TOXICS REDUCTION ACT

Transcription

1 ISLAND GOLD MINE RICHMONT MINES INC. TOXICS REDUCTION ACT TOXIC SUBSTANCE REDUCTION PLANS FOR TRA PHASE II SUBSTANCES

2 Table of Contents TOXICS REDUCTION ACT TOXIC SUBSTANCE REDUCTION PLANS FOR TRA PHASE II SUBSTANCES 1.0 SUMMARY... 1 CERTIFICATION STATEMENTS ATTACHMENTS List of Attachments Attachment Number Document Type Substance Version 1 Master Document Supporting Various Toxic Substance Reduction Plans Particulate Matter Substances Toxic Substance Reduction Plan (Skeleton) Particulate Matter Toxic Substance Reduction Plan (Skeleton) Particulate Matter Toxic Substance Reduction Plan (Skeleton) Particulate Matter Toxic Substance Reduction Plan Nitrogen Oxides Toxic Substance Reduction Plan Carbon Monoxide Toxic Substance Reduction Plan Nitric Acid 1.0 December 16, 2012 VERSION 1.0 i

3 1.0 SUMMARY TOXICS REDUCTION ACT TOXIC SUBSTANCE REDUCTION PLANS FOR TRA PHASE II SUBSTANCES This Document contains Toxic Substance Reduction Plans (the Plans), which have been prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed TRA Phase II toxic substances (the Toxic Substances) for which the Richmont Mines Inc. (Richmont) Island Gold Mine facility (the Facility) has triggered reporting. The TRA was passed in the Ontario Legislature in June The Ontario Ministry of the Environment (MOE) has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however, it does not restrict or require elimination of prescribed toxic substance. Under the TRA, regulated facilities are required to: perform quantification, accounting and reporting on the toxic substance use, creation, amount contained in product and release at the Facility on an annual basis; prepare Toxic Substance Reduction Plans in which it is documented, where feasible, how the use and creation of toxic substances might be reduced; have the Toxic Substance Reduction Plan certified by an MOE licensed Toxic Substance Reduction Planner (the Planner) as well as the Highest Ranking Employee (the HRE) at the Facility; prepare Plan Summaries containing various components of the Toxic Substance Reduction Plans and make them available to the public; submit annual reports on progress made on the Plans; and update the Plans at least every five years. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of toxic substance reduction options identified in the Plan (if any) is not a requirement of the TRA or O.Reg.455/09. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substances since the Facility meets the TRA s definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the respective National Pollutant Release Inventory reporting thresholds for the Toxic Substances. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2010, 2011 and 2012 reporting years in accordance with s.12 of O.Reg.455/09, and the Plans contained within this document satisfy the Toxic Substance Reduction Plan and Plan Summary preparation requirements of the TRA and O.Reg.455/09 for Phase II substances. Version 1.0 1

4 TOXICS REDUCTION ACT TOXIC SUBSTANCE REDUCTION PLANS FOR TRA PHASE II SUBSTANCES As required by s.3 of the TRA, an individual Plan has been prepared for each of the Toxic Substances. In preparing the Plans, the Facility has prepared an individual, stand-alone Toxic Substance Reduction Plan for the following prescribed Toxic Substances: Nitrogen Oxides; Carbon Monoxide; and Nitric Acid. Per guidance provided in s.5.2 of the MOE publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit), where toxic substances travel together through a process (e.g. metals in a mineral processing facility), a Facility may develop a single Master Document which can be referred to in individual Toxic Substance Reduction Plans, provided that the individual Plan for each toxic substance still satisfies all of the requirements of the TRA and O.Reg.455/09. Richmont has elected to take advantage of this administrative efficiency afforded by O.Reg.455/09 through the preparation of the Master Document entitled TRA Master Document Supporting Toxic Substance Reduction Plans for: Particulate Matter; PM10; PM2.5 (Version 1.0) which provides various Toxic Substance Reduction Plan content requirements of the TRA and O.Reg.455/09 for the following Toxic Substances for which the Facility has triggered reporting, and which travel together through the Facility s process: Particulate Matter; PM10; and PM2.5. Where appropriate, Plans for the above noted Toxic Substances reference various contents of the Master Document in order to satisfy the Toxic Substance Reduction Plan preparation requirements of the TRA and O.Reg.455/09. Plans which refer to the Master Document for all required Plan components are referred to as Skeleton Plans and are identified as such in the above Table of Contents. This approach to Plan preparation is seen as a significant administrative efficiency as it minimizes duplication of information to the greatest extent allowed by the TRA and O.Reg.455/09. Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase I Plans for the Facility have been assembled using the Single Document format and therefore the attached Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. Version 1.0 2

5 CERTIFICATION STATEMENTS

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8 ATTACHMENTS

9 ISLAND GOLD MINE RICHMONT MINES INC. TRA MASTER DOCUMENT SUPPORTING TOXIC SUBSTANCE REDUCTION PLANS FOR: PARTICULATE MATTER PM10 PM2.5 VERSION 1.0

10 Document Version Control TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 This document constitutes Version 1.0 of this Master Document which supports various Toxic Substance Reduction Plans. Section 22 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.13 of O.Reg.214/11) provides the framework for Plan review and requirements for a new version of the Plan. Toxic Substance Reduction Plans must be updated by the end of the calendar year in which a significant process change (as defined in s.1 (3) of O.Reg.455/09) occurs. The first mandatory Plan update is required to be completed by December 31, Future updates of this Master Document will be assigned a new version number. Version Date Revision Description Reviewed By (Facility Contact) 1.0 December 2013 TRA Master Document Supporting Plans for Particulate Matter, PM10, PM2.5 Version 1.0 Melanie Gauthier VERSION 1.0 i

11 Executive Summary TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 This Master Document has been prepared as supporting documentation for respective Toxic Substance Reduction Plans (the Plans) for various reportable size fractions of particulate matter which are prescribed toxic substances (the Toxic Substances) for which the Richmont Mines Inc. (Richmont) Island Gold Mine facility has triggered reporting under the Toxics Reduction Act (TRA) and Ontario Regulation (O.Reg.) 455/09. The TRA was passed in the Ontario Legislature in June The Ontario Ministry of the Environment (MOE) has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however, it does not restrict or require elimination of the prescribed toxic substance. Richmont operates the Island Gold Mine facility (the Facility) which is located in Dubreuilville, Ontario. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substances covered by this Master Document (the Toxic Substance) since the Facility meets the TRA s definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the respective reporting thresholds, adopted by the TRA from National Pollutant Release Inventory, for each of the Toxic Substances. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2012 reporting years in accordance with s.12 of O. Reg. 455/09. This Master Document provides various Toxic Substance Reduction Plan content requirements of the TRA and O. Reg. 455/09 for the following prescribed toxic substances for which the Facility has triggered reporting, and which travel together through the Facility s process: Particulate Matter; PM 10 ; and PM 2.5. Section 4(1) of the TRA requires that a Plan include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. The Toxic Substances whose respective Plans reference this Master Document have triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility which are defined as creations of the Toxic Substances under the TRA framework. The first activity that has been classified as a creation of the Toxic Substances for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the generation of suspended particulate matter in various size fractions as dust; which is subsequently released either as stack or fugitive emissions. The second activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting VERSION 1.0 ii

12 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 exercise for the Toxic Substances is the generation of the Toxic Substances in the form of particulate matter as a result of stationary combustion. As a result of voluntary and regulatory commitments described within this Plan, the Facility is of the opinion that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected, and therefore a statement of the Facility s intent to reduce creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substances are never used in the Facility process and therefore no statement with respect to intent to reduce use of the Toxic Substances is required. In light of the above, the objectives of this Master Document, and the respective Plans that refer to it, are as follows: provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substances. Per guidance provided in s.5.2 of the MOE publication Toolkit for Toxic Substance Reduction Planning, version dated, February 15, 2013 (the MOE Planning Toolkit), where toxic substances travel together through a process (e.g. different size fractions of suspended particulate matter), a Facility may develop one or several Master Document which can be referred to in individual Toxic Substance Reduction Plans, provided that the individual Plan for each toxic substance still satisfies all of the requirements of the TRA and O.Reg.455/09. Richmont has elected to take advantage of this administrative efficiency afforded by O.Reg.455/09 through the preparation of Master Document. As required by s.3 of the TRA, an individual Plan has been prepared for each of the above noted Toxic Substances, however, those Plans reference various contents of this Master Document as appropriate in order to satisfy the Toxic Substance Reduction Plan preparation requirements of the TRA and O.Reg.455/09. This is seen as a significant administrative efficiency as it minimizes duplication of information to the greatest extent allowed by the TRA and O.Reg.455/09. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of toxic substance reduction options identified in the Plan (if any) is not a requirement of the TRA or O.Reg.455/09. Since all required components of a Plan Summary are provided in this Master Document, a general Plan Summary which has been prepared based on this Master Document and in accordance with s.23 of O.Reg.455/09 has been provided in Appendix D. This Plan Summary is referenced in respective Plans for the Toxic Substances, as appropriate. Furthermore the Plan Summary is available on Richmont s website and can be provided to a member of the public upon written request. This Master Document provides content that satisfies various Toxic Substance Reduction Plan preparation requirements for various prescribed Toxic Substances under the TRA and O.Reg.455/09. Please see individual Toxic Substance Reduction Plans for additional information. The Facility is required to submit annual reports to the MOE on progress made on the Plans and update the Plans at least every five years. VERSION 1.0 iii

13 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 Table of Contents 1.0 INTRODUCTION BASIC FACILITY INFORMATION PLANNER LICENSE NUMBER STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN Statement of Intent Objectives of the Plan TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2012 REPORTING YEAR Description of each Process that uses the Toxic Substance Description of How, When, Where and Why the Substance is Used or Created Records of Identification and Description of Stages and Processes of Facility Operation and Record Containing Process Flow Diagrams Toxic Substance Accounting Information Quantifications at Process Level for Previous Year Records of Methods and Rationale for Selecting each Method used to Track and Quantify the Toxic Substance ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE OPTIONS CONSIDERED FOR REDUCTION Identification of Toxic Substance Reduction Options in Each of Seven Toxic Substance Reduction Categories Estimates of Potential Reductions Associated with Each Identified Toxic Substance Reduction Option Identification of Technically Feasible Options Analysis of Economic Feasibility of Technically Feasible Options RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS PLANNER RECOMMENDATIONS AND RATIONALE PLAN SUMMARY... 9 Version 1.0 iv

14 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 APPENDICES APPENDIX A Toxic Substance Quantification, Accounting and Reporting Information for the 2012 Reporting Year APPENDIX B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance APPENDIX C Planner Recommendations APPENDIX D Plan Summary Version 1.0 v

15 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM INTRODUCTION Toxic Substance Reduction Plans (the Plans) which reference this Master Document were prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the Richmont Mines Inc. (Richmont) Island Gold Mine Facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The MOE has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Under the TRA, regulated facilities are required to: perform quantification, accounting and reporting on the toxic substance use, creation, amount contained in product and release at the Facility on an annual basis; prepare Toxic Substance Reduction Plans in which it is documented, where feasible, how the use and creation of toxic substances might be reduced; have the Toxic Substance Reduction Plan certified by an MOE licensed Toxic Substance Reduction Planner (the Planner) as well as the Highest Ranking Employee (HRE) at the Facility; prepare Plan Summaries containing various components of the Toxic Substance Reduction Plans and make them available to the public; submit annual reports on progress made on the Plans; and update the Plans at least every five years. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of toxic substance reduction options identified in a given Plan (if any) is not a requirement of the TRA or O.Reg.455/09. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substances since the Facility meets the TRAs definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the respective National Pollutant Release Inventory reporting thresholds for each of the Toxic Substances. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2012 reporting years in accordance with s.12 of O.Reg.455/09, and Plans which reference this Master Document satisfy the Toxic Substance Reduction Plan and Plan Summary preparation requirements of the TRA and O.Reg.455/09. Version 1.0 1

16 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM BASIC FACILITY INFORMATION The following table is adapted from Appendix 3 of the MOE Planning Toolkit and provides the applicable Basic Facility Information stipulated in section 18(2) of O.Reg.455/09. Mandatory Basic Facility Information Item Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any NPRI and O.Reg.127/01 Identification Numbers The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full time employee equivalents at the facility North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code Public contact Technical contact and person who is responsible for coordinating plan preparation The person who prepared the plan Highest Ranking employee at the facility who has management responsibilities relating to the facility and who is responsible for making certification The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum Parent Company Information Details This is a Master Document which provides supporting information for Toxic Substance Reduction Plans for the following Substances: Particulate Matter, PM10 and PM2.5 (Per TRA guidance, no CAS number applies to these substances) NPRI ID: O.Reg.127/01 ID: N/A Richmont Island Gold Mine Mines Richmont Inc. 15 Goudreau Road, Dubreuilville, ON P0S 1B Mining & Oil & Gas Extraction Metal Ore Mining Gold & Silver Ore Mining Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 Russell Polack Toxic Substance Reduction Planner Golder Associates Ltd Lorne Street, Sudbury, ON P3C 4R9 (705) Jean Bastien Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) UTM Zone E, N Mines Richmont Inc. 161, avenue Principale Rouyn-Noranda, QC J9X 4P6 (819) Version 1.0 2

17 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM PLANNER LICENSE NUMBER As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows: Russell Polack Air Quality Specialist Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. This Master Document outlines the Facility s position that no toxic substance reduction options can be identified for the Toxic Substances. The following subsections are intended to be referenced by respective Plans for the appropriate Toxic Substances. 4.1 Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. A statement of the Facility s intent to reduce its creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is not used in the Facility s process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility which are interpreted as creations of the Toxic Substance under the TRA framework. The first activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the generation by physical means of suspended particulate matter in various size fractions commonly referred to as dust; which is subsequently released either as stack or fugitive emissions. The second activity that has been classified as a creation of the Toxic Substance is the generation of suspended particulate matter as a by-product of stationary combustion. The MOE has stated that the TRA is not intended to focus on end of pipe emissions as they don t necessarily have any bearing on the amount of a substance that is used or created, however in this case, end of pipe emissions of suspended particulate matter is the determining factor of the Facility s TRA reporting status with respect to the Toxic Substance. Despite the Facility s reporting status with respect to the Toxic Substance, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected. This opinion is supported by the following two aspects: Version 1.0 3

18 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 Compliance with Regulatory Requirements It is well documented that release of suspended particulate matter is an inherent by-product of mining and mineral processing and that the activities leading to the release of suspended particulate matter are essential to the process of mining and mineral processing. In recognition of this, the MOE has imposed various regulatory requirements related to the release of suspended particulate matter, which include: Ontario Regulation 419/05, under which a Facility must demonstrate compliance with substance-specific ground-level concentration limits of emitted substances, including suspended particulate matter in all forms that are reportable under the NPRI and TRA reporting programs. The requirement for any Facility that may discharge any contaminant to the atmosphere to apply for and obtain an Environmental Compliance Approval (ECA) for air which approves the facility s emissions and provides performance limits, documentation requirements and reporting requirements which a Facility must meet in order to maintain compliance with the ECA on an ongoing basis. The Facility currently meets and/or exceeds all of the above regulatory requirements which are designed to control the release of the Toxic Substance and minimize potential off-site impacts resulting from the release of the Toxic Substance. Measures Currently in Place to Minimize Releases of Suspended Particulate Matter As a result of satisfying all of the above noted regulatory requirements in addition to voluntary actions with respect to suspended particulate matter releases, the Facility actively implements a variety of controls to minimize suspended particulate matter releases from different parts of its process components. These controls include, but are not limited to, the following: The use of calcium chloride dust suppressant on roads. Watering to suppress dust as required, when undertaking non-routine tasks. Operation of various baghouses and/or dust collectors serving various process components to minimize suspended particulate matter. Measures in place to minimize fuel consumption including, but not limited to, implementation of a preventative maintenance program to ensure that equipment runs as efficiently as possible. 4.2 Objectives of the Plan The Objectives of the Plan are as follows: provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and Version 1.0 4

19 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 document how the Facility has fulfilled the applicable requirements under the TRA and O. Reg. 455/09 with respect to the Toxic Substance. 5.0 TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2012 REPORTING YEAR As required by s.12 of O.Reg.455/09, the Facility has fulfilled its Toxic Substance Quantification, Accounting and Reporting (QAR) requirements for the Toxic Substances for all reporting years to date. The Toxic Substance QAR exercises were completed in accordance with subsections of s.12 of O.Reg.455/09 and consider guidance provided in the MOE publication entitled Toolkit for Toxic Substance Accounting, dated 2011 (PIBS 8498e; the Accounting Toolkit). Per guidance, Toxic Substance QAR information for the 2012 reporting year was relied upon in the preparation of this Plan. The appropriate Toxic Substance QAR information for the 2012 reporting year was submitted by the Facility before the deadline of June 1, The 2012 Toxic Substance QAR information is provided in Appendix A. The following sections provide a description of how the Toxic Substance QAR exercise was completed and how each applicable item under s.12 of O.Reg.455/09 is addressed by these Toxic Substance QAR exercises. 5.1 Description of each Process that uses the Toxic Substance Description of How, When, Where and Why the Substance is Used or Created The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility which are defined as creations of the Toxic Substance under the TRA framework. The first activity that has been classified as a creation of the Toxic Substance is the generation by physical means of suspended particulate matter in various size fractions as dust; which is subsequently released either as stack or fugitive emissions. The second activity that has been classified as a creation of the Toxic Substance is the generation of particulate matter as a by-product of combustion of fuels in stationary equipment. The Toxic Substance is never used in the Facility process. For the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance, the calculated release values have been assumed to be equal to the amount created for each emission source, despite the fact that some of these releases are controlled releases. Section 12(6) of O.Reg.455/09 provides considerations for determining the Best Available Methods for tracking and quantifying the Toxic Substance. MOE guidance pertaining to this section of O.Reg.455/09 states that the importance of selecting Best Available Methods is to provide the best decision making information when determining which toxics reduction options, if any, are worthwhile to implement. It should be noted that, given the Facility s decision to not include in this Plan a statement of its intent to reduce the creation of the Toxic Substance (as supported by the information provided in the Statement of Intent section of the Plan), no decisions will be made with respect to toxics reduction based on the calculated creation values for the Toxic Substance. Taking this into consideration, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and applying the Best Available Methods for quantifications in this case. Version 1.0 5

20 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 A graphical representation of the Facility s creation and subsequent release of the Toxic Substance is provided as part of the Toxic Substance QAR exercise in Appendix A. Process Flow Diagrams (PFDs) and associated descriptions of stages and processes are described in detail in the following section Records of Identification and Description of Stages and Processes of Facility Operation and Record Containing Process Flow Diagrams Per guidance provided in the Accounting Toolkit, PFDs have been provided as part of the Toxic Substance QAR exercise to give a visual representation of the movement of the Toxic Substance through every stage of the process where it is present and to show the relationships between the processes. The PFD provides the appropriate level of detail to satisfy s.12 of O.Reg.455/09. It demonstrates in each stage where the Toxic Substances are present has been broken down into a sufficient number of individual processes to satisfy s.12(3) of O.Reg.455/09, and introduces Activity IDs for activities for which process-level quantifications for the Toxic Substances have been completed, including the following: the amount of the Toxic Substance that enters the process; and any NPRI-reportable releases of the Toxic Substance. It should be noted that the Toxic Substance cannot be used in the Facility process and therefore no quantifications are required for an amount of Toxic Substance used. The descriptions provided in this PFD are detailed and reference each individual Activity ID. These activity IDs are subsequently used in the required Toxic Substance quantification and accounting. 5.2 Toxic Substance Accounting Information Quantifications at Process Level for Previous Year Toxic Substance quantifications are also provided in Appendix A. This information is provided on the Calculations, Input/Output Analysis and Summary page. A quantification is provided for each Activity ID identified in the PFD, along with the following: a description of the quantification method; a rationale for selecting each quantification method (see following section); data used to quantify the activity subject to each Activity ID; Data Quality for the quantification; and sample calculation. The Calculations, Input/Output Analysis and Summary page also provides an input/output analysis for each stage where the Toxic Substances are present as well as an input/output balance for entire Facility process. A description of why the sums of inputs and outputs are not equal is provided along with a comment regarding the acceptability of this input/output imbalance. Version 1.0 6

21 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM Records of Methods and Rationale for Selecting each Method used to Track and Quantify the Toxic Substance In accordance with s.12(6) of O.Reg.455/09, for each quantification method that was used to prepare processlevel quantifications, a rationale for why the method was identified as the best available for the purpose of completing the exercise is provided. In the process of identifying best available methods, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and applying the best available methods for quantifications and collecting the information necessitated by each quantification method. The Facility understands that the methods used to complete the 2012 Toxic Substance QAR exercise can only be changed under the circumstances stipulated in s.12(7) of O.Reg.455/09. At this time, the Facility does not intend to change the quantification methods that were used to complete the 2012 Toxic Substance QAR exercises for the purpose of completing Toxic Substance QAR exercises for subsequent years. 6.0 ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE As required by s.18(1) of O.Reg.455/09, direct and indirect costs have been estimated for the Toxic Substance. In preparing the cost estimates, several departments at the Facility were consulted. Cost items associated with the Toxic Substances were identified in various categories. The cost estimates are provided in Appendix B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance. Ontario Regulation 455/09 does not specify the level of detail to which a Facility must examine costs associated with a toxic substance, however the Facility feels that it has gone to reasonable lengths in its efforts to estimate the costs associated with the Toxic Substances. 7.0 OPTIONS CONSIDERED FOR REDUCTION Section 17 of O.Reg.455/09 outlines the requirements for identification of toxic substance reduction options and provides the seven categories of toxic substance reduction options under which options are to be identified as part of the Plan. 7.1 Identification of Toxic Substance Reduction Options in Each of Seven Toxic Substance Reduction Categories With the assistance of a licensed Toxic Substance Reduction Planner, Facility personnel have considered each of the seven categories for toxic substance reduction options. It is not necessarily a requirement under O.Reg.455/09 to provide toxic substance reduction options, however s.17(1)2 of O.Reg.455/09 states that the following must be provided in the event that an option for toxic substance reduction cannot be identified in any of the seven toxic substance reduction categories: Version 1.0 7

22 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 17(1)2. If an option cannot be identified for a category listed in paragraph 1, an explanation of why no option could be identified for the category The following statement satisfies s.17(1)2 of O.Reg.419/05 each of the seven toxic substance reduction categories for the Toxic Substance. For reasons explained in the Statement of Intent Section of this Plan, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substances to the greatest extent that can reasonably be expected and therefore no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. 7.2 Estimates of Potential Reductions Associated with Each Identified Toxic Substance Reduction Option No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide estimates of potential reductions associated with identified toxic substance reduction options under s.17(1)3 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 7.3 Identification of Technically Feasible Options No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide a list of toxic substance reduction options that have been determined to be technically feasible under s.17(1)4 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 7.4 Analysis of Economic Feasibility of Technically Feasible Options No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide an analysis of economic feasibility for any toxic substance reduction options that have been determined to be technically feasible under s.17(1)5 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 8.0 RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented. Version 1.0 8

23 TRA MASTER DOCUMENT SUPPORTING PLANS FOR PARTICULATE MATTER, PM10 AND PM2.5 Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified. 9.0 PLANNER RECOMMENDATIONS AND RATIONALE As required by s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), the Facility provided a draft copy of the Plan to a licensed Toxic Substance Reduction Planner for the purpose of obtaining recommendations with respect to the plan. It should be noted that implementation of Planner Recommendations is not a requirement of O.Reg.455/09 or the TRA. Planner recommendations and rationale have been provided by a licensed Toxic Substance Reduction Planner with respect to this Master Document since the majority of the issues that s.18.2(3) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) requires the Planner to comment on are covered in this Master Document. These recommendations are provided in Appendix C and are referenced by respective Plans for the Toxic Substances, as appropriate PLAN SUMMARY As required by s.8 of the TRA, a Plan Summary must be prepared in accordance with s.23 of O.Reg.455/09. Since all required components of a Plan Summary are provided in this Master Document, a general Plan Summary which has been prepared based on this Master Document has been provided in Appendix D. This Plan Summary is referenced in respective Plans for the Toxic Substances, as appropriate. Furthermore the Plan Summary is available on Richmont s website and can be provided to a member of the public upon written request. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years. c:\users\rpolack\desktop\for home 28nov13\tra\rig\reporting\attachment 1 - pm master\ rig tra master doc - pm 8dec13 rlp.docx Version 1.0 9

24 MASTER DOCUMENT SUPPORTING VARIOUS TOXIC REDUCTION PLANS APPENDIX A Toxic Substance Quantification, Accounting and Reporting Information for the 2012 Reporting Year Version 1.0

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28 MASTER DOCUMENT SUPPORTING VARIOUS TOXIC REDUCTION PLANS APPENDIX B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance Version 1.0

29 Estimates of 2012 Direct and Indirect Baseline Costs Associated with Various TRA Phase II Toxic Substances S.18(1) of O.Reg.455/09 requires that direct and indirect costs be estimated for the Toxic Substance for which the Plan is being prepared. A Facility has the flexibility to determine how and to what level of detail to calculate direct and indirect costs. The MOE indicates that an understanding of direct and indirect costs associated with a prescribed toxic substance will assist the Facility in assessing the economic feasibility of identified toxic substance reduction options. The TRA Phase II substances included in this cost estimation exercise have triggered reporting under the TRA as a result of respective activities that the TRA defines as "creations" of each Toxic Substance. Since these substances are "created" rather than used, no means of calculating costs associated with these "creations" in a way that yields meaningful information was immediately evident. In order to satisfy the requirement to estimate direct and indirect costs associated with each toxic substance, a simple cost estimation exercise was completed, which relies on various cost items that can be considered to be tied to various Toxic Substances as well as "creation" values which were reported by the Facility to the TRA for the 2012 reporting year. It should be noted that, given the Facility s decision to not include in respective Toxic Substance Reduction Plans a statement of its intent to reduce the creation of the Toxic Substances (as supported by the information provided in the Statement of Intent sections of the respective Plans), no decisions will be made with respect to toxics reduction based on the costs calculated below. Taking this into consideration, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and estimating direct and indirect costs associated with these Toxic Substances. The table below provides categories and associated costs for items that may be associated with the Phase II Toxic Substances. Information contained in the table below was provided by Facility personnel and represents an appropriate level of detail for this cost estimating exercise. Costs for each TRA Phase II Toxic Substance associated with each cost category were calculated by multiplying each Toxic Substance's percentage of the total annual release of all substances associated with cost item by the cost of the cost item. Costs associated for each toxic substance for each cost item were then summed to calculate the total estimated direct or indirect baseline cost associated with each Phase II Toxic Substances NOx CO PM PM10 PM2.5 Substance Creation Value Reported to the TRA for the 2012 Baseline Year (tonne/yr) Cost Item Cost Toxic Substances Associated with Cost Item Total Annual Release of Substances Associated with Cost Item (tonnes/yr) Substance Creation Percent of Total Annual Creation of Substances Associated with Cost Item Cost Associated with Toxic Substance NOx CO PM PM10 PM2.5 NOx CO PM PM10 PM2.5 Dust Suppressants $ 28, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 13, $ 7, $ 6, Raw Materials $ 118, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 57, $ 32, $ 27, Utilities (Propane, Diesel) $ 2,075, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ 126, $ 1,323, $ 305, $ 172, $ 147, Review of Traffic Volumes $ 3, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 1, $ $ Engineering Controls (Enclosures, road paving) $ 73, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 35, $ 20, $ 17, Evironmental Compliance $ 15, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ $ 9, $ 2, $ 1, $ 1, Permitting Fees $ 3, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ $ 1, $ $ $ TOTAL COST ASSOCIATED WITH EACH TOXIC SUBSTANCE: $ 127, $ 1,334, $ 417, $ 236, $ 201, Sample Calculation for PM from Dust Suppressants: PM Cost = PM Creation [PM Creation + PM10 Creation + PM2.5 Creation] x Cost of Dust Suppressants PM Cost = $ 13,827.52

30 MASTER DOCUMENT SUPPORTING VARIOUS TOXIC REDUCTION PLANS APPENDIX C Planner Recommendations Version 1.0

31 DATE December 13, 2013 PROJECT No TO Melanie Gauthier Richmont Island Gold Mine CC Sean Capstick FROM Russell Polack TOXIC SUBSTANCE REDUCTION PLANNER RECOMMENDATIONS ON THE DRAFT DOCUMENT ENTITLED MASTER DOCUMENT SUPPORTING TOXIC SUBSTANCE REDUCTION PLANS FOR: PARTICULATE MATTER; PM10; AND PM2.5 Golder Associates Ltd. (Golder) was retained by Mines Richmont Inc. Island Gold Mine (the Facility) to provide various services pertaining to Phase II Toxic Substance Reduction Plan preparation under the Toxics Reduction Act (TRA), including Toxic Substance Reduction Planner recommendations (Planner Recommendations). The Facility is required to prepare Plans for various prescribed toxic substances (the Toxic Substances) which travel together through the Facility process, and therefore the Facility has elected to take advantage of administrative efficiencies afforded by the TRA and Ontario Regulation (O.Reg.) 455/09 by preparing a single Master Document which satisfies various Plan requirements for all of the Toxic Substances. Background As required by s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), a facility is required to provide a draft copy of the Plan to a licensed Toxic Substance Reduction Planner (the Planner) for the purpose of obtaining recommendations with respect to the Plan. This technical memorandum fulfills the requirements of s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11). Following Ontario Ministry of the Environment (MOE) guidance, respective plans for each Toxic Substance have been prepared as Skeleton Plans which simply reference content found in a Master Document which contains the information required to satisfy the Plan Preparation requirement of the TRA and O.Reg.455/09. Therefore, this Technical Memorandum fulfills the requirements of s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) for all of the following draft Plans: Toxic Substance Reduction Plan Particulate Matter Version 1.0; Toxic Substance Reduction Plan PM10 Version 1.0; and Toxic Substance Reduction Plan PM2.5 Version 1.0. Golder Associates Ltd Lorne Street, Sudbury, Ontario, Canada P3C 4R9 Tel: +1 (705) Fax: +1 (705) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

32 Melanie Gauthier Richmont Island Gold Mine December 13, 2013 Planner Recommendation Requirements Under the Toxics Reduction Act and Ontario Regulation 455/09 Section 18.2(3) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) provides the areas of a given Plan in which Planner Recommendations are required to be documented (the Areas of Recommendation). As required by s.18.2(4) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), a Planner must also provide a rationale for each Planner Recommendation. Implementing Planner Recommendations (if any) is voluntary. As stated in s.18.2(2) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), Planner Recommendations shall be provided for the purpose of improving all aspects of the Plan, including: the potential for reducing the use and creation of the toxic substance at the facility; and the business rationale for implementing the Plan. Section 18.2(5) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) a Planner must provide a written explanation if the Planner is of the opinion that no recommendations are necessary with respect any of the Areas of Recommendation. Written Explanation for No Necessary Recommendations The Planner is of the opinion that no recommendations are necessary with respect to any of the Areas of Recommendation for any of the Plans. The following written explanation is being provided by the Planner to the Facility under s.18.2(5) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) and satisfies the Facility s requirements for Planner Recommendations under s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11): The Planner is of the opinion that no recommendations are necessary with respect to any of the matters listed in paragraph 1 to 6 of s.18.2(3) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) for the respective Plans of any of the Toxic Substances. The rationale for this opinion is that the Planner and the Facility feel that there is little value in providing Planner Recommendations on a Plan which does not include a statement of the Facility s intent to reduce its use or creation of the Toxic Substance, but which the Planner feels is compliant with the TRA and O.Reg.455/09. Closure This technical memorandum provides the documentation required to satisfy s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) with respect to the individual draft Plans listed within this document. It is recommended that a copy of this technical memorandum be appended to the final Master Document. Yours very truly, GOLDER ASSOCIATES LTD. Russell Polack, M.Sc. Toxic Substance Reduction Planner License No. TSRP0002 HJ/RLP/FSC/ms n:\active\2013\1190 sudbury\1192\ richmont tra ph ii dubreuilville\reporting\attachment 1 - pm master\app c - planner recommendations\appendix c 13dec13 rig pm master doc planner recs.docx 2/2

33 MASTER DOCUMENT SUPPORTING VARIOUS TOXIC REDUCTION PLANS APPENDIX D Plan Summary Version 1.0

34 TOXIC SUBSTANCE REDUCTION PLAN SUMMARY This Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the Toxics Reduction Act and satisfies the minimum Plan Summary content requirements stipulated in Section 24 of Ontario Regulation (O.Reg.) 455/09. Basic Facility Information Mandatory Basic Facility Information Item Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any National Pollutant Release Inventory (NPRI) and O.Reg.127/01 Identification Numbers The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full time employee equivalents at the facility North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code Public contact The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum Parent Company Information Details This Plan Summary applies to the Toxic Substance Reduction Plans for the following prescribed Toxic Substances: Particulate Matter, PM10, PM2.5 (Per O.Reg.455/09; no single CAS numbers apply to these substances ) NPRI ID: O.Reg.127/01 ID: N/A Richmont Island Gold Mine Mines Richmont Inc. 15 Goudreau Road, Dubreuilville, ON P0S 1B Mining & Oil & Gas Extraction Metal Ore Mining Gold & Silver Ore Mining Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 UTM Zone E, N Mines Richmont Inc. 161, avenue Principale Rouyn-Noranda, QC J9X 4P6 (819) of 5

35 List of All Substances for which Toxic Substance Reduction Plans Have Been Prepared at the Facility The Facility has prepared Toxic Substance Reduction Plans for the following prescribed Toxic Substances: Arsenic* Cadmium* Chromium* Copper* Lead* Manganese* Zinc* Cyanides (Ionic)* Nitrogen Oxides (CAS number ) Carbon Monoxide (CAS number ) Particulate Matter* PM10* PM2.5* Nitric Acid (CAS number ) *Per O.Reg.455/09, no single CAS numbers apply to these substances Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. A statement of the Facility s intent to reduce its creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is not used in the Facility s process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility which are interpreted as creations of the Toxic Substance under the TRA framework. The first activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the generation by physical means of suspended particulate matter in various size fractions commonly referred to as dust; which is subsequently released either as stack or fugitive emissions. The second activity that has been classified as a creation of the Toxic Substance is the generation of suspended particulate matter as a by-product of stationary combustion. 2 of 5

36 The MOE has stated that the TRA is not intended to focus on end of pipe emissions as they don t necessarily have any bearing on the amount of a substance that is used or created, however in this case, end of pipe emissions of suspended particulate matter is the determining factor of the Facility s TRA reporting status with respect to the Toxic Substance. Despite the Facility s reporting status with respect to the Toxic Substance, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected. This opinion is supported by the following two aspects: Compliance with Regulatory Requirements It is well documented that release of suspended particulate matter is an inherent by-product of mining and mineral processing and that the activities leading to the release of suspended particulate matter are essential to the process of mining and mineral processing. In recognition of this, the MOE has imposed various regulatory requirements related to the release of suspended particulate matter, which include: Ontario Regulation 419/05, under which a Facility must demonstrate compliance with substancespecific ground-level concentration limits of emitted substances, including suspended particulate matter in all forms that are reportable under the NPRI and TRA reporting programs; The requirement for any Facility that may discharge any contaminant to the atmosphere to apply for and obtain an Environmental Compliance Approval (ECA) for air which approves the facility s emissions and provides performance limits, documentation requirements and reporting requirements which a Facility must meet in order to maintain compliance with the ECA on an ongoing basis; The Facility currently meets and/or exceeds all of the above regulatory requirements which are designed to control the release of the Toxic Substance and minimize potential off-site impacts resulting from the release of the Toxic Substance. Measures Currently in Place to Minimize Releases of Suspended Particulate Matter As a result of satisfying all of the above noted regulatory requirements in addition to voluntary actions with respect to suspended particulate matter releases, the Facility actively implements a variety of controls to minimize suspended particulate matter releases from different parts of its process components. These controls include, but are not limited to, the following: The use of calcium chloride dust suppressant on roads. Watering to suppress dust as required, when undertaking non-routine tasks. Operation of various baghouses and/or dust collectors serving various process components to minimize suspended particulate matter. Measures in place to minimize fuel consumption including, but not limited to, implementation of a preventative maintenance program to ensure that equipment runs as efficiently as possible. 3 of 5

37 Objectives of the Toxic Substance Reduction Plan The Objectives of the Plan are as follows: provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. Description of Why the Toxic Substance Is Used or Created The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility which are defined as creations of the Toxic Substance under the TRA framework. The first activity that has been classified as a creation of the Toxic Substance is the generation by physical means of suspended particulate matter in various size fractions as dust; which is subsequently released either as stack or fugitive emissions. The second activity that has been classified as a creation of the Toxic Substance is the generation of particulate matter as a by-product of combustion of fuels in stationary equipment. The Toxic Substance is never used in the Facility process. For the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance, the calculated release values have been assumed to be equal to the amount created for each emission source, despite the fact that some of these releases are controlled releases. S.12(6) of O.Reg.455/09 provides considerations for determining the Best Available Methods for tracking and quantifying the Toxic Substance. MOE guidance pertaining to this section of O.Reg.455/09 states that the importance of selecting Best Available Methods is to provide the best decision making information when determining which toxics reduction options, if any, are worthwhile to implement. It should be noted that, given the Facility s decision to not include in this Plan a statement of its intent to reduce the creation of the Toxic Substance (as supported by the information provided in the Statement of Intent section of the Plan), no decisions will be made with respect to toxics reduction based on the calculated creation values for the Toxic Substance. Taking this into consideration, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and applying the Best Available Methods for quantifications in this case. Rationale for Not Implementing Toxic Substance Reduction Options As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented. Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. 4 of 5

38 Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified. Statement that the Plan Summary Accurately Reflects the Current Version of the Plan As required by s.24(1)8 of O.Reg.455/09 this Plan Summary accurately reflects the current version of the Plan. Planner License Number As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows: Russell Polack Air Quality Specialist Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP0002 Copies of the Certification Certification statements are provided in the following page. 5 of 5

39 December 2013 Project No Melanie Gauthier Richmont Mines Inc. Island Gold LICENSED TOXIC SUBSTANCE REDUCTION PLANNER CERTIFICATION STATEMENT FOR PHASE II TOXIC SUBSTANCE REDUCTION PLANS FOR RICHMONT MINES INC. ISLAND GOLD Dear Ms. Gauthier: Golder Associates Ltd. (Golder) was retained by Richmont Mines Inc. Island Gold (the Facility) to provide various services pertaining to Phase II Toxic Substance Reduction Plan preparation under the Toxics Reduction Act (TRA), including Toxic Substance Reduction Planner (Planner) certification of Phase II Toxic Substance Reduction Plans (the Plans). The following Planner Certification Statement which is made under s.19.1(4) of Ontario Regulation (O.Reg.) 455/09 (as amended by s.11 of O.Reg.214/11) satisfies the Planner Certification requirements for the Plans that are assembled as a single document as of the date of this Certification Statement. Furthermore, the following Certification Statement is limited to the respective versions of the Plans which are dated as indicated in the Certification Statement: As of, I, Russell Polack certify that I am familiar with the processes at the Richmont Mines Inc. Island Gold Mine facility that use or create the toxic substances referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the toxic substance reduction plans referred to below for the toxic substances and that the plans comply with that Act and Ontario Regulation 455/09 (General) made under that Act. Particulate Matter () PM10 () PM2.5 () Nitrogen Oxides () Carbon Monoxide () Nitric Acid () Russell Polack Toxic Substance Reduction Planner License No. TSRP0002 HJ/RLP Date Golder Associates Ltd Lorne Street, Sudbury, Ontario, Canada P3C 4R9 Tel: +1 (705) Fax: +1 (705) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

40 Toxic Substance Reduction Plans Certification by Highest Ranking Employee As required by s.4(2) of the Toxics Reduction Act (TRA), Toxic Substance Reduction Plans must contain a certification, signed by the highest ranking employee at the Richmont Mines Inc. Island Gold Mine (the Facility) who has management responsibilities relating to the Facility. The following Certification Statement is being made under s.19(2) of Ontario Regulation (O.Reg.) 455/09 (as amended by s.11 of O.Reg.214/11) and satisfies the requirements of s.4(2) of the TRA for the Toxic Substance Reduction Plans that are assembled within this single document as of the date of this Certification Statement. Furthermore, the following Certification Statement is limited to the respective versions of the Plans which are dated as indicated in the Certification Statement: As of (insert date), I, (insert name), certify that I have read the toxic substance reduction plans for the toxic substances referred to below and am familiar with their contents, and to my knowledge the plans are factually accurate and comply with the Toxics Reduction Act, 2009 and Ontario Regulation 455/09 (General) made under that Act. Particulate Matter () PM2.5 () PM10 () Nitrogen Oxides() Carbon Monoxide () Nitric Acid () Signature Date Jean Bastien Print Name Jean Bastien Mine Manager

41 ISLAND GOLD MINE RICHMONT MINES INC. TOXIC SUBSTANCE REDUCTION PLAN PARTICULATE MATTER VERSION 1.0

42 Document Version Control TOXIC SUBSTANCE REDUCTION PLAN PARTICULATE MATTER This document constitutes Toxic Substance Reduction Plan Version 1.0 for the prescribed toxic substance referred to as Particulate Matter under the Toxics Reduction Act. Section 22 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.13 of O.Reg.214/11) provides the framework for Plan review and requirements for a new version of the Plan. This plan must be updated by the end of the calendar year in which a significant process change (as defined in s.1(3) of O.Reg.455/09) occurs. The first mandatory Plan update is required to be completed by December 31, Future updates of this Plan will be assigned a new version number. Version Date Revision Description Reviewed By (Facility Contact) 1.0 December 2013 Plan Version 1.0 Melanie Gauthier VERSION 1.0 i

43 Executive Summary TOXIC SUBSTANCE REDUCTION PLAN PARTICULATE MATTER This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed toxic substance referred to as Particulate Matter (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The Ontario Ministry of the Environment (MOE) has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Richmont operates the Island Gold Mine facility (the Facility) which is located in Dubreuilville, Ontario. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substance since the Facility meets the TRAs definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2010, 2011 and 2012 reporting years in accordance with s.12 of O.Reg.455/09. This Plan satisfies the Toxic Substance Reduction Plan preparation requirements of the TRA and O.Reg.455/09. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of any toxic substance reduction options identified in the Plan is not a requirement of the TRA or O.Reg.455/09. Where appropriate, this Plan references the document entitled Master Document Supporting Toxic Substance Reduction Plans for Particulate Matter; PM10; PM2.5 Version 1.0 (the Master Document) which is attached as a part of this Single Document. This approach follows guidance provided in s.5.2 of the MOE Planning. More details on the administrative efficiency afforded by the Master Document are provided within that document. A Toxic Substance Reduction Plan Component Checklist (the Plan Component Checklist), which outlines the minimum content requirements of a Toxic Substance Reduction Plan, is provided following this Executive Summary. This Plan is structured so that section headings correspond to the items in the Plan Component Checklist. This approach is designed to provide a clear depiction of this Plan s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. S.4(1) of the TRA requires that a Plan include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. VERSION 1.0 ii

44 TOXIC SUBSTANCE REDUCTION PLAN PARTICULATE MATTER The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility which are defined as a creation of the Toxic Substance under the TRA framework. The first activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of suspended particulate matter in various size fractions as dust; which is subsequently released either as stack or fugitive emissions. The second activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the appearance of the Toxic Substance in the form of suspended particulate matter as a by-product of stationary combustion. As a result of regulatory commitments described within this Plan, the Facility is of the opinion that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected, and therefore a statement of the Facility s intent to reduce creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance cannot be used in the Facility process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. In light of the above, the objectives of this Plan are as follows: provide support for the Facility s position that, under the TRA s framework, it is impossible to reduce the flow-through use of the Toxic Substances without reducing Facility production; provide the reader with an understanding of the nature of the Facility activity which the TRA has defined as a use of the Toxic Substance; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. A Plan Summary corresponding to this Plan which was prepared in accordance with s.23 of O.Reg.455/09 is included as Appendix D of the Master Document. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on Richmont s website and can be provided to a member of the public upon written request. This Plan documents the Facility s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years. VERSION 1.0 iii

45 TOXIC SUBSTANCE REDUCTION PLAN PARTICULATE MATTER Toxic Substance Reduction Plan Component Checklist The following checklist is adapted from Appendix 4 of the MOE Planning Toolkit. It outlines mandatory Toxic Substance Reduction Plan components and provides a reference to the section of this Plan which provides the required information to satisfy each mandatory component. Mandatory Plan Component Provided? Plan Section Reference Basic facility information Yes s.2.0 Planner license numbers Yes s.3.0 Statement of intent to reduce the use and/or creation of toxic substance (or reasons for not including one) Objectives of the Plan Yes s.4.0 Description of each process that uses the toxic substance Yes s.5.0 description of how, when, where and why the substance is used or created Yes s.5.0 records of identification and description of stages and processes of a facility's operation and a record containing process flow diagrams. Toxic substance accounting information Yes s.5.0 quantifications at process level for previous year Yes s.5.0 record of methods and rationale for selecting each method used to track and quantify toxic substance Estimate of direct and indirect annual costs associated with the toxic substance Yes s.6.0 Options considered for Reduction Yes s.7.0 identification of toxic substance reduction options in each of seven toxic reduction categories stipulated in O.Reg.455/09 or explanation of why no option could be identified estimate of potential reductions in use, creation, contained in product, release (air, land and water), disposal, transfer of toxic substances achieved if option was implemented and the information used to develop the estimate identification of technically feasible options N/A s.7.0 analysis of economic feasibility of technically feasible options, including anticipated savings and payback period N/A s.7.0 For each option to be implemented a description of implementation steps and a timetable for implementation N/A N/A a summary of estimated toxics reduction in use, creation, released, disposed, transferred for recycling, and/or contained in product (as a percentage and unit of measurement) anticipated dates for achieving use and creation reductions N/A N/A OR If no options were implemented provide the rationale for this decision Yes s.8.0 Planner Recommendations and Rationale Yes s.9.0 Certifications by the highest ranking employee and the toxics reduction planner Yes s.11.0 Yes Yes Yes Yes N/A N/A s.4.0 s.5.0 s.5.0 s.7.0 s.7.0 N/A VERSION 1.0 iv

46 Table of Contents TOXIC SUBSTANCE REDUCTION PLAN PARTICULATE MATTER 1.0 INTRODUCTION BASIC FACILITY INFORMATION PLANNER LICENSE NUMBER STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2011 REPORTING YEAR ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE OPTIONS CONSIDERED FOR REDUCTION RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS PLANNER RECOMMENDATIONS AND RATIONALE PLAN SUMMARY CERTIFICATIONS... 1 VERSION 1.0 v

47 TOXIC SUBSTANCE REDUCTION PLAN PARTICULATE MATTER 1.0 INTRODUCTION Refer to Master Document Section BASIC FACILITY INFORMATION Refer to Master Document Section PLANNER LICENSE NUMBER Refer to Master Document Section STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN Refer to Master Document Section 4.0 and its subsections. 5.0 TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2011 REPORTING YEAR Refer to Master Document Section 5.0 and its subsections. 6.0 ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE Refer to Master Document Section 6.0 and its subsections. 7.0 OPTIONS CONSIDERED FOR REDUCTION Refer to Master Document Section 7.0 and its subsections. 8.0 RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS Refer to Master Document Section 8.0 and its subsections. 9.0 PLANNER RECOMMENDATIONS AND RATIONALE Refer to Master Document Section PLAN SUMMARY Refer to Master Document Section CERTIFICATIONS Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. Version 1.0 1

48 ISLAND GOLD MINE RICHMONT MINES INC. TOXIC SUBSTANCE REDUCTION PLAN PM10 VERSION 1.0

49 Document Version Control TOXIC SUBSTANCE REDUCTION PLAN PM10 This document constitutes Toxic Substance Reduction Plan Version 1.0 for the prescribed toxic substance referred to as PM10 under the Toxics Reduction Act. Section 22 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.13 of O.Reg.214/11) provides the framework for Plan review and requirements for a new version of the Plan. This plan must be updated by the end of the calendar year in which a significant process change (as defined in s.1(3) of O.Reg.455/09) occurs. The first mandatory Plan update is required to be completed by December 31, Future updates of this Plan will be assigned a new version number. Version Date Revision Description Reviewed By (Facility Contact) 1.0 December 2013 Plan Version 1.0 Melanie Gauthier VERSION 1.0 i

50 Executive Summary TOXIC SUBSTANCE REDUCTION PLAN PM10 This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed toxic substance referred to as PM10 (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The Ontario Ministry of the Environment (MOE) has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Richmont operates the Island Gold Mine facility (the Facility) which is located in Dubreuilville, Ontario. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substance since the Facility meets the TRAs definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2010, 2011 and 2012 reporting years in accordance with s.12 of O.Reg.455/09. This Plan satisfies the Toxic Substance Reduction Plan preparation requirements of the TRA and O.Reg.455/09. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of any toxic substance reduction options identified in the Plan is not a requirement of the TRA or O.Reg.455/09. Where appropriate, this Plan references the document entitled Master Document Supporting Toxic Substance Reduction Plans for Particulate Matter; PM10; PM2.5 Version 1.0 (the Master Document) which is attached as a part of this Single Document. This approach follows guidance provided in s.5.2 of the MOE Planning. More details on the administrative efficiency afforded by the Master Document are provided within that document. A Toxic Substance Reduction Plan Component Checklist (the Plan Component Checklist), which outlines the minimum content requirements of a Toxic Substance Reduction Plan, is provided following this Executive Summary. This Plan is structured so that section headings correspond to the items in the Plan Component Checklist. This approach is designed to provide a clear depiction of this Plan s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. S.4(1) of the TRA requires that a Plan include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. VERSION 1.0 ii

51 TOXIC SUBSTANCE REDUCTION PLAN PM10 The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility which are defined as a creation of the Toxic Substance under the TRA framework. The first activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of suspended particulate matter in various size fractions as dust; which is subsequently released either as stack or fugitive emissions. The second activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the appearance of the Toxic Substance in the form of suspended particulate matter as a by-product of stationary combustion. As a result of regulatory commitments described within this Plan, the Facility is of the opinion that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected, and therefore a statement of the Facility s intent to reduce creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance cannot be used in the Facility process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. In light of the above, the objectives of this Plan are as follows: provide support for the Facility s position that, under the TRA s framework, it is impossible to reduce the flow-through use of the Toxic Substances without reducing Facility production; provide the reader with an understanding of the nature of the Facility activity which the TRA has defined as a use of the Toxic Substance; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. A Plan Summary corresponding to this Plan which was prepared in accordance with s.23 of O.Reg.455/09 is included as Appendix D of the Master Document. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on Richmont s website and can be provided to a member of the public upon written request. This Plan documents the Facility s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years. VERSION 1.0 iii

52 TOXIC SUBSTANCE REDUCTION PLAN PM10 Toxic Substance Reduction Plan Component Checklist The following checklist is adapted from Appendix 4 of the MOE Planning Toolkit. It outlines mandatory Toxic Substance Reduction Plan components and provides a reference to the section of this Plan which provides the required information to satisfy each mandatory component. Mandatory Plan Component Provided? Plan Section Reference Basic facility information Yes s.2.0 Planner license numbers Yes s.3.0 Statement of intent to reduce the use and/or creation of toxic substance (or reasons for not including one) Yes s.4.0 Objectives of the Plan Yes s.4.0 Description of each process that uses the toxic substance Yes s.5.0 description of how, when, where and why the substance is used or created Yes s.5.0 records of identification and description of stages and processes of a facility's operation and a record containing process flow diagrams. Yes s.5.0 Toxic substance accounting information Yes s.5.0 quantifications at process level for previous year Yes s.5.0 record of methods and rationale for selecting each method used to track and quantify toxic substance Yes s.5.0 Estimate of direct and indirect annual costs associated with the toxic substance Yes s.6.0 Options considered for Reduction Yes s.7.0 identification of toxic substance reduction options in each of seven toxic reduction categories stipulated in O.Reg.455/09 or explanation of why no option could be identified estimate of potential reductions in use, creation, contained in product, release (air, land and water), disposal, transfer of toxic substances achieved if option was implemented and the information used to develop the estimate identification of technically feasible options N/A s.7.0 analysis of economic feasibility of technically feasible options, including anticipated savings and payback period N/A s.7.0 For each option to be implemented a description of implementation steps and a timetable for implementation N/A N/A a summary of estimated toxics reduction in use, creation, released, disposed, transferred for recycling, and/or contained in product (as a percentage and unit of measurement) anticipated dates for achieving use and creation reductions N/A N/A OR If no options were implemented provide the rationale for this decision Yes s.8.0 Planner Recommendations and Rationale Yes s.9.0 Certifications by the highest ranking employee and the toxics reduction planner Yes s.11.0 Yes N/A N/A s.7.0 s.7.0 N/A VERSION 1.0 iv

53 Table of Contents TOXIC SUBSTANCE REDUCTION PLAN PM INTRODUCTION BASIC FACILITY INFORMATION PLANNER LICENSE NUMBER STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2011 REPORTING YEAR ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE OPTIONS CONSIDERED FOR REDUCTION RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS PLANNER RECOMMENDATIONS AND RATIONALE PLAN SUMMARY CERTIFICATIONS... 1 VERSION 1.0 v

54 TOXIC SUBSTANCE REDUCTION PLAN PM INTRODUCTION Refer to Master Document Section BASIC FACILITY INFORMATION Refer to Master Document Section PLANNER LICENSE NUMBER Refer to Master Document Section STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN Refer to Master Document Section 4.0 and its subsections. 5.0 TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2011 REPORTING YEAR Refer to Master Document Section 5.0 and its subsections. 6.0 ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE Refer to Master Document Section 6.0 and its subsections. 7.0 OPTIONS CONSIDERED FOR REDUCTION Refer to Master Document Section 7.0 and its subsections. 8.0 RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS Refer to Master Document Section 8.0 and its subsections. 9.0 PLANNER RECOMMENDATIONS AND RATIONALE Refer to Master Document Section PLAN SUMMARY Refer to Master Document Section CERTIFICATIONS Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. Version 1.0 1

55 ISLAND GOLD MINE RICHMONT MINES INC. TOXIC SUBSTANCE REDUCTION PLAN PM2.5 VERSION 1.0

56 Document Version Control TOXIC SUBSTANCE REDUCTION PLAN PM2.5 This document constitutes Toxic Substance Reduction Plan Version 1.0 for the prescribed toxic substance referred to as PM2.5 under the Toxics Reduction Act. Section 22 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.13 of O.Reg.214/11) provides the framework for Plan review and requirements for a new version of the Plan. This plan must be updated by the end of the calendar year in which a significant process change (as defined in s.1(3) of O.Reg.455/09) occurs. The first mandatory Plan update is required to be completed by December 31, Future updates of this Plan will be assigned a new version number. Version Date Revision Description Reviewed By (Facility Contact) 1.0 December 2013 Plan Version 1.0 Melanie Gauthier VERSION 1.0 i

57 Executive Summary TOXIC SUBSTANCE REDUCTION PLAN PM2.5 This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed toxic substance referred to as PM2.5 (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The Ontario Ministry of the Environment (MOE) has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Richmont operates the Island Gold Mine facility (the Facility) which is located in Dubreuilville, Ontario. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substance since the Facility meets the TRAs definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2010, 2011 and 2012 reporting years in accordance with s.12 of O.Reg.455/09. This Plan satisfies the Toxic Substance Reduction Plan preparation requirements of the TRA and O.Reg.455/09. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of any toxic substance reduction options identified in the Plan is not a requirement of the TRA or O.Reg.455/09. Where appropriate, this Plan references the document entitled Master Document Supporting Toxic Substance Reduction Plans for Particulate Matter; PM10; PM2.5 Version 1.0 (the Master Document) which is attached as a part of this Single Document. This approach follows guidance provided in s.5.2 of the MOE Planning Toolkit. More details on the administrative efficiency afforded by the Master Document are provided within that document. A Toxic Substance Reduction Plan Component Checklist (the Plan Component Checklist), which outlines the minimum content requirements of a Toxic Substance Reduction Plan, is provided following this Executive Summary. This Plan is structured so that section headings correspond to the items in the Plan Component Checklist. This approach is designed to provide a clear depiction of this Plan s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. Section 4(1) of the TRA requires that a Plan include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. VERSION 1.0 ii

58 TOXIC SUBSTANCE REDUCTION PLAN PM2.5 The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to two activities at the Facility which are defined as a creation of the Toxic Substance under the TRA framework. The first activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of suspended particulate matter in various size fractions as dust; which is subsequently released either as stack or fugitive emissions. The second activity that has been classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substances is the appearance of the Toxic Substance in the form of suspended particulate matter as a by-product of stationary combustion. As a result of regulatory commitments described within this Plan, the Facility is of the opinion that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected, and therefore a statement of the Facility s intent to reduce creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance cannot be used in the Facility process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. In light of the above, the objectives of this Plan are as follows: provide support for the Facility s position that, under the TRA s framework, it is impossible to reduce the flow-through use of the Toxic Substances without reducing Facility production; provide the reader with an understanding of the nature of the Facility activity which the TRA has defined as a use of the Toxic Substance; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. A Plan Summary corresponding to this Plan which was prepared in accordance with s.23 of O.Reg.455/09 is included as Appendix D of the Master Document. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on Richmont s website and can be provided to a member of the public upon written request. This Plan documents the Facility s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years. VERSION 1.0 iii

59 TOXIC SUBSTANCE REDUCTION PLAN PM2.5 Toxic Substance Reduction Plan Component Checklist The following checklist is adapted from Appendix 4 of the MOE Planning Toolkit. It outlines mandatory Toxic Substance Reduction Plan components and provides a reference to the section of this Plan which provides the required information to satisfy each mandatory component. Mandatory Plan Component Provided? Plan Section Reference Basic facility information Yes s.2.0 Planner license numbers Yes s.3.0 Statement of intent to reduce the use and/or creation of toxic substance (or reasons for not including one) Yes s.4.0 Objectives of the Plan Yes s.4.0 Description of each process that uses the toxic substance Yes s.5.0 description of how, when, where and why the substance is used or created Yes s.5.0 records of identification and description of stages and processes of a facility's operation and a record containing process flow diagrams. Yes s.5.0 Toxic substance accounting information Yes s.5.0 quantifications at process level for previous year Yes s.5.0 record of methods and rationale for selecting each method used to track and quantify toxic substance Yes s.5.0 Estimate of direct and indirect annual costs associated with the toxic substance Yes s.6.0 Options considered for Reduction Yes s.7.0 identification of toxic substance reduction options in each of seven toxic reduction categories stipulated in O.Reg.455/09 or explanation of why no option could be identified estimate of potential reductions in use, creation, contained in product, release (air, land and water), disposal, transfer of toxic substances achieved if option was implemented and the information used to develop the estimate identification of technically feasible options N/A s.7.0 analysis of economic feasibility of technically feasible options, including anticipated savings and payback period N/A s.7.0 For each option to be implemented a description of implementation steps and a timetable for implementation N/A N/A a summary of estimated toxics reduction in use, creation, released, disposed, transferred for recycling, and/or contained in product (as a percentage and unit of measurement) anticipated dates for achieving use and creation reductions N/A N/A OR If no options were implemented provide the rationale for this decision Yes s.8.0 Planner Recommendations and Rationale Yes s.9.0 Certifications by the highest ranking employee and the toxics reduction planner Yes s.11.0 Yes N/A N/A s.7.0 s.7.0 N/A VERSION 1.0 iv

60 Table of Contents TOXIC SUBSTANCE REDUCTION PLAN PM INTRODUCTION BASIC FACILITY INFORMATION PLANNER LICENSE NUMBER STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2011 REPORTING YEAR ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE OPTIONS CONSIDERED FOR REDUCTION RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS PLANNER RECOMMENDATIONS AND RATIONALE PLAN SUMMARY CERTIFICATIONS... 1 VERSION 1.0 v

61 TOXIC SUBSTANCE REDUCTION PLAN PM INTRODUCTION Refer to Master Document Section BASIC FACILITY INFORMATION Refer to Master Document Section PLANNER LICENSE NUMBER Refer to Master Document Section STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN Refer to Master Document Section 4.0 and its subsections. 5.0 TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2011 REPORTING YEAR Refer to Master Document Section 5.0 and its subsections. 6.0 ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE Refer to Master Document Section 6.0 and its subsections. 7.0 OPTIONS CONSIDERED FOR REDUCTION Refer to Master Document Section 7.0 and its subsections. 8.0 RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS Refer to Master Document Section 8.0 and its subsections. 9.0 PLANNER RECOMMENDATIONS AND RATIONALE Refer to Master Document Section PLAN SUMMARY Refer to Master Document Section CERTIFICATIONS Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. Version 1.0 1

62 ISLAND GOLD MINE RICHMONT MINES INC. TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES VERSION 1.0

63 Document Version Control TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES This document constitutes Toxic Substance Reduction Plan Version 1.0 for the prescribed toxic substance referred to as Nitrogen Oxides under the Toxics Reduction Act. S.22 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.13 of O.Reg.214/11) provides the framework for Plan review and requirements for a new version of the Plan. This plan must be updated by the end of the calendar year in which a significant process change (as defined in s.1(3) of O.Reg.455/09) occurs. The first mandatory Plan update is required to be completed by December 31, Future updates of this Plan will be assigned a new version number. Version Date Revision Description Reviewed By (Facility Contact) 1.0 December 2013 Plan Version 1.0 Melanie Gauthier VERSION 1.0 i

64 Executive Summary TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed toxic substance referred to as Nitrogen Oxides (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The Ontario Ministry of the Environment (MOE) has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Richmont operates the Island Gold Mine facility (the Facility) which is located in Dubreuilville, Ontario. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substance since the Facility meets the TRAs definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for the 2012 reporting year in accordance with s.12 of O.Reg.455/09. This plan satisfies the Toxic Substance Reduction Plan preparation requirements of the TRA and O.Reg.455/09. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of toxic substance reduction options identified in the Plan (if any) is not a requirement of the TRA or O.Reg.455/09. A Toxic Substance Reduction Plan Component Checklist (the Plan Component Checklist), which outlines the minimum content requirements of a Toxic Substance Reduction Plan, is provided following this Executive Summary. This Plan is structured so that section headings correspond to the items in the Plan Component Checklist. This approach is designed to provide a clear depiction of this Plan s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. S.4(1) of the TRA requires that a Plan include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to its generation as a byproduct of combustion of fuels in stationary equipment and detonation of explosives, which are classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance. VERSION 1.0 ii

65 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES As a result of voluntary and regulatory commitments described within this Plan, the Facility is of the opinion that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected, and therefore a statement of the Facility s intent to reduce creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is never used in the Facility process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. In light of the above, the objectives of this Plan are as follows: provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Plans for Phase II substances for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. A Plan Summary prepared in accordance with s.23 of O.Reg.455/09 is included as a part of this Plan. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on the Facility s website and can be provided to a member of the public upon written request. This Plan documents the Facility s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg 455/09. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years. VERSION 1.0 iii

66 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES Toxic Substance Reduction Plan Component Checklist The following checklist is adapted from Appendix 4 of the MOE Planning Toolkit. It outlines mandatory Toxic Substance Reduction Plan components and provides a reference to the section of this Plan which provides the required information to satisfy each mandatory component. Mandatory Plan Component Provided? Plan Section Reference Basic facility information Yes s.2.0 Planner license numbers Yes s.3.0 Statement of intent to reduce the use and/or creation of toxic substance (or reasons for not including one) Objectives of the Plan Yes s.4.2 Description of each process that uses the toxic substance Yes s.5.1 description of how, when, where and why the substance is used or created Yes s records of identification and description of stages and processes of a facility's operation and a record containing process flow diagrams. Toxic substance accounting information Yes s.5.2 Yes Yes s.4.1 s quantifications at process level for previous year Yes s record of methods and rationale for selecting each method used to track and quantify toxic substance Yes s Estimate of direct and indirect annual costs associated with the toxic substance Yes s.6.0, App B Options considered for Reduction Yes s.7.0 identification of toxic substance reduction options in each of seven toxic reduction categories stipulated in O.Reg.455/09 or explanation of why no option could be identified estimate of potential reductions in use, creation, contained in product, release (air, land and water), disposal, transfer of toxic substances achieved if option was implemented and the information used to develop the estimate identification of technically feasible options N/A s.7.3 analysis of economic feasibility of technically feasible options, including anticipated savings and payback period N/A s.7.4 For each option to be implemented a description of implementation steps and a timetable for implementation N/A N/A a summary of estimated toxics reduction in use, creation, released, disposed, transferred for recycling, and/or contained in product (as a percentage and unit of measurement) anticipated dates for achieving use and creation reductions N/A N/A OR If no options were implemented provide the rationale for this decision Yes s.8.0 Planner Recommendations and Rationale Yes s.9.0, App C Certifications by the highest ranking employee and the toxics reduction planner Yes s.11.0 Yes N/A N/A s.7.1 s.7.2 N/A VERSION 1.0 iv

67 Table of Contents TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES 1.0 INTRODUCTION BASIC FACILITY INFORMATION PLANNER LICENSE NUMBER STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN Statement of Intent Objectives of the Plan TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2012 REPORTING YEAR Description of each Process that uses the Toxic Substance Description of How, When, Where and Why the Substance is Used or Created Records of Identification and Description of Stages and Processes of Facility Operation and Record Containing Process Flow Diagrams Toxic Substance Accounting Information Quantifications at Process Level for Previous Year Records of Methods and Rationale for Selecting each Method used to Track and Quantify the Toxic Substance ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE OPTIONS CONSIDERED FOR REDUCTION Identification of Toxic Substance Reduction Options in Each of Seven Toxic Substance Reduction Categories Estimates of Potential Reductions Associated with Each Identified Toxic Substance Reduction Option Identification of Technically Feasible Options Analysis of Economic Feasibility of Technically Feasible Options RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS PLANNER RECOMMENDATIONS AND RATIONALE PLAN SUMMARY CERTIFICATIONS... 9 VERSION 1.0 v

68 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES APPENDICES APPENDIX A Toxic Substance Quantification, Accounting and Reporting Information for the 2012 Reporting Year APPENDIX B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance APPENDIX C Planner Recommendations APPENDIX D Plan Summary VERSION 1.0 vi

69 1.0 INTRODUCTION TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed toxic substance referred to as Carbon Monoxide (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine Facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The MOE has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Under the TRA, regulated facilities are required to: perform quantification, accounting and reporting on the toxic substance use, creation, amount contained in product and release at the Facility on an annual basis; prepare Toxic Substance Reduction Plans in which it is documented, where feasible, how the use and creation of toxic substances might be reduced; have the Toxic Substance Reduction Plan certified by an MOE licensed Toxic Substance Reduction Planner (the Planner) as well as the Highest Ranking Employee (HRE) at the Facility; prepare Plan Summaries containing various components of the Toxic Substance Reduction Plans and make them available to the public; submit annual reports on progress made on the Plans; and update the Plans at least every five years. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of toxic substance reduction options identified in a given Plan (if any) is not a requirement of the TRA or O.Reg.455/09. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substances since the Facility meets the TRAs definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2010, 2011 and 2012 reporting years in accordance with s.12 of O.Reg.455/09, and this Plan satisfies the Toxic Substance Reduction Plan and Plan Summary preparation requirements of the TRA and O.Reg.455/09 for the Toxic Substance. Version 1.0 1

70 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES 2.0 BASIC FACILITY INFORMATION The following table is adapted from Appendix 3 of the MOE Planning Toolkit and provides the applicable Basic Facility Information stipulated in section 18(2) of O.Reg.455/09. Mandatory Basic Facility Information Item Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any NPRI and O.Reg.127/01 Identification Numbers The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full time employee equivalents at the facility North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code Public contact Technical contact and person who is responsible for coordinating plan preparation The person who prepared the plan Highest Ranking employee at the facility who has management responsibilities relating to the facility and who is responsible for making certification The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum Parent Company Information Nitrogen Oxides, NPRI ID: O.Reg.127/01 ID: N/A Details Richmont Island Gold Mine Mines Richmont Inc. 15 Goudreau Road, Dubreuilville, ON P0S 1B Mining & Oil & Gas Extraction Metal Ore Mining Gold & Silver Ore Mining Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 Russell Polack Toxic Substance Reduction Planner Golder Associates Ltd Lorne Street, Sudbury, ON P3C 4R9 (705) Jean Bastien Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) UTM Zone E, N Mines Richmont Inc. 161, avenue Principale Rouyn-Noranda, QC J9X 4P6 (819) Version 1.0 2

71 3.0 PLANNER LICENSE NUMBER TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows: Russell Polack Air Quality Specialist Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. This Plan outlines the Facility s position that no toxic substance reduction options can be identified for the Toxic Substance at this time. 4.1 Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. A statement of the Facility s intent to reduce its creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is not used in the Facility s process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to its generation as a byproduct of combustion of fuels in stationary equipment and detonation of explosives, which are classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance. The MOE has stated that the TRA is not intended to focus on end of pipe emissions as they don t necessarily have any bearing on the amount of a substance that is used or created, however, in this case, end of pipe emission of the Toxic Substance are the determining factor of the Facility s TRA reporting status with respect to the Toxic Substance. Despite the Facility s reporting status with respect to the Toxic Substance, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected. This opinion is supported by the following two aspects: Compliance with Regulatory Requirements It is well documented that the release of combustion products such as the Toxic Substance is an inherent byproduct of mining and mineral processing and that the activities leading to the release of combustion products Version 1.0 3

72 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES are essential to the process of mining and mineral processing. In recognition of this, the MOE has imposed various regulatory requirements related to the release of combustion products, which include: Ontario Regulation 419/05, under which a Facility must demonstrate compliance with substance-specific ground-level concentration limits of emitted substances, including combustion products in all forms that are reportable under the NPRI and TRA reporting programs. The requirement for any Facility that may discharge any contaminant to the atmosphere to apply for and obtain an Environmental Compliance Approval (ECA) for air which approves the facility s emissions and provides performance limits, documentation requirements and reporting requirements which a Facility must meet in order to maintain compliance with the ECA on an ongoing basis. The Facility currently meets and/or exceeds all of the above regulatory requirements which are designed to control the release of the Toxic Substance and minimize potential off-site impacts resulting from the release of the Toxic Substance. Measures Currently in Place to Minimize Releases of Combustion Products As a result of satisfying all of the above noted regulatory requirements in addition to voluntary actions with respect to combustion product releases, the Facility actively implements a variety of controls to minimize combustion product releases from different parts of its process components. Some examples of such controls are provided below. Measures in place to minimize fuel consumption, including but not limited to: regular maintenance of equipment; planning procedures to use existing equipment as efficiently as possible, thereby minimizing the need for additional equipment; and statement of technology in mining equipment fleet to minimize releases from combustion. Measures in place to optimize explosives usage, including but not limited to: facility has recently switched to emulsion explosives which reduces explosives usage, and increases the rate of detonation. 4.2 Objectives of the Plan provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and document how the Facility has fulfilled the applicable requirements under the TRA and O. Reg. 455/09 with respect to the Toxic Substance. Version 1.0 4

73 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES 5.0 TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2012 REPORTING YEAR As required by s.12 of O.Reg.455/09, the Facility has fulfilled its Toxic Substance quantification, accounting and reporting (QAR) requirements for the Toxic Substance for all reporting years to date. The Toxic Substance QAR exercises were completed in accordance with subsections of s.12 of O.Reg.455/09 and consider guidance provided in the MOE Planning. Per guidance, Toxic Substance QAR information for the 2012 reporting year was relied upon in the preparation of this Plan. The appropriate Toxic Substance QAR information for the 2012 reporting year was submitted by the Facility before the deadline of June 1, The 2012 Toxic Substance QAR information is provided in Appendix A. The following sections provide a description of how the Toxic Substance QAR exercise was completed and how each applicable item under s.12 of O.Reg.455/09 is addressed by these Toxic Substance QAR exercises. 5.1 Description of each Process that uses the Toxic Substance Description of How, When, Where and Why the Substance is Used or Created The activity that has been classified as a creation of the toxic substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of the Toxic Substance as a by-product of combustion of fuels in stationary equipment and detonation of explosives Records of Identification and Description of Stages and Processes of Facility Operation and Record Containing Process Flow Diagrams Per guidance provided in the Accounting Toolkit, Process Flow Diagrams (PFDs) have been provided as part of the Toxic Substance QAR exercise to give a visual representation of the movement of the Toxic Substance through every stage of the process where it is present and to show the relationships between the processes. The PFD provides the appropriate level of detail to satisfy s.12 of O.Reg.455/09. It demonstrates in each stage where the Toxic Substance is present has been broken down into a sufficient number of individual processes to satisfy s.12(3) of O.Reg.455/09, and introduces Activity IDs for activities for which process-level quantifications for the Toxic Substances have been completed, including the following: the amount of the Toxic Substance that enters the process; and any NPRI-reportable releases of the Toxic Substance. It should be noted that the Toxic Substance is not used in the Facility process and therefore no quantifications are required for an amount of Toxic Substance used. The descriptions provided on these PFD are detailed and reference each individual Activity ID. These activity IDs are subsequently used in the required Toxic Substance quantification and accounting. Version 1.0 5

74 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES 5.2 Toxic Substance Accounting Information Quantifications at Process Level for Previous Year Toxic Substance quantifications are also provided in Appendix A. This information is provided on the Calculations, Input/Output Analysis and Summary page. A quantification is provided for each Activity ID identified in the PFD, along with the following: a description of the quantification method; a rationale for selecting each quantification method (see following section); data used to quantify the activity subject to each Activity ID; Data Quality for the quantification; and sample calculation. The Calculations, Input/Output Analysis and Summary page also provides an input/output analysis for each stage where the Toxic Substances are present as well as an input/output balance for entire Facility process. A description of why the sums of inputs and outputs are not equal is provided along with a comment regarding the acceptability of this input/output imbalance Records of Methods and Rationale for Selecting each Method used to Track and Quantify the Toxic Substance In accordance with s.12(6) of O.Reg.455/09, for each quantification method that was used to prepare processlevel quantifications, a rationale for why the method was identified as the best available for the purpose of completing the exercise is provided. In the process of identifying best available methods, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and applying the best available methods for quantifications and collecting the information necessitated by each quantification method. The Facility understands that the methods used to complete the 2012 Toxic Substance QAR exercise can only be changed under the circumstances stipulated in s.12(7) of O.Reg.455/09. At this time, the Facility does not intend to change the quantification methods that were used to complete the 2012 Toxic Substance QAR exercises for the purpose of completing Toxic Substance QAR exercises for subsequent years. 6.0 ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE As required by s.18(1) of O.Reg.455/09, direct and indirect costs have been estimated for the Toxic Substance. In preparing the cost estimates, several departments at the Facility were consulted. Cost items associated with the Toxic Substance were identified in various categories. The cost estimates are provided in Appendix B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance. Version 1.0 6

75 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES Ontario Regulation 455/09 does not specify the level of detail to which a Facility must examine costs associated with a toxic substance, however, the Facility feels that it has gone to reasonable lengths in its efforts to estimate the costs associated with the Toxic Substance. 7.0 OPTIONS CONSIDERED FOR REDUCTION Section 17 of O.Reg.455/09 outlines the requirements for identification of toxic substance reduction options and provides the seven categories of toxic substance reduction options under which options are to be identified as part of the Plan. 7.1 Identification of Toxic Substance Reduction Options in Each of Seven Toxic Substance Reduction Categories With the assistance of a licensed Toxic Substance Reduction Planner, Facility personnel have considered each of the seven categories for toxic substance reduction options. It is not necessarily a requirement under O.Reg.455/09 to provide toxic substance reduction options, however, s.17(1)2 of O.Reg.455/09 states that the following must be provided in the event that an option for toxic substance reduction cannot be identified in any of the seven toxic substance reduction categories: 17(1)2. If an option cannot be identified for a category listed in paragraph 1, an explanation of why no option could be identified for the category The following statement satisfies s.17(1)2 of O.Reg.419/05 each of the seven toxic substance reduction categories for the Toxic Substance. For reasons explained in the Statement of Intent Section of this Plan, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected and therefore no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. 7.2 Estimates of Potential Reductions Associated with Each Identified Toxic Substance Reduction Option No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide estimates of potential reductions associated with identified toxic substance reduction options under s.17(1)3 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 7.3 Identification of Technically Feasible Options No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide Version 1.0 7

76 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES a list of toxic substance reduction options that have been determined to be technically feasible under s.17(1)4 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 7.4 Analysis of Economic Feasibility of Technically Feasible Options No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide an analysis of economic feasibility for any toxic substance reduction options that have been determined to be technically feasible under s.17(1)5 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 8.0 RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented. Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified. 9.0 PLANNER RECOMMENDATIONS AND RATIONALE As required by s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), the Facility provided a draft copy of the Plan to a licensed Toxic Substance Reduction Planner for the purpose of obtaining recommendations with respect to the plan. It should be noted that implementation of Planner Recommendations is not a requirement of O.Reg.455/09 or the TRA. A memorandum addressing requirements pertaining to recommendations by a planner under s.18.2 of O.Reg.455/09 is provided in Appendix C Planner Recommendations and Rationale PLAN SUMMARY As required by s.8 of the TRA, a Plan Summary prepared in accordance with s.23 of O.Reg.455/09 is included in Appendix D. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on the Facility s website and can be provided to a member of the public upon written request. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years. Version 1.0 8

77 11.0 CERTIFICATIONS TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. Version 1.0 9

78 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES APPENDIX A Toxic Substance Quantification, Accounting and Reporting Information for the 2012 Reporting Year Version 1.0

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82 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES APPENDIX B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance Version 1.0

83 Estimates of 2012 Direct and Indirect Baseline Costs Associated with Various TRA Phase II Toxic Substances S.18(1) of O.Reg.455/09 requires that direct and indirect costs be estimated for the Toxic Substance for which the Plan is being prepared. A Facility has the flexibility to determine how and to what level of detail to calculate direct and indirect costs. The MOE indicates that an understanding of direct and indirect costs associated with a prescribed toxic substance will assist the Facility in assessing the economic feasibility of identified toxic substance reduction options. The TRA Phase II substances included in this cost estimation exercise have triggered reporting under the TRA as a result of respective activities that the TRA defines as "creations" of each Toxic Substance. Since these substances are "created" rather than used, no means of calculating costs associated with these "creations" in a way that yields meaningful information was immediately evident. In order to satisfy the requirement to estimate direct and indirect costs associated with each toxic substance, a simple cost estimation exercise was completed, which relies on various cost items that can be considered to be tied to various Toxic Substances as well as "creation" values which were reported by the Facility to the TRA for the 2012 reporting year. It should be noted that, given the Facility s decision to not include in respective Toxic Substance Reduction Plans a statement of its intent to reduce the creation of the Toxic Substances (as supported by the information provided in the Statement of Intent sections of the respective Plans), no decisions will be made with respect to toxics reduction based on the costs calculated below. Taking this into consideration, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and estimating direct and indirect costs associated with these Toxic Substances. The table below provides categories and associated costs for items that may be associated with the Phase II Toxic Substances. Information contained in the table below was provided by Facility personnel and represents an appropriate level of detail for this cost estimating exercise. Costs for each TRA Phase II Toxic Substance associated with each cost category were calculated by multiplying each Toxic Substance's percentage of the total annual release of all substances associated with cost item by the cost of the cost item. Costs associated for each toxic substance for each cost item were then summed to calculate the total estimated direct or indirect baseline cost associated with each Phase II Toxic Substances NOx CO PM PM10 PM2.5 Substance Creation Value Reported to the TRA for the 2012 Baseline Year (tonne/yr) Cost Item Cost Toxic Substances Associated with Cost Item Total Annual Release of Substances Associated with Cost Item (tonnes/yr) Substance Creation Percent of Total Annual Creation of Substances Associated with Cost Item Cost Associated with Toxic Substance NOx CO PM PM10 PM2.5 NOx CO PM PM10 PM2.5 Dust Suppressants $ 28, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 13, $ 7, $ 6, Raw Materials $ 118, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 57, $ 32, $ 27, Utilities (Propane, Diesel) $ 2,075, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ 126, $ 1,323, $ 305, $ 172, $ 147, Review of Traffic Volumes $ 3, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 1, $ $ Engineering Controls (Enclosures, road paving) $ 73, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 35, $ 20, $ 17, Evironmental Compliance $ 15, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ $ 9, $ 2, $ 1, $ 1, Permitting Fees $ 3, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ $ 1, $ $ $ TOTAL COST ASSOCIATED WITH EACH TOXIC SUBSTANCE: $ 127, $ 1,334, $ 417, $ 236, $ 201, Sample Calculation for PM from Dust Suppressants: PM Cost = PM Creation [PM Creation + PM10 Creation + PM2.5 Creation] x Cost of Dust Suppressants PM Cost = $ 13,827.52

84 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES APPENDIX C Planner Recommendations Version 1.0

85 DATE December 2013 PROJECT No TO Melanie Gauthier Richmont Island Gold Mine CC Sean Capstick FROM Russell Polack TOXIC SUBSTANCE REDUCTION PLANNER RECOMMENDATIONS ON THE DOCUMENT ENTITLED TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES Golder Associates Ltd. (Golder) was retained by Mines Richmont Inc. Island Gold Mine (the Facility) to provide various services pertaining to Phase II Toxic Substance Reduction Plan preparation under the Toxics Reduction Act (TRA), including Toxic Substance Reduction Planner recommendations (Planner Recommendations). As required by s.18.2 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.10 of O.Reg.214/11), a facility is required to provide a draft copy of the Plan to a licensed Toxic Substance Reduction Planner (the Planner) for the purpose of obtaining recommendations with respect to the Plan. This technical memorandum fulfills the requirements of s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) for the draft document entitled Toxic Substance Reduction Plan Nitrogen Oxides, Version 1.0 (the Plan) which has been prepared for the prescribed toxic substance referred to as Nitrogen Oxides (the Toxic Substance). Planner Recommendation Requirements Under the Toxics Reduction Act and Ontario Regulation 455/09 Section 18.2(3) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) provides the areas of a given Plan in which Planner Recommendations are required to be documented (the Areas of Recommendation). As required by s.18.2(4) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), a Planner must also provide a rationale for each Planner Recommendation. Implementing Planner Recommendations (if any) is voluntary. As stated in s.18.2(2) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), Planner Recommendations shall be provided for the purpose of improving all aspects of the Plan, including: the potential for reducing the use and creation of the toxic substance at the facility; and the business rationale for implementing the Plan. Section 18.2(5) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) a Planner must provide a written explanation if the Planner is of the opinion that no recommendations are necessary with respect any of the Areas of Recommendation. Golder Associates Ltd Lorne Street, Sudbury, Ontario, Canada P3C 4R9 Tel: +1 (705) Fax: +1 (705) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

86 Melanie Gauthier Richmont Island Gold Mine December 2013 Written Explanation for No Necessary Recommendations The Planner is of the opinion that no recommendations are necessary with respect to any of the Areas of Recommendation for any of the Plans. The following written explanation is being provided by the Planner to the Facility under s.18.2(5) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) and satisfies the Facility s requirements for Planner Recommendations under s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11): The Planner is of the opinion that no recommendations are necessary with respect to any of the matters listed in paragraph 1 to 6 of s.18.2(3) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) for the respective Plans of any of the Toxic Substances. The rationale for this opinion is that the Planner and the Facility feel that there is little value in providing Planner Recommendations on a Plan which does not include a statement of the Facility s intent to reduce its use or creation of the Toxic Substance, but which the Planner feels is compliant with the TRA and O.Reg.455/09. Closure This Technical Memorandum provides the documentation required to satisfy s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) with respect Plans identified above. It is recommended that a copy of this Technical Memorandum be appended to the final Plan. Yours very truly, GOLDER ASSOCIATED LTD. Russell Polack, M.Sc. Toxic Substance Reduction Planner License No. TSRP0002 DCC/RLP c:\users\rpolack\desktop\for home 28nov13\tra\rig\reporting\attachment 7 - co\app c - planner recs\appendix c co planner recs 8dec13 rlp.docx 2/2

87 TOXIC SUBSTANCE REDUCTION PLAN NITROGEN OXIDES APPENDIX D Plan Summary Version 1.0

88 TOXIC SUBSTANCE REDUCTION PLAN SUMMARY This Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the Toxics Reduction Act and satisfies the minimum Plan Summary content requirements stipulated in Section 24 of Ontario Regulation (O.Reg.) 455/09. Basic Facility Information Mandatory Basic Facility Information Item Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any National Pollutant Release Inventory (NPRI) and O.Reg.127/01 Identification Numbers The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full time employee equivalents at the facility North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code Public contact The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum Parent Company Information Details Nitrogen Oxides (CAS Number ) NPRI ID: O.Reg.127/01 ID: N/A Richmont Island Gold Mine Mines Richmont Inc. 15 Goudreau Road, Dubreuilville, ON P0S 1B Mining & Oil & Gas Extraction Metal Ore Mining Gold & Silver Ore Mining Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 UTM Zone E, N Mines Richmont Inc. 161, avenue Principale Rouyn-Noranda, QC J9X 4P6 (819) List of All Substances for which Toxic Substance Reduction Plans Have Been Prepared at the Facility The Facility has prepared Toxic Substance Reduction Plans for the following prescribed Toxic Substances: Arsenic* Cadmium* Chromium* Copper* Lead* Manganese* Zinc* Cyanides (Ionic)* 1 of 4

89 Nitrogen Oxides (CAS number ) Carbon Monoxide (CAS number ) Particulate Matter* PM10* PM2.5* Nitric Acid (CAS number ) *Per O.Reg.455/09, no single CAS numbers apply to these substances Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. A statement of the Facility s intent to reduce its creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is not used in the Facility s process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to its generation as a by-product of combustion of fuels in stationary equipment and detonation of explosives, which are classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance. The MOE has stated that the TRA is not intended to focus on end of pipe emissions as they don t necessarily have any bearing on the amount of a substance that is used or created, however in this case, end of pipe emission of the Toxic Substance are the determining factor of the Facility s TRA reporting status with respect to the Toxic Substance. Despite the Facility s reporting status with respect to the Toxic Substance, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected. This opinion is supported by the following two aspects: Compliance with Regulatory Requirements It is well documented that the release of combustion products such as the Toxic Substance is an inherent by-product of mining and mineral processing and that the activities leading to the release of combustion products are essential to the process of mining and mineral processing. In recognition of this, the MOE has imposed various regulatory requirements related to the release of combustion products, which include: Ontario Regulation 419/05, under which a Facility must demonstrate compliance with substancespecific ground-level concentration limits of emitted substances, including combustion products in all forms that are reportable under the NPRI and TRA reporting programs. 2 of 4

90 The requirement for any Facility that may discharge any contaminant to the atmosphere to apply for and obtain an Environmental Compliance Approval (ECA) for air which approves the facility s emissions and provides performance limits, documentation requirements and reporting requirements which a Facility must meet in order to maintain compliance with the ECA on an ongoing basis. The Facility currently meets and/or exceeds all of the above regulatory requirements which are designed to control the release of the Toxic Substance and minimize potential off-site impacts resulting from the release of the Toxic Substance. Measures Currently in Place to Minimize Releases of Combustion Products As a result of satisfying all of the above noted regulatory requirements in addition to voluntary actions with respect to combustion product releases, the Facility actively implements a variety of controls to minimize combustion product releases from different parts of its process components. Some examples of such controls are provided below. Measures in place to minimize fuel consumption, including but not limited to: regular maintenance of equipment; planning procedures to use existing equipment as efficiently as possible, thereby minimizing the need for additional equipment; and statement of technology in mining equipment fleet to minimize releases from combustion. Measures in place to optimize explosives usage, including but not limited to: facility has recently switched to emulsion explosives which reduces explosives usage, and increases the rate of detonation. Objectives of the Toxic Substance Reduction Plan The Objectives of the Plan are as follows: provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. Description of Why the Toxic Substance Is Used or Created The activity that has been classified as a creation of the toxic substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of the Toxic Substance as a by-product of combustion of fuels in stationary equipment and detonation of explosives. 3 of 4

91 Rationale for Not Implementing Toxic Substance Reduction Options As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented. Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified. Statement that the Plan Summary Accurately Reflects the Current Version of the Plan As required by s.24(1)8 of O.Reg.455/09 this Plan Summary accurately reflects the current version of the Plan. Planner License Number As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows: Russell Polack Air Quality Specialist Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP0002 Copies of the Certification Certification statements are provided in the following page. 4 of 4

92 December 2013 Project No Melanie Gauthier Richmont Mines Inc. Island Gold LICENSED TOXIC SUBSTANCE REDUCTION PLANNER CERTIFICATION STATEMENT FOR PHASE II TOXIC SUBSTANCE REDUCTION PLANS FOR RICHMONT MINES INC. ISLAND GOLD Dear Ms. Gauthier: Golder Associates Ltd. (Golder) was retained by Richmont Mines Inc. Island Gold (the Facility) to provide various services pertaining to Phase II Toxic Substance Reduction Plan preparation under the Toxics Reduction Act (TRA), including Toxic Substance Reduction Planner (Planner) certification of Phase II Toxic Substance Reduction Plans (the Plans). The following Planner Certification Statement which is made under s.19.1(4) of Ontario Regulation (O.Reg.) 455/09 (as amended by s.11 of O.Reg.214/11) satisfies the Planner Certification requirements for the Plans that are assembled as a single document as of the date of this Certification Statement. Furthermore, the following Certification Statement is limited to the respective versions of the Plans which are dated as indicated in the Certification Statement: As of, I, Russell Polack certify that I am familiar with the processes at the Richmont Mines Inc. Island Gold Mine facility that use or create the toxic substances referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the toxic substance reduction plans referred to below for the toxic substances and that the plans comply with that Act and Ontario Regulation 455/09 (General) made under that Act. Particulate Matter () PM10 () PM2.5 () Nitrogen Oxides () Carbon Monoxide () Nitric Acid () Russell Polack Toxic Substance Reduction Planner License No. TSRP0002 HJ/RLP Date Golder Associates Ltd Lorne Street, Sudbury, Ontario, Canada P3C 4R9 Tel: +1 (705) Fax: +1 (705) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

93 Toxic Substance Reduction Plans Certification by Highest Ranking Employee As required by s.4(2) of the Toxics Reduction Act (TRA), Toxic Substance Reduction Plans must contain a certification, signed by the highest ranking employee at the Richmont Mines Inc. Island Gold Mine (the Facility) who has management responsibilities relating to the Facility. The following Certification Statement is being made under s.19(2) of Ontario Regulation (O.Reg.) 455/09 (as amended by s.11 of O.Reg.214/11) and satisfies the requirements of s.4(2) of the TRA for the Toxic Substance Reduction Plans that are assembled within this single document as of the date of this Certification Statement. Furthermore, the following Certification Statement is limited to the respective versions of the Plans which are dated as indicated in the Certification Statement: As of (insert date), I, (insert name), certify that I have read the toxic substance reduction plans for the toxic substances referred to below and am familiar with their contents, and to my knowledge the plans are factually accurate and comply with the Toxics Reduction Act, 2009 and Ontario Regulation 455/09 (General) made under that Act. Particulate Matter () PM2.5 () PM10 () Nitrogen Oxides() Carbon Monoxide () Nitric Acid () Signature Date Jean Bastien Print Name Jean Bastien Mine Manager

94 ISLAND GOLD MINE RICHMONT MINES INC. TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE VERSION 1.0

95 Document Version Control TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE This document constitutes Toxic Substance Reduction Plan Version 1.0 for the prescribed toxic substance referred to as Carbon Monoxide under the Toxics Reduction Act. S.22 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.13 of O.Reg.214/11) provides the framework for Plan review and requirements for a new version of the Plan. This plan must be updated by the end of the calendar year in which a significant process change (as defined in s.1(3) of O.Reg.455/09) occurs. The first mandatory Plan update is required to be completed by December 31, Future updates of this Plan will be assigned a new version number. Version Date Revision Description Reviewed By (Facility Contact) 1.0 December 2013 Plan Version 1.0 Melanie Gauthier VERSION 1.0 i

96 Executive Summary TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed toxic substance referred to as Carbon Monoxide (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The Ontario Ministry of the Environment (MOE) has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Richmont operates the Island Gold Mine facility (the Facility) which is located in Dubreuilville, Ontario. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substance since the Facility meets the TRAs definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for the 2012 reporting year in accordance with s.12 of O.Reg.455/09. This plan satisfies the Toxic Substance Reduction Plan preparation requirements of the TRA and O.Reg.455/09. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of toxic substance reduction options identified in the Plan (if any) is not a requirement of the TRA or O.Reg.455/09. A Toxic Substance Reduction Plan Component Checklist (the Plan Component Checklist), which outlines the minimum content requirements of a Toxic Substance Reduction Plan, is provided following this Executive Summary. This Plan is structured so that section headings correspond to the items in the Plan Component Checklist. This approach is designed to provide a clear depiction of this Plan s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. Section 4(1) of the TRA requires that a Plan include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to its generation as a byproduct of combustion of fuels in stationary equipment, detonation of explosives and wood burning, which are classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance. VERSION 1.0 ii

97 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE As a result of voluntary and regulatory commitments described within this Plan, the Facility is of the opinion that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected, and therefore a statement of the Facility s intent to reduce creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is never used in the Facility process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. In light of the above, the objectives of this Plan are as follows: provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Plans for Phase II substances for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. A Plan Summary prepared in accordance with s.23 of O.Reg.455/09 is included as a part of this Plan. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on the Facility s website and can be provided to a member of the public upon written request. This Plan documents the Facility s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years. VERSION 1.0 iii

98 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE Toxic Substance Reduction Plan Component Checklist The following checklist is adapted from Appendix 4 of the MOE Planning Toolkit. It outlines mandatory Toxic Substance Reduction Plan components and provides a reference to the section of this Plan which provides the required information to satisfy each mandatory component. Mandatory Plan Component Provided? Plan Section Reference Basic facility information Yes s.2.0 Planner license numbers Yes s.3.0 Statement of intent to reduce the use and/or creation of toxic substance (or reasons for not including one) Objectives of the Plan Yes s.4.2 Description of each process that uses the toxic substance Yes s.5.1 description of how, when, where and why the substance is used or created Yes s records of identification and description of stages and processes of a facility's operation and a record containing process flow diagrams. Toxic substance accounting information Yes s.5.2 Yes Yes s.4.1 s quantifications at process level for previous year Yes s record of methods and rationale for selecting each method used to track and quantify toxic substance Yes s Estimate of direct and indirect annual costs associated with the toxic substance Yes s.6.0, App B Options considered for Reduction Yes s.7.0 identification of toxic substance reduction options in each of seven toxic reduction categories stipulated in O.Reg.455/09 or explanation of why no option could be identified estimate of potential reductions in use, creation, contained in product, release (air, land and water), disposal, transfer of toxic substances achieved if option was implemented and the information used to develop the estimate identification of technically feasible options N/A s.7.3 analysis of economic feasibility of technically feasible options, including anticipated savings and payback period N/A s.7.4 For each option to be implemented a description of implementation steps and a timetable for implementation N/A N/A a summary of estimated toxics reduction in use, creation, released, disposed, transferred for recycling, and/or contained in product (as a percentage and unit of measurement) anticipated dates for achieving use and creation reductions N/A N/A OR If no options were implemented provide the rationale for this decision Yes s.8.0 Planner Recommendations and Rationale Yes s.9.0, App C Certifications by the highest ranking employee and the toxics reduction planner Yes s.11.0 Yes N/A N/A s.7.1 s.7.2 N/A VERSION 1.0 iv

99 Table of Contents TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE 1.0 INTRODUCTION BASIC FACILITY INFORMATION PLANNER LICENSE NUMBER STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN Statement of Intent Objectives of the Plan TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2012 REPORTING YEAR Description of each Process that uses the Toxic Substance Description of How, When, Where and Why the Substance is Used or Created Records of Identification and Description of Stages and Processes of Facility Operation and Record Containing Process Flow Diagrams Toxic Substance Accounting Information Quantifications at Process Level for Previous Year Records of Methods and Rationale for Selecting each Method used to Track and Quantify the Toxic Substance ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE OPTIONS CONSIDERED FOR REDUCTION Identification of Toxic Substance Reduction Options in Each of Seven Toxic Substance Reduction Categories Estimates of Potential Reductions Associated with Each Identified Toxic Substance Reduction Option Identification of Technically Feasible Options Analysis of Economic Feasibility of Technically Feasible Options RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS PLANNER RECOMMENDATIONS AND RATIONALE PLAN SUMMARY CERTIFICATIONS... 9 VERSION 1.0 v

100 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE APPENDICES APPENDIX A Toxic Substance Quantification, Accounting and Reporting Information for the 2012 Reporting Year APPENDIX B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance APPENDIX C Planner Recommendations APPENDIX D Plan Summary VERSION 1.0 vi

101 1.0 INTRODUCTION TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed toxic substance referred to as Carbon Monoxide (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine Facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The MOE has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Under the TRA, regulated facilities are required to: perform quantification, accounting and reporting on the toxic substance use, creation, amount contained in product and release at the Facility on an annual basis; prepare Toxic Substance Reduction Plans in which it is documented, where feasible, how the use and creation of toxic substances might be reduced; have the Toxic Substance Reduction Plan certified by an MOE licensed Toxic Substance Reduction Planner (the Planner) as well as the Highest Ranking Employee (HRE) at the Facility; prepare Plan Summaries containing various components of the Toxic Substance Reduction Plans and make them available to the public; submit annual reports on progress made on the Plans; and update the Plans at least every five years. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of toxic substance reduction options identified in a given Plan (if any) is not a requirement of the TRA or O.Reg.455/09. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substances since the Facility meets the TRA s definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2010, 2011 and 2012 reporting years in accordance with s.12 of O.Reg.455/09, and this Plan satisfies the Toxic Substance Reduction Plan and Plan Summary preparation requirements of the TRA and O.Reg.455/09 for the Toxic Substance. Version 1.0 1

102 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE 2.0 BASIC FACILITY INFORMATION The following table is adapted from Appendix 3 of the MOE Planning Toolkit and provides the applicable Basic Facility Information stipulated in section 18(2) of O.Reg.455/09. Mandatory Basic Facility Information Item Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any NPRI and O.Reg.127/01 Identification Numbers The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full time employee equivalents at the facility North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code Public contact Technical contact and person who is responsible for coordinating plan preparation The person who prepared the plan Highest Ranking employee at the facility who has management responsibilities relating to the facility and who is responsible for making certification The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum Parent Company Information Carbon Monoxide, NPRI ID: O.Reg.127/01 ID: N/A Details Richmont Island Gold Mine Mines Richmont Inc. 15 Goudreau Road, Dubreuilville, ON P0S 1B Mining & Oil & Gas Extraction Metal Ore Mining Gold & Silver Ore Mining Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 Russell Polack Toxic Substance Reduction Planner Golder Associates Ltd Lorne Street, Sudbury, ON P3C 4R9 (705) Jean Bastien Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) UTM Zone E, N Mines Richmont Inc. 161, avenue Principale Rouyn-Noranda, QC J9X 4P6 (819) Version 1.0 2

103 3.0 PLANNER LICENSE NUMBER TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows: Russell Polack Air Quality Specialist Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. This Plan outlines the Facility s position that no toxic substance reduction options can be identified for the Toxic Substance at this time. 4.1 Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. A statement of the Facility s intent to reduce its creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is not used in the Facility s process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to its generation as a byproduct of combustion of fuels in stationary equipment, detonation of explosives and wood burning, all of which are classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance. The MOE has stated that the TRA is not intended to focus on end of pipe emissions as they don t necessarily have any bearing on the amount of a substance that is used or created, however in this case, end of pipe emission of the Toxic Substance are the determining factor of the Facility s TRA reporting status with respect to the Toxic Substance. Despite the Facility s reporting status with respect to the Toxic Substance, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected. This opinion is supported by the following two aspects: Compliance with Regulatory Requirements It is well documented that the release of combustion products such as the Toxic Substance is an inherent byproduct of mining and mineral processing and that the activities leading to the release of combustion products Version 1.0 3

104 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE are essential to the process of mining and mineral processing. In recognition of this, the MOE has imposed various regulatory requirements related to the release of combustion products, which include: Ontario Regulation 419/05, under which a Facility must demonstrate compliance with substance-specific ground-level concentration limits of emitted substances, including combustion products in all forms that are reportable under the NPRI and TRA reporting programs. The requirement for any Facility that may discharge any contaminant to the atmosphere to apply for and obtain an Environmental Compliance Approval (ECA) for air which approves the facility s emissions and provides performance limits, documentation requirements and reporting requirements which a Facility must meet in order to maintain compliance with the ECA on an ongoing basis. The Facility currently meets and/or exceeds all of the above regulatory requirements which are designed to control the release of the Toxic Substance and minimize potential off-site impacts resulting from the release of the Toxic Substance. Measures Currently in Place to Minimize Releases of Combustion Products As a result of satisfying all of the above noted regulatory requirements in addition to voluntary actions with respect to combustion product releases, the Facility actively implements a variety of controls to minimize combustion product releases from different parts of its process components. Some examples of such controls are provided below. Measures in place to minimize fuel consumption, including but not limited to: regular maintenance of equipment; planning procedures to use existing equipment as efficiently as possible, thereby minimizing the need for additional equipment; and statement of technology in mining equipment fleet to minimize releases from combustion. Measures in place to optimize explosives usage, including but not limited to: Facility has recently switched to emulsion explosives which reduces explosives usage, and increases the rate of detonation. Measures in place to minimize wood burning, including but not limited to: re-using scrap wood material and pallets; and planning procedures which minimize the generation of scrap wood. 4.2 Objectives of the Plan The objectives of the Plan are: provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and Version 1.0 4

105 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. 5.0 TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2012 REPORTING YEAR As required by s.12 of O.Reg.455/09, the Facility has fulfilled its Toxic Substance quantification, accounting and reporting (QAR) requirements for the Toxic Substance for all reporting years to date. The Toxic Substance QAR exercises were completed in accordance with subsections of s.12 of O.Reg.455/09 and consider guidance provided in the MOE Planning. Per guidance, Toxic Substance QAR information for the 2012 reporting year was relied upon in the preparation of this Plan. The appropriate Toxic Substance QAR information for the 2012 reporting year was submitted by the Facility before the deadline of June 1, The 2012 Toxic Substance QAR information is provided in Appendix A. The following sections provide a description of how the Toxic Substance QAR exercise was completed and how each applicable item under s.12 of O.Reg.455/09 is addressed by these Toxic Substance QAR exercises. 5.1 Description of each Process that uses the Toxic Substance Description of How, When, Where and Why the Substance is Used or Created The activity that has been classified as a creation of the toxic substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of the Toxic Substance as a by-product of combustion of fuels in stationary equipment, detonation of explosives and wood burning Records of Identification and Description of Stages and Processes of Facility Operation and Record Containing Process Flow Diagrams Per guidance provided in the Accounting Toolkit, Process Flow Diagrams (PFDs) have been provided as part of the Toxic Substance QAR exercise to give a visual representation of the movement of the Toxic Substance through every stage of the process where it is present and to show the relationships between the processes. The PFD provides the appropriate level of detail to satisfy s.12 of O.Reg.455/09. It demonstrates in each stage where the Toxic Substance is present has been broken down into a sufficient number of individual processes to satisfy s.12(3) of O.Reg.455/09, and introduces Activity IDs for activities for which process-level quantifications for the Toxic Substances have been completed, including the following: the amount of the Toxic Substance that enters the process; and any NPRI-reportable releases of the Toxic Substance. It should be noted that the Toxic Substance is not used in the Facility process and therefore no quantifications are required for an amount of Toxic Substance used. Version 1.0 5

106 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE The descriptions provided on these PFD are detailed and reference each individual Activity ID. These activity IDs are subsequently used in the required Toxic Substance quantification and accounting. 5.2 Toxic Substance Accounting Information Quantifications at Process Level for Previous Year Toxic Substance quantifications are also provided in Appendix A. This information is provided on the Calculations, Input/Output Analysis and Summary page. A quantification is provided for each Activity ID identified in the PFD, along with the following: a description of the quantification method; a rationale for selecting each quantification method (see following section); data used to quantify the activity subject to each Activity ID; data quality for the quantification; and sample calculation. The Calculations, Input/Output Analysis and Summary page also provides an input/output analysis for each stage where the Toxic Substances are present as well as an input/output balance for entire Facility process. A description of why the sums of inputs and outputs are not equal is provided along with a comment regarding the acceptability of this input/output imbalance Records of Methods and Rationale for Selecting each Method used to Track and Quantify the Toxic Substance In accordance with s.12(6) of O.Reg.455/09, for each quantification method that was used to prepare processlevel quantifications, a rationale for why the method was identified as the best available for the purpose of completing the exercise is provided. In the process of identifying best available methods, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and applying the best available methods for quantifications and collecting the information necessitated by each quantification method. The Facility understands that the methods used to complete the 2012 Toxic Substance QAR exercise can only be changed under the circumstances stipulated in s.12(7) of O.Reg.455/09. At this time, the Facility does not intend to change the quantification methods that were used to complete the 2012 Toxic Substance QAR exercises for the purpose of completing Toxic Substance QAR exercises for subsequent years. Version 1.0 6

107 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE 6.0 ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE As required by s.18(1) of O.Reg.455/09, direct and indirect costs have been estimated for the Toxic Substance. In preparing the cost estimates, several departments at the Facility were consulted. Cost items associated with the Toxic Substance were identified in various categories. The cost estimates are provided in Appendix B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance. Ontario Regulation 455/09 does not specify the level of detail to which a Facility must examine costs associated with a toxic substance, however the Facility feels that it has gone to reasonable lengths in its efforts to estimate the costs associated with the Toxic Substance. 7.0 OPTIONS CONSIDERED FOR REDUCTION Section 17 of O.Reg.455/09 outlines the requirements for identification of toxic substance reduction options and provides the seven categories of toxic substance reduction options under which options are to be identified as part of the Plan. 7.1 Identification of Toxic Substance Reduction Options in Each of Seven Toxic Substance Reduction Categories With the assistance of a licensed Toxic Substance Reduction Planner, Facility personnel have considered each of the seven categories for toxic substance reduction options. It is not necessarily a requirement under O.Reg.455/09 to provide toxic substance reduction options, however s.17(1)2 of O.Reg.455/09 states that the following must be provided in the event that an option for toxic substance reduction cannot be identified in any of the seven toxic substance reduction categories: 17(1)2. If an option cannot be identified for a category listed in paragraph 1, an explanation of why no option could be identified for the category The following statement satisfies s.17(1)2 of O.Reg.419/05 each of the seven toxic substance reduction categories for the Toxic Substance. For reasons explained in the Statement of Intent Section of this Plan, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected and therefore no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. 7.2 Estimates of Potential Reductions Associated with Each Identified Toxic Substance Reduction Option No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be Version 1.0 7

108 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide estimates of potential reductions associated with identified toxic substance reduction options under s.17(1)3 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 7.3 Identification of Technically Feasible Options No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide a list of toxic substance reduction options that have been determined to be technically feasible under s.17(1)4 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 7.4 Analysis of Economic Feasibility of Technically Feasible Options No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide an analysis of economic feasibility for any toxic substance reduction options that have been determined to be technically feasible under s.17(1)5 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 8.0 RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented. Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified. 9.0 PLANNER RECOMMENDATIONS AND RATIONALE As required by s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), the Facility provided a draft copy of the Plan to a licensed Toxic Substance Reduction Planner for the purpose of obtaining recommendations with respect to the plan. It should be noted that implementation of Planner Recommendations is not a requirement of O.Reg.455/09 or the TRA. A memorandum addressing requirements pertaining to recommendations by a planner under s.18.2 of O.Reg.455/09 is provided in Appendix C Planner Recommendations and Rationale. Version 1.0 8

109 10.0 PLAN SUMMARY TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE As required by s.8 of the TRA, a Plan Summary prepared in accordance with s.23 of O.Reg.455/09 is included in Appendix D. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on the Facility s website and can be provided to a member of the public upon written request. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years CERTIFICATIONS Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the Highest Ranking Employee (HRE) and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. Version 1.0 9

110 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE APPENDIX A Toxic Substance Quantification, Accounting and Reporting Information for the 2012 Reporting Year Version

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114 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE APPENDIX B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance Version 1.0

115 Estimates of 2012 Direct and Indirect Baseline Costs Associated with Various TRA Phase II Toxic Substances S.18(1) of O.Reg.455/09 requires that direct and indirect costs be estimated for the Toxic Substance for which the Plan is being prepared. A Facility has the flexibility to determine how and to what level of detail to calculate direct and indirect costs. The MOE indicates that an understanding of direct and indirect costs associated with a prescribed toxic substance will assist the Facility in assessing the economic feasibility of identified toxic substance reduction options. The TRA Phase II substances included in this cost estimation exercise have triggered reporting under the TRA as a result of respective activities that the TRA defines as "creations" of each Toxic Substance. Since these substances are "created" rather than used, no means of calculating costs associated with these "creations" in a way that yields meaningful information was immediately evident. In order to satisfy the requirement to estimate direct and indirect costs associated with each toxic substance, a simple cost estimation exercise was completed, which relies on various cost items that can be considered to be tied to various Toxic Substances as well as "creation" values which were reported by the Facility to the TRA for the 2012 reporting year. It should be noted that, given the Facility s decision to not include in respective Toxic Substance Reduction Plans a statement of its intent to reduce the creation of the Toxic Substances (as supported by the information provided in the Statement of Intent sections of the respective Plans), no decisions will be made with respect to toxics reduction based on the costs calculated below. Taking this into consideration, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and estimating direct and indirect costs associated with these Toxic Substances. The table below provides categories and associated costs for items that may be associated with the Phase II Toxic Substances. Information contained in the table below was provided by Facility personnel and represents an appropriate level of detail for this cost estimating exercise. Costs for each TRA Phase II Toxic Substance associated with each cost category were calculated by multiplying each Toxic Substance's percentage of the total annual release of all substances associated with cost item by the cost of the cost item. Costs associated for each toxic substance for each cost item were then summed to calculate the total estimated direct or indirect baseline cost associated with each Phase II Toxic Substances NOx CO PM PM10 PM2.5 Substance Creation Value Reported to the TRA for the 2012 Baseline Year (tonne/yr) Cost Item Cost Toxic Substances Associated with Cost Item Total Annual Release of Substances Associated with Cost Item (tonnes/yr) Substance Creation Percent of Total Annual Creation of Substances Associated with Cost Item Cost Associated with Toxic Substance NOx CO PM PM10 PM2.5 NOx CO PM PM10 PM2.5 Dust Suppressants $ 28, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 13, $ 7, $ 6, Raw Materials $ 118, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 57, $ 32, $ 27, Utilities (Propane, Diesel) $ 2,075, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ 126, $ 1,323, $ 305, $ 172, $ 147, Review of Traffic Volumes $ 3, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 1, $ $ Engineering Controls (Enclosures, road paving) $ 73, PM, PM10, PM N/A N/A 49% 28% 24% N/A N/A $ 35, $ 20, $ 17, Evironmental Compliance $ 15, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ $ 9, $ 2, $ 1, $ 1, Permitting Fees $ 3, PM, PM10, PM2.5, NOx, CO % 64% 15% 8% 7% $ $ 1, $ $ $ TOTAL COST ASSOCIATED WITH EACH TOXIC SUBSTANCE: $ 127, $ 1,334, $ 417, $ 236, $ 201, Sample Calculation for PM from Dust Suppressants: PM Cost = PM Creation [PM Creation + PM10 Creation + PM2.5 Creation] x Cost of Dust Suppressants PM Cost = $ 13,827.52

116 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE APPENDIX C Planner Recommendations Version 1.0

117 DATE December 2013 PROJECT No TO Melanie Gauthier Richmont Island Gold Mine CC Sean Capstick FROM Russell Polack TOXIC SUBSTANCE REDUCTION PLANNER RECOMMENDATIONS ON THE DOCUMENT ENTITLED TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE Golder Associates Ltd. (Golder) was retained by Mines Richmont Inc. Island Gold Mine (the Facility) to provide various services pertaining to Phase II Toxic Substance Reduction Plan preparation under the Toxics Reduction Act (TRA), including Toxic Substance Reduction Planner recommendations (Planner Recommendations). As required by s.18.2 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.10 of O.Reg.214/11), a facility is required to provide a draft copy of the Plan to a licensed Toxic Substance Reduction Planner (the Planner) for the purpose of obtaining recommendations with respect to the Plan. This technical memorandum fulfills the requirements of s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) for the draft document entitled Toxic Substance Reduction Plan Carbon Monoxide, Version 1.0 (the Plan) which has been prepared for the prescribed toxic substance referred to as Carbon Monoxide (the Toxic Substance). Planner Recommendation Requirements Under the Toxics Reduction Act and Ontario Regulation 455/09 Section 18.2(3) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) provides the areas of a given Plan in which Planner Recommendations are required to be documented (the Areas of Recommendation). As required by s.18.2(4) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), a Planner must also provide a rationale for each Planner Recommendation. Implementing Planner Recommendations (if any) is voluntary. As stated in s.18.2(2) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), Planner Recommendations shall be provided for the purpose of improving all aspects of the Plan, including: the potential for reducing the use and creation of the toxic substance at the facility; and the business rationale for implementing the Plan. Section 18.2(5) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) a Planner must provide a written explanation if the Planner is of the opinion that no recommendations are necessary with respect any of the Areas of Recommendation. Golder Associates Ltd Lorne Street, Sudbury, Ontario, Canada P3C 4R9 Tel: +1 (705) Fax: +1 (705) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

118 Melanie Gauthier Richmont Island Gold Mine December 2013 Written Explanation for No Necessary Recommendations The Planner is of the opinion that no recommendations are necessary with respect to any of the Areas of Recommendation for any of the Plans. The following written explanation is being provided by the Planner to the Facility under s.18.2(5) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) and satisfies the Facility s requirements for Planner Recommendations under s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11): The Planner is of the opinion that no recommendations are necessary with respect to any of the matters listed in paragraph 1 to 6 of s.18.2(3) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) for the respective Plans of any of the Toxic Substances. The rationale for this opinion is that the Planner and the Facility feel that there is little value in providing Planner Recommendations on a Plan which does not include a statement of the Facility s intent to reduce its use or creation of the Toxic Substance, but which the Planner feels is compliant with the TRA and O.Reg.455/09. Closure This technical memorandum provides the documentation required to satisfy s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) with respect Plans identified above. It is recommended that a copy of this technical memorandum be appended to the final Plan. Yours very truly, GOLDER ASSOCIATED LTD. Russell Polack, M.Sc. Toxic Substance Reduction Planner License No. TSRP0002 DCC/RLP/FSC/ms n:\active\2013\1190 sudbury\1192\ richmont tra ph ii dubreuilville\reporting\attachment 6 - co\app c - planner recs\appendix c 13dec13 co planner recs.docx 2/2

119 TOXIC SUBSTANCE REDUCTION PLAN CARBON MONOXIDE APPENDIX D Plan Summary Version 1.0

120 TOXIC SUBSTANCE REDUCTION PLAN SUMMARY This Toxic Substance Reduction Plan Summary has been prepared in accordance with Section 8(2) of the Toxics Reduction Act and satisfies the minimum Plan Summary content requirements stipulated in Section 24 of Ontario Regulation (O.Reg.) 455/09. Basic Facility Information Mandatory Basic Facility Information Item Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any National Pollutant Release Inventory (NPRI) and O.Reg.127/01 Identification Numbers The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full time employee equivalents at the facility North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code Public contact The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum Parent Company Information Details Carbon Monoxide (CAS Number ) NPRI ID: O.Reg.127/01 ID: N/A Richmont Island Gold Mine Mines Richmont Inc. 15 Goudreau Road, Dubreuilville, ON P0S 1B Mining & Oil & Gas Extraction Metal Ore Mining Gold & Silver Ore Mining Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 UTM Zone E, N Mines Richmont Inc. 161, avenue Principale Rouyn-Noranda, QC J9X 4P6 (819) List of All Substances for which Toxic Substance Reduction Plans Have Been Prepared at the Facility The Facility has prepared Toxic Substance Reduction Plans for the following prescribed Toxic Substances: Arsenic* Cadmium* Chromium* Copper* Lead* Manganese* Zinc* Cyanides (Ionic)* 1 of 4

121 Nitrogen Oxides (CAS number ) Carbon Monoxide (CAS number ) Particulate Matter* PM10* PM2.5* Nitric Acid (CAS number ) *Per O.Reg.455/09, no single CAS numbers apply to these substances Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement. A statement of the Facility s intent to reduce its creation of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is not used in the Facility s process and therefore no statement with respect to intent to reduce use of the Toxic Substance is required. The Toxic Substance has triggered reporting under the TRA and O.Reg.455/09 due to its generation as a by-product of combustion of fuels in stationary equipment, detonation of explosives and wood burning, all of which are classified as a creation of the Toxic Substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance. The MOE has stated that the TRA is not intended to focus on end of pipe emissions as they don t necessarily have any bearing on the amount of a substance that is used or created, however in this case, end of pipe emission of the Toxic Substance are the determining factor of the Facility s TRA reporting status with respect to the Toxic Substance. Despite the Facility s reporting status with respect to the Toxic Substance, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected. This opinion is supported by the following two aspects: Compliance with Regulatory Requirements It is well documented that the release of combustion products such as the Toxic Substance is an inherent by-product of mining and mineral processing and that the activities leading to the release of combustion products are essential to the process of mining and mineral processing. In recognition of this, the MOE has imposed various regulatory requirements related to the release of combustion products, which include: Ontario Regulation 419/05, under which a Facility must demonstrate compliance with substancespecific ground-level concentration limits of emitted substances, including combustion products in all forms that are reportable under the NPRI and TRA reporting programs. 2 of 4

122 The requirement for any Facility that may discharge any contaminant to the atmosphere to apply for and obtain an Environmental Compliance Approval (ECA) for air which approves the facility s emissions and provides performance limits, documentation requirements and reporting requirements which a Facility must meet in order to maintain compliance with the ECA on an ongoing basis. The Facility currently meets and/or exceeds all of the above regulatory requirements which are designed to control the release of the Toxic Substance and minimize potential off-site impacts resulting from the release of the Toxic Substance. Measures Currently in Place to Minimize Releases of Combustion Products As a result of satisfying all of the above noted regulatory requirements in addition to voluntary actions with respect to combustion product releases, the Facility actively implements a variety of controls to minimize combustion product releases from different parts of its process components. Some examples of such controls are provided below. Measures in place to minimize fuel consumption, including but not limited to: regular maintenance of equipment; planning procedures to use existing equipment as efficiently as possible, thereby minimizing the need for additional equipment; and statement of technology in mining equipment fleet to minimize releases from combustion. Measures in place to optimize explosives usage, including but not limited to: Facility has recently switched to emulsion explosives which reduces explosives usage, and increases the rate of detonation. Measures in place to minimize wood burning, including but not limited to: re-using scrap wood material and pallets; and planning procedures which minimize the generation of scrap wood. Objectives of the Toxic Substance Reduction Plan The Objectives of the Plan are as follows: provide the reader with information on measures currently in place at the Facility which control the creation and subsequent release of the Toxic Substance; provide support for the Facility s position with respect to the Statement of Intent of this Plan; and document how the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. 3 of 4

123 Description of Why the Toxic Substance Is Used or Created The activity that has been classified as a creation of the toxic substance for the purpose of the required TRA Quantification, Accounting and Reporting exercise for the Toxic Substance is the generation of the Toxic Substance as a by-product of combustion of fuels in stationary equipment, detonation of explosives and wood burning. Rationale for Not Implementing Toxic Substance Reduction Options As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented. Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified. Statement that the Plan Summary Accurately Reflects the Current Version of the Plan As required by s.24(1)8 of O.Reg.455/09 this Plan Summary accurately reflects the current version of the Plan. Planner License Number As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows: Russell Polack Air Quality Specialist Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP0002 Copies of the Certification Certification statements are provided in the following page. 4 of 4

124 December 2013 Project No Melanie Gauthier Richmont Mines Inc. Island Gold LICENSED TOXIC SUBSTANCE REDUCTION PLANNER CERTIFICATION STATEMENT FOR PHASE II TOXIC SUBSTANCE REDUCTION PLANS FOR RICHMONT MINES INC. ISLAND GOLD Dear Ms. Gauthier: Golder Associates Ltd. (Golder) was retained by Richmont Mines Inc. Island Gold (the Facility) to provide various services pertaining to Phase II Toxic Substance Reduction Plan preparation under the Toxics Reduction Act (TRA), including Toxic Substance Reduction Planner (Planner) certification of Phase II Toxic Substance Reduction Plans (the Plans). The following Planner Certification Statement which is made under s.19.1(4) of Ontario Regulation (O.Reg.) 455/09 (as amended by s.11 of O.Reg.214/11) satisfies the Planner Certification requirements for the Plans that are assembled as a single document as of the date of this Certification Statement. Furthermore, the following Certification Statement is limited to the respective versions of the Plans which are dated as indicated in the Certification Statement: As of, I, Russell Polack certify that I am familiar with the processes at the Richmont Mines Inc. Island Gold Mine facility that use or create the toxic substances referred to below, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the toxic substance reduction plans referred to below for the toxic substances and that the plans comply with that Act and Ontario Regulation 455/09 (General) made under that Act. Particulate Matter () PM10 () PM2.5 () Nitrogen Oxides () Carbon Monoxide () Nitric Acid () Russell Polack Toxic Substance Reduction Planner License No. TSRP0002 HJ/RLP Date Golder Associates Ltd Lorne Street, Sudbury, Ontario, Canada P3C 4R9 Tel: +1 (705) Fax: +1 (705) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

125 Toxic Substance Reduction Plans Certification by Highest Ranking Employee As required by s.4(2) of the Toxics Reduction Act (TRA), Toxic Substance Reduction Plans must contain a certification, signed by the highest ranking employee at the Richmont Mines Inc. Island Gold Mine (the Facility) who has management responsibilities relating to the Facility. The following Certification Statement is being made under s.19(2) of Ontario Regulation (O.Reg.) 455/09 (as amended by s.11 of O.Reg.214/11) and satisfies the requirements of s.4(2) of the TRA for the Toxic Substance Reduction Plans that are assembled within this single document as of the date of this Certification Statement. Furthermore, the following Certification Statement is limited to the respective versions of the Plans which are dated as indicated in the Certification Statement: As of (insert date), I, (insert name), certify that I have read the toxic substance reduction plans for the toxic substances referred to below and am familiar with their contents, and to my knowledge the plans are factually accurate and comply with the Toxics Reduction Act, 2009 and Ontario Regulation 455/09 (General) made under that Act. Particulate Matter () PM2.5 () PM10 () Nitrogen Oxides() Carbon Monoxide () Nitric Acid () Signature Date Jean Bastien Print Name Jean Bastien Mine Manager

126 ISLAND GOLD MINE RICHMONT MINES INC. TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID VERSION 1.0

127 Document Version Control TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID This document constitutes Toxic Substance Reduction Plan Version 1.0 for the prescribed toxic substance referred to as Nitric Acid under the Toxics Reduction Act. Section 22 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.13 of O.Reg.214/11) provides the framework for Plan review and requirements for a new version of the Plan. This plan must be updated by the end of the calendar year in which a significant process change (as defined in s.1(3) of O.Reg.455/09) occurs. The first mandatory Plan update is required to be completed by December 31, Future updates of this Plan will be assigned a new version number. Version Date Revision Description Reviewed By (Facility Contact) 1.0 December 2013 Plan Version 1.0 Melanie Gauthier VERSION 1.0 i

128 Executive Summary TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O.Reg.) 455/09 for the prescribed toxic substance referred to as Nitric Acid (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine Facility. Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The MOE has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing use and/or creation of prescribed substances; however, it does not restrict or require elimination of prescribed toxic substance. Richmont operates the Island Gold Mine facility (the Facility) which is located in Dubreuilville, Ontario. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substance since the Facility meets the TRAs definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for the 2012 reporting year in accordance with s.12 of O.Reg.455/09. This Plan satisfies the Toxic Substance Reduction Plan preparation requirements of the TRA and O.Reg.455/09. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of toxic substance reduction options identified in the Plan (if any) is not a requirement of the TRA or O.Reg.455/09. A Toxic Substance Reduction Plan Component Checklist (the Plan Component Checklist), which outlines the minimum content requirements of a Toxic Substance Reduction Plan, is provided following this Executive Summary. This Plan is structured so that section headings correspond to the items in the Plan Component Checklist. This approach is designed to provide a clear depiction of this Plan s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. S.4(1) of the TRA requires that a Plan include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. The Facility is of the opinion that it has previously optimized its use of the Toxic Substance to the greatest extent that can reasonably be expected at this time., and therefore a statement of the Facility s intent to reduce use of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is never created within the Facility s process and therefore no statement with respect to intent to reduce creation of the Toxic Substance is required. VERSION 1.0 ii

129 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID In light of the above, the objectives of this Plan are as follows: provide support for the Facility s position with respect to the Statement of Intent of this Plan; and document how, by preparing this Plan, the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. A Plan Summary prepared in accordance with s.23 of O.Reg.455/09 is included as a part of this Plan. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on the Facility s website and can be provided to a member of the public upon written request. This Plan documents the Facility s compliance with the Toxic Substance Reduction Plan requirements of the TRA and O.Reg.455/09. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years. VERSION 1.0 iii

130 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID Toxic Substance Reduction Plan Component Checklist The following checklist is adapted from Appendix 4 of the MOE Planning Toolkit. It outlines mandatory Toxic Substance Reduction Plan components and provides a reference to the section of this Plan which provides the required information to satisfy each mandatory component. Mandatory Plan Component Provided? Plan Section Reference Basic facility information Yes s.2.0 Planner license numbers Yes s.3.0 Statement of intent to reduce the use and/or creation of toxic substance (or reasons for not including one) Yes s.4.1 Objectives of the Plan Yes s.4.2 Description of each process that uses the toxic substance Yes s.5.1 description of how, when, where and why the substance is used or created Yes s records of identification and description of stages and processes of a facility's operation and a record containing process flow diagrams. Yes s Toxic substance accounting information Yes s.5.2 quantifications at process level for previous year Yes s record of methods and rationale for selecting each method used to track and quantify toxic substance Yes s Estimate of direct and indirect annual costs associated with the toxic substance Yes s.6.0, App B Options considered for Reduction Yes s.7.0 identification of toxic substance reduction options in each of seven toxic reduction categories stipulated in O.Reg.455/09 or explanation of why no option could be identified estimate of potential reductions in use, creation, contained in product, release (air, land and water), disposal, transfer of toxic substances achieved if option was implemented and the information used to develop the estimate identification of technically feasible options N/A s.7.3 analysis of economic feasibility of technically feasible options, including anticipated savings and payback period N/A s.7.4 For each option to be implemented a description of implementation steps and a timetable for implementation N/A N/A a summary of estimated toxics reduction in use, creation, released, disposed, transferred for recycling, and/or contained in product (as a percentage and unit of measurement) anticipated dates for achieving use and creation reductions N/A N/A OR If no options were implemented provide the rationale for this decision Yes s.8.0 Planner Recommendations and Rationale Yes s.9.0, App C Certifications by the highest ranking employee and the toxics reduction planner Yes s.11.0 Yes N/A N/A s.7.1 s.7.2 N/A VERSION 1.0 iv

131 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID Table of Contents 1.0 INTRODUCTION BASIC FACILITY INFORMATION PLANNER LICENSE NUMBER STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN Statement of Intent Objectives of the Plan TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2012 REPORTING YEAR Description of each Process that uses the Toxic Substance Description of How, When, Where and Why the Substance is Used or Created Records of Identification and Description of Stages and Processes of Facility Operation and Record Containing Process Flow Diagrams Toxic Substance Accounting Information Quantifications at Process Level for Previous Year Records of Methods and Rationale for Selecting each Method used to Track and Quantify the Toxic Substance ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE OPTIONS CONSIDERED FOR REDUCTION Identification of Toxic Substance Reduction Options in Each of Seven Toxic Substance Reduction Categories Estimates of Potential Reductions Associated with Each Identified Toxic Substance Reduction Option Identification of Technically Feasible Options Analysis of Economic Feasibility of Technically Feasible Options RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS PLANNER RECOMMENDATIONS AND RATIONALE PLAN SUMMARY CERTIFICATIONS... 8 Version 1.0 v

132 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID APPENDICES APPENDIX A Toxic Substance Quantification, Accounting and Reporting Information for the 2012 Reporting Year APPENDIX B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance APPENDIX C Planner Recommendations APPENDIX D Plan Summary Version 1.0 vi

133 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID 1.0 INTRODUCTION This Toxic Substance Reduction Plan (the Plan) was prepared in accordance with s.3 of the Toxics Reduction Act (TRA) and s.9 of Ontario Regulation (O. Reg.) 455/09 for the prescribed toxic substance referred to as Nitric Acid (the Toxic Substance) for the Richmont Mines Inc. (Richmont) Island Gold Mine Facility (the Facility). Guidance in the Ontario Ministry of the Environment (MOE) publication Toolkit for Toxic Substance Reduction Planning, version dated February 15, 2012 (the MOE Planning Toolkit) was followed, as appropriate. The TRA was passed in the Ontario Legislature in June The MOE has stated that the goal of the TRA is to promote reductions in the use and creation of prescribed toxic substances, inform Ontarians about toxic substances in their communities and to help ensure that Ontario is well positioned to compete in an increasingly green global economy. The TRA augments the traditional end of pipe pollution control approach to managing releases by focusing on reducing the use and creation of prescribed toxic substances. The TRA is intended so that regulated facilities give a consistent level of consideration to opportunities for reducing prescribed substances; however it does not restrict or require elimination of prescribed toxic substance. Under the TRA, regulated facilities are required to: perform quantification, accounting and reporting on the toxic substance use, creation, amount contained in product and release at the Facility on an annual basis; prepare Toxic Substance Reduction Plans in which it is documented, where feasible, how the use and creation of toxic substances might be reduced; have the Toxic Substance Reduction Plan certified by an MOE licensed Toxic Substance Reduction Planner (the Planner) as well as the Highest Ranking Employee (HRE) at the Facility; prepare Plan Summaries containing various components of the Toxic Substance Reduction Plans and make them available to the public; submit annual reports on progress made on the Plans; and update the Plans at least every five years. Unlike tracking, accounting, reporting and preparation of a Toxic Substance Reduction Plan which are all requirements; the implementation of any toxic substance reduction options identified in the Plan is not a requirement of the TRA or O.Reg.455/09. The Facility is captured by the requirements of the TRA pertaining to the Toxic Substances since the Facility meets the TRA s definition of target facilities with North American Industry Classification System codes commencing with the digits 212 (mining except oil and gas that processes minerals, but only if the mineral processing at the facility involves the use of chemicals to separate, refine, smelt or concentrate metallic or non-metallic minerals from an ore) and also triggered the National Pollutant Release Inventory (NPRI) reporting threshold for the Toxic Substance. As such, the Facility has completed Toxic Substance quantification, accounting and reporting requirements under the TRA for 2010, 2011 and 2012 reporting years in accordance with s.12 of O.Reg.455/09, and this Plan satisfies the Toxic Substance Reduction Plan and Plan Summary preparation requirements of the TRA and O.Reg.455/09. Version 1.0 1

134 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID 2.0 BASIC FACILITY INFORMATION The following table is adapted from Appendix 3 of the MOE Planning Toolkit and provides the applicable Basic Facility Information stipulated in section 18(2) of O.Reg.455/09. Mandatory Basic Facility Information Item Substance Name and Chemical Abstracts Service (CAS) Registry Number, if any NPRI and O.Reg.127/01 Identification Numbers The legal and trade names of the owner and the operator of the facility, the street address of the facility and the mailing address of the facility, if different The number of full time employee equivalents at the facility North American Industry Classification System (NAICS) codes and the six-digit NAICS Canada code Public contact Technical contact and person who is responsible for coordinating plan preparation The person who prepared the plan Highest Ranking employee at the facility who has management responsibilities relating to the facility and who is responsible for making certification The spatial coordinates of the facility expressed in Universal Transverse Mercator (UTM) within a North American Datum 83 (NAD83) datum Parent Company Information Details Nitric Acid (CAS number ) NPRI ID: O.Reg.127/01 ID: N/A Richmont Island Gold Mine Mines Richmont Inc. 15 Goudreau Road, Dubreuilville, ON P0S 1B Mining & Oil & Gas Extraction Metal Ore Mining Gold & Silver Ore Mining Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 Melanie Gauthier Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) Extension 2221 Russell Polack Toxic Substance Reduction Planner Golder Associates Ltd Lorne Street, Sudbury, ON P3C 4R9 (705) Jean Bastien Richmont Island Gold Mine 15 Goudreau Road, Dubreuilville, ON P0S 1B0 (705) UTM Zone E, N Mines Richmont Inc. 161, avenue Principale Rouyn-Noranda, QC J9X 4P6 (819) Version 1.0 2

135 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID 3.0 PLANNER LICENSE NUMBER As required by s.18(2) of O.Reg.455/09 (as amended by s. 9(2) of O.Reg.214/11), the Licensed Toxic Substance Reduction Planner responsible for providing Planner Recommendations on and certification of this Plan is as follows: Russell Polack Air Quality Specialist Golder Associates Ltd. Toxic Substance Reduction Planner License Number TSRP STATEMENT OF INTENT AND OBJECTIVES OF THE PLAN As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. This Plan outlines the Facility s position that no toxic substance reduction options can be identified for the Toxic Substance at this time. 4.1 Statement of Intent As required by s.4(1) of the TRA, a Plan must include either a statement of the Facility s intent to reduce the use and/or creation of the Toxic Substance at the Facility, or the reasons for not including this statement, as well as objectives of the Plan. A statement of the Facility s intent to reduce use of the Toxic Substance has not been included as a part of this Plan. The Toxic Substance is never created within the Facility s process and therefore no statement with respect to intent to reduce creation of the Toxic Substance is required. The Facility is of the opinion that it has previously optimized its use of the Toxic Substance to the greatest extent that can reasonably be expected at this time. It should be noted that the Facility currently complies with all environmental regulations that control the release and disposal of the Toxic Substance, and possesses all applicable environmental approvals. The MOE has stated that the TRA is not intended to focus on these end of pipe emissions, however, the fact that the Facility meets or exceeds the strict release limits imposed by these regulations, despite the relatively large amount of the Toxic Substance that is required to be used in order to operate the Facility, is a further indication of optimal use of the Toxic Substance at the Facility. 4.2 Objectives of the Plan The Objectives of the Plan are as follows: provide support for the Facility s position with respect to the Statement of Intent of this Plan; and Version 1.0 3

136 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID document how, by preparing this Plan, the Facility has fulfilled the applicable requirements under the TRA and O.Reg.455/09 with respect to the Toxic Substance. 5.0 TOXIC SUBSTANCE QUANTIFICATION, ACCOUNTING AND REPORTING INFORMATION FOR THE 2012 REPORTING YEAR As required by s.12 of O.Reg.455/09, the Facility has fulfilled its Toxic Substance Quantification, Accounting and Reporting (QAR) requirements for the Toxic Substances for all reporting years to date. The Toxic Substance QAR exercises were completed in accordance with subsections of s.12 of O.Reg.455/09 and consider guidance provided in the MOE publication entitled Toolkit for Toxic Substance Accounting, dated 2011 (PIBS 8498e). Per guidance, Toxic Substance QAR information for the 2012 reporting year was relied upon in the preparation of this Plan. The appropriate Toxic Substance QAR information for the 2012 reporting year was submitted by the Facility before the deadline of June 1, The 2012 Toxic Substance QAR information is provided in Appendix A. The following sections provide a description of how the Toxic Substance QAR exercise was completed and how each applicable item under s.12 of O.Reg.455/09 is addressed by these Toxic Substance QAR exercises. 5.1 Description of each Process that uses the Toxic Substance Description of How, When, Where and Why the Substance is Used or Created The Toxic Substance is introduced into the Acid Wash Solution Tank in the acid wash process of the Facility s processing plant. The intended function of the acid is to react with impurities and free up active sites on carbon granules, thereby washing activated carbon prior to carbon reactivation for reuse in the gold leaching process. Although it is recycled to the greatest extent possible, nitric acid is ultimately destroyed by neutralization in the Acid Wash Vessel. The Toxic Substance is never created at the Facility Records of Identification and Description of Stages and Processes of Facility Operation and Record Containing Process Flow Diagrams Per guidance provided in the Accounting Toolkit, Process Flow Diagram (PFDs) have been provided as part of the Toxic Substance QAR exercise to give a visual representation of the movement of the Toxic Substance through every stage of the process where it is present and to show the relationships between the processes. The PFD provides the appropriate level of detail to satisfy s.12 of O.Reg.455/09. It demonstrates in each stage where the Toxic Substance is present has been broken down into a sufficient number of individual processes to satisfy s.12(3) of O.Reg.455/09, and introduces Activity IDs for activities for which process-level quantifications for the Toxic Substances have been completed, including the following: the amount of the Toxic Substance that enters the process; and any NPRI-reportable releases of the Toxic Substance. Version 1.0 4

137 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID It should be noted that the Toxic Substance is not used in the Facility process and therefore no quantifications are required for an amount of Toxic Substance used. The descriptions provided on these PFD are detailed and reference each individual Activity ID. These activity IDs are subsequently used in the required Toxic Substance quantification and accounting. 5.2 Toxic Substance Accounting Information Quantifications at Process Level for Previous Year Toxic Substance quantifications are also provided in Appendix A. This information is provided on the Calculations, Input/Output Analysis and Summary page. Quantification is provided for each Activity ID identified in the PFD, along with the following: a description of the quantification method; a rationale for selecting each quantification method (see following section); data used to quantify the activity subject to each Activity ID; data quality for the quantification; and sample calculation. The Calculations, Input/Output Analysis and Summary page also provides an input/output analysis for each stage where the Toxic Substance is present as well as an input/output balance for entire Facility process. A description of why the sums of inputs and outputs are not equal is provided along with a comment regarding the acceptability of this input/output imbalance Records of Methods and Rationale for Selecting each Method used to Track and Quantify the Toxic Substance As required by s.12(6) of O.Reg.455/09, for each quantification method that was used to prepare process-level quantifications, a rationale for why the method was identified as the best available for the purpose of completing the exercise is provided. In the process of identifying best available methods, the Facility used judgement based on relevance and effort required to obtain information and feels that it has gone to reasonable efforts in identifying and applying the best available methods for quantifications and collecting the information necessitated by each quantification method. The Facility understands that the methods used to complete the 2012 Toxic Substance QAR exercise can only be changed under the circumstances stipulated in s.12(7) of O.Reg.455/09. At this time, the Facility does not intend to change the quantification methods that were used to complete the 2012 Toxic Substance QAR exercises for the purpose of completing Toxic Substance QAR exercises for subsequent years. Version 1.0 5

138 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID 6.0 ESTIMATE OF DIRECT AND INDIRECT ANNUAL COSTS ASSOCIATED WITH THE TOXIC SUBSTANCE As required by s.18(1) of O.Reg.455/09, direct and indirect costs have been estimated for the Toxic Substance. In preparing the cost estimates, several departments at the Facility were consulted. Cost items associated with the Toxic Substances were identified in various categories. The cost estimates are provided in Appendix B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance. Ontario Regulation 455/09 does not specify the level of detail to which a Facility must examine costs associated with a toxic substance, however the Facility feels that it has gone to reasonable lengths in its efforts to estimate the costs associated with the Toxic Substances. 7.0 OPTIONS CONSIDERED FOR REDUCTION Section 17 of O.Reg.455/09 outlines the requirements for identification of toxic substance reduction options and provides the seven categories of toxic substance reduction options under which options are to be identified as part of the Plan. 7.1 Identification of Toxic Substance Reduction Options in Each of Seven Toxic Substance Reduction Categories With the assistance of a licensed Toxic Substance Reduction Planner, Facility personnel have considered each of the seven categories for toxic substance reduction options. It is not necessarily a requirement under O.Reg.455/09 to provide toxic substance reduction options, however s.17(1)2 of O.Reg.455/09 states that the following must be provided in the event that an option for toxic substance reduction cannot be identified in any of the seven toxic substance reduction categories: 17(1)2. If an option cannot be identified for a category listed in paragraph 1, an explanation of why no option could be identified for the category The following statement satisfies s.17(1)2 of O.Reg.419/05 each of the seven toxic substance reduction categories for the Toxic Substance. For reasons explained in the Statement of Intent Section of this Plan, the Facility feels that it has previously optimized its control of the creation and subsequent release of the Toxic Substance to the greatest extent that can reasonably be expected and therefore no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. 7.2 Estimates of Potential Reductions Associated with Each Identified Toxic Substance Reduction Option No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be Version 1.0 6

139 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide estimates of potential reductions associated with identified toxic substance reduction options under s.17(1)3 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 7.3 Identification of Technically Feasible Options No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide a list of toxic substance reduction options that have been determined to be technically feasible under s.17(1)4 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 7.4 Analysis of Economic Feasibility of Technically Feasible Options No toxic substance reduction options have been identified under s.17(1)1 of O.Reg.455/09, however, an explanation of the Facility s rationale for the conclusion that no toxic substance reduction options can be identified in any category has been provided, thereby satisfying s.17(1)2. Therefore, the requirement to provide an analysis of economic feasibility for any toxic substance reduction options that have been determined to be technically feasible under s.17(1)5 of O.Reg.455/09 are not required to satisfy s.17 of O.Reg.455/09 for the purposes of this Plan. 8.0 RATIONALE FOR NOT IMPLEMENTING TOXIC SUBSTANCE REDUCTION OPTIONS As required by s.18(4) of O.Reg.455/09 (as amended by s.9(3) of O.Reg.214/11), a Plan must contain an explanation of why no toxic substance reduction options will be implemented. Facility personnel have considered each of the seven categories for toxic substance reduction options, and, in light of the information provided in the Statement of Intent section of this Plan, the Facility feels that no toxic substance reduction options can be identified in any of the seven toxic substance reduction categories. Therefore the rationale for not implementing toxic substance reduction options is that no toxic substance reduction options could be identified. 9.0 PLANNER RECOMMENDATIONS AND RATIONALE As required by s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), the Facility provided a draft copy of the Plan to a licensed Toxic Substance Reduction Planner for the purpose of obtaining recommendations with respect to the plan. It should be noted that implementation of Planner Recommendations is not a requirement of O.Reg.455/09 or the TRA. A memorandum addressing requirements pertaining to recommendations by a planner under s.18.2 of O.Reg.455/09 is provided in Appendix C Planner Recommendations and Rationale. Version 1.0 7

140 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID 10.0 PLAN SUMMARY As required by s.8 of the TRA, a Plan Summary prepared in accordance with s.23 of O.Reg.455/09 is included in Appendix D. Information contained in the Plan summary has been provided to the MOE through the Single Window reporting system. Furthermore the Plan Summary is available on the Facility s website and can be provided to a member of the public upon written request. The Facility is required to submit annual reports to the MOE on progress made on this Plan and update the Plan at least every five years CERTIFICATIONS Section 3(2) of the TRA allows for the preparation of a single document which contains more than one Plan (the Single Document), and s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) allow for the HRE and Planner respectively to sign certification statements which apply to all Plans contained within the Single Document prepared under s.3(2) of the TRA. The Phase II Plans for the Facility have been assembled using the Single Document format and therefore the Certification Statements which have been made under s.19(2) and s.19.1(4) of O.Reg.455/09 (as amended by s.11 of O.Reg.214/11) by the HRE and Planner respectively satisfy the Plan certification requirements of O.Reg.455/09 and the TRA for all Plans contained within this Single Document. The Certification Statements are attached at the front end of this Single Document. c:\users\rpolack\desktop\for home 28nov13\tra\rig\reporting\attachment 7 - nitric acid\ rig tra nitric acid 8dec13 rlp.docx Version 1.0 8

141 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID APPENDIX A Toxic Substance Quantification, Accounting and Reporting Information for the 2012 Reporting Year Version 1.0

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145 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID APPENDIX B Estimate of Direct and Indirect Annual Costs Associated with the Toxic Substance Version 1.0

146 Estimates of 2012 Direct and Indirect Baseline Costs Associated with the Toxic Substance S.18(1) of O.Reg.455/09 requires that direct and indirect costs be estimated for the Toxic Substance for which the Plan is being prepared. A Facility has the flexibility to determine how and to what level of detail to calculate direct and indirect costs. The MOE indicates that an understanding of direct and indirect costs associated with a prescribed toxic substance will assist the Facility in assessing the economic feasibility of identified toxic substance reduction options. The table below provides categories, descriptions and assoiciated costs for costs that may be associated with the Toxic substance. Information contained in the table below was provided by Facility personnel and represents an appropriate level of detail for this cost estimating exercise. Cost Associated with Cost Category Cost Item Description the Toxic Substance Raw Materials Purchase of Nitric Acid $19, Operation Costs PPE (Total Facility-wide cost of PPE divided by number of TRAreportable toxic substances, ie. $330, / 14) $23, Air & Water Emissions Control Emergency Planning $3, Total Cost $46,294.52

147 TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID APPENDIX C Planner Recommendations Version 1.0

148 DATE December 2013 PROJECT No TO Melanie Gauthier Richmont Island Gold Mine CC Sean Capstick FROM Russell Polack TOXIC SUBSTANCE REDUCTION PLANNER RECOMMENDATIONS ON THE DOCUMENT ENTITLED TOXIC SUBSTANCE REDUCTION PLAN NITRIC ACID Golder Associates Ltd. (Golder) was retained by Mines Richmont Inc. Island Gold Mine (the Facility) to provide various services pertaining to Phase II Toxic Substance Reduction Plan preparation under the Toxics Reduction Act (TRA), including Toxic Substance Reduction Planner recommendations (Planner Recommendations). As required by s.18.2 of Ontario Regulation (O.Reg.) 455/09 (as amended by s.10 of O.Reg.214/11), a facility is required to provide a draft copy of the Plan to a licensed Toxic Substance Reduction Planner (the Planner) for the purpose of obtaining recommendations with respect to the Plan. This technical memorandum fulfills the requirements of s.18.2 of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) for the draft document entitled Toxic Substance Reduction Plan Nitric Acid, Version 1.0 (the Plan) which has been prepared for the prescribed toxic substance referred to as Nitric Acid (the Toxic Substance). Planner Recommendation Requirements Under the Toxics Reduction Act and Ontario Regulation 455/09 Section 18.2(3) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) provides the areas of a given Plan in which Planner Recommendations are required to be documented (the Areas of Recommendation). As required by s.18.2(4) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), a Planner must also provide a rationale for each Planner Recommendation. Implementing Planner Recommendations (if any) is voluntary. As stated in s.18.2(2) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11), Planner Recommendations shall be provided for the purpose of improving all aspects of the Plan, including: the potential for reducing the use and creation of the toxic substance at the facility; and the business rationale for implementing the Plan. Section 18.2(5) of O.Reg.455/09 (as amended by s.10 of O.Reg.214/11) a Planner must provide a written explanation if the Planner is of the opinion that no recommendations are necessary with respect any of the Areas of Recommendation. Golder Associates Ltd Lorne Street, Sudbury, Ontario, Canada P3C 4R9 Tel: +1 (705) Fax: +1 (705) Golder Associates: Operations in Africa, Asia, Australasia, Europe, North America and South America Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.