Does Alaska Assume all KSM Project Risk?
We have heard several claims that BC takes all the benefits of mining in transboundary watersheds while Alaskans assume the risk of harm to their way of life, water, fisheries, culture and jobs. However, several facts about the KSM Project collectively indicate that KSM is not a risk to the Alaskan environment, economy or its communities.
- The KSM Project underwent a rigorous independent joint harmonized BC-CANADA environmental assessment over an 81-month period, and, in all instances, the British Columbia Environmental Assessment Office (BC EAO) and the Ministry of Energy and Mines, along with the Canadian Environmental Assessment Agency (CEAA) concluded that KSM was not likely to cause adverse environmental effects, including potential effects to the Unuk River, which flows into Alaska, when implementation of the proposed mitigation measures is taken into account. It was on this basis, the KSM Project was approved by the appropriate Federal and Provincial regulatory authorities in their role as statutory decision makers on behalf of the Crown and all citizens of British Columbia and Canada. See the EA report CEAA Comprehensive Study Report here.
- During the Environmental Assessment (EA) process, Seabridge worked in close collaboration with all regulators, including Alaskan State and US Federal officials (EPA, DOI, NOAA, Fish and Wildlife Service), having more than 85 different meetings and interactions with these regulators, to ensure that downstream waters were not impacted by the proposed operations. Alaskan regulators remain actively involved in the permitting of the KSM Project and are ensuring the concerns of Alaskans are continuing to be acknowledged and addressed. See a list of Alaskan regulatory interactions here
- Both the Canadian Federal and Provincial regulators determined KSM will not have an impact on US (i.e. Alaskan) waters. Questions from Alaskan regulatory agencies were addressed and answered throughout the EA process. The EA and CEAA report also states, the participating US Federal and State agencies did not identify any outstanding transboundary concerns with the EA. Furthermore, a representative of the Alaska Department of Natural Resources stated, “Four of the same resource managers and specialists who review Alaskan mines have examined KSM’s plan. They found no significant issues with the application.”
- The KSM Project Tailings Management Facility is located in the upper reaches of the Bell Irving River Basin and drains into Canadian waters, not the Unuk River, or any other US waterway. View map here.
- Seabridge has been collecting surface water quality monitoring data for the KSM Project in upper Mitchell Creek, upstream of the confluence with McTagg Creek, since 2007 (more than 10 years). Water testing stations are noted on this map. Mitchell Creek metal concentrations in water are naturally elevated in several metals including copper and iron, due to the receding Mitchell Glacier which is exposing the Mitchell deposit, from which naturally occurring acid rock drainage is being produced, due to the sulphide mineralization oxidizing. This naturally occurring impact to the water quality is observed and has been measured from the Mitchell Deposit to the BC-Alaskan border, which is approximately 30 km downstream. Water in the Unuk River cannot therefore be characterized as pristine.Average concentrations of arsenic, copper, iron, selenium, and zinc are naturally above applicable BC water quality guidelines within Mitchell and Sulphurets creeks, and the Unuk River. See images of the naturally degraded water quality in the project area here.
- Plans include a Water Storage Facility (WSF) upstream of the Alaskan border. As part of its operations, Seabridge plans to discharge treated water from two Water Treatment Plants (WTPs), which will be located in the Mitchell Valley. These WTPs will reduce the concentrations of many parameters in the Unuk River and the water quality contained behind the WSF will be no worse than what has seen to be occurring naturally at the site and is currently flowing down the river to Alaska.
- On tables that can be found here, a summary of the data collected in upper Mitchell Creek has been compared to the average projected Water Treatment Plant discharge concentrations, which were determined in pilot testing. As the tables indicate, all predicted Water Treatment Plan discharge concentrations are at or below the average background concentrations in upper Mitchell Creek, which means water discharge will create an improvement over natural background conditions, and this will not impact water quality within the Unuk River.
- The WSF construction and operation plans acknowledge the existing presence of naturally occurring acid water and account for the presence of future acid generation, with the inclusion of an asphalt core into the WSF design.
- Furthermore, the WSF is impervious to acid and is resistant to earthquakes. The KSM dams are designed to resist the effects of the maximum credible earthquake that can arise in the area. Seismic records and accounts of earthquakes in this area since 1700 were reviewed, and the historical records for earthquakes up to 350 km from the site were assessed to determine the strongest earthquake effects that could potentially occur in a 10,000-year period. The maximum credible earthquake was also assessed considering the largest earthquakes in the northwestern British Columbia region which are generally associated with the offshore subduction zone (e.g. Queen Charlotte Fault), located 340 km west of KSM, which recently experienced a magnitude 8.4 earthquake. Although the local faults at the site are inactive, the maximum seismic load from an unknown local fault was also assessed and assumed to potentially occur. The KSM dam designs meet or exceed Canadian and Alaskan regulatory requirements and the Canadian Dam Safety Association guidelines. The KSM dam designs include materials that can resist deformations and exceed design guidelines for stability and control of water.
- Although Seabridge received the BC Environmental Assessment Approval prior to the Mount Polley incident which occurred on August 4, 2014, the Canadian Federal government approval was granted on December 19, 2014, well after the Mount Polley incident and just a few weeks prior to the release of the Mount Polley Panel Report. The Federal government approval, prior to the release of the Mount Polley Panel Report, can be interpreted as a sign of confidence in the design of KSM water management strategy, including the TMF and WSF.
- Seabridge implemented an Independent Geotechnical Review Board (IGRB) to review construction, operation and closure of all major structures including the Tailings Management Facility and the Water Storage Dams. The initial IGRB Report provides assurance that the IGRB finds the major structures appropriately located, and safely designed for both construction and operation.
- Once the KSM project begins operations, it will be subject to monitoring requirements under a variety of approved plans including aquatic effects management, selenium management, wildlife management and the Canadian Federal Government Metal Mining and Effluent Regulations. This monitoring will further minimize and manage potential impacts to the local environment and ensure no downstream impacts to the Unuk River.
- The project is financially robust and capable of supporting long term closure costs. The costs for long term (i.e. perpetual) water treatment and monitoring have been accounted for and are publicly available in Seabridge’s recently updated and published 2016 pre-feasibility study that was filed on SEDAR on November 4, 2016.
In addition, Seabridge has committed to beginning construction only once a partner heavily experienced in copper-gold mine construction and operation has been secured.