An outline of a monitoring plan is

needed, with a clearly stated

commitment that the monitoring plan
willOctober
be designed 30,to2014
have aResponse
statistical to Technical Comments - Sabina Gold Silver Corp. Back River Project
power level of 0.8 or greater in terms of
its ability to detect changes from baseline
conditions, and to trigger adaptive
Subject management
TC Number Area Reference Reviewerif negative impacts are
Recommendation Agree with TC Sabina Response
occurring. This commitment can be
achieved through a combination of
ensuring sufficient future sampling
frequency, and/or through the use of a
Terrestrial and
KIA_IR-1 Marine Vol. 5, Sec. 5.9.1.2, Page 5-153 higher alpha level (e.g., alpha of 0.20 Yes Please see expanded response KIA IR-1.
rather than alpha of 0.05). Sabina should
Wildlife consider that, where 2 years of baseline
data do not exist (i.e., whereby the same
methods in thelike
The KIA would samethelocations
community weretoused
be
to measuretothe
consulted seesame
how variables
much of the in each
items
Terrestrial and year), additional
identified
Please seeinIssue
Table1baseline
5.1-6
as datatypically
thisthey
relatesmay need
to the eat
KIA_IR-2 Marine Vol. 5, Sec. 5.8.4, Page 5-150 to
per be collected
week.
Monitoring The
Plan such
KIA that two
would also years
like toofsee Yes Please see expanded response KIA IR-1.
Wildlife baseline data
exposure riskscan be combined
to toddlers into a
and adults
single data base
consuming with aparts
particular measure
of theofbody
inter-
of
annual variation,
these animals suchwhich can
as fat, be used
brains, as a
kidney,
reference point against which
and liver, each of which takes up metals monitoring
Terrestrial and data
to can be compared
a different degree than for meat.
adequateThe KIA
KIA_IR-3 Marine Vol. 8, Chapter 5, Page 5-8, Table statistical
would liketests.
modelling to be based on No Please see expanded response KIA-IR-3.
5.1-5 and Table 5.1-6
Wildlife future worst case scenarios, and Sabina
should consult with the KIA and local
members of the community about these
risks, to explain what these risks will
Terrestrial and mean in terms of how much caribou they
Please see Issue
can consume, 1 as body
which this relates to the
parts will pose
KIA_IR-4 Marine Vol. 5, Sec. 5.9.1.2, Page 5-155 Monitoring Yes Please see expanded response KIA IR-1.
Wildlife the greatestPlanrisks, and which geographic
locations should be avoided during
hunting in order to stay healthy.
Provide
Review of a brief
the 2013discussion
baseline in the FEIS that
prompted
Terrestrial and Vol. 5, Sec. 6.5.2.7 (and other explains why
additional the dietary
questions. Themodelling
camera effort found In the FEIS, Sabina commits to including this brief discussion on why the dietary modelling found that mercury will not
KIA_IR-5 Marine sections related to effects of thatday
per mercury
wouldmay threatenbetween
be different the health a of Yes
Wildlife contaminants on wildlife) humans but will not threaten threaten the health of grizzly bears.
camera programmed to take athe health
of grizzly bears.
photograph every 5 minutes + with Remote cameras were programmed to take both timed photographs and motion-triggered photographs. For all cameras, the
motion triggered capacity, compared to period where the camera was available to take photographs (batteries functioning and not obscured by snow or knocked
those only taking motion triggered
Terrestrial and photos, or only taking timed photos. over by wildlife) was recorded and wildlife observations were then calculated as observations/(available) day.
Vol. 5, Figure 8.1-7, Page 8-22, 2013
KIA_IR-6 Marine Wildlife Baseline After reviewing the 2013 wildlife Yes Note that observations recorded on days where the camera was obscured by snow for part of the day were censored
Wildlife baseline, please clarify: a) if and how
each of i)is the timed-cameras, and ii) the (removed) from the data such that the analysis did not deal with fractions of days in the calculations.
The KIA satisfied with the engagement,
motion-triggered
and we encouragecameras Sabina to werecontinue Timed and motion-triggered cameras were analyzed separately.
corrected for monitoring
along the direction it has effort
taken (active
to inform
camera
us. The timeisper
KIA stillday);
quite and b) whether
concerned about
Geotechnical data from the motion-triggered cameras Sabina will continue to optimize the location and design of the TIA and engage KIA in the process. Results will be captured in
KIA_IR-7 Site Layout - Throughout the
The location
proponent andisdesign
asked of
to the TIA,
provide and
an Yes
Engineering andencourage
we timed-cameras Sabina were kept separate
to continue the FEIS.
analysis
during of the
analysis. additional benefit
investigating
generated fromoptions to reduceof
the extraction the
the
risk/improve
resources the design
located at the/function
George Lake of the
TIA.
site. The analysis should consider the
additional revenues and costs for the Sabina will continue to optimize the extraction of the resources located at the George Property including accounting for
KIA_IR-8 Geotechnical N/A Yes engineering costs and environmental liability. Additional information on this topic will be presented in the publically
Engineering George Lake deposit (economic), and it
must also consider the engineering costs available Feasibility Study Report.
and environmental
The KIA feels that the liability during care &
foundation
maintenance,
conditions of the closure,
proposedpost-closure
WRSA’s have
periods.
not beenThe KIA suggests
described that this be
in a meaningful way;
considered as a component
if there is currently inadequate of Sabina’s
KIA_IR-9 Geotechnical Vol. 9, Sec. 2.2.1 Feasibility
information, Study.
the KIA requests that data Partially In the FEIS, Sabina commits to providing a detailed summary of overburden and permafrost conditions for the property with
Engineering gaps must be identified and proposed sufficient detail to demonstrate how planned surface infrastructure such as the WRSA's will interact with this system.
measures to mitigate some of these
uncertainties
The KIA strongly prior to the FEIS should
recommends be
that Sabina
described
investigateprior other toalternatives
the FEIS. (location
Provide a contingency
and design) for the TIA.plan if theathermal
Provide TIA Sabina commits to further substantiating the waste rock closure design criteria and completing a thermal analysis, inclusive
Geotechnical performance of the Waste
alternatives assessment Rock Storage
identifying
KIA_IR-10 Engineering Vol. 9, Sec. 2.2.1 Area is not assumed (i.e., if itand
does not Partially of climate change considerations to demonstrate the viability of the plan. This information will be presented in the FEIS.
environmental, engineering, Sabina does not believe a contingency plan is warranted at this stage.
remain frozen,
economic and begins
reasoning to thaw).
for potential sites.
The KIA requires a description of the
foundation beneath the TIA and
embankments, including a description of Sabina commits to optimizing the location and design of the TIA based on an alternatives assessment founded on
KIA_IR-11 Geotechnical Vol. 9, Sec. 2.2 the permafrost and ice conditions along Yes environmental, technical, and economic reasons. In addition Sabina commits to providing a detailed summary of the
Engineering with precedent for lining the entire basin. overburden and permafrost conditions for the TIA foundation with sufficient detail to justify and support the design. This
In the FEIS, the KIA would like to see data information will be provided in the FEIS.
Provide contingency
gaps identified measuresmeasures
and mitigation in the case
that the design
proposed to avoid intent currently proposed
uncertainties
emerges
associated aswithbeing not practical
potential or feasible
liner cracks. The
during
KIA willthe
need FS todesign
review stage.
a moreInformation
detailed Sabina commits to further substantiating the waste rock closure design criteria and completing a thermal analysis, inclusive
Geotechnical
KIA_IR-12 Engineering Vol. 9, Sec. 2.15 regarding
descriptionthe of waste
the TIArock storage
design area
and basin, Partially of climate change considerations to demonstrate the viability of the plan. This information will be presented in the FEIS.
PAG/nPAG
and underlying (potentially
context,acid generating:
as well as Sabina does not believe a contingency plan is warranted at this stage.
non potentially
contingency andacid
hazardgenerating) design in
considerations
intent, as well Study
the Feasibility as projected
and thefreeze-up
FEIS.
times, are requested by the KIA.
1
 October 30, 2014 Response to Technical Comments - Sabina Gold Silver Corp. Back River Project

Subject
TC Number Area Reference Reviewer Recommendation Agree with TC Sabina Response
The
Sabina KIAshould
would provide
like the shallow
proponent to
incorporate
geotechnicalthe presence/absence
conditions of the various of
1.
fuelIf scale
lithology
storage factors
trends aresiderite
for
facilities, applied,
this would ensure
(Iron give For the FEIS, Sabina commits to providing a detailed summary of overburden and permafrost conditions for the property with
KIA_IR-13 Geotechnical Vol. 2, Sec. 6.4 assumptions
Carbonate;
reviewers a FeCO3) used inunderstanding
proper scaling
into calculations
the FEIS. Andof the Yes sufficient detail to demonstrate how planned surface infrastructure such as the fuel storage areas will interact with this
Engineering are adequately
further,
foundation and described
include information
layout should andinbe
quantify
the FEIS system.
any
on uncertainty
the percentage
available, associated
assessed,ofand with these
'dolomite/ankerite'
integrated into
assumptions
deposits suchtothat the KIAonly' can and, if Sabina commits to providing additional discussion of the carbonate mineralogy in the FEIS. However, it is noted that iron
the FEIS relative 'dolomite
carbonate was only found in a few samples, and that
evaluate
significant, their tolerance on
to comment to these
any 1) For the FEIS, Sabina commits to describing all of theit assumptions
is unlikely that there
made in will
the be any statistically
scaling calculationssignificant trends
and the level of with
uncertainty levels. The KIA will need to lithology.
uncertainty and conservatism that is built into those calculations.
lithological trends.
Geotechnical 2. Conduct
review additional
the FEIS on-site
for details tests that
of humidity
KIA_IR-14 Engineering Vol. 11 (App 4A) would Partially More generally, Sabina commits
that the to providing
set offurther interpretation and discussion onon the effectiveness and reactivity
material of the
cell testmore closely mimic
interpretations, and conditions
for details 2) Sabina
different
acknowledges current field barrel tests were conducted relatively coarse grained (half
applied in the laboratory,
about different lithologiesand/or and/ortrue zones split core)forms of neutralization
that was potential
available at the in each
time those testsofwere
the rock types, Due
initiated. as determined
to the verythrough
hard anddifferent types
competent of acid
nature ofbase
the core,
field
within conditions.
the deposit Two suggestions
areas, which may are:have accounting tests, NAGless
there is considerably tests, mineralogical
fines characterization
present in those and is
tests that what humidity
presentcell tests.
in the Please also
laboratory scalesee the and
tests, corresponding NRCan
likely less fines
(i) Particleproportions
size distribution (PSD) analyses responses
than will bethat provide
present further information
in run-of-mine on how
blast rock. the effectiveness
However, at this stageofin silicate NP atitbuffering
the project, pH willtobe
is not feasible evaluated
conduct for
additional
different of materials with samples withscale
low sulphide content true
and reactivity.
should
unreactive be conducted
neutralizing onpotential
existing fieldthan on-site field tests to simulate field conditions due to the length of time required to achieve stable leaching
barrel
assumed. material,
The KIA aswould
grain size like has
to seea these conditions in that type of test (minimum of 2 to 3 years). Sabina has completed an extensive laboratory based kinetic testing
KIA_IR-15 Geotechnical Vol. 11 Appendix 4A, Sec. 3.33, page significant influence onseparatedmineral out to Partially program representing each of the main lithologies present at the site, and has recently initiated more tests to improve the
Engineering 3-21 pieces of information
weathering
feel comfortable rates;that the true representativeness of some of these materials. The humidity cell tests will be the primary input to the updated water quality
(ii) Currently,potential
neutralizing field barrel of thematerial
deposits is predictions (source terms) for the FEIS.
consists
understood. of halved NQ (i.e., 2 inch
diameter) drill core, with no attempt to Sabina notes that the airstrip was constructed from run-of-quarry greywacke and gabbro with similar geochemical
generate
Sabina
The KIAprovide finer grained
requests further materials.
rationale
that Sabina as to
provide characteristics to much of the greywacke and gabbro from the deposit areas. This is effectively a larger scale field test on the
Geotechnical Therefore,
criteriathe KIAbeen
suggests Sabina
types ofcommits
materialtothat
providing thetoappropriate
be used forjustification for design criteria adopted
zone offorthe
any water management
rock piles. structures
Sabina is at
KIA_IR-16 Engineering Vol. 2, Sec. 6.7.4 and 7.10.3.2
why
contingency have
measures thethat
ifselected,
seepage that do Partially Lytle
are likely cover material within the active final waste
additional
not
ratessimply
are not field
rely
asonbarrels befor
decisions
assumed constructed
made
the DEIS.for for willingand
to Occurrence Lakes inmonitoring
commit to seepage the FEIS. Sabina does notof
downgradient believe a contingency
the quarry plan
and airstrip to isobtain
warranted at this
field scale stage.
data, and could use this
tests with
other crushed
projects. drill core orSabina
Furthermore, waste rock data in subsequent refinements to the predictions. However, it is unlikely that data from a seep survey would be available
for thethat
states purpose of moredischarge
the sewage closely to the before July 2015. Therefore, the data is not likely to be available for the FEIS.
mimicking
tundra willgrain
occursize at andistributions,
"acceptableand
total surface
distance" from areas
the experiencing
aqueous receiving
weathering Sabina commits to provide further rationale and methodology for criteria selection during the water licensing process.
KIA_IR-17 Water Quality
Vol. 2, Chapter 2, Sec. 6.4, Page 6-7, environment(higher to ensure surfaceCCME area in
water Yes Further, Sabina commits to provide specific tundra discharge locations for treated sewage, along with supporting rationale, in
Table 6.4-1 particulate
quality objectivesform), (WQOs)
to be encountered
are met once
during reaches
mine operations. the FEIS.
runoff the closest water body or
watercourse. The FEIS should provide
specific tundra discharge locations along
with
The KIA supporting
encourages rationale
Sabinafor tothose
consider
Vol. 2, Chapter 2 Sec. 6.4, Pages 6-7 locations. Thisofrationale
construction an incineratorshouldon include
site at To clarify: during site preparation and construction, treated effluent at the MLA will be discharged to the terrestrial
KIA_IR-18 Water Quality Table 6.4-1 how
an earlyCCME stage,WQO suchwillthat
be metsludge between
can bethe No environment. Sludge and other waste collected from Pacto systems will be incinerated.
discharge
incinerated site and nearest water body.
immediately.
Sabina should provide rationale as to why
the water quality criteria concentrations
presented in Table 6.6-2 are appropriate
for this particular site and project.
Vol. 2, Chapter 2, Sec. 6.6.1.6. Page Specific locations for discharges to the Sabina commits to provide further rationale and methodology for criteria selection during the water licensing process.
KIA_IR-19 Water Quality Yes Further, Sabina commits to provide specific tundra discharge locations for treated sewage, along with supporting rationale, in
6-17, and Sec. 6.7.1.5, Page. 6-38 tundra, along with rationale for those the FEIS.
locations, and how CCME WQO will be
met between the discharge site and
nearest water body, should be provided
as part of the FEIS.
Sabina commits to provide further rationale and methodology for criteria selection during the water licensing process.
KIA_IR-20 Water Quality Vol. 2, Table 6.6-2 Please see Issue 19 as this relates to the Yes Further, Sabina commits to provide specific tundra discharge locations for treated sewage, along with supporting rationale, in
Excess Water Discharge
the FEIS.

Specific locations as to where discharges

KIA_IR-21 Water Quality Vol. 2, Chapter 2, Sec. 6.6.3 Page 6- will be applied to the tundra, along with Yes Sabina commits to provide specific tundra discharge locations for treated sewage, along with supporting rationale, in the
20 and Sec. 6.7.3, Page 6-40 rationale for those locations, should be FEIS.
provided as part of the FEIS

Further rationale as to why criteria have

Vol. 2, Chapter 2, Sec. 6.6.5/6.7.6 been selected and the appropriateness of
KIA_IR-22 Water Quality -Pages 6-21/6-41 its application to the Project LSA should Yes Sabina commits to provide further rationale and methodology for criteria selection during the water licensing process.
be provided by Sabina

KIA_IR-23 Water Quality Table 6.4-3 Please see Issue 22 as this relates to the Yes Sabina commits to provide further rationale and methodology for criteria selection during the water licensing process.
Secondary Containment Water Discharge
The KIA recommends construction of an
incinerator on site such that the
application of sludge to the tundra, which
can alter vegetation and attract wildlife,
Vol. 2, Chapter 2, Sec. is not required. Further, the KIA would To clarify: during site preparation and construction, treated sewage effluent at the Goose and George camps will be
KIA_IR-24 Water Quality 6.6.8.1/6.6.7.1 Pages 6-23/6-43 like to know which water bodies or water No discharged to the terrestrial environment. The sludge and other waste collected from Pacto systems will be incinerated.
courses the runoff will be directed to
should sludge continue to be spread onto
the tundra at the Goose and George
camps.
2
 October 30, 2014 Response to Technical Comments - Sabina Gold Silver Corp. Back River Project

Subject
TC Number Area Reference Reviewer Recommendation Agree with TC Sabina Response

Further rationale as to why criteria have

KIA_IR-25 Water Quality Vol. 2, Chapter 2, Sec. 6.6.8.4, Table been selected and the appropriateness of Yes Sabina commits to provide further rationale and methodology for criteria selection during the water licensing process.
6.6-6 its application to the Project LSA should
be provided by Sabina.

Vol. 2, Chapter 2, Sec. 6.6.8.5. / Please see Issue 25 as this relates to the
KIA_IR-26 Water Quality 6.7.9.5 Table 6.6-7/6.7-6 Seepage Criteria more discussion about Yes Sabina commits to provide further rationale and methodology for criteria selection during the water licensing process.
The KIA requests
Sabina’s definition of an "acceptable
distance" from the aqueous receiving
environment will be determined to
Vol. 2, Chapter 2, Sec. 9.2.1, Page 9- ensure CCME WQOs are met once runoff Sabina commits to developing a water and load balance that will be used to develop water management plans for all stages
of the project including construction, operation, closure and post-closure. This will be used to demonstrate that any
KIA_IR-27 Water Quality 2; Vol. 6, Chapter 6, Sec. 4.5.3.4 reaches the closest water body or water Yes discharge that runoff will comply with appropriate WQOs once it reaches the closest waterbody or watercourse. Locations
Page 4-49; Vol. 6 – Freshwater course. Specific locations for discharges
Environment to the tundra, along with rationale for for discharges to the tundra along with rationale for their selection will be provided. This information will be provided as part
of the FEIS.
those locations, and how CCME WQO will
be met between the discharge site and
Clarify
nearestthe TSS body,
water threshold,
should andbemitigation
provided
measures at that threshold. The KIA In the FEIS, Sabina commits to clarifying the TSS thresholds and mitigation measures to meet those limits as well as
Vol. 6, Chapter 2; Vol. 6, Chapter 5, as part of the FEIS.
KIA_IR-28 Water Quality Sec. 4.5.2.1, Page 4-43 would
The KIAalso like tothat
requests know the fate
Sabina of the
include Yes describing the fate of water removed from Llama Lake, Lytle Lake and Occurrence Lake as part of the site-wide water and
water
seepage removed
from the from
TIALlama Lake, Lytle
as a pathway load balance.
Lake and Occurrence
specifically highlightedLake. in addition to
runoff for pH,
Include the following nutrients, mine metals,
phases Cl in
and
the
CN freshwater
identified EMPsindicators,
in the FEIS, should monitor
or provide a
Vol. 6, Chapter 5, Sec. 4.5.1.1, Page convincing
for inputs via this pathway,
reason and should
for their non-inclusion: Sabina commits to including seepage from the TIA as a pathway for the freshwater water quality assessment chapter for the
KIA_IR-29 Water Quality 4-37, Table 4.5-3; Page 4-39, Table 1. present mitigation
Mine Waste Rockfor andreducing
Tailingsinputs
MP - add Yes
4.5-5, Table 4.5-6 FEIS.
due to seepage.
construction, andSabina
closure should
becauseupdatemine
the
rock,FEIS to highlight
which seepage from
may be potentially acidthe
TIA as a pathway (distinct
generating (PAG) will be used for from runoff),
and should include
construction and needs "seepageto befrom TIA" in
identified
the bulleted
and segregated list during
of activities under "Mine
construction, and
Vol. 10, Chapter 1, Overall Env. Mgt. Water Contact".
KIA_IR-30 Water Quality Plan Table 13.1, Page 16 tailings need to be managed during Yes Sabina commits to updating this table in the FEIS to reflect these recommendations.
closure.
2. Site Water Monitoring and
Management Plan – add Temporary
closure and Final Closure because water
Include
must bezooplankton
monitored and as part
managedof theduring
AEMP
Vol. 10, Chapter 19, Sec. 7, Table for the project.
temporary closure Care andwithfinalsampling
closure.and
KIA_IR-31 Water Quality No Please see extended response KIA-IR- 31.
7.2-2 and 7.2-3 analytical protocols
3. Fish Offsetting Plancan make
– add touse
Finalof
these
Closure, data.
as fish compensation must be
effective at closure.
Sabina address the potential seasonal The connectivity of Ponds B and C with waterbodies in the TIA footprint is irrelevant as fish do not inhabit these ponds and
Vol. 6, Sec. 7, Page 7-15; Appendix connectivity of ponds B and C with any barriers preclude fish from accessing this area. Extensive sampling determined that ponds and streams within and upstream
V6-6B - 2011 Fish and Fish Habitat ponds within the TIA footprint, and to of the Goose TIA footprint (including Ponds B and C) are non-fish bearing (see Figure 3.1-1 in Back River Project: 2013
KIA_IR-32 Fish and Fish Baseline Report; Vol. 10. CHA 21 No
Habitat provide information on how they plan on Freshwater Fish and Fish Habitat Baseline Report (Rescan 2014) which can be found as Appendix G in the Information
Draft Conceptual Fish Offsetting Plan determining the presence or absence of Response package, and in Rescan 2012, which can be found as Appendix V6-6B). This sub-watershed flows into Giraffe Lake,
page 2-18 fish within these ponds prior to project a known fish-bearing waterbody. A series of barriers and ephemeral flow patterns in Giraffe Inflow prevent upstream egress
construction. for fish in Giraffe Lake (Rescan 2014; see Appendix G in the Information Response package).
The
SabinaKIAusemakes
figurestheillustrating
following suggestions
creek cross
in order to
sections improve
under baselinethe document:
and projected
KIA_IR-33 Fish and Fish Vol. 6., Sec. 7, Pages 7-41 - 7-42; Vol. 1. For eachfor
scenarios wildlife
a range VEC,
of wetpleaseandintegrate
dry years Yes Sabina commits to use figures illustrating creek cross sections under baseline and projected scenarios for a range of wet and
Habitat 6. Appendix V6-1D information
The
would KIAaid in presented
wished thefor Sabina
review inofTable
to KIA-24 of
provide
potential dry years in the FEIS.
the Draft
measured, Clarification IR
impacts. rather than assumed, levels ofResponse
package,
the proportionwhichof presents
variousinformation
arsenic species on
the total high
comprising quality
total arsenichabitat lost, altered
in country foods
and
within disturbed.
the LSA, Please also consider
predictions for how the
Country Foods 2013 Report, Sec. total medium
proportion quality habitat
of arsenic species lost, altered,
will change
KIA_IR-34 New IR or Partially Please see expanded response KIA-IR-34.
5.2.2 and 7.3.4 duedisturbed
to project inactivities,
this rating,and as include
medium
quality
monitoring habitat
for still
changeshas value for these
in inorganic
species. This may
arsenic species in lead to changes
monitoring plans.in
magnitude
Please also ratings.
include more geographically
Vol. 5, Section 5.6.2.1, Section 2. For each
relevant andwildlife
up to dateVEC, references
please fineon tune
Terrestrial and 5.6.2.2 (whole section), Section the methodology
arsenic in this section.such that the
KIA_CR-1 Marine 5.6.4.1 (Comments apply to all definitions for magnitude, and duration Partially Please see expanded response KIA-CR-1.
Wildlife relevant sections for other wildlife are justifiable for each wildlife VEC based
VECs as well) on species life-history traits and
population biology, including lifespan,
population variance (derived from studies
Terrestrial and with high power), and breeding
Vol. 5, Table 5.6-8, Section 5.8, Page See rationale and recommendation for
frequency.
KIA_CR-2 Marine 5-147 IssueKIA1 feels that with more Partially Please see expanded response KIA-CR-1.
Wildlife The
consideration of the totals provided in
KIA-24, more consideration of effects that
act in tandem among species, inclusion of
moderate quality habitat, and creation of
species-specific magnitude and duration 3
terms, some of the total effect ratings for
terrestrial and marine wildlife VECs may
 October 30, 2014 Response to Technical Comments - Sabina Gold Silver Corp. Back River Project

Subject
TC Number Area Reference Reviewer Recommendation Agree with TC Sabina Response

Terrestrial and
KIA_CR-3 Marine Vol. 5, Section 7.6.5, Table 7.6-4, See rationale and recommendation for Partially Please see expanded response KIA-CR-1.
Page 7-60 Issue 1
Wildlife

Terrestrial and
See rationale and recommendation for
KIA_CR-4 Marine Vol. 5, Section 8.5.2.2, Page 8-43 The
IssueKIA
1 would like to see a more Partially Please see expanded response KIA-CR-1.
Wildlife complete discussion about how effects The effects assessment and cumulative effects assessment for each wildlife VEC includes a literature review of primary and
may act synergistically or additively on industry reports (where available) that are used to define the potential effect and its likely effect on the VEC being discussed.
wildlife VECs for a more complete
consideration of total effects. Including The effects assessment evaluates each of the potential effects separately and then evaluates the potential for reduced
Terrestrial and evidence or lack of evidence of total reproductive productivity. This potential effect was included, because additive, synergistic effects are typically felt on
KIA_CR-5 Marine Vol. 5, Section 8.6.5, Table 8.6-7 effects on wildlife from other operating Yes reduced reproductive output. Where primary literature was available, or industry reports, that provide evidence of
Wildlife projects of a similar size and geographic synergistic effects on wildlife species, it was included in this section of the report. Additional text will be added to make this
The KIAKIA
extent,
1. The stillrequires
with requires a adescription
good statisticalconceptual
power, ofdesign
the connection between synergistic effects from the combination of effects and the likely effects on reproductive productivity.
for
wouldthehelp
foundation closure of thethe
to validate
beneath project
conclusions
TIA and with this that
information,
there will be which
embankments, noincludingcan bea used
significant impacts in the
description on of Sabina commits to adding additional references to monitoring programs from other, similar, operating projects in similar
environmental
wildlife,
the or theyassessment
permafrost mayice
and cause within
beconditions for thealong habitats to the discussion
Sabina commits of effects
to providing in the FEIS,
a conceptual designwhere additional
for the information
closure of the projectisthat
available.
can be used in the environmental
Geotechnical Volume 2, Section 8.8 and Volume 9, FEIS. As is, the full
reconsideration
with precedent of range
for this
lining of
thepotential
rating. entire basin.
KIA_CR-6 Engineering Section 2.16 impacts Yes assessment. The potential impacts of Closure effects will be identified and assessed within the FEIS.
Based oncannot
In the FEIS, the the be assessed
preliminary
KIA woulddesign based
like to see ondata
the
details
presented of
gaps identifiedthe
by thedesign
and provided
proponent,
mitigationthe for closure.
KIA
measures
The
would impacts
proposed liketo of
Sabina these
avoid to effects should
provide
uncertainties additional be
identified
details
associated andwithassessed
to ensure that the
potential within
tailings
liner the DEIS,
dam
cracks. The
or data
will
KIA will gaps
needidentified.
be designed with the
to review possibility
a more detailedof Sabina commits to optimizing the location and design of the TIA based on an alternatives assessment founded on
Geotechnical internal
description erosionof the caused by filter
TIA design and basin, environmental, technical, and economic reasons. In addition Sabina commits to providing a detailed summary of the
KIA_CR-7 Volume 9, Section 2.2 incompatible materials, Yes
Engineering and underlying context, whichas wellcouldas lead overburden and permafrost conditions for the TIA foundation with sufficient detail to justify and support the design. This
to piping andand
contingency other forms
hazard of internal in
considerations information will be provided in the FEIS.
erosion, in mind.
the Feasibility Study Theand proponent
the FEIS.may
need to provide information on the use
of "filter-compatible
2. The proposed location materials",
of the TIA whereby
is not
additional
ideal for the layers,
KIA, theof different particlefield
rugged boulder
Geotechnical Sabina commits
The current planstofor
completing
overburdenanddisposal
presenting all appropriate
assume geotechnical
that the overburden andbe
would hydrotechnical
encapsulatedanalysis of therock
in the waste TIA dumps
structure,
KIA_CR-8 Engineering Volume 9, Section 3.5.3 sizes,
is not are
ideal added in-betweenthe
for maintaining theintegrity
two main Yes including itswould
foundation in theSabina
FEIS. commits to further substantiating the waste rock closure design criteria and completing
layers. Failing toliner,
of geosynthetic include thesuch
KIA strongly where they be frozen.
considerations
recommends that carefully
Sabinamay result in
investigate a thermal analysis, inclusive of climate change considerations to demonstrate the viability of the plan. This information will
The
otherKIA
significant recommends
environmental
alternatives doing
(location anda sufficient
and social
design) be presented in the FEIS. Freezing is expected to eliminate the potential for seepage from the overburden materials.
number
impacts,
for the TIA.ofand SFE tests
may notsuchmeet thatthea required
normal
distribution
level due diligence curve ofinresulting
dam design. values can Nonetheless, the overburden is still considered to have a low potential for neutral metal leaching based on two lines of
Geotechnical be created,
Updated and so that
information onmean
the dam andand TIA evidence. First, all of the natural runoff and shallow groundwater associated with the active zone in the area is in contact
KIA_CR-9 Page 4-2-Vol 11(App1A to 4A) Partially
Engineering variance
design will levels can be predicted.
be included This will
in the Feasibility with overburden and there is no evidence of anomalous levels of metals. Second, the solid phase trace element analysis
allow
Study for
andproper
FEIS, which anticipation
will need andto be indicates that, with the exception of selenium, trace elements are not elevated in the overburden. The information provided
management
reviewed by the of effluent
KIA withfrom these in Page 4-2 Vol 11 (App 1a to 4a) indicating that Se levels were elevated with respect to three times crustal basalt and shale
The KIA would
overburden
considerations like
materials. the proponent
in mind, and will becommit abundances was somewhat misleading in that Se concentrations exceeded the basalt values (avg values of 0.05 ppm Se), but
to doingdiscussed
further this additional duringsampling
the final and not the shale values (avg values of 0.6 ppm Se). Shale is considered to be a more appropriate basis for comparison given that
testing,
technicaland would like a timeline the majority of the rocks
KIA_CR-10 Geotechnical Volume 2, Section 7, Volume 11, meetings.
Partially Sabina has completed theinadditional
the area are clasticand
sampling sediments, and based
testing work on provide
and can typical data for details
further shale, the overburden
on the programsamples
and the do
Engineering plans 16 & 22, Appendix V11-4A regarding when results are expected. The not show
results to any enrichment
KIA once in selenium concentrations.
data interpretation is complete. The results and interpretation will be included in the FEIS.
KIA would like to review the data
collection
The developer plan,should
results,provide
and conclusions
additional
of
andthis work. details on the water
consistent
management system and related
structures. The Proponent should ensure Sabina commits to providing additional justification for design criteria adopted for any water management structures.
KIA_CR-11 Water Quality Volume 10, Plan 7, Section 3 and that water management structures do Yes Furthermore, Sabina commits to completing and presenting all appropriate geotechnical and hydrotechnical analysis of
Volume 11, Appendix 4c. not result in permafrost degradation and water management structure in the FEIS.
related impacts. The KIA requests details
The
to beKIA would like
provided in theSabina
FEIS toforcommit
a full to
sorting
review. and using nPAG materials for
surface structures. Identifying additional In the FEIS, Sabina commits to identifying and quantifying geochemically suitable material that will be available for
Vol. 2, Chapter 2, Sect. 6.6.2.1, Page sources of construction material will be
KIA_CR-12 Water Quality 6-18 No construction. Details for specific locations, extraction and sorting methods will be provided as part of water licensing
an important consideration in the impact process.
assessment, and the KIA would like to
review the locations and
extraction/sorting methods in the FEIS. Traditional knowledge was reviewed for baseline and existing environment information from Section 8 in the Inuit Knowledge
Please provide an example of how this of Sabina Gold & Silver Corporation's Back River (Hannigayok) Project (Appendix V3-3A of the DEIS) summarizes Inuit
particular TK has been incorporated into
KIA_CR-13 Water Quality Vol. 6, Chapter 4, Sect. 4.2.4, Page 4- the effects assessment presented in the Yes observations regarding water quality in the Back River Project area. These water quality observations were applied in the
31 regional context of the baseline assessment, but the TK review identified no specific water quality information for
DEIS,
The KIAor would
removelike if this statement
for Sabina is
to provide, waterbodies in the immediate vicinity of the Project. In the FEIS, Sabina commits to revising the TK section in Chapter 4 of
incorrectly
and to review, incorporated.
more information and the DEIS to more accurately reflect the application of TK.
rationale (including conservative
assumptions about climate change, depth
of the active layer, ground heaving, etc) Sabina commits to further substantiating the waste rock and TIA closure design criteria and completing a thermal analysis,
Vol 10, Chapter 7 to 10, Sect. 3.7.4,
KIA_CR-14 Water Quality Page 35 used for the selection of cap depths in Yes inclusive of climate change considerations to demonstrate the viability of the plan. This information will be presented in the
the FEIS. As stewards of the land, the KIA FEIS.
requires assurance of WRSA and TIA
security into the far future. Please also
note the Recommendation(s) listed under
Issue 7 (TIA Design and Location) above.
4
 October 30, 2014 Response to Technical Comments - Sabina Gold Silver Corp. Back River Project

Subject
TC Number Area Reference Reviewer Recommendation Agree with TC Sabina Response
The KIA requests that Sabina include the
monitoring of dust and its associated
contaminants deposited on and within Potential influence of dust on surface water quality is currently included in the AEMP in a number of ways. Dust that falls on
the snowpack during the winter months will become a part of the snowmelt which will enter surface waters, and this water is
KIA_CR-15 Water Quality Vol 10, Chapter 19 the snowpack as part of the AEMP. No directly measured as part of spring freshet sampling. During the open-water season, any influence of dust on surface waters
Identification of pathways contributing to
contaminants within water will increase will also be directly measured by surface water sampling. There is also an Air Quality Monitoring Program (see Volume 10,
Chapter 17 of the DEIS) that will be in place to monitor dust.
the ability to anticipate and adaptively
manage aquatic contaminant loading.
Please modify the language in the FEIS to
clearly reflect that water quality in the
KIA_CR-16 Water Quality N/A TIA will be monitored until these Yes Sabina commits to monitoring TIA water quality until the WQO's are met.
aforementioned objectives are met.
It is important to the KIA that any
potential impacts on fisheries
productivity of Umwelt Lake following Sabina commits to including additional details in the FEIS. As part of ongoing feasibility studies, the water balance is being
Vol 6. Section 1-46, Vol 6. Appendix
KIA_CR-17 Fish and Fish V6-1C, Vol 6. Section 7.5.2.1, Page 7- water withdrawal be fully understood to Yes refined, and final details will be included in the FEIS. The updated water balance will be used to provide additional details on
Habitat ensure that we have a complete picture the Umwelt Lake and outflow system in the FEIS. If an updated effects assessment indicates residual effects, then mitigation
37 of the potential impacts from the project. measures such as offsetting will be considered in collaboration with DFO and the KIA.
The
In KIAFEIS,
the wouldthelike
KIA the aforementioned
would like Sabina to
details clarified aorsecond
clarify whether addressed
yearinofthe
fishFEIS.
sampling in Giraffe Lake was, or will be, Sabina commits to conducting a second year of baseline fish sampling in Giraffe Lake if this lake remains a potential receiving
Fish and Fish completed and will be included in the environment. Sabina will make this information available in the FEIS or prior to the final technical review.
KIA_CR-18 Habitat Vol. 5, Section 5.6.3 FEIS for review. If not, please indicate Partially
whether Sabina has plans to complete an
additional sampling survey
The KIA recommends if thismethods
repeating lake in
the near
from 2013 future.
for a second year, such that
data from both years can be analyzed Additional work has been completed on the Rascal-Goose Stream and potential diversion work, and has been submitted to
Fish and Fish Vol 10, Chapter 21, Draft Conceptual DFO as part of the Site Preparation Package. A stand-alone report on the Rascal Realignment work (including all information
KIA_CR-19 Fish Offsetting Plan, Page 2-18, Vol. together, providing information on inter- Yes
Habitat 6, Section 7, Page 7-6. year variability. Please provide relating to hydrology, fish habitat and fish populations) is included as Appendix DFO-1: Fisheries Assessment of Rascal Stream
The Proponent
information is requested
regarding plans toforamend the
additional Re-alignment, Back River Project (Rescan 2014) to this Technical Response package.
legislative or
sampling, requirement sectionfor
justify the reason of the
only
OPEP,
one year as they
of datamust comply with section
collection.
168 (1) (b) (iii) of the CSA, 2001. The
Proponent is to include a list of all Sabina commits to amending the legislative requirement section of the OPEP to comply with section 168 (1) (b) (iii) of the
Volume 10, Page 1, Section 1, employees authorized to implement the
TC-1 Marine Safety Introduction OPEP and their contact information, on Yes CSA, 2001. Sabina will include a list of all employees authorized to implement the OPEP and their contact information, on the
Oil Handling Facility Declaration. It should be noted that any list of authorized employees would be initial in detail as Sabina
1.1 Legislative Requirement the Oil Handling Facility Declaration. will not have all relevant positions hired. All requested information will be included in the FEIS.
The Proponent
Transport Canada is required
requires to provide
that the
details
Proponent on the Accommodation
provide an updated Barge
and and
compliance
compliant OPEP withprior
regulatory
to the
requirements.
commencement Details
of theare to include the
Project.
type of vessels involved, intended
DEIS Volume 2 purpose, pollution prevention and For the FEIS, Sabina will provide details on any accommodation barge or overwintering fuel vessel proposed for use. This will
TC-2 Marine Safety Appendix V2-4A Transportation Yes address compliance with regulatory requirements and include information on the type of vessels involved, operations plan,
Study, Page 10,Timelines response measures and planned mooring and risk assessment.
arrangements. The Proponent is required
to provide their operations plan and risk
assessment for overwintering of a fuel
vessel. The risk is
The Proponent assessment
advised tomustreviewbethe
DEIS Volume 2 specific to the overwintering location.
TC-3 Marine Safety Appendix V2-4A Transportation above regulatory requirements Yes Sabina commits to reviewing, for the FEIS, the stated regulatory requirements specific to choice of route and vessels.
applicable in regards to choice of route
Study, Page 9 and vessels.