Chapter 4 - Environmental, Health And Safety Management System

4.13.1 Purpose

The objectives of VBNC's Public Involvement Plan are to:

provide information to the public regarding the Project;

inform the community regarding Project design and activities;

identify the need for mitigation;

gain an understanding of public concerns;

develop two-way communication with nearby communities; and

assist in obtaining input to EH&S management decisions.

VBNC has undertaken an extensive communications and public involvement initiative to date (described in Chapter 5). VBNC is fully committed to continue this effort during the life of the Project. To this end, VBNC will continue using many of the following public involvement techniques:

mail-outs to households on the North Coast of Labrador;

videos on Project components;

communication sessions to explain the results of the EIS to a wide audience;

information sessions on specific subjects;

maintenance of VBNC public offices;

open houses;

workshops on Project development;

meetings with government officials and interest groups and other parties;

Figure 4.4 Inuktitut Place Names

Figure 4.5 Innu-aimun Place Names

presentations to interest groups and the public;

kitchen-table talks;

community forums;

site visits;

toll-free telephone lines;

conference and trade shows;

company newsletter;

annual environment reporting;

release of Project documents; and

media releases.

4.13.3 Implementation

VBNC will implement the Public Involvement Plan using proven techniques and appropriate measures as described in Chapter 5. Techniques will be selected that are appropriate for the specific involvement objectives. VBNC's Corporate Communications Department will coordinate these activities, drawing upon various specialists within the company as appropriate, for example construction and operation engineers and EH&S personnel.

VBNC will closely monitor the effectiveness of public involvement activities, the success of techniques and the effectiveness of communication achieved by various techniques.

4.14 Monitoring and Follow-up Plan

4.14.1 Purpose

This section addresses the requirements of Section 10 of the Final Guidelines regarding monitoring and follow-up.

The methods and approach to monitoring and follow-up are described in this section. Monitoring includes the specific programs developed by VBNC to comply with acts, regulations, permits, and corporate commitments. Monitoring can be further defined as those activities undertaken by the proponent to demonstrate that the Project operates within specific limits of environmental performance.

A follow-up program as defined in Canadian Environmental Assessment Act, means a program for (a) verifying the accuracy of the environmental assessment of a project and (b) determining the effectiveness of any measures taken to mitigate the adverse environmental effects of the project.

VBNC proposes to institute a follow-up program in cooperation with regulatory authorities and interested parties. VBNC recommends the follow-up program be conducted to determine that the:

predictions of the environmental assessment, with respect to the VECs examined, are valid and being met;

models used in the assessment process to predict potential effects are valid and the results are verified;

environment is being protected from any adverse effects of the Project; and

mitigative measures taken to protect the environment from the Project are effective.

The results of the follow-up program will be used to improve the understanding of environmental cause-and-effect relationships and to provide an early warning of undesirable change in the environment.

4.14.2 Content

4.14.2.1 Compliance Monitoring

This section describes the monitoring program developed by VBNC to meet regulatory and internal policies and standards.

Biophysical Monitoring

Compliance monitoring, to meet specific requirements under existing legislation for air quality and water quality, has been addressed in Appendix 4F and 4G. Compliance monitoring will be conducted for water quality at effluent discharge points which include Anaktalak Bay and Kangeklualuk Bay. Air quality compliance monitoring will include ambient and emission sampling for nitrogen oxides, total suspended particulates, and appropriate metals.

Socio-Economic Monitoring

Subject to proprietary information, socio-economic data relating to mine expenditures will be available to the appropriate agencies. Worker health and recruitment status will also be available. VBNC will assist government agencies by providing mine-related information. If socio-economic variables related to the IBAs are required, this information will be provided to the appropriate parties.

Compliance with Internal Policies and Standards

First priority, for employment will be given to residents located in communities that are near the Project site. Second priority will be given to Labradorian individuals with the right qualifications. Island of Newfoundland residents will receive third priority.

Hiring and training will be undertaken with consideration for Innu and Inuit peoples, residents in adjacent communities, and gender equity. Personnel will be qualified for the positions for which they are hired, for the purpose of safety and efficiency. Following that, the main principle governing hiring priorities is that of adjacency.

To monitor success in meeting these goals, VBNC is already tracking characteristics of the labour force and income levels by:

Innu and Inuit peoples;

gender;

geographic location (Labrador, Newfoundland, Canada); and

job category.

These employment priorities will be supported by training initiatives, including the Multi-Party Training Plan, which will facilitate Aboriginal peoples obtaining new jobs and filling vacancies that may be created through other mining developments in northern Labrador. The goal of this training program is to enhance the participation of Innu and Inuit peoples in these positions.

To monitor success in meeting training goals, the numbers of employees participating and success rates of VBNC training and orientation programs will be recorded in a manner similar to labour force data.

4.14.2.2 Follow-Up Program

The VBNC follow-up program will integrate monitoring results and evaluate the effectiveness of mitigation measures. Monitoring data will be subjected to analysis which will help VBNC determine if there are any undesirable environmental effects of Project activities. VBNC will then initiate investigative, preventive, or if warranted, corrective actions. These studies should have clear hypotheses, achievable objectives, and sound methodologies. Careful consideration should be given to the availability of previously collected data. Potential cumulative environmental effects will also be considered. The spatial and temporal boundaries of each study will be defined.

4.14.3 Implementation

4.14.3.1 Roles and Reporting

VBNC proposes to form environmental monitoring committees with LIA, the Innu Nation and other interested parties. The follow-up program will extend over the life of the Project. These committees would foster exchange of information and concerns regarding specific environmental issues relating to the Project. The committees may also provide an opportunity to integrate Aboriginal knowledge into the follow-up program.

Environmental monitoring committees would meet on a regular basis to:

review the follow-up program and provide input on its effectiveness and the need for any revisions;

receive monitoring reports, on a regular basis, for various aspects of the monitoring program;

determine the need for any corrective or mitigative measures for the Project, based on the monitoring reports and associated analyses;

discuss mutual issues and concerns; and

incorporate, where appropriate, Aboriginal knowledge in the monitoring program.

The results of the work of the committee will be reported in the VBNC Environmental Health and Safety Annual Report.

Monitoring of environmental effects of the Project on socioeconomic factors for management purposes other than those described above, are the responsibility of the relevant Aboriginal, provincial and/or federal governments. The reporting procedures and measures of the relevant departments and agencies have yet to be determined. VBNC is prepared to actively participate in such monitoring activities by providing additional data on Project activities and practices, as required and where available, to the appropriate authorities.

4.14.3.2 Funding

Follow-up program activities required for regulatory compliance would be funded by VBNC. Partnerships with other interested parties would be encouraged where there are areas of mutual benefit. VBNC, in cooperation with others, would consider joint funding of programs of special interest to VBNC. For example, INCO/VBNC have participated in programs investigating the environmental effects associated with acid rock drainage and the assessment of technologies to monitor potential mine related effects in the aquatic receiving environment (aquatic effects technology evaluation). VBNC has also jointly funded environmental studies with others on issues of mutual concern (e.g., ice characterization). In these cases, independent researchers have contributed to the value of the program.

4.14.3.3 Candidate Topics

The evaluation of environmental effects has followed a methodology based on the identification and scientific assessment of interactions between the Project and a set of Valued Environmental Components, which have been selected for consideration in this EIS (Chapter 6). The selected Valued Environmental Components encompass the potential environmental effects of the Project on physical and ecological receptors. Interactions between the Project and these Valued Environmental Components are described in detail in Chapters 8 to 24.

The VBNC follow-up program will monitor cause-and-effect relationships between the Project and Valued Environmental Components, in keeping with one or more of the following criteria:

the magnitude (i.e., major or moderate) of potential adverse environmental effects;

the significance (i.e., major or moderate) of these effects;

the level of confidence (i.e., high or moderate) with which predictions have been made;

the sustainability of the interaction between the Project and the Valued Environmental Component; and

whether the Valued Environmental Component is already the subject of a monitoring program for compliance purposes.

4.15 Auditing and Continuous Improvement Plan

4.15.1 Purpose

VBNC is committed to reviewing and continually improving its EH& S Management System, with the objective of improving overall EH& S performance. The EH& S Management System is seen as an organizing framework that needs to be continually monitored and periodically reviewed to provide direction for response to changing internal and external factors. The Auditing and Continual Improvement Plan will establish a program to review, assess and improve EH&S performance. The continual improvement model is described in Figure 4.2.

Objectives for auditing and continual improvement include:

to evaluate the conformance and effectiveness of procedures, guidelines and training in meeting with EH&S policies and performance objectives;

to ensure conformance with government legislation and management policies;

to evaluate performance objectives and targets;

to evaluate the ability of the internal management review process to sustain effectiveness of the EH&S Management System;

to optimize EH&S management/cost relationships;

to evaluate EH&S management programs;

to identify EH&S system weaknesses and areas for improvement;

to provide information to support appropriate changes and accelerate the process of continual improvement;

to promote understanding between parties, both internal and external; and

to continually improve EH&S performance.

4.15.2 Content

The Auditing and Continual Improvement Plan will provide mechanisms for checking performance and a corrective action such as:

monitoring and measurement;

non-conformance reporting ;

corrective and preventive action plans;

record keeping and documentation control; and

EH&S system audits.

Auditing is necessary to verify conformance of EH&S practices to the EH&S Management System. It will also enable VBNC to achieve its objective of continual improvement by providing the necessary feedback on the EH&S Management System to VBNC management.

4.15.3 Implementation

Successful EH&S audit programs require detailed and clear program objectives and expected outcomes with which to measure progress. There must be clear knowledge and identification of stakeholders to the program and a willingness to listen to, work with and accommodate their recommendations where appropriate and feasible (W. J. Middleton, INCO, 1995).

Auditing is an ongoing function. Both formal and informal audits will be undertaken. INCO will conduct the corporate EH&S audits.

Training, Awareness and Competence

The Auditing and Continual Improvement Plan will establish and maintain procedures to make employees at every level, contractors and, where appropriate, sub-contractors, aware of:

the importance of conformance with the EH&S Management Plan, including polices and procedures;

the significant environmental effects, actual or potential, of their work and the importance of improved personal performance;

their roles and responsibilities in achieving conformance with the EH&S Management System, including emergency preparedness and response requirements; and

the potential consequences of not following specific operating procedures.

Training, awareness and competence will be achieved through the Occupational Health and Safety Plan (Section 4.7), Human Resources Plan (Section 4.9), and the Education and Orientation Plan (Section 4.11).

Documentation

VBNC will establish and maintain procedures for controlling documents to enable:

documents to be located;

periodic review, revision and approval by authorized personnel;

current versions of relevant documents to be available;

removal of obsolete documents to protect against unintended use; and

identification of retention of obsolete documents being retained.

Procedures and responsibilities will be established under the Auditing and Continual Improvement Plan concerning the creation and modification of documents. Documents will be legible, dated, readily identifiable, maintained in an orderly manner, and retained for specific periods of time.

Operational Control

VBNC will continue to identify operations and activities which may result in significant EH&S effects, in keeping with EH&S policy, objectives and targets. These activities will be planned, including maintenance, to enable them to be carried out under specified conditions by:

establishing and maintaining the documented Emergency Response and Contingency Plan (Section 4.6);

stipulating standard operating procedures; and

communicating relevant procedures and requirements to appropriate personnel and contractors.

Emergency Preparedness and Response

Procedures to identify potential for and response to accidents and emergency situations, and preventing or mitigating potential EH&S effects that may be associated with them, will be established and maintained in the Auditing and Continual Improvement Plan. Specific procedures for response to accidents and emergencies are included in the Emergency Response and Contingency Plans (Section 4.6).

VBNC will review and revise, where necessary, its emergency preparedness and response procedures. Procedures will be tested periodically to determine their effectiveness and applicability, where practicable.

Records

The Auditing and Continual Improvement Plan will include procedures for the identification, maintenance and disposition of EH&S records, including training records and the results of audits and reviews. Records will be maintained, as required and appropriate, to demonstrate conformance to the EH&S Management System.

4.16 Specific Environmental Management Needs

Specific environmental design and management needs for each Valued Environmental Component have been identified in Chapters 8 through 24 (Volumes 3 and 4) of this EIS. Table 4.1 shows which of the EH&S Plans of this EH&S Management System will be implemented to meet these specific needs for each Valued Environmental Component. The Project phases where the various element Plans will be implemented to meet these needs are also provided.

Appendix 4H summarizes the specific environmental design and management needs for each Valued Environmental Component. For each specific environmental concern, the recommended actions are linked to the EH&S Plans under which they will be implemented. In this way, the extensive measures identified as environmental design and mitigation are organized into a comprehensive EH&S Management System. Each measure, if not already incorporated into the Project design as described in Chapter 3 of this EIS, will be incorporated into the appropriate EH&S Plan and at the appropriate time in the Project development. This approach is practical and reflects the dynamic, life-of-project horizon that is necessary to effectively meet the EH&S management needs of the Project.

4.17 References

Barnes, J.L., K. Pytyck, S.W. Speller, D.R. Maynard, M. Crowell and B. Thompson. 1996. Life-of-Project Environmental Management Strategy: Northumberland Strait Bridge Project. 49^th Canadian Geotechnical Conference of the Canadian Geotechnical Society, Volume 1, pp. 343-350, St. John's, NF.

CEAA (Canadian Environmental Assessment Agency). 1994. Responsible Authority's Guide. Hull, PQ.

CSA (Canadian Standards Association). 1991. Emergency Planning for Industry. CAN/CSA-Z731-M91. Rexdale, ON.

Middleton, W. J. 1995. The Evolution of INCO's Corporate Environmental, Health and Safety Audit Program. Sudbury, ON.

Strait Crossing Inc. 1993. Environmental Management Plan for the Northumberland Strait Crossing Project. Calgary, AB.

VBNC. 1997a. Environmental Protection Plan for Advanced Exploration Activities at Voisey's Bay - Advanced Exploration Activities, Abandonment/Rehabilitation - Voisey's Bay Nickel Company Limited, St. John's, NF.

VBNC. 1997b. Environmental, Health and Safety Guideline. Emergency Response Plan. Voisey's Bay Nickel Company Limited, St. John's, NF.

VBNC. 1997c. Oil Pollution Emergency Plan, Voisey's Bay Exploration Site, Labrador. Voisey's Bay Nickel Company Limited, St. John's, NF.

Appendix 4A

Aboriginal Policy

VBNC ABORIGINAL POLICY:
IMPACTS AND BENEFITS AGREEMENTS

Background

The Whitehorse Mining Initiative, which was adopted by representatives from the mining industry, government, the Aboriginal community, and the environmental community, acknowledged that a cooperative approach to development places responsibilities and obligations on all stakeholders, but that mutual advantages would result from lasting, positive relationships between mining companies and other stakeholders.

The Voisey's Bay area has been occupied by Aboriginal peoples of Labrador for centuries. The Inuit and Innu each have a society and culture based on strong ties to the land. The Innu Nation, on behalf of the Innu, and Labrador Inuit Association ("LIA"), on behalf of Inuit, are negotiating separate comprehensive land claims with the Government of Canada and the Government of Newfoundland and Labrador.

VBNC is negotiating an Impacts and Benefits Agreement ("IBA") with each of the Innu Nation and LIA. The company's intent is that the Voisey's Bay Mine/Mill Project ("the Project") be developed in a way that respects the rights and culture of both Innu and Inuit, provides socio-economic benefits to nearby communities and addresses potential environmental, economic and social impacts. Separate and parallel IBA negotiations are taking place on a confidential basis. These negotiations are not yet concluded. The following description outlines VBNC's current approach towards issues being addressed in these negotiations. Of course, positions on specific issues may be enhanced or otherwise modified through the negotiating process.

The Principles

VBNC Objectives
VBNC's overall objective in IBA negotiations is to establish a mutually beneficial and stable long-term relationship with both the Innu and Inuit of Labrador. Such a relationship, built around the jointly agreed objectives and commitments contained in the respective IBAs, should allow the Project to be developed in a responsible and timely fashion even in the circumstances of unsettled land claims. VBNC is also committed to addressing environmental impacts of the development, and to providing significant socio-economic benefits to both Aboriginal peoples. In return, VBNC is seeking to obtain the support of both the Innu and the Inuit communities for the Project.

VBNC Approach

Having examined other arrangements between resource companies and Aboriginal peoples, VBNC wants to establish a relationship with the Innu and Inuit based on mutual respect, cooperation, trust and good faith. This relationship would address interests of both Parties to each IBA through general commitments contained in the Agreement. We, therefore, believe that an IBA should provide for an on-going relationship within a framework of shared commitments. These shared and binding commitments should provide the tools for VBNC, the Innu Nation and LIA to work cooperatively to meet the mutual commitments and objectives set out in their respective IBAs. In the interest of a long-term successful relationship, VBNC cannot make commitments that cannot be met and will not take on responsibilities that are historically the responsibility of government - be they Aboriginal governments and agencies, or those of Newfoundland and Canada.
IBA Topics

VBNC believes that joint commitments on the following subjects will provide the basis for a mutually beneficial relationship between the company and the Innu Nation and between the company and LIA:

Education

Training

Employment

Workplace Conditions

Business Opportunities

Environmental Protection

Social and Cultural Protection

Use of Infrastructure and Facilities

Financial Issues

Implementation

Dispute Resolution

Information and Communications

The Commitments

To build a successful relationship, each Party to an IBA must share the responsibility for achieving the stated objectives of that agreement. VBNC is prepared to make the following commitments and to work with Aboriginal people in achieving them:

Education

VBNC is committed to supporting education and life-long learning in both the Innu and Inuit communities, so that Innu and Inuit will have greater opportunities to work in the mining industry and to contribute positively to community life. The kind of support envisaged would include sponsoring "stay-in-school" programs, career counselling, school competitions and achievement awards, cooperative education, as well as the establishment of a scholarship trust fund to be used for post-secondary education related to the mineral industry or other subject areas. These initiatives would be designed to benefit employees and the communities generally.

Training

VBNC is committed to providing training opportunities to both Innu and Inuit so that they have opportunities for employment on the Voisey's Bay Project, advance according to their abilities and aspirations and make a positive contribution to their communities. These training programs will relate directly to employment on the Project and will be an integral component of VBNC's overall human resources strategy.

Through the Multi-Party Training Plan (MPTP), a comprehensive pre-employment training strategy is being designed with input from the Innu Nation and LIA representatives to provide education, training and other support programs that respond to the unique needs of the Innu and Inuit of Labrador.

In addition to pre-employment training initiatives for Innu and Inuit, VBNC's Human Resources Strategy will establish comprehensive on-the-job training programs for Innu and Inuit employees. These programs will provide apprenticeship placements, apprenticeship block training programs, on-going skill development, cooperative employment and summer employment programs for students. VBNC will also make provisions for the training of Innu and Inuit employees as instructors so they can train other employees. The programs will all be designed to foster an attitude of life-long learning and provide opportunities for career advancement.

Employment

The joint goal of commitments in the area of employment is to maximize the involvement of qualified Aboriginal peoples in the Project's workforce. The education and training provisions of each IBA are an essential part of the strategy to achieve this objective. In addition, VBNC is prepared to establish employment objectives in consultation with the Innu Nation and LIA respectively. These objectives will be realistic estimates that will guide recruitment and hiring procedures. To make this process effective and to avoid overlap constructive three-way discussion between VBNC, LIA and the Innu Nation will be required to set quantifiable objectives. Further, Aboriginal Employment Coordinators will help support career development among Innu and Inuit employees and reduce barriers to employment and advancement of Innu and Inuit.

In addition, VBNC will notify its contractors that employment of Innu and Inuit will be a factor in evaluating all bids.

Workplace Conditions

The objective of provisions related to workplace conditions is to provide a safe, healthy workplace that is conducive to the effective and efficient functioning of the Project and respectful of the cultural diversity of VBNC's employees. A key initiative is to try to organize work schedules in such a way that Aboriginal employees can participate in the wage economy and still maintain some of their traditional activities on the land. This requires balancing the company's needs for a safe and efficient operation with the needs of its Innu and Inuit employees to spend time on the land. To this end, alternatives such as cultural leave provisions, special work rotations and job sharing may be considered.

VBNC is also committed to implementing a variety of measures designed to create a workplace that supports and protects Innu and Inuit society and culture. These measures include:

cooperation with community counselling services and other agencies to help employees and their families deal with permanent employment on the Project

facilitation of mentoring roles

implementation of cross-cultural training programs for all employees

provision of reasonably available country food

Business Opportunities

VBNC will implement measures to promote and assist the development of business skills in both Innu and Inuit businesses.

To help develop business capacity, VBNC will provide funds to each of the Innu Nation and LIA to establish revolving loan funds. VBNC will also contribute to a Business Centre for each by providing financial support while local business capacity is building and by providing expertise on a continuing basis.

To help promote Aboriginal businesses as suppliers and service providers to the Project, in each of the Innu and Inuit IBAs, business participation objectives will be established by VBNC after consultation with Innu Nation and LIA regarding existing business capability and VBNC needs. To help achieve these objectives a full range of tools may be used, including first right to negotiate contracts within certain agreed-upon categories; restricting certain tender calls to either Innu or Inuit businesses as appropriate; structuring tender calls to provide access to small businesses; reducing or waving tender deposits; offering letters of intent to assist in securing financing; advising contractors that preference will be given to bids that include Innu and Inuit involvement; providing timely notice on upcoming contracts; and using pre-qualification processes to promote competitiveness of bids from Innu and Inuit businesses.

For each agreement, a Business Development Advisory Committee will review and advise upon the effectiveness of measures designed to promote business, including the business participation objectives.

As in the case of employment objectives, effective three-way communication and cooperation between VBNC, the Innu Nation and LIA will be required in this area of business objectives.

Environmental Protection

VBNC is committed to sound environmental practices including enacting measures intended to protect the relationships of Innu and Inuit with the resources, land and sea during the Project.

To achieve this objective, VBNC has proposed to establish an Environment Committee with the Innu Nation and also one with LIA. These committees would allow for the active involvement of both the Innu and Inuit in environmental planning and for discussion regarding environmental standards and priorities.

VBNC will also consult with each of the Innu Nation and LIA when planning monitoring programs and mitigation measures. Close coordination and cooperation between the two Committees is very desirable and will be strived for.
Other commitments regarding environmental protection include:

funding for independent Aboriginal monitors in the initial years

Wildlife Harvesting Compensation Regimes

Social and Cultural Protection

VBNC is committed to protecting and supporting both the Innu and Inuit way of life, their respective societies and cultures in relation to the Project, and to minimizing any negative impacts of the Project.

Since both the Innu and Inuit cultures, like all cultures, are evolving, it may be difficult to determine the precise impact of the company's activities. In order to meet its commitment, VBNC will provide funding for separate Social and Cultural Protection Funds to be established by Innu Nation and LIA respectively, to protect their society and culture and alleviate impacts from the Project. This will allow Innu and Inuit to determine priority needs and design and implement solutions for their particular situation.
In addition to the Social & Cultural Protection trust funds, commitments contained under other subject headings, such as "Workplace Conditions" for example, have the capacity to contribute significantly to social and cultural protection.

Use of Infrastructure and Facilities

VBNC is committed to providing Aboriginal peoples with reasonable access to and use of infrastructure and facilities at the minesite, and to opportunities which may arise in relation to the infrastructure and facilities. Three-way communication and cooperation between VBNC, the Innu Nation and LIA is important in the effective implementation of these commitments.

Financial Provisions

VBNC is committed to negotiating a financial package which will include funding to support the commitments contained in the IBAs as well as for an ongoing financial participation in the project. This on-going financial participation regime may include fixed payments and a formula that will allow both Innu and Inuit to share in the risks and rewards of the Project. Programs which require financial support include:

Competitions, Prizes and Achievement Awards

Scholarship Trust Fund

Business Centre

Revolving Loan Fund

Business Development Advisory Committee

Environment Committee

Independent Environmental Monitors

Wildlife Harvesting Compensation Regime

VBNC will strive to negotiate a total financial package that is fair and equitable, taking into account all relevant factors.

Implementation

In order to provide the flexibility intended by this approach to IBAs, implementation of each IBA will be carried out by regular operating departments working with representatives from the respective Aboriginal peoples. In addition, a proactive implementation team, consisting of senior representatives, will be established for each agreement and will have the primary responsibility for the on-going relationship between VBNC and the Innu Nation or LIA as appropriate. Each team will prepare an implementation plan for the IBA and will monitor its execution.

Dispute Resolution

VBNC will give operating departments the flexibility to settle disputes at the operations level. However, if resolution is not possible at this level, disputes will be referred to the implementation team which will have the authority to use a variety of measures including mediation. If an issue is not resolved at this stage, the Presidents of VBNC and the Innu Nation and/or LIA, as the case may be, will consider the dispute. At this point, VBNC proposes that unresolved disputes be sent to binding arbitration, unless either party chooses to litigate the issues. Generally, it is the objective of the dispute resolution mechanism to settle disputes at the earliest possible opportunity without involving third-parties.

Information and Communications

VBNC is committed to making sure its employees and contractors are aware of the provisions of the IBAs and that they adhere to them. VBNC will also work with the Innu Nation and LIA to inform Innu and Inuit about the provisions of their respective IBA and ensure that there is close on-going communication between the parties. Information will be provided in Innu-aimun and Inuktitut, as appropriate.

Appendix 4B

Legislation, Permit, Approvals, and Authorizations

Legislation That May Be Applicable to the Voisey's Bay Mine/Mill Project

Legislation	Agency	Project Activity
Federal
Canadian Environmental Assessment Act and Regulations	Canadian Environmental Assessment Agency and Responsible Authority	Mine/Mill Development
Canadian Environmental Protection Act	Marine Environment Division Environmental Protection Service Environment Canada	Hazardous Wastes, POL Storage
Canadian Environmental Protection Act - Part VI (Ocean Dumping Regulations, 1988)	Marine Environment Division Environmental Protection Service Environment Canada	Port Development
Fisheries Act Metal Mining Liquid Effluent Regulations	Department of Fisheries and Oceans	Works or Undertakings Affecting Fish Habitat
Navigable Waters Protection Act Navigable Waters Works Regulations	Canadian Coast Guard Department of Fisheries and Oceans	Works or Construction Activity in Navigable Waters
Canada Shipping Act Aids to Navigation Protection Regulations Air Pollution Regulations Anchorage Regulations Boat and Fire Drill Regulations Charts and Nautical Publications Regulations Classed Ship Inspection Regulations Collision Regulations Crew Accommodation Regulations Dangerous Chemicals and Noxious Liquid Substances Regulations Dangerous Bulk Materials Regulations Dangerous Goods Shipping Regulations Eastern Canada Vessel Traffic Services Zone Regulations Emergency Position Indicating Buoy Regulations Fire Detection and Extinguishing Equipment Regulations Garbage Pollution Prevention Regulations Home-trade, Inland and Minor Waters Voyages Regulations Hull Construction Regulations Hull Inspection Regulations Life Saving Equipment Regulations Marine Machinery Regulations Navigating Appliances and Equipment Regulations Non-Pleasure Craft Sewage Pollution Prevention Regulations Oil Pollution Prevention Regulations Pollutant Discharge Reporting Regulation Pollutant Substances Regulations Publication of Standards Regulations Safe Manning Regulations Safe Working Practices Regulations Ship Radio Inspection Fees Regulations Ship Station Radio Regulations Ship Station Technical Regulations Shipping Casualties Reporting Regulations Ships' Crews Food and Catering Regulations Ships' Deck Watch Regulations Steering Appliances and Equipment Regulations Tonnage Regulations Vessel Traffic Services Zones Regulations VHF Radiotelephone Practices and Procedures Regulations	Canadian Coast Guard (DFO), Department of Fisheries and Oceans and Transport Canada Canadian Coast Guard (DFO), Department of Fisheries and Oceans and Transport Canada	Shipping Worker Health and Safety Shipping Worker Health and Safety
Aeronautics Act Canadian Aviation Regulations	Transport Canada	Airstrip Operations
Transportation of Dangerous Goods Act, 1992 and Regulations	Transport Canada	Transporting and Handling Dangerous Goods
Explosives Act Explosives Regulations Ammonium Nitrate and Fuel Order	Natural Resources Canada	Mine/Mill Development Mining Operations
Transportation Act Ammonium Nitrate Storage Facilities Regulations	Canadian Transport Commission	Storage of Ammonium Nitrate at Site
Transportation Act Flammable Liquids Bulk Storage Regulations	Canadian Transport Commission	Storage of Flammable Liquids at Site
National Building Code of Canada	Canadian Commission on Building and Fire Codes	Facilities
National Fire Code of Canada	Canadian Commission on Building and Fire Codes	Facilities
National Plumbing Code of Canada	Canadian Commission on Building and Fire Codes	Facilities
Radiocommunication Act	Industry Canada	Communication
Provincial
Environmental Assessment Act Environmental Assessment Regulations	Department of Environment and Labour	Mine/Mill Development
Transportation of Dangerous Goods Act and Regulations	Department of Works, Services and	Transporting or Handling
Environment Act	Department of Environment and Labour	Altering a Waterbody, Using Surface, Ground and Shore Waters
Air Pollution Control Regulations		Construction and Operation and Facilities
Environmental Control (Water and Sewage) Regulations		Construction and Operation and Facilities
Gasoline Volatility Control Regulations		Transport and Handling of Hazardous Goods
Storage and Handling of Gasoline and Associated Products Regulations	Department of Environment and Labour	Transport and Handling of Hazardous Goods
Ozone Depleting Substance and Replacement Regulations		Facilities
Fire Prevention Act, 1991 Fire Prevention Fire Extinguisher and Fixed Fire Extinguishing Systems Regulations Fire Prevention Flammable and Combustible Liquids Regulations Fire Prevention Regulations Fire Prevention Smoke and Fire Alarm Regulations	Department of Government Services and Lands	Facilities
Food and Drug Act Food Premises Regulations	Department of Health	Worker Health and Safety
Forestry Act	Department of Forest Resources and Agrifoods	Mine/Mill Development
Cutting of Timber Regulations		Mine/Mill Development
Forest Fire Offence and Penalty Regulations		Accidental Event
Forest Fire Regulations		Accidental Event
Forest Fires Liability and Compensation Regulations		Accidental Event
Historic Resources Act Archaeological Investigation Permit Regulations	Department of Tourism, Culture and Recreation	Archaeological Sites
Labour Relations Act Labour Relations Regulations	Department of Environment and Labour	Worker Health and Safety
Labour Standards Act Labour Standards Regulations	Department of Environment and Labour	Worker Health and Safety
Lands Act	Lands Branch Department of Government Services and Lands	Altering a Waterbody, Using Surface, Ground and Shore Waters
Mineral Act Mineral Regulations	Department of Mines and Energy	Mine Development Exploration
Mines Act Mines Safety of Workers Regulations	Department of Mines and Energy	Mine Development Worker Safety
Motorized Snow Vehicles and All-Terrain Vehicles Act Motorized Snow Vehicles and All-Terrain Vehicles Regulations	Department of Government Services and Lands	Worker Safety
Occupational Health and Safety Act Occupational Health and Safety First Aid Regulations Occupational Health and Safety Regulations Workplace Hazardous Materials Information System (WHMIS) Regulations	Department of Environment & Labour	Mine/Mill Construction and Operation Worker Health and Safety
Public Health Act Sanitation Regulations	Department of Health	Facilities, Worker Health and Safety
Public Safety Act Boiler, Pressure Vessel and Compressed Gas Regulations Electrical Regulations	Department of Government Services and Lands	Facilities, and Worker Health and Safety
Quarry Materials Act Quarry Materials Regulations	Department of Mines and Energy	Quarrying
Waste Material Disposal Act	Department of Government Services and Lands	Waste Disposal
Wild Life Act Wild Life Regulations	Wildlife Division Department of Forest Resources and Agrifoods	Nuisance Animal Control
Workers' Compensation Act Workers' Compensation Regulations	Department of Environment and Labour	Worker Health and Safety
Exploration permit		Department of Mines & Energy
Works, Services and Transportation Act	Department of Works, Services and Transportation	Worker Health and Safety

Required Permits/Approvals/Authorizations

Permit, Approval or Authorization	Agency
Federal
Release under the CEAA	Department of Fisheries and Oceans
Transportation of Dangerous Goods	Transport Canada
Registration or Certification of Airstrip	Airport Group, Transport Canada
Authorization for Works or Undertakings Affecting Fish Habitat	Department of Fisheries and Oceans
Permit for Construction Within Navigable Waters	Canadian Coast Guard, DFO
Application for a Water Lease	Transport Canada
Ocean Disposal Permit	Environmental Protection Service Environment Canada
Permit to Store, Handle and Transport Dangerous Goods	Environment Canada
Notification to Handle or Transport Dangerous Goods	Transport Canada
Explosives Purchase and Possession Permit	Natural Resources Canada
Explosives Transportation Permit	Natural Resources Canada
Temporary Magazine Licence	Natural Resources Canada
Magazine Licence	Natural Resources Canada
Approval under the National Building Code of Canada	Engineering Services Department of Government Services and Lands
Approval under the National Fire Code of Canada	Engineering Services Department of Government Services and Lands
Radio Station Licence	Communications Industry Canada
Provincial
Release from the environmental assessment process	Environmental Assessment Division Department of Environment and Labour
Permit to Install or Alter a Pressure Piping System	Engineering Services Department of Government Services and Lands
Certificate of Plant Registration for Power, Heating, Refrigeration, Compressed Gas or Combined Plant	Engineering Services Department of Government Services and Lands
Building Accessibility	Engineering Services/Operations Division Department of Government Services and Lands
Permit to Occupy Crown Land	Customer Services Department of Government Services and Lands
Authorization to Control Nuisance Animals	Wildlife Division Department of Forest Resources and Agrifoods
Permit to Install, Alter, Repair or Extend Any Electrical Equipment or Inspection of Work	Operations Division Department of Government Services and Lands
Electrical Maintenance Permit	Mechanical/Building Inspections Department of Government Services and Lands
Approval is Required for Drawings and Specifications before Installation of or Major Alterations to an Elevator	Engineering Services Department of Government Services and Lands
Certificate of Inspection for Elevators	Mechanical/Building Inspections Department of Government Services and Lands
Food Establishment Licence - Temporary Facility	Operations Division Department of Government Services and Lands
Food Establishment Licence	Operations Division Department of Government Services and Lands
Certificate of Approval for Storage and Handling of Gasoline and Associated Products	Operations Division Department of Government Services and Lands
Permit for Flammable and Combustible Liquid Storage and Dispensing (above or below ground) and for Bulk storage (above ground only)	Engineering Services Department of Government Services and Lands
Approval for Fuel Storage and Handling - Temporary Storage Remote Locations	Operations Division Department of Government Services and Lands
Certificate of Approval for a Commercial Septic System >4,500 L/day in an Unserviced Area and Not Covered under a Municipality	Engineering Services Department of Government Services and Lands
Certificate of Approval Any Water Supply System >4,500 L/day	Engineering Services Department of Government Services and Lands
Certificate of Approval for a Waste Management System	Operations Division Department of Government Services and Lands
Archaeological Research Permit	Cultural Heritage Division Department of Tourism, Culture and Recreation
Blaster's Safety Certificate	Workplace Safety Programs Division Department of Environment and Labour
Certificate of Approval for Construction (Site Drainage)	Water Resources Division Department of Environment and Labour
Certificate of Approval for Culvert Installation	Water Resources Division Department of Environment and Labour
Certificate of Approval for Dams and Appurtenant Structures	Water Resources Division Department of Environment and Labour
Certificate of Approval for any Industrial Processing Works	Industrial Environmental Engineering Division Department of Environment and Labour
Permit to Burn	Forest Fire Protection Department of Forest Resources and Agrifoods
Permit to Cut Crown Timber	Newfoundland Forest Service Department of Forest Resources and Agrifoods
Operating Permit	Newfoundland Forest Service Department of Forest Resources and Agrifoods
Quarry Development Permit	Mineral Lands Division Department of Mines and Energy
Certificate of Environmental Approval for Water and Sewer Works	Environmental Management Division Department of Environment and Labour
Certificate of Environmental Approval to Alter a Body of Water	Water Resources Division Department of Environment and Labour
Certificate of Environmental Approval for Water Course Crossings	Water Resources Division Department of Environment and Labour
Water Use Authorization	Water Resources Division Department of Environment and Labour
Registration/Exemption with the Workers Compensation Commission	Assessment Department Workers Compensation Commission
Letter of Approval to Occupy	Operations Division Engineering Services Mechanical/Building Inspections Department of Government Services and Lands
Municipal
Approval for Waste Disposal	Town/Community Council

Appendix 4C

Exploration EH&S Documentation

Environmental Protection Plan (EPP)

VBNC has developed and is implementing a comprehensive EPP to help ensure a high level of environmental protection throughout its work areas and activities associated with the continued exploration at Voisey's Bay. The purpose of an EPP is to:

ensure that commitments to reduce environmental effects will be met;

document environmental concerns and appropriate protection measures;

provide concise and clear instructions to Project personnel regarding procedures for protecting the environment;

provide a reference document for personnel when planning and/or conducting specific activities;

provide a training aid during implementation efforts; and

provide a reference to applicable legislative requirements.

The EPP has been designed to be updated as the level of activity changes. As well, EPPs will be prepared for all activities of the project. The current EPP was revised in April, 1997.

Health and Safety Manual

This manual provides guidelines and standards to recognize occupational health hazards, evaluate their significance, determine a means of detection and measurement, and recommend control measures. It outlines the organization, responsibilities and job task procedures.

Oil Pollution Emergency Plan (OPEP)

The OPEP has been prepared as part of VBNC's commitment towards the safety and well being of its employees, the community and the environment. It provides guidance to personnel in responding to an oil pollution accident. The three primary functions of the OPEP are to:

Define appropriate actions in responding to specific incidents;

Provide comprehensive lists of those agencies or personnel with which VBNC may need to communicate; and

Define the content of pollution incident reports.

The OPEP was revised and implemented in April, 1997.

Emergency Response Plan

The ERP identifies the actions and procedures required to minimize and control releases to the environment during possible unplanned events. VBNC maintains procedures identifying the potential for and response to accidents and emergencies as well as means of preventing and mitigating environmental impacts in the event of an unplanned release. Where practicable, this includes periodic testing of these emergency procedures to assess the adequacy of the procedures and to provide training for the emergency response teams. The current ERP was revised in August, 1997.

Rehabilitation Guidelines

This document provides guidelines to rehabilitate areas impacted by construction. It provides the overall guidelines and principles related to the decommissioning of specific facilities. Together with the EPP, this plan forms an integral part of the overall environmental management planning approach of VBNC.

Appendix 4D

Project Safety Hazards

Project Safety Hazards

Climate

Winter temperatures in the Project area drop below -40°C. Coupled with strong winds, these extreme temperatures pose a major safety challenge for personnel. Proper winter clothing and gear that maintain a comfortable body temperature and shield against wind exposure are required from approximately the beginning of October to mid-May. In addition, severe windstorms and snowfalls can create occasional white-out conditions, which can last from several hours to several days. White-out conditions can reduce visibility to 1 m. Detailed procedures and training will be in place to ensure safety of personnel during extreme, white-out conditions.

Because of the risks of personnel becoming injured, lost, or stranded in these white-outs, frostbite and hypothermia are potential safety hazards. Proper precautions must be taken. Frostbite and hypothermia result from chilling by cold wind and air temperatures, cold water, associated physical exertion, and inadequate clothing. Hypothermia results in lowering of the internal body-core temperature. Frostbite can lead to damaged tissues, loss of extremities and infection.

Specific rules and procedures will be enforced at the Project site, including the requirement that employees wear winter gear (snow parkas, pants, hard-toe snowboots) and travel with emergency packs while in vehicles. Additional measures will include training on the prevention, symptoms, and treatment of frostbite and hypothermia. Special training and procedures will be initiated to protect the safety of personnel during extreme white-out conditions.

Wildlife

Black bears, polar bears, wolves, and foxes are among the wildlife that can pose a potential threat to unprotected and unaware field workers and camp residents. All employees will be trained on how to respond to wildlife encounters and the appropriate measures for avoiding attacks.

Communications

The primary communications link to St. John's and other major centres will be via microwave tower system. If technical problems arise in severe weather, a backup communications system using contracted satellite service and radio will be available for sending communication transmissions from the mine site to receiving stations outside the camps.

VHF (FM) radios, mounted in vehicles and equipment, and hand-held radio units for field personnel and supervisors will be used for local communications throughout the mine site and surrounding areas. Appropriate personnel will be trained in the proper use of this equipment. Communications between the mine site and aircraft will be through pre-determined VHF channels established by trained and licensed personnel.

Transportation

Aircraft

Charter aircraft will be used to transport personnel to and from the Project site. Operators will be selected based on availability of required aircraft types and qualified, competent crews.

Airstrip and aircraft safety and operation procedures will be based on Transport Canada regulations. Manifests will account for all passengers travelling by air before each departure.

Employees transported in and working around helicopters will be instructed on the hazards posed by helicopter operations, as well as proper signalling and communication techniques.

Vehicles

A seat belt policy will be enforced at the Project site. The policy regarding seat belts will be discussed with all employees, contractors, and visitors at the safety orientation.

Given the extreme climatic and ground conditions, injuries resulting from vehicular accidents are potentially serious and/or life threatening. Additional preventive measures will be taken to address these site-specific concerns, especially for vehicle operation on ice. Light duty vehicles and mobile equipment training, inspections, and proper operating procedures will be clearly outlined.

Ships

The transportation system will be designed and managed to ensure the safety of workers. Risks will be managed through proper design, compliance with standards, a proactive safety management system, continuous risk assessment, and implementing measures that can be justified as reasonable and practicable. All shipping-related activities will be conducted in accordance with all applicable legislation.

Vessel communications and navigation systems will comply with all applicable regulations. Advanced marine navigation and communications equipment will include the latest in Electronic Chart and Display Information Systems (ECDIS).

Special provisions will be made to provide communications with local communities and other users of fast ice. VBNC will work to develop communications protocols and provision of services to achieve a high level of effectiveness.

Notification systems will include a number of alternative ways to receive real time notices of vessel's impending arrival and actual progress through the ice. Route patrols, in contact with project dispatch will report on condition of the track, status of ice bridges and other precautionary measures. This information will be provided in a timely and efficient manner to stakeholders.

Open Pit Mining

Pit Slope Failure

Minor rock slippages will be contained by safety berms established in pit slopes at 20 m intervals. These berms will require periodic cleaning to clear fallen debris or rock from blasting operations. Although detailed geotechnical studies and design will reduce the chance of instability, the risk of major failure cannot be dismissed. Pit slope deterioration is generally evident in advance of failure so that risk to personnel is low and sufficient time is available for corrective measures to be taken. Ongoing comprehensive slope monitoring will be an integral part of the operations criteria in order to predict the occurrence of a major pit slope failure during mining of the open pit. Pit slopes will be designed to reduce failures.

Fire

The potential for an uncontrolled fire in the pit is limited, given the open operating conditions. Fire, should it occur, would most probably involve a piece of mobile equipment or an electrical substation. Large mobile mine equipment will be equipped with an on-board engine fire suppression systems and fire extinguishers. In the event of a fire, workers will initiate the emergency response plan. The emergency response fire-fighting team will be contacted by radio and will, upon arrival, assume fire-fighting duties with appropriate equipment.

Blasting

The primary blasting agents will be bulk ammonium nitrate/fuel oil and amonium nitrate based emulsions. The rules for safe use, handling and storage, which are stipulated for mining operations in the Newfoundland and Labrador Mines Safety of Workers Regulations, will be followed.
The primary potential hazard arising from open pit blasting is damage by flyrock. The anticipated zone of flyrock dispersion will be clearly defined prior to each blast, and all personnel and equipment will be moved a safe distance from the area.

Underground Mining

Ventilation

Underground ventilation will be provided by main and auxiliary fans and ducts for fresh air intakes. The ventilation system will also remove air containing contaminants generated by equipment exhaust emissions, and dust from drilling and blasting operations. The design, installation and operation of ventilation systems will conform with the Newfoundland and Labrador Mines Safety of Workers Regulations.

Failure of one or all main fans, or major short-circuiting of fresh or exhaust air, may result in unacceptably high concentrations of air contaminants from engine exhaust and airborne dust. All the main fans will be continuously monitored. In the case of mechanical or electrical failure, an alarm system will be triggered, which will alert mine management personnel of the failure in order that appropriate actions can be initiated immediately. Preventive maintenance will ensure that such failures are rare. An adequate spare parts inventory will be kept on site to facilitate repairs in the event of a major breakdown.

Any short-circuiting of exhaust air into the fresh air streams will contaminate the air supply. A higher air pressure will be maintained in the fresh air supply areas and ducts than in the exhaust air areas and ducts. This will prevent any release from the exhaust side to the fresh air side. Regular monitoring of all areas will provide early detection of short-circuiting. If short-circuiting is detected, the ventilation system will be repaired immediately.

In addition to the main ventilation system, auxiliary ventilation will supply adequate air flows to areas of the mine that are off the main circuit. Operating procedures for auxiliary ventilation will be established. Employees will not be permitted to begin working in areas before an adequate ventilation loop has been established.

Routine and frequent monitoring of air flows and air contaminant levels is critical in detecting system malfunction or poor air quality. In the event that the ventilation system proves inadequate or performs incorrectly, operations will be completely or partially suspended in the affected area until an adequate solution is implemented.
Following restoration of ventilation and following after blasting operations, work in the affected section of the underground mine will be allowed to resume only after an adequate time has passed to allow underground air quality to return to normal operating quality.

Falls of Ground

Ground support design and the installation of a combination of rock bolts, and other ground support systems will limit the hazard of falls of ground. Ground support standards and procedures will be established for the underground mines.

In the unlikely event that a fall of ground should occur, the access ramps, the production/service shaft, and the ventilation raise will provide escape routes, thus reducing the potential for entrapment. The Mine Rescue Team will be trained to assist in freeing trapped personnel and providing emergency medical treatment until the injured can be treated at the on-site facilities or medically evacuated.
Fire Underground

Mobile and electrical equipment pose a potential fire hazard. On-board fire suppression systems on mobile equipment and the availability of fire extinguishing equipment will reduce the risk of fire. However, the smoke and gases resulting from an underground fire can be a serious hazard to worker safety.

In the event of a mine fire, the fire warning system will be activated. Underground personnel will retreat to a self-contained refuge station to await further instructions or rescue.

Regular drills of mine rescue teams, evacuation techniques, and use of self rescue apparatus will ensure that correct and effective procedures are followed in the event of an underground fire.

Estimating water inflows into underground mines involves hydrogeological analysis and application of engineering judgement and experience. Actual water inflow volumes will be assessed to determine the adequacy of the pumping system, which will be designed with surplus pumping capacity. If inflows exceed the designed surplus pumping capacity, it will be necessary to either seal the inflow using grouting techniques, or allow partial flooding of the mine until additional pumping capacity is installed.

While sudden, unexpected and uncontrollable water flows are extremely unlikely, emergency planning will include contingencies for situations such as a large volume in-rush or mechanical and/or electrical failure of the pumping systems. Personnel will evacuate the mine well in advance of water levels rising to dangerous levels.

Loss of Power to Pumps and Fans

In the event of a general power failure, the underground work will cease until such time as work can proceed safely. Once power is re-established, it will be supplied on a priority basis to the pumps and fans underground. In the case of partial power failure or limited power availability at the mine site, pumps will be started first. Starting fans will have a second priority and production equipment will have the lowest priority.

Common to all industrial activities, slips, trips, and falls are major safety hazards. Given the icy and slippery ground conditions on the surface during the winter, employees will be reminded to take special care regarding footing. Safety instructions and training will emphasize these hazards.

Fall protection, including the use of safety harnesses, will be provided for work at heights. Safe working procedures will be in place for all work at heights, on ladders, on scaffolding, and while ascending and descending mobile equipment and plant steps.

Manual Handling

Manual handling of materials increases the potential for back injuries and muscle strain. Lifting, especially when done alone and improperly, may result in injuries that accrue lost work days and require physician consultation, therapy, and use of medications. Lifting and back protection programs will be incorporated into employee training.

Drowning

Drowning is a potential hazard to anyone travelling or working on open water or frozen lakes and rivers. Accidental immersion in cold water can quickly precipitate the onset of hypothermia or drowning. Ice monitoring will be performed to assess ice thickness and ensure safe conditions.

Treatment of hypothermia, cold water survival techniques, and drown-proofing, as well as the provision and use of personal flotation devices, will be fundamental components of the safety program to protect workers, contractors, and visitors from drowning.

Diesel Emissions, Exhaust Particulates, and Gases

All work areas will be properly ventilated. Potential occupational exposure to diesel exhaust air contaminants may occur and in underground mining operations and during maintenance of vehicles in enclosed buildings. Air monitoring and engineering controls, personal protective equipment, and administrative controls will reduce occupational exposures.

Occupational exposures underground will depend greatly on the amount of ventilation, quality of air, exhaust controls on equipment, equipment maintenance, and fuel quality. Efforts will be taken in all these areas to determine the mix of controls that will be most effective in maintaining exposures below the OELs.

Confined Space

Confined space entry requires a signed work permit and prior authorization. Work entry procedures will require that site preparation, ventilation requirements, air contaminant testing, standby worker presence, emergency rescue equipment, and all safety procedures are reviewed and discussed with the employee before work begins. Self-contained breathing apparatus (SCBA's) will be available if needed for confined space entry. Workers will be alerted to the availability and locations of SCBA's. Workers who are declared medically fit to use SCBA's by a physician will be trained on the use of SCBA's.

Air Quality

Indoor air quality is an important issue, particularly at the accommodations complex, maintenance shops, and offices. In all cases, establishing acceptable indoor air quality is critical. This is especially important given the extreme climatic conditions and close living and working quarters at the Project site.

Smoking will be permitted only in designated areas, with separate ventilation, that are not normally used by non-smokers. Other measures to ensure good air quality will include effective ventilation and heating systems, maintenance and cleaning procedures, and control of noxious cleaning and chemical products.

Appendix 4E

Permit Protocol Status

S A M P L E

VOISEY'S BAY NICKEL COMPANY LIMITED
PERMIT PROTOCOL STATUS
FEBRUARY 1 - 28, 1997

File No. 53-106

PERMITS OBTAINED DURING THE MONTH OF FEBRUARY

Exploration Approval for First Quarter Winter Drill Program from the Dept. of Mines and Energy. Issued to VBNC on February 17, 1997.

Approval to Dispose of One Sling Load of Garbage per Week at the Nain Disposal Area. Issued to VBNC by the Town of Nain on January 27, 1997.

APPLICATIONS UNDER REVIEW

Licence for Temporary Camps at Voisey's Bay and Man-o-war, Kiglapait Camps. Submitted to the Dept. of Government Services and Lands, Crown Lands on February 4, 1997 by VBNC.

Commercial Cutting Permit Submitted to the Dept. of Forest Resources and Agrifoods on March 10, 1997 by VBNC.

ANTICIPATED APPROVALS

Radio Station Licences from Industry Canada.

Exploration Approval for Geotechnical Investigation for Proposed Mill Site from the Dept. of Mines and Energy.

Appendix 4F

Air Quality Management

Air Quality

The purpose of the Air Quality Management Strategy is to control air emissions and to ensure that they satisfy regulatory and/or permit requirements. This strategy involves plans to assess, reduce and control gaseous and particulate emissions.

Reduction/Prevention Strategies

The main Project activities that will affect air quality include diesel engine use and mining, processing, and transport of ore/concentrate. Potential air quality related effects result from particulate and gaseous emissions, as well as from fugitive dust. The identified control measures include the following:

compliance with all applicable regulations;

use of exhaust gas heat recovery systems in the power generation units to best utilize the fuel consumed;

use of low-sulphur fuels;

preventative maintenance and efficient equipment to achieve optimum performance and to reduce emissions; and

appropriate design to provide adequate air dispersion.

The identified control measures for ore/concentrate handling including the following:

passage of off-gas from each kiln through a wet scrubber for dust recovery;

appropriate control methods to reduce fugitive dust such as road watering,
vehicle speed regulation and optimizastion vehicle size to reduce number of trips;

use of fabric filter dust collectors at both the ore processing and the port site;

covered vehicles for hauling concentrate;

covered conveyor belts for ore and concentrate with dust collection;

covered buildings for transferring material from trucks to process equipment; and

prompt reclamation of disturbed areas.

Workplace Air Quality Control Measures

Workplace air quality control measures will include the following:

provision of adequate ventilation for all work places;

use of respirable protection measures where applicable;

engineering controls to reduce workplace exposure; and

use of climate controlled vehicles.

Air emissions are regulated by the Province of Newfoundland and Labrador in accordance with the Air Pollution Control Regulations under the Environment Act (1996). A list of criteria, objectives, and limits applying to air quality is provided in Chapter 8 (Table 8.1).
BR> Monitoring

During operation, VBNC will conduct emission and ambient air monitoring for nitrogen oxides (NO_x), total suspended particulate (TSP), and appropriate metals including airborne nickel-containing aerosols. The program will be subject to review and approval by NDOEL. Results will be reported to NDOEL as required by permits.
Ambient air quality monitoring will occur at various site locations, including along access roads, and near crushers, diesel power generators, boiler stacks and other air emission sources. Air quality originating from open pit and underground work areas (upcast raises) will be monitored during the operations phase of the Project.
Any observed exceedance of air quality standards will be considered an incident. If, upon examination, there is reason to believe that the incident is due to Project activities, and may be repeated, then a response plan will be initiated. The response plan will link the monitoring results to operating procedures and identify any refinements of mitigation measures that may be required.

The principal strategies to mitigate potential air quality changes following construction include:

modification of dust collection systems;

increase or modifications of dust suppression procedures as required for underground and surface activities;

modification of wet scrubbers as necessary to maintain efficient dust recovery during concentrate dewatering.

Appendix 4G

Water Quality Management

Water Quality

During construction, the potential Project and aquatic environment interactions will be associated with stream crossings, mine site construction, dam and road construction, discharge pipelines, sewage effluent, and the construction of port site. Once in operation the Project will interact with the aquatic environment as a result of water consumption (process and potable) water diversions, tailings, and mineralized mine rock storage, and treated water discharges. The location and identification of watersheds potentially affected by project activities are described in Chapters 3 and 10

The principal objectives for the water management strategy are:

comply with regulatory requirements;

provide sufficient water resources to allow for smooth and uninterrupted operation of the Project;

apply the principle of pollution prevention to the design and operation of site facilities;

recycle process water to reduce both extraction requirements as well as treated water discharge;

provide treatment/settlement capability for all planned discharges, with sufficient capacity to handle possible upset conditions/high flow events;

collect and treat, if required, all water that comes in contact with operations;

reduce the number of discharge points from the operations; and

select discharge points that reduce the effects of water quality and quantity on the receiving environment.

Construction

During construction water management measures including temporary sediment and erosion control facilities such as sedimentation ponds, site drainage ditches and diversion structures/channels will be among the first facilities to be constructed. Construction methods for preventing discharge and environmental effects are described in Chapter 3.

Open Pit Operation

The principal objectives for water management with respect to the Open Pit are:

intercept and direct to either the Surge Pond or South Sedimentation Pond;

collect and treat all Open Pit water in the Plant Site Water Treatment Plant prior to discharge at Anaktalak Bay; and

monitor groundwater entering the Open Pit. Should groundwater quality be effected then it will be pumped and treated at the Plant Site Water Treatment Plant prior to discharge at Anaktalak Bay.

Mill Site Operation

Runoff from the South Overburden Storage, East Mine Rock Storage and mill operations area represents potential sources of surface water contamination and will therefore require containment and management. The following specific water management objectives have been identified:

intercept and redirect clean surface water away from the storage areas and mill back to its natural course;

direct all surface water collected in the mine/mill area to the Plant Site Sedimentation Pond;

provide sediment control for the South Overburden Storage and haul roads; and

all water used in operations either reclaimed within the mill or treated and discharged to Anaktalak Bay.

The sub-catchment to the east of the East Mine Rock Storage will be diverted to control runoff away from the South Sedimentation Pond. A diversion dam will be constructed to divert runoff to the east.

The South Sedimentation Pond and the Plant Site Sedimentation Pond will be designed to adhere to the following criteria:

sufficient capacity to accommodate the spring runoff from the upstream catchment area;

sufficient emergency spillway capacity to pass 100-year return period peak flow; and

adequate freeboard of above the maximum water level.

The South Sedimentation Pond will be constructed using a perimeter earth dam at the base of the slope south of the open pit. The pond will be constructed with a suitable low permeability material to reduce seepage.

Headwater Pond Operation

During Start-up and Open Pit mining, Headwater Pond will serve as a disposal area for mineralized mine rock and tailings. A reclaim line will be installed for the purposes of reclaiming water to the mill. Excess water will be treated at the Plant Site Water Treatment Plant prior to discharge to Anaktalak Bay.

Specific objectives for the management of Headwater Pond include:

provide for the long-term submergence of mineralized mine rock and tailings;

provide storage and treatment of discharge to comply with applicable regulations;

emergency overflow from Headwater Pond to be directed east towards Throat Bay away from Reid Brook; and

construction of perimeter dams to include a grout blanket for seepage control.

North Tailings Basin

Specific water management objectives for North Tailings Basin include:

reduce clean surface water runoff entering basin;

reduce the effect on the existing hydrologic regime;

permanently submerge deposited tailings;

allow for the storage of all water entering the basin. If required, water will be treated for pH adjustment and metal reduction prior to discharge;

accommodate annual runoff and tailings discharges;

maintain water levels and deposit tailings to avoid exposed beach formation along the shores of the tailings basin; and

allow for settlement of tailings fines prior to decant of the supernatant for reclaim or effluent discharge.

The west sub-watershed and south sub-watershed will be diverted away from the North Tailings Basin. This will reduce the amount of water entering the tailings area. The south sub-watershed will be diverted along the southwestern shore of polishing pond and will drain to the watercourse below Dam N2. The west sub-watershed will be diverted north of North Tailings Basin.

Under existing conditions, outflow from the east end of the basin discharges to both the south and the northeast. The basin will be designed to discharge only to the south. The purpose of Dam N3 is therefore to berm the low point at the northeast basin perimeter. The primary purpose of Dam N4 and Dam N5 is to attenuate and direct flows from their respective upstream drainage areas into a diversion channel or pipe by-passing North Tailings Basin. Dam N6 is located at a low point in North Tailings Basin perimeter and prevents surface water discharge from the basin into the adjacent watershed. Treated water from North Tailings Basin will be discharged to Kangeklualuk Bay via a pipeline and diffuser. The accumulation of runoff, process water and tailings during the winter months when the facilities are not being decanted is an important component of the operating range.

Port Site

The principal objectives for water quality management are:

divert natural surface runoff from the perimeter of the Port Site to two sedimentation ponds; and

maintain acceptable marine water quality as a result of Plant Site Water Treatment Plant discharge at Anaktalak Bay.

Monitoring

Water quality is regulated under provincial and federal regulations and permits. For any undertaking which has the potential to affect water quality through the discharge of treated or untreated effluents, NDOEL may require that all discharges comply with criteria set out in the Environmental Control (Water and Sewage) Regulations (1980). NDOEL may specify additional criteria as conditions of the Operating Permit. Schedule A of the Regulations applies to discharge of sewage into a body of water. Schedule B of the Regulations applies to sewage or effluent discharge. Water use is regulated by permit under NDOEL for activities within 15 m of a water body related to water withdrawals, intake structures, placement of dams, culverts, waste water disposal, and others. All permitted project discharges will be subject to these regulations.

Monitoring for water quality is to take place at all discharge points as designated by the federal and provincial regulations and at frequencies, and for the required parameters as laid out in these regulations and the Operating Permits. Samples will be analyzed utilizing both on-site facilities and off-site laboratories. Drinking water supplies at the Project site will come from groundwater sources and will be selected to satisfy the Guidelines for Canadian Drinking Water (Health and Welfare Canada 1993). Sufficient analysis are to be performed on site to allow for a quick response to effluent quality changes.

Federal and provincial regulations specify the monitoring and reporting frequencies for a wide range of analyzes in effluent water. Reporting procedures are also outlined in the applicable legislation.
The main discharges to be monitored for water quality compliance are:

marine discharge to Anaktalak Bay; and

marine discharge to Kangeklualuk Bay.

Following treatment, these flows will discharge, into marine waters and will be subject to MMLER and the Environmental Control (Water and Sewage) Regulations.

Samples of effluent from the point of discharge will be taken for analysis ("end of pipe" samples). Parameters to be measured in undiluted discharge, under both regulations, include chemical and physical parameters and nutrients.

Discharge from the sewage treatment plant is subject to monitoring under provincial Environmental Control (Water and Sewage) Regulations (1980) enforced by NDOEL. Parameters to be measured include chemical and physical parameters plus nutrients. NDOEL may specify additional criteria as conditions under the Operating Permit.

Ambient environmental monitoring will include the following sampling locations:

control or background locations to monitor natural variability;

downstream of environmental effluent discharge points in Anaktalak Bay and Kangeklualuk Bay. These locations will be monitored to confirm model predictions; and

downstream of containment structures to assess containment performance (e.g., Dams H1 & H2).

An important aspect of the ambient environmental monitoring for water quality is focusing on the quality of the receiving waters subjected to discharge of seepage or decant from the North Tailings Basin and Headwater Pond. The long term condition of these receiving waters has been predicted using models. Monitoring during the operations phase of the mine, in particular the seepage from Headwater Pond after the termination of the open pit mining, as well as during the decommissioning phase, will allow for verification of the modeling results. This will ensure that appropriate mitigative actions are taken in a timely manner that provides full protection to these watersheds after decommissioning is complete (post-decommissioning).

The monitoring program involves analyzing a comprehensive suite of metals as well as sulphate, other anions, conductivity and pH from locations close to the dams, at intermediate and coastal ponds. Sulphate is considered a key parameter of the monitoring program, allowing early detection of potential effects upon the receiving watersheds. In addition, bio-monitoring will be conducted to evaluate the potential effects of the receiving water on target species of fish and biota present in these watersheds.

The monitoring program will commence as soon as the placement of tailings and mineralized mine rock commences in Headwater Pond, and will include seasonal effects, particularly those periods of low flow that affect receiving water quality.

VBNC has developed corrective strategies for post construction should monitoring determine unacceptable changes in water quality. These strategies deal primarily with dam seepage performance and effluent quality and include:

collection and pump back of seepage at dam locations;

diffusion barrier construction to isolate tailings in Headwater Pond from pond water to mitigate downstream water quality effects; and

modification of a treatment plant (process effluent or sewage treatment effluent) to maintain acceptable discharge water quality.

Appendix 4H

Specific Environmental Management Needs

The following tables have been prepared for illustrative purposes and provide an outline of the features and mitigation measures discussed in greater detail elsewhere in this EIS. Table 4.H.1 describes, for atmospheric environment, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be addressed through a combination of Project design features and environmental protection procedures. Monitoring will provide an important feedback loop in EH&S decision-making.

Table 4.H.1: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Atmospheric Environment

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Air Quality
Project Design Features	extensive baseline studies and modelling completed to identify and evaluate atmospheric conditions use of fabric filter dust collectors at strategic locations in the milling process use of scrubbers to remove dust from the off-gas of rotary kilns closed conveyors and transfer points generator stack heights that maintain acceptable dispersion of emitted contaminants focus on efficient power generation to reduce emissions
Environmental Protection Plan	air quality management strategies dust suppression procedures use of low sulphur fuels
Reclamation Plan	progressive re-vegetation and surface stabilization to reduce wind erosion
Education and Orientation Plan	personnel EH&S briefing
Monitoring and Follow-up	air quality monitoring ambient air monitoring stack emissions monitoring equipment exhaust measurements
Audit and Continual Improvement Plan	audit implementation of procedures and policies development of corrective action plans audit review and continual improvement procedures

Table 4.H.2 describes, for ice, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include those that can be primarily addressed through environmental protection planning procedures in consultation with LIA and Innu Nation.

Table 4.H.2: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Ice

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Physical Effects During Early and Mid-winter	Physical Effects During Break-up	Oil and Concentrate Spills Affecting the Ice Environment
Project Design Features	extensive surveys to identify and evaluate ice conditions and freezing trends use of vessels with ice-breaking capabilities		modelling of spill events
Environmental Protection Plan	marine vessel traffic management procedures marine communication systems ice management procedures winter shipping not to begin until ice is at least 20 cm thick ship route will be maintained , as much as possible, in the centre of channels lower winter shipping speed	marine communication systems	marine vessel traffic management procedures fuel management procedures oil pollution emergency response procedures
Emergency Response and Contingency Plans	personnel EH&S briefing	personnel EH&S briefing	oil pollution emergency response procedures
Education and Orientation Plan			shoreline cleanup and assessment training (SCAT) ship spill procedures awareness training
Aboriginal Involvement Plan	discussions with LIA and Innu Nation on shipping	discussions with LIA and Innu Nation on termination date of winter shipping
Monitoring and Follow-up	surface patrol to monitor hazard along un-frozen track	surface patrol to monitor hazard along un-frozen track
Audit and Continual Improvement Plan	audit implementation of procedures and policies development of corrective action plans audit review and continual improvement procedures	audit implementation of procedures and policies development of corrective action plans audit review and continual improvement procedures	audit implementation of procedures and training development of corrective action plans audit review and continual improvement procedures

Table 4.H.3 describes, for water, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be addressed primarily through a combination of Project design features and environmental protection planning procedures.

Table 4.H.3 Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Water

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Water Quality	Accidental Events (fuel/oil spills, fire)
Project Design Features	construction of a pond water reclaim pipeline to recycle water from the tailings and mineralized mine rock facilities hydrogeology of tailings basins construction of freshwater diversions at the North Tailings Basin to reduce runoff water into tailings basin extensive water surveys of freshwater and marine environments selection of tailings/mine rock sites to minimize dam construction and surface water diversions drawdown volume limit for Camp Pond construction of zoned earth embankment dams	oil storage facilities have containment berms fire fighting equipment on site
Environmental Protection Plan	excess tailings pond water treated and discharged to marine environment identification of mineralized rock procedures water management strategies erosion and sediment control procedures sewage disposal procedures minimum alteration of surface and groundwater patterns and flows reduce or avoid instream activity	fuel management procedures hazardous materials management procedures
Emergency Response and Contingency Plans		oil pollution emergency response procedures specific material handling procedures fire fighting response procedures
Reclamation Plan	prevent metal migration from tailings porewater to pond water return of water courses evaluation of open pit water discharge
Education and Orientation Plan	personnel EH&S briefing	shoreline cleanup and assessment training (SCAT)
Occupational Health and Safety Plan	travelling procedures	fire fighting, prevention and control procedures training
Monitoring and Follow-up	monitoring of dams for seepage potable water monitoring receiving water quality monitoring	monitoring spill remediation efforts
Audit and Continual Improvement Plan	audit implementation of plans, policies and training development of corrective action plans audit review and continual improvement procedures

Table 4.H 4 describes, for freshwater fish and habitat, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be best addressed through a combination of Project design features and environmental protection planning procedures. Monitoring and a habitat compensation plan will be negotiated with DFO.

Table 4.H.4: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Freshwater Fish and Habitat

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Harmful Alteration, Disruption or Destruction (HADD) of Fish Habitat	Fish Mortality, Sub-lethal and Chronic Effects on Fish	Depletion of Fish Stocks
Project Design Features	extensive surveys to identify and evaluate fish and fish habitat compliance with legislation (MMLER) and HADD consolidation of Project features to minimize HADD (e.g. combined mine rock/tailings in Headwater Pond) diversion of potentially contaminated effluent discharges away from Reid Brook watershed reduction of effluent discharges to freshwater design of diversion channels to control erosion design of stream crossing to reduce habitat loss treatment of effluents selection of airstrip location away from Reid Brook minimal alteration of surface water and groundwater flows all dams and dykes to meet design criteria for the Canadian Dam Safety Association (CDSA) guidelines	compliance with legislation (MMLER) and HADD diversion of potentially contaminated effluent discharges away from Reid Brook watershed reduction of effluent discharges to freshwater sedimentation ponds to control total suspended solids (TSS) design of diversion channels to control erosion use of siltation screens treatment of effluents minimal alteration of surface water and groundwater flows all dams and dykes to meet design criteria for the Canadian Dam Safety Association (CDSA) guidelines	water intakes to include fish guards design of diversion channels to facilitate fish passage design of stream crossings to facilitate fish passage fish recovery and release procedures fire fighting equipment on site
Environmental Protection Plan	restricted work procedures during sensitive periods for fish compliance with legislation and government policies effluent treatment procedures minimal alteration of surface water and groundwater flows	compliance with legislation and government policies sediment control procedures hazardous materials management procedures procedures to prevent loss of fish resulting from stream diversions	No hunting and fishing policy Restricted work procedures during sensitive periods for fish Procedures to prevent loss of fish resulting from stream diversions culvert installation procedures

(Cont'd)

Table 4.H.4 (Continuted): Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Freshwater Fish and Habitat

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Harmful Alteration, Disruption or Destruction (HADD) of Fish Habitat	Fish Mortality, Sub-lethal and Chronic Effects on Fish	Depletion of Fish Stocks
	procedures to prevent loss of fish resulting from stream diversions culvert installation procedures guidelines for buffer zones erosion prevention procedures dust suppression on roads and in open pit stream crossing guidelines blasting procedures fuel management procedures hazardous materials management procedures stop work and restricted work procedures	culvert installation procedures dust suppression on roads and in open pit
Emergency Response and Contingency Plans	oil pollution emergency response procedures fire response procedures	oil pollution emergency response procedures fire response procedures
Occupational Health and Safety Plan	personnel fire fighting equipment on site fire prevention, control and fighting training safety procedures for all work on and around water (including fuel handling)	personnel fire fighting equipment on site fire prevention, control and fighting training safety procedures for all work on and around water (including fuel handling)	fire fighting equipment on site safety procedures for all work on and around water (including fuel handling)
Aboriginal Involvement Plan	discussion with LIA and Innu Nation on HADD		harvesting fish from Headwater Pond and North Tailings Basin for local use or other alternatives
Reclamation Plan	re-slope and re-vegetate for erosion control restore natural drainage and stream channels where feasible and where it will benefit fish and fish habitat allow and encourage re-establishment of fish and fish habitat in disrupted areas during decommissioning	re-slope and re-vegetate for erosion control restore natural drainage and stream channels where feasible and where it will benefit fish and fish habitat
Monitoring and Follow-up	water quality monitoring habitat compensation plan	water quality monitoring environmental monitoring
Audit and Continual Improvement Plan	audit of implementation of procedures, policies, guidelines and training development of corrective action plans audit review and continual improvement procedures	audit of implementation of procedures, policies and training development of corrective action plans audit review and continual improvement procedures

Table 4.H.5 describes, for marine fish and fish habitat, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be addressed primarily through a combination of Project design features and environmental protection planning procedures.

Table 4.H.5: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Marine Fish and Fish Habitat

	EH&S CONCERNS
Design/EH&S Plans to be Implemented		Fish Mortality, Sub-lethal and Chronic Effects on Fish	Harmful Alteration, Disruption or Destruction (HADD) of Fish Habitat
Project Design Features		extensive surveys to identify and evaluate marine fish resources compliance with legislation (MMLER) closed loading system to eliminate dust release settling pond design to ensure sufficient effluent residence time oil storage facilities have containment berms	compliance with legislation (MMLER) and HADD treatment of effluent
Environmental Protection Plan		discharge programs for vessels water management strategies air quality management strategies procedures for dust suppression fuel management procedures hazardous materials management procedures marine vessel traffic management procedures	marine construction activities timed to avoid sensitive biological periods procedures for blasting in the marine environment procedures for marine construction effluent treatment procedures fuel management procedures hazardous materials management procedures
Emergency Response and Contingency Plans		oil pollution emergency response procedures	oil pollution emergency response procedures
Education and Orientation Plan		shoreline cleanup and assessment training (SCAT) personnel EH&S briefing	shoreline cleanup and assessment training (SCAT) personnel EH&S briefing
Monitoring and Follow-up		water quality monitoring air quality monitoring	water quality monitoring air quality monitoring
Audit and Continual Improvement Plan		audit implementation of strategies, procedures and training development of corrective action plans audit review and continual improvement procedures	audit implementation of strategies, procedures and training development of corrective action plans audit review and continual improvement procedures

Table 4.H.6 describes, for marine mammals, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues such as release of contaminants that can be addressed through Project design features, and habitat disturbances and encounters with marine traffic that are best addressed by environmental protection planning procedures.

Table 4.H.6: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Marine Mammals

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Habitat Disturbance/Collisions with Marine Traffic	Release of Contaminants (effluent release, concentrate dust, fuel/oil spill)
Project Design Features	extensive surveys to identify and evaluate marine mammal resources in VBNC claim block	operations effluent will pass through diffusers to maximize initial dilution controlled release of freshwater closed loading system to eliminate dust release settling pond design to ensure sufficient effluent residence time oil storage facilities have containment berms use of double-hulled tankers for shipping no shipping of fuel in winter
Environmental Protection Plan	marine vessel traffic management procedures all vessels will travel within designated shipping route winter vessel speeds limited to 7-10 knots when possible procedures for blasting in the marine environment procedures for marine construction marine mammal survey prior to blasting at port site	water management strategies water quality monitoring procedures air quality management strategies dust suppression procedures fuels management procedures hazardous materials management procedures
Emergency Response and Contingency Plans		oil pollution emergency response procedures
Education and Orientation Plan	personnel EH&S briefing	shoreline cleanup and assessment training (SCAT) personnel EH&S briefing
Aboriginal Involvement Plan	consultation with LIA and Innu Nation on marine mammals management procedures	consultation with LIA and Innu Nation on oil spill response procedures
Monitoring and Follow-up		water quality monitoring air quality monitoring
Audit and Continual Improvement Plan	audit implementation of procedures, policies and training development of corrective action plans audit review and continual improvement procedures	audit implementation of procedures, policies and training development of corrective action plans audit review and continual improvement procedures

Table 4.H 7 describes, for plant communities, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S plans. The principal EH&S concerns include issues that can be addressed through a combination of Project design features, environmental protection planning procedures, and emergency response and contingency plans.

Table: 4.H.7: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Plant Communities

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Fire	Disturbance of Sensitive Land Types	Contaminant Uptake
Project Design Features	research into ecological land classifications and vegetation surveys in the VBNC claim block fire breaks along roads around facility	identification and inventory of sensitive land types	use of scrubbers for dust control use of low sulphur fuel use of fabric filter dust collectors at mill and port sites
Environmental Protection Plan	fuel management procedures hazardous materials management procedures	vegetation clearing procedures grubbing and disposal of organic debris procedures traffic management procedures (ATVs and vehicles)	dust suppression procedures equipment maintenance procedures
Emergency Response and Contingency Plans	fire fighting response procedures fire fighting equipment on site
Occupational Health and Safety Plan	fire fighting, prevention and control procedures training
Reclamation Plan		reclamation of disturbed sites development of test plots to evaluate suitability of indigenous species for re-vegetation
Education and Orientation Plan	fire fighting, prevention and control procedures training	avoidance of sensitive habitat training
Aboriginal Involvement Plan		discussions with LIA and Innu Nation on reclamation of disturbed sites
Monitoring and Follow-up	fire hazard monitoring		air quality monitoring
Audit and Continual improvement Plan	audit of implementation and training procedures development of corrective action plans audit review and continual improvement procedures	audit of implementation procedures development of corrective action plans audit review and continual improvement procedures

Table 4.H 8 describes, for waterfowl and seabirds, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be best addressed through the development of environmental protection planning procedures

Table 4.H.8: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Waterfowl and Seabirds

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Disturbance of Sensitive Habitat	Human Encounters	Oil Spills in the Marine or Freshwater Environment	Water Quality
Project Design Features	extensive surveys to identify and evaluate sensitive habitat in the VBNC claim block		oil storage facilities have containment berms use of double-hulled tankers for shipping no shipping of fuel in winter	construction of a pond water reclaim pipeline to recycle water from the tailings and mine rock facilities construction of freshwater diversions at the North Tailings Basin to reduce runoff water into tailings basin selection of tailings/mine rock sites to minimize dam construction and surface water diversions
Environmental Protection Plan	buffer zone guidelines noise control procedures vehicle and ATV traffic management procedures	no feeding, hunting or harassment policy traffic management procedures	fuel management procedures marine vessel traffic management procedures	reduce or avoid instream activity minimum alteration of surface and groundwater patterns and flows sewage disposal procedures erosion and sediment control procedures fuel management procedures hazardous materials management procedures dust suppression in open pit and on roads
Emergency Response and Contingency Plans			oil pollution emergency response procedures	emergency response procedures
Monitoring and Follow-up				water quality monitoring
Education and Orientation Plan		personnel EH&S briefing wildlife encounters response training		shoreline cleanup and assessment training (SCAT) personnel EH&S briefing
Aboriginal Involvement Plan	discussions with elders and hunters on management of waterfowl	discussions with LIA and Innu Nation on waterfowl and seabird management procedures
Audit and Continual Improvement Plan	development of corrective action plans audit review and continual improvement procedures	development of corrective action plans audit review and continual improvement procedures	development of corrective action plans audit review and continual improvement procedures

Table 4.H.9 describes, for caribou, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be best addressed through the development of environmental protection planning procedures.

Table 4.H.9: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Caribou

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Helicopter and Other Noise Disturbances	Vehicle Collisions and Encounters with Humans	Disturbance to Sensitive Habitat
Project Design Features			extensive surveys to identify and inventory caribou travel routes and migration patterns road grading to facilitate caribou movements
Environmental Protection Plan	air and vehicle traffic management procedures noise control procedures blasting procedures	traffic management procedures no hunting and fishing policy	stop work or restricted work procedures
Emergency Response and Contingency Plan	wildlife encounters procedures	wildlife encounters procedures	wildlife encounters procedures
Occupational Health and Safety Plan	wildlife encounters procedures	wildlife encounters procedures
Education and Orientation Plan	personnel EH&S briefing wildlife encounters response training	personnel EH&S briefing wildlife encounters response training	personnel EH&S briefing
Monitoring and Follow-Up		documentation of human/vehicle/caribou encounters	review caribou movements
Audit and Continual Improvement Plan	development of corrective action plans audit review and continual improvement procedures	development of corrective action plans audit review and continual improvement procedures	development of corrective action plans audit review and continual improvement procedures

Table 4.H.10 describes, for black bear, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be best addressed through the development of environmental protection planning procedures.

Table 4.H.10: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Black Bear

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Attraction to Camp	Encounters with Humans and Vehicles	Disturbance of Sensitive Habitat
Project Design Features	fencing accommodation, work and storage areas, if required		extensive surveys and radio-telemetry monitoring of black bears inventory and protection of occupied dens
Environmental Protection Plan	food and waste management procedures	ATV use procedures avoidance of occupied den procedures no feeding or harassment policy no pets on site policy	ATV use procedures blasting procedures avoidance of occupied dens
Emergency Response and Contingency Plans	wildlife encounters procedures	wildlife encounter procedures
Occupational Health and Safety Plan	wildlife encounters procedures	wildlife encounters procedures
Education and Orientation Plan	personnel EH&S briefing wildlife encounters procedures	personnel EH&S briefing wildlife encounters procedures	personnel EH&S briefing
Aboriginal Involvement Plan		discussion with elders on bear management
Monitoring and Follow-up	documentation of all human/bear encounters	monitoring den use documentation of all human/vehicle/bear encounters	monitoring den use
Audit and Continual Improvement Plan		audit implementation of procedures, policies and training development of corrective action plans audit review and continual improvement procedures	audit implementation of habitat protection procedures development of corrective action plans audit review and continual improvement procedures

Table 4.H.11 describes ,for species of special conservation status, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be best addressed through the development of environmental protection planning procedures.

Table 4.H.11: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Species of Special Conservation Status

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Habitat Disturbance	Human Encounters/Disturbance	Oil Spills in the Marine Environment
Project Design Features	extensive surveys to identify and evaluate species of special conservation status		oil storage facilities have containment berms use of double-hulled tankers for shipping no shipping of fuel in winter
Environmental Protection Plan	reduction of in-stream activity buffer zone guidelines noise control procedures blasting procedures	vehicle use procedures pre-blasting surveys no feeding, hunting or harassment policy	marine vessel traffic management procedures fuel management procedures
Emergency Response and Contingency Plans			oil pollution emergency response procedures
Education and Orientation Plan	personnel EH&S briefing habitat avoidance training	personnel EH&S briefing wildlife encounters response training habitat avoidance training	personnel EH&S briefing shoreline cleanup and assessment training (SCAT) habitat avoidance training
Aboriginal Involvement Plan		discussions with LIA and Innu Nation on management of species with special conservation status
Monitoring and Follow-up	harlequin duck monitoring
Audit and Continual Improvement Plan	audit implementation of procedures and training development of corrective action plans audit review and continual improvement procedures	audit implementation of procedures and training development of corrective action plans audit review and continual improvement procedures	audit implementation of procedures and training development of corrective action plans audit review and continual improvement procedures

Table 4.H.12 describes, for historic resources, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be best addressed through a combination of Project design features and environmental protection planning procedures.

4.H.12: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns:
Historic Resources

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Loss or Alteration of Historic Resources, including Archaeological Sites and Artifacts
Project Design Features	extensive survey to identify and evaluate historic resources development of a Historic Resources Plan use of predictive model of historic resources potential as a planning tool infrastructure will be designed or sited to avoid historic resources where possible
Environmental Protection Plan	historic resources protection procedures avoidance of known sites where possible
Emergency Response and Contingency Plans	SCAT team will include a professional archaeologist historic resources contingency procedures
Education and Orientation Plan	personnel EH&S briefing historic resources orientation program
Aboriginal Involvement Plan	Innu and Inuit monitors and archaeological researchers reporting results to Innu and Inuit communities
Monitoring and Follow-up	surveillance monitoring
Audit and Continual Improvement Plan	audit implementation of plans, policies and training development of corrective action plans audit review and continuous improvement procedures

Table 4.H.13 describes, for Aboriginal land use and culture, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be addressed through a combination of Project design features and environmental protection planning procedures.

4.H.13: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns:
Aboriginal Land Use and Culture

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Loss of Control	Cultural Dislocation	Effect on Subsistence
Project Design Features	providing funding for LIA and Innu Nation to undertake exercises in issues scoping commute operation negotiating impact and benefits agreement	commute operation rotational employment phased operations policies to encourage women to pursue non-traditional careers	rotational employment
Environmental Protection Plan		no hunting and fishing policy	no hunting and fishing policy
Occupational Health and Safety Plan	no drugs and alcohol policy	no drugs and alcohol policy substance abuse prevention and healing programs in communities translation and interpretation services trilingual safety language
Education and Orientation Plan		cross-cultural training gender sensitivity training female non-traditional career policy
Aboriginal Involvement Plan	consultation on environmental management, land use and cultural matters	cross-cultural and gender sensitivity training programs designed in consultation with LIA and the Innu Nation	consultation with local hunters incorporation of Aboriginal knowledge
Monitoring and Follow-up	Aboriginal involvement in environmental monitoring	Aboriginal involvement in environmental monitoring	Aboriginal involvement in environmental monitoring
Audit and Continual Improvement Plan	audit implementation of policies and training development of corrective action plans audit review and continual improvement procedures	audit implementation of policies and training development of corrective action plans audit review and continual improvement procedures	audit implementation of policies and training development of corrective action plans audit review and continual improvement procedures

(Cont'd)

4.H.13 (Continued): Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Aboriginal Land Use and Culture

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Impaired Mobility and Access	Contamination of Country Foods
Project Design Features	avoid affecting travel in valleys leading from Voisey's Bay to the interior limited shipping season
Environmental Protection Plan	vessel traffic management procedures	waste management procedures water management plan dust suppression in open pit and on roads
Occupational Health and Safety Plan	suspended shipping based on ice thickness
Aboriginal Involvement Plan	discussions with local hunters to determine ice conditions
Monitoring and Follow-up	Aboriginal involvement in environmental monitoring	Aboriginal involvement in environmental monitoring
Audit and Continual Improvement Plan	audit implementation of policies and training development of corrective action plans audit review and continual improvement procedures

Note: Impact and Benefits Agreements are under negotiation with LIA and Innu Nation. VBNC's
Aboriginal policy is in Appendix 4A.

Table 4.H.14 describes, for employment and business, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be addressed through a combination of Project design features and negotiated Impact and Benefits Agreements.

Table 4.H.14: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Employment and Business

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Business Disruption	Inflation	Unemployment
Project Design Features	rotational employment with multiple pick-up points adoption of principles for business development and adjacency	rotational employment with multiple pick-up points	rotational employment with multiple pick-up points
Human Resources Plan			training policy
Public Involvement Plan	community consultation and information	community consultation and information	community consultation and information
Monitoring and Follow-up	community involvement in effects monitoring	community involvement in effects monitoring	community involvement in effects monitoring
Audit and Continual Improvement Plan			audit implementation of policies and training development of corrective action plans audit review and continual improvement procedures

Table 4.H.14 (Continued): Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Employment and Business

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Increased Business Competition	Labour Force Displacement	Decreased Demand for Goods and Services
Project Design Features	rotational employment with multiple pick-up points	rotational employment with multiple pick-up points	rotational employment with multiple pick-up points
Public Involvement Plan	community consultation and information	community consultation and information	community consultation and information
Monitoring and Follow-up	community involvement in effects monitoring	community involvement in effects monitoring	community involvement in effects monitoring

Note: Impact and Benefits Agreements are under negotiation with LIA and Innu Nation. VBNC's Aboriginal policy is in Appendix 4A.

Table 4.H.15 describes, for local, regional and provincial economies, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be addressed through a combination of Project design features and negotiated Impact and Benefits Agreements.

Table 4.H.15: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Local, Regional and Provincial Economies

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Effects on Subsistence	Inflation and Cost of Living	Decommissioning Effects
Project Design Features	rotational employment	rotational employment with multiple pick-up points	rotational employment with multiple pick-up points
Occupational Health and Safety Plan	no drugs and alcohol policy
Human Resources Plan			training policy
Public Involvement Plan	community consultation and information	community consultation and information	community consultation and information
Monitoring and Follow-up	Aboriginal involvement in environmental effects monitoring	community involvement in environmental effects monitoring	community involvement in environmental effects monitoring
Audit and Continual Improvement Plan	audit implementation of policies and training development of corrective action plans audit review and continual improvement procedures		audit implementation of policies and training development of corrective action plans audit review and continual improvement procedures

Note: Impact and Benefits Agreements are under negotiation with LIA and Innu Nation. VBNC's Aboriginal policy is in Appendix 4A.

Table 4.H.16 describes, for services and infrastructure, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be addressed primarily through Project design features.

Table 14.H.16: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Services and Infrastructure

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Demand for Government Administration	Demand for Transportation Services and Infrastructure	Demand for Utility, Communication, Potable Water Supply and Waste Disposal	Demand for Housing
Project Design Features	compliance with legislation and regulations multiple pick-up points	on-site airstrip on-site wharf and docking facilities use of Nain airstrip and Happy Valley-Goose Bay airport multiple pick-up points	power generation on-site communication infrastructure on-site water supply obtained on-site waste disposal on-site multiple pick-up points	on-site accommodations and related facilities for workers multiple pick-up points
Emergency Response and Contingency Plans	establish emergency response procedures	establish emergency response procedures
Occupational Health and Safety Plan		transportation policy
Human Resources Plan	compliance with legislation and regulations			accommodations for women and married couples
Public Involvement Plan	community consultation and information	community consultation and information notification of emergency situations	community consultation and information employment and procurement policy	community consultation and information
Audit and Continual Improvement Plan	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation

(Cont'd)

Table 4.H.16 (Continued): Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Services and Infrastructure

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Demand for Health Care Services and Infrastructure	Demand for Social Services and Infrastructure	Demand for Safety and Security Services and Infrastructure	Demand on Education Services and Infrastructure
Project Design Features	on-site clinic 24 hour contact with Melville Hospital arrangement for assistance with town of Nain commitment to help fund new hospital construction in Happy Valley-Goose Bay multiple pick-up points	multiple pick-up points	on-site security on-site response teams arrangement for assistance with town of Nain multiple pick-up points	multiple pick-up points
Emergency Response and Contingency Plans	establish emergency response procedures	establish emergency response procedures	establish emergency response procedures
Occupational Health and Safety Plan	transportation policy environmental and safety procedures	transportation policy environmental and safety procedures occupational health and safety committee	transportation policy environmental and safety procedures occupational health and safety committee
Human Resources Plan	no drug and alcohol policy no harassment policy employee assistance plan health care plan employee benefits plan bereavement policy family emergency directive	no drug and alcohol policy no harassment policy employee assistance plan health care plan employee benefits plan vacation leave bereavement policy family emergency directive	no drug and alcohol policy employee assistance plan vacation leave bereavement policy family emergency directive	training/ education policy student training policy
Education and Orientation Plan	job training site orientation environmental and safety training	cross cultural training gender sensitivity training environmental and safety training	cross cultural training gender sensitivity training	impact and benefits agreements
Public Involvement Plan	community consultation and information	community consultation and information	community consultation and information	community consultation and information
Audit and Continual Improvement Plan	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation
Note: Impact and Benefits Agreements are being negotiated with LIA and Innu Nation. VBNC's Aboriginal policy is in Appendix 4A.

(Cont'd)

Table 4.H.16 (Continued): Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Services and Infrastructure

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Demand for Culture and Recreation Services and Infrastructure	Demand for Commercial Services and Infrastructure
Project Design Features	on-site recreational facilities multiple pick-up points	on-site airstrip on-site wharf and docking facilities shipping supplies from Placentia use of Nain airstrip and Happy Valley-Goose Bay airport multiple pick-up points
Public Involvement Plan	community consultation and information	community consultation and information
Audit and Continual Improvement Plan	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation
Note: Impact and Benefits Agreements are being negotiated with LIA and Innu Nation. VBNC's Aboriginal policy is in Appendix 4A.

Table 4.H.17 describes, for family and community, the relationship between EH&S concerns and the specific mitigation that will be applied in the various EH&S Plans. The principal EH&S concerns include issues that can be addressed primarily through Project design features and the Human Resources Plan.

Table 4.H.17: Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Family and Community

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Work-related Stress	Managing Income	Income Differentials and Cost of Living
Project Design Features	commuting work schedule employment and income	employment and income
Emergency Response and Contingency Plans	established emergency response procedures
Occupational Health and Safety Plan	no drugs and alcohol policy environmental and safety procedures safety procedures established
Human Resources Plan	translation and interpretation services no drugs and alcohol policy employee assistance plan conflict resolution policy work clothing and safety equipment policy vacation leave bereavement policy family emergency directives harassment policy	no drugs and alcohol policy employee assistance plan
Education and Orientation Plan	job training site orientation environmental and safety training cross-cultural training gender sensitivity training
Public Involvement Plan	community consultation and information	community consultation and information
Audit and Continual Improvement Plan	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation

(Cont'd)

Table 4.H.17 (Continued): Design/Plans for Mitigation of Environmental, and Health and Safety (EH&S) Concerns: Family and Community

	EH&S CONCERNS
Design/EH&S Plans to be Implemented	Marital and Family Stress	Social and Health Problems	Community Leadership
Project Design Features	commuting work schedule operations phases employment and income	employment and income work schedule pick-up points transportation
Emergency Response and Contingency Plans	establish emergency response procedures	establish emergency response procedures
Occupational Health and Safety Plan	no drugs and alcohol policy	no drugs and alcohol policy
Human Resources Plan	no drugs and alcohol policy employee assistance plan employee benefits vacation leave bereavement policy family emergency directives	no drugs and alcohol policy employee assistance plan health care plan bereavement policy family emergency directives
Education and Orientation Plan	cross-cultural training gender sensitivity training	cross-cultural training gender sensitivity training
Aboriginal Involvement Plan	Aboriginal involvement impact and benefits agreements	Aboriginal involvement impact and benefits agreements	Aboriginal involvement impact and benefits agreements
Public Involvement Plan	community consultation and information	community consultation and information	community consultation and information
Audit and Continual Improvement Plan	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation	regular review and update of plans, policies and procedures annual reporting to appropriate government agencies, LIA and Innu Nation
Note: Impact and Benefits Agreements are being negotiated with LIA and Innu Nation. VBNC's Aboriginal policy is in Appendix 4A.

4.13 Public Involvement Plan

4.13.1 Purpose

4.13.2 Content

4.13.3 Implementation

4.14 Monitoring and Follow-up Plan

4.14.1 Purpose

4.14.2 Content

4.14.2.1 Compliance Monitoring

4.14.2.2 Follow-Up Program

4.14.3 Implementation

4.14.3.1 Roles and Reporting

4.14.3.2 Funding

4.14.3.3 Candidate Topics

4.15 Auditing and Continuous Improvement Plan

4.15.1 Purpose

4.15.2 Content

4.15.3 Implementation

4.16 Specific Environmental Management Needs

4.17 References

Appendix 4A

Aboriginal Policy

Appendix 4B

Legislation, Permit, Approvals, and Authorizations

Appendix 4C

Exploration EH&S Documentation

Appendix 4D

Project Safety Hazards

Appendix 4E

Permit Protocol Status

Appendix 4F

Air Quality Management

Appendix 4G

Water Quality Management

Appendix 4H

Specific Environmental Management Needs