Environmental Impact Assessment of the Citronen Zinc Project, North

Citronen Base Metal Project

Environmental Impact Assessment (Volume 1)

January 2015 Rev 6

Licence 2007/02

Licensee Bedford (No. 3) limited (a wholly owned subsidiary of Ironbark Zinc Limited)

Prepared by

Ironbark Zinc Limited Level 1 350 Hay Street Subiaco 6008 Western Australia Tel.: + 61 8 6461 6350

and

Orbicon A/S Ringstedvej 20 DK-4000 Roskilde Denmark Tel: + 45 46 30 03 10

REV. NO ISSUE DATE DESCRIPTION OF REVISION 01 Feb 2011 Draft report issued to BMP. Inclusion of NERI preliminary comments (February 2011). 02 March 2011 Shipping impacts update. Dust impacts update. 03 Aug 2012 Inclusion of BMP comments (April 2011). 04 March 2013 Inclusion of BMP comments (December 2012). Inclusion of BMP comments (February 2013). 05 July 2014 Final report submitted to MLSA (English, Danish, Greenlandic) Inclusion of BMP comments (December 2014). 06 January 2015 Final report submitted to MLSA (English, Danish, Greenlandic)

Contents

1 EXECUTIVE SUMMARY ...... 1

2 INTRODUCTION...... 11

2.1 Project setting ...... 11

2.2 Ironbark Zinc Limited ...... 13

2.3 Project history ...... 14

3 LEGISLATIVE FRAMEWORK AFFECTING THE PROJECT ...... 15

3.1 Greenlandic legislation ...... 15

3.1.1 Mineral Resources Act (2009) ...... 15

3.1.2 The Northeast Greenland National Park ...... 17

3.2 International obligations ...... 20

3.3 Shipping Regulations ...... 23

4 EIA PROCESS ...... 24

4.1 EIA Guidelines for mine operations ...... 24

4.2 Plan of Study ...... 24

4.3 Public hearing ...... 25

5 EXISTING ENVIRONMENT ...... 26

5.1 Climate ...... 29

5.2 Topography ...... 30

5.3 Geology ...... 31

5.3.1 Deposit Types ...... 33

5.3.2 Mineralisation ...... 33

5.4 Soils ...... 34

5.5 Permafrost and Groundwater ...... 35

5.6 Surface Water Resources ...... 35

5.6.1 Lake Platinova ...... 35

5.6.2 Eastern River ...... 36

5.6.3 Esrum Lake and River ...... 44

5.6.4 Gossan Puddles/ Gossan Creeks...... 45

iii

5.7 Marine Waters ...... 45

5.7.1 Citronen Fjord ...... 45

5.7.2 Wandel and Greenland Seas ...... 51

5.7.3 Sea Ice ...... 52

5.7.4 Icebergs ...... 52

5.7.5 North East Water Polynya (NEW) ...... 53

5.8 Flora and Fauna ...... 55

5.8.1 Flora ...... 55

5.8.2 Fauna ...... 57

5.8.3 Fauna – Greenland Sea ...... 60

5.8.4 Threatened Species ...... 70

5.8.5 National Responsibility Species ...... 71

5.9 Socio and economic setting ...... 71

5.9.1 Local inhabitants and their use of the area ...... 71

5.9.2 Archaeology and cultural heritage ...... 72

6 PROJECT DESCRIPTION ...... 74

6.1 Construction ...... 74

6.2 Mining ...... 74

6.2.1 Underground Operation ...... 74

6.2.2 Open Pit Operations ...... 78

6.3 Ore Processing ...... 79

6.3.1 Ore Transfer to ROM ...... 79

6.3.2 Crushing ...... 79

6.3.3 Dense Media Separation ...... 79

6.3.4 Milling ...... 80

6.3.5 Flotation and Reagents ...... 80

6.3.6 Concentrate Dewatering ...... 83

6.4 Concentrate Storage ...... 83

6.5 Mine Waste ...... 83

6.5.1 Waste Geochemical Characterisation ...... 84

6.5.2 Waste Rock Management ...... 93 iv

6.5.3 Tailings Management ...... 94

6.6 Port Facility and Loading of Product ...... 102

6.7 Shipping ...... 103

6.7.1 Shipping Guidelines and Regulations ...... 103

6.7.2 Shipping vessel ...... 106

6.7.3 Route and Periods of Passage ...... 107

6.7.4 Emergency Procedures – Shipping ...... 110

6.8 Supporting Infrastructure ...... 110

6.9 Personnel, Transport and Accommodation ...... 110

6.10 Power Supply and Fuel Storage ...... 111

6.11 Explosives ...... 111

6.12 Water Supply ...... 112

6.13 Workshops and Warehousing ...... 112

6.14 Dust Management ...... 112

6.14.1 Air Quality Modelling ...... 113

6.15 Greenhouse Gas and other Gas Emissions ...... 122

6.16 Noise ...... 122

6.17 Domestic and Industrial Waste Management ...... 123

6.18 Health and Safety Management ...... 124

6.19 Emergency Preparedness ...... 125

6.19.1 Site Emergency Management ...... 125

6.19.2 Shipping Emergency Management ...... 126

6.20 Project Alternatives Considered ...... 126

7 Impact Assessment and Mitigation Measures ...... 129

7.1 Risk Analysis Method ...... 129

7.2 Citronen Fjord Ecosystem – Screening Level Ecological Risk Assessment ...... 130

7.2.1 Terrestrial Soil ...... 130

7.2.2 Surface Water ...... 131

7.2.3 Sediment ...... 131

7.2.4 Existing conditions ...... 131

7.2.5 Ecotoxicological Testing ...... 132 v

7.3 Flora ...... 132

7.3.1 Vegetation ...... 132

7.3.2 Topsoil ...... 133

7.3.3 Fauna habitat ...... 133

7.3.4 Flora management and mitigation measures ...... 134

7.4 Fauna ...... 134

7.4.1 Fauna habitat - freshwater ...... 134

7.4.2 Fauna habitat - marine ...... 135

7.4.3 Fauna - shipping ...... 136

7.4.4 Fauna - mine site ...... 136

7.4.5 Fauna interaction ...... 138

7.4.6 Fauna management and mitigation measures ...... 139

7.5 Freshwater Resources and Surface Water ...... 139

7.5.1 Eastern River ...... 139

7.5.2 Lake Platinova ...... 140

7.5.3 Pit dewatering ...... 143

7.5.4 Surface water flow ...... 147

7.5.5 Water management and mitigation measures ...... 148

7.6 Waste Rock Dumps ...... 149

7.6.1 Waste rock dumps ...... 149

7.6.2 Waste dump stability ...... 156

7.6.3 Landform aesthetics ...... 156

7.6.4 Waste dump management and mitigation measures ...... 157

7.7 Tailings Storage Facility (TSF) ...... 157

7.7.1 TSF containment ...... 157

7.7.2 TSF and flood events ...... 159

7.7.3 TSF stability ...... 160

7.7.4 TSF dust ...... 162

7.7.5 TSF - fauna ...... 162

7.7.6 TSF aesthetics ...... 163

7.7.7 TSF and rainfall changes – Cumulative Effects ...... 163 vi

7.7.8 TSF management and mitigation measures ...... 165

7.8 Shipping assessment - routine events ...... 165

7.8.1 Sound and noise ...... 166

7.8.2 Regular discharges ...... 167

7.8.3 Shipping and Hydrocarbon Licence Areas – Cumulative Impacts...... 168

7.8.4 Marine fauna ...... 169

7.8.5 Marine fauna management and mitigation measures ...... 192

7.9 Shipping – unplanned events ...... 193

7.9.1 General impacts – unplanned events ...... 194

7.9.2 Shipping (unplanned events) management and mitigation measures ...... 198

7.10 Air Emissions ...... 199

7.10.1 Dust ...... 199

7.10.2 Dust management and mitigation measures ...... 203

7.10.3 Greenhouse Gas ...... 203

7.10.4 Greenhouse gas management and mitigation measures ...... 204

7.11 Hazardous Materials ...... 205

7.11.1 Hazardous materials – unplanned events ...... 205

7.11.2 Hazardous materials management and mitigation measures ...... 205

7.12 Archaeology and Cultural Heritage ...... 206

7.12.1 Culturally significant sites ...... 206

7.12.2 Archaeology management and mitigation measures ...... 206

8 ENVIRONMENTAL MANAGEMENT ...... 207

8.1 Environmental Management Principles ...... 207

8.2 Environmental Management System ...... 207

8.3 Preliminary Environmental Management Plan ...... 208

9 ENVIRONMENTAL MONITORING PLAN ...... 209

10 DECOMMISSIONING AND CLOSURE PROCESS ...... 214

10.1 Closure Objectives ...... 214

10.2 Conceptual Closure Plan ...... 215

11 REFERENCES ...... 218

vii

Figures

Figure 1. Greenland and the position of Citronen Fjord in Peary Land...... 12 Figure 2. Citronen Fjord granted tenements (2007 in blue, 2008 in red)...... 13 Figure 3. Northeast Greenland National Park (map from Aastrup et al. 2005) ...... 18 Figure 4. The fauna and flora protection areas in the northern part of the national park (Aastrup & Boertmann 2009) ...... 19 Figure 5. The position of species specific core areas for mammals, birds and the grass Puccinellia bruggemanni in Fauna and Flora protection area No 16. (Aastrup & Boertmann 2009) ...... 20 Figure 6. The location of Ramsar sites 10 and 11 inside Northeast Greenland National Park. (Aastrup & Boertmann 2009) ...... 22 Figure 7. Wind Rose based on wind measured at Citronen (Nov 2008-July 2009 and July 2010-Sept 2010) ...... 29 Figure 8. Citronen Fjord in Peary Land, North Greenland ...... 30 Figure 9. Geological stratigraphic column of Citronen Fjord ...... 31 Figure 10. Local geology at Citronen Fjord (refer to Figure 9, stratigraphic column, for key)...... 32 Figure 11. Zones of mineralisation at Citronen ...... 34 Figure 12. Correlation between Stream Flow and Air Temperature...... 37 Figure 13. 1994 Eastern River flow and total zinc concentrations...... 39 Figure 14. 1997 Eastern River flow and total zinc concentration...... 40 Figure 15. 2010 Eastern River flow and total zinc concentration...... 41 Figure 16. Eastern River flow rates for 1994, 1997 and 2010...... 41 Figure 17 Comparison of zinc concentrations in Eastern River in 1994, 1995, 1997 and 2010...... 42 Figure 18. Zinc loading to the Eastern River...... 43 Figure 19. Bathymetry of Citronen Fjord (DHI, 2010)...... 46 Figure 20. Marine water stations H1–H4 in Citronen Fjord, showing concentrations of Zn, Cu, Pb and temperature with depth...... 49 Figure 21. Location of Wandel and Greenland Seas...... 51 Figure 22. Location of the North East Water (NEW) off the east coast of Greenland...... 53 Figure 23. Ice off north east Greenland May 26, 2008 (Boertmann & Nielsen 2010)...... 54 Figure 24. Ice off north east Greenland July 26, 2008 (Boertmann & Nielsen 2010)...... 54 Figure 25. Map showing NDVI-values (Normalised Difference Vegetation Index) from northeast Greenland in Aug 2004...... 56 Figure 26 The Citronen Project proposed mine layout ...... 76 Figure 27 Layout of the processing plant and accommodation area...... 77 Figure 28 . ANP/AGP as a function of total sulfur content...... 85

viii

Figure 29 Acid neutralisation Potential as a Function of Acid Generating Potential...... 87 Figure 30 Waste rock humidity cell leachate pH over time...... 89 Figure 31 Tailings humidity cell leachate pH over time...... 89 Figure 32 Waste rock humidity cell leachate zinc release rates...... 90 Figure 33 Tailings humidity cell leachate zinc load release rates...... 90 Figure 34 Waste rock humidity cell leachate lead release rates...... 91 Figure 35 Tailings humidity cell leachate lead release rates...... 91 Figure 36. Approximate shipping route...... 107 3 Figure 37. Spatial distribution of the maximum annual average PM10 concentrations (ug/m ) predicted in the mine vicinity (Golder, 2011)...... 116 Figure 38. Spatial distribution of the maximum annual average PM concentrations (ug/m3) predicted in the mine vicinity (Golder, 2011)...... 117 2 Figure 39. Spatial distribution of the predicted maximum annual zinc deposition (g/m ) based on PM10 emissions (Golder, 2011)...... 118 Figure 40. Spatial distribution of the predicted maximum annual zinc deposition (g/m2) based on PM emissions (Golder, 2011)...... 119 2 Figure 41. Spatial distribution of the predicted maximum annual lead deposition (g/m ) based on PM10 emissions (Golder, 2011)...... 120 Figure 42. Spatial distribution of the predicted maximum annual lead deposition (g/m2) based on PM emissions (Golder, 2011)...... 121 Figure 43. Typical frequency bands of sounds produced by marine mammals and fish compared with nominal low- frequency sounds associated with commercial shipping (source: OSPAR, 2009)...... 167 Figure 44. The Kanumas and assessment area on the eastern side of Greenland (Boertmann et al., 2009)...... 171 Figure 45. Polynyas occurring on the eastern side of Greenland (Boertmann et al., 2009)...... 172 Figure 46. The hatched area marks the important spring staging areas for common eider in the NEW...... 173 Figure 47. Distribution and size of breeding colonies of common eider on the Eastern coast of Greenland during surveys in July and August 2009. (Boertmann and Nielsen 2010)...... 174 Figure 48. Distribution and size of observations including breeding colonies of ivory gull during surveys in July and August 2009 (Boertmann and Nielsen 2010)...... 175 Figure 49. Distribution and numbers of little auk observed during the NERI 2008 aerial survey in May and June. .. 178 Figure 50. Distribution and size of breeding colony on ross’s gull on the eastern ...... 179 Figure 51. Distribution and size of breeding colonies of fulmar on the eastern coast of ...... 180 Figure 52. Core area for polar bear near the NEW...... 182 Figure 53. The distribution of Atlantic walrus in the east Greenland area...... 185 Figure 54. The potential and the 2007 whelping area for harp and hooded seals in the Greenland Sea...... 187 Figure 55. The general distribution of narwhal (Boertmann et al., 2009)...... 190 ix

Figure 56 Protection zones for narwhal (also bowhead whale and walrus) in north east Greenland...... 191 Figure 57. Designation of particularly important oil spill-sensitive summer areas (preliminary assessment) ...... 195

Tables

Table 1. Summary of sample collection for all baseline studies at Citronen Fjord...... 28 Table 2. Metal (total) and nutrient concentrations from Lake Platinova at 0, 6 and 10m depths compared to Greenland Water Quality Guidelines (BMP 2011) and Canadian Council of Ministers of the Environment (CCME, 2007)...... 36 Table 3. Eastern River Daily Total Metals Concentrations (1994, 1997, 2010)...... 38 Table 4. Metal (total) concentrations from Eastern River in 2010 compared to the Greenland Water Quality Guidelines (BMP 2011) and Canadian Council of Ministers of the Environment (CCME, 2007)...... 43 Table 5. Metal (total) concentrations from Esrum River in 2010 compared to the Greenland Water Quality Guidelines (BMP 2011) and Canadian Council of Ministers of the Environment (CCME, 2007)...... 44 Table 6. Temporary gossan water features pH...... 45 Table 7. Citronen Fjord water quality...... 47 Table 8. Ranges in marine water column metal concentrations in Citronen Fjord (H1 –H4) and reference stations (Depot Bay and Frederick E. Hyde Fjord West) compared to Greenland Water Quality Guidelines (BMP 2011) marine water quality limits...... 50 Table 9. Fauna species occurring in the Citronen Fjord area which are on the Regional Greenland Red List and IUCN Red List of Threatened Species...... 70 Table 10. National Responsibility Species that occur in the Citronen Fjord region...... 71 Table 11. Preliminary listing of processing reagents...... 82 Table 12. Sample quantities for each waste source for the geochemical characterisation program...... 84 Table 13. Statistical summary of acid-base accounting results ...... 86 Table 14 Humidity cell test durations summary...... 88 Table 15. Summary of design criteria and assumptions...... 95 Table 16 Thermistor measurements of beach area (August 2010)...... 101 Table 17 Opening and closing dates of lead from Cape Nordostrundingen to Frederick Hyde Fjord (Enfotec March 2011)...... 109

Table 18. Summary of PM/PM10 zinc and lead emissions used in dust modelling (Golder 2011)...... 115 Table 19 Anticipated waste types and destinations...... 124

Table 20 Comparison of maximum modelled Lake Platinova surface water concentrations to freshwater screening values during 16 years of operations and closure...... 142 Table 21 Comparison of maximum modelled Lake Platinova sediment concentrations to freshwater sediment screening values during 16 years of operations and closure...... 143 Table 22. Comparison of maximum modelled Citronen Fjord surface water concentrations to marine water screening values during final three years of operations and closure...... 144 Table 23 Comparison of maximum modelled Citronen Fjord sediment concentrations to marine sediment screening values during final three years operations and closure...... 145 Table 24 Input solutions for the geochemical modeling...... 151 Table 25 Surface water hydrology input values...... 153 Table 26 Citronen Fjord background water quality compared to modelled water quality during operations and the final three years of operations/ closure...... 153 Table 27 Comparison of maximum modeled Citronen Fjord sediment concentrations to marine sediment screening values during operations...... 154 Table 28 Comparison of maximum modelled Citronen Fjord sediment concentrations to marine sediment screening values during final three years and closure...... 155 Table 29. Minimum Factors of Safety for Dam Stability ...... 160 Table 30: Overview of most important species of birds from Boertmann et al. (2009)’s assessment area...... 170 Table 31. Overview of marine mammals occurring in the assessment area (from Boertmann et al., 2009)...... 183

Table 32. Summary of maximum predicted zinc and lead (PM/PM10) deposition from dust at Citronen off-site receptors (Golder 2011)...... 199 Table 33. Comparison of Maximum Modelled Soil Concentrations to Soil Screening Values...... 200 Table 34 Comparison of Maximum Modelled Citronen Fjord Surface Water Concentrations during First 13 Years of Operations to Marine Water Screening Values...... 201 Table 35 Comparison of Maximum Modelled Citronen Fjord Surface Water Concentrations during Final Three Years of Operations/Closure to Marine Water Screening Values...... 202 Table 36. Citronen Environmental Monitoring Program ...... 211 Table 37. Conceptual Closure Plan for the Citronen mining project ...... 215

Appendices (Volume 2)

Appendix 1. Third Baseline Study in the Citronen Fjord Area, North Greenland 2010. Ironbark & Orbicon. 2010

Appendix 2. Vertebrates of the Citronen Region, Orbicon 2010.

Appendix 3. The biological importance of the North East Water polynya, NE Greenland, Orbicon 2010

Appendix 4. Risk Assessment Matrix. Ironbark 2010

Appendix 5. MPL-001 Loss of Containment and Emergency Management Plan. Ironbark 2012.

Appendix 6. Citronen Preliminary Environmental Management Plan

xii

1 EXECUTIVE SUMMARY

Ironbark’s Citronen Zinc Project (the Project), includes the development, operation and ultimate reclamation of a zinc and lead mine at Citronen Fjord in North Greenland. The Project will comprise mining three deposits (both underground and open pit) with an on-site processing facility to produce mineral concentrates of zinc and lead. The concentrates will be shipped off-site to Iceland and subsequently to a smelter for further processing. The anticipated mine life is 14 years.

Project description Tenements EL2007/02, EL2007/31, EL2010/47, EL2011/33

Mining Reserve Beach, Esrum and Discovery deposits. 44.9Mt at an average grade of 5.4% Zn + Pb Components 2 x underground, 1 x open pit, 2 x waste rock dumps, Tailings Storage Facility, port, processing plant, ancillary infrastructure Mining rate 3.3Mtpa Mining method Room and pillar mining in underground. Conventional open pit, drill and blast, hydraulic excavation, load and haul Processing type Crushing and flotation Life of Mine Underground 11 years, open pit 3 years Waste rock volume Underground 0.41Mt , Open pit 18.3Mt DMS Rejects volume 14.4Mt Tailings waste volume 26.4Mt Mine waste characterisation Waste rock will be non-acid forming Tailings waste is acid generating Estimated project footprint Approximately 150ha

Regional Context

The Citronen Fjord is located in Peary Land and is an appendage of the much larger Frederick E. Hyde Fjord. Citronen Fjord is approximately 2,000 kilometres (km) north-northeast from Greenland’s capital, Nuuk and 940km from Qaanaaq the nearest Greenlandic settlement. The Project lies at the head of Citronen Fjord on the eastern shore, in the junction of two glacial valleys in which the Esrum and Eastern Rivers run, and is surrounded by bare mountains up to 1,000m high. Access to the site is currently via aircraft, with ocean access possible during the summer months via Frederick E. Hyde Fjord.

The Citronen Fjord area is in the High Arctic Region with long, cold winters and short, cool summers and with continuous permafrost where the ground stays frozen all year. Mean daily temperatures

1 above freezing occur from June until September. Precipitation is very low (in the order of 200mm per year) and mainly falls as snow. Frederick E. Hyde and Citronen Fjords are ice-locked most of the year.

Lake Platinova is the only lake in the immediate vicinity of the Project. This is a small, rounded depression, fed by precipitation and melting of the active layer surrounding the lake. The Eastern River runs through the Project area before entering Citronen Fjord. Its main water source is from local glaciers and the runoff is therefore mainly controlled by air temperature. Considerable amounts of metals (zinc, lead, iron, cadmium, aluminum and nickel) from exposed areas of intensely oxidised sulfide minerals in the Project area are naturally washed into the Eastern River. This leads to elevated metal concentrations in the water column for two to three weeks when the river starts to run in late May to early June. These high metal concentrations are therefore also found in Citronen Fjord. Another river, the Esrum River, just west of the Project area also has elevated metal concentrations early in the summer season.

The low temperatures during the short summer season combined with very low precipitation results in a sparse and discontinuous vegetative cover that consist of a small number of flora species (49 identified to date) adapted to these extreme conditions. The number of animals is also very low. Eight species of birds breed or are believed to breed occasionally in the Citronen area. In addition, small numbers of non-breeding pink-footed geese migrate through the area and occasionally stop over to feed and rest. Six terrestrial mammals and one marine mammal occur throughout the year. This includes small numbers of muskoxen and wolf. Polar bears have been recorded from Frederick E. Hyde Fjord in spring. Satellite tagged bears were recorded in the Citronen Fjord area in the 1990’s.

Four animal species (wolf, polar bear, arctic tern and ivory gull) listed on the Greenland Red List of threatened species have been recorded from the Citronen area. Except for the wolf, the red-listed species are uncommon visitors to the Project area. Small numbers of wolves occur throughout the years and may also breed in the area some years, however the Citronen area is not known to be of particular importance for wolves or any of the other red-listed species.

A small sedentary arctic char population live in Lake Platinova, while Eastern and Esrum River have no fish. Little is known about marine fish in Citronen Fjord except that four-horned sculpin is common and that small numbers of arctic char have been recorded.

The proposed shipping route will enter the Greenland and Wandel seas and hence fauna associated with these two bodies of water have been included in the assessment. Fauna occurrences in these areas are primarily seasonal (although not for all animals) with many found on the coastal zone and in the ecologically important North East Water (NEW) polynya. Fifteen species of seabird, four species of seal, five species of rorqual whales, five species of toothed whales and 26 species of fish have been

2 recorded and documented in detail. Other mammals that occur are the polar bear, walrus and bowhead whale.

Project Description

The proposed mining operation will occur at a rate of 3.3 million tonnes per annum at three deposits: initially two below surface and later, one open pit.

The mined ore will be delivered by trucks to the processing plant. The ore will first pass through a two stage crushing process followed by Dense Media Separation (DMS) where waste fractions (DMS rejects) will be removed by flotation and disposed of to a DMS rejects dump. The ore continues onward through two milling processes before entering flotation. Milled material is fed into an agitated water tank with the addition of standard flotation reagents. The reagents bind to the metals causing the matrix to float to the surface. Here they are suspended within a stable froth, prior to collection. The pre-flotation waste is disposed at the tailings storage facility. After flotation the froth is cleaned and the material dewatered through pressure filters to produce a concentrate cake. The concentrate is transported by covered conveyor to a fully enclosed, heated concentrate shed prior to shipping off site.

A 3.6 million cubic metre tailings storage facility will be constructed. The facility will have a dam wall and will be lined with a geo-membrane to contain seepage. A diversion drain will be constructed to prevent runoff from the mountain from entering the facility. The tailings storage facility will be operational for the life of the mine, but primarily used for disposal of tailings in the first year. Once sufficient space is available, tailings will be disposed within the underground mine.

Mining waste rock from Citronen will be deposited at the Waste Rock Dump and DMS Rejects Dump. The dumps have been located so as to ensure stable slopes, and where practicable, blending into the natural surrounding topography. A diversion drain will be constructed on the upper side of the waste dump to prevent water runoff from the mountain from entering the dump. At closure, the waste rock dumps will be designed with shallow final batters and forward sloping berms to minimise water retention.

A 15m wide access pier will be constructed which extends into Citronen Fjord to facilitate shipping of concentrate off site. The concentrate will be loaded into ice-class bulk carriers. The production rate at Citronen will correspond to the requirement for three return trips per year from Citronen Fjord to a designated marshalling port. Shipping studies indicate that the shipping “window” is generally open July through to September (subject to prevailing conditions), however the average shipping dates with regard to the vessel ice class (PC 4-5) are from the 1st August to the 28th of August. The shipping

3 route will be dictated by the location of the open water lead that develops along the eastern coast of Greenland.

Other large installations will be four diesel generators with a total power generating capacity of 28MW and two 25ML diesel tanks. In addition, a 250 person self-contained camp will be constructed, as well as a workshop. The water supply will be sourced from Lake Platinova and the lake will have its capacity increased through construction of a dam wall to enable a greater storage volume. There is an existing airstrip at the Project. This airstrip will be extended after the first year of operations.

Key Environmental Issues

The environmental impact assessment has identified the following environmental issues as being the key areas requiring detailed assessment and management for the Citronen Project.

Freshwater or marine water resources A Screening-Level Ecological Risk Assessment (SLERA) including ecotoxicity testing was conducted to assess and describe potential transport and exposure pathways from contaminant sources (i.e., waste rock dumps and tailings storage facility) to potential ecological receptors at the Project. The SLERA identified constituents within the surface water, sediment and surface soils with the potential to affect receptors at the Project. Fish, aquatic invertebrates and aquatic plants in the Citronen Fjord, at the mouth of the Eastern River, were identified as the main ecological receptors.

Based on the toxicity and geochemical testing the SLERA study concluded mine wastes will not significantly increase the levels of metals in the aquatic or terrestrial environment of the Citronen Fjord area above those of background levels or comparable guidelines. The SLERA results are summarised below:

Area Media Constituent Receptor Potential Risk and Phase Lake Surface water Nil Nil No risk Platinova Sediment Nil Nil No risk

Citronen Surface water Zinc Piscivorous birds Potential risk during final three years Fjord operations and closure

Sediment Zinc Piscivorous birds Potential risk during final three years operations and closure

Arsenic Piscivorous birds, Potential risk during final three years marine mammals operations and closure

Ecotoxicity testing indicated that there is no toxicity associated with the tailings supernatant to either marine invertebrates or fish.

Mine waste facilities Geochemical characterisation was conducted on various mine wastes (waste rock, tailings and DMS rejects) to assess the potential for release of contaminants to the environment. The main focus was on the potential leaching of metals and the generation of acid which could release metals into the surrounding environment.

The geochemical testing studies indicate that the potential for acid rock drainage and metal leaching from waste rock is low and will lead to no or very limited contamination of the localised terrestrial ecosystem at the dump. The acid-based-accounting shows that waste rock samples with low total sulphur are likely to be classified as non acid-generating due to the presence of excess neutralisation potential in the form of calcite and/or dolomite. The total sulphur content of the waste rock can assist with waste rock management during operations.

Geochemical testing indicated that tailings will most likely generate acid after long-term exposure to oxygen and water and as such will require an additional level of containment normally accepted in conventional tailings facilities. Accordingly, the dam area will be lined with a geo-membrane liner to contain all seepage and will be capped upon closure. As such, the tailings will be a fully contained facility with no anticipated release of tailings to the environment.

Dust Air dispersion modelling was conducted to assess the potential dispersal of dust at the proposed Project. Dust [i.e. particulate matter (PM)] emissions were developed and ground level PM concentrations and deposition estimates were predicted for the mining operations based upon meteorological data and air emission sources.

The dust modelling showed that the highest dust concentrations will occur along the haul roads however this is mainly caused by vehicle turbulent wake and is expected to contain minimal dust from the loads containing metals such as zinc and lead. Contamination with dust containing zinc and lead is likely to mainly occur at the pit and the crusher with local dust dispersal from the underground vent raises.

Dust emissions will be managed using the Best Available Techniques to control dust at point sources.

Shipping The production rate at Citronen will correspond to the requirement for approximately three return trips per year from Citronen Fjord to a designated marshalling point (possibly Akureyri, Iceland), using ice- class bulk carriers. Ship transport (incl. ice-breaking) has the potential to impact seabirds and marine mammals along and in the vicinity of the shipping route. The most sensitive area along the shipping route is the Northeast Water (NEW) polynya, which provides habitat for numerous marine mammals and breeding seabirds.

The seabird species considered to be most sensitive to impacts from shipping are the common eider, ivory gull, thick-billed murre, little auk, ross’s gull and fulmar, with potential impacts to ross’s gull and fulmar considered more significant. Shipping will not occur within five kilometres of a bird cliff if it is occupied by murre (Uria aalge), thick-billed murres (Uria lomvia), little auks (Alle alle), kittiwakes (Rissa tridactyla), northern fulmar (Fulmarus glacialis) or great cormorants (Phalacrocorax carbo), as it is illegal to shoot or generate noise in the vicinity of these populations.

The marine mammal species considered to be most sensitive to shipping are polar bear, walrus, hooded seal, harp seal, bearded seal, bowhead whale and narwhal. Potential impacts are expected to be local and primarily due to the short-lived, infrequent shipping to and from Citronen Fjord.

To reduce the risk of shipping accidents and to minimise the impact on the environment in the unlikely event of an accident resulting in the release of fuel or concentrate, environmental and safety procedures will be implemented. The ice-class bulk carriers that will be used will be of the highest “ice class” suitable for conditions off the coast of Greenland.

The most serious environmental impact related to a shipping accident would be a fuel oil spill. Because of the slow decomposition rates due to low ambient temperatures, the oil would be preserved for a long time. The probability of a large fuel oil spill, chemical spill or unexpected loss of materials is very low, due to the short duration of the shipping window, the small number of trips and the mitigation measures proposed. In the unlikely event of a shipping accident resulting in the release of fuel or concentrate the Emergency Response Plan would be activated.

Vegetation and terrestrial habitat On average the vegetation cover in the Citronen area is about 5%, however most areas are characterised by almost bare ground with loose rubble and broken slopes with no or very little vegetation cover. Continuous vegetation is mostly found in depressions and along streams. This vegetation is dominated by a few plant species that are common and widespread in north Greenland, therefore clearing within the Project will not impact representative flora of the area. Among the flora species known to occur in the Citronen area none are rare or endangered.

The vegetation in the Citronen area provides food for a number of mammals and birds (and invertebrates), in particular muskoxen, arctic hare and collared lemming as well as ptarmigan and staging geese. However, given that plants cover only a small percentage of the ground in the Citronen area, and because the overall footprint of the Project is relatively small with some of the major facilities in areas with almost no vegetation (pit and airstrip), the loss of fauna habitat is considered very small in relation to the surrounding available vegetation.

Fauna While the construction and operation of a mine at Citronen has the potential to impact local fauna of the region, it is considered that the majority of fauna in the region will not be significantly impacted by the Project for the following reasons:

• No fish live in the Eastern River and therefore it is anticipated that the Project will not impact on the fauna of the river; • The construction of the port facility only relates to a minor loss in habitat for marine fauna. Any change in water quality from suspended material during construction will be temporary; • Fauna that normally inhabit areas at the Project are likely to move to areas outside the mine once disturbance and construction begin; • Limited vegetation within the Project area will not attract fauna for feeding purposes; and • Hunting will be forbidden on the mine site.

There is potential for adverse impacts to the Lake Platinova arctic char population due to the extreme fluctuations in water quantity within the lake expected whilst the lake is used as the site water supply. Upon closure the lake will be allowed to return to pre-mining levels.

Surface water regimes It is planned to pump 1.3 million m3 from the Eastern River into Lake Platinova during the summer months (corresponding to 1,000 m3 of water per hour). Water in the lake will then be used as the site water supply. Removal of this volume of water from Eastern River has potential to alter the flow dynamics of the river, however the required volume of water approximates to 8.8 % of the total runoff and as such is not expected to have a significant impact on the ecology of the river or receiving water (Citronen Fjord) due to the overall high volume of water that flows in the river as a result of melting snow and ice.

In order to contain the increased water volume required in Lake Platinova, an embankment will be constructed along the north-east shore of the lake. The use of lake water for production will cause the water level to vary between a low level in spring (May) and a high level in July-August after water has been pumped into the lake from Eastern River. The natural lake overflow is directed back to the Eastern River. This overflow will be blocked whilst the lake is in use for the Project. The lake

7 embankment is not expected to adversely impact on the overall surface water regime in the Project area as the contribution of overflow water from the lake to the river is estimated as a low percentage of the river volume.

Diversion drains will be constructed around the pit crest, underground decline, tailings storage facility and waste rock dumps to prevent water from entering these facilities, particularly melting water in spring and summer. The water will be diverted to Eastern River and/or Citronen Fjord. A few small temporary streams may also be diverted around the mine facilities at the shore of the fjord. The diversion drains at the pit, decline, tailings storage facility and waste rock dumps will remain on closure while the other diversions (not required for long term stability) will be removed during the rehabilitation of the mine.

Precipitation in the Project area is very limited and the annual runoff of the local catchment area is small and limited from June to September. The diversion drains around the mine facilities will therefore only be diverting small amounts of water during a short time of the year. The diverted water will be directed to the original outflow destination.

Unplanned release of hazardous materials to land or water Unplanned releases in connection with transport, storage and handling of hazardous materials such as fuel, grease, paint and chemicals could potentially cause contamination of soil or water resources at the Project.

Fuel, cargo and concentrate will be shipped to and from the Project each summer. An ice-class bulk carrier will enter the port at Citronen Fjord approximately three times each year between July and early September. Sailing in ice-covered waters poses an increased risk of shipping accidents. The ships that will be used will be of the highest “ice class” suitable for conditions off the coast of Greenland.

The risk of potential contamination of the marine environment due to accidental release of concentrate or fuel during shipping is considered moderate. This is due to the potential severity of this event if it occurs, although the probability of this happening is very low.

Hydrocarbons (such as oil, petrol and diesel) can also cause localised contamination on site. Appropriate storage (consistent with Greenland government regulations and guidelines) and handling of hazardous materials will reduce the risk of contamination from these materials. Bulk hydrocarbons will be stored within bunded tanks and pipelines carrying such materials will also be bunded to capture leaks or spills.

It is considered that the risk of contamination from hazardous surface soil or water resources in and around the mine area is low. None of the planned mine activities would result in more than very limited and localised contamination.

Greenhouse gas Carbon dioxide and other greenhouse gases will be generated by the diesel power plant and vehicles. Visiting aircraft and ships will also generate greenhouse gases. Approximately 50 million litres of diesel will be consumed annually by the Project (80% power generation and 20% mobile equipment).

Emissions will be limited through the use of high quality diesel and ongoing maintenance of plant and equipment. The selection of modern economical equipment during the design phase will further reduce the generation of greenhouse gases. The emissions are not considered to significantly impact the air quality in the area.

Rehabilitation and closure Once the end of mine life has been reached, it is Ironbark’s goal to rehabilitate the land to an environmentally acceptable state and manage the environment through a program of post-closure rehabilitation and monitoring. Ironbark plans to develop a rehabilitation and closure strategy that allows life-of-mine closure planning that is responsive to project planning decisions and changing regulatory framework.

A Decommissioning and Closure Plan (DCP) will be developed for the mine, and regularly updated and refined throughout the life of the mine. The DCP will consider the results of testing and monitoring as well as any changes to the environmental, regulatory and social environment that may have occurred over the life of the mine.

Conclusion

Overall, the risk analyses conclude that most Project activities have a low risk level of disturbing or contaminating the environment at Citronen Fjord. Ironbark will implement suitable mitigation measures to manage any potential risks. This generally low level of risk is consistent with the nature and scale of the Project, which includes factors such as:

• Tailings waste will be contained within a fully lined facility or underground; • Waste rock is characterised as being non-acid generating, with high neutralisation capacity; • Modelled contamination effects of constituents of concern are highly conservative, based on overly conservative assumptions. Values should therefore be considered as overall maximums and are unlikely to be fully realised during the Project; • Modelled constituent concentration levels are below background or guideline levels with the exeception of nickel; • Modelled mine waste runoff results indicate they will not significantly increase the concentrations of metals in either terrestrial soil, surface water or sediment at the Project; • A relatively small scale of disturbance will occur, with only limited clearing of vegetation in a region sparsely vegetated; • No populations of flora or fauna are unique to the Project area; • Shipping of the saleable product for the Project will only require three return trips per year between Greenland and designated marshalling area thus limiting impacts from shipping; and • Most potential impacts having only a localised affect, which can be readily managed or remediated.

2 INTRODUCTION

The proposed Citronen Zinc project (the Project), includes the development, operation and ultimate reclamation of a zinc and lead mine at Citronen Fjord in Peary Land, Greenland. The Project will comprise mining three deposits (both open pit and underground) with an on-site processing facility to produce mineral concentrates of zinc and lead. The concentrates will be shipped off-site to a smelter for further processing.

It is a requirement of the Government of Greenland that an Environmental Impact Assessment (EIA) and Social Impact Assessment (SIA) are prepared to evaluate the potential impacts of the Project on the environment and the community. The EIA process is a detailed study of potential environmental impacts and identification of procedures that may be used to manage or avoid any identified impacts.

A separate Social Impact Assessment (SIA) has also been prepared to assess the socio-economic impacts of the Project. This will form the basis of an Impact Benefit Plan and Impact Benefit Agreement once the public hearing process is finished.

2.1 Project setting

The Project is located in the High Arctic Region at the Citronen Fjord in north-eastern Greenland (Figure 1), approximately 2,100km north of the capital Nuuk. The remote site is located at latitude 83° 03’N and longitude 28°15’W, and as such, is further north than the most northerly permanently manned airfield in the world at Alert, and further north than what was the most northerly base metal mine in the world at Polaris in Canada (closed in 2001).

Greenland is the world’s largest island, and is positioned in the northern Atlantic Ocean, between latitude 59 and 84°N and longitude 12 and 72°W. Canada lies immediately to the west, across Baffin Bay, while Iceland lies 400km off the south-east coast, and the United Kingdom a further 1,200km in the same direction.

The nearest permanent residence to Citronen Fjord is Station Nord, 240km south-west. Station Nord is a Danish outpost manned during winter by five army personnel. An all-weather airstrip is maintained there. Alert, a Canadian Forces station on the northern tip of Ellesmere Island, also maintains a year- round airstrip, as does Thule, a US Airforce base on Greenland’s western coast.

Figure 1. Greenland and the position of Citronen Fjord in Peary Land.

The Citronen Fjord deposit was discovered and first drilled by Platinova A/S in 1993. Exploration between 1993 and 2010 has further delineated the deposit, revealing a large amount of zinc and lead mineral sulphides. The deposit is located on tenements held by Bedford (No. 3) Limited, a wholly owned subsidiary of Ironbark under exclusive licence 2007/02 (Figure 2).

Figure 2. Citronen Fjord granted tenements (2007 in blue, 2008 in red).

2.2 Ironbark Zinc Limited

Ironbark Zinc Limited is a well-funded company listed on the Australian Securities Exchange (ASX:IBG), with a market capitalisation of US$100million. Ironbark’s key focus is the wholly owned Citronen base metal deposit. The goal of the Citronen Base Metal Project is to develop, establish and operate a world class zinc lead mine at Citronen Fjord.

Ironbark is the licensee for the deposit at Citronen Fjord. Ironbark also holds multiple exploration licences granted by the Greenland Mineral Licence and Safety Authority (MLSA) during 2007, which cover an area of 120 square kilometres at Citronen Fjord and an additional 1,700 square kilometres around Citronen Fjord. The company is well respected within industry and seeks to build shareholder value through exploitation and development of its projects and also seeks to actively expand the project base controlled by Ironbark. The board and management of Ironbark have extensive technical and corporate experience in the mineral sector. Two prominent base metal companies are significant shareholders in the company.

2.3 Project history

The summary of the exploration and assessment history of the Citronen Zinc Project is as follows:

• 1960 - US Geological Survey geologists noted gossans to the south of Frederick E. Hyde Fjord, about 20km east of Citronen Fjord;

• 1969 - A British Joint Services Expedition noted gossans in the vicinity of Citronen Fjord. These were sampled, but gave no indication of significant mineralisation;

• 1979-1982 - Citronen Fjord was mapped as part of the systematic regional mapping by the Geological Survey of Greenland;

• 1993 - Platinova A/S conducted a prospecting survey into the Frederick E. Hyde Fjord area, and identified base metal mineralisation on the banks of the Eastern River (now known as the Discovery Zone). This prompted a full-blown exploration program the same summer;

• 1993–1997 - Extensive exploration occurred over a period of five years. This program also included an initial environmental reconnaissance (1993), and two follow-up baseline surveys (1994 and 1997);

• 1998 – Kvaerner Metals completed an “order of magnitude” study into the Citronen Zinc Project. A downturn in the zinc price caused this project to be placed on hold;

• 2002 (approx.) – Platinova A/S passed into administration and relinquished the exploration leases;

• 2005 – Globe Star Mining Corp acquired title to the property, and subsequently transferred the title to Bedford (No.3) Limited;

• 2007 – Ironbark Gold acquired 100% of the Citronen Zinc Project from Bedford (No.3) Limited;

• In 2009 the company name was changed to Ironbark Zinc Limited (Ironbark). Ironbark will continue development of the Project including further exploration in the Citronen Fjord area.

3 LEGISLATIVE FRAMEWORK AFFECTING THE PROJECT

Greenland is part of the Kingdom of Denmark. Autonomous local governance was introduced to Greenland in 1979. On 21 June 2009 the Act on Greenland Self Government came into force, which stated that Greenland could take over the administration of natural resources from Denmark. Consequently the Naalakkersuisut (Government of Greenland) decided to immediately take control of the mineral resource sector. The MLSA (under the Greenland Self Government) is responsible for the management of mineral resource activities in Greenland.

3.1 Greenlandic legislation

Subsequent to establishing Greenlandic responsibility for management and regulation of the mineral resources sector, a new Act on Mineral Resources in Greenland came into force on 1 January 2010 (Greenland Parliament Act no. 7 - 7 December 2009 on mineral resources and mineral resource activities). This law regulates all matters concerning mineral resource activities, including environmental matters (such as pollution) and nature protection.

3.1.1 Mineral Resources Act (2009)

The new Mineral Resources Act (the Act) is similar to the previous Mineral Resource Act of 1998. However, there are several new provisions including new chapters concerning the environment, nature and the climate. Furthermore, the Act now specifically stipulates that an Environmental Impact Assessment must be prepared before permission to exploit minerals can be granted.

Of particular relevance to the Environmental Impact Assessment is the regulation of environmental protection. This is included in Chapter 13 which is divided into three sections on environmental protection, climate protection and nature conservation.

Under environmental protection, the following provisions are of particular importance for the mine project at Citronen Fjord:

• The use of best available techniques, including less polluting facilities, machinery, equipment, processes and technologies should be applied (§53);

• When selecting measurements to prevent and mitigate pollution, attention should be paid to the environment of the site and how metals and other pollutants can have an influence on specific species and the ecosystem (§53); and • When selecting a site a place should be chosen where the pollution has least impact on the environment. Furthermore when choosing machinery and working processes the best available techniques should be selected that generate least pollution, emissions and waste (§53).

In the section on climate protection, the Act states that when the Greenland Government makes a decision on approving the establishment and operation of a facility, it attaches importance to the considerations taken for avoiding a negative impact on the climate (§56).

In the nature conservation section, the Act states that when granting a licence for approval of an activity, the Greenland Government attaches importance to the consideration of avoiding impairment of nature and the habitats of species in designated national and international nature conservation areas and disturbance of the species for which the areas have been designated (§ 60).

Chapter 15 of the Act deals with Environmental Impact Assessments (EIA). In §73 it is stated that exploitation of minerals can be granted only when an assessment has been made of the environment (EIA) and it has been approved by the Greenland Government. It is further stipulated that the Greenland Government will lay down specific provisions regarding the contents of the EIA (§74, 3). These provisions are currently available as the BMP Guidelines – for preparing an Environmental Impact Assessment (EIA) Report for Mineral Exploration in Greenland (2nd Edition January 2011).

There have been two amendments to the Mineral Resources Act, adopted in December 2012 and June 2014. The December 2012 amendment resulted in the discontinuation of BMP, replacing it with the formation of the Mineral Resource Authority (MRA). The MRA consists of the Mineral and Licence Safety Authority (MLSA) and Environmental Agency for Mineral Resource Activities (EAMRA) in January 2013. The June 2014 amendment was regarding changes in public consultations for EIA’s and SIA’s.

In order to advance its exploration licence into an exploitation licence, Ironbark must apply to the MLSA for such a licence pursuant to the provisions given in section 16 of the Act. The application for an exploitation licence must be accompanied by a number of documents, including:

• A declaration that the deposit at Citronen Fjord is commercially viable and that Ironbark intends to exploit the deposit;

• A bankable feasibility study of the Citronen Fjord deposit on which the declaration is based;

• An Environmental Impact Assessment; and

• A Social Impact Assessment, including an Impact Benefit Agreement with the public authorities.

3.1.2 The Northeast Greenland National Park

Twelve areas in Greenland are protected under the Nature Protection Act. This includes the Northeast Greenland National Park (Figure 3). With an area of 972,000 km2, this is the largest national park in the world of which 200,000 km2 is snow and ice-free during summer. Citronen Fjord is situated in the northern part of the national park.

The national park was created on 22 May 1974 and has no permanent human population. During winter the personnel of three small military bases, a civilian weather station and a research station (numbering around 30) are the only inhabitants in the national park. This number increases in summer when many scientists work in the national park.

Figure 3. Northeast Greenland National Park (map from Aastrup et al. 2005)

The Ministry of Environment and Nature is responsible for the administration of all protected areas in Greenland, including the Northeast Greenland National Park. Applications for prospecting, exploration and exploitation of minerals in the national park are administrated according to the Mineral Resources Act.

The future management of the national park is currently being discussed within the Greenland Government. A number of reports have been prepared which present new information about the occurrence of flora, fauna and habitats in the national park, most notably Aastrup et al. (2005), Aastrup & Boertmann (2009), and Boertmann & Nielsen (2010). Pertinently, it has been proposed to divide the national park into three levels of management:

1. Species specific core areas (i.e. “biodiversity hot spots”) which are often of small size and with vaguely defined borders (eg. muskoxen range);

2. Fauna and flora protection areas which are larger areas often with many specific core areas or special nature types; and 3. The national park outside the specific core areas and the fauna and flora areas.

According to these anticipated management levels, the proposed Project would be managed within Level Three as it is located outside any species specific core areas and fauna protection areas (Figure 4).

Figure 4. The fauna and flora protection areas in the northern part of the national park (Aastrup & Boertmann 2009)

The fauna and flora protection area closest to Citronen Fjord is Area 16 (Figure 5). This includes a number of species specific core areas for the following species of fauna: muskoxen, pink-footed goose, light-bellied brent goose, ivory gull and Arctic char. It also includes the grass Puccinellia bruggemanni. Given the distances (> 50km) to the nearest core areas and fauna and flora areas, the Project is unlikely to impact on the flora and fauna in these areas.

Figure 5. The position of species specific core areas for mammals, birds and the grass Puccinellia bruggemanni in Fauna and Flora protection area No 16. (Aastrup & Boertmann 2009)

3.2 International obligations

Greenland has ratified a number of international conventions regarding nature and biodiversity, through its membership of the Danish Realm (Denmark with Greenland and the Faroe islands). Greenland also participates in different forums of international cooperation. The conventions and international forums include the following:

• The Convention on Biological Diversity (CBD) on the conservation of biological diversity, sustainable use of its components and fair and equitable sharing of benefits arising from genetic resources.

• The Washington Convention/ Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) on sustainable trade of endangered plants and animals.

• The International Whaling Commission on conservation of whale stocks including to set limits on the numbers and size of whales which may be taken.

• The Ramsar Convention on the protection of wetlands of international importance.

• The Conservation of Arctic Flora and Fauna (CAFF) which is the Biodiversity Working group of the Arctic Council with the mandate to address the conservation of Arctic biodiversity, and communicate the findings to the governments and residents of the Arctic, helping to promote practices which ensure sustainability of the Arctic's living resources.

• The North Atlantic Marine Mammal Commission (NAMMCO) is an international body for cooperation on the conservation, management and study of marine mammals in the North Atlantic.

• The Canada/Greenland Joint Commission on Conservation and Management of Narwhal and Beluga (JCNB) collects information and gives recommendation regarding the maximum annual catch of Narwhal and Beluga.

• International Union for Conservation of Nature (IUCN) is an international organisation dedicated to natural resource conservation. IUCN publishes a "Red List" compiling information from a network of conservation organisations to rate which species are most endangered.

• UNESCO’s World Heritage Convention a global instrument for the protection of sites of cultural and natural heritage. In 2004 Ilulissat Icefjord was admitted onto UNESCO's World Heritage List.

• UNESCO’s World Network of Biosphere Reserves which covers internationally-designated protected areas, known as biosphere reserves including the Man and Biosphere reserve program (MAB).

• Convention on the Conservation of Migratory Species of Wild Animals (BONN Convention) is an inter-governmental treaty that aims to conserve terrestrial, marine and avian migratory species throughout their range.

• United Nations Framework Convention on Climate Change (UNFCCC) is an international environmental treaty where developed countries are required to take measures aimed at stabilising greenhouse gas concentrations in the atmosphere and to provide assistance to developing countries. • Agreement on Conservation of Polar Bears. An international agreement between the states of the Arctic region, which protects polar bears in the circumpolar countries.

• Circumpolar Eider Conservation Strategy aims to protect eiders in the circumpolar countries.

Of these obligations, the Ramsar convention, the CBD IUCN and the UNESCO World Network of Biosphere Reserves are of particular relevance to the project, as discussed below:

The Ramsar Convention - Greenland has designated 11 Ramsar sites. These areas are to be conserved as wetlands and should be incorporated in the national conservation legislation however this has not yet been applied in Greenland. Two of the sites are located inside the Northeast Greenland National Park (Kilen and Hochsletter) (Figure 6). These wetlands of international importance are located more than 300 and 800km respectively, from Citronen Fjord. No impact is anticipated due to the large distances between the Ramsar sites and the Project area.

Figure 6. The location of Ramsar sites 10 and 11 inside Northeast Greenland National Park. (Aastrup & Boertmann 2009)

The Convention on Biological Diversity - guides national strategies and policies and implements themes such as sustainable use and precautionary principles. Its application to the Project will be through the implementation of national laws and regulations, particularly, the Mineral Resource Act.

International Union for Conservation of Nature - lists threatened species status (the IUCN Red List). A number of species from this list are found in the Project area. The status of these species in the Project area is described in Section 5.8.

UNESCO’s World Network of Biosphere Reserves - includes the Northeast Greenland National Park in which the Project is situated. The UNESCO biosphere reserves are found in different countries across all the regions of the world and are meant to demonstrate a balanced relationship between man and nature (e.g. sustainable development).

3.3 Shipping Regulations

See Section 6.7.1.

4 EIA PROCESS

4.1 EIA Guidelines for mine operations

The MLSA has issued guidelines on preparing an Environmental Impact Assessment (EIA) report for mineral exploitation. The guidelines list a number of topics and issues that must be covered during the EIA process. These include:

• An environmental baseline study which includes collection of two to three years pre-mining baseline data;

• Preparation of a detailed plan (Plan of Study) for the EIA process that should be submitted to BMP prior of start of the process and which includes a table of contents;

• The EIA must cover the following: non-technical summary, introduction to the Project, description of the environment, a description of all phases of the mine project, an assessment of environmental impacts, an environmental management plan, an environmental monitoring plan, comments from the public hearing, conclusions and references;

• The EIA should include a description of the chemical composition, acid generation potential and ecological toxicity tests for the ore, waste and tailings;

• The chemical concentrations should be compared to international guidelines that are agreed with MLSA;

• Disturbance of the natural environment needs to be assessed; and

• The public should be involved throughout the process.

4.2 Plan of Study

In June 2010, Ironbark engaged environmental consultants Orbicon to prepare a Draft Plan of Study for the EIA. The aim of this document was to provide the MLSA with sufficient information to enable it to approve the proposed EIA process for the Project, as required by the MLSA’s EIA Guidelines. The Plan of Study included a brief description of the Project, a table of contents for the draft EIA, a list of studies already undertaken in the Citronen Fjord area and other studies relevant for the EIA process, a list of studies that would be carried out in 2010 which will provide essential information for the EIA report and a technical memorandum describing the planned geochemical testing.

In addition to the studies already undertaken in the Citronen Fjord, the Plan of Study proposed that the following additional studies were carried out:

1. Geochemical studies - A geochemical testing program to determine the potential for acid rock drainage and metal leaching associated with the Project waste rock, lean ore and tailings. 2. Toxicological testing - A toxicological testing program to identify the concentration levels of potentially toxic materials within the tailings effluent to aquatic organisms. 3. Modelling of dust dispersal - A model for anticipated dust dispersal will be prepared. 4. Hydrology study - Data on the water flow and water chemistry in rivers and streams will be collected in order to calculate the annual run-off. This will make it possible to determine baseline metal concentrations in the Eastern River, specifically zinc prior to any mining activities in the catchment area. 5. Study of arctic char - Data on the distribution of the arctic char within the Project region will be collected. The survey will include the lower parts of Eastern and Esrum Rivers and Lake Platinova, where trout has previously been observed.

In June 2010 confirmation was received from the MLSA (BMP) that the Plan of Study was approved. The additional studies have subsequently been implemented and included in the EIA.

4.3 Public hearing

Following preliminary approval by the EAMRA this EIA will be made available for public comment. The report will be posted on the Government of Greenland website and will be made available as per the guidelines provided by the MLSA.

The exploitation licence and approvals can only be issued by MLSA after a thorough evaluation of the EIA is undertaken by EAMRA and Danish Centre for Environment and Energy (DCE) in cooperation with the Greenland Institute of Natural Resources (GINR). In addition, any affected organisations and authorities, as well as the general public, must have the opportunity to express their opinion on the assessment, as per section 61(1) and section 61(2) of the Act. Comments will be evaluated and considered for inclusion in the decision-making process, and will be included in the final version of the EIA report.

5 EXISTING ENVIRONMENT

The MLSA requires two to three years of environmental baseline studies to adequately characterise an area prior to project start (BMP, 2007). Prior to 2010, two years of detailed baseline studies have been completed in the Citronen Fjord area in 1994 and 1997 (Glahder and Asmund, 1995 and Glahder, 1998, respectively), as well as a reconnaissance study in 1993 (Glahder and Langager, 1993) and marine water sampling in Citronen Fjord in the winter of 1995 (Johansen and Asmund, 1995).

In 2010, Ironbark and Orbicon conducted another baseline study of the Project during the summer months July- September (see Appendix 1).

A description of the baseline studies conducted in the Citronen Fjord area to date is presented below, with sample collection summarised in Table 1:

1. Glahder and Langager (1993) – Reconnaissance survey of Citronen Fjord conducted in 1993 aimed at examining the characteristics of the area and gathering information to design the baseline study. Information gathered included depth soundings (maximum 80m) of Citronen Fjord, measurements of water flow in Eastern and Esrum Rivers, fresh and marine water samples, observations of fauna, mapping of areas with closed vegetation and collection and identification of 48 higher plant species in the Citronen Fjord area.

2. Glahder and Asmund (1995) - The first environmental baseline study, conducted in July and August of 1994, included sampling of water and sediment from Eastern and Esrum Rivers, four marine water column stations from Citronen Fjord (0, 2, 5, 10, 15, 20, 30, 50, 75 and 100m depths) and 30 surface stations, marine sediment from Citronen Fjord, one fish species from Citronen Fjord (fourhorned sculpin – Myoxocephalus quadricornis), seaweed from Citronen Fjord (Laminaria sp.) and opportunistic mussels attached to the holdfasts of seaweed, higher plants (Dryas integrifolia, Salix arctica and Poa sp.) and animal scats (collared lemming - Discrostonyx torquatus, arctic hare -Lepus arcticus and muskoxen - Ovibos moschatus). In addition, observations of flora and fauna were recorded from the Citronen Fjord area and water flow measurements were taken from the Eastern River to allow calculation of water discharge.

a. Fresh water samples from Eastern and Esrum Rivers were analysed for zinc, with selective samples also analysed for cadmium, lead and copper. Marine water samples taken at various depths were analysed for zinc, cadmium, lead and copper. Selective samples of seaweed (Laminaria sp.) and the livers of fish (M. quadricornis) were

analysed for zinc, cadmium, lead, copper and mercury. All other samples are stored frozen at DCE (Denmark) and are yet to undergo analysis.

3. Johansen and Asmund (1995) - Work focused on continuing and extending water sampling within the marine water column of Citronen Fjord to capture seasonal variation of metal concentrations by sampling in April. Eastern River water samples were also collected by DCE in the summer of 1995 for analysis of zinc concentrations.

4. Glahder (1998) - The second environmental baseline study was conducted from 31 July to 13 August 1997. Samples types were collected as per the 1994 baseline study, with the exception of sediment from Citronen Fjord and surface marine water. Water samples and measurements of water flow were also taken from the Eastern River as per 1994. All water samples (marine and fresh) were analysed for zinc concentrations only. Remaining samples are held by DCE.

5. Ironbark 2010 baseline study - The third environmental baseline study of the Citronen Fjord area (Appendix 1) was undertaken in 2010 by Ironbark and Orbicon . This was closely based on previous baseline studies undertaken by Glahder and Asmund (1995) and Glahder (1998). The following samples were taken:

a. Citronen Fjord - Four marine water column stations - 0, 2, 5, 10, 15, 20, 30, 50, 75 and 100m depths (or to maximum depth); b. Eastern River and Esrum River – water and sediment. Permanent stations in Eastern River and Esrum River from 2 June – 18 August to capture variations in metal concentration; c. Lake Platinova - Sediment and water; d. Marine fish - four-horned sculpin (Myoxcephalus quadricornis) and arctic char (Salvelinus alpinus) (livers) from Citronen Fjord; e. Seaweed (Laminaria sp.) from Citronen Fjord; f. Soil samples from five stations located around the Citronen Fjord area; g. Higher plants - arctic willow (Salix arctica), entired-leafed mountain avens (Dryas integrifolia) and purple saxifrage (Saxifraga oppositifolia); h. Animal scats of arctic hare (Lepus arcticus) and muskoxen (Ovibos moschatus); i. Observations of flora and fauna; j. Meteorological data has been collected since 2008 - parameters include wind direction, wind speed, dry-bulb temperature and precipitation; k. Reference samples were collected from two sites along Frederick E. Hyde Fjord that are considered unlikely to be affected by the proposed mining activities. The use of reference sites enables changes due to implementation of the Project to be distinguished from natural changes and potential changes due to other human

influences. The two sites are Depot Bay, located approximately 20km to the east of Citronen Fjord and FEHF (West), located approximately 2km to the west of the Citronen Fjord mouth. Samples consisted of marine water column, marine sediment, seaweed (Laminaria sp.), soil, higher plants (S. arctica, D. integrifolia, S. oppositifolia), animal scats (L. arcticus and O. moschatus) and physico-chemical data.

All marine and fresh water samples were analysed for a full suite of metals and major ions. A representative selection of marine and freshwater sediment samples from 1994, 1997 and 2010 are currently being analysed for selected analytes. All other samples are currently stored at DCE prior to analysis.

Table 1. Summary of sample collection for all baseline studies at Citronen Fjord.

Sample Type 1994 1995 1997 2010

Eastern River water X X X X Esrum River water X X X Lake Platinova water X Lake Platinova sediment X Eastern River sediment X X X Esrum River sediment X X X Marine water (CF) X X X X Marine sediment (CF) X Higher plants X X X Animal scats X X X Seaweed X X X

Fish X X X

Soil X X X

Reference marine water column X

Reference sediment (marine) X

Reference seaweed X

Reference plants X

Reference animal scats X

Reference soil X

Fauna observations X X X

5.1 Climate

Limited data exists from the Citronen Fjord region because climate data was only recorded during a few years in the mid 1990’s and from 2007 to present. However, the overall weather regime is invariably very similar to Kap Moltke in South Peary Land 110km south of Citronen Fjord for which data from 1973 – 2002 was recently published (Mortensen 2003). The weather station at Kap Moltke is situated on the shore of the Independence Fjord. There is midnight sun from mid-April to early September and total darkness from mid-October until late February.

The annual average temperature at Kap Moltke is -14.7°C and the average temperature for the warmest month, July, is 5.5°C. The average temperature for the three coldest months, January, February and March, are -30.3°C, -30.2°C and -29.9°C, respectively. The lowest temperature recorded at Kap Molthe during 1973-2002 was -46.1°C.

Precipitation (primarily snowfall) has not been recorded at Citronen Fjord or at Kap Moltke. At Station Nord, 270km south-east of Citronen Fjord, the average annual precipitation is 190mm and precipitation at Citronen Fjord is probably in the same order of magnitude, i.e. between 100 and 200mm per year.

Figure 7 shows the wind speeds and directions at Citronen Fjord based on data from November 2008- July 2009 and July 2010-September 2010. Storms were normally recorded only during autumn and winter and were from a southerly or northerly direction. The winds from the south were typically relatively warm and dry Foehn winds from the ice cap, which caused the temperature to rise by 10- 20°C in a relatively short time.

Figure 7. Wind Rose based on wind measured at Citronen (Nov 2008-July 2009 and July 2010-Sept 2010)

5.2 Topography

The proposed Project is situated at Citronen Fjord in Peary Land, North Greenland. Citronen Fjord is a small branch of the Frederick E. Hyde Fjord and is situated at 83 degrees North and 28 degrees West (Figure 8). Peary Land is uninhabited by humans. The nearest settlement is Qaanaaq, in north-west Greenland almost 1,000km away. A small military and scientific base, Station Nord, is located 240km south-east of Citronen Fjord.

Figure 8. Citronen Fjord in Peary Land, North Greenland

The Project lies at the head and east shore of Citronen Fjord in the junction of two glacial valleys in which the Esrum and Eastern Rivers run, and surrounded by bare mountains up to 1,000m high. The glacial valleys are filled with glacial till, which has been eroded in benches while the bases of the mountain slopes are covered with scree taluses. The Citronen Fjord itself is a drowned glacial valley. Most of the area is below 600m with higher mountains crowned by local glacier caps reaching over 1,100m.

The Citronen Fjord area is comprised of extensive barren landscapes with bedrock and boulder fields. There are extensive areas of patterned ground, stone rings, creeping soil and solifluction on most of the slopes towards Citronen Fjord. Permafrost is widespread in the Citronen Fjord area and extends to depths of several hundreds of metres. On the ground, evidence of permafrost is visible with frost boils and patterned ground being common.

5.3 Geology

The Citronen zinc-lead deposit is hosted by sediments of the Lower Palaeozoic Franklandian Basin (Figure 9). The deposit is interpreted to be of Sedimentary-Exhalative type (SEDEX) and syn- depositional with sedimentation at formation. The geology of northern Greenland is contemporaneous to that of parts of north-eastern Canada, which also hosts several large base metal deposits of SEDEX and Mississippi Valley Type deposits.

Figure 9. Geological stratigraphic column of Citronen Fjord

Stratiform sulfides are hosted by the Upper Ordovician–Lower Silurian Amundsen Land Group. This Group is comprised of mudstones, cherts, interbedded in places with turbidites and calcareous carbonate conglomerates of inferred debris flow origin. The carbonate debris flows are useful stratigraphic markers and are present at Citronen Fjord between all major sulfide horizons. The stratigraphic column highlights periods of massive sulfide deposition in relation to regional geology.

Erosion within the immediate fjord area and along the Trolle Land Fault Zone, which extends to the south-east of the deposit, has exposed a large cross-section thickness of the geology in the Project area (Figure 10). Within the central beach area the ‘eroded valley’ is overlain by glacial till- unconsolidated rock referred to as overburden.

Figure 10. Local geology at Citronen Fjord (refer to Figure 9, stratigraphic column, for key).

5.3.1 Deposit Types

Citronen Fjord is an example of Sedimentary-Exhalative type (SEDEX). SEDEX deposits are formed in submarine environments by the precipitation of sulfides from metal bearing fluids, introduced onto the seafloor through underlying fractures, which act as metal-bearing fluid conduits. Large amounts of sulfur are precipitated (principally as pyrite) and focused around vent areas or ‘mounds’ on the sea floor. Zinc and lead-bearing sulfides at Citronen are located as laminate horizons within these larger sulfide accumulations.

5.3.2 Mineralisation

Ore mineralisation is pyrite dominated with variable amounts of sphalerite ((Zn/Fe)S) and to a lesser extent galena (PbS) present as sulfide species. Minor chalcopyrite (CuFeS2) has been documented as interpreted to be formed during remobilisation and enrichment of primary stratiform hosted mineralisation. No economically significant copper (Cu) or silver (Ag) has been identified associated with massive sulfide mineralisation. Primary mineralisation (massive sulfides) are generally fine to medium grained, weakly to moderately laminated and bedded parallel with regionally deposited sediments. Gangue mineralogy is silt and clay from mudstones deposited contemporaneously with sulfide mineralisation.

There are three separate areas of mineralisation currently identified (Figure 11):

• Discovery – where the mineralisation was first discovered outcropping at surface. Level 1, 2 and 3 sulfides are present and are shallow in nature;

• Beach – underneath the main beach area at the head of the fjord. Level 1, 2 and 3 are present within the area. Mineralisation predominantly exists within the Level 2 and 3 horizons, which are at 110 and 180m below surface respectively; and

• Esrum – underneath the Esrum River and adjacent hillside. Mineralisation is predominantly level 2 and level 3 sulfides, which are the same horizons as present at Beach and Discovery zones.

Mineralisation at Citronen is drilling constrained and intercepts indicate that Beach and Esrum are contiguous in nature.

A comprehensive geotechnical assessment of the mine design has been completed to ensure the mine can be operated safely and be compatible with the surrounding natural structures at Citronen including the fjord (portions of the mine will be below sea level). To ensure a safe working environment, mining will only occur within allowable distances from the ocean to maintain a frozen section of ground between the mine and the fjord. The conditions within the mine will be in-situ, ie frozen. There will be no heating of the mine air.

Figure 11. Zones of mineralisation at Citronen

5.4 Soils

Areas with impeded drainage in the Citronen Fjord area have moist soils with accumulations of organic matter apparent in some areas, such as those of deciduous dwarf shrubs such as Salix arctica. Compared with other terrestrial ecosystems, arctic shrub tundra ecosystems have a high proportion of microbially fixed nutrients in the soil, in relation to the amounts fixed in the vegetation (Jonasson et al., 1999). This is because most arctic ecosystems have large deposits of nutrient-containing soil organic matter and low plant biomass, with the release of nutrients from the soil organic matter being slow because of environmental constraints to decomposition, paired with high nutrient immobilisation by the soil microorganisms (Jonasson et al., 1998 and Shaver et al., 1996).

The Citronen Fjord area contains extensive areas of patterned ground, stone rings, soil filled cracks and rock outcroppings. The areas that are able to support soils are inhabited with arctic tundra shrubbery, with roots close to the surface of the hard soil. Soils are mainly thin (< 5cm) and gravelly, typically accumulating along the river valleys, in close proximity to Citronen Fjord or other wind protected areas capable of sustaining moist soils.

5.5 Permafrost and Groundwater

The project area is in a location of continuous permafrost. In general, the top of the permafrost, the frost table, is considered to be approximately one metre below terrain during July and August. This equates to an active layer with a maximum thickness of approximately one metre. The extent of the active layer will depend upon the soil condition; for example, the summer active layer could reach thicknesses of up to approximately 1.5m in coarse material such as gravel. During the cold season the frost table is near or at terrain and the active layer is completely frozen. Thermistors were installed at the Project area during 2010, which identified sub zero temperature up to 180m depth.

In regions of continuous permafrost the frost table location can have a large impact on the water regime. Intact permafrost is an impenetrable water boundary. During the cold season the frost table is approximately at terrain which prevents infiltration. As the season warms, the frost table moves into the soil/gravel as the active layer develops. Snow melt and precipitation infiltrate into the active layer and travel laterally (roughly parallel to both the ground terrain and the frost table).

During the warmest months when the active layer has reached its maximum extent, a large percentage of precipitation can be conveyed through the active layer and attenuate the river storm water hydrograph/peak flow. The annual freeze/thaw cycle also influences the contact time between water and rock and the resulting water quality.

5.6 Surface Water Resources

Due to the very low precipitation in Peary Land (approx. 200mm/year), wetlands are few and limited to sites where slopes and soil conditions retain water from melting ice runoff in the upper layers. There are numerous streams throughout the area which mainly flow in the period of snow melt in June-July.

5.6.1 Lake Platinova

Lake Platinova is the only freshwater lake in the immediate vicinity of the Project. This is a small, rounded depression, fed by precipitation and melting of the active layer surrounding the lake. The current volume of the lake is approximately 0.5 million m3. The maximum depth is approximately 11m and the lake is ice free in summer.

An interconnecting flood channel indicates that the Eastern River receives inflows from the outlet of Lake Platinova during flood periods, however the passage of water in the channel is limited due to the low annual precipitation, and the channel typically remains dry for most of the season. The lake has a sedentary population of arctic char.

5.6.1.1 Lake Platinova – Water Quality

Table 2 indicates the baseline water quality of Lake Platinova in comparison to water quality guidelines for Greenland and Canada. The concentrations of all metals are low, with all water parameters for the lake below the guideline levels.

Table 2. Metal (total) and nutrient concentrations from Lake Platinova at 0, 6 and 10m depths compared to Greenland Water Quality Guidelines (BMP 2011) and Canadian Council of Ministers of the Environment (CCME, 2007).

Parameter (µg/L) Lake Platinova CCME BMP 0 m 6 m 10 m (2007) (2011) Zinc <0.5 <0.5 2.1 30 10 Lead <0.1 <0.1 0.1 1-7 2 Iron 0.013 0.01 0.044 300 30 Copper 0.2 0.2 0.4 2-4 3 Cadmium <0.005 <0.005 <0.005 0.017 0.2 Arsenic 0.1 0.1 0.1 5 5 Aluminum 17 14 34 5-100 NA Nickel 0.2 0.3 0.2 25-150 5 Total P <10 <10 <10 20 -

+ Ammonium (NH4 ) <20 <20 <20 - -

- Nitrate (NO3 ) <10 <10 <10 - - *Water was sampled 17 August 2010.

5.6.2 Eastern River

The Eastern River runs through the Project area, crossing a large alluvial floodplain prior to entering Citronen Fjord. This Eastern River drains precipitation and groundwater following melting of the upper active layer, however the main water source is from melting of snow and ablation from local glaciers. Due to the rare rain events in the area, it is apparent that the direct runoff is mainly controlled by air temperature and solar radiation. This is illustrated by the marked increase in the 2010 Eastern River flow shortly after the average daily air temperature rises above freezing (Figure 12). The flow of the river is limited from June – November when temperatures are comparatively elevated. The water in the river is clear most of the time, but during warmer periods, the increased flow from the melting of local glaciers increases the turbidity.

Figure 12. Correlation between Stream Flow and Air Temperature.

The total water discharge estimated in Eastern River in 2010 was 15,671,648 m3. Flows commenced on 2 June (day zero), continuing for 106 days until 15 September. A maximum diurnal water discharge of 245,376 m3/day occurred on 26 July. It is noted however that the stream flow in Eastern River is not stable over the season due to the tendency for stream flows to be quite erratic as a result of the variation of melting as described above.

Water discharge estimates were much higher in previous baseline studies, with maximum diurnal discharge estimates of 3,500,000 m3/day in 1994 (Glahder and Asmund, 1995) and > 9,000,000 m3/day in 1997 (Glahder, 1998). Due to the difficulty in safely obtaining a water flow measurement in 2010, it is anticipated that the value for total water discharge could have +/- 25-50 error and hence must be considered a conservative value.

5.6.2.1 Eastern River – Water Quality

The Eastern River passes over sulfidic outcrops (i.e., gossan or showings) resulting in release of elevated concentrations of metals into the river and ultimately into the Citronen Fjord. Within the Eastern River Basin, hillslope runoff and shallow groundwater flow travel over and through the gossans before entering the Eastern River increasing the metal/metalloid load.

During the 1994 baseline study (Glahder and Asmund, 1995), a daily monitoring point in the Eastern River (V1) was established, and water samples were collected and flow measurements were conducted each day during the field season which lasted from June 8 through August 22, 1994. Freshwater and marine samples were analysed for total cadmium, copper, lead, and zinc. The mean total zinc concentration was 161 micrograms per litre (µg/L) over the field sampling period (Table 3).

Table 3. Eastern River Daily Total Metals Concentrations (1994, 1997, 2010).

units in µg/L Al As Cd Cu Fe Hg Ni Pb Zn Year 1994 Eastern River (V1) June 8 through August 22 #of Samples 18 17 19 76 Mean 0.91 2.2 0.86 161 Min (detect) 0.06 0.03 0.01 0.80 Max 2.1 7.5 2.8 2445 Median 1.0 2.7 0.74 5.1 Standard Deviation 0.60 2.0 1.0 414 Year 1997 Eastern River (V1) June 22 through August 11 #of Samples 26 Mean 13 Min (detect) 0.1 Max 37 Median 12.7 Standard Deviation 8 Year 2010 Eastern River (MP-05) June 2 through August 14 #of Samples 51 51 51 51 51 51 51 51 51 Mean 93.6 0.25 1.6 0.54 191.9 ND 1.2 1.2 463 Min (detect) 4.9 0.16 0.01 0.10 5.3 ND 0.05 0.03 0.6 Max 663.5 0.39 10.9 2.9 4025.4 ND 8.1 21.4 3657 Median 37.7 0.22 0.05 0.38 51.2 ND 0.16 0.15 5.5 Standard Deviation 148 0.10 2.9 0.52 595 ND 2.1 3.9 939 Notes: ND= Not detected, blank = not analysed.

At the beginning of the field season, zinc concentrations within the Eastern River were high (2.45 milligrams per litre [mg/L]) while flows were low (Figure 13). As the 1994 summer season progressed, flows increased and zinc concentrations declined by several orders of magnitude. These trends suggest that zinc and other metals are flushed from oxidized mineralised rock immediately upon contact with water (“first flush”) and concentrations decrease as a result of dilution.

Figure 13. 1994 Eastern River flow and total zinc concentrations.

During the 1997 field season (Glahder, 1998) the daily monitoring point in Eastern River (V1) was again established and provided a lower mean zinc concentration (13 µg/L) then the previous study and a maximum zinc concentration of 37 µg/L (Table 3). These results suggest that initiation of sampling on June 22 did not capture the first flush, and higher flow rates were already present in the Eastern River by the time daily sampling was initiated (Figure 14).

Figure 14. 1997 Eastern River flow and total zinc concentration.

The 2010 baseline monitoring, based upon previous studies, included a more rigorous analysis of water quality at select sampling locations across the site (Ironbark, 2010). Care was taken to sample at the same locations as previous studies whenever possible, however, the daily monitoring point in the Eastern River (MP-05) was moved slightly downstream (~ 50 m) from the previous sampling location (V1) towards the new bridge. The average total zinc concentration of 463 µg/L (Table 3) and maximum concentration of 3.66 mg/L are elevated compared to previous years which appears related to the lower flow in the Eastern River in 2010 (Figure 15 and Figure 16).

Figure 15. 2010 Eastern River flow and total zinc concentration.

Figure 16. Eastern River flow rates for 1994, 1997 and 2010.

Zinc concentrations in the Eastern River water samples from 2010 are shown in Figure 17 and compared to previous studies (1994, 1995 and 1997). Concentrations in 2010 show a similar trend to previous sampled years, with very high zinc concentrations following initial runoff early in the season.

4000

3500

3000

2500 2010 2000 1997 1500 Zinc (µg/L) 1995 1000 1994 500

0 0 10 20 30 40 50 Day

Figure 17 Comparison of zinc concentrations in Eastern River in 1994, 1995, 1997 and 2010.

In 2010 the Eastern River experienced spikes in zinc load (Days 1 – 12) which are attributed to the very high zinc concentrations observed in the Eastern River early in the season (maximum 3657µg/L). The maximum zinc load per day was 143.9 kg/day, observed on 10 June.

The cumulative zinc loading for the Eastern River is presented in Figure 18. In each year of monitoring a high concentration of zinc is evident during the initial flows of the river, again illustrating the early season flow containing the bulk of the zinc due to contact with gossan material. The total zinc load transported in the Eastern River from 2 June – 18 August 2010 is estimated between 770 and 900 kg.

Figure 18. Zinc loading to the Eastern River.

The natural concentration ranges of selected metals in the Eastern River in 2010 are presented in Table 4. The concentrations are compared to CCME (2007) and BMP (2011) water quality guidelines. The maximum concentrations of zinc, lead, iron, cadmium, aluminium and nickel in Eastern River are elevated compared to the guidelines.

Table 4. Metal (total) concentrations from Eastern River in 2010 compared to the Greenland Water Quality Guidelines (BMP 2011) and Canadian Council of Ministers of the Environment (CCME, 2007). Parameter Eastern River 2010 CCME (2007) BMP (2011) (µg/L) Zinc 0.3 - 3657 30 10 Lead 0.03 - 21.38 1 - 7 2 Iron 5.3 - 4025 300 30 Copper 0.10 - 2.86 2 - 4 3 Cadmium 0.00 - 10.86 0.017 0.2 Arsenic 0.01 - 0.39 5 5 Aluminum 0.1 - 663 5 - 100 - Nickel 0.05 - 8.11 25 - 150 5 Highlighted = above Greenland water quality guideline levels

5.6.3 Esrum Lake and River

Esrum Lake is situated about 25km from Citronen Fjord in the upper parts of the Esrum River Valley. This is a very different lake situated on the floor of a valley separating two local glacier caps on top of a higher mountain plateau. The lake is fed primarily by ablation from the surrounding glaciers.

The lake is drained by the Esrum River, which is situated west of the Project area, and ultimately leads to Citronen Fjord. Because the lake is mainly fed with water from glaciers the water has a high content of suspended solids (as has Esrum River). This river does not flow through any known zinc ore bodies and has lower zinc concentrations than the Eastern River.

At the upper reaches of Esrum River, a glacier flows down the valley to a confluence, blocking the Esrum River and forming an ice dam backing up to Lake Esrum. Following increases in solar radiation and temperature in the summer months, the melting of the glacier eventually undermines the ice dam, suddenly releasing the impounded water and flooding the Esrum River flood plain. It is not expected that mining activities will impact the Esrum Lake or River.

5.6.3.1 Esrum River – Water Quality

The natural concentration ranges of selected metals in the Esrum River in 2010 are presented in Table 5. The concentrations are compared to CCME (2007) and BMP (2011) water quality guidelines.

Table 5. Metal (total) concentrations from Esrum River in 2010 compared to the Greenland Water Quality Guidelines (BMP 2011) and Canadian Council of Ministers of the Environment (CCME, 2007).

Parameter Esrum River 2010 CCME (2007) BMP (2011) (µg/L) Zinc 0.54 - 4.38 30 10 Lead 0.039 - 0.47 1 - 7 2 Iron 20.5 - 392 300 30 Copper 0.22 -7.57 2 - 4 3 Cadmium 0.002 - 0.023 0.017 0.2 Arsenic 0.04 - 0.36 5 5 Aluminum 20.9 - 938 5 - 100 - Nickel 0.07 - 0.93 25 - 150 5 Highlighted = above Greenland water quality guideline levels

The maximum concentrations of iron, copper and particularly aluminium in Esrum River are elevated compared to the guidelines. The Esrum River contains low constituent concentrations (average and

maximum zinc concentrations of 2.0 and 4.4 µg/L, respectively) compared to the Eastern River suggesting that gossan runoff/seepage into the Esrum River is limited.

5.6.4 Gossan Puddles/ Gossan Creeks

Precipitation and meltwater runoff occasionally ponds and forms puddles or creeks on the gossans within the Eastern River Basin including gossans within and upgradient of the Discovery zone. These temporary water bodies appear to contribute metal load to the Eastern River during the summer months. The water chemistry associated with the temporary gossan puddles and creeks is highly variable (acidic to neutral pH) (Table 6).

Table 6. Temporary gossan water features pH.

Sample Location Date pH Main Eastern River-Upgradient of Gossan/showings 8/18/1993 7.7 Main Eastern -Within Gossan/showings 8/18/1993 7.7 Main Eastern River-Downgradient of Gossan/showings 8/20/1993 7.8 Main Eastern River-Downgradient of Gossan/showings 8/20/1993 7.8 Creek slowly flowing from Gossan/showing into Eastern River 8/23/1993 3.1 (Prior to Sample 2) Base Camp Lake(aka Lake Platinova) 8/23/1993 1.8 Brooklet from Showings/Gossan 8/1/1994 2.42

5.7 Marine Waters

5.7.1 Citronen Fjord

Citronen Fjord is a relatively small fjord that extends about 4km southwards from the Frederick E. Hyde Fjord. The fjord has been formed from early glacial activity, resulting in a valley flanked by mountains up to 1000m high on the western and eastern sides. The Eastern and Esrum Rivers flow into Citronen Fjord, forming deltas where they meet the fjord. Due to the extreme cold weather the fjord is ice-locked for most of the year.

A bathymetric survey of Citronen Fjord was carried out in 2010 (DHI, 2010). Depths exceed 100m in most of the fjord and in the northern part reached more than 200m (Figure 19). The western side of Citronen Fjord has a steeper slope than the eastern. The survey showed that the depth at the planned port side, in Citronen Fjord, is sloping gently outwards.

Figure 19. Bathymetry of Citronen Fjord (DHI, 2010).

5.7.1.1 Citronen Fjord – Water Quality

During the 1994 baseline study (Glahder and Asmund, 1995), four sampling stations, H1 – H4, were established in Citronen Fjord to collect water samples from multiple depths within the water column. The mean total zinc concentrations were similar in locations H1 – H3 at approximately 1.5 µg/L and higher at H4 at 4.6 µg/L (Table 7). No obvious trends in zinc concentrations with depth were observed at the Citronen Fjord sampling stations.

Table 7. Citronen Fjord water quality.

Total Zinc Concentrations (units in µg/L) 1994 1995 1997

Station: H1 H2 H3 H4 Station: H1 H2 H3 H4 Station: H1 H2 H3 H4 0 m - 0 m - 0 m - 0 m - 5 m - 5 m - 5m - 15 m - 0 m - 0 m - 0 m - 0 m - Depth: Depth: Depth: 30 m 30 m 50 m 100 m 25 m 50 m 90m 150 m 30 m 30 m 50 m 100 m Sample Sample Sample 7/29 7/29 7/29 7/29 7/1 7/1 7/1 7/1 8/11 8/11 8/11 8/12 Date: Date: Date: Count 7 7 8 10 Count 5 6 8 7 Count 7 7 8 10 Mean 1.6 1.2 1.4 4.6 Mean 6.7 4.3 4.3 5.3 Mean 1.5 2.4 2.4 2.6 Minimum 0.3 0.3 0.4 2.0 Minimum 4.9 3.0 2.1 2.7 Minimum 0.8 0.8 0.9 0.3 Maximum 2.4 2.5 3.3 9.2 Maximum 10.7 6.2 11.1 8.1 Maximum 4.8 7.0 5.8 11.5 Median 1.9 0.7 1.0 3.4 Median 6.1 3.7 2.9 4.8 Median 1.0 1.6 1.9 1.8 Standard Standard Standard 0.8 1.0 1.1 2.4 2.3 1.3 3.0 2.4 1.5 2.2 1.7 3.3 Deviation Deviation Deviation Total Zinc Concentrations (units in µg/L) 2010 Station: H1 H2 H3 H4

Depth: 0 m - 50 m 0 m - 75 m 2 m - 100 m 0 m - 100 m Sample 8/9 8/9 8/15 8/17 Date: Count 8 9 9 10 Mean 7.1 4.0 1.8 2.5 Minimum 1.6 0.7 0.1 0.0 Maximum 20.1 12.6 7.5 9.9 Median 5.3 3.2 0.7 0.8 Standard 6.3 3.5 2.4 3.9 Deviation

Similarly in the 1997 baseline study (Glahder, 1998), the four Citronen Fjord stations (H1 – H4) were sampled from multiple depths within the water column. The mean total zinc concentrations in the Citronen Fjord were approximately the same as during the previous study. In general, concentrations of zinc and other metals were higher near the surface of the fjord and decreased with increasing depth.

In 2010, zinc concentrations at the Citronen Fjord stations trended towards lower concentrations with depth with the exception of the samples collected from 50m deep. There is thermal stratification evident in the water column of Citronen Fjord (Figure 20), with the fresher surface waters showing higher temperatures than the lower denser waters.

Figure 20. Marine water stations H1–H4 in Citronen Fjord, showing concentrations of Zn, Cu, Pb and temperature with depth. Measurements were carried out in August 2010.

Table 8 shows the range in water column metal concentrations at four stations in Citronen Fjord (H1- H4) and two reference stations in Frederick E. Hyde Fjord. Depot Bay in Frederick E Hyde Fjord is located approximately 20km to the east of Citronen Fjord mouth, while FEHF (west) is located approximately 2km to the west. Concentrations of zinc, copper and lead in Citronen Fjord were found to exceed the MLSA guidelines at some depths and even in Frederick E Hyde Fjord metal concentrations above MLSA guideline levels were recorded in a few cases. A more comprehensive account of the water quality of Citronen Fjord is presented in Appendix 1.

Table 8. Ranges in marine water column metal concentrations in Citronen Fjord (H1 –H4) and reference stations (Depot Bay and Frederick E. Hyde Fjord West) compared to Greenland Water Quality Guidelines (BMP 2011) marine water quality limits.

Parameter Citronen Fjord Depot FEHF BMP (µg/L) H1 H2 H3 H4 Bay (2011) Zinc 1.6 – 20.1 0.7 – 12.6 0.1 – 7.5 0.02 – 9.8 0.8 – 3.4 0.2 – 7.5 10

Copper 2.2 – 6.7 1.3 – 6.1 0.3 – 9.7 0.4 – 4.4 0.5 – 4.2 0.4 – 2.1 2

Lead 0.9 – 7.5 0.5 – 6.2 0.2 – 7.7 0.1 – 1.2 0.2 – 1.9 0.2 – 4.2 2

Cadmium 0.02 – 0.02 – 0.1 0.01 -0.05 0.01 –0.07 0.03 – 0.07 0.03 – 0.07 0.2 0.04

Mercury 0.002 – 0.001 – 0.001 – 0.001 – 0.001 – 0.002 – 0.05 0.003 0.004 0.004 0.004 0.003 0.004 Nickel - 1.1 - 1.2 1.3 – 1.6 - 1 – 1.4 1.3 – 2.3 5

*Water sampled in August 2010. Depths ranged 0 – 100m. Highlighted = above Greenland water quality guideline levels

5.7.2 Wandel and Greenland Seas

The shipping route will be through Citronen and Frederick E. Hyde Fjords and out into the Wandel and Greenland Seas (Figure 21). The Wandel Sea is a body of water in the Arctic Ocean, stretching from north east of Greenland to Svalbard. Seas farther north and north west of the Wandel Sea are frozen year-round. The Wandel Sea stretches as far west as Cape Morris Jesup. In the south, it stretches to Nordostrundingen. Further south is the Greenland Sea.

The Greenland Sea is a body of water that borders Greenland to the west, the Svalbard Archipelago to the east, Fram Strait and the Arctic Ocean to the north, and the Norwegian Sea and Iceland to the south. The sea has Arctic climate with regular northern winds and temperatures rarely rising above 0°C.

Figure 21. Location of Wandel and Greenland Seas.

Major islands of the Greenland Sea include the Svalbard Archipelago, Edvards, Eila, Godfred Hansens, Île-de-France, Jan Mayen Lynns, Norske and Schnauders. Of those, only the Svalbard islands are inhabited, and Jan Mayen has only temporal military staff.

The climate is Arctic and varies significantly across the vast sea area. Air temperatures fluctuate between –49°C, near Spitsbergen in winter, and 25 °C off Greenland in summer. Averages are –10 °C in the south and –26 °C in the north in February, which is the coldest month. The corresponding values for the warmest month, August, are 5 °C in the south and 0 °C in the north. The summer is very short, as the number of days per year when the temperature rises above 0 °C varies between

140 in the south to 31 in the north. The annual precipitation is 250 mm in the north, but is twice as high in the south.

The most significant feature in the physical marine environment is the presence of icebergs and sea ice throughout the year. Because of frequent fogs and winds and currents, which continuously transport ice and icebergs through the Greenland Sea to the south, the Greenland Sea has a narrow window for commercial navigation.

5.7.3 Sea Ice

5.7.3.1 Fast Ice

Fast ice is a form of sea ice which is fastened to a shore. Fast ice covers all the fjords and a shelf along the outer coast of north Greenland most of the year. This includes Citronen Fjord and Frederick E. Hyde Fjord. In recent years the sea ice in Citronen Fjord has thawed during late July and the fjord has been free of fast ice during much of August. Occasionally Frederick E. Hyde Fjord becomes more or less ice free, as was observed in 2010. The fast ice belt off the coast only breaks up infrequently, and usually blocks the mouth of Frederick E. Hyde Fjord throughout the summer (Boertmann 1996).

5.7.3.2 Drift and Pack Ice

Drift ice is sea ice that floats on the surface of the water. When the drift ice is driven together into a large single mass, it is called pack ice. Off the east coast of Peary Land, a long wide stretch of open water (a lead) usually develops during summer in the shear zone between the shore fast ice and the drift ice. To the north-east of this lead, multi-year polar drift ice covers the ocean. The drift ice consists of a mixture of multi-year and first-year ice with scattered icebergs from the glaciers on the coast. The drift ice is transported south along the coast by the East Greenland Current.

5.7.4 Icebergs

Icebergs in the Greenland Sea originate from glacial outlets. They are different to sea ice as they are primarily comprised of fresh water and because of this the majority of the iceberg is submerged under water unable to be seen. It is for this reason that they present a considerable hazard for ships.

Icebergs from the north east Greenland glaciers generally move southwards along the coast, where they are transported by the East Greenland Current.

5.7.5 North East Water Polynya (NEW)

The North East Water (NEW) is a polynya off the north east coast of Greenland (Figure 22). A polynya is an area of open water surrounded by sea ice that occurs seasonally at the same time and place each year. The NEW typically begins to open in April and closes in September. However, even during winter cracks and leads of open water are present.

Figure 22. Location of the North East Water (NEW) off the east coast of Greenland. The area of open water varies considerably during the years but also between years. The black line marks the protection zone for marine mammals (narwhals, bowhead whale and walrus) in the northern part of east Greenland.

The extent of the NEW varies considerably from year to year. In spring it typically extends from the Nordostrundingen at app. 81° N, 11° W and southwards to the Henrik Krøyer Holme which is three small islands situated at 80° 38’ N; 13° 43’ W (Figure 23). Later during the summer the borders are less well defined as a large area of open water typically develops off the northeast coast of Greenland (Figure 24).

North East Water

Greenland

Figure 23. Ice off north east Greenland May 26, 2008 (Boertmann & Nielsen 2010). Blue represents open water. Purple and red indicate high ice concentrations, yellow and green low concentrations.

North East Water

Greenland

Figure 24. Ice off north east Greenland July 26, 2008 (Boertmann & Nielsen 2010).

The predictability of the NEW makes it important habitat for birds and mammals. There are several breeding and non-breeding seabird colonies that occur throughout the open water parts of the NEW or on the cliffs along the shore close to the NEW. During the shipping period in summer (July-August), breeding and non-breeding fulmars (Fulmarus glacialis) are the most susceptible seabirds to

disturbance, as they have been recorded in low densities throughout the NEW in summer and leave the NEW shortly before it freezes over again in September. The fulmar is not listed on the Greenland Red List of threatened species (Boertmann 2007).

Walruses, ringed seals and small numbers of polar bears are present in the NEW throughout the year. From May to June, when larger areas of open water appear, other marine mammals migrate into the NEW. Bearded seals and narwhals are common and widespread throughout the NEW in August and relatively large numbers of bowhead whales have been recorded from the NEW and the sea just off the NEW in recent years. There are a number of marine mammals that are listed on the Greenland Red List of threatened species which occur in the NEW. The bowhead whale is listed as Critically Threatened, the polar bear as Vulnerable and the walrus as Near Threatened. Narwhal and bearded seal are both listed as Data Deficient.

A more comprehensive description of the NEW is provided in Appendix 3 – The biological importance of the North East Water polynya, NE Greenland.

5.8 Flora and Fauna

The Citronen Fjord is situated in the High Arctic Region, defined as the area with very low precipitation, four months of semi-darkness during winter and a very short and cold growing season. As such, the Citronen Fjord region is an extremely harsh environment that supports only a small number of plant and animal species adapted to these most extreme conditions.

For the purpose of this EIA, higher plants, seaweed and vertebrates have been used as a guide to the overall biodiversity of the area. Within Greenland, these flora and fauna elements are best known in terms of habitat requirements, diet, and sensitivity to disturbance and pollution. An annotated list of all species of higher plants, birds, mammals and fish recorded from the area is included in the 2010 baseline survey (Appendix 1).

5.8.1 Flora

The vegetative cover in Peary Land, including the Citronen Fjord region, is sparse and discontinuous. A study in 1988 of the vegetation cover in North Greenland north of 74 degrees north using NOAA satellite images showed that only in a few places did the vegetation cover exceed 8%. The amount of vegetation cover in Peary Land in August 2004 monitored from multispectral satellite data in August 2004 (Normalised Difference Vegetation Index (NDVI) calculation) show that the Citronen Fjord region has particularly sporadic plant cover with low NDVI values, indicating low amounts of green vegetation (Figure 25).

Citronen

Figure 25. Map showing NDVI-values (Normalised Difference Vegetation Index) from northeast Greenland in Aug 2004. Increasing NDVI values indicate increasing amounts of green vegetation (from Boertmann & Nielsen 2010).

Field observations in the Citronen Fjord area in August 2010 confirmed that the overall vegetation cover is very low and that large expanses have virtually no vegetation at all. Continuous vegetation is limited to lowlands below 300m (Aastrup & Christensen, 1986) and only where water is available during the summer months. Such areas include slopes under snow-patches and along rivers, lakes and ponds (Møller et al., 2004) and are almost exclusively found along the shore of the fjord and along the Esrum and Eastern river valleys.

With less than two months of summer-vegetative growth and very low precipitation, only the most cold-hardy plant species can grow in the Citronen Fjord area. This is most likely why only approximately 50 species of higher plant species so far have been recorded in this area (Glahder & Langager, 1993). However, this should be taken as a minimum since between 74 and 80 species have been recorded in areas in Peary Land that have had more extensive surveys (Glahder & Langager 1993).

The higher plant species known from the Citronen Fjord area consist of widespread and common species in Greenland that reach their most northern distribution at Citronen, as well as specific high- arctic plants with their distribution limited to north Greenland. Neither of the two vascular plants that are endemic to the national park (Potentilla rubella and Puccinellia bruggemanni) have been recorded at Citronen.

Arctic willow (Salix arctica), entired-leafed mountain avens (Dryas integrifolia) and purple saxifrage (Saxifraga oppositifolia) are among the most common and widespread plants species in the Citronen Fjord area. In wetlands, sedges (Carex spp.), cotton grass (Eriophorum spp.) and bellardi bog sedge (Kobresia myosuroides) are the dominant species. The diversity of plants is higher at wind protected sites with permanently moist soil during the growth season and typically includes mountain sorrel (Oxyria digyna), bulbous saxifrage (Saxifraga cernua) and lacerate dandelion (Teraxacum arcticum), as well as various species of grasses. Such “green spots” are found in the Eastern and Esrum River valleys, south of Lake Platinova and along the shore of Citronen Fjord. These areas of continuous vegetation cover are likely feeding grounds for mammals (muskoxen, arctic hare and collared lemming) and birds (ptarmigan and staging geese).

5.8.2 Fauna

5.8.2.1 Birds

Seventeen species of birds have been recorded from the Citronen Fjord area. Of these, eight breed or are believed to breed occasionally in the area. Most notably among the non-breeding bird species are large numbers of geese that spend the summer in Peary Land. In winter (October – February) no birds are found at Citronen Fjord. Birds that occur regularly in the area during summer are described briefly below. All of these birds occur throughout large parts of the national park. A more comprehensive description is provided in Appendix 1.

Divers Red-throated diver (Gavia stellata) breeds in small numbers throughout Peary Land and is a regular visitor to the Citronen Fjord region between late June and mid-September.

Geese The pink-footed goose (Anser brachyrhynchus) is a common non-breeding summer visitor to north Greenland. The geese arrive in late June and depart late August to mid- September. Few geese occur in the Citronen Fjord region during summer but many flocks of migrating geese pass over the area in June-July and late August to mid-

September. The geese, which stop-over to rest in the Citronen Fjord region, have mainly been recorded from the shore of the Citronen Fjord and in the Eastern River and Esrum River valleys where they feed on sedges and grasses.

Ptarmigans The ptarmigan (Lagopus mutus) is a widespread and relatively common breeding bird in the Citronen Fjord region, although numbers fluctuate between years. The ptarmigans migrate southwards during the darkest months leaving the Citronen Fjord region in late September – October and returning in February.

Skuas and gulls The long-tailed skua is a regular visitor, breeding in the Citronen Fjord area where breeding has been recorded near Lake Platinova in the mid-1990’s and in 2008-2010. The skuas are migratory arriving in late May and leaving in August-September. On the breeding ground the skuas feed mainly on lemmings. The glaucous gull (Larus hyperboreus) is a regular visitor to Citronen Fjord outside the winter period. No breeding sites are known from the area.

Waders (shorebirds) Four species of waders occur regularly in the Citronen Fjord region. The ringed plover (Charadrius hiaticula) is the most numerous and widespread wader with several pairs breeding at gravel-beds in association with lakes, rivers and estuaries in the Citronen Fjord region. Knot (Calidris canutus) is the least common of the waders that breed at Citronen Fjord with only a single record from 1997. Sanderling (Calidris alba) is a relatively common breeding bird in the Citronen Fjord region, typically breeding on dry coastal tundra. The ruddy turnstone (Arenaria interpres) breeds in small numbers at Citronen Fjord usually close to the coast. The four species of waders arrive to Citronen Fjord during late May and early June and leave in August – beginning of September.

Passerine birds The snow bunting is widespread in the Citronen Fjord region but the breeding population is small with the pairs widely scattered in the valleys and along the shore of the fjord. The buntings arrive in late April and leave again in September-October.

5.8.2.2 Mammals

Six terrestrial and one marine mammal occur throughout the year in the Citronen Fjord region. The polar bear is an uncommon visitor to the Frederick E. Hyde Fjord, but has so far never been recorded at Citronen Fjord. A more comprehensive description is provided in Appendix 1.

Ringed seal The ringed seal (Phoca hispida) is a common marine mammal in Citronen Fjord throughout the year. Breeding takes place in spring when the pups are born in snow dens on the sea ice. Ringed seals are opportunistic feeders and prey on a wide variety of fish and invertebrates.

Muskoxen Muskoxen (Ovibos moschatus) occur throughout the Citronen Fjord area but it is generally a low density species and the population is believed to be small. The findings of both summer and winter scats along the shore of the Citronen Fjord and in the adjacent valleys indicate that muskoxen regularly feed in these areas throughout the year. The calves are born in late winter.

Wolf The wolf (Canis lupus) is a rare inhabitant in Greenland, limited to the North and north east. It has been observed most years in the Citronen Fjord region in recent decades but the numbers have fluctuated widely from year to year. Wolves are resident in north Greenland.

Arctic fox The arctic fox (Alopex lagopus) is the most common and widespread carnivore in the Citronen Fjord area, however the population is small most years. The fox is mainly found along the coast and in valleys. It is an opportunistic feeder, but in years with many collared lemmings they will prey almost exclusively on this species during the summer.

Polar bear The polar bear (Ursus maritimus) is an uncommon visitor to the fast ice of Frederick E. Hyde Fjord during spring but no bears have been recorded within the Citronen Fjord area. The bears observed in Frederick E. Hyde Fjord are most likely vagrants from the population off east and northeast Greenland.

Stoat The stoat (or ermine) (Mustela erminia) is a terrestrial predator belonging to the weasel family. It has only been observed a few times in the Citronen Fjord area. It is highly dependent on collared lemmings and its numbers fluctuate with this.

Arctic hare The arctic hare (Lepus arcticus) is a relatively common and conspicuous mammal in the Citronen Fjord area, although the hare population shows large fluctuations in numbers.

Collared lemming The collared lemming (Discrostonyx torquatus) is the only rodent in the Citronen Fjord area and it has a cyclic population dynamic typically being abundant every four years and rare in other years. However, rather few observations have been made in the area and it may be less common even in peak years than in other parts of Greenland.

5.8.2.3 Fish

Only two fish species are known with certainty to occur in the Citronen Fjord area: arctic char and four-horned sculpins. It must be assumed that at least some of the additional nine species of fish that have been recorded in Jørgen Brønlund Fjord in South Peary Land also occur in Citronen Fjord (Glahder & Langager 1993).

Four-horned sculpin The four-horned sculpin (Myoxcephalus quadricornis) is very common in Citronen Fjord where it inhabits shallow waters during summer.

Arctic char There is a small freshwater resident (non-anadromous) population of arctic char (Salvelinis alpinus) in Lake Platinova. No arctic char have been recorded from rivers in the Citronen Fjord area, however several arctic char from a seagoing (anadromous) population has been caught in Citronen Fjord (Appendix 1). The natal river of these arctic char is unknown.

5.8.3 Fauna – Greenland Sea

The marine life of the Greenland Sea has the typical properties of Arctic oceans with low biodiversity but often very numerous and dense animal populations. The food web from primary producers to top predators is relatively simple.

A very significant event in the Arctic marine environment is the spring bloom of planktonic algae which are subsequently grazed upon by large numbers zooplankton, including copepods of the genus Calanus. Calanus copepods are key prey species of many small fish, in particular Arctic cod and polar cod, as well as several seabirds and marine mammals. The occurrence of the seabirds is governed by

the presence of sea ice, which is why they are scarce in large regions in summer and almost absent in winter but, on the other hand, very numerous in areas with predictable open waters in spring and summer.

A very specialised community also exists on the underside of the drifting sea ice where algae live in or on the ice. The algae are grazed upon by copepods which are eaten by the two cod species, the polar cod (Boreogadus saida) and the Arctic cod (Arctogadus glacialis). Due to their abundance in the Greenland Sea these cod species are also very important food items for seabirds, whales and seals. Seabirds and marine mammals are mainly found in the NEW polynya (see 5.7.4). The polar bear, which mainly feed on seals, is the top predator in this ecosystem.

The Danish Centre for Environment and Energy (DCE) at Aarhus University conducted an assessment of the impact of hydrocarbon activities on the north east coast of Greenland (The Western Greenland Sea - A preliminary strategic environmental impact assessment of hydrocarbon activities in the KANUMAS East area - NERI Technical Report no. 719, Boertmann et al. 2009). This assessment area is within close proximity of the intended shipping route for the Project. Hence it has been considered as a fair representation of the biological environment of the proposed shipping route and has been used in the descriptions of marine fauna below.

5.8.3.1 Birds – Shipping Route

Approximately 15 species of seabird are found within the assessment area. During summer large numbers of these birds occur, primarily due to the absence of sea ice and the increase in the amount of open water. Some species are still categorised as rare or threatened due to small numbers found in other parts of Greenland. The NEW polynya hosts significant breeding colonies, as do other polynyas in the assessment area.

Northern Fulmar Breeding colonies occur within the assessment area, mostly on the coastal cliffs and the shores of the NEW. Fulmars are widespread within the assessment area however occur at low concentrations. Fulmars are surface feeders, with fish and crustaceans making up most of their diet. Fulmars have a favourable conservation status within the assessment area.

Common Eider The common eider occurs in high numbers in the assessment area. Breeding eiders are found on the coast and also on small islands. In the spring eiders will congregate together

prior to the moulting season in the summer. Once moulting is over they are flightless and are considered to be at their most vulnerable. Eiders feed off the seabed, diving down to reach mollusks, crustaceans and echinoderms. The common eider has a favourable conservation status.

Kittiwake Kittiwakes are described as pelagic seabirds that only visit the coast when breeding. Concentrations in the assessment area are generally low although they can be found in larger concentrations in late summer. The kittiwake diet consists of small fish such as polar cod and crustaceans, obtained from the water surface. In contrast to its national conservation status of ‘threatened’, the kittiwake population in east Greenland is increasing (Gilg et al. 2005).

Sabine Gull The sabine Gull breeds on small islands within open waters, often alongside Arctic terns. They colonise the low islands from late May and leave in August once the chicks are fledged. They are most sensitive during this time in the breeding colony. The sabine gull is classified as ‘Near Threatened’ on the Greenland Red list. They feed on small fish and invertebrates from the surface of the water.

Ivory Gull The ivory gull has a high conservation value, and it is red-listed due to its small global population. The most important area for ivory gull is the NEW polynya and along shore leads. It occurs in migration concentrations on the drift ice, in breeding colonies and in feeding concentrations during summer. They are surface feeders, however they also take advantage of food left by polar bears and from human activities.

Glaucous Gull The glaucous gull is the most widespread and common breeding seabird within the coastal part of the assessment area. Breeding occurs during the summer months on either steep cliffs or on low islands generally in conjunction with large numbers of other seabirds. The gull has a favorable conservation status. Usually confined to the coast, glaucous gulls are omnivores and feed on other small seabirds, eggs and chicks. Rubbish from human activities will also form part of their diet if available.

Ross’s Gull Ross’s gull is listed as vulnerable on the Greenland National Red list. It is a rare species, with only two known breeding sites in Greenland, one being in the NEW polynya. Not much is known about this gull, however breeding is assumed to occur on the coast

Arctic Tern Arctic terns are surface feeders. Concentrations are mainly found at the breeding colonies along the coast, adjacent to polynyas. There are also breeding pairs inland at lakes. In east Greenland the species has a favourable conservations status, however is listed as ‘Near Threatened’ on the national red list due to population decline in west Greenland.

Thick-billed Murre Thick-billed murre (the breeding population) has an unfavourable conservation status and the Greenland population is red-listed. Concentrations occur in summer at the breeding colonies (only at the Scoresby Sund polynya) and at feeding grounds. Murres occur both in coastal and offshore waters. They are not in large numbers in the NEW. Murres are diving birds that spend a lot of time on the water surface.

Little Auk Little auk is the most numerous seabird in the assessment area. The majority occur near the Scoresby Sund polynya where the breeding colonies are. The conservation status of this breeding population is favourable. Millions of birds from breeding population at Svalbard also move through the assessment area during spring and summer and could potentially be disturbed. Little auks feed on large pelagic crustaceans, primarily copepods.

Black Guillemot Black guillemots are categorized as of ‘Least Concern’ on the national red list. It is a common breeder on coasts near the Scoresby Sund polynya. They breed on the coast cliffs. Black guillemots feed on fish and invertebrates, diving down to the kelp beds on the shore. Offshore they feed on fauna found among the ice.

5.8.3.2 Mammals – Shipping Route

There are 19 species of marine mammals found in the assessment area consisting of seals, whales, walrus and polar bear. The mammals are dependent on the open waters for breathing and feeding. As such, the polynyas and lead zones are critical habitat for these animals.

Polar bear Polar bears are of international and national conservation value. Polar bear numbers are variable both seasonally and annually largely due to fluctuations of ice density and prey availability. The NEW polynya is an important feeding and breeding area for polar bears (Aastrup & Boertmann 2009). Many breeding dens are found along the coast and the bears feed on seals on the sea ice, mainly close to the shore (Figure 45). When the NEW opens the bears are found along the edges, however in July-August few seem associated with the NEW (Boertmann et al. 2009 and Boertmann & Nielsen 2010).

Walruses The walrus population on the east coast of Greenland is probably more or less isolated. Walrus is classified as Near Threatened on the Greenland Red List. It is moreover a resource for the people living near Scoresby Sund. The conservation status of the population is favourable as it shows signs of improvement, as they are protected within the national park. Hunting of walrus occurs at the southern edge of the park, near Scoresby Sund. There are several important concentration areas on the eastern coast of Greenland: terrestrial haul-outs and spring/winter concentrations areas in some polynyas. The movement north of adult male walruses and their wintering in the Northeast Water area indicate that this polynya is an important wintering and mating area.

The most important walrus areas in the assessment area are the uglits (haul-out spots), (Sandøen and Lille Snenæs) their surrounding waters, the summer concentration areas (coasts of Hovgaard Ø, Amdrup Land and Kilen) and winter concentration areas (shallow parts of the NEW and the Wollaston Forland polynya) (Figure 46). It is well documented that walruses, particularly when hauled out on land, are sensitive to disturbance, including sailing, traffic on land, and flying (Born et al. 1995).

Seals

Four species of seals occur along the shipping route. Two resident species, the ringed seal (Phoca hispida) and the bearded seal (Erignathus barbatus), and two which perform extensive seasonal migrations, the hooded seal (Cystophora cristata) and the harp seal (Phoca groenlandica). The seals are classified as Least Concern on the Greenland Red List, except for the bearded seal which is classified as Data Deficient.

Harp seal The Harp Seal is a relatively common seal within the assessment area and is listed as of ‘Least Concern’ (LC) on the Greenland and the global Red Lists. Harp seals perform long seasonal migrations between whelping and moulting grounds in the drift ice and summer feeding areas in more or less ice-free waters. Harp seals assemble in large concentrations, and whelp and nurse their pups on drift ice in March–April (the lactation period is 10–12 days). Harp seals mainly feed on polar cod, capelin, krill and amphipods.

Hooded seal This is a large migratory seal which, like the harp seal, assembles in whelping and moulting areas on the ice. Whelping takes place late March-early April and hooded seals nurse their pups for only a few days. Numbers of Hooded seals were greatly reduced by Norwegian hunters after World War Two and have not recovered to original population numbers. However Greenlanders are still allowed to hunt these seals for subsistence. Hence the conservation status is unfavourable but listed as of ‘Least Concern’ (LC) on the Greenland Red List.

Ringed seal This is a small seal adapted to life in ice-covered waters. It can maintain breathing holes in thick winter ice and gives birth in lairs made in snowdrifts associated with its breathing holes. The ringed seal is common and widespread in the assessment area, both in the fjords and in the drift ice off the coast. The main breeding habitat is considered to be coastal fast ice and consolidated drift ice. The ringed seal is listed as of ‘Least Concern’ (LC) on the Greenland Red List. Ringed seals differ from hooded and harp seals as they do not form whelping colonies and as such as less sensitive to disturbance.

Bearded seal The bearded seal is a large seal and are usually associated with dynamic drift ice. The bearded seal is believed to have a uniform and widespread distribution although are not as numerous or common as ringed seals. They are listed as ‘Data Deficient’ on the Greenland Red List. They are hunted year round in the Scoresby Sund polynya.

Baleen Whales

Baleen whales occurring in the assessment area include bowhead whales and five species of rorquals (the family Balaenopteridae): blue whale, fin whale, minke whale, sei whale and humpback whale. The most significant baleen whale species in relation to shipping is the bowhead whale.

Bowhead whale The bowhead whale population in eastern Greenland (the Spitsbergen Stock) is very small and is classified Critically Endangered by the IUCN list. Recent observations (not yet published) in combination with the observation of a calf in 2009 (Boertmann & Neilsen 2010) indicate that the NEW polynya is particularly important to bowhead whales.

Minke whale Minke whales are relatively small whales compared to the other species of rorquals. Minke whales feed on a large variety of prey and their distribution and numbers is most likely due to variations in the abundance and distribution of prey. The population occurring in the assessment area has a favourable conservation status. Both the global Red List (IUCN 2008) and the Greenland Red List categorise the minke whale as of ‘Least Concern’ (LC).

Sei whale Sei whales are found all over the world, moving seasonally between high latitude and tropical waters. Their distribution appears to be unpredictable, regularly occupying waters one year and then not seen the following years. They feed on small fish, krill, squid and copepods. It is not known to what extent sei whales use the assessment area, but they probably occur within the same areas as fin whales as these two species are often found together. Sei whales are classified as ‘Data Deficient’ (DD) on the Greenland Red List.

Blue whale The blue whale is the largest animal in the world. Their diet consists mainly of krill. Blue whales occur frequently in the waters between Iceland and Greenland (south of the assessment area). Their most important feeding grounds in the North Atlantic are in eastern North America (St. Lawrence Bay, Newfoundland, Labrador) and the Greenland Sea / Denmark Strait area, including waters from northern and western Iceland and the waters of the assessment area (east of the drift ice). The population occurring in the assessment area has an unfavourable conservation status, due to heavy commercial whaling in the early 1900’s. Blue whales are categorised as ‘Data Deficient’ (DD) on the Greenland Red List.

Fin whale Fin whales are common and widespread within the assessment area. They have a global distribution from temperate to polar waters however are less common in the tropics. Fin whales feed on krill and fish such as herring and capelin. Fin whales occur in the

assessment area mainly off the east side of the drift ice and mainly in the summer and autumn. Fin whales are categorised as ‘Endangered’ on the global Red List however in the North Atlantic they are abundant and the population here has a favourable conservation status, listed as of ‘Least Concern’ on the Greenland Red List. Fin whales are not hunted in the assessment area.

Humpback whale Humpbacks are widely distributed and occur seasonally in all oceans. Krill and small fish are their primary diet. Humpbacks migrate between mid- and high-latitude summer feeding grounds and tropical or subtropical winter breeding and calving grounds. The importance of this species in east Greenland is unknown due to limited studies done. However, numbers in the assessment area are increasing and as such is listed as of ‘Least Concern’ on the Greenland Red List. In the 1980’s Humpback whales were protected on a world-wide basis.

Toothed whales

Five species of toothed whale are common in the northern North Atlantic: killer whale, pilot whale, white-beaked dolphin, bottlenose whale and sperm whale. The distribution of these species is not restricted to the Arctic. All are found in boreal waters, and sperm and killer whales occur in all oceans. Moreover, they all avoid densely ice-covered waters, so their use of the assessment area is restricted to the ice-free months. With the expected reduction in sea-ice cover due to climate change, they may become more frequent and stay for longer times in the assessment area (Boertmann et al., 2009). Besides the five widely spread species of toothed whales mentioned above, there is one exclusively Arctic toothed whale found off eastern Greenland: the narwhal.

Narwhal Narwhals are High Arctic mammals that feed primarily on Greenland halibut. Narwhals migrate from the shallow fjords in summer to deep ice-covered waters in the winter and area present in the assessment area. Narwhal skin and tusks are traded in Ittoqqortoormiit and Tasiilaq and hence are important for hunters. Narwhals are protected within the Northeast Greenland National Park and are considered to have a favourable conservation status.

Long-finned pilot whale Long-finned pilot whales observed in the assessment area are likely to be roaming individuals that belong to the known large north Atlantic population. They feed primarily

on squid but also on fish such as cod and herring. Pilot whales are occasionally caught by hunters from Tasiilaq and Ittoqqortoormiit. The long-finned pilot whale is listed as ‘Data deficient’ according to the IUCN (2008) Red List.

White-beaked dolphin White-beaked dolphins are the most common dolphin off south east Greenland, in Denmark Strait and the seas around Iceland (Reeves et al. 1999). White-beaked dolphins’ prefer shallow waters (less than 200m deep). Their diet consists mostly of small schooling fish such as herring, capelin, lesser sandeel and cod. Migration patterns are unknown. In Greenland, white-beaked dolphins are caught for subsistence. They are listed as ‘Least Concern’ on the Global Red List.

Killer whale The killer whale is the top predator in all oceans. Their diet is varied, with different populations specialising in local prey items which can range in size from herring to blue whales. They occur in almost all areas of Greenland however are generally absent in coastal areas. In Greenland, killer whales are hunted for food but also as they are considered as competition to human hunters. Killer whales are listed as ‘Data Deficient’ on the global Red List.

Sperm whale Sperm whales are the largest toothed whale, and the third largest animal in the world. They are found in all oceans. Fish and cephalopods are their primary diet. Commercial whaling depleted some stocks of these whales during the 19th and 20th centuries. Commercial whaling of this species in the north Atlantic ceased in the 1980’s. On the Greenland Red List, sperm whales are listed as ‘Not Applicable’ and globally as ‘Vulnerable’ (IUCN 2008).

Northern bottlenose whale Next to the sperm whale, the northern bottlenose whale is the largest toothed whale in the north Atlantic. Bottlenose whales feed on squid and fish but also prawns, starfish and sea cucumbers. They are found in deep waters. The Red List status of the northern bottlenose whale is ‘Data Deficient’ on the global list, and ‘Not applicable’ on the Greenland list.

5.8.3.3 Fish – Shipping Route

There are limited studies on the presence of non-commercial fish in east Greenland. Some 26 species have been recorded on the northeast Greenland shelf. These fish are a likely source of food for many Arctic animals and would play an important part on the ecology of this region. The most important species have been described below.

Greenland halibut The Greenland halibut is an Arctic (or sub-Arctic) flat-fish that lives mainly in deep water along continental slopes. In winter the halibut spawns a large number of eggs which once hatched drift with currents to nursery areas. It does occur in the assessment area but not in large numbers. Greenland halibut is commercially fished.

Polar cod Polar cod is a pelagic or semi-pelagic species occurring in coastal waters, often in association with sea ice. It is generally found in cold Arctic waters. Between November and February, Polar cod spawn their eggs which remain under ice until late spring once the ice starts to melt. Their main diet consists of copepods, amphipods and small fish. Polar cod are common prey for several marine mammals and seabirds in the assessment area.

Capelin The capelin is common small cold water fish in the northern hemisphere. Common diet items include plankton, krill and crustaceans. In the spring and summer these fish migrate northwards for feeding and to spawn, returning back again between September and November. Capelin is an important forage species for several commercial fish, whales and seabirds, particularly on their southwards migration.

Arctic char The Arctic char is widespread in Greenland and has a circumpolar distribution. They are of two types: resident and anadromous populations. Resident populations live exclusively in either lakes or rivers whilst anadromous populations will migrate out to sea in the summer, returning in the autumn to spawn. Arctic char are considered a valuable food source for Greenland people. Small fish, larvae, zooplankton and crustaceans make up the primary diet for sea going populations.

5.8.4 Threatened Species

Four animal species occurring in the Citronen Fjord area are listed on the regional Greenland Red List of threatened species (Boertmann, 2007):

• Wolf is listed as Vulnerable because of its small (< 1000 animals) population in Greenland; • Polar bear is listed as Vulnerable because its small population is declining; • Ivory gull is listed as Vulnerable because of its very small and declining population (approx. 2,000 adults) in Greenland; and • Arctic tern is listed as Near Threatened because of its large decline in Greenland.

The polar bear and ivory gull are also on the International Union for Conservation of Nature (IUCN) Red List of threatened species (Table 9).

Table 9. Fauna species occurring in the Citronen Fjord area which are on the Regional Greenland Red List and IUCN Red List of Threatened Species.

Importance Main habitat Greenland Period of of Citronen Species Status in Citronen red-list IUCN red List occurrence Fjord to area status population Rare/ Wolf uncommon Year-round Throughout Vulnerable Not listed Low resident Uncommon Polar visitor to Sea ice Spring Vulnerable Vulnerable Low bear Frederick E (coastal) Hyde Fjord

Ivory Occasional Pack Near May-October Vulnerable Low gull visitor ice/coastal threatened

Arctic June- Near Rare visitor Coastal Not listed Low tern September threatened

Except for the wolf, the red-listed species recorded from the Citronen Fjord area are uncommon or rare visitors with no known breeding grounds in or near the fjord. Small numbers of wolves seem to occur in the Citronen area throughout the years and a pack might some years have bred in the area. However the Citronen area is not known to be of particular importance for wolf or any of the other red-listed species.

5.8.5 National Responsibility Species

The Greenland Red List also recognises a number of national responsibility species. These are species where more than 20% of the global population occurs in Greenland and for which Greenland therefore has a special responsibility to protect. Four national responsibility species have been recorded from the Citronen Fjord area (Table 10).

Table 10. National Responsibility Species that occur in the Citronen Fjord region.

Percentage of total world Status in Citronen Species population in Greenland (%) Fjord area Uncommon visitor to Polar bear (Ursus maritimus) > 20 Frederick E. Hyde Fjord Pink-footed goose (Anser brachyrhynchus)1 > 30 Common summer visitor Knot (Calidris canutus) > 50 Uncommon breeding bird Arctic redpoll (Carduelis hornemannii) > 50 Occasional visitor

5.9 Socio and economic setting

5.9.1 Local inhabitants and their use of the area

Peary Land has been uninhabited for the last 600 years. The nearest Greenlandic settlement (and the northernmost settlement in the world) is Qaanaaq in north west Greenland, 940km from Citronen Fjord. Peary Land, including Citronen Fjord, is not used for fishing, hunting or other human activities by the Greenlandic population or people from other nations. This is due to the remoteness and the fact that sea ice covers the ocean around North Greenland most of the year.

A small military and scientific base, Station Nord, which includes a landing strip (but no port) is situated on the north east coast of Greenland, 240km from Citronen Fjord. The base has a permanent staff of five people.

Further information regarding demography and the uses of Peary Land are discussed in a separate Social Impact Assessment (SIA), including an Impact Benefit Plan and Impact Benefit Agreement as required by Greenland Government.

1 Iceland/East Greenland breeding population

5.9.2 Archaeology and cultural heritage

Two Paleo-Eskimo cultures of humans are known to have previously lived in northern Greenland. The Independence I culture, named after the Independence Fjord, flourished in northern and northeastern Greenland from 2,400 to 1,000 BC. The Independence II culture arose in the same place in the 8th century B.C., roughly 600 years after the disappearance of Independence I, but then disappeared around 80 BC.

During the Medieval Warm Period (c. 1,000 – 1,300 AC) the Thule culture, that is the ancestors of modern Inuit, expanded briefly to inhabit much of north Greenland during a 100-200 year period. Since the Thule Culture left, the region has been without human habitation.

Archaeological traces are widespread in Peary Land; in particular, “tent rings” (stones arranged in a ring to stabilise a tent made of skins) as well as stone and bone artefacts such as knives and needles are present.

In July of 1994, the Greenland National Museum and Archives conducted an archaeological survey of the Citronen Fjord area (Kapel, 1994) to ensure that no protected sites or other archaeological interests would be affected by exploration activities undertaken by Platinova A/S at the time.

The archaeological survey covered an area of 6.5km², including the river delta, investigating the eastern side of Citronen Fjord to Frederick E. Hyde Fjord, and the Eastern and Esrum River valleys to a distance of 4-5km from Citronen Fjord.

No evidence of former Eskimo settlements were found within the area, with the only sign of potential pre-historical activities being a site on the eastern shore of Citronen Fjord, marked as “A2” in Kapel (1994). This site comprises of three stones arranged in a row, and may have been placed by members of the Thule culture to support an “umiak” – an 8-10m long open boat used in summer to move people and possessions to seasonal hunting grounds.

In subsequent discussions with the Greenland National Museum and Archives, they have expressed that the Kapel (1994) report sufficiently characterises the archaeology of the Citronen Fjord area. However, prior to works, there is a need for an archaeological registration and documentation of the probable anthropology structure (A2) and near surroundings.

In the 2010 field season, the A2 site was located during the environmental baseline studies. The structure(s) were photographed, measured and a GPS location of the site was recorded. Prior to any

72 disturbance of the area, a staff member of the Greenland National Museum and Archives will further photograph and measure the A2 structure and 10-15m around the site as part of the archaeological registration and documentation of the site.

The site will be appropriately marked and all Ironbark staff and contractors will be made aware of the site. No disturbance of the site will take place prior to archaeological registration and documentation, and approval to disturb the site.

6 PROJECT DESCRIPTION

This section provides details of the construction, mining, processing and associated facilities required for operations at Citronen. The site layout is presented in Figure 26 and Figure 27, which indicates the proposed locations for the respective facilities, infrastructure, and roads.

6.1 Construction

Construction work is estimated to take approximately 2 years. The construction work will consist of two phases. During the first phase the construction camp accommodation, fuel storage facility and communications will need to be established prior to mobilisation of the initial construction workers. Construction equipment and materials will be brought to site during the first shipping window. The port area will be completed.

The second phase comprises the remaining construction works. This includes the construction of the haul roads and access roads building of the processing plant, and construction of the tailings storage facility and pipeline.

The majority of the project facilities will be constructed utilising construction companies supplemented with specialists where required.

6.2 Mining

Mining production will occur at a rate of 3.3 million tonnes per annum (Mtpa). The mining operations will use standard industry techniques for hard rock mining based on the style of mineralisation, and proximity to the surface. The deposit is formed by three ore zones: Beach, Esrum and Discovery. Beach and Esrum occur at depths of 100-400m below surface and will be extracted using conventional trackless underground techniques. The Discovery ore zone is amenable to open pit mining due to its proximity to surface. The ratio of annualised production rates, for open pit to underground under the current proposal is a 50:50 split open pit to underground until the depletion of Discovery orebody. Mining thereafter will be sourced 100% from underground until year 13 at which point open pit mining would commence.

6.2.1 Underground Operation

45M tonnes of ore and waste will be extracted from the underground mine during its operational life of 14 years. Of this total extraction, approximately 44M tonnes of ore (Beach and Esrum) will be processed through the plant, the remaining 500,000 tonnes being development waste that will be

74 disposed of underground in existing stopes or mining panels, or where unavoidable at the surface waste dump. Access to the underground will be via a portal at surface level.

Mining thicknesses are a minimum of 4m height, up to a maximum of 30m thickness. Panels of ore in the range of 4m to 15m height will be mined using conventional room and pillar mining. Panels of 15m to 30m height will be mined using long hole stoping.

The mining schedule will be optimised for production and the fleet will be selected to ensure economies of scale. Equipment proposed is at the upper end of underground mining sizes/capacities, which affords economy of operations through reduced emissions, lower fuel consumption and minimisation of total truck kilometres travelled as compared to smaller equipment. Underground material will be transported using 60 tonne trucks. Proposed equipment is from leading international manufacturers who share the goal to increase efficiency in mining plant, through the use of cutting edge technology to maximise output with reduced fuel consumption and exhaust emissions.

Open pit

Concentrate Storage Fuel Storage Conveyor ROM Pad Fuel Eastern River Waste Station Dump

TSF Explosives Magazines

Power DMS Lake Plant Rejects Platinova Port Process Plant

Airstrip

Citronen Fjord Esrum River

Figure 26 The Citronen Project proposed mine layout

Figure 27 Layout of the processing plant and accommodation area.

6.2.1.1 Underground Dewatering

The assumption is made the mine will be dry except for the decanted water from the process tailings used underground for backfill. Submersible pumps will be used to pump mine water from ramp/drift headings and designated sumps on the levels in the event of local thaws, or to handle flush water from backfill operations that has not had time to freeze. Water will be pumped back into the processing circuit.

6.2.2 Open Pit Operations

The Discovery ore body hosts 9.2M tonnes of ore, which can be economically mined, in conjunction with 18M tonnes of waste. The discovery ore body is located at shallow depth and with variable topography. The open pit will not be mined until the last three years of the mine life.

Ore mined at the open pit and underground will be delivered by the mining trucks to temporary stockpiles located at the Run of Mine (ROM) pad for processing at the Citronen plant. Waste mined from the open pit and underground will be deposited at the waste rock dump north of the pit. During the return trip from the ROM pad the ore trucks will back haul DMS rejects from the processing plant to the DMS rejects dump.

Mining is proposed using benchmark equipment for an operation of this size - 90 tonne payload trucks using a 125 tonne excavator. Equipment will be sourced from leading manufacturers and suppliers to the global mining industry. In procuring modern equipment, Ironbark will ensure reliability in a remote environment, whilst also benefiting from the efficiencies of modern engines and electronic control systems thus reducing operating costs by reducing fuel consumption and accordingly reducing exhaust gas emissions.

6.2.2.1 Open Pit Dewatering

During mining of the open pit, water will be removed by either submersible or floating pumps. The volume of water is anticipated to be low. Surface water will be redirected around the pit by diversion bunding. Groundwater movement into the pit is also expected to be minimal due to the freezing ground temperatures. Water quality in the pit will be routinely tested and compared against guideline values. Water that does not meet guideline concentrations will be pumped to the processing plant for reuse. Water meeting guidelines values will be pumped to the Eastern River.

6.3 Ore Processing

Processing of ore at Citronen will undergo several stages: Crushing, Dense Media Separation, Milling, Flotation and Concentrate Dewatering. The primary crusher is located adjacent to the ROM pad and is a fully enclosed site installation. The process plant will be fabricated off site atop three separate barges that will be shipped to site and berthed adjacent to the crusher prior to final commissioning. The operational process plant will be enclosed within a single building providing a controlled environment, with heating and ventilation controls. All process facility ventilation will exhaust via baghouses (dust filtration), thus removing particulate matter from the process plant exhaust air. Internal drainage within the process building will be captured to sumps located within the floor and the water is recycled back into the plant water main.

6.3.1 Ore Transfer to ROM

The ore will be delivered by haul truck to the ROM area (Figure 27) and either direct dumped into the ROM bin or onto the ROM pad, then transferred by front end loader (FEL) to the ROM bin. The ore is fed by a vibratory grizzly feeder drawing ore from the ROM bin and feeding into the jaw crusher where it will be crushed.

The ROM pad will be built from stone fill/quarry material. The pad will be an elevated plateau, creating a self serving surface water diversion around the pad. Any drainage required on top of the pad will be diverted back into the process area for reclamation and reuse. Due to the low rainfall in the area (less that 200mm annually) this is not expected to be a significant volume. Dust generation will be minimised during material transfer by wetting down of surfaces as required.

6.3.2 Crushing

A two stage crushing process will reduce the ore size to fractions smaller than 38mm ahead of onward processing. The crusher hopper is located within an open fronted building, whilst the crusher itself is located adjacent to the hopper within a fully enclosed building that creates a controlled environment and enables the exhaust air to be filtered through baghouses to remove particulate matter.

6.3.3 Dense Media Separation

Due to the nature of the ore (banded sulphides) at Citronen, it is amenable to a dense media separation (DMS). Ore is reduced to suitable size fractions (<38mm - achieved through the preceding two stage crush) and processed through a cyclone or rotating drum which takes advantage of the specific gravity (SG) differences between the waste materials and the metal rich ore. The lighter waste is split from the heavier ore by maintaining a separating medium (incorporating milled ferrosilicon) at

79 a defined SG. The waste (DMS rejects) is removed from the process flow, and disposed of to a DMS rejects dump (approximately eight million tons). Ore continues onward through the process flow. The ferrosilicon material does not dissolve and hence will be recycled again and again by magnetic recovery as the ore continues through the process. Some ferrosilicon may exit through process in the following ways: it may become trapped in the pores and interstices of the ore and loss through the recovery circuit feed which is disposed in the tailings waste stream.

6.3.4 Milling

To enable further processing, the ore has to be further reduced in size so that an appropriate proportion of metal can be liberated during the subsequent flotation. Milling (comminution) at Citronen will be achieved through two mills in sequence plus regrinding to facilitate additional grinding on an as required basis.

6.3.5 Flotation and Reagents

Froth flotation is a common process for sulfidic ores. The flotation works by feeding milled material into an agitated water tank with the addition of standard flotation reagents. The reagents bind to the metals causing the matrix to become hydrophobic and float to the surface of the ‘cell’. Here they are suspended within a stable froth, prior to collection.

A preliminary, indicative list of the reagents to be used in the process is listed in Table 11. Due to changes in technology and mineral recovery techniques, it is possible that these specific reagents (and their consumption rates) may change, both prior to operations and during operations. Final reagent types and consumption rates required for approvals and applicable guidelines will be determined closer to the project commencing. Current Material Safety Data Sheets for the listed reagents (Table 11), were sourced from the supplier websites (see References, MSDS, and the corresponding website).

All reagents (except lime) will be supplied in small volume drums (205L) or bulky bags (1000kg) and will be transported to site in sea containers. These containers will be transferred to site and stored at the container storage area north of the process plant. The drums and bulky bags will be accessed directly from the containers as required. The lime will be stored within a bulk storage tank. All storage and containment will comply with relevant Greenland regulations for storage of hazardous materials.

The flotation waste stream is fine ‘tailings’ that are disposed of and contained within the Tailings Storage Facility. The tailings will contain any residual reagents either within the solid tailings component or dissolved in the supernatant. The concentration of reagents is likely to be a high

80 proportion of the consumption rate with the exception of copper sulphate2. The majority of the copper sulphate will bind with the zinc particles (the copper sulphate floats the zinc away from the waste) and exit the process within the ore concentrate (ie the product). No reagents will be released to the environment as they will be completely contained within the TSF. The concentration of reagents entering the process is very low (again, with the exception of copper sulphate) and has been illustrated as a percentage weight in Table 11. This percentage weight is for dry tonnes only and will be even less as the processing liquor also contains a significant amount of liquid, thus further reducing the overall percentage of reagent in the tailings stream.

Limited information is available on the environmental fate of reagents. Hydrous copper sulphate (activator) has potential bioaccumulation effect in living tissue (primarily due to the copper) and will bind readily to sediment. Burnt lime is found to have no bioaccumulation effect or food chain concentration toxicity. Tailings are not typically analysed for concentrations of reagents. This is primarily due to the extremely small quantities of the reagent compared to the tailings volume. In addition the reagents, if ever released into the environment, would be in a multi-chemical solution and individual effects on the environment would be impossible to assess.

2 The consumption of copper sulphate is estimated using a standard calculation for zinc processing and is based on volume copper sulphate per % zinc.

Table 11. Preliminary listing of processing reagents.

End point/ Reagent Chemical Type Form Consumption % weight* Toxicity/ Ecotoxicity destination

Dense FeSi Ferrosilicon milled 0.16 kg/t 0.016 Milled ferrosilicon is not anticipated to be toxic. Fe media Oral rat LD50 30,000mg/kg, Si Oral rat LD50 3160mg/kg

Depressant Dextrin modified starch powder 0.1 kg/t 0.01 No information found, not anticipated to be toxic.

Depressant CaLigno Calcium Lignosulphonat, powder 0.35 kg/t 0.035 Oral rat LD50 > 715 g/kg This material is expected technical, Borregarde R-SO3H to be toxic to aquatic life.

Contained within the Blocker D200 alcohol ethoxylate, monobutyl liquid Wsol 0.02 kg/t 0.002 Oral rat LD50 6560 mg/kg. No LC50 data available Tailings Storage Facility. ether blend however expected to be toxic to aquatic organisms.

Collector SEX Sodium Ethyl Xanthate Powder or 0.14 kg/t 0.014 Sodium ethyl xanthate has an acute oral (rat) LD50 pellets value of >800mg/kg.

Collector 9323 dialkyl dithiophosphinate neat liquid 0.13 kg/t 0.013 Oral rat LD50 > 5000 mg/kg estimated. No aquatic monothiophosphinate blend LC50 available.

Oral rat LD50 300 mg/kg. Activator CuSO4.5H Hydrous copper sulfate liquid 0.8 kg/t 0.08 Ore concentrate/ 2O LC50/96-hour values for fish are less than 1 mg/L. contained within Tailings The IC50/72-hour values for algae are less than 1 mg/L. (Toxicity data for copper). Storage Facility.

Frother IF6-3N polyglycol blend, C&MS neat liquid 0.02 kg/t 0.002 No information found. Discharge into waterways at large concentrations may affect aquatic life.

Flocculant Magnafloc Copolymer of acrylamide and Powder 0.05 kg/t conc Acute toxicity LD50 oral (rat) >2000mg/kg M10 sodium acrylate Toxicity to fish (Brachydanio rerio) h/LC50 357 Contained within the mg/L. Tailings Storage Facility.

Burnt Lime CaO Calcium Oxide solids sizing 1.75 kg/t 0.175 Because of the high pH of this product, at high 100% -3mm concentrations it would be expected to produce significant ecotoxicity upon exposure to aquatic organisms and aquatic systems. * Dry tonnes, excluding any liquid

6.3.6 Concentrate Dewatering

After flotation the froth is cleaned and the material dewatered through pressure filters to produce a concentrate cake. The concentrate is a fine grained ‘filter cake’ with 80% of particles passing 15um with the final product retaining approximately 8-10% moisture. The waste water is collected in the concentrate dewatering area and recycled back through the process plant. The concentrate is transported by conveyor to the concentrate storage shed prior to removal off site.

6.4 Concentrate Storage

Concentrate produced will be stored within a fully enclosed, heated concentrate shed. The concentrate is kept dry and contained prior to shipping to Iceland. Entrance to the concentrate shed is via a sealed door and the exhaust air from the shed is filtered through baghouses as per other process installations on site.

6.5 Mine Waste

The Citronen Project will produce three bulk waste streams: – 1. Waste rock; 2. DMS rejects; and 3. Tailings.

Waste rock is the by-product associated with the development and operation of underground and open pit mines. Waste rock comprises non-mineralised and mineralised waste - the latter being rock that contains mineralisation at a sub-economic grade (no contained value) or which for technical reasons cannot be treated. Waste rock at the Project will be stored in the waste rock dump.

DMS rejects are essentially a waste rock comprised of non/low mineralised rock of >1.5mm and <38mm size. The DMS rejects will be disposed to a DMS rejects dump.

Tailings are created as a consequence of the froth flotation separating the valuable metals from the remainder of the material. Tailings storage at Citronen will be via two methods. The first being disposal to a surface Tailings Storage Facility (TSF), and the second being disposal to the underground mine. Within the mine the tailings will be placed into mined voids as a thickened slurry which the ambient temperature will cause to freeze over time.

Mine waste will be managed such that any drainage or release to the environment resulting from mine wastes will comply with guidelines and limits as agreed between Greenlandic authorities and Ironbark.

6.5.1 Waste Geochemical Characterisation

Geochemical characterisation studies were conducted to develop an understanding of the potential for acid rock drainage and metal leaching of waste rock and tailings waste expected from the Citronen Project. A summary of the characterisation program is provided in Table 12. The full geochemistry of waste rock/lean ore, tailing and other materials including Dense Media Separation (DMS) Rejects, Prefloat Concentrate (Prefloat tailings), surface overburden (glacial till) and gossan samples are presented in Citronen Project Mine Waste Geochemical Characterisation, Tetra Tech July 2012.

Table 12. Sample quantities for each waste source for the geochemical characterisation program.

Geochemical Analysis

Kinetic Static Testing Testing Acid-base Synthetic Net Acid Sample Type Elemental Accounting Mineralogy Precipitation Generation Humidity Cell Analysis by (ABA) with (XRD and Leaching Testing (NAG Testing Four-acid Sulfur Optical) Procedure pH/Extract (HCT) Digestion Speciation (SPLP) Analysis)

Waste Rock 32 32 2 6 12/2 6

Tailings 3 3 3 _ _ 3 Composites

Other Materials 9 8 1 3 _ _

Thirty-two waste rock/lean ore drill core samples were largely selected from the open pit-amenable Discovery Zone which will produce the highest tonnage of waste rock to be stored on the surface. Two mineralised waste rock/lean ore samples were collected from the Beach Zone and one mineralised waste rock/lean ore sample was collected from the Esrum Zone.

Rougher and cleaner tailings subsamples obtained from recent flotation pilot testing and composited using a ratio of 40% cleaner tailings and 60% rougher tailings were also subjected to ABA. Additional details related to selection of other materials subjected to geochemical characterisation are provided in Citronen Project Mine Waste Geochemical Characterisation, Tetra Tech July 2012.

A summary of the testing results is included below in Section 6.4.1.

6.5.1.1 Acid-base Accounting

Acid-base accounting (ABA) is the most commonly used static test method to estimate the capacity of material to produce and neutralise acid. All samples were subjected to ABA with sulfur speciation. Table 13 provides a summary of the ABA results for all waste rock samples, waste rock samples selected for humidity cell testing, and tailings samples.

Sulfate sulfur is low in waste rock samples (< 0.07 wt %). The low sulfate sulfur content of most samples suggests minimal oxidation of pyrite has taken place to date. The sulfate content of the tailings samples is approximately 1% or less.

The Net Neutralisation Potential (NNP) as a function of total sulfur content (Figure 28) shows that the waste rock samples are generally categorised as net neutralising regardless of sulfur content whereas tailings samples are all considered likely to eventually generate acid. The results suggest that as the sulfur content of Citronen Project waste materials (e.g., waste rock, tailings, Prefloat tailings) increases above 8 wt. %, the samples become more likely to be classified as PAG.

Figure 28 . ANP/AGP as a function of total sulfur content.

Table 13. Statistical summary of acid-base accounting results

Net Neutralisation Pyritic Sulfide Sulfur Neutralisation Total Sulfur Insoluble Sulfur Potential (HNO 3 Extractable) potential ratio Sample Type Statistics NNP

ANP/ AGP (wt. %) (wt. %) (wt. %) (kg CaCO 3/Tonne)

Average 4.45 3.20 1.15 407.9 94.0

Median 1.16 0.91 0.30 322.7 20.0 All Waste Rock/ Lean Ore Samples (n= 32) Minimum 0.04 0.01 0.00 -474.4 0.4

Maximum 34.30 25.18 9.05 897.4 961.6

Average 9.23 6.94 2.27 256.1 5.7

All Humidity Cell Waste Median 8.8 6.965 1.81 174.3 1.8 Rock/Lean Ore Samples (n= 6) Minimum 1.38 1.13 0.25 -0.8 1.0

Maximum 21.4 15.23 6.12 851.1 25.1

HC-3; Beach/Esrum L3 31.11 25.96 4.81 -551.2 0.3 Tailings Composite HC-4; Beach L2 Tailings Not 33.21 25.61 7.44 -603.1 0.2 Composite Applicable HC-5; Discovery L1 Tailings 36.54 32.69 3.63 -752.7 0.3 Composite HC = Humidity cell, L = mineralised horizon level ANP/AGP ≥ 2 = unlikely to generate acid (non-PAG), ANP/AGP < 1 = potentially acid generating (PAG), ANP/AGP from 1 to 2 is in the uncertain range.

Using the NNP criteria to distinguish between non-PAG and PAG waste rock indicates that only one mineralised waste rock/lean ore sample is likely to generate acid. Figure 29 shows that two of the 32 waste rock/lean ore samples that have been subjected to ABA are identified as PAG using the ANP/AGP ≤ 1 and five samples are in the uncertain range (ANP/AGP > 1 and < 2). One sample is on the ANP/AGP cut-off at ANP/AGP = 1.0 having approximately equal acid generating and acid neutralisation potential. The sample was identified as PAG but also could be considered in the uncertain range.

Figure 29 Acid neutralisation Potential as a Function of Acid Generating Potential.

6.5.1.2 Humidity Cell Test Results

Humidity cell testing is an accelerated kinetic weathering test conducted at room temperature on < ¼ inch material. During the procedure, material is exposed to moist, oxygenated air which accelerates the weathering of sulfide minerals. On a weekly basis, the weathering solids are rinsed with water and the leachate is analyzed for its chemical constituents. Six waste rock/lean ore samples and three

87 tailings composites were subjected to kinetic testing to further assess acid generating potential and metal leaching behavior. Testing was conducted for periods of 30 to 107 weeks. Testing was ceased if it was observed that pH and zinc release rates were stable and suitable to be used for modeling release rates. A summary of the durations of the Humidity Cell Tests is in Table 14.

Table 14 Humidity cell test durations summary.

Sample Start-up Termination Lab ID Sample ID Weeks Type Date Date

HC-1 IBX041- CF08-165 3-Jun-10 21-Jun-12 107

HC-2 IBX042- CF08-168 3-Jun-10 11-Mar-11 40

CF08-153 (64- HC-6 12-Aug-10 21-Jun-12 97 68.4)

HC-7 CF08-172 (47-51) 12-Aug-10 11-Mar-11 30 Waste Rock

HC-8 CF09-191 (64-68) 12-Aug-10 10-Nov-11 65

HC-9 CF09-186 (84-88) 12-Aug-10 10-Nov-11 65

HC-3 Beach/Esrum L3 17-Jun-10 11-Mar-11 38

HC-4 Beach L2 17-Jun-10 21-Jun-12 105 Tailings HC-5 Discovery L1 15-Jul-10 10-Nov-11 69

All waste rock and tailings humidity cells are producing leachates with relatively stable neutral to alkaline pH (Figure 30 and Figure 31, respectively).

Weekly release rates (mg/kg/week) are presented in the following figures for tailings and waste rock respectively: • Zinc (Figure 32 and Figure 33); and • Lead (Figure 34 and Figure 35).

Figure 30 Waste rock humidity cell leachate pH over time.

Figure 31 Tailings humidity cell leachate pH over time.

Figure 32 Waste rock humidity cell leachate zinc release rates.

Figure 33 Tailings humidity cell leachate zinc load release rates.

Figure 34 Waste rock humidity cell leachate lead release rates.

Figure 35 Tailings humidity cell leachate lead release rates.

On cessation, the humidity cells were producing neutral pH leachate with high sulfate and calcium concentrations and relatively low iron concentration. It is anticipated that the tailings will eventually produce higher iron concentrations in the leachate when either the available calcite is fully consumed by the acidity that is being produced or the surface of the calcite is coated with the gypsum precipitates and is no longer reactive.

Humidity cell testing of tailings samples demonstrates that the neutral pH leachates contain elevated concentrations of regulated metals including zinc, cadmium, copper, lead, and nickel and metalloids including arsenic and selenium relative to applicable water quality guidelines. Isolated exceedances of regulatory guideline values for iron and mercury are also observed. These high metal release rates in combination with elevated sulfate and calcium suggest that pyrite oxidation is taking place but the associated acidity is largely being neutralised by readily available carbonate minerals.

Leaching of regulated constituents and sulfate from waste rock samples is low compared to the tailings samples and highly variable. This variability in leachate quality associated with waste rock humidity cell tests suggests that leachate quality is impacted by sulfur content and availability of excess neutralisation potential. This is demonstrated by the low metal release rates associated with the non-PAG waste rock sample as compared to the fairly consistent release of elevated levels of cadmium, lead and zinc associated with the PAG waste rock sample.

Sulfate and metal leaching rates associated with kinetic testing of waste rock and tailings under laboratory conditions are elevated compared to rates anticipated during operations due to low on site temperatures which reduce bacterial activity and the associated sulfide oxidation rates.

6.5.1.3 Net Acid Generation Testing

The NAG pH was measured on 12 waste rock/lean ore samples including all waste rock/lean ore humidity cell samples; the extract of two of these samples (HC-1 and HC-2) were analysed for dissolved metals.

NAG pH levels below 4.5 are usually characterised as acid generating while values above six are characterised as non-acid generating. Ten of the 12 samples analysed resulted in alkaline pH values which demonstrates that the samples are not expected to generate acid consistent with ABA results which suggested the samples were in the uncertain to unlikely range of acid generation.

HC-1 produced a NAG pH of 2.92 consistent with the ABA results and depletion calculations which suggest the sample is likely to eventually generate acid. One other sample produced a very low NAG pH of 1.74, which confirms the ABA results (NNP = -464.4 mg CaCO3/kg rock and ANP/AGP= 0.4).

6.5.2 Waste Rock Management

Mining waste rock from Citronen will be placed within the Waste Rock Dump (WRD) and DME Rejects Dump (DRD) (Figure 26). The waste dumps have been located so as to ensure stable slopes, and where practicable, blending into the natural surrounding topography. Waste dumps are constructed by tipping the waste at the ‘tip head’, which forms the ‘tip-to’ crest and toe of the batter (~37degrees). Upon closure of the facility (or when permissible during operations) the batter will be pushed down (using a tracked dozer) to the designed ‘push-to’ crest and toe. At closure, WRDs are designed with shallow final batters (~20 degrees) and forward sloping berms to minimise water retention. A diversion drain will be constructed on the upper side of the waste dump to prevent water runoff from the mountain from entering the dump.

DMS rejects will be back hauled from the ROM pad by the mining trucks (OP and UG) and the material deposited at the DRD. DRD design is as per WRD design with shallow final batters and forward sloping berms.

The geochemical characterisation studies suggest that blending of waste rock based on total sulfur content is likely to be an acceptable management strategy to prevent acidic conditions and limit metal leachate loads. Preliminary data, suggests that a sulfur cutoff of approximately 8wt.per cent is an acceptable value to segregate non-acid generating and potentially acid generating material. However, operational waste rock management should also be based on visual observations since initial ABA results suggest that shale/mudstone and massive sulfide lithologies may pose the only potential to generate ARD leachate. Decisions for blending of acid generating mine rock will be based on the results of further characterisation and on the estimated tonnages of acid generating and non-acid generating waste rock material. Non-acid generating mine rock will be preferentially used as construction material. While acid generating mine rock be blended (comingled) with non-acid generating lithologies.

Potential development of an operational waste rock block model based on total sulfur and rock type/lithologies in combination with the mine schedule will help identify PAG and non-PAG waste rock tonnages, locations and enable appropriate blending of waste rock during operations.

Visual observations during drilling will be conducted along with confirmation and random analytical sampling to verify the expected behavior of the waste rock. Additional geochemical characterisation as

the Project moves towards permitting and operations will help fine tune this waste rock management approach.

Waste Rock Management has been summarised in the Environmental Management Plan Section 8.3. A detailed Waste Rock Management Plan will be developed prior to the construction phase.

6.5.2.1 Waste Dump Closure

Closure of the Waste Rock Dump and DMS Rejects Dump will be detailed in a Decommissioning and Closure Plan. The plan will incorporate the evolving waste dump design as well as the three primary objectives for closure at Citronen, that all structures are: physically safe for users, physically stable and chemically stable.

The waste dumps will be shaped to form a stable structure. This is likely to include pushing down batter slopes to an angle less than angle of repose. The top of the waste landform will be capped with benign material and shaped to form a convex shape to discourage retention of water. Berms between lifts will be forward sloped to discourage retention of water. A toe bund will be constructed at the base of the dump to catch any silt or debris coming from the dump and prevent any from entering the Eastern River.

6.5.3 Tailings Management

Tailings waste will be disposed of via two methods – within a conventional dam (Tailings Storage Facility, TSF) and as backfill within the underground mine.

6.5.3.1 Dam Design and Stability

The TSF will become the final repository for the tailings produced as a result of the zinc and lead extraction process. The impoundment design includes a low permeability liner system to minimise the migration of tailings or process water to the environment. The TSF will incorporate a primary geomembrane liner and a secondary soil liner.

The TSF covers an area of 30.6 hectares with the ultimate capacity anticipated to be 3.6 million cubic metres. Table 15 summarises the design criteria and assumptions used for the TSF feasibility design. Site-specific design criteria for the TSF were developed based on the following guidelines and bulletins:

• International Commission on Large Dams (ICOLD) – Various Bulletins • Canadian Dam Association (CDA) – Dam Safety Guidelines, January 1999 • The Mining Association of Canada – A Guide to the Management of Tailings Facilities, September 1998.

Table 15. Summary of design criteria and assumptions.

1.0 Basic data

1.1 Total tailings is 9.0 Mt

1.2 Tailings produced at 240 t/d

1.3 580,557 m3 tailings storage requirement for year 1; 371,000 m3 capacity required for years 2 through 8

1.4 Tailings solids specific gravity = 3.6

1.5 Tailings slurry consists of 58% solids by weight

2.0 Dam stability

2.1 Minimum factors of safety – refer to Table 29, Section 7.7.3.

2.2 Maximum Design Earthquake (MDE) = Maximum Credible Earthquake (MCE)

2.3 Use pseudo-static methods of analysis

2.4 Peak Ground Acceleration (PGA) factored by 50% for pseudo-static analysis

2.5 Assume tailings fully liquefy under earthquake conditions

3.0 Storm water

3.1 Diversions designed for 100-year, 24-hour storm event

3.2 During operations, the impoundment will completely contain runoff resulting from the 24-h 50% PMP (Probable Maximum Precipitation) event in addition to the normal operating pool volume as determined from the impoundment water balance while maintaining minimum 1m of residual freeboard between the dam crest and the maximum water level.

3.3 Emergency spillway designed to pass the 24-hour PMP event while maintaining 1m (minimum) of residual freeboard between the dam crest and the maximum water level.

3.4 Use Soil Conservation Service (SCS) Technical Release 55 (TR-55) methods of analysis

3.5 Antecedent Moisture Condition (AMC) II assumed

The TSF location has been selected based on suitable topography and is shown in Figure 26.

Geochemical characterisation has indicated that the tailings are acid producing. As such the TSF will require an additional level of seepage containment normally accepted in conventional tailings facilities. Accordingly, the dam base and walls will be lined with a 60mil (1.5mm) thick High Density

Polyethylene (HDPE) geomembrane to prevent seepage through to the dam walls. This will mitigate any release of water or tailings material through the dam floor or walls. It will also limit the potential for instability due to pore water pressure build up. HDPE liners are the most common form of geomembrane used for this purpose due to their excellent chemical and UV resistance, as well as being tough and thus practical to install.

The dam will contain five primary earth fill zones. The purpose of these various zones is described below from upstream to downstream.

The upstream side of the dam will consist of a protective fill layer. This material is not critical to the stability of the structure and is present to protect the HDPE geomembrane from damage from the environment (mainly ice buildup). It should consist of smaller grained material (15 mm minus) and free of organic material.

The next material on the embankment will be the bedding layer for the HDPE liner. This material will serve as bedding material for the geomembrane liner and also a low permeability seal for the dam in the event of liner leakage. This material will be very similar to the material used as the protective liner except that this material will have a permeability specification and therefore contain a greater amount of fines.

In order for the bedding layer to not migrate into the drain rock layer if a hydraulic head is present, a filter material is needed. This material will consist of a sandy material that is coarser than the bedding layer and finer than the drain gravel. This material will have a higher permeability to allow more water to drain through this material than the bedding layer. This material will not allow the fines to migrate in to the drain rock and cause voids in the embankment.

Drainage gravel will be placed just downstream of the filter material. The purpose of this material is to drain any water (meteoric or process) that infiltrates into the embankment. This material is critical to the function of the embankment. This material will allow water to drain lowering the phreatic surface (level to which water in an open pipe would rise to) in the embankment to help ensure the required factor of safety with regards to stability of the structure. The better this material drains the water from the embankment, the more stable the structure.

The downstream structural fill zone of the dam will be constructed with rock fill material available on site. The rock fill material will provide the embankment with structural strength to resist earthquake forces. This material can be a combination of mine development rock, inert waste rock, or local borrow fill.

A zoned earth embankment, like the one designed for this project, is the state of the practice for tailings dam construction. It provides an environmentally responsible and safe manner in which to store tailings.

A program to regularly monitor and analyse the key elements of the tailings facility, including tailings characteristics, the tailings embankment, water and seepage, will be established and maintained. Currently it is expected that the monitoring installations at the tailings dam will consist of monitoring survey monuments for dam movement, vibrating wire piezometers for measuring foundation and fill water levels, thermistor monitoring, and ground water monitoring wells down gradient of the tailings impoundment for monitoring water quality.

The analysis of the monitoring data, which will include a comparison of recent data against previous results and design expectations, undertaken on a schedule that ensures prompt detection of any unfavourable conditions.

A routine inspection program will be established for assessing ongoing environmental and safety performance of the impoundment and appurtenant structures, including all critical structures such as the tailings dam, beach and supernatant pond.

6.5.3.2 Tailings Transport and Deposition

Tailings will be pumped from the process plant to the TSF or underground via a HDPE pipeline. The pipeline will be laid within a containment bund and on the surface to enable regular visual inspection and maintenance of pipelines.

Tailings deposition within the dam is via an HDPE pipe running along the TSF wall with intermittent spigots to manage the location of deposition. Tailings deposition will occur from the embankment as well as multiple points around the impoundment. The tailings will be deposited into the TSF at discreet locations to set up sloping tailings beaches that keep the water pool as far away from the tailings dam as possible and maintain a minimal supernatant water pool in a designated location of the TSF for reclaim purposes during operations.

The tailings slurry is estimated to be at 60-70% solids. As the tailings is deposited at each spigot point it will spread out and remain wet (due to the warm temperature of the slurry) until deposition stops and starts again at a new spigot. Once tailings deposition has ceased in each location it will freeze over as moisture content is expected to remain at about 50%. During the life of the mine the majority of the tailings will be frozen. Tailings will be deposited in a manner which promotes freezing.

Water reclaim is anticipated to be minimal (based on similar arctic experience) and will be restricted to the warmer summer months. During those months, a portable reclaim pump facility will be installed at appropriate locations within the dam so water can be captured. A HDPE pipeline will be laid next to the tailings line to return the water back to the process plant.

A diversion drain will be constructed on the upper side of the tailings pond to prevent runoff from the mountain from entering the facility. Similarly, a drain will also be constructed at the toe of the dam wall to divert any surface flow from nearing the dam.

The TSF will be initially constructed to accommodate 1.5 million m3 of tailings, which corresponds to approximately one year’s tailings production. Once sufficient mine void is available, tailings will be disposed as backfill within the underground mine. When disposal to underground is not able to take place, tailings will be intermittently deposited within the TSF. Any required expansion of the TSF capacity will be achieved through downstream lifting of the dam walls and extension of the HDPE liner, as per normal industry practice.

Tailings Waste Management has been summarised in the Environmental Management Plan Section 8.3. A Tailings Storage Facility Management Plan will be developed prior to the construction phase.

6.5.3.3 Freeboard Design

Throughout the life of the facility, during normal operating conditions the process water pool will be isolated from the dam by a broad tailings beach. Due to a relatively short fetch across the impoundment, water pool wave run-up is not expected to impact the dam crest during normal operating conditions or when the pool surface is elevated during storm events. Sufficient storage capacity will be maintained in the impoundment such that a minimum of 1m of residual freeboard will be maintained above the maximum water surface elevation attained during the Probable Maximum Flood (PMF).

6.5.3.4 TSF Storm Water Management

The storm water management approach for the Citronen Fjord TSF will be to limit, to the maximum extent practical, the volume of storm water runoff that enters the TSF. This will be accomplished by constructing a surface water diversion channel along the east side of the ultimate TSF. Because of the small quantity of runoff anticipated, the access roads will have a roadside drain that will be used as the diversion channel. The surface water diversion will collect flows from the TSF catchment area and

convey them to the north and south of the TSF and ultimately to the Eastern River. The surface water diversion is designed to convey the 100-year frequency, 24-hour duration rainfall event.

Extreme precipitation events in excess of the 100-year frequency event may result in overtopping of the surface water diversion. If a failure of the surface water diversion occurs, surface water flows will be conveyed to the TSF. During operations, adequate storage will be maintained within the TSF to completely store runoff resulting from the 50% PMF event (assuming surface water diversion failure at the onset of the event) while maintaining 1m (minimum) of residual freeboard to the tailings dam crest. Excess water stored within the TSF during operations will be discharged through a temporary reclaim system as required during the summer months.

6.5.3.5 Emergency Spillway

As the TSF nears the end of its operating life, adequate storage of the 50% PMF event will no longer be achievable. At that time, an emergency spillway will be constructed to protect the tailings dam from overtopping during extreme precipitation events.

The spillway design is based on the flowing criteria:

• The spillway will be designed to handle runoff for the PMP, 24-hour duration storm event; • Rainfall from the emergency spillway design storm event was estimated to be 81 mm; • The spillway must be capable of conveying the peak flow during the PMP event while maintaining a minimum of 1m of residual freeboard at closure conditions; • The north and south diversion channels are assumed to fail at the onset of the spillway design storm; • The emergency spillway is assumed to be rip-rap-lined with a corresponding Manning’s roughness coefficient as given in “Open Channel Hydraulics” (Chow, 1959) of n = 0.035; and • The initial surface elevation in the Citronen Fjord TSF impoundment at the onset of the PMP, 24-hour duration storm event is assumed to be 68.75 m, which corresponds with the invert of the proposed emergency spillway.

The emergency spillway is designed to discharge runoff from storms up to and including the full PMF event, while still maintaining a minimum of 1m of residual freeboard to the tailings dam crest during operations (and closure). For the design of the emergency spillway, the diversion channels around the TSF are assumed to fail at the onset of the Probably Maximum Precipitation (PMP) storm and runoff from the entire 155 ha catchment area is routed through the tailings facility.

The spillway will be located at the northern end of the TSF. Discharge from the spillway will be directed away from the TSF and follow the natural topographic gradient towards Citronen Fjord. It is

not anticipated that a sedimentation basin will be required for the spillway at this stage due to the low risk of environmental contamination. The reasons for this are: • During a PMP event, 1m freeboard allowance will remain allowing some settling of tailings solids prior to overflow; • The majority of tailings will be frozen and will not enter the rainfall solution; and • Ecotoxicity test results concluded that concentrations of tailings decant water (including 100%) are not toxic to lower level aquatic communities. However, during operations, further testing of supernatant will be conducted to monitor the toxicity level of the supernatant and the likely solids suspension rate. Results of this monitoring will then be used to re-evaluate any risk of the supernatant to the environment in a flood situation.

6.5.3.6 Tailings Backfill Design and Testing

For efficient environmental performance, the need of structural fill for mine stability, and to increase recovery, tailings will be used as backfill underground. Backfill will be required in all mining stopes and will be allowed to freeze in place thus providing an extra mechanism of ground support.

Two alternatives were considered, iced backfill and other pastefill. After review of literature, positive results of in-ground thermistors, and to avoid the cost of fill additives, iced backfill was chosen to detail feasibility. Feasibility was evaluated from the standpoint of strength, properties of delivery to the face, and freeze time.

Once the iced backfill is placed underground, the excess water will decant and be pumped out of the mine. Normally tailings paste used for backfill is thickened in a pastefill plant, however, this idea was rejected due to the difficultly of application in arctic conditions. The 55:45 solid to water tailings mixture that the mill will produce can be pumped underground by high-volume delivery centrifugal pumps. The backfill is expected to be delivered into the stope at 2°C. At this delivery temperature in a stope which requires 10,500 m3 of backfill the expected freeze time is 75 days.

Underground temperature calculations Citronen site is in an area of continuous permafrost where the ground stays frozen all year, and in an area where the ultimate depth as projected by literature using measured geothermal gradient is approximately 400m.

To ensure frozen ground would be present in the mine, the temperature was measured by placing thermistors in drill holes at varying depth. The readings were undertaken from July 1 to August 15 2010, the warmest time of the year. The results are shown in Table 16. The calculated geothermal gradient using the data (not including the first 12 m which is non-linear) is 29.4 m per 1°C, or 88.2 m

100 per 3°C. This result agrees in principal with data collected from other arctic location’s measurements and the recognised rule of thumb of 100m per 3°C for arctic permafrost temperature gradient.

Table 16 Thermistor measurements of beach area (August 2010).

Depth Below Temperature Surface (m) (°C) 0 -13.6 4 -13.4 8 -13.1 12 -13.1 14 -13.0 70 -10.5 100 -9.7 150 -8.4

The depth of cover to mine floor at the Beach deposit ranges from 116m Level II sulphide (in the centre of the resource) to 211m to Level III also in the centre of the Beach area. Using the measured thermal gradient, the rock temperature at these two depths will be -9.6°C at 116m and -6.4°C at 211m.

Surface topography differences above the Esrum deposit affect the depth of cover to underground Esrum mine floor. The depth of cover at Esrum ranges from 275m in the north part of the resource to Level II sulphide, to 592m to Level III sulphide at the southwest part of the resource. Thermal gradients suggest that, at the deepest part of the Esrum deposit, the temperature will be just below 0°C.

Thermal analyses were performed for time to freeze the tailings slurry in a stope underground. The typical room is approximately 1,000m laterally underground. The room is a mine stope with the walls, floor, and ceiling of the room consisting of exposed rock. The modelling described was utilised to determine the time necessary for the mass of tailings slurry to freeze after being pumped into the rock room. Two different room sizes were considered: 7m x 10m x 150m, and 14m x 10m x 150m.

The transient models were each run for five years to determine the length of time necessary for the slurry to freeze completely. The model indicates that for the 150m by 7m room, the slurry would be expected to freeze completely in 75 days. For the 150m by 14m room, the slurry would be expected to freeze completely in 200 days.

101

6.5.3.7 TSF Closure

Closure of the tailings facility will be comprised of two main elements: an earthen cover system for the tailings deposited in the dam and a surface water management system. The cover system will be designed to limit water infiltration into the facility. The surface water management system after closure will direct water across the surface of the reclaimed tailings facility so as to further reduce water infiltration.

The tailings deposition system will be modified during the final months of operation, as necessary, to form the final tailings surface topography which will provide positive drainage to the final emergency spillway. Final tailings deposition will include allowances for post-closure settlement. The post-closure surface water management system is designed to minimise water pooling on the surface of the TSF cover and reduce the potential for infiltration.

The post-closure cover design consists of a 0.5m thick layer of low permeability material derived from waste rock and DMS rejects stockpiles. The surface will be armoured if necessary, to reduce the risk of surface erosion and returned to a condition similar to that which was present before operations. Erosion protection consisting of rock riprap will be placed, as necessary, in the drainage channels to limit erosion.

Closure of the tailings embankment will consist primarily of vegetating the dam crest and downstream slope, if required. Progressive reclamation of the downstream slope can occur immediately following construction of the final embankment. During operations, an evaluation of the performance of the embankment with regards to erosion will be made. If unacceptable levels of erosion are noted, re- contouring of the downstream slope may be required at closure.

All diversion ditches that were constructed to limit inflow to the tailings facility will be left in place and allowed to naturally fill in with eroding rock and soil from the slopes that exist above the ditches.

6.6 Port Facility and Loading of Product

The site will require suitable port facilities to accommodate incoming vessels, which will be formed by a 15m wide access pier constructed of quarry run/gravel. The access pier will extend into Citronen Fjord until the water is at 12m existing depth, which permits the draft required for the ice-class bulk carriers. The pier will be finished with a compacted wearing course and rock armour to the batters. The pier head will be formed by a rectangular sheet pile cell filled with quarry run/gravel. From the

102

pier head it will be possible to access the bulk carriers for concentrate loading and incoming supplies. Moorings will be established onshore and offshore to enable wharfing of the vessels.

A storage area will be established adjacent to the port for the 1000 Twenty-foot Equivalent Units (TEU) of shipping that are envisaged per annum. Explosives (detonators and high explosives) will be unloaded and moved to the explosives storage areas located at the southern extent of the site. Blasting agents (Ammonium Nitrate prill) will be stored in containers in the storage area.

A 200 tonne crane located at the pier head will be used to offload containers from the ship, which will be moved by reach-stackers to the adjacent container storage area. Concentrate will be loaded onto fixed conveyors that exit the concentrate shed. The conveyors will run adjacent to the pier and thereafter transferring to the fixed ship loader. The ship loader will be a covered conveyor with a powered chute that places the concentrate into the cargo hold. This type of operation can be conducted in most weather conditions.

6.7 Shipping

Due to the remote nature of Citronen Fjord, which is accessible only via air or sea, the saleable end product (concentrate) and required volumes of supplies, consumables, and heavy items will be shipped to and from Citronen. A forward marshalling port will be established (possibly Akureyri, Iceland) to handle all shipping of concentrate from site (and tranship the concentrate on regular cargo shop to a nominated port in Europe) and act as a marshalling yard for back shipping of supplies to Citronen. Shipping has been summarised in this section and is also discussed in detail in the Navigational Safety Investigation report (MTHojgaard, July 2014).

6.7.1 Shipping Guidelines and Regulations

All shipping required for the Project will be done in accordance with the appropriate and applicable regulations and guidelines for Greenland waters. The following documents shall be observed: • International Maritime Organisation (IMO) resolution 1024 – Guidelines for ships operating in polar waters; • IMO circulation 221 – Mandatory ship reporting system; • Danish Maritime Authority (DMA) order no. 417 – Order on technical regulation on safety of navigation in Greenland territorial waters; • IMO resolution 893 – Guidelines for voyage planning; • IMO circulation 1185 – Guide for cold water survival; • DMA – Technical regulation on the use of ice searchlights during navigation in Greenland waters; and • IMO circulation – Guidelines for owners/operators preparing emergency towing procedures.

103

Operating in ice will be undertaken by an experienced ice management company with knowledge about navigation in north Greenland waters.

6.7.1.1 International Maritime Organisation

In 2009, the IMO Maritime Safety Committee (MSC) approved the revised Guidelines for ships operating in polar waters. The IMO is currently developing draft international codes of safety for ships operating in polar waters (Polar Code3 and Ballast Water Convention4), which would cover the full range of design, construction, equipment, operational, training, search and rescue and environmental protection matters relevant to ships operating in the inhospitable waters surrounding the two poles.

6.7.1.2 International Convention for the Prevention of Pollution from Ships (MARPOL)

The MARPOL Convention is the main international convention covering prevention of pollution of the marine environment by ships from operational or accidental causes. It is a combination of two treaties adopted in 1973 and 1978 respectively and also includes the Protocol of 1997 (Annex VI). It has been updated by amendments through the years.

The International Convention for the Prevention of Pollution from Ships (MARPOL) was adopted on 2 November 1973 at IMO and covered pollution by oil, chemicals, harmful substances in packaged form, sewage and garbage. The Protocol of 1978 relating to the 1973 International Convention for the Prevention of Pollution from Ships (1978 MARPOL Protocol) was adopted at a Conference on Tanker Safety and Pollution Prevention in February 1978, held in response to a spate of tanker accidents in 1976-1977. As the 1973 MARPOL Convention had not yet entered into force, the 1978 MARPOL Protocol absorbed the parent Convention. The combined instrument is referred to as the ‘International Convention for the Prevention of Marine Pollution from Ships, 1973’.

The Convention includes regulations aimed at preventing and minimizing pollution from ships - both accidental pollution and that from routine operations and currently includes six technical Annexes.

Annex I Regulations for the Prevention of Pollution by Oil - Covers prevention of pollution by oil from operational measures as well as from accidental discharges. The 1992 amendments to Annex I made it mandatory for new oil tankers to have double hulls and brought in a phase-in schedule for existing tankers to fit double hulls, which was subsequently revised in 2001 and 2003.

3 http://www.imo.org/MediaCentre/HotTopics/polar/Pages/default.aspx 4 http://www.imo.org/OurWork/Environment/BallastWaterManagement/Pages/Default.aspx

104

Annex II Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk - Annex II details the discharge criteria and measures for the control of pollution by noxious liquid substances carried in bulk. Some 250 substances were evaluated and included in the list appended to the Convention. No discharge of residues containing noxious substances is permitted within 12 miles of the nearest land.

Annex III Prevention of Pollution by Harmful Substances Carried by Sea in Packaged Form - Annex III contains general requirements for the issuing of detailed standards on packing, marking, labeling, documentation, stowage, quantity limitations, exceptions and notifications for preventing pollution by harmful substances. The International Maritime Dangerous Goods (IMDG) Code has, since 1991, included marine pollutants.

Annex IV Prevention of Pollution by Sewage from Ships - Annex IV contains requirements to control pollution of the sea by sewage.

Annex V Prevention of Pollution by Garbage from Ships - This annex deals with different types of garbage and specifies the distances from land and the manner in which they may be disposed of. The requirements are much stricter in a number of "special areas" but perhaps the most important feature of the Annex is the complete ban imposed on the dumping into the sea of all forms of plastic.

Annex VI Prevention of Air Pollution from Ships - The regulations in this annex set limits on sulfur oxide and nitrogen oxide emissions from ship exhausts as well as particulate matter and prohibit deliberate emissions of ozone depleting substances. Emission control areas set more stringent standards.

6.7.1.3 Arctic Council

The northern polar areas, the Arctic Ocean and Arctic coastal areas are regulated by national regulations in the respective countries and their Exclusive Economic Zone (EEZ) while international law and IMO regulations provide the legal framework for the international water of the Arctic Ocean (including the Greenland Sea).

There is however a high level intergovernmental group established based on the Ottawa Declaration of 1996. This is the Arctic Council, created to provide a means for promoting cooperation, coordination and interaction among the Arctic States, with the involvement of the Arctic Indigenous communities, in particular issues of sustainable development and environmental protection in the Arctic.

105

Member States of the Arctic Council are Canada, Denmark (including Greenland and the Faroe Islands), Finland, Iceland, Norway, Russia, Sweden, and the USA. In addition there are permanent participants representing different groups of indigenous people.

Many of the tasks and activities of the Arctic Council are addressing environmental protection and sustainable development and conducted in the following working groups: • Arctic Monitoring and Assessment Programme (AMAP); • Conservation of Arctic Flora and Fauna (CAFF); • Emergency Prevention, Preparedness and Response (EPPR); • Protection of the Arctic Marine Environment (PAME); • Sustainable Development Working Group (SDWG).

Working Group Management Boards are typically comprised of representatives of national governmental agencies of the Arctic Council member states, connected to the mandates of the working groups and representatives of the permanent participants. It is the responsibility of the working groups to execute the programs and projects mandated by the Arctic Council Ministers. These mandates are stated in the ministerial declarations, the official documents that result from ministerial meetings. All decisions of the Arctic Council and its subsidiary bodies are by consensus of the eight Arctic member states.

6.7.2 Shipping vessel

Two solutions were considered for the transport of concentrate from Citronen Fjord: An icebreaking tug with barge versus two ice-class bulk carriers. The solution with the ice-class bulk carriers was chosen due to the greater load capacity, resulting in fewer required trips per year, ease of operation and greater economic benefit.

Shipping to and from Citronen will utilise two high ice class mine re-supply vessels.

A. One Polar Class 3 (PC3), 65,000 Deadweight Cargo Capacity (DWCC) vessel designed to carry zinc and lead concentrates, arctic diesel and TEUs (Class & Non Class) without ice breaker escort. B. One Polar Class 4 (PC4), 55,000 DWCC vessel designed to carry zinc and lead concentrates, arctic diesel and TEUs (Class & Non Class) without ice breaker escort.

Concentrate production will be approximately 300,000 tonnes per annum (peaking at 320,000). Based on the selected ships capacity, this will corresponds to a requirement for approximately 3 return trips per year.

106

The two Polar Class vessels would carry about 360,000 wet metric tons (wmt) of zinc and about 20,000 wmt of lead. At all times, the Polar Class vessels would sail in a convoy with the PC3 vessel, larger both in terms of dimensions and horsepower, acting as the escort for the smaller PC4.

6.7.3 Route and Periods of Passage

As the ice cover varies from year to year there is no specific shipping route from the open waters of the Greenland Sea to Citronen Fjord. The sailing route will depend on the lead in the ice developing in the shear zone between the shore fast ice and the drift ice. Consequently the final sailing route cannot be determined until closer to each shipping period and will have to be adjusted for each trip.

There are three zones of ice that a ship would traverse to go from open water in the Greenland Sea to Citronen Fjord and back: 1. The pack ice of the northern Greenland Sea from open water to Cape Nordostrundingen; 2. The pack ice of the Wandel Sea from Cape Nordostrundingen to Frederick Hyde Fjord; 3. The fast ice zone of Frederick Hyde Fjord, including the offshore fast ice.

An approximate shipping route is illustrated in Figure 36.

Figure 36. Approximate shipping route.

107

The most important feature of the ice cover of the Wandel Sea that would influence the accessibility of Citronen Fjord to marine navigation is the appearance of the shipping lead that runs from Cape Nordostrundingen northward to the eastern entrance to Frederick Hyde Fjord in most summers. Shipping studies indicate the most likely period of passage will be between July and September, subject to prevailing conditions (Enfotec 2011). The shipping route will be dictated by the location of the open water lead that develops within the ice.

The average number of days (with dates) of the lead between Cape Nordostrundingen to Frederick Hyde Fjord is outlined in Table 17. This lead has remained open an average of 42.5 days over the 28 years. However, there has been a wide degree of variation in the number of days the lead remained open from one year to the next in the historical record, from a high of 100 days in 1990 to only 12 days in 1997 and 2009. A lead may form any time between mid-June to late September but is most frequently encountered in the last week of August and the first week of September.

On the ‘Northbound’ voyage, the polar class vessels would load TEUs and arctic diesel at the designated marshalling port before sailing to Citronen Fjord. Arctic diesel would be discharged followed by TEU cargo.

The concentrate cargo would be carried on the ‘Southbound’ voyage. In addition to loading concentrate cargo, the two vessels would also load backhaul cargo, which would be comprised of either empty or loaded TEUs, thereby assisting the project with the maintenance of an efficient TEU supply chain. Dangerous goods (explosives) and controlled substance will be shipped in suitable approved containers (as per established shipping arrangements).

If shipping off site is not possible due to unfavourable or icy weather conditions, concentrate will continue to be processed until there isn’t enough fuel to run the power plant and/or there is no more room to store the concentrate. The additional concentrate will be temporarily stored in an appropriate location within the concentrate storage shed. Once all storage room is gone, the process plant would be moved into a care and maintenance phase until shipping could be resumed the following year.

As most operational activities will cease the environmental impacts during this time would be reduced. A skeleton crew would remain on site to ensure that any required monitoring, servicing and maintenance would take place. Depending on economics, other alternatives to getting the product off site would be investigated at the time, however the likelihood of this occurring has been considered low.

108

Table 17 Opening and closing dates of lead from Cape Nordostrundingen to Frederick Hyde Fjord (Enfotec March 2011).

Year** Opening date Closing date Days per season

1978 25 July 2 September 36* 1979 6 July 15 September 49* 1980-83 No data available 1984 13 July 25 September 74 1985 14 July 30 September 77 1986 13 July 18 September 59* 1987 7 August 9 September 12* 1988 21 July 27 September 65* 1989 No data available 1990 7 June 15 September 100 1991 10 June 5 September 87 1992-93 No data available 1994 22 June 3 August 26* 1995 17 July 30 September 41* 1996 20 June 15 September 51* 1997 23 June 5 September 31* 1998 24 June 30 September 93* 1999 23 July 10 September 34* 2000 10 July 10 September 32* 2001 22 July 10 September 24* 2002 22 May 5 September 63* 2003 13 August 29 August 19* 2004 7 July 6 September 62 2005 22 June 16 August 24* 2006 2 June 16 September 41* 2007 31 July 19 August 15 2008 7 June 3 September 38* 2009 3 July 9 September 12* 2010 24 May 27 September 23* Average: 42.4 days/year * Days not consecutive

109

6.7.4 Emergency Procedures – Shipping

See Section 6.16.2.

6.8 Supporting Infrastructure

Due to the remote nature of the site, Ironbark will need to establish all supporting infrastructure to enable continual operations at site. This will include a 1500m airstrip, power generating facilities, site operational facilities and accommodation facilities.

6.9 Personnel, Transport and Accommodation

During the two years of construction, the expected use of manpower will be equal to approximately 300 full time employees (local and foreign). Once construction is complete and operations have commenced, this number will decrease to approximately 470 per year with 290 people on site at any one time.

Site personnel will be housed in motel-style accommodation for their duration on site. The accommodation will be a self-contained camp, with cooking and mess facilities, en-suite bathrooms, and entertainment facilities.

At the beginning stages of construction, current temporary accommodation will be used. It is planned to erect the camp as early as possible so that it can be utilised for the construction workers and subsequently refurbished for use by operations personnel.

During operations the camp is designed to accommodate approximately 290 people based on an 8+1 concept and comprises eight accommodation blocks spread around a central reception block. This layout was selected to enable camp residents to access central facilities through small connection corridors without having to go outdoors.

All buildings, ancillary facilities and electrics will be designed and constructed according to the Greenlandic Building Regulations, adhering to requirements including those for heating insulation and fire safety. The camp will be divided into several fire sections to avoid fire spreading.

The buildings will be delivered as fully fitted-out prefabricated modules equipped with on-site works being foundations, connection of services reticulation systems, fitting-up and furnishing. The foundations will comprise of prefabricated components and will consist of steel frames fixed to buried concrete slabs. The buildings will be placed with the floor level raised one metre above the ground to preserve the permafrost.

During initial stages of operation site personnel will reach Citronen using aircraft from Keflavik, Iceland, via Station Nord, then onward to Citronen. The existing permanent runway is 300m long. A

110

runway of 1500 is required for the planned aircraft when they fly directly from Keflavik to Citronen. Personnel are envisaged to comprise a mix of Greenlandic, Danish, European and North Americans.

Employees on site will work a fixed Fly In Fly Out (FIFO) rotation, which will be of the order of six weeks on three weeks off.

6.10 Power Supply and Fuel Storage

Site power will be supplied by four No.7 MW diesel generators (+2 backup) for a total power generating capacity of 28MW. The generators will be housed within the power plant building (adjacent to the truck workshop), and a glycol heat recovery system will be utilised to recover energy and provide heating for site buildings.

Diesel fuel for the power plant will be stored in the main diesel storage tanks, located at the northern extent of the site, at 600m distance from the main site facilities as per statutory requirements. The two tanks have a storage capacity of 25 million litres each. Thus a total site storage capacity of approximately 70 million litres is anticipated. The fuel tanks are designed according to the Technical Regulations for Flammable Liquids (1985) applicable for fuel storage in Greenland. Each tank is within an earth-bunded area with 115% containment volume. Diesel will be pumped from the main tanks to intermediate holding tanks/fuel farm located adjacent to the power plant building and heavy plant workshop. Fire safety systems will be installed to the power plant building and diesel tanks.

The diesel is delivered from Iceland and transferred via surface pipelines that run from the pier head to the main fuel tanks.

Aviation fuel will also be shipped to site and stored in a dedicated tank located at the fuel storage area. Transfer of aviation fuel to the runway will be using dedicated fuel truck and trailers.

6.11 Explosives

Explosives (detonators and Ammonium Nitrate prill) will be used for blasting the underground and open pit. These explosives will be stored at the explosive magazine located at the southern extent of the site. It is estimated that 39000 tonnes of explosive will be used throughout the mine life. During blasting there is the potential to release nitrogen salts into the environment. The majority of blasting will occur underground where it is expected that most of the nitrogen released will be captured underground and removed either with the ore to the processing plant or to the waste dump with the waste. Blasting during the open pit mining will result in more nitrogen released into the environment.

111

However given the total nitrogen content of the explosive is approximately 1/3 and the amount used per hole is small (6 kg/hole) the amount released is expected to be insignificant.

6.12 Water Supply

Water supply to the site at Citronen will be sourced from Lake Platinova. The lake will have its current holding capacity increased from 0.5 million m3 to 1.8 million m3 through construction of a dam wall. Natural inflows to Lake Platinova are not sufficient to sustain required water volumes for site so seasonal pumping from the Eastern River will be undertaken to provide the 1,664,400 m3 cubic meters of water (per annum) required for operations. Water will be pumped from Lake Platinova to the process plant for consumption. Drinking water will be pumped to the self-contained potable water treatment plant prior to human consumption.

6.13 Workshops and Warehousing

Site facilities will include a main workshop for maintenance of the mobile equipment fleet including light vehicles. Also within this facility will be a boiler makers/fabrication workshop and electrical workshop to enable self-sufficiency on site.

Within the process plant there will be small workshop facilities to enable maintenance to be undertaken. The underground mine will also have a small workshop underground to enable servicing and repairs of equipment to be undertaken, eliminating the need to tram all equipment to surface.

6.14 Dust Management

There are several operational areas that have been identified as potential dust sources and hence will require specific dust management: • Open pit mine; • Underground mine; • Process plant/con shed; • Tailings dam; • Seaborne concentrate loading point; and • Haul roads.

Traditional management of dust in a mining environment is through the use of water sprays (static and truck mounted), however this approach in a cold environment is clearly subject to ambient temperature and prevailing weather conditions.

112

Open pit mining causes dust through load and haul activities, and surface blasting. In respect of loading and hauling, the predominant generation of dust is during loading. Muck piles will be wetted down prior to loading in areas where lots of dust is created (subject to temperature). Surface drilling utilises water (or air mist) as required to suppress dust. During surface blasting explosives create significant volumes of gas that can provide energy for fine particles to come into suspension. The ability to control dust during blasting is limited as it is not feasible to wet down the area due to safety reasons. Wind can greatly affect dust from blasting and under adverse conditions firing of the shot can be postponed to reduce dust generation.

Underground mining causes dust within the workings of the mine, which is transported in the air and exhausted from the mine via the vent raises. Maintaining a good working environment is preferable by minimising dust at source locations (working faces) rather than dealing with dust in suspension. Wetting down of muck piles in development drives and stopes, and misting sprays are generally sufficient to achieve this, and a balance has to be achieved between dust suppression and avoiding freezing the moisture added to the blasted material.

The process plant and concentrate shed will be heated to ensure an appropriate atmosphere is maintained. Exhaust air from these buildings will be filtered.

Tailings deposition within the TSF will be as wet slurry and accordingly provide a mechanism for suppression of dust by the presence of a layer of water until such time as it is reclaimed from the TSF or freezes in-situ.

Concentrate loading to the bulk carrier will occur at the port site. Dust will be minimised by the use of covered conveyors, hatches to cargo holds and a sock fitted to the telescopic chute, which discharges to the hold.

Haul road fugitive dust can be suppressed through light wetting with a water truck, but this has to be managed carefully in a cold climate to avoid potential ice build up. During instances of ice build-up, one would preclude the ability for dust to become airborne. Regular maintenance of the road surface through grading will assist in minimising dust.

6.14.1 Air Quality Modelling

In order to assess the potential dispersal of dust at the proposed mine air dispersion modelling was conducted. Dust (particulate matter, PM) emissions were developed and ground level PM concentrations and deposition estimates were predicted for the mining operations based upon meteorological data, air emission sources and receptor locations at the Project (Golder, 2011).

113

Two scenarios were modelled that considered PM emissions (with particle size of 30 µm or less) and

PM10 emissions (with particle size of 10 µm or less). A summary of the estimated pollutant emissions for the mine activities which were included in the dust modelling is presented in Table 18. Haul traffic is predicted to contribute the most dust to the site (both PM and PM10), however this is not likely to contain and zinc or lead dust. Crusher operations are estimated to produce less dust than hauling activities however the dust is more likely to contain a proportion of zinc and lead.

The spatial distribution of the maximum annual PM and PM10 concentrations are presented in Figure 37 and Figure 38, respectively. The spatial distributions would be the same for the deposition of both lead and zinc, assuming that the zinc and lead content in the emissions was the same as in the ore (Figures 40 - 43). The maximum values are mainly due to the crusher operations. Other sources, such as those associated with the haul road and blasting, have lower predicted impact.

Dust monitoring will be conducted using deposition gauges during every field season to determine the natural deposition of dust, including lead and zinc concentrations, at the project prior to disturbance. Dust monitoring will continue during operations for evaluation of dust controls and dust management techniques.

114

Table 18. Summary of PM/PM10 zinc and lead emissions used in dust modelling (Golder 2011).

115

Crusher area

Open pit area

3 Figure 37. Spatial distribution of the maximum annual average PM10 concentrations (ug/m ) predicted in the mine vicinity (Golder, 2011).

116

Crusher area

Open pit area

Figure 38. Spatial distribution of the maximum annual average PM concentrations (ug/m3) predicted in the mine vicinity (Golder, 2011).

117

Crusher area

Open pit area

2 Figure 39. Spatial distribution of the predicted maximum annual zinc deposition (g/m ) based on PM10 emissions (Golder, 2011).

118

Crusher area

Open pit area

Figure 40. Spatial distribution of the predicted maximum annual zinc deposition (g/m2) based on PM emissions (Golder, 2011).

119

Crusher area

Open pit area

*0.0365g/m2/year

2 Figure 41. Spatial distribution of the predicted maximum annual lead deposition (g/m ) based on PM10 emissions (Golder, 2011). * German Air Quality Control Guidelines, maximum lead levels (Luft, 2002).

120

Crusher area

Open pit area

*0.0365g/m2/year

Figure 42. Spatial distribution of the predicted maximum annual lead deposition (g/m2) based on PM emissions (Golder, 2011). * German Air Quality Control Guidelines, maximum lead levels (Luft, 2002).

121

6.15 Greenhouse Gas and other Gas Emissions

Greenhouse gas emissions will be from several sources, namely the diesel power plant and the site mobile equipment including the mining fleets. Approximately 50 million litres of diesel will be consumed on an annual basis.

Site emissions are primarily vented from the site power plant. The underground ventilation will provide exhaust of diesel fumes generated underground and mobile equipment operating on the surface will be free to exhaust straight to atmosphere. The use of explosives for blasting creates gases, which vent to air, be it directly for surface blasting or via exhaust shafts for underground blasting.

Air emissions can only be calculated from the anticipated site fuel consumption and the technical

specifications of the power plant. Total site emissions will be in the region of 132,700 tonnes CO2, which corresponds to fuel consumption of approximately 50 million litres per annum of diesel. This has been calculated by using the factor of 2.68kg of carbon per litre of diesel consumed. This figure can be compared to the total Greenland contribution of 685,000 tonnes in 2008 (Nielsen et al, 2010). Development of the Citronen Project will increase the carbon output of Greenland.

Emissions will be limited through the use of high quality diesel and ongoing maintenance of plant and equipment. The selection of modern economical equipment during the design phase will further reduce the generation of greenhouse gases. Potential reductions in the amount of emissions will be investigated once equipment is operating and accurate emissions can be calculated.

The amount of nitrogen oxides, sulphur oxides and particulate matter emissions from the selected 7MW power plant are 1776, 127 and 30 mg/m3 respectively.

6.16 Noise

Noise has been identified for consideration for the project. Given the remote location of the project it is unlikely to result in an impact on the surrounding environment. Noise impacts on fauna is regarded as to be insignificant given that fauna generally move from noise areas. The area is not in a preferred habitat area. Noise impacts with regards to employees will be monitored and in line with suitable safety guidelines for noise limits. Where required, machinery will be fitted with noise reduction devices and employees will be required to wear personnel hearing protection where indicated.

122

6.17 Domestic and Industrial Waste Management

Domestic and industrial waste will be disposed of through the use of an incinerator, as per normal practice in remote environments similar to Citronen. The incinerator will be an Atlas type 600 SL B WSP (or similar), which can burn 400kg of combustible waste per day and 100L of sludge oil per hour. Waste will be disposed of in accordance with applicable regulations.

The incinerator plant will be installed as an early priority at the beginning of the construction phase and will have sufficient capacity to handle combustible waste generated during the construction period. It will continue during the operation phase.

Incinerator ash will be disposed of to a site landfill, which will also handle all non-combustible waste, which does not have to be removed from site. The landfill will be located between the tailings dam wall and the waste rock dump, which abuts it, to ensure the landfill is fully encapsulated. Medical waste will be incinerated and disposed of as per domestic and industrial waste.

Mobile equipment tyres will be repaired where possible, but upon reaching the end of their useful life shall be encapsulated within the waste dump or placed underground within a stoping panel or mined room prior to backfill with tailings. A proportion of metal waste will also be disposed of to landfill or to underground.

Waste water and effluent from the accommodation, and administration facilities will be treated using a packaged sewage treatment plant. Effluent from the camp site will be carried to the sewage treatment plant through pipelines running below the arctic corridors to the main warehouse. Effluent from waste water will go into the process plant. The treatment plant will be installed as a priority at the beginning of the construction phase.

Domestic and industrial waste has been summarised in Table 19. A Waste Management Plan has been incorporated into the overall Environmental Management Plan in Section 8.3.

123

Table 19 Anticipated waste types and destinations.

Type of waste Origin Destination Treatment

Domestic putrescible Accommodation and Incinerator Incinerated waste administration facilities

Non-combustible Accommodation, Site landfill area Buried waste administration facilities, heavy and light vehicle workshops, process plant, port

Medical waste Medical station Incinerator Incinerated.

Industrial waste Heavy and light vehicle Incinerator, site landfill Recycled if possible, workshops, process plant, area incinerated or buried. port Waste oil Heavy and light vehicle Incinerator Incinerated workshops, process plant, port Incinerator ash Incinerator Site landfill area Buried

Tyres Heavy and light vehicles Waste dump Recycled if possible; buried

Waste water and Accommodation, Packaged sewage Biological breakdown of effluent administration and ablution treatment plant, then waste into effluent and facilities disposal of water to the sludge for disposal Eastern River and dried sludge to the waste dump

Hazardous waste (eg Process plant, storage area TSF or off site approved Treated by diluting through reagents) facility the process plant or contained and shipped off site

6.18 Health and Safety Management

Health and safety management on site will be to North American regulations pertaining to mining, which are benchmark statutory regimes. These requirements will be achieved at Citronen through a well-recognised risk based approach as per international best practice. The continual wellbeing of personnel and provision of a safe working environment will be ensured through implementation of a health and safety management system structured along the basis of OHSAS 18001, a recognised synergy of international health and safety management systems.

124

As part of the health, safety and environmental management system the operation will strive for continual improvement through training, optimisation and evolution of the operational procedures. Ironbark’s commitment to health and safety is in accordance with its corporate social responsibilities and corporate policy, which has zero harm at its foundations.

6.19 Emergency Preparedness

6.19.1 Site Emergency Management

Citronen will develop a Site Emergency Response Plan, covering all potential safety, health and environmental emergency situations and their management. The development of the plan and associated procedures will use risk and probability analysis tools, and will include necessary contingency and required resources to adequately manage an emergency situation. The Site Emergency Response Plan will set forth specific actions to be followed and a management controls should an emergency arise. The basic premise is that emergencies, whilst not expected, will be well planned for.

Fundamental to provision of a safe work environment and operation is the provision of adequate resources to manage emergencies. Any emergencies at operations of a remote nature similar to Citronen require a team with a high degree of self-sufficiency. Citronen will have in place an Emergency Response Team (ERT), which will comprise of specialist personnel drawn from the work force and trained in various aspects of emergency response. A full time ERT co-ordinator will be appointed on site, who in addition to fulfilling this role will also be the site medic. Supporting the ERT co-ordinator will be ‘on-call’ personnel drawn from operations and management having been trained as paramedics, fire-fighters and in other rescue disciplines.

The ERT will receive suitable resources in the form of site ambulance, fire tender, medical resources and health care facilities, as well as regular training and practice drills to ensure the highest provision of emergency service. Through training and maintaining a well-equipped ERT the site at Citronen will be able to deal with emergencies.

ERT provisions will be ancillary to back-up systems and safety controls designed to minimise potential hazards. Back-up power facilities will be available to ensure continued operation of life critical systems, namely ventilation, communications and power/heating to the accommodation, healthcare and runway facilities. Emergency evacuation planning will be undertaken and allowance made to ensure timely evacuation can be affected.

125

Environmental scenarios that will be incorporated into the emergency management plan include (but not limited to): fire, small and large fuel spills, small and large chemical spills, and any accidental release of fuel, chemicals, tailings, metal concentrate or any waste product into the Eastern River and/or Citronen Fjord.

A preliminary management plan for the loss of containment has been developed outlining those scenarios related to unplanned release of materials. This plan, Loss of Containment and Emergency Management Plan, can be found in Appendix 5 and will form part of the Environmental Management System (Section 8.2). This plan will be updated prior to the commencement of construction, and later operations, on site.

6.19.2 Shipping Emergency Management

A specific Shipping Emergency Response Plan will be developed separate to the site emergency plan. This plan will be developed in conjunction with Ironbark and the shipping contractor and based on applicable maritime regulations (such as those outlined by the Danish Maritime Authority) in regards to safe and environmentally responsible shipping in emergency situations.

The Loss of Containment and Emergency Management Plan mentioned in Section 6.16 (Appendix 5) includes unplanned release of hydrocarbons, chemicals or metal concentrate at sea and will form part of this overarching Shipping Emergency Response Plan.

6.20 Project Alternatives Considered

The location of the ore zones, and hence the open pit and underground mine, is fixed. All other Project components have some degree of flexibility in where they are located. This allowed Ironbark flexibility to move or redesign components to avoid or minimise impacts on environmental features. Alternatives for the Project considered the following factors:

• geological location; • licence holdings; • resource quality; • resource accessibility; • location of areas of potential conservation value; • practical resource extraction issues; and • economically viable scale of operation.

126

Transport of ore, underground crusher Ironbark investigated the feasibility of a crusher located underground, and ore transported to surface via conveyor, however the requirement to crush discovery open pit ore precluded the primary crusher being placed underground.

Transport of ore, portal crusher Ironbark assessed the viability of a primary crusher located at the portal and ore conveyed to the process plant. The remote primary crusher had several operational disadvantages, and the conveyor alignment crossed the most suitable location for the DMS dump. Realisation of conveyor belt operational economies is also much reduced if power is generated through a diesel power plant.

Large open pit at beach Ironbark carried out a trade-off study to investigate a large open pit at the Beach ore zone, but this was deemed not feasible due to the close proximity of the Citronen Fjord and the requirement to divert the Eastern River around the proposed pit crest. A large open pit would also have created significant volumes of waste that would have to be disposed of to a very significant waste dump.

Starter pit at beach During instances when the orebody (Beach South) is in proximity to surface it is possible to excavate a starter pit to extract initial ore prior to development of an underground decline. The requirement to divert the Eastern River due to proximity to any potential starter pit precluded the adoption of this approach.

Waste Dump locations Ironbark investigated other potential locations for waste rock dumps, but no suitable alternative locations were deemed appropriate in consideration of surface water flows, proximity to operations and surface topography.

Tailings storage facility location Ironbark investigated other options for location of the TSF, but no suitable alternatives were found in consideration of the surface water hydrology, geotechnical requirements and surface topography.

Tailings storage facility for life of mine tailings Ironbark assessed the potential to store all operational tailings within a large TSF, but a suitably large area meeting the aforementioned requirements was not available.

Tailings sub-aqueous disposal The presence of an adjacent deep body of water provides a suitable mechanism for disposal of tailings in a subaqueous environment. A preliminary assessment has been conducted to assess the suitability

127 of subaqueous disposal of the project tailings within Frederick E Hyde Fjord. Further studies are required prior to this alternative option being pursued.

Power generation Ironbark investigated the feasibility of sustainable power sources (hydro and wind), but these were found to be sporadic energy sources and therefore not suitable. The use of a sealed/packaged nuclear ‘battery’ as is common place in remote communities in North America was investigated and would have provided sufficient power in a sustainable manner, however the Greenlandic policy on nuclear power as well as the emotional aspects associated with nuclear power in a national park was deemed to preclude this option.

Zinc smelter at Citronen Ironbark investigated the potential to further refine the concentrate through smelting at site to produce a pure metal product; however the significant amount of energy required for roasting and subsequent electro winning is prohibitive due to the requirement to generate power through the use of diesel power generation. The environmental impacts of a smelter are also far more substantial than a mine with a processing plant due to smelters being net generators or consumers of acid and significant stack emissions.

128

7 Impact Assessment and Mitigation Measures

7.1 Risk Analysis Method

Ironbark uses a risk analysis model based on Australian/New Zealand Standard (AS/NZS) 4360:2004 Risk Management, as an assessment tool for environmental issues. The model uses a 5x5 risk matrix with four determined risk levels - Low to Extreme (Appendix 4).

The generally accepted measure of risk is the product of the likelihood of an event occurring and the consequence of that event. For example, an event that has a high likelihood and moderate consequence may be considered to have a similar risk level as an event that has a moderate or low likelihood but high consequence. To maximise the outcome of managing risks it is important that resources are allocated on a priority basis and that the highest priority issues are actioned first.

Ironbark has undertaken a risk analysis of major project tasks and activities (aspects) that have potential to impact on the environment. The priority risk rating from this analysis indicates that most site activities have an inherent (the risk before mitigation or management) risk level of low, with one activity rated as moderate and two activities rated as high. Ironbark considers this generally low level of risk is consistent with the nature and scale of the Project, which includes factors such as:

• Location in a remote area of Greenland, with the nearest permanent habitation being the Danish army base at Station Nord, 240km south-west of the Project; • Location in an arctic environment, with limited rainfall, permafrost and sub-zero temperatures. This results in reduced weathering/oxidisation of materials, freezing of mine wastes, limited runoff during a short period of the year and small numbers of plant and animal species that are able to adapt to these extreme conditions; • Tailings will be contained within a fully lined facility and underground; • A relatively small scale of disturbance, with limited clearing planned in a region sparsely vegetated; • No populations of flora or fauna unique to the Project area, eliminating the risk of catastrophic or major consequences to specific environmental factors; and • Most potential impacts having only a localised affect, which can be readily managed or remediated.

A key outcome of the environmental impact assessment is to rank impacts, so specific measures can be prioritised and developed for high risk impacts, to reduce residual risk (the risk after mitigation measures are implemented) to as low as practicable. Ironbark considers that by implementing control measures identified in this document and also the Citronen Environmental Management Plan (EMP)

129

(Appendix 6), the residual level of risk for the majority of assessed aspects can be reduced to low or moderate levels.

7.2 Citronen Fjord Ecosystem – Screening Level Ecological Risk Assessment

Project activities, in particular in association with deposition of mine waste at the waste dumps and the tailings facility, can potentially lead to contamination of the ecosystem with chemicals, including toxic heavy metals.

In order to assess potential chemical release points and transport routes and describe potential exposure pathways from contaminant sources to potential receptors (i.e., aquatic and terrestrial plants and animals) a Screening-Level Ecological Risk Assessment (SLERA) for terrestrial soil, marine and freshwater sediment, and marine and freshwater surface water including a toxicity test was initiated (Tetra Tech April 2012).

The results of the initial screening and conservative food web modelling identified Constituents of Potential Ecological Concern (COPECs) to ecological Receptors of Concern (ROC) at the Site, which supported a decision to conduct a more realistic exposure and risk characterisation using refined assumptions for the Site. Refinements included the use of bioaccumulation factors, site use factors, and dietary composition.

The conservative modelling identified a number of media/ COPEC/ upper-trophic level ROC combinations for which acceptable risks were found at the Site. The modelling focused on those media/COPEC/ROC combinations for which potential risk was identified as a result of the conservative modeling and for which appropriate Toxicity Reference Values (TRVs) were available in the toxicological literature. The absence of appropriate TRVs for some media/COPEC/ROC combinations means that it is not possible to dismiss potential risk for those particular combinations.

Standard ecological risk assessment practice (USEPA 1997) places ecological risk into the context of assessment and measurement endpoints, where assessment endpoints are those characteristics of an environment that need to be protected and measurement endpoints provide distinct measures of this degree of protection. The results of the conservative food web modelling suggest the possibility of risk for some COPECs in certain media and for certain types of receptors. The results of the SLERA are discussed below for soil, sediment and surface water at the Project.

7.2.1 Terrestrial Soil

Based on the initial screening of the SLERA, no inorganic constituents were identified as COPECs in terrestrial surface soil at the Project because the maximum modelled concentrations were less than

130 the respective ESV. However, some COPECs were identified as uncertainties due to the lack of modelled data. It should be noted that the uncertain COPECs may or may not pose a risk to receptors.

7.2.2 Surface Water

Ecological receptors identified that may be exposed to COPEC’s in Citronen Fjord surface water included aquatic communities, mammals (surrogate species included harbor seal for Citronen Fjord) and birds (surrogate species included herring gull, spotted sandpiper, and belted kingfisher).

The risks to aquatic communities were defined relative to concentrations of COPECs in surface water of Citronen Fjord during the first 135 years of operations and during the final three years of operations/closure and Lake Platinova during operations/closure based on ecological screening values.

There were three surface water COPECs (lead, nickel and zinc) during the final three years of operations/closure with potential risk to aquatic communities in the Citronen Fjord. Potential food web risk was indicated for zinc for the belted kingfisher during the final three years of operations/closure.

7.2.3 Sediment

Ecological receptors identified that may be exposed to COPECs in sediment of Citronen Fjord included benthic invertebrates, mammals and birds.

Arsenic and zinc were the only COPECs retained in the screening for the Citronen Fjord sediment during the final three years of operations/closure. The risks to benthic invertebrates were defined relative to concentrations of COPECs in sediment of Citronen Fjord based on ecological screening values. Arsenic and zinc indicated potential risk to benthic communities in Citronen Fjord sediment during the final three years of operations/ closure. Potential food web risk was found for arsenic and zinc in Citronen Fjord sediment during the final three years of operations/closure to the belted kingfisher. The harbor seal and herring gull were also found to be at risk from arsenic in the sediments of Citronen Fjord during the final 3 years of operations/closure.

7.2.4 Existing conditions

Current conditions indicate zinc in the natural background sediment and surface water of Citronen Fjord present risk to aquatic receptors. Surface water zinc concentrations associated with the first flush into the Eastern River under summer thaw conditions are well above the surface water screening

5 The SLERA study was conducted based on a 16 year mine life.

131

value of 0.01 mg/L with minimum concentrations of approximately 0.4-0.5 mg/L to maximum concentrations over 2 mg/L. Therefore, the risk surrounding zinc concentrations in sediment and surface water during operations and closure may not be warranted due to the natural background concentration of zinc in the Eastern River.

7.2.5 Ecotoxicological Testing

No significant mortality of the mysid shrimp, (Americamysis bahia), and the sheepshead minnow, (Cyprinodon variegatus), was observed at any test concentration including 100% tailings supernatant. The results of these tests indicate that there is no toxicity associated with the tailings supernatant to

either species because the calculated LC50 was greater than 100%. Therefore, the risks to lower trophic level aquatic communities indicated in the SLERA are not substantiated by the toxicity tests.

7.3 Flora

7.3.1 Vegetation

Clearing of vegetation will be required for the waste rock dump, DMS rejects dump, tailings storage facility, processing plant, haul roads, air strip and other infrastructure, including the accommodation camp. Much of the area where disturbance will occur is characterised by almost bare ground with loose rubble and broken slopes with no or very little vegetation cover.

On average the vegetation cover in the Citronen area is about 5% but some areas, such as the Discovery Zone and the area where the airstrip will be constructed, have virtually no vegetation. Continuous vegetation is mostly found in depressions and along streams. This vegetation is dominated by a few plant species that are common and widespread in North Greenland, therefore clearing within the Project will not impact representative flora of the area. Among the (approximate) 50 species of plant species known to occur in the Citronen Region none are rare or endangered.

The loss of vegetation is regarded as mostly temporary as re-growth will take place when the mine is closed and rehabilitation is encouraged. Regrowth is likely to take a long time (possibly in excess of 50 years) due to the extreme weather conditions.

Management and mitigation measures are discussed in Section 7.3.4, and in more detail in appendix 6 – Environmental Management Plan. These measures including minimising disturbance by planning infrastructure to have as small a footprint as possible, avoiding as far as practicable any clearing of

132 remnant vegetation during construction, no vegetation to be disturbed by temporary works such as access tracks or site offices.

Residual Risk rating is Low.

7.3.2 Topsoil

Clearing of vegetation will also require some removal of the upper soil layer. Less than 10% of the ground of the Project area has a soil layer and most of this is found in patches along the fjord. While most of the soil resource at the waste dump and tailings pond will be overlayed and lost, the soil resource at the fjord may be conserved where practicable and subsequently put back in place at the end of the life of the mine.

As the overall area that will lose its soil layer is small in relation to surrounding available land, the overall loss of soil is considered to be insignificant. With mitigating measures implemented to conserve and re-use at the end of mine life, the significance of the impact is further reduced.

Management and mitigation measures are discussed in Section 7.3.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk rating is Low.

7.3.3 Fauna habitat

Given that plants cover only a small percentage of the ground in at Citronen, and because the overall footprint of the mine project is relatively small with several of the major constructions works in areas with almost no vegetation (pit and airstrip), the impact to fauna habitat is considered very small in relation to the surrounding available vegetation. It is anticipated that species such as arctic hare, collared lemming and ptarmigan may adapt to human presence and infra-structure, therefore efforts will be made to retain some areas of continuous vegetation as a potential food source. The loss of terrestrial habitat due to the mine Project is therefore considered insignificant.

Management and mitigation measures are discussed in Section 7.3.4, and in more detail in appendix 6 – Environmental Management Plan. These measures include cleaning machinery prior to arriving on

133

site, vehicle hygiene measures to avoid the spread of weeds on site, and implementing weed control measures.

Residual Risk rating is Low.

7.3.4 Flora management and mitigation measures

• Minimise disturbance by planning infrastructure to have as small a footprint as possible; • During construction works, clearing of remnant vegetation will be avoided as far as practicable; • No vegetation is to be disturbed for temporary works such as access tracks, spoil areas or site offices; • Vehicles and equipment will not be parked or driven over vegetation to be retained; • If useable topsoil is present, conserve it for use in progressive and end of mine rehabilitation; • Clean machinery prior to arriving on site as there will be no wash down facilities available and equipment will not be granted entry if not thoroughly clean; • Machinery and vehicle hygiene measures will avoid the inadvertent spread of weeds throughout the site; and • Any weeds encountered on site will be eradicated or controlled using the least toxic methods practicable (i.e. physical or other means of removal before the use of chemicals).

7.4 Fauna

7.4.1 Fauna habitat - freshwater

The overall dynamic of Lake Platinova will change when a dam will be constructed to increase the water holding capacity to approximately 1.8 million m3. Water will be pumped into the lake from Eastern River during summer. The water level of the lake will drop gradually during autumn, winter and spring as water is used in the processing plant and as potable water for the Project.

No fish occur in the Eastern River and therefore it is anticipated that the Project will have little to no impact on the fauna of the river.

Lake Platinova has a resident population of arctic char. The fluctuations in water quantity and quality within the lake due to pumping could potentially have an impact on the lake ecosystem, including the arctic char population.

134

The long term impact on the char population is difficult to assess with certainty. Large scale annual fluctuations in the depth of the lake may have a negative impact on breeding of the chars and could lead to the decline or loss of this population in the lake. If the arctic char population in Lake Platinova is lost during the life of the mine, it is recommended that fish from a resident population in the region are introduced when the mine is closed and the level of the lake has stabilised.

It is likely that the fauna will be impacted by the removal of water from Lake Platinova to an unnatural low level, hence the significance of this impact is considered High.

Management and mitigation measures are discussed in Section 7.4.6, and in more detail in appendix 6 – Environmental Management Plan. These measures include monitoring arctic char health and returning the lake embankment to allow the water levels to return to natural levels once mining has closed, and fish from a resident population in the region are to be reintroduced on mine closure.

Residual Risk rating is High.

7.4.2 Fauna habitat - marine

The port and some associated infrastructure facilities will be constructed at the shore of Citronen Fjord. This will require some re-profiling of the shore. A 15m wide access dike will also be constructed.

The dredging to deepen the water at the port will lead to a local loss of shallow marine habitat and a temporary increase in suspended material in the sea water. The construction of the port itself will lead to a minor loss of inter-tidal habitat. The re-profiling of the shore and sea floor will remain after mine closure.

Little is known about the marine flora and fauna of Citronen Fjord. However, data collected in connection with the ecological baseline work suggest that four-horned sculpins are the only resident marine fish in shallow waters, that anadromous arctic char occur in small numbers during summer and that very few/no mussels or seaweed are present at low depths (below 10m). Marine mammals (seals) or seabirds were not recorded in the south-east corner of the fjord during the 2010 baseline survey.

The increase in suspended material in the sea water due to the dredging and construction of a dike will be temporary and will most likely have less of an impact on the marine flora and fauna than the very large amount of silt which naturally discharges into the fjord from the Eastern and Esrum rivers during the warmer months. It was observed that the entire fjord was covered by approximately 2m

135 layer of very silted water for four to five days during a particularly warm period (which has caused an increase in ice melt upstream).

The impact of the port during the operation and post operation phases is also considered to be very low because of the small footprint area. It can therefore be concluded that the loss of marine habitat during the construction and operation of a port has a very low significance to the marine flora and fauna of the Citronen Fjord.

Management and mitigation measures are discussed in Section 7.4.6.

Residual Risk rating is Low.

7.4.3 Fauna - shipping

See Section 7.8.

7.4.4 Fauna - mine site

A number of mining activities may potentially disturb mammals and birds in the mine area:

• Noise disturbances from blasting at the pit site and from the crushers, power plant, trucks and other infrastructure. In particular the intermittent blasting noise, which can be heard at a significant distance from the mine, has the potential of scaring mammals and birds.

• Visual disturbances from personnel, roads, buildings and other project structures which might cause mammals and birds to avoid utilising habitat in and near the mine area.

Mammal and bird species react very differently to noise and visual disturbances. Among the mammals that regularly occur at Citronen, muskoxen and wolves must generally be considered the potentially most sensitive to disturbance from the Project.

So far encounters between muskoxen and human activities in north Greenland are rare and relatively little is known about the short and long term impact of for example mine projects within the range of muskoxen. However, some reaction to noise and visual disturbance from the Project area is expected at least among some parts of the population.

In muskoxen, most deposition of fat takes places during summer while during winter they are generally losing weight. It can be said therefore that muskoxen are particularly sensitive to disturbances during late winter (March – May) when fat deposits are low and food resources often

136 depleted. Late winter also coincides with the calving period which makes the cows and calves particularly vulnerable to any kind of disturbance.

Wolves in north Greenland often show relatively little fear of man probably because they have rarely or never met humans before. However, the noise and human activities from the Project will most likely cause wolves to avoid the Project area and near surroundings. Other mammals, such as the arctic fox and arctic hare usually habituate well to human activities where they are not hunted. This was observed at the camp at Citronen where hares were observed occasionally foraging between the tents.

It is likely that some of the collared lemmings of the Citronen Fjord area will inhabit the Project area, as lemmings have been known to follow paths and roads that lead them directly through areas of human habitation and show little fear of people. When lemmings migrate they do not travel to a specific destination, they are simply moving away from their crowded feeding grounds in search of new ones. As such, at Citronen it is expected that lemmings will move within and around the Project site where vegetation is available.

Among the species of birds that regularly occur in or close to the Project area, pink-footed geese are known to be sensitive to disturbance especially during the three week period when they moult their flight feathers and are unable to fly. Although no or very few geese seemed to over-summer (or moult) in the Citronen Fjord area during early-mid August 2010, clear signs were observed that geese had utilised the green patches of vegetation along the shore of the fjord and in the nearby valleys earlier the same year. This is most likely geese that have spent a few days foraging in these areas before continuing towards the north and north-west. It is unknown if the geese moved away because they were disturbed by the activities at the Citronen camp, because the food resources were depleted or for other reasons.

Among the birds that breed in the Project area, in particular long-tailed skua, ringed plover, sanderling and ruddy turnstone could potentially be disturbed by the mining. However, the three species of waders are not known to be particularly sensitive to noise or visual disturbance but will most likely avoid breeding within some hundred meters of human infrastructure.

Mining activities at the Project have the potential to cause localised disturbance of terrestrial mammals and birds, particularly muskoxen, lemmings, wolves, pink-footed geese and breeding waders. However it is likely that these species will move to areas outside the mine site once disturbance and construction begins. As this movement may not be far from the site it is recommended that vehicles (or any similarly noisy machinery) are prohibited off site during the period March to mid-August when these species are most sensitive to disturbance. One exception to this

137 maybe when environmental staff are required to travel for sampling or monitoring purposes. Overall the noise or visual impact of the mine to the local fauna is considered low.

Management and mitigation measures are discussed in Section 7.4.6, and in more detail in appendix 6 – Environmental Management Plan. These measures include prohibiting movement of vehicles and people outside the project area, unless management approval has been given.

Residual Risk rating is Low.

7.4.5 Fauna interaction

The Project could potentially lead to increased direct mortality among animals and birds due to road kills, increased nest predation of birds due to enhanced concentration of human-subsidised predators and poaching.

The movement of trucks and other vehicles along the haul and service roads represents a potential risk for road kills of animals. However, given the small number of animals expected on site and if reasonable speed limits are set then the anticipated impact is considered to be low.

It has been suggested that human development in remote areas could lead to concentrations of human-subsidised predators (such as arctic foxes) and reduced nest survival of ground breeding birds. A recent study from the tundra of Alaska failed to detect such a relationship between infrastructure and nest survival for waders as a group (Liebezeit et al. 2009). Lower productivity was recorded among a few species of waders closer to infrastructure while a relationship between infrastructure and nest among the most common species of waders was not recorded (Liebezeit et al. 2009). However, evidence was found that the risk of predation of passerine nests increased within 5km of infrastructure (Liebezeit et al. 2009). The only passerine that breeds regularly in the Project area is snow bunting. In order to minimise the risk of this potential impact it is recommended, that food waste is not left exposed to attract scavengers to site.

Hunting inside the the Northeast Greenland National Park is strictly forbidden except for a small group of local people living in Avanersuaq and Ittoqqortoormiit. Hunting will be forbidden on the mine site and as such the impact of poaching is not regarded as significant.

Management and mitigation measures are discussed in Section 7.4.6, and in more detail in appendix 6 – Environmental Management Plan. These measures include ensuring stipulated speed limits are enforced along roads, and ensuring adequate training of truck drivers and other staff to be aware of animal hazards and how to minimize any negative consequences.

138

Residual Risk rating is Low.

7.4.6 Fauna management and mitigation measures

• Water required for processing will be sourced from dewatering and TSF in conjunction with lake water • Monitor Lake Platinova water levels monthly. Arctic char health and abundance will be monitored. • On closure the lake embankment will be manipulated as to allow the water to return to natural water level • Sightings of fauna during the journeys will be recorded • Prohibit movements of people and vehicles (snowmobiles and All-Terrain Vehicles) outside the Project area during the period March to mid August (i.e. staff should not be allowed to go exploring the area), unless prior management approval has been given • Ensure stipulated speed limits are enforced along roads to minimise the risk of road kills • Ensure that truck drivers and other staff are trained to be aware of animal hazards and how to minimize any negative consequences • Ensure that food waste is not left exposed to attract scavengers to site • Prohibit poaching of muskoxen and other animals by company employees and contractors, as is regulation in National Parks • Native fauna shall not be captured, fed, harmed or disturbed. If fauna relocation is required, the Ironbark environmental representative shall be contacted. • Any incidental death or harm to fauna shall be reported in the site incident reporting system • Drill holes (or similar) shall be capped after completion of drilling

7.5 Freshwater Resources and Surface Water

7.5.1 Eastern River

During the three month (summer) period the Eastern River is flowing, 1.3 million m3 of water will be pumped into Lake Platinova for use on site, corresponding to 1,000 m3 of water per hour. Removal of this volume of water has potential to alter the flow dynamics of the Eastern River.

The average annual discharge of Eastern River during the three month flow period is about 17 million m3 (Tetra Tech, 2010). Pumping the required volume of water to Lake Platinova from Eastern River

139 approximates to 8.8% of the total runoff. Since the discharge of the Eastern River is mainly controlled by the air temperature (not precipitation) the flow is lowest during colder periods. During cold spells the pumping of water could therefore lead to a significant amount of water being removed from the lower part of Eastern River (the last 2km of the river before it meets the fjord) and will be most affected by the reduction in water levels. However even a substantial lowering of this part of the river during a few days will have little impact on the water dynamics of the area, or to the flora and fauna of the river as very few aquatic animals (and no fish) occur.

Management and mitigation measures are discussed in Section 7.5.5, and in more detail in appendix 6 – Environmental Management Plan. These measures including monitoring the Eastern River water level, flow and water discharge during times when the river is flowing.

Residual Risk rating is Low.

7.5.2 Lake Platinova

Water supply to the Project will be sourced from Lake Platinova. The annual requirement is estimated to be 1,664,440 m3. The current water storage in the lake is only 0.5 million m3, hence requiring an 8m high embankment to be constructed along the north-east shore to increase the water storage capacity to approximately 1.8 million m3. The water in the lake will be utilised for operational requirements in the processing plant and as potable water for the Project. This will result in water level variations that are significantly lower than natural levels in spring (May) and high in July-August after water has been pumped into the lake during Eastern River flows.

Lake Platinova is currently connected to Eastern River via a temporary flood channel on the northeastern side of the lake. Water normally only flows out of the lake into the river periodically during the snow melting period from June to early August, although this is not adequate for the migration of arctic char. The annual discharge into Eastern River via this channel is estimated to 0.5 million m3. The embankment will block this outlet to increase the water storage capacity of the lake. When the

Project ends and the need for process water stops, a new drainage channel will be formed that discharges Lake Platinova overflow back into Eastern River.

The change in water volume of Lake Platinova will have little impact on the overall surface water regime in the Project area other than the temporary outlet from the lake will stop discharging water into the Eastern River. However, some adverse impacts are anticipated to the lake ecosystem, including the arctic char population, due to the fluctuations in water quantity and quality within the lake due to pumping.

140

No impact to the Eastern River is anticipated because although water will be removed from the river it is already experiencing very high water flow (approximately 17 million m3) from melting snow and ice. The significance of the alteration of Lake Platinova water levels for water supply to the Project is considered to be High.

Management and mitigation measures are discussed in Section 7.4.6, and in more detail in appendix 6 – Environmental Management Plan. These measures include monitoring arctic char population in Lake Platinova and determining satisfactory abundance levels. If required introduce arctic char from nearby populations to supplement the population.

Residual Risk rating is High.

Between June and September each year of operation, 1.3 million m3 of water will be pumped from the Eastern River into Lake Platinova. During the first 25 days (approximate) of flow, Eastern River contains naturally elevated metal concentrations, in particular zinc, copper, cadmium and lead due to water contacting gossans (oxidised and weathered sulfidic rock) within the catchment area of the river. This includes maximum concentrations of 3657 µg/L of zinc, 21 µg/L of lead and 11 µg/L of cadmium (2010). As such water will not be pumped during this time to ensure that minimal concentrations of metals are directed to the lake.

If water with high metal concentrations was pumped into Lake Platinova it could potentially increase the metal concentrations in the water column and may have a negative impact on the lake ecosystem, including the resident arctic char population. To minimise the metal concentrations in the lake, river water shall be sampled and analysed for metals to ensure that levels are within acceptable limits prior to pumping to the lake.

In the SLERA study, COPECs identified in the surface waters of Lake Platinova for 16 years of operations and at closure were aluminum, arsenic, cadmium, copper, iron, lead, mercury, nickel and zinc. The surface water screening compared the modeled maximum concentrations of the COPECs in the lake during operations and closure to Greenland Water Quality Guidelines (BMP 2011) and Canadian Water Quality Guidelines (CCME 2007).

The screening of COPECs in Lake Platinova surface waters during operations/closure indicated that all COPECs were below the regulatory guideline values (\). However, some values are above natural background levels.

141

Table 20 Comparison of maximum modelled Lake Platinova surface water concentrations to freshwater screening values during 16 years of operations and closure.

Surface Water Surface Lake Platinova Water Eliminated Screening Water COPECs Quality From Risk Value Screening Assessment mg/L mg/L Value Source Aluminum 1.02E-04 0.100 a Yes Arsenic Not Above Background 0.004 b Yes Cadmium 2.76E-06 0.0001 b Yes Copper 8.26E-06 0.002 b Yes Iron Not Above Background 0.30 b Yes Lead 2.52E-04 0.001 b Yes Mercury Not measured 0.00005 b Yes Nickel 9.51E-05 0.005 b Yes Zinc 5.38E-04 0.010 b Yes

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a = CCME, 2007a; b= BMP, 2011.

Sediment concentrations (Table 21) are all below freshwater sediment screening values with the exception of lead and nickel. Mercury was retained as a data gap due to lack of screening values available. Lead and nickel where then assessed for exposure to lower and upper trophic level communities. This assessment confirmed that nickel required further evaluation in a refined site- specific assumption analysis for a food web model (muskrat, herring gull, spotted sandpiper and belted kingfisher). The results of this analysis showed that there was no potential risk from nickel to upper trophic receptors during operations or closure.

142

Table 21 Comparison of maximum modelled Lake Platinova sediment concentrations to freshwater sediment screening values during 16 years of operations and closure.

Modelled Sediment Sediment Eliminated

COPECs Concentration Screening Value Screening From Risk (mg/kg) (mg/kg) Value Source Assessment

Arsenic 3.42 17 a Yes Cadmium 0.823 3.5 a Yes Copper 12.61 197 a Yes Lead 122.1 91.3 a Retained Mercury 1.00E-03 NA NA Data gap Nickel 32.63 18 b Retained Zinc 157.30 315 a Yes

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a = CCME, 2002; b= NOAA, 2008

On closure, water will no longer be pumped to Lake Platinova. Due to the low concentrations of metals estimated to enter the lake, and the results obtained during the SLERA, it is expected over time that the water quality will quickly return to pre-mining conditions. This activity has therefore been considered to be a Low impact.

Management and mitigation measures are discussed in Section 7.5.5, and in more detail in appendix 6 – Environmental Management Plan. These measures include starting water pumping from the Eastern river will only once water quality is below agreed guideline limits.

Residual Risk rating is Low.

7.5.3 Pit dewatering

In the last year three years of mining, it is planned to mine an open pit in the Discovery Zone. During this time any water that enters the pit will have to be dewatered in order to facilitate mining (Section 6.1.2.1 Dewatering of Open Pit). Water that enters the pit will be from rainfall, snow melt and localised runoff. It is not anticipated that groundwater will contribute to inflow due to the permafrost. Large volume surface water runoff from the surrounding landscape will be diverted around and away from the pit edge by appropriately designed and installed diversion drains and bunding.

143

Water entering the open pit is likely to come into contact with waste rock/lean ore material exposed on the pit walls. Geochemical characterisation studies (Section 6.4.1) have indicated that this contact may potentially lead to elevated metal concentrations in any water within the pit. Should water from the pit enter the Eastern River and Citronen Fjord there may be a risk of contamination of these environments.

The modelled water quality in Citronen Fjord (SLERA July 2012), at the head of the Eastern River, during the last three years of operations and closure is outlined in Table 22. This includes inputs from not only the pit wall runoff but also leachates that may come from the waste dump and DMS rejects dump as indicated in the conceptual site model.

Table 22. Comparison of maximum modelled Citronen Fjord surface water concentrations to marine water screening values during final three years of operations and closure.

Modelled Surface Water Background range (2010) Eliminated Concentration Screening Value ug/L COPECs From Risk Citronen Eastern ug/L ug/L Assessment Fjord River Aluminum 27.2 100a Yes NA NA Arsenic 3.73 5b Yes NA NA Cadmium 0.179 0.2b Yes 0.01 – 0.12 0.01 – 10.9 Copper 0.547 2b Yes 0.4 – 6.7 0.1 – 2.9 Iron <5 30b Yes NA NA Lead 3.6 2b Retained 0.2 – 7.7 0.01 – 21.4 Mercury <0.05 0.005b Yes NA NA Nickel 25.5 5b Retained 1.3 – 2.3 0.05 – 8.1 Zinc 216 10b Retained 0.02 – 20.1 0.1 - 3657

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a b = CCME, 2007a; = BMP, 2011; NA Not Available

The results show lead, nickel and zinc exceed the screening values for surface water and required further evaluation. It is important to note that the levels for lead were lower than background concentrations in the Eastern River and Citronen Fjord (also Frederick E. Hyde Fjord - Table 26 Section 7.6.1). Zinc concentrations are lower than background values for the Eastern River. The background levels for zinc, lead and nickel in the Eastern River and lead and zinc in Citronen Fjord are all higher than the BMP guideline values.

144

Ironbark proposes the following measures are taken to ensure the potential environmental impact identified by the SLERA is effectively considered and managed: • Ironbark commits to ongoing geochemical testing and monitoring to further refine the SLERA model during mining operations; • Ironbark commits to suitable mitigation measures to manage water quality within the Citronen Fjord should the ongoing SLERA model indicate that this is required; and • Ironbark commits to meeting the licence environmental conditions as agreed by both Ironbark and the MRA following the public hearing sessions and white paper comments, and as updated during mine operations.

Arsenic and zinc were above screening values for sediment in the fjord and hence required further evaluation (Table 23).

Table 23 Comparison of maximum modelled Citronen Fjord sediment concentrations to marine sediment screening values during final three years operations and closure. Maximum Sediment Sediment Eliminated COPECs concentration Screening Value Screening From Risk mg/kg mg/kg Value Source Assessment Arsenic 270 41.6 a Retained Cadmium 0.3 4.2 a Yes Copper 2.4 108 a Yes Lead 12.5 112 a Yes Mercury NA NA NA Data gap Nickel NA 15.9 b Data gap Zinc 1090 271 a Retained

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a = CCME, 2002, b= NOAA, 2008

Lead nickel, zinc and arsenic were further assessed for exposure to lower and upper trophic level communities. This assessment confirmed that arsenic and zinc required further evaluation in a refined site-specific assumption analysis for a food web model (harbor seal, herring gull, spotted sandpiper and belted kingfisher). The results of this analysis showed that there is potential risk to fish eating birds as well as to marine mammals if the pit discharge enters the river/fjord.

The volume of water that needs to be pumped from the open pit is believed to be low. This is because precipitation is very low in the Citronen area (<200 mm per year) and diversion drains and bunding

145 will limit the amount of water entering the pit in the first instance. In addition, any water in the pit is most likely to be frozen, again limiting groundwater movement and or surface flow.

Water quality estimates from the SLERA Geochemical model represent maximum concentrations of constituents in the Citronen Fjord at the head in the Eastern River (i.e., no dilution). It is reasonable to anticipate some dilution of water from site inputs (eg waste rock dump leachates) will take place within the Citronen Fjord, however, a comparison of the August 2010 water quality obtained from the Eastern River (MP-05) with surface water quality from the Citronen Fjord obtained on the same date suggests mixing is limited (25-50% dilution) and highly variable depending on the constituent. Therefore, no dilution factor was used to represent Citronen Fjord water quality. In addition, the residence time of fresh water in Citronen Fjord has been estimated to only be a few days (Glahder and Asmund 1995) suggesting that exclusion of a dilution factor when considering risk in the Citronen Fjord is highly likely to be overly conservative and more likely to represent the worst case scenario that might not be realised.

As previously indicated, the pit will be dewatered during operations. The water quality will be routinely analysed to determine the appropriate disposal location. If water quality meets the Greenland BMP guidelines (BMP, 2011) the water will be pumped directly to the Eastern River. However, if the water quality does not meet the guidelines then this water will be pumped to the processing plant for reuse. Any waste water from the processing plant will then be discharged to, and contained within, the Tailings Storage Facility as per standard practice. Chemical treatment of the water may be considered should the above mitigation measures not manage the risk to an acceptable level. Consequently the risk of contamination during operations has been assessed as low.

After closure (when the plant is decommissioned), alternative mitigation measures may be required to manage the pit water as pumping will not be possible once the site is closed. Once dewatering from the pit ceases any water will remain as a pit lake in the bottom. A potential risk exists that water could leave the pit system either via groundwater infiltration or from surface overflow, however this is expected to be a very low probability due to permafrost in the pit wall.

As the operation progresses and more data is available Ironbark intends to continue the SLERA and geochemical characterisation studies to further refine the expected chemistry of the pit. Hydrological studies will also be conducted and will provide more information on the mechanics of the pit seepage. Obtaining a more precise model of what will happen with the pit will assist in determining the most appropriate and effective post-closure management strategy to ensure that any water discharge does not result in contamination of the environment and meets the guidelines values.

Due to the high water flow of the Eastern River (estimated at approximately 17million m3/year) and the estimated low amount of dewatering required it is anticipated that potentially contaminating water

146 will be highly diluted prior to entering Citronen Fjord. It is also highly likely that this dilution (although not considered in the model) will further reduce the metal concentrations estimated in the fjord. However due to the results of the modelled concentrations in the SLERA risk of contamination has therefore been considered Medium.

Management and mitigation measures are discussed in Section 7.5.5, and in more detail in appendix 6 – Environmental Management Plan. These measures include monitoring the water discharge volume from the open pit, and continue to geochemical testing of pit water. Melting water will be prevented from entering the pit by construction of diversion drains.

Residual Risk rating is Medium.

7.5.4 Surface water flow

Most mine facilities will be situated along the south-eastern shore of the Citronen Fjord. This includes fuel storage, port, container storage, power plant, crushers, main warehouse and accommodation block.

A 1,000m airstrip and 4.5km of haul road will be constructed between the pit and the crusher at the port. In addition, several service roads will connect the airstrip, the explosive magazine and the fuel storage area with the haul road. A number of buildings (explosive magazine, airport terminal) will also be constructed. The construction of the airstrip, roads and building will require some re-profiling of the terrain.

Diversion drains will be constructed around the pit crest, underground decline, tailings storage facility and waste rock dumps to prevent water from entering these facilities, particularly melting water in spring and summer. The water will be diverted to the Eastern River and/or the fjord. A few small temporary streams may also be diverted around the mine facilities at the shore of the fjord. The diversion drains at the pit, decline, tailings storage facility and waste rock dumps will remain on closure while the other diversions (not required for long term stability) will be removed during the rehabilitation of the mine.

Culverts will be constructed at two points on the Eastern River to allow haul road crossings. The flow of the Eastern River is limited to June – September/October. When running, the rate of flow is mainly controlled by the air temperature with high temperatures causing massive melting of upstream glaciers. The culverts will be sized accordingly and will be constructed to avoid a build up of “ponded” water upstream of the constriction points during a succession of warm days when peak flow occurs.

147

The culverts will also be constructed and sized to handle freezing conditions and in particular during break-up when blocks of ice are washed down the river.

Culverts will also be put in place to permit a small stream to run under the road adjacent to the DMS rejects dump. The construction of roads will not require other changes of rivers or streams. The culverts will be removed at mine closure.

The culverts should not cause any significant flow constrictions to the Eastern River or lead to erosion along the banks of the river.

Precipitation in the Project area is very limited and the annual runoff of the local catchment area is small and limited to June to September. The diversions around the mine facilities will therefore only be diverting small amounts of water during a short time of the year. The diverted water will be directed to its original outflow destination. The significance of this is therefore assessed to be low as no adverse impact is anticipated. The change in topography resulting from the construction of facilities for the mine is anticipated to have a low impact on the flow patterns and capacity of streams and rivers in the Project area. At closure, the drainage of the surface topography will be reinstated where practicable.

Management and mitigation measures are discussed in Section 7.5.5, and in more detail in appendix 6 – Environmental Management Plan. These measures include construction of diversion drains and bunding to direct water flow to the Eastern River.

Residual Risk rating is Low.

7.5.5 Water management and mitigation measures

• Monitor water levels monthly, including Eastern River water level, flow and water discharge during flows, volume of dewatering effluent from the pit • Water quality of Eastern River will be sampled and analysed in the first weeks prior to pumping. Pumping will only commence once water quality is below agreed guideline limits. Pit dewatering water will be pumped to the river on the downstream side of the Lake to prevent any entering the lake. • Monitor arctic char population in Lake Platinova. Determine satisfactory abundance levels. If required introduce arctic char from nearby lakes to supplement the population. • Water required for processing will be sourced from dewatering and TSF in conjunction with lake water

148

• On closure the embankment will be manipulated as to return the water level back as close to the original as possible • The discharge channel between Lake Platinova and Eastern River will be reinstated after operations • Continue geochemical testing of pit water. Analyse pit water prior to dewatering. Investigate alternatives for water disposal should acceptable water quality not be achieved. • Melting water will be prevented from entering the pit by construction of diversion drains and pit crest bunding • Water will be pumped from underground to the process plant or direct to TSF. On closure ice backfill and permafrost will prevent ARD formation • Diversion drains and bunding will be constructed where required to re-direct water flow to Eastern River • Maintain a minimum setback of 50 m from drainage lines for disturbances unless otherwise approved • Take water quality samples if potential contaminants are believed to have reached natural drainage channels • Ensure no construction material (such as gravel, blue metal) are left in river beds or banks or other watercourses or drainage channels • Culverts will be constructed where natural flows of water need to be maintained • Remove culverts at mine closure

7.6 Waste Rock Dumps

7.6.1 Waste rock dumps

The waste rock dump will be located south of the tailings storage facility. Approximately 18.7 million tonnes of waste rock will be deposited at the waste rock dump. Leachates coming from the waste rock dump are a potential contaminant source of the terrestrial ecosystem surrounding the dump and nearby water resources, e.g. Eastern River and Citronen Fjord.

The geochemical characterisation conducted on the waste rock material show that the waste rock is generally non-Potentially Acid Generating (non-PAG) regardless of the sulphur content. Only one out of 32 samples tested was likely to generate acid. Humidity cell testing has revealed that after 107 (max) weeks (average was 68 weeks) of testing all waste rock humidity cells were producing leachates with relatively stable neutral to alkaline pH.

149

Streams of melting water that passes through the waste rock dump and come in contact with waste rock material will cause an insignificant release of constituents. The very low annual precipitation at Citronen (less that 200 mm annually) means that most potential for leaching of water will be through contact with melting water from the mountain slopes behind the waste rock dump that runs through the dump and connects with the Eastern River. To minimise the contact with this meteoric water, a diversion drain will be constructed to divert the melting water around the waste rock dump and directly into the Eastern River.

Rejects from the Dense Media Separation (DMS) will be dumped at the DMS rejects dump located west of the tailings pond between the haul road and the airstrip. Leachates from DMS Rejects dump are also a potential contaminant source of Easter River and Citronen Fjord.

The trace metal content tests conducted on the waste rock samples suggested that elevated metal/metalloid concentrations such as lead, zinc, cadmium and arsenic are likely in runoff from the dump. The SLPS results showed that the DMS Rejects samples produced extracts with alkaline pH. These results suggest that release of constituents will generally be limited during contact with water. However, arsenic slightly elevated above the BMP Greenland Water Quality Guidelines (5 µg/l) was observed in the DMS Rejects extracts.

A toe bund will be constructed at the base of the DMS Rejects dump to capture any runoff from the dump (either water or silt). The bund will also direct any high water flow from the Eastern River away from the toe of the dump (during times of high flow the delta is variable year to year). The bund will divert water away from the dump which may impact the stability of the dump. Also, where possible, water must be avoided from contacting the dump as geochemical testing suggests that limited constituents such as metals would be released under such circumstances. Arsenic in DMS Rejects extracts, will most likely be diluted to levels well below BMP Greenland Water Quality Guidelines when coming in contact with the river. During 2010 the arsenic level in the Eastern River was measured to between 0.01µg/l and 0.39µg/l (Section 5.6.2.1, Table 3).

Water quality for the waste dump and DMS rejects dump (including pit wall runoff) were estimated to provide input to the geochemical model. Data used to estimate water quality was obtained from the geochemical characterisation program (Tetra Tech, July 2012) and baseline data, primarily the 2010 sampling event. A summary of the input solutions are provided in Table 24.

150

Table 24 Input solutions for the geochemical modeling.

Eastern River- Waste Rock/ Lean DMS Leachate Pit Wall Runoff (HC-1, HC- Parameter Early Season Ore Leachate (HC-1) (HC-2) 2, Acid Generating Ore)

pH 8 8.11 8.72 8.2 mg/L

Bicarbonate 84 141.5 79.3 75

Sulfate 19 52.8 22 71

Al 0.0021 0.016 0.16 0.56*

As 8.00E-05 3.40E-04 5.90E-04 0.098 Ba 0.0039 0.021 0.021 0.02 Ca 28.2 55.5 18.1 80.6 Cl 2.2 5 12 6.9 Cr 1.05E-05 1.00E-04 1.00E-04 1.00E-04 Fe 0.0125 0.004 0.001 5.00E-10 Mn 0.0213 0.047 0.0082 0.03 Mg 7.17 12.7 14.8 12.7 Cu 2.81E-04 5.90E-04 2.80E-04 0.015 Si 6.8 0.89 0.094 0.61 Cd 0.00154 1.80E-04 2.50E-06 0.008 Na 1.466 4.6 4.6 3.7 Co 2.81E-04 2.30E-04 2.30E-04 2.20E-04 Zn 0.492 0.036 8.00E-04 6.9 K 0.248 1.7 10 Pb 8.70E-05 5.50E-02 4.30E-04 5.00E-02 Ni 8.27E-04 0.001 0.67 Hg 1.15E-05 1.00E-05 1.00E-05 3.30E-05 Notes: Non-detected values were converted to ½ the reporting limit *Aluminum concentration set at 10 mg/L in gossan sample HC – humidity cell sample

The approach used to determine the hydrologic input parameters for the geochemical model is summarised in Table 25. Climate data obtained from Alert, Nunavut, Canada was used to estimate the runoff from each facility. The catchment areas represent the full build-out of each facility with the exception of the pit for which the entire drainage area was considered. To be conservative, runoff was calculated assuming 100% of the snowmelt and rain water will contact the rock/DMS Rejects (i.e., runoff coefficient of 1). The calculations are based on the assumption that the runoff/seepage emanating from each facility will be highest during June and July (80 per cent over 60 days) and the remaining 20% of runoff/seepage will occur during the month of August (~30 days).

The minimum Eastern River flow rates observed during the baseline studies were used in combination with the calculated runoff/seepage to estimate the mixing ratios (e.g., contribution to the total load)

151 for the geochemical model. Minimum flows provided upper estimates of the percentage of flow to the Eastern River associated with each facility. The minimum early season daily flow within the Eastern River to date was measured on June 7, 2010 (25,234 m3/day) whereas the minimum late season daily flow was measured on August 11, 1994 (23,007 m3/day).

Table 26 contains the estimated water quality in the Citronen Fjord, at the head of the Eastern River, during operations and closure and compares this quality with that already existing within Citronen and Frederick E. Hyde Fjords and the Eastern River.

152

Table 25 Surface water hydrology input values.

Runoff Early Season Contribution to Catchment Area 80% Runoff Annual Coefficient Total Eastern River Total Flow Precipitation Runoff/ Facility (Alert, Canada) Season (June-July, (Footprint) (100%) Minimum 60 Days) %

m2 m m3 m3/day m3/day

Waste Rock 369840 0.15 1 56844 758 25234 3.00% Dump DMS Reject 334509 0.15 1 51414 686 25234 2.72% Dump Open Pit 493713 0.15 1 75884 1012 25234 4.01%

Table 26 Citronen Fjord background water quality compared to modelled water quality during operations and the final three years of operations/ closure. Water quality values for Eastern River, Frederick E Hyde Fjord and Greenland Water Quality Guidelines (BMP 2011) included as a comparison.

Frederick E. Hyde Units in µg/L Eastern River Citronen Fjord Fjord

COPEC Background BMP Guidelines Background Modelled Modelled Final BMP Guidelines Background concentration Freshwater concentration Operations 3 years Seawater concentration (2010) (2011) (2010) (13 years) operations/ (2011) (2010) Closure Zinc 0.6 – 3657 10 0 – 20.1 0.586 216 10 0.2 – 7.5

Lead 0.03 – 21.38 1 0.1 – 7.67 1.66 3.59 2 0.2 – 4.2

Cadmium 0.01 – 10.9 0.1 0.01 – 0.118 0.0022 0.179 0.2 0.03 – 0.07

Copper 0.1 – 2.9 2 0.4 – 6.68 0.191 0.546 2 0.4 – 2.1

Nickel 0.05 – 8.1 5 1.3 – 2.3 0.912 25.5 5 1 – 2.3

Highlighted = above guidelines values.

153

The screening of COPECs in the Citronen Fjord water during the final three years of operations and during closure indicated that the maximum estimated concentration of lead, zinc and nickel were above guideline levels. Nickel was also above naturally occurring background levels.

The screening of COPECs in Citronen Fjord sediment during operations indicated that no metal concentrations were above screening values. However, during the final three years of operations and closure arsenic and zinc are above the regulatory values. All other COPEC’s were below screening values during operations and closure (Table 27 and Table 28). Therefore, zinc and arsenic were the only COPEC’s evaluated in the next step.

Table 27 Comparison of maximum modeled Citronen Fjord sediment concentrations to marine sediment screening values during operations. Sediment Sediment Eliminated Concentration Screening Screening From Risk COPECs Value Value Assessment (mg/kg) (mg/kg) Source

Arsenic 7 41.6 a Retained Cadmium 2.41 4.2 a Yes Copper 1.28 108 a Yes Lead 5.9 112 a Yes Mercury NA NA NA Data gap Nickel NA 15.9 b Data gap Zinc 6 271 a Yes

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a = CCME, 2002; b= NOAA, 2008

To further assess the impacts of these metals in the water and sediment of Citronen Fjord, arsenic, lead, nickel and zinc were evaluated with respect to both direct toxicity and indirect toxicity (i.e. trophic transfer) in identified receptors for the site. Potential food web risk from arsenic and zinc was found for all upper trophic level aquatic organisms (i.e., harbor seal, herring gull, spotted sandpiper, and belted kingfisher).

154

Table 28 Comparison of maximum modelled Citronen Fjord sediment concentrations to marine sediment screening values during final three years and closure. Maximum Sediment Sediment Eliminated COPECs concentration Screening Value Screening Value From Risk mg/kg mg/kg Source Assessment Arsenic 270 41.6 a Retained Cadmium 0.3 4.2 a Yes Copper 2.4 108 a Yes Lead 12.5 112 a Yes Mercury NA NA NA Data gap Nickel NA 15.9 b Data gap Zinc 1090 271 a Retained

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a = CCME, 2002, b= NOAA, 2008

The geochemical testing studies indicate that the potential for acid rock drainage and metal leaching from waste is low and will lead to no or very limited contamination of the localised terrestrial ecosystem at the dump. The acid-based-accounting shows that waste rock samples with low total sulphur are likely to be classified as non-acid generating due to the presence of excess neutralisation potential in the form of calcite and/or dolomite.

Geochemical modelling indicates that concentrations of metals (with the exception of nickel) expected in Citronen Fjord surface water from the waste rock dumps are within the ranges of natural background levels of the Eastern River and Citronen Fjord. Toxicity testing results determined that these concentrations (including nickel) are not anticipated to present a risk to aquatic organisms. Modelled sediment concentration of arsenic and zinc is expected to be above guideline and background levels during whilst the open pit is operating and closure, which may pose a low food web risk to fish eating birds and marine mammals in the fjord. Again, toxicity testing results indicate these concentrations are unlikely to pose a risk to receptors.

Overall the risk of contamination of the environment from the waste rock dumps is believed to be low. However, given the risk of modelled elevated arsenic and zinc in sediment this risk must be upgraded to medium.

Management and mitigation measures are discussed in Section 7.6.4, and in more detail in appendix 6 – Environmental Management Plan. These measures include developing a waste rock management plan and blending waste rock to prevent ARD formation. Residual Risk rating is Medium.

155

7.6.2 Waste dump stability

The influence of water is the single most important factor in respect to slope stability, with two primary affects: an increase in the density of the material and an increase in pore water pressure. Pore water pressure can cause a decrease in effective stress within the slope and therefore a reduction of shear strength of the material. The natural angle of repose of waste rock “as dumped” is 37°. If material were left as dumped an increase in weight through moisture or crest loading could facilitate failure of the slope.

To ensure long term stability of the waste dumps they are designed, and upon course, pushed to a shallow batter angle of 20° with shallow dipping 5° berms located every 10m vertically. The resultant overall angle of the dump (uppermost crest to lowermost toe) compares more favourably than the natural angle of repose of waste rock, and hence inhibits the potential to generate a slumping mechanism by reducing the volume of “at risk” material.

The waste dump design facilitates suitable and rapid drainage of any surface water capture. The hard nature and grading (fine through to extremely coarse) of waste rock results in an interlocking matrix that is resilient to erosion and stable at the proposed batter angles.

The waste dumps will also have constructed toe drains to capture surface silt runoff from the slopes.

Management and mitigation measures are discussed in Section 7.6.4, and in more detail in appendix 6 – Environmental Management Plan. These measures include designing the waste rock dump to ensure rapid drainage of water, and construction of a diversion bund at toe of dump to divert water away from dump edge.

Residual Risk rating is Low.

7.6.3 Landform aesthetics

The process of open pit mining will remove a significant proportion of the outcrop at the Discovery Zone, leaving an open pit. The material removed from the ore body is either deposited in the waste rock dump or taken away for further processing. The Waste dump will be built to blend in with the contours of the existing landforms as far as practicable. The change in the visual amenity of the pit area and waste dumps will be permanent.

156

Changes to the topography due to mining will have an impact on the visual amenity of the area however the region is not inhabited by people. The significance of the permanent changes to the visual amenity of the area is therefore deemed low.

Management and mitigation measures are discussed in Section 7.6.4, and in more detail in appendix 6 – Environmental Management Plan. These measures include planning waste rock dump and DMS reject dump to blend as far as practicable with the surrounding landscape.

Residual Risk rating is Low.

7.6.4 Waste dump management and mitigation measures

• Model potential development of pit lake and monitor water quality. • Continue geochemical characterisation of pit wall run-off. • Develop a Waste Rock Management Plan • Contain most waste rock in mined out section • Construct diversion drains and bunds on the mountain (upper) side of the waste dump to prevent melting water from entering the dump • Blend waste rock to prevent ARD formation • Continue waste characterisation testing of waste throughout the project to ensure that pre- project testing results and assumptions are valid • Design Waste rock dump to ensure rapid drainage of water • Construct diversion bund at toe of dump to divert water away from dump edge • At closure, batter down outermost slopes from angle of repose to gentler slope of 20°, with berms every 10m vertical height. • Plan waste rock dump and DMS reject dump to blend as far as practicable possible with surrounding landscape

7.7 Tailings Storage Facility (TSF)

7.7.1 TSF containment

Leachates seeping from the TSF are a potential contaminant source of the nearby Eastern River, Citronen Fjord and terrestrial ecosystem.

The geochemical characterisation of tailings material showed they are likely to generate acid (Section 6.4.1). Acid-base accounting results reveal that all tailings humidity cells are producing neutralisation potential ratios (ANP/AGP) less than 1 indicating that they are potentially acid generating (Section 6.4.1.1, Table 13). The trace metal content of tailings samples suggest that elevated metal/metalloid 157

concentrations such as lead, zinc, cadmium and arsenic are likely should runoff occur from the pond. The geochemical testing studies showed that if leachate was to seep from the facility then acid rock drainage and metal leaching from tailings would occur and that this could lead to contamination of receiving water sources.

7.7.1.1 Ecotoxicological testing (tailings supernatant)

Ecotoxicological testing was conducted using tailings supernatant from recent locked cycle flotation testing of samples from Citronen Project. The locked cycle flotation testing used reagents similar to those expected to be used during the Project. The tailings supernatant was considered an acceptable analog for seepage and runoff during operations and closure. The concentrations of Constituents of Potential Ecological Concern (COPECs) and other regulated constituents in the bulk sample were generally elevated compared to the estimated concentrations for seepage/runoff from the waste rock dump during operations and closure (SLERA July 2012, Table 7-1). Concentrations of copper, nickel, lead, zinc and iron in the supernatant were elevated above the ecological screening values presented in the SLERA (Canadian Environmental Quality Guidelines 2002, EU Environmental Quality Standards 2008 and BMP Greenland Water Quality Guidelines 2011). The waste rock leachate concentrations included the “first flush” results from the longest running humidity cell tests (HC-1 and HC-2) which represented the highest constituent concentrations from either cell.

A preliminary 48-hour range finding test was conducted using the mysid shrimp, Americamysis bahia. The tailings supernatant was diluted using artificial seawater to a maximum concentration of 10% supernatant. The results from this test indicate that the LC50, the concentration that is lethal to 50% of the test organisms, was greater than 10% tailings supernatant (this was the highest tested concentration in this range finding test). Upon completion of the range finding test, two 96-hour tests were conducted using the mysid shrimp, Americamysis bahia, and the sheepshead minnow, Cyprinodon variegatus. The tailings supernatant was salinated to 30 ppt. The salinated sample was then used to construction a dilution series of 9 concentrations using artificial seawater as a dilute (100%, 50%, 25%, 12.5%, 6.25%, 3.125%, 1.56%, 0.78%, 0.39%, and a control, 0%). No significant mortality was observed in any test concentration including 100% tailings supernatant.

The results of these tests indicate that there is no toxicity associated with the tailings supernatant to either species because the calculated LC50 was greater than 100%. Therefore, the risks to lower trophic level aquatic communities (Tetra Tech April 2012) are not substantiated by the toxicity tests.

The potential for the tailings facility to increase the levels of metals in the aquatic or terrestrial environment to levels that could impact the upper trophic aquatic life of the Citronen Fjord area

158 including fish, birds and mammals or lower trophic level communities including benthic macro- invertebrates and aquatic communities are therefore not considered significant.

The TSF will be a lined facility and as such the TSF is not expected to release any seepage or leachates into the environment. A diversion drain will be constructed that will lead melting water from the mountain slope away from the TSF, further reducing the risk of excess water within the facility. Given the conservative design of the TSF to fully maintain all tailings and water of the facility, and the results of the toxicity tests, the potential for contamination of the water resources and soil from the tailings facility is considered low.

Management and mitigation measures are discussed in Section 7.7.7, and in more detail in appendix 6 – Environmental Management Plan. These measures include the fact that the TSF will be an enclosed, lined facility that results in no release of seepage into the environment.

Residual Risk Rating is Low.

7.7.2 TSF and flood events

The foundation of the TSF management system is to minimise the amount of water entering the facility. Surplus water in the facility reduces storage capacity and will increase the time for the tailings to freeze. Diversion drains (designed for 100 year frequency, 24 hour flood events) will prevent runoff water from entering the facility.

Water will however, enter the facility through tailings decant, rainfall and snowfall and this must be managed. Local water will be removed from the system (from decant and rainfall) via a portable pumping arrangement. Water will be returned to the plant for reuse. High rainfall events cannot be managed simply by pumping and further management must be implemented to ensure that a high rainfall event can be adequately managed to prevent contamination of the downstream environment.

During operations, the TSF will have capacity to completely contain runoff resulting from the 24-h 50% PMP (Probable Maximum Precipitation) event in addition to the normal operating pool volume. In addition a minimum 1m residual freeboard has also been included in the design. As the facility is filled with tailings, the storage capacity will be reassessed and an emergency spillway constructed to ensure a PMF event overflows the facility at a pre-designated point.

If the TSF overflows due to a PMP event excess water will overflow the facility, leave via the spillway and dissipate out to the environment eventually reaching Citronen Fjord. It is not anticipated that the water will contain a high volume of solids or a high concentration of contaminants partly due to

159 majority of tailings will be frozen and not available to enter the rainwater solution and partly due to the fact that such a high volume will dilute any contaminants prior to entering the environment. Contamination or death of aquatic organisms is also not likely to occur from an overflow event as ecotoxicity testing has illustrated that even at 100% supernatant concentration, no significant mortality was observed. During operations the decant will be regularly sampled, analysed and monitored for water balance, solid suspension and toxicity. At closure, the TSF will be covered with a one metre layer of benign waste material so water cannot mix with the tailings and will be sloped towards the north encouraging water off the facility. These measures will further reduce the chance of contaminated water entering the fjord.

Due to the number of controls and design of the facility the risk of contamination of the environment from an overflow of the TSF is considered to be Low.

Management and mitigation measures are discussed in Section 7.7.7, and in more detail in appendix 6 – Environmental Management Plan. These measures include construction of diversion drains and bunding to prevent melting ice from the mountain slopes from entering the TSF

Residual Risk Rating is Low.

7.7.3 TSF stability

The TSF was designed based on site specific criteria drawn from the following agency publications: • International Committee on Large Dams (ICOLD) - Various Bulletins; • Canadian Dam Association- Dam Safety Guidelines, January 1999; and • The Mining Association of Canada - A Guide to the Management of Tailings Facilities, September 1998.

Acceptable slope stability design criteria for earth and rock fill dams advocated by the International Committee on Large Dams (ICOLD) and the Canadian Mining Association were adopted for design of the Citronen Fjord tailings dam. These requirements are summarised in Table 29.

Table 29. Minimum Factors of Safety for Dam Stability Loading Condition Minimum Factor of Safety Slope

Steady state seepage with maximum storage pool 1.5 Downstream

Earthquake 1.1 Downstream

160

Prior to the feasibility design being undertaken, a site investigation was carried out during the 2010 field season at Citronen, during which holes were drilled in the presence of a qualified geotechnical engineer. Undisturbed samples were obtained and kept frozen prior to geotechnical testing at a laboratory in Denmark, thus enabling the calculation of bearing capacities and such like to facilitate use in the design. Tests were undertaken to the appropriate standards, as was the calculation of the parameters for use in the design.

Selection of the tailings embankment type considers earthquake resistance, relative cost, environmental performance, ease of closure, ease of geomembrane-lining, and the ability to construct the embankment during the allotted construction season. Based upon the data available regarding available construction materials at the site, a conventional earth and rockfill dam with a geomembrane lined upstream slope was chosen. The dam will be constructed in stages with locally available materials placed and compacted in lifts. In general, the tailings dam will include fine grained lower permeability materials placed in the upstream portion of the dam and coarse high strength rock materials in the downstream portion of the dam. Intermediate filter materials will be required to transition between the fine and coarse grained materials. The fine grained material at the upstream face of the embankment will provide a suitable surface for the geomembrane. Further information on the construction of the facility is in Section 6.4.3.1.

Stability assessments were undertaken for the TSF based on the following criteria summarised below:

• Total tailings over the life of the Project is 9.0 Mt with tailings produced at 240t/day; • Tailings storage requirement for first year is 1,580,557 m3 and 371,000 m3 capacity required for years 2 through 8; • Tailings solids specific gravity = 3.6, tailings slurry consists of 58% solids by weight; • Maximum Design Earthquake (MDE) = Maximum Credible Earthquake (MCE); • Use pseudo-static methods of analysis; • Peak Ground Acceleration (PGA) factored by 50% for pseudo-static analysis; • Assume tailings fully liquefy under earthquake conditions; • Diversions designed for 100-year, 24-hour storm event; • The exterior face of the dam will be maintained in a drained condition, which will preclude the formation of ice in the pore space of the rock fill. As such, any ice will not present in sufficient quantities to form ice jacking, which could slowly loosen the dam and move material downhill; • During operations, the impoundment will completely contain runoff resulting from the 24h 50% PMP event in addition to the normal operating pool volume as determined from the impoundment water balance while maintaining 1m (minimum) of residual freeboard between the dam crest and the maximum water level; and

161

• Emergency spillway designed to pass the 24-hour PMP event while maintaining 1m (minimum) of residual freeboard between the dam crest and the maximum water level.

The tailings dam is designed to withstand ground motions associated with the maximum credible earthquake (MCE) without release of the tailings or supernatant. Based on the seismic evaluation provided by Voss, Poulsen, Simonsen, and Gregersen (2007), the corresponding peak bedrock acceleration at the impoundment is estimated to be 0.061g.

Further site investigation drilling and geophysics will be undertaken prior to final engineering design of the structures ahead of construction. This will enable further refinement of the design and specification for the construction and closure of the TSF to ensure that fit for purpose structures are designed and built.

Given the described engineering criteria and specifications, there is a low probability that wall failure will occur.

Management and mitigation measures are discussed in Section 7.7.7, and in more detail in appendix 6 – Environmental Management Plan. These measures include maintaining an emergency spillway, construction of diversion drain to minimise inflow from the surrounds.

Residual Risk Rating is Low.

7.7.4 TSF dust

See Section 7.10 - Dust.

7.7.5 TSF - fauna

The presence of the TSF could potentially attract either mammals or birds to the facility searching for a water source. This could result in mammals being caught in the slurried tailings unable to get out. Birds may also be affected by drinking the decanted water from the tailings which contains elevated metals and chemicals from processing.

It is not anticipated that many mammals would access the TSF due to the absence of food available on the facility and the chemistry of the water. It is also considered unlikely that an animal would become stuck in the slurry as it will be frozen for the majority of the year and reasonably hard even in the summer months. This impact has therefore been deemed as low.

162

Birds in the Project area will be able to source water from a variety of resources in the summer, hence it is unlikely to be a preferential supply. In the winter the water will be frozen and there will be no birds as they migrate south during the coldest and darkest months. Therefore this impact has also been deemed as low.

To determine if tailings supernatant would be toxic to marine fauna in the unlikely event that seepage entered the fjord an ecotoxicological testing program has been implemented (Tetra Tech April 2012)). No significant mortality was observed among the tested mysid shrimps and fish in any test concentrations including 100% tailings supernatant. This impact has therefore been deemed as low.

Management and mitigation measures are discussed in Section 7.7.7, and in more detail in appendix 6 – Environmental Management Plan. These measures include monitoring the facilities use by fauna.

Residual Risk Rating is Low.

7.7.6 TSF aesthetics

The construction of the tailings storage facility will require some major re-profiling of the area. However, in a landscape with almost no vegetation such as the Project area the facility will to a large extent blend into the surrounding landscape and the overall significance of the permanent changes to the topography at the tailings pond is therefore considered low.

Management and mitigation measures are discussed in Section 7.7.7, and in more detail in appendix 6 – Environmental Management Plan. These measures include designing the tailings dam to blend as far as possible with the surrounding landscape.

Residual Risk Rating is Low.

7.7.7 TSF and rainfall changes – Cumulative Effects

The tailings dam has been designed to current international standards. Climate change has not been specifically considered however the overall rainfall and its effect on the dam has been considered. Sufficient storage capacity will be maintained in the impoundment such that a minimum of 1m of residual freeboard will be maintained above the maximum water surface elevation attained during the Probable Maximum Flood (PMF). The PMF is the largest flood that could conceivably occur at a particular location, usually estimated from probable maximum precipitation, and where applicable snow melt, coupled with worst flood producing catchment conditions.

163

Water management for the TSF will be monitored daily throughout the life of the mine. The design and capability will be reviewed annually. Should changes be required due to any changes in rainfall then this will be picked up during these audits and the appropriate adjustments made. It is not anticipated that any change in rainfall, potentially from climate change (during the short duration of 14 years of mine operations) would result in an increase greater than that estimated for the PMF or 100 year, 24 hour storm event.

On closure, the overall design philosophy is to reduce the amount of water that can enter the TSF, by physically covering the dam and also designing a surface water management system to shed water from the dam. The cover system will be designed to limit water infiltration into the facility. The surface water management system after closure will direct water across the surface of the reclaimed tailings facility so as to further reduce water infiltration.

164

7.7.8 TSF management and mitigation measures

• The TSF will be an enclosed, lined facility that results in no release of seepage to the environment • Construct diversion drain and bunding to prevent melting water from the mountain slope behind the tailings facility from entering the facility • The water level in the facility will be monitored and engineered to prevent any overflow. Cut off valves and alarms will be installed. Excess water will be pumped from facility if required. • Deposition method will promote permafrost to minimise potential for ARD formation in long term • Cap with benign waste rock layer on closure • Develop a Tailings Storage Facility Management Plan • Construct TSF as per design for safe and stable facility • Maintain adequate freeboard in facility • Maintain emergency spillway for 1:100 rain events • Construct diversion drain and bunding to prevent melting water from the mountain slope behind the tailings facility from entering the facility • Plan tailings facility to blend as far as practicable possible with surrounding landscape • Monitor facility use by fauna

7.8 Shipping assessment - routine events

The production rate at Citronen will correspond to the requirement for three return trips per year from Citronen Fjord to the designated marshalling port using ice-class bulk carriers. Shipping studies indicate that the shipping “window” is generally open July through to September (subject to prevailing conditions), however the average shipping dates with regard to the vessel ice class (PC 4-5) are from the 1st August to the 28th of August. The shipping route will be dictated by the location of the open water lead that develops along the eastern coast of Greenland.

The ice-class bulk carriers will be managed in a way that minimises the use of resources and emissions. Therefore the route from Citronen Fjord to the marshalling port will be chosen based on finding the most open waters and avoid breaking the ice if not necessary, i.e. the ship would rather take a longer route than increasing the use of fuel when breaking ice. The maximum cruising speed in brash ice conditions would be five knots, with the trip from Citronen Fjord to open waters and back estimated to be approximately seven to eight days.

165

7.8.1 Sound and noise

Ships generate noise by propeller cavitation, the engine, water flow over the hull and flexing of the hull. Noise from ships is mostly low frequency, between 5-100Hz but in some instances can be higher. Ship transport (incl. ice-breaking) has the potential to displace marine mammals, particularly if the mammals associate negative events with the noise, which is the case in the southern part of eastern Greenland assessed by Boertmann et al. (2009), where narwhals and walruses are hunted from motor boats. The loudest noise levels from shipping activity result from icebreakers, particularly when they operate in ramming mode. Peak noise levels may then exceed the ambient noise level up to 300km from the sailing route (Davis et al., 1990).

Masking of underwater sound of marine mammals is likely to occur from the continuous noise from ship propellers and this has been demonstrated for white whales and killer whales in Canada (Foote et al., 2004 and Scheifele et al., 2005). Sperm whales showed diminished foraging effort during air gun emissions, but it is not clear if this was due to masking of echolocation sounds or to behavioural responses of the whales or the prey (Miller et al., 2005 in Jochens 2008). The most noise-vulnerable whale species along the shipping route will be narwhal and bowhead whale, and there will be a risk of temporary displacement from critical habitats. Other whales occur in summer and will also be vulnerable, but their occurrence is less regular and no concentrations areas are known along the shipping route (Boertmann et al., 2009).

In general, seals display considerable tolerance to underwater noise (Richardson et al., 1995), confirmed by a study in Arctic Canada in which ringed seals showed only limited avoidance to seismic operations (Lee et al., 2005). In another study, ringed seals had habituated to industrial noise (Blackwell et al., 2004). However ‘hauled-out’ walruses and whelping hooded and harp seals on the drift ice have the potential to be disturbed and displaced by activities such as drilling (not by the seismic noise itself), although the whelping period is early in the spring, prior to shipping.

Helicopters produce a strong noise which can scare marine mammals as well as birds. Particularly walruses hauled out on land or ice will be sensitive to this activity, and helicopter noise poses a risk of displacement of the walruses from important feeding grounds. Denning polar bears are apparently relatively tolerant to noisy activities as their snow dens provide acoustic insulation (Linell et al., 2000).

Concerns regarding acoustic impacts associated with noise from large vessels such as the Citronen ice-breaker tug have focused mainly on animals that predominately use low frequencies to hear and to communicate (Figure 43). However, in addition to their predominant low-frequency radiated noise, modern cargo ships can radiate high frequency noise. Noise in these frequency bands has the potential to interfere (over relatively short ranges) with the communication signals of many marine

166

mammals, including toothed whale species, not typically thought of in terms of masking from shipping noise.

Figure 43. Typical frequency bands of sounds produced by marine mammals and fish compared with nominal low-frequency sounds associated with commercial shipping (source: OSPAR, 2009).

7.8.2 Regular discharges

Ships produce a range of materials from normal operations that must be removed from the ship. This can be done either by release to the ocean, incineration on board or disposed on land at port-based facilities. These regular discharges include waste oil, ballast water, bilge water, oily water and sludge, sewage, garbage and grey water. These discharges are primarily regulated through the IMO’s International Convention for the Prevention of Pollution from Ships, 1973. Where possible, these discharges will be disposed of at available port based facilities or into the ocean within allowable limits as directed by these regulations. Due to the small number of trips expected by the ship for the Project it is anticipated any impact from these regular discharges will be negligible.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

7.8.2.1 Ballast water

The environmental impact of concern from ballast water is the introduction of invasive non-indigenous species. When introduced in new areas, these species could thrive and become a threat to other indigenous species and the ecosystem.

167

There are several international examples of species that have caused severe damage to the marine ecosystem after being introduced into new areas. One example is the comb jellyfish (Mnemiopsis leidyi) that demonstrates the enormous impact that a small, apparently innocuous species can have in a new habitat. When the comb jellyfish spread, the entire pelagic ecosystem was profoundly modified, and the catch of pelagic fish was severely decreased.

At a conference in 2004, the International Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM Convention) was adopted, a new international convention to prevent the potentially devastating effects of the spread of harmful aquatic organisms carried by ship ballast water. The Convention will require all ships to implement a Ballast Water and Sediments Management Plan. All ships are required to carry a Ballast Water Record Book and to carry out ballast water management procedures to a given standard. Existing ships will be required to do the same, but after a phase-in period (IMO, 2010).

The IMO Marine Environment Protection Committee (MEPC) adopted the following guidelines in 2006, which are part of a series developed to assist in the implementation of the BWM Convention, adopted in February 2004 (IMO, 2004; 2010):

• ballast water exchange design and control standards (G11); • design and construction to facilitate sediment control on ships (G12); • designation of areas for ballast water exchange (G14); • sediment reception facilities (G1); and • ballast water reception facilities (G5).

The ballast water on the bulk carriers will always be exchanged mid-ocean on the Citronen – marshalling port shipping route in order to minimise the risk of introducing new species in ports of origin or destination. This is according to the recommendations by IMO on ballast water handling (IMO, 2004). The risk of spreading non-native species is considered to be low.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

7.8.3 Shipping and Hydrocarbon Licence Areas – Cumulative Impacts

Shipping to and from Citronen Fjord will pass through hydrocarbon licence areas off northeast Greenland. The presence of two activities in the one area has the potential to impact the environment and cumulative impacts have been considered in this assessment. There is the potential for a collision between vessels which may result in unplanned releases of hazardous materials as described and assessed in Section 7.9 below. Overall any cumulative impacts are expected to be insignificant

168

primarily because of the very small number of round trips that will occur (3 per year) and their intermittent nature.

7.8.4 Marine fauna

Marine mammals, particularly large whales, are vulnerable to collisions with ships. These collisions can result in minor injuries to death. In the Arctic, few incidents have been recorded regarding collisions between ships and marine mammals (Arctic Council 2009). However this is likely to be due to the relatively small amount of sea traffic that occurs in this region. Of particular concern for this Project is the bowhead whale which is a larger whale and has less maneuverability than smaller whales.

The speed at which ships are travelling has been highlighted as a key factor in the number of collisions with marine mammals. Vessel speeds between 10 – 14 knots result in a 50% or greater increase in probability that an animal will survive a collision with a ship (Arctic Council 2009).

The anticipated speed of the icebreaker tug is between four knots in icy conditions to 11 knots in open waters. Ship personnel will be monitoring water conditions at all times (from on board the ship and also during helicopter reconnaissance) including watching for the presence of any marine mammals.

The risk ranking has been classified Low due to the low probability of a collision with fauna. This has been based on the low frequency of trips expected and low speed of the vessel.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

7.8.4.1 Seabirds

The occurrence of seabirds is governed by the presence of ice, which is why they are scarce in large regions in summer and almost absent in winter but, on the other hand, very numerous in areas with predictable open waters in spring and summer and along the coastal areas near polynyas.

Since bird-cliffs are steep, inaccessible areas, they are normally protected from disturbance from natural predators. Therefore the birds are especially sensitive to disturbance from human activities in the areas around bird cliffs. Their defence strategy is to escape from the threat and they may react

169

strongly, even if only slightly agitated (Greenland Institute of Natural Resources, 2003). Disturbances during breeding periods can result in parental desertion of eggs and young.

Table 30 provides an overview of birds that have been recorded in an assessment area on the Eastern coast of Greenland (Figure 44) (Boertmann et al., 2009), and may be encountered during shipping to and from Citronen Fjord.

Table 30: Overview of most important species of birds from Boertmann et al. (2009)’s assessment area.

Species Occurrence Main Greenland Red List Importance of Risk to Habitat status assessment population area to from population shipping

Ivory gull b/s/w; year round c & o Vulnerable (VU) high medium

Thick-billed murre b/s/mi; summer c & o Vulnerable (VU) high medium

Little auk b/mi; summer c & o Least Concern (LC) high low

Common eider b/m; summer c Least Concern (LC) high low

King eider b/m; summer c (spring) Least Concern (LC) medium low

Long-tailed duck b/m; summer c (spring) Least Concern (LC) medium low

Fulmar b/s/w; year-round c & o Least Concern (LC) low medium

Grey phalarope b/mi; summer c (spring) Least Concern (LC) low low

Arctic skua b; summer c Least Concern (LC) low low

Black-legged kittiwake b/s/mi; summer c & o Vulnerable (VU) low low

Glaucous gull b/s/mi; summer c Least Concern (LC) low low

Sabine’s gull B; summer c Near Threatened (NT) low low

Ross’s gull b/s; summer c & o Vulnerable (VU) low low

Arctic tern B; summer c Near Threatened (NT) low low

Black guillemot b/s/w; year round c & o Least Concern (LC) low low

Atlantic puffin B; summer c & o Near Threatened (NT) low low

B = breeding, s = summering, w = wintering, m = moulting, mi = migrant visitor, c = coastal, o = offshore.

170

Citronen Project

Figure 44. The Kanumas and assessment area on the eastern side of Greenland (Boertmann et al., 2009).

171

The International Union for Conservation of Nature (IUCN) Red List of Threatened Species lists all the birds outlined in Table 30 as Least Concern, with the exception of the ivory gull, which is listed as Near Threatened. Greenland’s Red List of Threatened Species (Boertmann, 2007) lists the common eider, thick-billed murre, black-legged kittiwake and ivory gull as Vulnerable; the arctic tern, Atlantic puffin and sabine’s gull as Near Threatened; with the other species as Least Concern.

Seabirds are locally abundant in coastal areas and in ice-free areas in Northeast Greenland in spring and summer, and many species breed in colonies close to polynyas (i.e. the NEW polynya) (Figure 45), where populations may be found as early as May.

NEW Polynya

Citronen Fjord

Figure 45. Polynyas occurring on the eastern side of Greenland (Boertmann et al., 2009).

The project intends to conduct the activities in accordance with the Greenland Government Act Order No. 8 of 2 March 2009 on the protection and hunting of birds, during the period 15 April – 15 September it is illegal to shoot or generate avoidable disturbance including boating and shipping within 1000m of a seabird colony (defined as site with at least 10 breeding pairs of seabirds) occupied by Thick-billed murres (Uria lomvia), Murre (Uria aalge), Razorbill (Alca torda), Little auks (Alle alle), Kittiwakes (Rissa tridactyla), Northern fulmar (Fulmarus glacialis) or Great comorant (Phalacrocorax carbo). It is furthermore illegal to fly within 3000m of a colony occupied by the same species of sea birds (vertically or horizontally) in a helicopter or fixed winged airplane. For sea bird colonies situated on an island or peninsula and occupied by common eider (Sometaria mollissima), black guillemot (Cepphus grylle), puffin (Fratercula arctica), Arctic tern (Sterna paradisaea), or other species of gulls

172 other than kittawakes the distance is 200m. Shipping in marked routes is exempted from the rules mentioned above.

The following evaluation provides a risk assessment of the potential impacts of shipping to and from Citronen Fjord on the bird species considered to be most significant (common eider, ivory gull, ross’s gull, thick billed murre, little auk and fulmar) in relation to the shipping route and NEW polynya. (Risks to seabirds from potential oil spills has been addressed in Section 7.9 Shipping Impacts – Accidental Discharge).

Common eider (Somateria mollissima) This sea duck arrives to the NEW in late April-early May. In June the ducks disperse and start breeding scattered along the coast (Figure 46). In 2008 about 4,600 eiders were observed along the coast in May-June (Boertmann et al. 2009). Between July and August 2009, 1384 birds were observed here (Boertmann & Nielsen 2010) (Figure 47).

Citronen Fjord

Figure 46. The hatched area marks the important spring staging areas for common eider in the NEW. The blue spots show important breeding areas (Aastrup & Boertmann 2009).

In July flocks of up to 100 males have been recorded off the coast (Falk et al. 1997). During July and August most eiders observed in connection with aerial counts in 2008 and 2009 were mainly females with young, non- or failed breeders and males (Boertmann et al. 2009, Boertmann & Nielsen 2010). Later in August-September the common eiders leave the NEW and migrate south. The common eiders are almost exclusively observed close to the coast.

173

Figure 47. Distribution and size of breeding colonies of common eider on the Eastern coast of Greenland during surveys in July and August 2009. (Boertmann and Nielsen 2010).

The common eider population is categorised at Least Concern on the IUCN and Greenland Red Lists. The most important breeding colony is found at the military outpost Daneborg however females with pulli were observed on the coast of the NEW (Boertmann & Nielsen 2010). As per the Greenland Government Act described above, shipping within 200m of a coastal area occupied by common eiders will be avoided.

Given that common eiders are relatively abundant on the coast of the NEW, have a favourable conservation status and the coastal zone (and breeding population) will be avoided within 200m the potential risk of shipping to this species has been considered Low.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

174

Ivory gull (Pagophila eburnean) The most important area for ivory gull is the NEW polynya and the lead system along the coast northwest of the NEW. Breeding colonies are placed on either steep cliffs, often on remote nunataks, on low gravel islands, beaches or even moraine covered ice floes (Boertmann et al., 2009). Greenland’s largest colony of this high arctic gull is located on Henrik Krøyer Holme (Boertmann & Nielsen 2010) (Figure 48), where 100-300 pairs breed (Aastrup & Boertmann 2009).

Greenland Government Act Exectutive Order No1, January 2,1 2004, on the protection and hunting of birds, during the period 15 April – 15 September it is illegal to shoot or generate avoidable disturbance including boating and shipping within 1000m of a seabird colony (defined as site with at least ten breeding pairs of seabirds) occupied by thick-billed murres (Uria lomvia), Murre (Uria aalge), razorbill (Alca torda), little auks (Alle alle), kittiwakes (Rissa tridactyla), northern fulmar (Fulmarus glacialis) or great cormorant (Phalacrocorax carbo). It is furthermore illegal to fly within 3000m of a colony occupied by the same species of sea birds (vertically or horizontally) in a helicopter or fixed winged airplane. For sea bird colonies situated on an island or peninsula and occupied by common eider (Sometaria mollissima), black guillemot (Cepphus grylle), puffin (Fratercula arctica), Arctic tern (Sterna paradisaea), or other species of gulls than kittawake the distance is 200m. Shipping in marked routes is exempted from the rules mentioned above

Figure 48. Distribution and size of observations including breeding colonies of ivory gull during surveys in July and August 2009 (Boertmann and Nielsen 2010).

175

The breeding period appears to be spread out from mid-June to early August (Falk et al. 1997). Preliminary results from satellite tracking of breeding ivory gulls suggest that while breeding, the adults regularly leave the nest for a few days and fly as far as 400km from the colonies to forage. In August, some of the gulls start to disperse away from Greenland towards the north of Svalbard. Breeding colonies may be sensitive to disturbance, particularly low level helicopter flights, but on the other hand under certain circumstances ivory gulls are able to habituate to disturbance (e.g. the colony at Station Nord is very close to the airstrip situated there) (Boertmann et al., 2009). Ivory gull is listed as Vulnerable on the Greenland Red List of Threatened Species, mainly because of the expected reductions in its primary habitat, sea ice.

There is a potential risk that shipping may impact the Ivory Gull however to what extent is difficult to quantify. Shipping will be occurring within the NEW which, as mentioned is an important area for this bird. However, to reduce this risk shipping will only occur outside the 200m exclusion area of the coast and relatively few trips will be made during the summer months (approximately 2-3 return trips per month). Additionally, noise from the ship will be limited to engine noise only given that no ice is anticipated to be present within the NEW (the ships preferential path will follow open leads of water). The potential risk has therefore been considered as Medium. Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Medium.

Thick-billed murre (Uria lomvia)

Thick-billed murres occur both in coastal and offshore areas. There are only two or three breeding colonies within Boertmann et al. (2009)‘s assessment area, all of which are situated at the Scoresby Sund polynya, a large distance from the Citronen shipping route.

Recent studies suggest that adult and young thick-billed murres from colonies in Svalbard migrate through the waters off east Greenland in autumn. When the chicks are two-three weeks old (and still unable to fly) they leave the colony in company with the male bird. Once in the water the chick starts a swimming migration accompanied by the male bird. The male then sheds all flight feathers and becomes flightless for several weeks. It is likely that a considerable part of the chicks and moulting adult murres from the Svalbard population swim/drift to the sea off Greenland’s east coast although definite data are limited. The murres subsequently spend part of the autumn in east Greenland waters before flying off to wintering areas further south. During the swimming migration the murres would be very vulnerable to oil pollution. Thick-billed murre concentrations are also sensitive to helicopter flyover.

176

The thick-billed murre population is listed as Vulnerable on the Greenland Red List, due to decline, and as Least Concern on the IUCN Red List.

The southern part of the proposed shipping route is likely to pass through an area where murres from the Svalbard population occur in autumn. The limited data available suggest that most murres are further off shore than the proposed shipping line. Due to the likely route of the ship crossing the swimming migration zone of the thick-billed murre as they travel between Svalbard and the Greenland Sea it is therefore assessed to have a medium risk classification.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Medium.

Little auk (Alle alle) The little auk is listed as Least Concern on the Greenland and IUCN Red Lists. This species is the most numerous breeding seabird on the eastern coast of Greenland, however the breeding distribution is limited to the coasts near the Scoresby Sund polynya (Figure 49). The species nests in large colonies on scree or talus rocks below steep cliffs, and little auk can forage at high densities up to approximately 100km from colonies, feeding largely on pelagic crustaceans. Breeding adults arrive at breeding colonies in June and fledged young and adults leave the colonies in August-September. In autumn they migrate through Baffin Bay and the northern Davis Strait to winter in the Davis Strait or further south. Adults moult their flight feathers after breeding, becoming flightless and forming large rafts in coastal areas.

As the most sensitive occurrences of little auk are the breeding colonies in Scoresby Land (away from the shipping route), and the species has a favourable conservation status, the risk to this species is low.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

177

Citronen Fjord

Scoresby Sund

Figure 49. Distribution and numbers of little auk observed during the NERI 2008 aerial survey in May and June. N = the total number of individuals counted during the surveys (from Boertmann et al., 2009).

Ross’s gull (Rhodosthetia rosea) Ross’s gull is a rare species, known to breed regularly in Greenland at only two sites; Henrik Krøyer Holme in the NEW polynya is one of these sites (Egevang and Boertmann, 2008). At Henrik Krøyer Holme a few pairs have been recorded among the ivory gulls and arctic terns (Figure 50).

Whilst little is known about the phenology and biology of the Greenlandic populations, breeding birds are probably confined to the coastal environment, while non-breeders and migrating birds occur in marginal ice zones of polynyas and in the drift ice (Boertmann et al., 2009). The breeding site on Henrik Krøyer Holme is sensitive to disturbance. Non-breeders occur in relatively high numbers in the NEW during summer (Falk et al., 1997 and Meltofte et al., 1981). The species is able to nest sporadically in space and time when they encounter a favourable site.

Ross’s gull is considered as threatened in Greenland and categorised as Vulnerable on the Greenland Red List, and as Least Concern on the IUCN Red List. As breeding birds are confined to the coastal environment, and shipping to and from Citronen Fjord will not generate noise within three kilometers of the cliffs with breeding birds, the risk to this species is considered low.

178

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

Citronen Fjord

Henrik Krøyer Holme

Figure 50. Distribution and size of breeding colony on ross’s gull on the eastern coast of Greenland (Boertmann et al., 2009). Fulmar (Fulmarus glacialis) The fulmar breeds in six colonies on cliffs along the edge of the NEW (Falk et al. 1997) (Figure 51). In the early 1990s the breeding population was estimated to about 1,500 pairs (Falk & Møller 1995). In addition to the breeding population a number of non-breeding fulmars were also associated with the colonies. The total number of fulmars in the NEW during summer was therefore estimated to 5,100 birds (Falk et al. 1997). Fulmars arrive to the colonies in April-May and leave the NEW shortly before it freezes over again in September (Falk et al. 1997).

During the breeding period fulmars were recorded in low densities all over the polynya (Falk et al. 1997). Aerial surveys for birds and mammals in 2008 and 2009 also recorded low densities of fulmars in the NEW (Boertmann et al. 2009 and Boertmann & Nielsen 2010).

The fulmar population is not considered threatened on the either the IUCN or Greenland Red List of Threatened Species and has been categorised as Least Concern on both lists. The breeding colonies are sensitive because many fulmars often rest on the water surface below the breeding cliffs (Boertmann et al., 2009) which makes them vulnerable to oil spills. Also, overflying helicopters pose a

179

risk to the breeding fulmars. According to Greenland Government it is presently illegal to shoot or generate noise within 3000m of a bird cliff if it is occupied by fulmar (Fulmarus glacialis).

As the fulmar is categorised at Least Concern on the IUCN and Greenland Red List of Threatened Species and shipping to and from Citronen Fjord will not generate noise within three kilometres of a bird cliff occupied by fulmar and when helicopters are operated specific flight altitudes and routes will be applied the risk to this species has been considered medium.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Medium.

Citronen Fjord

NEW polynya

Figure 51. Distribution and size of breeding colonies of fulmar on the eastern coast of Greenland (Boertmann et al., 2009).

7.8.4.2 Fish

Bony fish (teleosts) have inner ears which can detect particle displacement created by sound vibrations in the water when the source of the sound is close. Cartilaginous fish (elasmobranchs including sharks and rays) are able to detect these near-source vibrations through their lateral line. Some species of fish are also able to hear sound sources that are much further away. These species often have swim bladders in close association with the inner ear. The gas bubble within the swim bladder is more compressible than water and pulsates when exposed to sound thereby creating 180 particle movement that stimulates the auditory nerves and otoliths of the inner ear. For example, Atlantic cod have extensions of the swim bladder which allows them to discriminate between high and low repetition rates of ultrasonic pulses (Greenland Institute of Natural Resources, 2003). Cod are also able to distinguish between sounds that are separated by space or distance. Their most sensitive hearing is at 75 dB re 1 μPa at 160 Hz. Evidence suggests that herring can hear sounds in the range of 30 Hz to 4 kHz (Thomsen, 2006) with a hearing threshold of 75 dB re 1 μPa at 100 Hz (Greenland Institute of Natural Resources, 2003).

There has been only limited research conducted on hearing in fish and only a few species have been extensively studied. Fish that are likely to be sensitive to noise are often described as hearing specialists and can hear a wide frequency range such as cod. Hearing generalists such as salmon are thought to be able to hear only a narrow frequency range and are not expected to be sensitive to most noise sources. The distinction between hearing generalists and specialists is the specialist’s ability to detect the pressure part of a sound field, in addition to the particle motion field, which all fish can detect. The sensitivity to pressure is most often attained through swim bladders or other air-filled structures and effectively increases the active hearing range of fish up into higher frequencies.

Most fish off the coast of eastern Greenland spawn in winter, outside of the proposed shipping period. Both spawning and non-spawning arctic char migrate back to their natal rivers and lakes in June- September to winter in freshwater after having spent two to four months at sea; the most sensitive habitats are therefore the river mouths and their adjacent coastal areas. Whilst anadromous Arctic char have been caught in Citronen Fjord, the natal river of this population is unknown. The Esrum and/or Eastern Rivers are unlikely candidates due to the very high suspended solids and metal concentrations, as well as the Eastern River running dry. No Arctic char have been recorded from rivers in the Citronen Fjord area.

The presence of the bulk carriers will not result in noise impacts that would cause physical damage to fish or significantly interfere with spawning behaviour of Arctic char. It is anticipated that the majority of fish will swim away to avoid approaching the sound source from the vessel. Whilst hearing specialist fish such as herring and Atlantic cod may be able to detect noise from the shipping, the noise will be short-lived and infrequent and the most significant potential impacts are likely to be short-term behavioural changes. The risk of this impact has therefore been classified as Low.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

181

7.8.4.3 Marine mammals

The marine mammals that may be encountered during shipping to and from the Project corresponds with those found in the assessment area as described in Boertmann et al. (2009) (Figure 44) and are listed in Table 31.

The following evaluation provides a risk assessment of the potential impacts of shipping to and from Citronen Fjord on the most significant marine mammal species (polar bear, walrus, seals, bowhead whale and narwhal) in relation to the shipping route.

Polar bear (Ursus maritimus) The NEW polynya is an important feeding and breeding area for polar bears (Aastrup & Boertmann 2009). Many breeding dens are found along the coast and the bears feed on seals on the sea ice, mainly close to the shore (Figure 52). When the NEW opens the bears are found along the edges, however in July-August few seem associated with the NEW (Boertmann et al. 2009 and Boertmann & Nielsen 2010).

Figure 52. Core area for polar bear near the NEW. The area indicates where female bears with small pups have often been recorded (Aastrup & Boertmann 2009).

182

Table 31. Overview of marine mammals occurring in the assessment area (from Boertmann et al., 2009).

Species Period of Main Habitat Distribution Greenland Red List Importance of Occurrence and occurrence status assessment in assessment area to area population Polar bear Whole year Mainly ice-covered Widespread Vulnerable High waters

Walrus Whole year Coastal waters Low numbers, Near Threatened High very localised

Hooded seal March-October Whelp on drift ice Numerous Least Concern High

Harp seal March-October Whelp on drift ice Numerous Least Concern High

Bearded seal Whole year Coastal and offshore Widespread in Data Deficient High waters low numbers

Ringed seal Whole year Whole area, usually Common and Least Concern High in ice widespread

Bowhead Whole year Marginal ice zone Widespread, very Critically Endangered High whale few

Narwhal Whole year Fjords, ice edges Common Data Deficient High

Minke whale June-October Ice-free waters Unknown Least Concern Pot. medium

Sei whale June-October Ice-free waters Unknown Data Deficient Pot. medium

Blue whale June-October Ice-free waters Unknown Data Deficient Pot. medium

Fin whale June-October Ice-free waters Unknown Least Concern Pot. medium

Humpback June-October Ice-free waters Unknown Least Concern Pot. medium whale

Pilot whale June-October Outside ice-covered Unknown Least Concern Likely low areas

White June-October Outside ice-covered Unknown Not Applicable Likely low beaked areas dolphin Killer whale June-August Mainly ice-free Unknown Not Applicable Unknown waters, whole area

White whale Summer Fjords and shallow Very rare Critically Endangered Low waters Sperm whale May-November Deep waters, Unknown Not Applicable Likely low southern part Northern May-November Deep waters only, Likely rare Not Applicable Likely low bottlenose mainly southern part whale

183

Occasional encounters with individual polar bears on the ice may be possible from July to September, however little is known about the effect of noise and icebreakers on polar bears. Four Polar bears monitored at Svalbard spent a maximum of 14% of their time in the water (Boertmann et al, 2009). The transmission of noise through the air is far less efficient than through water and impacts to species from airborne noise that may be encountered on ice within the shipping route are not considered significant. Denning polar bears have been shown to be relatively tolerant to noisy activities as their snow dens provide acoustic insulation (Linell et al, 2000).

Even though the shipping route is an important area to polar bears it is not considered that infrequent passing from ships would have a large impact on the population. Denning locations are closer to the coast and are unlikely to be disturbed by ships in the open water.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

Walruses (Odobenus rosmarus) The walrus population on the eastern coast of Greenland is probably more or less isolated. The walrus is classified as Near Threatened on the Greenland Red List. It is moreover a resource for the people living in the town of Ittoqqortoormiit. The conservation status of the population is favourable as it shows signs of improvement, and the hunt takes only males at the margin of the range.

The most important walrus areas in the assessment area are the uglits (haul-out spots), (Sandøen and Lille Snenæs) their surrounding waters, the summer concentration areas (coasts of Hovgaard Ø, Amdrup Land and Kilen) and winter concentration areas (shallow parts of the Northeast Water and the Wollaston Forland polynya) (Figure 53). The Northeast Water is also habitat for walrus with young all year round (Born et al. 2009).

It is well known that walruses, particularly when hauled out on land, are sensitive to disturbance, including sailing, traffic on land, and flying (Born et al. 1995). This was for example documented by Born & Knutsen (1997) who, based on fieldwork in Boertmann et al. (2009)’s assessment area, concluded that air traffic should not go closer than 5km to walrus uglits in order to minimise disturbance.

The potential risk to walrus from shipping has been assessed as low. This is primarily due to the infrequency of the ships that will be passing through the open water. Ships and helicopters will not go closer than 5km to the haul-out areas, known sensitive areas for walrus.

184

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

Citronen Fjord Kilen Amdrup Hovgaard Ø

Wollaston Forland

Figure 53. The distribution of Atlantic walrus in the east Greenland area. Based on observations made by sealers, various expeditions and subsistence hunters living in the area – and catch statistics (Boertmann et al., 2009). Seals

Harp seal Harp seal whelping patches (Figure 54) on the drift ice are very important concentration sites in March–April. Outside the whelping season no particularly important sites are known (Boertmann et al.,

185

2009). As the whelping patches of harp seal are not in the vicinity of the shipping route and occur in March – April the risk is low.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

Hooded seal The whelping and moulting grounds (Figure 54) where high densities may occur in spring and early summer are the most critical habitats for hooded seals and during this period they are sensitive to disturbance.

Hooded seal whelping is more dispersed than that of harp seals, but more or less within the same area of the drift ice and also in March–April. Outside the whelping season no particularly important sites are known.

As the whelping patches of harp seal are not in the vicinity of the shipping route and occur in March – April the risk is low.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

186

Citronen Fjord

Figure 54. The potential and the 2007 whelping area for harp and hooded seals in the Greenland Sea. The potential area is where the whelping has been recorded in recent decades Øigärd et al., (2008) (Boertmann et al., 2009).

Ringed seal Ringed seal is an ecological key species of the east coast of Greenland. Densities vary from area to area, but no particularly important sites are known. It is an important resource for the inhabitants of the town of Ittoqqortoormiit.

Breeding ringed seal depend on stable sea ice when they establish territories, whelp and nurse the pups. This stationary behaviour makes them vulnerable to disturbance and particularly to activities which disrupt the stable ice. But ringed seals do not form whelping congregations as do harp and hooded seals; therefore the population is less sensitive to localised disturbance.

The population is listed as Least Concern on the Greenland Red List. However, reduction in the ice, primarily in summer, may have a negative effect. The risk is therefore medium.

Residual Risk Rating is Medium.

187

Bearded seal The bearded seal is listed as Data Deficient on the Greenland Red List. The population has a favourable IUCN conservation status, and the uniform and widespread distribution of bearded seals is believed to be good protection against overexploitation.

Bearded seals vocalise very often, especially during the breeding season in spring (Burns 1981); they may therefore be vulnerable to acoustic disturbance (noise) (Wiig et al., 1996). Their feeding habits also make them vulnerable to oil-polluted benthos. However, the dispersed distribution makes bearded seal populations less vulnerable to disturbance than the more gregarious species. The risk is therefore low.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

Baleen Whales

Bowhead whale Bowhead whales are considered Critically Endangered on the IUCN on Greenland red lists due to the extreme rarity of the species. The bowhead whales off east Greenland belong to the Spitsbergen stock. This population is still very small, perhaps only a few hundred occur. However the number of sightings has increased since the mid-1980’s and in 2009 a female and calf were observed off east Greenland (Boertmann & Neilsen 2010). This was the first observation of calves in the Spitsbergen stock for many decades. It is likely that the NEW polynya provides a foraging area for bowhead whales. This particular stock of bowheads was almost exterminated by two centuries of whaling (from 1611).

Bowheads are sensitive to disturbance (noise), and may avoid areas with activities such as drilling and seismic surveys. Local populations may be displaced or reduced by increased traffic and oil activities (Wiig et al. 1996). Ships required for the project will make approximately two to three ships return trips per month during the summer period.

Any impacts are most likely to be local and due to the short-lived, infrequent shipping to and from Citronen, the potential impacts of shipping are believed to be short term behavioral changes on an

188 individual level. However, given the extreme rarity of this species and the importance of the NEW polynya to this species, the risk of disturbance from shipping has been classified as a medium.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Medium.

Toothed whales

Besides the five widely spread species of toothed whales mentioned above, there is one exclusively Arctic toothed whale found off eastern Greenland: the narwhal.

Narwhal The narwhal population off eastern Greenland is likely to have a favourable conservation status, as they are fully protected within the Northeast Greenland National Park (Boertmann et al., 2009). Narwhal hunt is regulated in east Greenland and many are taken by hunters from Ittoqqortoormiit and Tasiilaq. it is unknown if the catch is sustainable. There is however a general conservation concern for the narwhal, as a significant part of the global population occurs off eastern Greenland and it is a resource for the communities living in east Greenland. The general distribution of narwhal is shown in Figure 55.

189

Figure 55. The general distribution of narwhal (Boertmann et al., 2009).

There is no information on population trends from east Greenland and the population is listed as Data Deficient on the Greenland Red List and Near Threatened on the IUCN Red List.

There is very little information to elucidate critical and important habitats off eastern Greenland. In spring narwhals congregate along the fast ice edges waiting for the fjords to be available, as seen along the southern ice edge in the NEW polynya in May 2008 (Boertmann et al., 2009). Large numbers have also been reported from some fjords, particularly Kangerlussuaq, not in the vicinity of the shipping route. Guidelines for environmental impact assessments of seismic surveys in Greenland waters (Boertmann 2010) establish preliminary specific summer protection zones for the narwhal (Figure 56).

190

Figure 56 Protection zones for narwhal (also bowhead whale and walrus) in north east Greenland. The protection period for the narwhal is from 1 July to 30 September (Boertmann 2010).

Cosens and Dueck (2006) found that icebreaking vessels produced noise at a level that narwhals would be expected to detect up to 30km away and the species is generally believed to be sensitive to noise impacts (seismic surveys, drilling, shipping, oil activities) which may cause displacement from critical habitats. No narwhals have been observed in Citronen or Frederick E. Hyde Fjord to date.

Narwhals undertake regular migration between shallower summer grounds in fjords, where they apparently do not feed, and wintering grounds in deep and densely ice-covered waters, where they feed; Citronen and Frederick E. Hyde Fjord may therefore be inhabited by narwhal some years. They are gregarious, occurring usually in groups comprising a few to more than 100 individuals.

Based on the sensitivity of narwhal to noise, the regular migration to shallower summer grounds in fjords and the occurrence in groups, there is a potential impact from shipping to displace narwhal in

191

Citronen Fjord and behavioural changes to the species. Potential impacts to narwhals from shipping are considered to be medium.

Management and mitigation measures are discussed in Section 7.8.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Medium.

7.8.4.4 Shipping and fauna - cumulative impacts

Operation of the bulk carriers required for the Citronen project may have a cumulative impact on the marine environment. Single impacts from the shipping may be (but not limited to): • Injury or death resulting from a collision; • Localised contamination from regular ship discharges; • Short term displacement or short term prey displacement from noise; • Injury or death caused by an accidental oil spill.

It is very difficult to estimate cumulative impacts on the pelagic marine environment given that monitoring of the fauna and water in this area is difficult. Also there is great natural variability in this area, contributing to the presence and behavior of fauna, for example ice cover and thickness which changes from year to year.

The number of trips to and from the project during the summer months is very low. With each return trip taking approximately nine days, the bulk carrier will only be passing the Greenland coast every four to five days over an average 42 day season (of open lead).

Given the very small number of trips that can be made and the low risk associated with the assessment of individual impacts, the cumulative impacts will most likely be negligible.

7.8.5 Marine fauna management and mitigation measures

• Specific procedures, actions and responsibilities to avoid or minimise impacts on marine mammals and seabirds will be integrated into the EMP in case species are encountered during shipping. • No significant noise will be generated within five kilometres of a bird cliff if it is occupied by murre (Uria aalge), thick-billed murres (Uria lomvia), little auks (Alle alle), kittiwakes (Rissa tridactyla), northern fulmar (Fulmarus glacialis) or great cormorants (Phalacrocorax carbo). • Observations of faunaduring shipping will be recorded.

192

7.9 Shipping – unplanned events

This section addresses the potential for unplanned or accidental fuel oil spill events, chemical spills and unexpected loss of materials associated with shipping, their likelihood and the potential impacts on environmental resources and receptors should they occur.

Sailing in more or less ice covered waters poses an increased risk of shipping accidents. If an accident were to occur there is risk that diesel fuel or product concentrate on the bulk carriers could be released into the water resulting in contamination of the marine environment. This would pose a very serious threat to aquatic wildlife in the area.

The most serious environmental impact related to a shipping accident would be an oil spill. Due to the slow decomposition rates associated with low ambient temperatures, the oil would be preserved for a long time. In addition the conditions of the Arctic make any recovery attempt very difficult.

In the unlikely event of a shipping accident resulting in the unexpected release of fuel, chemicals or product concentrate, the Site Emergency Response Plan would be activated. This includes a specific Loss of Containment Emergency Management Plan (Appendix 5) which will be further developed with the shipping contractor prior to construction and operations. The level of response will depend on the circumstances of the spill and nature of the resources which are threatened according to the following general guidance:

• Level 1 – a small spill which can be managed using facilities available from the shipping contractor or local to the spill site; • Level 2 – a medium spill which is estimated to be very unlikely and which requires the involvement of the project emergency response resources in addition to contractor facilities and manpower; or • Level 3 – a large spill which requires external resources to manage.

The most likely scenario of a Level 1 spill affecting the water surface would be a smaller spill of fuel oil during refueling which would cause localized impacts on water quality for a short period of time (such as two to three days). Level 2 or 3 spills are more severe and may be caused by sinking following a vessel collision or fire with a fuel oil spill likely to be the most severe of spills. Other events such as vessel breakdown or tow line break are not likely to result in a spill and hence no significant impacts are envisaged.

Zinc concentrate released in the sea from loss of carrier ships may cause elevated concentrations of zinc in the environment. The ore at Citronen hold low concentrations of other metal such as lead, cadmium and copper. The impacts of this scenario are unknown, although a high dilution factor would

193 be expected. The mass of the concentrate would likely cause it to settle to the bottom, where it may result in the localised death of marine organisms. However, it was estimated that the effects of a wrecked zinc ore carrier in 1991 off west Greenland was negligible (Boertmann 1996).

7.9.1 General impacts – unplanned events

In general, oil spills occurring in the coastal zone are regarded as much more deleterious than spills in the open sea. This may, however, not apply in an area such as north-east Greenland, which is dominated by sea ice for the major part of the year (Boertmann et al., 2009). Ice may trap and transport oil over long distances, but may also limit the spread of oil slicks compared with the situation in ice-free waters and even protect shores from being polluted. Furthermore, the ice edges, leads and polynyas are very important in a biological sense and therefore potentially very sensitive to oil spills. Knowledge on the behaviour of oil spill in ice-covered waters is however limited.

In summer (July – September) drift ice is rather dispersed and almost all coasts have at least a narrow stretch of open water (shore lead). Figure 57 shows a designation of particularly important oil spill-sensitive summer areas (Boertmann et al., 2009). In summer the marine mammals off north eastern Greenland are generally more dispersed than other times of the year, but seabirds will be assembled near the coastal breeding colonies. Late in the season the huge Svalbard populations of little auks and thick-billed murres move through the area in company with part of the breeding population of the threatened ivory gull (from north Greenland Svalbard and Arctic Russia). Arctic char assemble at the river mouths before moving into the freshwater spawning and wintering grounds.

In any marine environment, wildlife impacts from oil spills can be considered in three categories:

• Physical contact with the oil in any part of the water column or on shore can reduce the insulating capacity of fur or feathers, leading to hypothermia, or hindering the flight or buoyancy of birds; • Toxic contamination by ingestion, inhalation, or absorption (in the case of eggs) could damage the digestive system, liver, or lungs. Contaminants can be ingested one time after a single spill event, over years in areas of oil activity or situations with low level releases, or through the food chain as they are passed to higher trophic levels in the process of bioaccumulation; and; • Resource scarcity caused by inaccessible food can impact both resident and migratory populations.

194

Figure 57. Designation of particularly important oil spill-sensitive summer areas (preliminary assessment) (Boertmann et al., 2009).

Ice conditions may impact the magnitude or severity of wildlife impacts in several ways. Overall recovery from an oil spill is likely to take longer in Arctic species because slower rates of biodegradation and dispersion due to the colder temperature. Oil is most likely to be released in areas of open water as this is where the shipping routes are. This means that oil will pool within the open leads, polynyas and ice edges. These areas are where birds and mammals tend to feed, and where marine mammals surface to breathe. Also the shipping window is during the summer months when the most biological activity occurs in these important areas.

The probability of a large scale oil spill is very low however if an even like this was to occur it would most likely result in the death of a large number of fauna species. The shipping route passes through a biologically rich area vulnerable to oil pollution, partly due to the time of year being summer months when fauna congregates to breed and feed. In addition, the cold temperatures and ice conditions mean that surface oil persists in the environment for longer and can also be trapped under the ice. As such the risk rating for accidental discharge has been rated as High.

Management and mitigation measures are discussed in Section 7.9.2, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is High.

195

7.9.1.1 Impacts of oil spills - seabirds

Bird populations particularly at risk of being impacted by a Level 2 or 3 spill include the large assemblages of pre-breeding eiders in the polynyas. Some red-listed seabird species (e.g. thick billed murre and ivory gull) also occur and the populations of these will be exposed to increased mortality in case of a large spill.

Sea birds (i.e. auks, gulls and water fowl) are highly sensitive to oil spills because of their potential exposure to oil on the water surface and tendency to congregate in high density aggregations during critical periods such as breeding and migration. The oil principally affects birds by removal of the natural buoyancy and thermal insulating properties of the feathers and by ingestion during feeding and grooming. Seabirds affected by oil die from hypothermia, starvation and drowning.

Birds that forage at sea are sensitive to oil exposure. This could be particularly damaging to the population during the breeding season when parent birds are feeding unfledged young and subsequently for moulting young. Oil irritates the digestive organs, damages the liver, kidney and salt gland function, and causes anaemia.

The species most likely to be affected by a spill depends on the circumstances of the incident e.g. the time of year, location, size and type of oil and type of habitat affected. Severe events can be harmful at the population level (Piatt et al., 1990).

Management and mitigation measures are discussed in Section 7.9.2, and in more detail in appendix 6 – Environmental Management Plan.

7.9.1.2 Impacts of oil spills - fish

Fish in the open sea are less likely to be impacted by an oil spill as they are able to detect oil and can move elsewhere to avoid it (Boertmann et al. 2009). Dilution and dispersion of the oil will also reduce the impact to pelagic fish. However, fish on the coast are more susceptible to an oil spill as the oil concentration is greater due to the oil being trapped against the shoreline. Coastal fish such as Arctic char would be particularly vulnerable to an oil spill. Fish eggs and larvae would also be particularly vulnerable to oil spills and hence recruitment after an oil spill could be well below normal years affecting population size.

Oil spills may also affect fish stocks by tainting the fish meat making them unsuitable for human consumption. Again, this is most likely to occur in areas where the oil will accumulate, generally near the coast where fishing activities happen. Most commercial fishing occurs further south than the

196

proposed shipping route however the movement of an oil spill in the this area may move south with southward currents.

Management and mitigation measures are discussed in Section 7.9.2, and in more detail in appendix 6 – Environmental Management Plan.

7.9.1.3 Impacts of oil spills - marine mammals

Marine mammals can also be impacted by oil spills, although individuals (except polar bears) are not dependent on an intact fur layer for insulation. Polar bears are more sensitive to oil than whales and seals, as they swallow oil that they groom from their fur, and this habit may lead to the death of the bear. Polar bears more dependent on their fur for insulation than seals, and oil fouled fur increases heat loss which in turn gives rise to elevated metabolic rate (Boertmann 1996).

Whales and seals seem to be rather insensitive to fouling with oil. However, if seals or whales are trapped in areas where oil has accumulated, they might experience harmful effects from inhalation of evaporated hydrocarbons. Walrus and bearded seal feeding on benthos may also be exposed to oil through their food if oil sinks and accumulates on the sea floor. Bowhead whales, which occur in low numbers (and are red-listed), belong to a stock which was almost exterminated by heavy exploitation; the recovery of this population may be halted by even a slight increase in mortality.

In this context it is worth noticing that recent studies indicate that at least killer whales are very sensitive to inhaling oil vapours. This could apply to narwhals and bowhead whales, which often occur in densely ice-covered waters. During a large oil spill, such areas with limited open water will be covered by oil and whales will be forced to surface here. Walruses and other seals living in the ice may also be vulnerable to this scenario. The seals whelping on the drift ice will be very exposed to an oil spill in the area and many adults and pups may be fouled. Adult seals are rather robust to oiling, but pups are more likely to succumb. Walruses are also sensitive because the population is concentrated at relatively few sites and also because they are gregarious. Even though seals may tolerate some oil on their fur, such oiling may impact local hunters, as fouled skins are of no use and are impossible to sell.

Management and mitigation measures are discussed in Section 7.9.2, and in more detail in appendix 6 – Environmental Management Plan.

197

7.9.2 Shipping (unplanned events) management and mitigation measures

Safety during shipping is a high priority for Ironbark. Every effort will be made to reduce the risk of a shipping accident and to minimise the impact on the environment in the unlikely event of an incident resulting in the release of fuel or concentrate. The proposed shipping company, Fednav Limited has been chosen for their expertise in shipping in arctic environments. The company has been involved in Arctic shipping for more than fifty years. Fednav will be using IceNav™ system, a computer-based onboard ice navigation service, critical for shipping in the arctic region.

The ice-class bulk carriers that will be used will be of the highest “ice class” suitable for conditions off the coast of Greenland. Fednav environmental policies can be found on www.fednav.com/en/company/environmental-policy.

The probability of a large spill due to a blow out or a vessel incident is very low, due to the short duration of the shipping window, the limited number of trips and the choice of shipping vessel proposed.

The approach to tactical oil spill response will be to contain the spill, remove where possible any free oil and clean where appropriate. Clean up techniques will be managed to avoid additional impacts to sensitive environments.

• Ice-class bulk carriers will be used to transport concentrate and supplies. • Purpose built sealed tanks will be used for fuel storage and transport • A project specific Fuel and Oil Spill Contingency Plan will be developed • Regular maintenance of storage tanks will be undertaken to ensure fulfillment of regulatory requirements for offshore use and reduce the possibility of rupture or leaks • Refuelling operations will be conducted in calm weather conditions and rigorous monitoring of the refuelling operations will be carried out • Sewage, grey water and kitchen waste will be treated, handled and discharged according to MARPOL standards • Bilge and drainage water will be treated and discharged to MARPOL standards • The ballast water will always be exchanged mid-ocean on the Citronen – marshalling port shipping route in order to minimise the risk of introducing new species in ports of origin or destination

198

7.10 Air Emissions

7.10.1 Dust

This impact relates to the airborne dust and emissions of particulate matter generated from the Project. This includes potential dust emissions from mining activities including the process plant, crusher and haul roads. The dispersal of dust can potentially cause pollution of water and land and also affect visibility.

Open pit mining causes dust generation through load and haul activities, and through surface blasting. Underground mining causes dust within the workings of the mine. The dust is transported in the air and exhausted from the mine via the vent raises. Dust will also be generated during the crushing of ore, as the material is broken down to a smaller size fraction. Concentrate loading to the ships has the potential to cause dust during transfer of material. Haul road fugitive dust will occur during truck transport along these roads.

The dust dispersion model developed for the Project highlights areas that are likely to produce dust during operations. Activity rates used in estimating emissions as well as the content of zinc and lead in each source are considered conservative and the estimated impacts presented in this report are unlikely to occur for the full life of the mine.

The maximum annual zinc and lead dust deposition at off-site receptors (i.e. outside the mine area) is predicted to be between 0.13–0.33 g/m2 and 0.02–0.05 g/m2, respectively (Table 32).

Table 32. Summary of maximum predicted zinc and lead (PM/PM10) deposition from dust at Citronen off-site receptors (Golder 2011).

Maximum Annual Average Concentration Maximum Annual Deposition Pollutant (ug/m3) (g/m2)

2.83 8.21 PM 0.11 0.33 Zinc 0.02 0.05 Lead

14.20 4.1 PM 10 0.43 0.13 Zinc 0.06 0.02 Lead

The air dispersion model developed for the Project (Section 6.12.1) predicted that the highest dust concentrations will occur along the haul roads however the dust associated with transportation will mainly be caused by vehicle turbulent wake and contains little dust from the loads containing metals

199 such as zinc and lead. The highest dust concentrations containing zinc and lead (and hence deposition) will occur at the crusher area.

Concentrations of lead and zinc in surface soil were estimated in the SLERA (2012) using the results of the dust dispersion modeling presented in Golder’s Air Quality Modeling Report (Golder 2011) and exposure concentration methodology in USEPA (1999). The report evaluated dust emissions from mine roads and other sources of potential release from the proposed mine operations. The surface soil screening compared the modeled maximum concentrations of lead and zinc in surface soil due to deposition of dust to surface soil screening values. Screening values were available for all COPECs from NOAA (2010) and CCME (2007b).

The comparison of maximum concentration to soil screening values indicated that the maximum concentration of lead (50 mg/kg) and zinc (331 mg/kg) were below the screening value (600 and 360 mg/kg, respectively) (Table 33). Therefore, modelled concentrations of lead and zinc in surface soil are not anticipated to present a risk to ecological receptors.

Table 33. Comparison of Maximum Modelled Soil Concentrations to Soil Screening Values. Maximum Soil Screening Soil Eliminated COPECs concentration Value Screening From Risk mg/kg mg/kg Value Source Assessment Aluminum NA 50 a Data gap Arsenic NA 12 b Data gap Cadmium NA 22 b Data gap Copper NA 91 b Data gap Lead 50 600 b Yes Mercury NA 50 b Data gap Nickel NA 50 b Data gap Zinc 331 360 b Yes

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a = NOAA, 2010; b = CCME, 2007b

Dust deposition onto vegetation is predicted to take place mostly around the crusher, making the plants less palatable to wildlife. The impact of this is thought to be very low because of the limited amount of vegetation within the project site (approximately 5% cover) and few animals are predicted to utilise the vegetation close to the mine (see Section 7.4.4).

200

Based on the deposition model, it is likely that small amounts of dust will settle in the Eastern River and in Citronen Fjord. The model suggests that from this dust, only small amounts of metals, in particular lead and zinc, will enter the river and fjord systems. Dust from mine operations will most likely only lead to an insignificant increase in the metal concentrations of the river and fjord, which already contain naturally high metal concentrations due to water washing off the high sulfide gossans at the upper end of the river (Section 5.6.2.1 and 5.7.1.1).

The surface water screening in the SLERA (2012) compared the modelled maximum concentrations of the COPECs in each surface water body during operations and during closure to surface water screening values. These concentrations included inputs from all potential sources, including dust. Screening values used were from CCME (2007a) and BMP (2011).

The screening of COPECs in the Citronen Fjord during operations indicated that the maximum estimated concentration of all COPECs were below surface water screening values (Table 34).

Table 34 Comparison of Maximum Modelled Citronen Fjord Surface Water Concentrations during First 13 Years of Operations to Marine Water Screening Values. Surface Water Surface Concentration Eliminated Screening Value Water COPECs From Risk Screening mg/L mg/L Assessment Value Source Aluminum 1.01E-02 0.100 a Yes Arsenic 2.14E-05 0.005 b Yes Cadmium 2.20E-06 0.0002 b Yes Copper 1.91E-04 0.002 b Yes Iron Not Above Background 0.030 b Yes Lead 1.66E-03 0.002 b Yes Mercury 1.15E-05 0.00005 b Yes Nickel 9.12E-04 0.005 b Yes Zinc 5.86E-04 0.010 b Yes

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a = CCME, 2007a; b= BMP, 2011.

Lead, nickel, and zinc having concentrations higher than surface water screening values in Citronen Fjord during the last three years of operations due to mining of the open pit (Table 35).

201

Lead, nickel and zinc were further evaluated against lower and upper trophic receptors. This analysis showed that during the last three years when the open pit is operating there will be potential risk to fish eating birds from maximum modeled concentrations of zinc. Again, it must be noted that this assumption is likely to be overly conservative.

Table 35 Comparison of Maximum Modelled Citronen Fjord Surface Water Concentrations during Final Three Years of Operations/Closure to Marine Water Screening Values. Surface Water Surface Concentration Eliminated Screening Value Water COPECs From Risk Screening mg/L mg/L Assessment Value Source Aluminum 2.72E-02 0.100 a Yes Arsenic 3.73E-03 0.005 b Yes Cadmium 1.79E-04 0.0002 b Yes Copper 5.47E-04 0.002 b Yes Iron <5.0E-03 0.030 b Yes Lead 3.6E-03 0.002 b Retained Mercury <5.0E-05 0.00005 b Yes Nickel 2.55E-02 0.005 b Retained Zinc 2.16E-01 0.010 b Retained

Maximum Concentration is Lower than Screening Value Maximum Concentration is Higher than Screening Value a = CCME, 2007a; b= BMP, 2011

Overall dispersal of dust from Project activities is not anticipated to cause significant pollution or increases in metal levels in freshwater, marine water or land areas around the mine. Predicted maximum dust concentrations in both the air quality model and SLERA indicate that the risk to ecological receptors is low, particularly as most dust will be generated during the last three years of operation when the pit is mined. Further, mitigating measures will be implemented to reduce the release of dust specifically from the crusher, the haul roads and other mine facilities to ensure that dust is kept to a minimum and within applicable guideline limits. It is anticipated that the risk of this impact is Low.

Management and mitigation measures are discussed in Section 7.10.2, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

202

7.10.2 Dust management and mitigation measures

• Choose vehicles and other equipment based on energy efficiency technologies to optimise emissions rates • Construction methods will be employed that will keep dust generation to a minimum, and as required provide for the management of dust by watering the works area, roads and other areas immediately adjacent to the works when possible • Clearing will be done as per the agreed Clearing Plan within the construction plan and kept to a minimum. “Blanket” clearing will not be practised. • Use water to suppress dust emissions from unsealed roads, stockpiles and work areas when possible • No physical control of dust is available for blasting due to safety reasons. Blasting will only occur during times when wind conditions are optimal for minimal dust generation. • Crushing will be done within a sealed building. Any dust will be filtered with appropriate bag houses equipment. • All conveyors will be covered to minimise dust from crushed ore and concentrate • Concentrate will be loaded using covered conveyors, hatches on cargo holds and a sock fitted to the telescopic chute which discharges directly to the hold • Maintain thin layer of wet tailings/ice cover through deposition technique to minimise dust blowing off surface • Maintain diesel power plant, vehicles and other fuel powered equipment in accordance with manufacture’s specifications to minimise on emissions • Apply further dust suppression controls where dust levels are deemed excessive • No materials (including rubber or plastic products, waste oil or any other waste material) are to be burned unless authorised • Dust will be monitored on a regular basis • Report any dust levels that are deemed excessive as an environmental event

7.10.3 Greenhouse Gas

Carbon dioxide and other greenhouse gases will be generated by the diesel power plant and vehicles. Visiting aircraft and ships will also generate greenhouse gases.

Greenland is not a party to the Kyoto Protocol, however the Greenland government has requested Denmark to ratify the Kyoto Protocol without reservation for Greenland. In connection with the Danish ratification, Greenland and Denmark concluded a framework agreement to ratify the Kyoto Protocol. According to this agreement, Greenland must actively seek to reduce greenhouse gas emissions by 5.2% compared with 1990 levels (655 000 tonnes). This target however, is exempt of emissions from

203 the minerals industry. In 2007 the carbon dioxide emissions had increased to 674 000 tonnes, that is by 2.9% compared to the 1990 level (Grønlands Selvstyre 2009).

Approximately 50 million litres of diesel will be consumed annually by the Project (80% power generation and 20% mobile equipment). Emissions have been calculated as approximately 132,700 tonnes of carbon dioxide (assuming the emission from a litre of diesel generates 2,654 g CO2) (USEPA, 2005). The estimated carbon dioxide production due to the mining operation will correspond to approximately 20% of the total carbon dioxide emissions for Greenland calculated for 2007.

The emission levels from ships are internationally regulated with air pollution caps for sulphur oxide and nitrogen oxide stipulated by the IMO’s Marpol Annex VI. The bulk carriers will be governed by these regulations. Given the limited amount of trips (approximately three per year) required for the transport of the concentrate, greenhouse gas emissions from shipping are considered to have an insignificant environmental impact.

By adopting the Best Available Technique (BAT) principle, Ironbark will ensure that particular emissions from the power plant, trucks and other sources are kept at a minimum and these emissions are not considered to have a significant impact on the air quality in the area. With these measures in place and the fact that the Project emissions are not contributing to Greenland’s emission target the impact is assessed as Low.

Management and mitigation measures are discussed in Section 7.10.4, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

7.10.4 Greenhouse gas management and mitigation measures

• Use the best available technique (BAT) to ensure emissions are kept at a minimum possible and reduce energy use through energy efficient practices

204

7.11 Hazardous Materials

7.11.1 Hazardous materials – unplanned events

Unplanned releases in connection with transport, storage and handling of hazardous materials such as fuel, grease, paint, chemicals and explosives could potentially cause contamination of soil or water resources at the Project.

Hydrocarbons (such as oil, petrol and diesel) can have toxic effects on the environment. Due to their organic nature small amounts of hydrocarbons are generally broken down by bacteria in the soil, however this process is much slower in the arctic climate. Appropriate storage (consistent with Greenland government regulations and guidelines) and handling of hazardous materials will reduce the risk of contamination from these materials. Bulk hydrocarbons will be stored within bunded tanks and pipelines carrying such materials will also be bunded to capture leaks or spills. In the event of a spill, all hazardous material will be retained within the bund.

Good vehicle and equipment maintenance and prompt reactions to any spills will reduce contamination of the ground in the mine area.

It is considered that the risk of contamination from hazardous surface soil or water resources in and around the mine area is low. None of the planned mine activities would lead to more than very limited and localised contamination.

Management and mitigation measures are discussed in Section 7.11.2, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

7.11.2 Hazardous materials management and mitigation measures

• Design and construct hazardous material storage facilities with suitable impermeable materials • All hazardous substances will be contained and stored within appropriate bunded facilities. Areas with high potential for contamination (such as workshops) will be contained on impermeable hardstand areas. • Develop specific management plans and procedures for the transport, handling and storage of hazardous substances such as explosives, fuel, lubricants and chemicals • Concentrate will be stored in an enclosed building on a gravel pad with a liner 205

• Procedures will be put in place to control track in/out issues within the concentrate shed • Hazardous waste that cannot be disposed or treated on site will be contained and packaged as per applicable standards and shipped off site to an approved facility

7.12 Archaeology and Cultural Heritage

7.12.1 Culturally significant sites

An archaeological survey of the Citronen Project site was conducted by the Greenland National Museum in July 1994. The purpose of this survey was to ensure that no sites of archaeological interest would be affected by the exploration activities occurring at the time. The survey covered an area of 6.5 km2.

No evidence of former Eskimo settlement was found however observations were made that suggested there was human activity in this area in historic and pre-historic times. Of mention was one site in which three stones are present which were most likely used for supporting an open boat used by people of the Thule culture.

These stones will require documentation and registration by the Greenland Museum. Until that time, the location of the stones will be mapped and included in site plans as an area to be avoided and left undisturbed. The impact to any culturally significant sites is therefore deemed to be low.

Management and mitigation measures are discussed in Section 7.13.2, and in more detail in appendix 6 – Environmental Management Plan.

Residual Risk Rating is Low.

7.12.2 Archaeology management and mitigation measures

• No disturbance of the probable anthropology structure and near surroundings (15m radius) on the eastern shore of Citronen Fjord is to occur prior to archaeological registration and documentation by a person(s) from the Greenland National Museum • If any material of potential archaeological or cultural heritage significance are uncovered or revealed, works will immediately cease within 20m of the material and the Greenland National Museum, or other appropriate authority, will be notified as soon as practicable

206

8 ENVIRONMENTAL MANAGEMENT

8.1 Environmental Management Principles

Ironbark aims to conduct its business in an efficient and environmentally responsible manner that is compatible with the expectations of its shareholders, the Greenland Government and the community. Ironbark is committed to meeting its environmental responsibilities required under statutory regulations, with these encompassing social obligations, and minimising environmental impacts. The basis of Ironbark’s environmental management framework lies in management commitment and the allocation of resources to establish systems based on reducing environmental risk.

8.2 Environmental Management System

Ironbark is committed to developing and implementing an environmental management system (EMS) consistent with the internationally recognised continuous improvement model ISO14001:2004. The Ironbark EMS will be a structured, documented approach to managing risks and potential environmental impacts arising from the Project. The key elements of Ironbark’s environmental management framework include:

• An assessment of environmental risks;

• Identification of relevant government policy, law and guidelines;

• Incorporation of conditions of approval and other commitments;

• Development and implementation of environmental controls and improvements;

• Monitoring of environmental impacts and performance;

• Corrective action to address issues as they are identified; and

• Review of procedures and plans to ensure continual improvement.

The EMS functions as a robust tool for environmental management at Citronen to manage environmental related aspects and will undergo review and update, as part of its continual improvement to incorporate the environmental management and monitoring requirements, commitments and approval conditions resulting from the EIA process. The EMS will ensure that the environmental obligations associated with the Citronen Project are adequately managed in a manner that is planned, controlled, monitored, recorded and audited.

207

Environmental incidents will be reported, investigated, analysed and documented. Information gathered from the incident investigations will be analysed to monitor trends and to develop prevention programs which include corrective and preventative actions taken to eliminate the causes of incidents. All employees, contractors and sub-contractors will be required to adhere to the Ironbark EMS and the non-conformance and corrective action system in place at Citronen.

8.3 Preliminary Environmental Management Plan

The Citronen Preliminary Environmental Management Plan (EMP) (Appendix 6)) summarises commitments and management measures that Ironbark will implement to ensure the Project risks are managed to an acceptable level. The EMP outlines the management objectives under each environmental aspect identified in the EIA, the potential impacts to the environment, the mitigation measures for each impact, who is responsible for each commitment as well as the applicable pre- construction, construction, operational or decommissioning stage for which management is required. The commitments outlined in the EMP aim to provide a basis for which environmental performance and compliance can be measured throughout the Project.

More detailed environmental management plans will be developed for specific areas in response to environmental management requirements closer to commencement of the Project. Work procedures will be developed from these plans. The EMP(s) and work procedures will be periodically reviewed and updated over the life of the mine.

Environmental management commitments detailed in the EMP(s) will be included in relevant contract documents and technical specifications prepared for the Project. All Ironbark employees, contractors and other personnel employed on the Project will be made aware of the EMP(s) through the site induction process. During all phases of the Project, compliance with environmental management measures will be regularly monitored, any non-compliances addressed and improvement actions will be implemented.

The environmental objectives and outcomes that Ironbark aspire to achieve from the application of the EMP are outlined below under each of the environmental aspects.

208

9 ENVIRONMENTAL MONITORING PLAN

Environmental monitoring of the Citronen Project is inherently a long-term activity and requires both a conceptual base to provide testable measures of change, and continuing commitment to acquire the basic information necessary for long-term evaluations. Ecosystems, by their very nature, are dynamic systems, and are constantly adapting to environmental change. Furthermore, populations of fish, birds, mammals and other biota fluctuate with natural cycles and water quality shows significant natural variation as annual weather patterns change. In a broader sense, fauna respond in distinctive ways to physical and chemical environmental elements by selection and adaptation. The monitoring program must be comprehensive and flexible enough to show whether a change is due to human activity or natural variation.

The purpose of the environmental monitoring program is to develop a comprehensive and flexible method to assess the environmental status and trends in the Citronen Fjord area, including both spatial and temporal variations in water and sediment quality as well as in the health and abundance of the habitats and biota of the area. This information will provide insights into the effectiveness of management strategies in line with regulatory, policy and management requirements, indicate where objectives have been met, if actions should continue, and whether more stringent controls or management is warranted.

Water physico-chemistry analysis and biological monitoring methods will provide the capability for early detection of potential significant effects so that early management action can be taken to prevent ecologically important impacts. Monitoring ecosystem level responses in biological communities will provide information on the ecological importance of any likely impact.

It is proposed that monitoring of the following environmental aspects will be undertaken:

• Fresh and marine water from Eastern River, Lake Platinova and Citronen Fjord; • Site terrestrial soil; • Sediment from Eastern River, Lake Platinova and Citronen Fjord; • Flora distribution, health and abundance; • Fauna distribution, health and abundance; • Meteorological data; • Site dust emissions; • Mine waste Geochemical characterisation; • Pit lake water; and

209

• Water quality, sediment and biotic indicators (e.g. seaweed) at two reference stations in Frederick E. Hyde Fjord.

Wherever possible, the sampling stations used in the baseline studies have been retained to provide data continuity. Routine monitoring will commence prior to construction to ensure maximum provisions of pre-development baseline data. The samples will be collected and analysed in accordance with BMP guidelines.

Ironbark will conduct regular reviews of its environmental monitoring program to drive continual improvement and allow the program to be assessed in terms of its ability to 1) report on the risk to the ecological health of the Citronen environment; 2) establish whether regulatory requirements and environmental objectives are being met; 3) identify important components to be included in the monitoring program and equally identify any components that are not adding value; and 4) identify knowledge gaps that need to be filled by additional targeted investigations.

Ironbark will routinely monitor, collate and report monitoring data on both emissions and impacts of the mine to the Greenland authorities, including:

• Any environmental incidents or unplanned events leading to a release of material to the environment (atmospheric, aquatic and terrestrial): • Any non-compliances with environmental regulations or licence conditions; • Any complaints or grievances received; and • Records of any interactions with fauna.

Table 36 outlines the monitoring parameters and sampling locations proposed. Where relevant, the program includes control sites where no expected Project impacts are likely to be experienced.

210

Table 36. Citronen Environmental Monitoring Program

Monitoring Sites/activities to be monitored Parameter to be monitored Frequency Duration aspect

River water Eastern River; Esrum River Water flow, level, and discharge using self- Continual during flow period Life of mine; discharge recording pressure loggers installed in the (late May to early October) three years post rivers closure Freshwater source Lake Platinova Water levels prior and after embankment Weekly Life of Mine construction; Arctic char population At least annually, more detailed monitoring to be determined Freshwater quality Eastern River (representative baseline A suite of metals, ions and/or other analytes Eastern River: one Life of mine; stations including sites upstream, agreed with BMP, including zinc, copper, permanent station daily three years post adjacent to and downstream from the cadmium, lead, nickel, arsenic and mercury during initial flows; other closure mine) stations every second week Environmental parameters: pH, dissolved during flows Esrum River (representative baseline oxygen, turbidity, salinity, suspended solids stations upstream adjacent to and Esrum River: one permanent Analytes may be added or omitted based on downstream from the mine) station daily during initial interpretation of trends observed in the data flows; other stations every

second week during flows Lake Platinova (three baseline stations) Lake Platinova: every second week Marine water Citronen Fjord (baseline stations) and A suite of metals, ions and/or other analytes During early flows from Life of mine; quality reference stations in Frederick E. Hyde agreed with BMP, including zinc, copper, Eastern and Esrum Rivers, three years post Fjord cadmium, lead, nickel, arsenic and mercury then monthly during flows closure at increasing depths

211

Monitoring Sites/activities to be monitored Parameter to be monitored Frequency Duration aspect

Environmental parameters: pH, dissolved oxygen, turbidity, temperature, salinity and suspended solids at increasing depths

Analytes may be added or omitted based on interpretation of trends observed in the data

Freshwater Eastern River (representative baseline A suite of metals, ions and/or other analytes Annually (August) Life of mine; sediment quality stations including sites upstream, agreed with BMP, including zinc, copper, three years post adjacent to and downstream from the cadmium, lead, nickel, arsenic and mercury closure mine) Environmental parameters: redox-potential, Esrum River (representative baseline pH, dissolved oxygen, turbidity, salinity, stations upstream adjacent to and suspended solidsAnalytes may be added or downstream from the mine) omitted based on interpretation of trends observed in the data Lake Platinova (three baseline stations)

Marine sediment Citronen Fjord (baseline stations) and A suite of metals, ions and/or other analytes Annually (August) Life of mine; quality reference stations in Frederick E. Hyde agreed with BMP, including zinc, copper, three years post Fjord cadmium, lead, nickel, arsenic and mercury closure

Environmental parameters: redox-potential, pH, dissolved oxygen, turbidity, salinity, suspended solids

Analytes may be added or omitted based on interpretation of trends observed in the data

212

Monitoring Sites/activities to be monitored Parameter to be monitored Frequency Duration aspect

Dust deposition Sites where dust deposition was Total suspended particulates and PM10 Initially monthly but may Life of mine; predicted from dust modelling and at particulates, metal concentration of decrease to annually three years post reference sites particulate matter closure

Metal Representative baseline stations in Metals (including identified COPECs ) in Annually (August) Life of mine; concentrations in mine area and two reference stations arctic willow (Salix arctica) and entired- three years post tissues of higher leaved mountain avens (Dryas integrifolia) closure plants

Metal loads in Mammal droppings within project area Metals in lemming, hare and muskoxen Annually (August) or Life of mine; mammals droppings three years post opportunistically closure

Metal contents in Baseline stations in Citronen Fjord Metals (including identified COPECs) in Annually (August) Life of mine marine fish tissues of four-horned sculpin (Myoxocephalus quadricornis)

Metal contents in Baseline stations in Citronen Fjord and Metals (including identified COPECs) in Annually (August) Life of mine marine algae reference stations in Frederick E. Hyde Laminarin sp Fjord

Local climate Meteorological station Meteorological data including wind direction, Continual Life of mine wind speed, temperature, relative humidity, pressure and precipitation

Higher fauna Mine area and near surroundings Observations of birds and mammals and Annually (August) Life of mine other fauna made in connection with other monitoring activities

213

10 DECOMMISSIONING AND CLOSURE PROCESS

10.1 Closure Objectives

Once the end of mine life has been reached, it is Ironbark’s goal to restore the land to an environmental acceptable state and manage the environment through a program of post-closure care and maintenance (if required).

A Decommissioning and Closure Plan will be submitted to the Greenland Government in accordance with Sections 43 and 73 of the Mineral Resources Act.

Closure planning at Citronen will be an active and continuous process that will be constantly evolving. The closure process that Ironbark proposes to adopt is a dynamic approach that allows for the development of a Decommissioning and Closure Plan (DCP) which will be updated and refined throughout the life of the mine. The DCP will be updated on a regular basis to incorporate mine developments and considers the results of the testing and monitoring as well as any changes to the environmental, regulatory and social environment that may have occurred over the life of the mine.

The over-riding objectives of closure at Citronen are the following:

1. Physically safe so that the site is left safe for any users (people and wildlife);

2. Physical stable ensuring that the site can be considered safe from excessive slumping and erosion; and

3. Chemically stable meaning that any material remaining on the surface will not release substances at a concentration that would significantly harm the environment.

214

10.2 Conceptual Closure Plan

A brief and conceptual closure plan is outlined in Table 37. Ironbark proposes that this is used as the basis for the ongoing closure process described above.

Table 37. Conceptual Closure Plan for the Citronen mining project

Mine Facility Decommissioning and closure plan actions

Open pit void • Minor reshaping around the crest of the pit may be required at the end of life of the mine to manage surface water flow. • Retain pit crest bund to deter people and fauna from entering the pit void. • Allow the pit to fill with water. • Retain as permanent void. Backfilling the pit void with mine waste is not proposed.

Underground • Remove all sources of hazardous substances (temporary fuel and declines oil storage, including within disposed machinery and equipment). • The decline entrance will be backfilled with waste material to prevent access in accordance with the appropriate mine regulations.

Waste Rock Dump • The waste landform will be shaped to form a stable structure. This and DMS rejects may include pushing down batter slopes to a smaller angle. dump • The top of the waste landform will be capped with benign material and shaped to form a convex shape to discourage retention of water. • Berms between lifts will be forward sloped to discourage retention of water. • A toe bund will be constructed at the base of the dump to catch any silt or debris coming from the dump and prevent any from entering the Eastern River.

215

Mine Facility Decommissioning and closure plan actions

Tailings Storage • The pipeline and spigots will be removed. Facility • The top of the TSF will be covered with a 1m layer of waste

material from either underground or the pit. The top will be sloped towards the north encouraging water off the facility.

Processing Plant • All parts of the plant will be removed from site. • The area will be re-profiled to re-instate any required surface drainage.

Roads • Roads will remain in place and ripped to encourage revegetation.

• Any installed culverts will be removed and surface drainage re- established. • Roads required for monitoring purposes will remain intact.

Pipelines and tanks • All pipelines and tanks will be removed off site or buried as appropriate and as per regulations.

Facilities at Port • All buildings and equipment will be removed off site. site • Concrete foundations will be broken up and covered with rock fill

or coarse material. • The area will be reshaped where possible to restore natural slope and drainage.

Airstrip • The airstrip will remain on closure. Any specific requirements by the Ministry of Transport and Civil Aviation for Greenland will be incorporated into the Final Closure Plan. • The embankment will be partially removed on closure to allow the Lake Platinova lake to return to its original maximum level. embankment • The drainage channel between the Eastern River and Lake Platinova will be reinstated. • The lake will be repopulated with Arctic char if required.

216

Mine Facility Decommissioning and closure plan actions

Other buildings • All other buildings and infrastructure will be removed or buried. and infrastructure • Floating barges will be re-floated and tugged off site for salvage or (explosives magazine, resale. accommodation, messing facilities etc) All locations where • Remove all general waste off site or bury as appropriate. possible • Any contaminated soil will be removed and buried within the waste dump, underground or the tailings facility (whichever is considered more suitable to the type of contamination). • Rip the surface to alleviate compaction and encourage natural revegetation.

217

11 REFERENCES

Aastrup, P. & Boertmann, D. 2009. Biologiske Beskyttelsesområder i Nationalparkområdet, Nord- og Østgrønland. Danmarks Miljøundersøgelser. Faglig rapport fra DMU nr. 729. 91 pp.

Aastrup, P., Bay, C. & Christensen, B. 1986. Biologiske miljøundersøgelser i Nordgrønland 1984-85. Grønlands Fiskeri- og Miljøundersøgelser, 113 pp.

Aastrup, P., Egevang, C., Lyberth, B. & Tamstorf, M. 2005. Naturbeskyttelse og turisme i Nord- og Østgrønland. Danmarks Miljøundersøgelser. Faglig rapport fra DMU br. 545. 133 pp.

Arctic Council (2009). Arctic Marine Shipping Assessment 2009 Final Report.

Blackwell, S.B., Lawson, J.W. and Williams, M.T. 2004. Tolerance by ringed seals (Phoca hispida) to impact pipe-driving and construction sounds at an oil production island. – J. Acoust. Soc. Am. 115: 2346-2357.

Boertmann, D. 1996. Environmental impacts of shipping to and from Citronen Fjord. A preliminary assessment. NERI Technical Report 162. 35 pp.

Boertmann, D. 2007. Grønlands Rødliste, 2007. Direktoratet for Miljø og Natur, Grønlands Hjemmestyre. 152s. http://www2.dmu.dk/Pub/Groenlands_Roedliste_2007_DK.pdf

Boertmann, D., Johansen, K., Rasmussen, L., Schiedek, D. Ugarte, F., Mosbech, A., Frederiksen, M. and Bjerrum, M. 2009. The Western Greenland Sea. A preliminary strategic environmental impact assessment of hydrocarbon activities in the KANUMAS East area. National Environmental Research Institute, Aarhus University. 246 pp. - NERI Technical Report No. 719

Boertmann, D. & Nielsen, R.D. 2010. Geese, seabirds and mammals in north and northeast Greenland. Aerial surveys in summer 2009. National Environmental Research Institute, Aarhus University. 66 pp. – NERI Technical Report No. 773.

Boertmann, D., Tougaard, J., Johansen, K. & Mosbech, A. June 2010. Guidelines to environmental impacy assessment of seismic activities in Greenland waters. 2nd edition. National Environmental Research Institute, Aarhus University. – NERI Technical Report No. 785.

218

Born, E. W. 1995. Status of the polar bear in Greenland, Pp. 81-103 in Wiig, Ø., Born, E.W. and Garner, G. (eds.). Polar Bears. Proceedings of the 11th Working Meeting of the IUCN/SSC Polar Bear Specialist Group. – Occasional Paper of IUCN/SSC No 10. Gland Switzerland and Cambridge, UK.

Born, E. W. and Knutsen, L. Ø. 1997. Haul-out activity of male Atlantic walruses (Odobenus rosmarus rosmarus) in northeastern Greenland. – Journal of Zoology (London) 243: 381-396.

Bureau of Minerals and Petrol, Greenland Home Rule (BMP) 2007. BMP – guidelines – for preparing an Environmental impact assessment (EIA) Report for Mineral Exploitation in Greenland. BMP Nuuk. 16 pp.

Bureau of Minerals and Petrol, Greenland Home Rule (BMP) 2011. BMP – guidelines – for preparing an Environmental impact assessment (EIA) Report for Mineral Exploitation in Greenland. BMP Nuuk.

Burns, J. J. 1981. Bearded seal (Erignathus barbatus) Erxleben, 1777. Pp 145-170 in: Ridgway, S.H., & Harrison, R.J. eds. Handbook of marine mammals. Vol 2. Seals. – Academic Press, London.

Canadian Council Of Ministers for the Environment (CCME) 2002. Canadian Sediment Quality Guidelines for the Protection of Aquatic Life. Tables 1 and 2 – Probable Effect Level for Interim Freshwater and Marine Sediment Quality Guidelines.

Canadian Council Of Ministers of the Environment (CCME) December 2007a. Canadian Water Quality Guidelines for the Protection of Aquatic Life. Summary Table for Interim Freshwater and Marine Sediment Quality Guidelines.

Canadian Council Of Ministers of the Environment (CCME) 2007b, Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health (CSQG). Table 1 – Canadian Soil Quality Guidelines.

Chow, V.T. (1959). Open Channel Hydraulics. New York, NY: McGraw-Hill.

Cosens, S.E. and Dueck, L.P. 2006. Icebreaker Noise in Lancaster Sound, N.W.T., Canada: Implications for Marine Mammal Behaviour. Marine Mammal Science, 9 (3): 285-300.

219

Davis, R. A., Richardson, J., Thiele, L., Dietz, R. And Johansen, P. 1990. State of the Arctic Environment. Report of underwater noise. November 9, 1990 – Finnish Initiative on Protection of the Arctic Environment.

Egevang, C. and Boertmann, D. 2008. Ross’s Gulls (Rhodostethia rosea) Breeding in Greenland: A review, with Special Emphasis on Records from 1979 to 2007. – Arctic 61: 322- 328.

Enfotec Technical Services March 20011. Definition of Ice Conditions and Ship Access to Citronen Fjord Greenland. Draft Report for Ironbark Zinc Ltd.

Falk, K., Hjort, C., Andreasen, C., Christensen, K. D., Elander, M., Ericson, M., Kampp, K., Kristensen, R. M., Møbjerg, N., Møller, S., and Weslawski, J. M. 1997. Seabirds utilising the Northeast Water polynya. – Journal of Marine Systems 10: 47-65.

Foote, A. D., Osborne, R. W. and Hoelzel, A. R. 2004. Whale-call response to masking boat noise. – Nature 428: 910.

Glahder, C. 1998. National Environment Research Institute. Second Baseline Study in the Citronen Fjord Area, North Greenland 1997. NERI Research Notes No. 83. 46 pp.

Glahder, C. and Langager, H.C. National Environment Research Institute & Greenland Field Investigations. 1993. Reconnaissance in the Citronen Fjord area, North Greenland. 80 pp.

Glahder, C. and Asmund, G. 1995. National Environment Research Institute.. Baseline study in the Citronen Fjord area, North Greenland 1994. 40 pp.

Golder Associates, January 2011. Air Quality Modeling Report for the Proposed Citronen Mining Operations. 38pp

Greenland Institute of Natural Resources (2003) Biodiversity of Greenland - a country study. Technical Report No. 55, Pinngortitaleriffik, Grønlands Naturinstitut, 165 pp.

Grønlands Selvstyre. 2009. Redegørelse for virkemidler til reduktion af udledning af drivhusgasser 2008-2012, 99 pp.

IMO (2010) International Maritime Organisation. Accessed online: www.imo.org (January 11 2010).

220

IUCN 2008. 2008 IUCN Red List of Threatened Species. Web site visited Feb 2012 http://www.iucnredlist.org/.

Jochens, A. D., Biggs, K., Benoit-Bird, D., Engelhaupt, J., Gordon, C., Hu, N., Jaquet, M., Johnson, R., Leben, B., Mate, P., Miller, J. , Ortega-Ortiz, A., Thode, P., Tyack, P. T and Würsig, B. 2008. Sperm whale seismic study in the Gulf of Mexico: Synthesis report. – U.S. Dept. of the Interior, Minerals Management Service, Gulf of Mexico OCS Region, New Orleans, LA. OCS Study MMS 2008-006. 341 pp.

Johansen, P. and Asmund, G. 1995. Danmarks Miljøundersøgelser. Miljøundersøgelser i Citronen Fjord april 1995. 7 pp.

Jonasson, S., Michelsen, A. and Schmidt, I. K. 1999. Coupling of nutrient cycling and carbon dynamics in the Arctic, integration of soil microbial and plant processes. Applied Soil Ecology 11: 135-146

Kapel, H. 1994. Citronen Fjord, Nordgrønland. Arkæologisk rekognoscering udført I forbindeldse med et tilsynsbesøg. 20pp.

Lee, K., Azetsu-Scott, K., Cobanli, S. E., Dalziel, J., Niven, S., Wohlgeschaffen, G., and Yeats, P. 2005. Overview of potential impacts from produced water discharges in Atlantic Canada. Pp. 319-342 in Armsworthy et al. (eds.): Offshore oil and gas environmental effects monitoring. Approaches and technologies. – Batelle Press, Columbus, Ohio.

Liebezeit, J. R., S. J. Kendall, S. Brown, C. B. Johnson, P. Martin, T. L. McDonald, D. C. Payer, C. L. Rea, B. Streever, A. M. Wildman, and S. Zack. 2009. Influence of human development and predators on nest survival of tundra birds, Arctic Coastal Plain, Alaska. Ecological Applications 19:1628–1644

Linell, J. D. C., Swenson, J. E., Andersen, R. and Barnes, B. 2000. How vulnerable are denning bears to disturbance? – Wildlife Society Bulletin 28: 400-413

Luft, TA. 2002. First General Administrative Regulation Pertaining to the Federal Emission Control Act (Technical Instructions on Air Quality Control – TA Luft) of 24 July 2002. Federal Ministry for Environment, Nature Conservation and Nuclear Safety.

Meltofte, H., Elander, M. and Hjort, C. 1981. Ornithological observations in Northeast Greenland between 74°30’ and 76°00’N. lat., 1976. – Meddr Grønland, Biosci. 3: 53 pp.

221

Møller, P., Glahder, C. & Boertmann, D. 2004. Foreløbig miljøvurdering af land- og havområder i Nordgrønland. Status i forbindelse med afgrænsningen af kontinentsoklen. 2 udgave. Danmarks Miljøundersøgelser. 66 s.- Faglig rapport fra DMU nr. 431. 66 pp.

Mortensen, N.G. 2003. Klimamålinger på Kap Moltke 1973-2002. In.: Peary Land (eds) Martens, G., Jensen, J.F., Meldgaard, M. & Meltofte, H. Forlaget Atuagkat.

MTHojgaard, June 2014. Navigational Safety Investigation in connection with Citronen Zinc and Lead Project.

Muus, B. 1990. Fisk pp. 23-153 in Muus, B, Salomonsen, F & Vibe V. (ed.) Grønlands Fauna. – Gyldendal, Copenhagen.

National Environment Research Institute. 2010. Proposal for Greenland Water Quality Guidelines in connection with mining activities.

Nielsen, O.-K., Lyck, E., Mikkelsen, M.H., Hoffmann, L., Gyldenkærne, S., Winther, M., Nielsen, M., Fauser, P., Thomsen, M., Plejdrup, M.S., Albrektsen, R., Hjelgaard, K., Johannsen, V.K., Vesterdal, L., Rasmussen, E., Arfaoui, K. & Baunbæk, L. 2010. Denmark’s National Inventory. Report 2010. Emission Inventories 1990-2008 - Submitted under the United Nations Framework Convention on Climate Change and the Kyoto Protocol. – NERI Technical Report No 784.

OSPAR, 2009. Overview of the impacts of anthropogenic underwater sound in the marine environment. 134 pp.

Overrein, Ø. 2002. Virkninger av motorferdsel på fauna og vegetasjon. – Rapportserie nr. 119. Norsk Polarinstitutt, Tromsø.

Piatt, J. F., Carter, H. R. and Nettleship D. N. 1990. Effects of Oil Pollution on Marine Bird Populations. Proceedings from: the Oil Symposium Herndon, Virginia October 16-18, 1990.

Price, W.A., 2009, Prediction Manual for Drainage Chemistry from Sulphidic Geologic Materials, MEND Report 1.20.1. CANMET – Mining and Mineral Sciences Laboratories, Smithers, British Columbia, Canada, December, 2009.

222

Reeves, R. R., Smeenk, C., Kinze, C. C., Brownell, R. L. & Lien, J. 1999. White-beaked dolphin - Lagenorhynchus albirostris (Gray, 1846). Pp 1-30 in Ridgway, S.H. & Harrison, S.R. eds), Handbook of Marine Mammals, Vol. 6. – Academic Press, London.

Richardson, W. J., Greene, C. R. Jr., Malme, C. I. and Thomson, D. H. 1995. Marine mammals and noise. – Academic Press, San Diego. 576 pp.

Ross, W. G. 1993. Commercial whaling in the north Atlantic sector. Pp. 511-561 in Burns, J.J., Montague, J.J. and Cowles C.J. (eds.) The Bowhead Whale. – Special publication No. 2 of the Society for Marine Mammology.

Scheifele, P. M., Andrew, S, Cooper, R.A., Darre, M., Musiek, F.E. & Max, L. 2005. Indication of a Lombard vocal response in the St. Lawrence River beluga. – J. Acoust. Soc. Am. 117 (3): 1486–1492.

Shaver, G. R., Giblin, A. E., Nadelhoffer, K. J. and Rastetter, E. B. 1996. Plant functional types and ecosystem change in arctic tundra. In: Smith, T., Shugart, H. H. and Woodward, F. I. (Eds.), Plant Functional Types, Cambridge University Press, Cambridge. Pp. 152-172

Tetra Tech, September 2010. Stream Discharge and Water Supply Estimates Citronen Fjord Development Project. Prepared for Ironbark Zinc Ltd.

Tetra Tech, April 2012. Citronen Project Mine Waste Geochemical Characterisation-Final Report. Prepared for Ironbark Zinc Ltd.

Tetra Tech, July 2012. Citronen Project Screening Level Ecological Risk Assessment (SLERA) – Final Report. Prepared for Ironbark Zinc Ltd.

Thomsen, F., Lüdemann, K., Kafemann, R. and Piper, W. 2006. Effects of Offshore Wind Farm Noise on Marine Mammals and Fish. Biola, Hambury, Germany on behalf of COWRIE Ltd.

Wiig, Ø., Belikov, S. E., Bultonov, A.N. and Garner, G.W. 1996. Selection of marine mammal Valued Ecosystem Components and description of impact hypotheses in the Northern Sea Route Area. – INSOP Working paper, NO. 40 – 1996, II.4.3.

223

Websites for Material Safety Data Sheets

Ferrosilicon – www.washingtonmills.com, www.orica.com

Dextrin – www.sciencelab.com

Calcium Lignisulphonat – www.orica.com

D200 – www.hunstman.com

Sodium Ethly Xanthate – www.flottec.com

Dialkyl dithiophosphinate monothiophosphinate 9323 – www.cytec.com

Hydrous copper sulfate - www.sciencelab.com

IF6-3N – www.interfroth.com

Magnofloc M10 – www.edsi.ca/safety

Burnt lime – www.chemicallime.com

224