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, (LINK to a newly created page for the tables in the PDF) 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.
In addition, Seabridge has committed to beginning construction only once a partner heavily experienced in copper-gold mine construction and operation has been secured.
Seabridge has noted some confusion regarding its KSM Project as it relates to Alaskan waters. It is important to remember:
- The KSM tailings management facility (TMF) is not situated in waters upstream of the US border. KSM’s TMF is situated within the Nass River Watershed which flows entirely into Canadian waters. (See map)
- Seabridge worked extensively with Alaskan State and US Federal regulators (EPA, DOI, NOAA, Fish and Wildlife Service), having more than 85 different meetings and interactions with these regulators through the Environmental Assessment (EA) process to learn about and address the concerns of Alaskans. (See list of meetings with US and Alaskan agencies and regulators)
- Seabridge worked in close collaboration with all regulators, including Alaskan officials, to ensure that downstream waters were not impacted by the proposed operations. During the course of the EA, significant design changes, in excess of $300 million, were made to the water management system proposed at the mine site. Both the Canadian Federal and Provincial regulators determined KSM will not have an impact on US waters. Questions from Alaska regulatory agencies were addressed and answered throughout the Environmental Assessment process and as a result, no outstanding concerns remain.
Read our letter requesting correction of a publishing error regarding the location of the KSM Project’s TMF on the map contained within the fall issue of Ravencall. For additional informational purposes read the Canadian Environmental Assessment Agency’s Comprehensive Study Report for the KSM Project (Read the assessment here). View corrected map.
Read a letter written to BC Minister of Energy and Mines, the Honourable Bill Bennett from Dirk van Zyl (engineer and one of the Mount Polley report authors) clarifying that dry stack tailings is not the only best available technology for managing tailings.
Read an April 11, 2014 Juneau Empire article where 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.”
A report authored by Michael Price titled Sub-lethal metal toxicity concerns for Unuk watershed salmonids from Seabridge Gold’s proposed KSM mine is often used to claim Seabridge will release metals into the Unuk watershed that would exceed levels known to have serious impacts on salmon.
During the Environmental Assessment review for the KSM project, Dr. Chris Kennedy, a water toxicologist from Simon Fraser University, assessed the Price report and concluded “The COPC (contaminants of potential concern) screening approach used by Rescan (a Seabridge consultant) has followed standard risk assessment approaches, as recommended by the BC MoE (Ministry of Environment), the CCME (Canadian Council of Ministers of the Environment) and Environment Canada. The seven metals evaluated by Price (2014) were not identified as COPCs based on concentrations less than the BCWQ (BC Water Quality) or less than baseline concentrations, and therefore, no further evaluation was required. Furthermore, the Price (2014) review does not acknowledge the water treatment proposed for the Mine Site, which will reportedly result in a significant reduction of metals concentrations. It is our opinion that Rescan has relied on the best available science and methods to predict the potential for discharge from the Mine Site to affect aquatic life, including salmonids, in the Unuk River Watershed.” (Read the assessment here)
The regulators responsible for the KSM Environmental Assessment accepted Dr. Kennedy’s report and discounted Mr. Price’s.