24.0 FOLLOW-UP MONITORING AND ENVIRONMENTAL MANAGEMENT PLANS

Transcription

1 24.0 FOLLOW-UP MONITORING AND ENVIRONMENTAL MANAGEMENT PLANS 24.1 OBJECTIVES AND CONTEXT Under CEAA 2012, an EA must consider the need for, and the requirements of, follow-up monitoring. A follow-up program under CEAA 2012 has the following objectives: to verify the accuracy of the EA of a project; and to determine the effectiveness of measures taken to mitigate the adverse environmental effects of a project. These objectives have been expanded to include: compliance with environmental approvals, permits and authorizations; provide for adaptive management measures should environmental effects differ from that predicted, or incorporate new information that becomes available; and support environmental management plans used to manage environmental effects of the Project. The follow-up monitoring program will have a specific focus on key issues of relevance to the EA. The follow-up program will incorporate existing field data as applicable to define background conditions. The Project will involve a comprehensive set of monitoring programs covering key environmental components, each with its own scope and objective. Follow up monitoring will be used to inform adaptive management strategies and specific compliance monitoring will also inform adaptive management measures as appropriate PLAN FOR DEVELOPING FINAL FOLLOW-UP MONITORING PROGRAM The follow-up monitoring program presented in the EA is preliminary. The preliminary program is intended to demonstrate the commitment of GGM, as the proponent, to an appropriate and thorough process of verifying that the changes to the environment as a result of the Project are as predicted and that adverse effects are limited. Upon approval of the Final EIS/EA, and completion of permitting and construction, continued planning for Project implementation will include corresponding refinement of the follow-up program. Program plans are iterative by nature, and refinement will be carried out with consideration for the comments received during EA process and the associated authorizations, permitting and licensing processes. 24.1

2 While the follow-up monitoring program will be developed considering collective input as noted above, the program will also remain dynamic throughout its implementation period and remain flexible to enable adaptation to changing circumstances/requirements and ongoing input from stakeholders. The details of the program will be refined for implementation to consider the more specific aspects of monitoring/sampling location and frequency, parameters, program duration, during permitting and throughout all Project phases. Appropriate methods of disseminating and communicating follow-up results to the general public and Aboriginal communities will be developed ADAPTIVE MANAGEMENT As discussed in the EIS Guidelines, adaptive management is not considered as a mitigation measure, but if the follow-up program indicates that corrective action is required, the proposed approach for managing the action should be identified (Appendix A1). Adaptive management is a planned and systematic process for continuously improving environmental management practices by learning from their outcomes. Adaptive management provides the flexibility to address/accommodate new circumstances, to adjust monitoring, implement new mitigation measures or modify existing measures. The collective monitoring activities associated with the Project will be used to inform adaptive management strategies. An adaptive management framework is shown on Figure

3 \\Cd1220-f02\01609\active\ \drawing\Graphics\Corel\AdaptiveManagementResponseFramework\ _AdaptiveManagementFrameworkFigure24-1.cdr DRAFT Client/Project December 2015 Project No Greenstone Gold Mines GP Inc. (GGM) Hardrock Project Figure No DRAFT Title Adaptive Management Framework

4 24.4 REPORTING Although the form and frequency of EA follow-up reporting will be determined as the program is finalized it is anticipated that those elements relevant to EA follow-up will be assembled into a formal report and provided to interested parties on an annual basis during construction and operation and also during closure in years when monitoring is carried out. Depending on the results and considering the frequency of sampling events over the long term, particularly with respect to mitigation measures that prove to be effective and stable, it may be that, the monitoring and reporting frequency would be adjusted ATMOSPHERIC ENVIRONMENT Management and Monitoring Program Basis and Objectives The air dispersion modelling predicted, with the implementation of mitigation measures, that the increase in ambient concentrations of PoPC as a result of the Project are within regulatory limits and objectives at identified receptors. In order to confirm the effectiveness of the mitigation measures and to verify that ambient levels are within regulatory limits GGM will develop a follow-up monitoring program to monitor dust (PM and PM2.5) levels at selected offsite locations during the operating phase. The monitoring data will also be used to account for unanticipated environmental effects and provide for adaptive management Monitoring Methods The type of ambient monitoring equipment, selection of monitoring stations, frequency of sample collection, and duration of the program will be based on MOECC guidelines and consultation with government agencies. However, it is expected that the monitoring program will be comprised of the following key elements: ambient air quality in the LAA will be monitored to determine the suitability and effectiveness of dust control practices using dust fall jars, and high volume samplers for PM and/or PM2.5; select filtered samples will be assessed for metals (including arsenic, calcium, potassium and manganese) as designated within O.Reg 419/05. Monitoring stations will be placed based on predicted dispersion modelling for PoPC, and subject to power availability and siting constraints; equipment siting, operations, auditing, and reporting will follow MOECC requirements; and EA follow-up monitoring results will be compared with predictions presented in the EIS/EA, Appendix F1, and with applicable O. Reg. 419/05 criteria. 24.5

5 24.6 ACOUSTIC ENVIRONMENT Management and Monitoring Program Basis and Objectives Results of the noise model and vibration assessment predict that noise and vibration from construction, operation and closure activities will be below provincial thresholds at the closest receptors. GGM will develop a follow-up program to monitor sound levels at the closest receptors during construction and operation. Although the preliminary blast design meets the MOECC s criteria and mitigation is not required, GGM will monitor blast noise and vibration at key stages, comparing to NPC 119 criteria. In addition to verifying compliance with provincial regulatory noise and vibration limits, monitoring results will be used to assess the effectiveness of noise mitigation measures, and inform adaptive management Monitoring Methods The type of ambient monitoring equipment, selection of monitoring stations, frequency of sample collection, and duration of the program will be based on MOECC guidelines and consultation with government agencies. However, it is expected that the monitoring program will be comprised of the following key elements: ambient noise monitoring during summer months for the construction phase; an ambient monitoring program will be conducted during summer months for the first two years of operation; periodic monitoring of noise and vibration during blasting activities; equipment siting, operations, auditing, and reporting will follow MOECC requirements; and EA follow-up monitoring results will be compared with predictions presented in the Final EIS/EA, Appendix F2, and with applicable MOECC s environmental noise guideline Publication NPC 103. Monitoring results from the first two years of operation will be used to define a monitoring schedule going forward through the remaining LOM. The monitoring schedule will be developed in accordance with the requirements of MOECC Publication NPC GROUNDWATER Management and Monitoring Program Basis and Objectives Groundwater modelling predicts a minor and localized lowering of water table levels as a result of dewatering of the open pit during construction and operation and to a lesser extent during 24.6

6 closure when the open pit refills. Modelling also predicts that metal loading to the environment is anticipated to be less than at baseline conditions due to the partial removal of historical tailings. Although there are no groundwater supply users within the area (i.e., the LAA) where effects on groundwater are anticipated, GGM will develop a follow-up and monitoring program to monitor groundwater levels and groundwater quality at key Project locations. Monitoring data will be used to confirm the anticipated effects identified in the groundwater model and to meet regulatory requirement related to specific permits (i.e., Permit To Take Water) or conditions of approval Monitoring Methods During operations a detailed groundwater monitoring program will be implemented, building on the baseline monitoring program, to confirm potential changes in groundwater associated with mine operations. The EA follow-up and monitoring program for groundwater will be developed based on regulatory requirements for both quantity and quality. During closure, the groundwater monitoring program will be continued to document the recovery in groundwater levels as the open pit fills. The type of monitoring equipment, selection of monitoring stations, frequency of sample collection, and duration of the program will be based on MOECC guidelines and consultation with government agencies. However, it is expected that the monitoring program will be comprised of the following key elements: monitoring wells at select locations around the open pit to collect groundwater levels during construction, operation and closure to monitor the effects on groundwater levels due to open pit dewatering and recovery during closure; monitoring wells/drive point piezometers in the vicinity of Kenogamisis Lake, Southwest Arm Tributary, Goldfield Creek, and associated wetlands to collect groundwater levels during construction, operation and closure to monitor the effects on groundwater levels due to open pit dewatering and recovery during closure; monitoring wells upgradient, cross gradient, and downgradient of the TMF, WRSAs, and historical tailings to collected groundwater levels and water quality during construction, operation, and closure to document changes to groundwater levels and flow and groundwater quality; groundwater quality samples from monitoring wells will be monitored semi-annually during construction, operation and closure with the frequency progressively reduced based on monitoring results and project phase. Groundwater quality samples will be analyzed for general chemistry and select dissolved metals, with additional parameters added based on potential parameters of concern; and 24.7

7 EA follow-up monitoring results will be compared with applicable regulatory standards set out in CCME, MMER, ODWQS, PWQO, and O.Reg. 153/04 and Project specific regulatory approvals (PTTW, ECA, and certified Closure Plan) SURFACE WATER Management and Monitoring Program Basis and Objectives Water quantity effects as a result of the Project relate to potential streamflows and drainage area patterns in the LAA. Potential effects on water quality relate mainly to discharge of mine water effluent and sanitary effluent to receiving waters. Surface water quantity effects related to the Project will occur within the LAA. The water quantity effects related to the Project are negligible for Kenogamisis Lake. The changes in flows are within the natural range of flows experienced in the Kenogamisis Lake system. Surface water quality effects will not extend beyond the boundary of the LAA. The effluent mixing zone will be contained within the Southwest Arm of Kenogamisis Lake and baseline or PWQO background conditions will be achieved before reaching the LAA boundary. are limited to the mixing zone in Kenogamsis Lake where effluent quality is expected to meet PWQOs. The objectives of the water quality monitoring program are to confirm predicted effects of effluent discharges and runoff on water quality, confirm changes in drainage patterns and surface water flow, and determine if additional monitoring or mitigation measures are required as part of adaptive management, and to meet regulatory requirement related to specific permits (i.e., ECA, MMER, MISA) or conditions of approval Monitoring Methods During operations a detailed surface water monitoring program will be implemented, building on the baseline monitoring program, to confirm potential changes in surface water flows and quality associated with mine operations. The EA follow-up and monitoring program for surface water will be developed based on regulatory requirements for both quantity and quality. During closure, the surface water monitoring program will be continued as required in regulatory approvals, but may be reduced in frequency based on discharge requirements as as the open pit fills. The type of monitoring equipment, selection of monitoring stations, frequency of sample collection, and duration of the program will be based on MOECC guidelines and consultation with government agencies. However, it is expected that the monitoring program will be comprised of the following key elements: water level recording; 24.8

8 channel velocity, depth and flow profiling during ice-free period; and water quality. The type of monitoring equipment, selection of monitoring stations, frequency of sample collection, and duration of the program will be based on MOECC guidelines, site conditions, and baseline programs. It is expected that the monitoring program will be comprised of the following key elements: surface water quality monitoring stations in the Southwest Arm of Kenogamisis Lake to monitor effluent discharge on water quality. Monitoring to occur during construction, operation and closure; surface water quality monitoring stations in Barton Bay and Central Basin of Kenogamisis Lake to document changes in water quality as a result in reductions in loading from historical tailings sources and to assess potential effects from Project discharges. Monitoring to occur during construction, operation and closure, with the frequency progressively reduced based on monitoring results and project phase; surface water quality monitoring in streams and lakes in the LAA including: Goldfield Creek (downstream of TMF), Goldfield Creek Tributary, Goldfield Creek diversion channel, and Southwest Arm Tributary inflow to Southwest Arm of Kenogamisis Lake, and potentially Goldfield Lake and Mosher Lake. Monitoring of surface water quality at these proposed locations will be conducted during construction, operation and closure, with the frequency progressively reduced based on monitoring results and project phase; surface water quality monitoring of the pit lake during closure; surface water quality samples will be monitored monthly during construction, operation and closure with the frequency progressively reduced based on monitoring results and project phase. Water quality samples will be analyzed for general chemistry and select dissolved metals, with additional parameters added based on potential parameters of concern; sediment sampling in Kenogamisis Lake and in lower Kenogamisis River, as well as at comparable reference locations; implementation of Construction Monitoring Program to satisfy the requirements under the of Fisheries Act; and EA follow-up monitoring results will be compared with predictions presented in the Final EIS/EA, Appendix F5, and with applicable regulatory standards set out in MMER, MISA, PWQO, Project-specific ECA, and EEM requirements as part of the MMER. 24.9

9 24.9 FISH AND FISH HABITAT Management and Monitoring Program Basis and Objectives The Draft EIS/EA concludes that through mitigation and the implementation of a Fish Habitat Offset Plan no residual effects on fish habitat will occur as a result of the permanent alteration or loss of fish habitat due to stream diversion or placement of fill and structures in water. GGM will implement a monitoring program to confirm that offsetting measures meet their intended objectives. The monitoring program will consist of two components: compliance/construction monitoring for offsetting works; and habitat effectiveness monitoring. Compliance/construction monitoring will confirm that fish habitat offsets are constructed in accordance with the final Fish Habitat Offset Plan and that conditions of the Fisheries Act authorization are met. Habitat effectiveness monitoring will confirm that fish habitat offsets are functioning as intended after construction Monitoring Methods Compliance/construction monitoring for the fish habitat offsets works will be integrated into the supervision of fish habitat offset construction. These include: EEM program to evaluate the effects of mine effluent discharges on Kenogamisis Lake; ECA monitoring to evaluate the effects of mine effluent on Kenogamisis Lake (this will be harmonized with the EEM program); Construction Monitoring Program to satisfy the requirements under the Fisheries Act authorization for serious harm to fish. monitoring program to satisfy the permitting requirements under the Lakes and Rivers Improvement Act. A natural channel design specialist and fisheries biologist will be onsite during start-up and at critical periods of construction. Information to be documented during construction will include: written and photo-documented sequence of events during construction; changes in the design that are necessary to adapt to unanticipated field conditions;; technical issues that arise during construction and how they were addressed; confirmation that offsetting components meet design requirements; and confirmation that terms and conditions of the Fisheries Act authorization are met

10 An as-built report will be submitted to DFO, as required, following offsetting habitat construction. Habitat effectiveness monitoring will commence soon after the commissioning the channel and is recommended at the following intervals following construction: Year 1, Year 3, and Year 8. This will be confirmed with the DFO and the MNRF and identified in the final Fish Habitat Offset Plan. The specific data collection methods for the monitoring program will depend on the final Fish habitat Offset Plan measures implemented. As part of the final Fish Habitat Offset Plan, success criteria will be established. If success criteria are not achieved by a specified target year, a work plan will be developed to address objectives. The productivity of the diversion channel may be measured against the middle reach of Goldfield Creek (pre-construction) and could involve a comparison of physical habitat features such as: substrate diversity; and morphological function (where possible the constructed channel will have additional riffles and over-wintering pools). Monitoring will determine when benthic invertebrates begin to re-colonize the diversion channel. Data will be compared to pre-construction conditions (Goldfield Creek) to evaluate species richness and density of the diversion channel. This will be achieved through quantitative sampling during both baseline and effectiveness monitoring phases GEOCHEMISTRY Management and Monitoring Program Basis and Objectives The assessment of ARD/ML concluded that waste rock, and tailings generated by the Project are expected to contain PAG material. Historical tailings within the footprint of the open pit will be moved to the TMF during mine operation were effects from these historical tailings will be reduced. The objective of the geochemical follow-up and monitoring program will be to confirm geochemical model predictions, confirm the effectiveness of mitigation measures and verify the conclusions in the Final EIS/EA, and support operational management of waste rock through implementation of the Waste Rock Management Plan. Geochemical programs will also be developed to verify and support closure design related to cover requirements for the TMF and the WRSAs Monitoring Methods The release of parameters from mine waste material as a result of ARD/ML will be monitored through the collection of contact water and reclaim water from the TMF. These data will be 24.11

11 used to confirm geochemical and water quality predictions and to support on-going operational water management for the Project. The actual data collection will be addressed through the Groundwater (Section 24.7) and Surface Water (Section 24.8) monitoring programs. The geochemical characterization specific to waste rock will continue during the mine life and the results will be used to inform adaptive management and will be outlined in the Waste Rock Management Plan UPLAND VEGETATION AND WETLANDS Management and Monitoring Program Basis and Objectives Environmental effects on upland vegetation and wetlands will result from vegetation removal in upland habitats and wetland habitats throughout the PDA. As discussed in Section 12.5, following the implementation of mitigation measures the Project will not alter or remove an upland vegetation community type resulting in the loss of long-term viability of that vegetation community type in the RAA, and will not result in effects on a species listed on Schedule 1 of SARA or listed as threatened or endangered under the ESA. Also, the Project will not alter a wetland community type such that the long-term viability of that community type is compromised in the LAA. In order to confirm the effectiveness of mitigation and to verify the conclusions of the EIS/EA for upland vegetation and wetlands, GGM will develop a follow-up and monitoring program. The monitoring data will also be used to account for unanticipated environmental effects and provide for adaptive management Monitoring Methods The monitoring program will be developed to assess potential disturbance to upland vegetation and wetlands, and will include: Project footprint tracking through construction and operation; and verification monitoring of wetland function in the areas susceptible to drawdown. A monitoring program will be developed to monitor the success and stability of rehabilitated areas. The program will be designed to assess revegetated areas such as the WRSAs and TMF and former processing plant areas, which would be inspected during late spring and summer during active rehabilitation and periodically during post-closure. The objectives of the program are to determine whether revegetation measures are successful and confirm that erosion is not an issue. Progressive rehabilitation trials during operations are important to the success of revegetation efforts

12 24.12 WILDLIFE AND WILDLIFE HABITAT Management and Monitoring Program Basis and Objectives The Project will result in the loss of habitat for Canada Warbler, common nighthawk, eastern wood peewee; and SWH for waterfowl nesting, stopover and staging, for moose late winter cover, for turtle wintering and for taiga alpine butterfly. Other potential effects on wildlife mortality due to site clearing and vehicle collisions; change in wildlife movement due to sensory disturbance and Project components which may act as physical barriers. Following the implementation of mitigation measures to reduce or limit effects to wildlife and wildlife habitat, the Draft EIS/EA predicts that residual effects as a result of the Project: do not result in an adverse effect on the sustainability, within the RAA, of a species listed on Schedule 1 of SARA or listed as threatened or endangered under the ESA; do not result in an adverse effect on the sustainability, within the RAA, of a species of conservation concern; do not result in permanent loss of critical habitat for a species listed on Schedule 1 of SARA; do not result in the permanent loss of habitat from the RAA for a species listed as threatened or endangered under the ESA or identified as a species of conservation concern; and do not permanently alter a provincially significant wildlife habitat type in a manner that results in an adverse effect on the sustainability of a wildlife population within the RAA. GGM will implement a follow-up program in order to confirm the effectiveness of the mitigation and verify the results of the Final EIS/EA regarding residual adverse effects on wildlife Monitoring Methods The monitoring program for follow-up will include: recording Project-related wildlife-vehicle collisions or near misses. These data will be regularly reviewed by the Environmental Department. If a problem area is identified appropriate actions will be taken (e.g., warning signs, site-specific speed limits).; maintaining a wildlife observation log for the mine site and associated infrastructure (e.g., access roads). The log will be submitted to the MNRF each year. Project personnel and contractors will be encouraged to report sightings of wildlife on and around the Project site; GGM will incorporate the collection of data on wildlife use of rehabilitated areas into the regular rehabilitation monitoring as will be prescribed in the closure plan

13 24.13 HERITAGE RESOURCES Follow-up monitoring is not required for heritage resources. As stated in Section 19.7, if archaeological resources are encountered during construction GGM will stop work immediately and contact MTCS prior to the implementation of procedures and mitigation as required under the Ontario Heritage Act and the 2011 Standards and Guidelines for Consultant Archaeologists (Government of Ontario 2011). A Historical Resources or Traditional Land Use Discovery Environmental Management Plan will be prepared. This plan will outline procedures and protocols concerning the unexpected discovery of additional archaeological resources. Environmental management plans are discussed in Section LABOUR AND ECONOMY Follow-up monitoring for labour and economy will not be required as effects will largely be positive COMMUNITY SERVICES AND INFRASTRUCTURE Government agencies, public and private sector companies that provide community services and infrastructure will monitor the ongoing demand for community services as part of their normal planning practices. No follow-up and monitoring program is required LAND AND RESOURCE USE There are no planned follow-up programs or required compliance reporting for land and resource use. GGM will maintain open communication with local and regional authorities and interest groups throughout the life of the Project to identify and address issues pertaining to the Project s influence on land and resource use TRADITIONAL LAND AND RESOURCE USE Collaborative monitoring with Aboriginal community representatives may be considered for certain aspects of the Project similar to GGM s existing environmental monitoring program. Ongoing dialogue with Aboriginal communities with respect to monitoring will continue throughout the Project. A Historical Resources or Traditional Land Use Discovery Environmental Management Plan will be prepared. This plan will outline procedures and protocols concerning the unexpected discovery of additional archaeological resources. Environmental management plans are discussed in Section

14 24.18 HUMAN AND ECOLOGICAL HEALTH A future surface water quality and fish tissue quality monitoring program will be developed to monitor respective concentrations in the Southwest Arm of Kenogamisis Lake to determine if actual concentrations reflect predicted increases. Ongoing monitoring of fish tissue will be a condition of EEM. The data will serve several purposes such as fulfilling MMER/EEM requirements, permit requirements and ongoing monitoring of identified ecological and human health risks related to fish consumption. Fish will be collected from key locations in Kenogamisis Lake and a reference location. Supporting information of fish age, length and weight will be collected for fish and metals uptake will be examined considering the age and or size of the fish. Laboratory analyses will include a metals scan, mercury and methylmercury. Arsenic speciation will also be considered on a subset of fish ENVIRONMENTAL MANAGEMENT PLANS In addition to the ERP, and associated contingency plans (such as adverse weather and fire suppression) the EMPs for construction and operation will further refine the proposed environmental protection measures to be carried out by GGM, their contractors and subcontractors, during construction and operation respectively, to avoid or reduce potential effects. Table 24-1 describes the specific plans currently envisioned for the Project. These EMPs will be tied to the follow up and monitoring plans, and will outline contingency measures to respond to any exceedances of regulatory standards related to environmental discharges or other adverse effects. Contingency measures specific to each EMP will be implemented in the event that regular environmental and compliance monitoring programs detect deviations from standard operating conditions that result in, or may lead to, adverse effects on worker safety or the environment. The specific requirements for each EMP will be refined as the Project progresses through the permitting phase. Table 24-1 Environmental Management Plans ERP EMP Soil Management Plan Description An ERP will be developed to establish emergency response procedures that protect human health, the environment, and the Project. The site-specific ERP will be developed to reduce, contain, and control potential releases of hazardous material. The ERP will be developed in accordance with permitting or other regulatory instruments for the Project. The 2015 soils investigation is provided in Appendix E9. The purpose of the subsurface investigation was to investigate the soil quality in areas affected by historical mining activities. The primary use of the data will be to assess appropriate management options to be included as part of the Soil Management Plan

15 Table 24-1 Environmental Management Plans EMP Description The Soil Management Plan will outline soil management within the PDA including topsoil and overburden salvage, and historical impacted soil handling, treatment and storage for backhaul. Waste Rock Management Plan Surface Water Management Plan Waste Management Plan Air Quality Management and Monitoring Plan GHG Management Plan Traffic Management Plan Spill Prevention and Contingency Plan Explosives Management Plan Historical Resources or Traditional Land Use Discovery A Waste Rock Management Plan is provided in Appendix M. A site specific, water quantity and water quality plan for water withdrawals (. The Surface Water Management Plan will address excess flow control measures to manage extreme events to protect the receiving environment. Procedures and protocols to manage domestic waste and hazardous wastes generated by the Project. The Waste Management Plan will include management for material handling, disposal methods, training, auditing and contact information for licensed waste disposal contractors. An ambient monitoring plan to meet the requirements described MOECC s Operations Manual for Air Quality Monitoring in Ontario (MOE 2008) (Operations Manual). The Air Quality Management and Monitoring Plan will include duration of the monitoring program, air emission source(s), receptors, location of monitoring sites, monitoring methods equipment and procedures, and dispersion model. Standard management plans for control of fugitive dust emissions from the Project will be addressed. The management plans will be developed following MOECC requirements provided in Appendix B of MOECC Guideline A-10. Each management plan will contain information such as the source and location of emissions, frequency of operation, mitigation and reporting requirements. The GHG Management Plan will cover aspects such as measures to reduce the Project s GHG intensity through final Project design and compliance with relevant GHG emissions management and reporting legislations. The Traffic Management Plan will reduce disruption on the local transportation network during the construction, operation and closure phases. The Spill Prevention and Contingency Plan will outline procedures and protocols regarding spill prevention and spill management procedures to follow in the event of a spill. The plan will include procedures for fuel and lubricant delivery, storage requirements, detailed response system in the event of a spill and routine inspections of facilities. The Explosives Management Plan will detail procedures and protocols regarding material storage and blasting operations. The plan will outline control measures to be followed in order to prevent effects to operations and limit vibration beyond the PDA. It will also address the storage and mixing of explosives. This plan will outline the process of documentation concerning the unexpected discovery of additional archaeological resources or the unanticipated effect of historical/architectural resources

16 Table 24-1 Environmental Management Plans EMP Groundwater Monitoring Plan Erosion and Sedimentation Control Plan Biodiversity Management Plan Description The Groundwater Monitoring Plan will identify aspects of mine operation that could effect groundwater quantity and quality, and will include management practices to limit effects to groundwater flow systems. The Erosion and Sedimentation Control Plan will describe procedures and control measures during construction to mitigate erosion and sedimentation. Measures may include locating soil stockpiles away from watercourses and stabilizing them against erosion, containing work areas within perimeter fencing, removal of mud from construction vehicles in order to reduce deposition on roadways. The Biodiversity Management Plan will address the biodiversity needs and enhancement opportunities of natural areas and species located in the PDA. The plan will describe measures to limit adverse effects to the natural environment during construction and operation. The Biodiversity Management Plan will consist of a Vegetation and Wildlife Management Plan and Monitoring Program. Maintenance and effectiveness of the EMPs will be monitored through formal and informal audits, environmental monitoring, documentation of non-conformance incidents and implementation of corrective actions, and stakeholder feedback. Management reviews will be conducted periodically to consider changing circumstances which could require modifications to an EMP in order to support continual improvement and overall effectiveness REFERENCES Government of Ontario Standards and Guidelines for Consultant Archaeologists. Toronto: Ministry of Tourism, Culture and Sport