Detour Lake Gold Mine Project Follow-up Program

Transcription

1 Detour Lake Gold Mine Project Follow-up Program Last revised: June 2014

2 CONTENTS 1 Context Purpose of the Detour Lake Gold Mine Follow-up Program Ensuring Implementation of the Follow-up Program Follow-up Program Duration Decision Making Site Visits Evaluating Follow-up Program Success Follow-up Program Modifications Roles and Responsibilities in the Follow-up Program Proponent: Detour Gold Corporation Responsible Authorities: Natural Resources Canada and Fisheries and Oceans Canada Federal Authorities: Environment Canada and Health Canada Participation in the Follow-up Program Participation of Aboriginal Groups Participation of Ontario Ministries Follow-up Program Local Water Courses, Lakes and Wetlands: Water Quality; Fish and Fish Habitat Local Water Courses, Lakes and Wetlands: Watercourse Flows and Water Levels; Fish Habitat Local Water Courses, Lakes and Wetlands: Sediment Quality Groundwater System: Water Quality and Quantity Terrestrial Environment: Migratory Birds Species-at-Risk: Caribou Resource Harvesting (Country Foods): Local Fish Resource Harvesting (Country Foods): Wildlife and Plants (Caribou, Moose and Beaver) Land and Resource Use: Reclamation Air Quality, Noise and Greenhouse Gases Public Health and Safety: Road Traffic List of Abbreviations References

3 1 CONTEXT Detour Gold Corporation ( DGC ) is in the process of developing and operating a 61,200 tonnes per day open pit gold mine known as the Detour Lake Mine Project ( Project ). The Project is anticipated to have a minimum mine life of 16 years and is located approximately 185 km northeast of the town of Cochrane in a remote area of northern Ontario. The Project consists of an open pit mine, an ore processing plant, tailings and waste rock storage facilities. It also includes site access roads, power transmission lines, an explosives factory and storage areas, water management facilities, ancillary mine infrastructure, and associated activities. Pursuant to provisions under the Canadian Environmental Assessment Act, 1992 ( former CEAA ), the Project was subject to a comprehensive study environmental assessment ( EA ). A comprehensive study report 1 ( CSR ) was prepared by the Canadian Environmental Assessment Agency ( CEA Agency ) in November 2011 describing the EA process and the predicted potential environmental effects, proposed mitigation measures, determination of significance of environmental effects and a Follow-up Program Framework ( FUPF ) for the Project. The Project also underwent a number of EAs under Ontario s Environmental Assessment Act. In accordance with the Canada Ontario Agreement on Environmental Assessment Cooperation, cooperative EA processes involving both jurisdictions were conducted. In December 2011, when taking into account mitigation measures and the implementation of the FUPF described in the CSR 2, the federal Minister of the Environment determined that the Project was not likely to result in significant environmental effects. Under section 37 of the former CEAA, the Project was then referred back to Responsible Authorities ( RAs ), Natural Resources Canada ( NRCan ) and Fisheries and Oceans Canada ( DFO ), who then took a course of action decision in relation to the Project. Under the former CEAA, NRCan and DFO are required to ensure the implementation of mitigation measures and the design and implementation of a FUP for the Project to verify the accuracy of the predictions contained in the CSR. 2 PURPOSE OF THE DETOUR LAKE GOLD MINE FOLLOW-UP PROGRAM The former CEAA defines a FUP as a tool to: (1) verify the accuracy of the EA of a project; and, (2) determine the effectiveness of any measures taken to mitigate adverse environmental effects. The former CEAA also provides that the results of a FUP may be used for implementing adaptive management measures or for improving the quality of future EAs. Adaptive management is defined as a: planned and systematic process for continuously improving environmental management practices by learning about their outcomes. Adaptive management provides the flexibility to identify and implement new mitigation measures or to modify existing ones during the life of a project 3. The CSR provided a framework for the components to be included in the Project FUP and a number of environmental commitments made by DGC to implement mitigation measures, including a commitment to undertake the FUP, as set out in the October 11, 2011 letter to the CEA Agency 4. The implementation of the FUP will verify the predictions of the CSR, prepared in accordance with the former CEAA. Should any unanticipated potentially significant adverse environmental effects be identified, section 6 of this FUP outlines adaptive management measures to mitigate those effects to ensure they do not become significant. This FUP document is intended to provide a cooperative plan between RAs, FAs and DGC to ensure its communication, review and implementation. It provides measures to ensure the implementation of the FUP, a description of the roles and responsibilities of DGC, RAs and FAs in the FUP, the participation of involved Ontario ministries and Aboriginal groups in the FUP as well as specific details of the program in relation to the Valued Ecosystem Components ( VECs ) and Valued Socioeconomic Components ( VSECs ) that fall under the scope of this FUP. 1 Canadian Environmental Assessment Agency. (November 2011). Comprehensive Study Report Detour Lake Gold Mine, (Ottawa: Minister of Public Works and Government Services Canada, 2011). 2 Ibid., pp Adaptive under the Canadian Environmental Assessment Act, Operational Policy Statement, Canadian Environmental Assessment Agency, Ibid. 1, pp

4 3 ENSURING IMPLEMENTATION OF THE FOLLOW-UP PROGRAM 3.1 Follow-up Program Duration The FUP is set to begin following the submission of the first Annual FUP Report in June The FUP duration will depend on the individual VECs and VSECs identified in the FUP and will be reviewed and adjusted accordingly based on the mine life, including potential Project changes such as an increase in its duration or the early cessation of mining activities; and, considerations for decommissioning, reclamation and post-closure activities. In general, any of the elements of the postconstruction monitoring program described in Section 6 of the FUP may be extended, altered or added to if unanticipated potentially significant adverse environmental effects are confirmed and additional study is deemed necessary by the RAs. Each element of the post-construction monitoring program will be considered independently, and will also be reviewed as a whole, which includes cross-analysis of survey results. Nevertheless, extension of one survey type to an additional year does not imply the entire program will be extended. In other cases, where impacts are continually at or below the levels predicted in the CSR, an aspect of the program may be shortened or revised accordingly in these select areas. Proposals to extend or shorten aspects of the FUP are to be presented in the Annual FUP reports so they can be considered during the 90 day review period of the report. 3.2 Decision Making NRCan and DFO are responsible for ensuring the implementation of the FUP as per subsection 38(1) of the former CEAA and, as appropriate, will consult with federal and provincial authorities as well as involved Aboriginal groups, and will determine whether DGC has implemented the FUP as described in this document. 3.3 Site Visits To ensure implementation of the FUP, NRCan and DFO will mainly rely on inspection, compliance and monitoring reporting mandated by applicable federal and provincial legislative and regulatory instruments and summarized in the Annual FUP Report. If necessary, involved federal authorities will conduct site visits and/or review detailed federal and provincial reporting requirements to ensure implementation of the FUP. 3.4 Evaluating Follow-up Program Success The success of the FUP is dependent on the following considerations: EA predictions are being accomplished throughout the life of the project based on the mitigation measures that are put in place by DGC and set out for the 11 VEC and VSEC described in section 6 of the FUP; In situations where the criteria for considering adaptive management described in the FUP are being achieved, potential actions are being undertaken by DGC. These are outlined in section 4 of the FUP, and in more detail for each VEC and VSEC in section 6. In all cases where potential adaptive management measures are to be implemented, DGC must ensure that it has obtained the necessary federal and/or provincial approvals prior to adopting these measures. The yearly review of the Annual FUP Report is providing interested parties with the opportunity to assess whether the criteria for considering adaptive management by DGC have been achieved and to make recommendations to DGC, including on adaptive management. 3.5 Follow-up Program Modifications The FUP and adaptive management measures may require amendment or updates during the life of the Project to address changes in environmental conditions as a result of observed effects on the environment and/or modified based on new science, future federal and provincial permits, licenses, authorizations and/or approvals. To that effect, the FUP will be reviewed every five years by DFO and NRCan in collaboration with Federal Authorities ( FAs ) and DGC. As part of consultation on the FUP modifications, DFO and NRCan will also engage involved Ontario ministries and Aboriginal groups. It is anticipated that through the yearly reporting being submitted by DGC, NRCan and DFO will consider the comments submitted on the yearly reporting and identify whether changes are required prior to the 5-year review process. Any changes to the FUP will be communicated directly with those involved, as described in section 4 of this FUP. 4

5 4 ROLES AND RESPONSIBILITIES IN THE FOLLOW-UP PROGRAM 4.1 Proponent: Detour Gold Corporation As the proponent of the Project, DGC has been delegated aspects of the design and implementation of the FUP by the RAs, pursuant to s.17 of the former CEAA. The design and implementation of the FUP must be done to the satisfaction of the RAs and, if necessary, DGC will be responsible for implementing adaptive management measures and/or mitigation measures described in the FUP. To ensure implementation of the FUP, DGC is responsible for preparing and distributing not later than June 30 of each year an Annual FUP Report to the RAs. A copy of the full report shall also be distributed to FAs and Ontario ministries and Aboriginal groups described in this section. To facilitate access of the FUP to the public, a summary of the FUP will be made available for download through the DGC website. At a minimum, the Annual FUP Report will include the following information: 1. Plain language executive summary that provides a general background and summary of the Annual FUP Report s findings. In the executive summary, DGC is asked to provide an overview of how the FUP is successful based on considerations in section 3.4; 2. Rolling summary of project activities that includes the mine operations facilities and activities, major components for the mine and associated infrastructure and related information regarding permitting; 3. Summary of monitoring results, including illustration of trends, in relation to the FUP. In the monitoring results summary, DGC will specify requirements of monitoring such as part of federal/provincial regulatory approval/conditions as well commitments outlined by DGC in the CSR. This section will constitute the main body of the report and should provide an overview of the various monitoring programs, their results and interpretations for each of the 11 VECs and VSECs that fall under the scope of the FUP; 4. Summary of all supporting information, data and results from the FUP, and all studies and research. This includes references to where more details can be found validating the results and trends illustrated in the Annual FUP Report, including a summary of study and research programs which go beyond those specifically required by permits, where applicable; 5. Summary of all compliance reports required by the Project s regulatory instruments applicable for the reporting period; 6. Actions taken or planned to address environmental effects or compliance problems which are set out in the Annual FUP; 7. Comparison of the project effects to those predicted in the EA. This section should provide an overview of how the Project has performed, in an environmental capacity, relative to expectations defined through the federal EA process and related permitting; 8. Determination of effectiveness of mitigation measures at avoiding environmental effects designed to protect the environment; 9. Summary and evaluation of all Adaptive Environmental measures; 10. Rationale for and summary of new technologies investigated to reduce and/or avoid environmental effects that considers new environmental monitoring or mitigation technologies investigated during the reporting period; 11. Summary of Aboriginal, government and public concerns related to environmental effects and responses to those concerns. This section should also include a summary of comments received on the last iteration of the Annual FUP Report and how DGC resolved these comments. Upon receipt of the Annual FUP Report and no later than 90 days after its receipt, comments will be submitted directly to DGC. Comments on the Annual FUP Report shall be submitted to DGC, and if applicable, copied to NRCan and DFO. DGC will then work directly with those involved in addressing the comments and issues that arise. A summary of the comments received and how they were addressed should be included in the next iteration of the Annual FUP Report by DGC. Finally, in situations where the criteria for accepting the EA predictions described in section 6 of the FUP are not being achieved, the following actions will be considered and initiated by DGC, as necessary: 1) If possible, take immediate action (i.e. short term approaches) to correct problems. Include a discussion of the actions taken, their effectiveness and lessons learned. 2) Where immediate action is not suitable, the proponent will submit proposal for adaptive management: 5

6 a. Relevant federal departments to review and approve adaptive management approach, as appropriate. DGC will make best efforts to involve Aboriginal groups in the review and approval of proposed adaptive management approaches, where possible; b. Proponent to implement adaptive management, including monitoring protocol; c. Proponent to submit interim monitoring to verify effectiveness of adaptive management. 4.2 Responsible Authorities: Natural Resources Canada and Fisheries and Oceans Canada As the RAs for the Project, NRCan and DFO are responsible for the design of the FUP and to ensure it is implemented. Following the receipt of the Annual FUP Report from DGC, the RAs will review and provide comments to DGC in aspects which involve their mandates and interests no later than 90 days after receipt of the report. The RAs will draw on the expertise of the Federal Authorities to ensure the FUP s implementation, and if applicable, may also draw on the expertise of Ontario ministries, as described in sections 4.3 and 5.2 of the FUP, respectively. At any time, concerns associated with the implementation of the FUP can be brought to NRCan and DFO s attention. Should issues arise during the implementation of the program, NRCan and DFO may, at their discretion, coordinate and facilitate issue resolution to the extent possible. NRCan is responsible for including a description of how the program and its results may be obtained on the Canadian Environmental Assessment Registry Internet Site. 4.3 Federal Authorities: Environment Canada and Health Canada Following the receipt of the Annual FUP Report from DGC, the FAs, Environment Canada (EC) and Health Canada (HC), will assist in the review of the document and provide advice with respect to aspects which involve their mandates and interests. If warranted, comments on the Annual FUP Report shall be submitted to DGC, copied to NRCan and DFO no later than 90 days after receipt of the report. EC will be responsible for providing, on request, to NRCan and DFO specialist or expert information or knowledge in its possession. EC will also be responsible for providing any assistance requested by NRCan and DFO concerning the implementation of the FUP on which NRCan, DFO and EC have agreed. EC s jurisdictional responsibilities in the context of the DGC project relate to the protection of: Migratory birds and species at risk as mandated by the Migratory Birds Convention Act, 1994, and the Species at Risk Act (SARA), respectively; and, Water quality in context of the pollution prevention provisions of the Fisheries Act, including the Metal Mining Effluent Regulations. HC does not have jurisdictional responsibilities in the context of the DGC. However, upon receiving a request from the RAs, HC may assist in reviewing the objectives, design and results of monitoring studies, and may provide advice on proposed adaptive management measures in the follow-up when the monitoring results demonstrate that the environmental effects differ from predictions. 6

7 5 PARTICIPATION IN THE FOLLOW-UP PROGRAM 5.1 Participation of Aboriginal Groups In this FUP, Aboriginal Groups refer to the First Nations and Métis groups who participated in the consultation activities during the federal EA process, including the Moose Cree First Nation ( MCFN ), Taykwa Tagamou Nation ( TTN ), Wahgoshig First Nation ( WFN ), Timmins Métis and Northern Lights Métis Community Councils as represented by the Métis Nation of Ontario ( MNO ), and Waskaganish First Nation ( Waskaganish ). Each will receive a copy of the Annual FUP Report from DGC and may submit their comments to DGC no later than 90 days following receipt of the report, if applicable. At any time, Aboriginal groups can bring to NRCan and DFO s attention any concerns associated with the implementation of the FUP. 5.2 Participation of Ontario Ministries In this FUP, Ontario Ministries refers to the Ministry of the Environment (MOE), Ministry of Natural Resources (MNR), Ministry of Northern Development and Mines (MNDM). Each ministry will receive a copy of the Annual FUP Report. NRCan and DFO may draw on the expertise of provincial ministries by inviting the ministries, in writing, for advisory or technical support for matters relating to the respective ministries area of provincial responsibility, as appropriate. If applicable, the provincial ministries may provide comments on the Annual FUP Report; these shall be submitted to NRCan no later than 90 days following receipt of the report. At any time, Ontario ministries can bring to NRCan and DFO s attention any concerns associated with the implementation of the FUP. 7

8 6 FOLLOW-UP PROGRAM As described in the Project CSR, the elements included in the FUP were determined through consideration of the following factors, including: the potential residual adverse effects; the extent to which public and Aboriginal group concerns were raised during the federal and provincial EAs, including comments raised by the participant funding recipients; areas of federal interest; whether provincial approvals, permits or plans do include, or are reasonably predicted to include, monitoring and followup requirements; whether provincial and federal regulatory instruments exist to help ensure the effectiveness of mitigation measures; and, the extent to which mitigation measures are innovative in their approach as opposed to being common and well understood, or where the effectiveness of the proposed mitigation is difficult to predict with a high degree of certainty. Based on the CSR FUPF, the FUP includes the implementation of mitigation measures and adaptive management measures for the following VECs and VSECs: 6.1 Local Water Courses, Lakes and Wetlands: Water Quality; Fish and Fish Habitat; 6.2 Local Water Courses, Lakes and Wetlands: Watercourse Flows and Water Levels; Fish & Fish Habitat; 6.3 Local Water Courses, Lakes and Wetlands: Sediment Quality; 6.4 Groundwater system: Water quality and quantity; 6.5 Terrestrial Environment: Migratory Birds; 6.6 Species-at-risk: Caribou; 6.7 Resource Harvesting (Country Foods): Local Fish; 6.8 Resource Harvesting (Country Foods): Wildlife & Plants; 6.9 Reclamation: Land and Resource Use. At a minimum, the FUP should cover the VECs and VSECs, identified above. The following additional VECs and VSEC were included in the FUP by the RAs in consultation with DGC only as they relate to the Project s environmental effects: 6.10 Air Quality; 6.11 Public Health and Safety: Road Traffic. 8

9 6.1 Local Water Courses, Lakes and Wetlands: Water Quality; Fish and Fish Habitat Valued Ecosystem Component Aspect EA Prediction Rationale for Inclusion in FUP: Potential Residual Effect or Concern Verification / Assessment Methods Current Mitigation Local Water Courses, Lakes and Wetlands Water Quality; Fish and Fish Habitat (aspect of Project CSR FUPF) Effluent discharges expected to meet applicable regulatory thresholds defined through legislation, or site-specific permits and approvals; Receiving water quality expected to meet background conditions, or applicable criteria for the protection of aquatic life criteria; Effluent discharges will not compromise fish habitat. Tailings Impoundment Areas (TIA) discharge may adversely affect East Creek / Sunday Creek system water quality; Stockpile runoff and seepage may adversely affect receiving water quality; Potentially acid generating (PAG) waste rock may adversely affect water quality via acid rock drainage (ARD). Stormwater runoff / seepage from other Project components (including snowmelt) may adversely affect receiving water quality; Non-regulated discharges from transmission line construction & operations, including spills may adversely affect receiving water quality; Airborne emissions may adversely affect receiving water quality; Potable water quality may be impaired. Regular water quality sampling, analysis and data interpretation as dictated by legislation, or applicable site specific permits and approvals. This includes water quality monitoring of stockpile runoff and seepage to ensure acceptable quality for direct discharge to local watercourses after settling pond treatment; As an upstream, early warning indicator, regularly monitor and report on the effectiveness of the in-plant cyanide destruction and heavy metals precipitation system (e.g. monthly grab sampling for free cyanide and dissolved copper, lead, and cadmium of the TMA effluent); Development and implementation of a waste rock management plan (WRMP) with annual reporting that includes any recommended adaptive management measures needed to prevent and/or mitigate ARD. In-plant destruction of cyanide, and precipitation of heavy metals; TIA water management and recycle measures; TIA seepage collection, containment and/or treatment; Stockpile runoff and seepage collection, containment and/or treatment; Mine operations area runoff and seepage collection, containment and/or treatment; 9

10 General sediment and erosion control measures; 120 m vegetated mine site buffer zone bordering watercourses (excluding seepage collection system footprints); Waste rock management program to segregate PAG materials to the extent practicable, remaining PAG materials to be blended; Dust suppression; Construction restrictions at or near creek crossings; Routine inspection of construction areas near watercourses; Water treatment plant(s) for potable water; Water quality management to protect fish habitat as per the MMER. Criteria for Considering Adaptive Potential Adaptive Applicable Regulatory Instrument(s)/ Departments involved in FUP Effluent (seepage and surface water) discharges exceed applicable regulatory thresholds defined through legislation, or site specific permits and approvals; and/or, Receiving water quality exceeds background conditions, or applicable criteria for the protection of aquatic life. Further optimize efficiencies of in-plant effluent treatment; Further optimize TIA water management and recycle; Further optimize runoff and seepage collection system efficiencies; Divert portions of runoff and seepage effluent that are of concern to the TIA; Further optimize dust suppression efficiencies; Refine and optimize waste rock management plan to reduce potential for ARD; Further optimize water quality management. MMER; MOE ECA or CofA; MNDM Closure Plan; 10

11 Responsibilities In the Annual FUP Report, DGC will provide a summary of follow-up and monitoring information as outlined in the verification / assessment methods. DGC is also responsible for implementing mitigation measures and, if necessary, potential adaptive management measures described above. The Annual FUP Report prepared by DGC will also include relevant summary information regarding submissions and project performance to demonstrate the effectiveness of mitigation in relation to: EC s MMER requirements, including EEM data; MOE ECA or CofA permits/ approvals and submissions from DGC; and, MNDM s Closure Plan implementation, required under the Ontario Mining Act. This includes results from the waste rock management and tailings monitoring programs that are included as part of the annual closure report. 11

12 6.2 Local Water Courses, Lakes and Wetlands: Watercourse Flows and Water Levels; Fish Habitat Valued Ecosystem Component Aspect EA Prediction Rationale for Inclusion in FUP: Potential Residual Effect or Concern Verification / Assessment Methods Local Water Courses, Lakes and Wetlands Watercourse Flows and Water Levels; Fish and Fish Habitat (aspect of Project CSR FUPF) Dewatering of the open pit is expected to reduce Karel Creek and Linden Creek flows by 830 m 3 /d and 300 m 3 /d, respectively (base case), with a more conservative (but less likely) flow reduction estimate for Karel Creek of 2,160 m 3 /d; fish habitat compensation to be provided; Pit dewatering induced flow reductions expected to occur in close proximity to the open pit based on modeling of the 1 m groundwater drawdown isopleths; Interception of stockpile runoff and seepage not expected to have a significant adverse effect on fish habitat; Fish habitat associated with development of the TIA and MRS #2 to be completely displaced; fish habitat compensation to be provided; Water takings from local watercourses will not adversely affect watercourse flows or levels, to the extent that fish habitat would be significantly affected; Fish habitat compensation measures will function as intended. Dewatering of the open pit has the potential to reduce watercourse flows and/or watercourse (or lake) water levels, and affect associated fish habitat beyond those predicted by modeling during the EA processes; Interception of stockpile runoff and seepage may reduce receiving water flows, and associated fish habitat, beyond that predicted in the EAs, if it is necessary to divert stockpile runoff and seepage (other than that associated with MRS #1) to the TIA for further water quality treatment; Water takings from local watercourses beyond those provided for in the EA have the potential to reduce downstream water flows (or levels) such that unanticipated fish habitat effects could potentially occur; Redirection of a portion of Karel Creek flows (during high water conditions) to accelerate open pit flooding at mine closure could potentially affect fish habitat; Fish habitat compensation measures may not function as proposed. Periodic re-running of the open pit groundwater model at two year intervals during the first five years of pit dewatering, and periodically thereafter as determined by provincial approvals; Conduct groundwater modeling; Site area surface water flow and level monitoring ; Conduct statistical analyses of flow monitoring data as appropriate to the data to determine monthly and annual average flows, and return period statistics for extreme flows; 12

13 EEM requirements under MMER and monitoring consistent with provincial approvals; Periodic visual inspection of watercourse flows, water levels and habitat conditions; Consistency with DFO Letters of Advice and Fisheries Act Authorizations, including any reporting requirement terms and conditions therein; Annual assessment of compensatory fish habitat function during the first three years following installation, and periodic assessment thereafter consistent with provincial permitting and EEM requirements. Current Mitigation Criteria for Considering Adaptive Potential Adaptive Applicable Regulatory Instrument(s) Responsibilities Fish habitat compensation is being provided for anticipated flow-induced fish habitat losses to Karel Creek linked to open pit dewatering; Fish habitat compensation is being provided for the direct displacement of fish habitat resulting from development of the TIA and MRS #2. Follow-up groundwater modeling and field monitoring exceeds predicted open pit dewatering flow reduction effects on Karel Creek and Linden Creek; Water flows and /or levels are affected by water takings from local watercourses beyond levels predicted in the CSR; Fish habitat compensation measures are not functioning as intended. Provide additional fish habitat compensation plan for approval by DFO; If water levels drop below thresholds required for fish passage, line that portion of Karel Creek which is closest to the open pit, to allow for continued, seasonal fish passage between upstream and downstream portions of the creek, as per normal fish movement cycles; If water levels drop below thresholds required for fish passage, provide flow supplementation from nearby, unaffected water sources, including possible groundwater sources; Relocate affected watercourses further from the open pit area of dewatering influence, if water levels drop below thresholds required for fish passage; Redirect a portion of Karel Creek flows to the open pit at mine closure, if it can occur without adversely affecting Karel Creek fish habitat functions. DFO Fisheries Act Authorizations and Letters of Advice; MMER; MOE PTTW and ECA (or CofA); MNDM Closure Plan. In the Annual FUP Report, DGC will provide a summary of follow-up and monitoring information as outlined in the verification / assessment methods. DGC is also responsible for implementing mitigation measures and, if necessary, potential adaptive management measures described above. The Annual FUP Report prepared by DGC will also include relevant summary information regarding submissions and project performance in relation to: 13

14 EC s MMER requirements as well as EEM data (effluent criteria and water quantity/quality); DFO s fish habitat functions requirements; MOE PTTW and ECA requirements; and MNDM s Closure Plan implementation, required under the Ontario Mining Act. 14

15 6.3 Local Water Courses, Lakes and Wetlands: Sediment Quality Aspect EA Prediction Rationale for Inclusion in FUP: Potential Residual Effect or Concern Verification / Assessment Methods Current Mitigation Criteria for Considering Adaptive Potential Adaptive Valued Ecosystem Component Local Water Courses, Lakes and Wetlands Sediment Quality (aspect of Project CSR FUPF) No explicit sediment quality predictions stated through the EA process; Implied that receiving water sediment quality would not be adversely affected as receiving water quality expected to meet background conditions, or applicable criteria for the protection of aquatic life. Sediments in waters downstream of the TIA could be further impacted by TIA effluent discharges associated with Project effluents; Sediments in waters downstream of other Project components such as mineral stockpiles could potentially be affected by runoff and seepage releases, as well as by airborne dust. EC s MMER EEM and MOE s ECA monitoring programs include sediment and benthos sampling and reporting. Annual sediment sampling in the on-site collection ponds downstream of MRS #1. Water quality treatment and management as described in FUP table 6.1; Receiving water quality exceeds background conditions, or applicable criteria for the protection of aquatic life criteria; Sediment sampling shows a significant increase in metals concentrations beyond current background conditions; Further optimize water quality treatment and management as described in the FUP table 6.1; Develop further measures derived from the study of waters downstream of the TIA as provided for in the provincial ECA; Changes to effluent, runoff and seepage discharge locations and arrangements to reduce chances of sediment re-suspension; Further optimize dust suppression efficiencies. Applicable Regulatory Instrument(s) MMER EEM; MOE ECA; MNDM Closure Plan. 15

16 Responsibilities In the Annual Follow-up Report, DGC will provide a summary of follow-up and monitoring information as outlined in the verification / assessment methods. DGC is also responsible for implementing mitigation measures and, if necessary, potential adaptive management measures described above. The Annual FUP Report prepared by DGC will also include relevant summary information regarding submissions and project performance in relation to: EC s MMER requirements as well as EEM data; MOE ECA requirements; and MNDM s Closure Plan implementation, required under the Ontario Mining Act. 16

17 6.4 Groundwater System: Water Quality and Quantity Aspect EA Prediction Rationale for Inclusion in FUP: Potential Residual Effect or Concern Verification / Assessment Methods Current Mitigation Criteria for Considering Adaptive Valued Ecosystem Component Groundwater System Water Quality and Quantity (aspect of Project CSR FUPF) Open pit dewatering expected to reduce Karel Creek and Linden Creek flows by 830 m 3 /d and 300 m 3 /d, respectively (base case), with a more conservative (but less likely) flow reduction estimate for Karel Creek of 2,160 m 3 /d; fish habitat compensation to be provided; Pit dewatering induced flow reductions expected to occur in close proximity to the open pit based on modeling of the 1 m groundwater drawdown isopleths; Except as described below, precipitation entering mine rock and overburden stockpiles, after intersecting native ground, is expected to flow mainly in a lateral gradient, thereby directing seepage to the perimeter runoff and seepage collection facilities; A substantial portion of seepage from portions of MRS#1 located near to the open pit expected to drain subsurface to the open pit because of pit-induced dewatering gradients (mine water is to be pumped to the TIA); Runoff and seepage collection systems expected to intercept runoff and seepage such that the groundwater system does not become contaminated. Dewatering of the open pit has the potential to reduce watercourse flows, and/or watercourse (or lake) water levels, and associated fish habitat, beyond those predicted by modeling during the EA process; Seepage from the TIA and MRS has the potential to contaminate the local groundwater system. Periodic re-running of the open pit groundwater model at two year intervals during the first five years of pit dewatering, and periodically thereafter as determined by provincial approvals; MMER and open pit dewatering PTTW monitoring as per regulation and permit conditions; Undertake annual detailed water quality survey of runoff and seepage collection systems related to the TIA and MRS, during summer low flow conditions, with sampling intervals spaced at approximately 250 m, and with sampling to be conducted for a set of key parameters (ph, hardness, sulphate, copper, iron, lead, nickel, zinc, and weak acid total cyanide for TIA samples). Fish habitat compensation for potential adverse dewatering effects on Karel Creek and Linden Creek; TIA seepage collection; Stockpile runoff (MRS and low grade ore) and seepage collection. Follow-up groundwater modeling exceeds predicted open pit dewatering flow reduction effects on Karel Creek and Linden Creek; Groundwater shows signs of contamination outside of the Mine Operation Area as defined under MMER and delineated in the CSR. 17

18 Potential Adaptive Applicable Regulatory Instrument(s) Responsibilities Potential adaptive management measures applicable to maintaining fish habitat as per the FUP table 6.2; Further optimize runoff and seepage collection system efficiencies; Installation of additional monitoring wells. MMER; MOE PTTW; MNDM Closure Plan. In the Annual FUP Report, DGC will provide a summary of follow-up and monitoring information as outlined in the verification / assessment methods. DGC is also responsible for implementing mitigation measures and, if necessary, potential adaptive management measures described above. The Annual FUP Report prepared by DGC will also include relevant summary information regarding submissions and project performance in relation to: EC s MMER requirements and EEM data; DFO s fish habitat functions requirements; MOE PTTW requirements; and MNDM s Closure Plan implementation, required under the Ontario Mining Act. 18

19 6.5 Terrestrial Environment: Migratory Birds Valued Ecosystem Component Aspect EA Prediction Rationale for Inclusion in FUP: Potential Residual Effect or Concern Verification / Assessment Methods Current Mitigation Terrestrial Environment Migratory Birds (aspect of Project CSR FUPF) Mine site development will displace approximately 19.4 km 2 of previously undisturbed forest habitat; Transmission line development will displace a further approximately 3.26 km 2 of undisturbed forest habitat; Ground cover will be retained during construction of the transmission line; Riparian habitats bordering watercourses and lakes will be left largely intact, with the exception of lands taken up by runoff and seepage collection facilities; Noise propagation is such that 30 dba approximate sound levels are expected to be attained at the outer boundary of a 5 to 10 km buffer zone around the Project site; Site reclamation at closure will provide habitats suitable for a variety of migratory birds and other wildlife; Toxicity related to tailings ponds will not likely be a concern, as cyanide concentrations in the tailings ponds are expected to be less than 1 mg/l, well below any toxicity threshold; cyanide concentrations of less than 50 mg/l are considered safe for wildlife (Donato et al., 2007). Mine development has the potential to displace a greater area of migratory bird habitat than predicted during the EA process; Noise from site operations beyond that considered during the EA process has the potential to cause additional disturbance to breeding migratory birds, and potentially to interfere with the hunting success of owl species (a few of which are migratory). Periodic satellite imagery of the Project mine site area to confirm the physical displacement of previously undeveloped forest habitat; As-built dimensions of the transmission line right-of-way; Monitor avian species-at-risk at four year intervals, starting in 2013; Noise surveys to be conducted in summer and winter starting one year following commercial production, and at two-year intervals thereafter, to confirm noise model predictions; noise to be measured at representative stations positioned at 5 km and 10 km from the Project site centroid in each of the four cardinal directions, as limited by access; Monitoring of success of post-closure revegetation at the beginning and end of each growing season for post-closure years one through three; and annually for post-closure years four through ten; and at five-year intervals thereafter for an additional period of fifteen years. The MNDM Notice of Project Status will confirm the commencement of closure activities. Mine site developed as much as possible on previously disturbed areas, and in as compact an arrangement as practicable to limit disturbance to new habitat and to limit noise propagation; 19

20 Retain ground cover along transmission line by utilizing winter road access for primary construction; Maintain to the extent practicable, a 120 m mine site buffer zone adjacent to watercourses and lakes; Restore disturbed habitats at mine closure to habitats capable of supporting a diversity of wildlife species, including an emphasis on the development of Common Nighthawk habitat; Avoid tree clearing and land disturbance during the bird nesting season; Avoid disturbance to raptor nest sites; Pre-treat the mill effluent discharge to prevent wildlife toxicity. Criteria for Considering Adaptive Potential Adaptive Applicable Regulatory Instrument(s) Responsibilities Mine site and transmission line development displace larger than anticipated quantity (area) of previously undeveloped forest habitat; Ground cover not retained along transmission line right-of-way; Riparian habitats are impacted beyond boundaries predicted in the CSR; Noise propagation is such that 30 dba approximate sound levels are not expected to be attained at the outer boundary of a 5 to 10 km buffer zone around the Project site; Site reclamation at closure does not provide habitats suitable for a variety of migratory birds and other wildlife. Undertake trial test work to determine optimal site revegetation approaches for reclamation; Improve noise mitigation if and as required; EC Migratory Birds Convention Act, 1994; EC s SARA; MOE ECA Air (possibly); MNDM Closure Plan requirements. In the Annual FUP Report, DGC will provide a summary of follow-up and monitoring information as outlined in the verification / assessment methods. DGC is also responsible for implementing mitigation measures and, if necessary, potential adaptive management measures described above. The Annual FUP Report prepared by DGC will also include relevant summary information regarding submissions and project performance in relation to: EC s SARA and Migratory Birds Convention Act, 1994 requirements; MOE ECA requirements, if applicable; and MNDM s Closure Plan implementation, required under the Ontario Mining Act. 20

21 6.6 Species-at-Risk: Caribou Valued Ecosystem Component Aspect EA Prediction Rationale for Inclusion in FUP: Potential Residual Effect or Concern Verification / Assessment Methods Species-at-Risk (aspect of CSR FUPF) Caribou (aspect of Project CSR FUPF) Mine site development will displace approximately 19.4 km 2 of previously undisturbed forest habitat, including approximately 5.6 km 2 of Black Spruce Jack Pine forest which provides favoured late winter habitat for Caribou; Transmission line development will displace a further approximately 3.26 km 2 of undisturbed forest habitat; Caribou may avoid or show diminished use of, habitats within 5 to 10 km of the principal Project mine site area; Noise propagation is such that 30 dba approximate sound levels are expected to be attained at the outer boundary of a 5 to 10 km buffer zone around the Project site; Site reclamation at closure to provide habitats suitable for Caribou, with an emphasis on patchy lichen habitats to be developed on MRS (pending site trial success). Mine related noise emissions and other disturbances have the potential to displace Woodland Caribou to a greater extent than predicted during the EA process; Habitats developed for Caribou at closure are not utilized to the extent expected. Periodic satellite imagery of the Project mine site area to confirm the physical displacement of previously undeveloped forest habitat; As-built dimensions of the transmission line right-of-way; Early and late winter aerial helicopter surveys of Caribou (as well as Moose and Wolves), with such survey to be conducted annually through to the first two years of mine operations, and biannually (every two years) thereafter until the end of active mine closure; Possibly provide support to MNR s Caribou radio-telemetry program; Noise surveys to be conducted in summer and winter starting one year following commercial production, and at two-year intervals thereafter, to confirm noise model predictions; noise to be measured at representative stations positioned at 5 km and 10 km from the Project site centroid in each of the four cardinal directions, as limited by access; Monitor success of post-closure revegetation at the beginning and end of each growing season for post-closure years one through three, and annually for post-closure years four through ten; and at five-year intervals thereafter for an additional period of fifteen years. The MNDM Notice of Project Status will confirm the commencement of closure activities; Maintain wildlife log of general observations including sightings along access roads; Determine effects of mine-related dust on area lichen growth / survival; Conduct vegetation trials (test plots) to assess a variety of overburden / soil amendments directed at establishing lichen and other 21

22 vegetative communities for MRS reclamation; Complete satellite and noise monitoring, helicopter surveys, dust and vegetation surveys, revegetation trials (test plots) and revegetation at closure. Current Mitigation Criteria for Considering Adaptive Potential Adaptive Applicable Regulatory Instrument(s) Responsibilities Mine site developed as much as possible on previously disturbed areas, and in as compact an arrangement as practicable to limit disturbance to new habitat and to limit noise propagation; Avoid disturbance to known habitats for Caribou calving; Avoidance of development of new major access corridors (transmission line and roads); Implement wildlife management protocols to limit unnecessary disturbance to Caribou; Restore disturbed habitats at closure to habitats capable of supporting a diversity of wildlife species with a focus on Caribou as practical. Mine site and transmission line development displace the more quantity (area) of previously undeveloped forest habitat than anticipated in the CSR; When compared to the levels observed in baseline conditions, caribou are not being observed utilizing habitats beyond a buffer zone of 5 to 10 km of the principal Project mine site area and are not utilizing habitats within the buffer zone more sparingly; Noise propagation is such that 30 dba approximate sound levels are not expected to be attained at the outer boundary of a 5 to 10 km buffer zone around the Project site; Site reclamation at closure does not provide habitats which are suited to, and utilized by Caribou. Undertake trial test work to determine optimal site revegetation measures for reclamation including the development of specific habitats for Caribou; Improve noise mitigation if and as required. EC Species at Risk Act (SARA) and associated Boreal Woodland Caribou SARA Recovery Strategy; MNR Endangered Species Act and associated Woodland Caribou Conservation Plan; MNDM Closure Plan requirements. In the Annual FUP Report, DGC will provide a summary of follow-up and monitoring information as outlined in the verification / assessment methods. DGC is also responsible for implementing mitigation measures and, if necessary, potential adaptive management measures described above. The Annual FUP Report prepared by DGC will also include relevant summary information regarding submissions and project performance in relation to: EC s SARA requirements in accordance with the Boreal Woodland Caribou Recovery Strategy; MNR s Endangered Species Act and associated Woodland Caribou Conservation Plan requirements; and MNDM s Closure Plan implementation, required under the Ontario Mining Act. 22

23 6.7 Resource Harvesting (Country Foods): Local Fish Valued Ecosystem Component Aspect EA Prediction Rationale for Inclusion in FUP: Potential Residual Effect or Concern Verification / Assessment Methods Current Mitigation Criteria for Considering Adaptive Resource Harvesting (Country Foods) Local Fish (aspect of Project CSR FUPF) Effluent discharges expected to meet applicable regulatory thresholds defined through legislation or site specific permits and approvals; Receiving water quality expected to meet background conditions, or applicable criteria for the protection of aquatic life criteria; Mercury, lead and cadmium levels in fish (Northern Pike as the sentinel species) to remain below thresholds that would be of concern for human consumption. Fish numbers in downstream waters reduced; Fish in downstream waters of mine site activities could potentially accumulate heavy metals to levels unsuited for human consumption. Regular water quality sampling, analysis and data interpretation as dictated by legislation or applicable site specific permits and approvals; MMER EEM and ECA monitoring programs include sediment and benthos sampling and reporting; Fish flesh (Northern Pike) sampling for mercury in East Lake and downstream East Creek / Sunday Creek system waters as per ECA requirements; Local Aboriginal people to voluntarily submit fish for sampling and analysis. Consider engaging and funding Aboriginal people in the conduct of a harvesting and contaminant analysis program for country foods including pickerel/walleye, moose, beaver, and caribou. Water quality treatment and management as described in the FUP table 6.1; Maintain open dialogue with Aboriginal representatives and local fishermen; Conduct additional TK studies. Receiving water quality exceeds background conditions, or applicable criteria for the protection of aquatic life criteria; Sediment sampling shows a significant increase in metals concentrations beyond current background conditions; Fish sampling (northern pike) sampling for mercury, lead and cadmium to identify whether levels are above thresholds of concern for human consumption in East Lake and downstream East Creek/Sunday Creek system waters; Area fish samples (and species) turned in by Aboriginal fishermen show mercury, lead and cadmium levels above thresholds of concern 23