers also have
site wide radio communication. The locations of the Emergency Response Communication Flowchart are
described in Appendix G. The protocols for the use of radios during emergency response is outlined within the
GMRP - Project Safety, Health, and Environment Plan (PSHEP).

3.2.3 Spill Kits and Personal Protective Equipment
Both Universal and Oil kits are present on site. The kits are contained in polypropylene over pack with threaded
lids, snap clip lids or spring top lid barrels. These containers meet the TDGR for salvage drums suitable for use
as shipping containers. Contents of spill kits may vary from place-to-place depending on the type of spill that is
anticipated.

3.2.4 Spill Kit Contents
Universal spill kits are equipped with the following supplies:

•   Nitrile/Sol-vex gloves

•   safety goggles

•   disposable coveralls

•   universal absorbent pads

•   universal absorbent pillows

•   universal absorbent socks

•   universal booms

•   portable (insta) berms

•   disposable plastic bags

•   tie straps

•   caution tape

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