Highbank’s Swamp Point North Aggregate Project NoW Application

Highbank Resources Ltd.

Swamp Point North Aggregate Project
Notice of Work Application

October 29, 2013

SUITE 205 - 750 WEST PENDER STREET, VANCOUVER, BRITISH COLUMBIA, CANADA V6C 1G8
Telephone (1) (604) 647 6463 Fax (1) (604) 647 6455

Page
Table of Contents

1.0

EXECUTIVE SUMMARY ...........................................................................................1

2.0

INTRODUCTION .........................................................................................................2

3.0

LAND USE.....................................................................................................................3

4.0

CULTURAL HERITAGE RESOURCES AND FIRST NATIONS
ENGAGEMENT ...........................................................................................................3
4.1
ARCHAEOLOGICAL OVERVIEW ASSESSMENT ...............................................3
4.2
FIRST NATION ENGAGEMENT .............................................................................3

5.0
BARGE LANDING AND FORESHORE DEVELOPMENT...................................4
5.1
BARGE LOAD-OUT .................................................................................................4
5.2
CONSTRUCTION AND OPERATIONS EQUIPMENT AND
SUPPLIES ACCESS...................................................................................................5
5.3
FISHERIES AND OCEANS CANADA (DFO) AUTHORIZATION.......................5
5.4
NAVIGABLE WATERS ............................................................................................6
6.0
MINE PLAN ..................................................................................................................7
6.1
MINE CROSS-SECTIONS AND PLANS .................................................................7
6.2
DISTURBED AREA PROJECTIONS .......................................................................7
6.3
MINING ......................................................................................................................7
6.3.1
Site Roads and Ditches........................................................................................7
6.3.2
Clearing, Stripping and Soil Stockpiling ............................................................8
6.3.3
Production Methods and Development Plan .......................................................8
7.0

CRUSHING, SCREENING AND WASH PLANT (CSWP) .....................................9

8.0
WATER MANAGEMENT ........................................................................................10
8.1
WATER BALANCE.................................................................................................11
9.0

CAMP AND SAFETY PROVISIONS ......................................................................13

10.0

SURFACE EROSION PREVENTION AND SEDIMENT
CONTROL ..................................................................................................................13

11.0

RECLAMATION PLAN ............................................................................................15

12.0

MANAGEMENT SYSTEM AND PLANS ...............................................................16

13.0

OTHER PERMIT REQUIREMENTS .....................................................................17

14.0

REFERENCES ............................................................................................................18

ii

Page

List of Tables
Table 11.1 Reclamation Cost Estimate .....................................................................................16
List of Figures
Figure 2.1 Project Location .........................................................................................................2
Figure 5.1 Supply and Equipment Landing Ramp ......................................................................5
Figure 6.1 Typical Road and Ditch Cross-Section* ...................................................................8
Figure 8.1 Water Balance ..........................................................................................................12
Figure 10.1 Settling Pond at Barge Load-out ...........................................................................14
Figure 10.2 Erosion Control Features Map ...............................................................................15
Drawings
Project Location
DRAWING 1 Site Location and General Arrangement at Closure
DRAWING 2 Sections A, B and C
DRAWING 3 Sections D, E and LL
DRAWING 4 Mine Workings Year 1
Process Plant General Arrangement Layout

iii

Page
Appendices
APPENDIX 1 Archaeology Reconnaissance Study
APPENDIX 2 Nisga’a Correspondence
APPENDIX 3 Management Plans
EHSMS – Environmental, Health & Safety Management System
A - Occupational Health and Safety Plan
B – Mine Emergency Response Plan
C – Sediment and Erosion Control Plan
D – Hazardous Materials Handling Plan
E – Fuel Management and Spill Contingency Plan
F – Water Management Plan
G – Waste Management Plan
H – Reclamation Plan
I – Road Design
J – Mine Development Plan
K – Traffic Plan
L – Invasive Species Management Plan
M – Barge Load-out and Marine Safety Plan
N – Chance Find Procedure
O – Wildlife Management Plan
APPENDIX 4 Notice of Work Application Form

iv

1.0

EXECUTIVE SUMMARY

Highbank Resources Ltd. (Highbank) is proposing to develop the Swamp Point North
Aggregate project located on the east side of the Portland Canal, approximately 65 km south
of Stewart, BC. The small aggregate operation will seasonally produce 235,000 t/y over a
five year mine life. A 200 t/h capacity crushing, screening and wash plant will be
constructed to wash product, or product will be shipped out as run-of-mine without washing.
The product will be transferred via an upgraded existing road to a conveyor and barge loadout facility at the existing barge landing site.
The Project includes the following components:
•
•
•
•
•
•
•
•
•
•
•
•

Sand and gravel quarry
Crushing, screening, wash plant
Wash plant settling ponds
Topsoil and rejects stockpile
Camp
Generators
Upgraded onsite road
Laydown and product storage area
Fuel storage tanks
Conveyor
Barge load-out facility
Landing ramp

This report provides the project design and development details and management plans to
support this BC Mine Act, Notice of Work application.

1

2.0

INTRODUCTION

The Swamp Point North Aggregate / Portland Canal Aggregates property is located in
northwestern British Columbia ( on the east side of the Portland Canal, immediately north of
Swamp Point and the mouth of Donahue Creek (see Figure 2.1 and Location Map in the
drawings at the end of this report). The property consists of a 51.3 ha uplands Licence of
Occupation (#636317, expiry March 5, 2017) and a 7 ha foreshore Licence of Occupation
(#636316, expiry March 5, 2017). Drawing 1 (at the end of this document) shows the outline
of the licence areas.
Figure 2.1
Project Location

This report provides all necessary details to support the Notice of Work Application in
response to the deficiencies letter from the Ministry of Energy and Mines as noted in the
March 15, 2013 report from Jill Pardoe, P.Geo, Sr. Inspector, Permitting. This current
document provides updated designs and additional details that supersedes all previous project
development designs.

2

The Swamp Point North Aggregate Project is described as a glacial outwash complex.
Drilling, test pitting and computer modelling completed by Associated Geosciences in 2007
has shown the glacial outwash unit to range in thickness from 2 m to 90 m with an average
thickness of about 37 m. Drill logs and sampling analyses indicate that this unit is composed
primarily of gravel and sand, with minor amounts of silt, clay, and water-bearing layers.
3.0

LAND USE

Highbank’s Swamp Point North Aggregate project is located north of Donahue Creek. The
Swamp Point aggregates mine property, owned by Ascot Resources Ltd., was partially
constructed in 2007 and 2008 and shipped approximately 145,000 t of aggregate by barge in
2007. The Ascot property is located at Swamp Point south of Donahue Creek.
The Swamp Point North Aggregate project area was previously logged. Harvested logs were
transported offsite using the small gravel road and barge landing.
In 2005 and 2006, Portland Canal Aggregates Corporation completed an aggregate
exploration program on the property. There have been no other industrial uses at the site.

4.0
4.1

CULTURAL HERITAGE RESOURCES AND FIRST NATIONS
ENGAGEMENT

ARCHAEOLOGICAL OVERVIEW ASSESSMENT

An archaeological Preliminary Field Reconnaissance was completed in July 2013 by Kleanza
Consulting Ltd. The July 26th site visit conducted by Stephanie Huddlestan (Kleanza, Field
Director), Colleen Wesley (Metlakatla representative), Anthony Moore (Nisga’a
representative), Gary Musil (Highbank Resources) and Jim Place (Highbank Resources).
No archaeological materials, features or areas of archaeological potential were observed
during the Preliminary Field Reconnaissance and the site was deemed to have low
archaeological potential. The full report is included in Appendix 1.
No further surveys or monitoring were recommended; however, a chance find procedure is
required for the Licence of Occupation and is included in the management procedures in
Appendix 3.
4.2

FIRST NATION ENGAGEMENT

Highbank Resources Ltd., the operating company for Portland Canal Aggregates
Corporation, signed a Co-operation Agreement on November 5, 2012 with the Metlakatla
First Nation and the Metlakatla Development Corporation in the development of the Swamp
Point North Aggregate project.

3

The Agreement provided the Metlakatla with the opportunity to participate in the economic
benefits arising from the development of the property within their traditional territory. In the
Agreement, the Metlakatla undertakes and do not object or oppose regulatory applications or
approvals, Federal or Provincial sought by Highbank with respect to the Swamp Point North
Aggregate operations.
The other First Nations in the Swamp Point North area who have aboriginal rights for
hunting and fishing, are the Nisga’a. Discussions have been taking place over the years to
ensure they are fully aware of the plans for development of the area. A larger production rate
project was discussed with the Nisga’a in 2007.
The most recent correspondence with the Nisga’a regarding the current project plans were in
relation to the recent renewal for the Licence of Occupation, which outlined the development
plans for the small quarry operation presented in this Notice of Work application. The
Nisga’a issued a letter on August 2, 2013 listing their concerns regarding the current
proposed development plan, to which Highbank responded. Copies of these letters are
included in Appendix 2.
5.0
5.1

BARGE LANDING AND FORESHORE DEVELOPMENT

BARGE LOAD-OUT

The barge load-out has been designed by other consultants in consultation with Highbank.
The facility will consist of a shore located hopper into which the material will be placed by
front-end loader. From the hopper the conveyor will run over water for approximately 69
metres to the discharge point which will dump through a retractable, flexible chute. The
conveyor will be covered with hemispherical covers to prevent dust losses and have a solid
apron to collect any spillage. Any accumulated spillage will be reclaimed onto the conveyor,
as required. The conveyor system will be equipped with an emergency trip cord and guarded
in accordance with the latest safety regulations.
Barges of up to 5,000 tonne capacity will be positioned alongside five strategically placed
mooring dolphins using tugs and at a sufficient depth to accommodate all tidal fluctuations.
Empty barges will be positioned at the same time as the loaded barges are removed for
transportation. Barges to be loaded will be winched between five dolphins during loading to
ensure uniform distribution of the product. Barge loading and unloading will not proceed if
weather conditions preclude safe operations. Highbank and contract personnel will be
trained in all aspects of docking procedures for loading gravel.
The barge load-out area will be provisioned with life buoys, crew flotation vests, life
preserver rings, poles and ropes for rescuing anyone who is working near water and be in
compliance with Part 3.3.3 of the BC Health, Safety and Reclamation Code (HSRC). Spill
kits will also be provided.
Signs indicating restricted public access and associated hazards will be posted.

4

5.2

CONSTRUCTION AND OPERATIONS EQUIPMENT AND SUPPLIES
ACCESS

Construction and operations equipment and supplies will be brought in using landing craft or
small ramp barges and tugs. A small spur road and ramp will be constructed off the existing
road at an angle that allows craft to be manoeuvred into position for loading and unloading
(Figure 5.1). A spill kit will be located adjacent to this ramp.
Fuel (diesel) and fluids will be transported by licensed operators who will comply with all
applicable Provincial and Federal fuel handling legislation and procedures for off-loading on
site. Fuel, lubricants, hydraulic fluids, food and water for the camp and all supplies will be
delivered mainly by boat transportation from Stewart or Prince Rupert, to the landing ramp.
“Hot shot” and other urgent deliveries may be transported by floatplane.
Figure 5.1
Supply and Equipment Landing Ramp

Landing ramp

5.3

FISHERIES AND OCEANS CANADA (DFO) AUTHORIZATION

The load out facility will include dolphins with pilings driven into the seabed and the landing
ramp will enter into the intertidal zone. Barge loading will occur offshore where it will not
disturb habitat and the conveyor will be designed to catch any conveyor spillage.
Pilings provide cover, additional substrate and increase the complexity of the marine habitat.
Overall, there is expected to be a net gain in fish habitat. Highbank has contacted DFO to
initiate project review and obtain a Habitat Alteration, Disruption or Destruction (HADD)
Authorization.

5

The landing ramp will be used only at sufficient tide heights that allow adequate depth for
loading and unloading of equipment and supplies with minimal impact to the intertidal zone.
5.4

NAVIGABLE WATERS

Highbank has contacted Navigable Waters Protection, Transport Canada to obtain
authorization for the proposed barge load-out facility. This type of facility has been
constructed for previous projects on the coast and no issues have been identified to date.

6

6.0

MINE PLAN

Mine design was completed by DMT Geosciences Ltd.
6.1

MINE CROSS-SECTIONS AND PLANS

The mine has been designed to extract approximately of 109,000 m3 (235,000 t) of run of
mine sand and gravel per year over the five year period covered by the Notice of Work.
Drawing 1 (included at the end of this report) shows the extent of mine workings after five
years, highlighting the sloped areas and the final benches. Drawings 2 and 3 show crosssections across and along the mine at each annual stage of development, and Drawings 4 to 8
show the extent of mining in annual increments.
6.2

DISTURBED AREA PROJECTIONS

The total area of disturbance is estimated at 6.6 ha. Existing disturbance of the camp and
road area estimated at 1.1 ha. The first year of operations is estimated to disturb 3.9 ha,
followed by 0.4 ha of new disturbance in each of the subsequent four years of operations.
6.3
6.3.1

MINING
Site Roads and Ditches

The existing access road from the foreshore barge load out site to the pit area, of
approximately 750 m, will be widened and re-habilitated to meet the BC Code for a truck
haul road. The width over the haul section will be increased to 7.8 m plus a roadside ditch.
Bank sloping will widen the road width, and a Code-compliant safety berm will be built on
the outside edge.
The haul road will exceed the guidance gradient of 5% given in the Health Safety and
Reclamation Code, and will therefore require run-out lanes. These are shown on Drawing 4
to 8 at the end of this report. The road will be surveyed as the project moves into
construction. Any design revisions to meet Code will be detailed at that time and as built
drawings will be kept on site and filed with BC Mines if and as required.
For approximately 250 m from the plant, the roadside ditch gradient will be about 12%. The
lower portion of the ditch, approximately 500 m, will have a gradient of 6%. As appropriate,
ditch erosion will be minimized with silt fences, straw bales, settling ponds, and possibly
heavy duty polyethylene sheeting held in place with wooden stakes on steeper sections.
Thousand-year return, maximum 24-hour precipitation at Stewart is 177 mm (Ascot, 2005).
The drainage area for the road ditch ranges from close to zero at the exit of the pit and wash
plant area to approximately 5.5 ha at tidewater. Maximum discharge therefore is estimated to
be 0.114 m3/s. The ditch will be constructed to pass 110% of peak flows (Figure 6.1).

7

Figure 6.1
Typical Road and Ditch Cross-Section*

*Note: Not to scale

6.3.2

Clearing, Stripping and Soil Stockpiling

Initial clearing will fell trees and brush, salvaging as much timber as possible. A Special Use
permit or Licence to Cut will be obtained from BC Ministry of Forests prior to any clearing.
Dozers and backhoes will be used to strip the cover soils and load trucks and move the cover
soils to the stockpile (location indicated in Drawing 1). The soil stockpile will be sloped and
seeded to prevent as much run-off as possible, although it will be added to as mining
progresses. As and when possible over the life of the mine, cover soil will be spread on the
cut slopes and the slopes seeded. Tree planting will wait until final closure.
The depth of stripping is expected to average less than 0.25 m across the site; drilling results
indicate very shallow cover soils. The cover soil volume anticipated totals about 14,000 bcm.
The stockpile as designed will accommodate 18,000 bcm.
6.3.3

Production Methods and Development Plan

The initial Year 1 pit will generate the largest disturbance because a combination of the pit
location and the rising topography requires a long back-slope to achieve the desired slope
gradients of 2H:1V (27°). This slope gradient will ensure permanent stability and eliminate
the need for re-sloping during reclamation. The back-slope ends within the northern limit of
the current licence area, which was the major factor in determining the location of the pit.
Vegetation will be removed 2 m back from the edge of excavations for safety.
The pit will be developed from the top down in 5 m high lifts with a 2H:1V back slope to the
east and day-lighting the bench to the west. A berm will be retained at the edge of the bench
to prevent debris from falling down the outside slope while machinery is working close to the
edge and subsequently removed and a new berm formed as each bench is taken down.
Mining excavations will be carried out by conventional mining equipment consisting of a
D9/D10 dozer, excavator, front-end loaders and 35/40 tonne rear dump trucks. A dozer will
grade the back-slope to the current bench where it will be lifted by the loaders in 2.5 m

8

flitches either into a truck or directly to the wash-plant hopper. The maximum height of any
vertical face will be 2.5 m. All mobile equipment will be locked out at the end of each shift.
As the working level descends, a 10 m wide haul road will be established at a gradient of
10% from the working level to the wash plant with a side safety berm to meet Code
requirements. Safety berms will also be constructed on each bench to a height of at least 1.5
times the radius of the largest tyre in use, on site. The relatively slow rate of production will
allow aggregate to be loaded directly by loader from the pit to the wash-plant hopper, or
taken by a single truck to a small stockpile for re-handling into the plant.
The western run-out lane will eventually be lost to the extraction in the later stages. In lieu
of a run-out lane, a median berm will be installed to provide for arresting of a truck in the
event of brake failure.
7.0

CRUSHING, SCREENING AND WASH PLANT (CSWP)

The installation of a crushing, triple deck screen and washing plant (CSWP) is proposed to
prepare saleable product from the mined aggregate. The CSWP is rated at 200 tonnes per
hour raw feed through the plant, estimated to produce 128 tonnes of gravel, 72 tonnes of sand
and silt per hour. Silt will be mixed with soil in the stockpile and used for reclamation.
The CSWP will be located on the 70 m bench along with the settling and clarification ponds,
which will supply the water required. Water pumped from sumps on the descending levels
will be pumped up to the settling pond. Portable pumps will be installed as required to
prevent any uncontrolled flooding. Some product may be shipped without washing if
sufficient water is unavailable during short periods of time and if acceptable to clients.
Product will be stored as it is produced at a stockpile adjacent to the barge load-out to
maintain adequate space around the plant.
The water balance calculated for the wash-plant (see subsequent section) shows that the raw
feed moisture into the plant plus a make-up of 3.3 m3/h equals the moisture shipped with the
product. The washing and screening process uses 17.9 m3/h of water and the settling and
clarification ponds will provide a residence time of more than 24 hours with the wash water
usage at a maximum, plus flood storage and freeboard.
A berm will be constructed around the stockpiled material such that any drainage will either
exfiltrate through the gravel or divert into the settling ponds.
A dedicated diesel generator will power the CSWP. All diesel storage will be in double
walled tanks within a bermed containment area and monitored daily for leakage. A spill kit
for handling any loss of diesel will be located adjacent to the tank and generator.
The mine and plant will operate in daylight hours only, up to 12 hours per day, 6 days per
week for up to eight months of the year. The camp facilities and fuel tanks will be drained
and mothballed during the winter months. Given the remote location and the fact that

9

nothing of value will remain at the camp, full-time security will not be provided, but ad hoc
inspections will be carried out.
8.0

WATER MANAGEMENT

Average annual precipitation in Stewart is 1867 mm (Canadian Climate Norms 1981-2010).
Thousand-year return period, maximum 24-hour precipitation at Stewart is 177 mm (Ascot,
2005).
A 2005/2006 exploration drilling program comprising 10 cored drill holes showed
groundwater present in all of the holes. Piezometers were also installed in some of the holes
to determine the ground water interface.
The working face of the gravel pit will no doubt have ground water seeps throughout the
excavation area and this water will be channeled through the work area into ad hoc sumps on
the pit floor. A drainage collection ditch and pond will be constructed at the 35 m elevation
to collect water that can be pumped up to the wash plant settling ponds for make-up water as
needed or drain downslope where it will be intercepted by the road ditch system. The water
collection ditch may be lined, would only need to be constructed once for all five years of pit
development and would provide an added buffer for stormwater runoff from the pit.
A ditch and collection pond will also be constructed on the west side of the road leading from
the camp to the wash plant. Collected water may be pumped to the wash plant settling ponds
for make-up water or exfiltrate from the pond.
No creeks will be diverted or used by the mine development.
Start-up and makeup water for the plant will be obtained from site runoff and groundwater
seeps collected in the ditches, collection ponds and wash plant settling ponds. Once the wash
plant is operating, the only water requirement will be that associated with the shipped
products, a net loss in the system of 3.3 m3/hr. If there is insufficient water for washing
operations then the plant will produce unwashed aggregate or be shut down until sufficient
quantities of water have been restored.
If dry screened product only is required then the wash plant settling ponds water will
overflow after clarification into the road drainage ditch. The washing and screening process
uses 17.9 m3/h of water and the settling and clarification ponds will provide a residence time
of more than 24 hours with the wash water usage at a maximum, plus flood storage and
freeboard.
The sediment control pond at the barge load-out will discharge to the environment. It is the
only proposed settling pond on the property that discharges to a water body with aquatic life.
Water contaminants associated with construction and operation of an aggregates operation
are generally restricted to suspended sediments assuming effective implementation of a

10

hydrocarbon spill prevention and response plan. Turbidity (<15 NTU) is proposed as the
monitoring parameter target to ensure compliance and protection of the receiving
environment. A Waste Management Act permit will be obtained for the project discharge.
Receiving water quality objectives, discharge criteria and a monitoring program are
presented in the Water Management Plan in Appendix 3.
It is proposed to use groundwater from the existing drill holes to provide a water supply for
camp water (toilets and showers).
8.1

WATER BALANCE

Figure 8.1 presents the site water balance. Wash water requirements are estimated at
17.9 m3/h with 2.1 m3/h makeup water expected to be collected from site runoff.

11

Figure 8.1
Water Balance

SWAMP POINT NORTH - WATER BALANCE
RUN OF PIT MATERIAL
205 Tonnes / Hr @ 5% moisture
Water 10.8 m3 / hr

JAW CRUSHER
Minus 50mm
Oversize
+300 mm

CONE CRUSHER
Wash Water
17.9 m3 /hr
TRIPLE DECK WASH SCREEN
COARSE
To barge loader AGGREGATE & CHIPS
+3.00 mm
128 tonnes / hr @ 5% H2 O

SAND
- 3.00 mm
72 tonnes / hr @ 9% H2 O

= 6.4 m3 /hr contained

Site Reclaim

= 6.5 m3 /hr contained

Stockpile Drainage

Stockpile Drainage

3

2.1 m / hr
PROCESS WATER POND FROM STOCKPILES
SPRAY WASH WATER
SITE WATER COLLECTION DITCHES + SILT @ 2.5 tph max

Re-cycle water

CLARIFICATION POND

vnb 20/08/2013 Rev 4
235,000 tpa

12

To barge loader

9.0

CAMP AND SAFETY PROVISIONS

During the initial preparation of the site, the old camp will be refurbished and established for
occupation. A dedicated generator will be provided, with a double lined fuel tank with
integral berm provided to eliminate any possibility of spillage. Propane will be used for
heating and cooking. Spill kits will be located at the camp. The camp will include a first aid
room and a first-aid trained worker will be present on site at all times that the camp is
occupied, following the Code.
A satellite phone will be provided for remote communication. Handheld radios will be used
for site communication and traffic control on site.
Camp water will be from the existing drill holes. In the initial construction period, potable
water may have to be shipped in by boat on a temporary basis until the site water supply is
operational. Grey-water and sewage will report to a septic tank and septic field.
Recyclable waste will be kept separate and periodically hauled off-site to recycling facilities.
Putrescible waste will be stored in wildlife-proof garbage bins and periodically hauled offsite to the landfill in Prince Rupert. Inert, non-recyclable waste will be disposed of in a small
landfill at the laydown area.
A suitable area for a heli-pad will be staked out and marked according to legislated
requirements and a helicopter operator contracted to provide emergency evacuation services
for medical emergencies. A boat capable of evacuating the entire complement of the camp
will be on stand-by at the barge load-out at all times that the camp is occupied.
Details of the Occupational Health and Safety Plan, Emergency Response Plan, Fuel
Management and Spill Contingency Plan, Traffic Plan and Barge Loadout and Marine Safety
Plan are presented in Appendix 3.

10.0

SURFACE EROSION PREVENTION AND SEDIMENT CONTROL

Initial work on the property will include road rehabilitation, including the provision of
drainage ditches and culverts required to control the flow of surface water and maintain road
surfaces. Silt fences and straw bales will be used to slow down the water flow in the ditches.
Settling ponds will be constructed in all locations at the termination of collection ditches,
with a two-cell settling pond (Figure 10.1) at the last ditch before entering the marine
environment.
The settling ponds associated with the plant site will be filled either from surface run-off or
through groundwater percolation. It will be necessary to have sufficient water in these ponds
at start-up, if washed gravel production is required. If dry screened product only is required
then the collection pond water will overflow after clarification into the road drainage ditch.

13

As a part of the normal site and plant maintenance, any accumulations of fine silt/sediment
will be regularly cleaned out of all settling and polishing ponds.
In addition to road rehabilitation, secondary growth logging, removal of scrub and removal
of the surface cover soils to a stockpile will be carried out. Erosion of the soil/overburden
stockpiles will be controlled by grading and sloping the stockpiled material to a 2H:1V (27°)
slope and seeding with grass. Run-off from the soil stockpile will flow to the established
drainage ditch to exfiltrate into the gravel substrate or the final settling pond.
The mine open cut has been designed so that the slope crest coincides with the crest of the
NW/SE ridgeline. The combination of topography and slope crest ensures that precipitation
will flow away from the cut naturally. Diversion ditches are, therefore, not expected to be
required, but if field conditions dictate, a perimeter ditch will be constructed, excavated in
sand and gravel and equipped with silt fences and straw bales to control water flow, as noted
above.
Each of the benches will be sloped into the cut face as they are developed so that no water
escapes the pit. Entrained water will flow to the south-east end of the pit where it will flow
into an ad hoc sump and exfiltrate into the gravel or be pumped as make-up water to the wash
plant ponds on the 70 m level.
A colluvial clay glacial till up to 2.0 m in thickness is found on the property in patches.
Moderately impervious, it may be used to line the diversion ditches, ponds and embankment
foundations.
Figure 10.1
Settling Pond at Barge Load-out

14

Figure 10.2
Erosion Control Features Map

11.0

RECLAMATION PLAN

The end land use objective is wildlife habitat and forestry. The existing forest is dominated
by Western Hemlock and Sitka Spruce.
A summary of reclamation plans and costs are presented below, with additional detail
presented in the management plans in Appendix 3.
At the end of mining, the wash plant and camp site facilities will be dismantled and removed
from site. Hazardous materials and residual fuels and tanks will be removed from site and
sold or transferred to other sites. Hazardous wastes and any contaminated soils will be
removed from site and disposed of at appropriate hazardous waste facilities. Existing heavy
equipment on site will be used for regrading slopes. Water management structures such as
culverts, ponds, and ditches will be removed, graded and revegetated to allow for long-term
stable drainage of the site.
15

Reclamation will comprise of the spreading of topsoil on cut slopes and benches, seeding
with an approved seed mix and tree planting (pre-mining species of Western Hemlock and
Sitka Spruce). As and when possible over the life of the mine, cover soil will be spread on
the cut slopes and the slopes seeded. Road and camp areas would be scarified and seeded to
grass with trees planted. An invasive species management plan is included in Appendix 3.
The five year mine development plan has been divided into yearly phases and a reclamation
cost estimated for each phase, as if the mine had to be reclaimed at that time is presented in
Table 11.1. The equipment on site will be used to reclaim the land and no additional
equipment will have to be brought in.
The total area required to be tree-planted is 5.5 ha. Targeting 1200 saplings/ha gives 6,600
saplings at about $0.90 including labour and accommodation costs (at the camp).
The processing facility, camp and mobile equipment will be moved off site. Demobilisation
costs are estimated at $25,000.
The total reclamation cost after five years, including de-mobilisation and a 15% contingency
is estimated at $75,000.
Table 11.1
Reclamation Cost Estimate

Area

Hectares
(approx)

Camp & Common Areas
Year 1 Disturbance
Year 2 Disturbance
Year 3 Disturbance
Year 4 Disturbance
Year 5 Disturbance

1.1
3.9
0.4
0.4
0.4
0.4

Reclaim to
Seed @
$5,000/ha
$5,500
$19,500
$2,000
$2,000
$2.000
$2,000

Sapling and
Labour

Cumulative
Total

1320
4680
480
480
480
480

$1,188
$4,212
$432
$432
$432
$432

$6,688
$30,400
$32,832
$35,264
$37,696
$40,128

$25,000
$9,770

Equipment Removal
15% Contingency

Trees

$65,128
$74,898

In the event of temporary shut-down, the site will be suspended by draining fuel tanks and
locking out all equipment and vehicles left on site. This will be the same procedure used
each year prior to winter.
12.0

MANAGEMENT SYSTEM AND PLANS

Appendix 3 includes the following management plans:

16

EHSMS Framework
I – Road Design
K – Traffic Plan
As much information as possible is included for this application; however, the plans will be
reviewed and updated as necessary as the project moves into construction. Highbank’s
objective for the overall project will maintained. The objective is to develop, operate and
close the operation in a safe, efficient manner that provides a favourable return to
shareholders, protects the environment, complies will all provincial and federal legislation
and benefits local First Nations and communities.
In general, the mine management procedures will follow the Aggregate Operators Best
Management Practices Handbook for BC (MEM, 2002).
13.0

OTHER PERMIT REQUIREMENTS

Highbank’s project is below the production threshold of 500,000 t/y and therefore it is not a
reviewable project under the BC Environmental Assessment Act.
Expected permit requirements based on the details of the proposed project described herein:
Ministry of Energy and Mines, Mines Act, Notice of Work (this application)
Navigable Waters Protection, Transport Canada Authorization
DFO Habitat Alteration, Disruption or Destruction (HADD) Authorization
Waste Management Act permit for surface water runoff, sediment control ponds
Ministry of Forests, Licence to Cut permit for timber clearing
Ministry of Environment, Waste Management permit for inert waste landfill
Health Permit for camp operations

17

Discussions have been initiated with some of these permitting agencies and will continue to
ensure all required permits are in place prior to construction.

14.0
Ascot

Resources Ltd.,
www.eao.bc.ca.

2005.

REFERENCES

Environmental

Assessment

Certificate

Application.

BC Ministry of Energy and Mines, 2002. Aggregate Operators Best Management Practices
Handbook for British Columbia. Volume 1, Introduction and Planning. Volume 2,
Best Management Practices. http://www.em.gov.bc.ca/ .

18

DRAWINGS
Project Location
DRAWING 1 Site Location and General Arrangement at Closure
DRAWING 2 Sections A, B and C
DRAWING 3 Sections D, E and LL
Process Plant General Arrangement Layout

Appendix 1
Archaeological Reconnaissance Study
Kleanza Consulting

Kleanza Consulting Ltd.
5520 Kleanza Drive,
Terrace, BC, V8G 0A7
Phone 250-638-8970
Fax 250-638-8940
August 16, 2013
Mr. Victor Bryant
President and CEO
Highbank Resources
#600- 625 Howe Street
Vancouver, BC, V6C 2T6

RE: Preliminary Field Reconnaissance of Portland Canal, Swamp Point
North, Proposed Aggregate Quarry
1.0 Introduction
This letter report presents the results of an archaeological Preliminary Field Reconnaissance (PFR) of the
Phase 1 development area for the proposed Swamp Point North aggregate project (the project area).
This PFR assessed the Phase 1 location specifically, and did not include survey of the larger License of
Occupation (LOC). Kleanza Consulting (Kleanza) completed this field reconnaissance, at the request of
Highbank Resources, on July 26th, 2013.
The project area lies within the traditional territory of the Nisga’a and Metlakatla First Nations.
The project area was examined by pedestrian reconnaissance. The objective of the PFR was to assess the
archaeological site potential of the project area, and to determine if the proposed developments
required further archaeological work in the form of an Archaeological Impact Assessment (AIA). The
Archaeological potential of the project area was evaluated based on a desktop review of the proposed
Phase 1 location and nearby region, as well as thorough observations made during the field
reconnaissance.
No archaeological materials, features or areas of archaeological potential were identified within the
project area. No further archaeological survey or monitoring work is recommended for the proposed
development area, provided the proponent does not significantly amend the development area
boundaries.

5520 Kleanza Drive | Terrace, BC | V8G 0A7 | t. 250.638.8970 | f. 250.638.8940 |e. amanda@kleanza.com

August 16, 2013


2.0 Archaeological Assessment and Review Process
The Archaeology Branch, Ministry of Forests, Lands and Natural Resource Operations, the provincial
government agent responsible for the management of archaeological sites in BC, has established an
Archaeological Impact Assessment (AIA) process for industry development and research proponents to
evaluate and mitigate the impacts to heritage resources (Archaeology Branch, 1998). There are three
main stages in the AIA process:
a) Overview: The overview is intended to identify areas of archaeological potential and is
generally a mapping exercise and desktop review of previous assessments for a proposed development
area. Sometimes a PFR, or reconnaissance level survey, is conducted to verify the validity of an
overview and from there recommendations are made with regard to further archaeological impact
assessment studies. This study constituted a PFR.
b) Impact Assessment: The AIA focuses on inventory, or identification and evaluation of
archaeological resources within a proposed development area. An AIA includes both PFR level survey,
subsurface shovel testing, and the sampling of trees conducted under a Section 14, Heritage Inspection
Permit, issued by the Archaeology Branch.
c) Impact Management or Mitigation: Impact management usually involves the reduction of
adverse impacts to archaeological sites as a result of development, and typically includes site protection
(avoidance) by project redesign. In rare cases, sites cannot be avoided and systematic data recovery or
site mitigation is conducted. All sites located in the province that pre-date AD 1846 are protected by the
Heritage Conservation Act (HCA), and can only be altered under a Section 12 Alteration Permit issued by
the Archaeology Branch (Archaeology Branch, 2009).

3.0 Project Area Background
The proposed Phase 1 development area is located on the eastern shore of the Portland Canal near
Swamp Point, approximately 35 km west of Kitsault, BC. Donahue Creek is located approximately 300 m
south of the project area (Photo 1, Figure 1). This PFR assessed the Phase 1 location specifically, and did
not include survey of the larger License of Occupation (LOC).


August 16, 2013


Photo 1: View north to the project area. Mouth of Donahue Creek flowing into the Portland Canal pictured in
foreground.

The project area lies at an elevation between 0 to 84 meters asl 1 and falls within the Coastal Western
Hemlock Biogeoclimatic Zone. Western hemlock, western red cedar and Sitka spruce trees are common
throughout the Costal Western Hemlock Zone (Egan 1999). Other trees include amabilis fir, yellow
cedar, Douglas fir, grand fir, lodgepole pine, black cottonwood, western white pine, big leaf maple and
red alder. The understory is characterized by a blanket of moss, interspersed with a variety of flowers,
fungi and shrubs.
The project area is located along the north coast of BC, and would have been affected by glacial and sealevel histories. The north coast of BC was beneath 1,500 - 2,000 m of glacial ice during the Late
Wisconsinan glacial maximum approximately 16,000 years ago. By 15,000 to 14,500 years ago,
deglaciation was occurring rapidly at the mouth of the Skeena River, as ice was broken up by rising sea
levels (Clague, 1985; Fladmark, 2001). It is generally accepted that the outer coast was essentially icefree and habitable by humans by about 13,000 years ago, with the Prince Rupert area being ice free by
sometime prior to approximately 12,700 +/- BP 2 (Clague, 1985; Fladmark, 2001).
Major sea level changes affected the coastal portions of BC following the last glaciations. A combination
of eustatic, isostatic, and tectonic factors has created complex, regionally specific sea level histories for
coastal regions (Clague et al., 1982). Immediately following deglaciation, relative sea levels were higher
than present levels in the north coast mainland region, and proceeded to fall, to reach close to modern
1
2

Above Sea Level
Before Present (1950)

August 16, 2013


levels around 8,000 BP (Clague et al., 1982). However, sea level and environmental stabilization of the
North Coast mainland region did not occur until approximately 5000 BP (Fladmark, 1975; 2001). This
history of changing sealevels indicates a possibility for raised shoreline archaeological sites within the
project area, in areas that are now above the current sea level.

3.1 Development
The proposed development consists of construction of an aggregate quarry. Anticipated impacts to the
project area include the mining of aggregate material utilizing dozers , excavators, dump trucks and
other heavy machinery.

4.0 Methodology
4.1 Background Review
Prior to the field visit, basic background information relating to the project area was reviewed. This
included a review of the Provincial Heritage Register, using the Remote Access to Archaeological Data
(RAAD) application, to determine if any previously recorded sites were located within or adjacent to the
project area. Topographic maps and development plans of the project area were also reviewed.

4.2 Field Methods
The field assessment was limited to a visual inspection of the project area to assess archaeological
potential. A crew of 3 people, spaced 10 to 20 m apart conducted judgmental pedestrian traverses
throughout the project area. Please see Figure 2 for the location of these transects. These transects
focused on terrain features associated with archaeological potential, such as streams, ridges, and breaks
in slope. Terrain features were examined for archaeological potential. The ground surface was
inspected for evidence of cultural materials or features, such as trails or cultural depressions. Mature
trees were examined for any evidence of cultural modification, such as bark-stripping, tool marks, or
test holes. Natural exposures, such as tree throws and road cutbanks, were examined for evidence of
buried cultural deposits.
The location of field traverses were marked on field maps and recorded by GPS track logs. Field notes
were kept, detailing the overall terrain, vegetation, and archaeological potential of the project area.
The project area was also viewed from a low-flying float plane to provide the crew with an overview of
terrain features.

5.0 Results
5.1 Background Review
Ethnographic Background
As previously stated, the project lies within the traditional territory of the Metlakatla First Nation (Coast
Tsimshian) and the Nisga’a Nation.

August 16, 2013


Detailed historical and ethnographic accounts of the Tsimshian can be found in Beynon (1941) Garfield
(1939), Duff (1964), and others, and are nicely summarized by Halpin & Seguin (1990).
The Tsimshian are geographically located on the northwest coast, along the Nass and Skeena Rivers, and
along the inlets and islands along the estuaries extending south to Milbanke Sound (Halpin & Seguin
1990).
The Nisga’a are culturally similar to the Tsimshian peoples; however, they are distinctive both
geographically and linguistically (Halpin & Seguin 1990). Located in the Nass valley, the Nisga’a are
geographically divided into the lower Nass (Gitkateen and Gitgigenik) and the upper Nass (Gitwunksithk
and Gitlakdamiks). The upper Nass groups traditionally moved downriver during peak eulachon fishing
times, usually in late winter or early spring (Halpin & Seguin 1990). The Nisga’a’s social organization is
based on four clans: wolf, raven, eagle, and killer whale. The Nisga’a of the upper Nass had more focus
on land mammal hunting than their coastal neighbours.
The Tsimshian and Nisga’a annual subsistence round has been well documented by Boas (1916) and
summarized by Halpin & Seguin (1990). Winter consisted of eulachon fishing along the Nass and Skeena
Rivers with the remainder of the winter spent in the winter villages along the coast (Halpin & Seguin
1990). In the springtime, people gathered seaweed, halibut, herring eggs, cedar bark, and the inner
cambium of several trees species (hemlock, spruce, and lodgepole pine). In early June, the eggs of
seagulls and oyster catchers were gathered, and abalone was gathered from the beaches at lower tides
(Halpin & Seguin 1990). Salmon were gathered and processed at traditional fishing sites where seasonal
camps were maintained. Women harvested berries and crabapples, and cranberries were stored for
later use in the fall (Halpin & Seguin 1990). Various roots and shoots were also collected for
consumption during the summer months. In the early fall, people concentrated on the collection and
preservation of salmon, which was smoked and dried in great quantities (Halpin & Seguin 1990). After
the salmon season, the hunting of other large game and sea mammals was undertaken. Shellfish was
also collected and consumed throughout the winter months (Halpin & Seguin 1990).
A majority of the material culture used by the Tsimshian and Nisga’a was made of organic materials that
does not preserve well in inland archaeological sites, such as bone, antler, shell, and wood. In a boreal
forest environment with acidic soils, bone preservation is generally poor, and only the burning of bones
in a campfire or deposition within a matrix of shell aids in its preservation. Therefore, archaeological site
visibility in the northwest coast region largely depends on the accumulation of lithic materials from
stone tool use, or the remains of other physical features such as noticeable depressions in the ground,
trails, CMTs, petroforms, and rock art sites. The greatest concentration of lithics result from butchering
and processing of fish, meat, and hides in proximity to habitation structures at major camps, whereas
the procurement of plant resources, smaller mammals and birds, or kill sites of individual large game
animals leave little to no archaeological evidence. Round pits excavated into the ground for storage, also
referred to as cache pits, and were often located in the vicinity of fishing villages. These pits were used
to store large quantities of salmon and other foods for later use during the winter. Over time large
accumulations of shell and bone often formed on coastal village sites, known as shell middens. These
middens are still visible today, and are an important identifier of habitation sites along the coast.

August 16, 2013


Archaeological Background
According to the Provincial Heritage Register (accessed via Remote Access to Archaeological Data) there
is one previously recorded site within approximately 5 km of the project area (Figure 1). GjTm-1 is
located approximately 5 km north of the project area, and consists of 90 Culturally Modified Trees
(CMTs), including 2 aboriginally logged stumps, 70 tapered bark-stripped CMTs, 7 rectangular barkstripped CMTs and 11 girdled bark-stripped CMTs (Cooper et al. 2004). GjTm-1 was recorded by
Millennia Research Ltd., during an archaeological assessment of a proposed forestry block.
Expected archaeological site types within the project area included pre-contact CMTs, sub-surface
deposits and raised beach or shell midden sites.

5.2 Field Reconnaissance Results
The PFR was conducted on July 26th by Stephanie Huddlestan (Kleanza, Field Director), Colleen Wesley
(Metlakatla representative) and Anthony Moore (Nisga’a representative). Gary Musil (Highbank
Resources) and Jim Place (Highbank Resources) also accompanied the crew during the PFR.
5.2.1 Project Area Description
An old access/logging road connects the beach to the project area. It is still in good condition but has
aspens overgrowing on both sides.
The southern and eastern portion of the development area is gently undulating, with an overall aspect
toward the west. Areas of poorly drained ground are located throughout the project area. A road cutbank exposure was examined, and displays stratigraphy consisting of a thin humic layer (dark brown
organic silt) underlain by a mixture of light brown sand and poorly sorted rounded to sub-rounded
gravels, pebbles, cobbles and boulders ( Photo 2). The vegetation observed from this portion of the
survey consist primarily of hemlock with very few standing cedars. The understory is dense consisting of
aspen, blueberry, huckleberry, false azalea and a variety of fern species (Photo 3). Skunk cabbage and
sphagnum moss are also present within the poorly drained areas.


August 16, 2013


Photo 2: Example of exposed stratigraphy examined in the road cut-bank

The vegetation and terrain remained the same throughout the northern and western portion of the
development area. Geotechnical test pits excavated during 2007-08 were also identified during the
survey. Evidence of recent and historic logging is present throughout the project area including chainsaw
cut logs and stumps.
The western portion of the development area is located on steep side slopes (<30%). Hemlock is the
dominant tree species along the side slopes.
No archaeological materials, features or areas of archaeological potential were observed during the PFR.

Photo 3: Typical vegetation within the project area

August 16, 2013


5.2.2 Potential Assessment
The project area is considered to have low archaeological potential, due to the terrain being relatively
featureless and undulating, or steeply sloping and/or poorly drained. No landforms with the potential to
contain subsurface sites were identified. The project area has low potential for pre-1846 AD CMTs due
to the lack of mature cedar trees, and the extent of historical-era and recent logging activity.

6.0 Recommendations and Further Work
No areas of archaeological potential, or any archaeological materials or features, were identified within
the project area. It is considered unlikely that undiscovered subsurface materials are present in this
area. No further archaeological survey or monitoring work is recommended for the proposed project
area, provided the proponent does not significantly amend the development area boundaries of the
Phase 1 development.
If future phases of development are proposed outside of Phase 1, we also recommend conducting an
additional PFR of these areas.
Additionally it is recommended that the proponent:
Discuss with the involved First Nations any management concerns they may have in regards to
the proposed development area; and,
Recognize the possibility that additional, unidentified cultural heritage resources might be
present in portions of the project area that were not traversed on-the-ground.

7.0 Unanticipated Cultural Materials and Study Limitations
Every attempt was made to locate and record all archaeological sites within the development area
boundaries; however, the possibility exists that some cultural materials or features may have been
missed. If any unidentified archaeological or cultural heritage resources are encountered during
construction, work in the nearby vicinity should stop and the Archaeology Branch, the Ministry of
Forests, lands and Natural resource Operations, and a qualified archaeologist should be informed.

8.0 Closure
This report was prepared for use by the proponent specified herein. Any third party use of this report is
the responsibility of that third party. This study does not constitute a traditional use study, and was
prepared without prejudice to First Nations Treaty Negotiations, aboriginal rights or aboriginal title.


August 16, 2013


Signed by:

Amanda Palmer, M.A., Operations Manager

References
Archaeology Branch (1998). Archaeological Impact Assessment Guidelines. On file with the Ministry of
Forests, Lands and Natural Resource Operations , BC From
http://www.tca.gov.bc.ca/archaeology/docs/impact_assessment_guidelines/index.htm
Archaeology Branch (2009). Heritage Conservation Act (RSBC 1996): Chapter 187. On file with the
Ministry of Forests, Lands and Natural Resource Operations. Victoria, BC. From
http://www.bclaws.ca/Recon/document/freeside/--%20H%20-/Heritage%20Conservation%20Act%20%20RSBC%201996%20%20c.%20187/00_96187_01.xml
Boas, F. (1916). Tsimshian Mythology. Based on texts recorded by Henry w. Tate. Pp 29-1037 in 31st
Annual Report of the Bureau of American Ethnology for the Years 1909-1910. Washington.
Beynon, W. (1941). Tsimshians of Metlakatla, Alaska. American Anthropologist 43(1): 83-88.
Clague, J.J., J.R. Harper, R.J. Hebda, and D.E. Howes (1982). Late Quaternary sea levels and crustal
movements, coastal British Columbia. Canadian Journal of Earth Sciences, 19: 597-618.
Clague, J.J. (1985). Deglaciation of the Prince Rupert – Kitimat area, British Columbia. Canadian Journal
of Earth Sciences, 22: 256-265.
Cooper, D., J. Lindeberg, D. Owens and M. Eldridge. (2004) North Coast Forest District, Archaeological
Impact Assessments Conducted Under Permit 2002-294, Final Report of the 2002-2003 Field Season.
Unpublished repot on file with the Archaeology Branch, Ministry of Forests, Lands and Natural Resource
Operations, Victoria, BC
Duff, W. (1964). The Indian History of British Columbia. Vol. 1: The Impact of the White Man.
Anthropology in British Columbia. Memoirs 5. Victoria.
Egan, B. 1999 The Ecology of the Coast Western Hemlock Zone, Ministry of Forests, B.C.


August 16, 2013


Fladmark, K. (1975). A Paleoecological Model for Northwest Coast Prehistory. Mercury Series, Paper 43,
Archaeological Survey of Canada. Ottawa: National Museum of Man.
Fladmark, K. (2001). From Land to Sea: Late Quaternary Environments of the Northern Northwest Coast.
In Perspectives on Northern Northwest Coast Prehistory, edited by Jerome S. Cybulski. Hull: Canadian
Museum of Civilization, Archaeological Survey of Canada, Mercury Series Paper 160, pp. 25-47.
Garfield, V. (1939). Tsimshian Clan and Society. University of Washington Publications in Anthropology,
7(3): 167-340. Seattle.
Halpin M. & M. Seguin (1990). Tsimshian Peoples: Southern Tsimshian, Coast Tsimshian, Nishga, and
Gitksan. In, Handbook of North American Indians, edited by Wayne Suttles, Volume 7, Northwest Coast,
pp. 267-284. Washington: Smithsonian Institution.


hu
na

D

o

Surface Tenure
LOC# 635857

e

C

re

ek

^ GjTm-1

Foreshore Licence
LOC# 635856
Swamp
Point

P
or
tl
an
d
C
an
al
ek
re
C
o

n

Portland Canal
be

rs

Figure 1
Archaeological Sites

R

^

P ro j ec t A re a
Lo c a ti o n

o

.

Bonanza
Lake

5520 Kleanza Drive
Terrace, BC V8G 0A7

0

0.5

1

1.5

2

2.5

Kilometers

1:50,000
W:esridatadkmKleanzaPortland_CanalPortland_Canal_Fig1.mxd

Maple
Point

434500

6149500

434000

6150000

6150000

433500

6149500

433000

6149000

6149000

Surface Tenure
LOC# 635857

6148500

6148500

Foreshore Licence
LOC# 635856

.

P ro j ec t A re a
Lo c a ti o n
Portland Canal

6148000

6148000

Swamp
Point

Figure 2
Survey Transect Centre
Licence of Occupation
Phase 1 Development

5520 Kleanza Drive
Terrace, BC V8G 0A7

100

200

300

400

500

Meters

6147500

6147500

0

1:10,000
W:esridatadkmKleanzaPortland_CanalPortland_Canal_Fig2.mxd

433000

433500

434000

434500

Appendix 2
Nisga’a Correspondence

Highbank Resources Ltd.
#600 – 625 Howe Street
Vancouver, B.C. V6C 2T6
Ph: (604) 683-6648
Fax: (604) 683-1350
E-Mail: highbank@telus.net
www.highbankresources.com

Your ref: Nisga’a Lisims, letter dated August 2nd 2013

Dear Mr. Kiiskila,
This letter is in response to your August 2, 2013 letter from Collier Azak, CEO of the
Nisga’a Lisims Government.
For clarification, the original application for the Amended Licence of Occupation was at a time
when Highbank Resources Ltd. was considering an alternative loadout location, approximately 1.5 km
to the North of that proposed in the approved 51 ha Licence of Occupation area and included a larger
area of sand and gravel extraction. The current application is to expand the Licence of Occupation area
for the purposes of sand and gravel exploration. The currently proposed sand and gravel mining is only
for a small portion of the deposit located in the existing licence area and uses the existing loadout and
camp location.
Further to this clarification, the Nisga’a Lisims Government concerns and questions are
addressed as follows:
1) The expanded LOA application will be for sand and gravel exploration. All extraction and
loading will take place within the licenced 51 ha area.
2) No new roads, camps or other construction activity will take place in the expanded area at this
time.
3) It is expected that the validity of the approved application will be for the usual 5 years. A new
licence and consultation would need to take place prior to any sand and gravel extraction in the
new area.
4) The baseline studies in 2007 produced an ecosystem map and included a bird survey that
confirmed the presence of Marbled Murrelet in the Donahue Creek estuary and oceanfront and
indicated that they likely breed in the region (electronic copy of report with ecosystem map is
attached). There is only a small area of old growth forest located in the expanded LOA;
however, Gartner Lee’s report concluded the following:

“Marbled murrelets were detected on every Marine habitat survey during the breeding
season and were the second most abundant marine bird after mew gulls. Based on the
numbers of murrelets observed and the occurrence of suitable nesting habitat within the
region, it is highly likely that the species is breeding in the RSA.
“Nesting surveys for murrelets were not conducted as part of this assessment, and we
therefore cannot conclude with certainty that the species is not nesting in the LSA.
However; based on the small footprint of the proposed project and the Low and Very
Low nesting suitability typically observed in mature forest stands of the LSA, the
probability of murrelets nesting there is low. Based on the relatively small size of the
proposed development footprint and the even smaller area of mature forest proposed to
be removed, the amount of potential nesting habitat that would be impacted by
development is small relative to both the total amount of habitat available in the RSA and
habitat impacts from other resource development activities in the region, notably forest
harvesting.”

5) Highbank does not intend to carry out any activity other than exploration in the requested
expanded licence of occupation area. An environmental assessment under the BC Environmental
Assessment Act, including full consultation requirements, would need to be completed if
Highbank proposed to extract sand and gravel over the threshold production level of 1,000,000
metric tonnes over four years. Development plans would also need to be submitted and
permitted, including consultation, for extraction less than this production threshold in the
expansion area. The main purpose of the request for the expanded area is to consolidate the
resource holdings of Highbank and ensure that any investment in the existing, already permitted
area, can meet the usual financial hurdles in terms of project longevity and return to investors.
Highbank trust that the above answers any questions regarding the expanded LOA request but would be
pleased to address any further concerns.
Yours truly,

Vic Bryant
President / CEO
c.c. Mary Moran
Jenifer Hill – Micon International Ltd.
Attached: 2007 Baseline study

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Land Act:
Notice of Intention to Apply for
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Take notice that Portland Canal Aggregates Corp from
Vancouver, BC, have applied to the Ministry of Forests, Lands
and Natural Resource Operations (MFLNRO), Smithers, for
a Licence of Occupation - Quarrying purposes situated on
Provincial Crown land located ALL THAT UNSURVEYED
CROWN LAND IN THE VICINITY OF SWAMP POINT,
PORTLAND CANAL TOGETHER WITH THAT PART
OF DISTRICT LOT 2024, BEING NEVER SWEAT
MINERAL CLAIM, CASSIAR DISTRICT, CONTAINING
123.19 HECTARES, MORE OR LESS..
The Lands File for this application is 6406804. Written
comments concerning this application should be directed to
the Coast Mountains Land Officer, FLNRO, at Suite 200 –
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Appendix 3
Management Plans
EHSMS – Environmental, Health & Safety Management System
I – Road Design
K – Traffic Plan

EHS Management System
Framework

No.

EHSMS

00

Revision
Date
2013-10-28

Page
EHSMS-1

Swamp Point North
Aggregates Project

SIGNATURE

DATE

PREPARED BY:

J. Hill

__________________

Oct.25, 2013

REVIEWED BY:

V. Bryant

__________________

Oct.28, 2013

APPROVED BY:

V. Bryant

__________________

Oct.28, 2013

APPROVED BY:

__________________ _______________

ISSUE / REVISION INDEX
Issue
Code No.
RI
00

By
JH

Revision
Rev’d.
App.

Revision Details
Date
2013-10-28

Released for Information

Issue Codes: RI = Released for Information, IM = Released for Implementation, RC = Released for Revision
and Comment

Framework

No.

EHSMS

00

Revision
Date
2013-10-28

Page
EHSMS-2

PREFACE
This document forms part of the Environmental, Health and Safety Management System
(EHSMS) for the Swamp Point North Aggregates Project. The EHSMS in its entirety provides
the practices, procedures and resources that need to be implemented for effective management to
ensure the project complies with legislated requirements and best practices throughout the life of
the project.
The EHSMS includes the following documents:
EHSMS Framework - Document that provides the company’s environmental, health and
safety policies, objectives, organization, responsibilities, resources, document
management and review requirements for the EHS program.
I – Road Design
K – Traffic Plan
M – Barge Loadout and Marine Safety Plan

Framework

No.

EHSMS

00

Revision
Date
2013-10-28

Page
EHSMS-3

Mission Statement
To develop, operate and close the operation in a safe, efficient manner that provides a favourable
return to shareholders, protects the environment, complies will all provincial and federal
legislation and benefits local First Nations and communities. Highbank is committed to a
program of continual improvement of its management systems and environmental, health and
safety performance.
Organization and Responsibilities
The Mine Manager will ultimately be responsible for the Environmental, Health and
Safety compliance at the project.
A senior worker with appropriate environmental and technical expertise will be
responsible for Environmental Coordinator duties.
A senior worker with appropriate health and safety expertise will be responsible as
Health and Safety Coordinator for oversight and implementation of the Health and Safety
programs.
A worker trained in Industrial First Aid, including a Transportation Endorsement will be
on site when the camp is occupied.
Both the Environmental Coordinator and Mine Manager will have the authority to stop
construction/operations, if needed, to protect the environment.
Both the Health and Safety Coordinator and Mine Manager will have the authority to stop
construction/operations, if needed, to protect worker health and safety.
Environmental, health and safety compliance will be integrated in the site induction
program and all workers are responsible for notifying the Safety Officer, Environmental
Coordinator and/or Mine Manager if there is a potential for non-compliance.
Objectives and Targets
The mine management procedures generally follow the Aggregate Operators Best Management
Practices Handbook for BC (MEM, 2002) and the BC Health, Safety and Reclamation Code
(2008).
These Best Management Practices have been modified to be site-specific for the Swamp Point
North Aggregate Project and are maintained as plans and procedures within this Environmental
Health and Safety Management System (EHSMS). Specific plans integral to this EHSMS are
listed in the preface.

Framework

No.

EHSMS

00

Revision
Date
2013-10-28

Page
EHSMS-4

Auditing Program
At least annually, an internal auditing team will complete an environmental, health and safety
audit of site facilities and practices to check for legislative compliance and conformance with
plans and procedures in the EHSMS. An audit report will be prepared by the auditing team,
presented to management for review, and an action plan developed to correct any noncompliances or non-conformances. The Mine Manager, Environmental Coordinator and Health
and Safety Coordinator will be responsible for following up and documenting completion of
corrective actions.
Document Control and Record Keeping
Copies of all permits, plans and procedures related to the environmental, health and
safety programs will be kept on site and in head office.
All plans and procedures will be periodically reviewed by management and updated at
least annually.
All plans and procedures will be marked with the date and all outdated documents will be
clearly marked ‘superseded’ and archived.
Records will be kept in the main office on site for monitoring results, training, incident
reports and corrective actions.

Occupational Health and Safety
Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-1

Swamp Point North
Aggregates Project

SIGNATURE

DATE

PREPARED BY:

D. Makepeace

__________________

Oct.25, 2013

REVIEWED BY:

V. Bryant

__________________

Oct.28, 2013

APPROVED BY:

V. Bryant

__________________

Oct.28, 2013

APPROVED BY:

__________________ _______________

Issue
Revision
Code No. By Rev’d.
App.
RI
00 DM

Revision Details
Date
2013-10-28


and Comment

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-2

PREFACE
the project.
I – Road Design
K – Traffic Plan

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-3

Mine Health & Safety Regulatory Framework
The Preliminary Swamp Point North Aggregates Project Health and Safety Plan has been
developed to conform to regulatory requirements within the Province of British Columbia.
Highbank Resources is committed to meeting regulatory requirements, and to providing safe and
healthy working conditions for all site workers.
The B.C. Ministry of Energy, Mines and Petroleum Resources (MEM) has the regulatory
authority for worker health and safety on B.C. mine sites, including aggregate extraction
operations. MEM implements the Mines Act, RSBC Chapter 293, and its accompanying Health,
Safety and Reclamation Code for Mines in British Columbia, 2003 (Code). The Code requires
that aggregate operations adhere to the following:
Ensure that sand and gravel extraction activities are undertaken in a manner that protects
the health and safety of workers on the mining site and the public who may be affected
by the extraction activities;
Manage impacts of extraction activities on other resource values including timber, fish
and wildlife and their habitat, water quality and cultural heritage resources; and
Monitor the extraction of the aggregate resources and to ensure maximum extraction with
a minimum of environmental disturbance, taking into account sound engineering practice
and prevailing economic conditions.
Health & Safety Issues & Resolution
Highbank Resources Ltd. is committed to the Code purposes and understands that Health, Safety
and Environmental Protection are vital elements of the Project, and that this protection is
essential to achieving a long term successful operation. Highbank is also committed to:
Providing safe and appropriate equipment;
Ensuring the right for an employee to refuse to perform dangerous or unsafe work;
Developing, maintaining, and continually reviewing the operating practices and
procedures of the company; and
Promoting positive attitudes toward safety, health and environmental protection within
the organization.
Highbank will ensure that workers are adequately trained to do their jobs, and are provided with
instruction in safe work procedures and practices. This is expected to contribute to safer working
conditions and improved environmental protection.
A safe and healthy work place is the right and responsibility of all mine workers. All persons
employed or contracted to Highbank will be expected to correct or report unsafe conditions and
practices; to work cooperatively in preventing accidents, in all areas of the operation; and to
ensure that their individual actions adhere to environmental requirements and commitments for
the mine.

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-4

One member of the mine supervisory staff will be assigned primary responsibility for assessing,
monitoring and reporting on health, safety, training and environmental requirements for the
operation. This individual will be responsible for implementing and, as appropriate, expanding
the programs described in this section for the management of health, safety, security,
environment, materials handling, and emergency preparedness and response. Implementation of
these plans will be focused on ensuring compliance with the Code, including the following
Sections:
10.1.1 through 10.7.31 - Mine Plan and Reclamation (Closure) Plan;
1.6.1 - Establishing an Occupational Health and Safety Committee;
1.12.1 - Ensure all workers are under the direct supervision of a holder of an Open Pit
Shiftboss Certificate;
1.6.9 - Develop a Mine Health and Safety Program specific to the site;
1.7.1 through 1.7.3 - Accident and Dangerous Occurrence Protocols:
o 2.13.1 through 2.13.20 - Workplace Hazardous Materials Information (WHMIS);
o 3.6.1 - Provide and maintain first aid supplies and personnel; and
o 3.7.1 - Develop a Mine Emergency Response Plan.
Specific worker health and safety concerns common to aggregate operations are noise and dust.
Consideration of both noise and dust has been integral to design and planning of the Swamp
Point North Aggregates Project. Neither concern is expected to be significant in terms of off-site
human health, given the remote location of the site. Design and operational mitigation features,
in combination with the high precipitation at the site and contingency mitigation measures, are
expected to reduce dust to minimal levels. Similar measures have been undertaken for noise,
however it is recognized that personal protection measures will be required for workers in certain
areas of the site.
NOISE MANAGEMENT
Noise is associated with a number of common activities at aggregate operations, including
loading, crushing, screening, washing, and hauling. Noise levels can be expected to increase as
production increases.
As noted above, no significant off-site human health concerns related to noise are expected for
the Swamp Point North Aggregates Project Operation, due to the remote location of the site.
Noise will still be a factor for the employees on-site throughout the project life, and will be
addressed during all phases of the operation. Noise management and mitigation measures will
follow applicable practices described in the Aggregate Operators Best Management Practices
Handbook for British Columbia (MEM, 2002), including measures as described below.
Noise generating activities at aggregate operations have varying duration and intensity, such as
loading operations which are intermittent and have lower impact, versus processing and crushing
operations which are more continuous and have higher noise levels.

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-5

Noise at the Swamp Point North Aggregates Project will be mitigated to the extent practicable
during the construction, operation, and closure phases of the project. Specific noise sources at
the mine will include:
Mobile equipment (loaders, excavator, crawler tractor, grader) which generate noise from
sources such as the diesel engines, back-up alarms and the scraping and crushing noises
during excavation and transport to the processing plant.
Processing Plant, which generates noise from motor driven machinery, transfer points of
the material dropping to the next conveyor level, and from the crushing and sizing of
aggregate to product size.
Barge-loading operations, including the conveyor system, Barge-loader, onboard
generators, and dropping of aggregate into barge hold.
Noise at the Swamp Point North Aggregates Project will be mitigated to the extent practicable
through planned site layout (containment and dampening), operational controls (prevention), and
interception (ambient reduction). Highbank has incorporated the following measures in project
design and/or plans to implement them:
Institute a policy that all employees and contractors wear and/or use properly fitted
(hearing protection) Personal Protective Equipment (PPE) in any area, where a potential
noise hazard exists that could injure a worker or be prevented by using the PPE;
Incorporate engineered sound buffering designs where necessary to allow for the
reduction of noise (i.e., in the process plant control room);
Schedule noisy operations or construction activities at normal working hours to the extent
possible;
Alert and train employees and contractors to reduce noise emissions;
Retain as much vegetation cover (particularly trees) as possible around the perimeter of
the Open Pit and other operational areas;
Locate the Operations Camp as far away from the primary noise sources as possible;
retain vegetation cover around the camp; plant trees on the Mine Road fill slopes above
the camp; and plan facilities such that stockpiles and the Mine Road will create a height
of land between the Operations Camp and the primary noise sources;
As above, construct and place stockpiles to not only meet operational requirements, but
to intercept and dissipate point source and ambient noise from the extraction area, in
order to minimize noise at the Operations Camp;
Minimize crushing operations in proximity to the Operations Camp;
Examine alternatives to minimize crusher noise when the Processing Plant is nearest to
the Operations Camp, such as crush the east side of the top bench first, feed the crusher
from top and convey to the Processing Plant, with the latter possibly located at a lower
bench;
Minimize drop heights of all materials to reduce the noise of rocks falling onto metal
surfaces;

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-6

Use conveyor systems that are designed for addition of covers, should these prove to be
necessary;
Maintain smooth running roads surfaces on all access roads and pit floors to reduce tire
noise and increase tire life;
Minimize mobile equipment speeds and limit amount of equipment on-site – only have
the necessary equipment on-site;
Operate equipment within specifications and capacity (e.g., don’t overload machines) and
use noise abatement accessories such as sound hood and mufflers;
Turn equipment off when not in use;
Restrict use of sirens and reversing alarms to the minimum, and consider the use
alternative non-audible back-up alarms. A variance from MEMPR Health and Safety
would be required to approve the latter;
Perform regular inspection and maintenance, check that noise abatement devices are in
good order (e.g., brakes, exhaust mufflers, engine hoods); and
Locate major electrical generation facilities as far away from the Operations Camp as
possible.
AIR QUALITY MANAGEMENT
General Equipment & Process Plant Safety Considerations
Parts 1.11.1 (1) & (2) of the Code require the manager to:
Ensure that workers are adequately trained to do their job or are working under the
guidance of someone who has competency both in the job and in giving instructions; and
Ensure that all employees receive thorough orientation and basic instruction in safe work
practices.
The Code is also specific regarding the operator’s responsibility. Part 6.19.1 of the Code
indicates that:
The operator of any unit of mobile equipment shall be directly responsible for is safe
operation and for maintaining full control of the unit and complying with all provisions of
the Mines Act, the regulations and the Code insofar as the operation of the equipment is
concerned, and operators shall wear their seatbelts and drive with their headlights on and,
where required, a flag equipped whip antenna light or flashing light on at all times.
Highbank Resources is committed to operating a safe and healthy work environment, and is
proposing to additionally:
Produce an Occupational Health & Safety Policy Manual for distribution to employees
and contractor during the construction and operational phases of the Project;

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-7

Define guidelines regarding the use of equipment on the job to assure compliance with
applicable laws, fulfill training and due diligence obligations, and to promote the safety
of all employees working on the Project;
Ensure that no employee or contractor operates any equipment, mobile or stationary
unless the minimum training required for that particular equipment pursuant to the
approved (classroom & field) training program, has been completed;
Ensure adequate training direction and instruction of employees, in the safe performance
of their duties; and that they are qualified to perform assigned duties;
Establish and maintain proper operational inspections and adequate standards of
maintenance of the workplace and equipment;
Ensure that all personnel are trained in the general maintenance and operation of the
following safety equipment (lights, audible backup alarms (or MEMPR approved
alternatives), fire suppression systems and VHF radios for operation communication);
Ensure that adequate resources are available and will meet required safety needs;
Develop work procedures, that are conducive to a safe and healthy workplace;
Ensure that employees have access to relevant company reference and training manuals at
all times.
Process Plant Operations
The Swamp Point North Aggregates Project Processing Plant has been designed to comply with
health, safety and environmental regulations, to meet the required production requirements, to
operate at a minimum of cost, and to be built at a reasonable capital cost. The final plant
arrangement will have gone through extensive process design, equipment selection, and layout to
meet these objectives, and to ensure that safety requirements have been incorporated into the
plant facilities.
These safety requirements will complement the program the company will develop to monitor
workplace contaminants where necessary to ensure that workers are not overexposed to harmful
agents, particularly respirable dust. Applicable threshold limit values (TLV) will be applied as
per the Code.
The Code has many Parts which relate to the safe operation of processing plants, and these must
be complied with to ensure the health and safety of employees in the operation. The designed
plant for this Project will have safety guards around all moving equipment, and emergency pullcords on both sides of any conveyors with personnel access. The company will ensure that these
safeguards are kept in good working order. Ongoing safety training of plant personnel will be
implemented, as the company believes this is imperative, and it will be considered to be one of
the most vital and monitored features of the operation.
Fugitive dust at the Processing Plant is primarily a potential concern for the crushers. Once the
aggregate has been washed, as is expected to be the case for most of the product, fugitive dust is
not expected to be of concern.

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-8

Water misters will be installed at the jaw crusher to control fugitive dust. The Processing Plant
design will also include dust curtains and other covers to prevent dust dispersion. Any product
conveyors potentially exposed to wind will be covered. If other sources of fugitive dust become
apparent during operation, these will be addressed using appropriate mitigation measures. As
there are a very large number of aggregate process plants in operation, finding proven and
effective methods to deal with fugitive dust control is not expected to be a concern.
Material (aggregate) spillages will be minimized by spill collection systems installed on the
feeders; chute receiving and discharge points and conveyor belts.
The Processing Plant has been designed to meet or exceed industry standards in regards to
operational and maintenance functions. There has been a concerted effort to ensure operator
comfort and ease of clean-up; as well the plant has been designed for ease of access and
maintainability, in order that the company can meet its production goals.
Barge Loading Operations
The Code will require that appropriate Personal Protection Equipment (PPE) be worn at all
times. The barge load-out area will be provisioned with life buoys, crew flotation vests, life
preserver rings, poles and ropes for rescuing anyone who is working near water and be in
compliance with Part 3.3.3 of the BC Health, Safety and Reclamation Code (HSRC).
Fugitive dust from the Barge-loader is not expected to be a concern due to the gravel’s high
moisture content. The conveyor will be covered with hemispherical covers to prevent dust
losses. A solid apron will be installed under the conveyor and return idlers to pick up any debris
that might spill off the conveyor. The head pulley of the conveyor will be fully enclosed with
chutwork to minimize the generation of fugitive dust during the transfer onto the barge.
Washing of aggregate products is also expected to minimize potential for dust generation from
processed products, as are the high levels of precipitation at this site.
There will be some noise from the ships, but this is expected to be local in nature and not of
concern for worker Health and Safety.
Safety Measures for Public Access
The Swamp Point North Aggregates Project Operation is in a remote area, so there will be fewer
concerns with public access to the site than with similar operations located near urban centers.
Access to the site will only be by way of water (boats and tugs along the Portland Canal) or by
air (helicopter/float plane). Therefore, it will be easier for the company (manager) to enforce
Parts 1.3.1 to 1.3.3 of the Code. These Parts effectively give the company (manager) the right to
control and administer authority to who may or may not enter the mine (operation). This control
includes appropriate signage to warn unauthorized persons of potential dangers.

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-9

As part of the on-site infrastructure there will a security/first aid office and staff tasked with
ensuring compliance with the Code during construction and operational phases of this Project.
Highbank is proposing to provide emergency shelter for small craft experiencing difficulties in
the Portland Canal.
All lighting and navigation lights appropriate for safety on the barge loading facility will be
operational throughout all phases of Project. The barge loading facility will be well lit during
use, which would typically be once to twice a week during full operations.
First Aid & Medical Services
Pursuant to Part 3.6.1 of the Code, the company (Mine Manager) shall provide and maintain first
aid supplies and services as required by the Workers Compensation Board (WCB). Highbank
will operate in compliance with the WCB Occupational Health and Safety Regulation, Part 33,
B.C. Regulation 348/2003 and its accompanying Occupational Health and Safety Guidelines.
Due to the remote location of Swamp Point, medical assistance will be able to reach the mine
only by helicopter or floatplane (restricted to day and Visual Flight Rules (VFR) conditions) or
by boat. It will therefore be necessary for the mine to have First Aid facilities and suitably
trained staff such that a patient can be stabilized for several hours. A satellite phone will be
available to report the injury and call for assistance. The Swamp Point North Aggregates Project
will have a fully equipped First Aid Room with a minimum Level 1 First Aid kit at the Project.
The mine will have an appropriately trained Industrial First Aid Attendant in compliance with
the above regulations and guidelines during construction, operations and reclamation /
decommissioning.
To complement this, Highbank will provide procedures that all employees and contractors will
have to follow for accidents, first aid treatments, and dangerous occurrences. Preliminary
procedures include the following:
Ensure that the injured worker is provided with the best available first aid treatment onsite. Then, except for the purpose of saving a life or relieving human suffering, ensure
that the scene of the accident or occurrence is not disturbed without appropriate approvals
as required by Part 1.7.1 (2) of the Code.
All mobile equipment that will be left on site will be locked out at the end of each shift.
Fire extinguishers will be kept at key locations on site.
Signs indicating restricted public access and associated hazards will be posted at the
dock.
Follow the appropriate Emergency Evacuation Procedures and Emergency Contact
Protocols that have been established for a particular area of operations.
If the injury is an obvious fatality, immediately contact the Mine Manager, who in turn
will contact the appropriate authorities (RCMP and Chief Inspector of Mines). Every
serious accident must be reported to the Mine Manager, immediately after requesting a

Plan

No.

OHS

00

Revision
Date
2013-10-28

Page
OHS-10

helicopter. The Mine Manager will contact the Ministry of Energy, Mines, and
Petroleum Resources, who will then advise whether or not the ministry will investigate
the accident.
The necessary accident investigation report forms must be completed as soon as possible
and forwarded through the appropriate channels.
Results of the investigation will be reviewed by the Manager and then made available to
other interested parties to ensure that the incident is not repeated.
Records will be kept in the main office for monitoring results, incident reports and
corrective actions.
Dangerous Occurrences will be addressed as follows:
All dangerous occurrences (incidents, close calls, and accidents) must be reported to the
appropriate Foreman. If necessary, a follow-up investigation will be carried out within
24 hours of the occurrence and/or receipt of the incident/accident report. The Foreman
will forward the information to the Mine Manager, who will then make the decision as to
whether a full investigation is required.
Dangerous occurrences include, but are not limited to the following:
o First aid of minor sprains and sores;
o Hospitalization and medical aids;
o Damage to equipment; and
o Close calls of any sort.
If the occurrence is an unusual accident or unexpected event which had the potential to result in
serious injury, then Part 1.7.3 (11) of the Code requires notification to the Inspector of Mines.
Emergency Response
The Code requires mine (aggregate) operations of this project size to comply with Parts 3.7.1
(Mine Emergency Response Plan), and Parts 3.7.5 through 3.7.13 (Mine Rescue Teams).
Highbank Resources will develop an Emergency Response Plan in accordance with the above
regulatory requirements of MEM. The company will ensure that appropriate numbers of
employees are trained in first aid, firefighting, mine rescue and environmental response, in order,
to provide emergency response capabilities at the Project site.

Mine Emergency Response Plan
No.
00

MER

Revision
Date
Page
2013-10-28
MER-1

Swamp Point North
Aggregates Project

SIGNATURE

DATE

PREPARED BY:

D. Makepeace

__________________

Oct.25, 2013

REVIEWED BY:

V. Bryant

__________________

Oct.28, 2013

APPROVED BY:

V. Bryant

__________________

Oct.28, 2013

APPROVED BY:

__________________ _______________

Issue
Revision
Code No. By Rev’d.
App.
RI
00 DM

Revision Details
Date
2013-10-28


and Comment

Mine Emergency Response Plan
MER

No.
00

Revision
Date
Page
2013-10-28
MER-2

PREFACE
the project.
I – Road Design
K – Traffic Plan

Highbank’s Swamp Point North Aggregate Project NoW Application

Highbank’s Swamp Point North Aggregate Project NoW Application

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