Final EIA Hudson White Mountain Project Updated March 2015

Hudson Resources Inc. Environmental Impact Assessment (EIA): White Mountain Anorthosite Mining Project

Property License 2002-06 February 2015

Inuplan Office Nuuk Issortarfimmut 13 Postboks 1024 DK-3900 Tel. + 299 343700 www.inuplan.gl Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Table of Contents

1" Non&Technical"Summary"...... "1" 1.1" English"...... "1" 1.2" Greenlandic"...... "10" 1.3" Danish"...... "21" 2" Introduction"...... "31" 3" Regulatory"Framework"...... "32" 4" Description"of"the"White"Mountain"Project"...... "33" 4.1" Location"...... "34" 4.2" The"Material/Ore"...... "35" 4.3" Mining"Operations"...... "36" 4.3.1% Mining%Method%...... %36% 4.3.2% Processing%Facility%...... %36% 4.4" Infrastructure"...... "37" 4.4.1% Port%Facilities%and%Transport%...... %37% 4.4.2% Road%...... %39% 4.5" Infrastructure"and"Camp"Complex"...... "39" 4.5.1% Power%Source%...... %42% 4.5.2% Explosives%Storage%Facility%...... %42% 4.5.3% Water%Supply%and%Treatment%...... %43% 4.5.4% Sewage%Treatment%and%Discharge%...... %44% 4.5.5% Solid%Waste%Disposal%...... %45% 4.5.6% Tailings%...... %45% 4.6" Personnel"...... "46" 4.7" European"Facility"...... "47" 4.8" Alternatives"Considered"...... "47" 4.8.1% Zero Alternative%...... %47% 4.8.2% Energy Supply Alternatives%...... %48% 4.8.3% Location of Port and Process Plant%...... %48% 4.8.4% Deposition of Tailings Alternatives%...... %49% 4.9" Closure"Plan"...... "49" 5" Environmental"Baseline"(Description"of"the"area)"...... "50" 5.1" Physical"Environment"...... "50" 5.1.1% Terrestrial Topography%...... %50% 5.1.2% River Continuum%...... %51% 5.1.3% Lake Bottom Geology%...... %54% 5.1.4% Bathymetry%...... %55% 5.1.5% Geology%...... %55% 5.1.6% Climate%...... %56%

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

5.1.7% Noise%...... %59% 5.1.8% Dust%...... %59% 5.2" Terrestrial"Environment"...... "59" 5.2.1% Vegetation%...... %59% 5.2.2% Terrestrial Wildlife%...... %62% 5.2.3% Birds%...... %62% 5.2.4% Mammals%...... %67% 5.3" Limnetic"(Open"Water)"Environment"...... "72" 5.3.1% Water Quality%...... %72% 5.3.2% Vegetation%...... %76% 5.3.3% Fauna%...... %77% 5.3.4% Fish%...... %78% 5.4" Marine"Environment"...... "81" 5.4.1% Water Quality%...... %81% 5.4.2% Marine Sediment%...... %82% 5.4.3% Marine Flora%...... %82% 5.4.4% Marine Fauna%...... %83% 5.5" Areas"of"Interests/Conflicts"...... "86" 5.5.1% Cultural Sites%...... %86% 5.5.2% Local Hunting and Fishing%...... %86% 5.6" Sensitive"Areas"and"Protected"Areas"...... "88" 5.7" Traffic"...... "89" 6" Methods"Used"for"Environmental"Impact"Assessment"...... "90" 6.1" Purpose"and"Approach"...... "90" 7" Environmental"Impact"and"Mitigations"...... "93" 7.1" Mine"Site"...... "94" 7.2" Infrastructure"(Roads,"Harbour,"Heliport)"...... "95" 7.3" Tailings"Disposal"...... "97" 7.3.1% Tailings%Chemical%Composition%...... %97% 7.3.2% Tailings%Lake%Description%...... %97% 7.3.3% Tailings%Impact%on%Fresh%Water%...... %99% 7.4" Noise"...... "107" 7.5" Dust"...... "110" 7.6" Emissions"...... "111" 7.7" Impact"From"Waste"and"Wastewater"...... "114" 7.8" Potential"for"an"Oil"and"Chemical"Spill"into"the"Water"Environment"...... "115" 7.9" Impact"on"Ecological"Environment"...... "115" 7.9.1% Vegetation%...... %116% 7.9.2% Birds%...... %116% 7.9.3% Mammals%...... %117% 7.9.4% Loss%of%Terrestrial%Habitat%...... %118%

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Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

7.9.5% Changes%of%Freshwater%Habitats%...... %119% 7.10" Invertebrates"...... "120" 7.10.1% Effect%of%Suspended%Solids%...... %120% 7.10.2% Effect%of%Contamination%...... %121% 7.11" Freshwater"Fish"...... "121" 7.11.1% Suspended%Solids%...... %121% 7.11.2% Contamination%of%Fish%...... %122% 7.12" Marine"Ecology"...... "123" 7.12.1% Marine%Invertebrates%...... %124% 7.12.2% Marine%Fish%...... %125% 7.12.3% Marine%Mammals%...... %126% 7.13" Introduction"of"invasive"non&indigenous"species"with"ballast"water"...... "126" 7.14" Cultural"Heritage"and"Human"Activities"...... "127" 7.14.1% Cultural%Heritage%...... %127% 7.14.2% Human%Activities%...... %127% 7.15" Cumulative"effects"...... "128" 8" Environmental"Management"Plan"...... "129" 9" Environmental"Monitoring"Program"...... "130" 9.1" Marine"Monitoring"Program"...... "130" 9.2" Fresh"Water"Monitoring"Program"...... "131" 9.3" Terrestrial"Monitoring"Program"...... "133" 10" Closure"Activities"...... "135" 10.1" Close"Down"and"Decommissioning"of"the"Mine"...... "135" 10.2" Pit"Area"...... "135" 10.3" Tailings"Pond"...... "135" 10.4" Road&Transect"...... "135" 10.5" Camp"Site"...... "136" 11" Public"Consultation"...... "137" 12" Conclusions"...... "138" 13" References,"authors"...... "139" Appendix"1."...... "Regulations"and"Guidelines" 1" Appendix"2."...... "Dust"Calculations" 4"

List of Tables TABLE"1.1"&"SUMMARY"OF"ENVIRONMENTS"IMPACTS% 8% TABLE%4.1%T%ASSAY%OF%ALL%MAJOR%ELEMENTS%IN%THE%ANORTHOSITE% 35% TABLE%4.2%T%PERFORMANCE%SPECIFICATIONS%FOR%THE%SEWAGE%TREATMENT%SYSTEM.% 45% TABLE%5.1%T%DIMENSIONS%OF%THE%LAKE%SYSTEM%INCLUDING%THE%TAILINGS%LAKE%A.% 52% TABLE%5.2%T%ANNUAL%FLOW%RATE%EXITING%LAKE%C%AND%LAKE%D% 54%

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

TABLE%5.3%T%RESULT%OF%IN%SITU%MEASUREMENTS%OF%PHYSICAL%PARAMETERS%IN%THE%PROJECT%AREA.% 73% TABLE%5.4%T%RESULT%OF%WATER%SAMPLE%ANALYSES%FROM%THE%PROJECT%AREA%COLLECTED%IN%2012.% 74% TABLE%5.5%T%LIST%OF%THE%REGISTERED%FRESHWATER%VEGETATION%IN%THE%PROJECT%AREA.% 77% TABLE%5.6%T%OBSERVATION%OF%INVERTEBRATE%GROUPS%(ORDERS)%IN%THE%NAAJAT%AREA.% 77% TABLE%5.7%T%DENSITIES%OF%ARCTIC%CHAR%FOUND%IN%WESTERN%GREENLAND.% 81% TABLE%5.8%T%LIST%OF%THE%ARCHAEOLOGICAL%FEATURES%REGISTERED%DURING%THE%SURVEY%2013.% 87% TABLE%6.1%T%A%LIST%OVER%THE%IDENTIFIED%AND%SELECTED%VEC'S% 91% TABLE%6.2%T%CRITERIA%FOR%THE%ASSESSMENT%OF%IMPACTS.% 92% TABLE%6.3%T%RANKING%OF%SIGNIFICANCE%OF%ENVIRONMENTAL%IMPACTS%(DONG,%2006).% 92% TABLE%7.1%T%SIGNIFICANT%RESULTS%FROM%THE%COLUMN%MOBILIZATION%TEST% 103% TABLE%7.2%–%LC50%COPPER%CONCENTRATION%VALUES% 104% TABLE%7.3%T%ASSAY%TABLE%FOR%FRESHWATER%ALGAE%TOXICITY%TEST% 105% TABLE%7.4%T%CONCENTRATION%VS.%PERCENT%INHIBITION% 106% TABLE%7.5%T%NOISE%LEVELS%FOR%MAJOR%EQUIPMENT%AT%WHITE%MOUNTAIN% 107% TABLE%7.6.%ANNUAL%DIESEL%FUEL%CONSUMPTION%FOR%MAJOR%EQUIPMENT.% 112%

TABLE%7.7%T%ANNUAL%EMISSIONS%OF%CO2,%NOX%AND%SOX%FROM%COMBUSTION%OF%DIESEL%FUEL% 113% TABLE%9.1%T%THE%SAMPLING%POSITIONS%OR%THE%MARINE%STATIONS.% 130% TABLE%9.2%T%THE%SAMPLING%POSITIONS%FOR%WATER%STATIONS.% 132% TABLE%9.3%T%THE%SAMPLING%POSITIONS%FOR%LICHEN%STATIONS.% 133% % APPENDIX%TABLE%1%T%SUMMARY%OF%NATIONAL%LEGISLATION%AND%GUIDELINES.% 1% APPENDIX%TABLE%2%T%INTERNATIONAL%AGREEMENTS%AND%GUIDELINES%ON%BAT%AND%BEP.% 2% APPENDIX%TABLE%3%T%SUMMARY%OF%RESULTS%FROM%THE%UNPAVED%INDUSTRIAL%ROAD%DUST% CALCULATOR% 7% % List of Figures: FIGURE%1.1%T%PROJECT%LOCATION% 2% FIGURE%1.2%T%PROJECT%LOCATION%WEST%COAST%OF%GREENLAND% 3% FIGURE%1.3%T%AERIAL%VIEW%OF%THE%PROJECT%AREA%LOOKING%TOWARDS%EAST% 4% FIGURE%4.1%T%MAP%VIEW%OF%THE%WHITE%MOUNTAIN%PROJECT%(NAAJAT%PROPERTY)%IN%WESTERN% GREENLAND% 34% FIGURE%4.2%T%PROCESS%DESIGN%FOR%THE%WHITE%MOUNTAIN%ANORTHOSITE% 37% FIGURE%4.3:%T%PLAN%VIEW%OF%THE%PROJECT%(MINE%SITE,%TAILINGS%AREA,%ROAD,%AND% CAMP/PROCESSING%AREA)% 38% FIGURE%4.4.%%CROSS%SECTION%OF%THE%STORAGE,%LOAD%OUT%FACILITY%AND%PORT%ARRANGEMENT.% 40% FIGURE%4.5%T%THE%OVERALL%SITE%LAYOUT%OF%THE%CAMP,%PLANT%AND%PORT%FACILITY% 41% FIGURE%4.6%T%HUDSON%EXPLOSIVES%STORAGE%AT%WHITE%MOUNTAIN% 43% FIGURE%4.7%T%LOCATION%OF%DRINKING%WATER%LAKE%(LAKE%E)% 44% FIGURE%4.8%T%LOCATION%OF%TAILINGS%DISPOSAL%LAKE% 46% FIGURE%4.9%T%SCHEMATIC%OVERVIEW%OF%THE%EUROPEAN%ACTIVITIES.% 47% FIGURE%5.1%T%MAP%OF%THE%TERRESTRIAL%WITHIN%THE%PROJECT%AREA.% 50% FIGURE%5.2%T%OVERVIEW%OF%THE%TERRESTRIAL%TOPOGRAPHY%WITHIN%THE%PROJECT%AREA.% 51% FIGURE%5.3%T%THE%WATER%FLOW%OF%THE%RIVER%CONTINUUM%IN%DRAINAGE%THE%MINE%AREA.% 52% FIGURE%5.4%T%FP111%GLOBAL%FLOW%PROBE%METER% 53% FIGURE%5.5.%FLOW%METER%STATION%AT%OUTFLOW%OF%LAKE%C.% 54% FIGURE%5.6%T%FLOW%METER%STATIONS%AT%OUTFLOW%OF%LAKE%D.% 54%

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

FIGURE%5.7%T%PROJECT%GEOLOGY%–%WHITE%MOUNTAIN%ANORTHOSITE.% 55% FIGURE%5.8%T%AVERAGE%AIR%TEMPERATURE%(°C)%KANGERLUSSUAQ,%SISIMIUT%AND%PRECIPITATION% (MM)%%%KANGERLUSSUAQ%PRECIPITATION%(MM),%SISIMIUT%,%SOURCE%DANISH% METEOROLOGICAL%INSTITUTE.% 57% FIGURE%5.9%–%COMPARISON%OF%2014%PRECIPITATION%TO%LONG%RANGE%AVERAGE%MONTHLY% AMOUNTS% 58% FIGURE%5.10%T%WIND%DIRECTIONS%OVER%THE%ENTIRE%YEAR% 58% FIGURE%5.11%T%WIND%SPEED%DATA%FROM%KANGERLUSSUAQ%FOR%THE%PERIOD%FROM%1974%THROUGH% 2012.% 59% FIGURE%5.12%T%THE%VEGETATION%HABITATS%IN%AND%AROUND%THE%PROJECT%AREA.% 60% FIGURE%5.13%T%LOCATION%OF%THE%SMALL%ROUNDTLEAVED%ORCHID%(AMERORCHIS%ROTUNDIFOLIA).% 61% FIGURE%5.14%T%AMERORCHIS%ROTUNDIFOLIA%AT%A%MOIST%HEATH%NEAR%WM04.% 62% FIGURE%5.15%T%MAP%OF%THE%STAGING%AREA%FOR%WHITE%FRONTED%GEESE%IN%THE%KANGERLUSSUAQ% AREA% 65% FIGURE%5.16%T%CARIBOU%OBSERVED%WITHIN%THE%WHITE%MOUNTAIN%AREA.% 67% FIGURE%5.17%T%CARIBOU%CALVING%AREAS%FAR%FROM%MINE%SITE% 68% FIGURE%5.18%T%THE%MARCH%2010%DISTRIBUTION%OF%THE%KANGERLUSSUAQTSISIMIUT%CARIBOU%IN%THE% NORTH%REGION.% 68% FIGURE%5.19%T%ACCESSIBLE%AREA%FOR%MUSKOX%IN%THE%NORTH%REGION.%SOURCE:% 70% FIGURE%5.20%T%REMNANTS%OF%MUSKOX%WITHIN%THE%HUDSON%PROJECT%AREA.% 70% FIGURE%5.21%T%LOCATIONS%OF%EAGLE,%FOX%AND%HARE%OBSERVATIONS%IN%THE%NORTH%REGION,% MARCH%2005% 71% FIGURE%5.22%T%MAP%SHOWING%THE%STATION%OF%WATER%SAMPLES%IN%BOTH%2012%AND%2013.% 73% FIGURE%5.23%T%STREAM%SEDIMENT%DATA%FROM%GEUS%SHOWING%ELEVATED%COPPER%IN%THE%AREA.% 75% FIGURE%5.24%–%COMMON%MARE'S%TAIL%AT%STATION%20.% 76% %FIGURE%5.25%T%FISHING%AREA%FOR%ARCTIC%CHAR%IN%ITILLEQ%FJORD.% 79% FIGURE%5.26%T%THE%STATIONS%INVESTIGATED%FOR%ARCTIC%CHAR%IN%2012%AND%2013.% 80% FIGURE%5.27%T%POPULATION%ESTIMATES%OF%ARCTIC%CHAR%IN%THE%PROJECT%AREA.% 80% FIGURE%5.28%T%OVERVIEW%OF%THE%AREA%WITH%THE%TWO%FJORDS%OF%INTERESTS.% 82% FIGURE%5.29%T%FISHING%AREA%FOR%CAPELIN%IN%ITILLEQ%FJORD,%(NIELSEN%ET%AL.,%2000).% 84% FIGURE%5.30%T%FISHING%AREA%FOR%LUMP%SUCKER%IN%ITILLEQ%FJORD,%(NIELSEN%ET%AL.,%2000).% 85% FIGURE%5.31%T%LOCATION%OF%THE%ARCHAEOLOGICAL%SITES%ALONG%THE%ROAD%AND%THE%PIT.% 87% FIGURE%5.32%T%OVERVIEW%OF%PROTECTED%AREAS%IN%THE%KANGERLUSSUAQ%REGION.%FROM% NUNAGIS.GL% 88% FIGURE%7.1%T%SPATIAL%BOUNDARIES%WHERE%POTENTIAL%EFFECTS%FROM%THE%MINE%PROJECT%MAY% OCCUR.% 93% FIGURE%7.2%T%PLAN%VIEW%OVER%THE%PIT%IN%YEARS%5,%10,%15%AND%20.% 94% FIGURE%7.3%T%CROSS%SECTION%OF%THE%PIT% 95% FIGURE%7.4%T%PROJECT%VIEW%FROM%THE%SONDRESTROM%FJORD% 96% FIGURE%7.5%T%ASSAYS%OF%MAJOR%AND%MINOR%ELEMENTS%IN%THE%TAILINGS%AND%THE%PRODUCT.% 97% FIGURE%7.6%T%EXTENT%OF%TAILINGS%DISPOSAL%IN%LAKE%A%AFTER%5,%10,%15%AND%20%YEARS.% 98% FIGURE%7.7%T%PHOTOS%FROM%THE%TURBIDITY%TEST.% 100% FIGURE%7.8%T%TAILINGS%MOBILIZATION%TEST%AT%SRC.% 102% FIGURE%7.9%T%COPPER%VALUES%IN%LAKE%D%AS%A%FUNCTION%OF%PRECIPITATION% 104% FIGURE%9.1%T%MAP%OF%MARINE%SAMPLING%POSITIONS%AT%THE%WHITE%MOUNTAIN%PROJECT%AREA% 131% FIGURE%9.2%T%OVERVIEW%OF%FRESH%WATER%SAMPLING%STATIONS% 132%

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

FIGURE%9.3%T%SAMPLING%STATIONS%FOR%LICHENS%(F.%NIVIALIS)% 134%

APPENDIX%FIGURE%1%T%EXPECTED%DUST%DISPERSION%AT%THE%CAMP/PORT%SITE%...... %8% APPENDIX%FIGURE%2%T%EXPECTED%DUST%SPREADING%AT%THE%PIT%SITE%...... %10%

Background Technical Reports: (Available at: www.hudsonresources.ca/EIA/Hudson_EIA_Background_Technical_Reports.pdf)

HUD$TECHNICAL$REPORT$1.$ COMPLETE$LIST$OF$PLANTS$OBSERVED$IN$THE$AREA.$$ HUD$TECHNICAL$REPORT$2.$ NOX$EMISSIONS$CALCULATIONS$ HUD$TECHNICAL$REPORT$3.$ ACID$GENERATING$POTENTIA$ HUD$TECHNICAL$REPORT$4.$ TAILINGS$MOBILIZATION$TEST$PROCEDURES$(COLUMN$TEST)$

HUD$TECHNICAL$REPORT$5.$ LIST$OF$MACROPHYTES$AND$MACRO@INVERTEBRATES$ HUD$TECHNICAL$REPORT$6.$ WATER$FLOW$CALCULATIONS$ $ HUD$TECHNICAL$REPORT$7.$ ROAD$CONSTRUCTION$ANALYSIS$ HUD$TECHNICAL$REPORT$8.$ TAILINGS$STUDY$ HUD$TECHNICAL$REPORT$9.$ FRESHWATER$ALGAE$TOXICITY$TEST$ HUD$TECHNICAL$REPORT$10.$ REPORT$ON$SILICA$CONCENTRATION$IN$ANORTHOSITE$DUST$ HUD$TECHNICAL$REPORT$11.$ REPORT$ ON$ ARCHAEOLOGICAL$ SURVEY$ PERFORMED$ FOR$ HUDSON$RESOURCES$AT$QAQORTORSUAQ$ HUD$TECHNICAL$REPORT$12.$ NAAJAT$(WHITE$MOUNTAIN)$BASELINE$SURVEY$2012$ HUD$TECHNICAL$REPORT$13.$ NAAJAT$(WHITE$MOUNTAIN)$BASELINE$SURVEY$JULY$2013$ HUD$TECHNICAL$REPORT$14.$ NAAJAT$ (WHITE$ MOUNTAIN)$ BASELINE$ SURVEY$ AUGUST$ –$ SEPTEMBER$2013$ HUD$TECHNICAL$REPORT$15.$ WHITE$ MOUNTAIN$ TERRESTRIAL$ ECOLOGICAL$ BASELINE$ SURVEY$2012$@$13$ HUD$TECHNICAL$REPORT$16.$ REPORT$ ON$ FRESHWATER$ HABITAT$ DESCRIPTION$ AND$ ELECTROFISHING$

vii

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

List of Acronyms and Abbreviations

% Percent < Smaller Than > Larger Than °C Degrees Celsius ADTs Average Daily Traffic ANFO Ammonium Nitrate and Fuel Oil BAT Best Available Technology BEP Best Environmental Practices BMP Bureau of Minerals and Petroleum (now MLSA) Convention for the Control and Management of BWM Ships' Ballast Water and Sediments CO2 Carbon Dioxide dBA Decibel A-weighted DO Diluted Oxygen EIA Environmental Impact Assessment EL Exploration License EMP Environmental Management Plan GHG Green House Gases GINR Greenland Institute of Natural Resources GNMA Greenland National Museum and Archives GWQG Greenland Water Quality Guideline Ha Hectare (10.000 m2) hr Hour IUCN International Union for Conservation of Nature Km Kilometer Knot 1,852 km/hour kW Kilowatt L Liter m Meter M2 Square meter M3 Cubic meter Ma Millions of Years Ago mg Milligram MLSA Mineral Licensing and Safety Agency (former BMP) mm Millimeter N Nitrogen NOx Oxides of Nitrogen NWT North West Territories, Canada PE Population Equivalent µm Microns

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Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

ROM Run-of-Mine Sec Second SIA Social Impact Assessment SOx Oxides of Sulphur SRC Saskatchewan Research Council SS Suspended Solids T Temperature TNT Trinitrotoluene (Dynamite) TSP Total Suspended Particulates UNCLOS United Nations Convention on the Law of the Sea VEC Valued Ecosystem Component wk Week yr Year

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

1 Non-Technical Summary 1.1 English Introduction

Hudson Resources Inc. (Hudson) is a Canadian mineral exploration company developing the White Mountain (Naajat) Anorthosite Project (the Project). The Project is situated on the central west coast of Greenland at approximately latitude 66°33’N (approximately the Arctic Circle) and longitude 52°10’W. It is approximately 80 km southwest of the international airport at Kangerlussuaq and approximately 80 km to the southeast of Sisimiut, the nearest town. Hudson has a 100% interest in the 95 sq. km Naajat exploration license area (EL 2002/06). Hudson is proposing to establish a mining and processing operation at the Naajat property (Figure 1.1). The Project includes: ! Open pit mine; ! Processing facility; ! Access roads ! Tailings disposal area ! Port ! Infrastructure and camp complex Hudson plans to mine approximately 285,000 tonnes of ore annually and transport 200,000 tonnes of processed material to Europe, North America and Asia. The material will be a key ingredient in the manufacturing of E-Glass fiberglass. Approximately 85,000 tonnes of waste material will be safely disposed of on site annually. Along with this Environmental Impact Assessment (EIA), Hudson has submitted an Social Impact Assessment (SIA) and Feasibility Study as its application for an exploitation license to the Government of Greenland’s Mineral Licenses and Safety Authority (MLSA). If successful, license issuance will be followed by a construction period beginning in early 2015. The operation is expected to commence in the second half of 2015 or early 2016, and continue for 20+ years. The life of the operation is only limited by the availability and sustainability of international markets to sell the anorthosite material. There are currently sufficient resources defined for at least 120 years of operation. The EIA has been carried out in accordance with the official guideline of the Mineral Licensing and Safety Agency, “BMP guidelines – for preparing an Environmental Impact Assessment (EIA) Report for Mineral Exploitation in Greenland” 2nd Edition, January

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

2011, (BMP, 2011). This section is the Non-technical Summary (NTS) of the EIA which has been prepared as part of the EIA process. The Project The White Mountain license area extends to approximately 95 sq. km. The physical components of the Project include the following: mine, port, access road, processing facility, worker camp, and the tailings disposal area.

White Mountain (Naajat EL) Project Location

52°30'0"W 52°0'0"W 51°30'0"W 51°0'0"W 50°30'0"W

66°56'0"N 66°56'0"N ¯ Kangerlussuaq

66°45'0"N 66°45'0"N

Mine Location Access Road

Sarfartoq EL Process Plant and Port Location (Hudson's Rare Earth Project)

66°34'0"N 66°34'0"N

Naajat EL

0 3.75 7.5 15 22.5 30

66°23'0"N Kilometers 66°23'0"N

52°30'0"W 52°0'0"W 51°30'0"W 51°0'0"W 50°30'0"W Figure 1.1 - Project Location The project will extract the ore from an open pit mine situated approximately 5 km north of the Sondre Stromfjord. Mining would be by drilling and blasting without the need for stripping of surface material or waste rock. Approximately 30 full time positions are expected to be required at the mine site during operation. After taking into account rotating two shifts, approximately 57 people are required, including 10 contractor positions. The work season for the mining operations will be 9 months, and the processing plant will run 10 months per year. Hudson’s objective is to have a

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Greenlandic workforce making up a minimum of 80% of all positions (or 46 employees). The mine life is expected to exceed 20 years.

Figure 1.2 - Project Location West Coast of Greenland

The rock will undergo initial crushing at the pit site before transported by haul truck along a new 10 km haul road to a process plant to be built next to the Sondre Stromfjord. A new port facility will be established adjacent to the plant. The port will be constructed of blasted rock. The rock used for port and road construction is a granite which is prevalent in the area, is benign and does not contain any sulphides and only minor metals. It is expected that the port will load ships eight months per year, and will not initially operate December through March due to potential ice conditions. During the processing stage approximately 30 percent of the ore (85,000 tonnes annually) will be rejected due to the magnetic separation process which is required to produce a commercial product. The rejected material does not contain any sulphides or heavy metals and is therefore not acid generating and can be safely disposed of underwater. This material will be hauled by truck for disposal in a lake that is situated between the mine and the port. The lake is located at the head of a lake system that eventually discharges into the Itilleq Fjord.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Søndre Strømfjord

Mining area

Figure 1.3 - Aerial View of the Project Area looking towards East The project facilities will consist of a housing complex for up to 40 people (enough to cover on-site staff plus overflow), offices, workshops and a processing plant, where the ore will undergo additional crushing and magnetic separation. The material will go from the process plant by conveyor to a covered storage facility adjacent to the dock. Power for the process plant, truck shop and accommodation buildings will be provided by two 400 kW diesel generators. A separate 25 kW generator is planned to meet power requirements at the quarry. On completion of mining operations, a closure plan and reclamation plan will be implemented (Section10). The Existing Environment The Project area includes the mine and all infrastructure associated with the mining activities. Major categories of study included: General Environment, Emissions, Water and Wastewater, Freshwater, Fuel Spillage, Terrestrial Ecology, Freshwater Ecology, Marine Ecology, Cultural Heritage, and Recreational Activities. Within each of these

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

major categories, typical study subjects included: noise, dust, flora, fauna, habitat, hunting and fishing. The conclusion of the report is that there will be a negligible to minor residual effect as a result of the Project. An example of some of the issues are present below. Terrestrial Environment Sites of International and National Conservation Importance The Government of Greenland in collaboration with international organizations has identified areas of biological importance in Greenland’s marine and coastal environment. The designated protected area closest to the proposed operations is on the opposite side of Sondre Stromfjord, approximately 70 km east of the new port facility. The Government has identified several “Areas Important to Wildlife” where mineral and petroleum exploration and extraction activities are regulated in accordance with the Mineral Extraction Act. These areas include bird colonies and adjacent buffer zones. Eleven sites throughout Greenland have been identified by the Government of Greenland for inclusion in the Ramsar list of Wetlands of International Importance Ramsar sites. None of these sites occur in the vicinity of Sondre Stromfjord and the Project will not effect them in any way. Birds Two protection zones for seabird colonies (eider) have been identified, one each in Sondre Stromfjord and Itilleq Fjord. Additional protection zones have also been designated around critical nesting areas for White fronted geese. The closest of these is approximately 25 km from the mine site. The project will not conduct any activities in the Itilleq Fjord. The White fronted Goose breeds only in the area between the Maniitsoq Icecap and Upernavik and is considered endangered according to the Greenlandic Red list. A single pair of geese has been noted to be nesting in a lake a few kilometers from the pit, and the valley south-west of the project area hosts a known resting locality for migratory white fronted geese. Both of these locations are situated a reasonable distance from the proposed activities. The proposed project site at White Mountain holds relatively few other bird species, all of which are common and widespread in West Greenland. The Project is only expected to have a minor residual effect on birds. Flora and Fauna Terrestrial wildlife in the area is limited to caribou, arctic hare, arctic fox and muskox (the latter is rare in the area). As a consequence of the proposed activities some of these

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

mammals are expected to relocate, but according to international studies, the relocation will be limited (less that 5 km). The Project is only expected to have a minor residual effect on mammals. Freshwater Environment Analysis of water quality samples from the project area indicated naturally occurring concentrations of copper (at each of 5 sampling locations) and nickel (one sampling location) which exceed freshwater quality guideline values. Concentration levels of other metals were below the relevant guideline values. Two species of freshwater fish are abundant in Greenland, the Arctic Char and the Three-spined Stickleback; both species are widely present in the rivers and lakes of the project area. The Project is only expected to have a negligible/minor residual effect on fish and will not effect the population in any way. Marine Environment The marine environment around the project area contains two fjords that differ significantly. The Sondre Stromfjord receives glacial deposits, whilst the Itilleq Fjord receives freshwater outflow from the project area. The seabed of Sondre Stromfjord is greatly influenced by input of glacial material and the tidal current. This results in variability in the seabed with some areas with bedrock area and others filled with silted sediment. Both fjords are classified as having a sheltered coast with no drifting ice. The most abundant coastal fish species in both fjords are Greenland Cod, Sculpin and Atlantic Cod. Harbour Seal is a protected species in Greenland and is designated as critically endangered. The Harbour Seal is dependent on access to haul-out locations for reproduction and moulting; this was last recorded in the former haul-out location beside Kangerlussuaq Airport in 1995-97. Several other species of seals and whales are believed to appear in the outer Sondre Stromfjord. The Project is only expected to have a negligible/minor residual effect on flora and fauna in the Sondre Stromfjord. The Project will not effect the Itilleq Fjord. Cultural Heritage Twelve sites of archaeological importance have been identified in the area between the mine site and the port. Eight of these sites are protected under Greenland’s conservation laws. It should be noted that Arnangarnup Qoorua (the Paradise Valley), which is located approximately 15 km to the southeast of the project, was proposed as a potential candidate for a UNESCO World Heritage Area in 2003 due to its cultural significance. It

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

has not been selected for world heritage status to date, and given that the White Mountain project will not have any impact on the Paradise Valley, it is not seen as an issue for development. The Project is only expected to have a minor residual effect on archaeological remnants. Mitigation Measures The Project, as first envisioned, has been amended as a result findings from the EIA. These changes to avoid or reduce potential environmental effects include: - Previously unrecorded orchids in the area have been identified, marked and avoided; - The mine/port haul route has been aligned to avoid identified archaeological remnants; and - In accordance with the relevant international convention, ships’ ballast water will be changed in mid-ocean and not in the fjord. An Environmental Management Plan (EMP) will be developed for the project, and will address the following areas/activities:

• Open pit mining operation • Traffic • Ore processing and infrastructure • Water supply • Offices and associated support facilities • Maintenance activities associated with the above areas The EMP will describe how the risks identified in the EIA will be mitigated during the construction, operation and decommissioning phases of the mine project. The EMP will be developed from the EIA findings and analysis and will include the following:

• the measures to be taken by Hudson and it’s contractors during all phases of the project to eliminate or avoid adverse environmental impacts identified in the EIA, or to reduce them to acceptable levels, • the actions needed to implement these measures, and • the people responsible for implementing those actions. The EMP will include each of the following:

• Health and Safety Plan • Dust Management Plan • Noise Management Plan • Tailing Management Plan • Public Safety Plan

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

• Waste Management Plan • Spill Response Plan • Decommissioning Plan • Spill Response Plan • Decommissioning Plan Environmental Effects The EIA has taken account of the measures proposed to avoid or reduce significant environmental effects. The findings of the EIA are summarized in the following table. Table 1.1 - Summary of Environments Impacts

VALUED ECOSYSTEM POSSIBLE EFFECT POSSIBLE IMPACT SIGNIFICANCE COMPONENT (VEC) Archaeological remnants Cultural Heritage Physical Minor Birds Oil and Chemical Spill Loss of insulation Minor Birds Loss of Terrestrial Habitat Disturbing of nesting and resting areas for birds Minor Changing bathymetry Tailings Disposal Discarding tailings in Lake A Minor Char fishing Human Activites Reduced stock or increased content of chemicals Minor Contamination elements Freshwater Discarding tailings in Lake A Minor Fish Oil and Chemical Spill Contamination Minor Fish Invertebrates Physical due to affected lake area Minor Fish Invertebrates Tailings deposit Suspended solids Negligible Fish Invertebrates Tailings deposit Contamination Minor Fish Marine Fish Physical due to Contaminants Negligible Flora Emissions Fertilizing Minor Flora Dust Shadowing Minor Habitat changes Freshwater Discarding tailings in Lake A Minor Human Health Noise Hearing damages Minor Human Health Dust Respiratory diseases Minor Human Health Emissions Respiratory Diseases Minor Hunting and fishing Noise Relocation of wildlife due to disturbance Moderate Hunting and fishing Noise Disturbance from Helicopter Negligible Invertebrate Invertebrates Physical due to affected lake area Minor Invertebrate Invertebrates Tailings deposit Suspended solids Negligible Invertebrate Invertebrates Tailings deposit Suspended solids Minor Invertebrate Marine Invertebrates Physical due to Contaminants Negligible Lake habitats Changes(of(Freshwater(Habitats Physical Negligible Mammals Mining Activities Disturbance and re-location Minor Mammals Loss of terrestrial habitat Relocation due to size of area and Noise Minor Mammals Marine Mamals Physical due to noise Negligible Mammals Marine Mamals Physical due to Contaminants Negligible Marine Fauna Wastewater Contamination Minor Marine Flora Wastewater Degradation of Flora Minor Marine habitat Marine ecology Physical due to Seabed changes Negligible Marine habitat Marine ecology Physical due to Nutrient increase Negligible Marine habitat Marine ecology Physical due to noise Negligible Marine Mammals Oil and Chemical Spill Contamination Minor River habitats Changes(of(Freshwater(Habitats Physical Negligible seizing area Tailings Disposal Discarding tailings in Lake A Minor Suspended solids Freshwater Discarding tailings in Lake A Minor Topography Mine Site Physical Minor Topography Infrastructure Physical Minor visual Tailings Disposal Discarding tailings in Lake A Minor visual Tailings Disposal, Post Closure Discarding tailings in Lake A Negligible Water Quality Emissions Eutrophication Minor Water quality Wastewater Reduced quality Minor Wildlife Dust Coverage of food Minor Wildlife Noise Scaring away Minor

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Cumulative Effects As there are no other developments or projects within or close to the project area, there will not be any cumulative environmental effects. Conclusions Areas of international and national importance for flora and fauna will not be disturbed by the project. The project will result in some disturbance of caribou and muskox in the project area at a distance of up to five km from the infrastructure components. This disturbance will have a minor effect on the already sparse hunting activities in the area. The deposition of waste rock material in nearby lakes is anticipated to have a negligible effect on lake and river habitats, and a negligible/minor effect on freshwater invertebrates. The waste rock material does not contain any significant metal content and the leaching of metals is regarded as low. The Project is not expected to effect fishing in the area. Following completion of mining activities, closure of the mine will include the removal of all infrastructural components. The remains of the road will be left in place, although ripped to encourage re-vegetation. A comprehensive environmental management plan and monitoring program will ensure that emerging and unforeseen problems will be handled in a timely and appropriate manner.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

1.2 Greenlandic Aallaqqaasiut Hudson Resoursces Inc. (Hudson) aatsitassanik misissuinermut suliffeqarfiuvoq Canadameersoq Qaqortorsuup Kangiliani (Naajat) Anorthositisiorfissamik (Suliniut) ineriartortitsisoq. Suliniut inissisimavoq Kalaallit Nunaata Kitaata sineriaata qitiani allorniusap sanimukartup 66º33᾽N (qaasuitsup killeqarfiata missaani) aamma aallorniusap tukimukartup 52º10᾽W missaani. Inissisimavoq nunanut assigiinngitsunut mittarfiup Kangerlussuup 80 kilometerinik kujataata-kippasissuani aammalu Sisimiut 80 kilometerinik kujataata-kangisissuata missaani, illoqarfik qaninnerpaaq. Hudson-ip 100%- imik soqutigisaraa 95 kvadratkilometer-it misissuinissamut akuersissuteqarfiusoq. (EL 2002/06). Hudson-ip siunnersuutigaa piiaaffimmik aamma suliarinnilluni ingerlatsivimmik aallartitsissalluni Naajani pigisami (Takussutissiaq 1.1). Suliniummut ilaapput: ! Aatsitassanik piiaaffik ammasoq; ! Suliaqarfittut sanaartugaq; ! Aqqutit ! Aatsitassiornermi sinnikunut eqqaavissaq ! Umiarsualivik ! Ataqatigiinnermut attaveqaatit aamma Najugaqarfissaq Hudson-ip pilersaarutigaa ukiumut aatsitassiaq 285.000 tonsi piiarneqartassasoq aammalu atortussiaq suliarineqarsimasoq 200.000 tonsi nassiunneqartarluni Europamut, Amerika Avannarlermut aamma Asiamut. Atortussiaq E-Class glasfiberiliornermi akussaavoq pingaarneq. Igitassat 85.000 tonsit missaat ukiut tamaasa suliniuteqafimmi isumannaatsumik iginneqartassapput. Avatangiisinut Sunniutaasinnaasumik Nalilersuinermut (EIA) ilanngullugu Hudson nassiussisimavoq Inuiaqatigiinnut Sunniutissamik Nalilersuinermik (SIA) aamma Misissueqqaarnermik piiaanissamut akuersissummut qinnuteqaatiminut Kalaallit Nunaanni Naalakkersuisut Aatsitassanut Ikummatissanullu Aqutsisoqarfiannut (MSLA). Iluatsippat, akuersissutip atulersinneqarnera malinneqassaaq 2015-imi siusissumik sanaartornermik. Ingerlatsineq naatsorsuutiineqarpoq 205-ip ukiup affaata aappaani imaluunniit 2016-imi siusissumi aallartissasoq, ukiullu 20-t sinnelugit ingerlalluni. Ingerlatsinerup sivisussusaa taamaallaat killilerneqarpoq aatsitassiassaqarneranik aamma nunat assigiinngitsut niuerfiisa atortussamik anorthositimik tunisisinnaanerisa attartussusaannik. Maannakkut isumalluutit naammattut aalajangerneqarput minnerpaamik ukiunut 120-inut ingerlatsinermi naammattut.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Avatangiisinut Sunniutaasuínnaasumik Nalilersuineq (EIA) suliaineqarsimavoq Aatsitassanut Ikummatissanullu Autsisoqarfiup (MSLA) pisortatigoortumik najoqqutassaa “Kalaallit Nunaanni Aatsitassanik Piiaanissamut Avatangiisinut Sunniutaasinnaasunik Nalilersuinermut (EIA) Nalunaarusiamik suliarinninnermut – Aatsitassanut Ikummatissanullu Pisortaqarfiup (BMP) najoqqutassai” malillugit, aappassaanik saqqummiuteqqitaq, Januaari 2011, (BMP, 2011). Imikkoortoq una tassaavoq Avatangiisinut Sunniutaasinnaasunik Nalilersuineruop teknik-itiguunngitsumik eqikkarnertaa (NTS) Avatangiisinut Sunniutaasinnaasunik Nalilersuinermik (EIA) suliaqarnermi ilaasoq. Suliniut Qaqortorsuup Kangiliani akuersissuteqarfik isorartussuseqarpoq 95 kvadratkilometerit missaannik. Suliniutip ilai timitalik ilaqarput tulliuttunik: aatsitassarsiorfik, umiarsualivik, aqqusineq, suliffeqarfittut sanaartugaq, sulisunit najugaqarfissaq amma aatitassarsiornermi sinnikunut inissaq.

White Mountain (Naajat EL) Project Location

52°30'0"W 52°0'0"W 51°30'0"W 51°0'0"W 50°30'0"W

66°56'0"N 66°56'0"N ¯ Kangerlussuaq

66°45'0"N 66°45'0"N

Mine Location Access Road

Sarfartoq EL Process Plant and Port Location (Hudson's Rare Earth Project)

66°34'0"N 66°34'0"N

Naajat EL

0 3.75 7.5 15 22.5 30

66°23'0"N Kilometers 66°23'0"N Takussutissuaq52°30'0"W 1.1 - Suliniutip52°0'0"W inissisimaffia 51°30'0"W 51°0'0"W 50°30'0"W

Suliniutip aatsitassiaq piiarniarpaa paaffimmiit aamasumit Kangerlussuup avannarpasissuani 5 km missaani inissisimasumit. Aatsitassarsiorneq

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

ingerlanneqassaaq qillerinikkut aamma qaatiterinikkut nunap qaavanik nunap qaavanik imaluunniit ujaqqanik piiaanissaq pisaiaqassanngilaq. Piffissaq tamakkerlugu atorfiit 30-t missaat naatsorsuutigineqarpoq aatsitassarsiorfimmi ingerlatsinermi pisariqatinneqassasut. Paarlagaallutiksulisut marlukkaartut ilanngutereerlugit, inuit 57-it missaat pisariaqartinneqarput, ilagalugit suliassinneqartartunut suliffissat qulit (10). Aatsitassarsiorneq ukiumut qaammatit qulingiluat ingerlanneqartassaaq kisianni suliaqarfittut sanaartugaq ukiumut qaammatit qulit ingerlanneqartassaaq. Hudson.ip anguniagai sulisut minnerpaamil 80%-inik (imaluunniit sulisut 46-it) kalaallinik sulisoqarnissaq. Aatsitassarsiorfiusinnaanera naatsorsuutigineqarpoq ukiut 20-it sinnissagai.

Takussutissuaq 1.2 - Suliniutp inissisimaffia Kalaallit Nunaata Kitaata sineriaani

Qaarsoq aallarnersaataasumik aserorterneqassaaq piiaaffeqarfimmi uniartakkanik oqimaatsunut aqqutissakkut nutaajusukkut 10 km suliaqarfittut sanaartukkamut Kangerlussuup sinaani sananeqartussamut ingerlanneqarnermini. Nutaamik umiarsualiveqafissamik pilersitsisoqassaaq auliaqarfimmut attuumasumik. Umiarsualivik qaarsumik qaartitamik sananeqassaaq. Qaarsoq umiarsualivimmut aamma aqqutissamut sananermi atorneqartoq granittiuvoq tamaani nalinginnaasoq, naviananngitsuuvoq aamma sulfidinik akoqarani aammalu annikitsuinnarmik saviminertaqarluni. Ilimagineqarpoq umiarsualivik ukiumut qaammatit arfineq-pingasut umiarsuarnik usilersuisassasoq, aamma aallaqqaataaniit decembarimit marsi tikillugu ammasassanani sikoqariataarsinnaanera pissutigalugu.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Suliarinninnerup nalaani aatsitassiap 30 procentiata missaa (ukiumut 85.000 tonsit) iginneqartassapput pissutigalugu kajungerisunik immikkoortiterilluni ingerlatsineq pisariaqarmat aningaasatigut iluanaarniutissamik atortussamik atortussiornermi. Atortussaq iginneqartoq sulfidinik imaluunniit aatsitasssanik oqimaatsunik akoqanngilaq aamma taamaammat seernamik pilersitsisarani aammali isumannaatsumik iginneqarsinnaalluni immap iluanut. Atortussaq taanna iginniarlugu usisaatinik kalinneqartassaaq tasermut aatsitassarsiorfiup umiarsualiviullu akornanni inissisimasumut. Taseq inissisimavoq taseqarfiup nuuani naggataatigut Itillit Kangerluani kuuttuulluni.

Søndre Strømfjord

Mining area

Takussutissuaq 1.3 - Suliniuteqarfik kangianut isigaluni timmisartumit assilisaq (Kangerlussuaq ungataani takuneqarsinaavoq).

Suliniummi atortut tassaapput inuit 40-t tikillugit najugaqarfissaat (aatsitassarsiornermi sulisut aamma sinnerlugit najugaqarfigisinnaasaat); allaffiit, sulliviit aamma suliaqarfittut sanaartugaq, tassani aatsitassiaq aserorterneqassaaq aammalu kangersumik immikkoortiterissutikkuussalluni. Artortussaq suliaqarfittut sanaartukkamit assartuutit aqqutigalugiy quersuarmut matoqqasumut umiarsualivimmut attuumasumut ingerlassaaq. Suliaqarfittut sanaartukkamut, usisaatinut sullivimmut aamma najugaqarfissatut sanaartukkamut sarfaq diesel generatorinit 400kW marlunnit pilersinneqassaaq.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Aserorterivimmi piumasaqaatit eqqortinniarlugit immikkut generatori 25 kW pilersaarutaavoq. Aatsitassarsiornerup naammassinerani, matusinermi pilersaarut aamma nunanngortitseqqinnermi pilersaarut naammassineqassaaq (Immikkoortoq 10). Avatangiisit Pioreersut Suliniuteqarfissamut ilaapput aatsitassarsiorfik aamma ataqatigiinnermut atortut aatsitassarsiornermut tunngassut tamarmik. Misissugassat immikkoortiternerisa annerit ilagaat: Nalinginnaasumik Avatagiisit, Aniasoornerit, Imeq aamma Errortuutikoq, Imeq tarajuunngitsoq, Ikummatissamik kuuttoorneq, Nunami Uumassusillit Pissuseqatigiinnerat, Imermi tarajuunngitsumi Uumassusillit Pissuseqatigiinnerat, Imaani Uumassusillit Pissuseqatigiinnerat, Kulturikkut Kingornussat aamma Sunngiffimmi Sammisat. Taakku misissugassat immikkoortiternerisa ilanu, misissugassat nalinginnaasut ilagaat: nipiliorneq, pujorala, naasut, uumasut, uumasoqarfiit, piniarneq aamma aalisarneq. Nalunaarusiaq inerniliivoq Suliniut pissutiggalugu pilersinneqartunik pingaaruteqanngitsunik minnernik aunniutinik kinguneqassasoq. Sammineqartut ilaat pillugit takussutissiaq ataa saqqummiunneqarpoq. Pinngortitami pissuseqatigiinneq Sumiiffiit Nunat assigiinngitsut aamma Nuna tamakkerlugu Eriaginartitaattut Pingaarutilik Kalaallit Nunaanni Naalakkersuisut nunani assigiinngitsuni kattuffiit suleqatigalugit sumiissusersisimapput sumiiffinnik uumasulinnut pingaaruteqartunik Kalaallit Nunaata imaani aamma sineriaani avatangiisini. Sumiiffittut illersorneqartutut toqqarneqarsimasut ingerlatsivissatut siunnersuutigineqartumut qaninnerpaat Kangerlussuup akianiipput, umiarsualiveqarfiup nutaap 70 km kangianiillutik. Naalakkersuisut sumiissusersisimapput arlalinnik “Uumasunut sumiiffiit pingarutillit” aatsitassanik aamma ikummatissanik misissuinissat aamma piiaanissat malittarisassaqartut Aatsitassanut Ikummatissanullu Intasit malillugu. Sumiiffiit taakku ilagaat timmiarpaat inaat aamma tassunga atasut akunnermiliuttarfiit. Kalaallit Nunaat tamakkerlugu sumiiffiit aqqanillit Kalaallit Nunaanni Naalakkersuisunit sumiissusersineqarsimapput Ramsar allattorsimaffianut Nunat Masarsoqarfiit Nunanut Assigiinngitsunut Pingaarutillit Ramsareqarfiit ilanngunneqartussatut. Sumiiffiit taakku arlaannaalluunniit Kangerlussuup eqqaani siumugassaanngillat aamma suliniutip qanorluunniit sunnernavanngilai.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Timmissat Illersorneqarfissat marluk imaani timmiarpaat inaat (miteq siorartooq/aavooq) sumiissuserneqarsimapput, ataaseq Kangerlussuarmi aamma Itillip Kangerluani. Suli illersorneqarfissat aamma sumiissuserneqarsimapput nerlerit ulloqarfii pingaaruteqartut kaajallallugit. Taakkunannga qaninneq aatsitassarsiorfimmiit 25 km missaanik ungasissuseqarpoq. Suliniut Itillip Kangerluani sulianik ingerlassinianngilaq. Nerleq piaqqiortarpoq taamaallaat Maniitsup Sermiata aamma Upernaviup Akornanni aamma isigineqarpoq nungoratarsinnaasutut Kalaallit Nunaanni Allattuiffik Aappalaartoq malillugu. Nerlerit aappariit ataatsit malugineqarsimapput ivasut tasermi piiaafimmiit kilometerit arlalialuit ungasitsigisumi aamma qooroq suliniuteqarfiup kujataani- kippasissuani ilisimaneqarpoq nerlernut ingerlaartunut qasuersaarfittut inisimaviusoq. Sumiiffiit taaku marluk inissisimapput suliffissatut siunnersuutigineqartumit naleqquttumik ungasissusilittut. Suliniuteqarfissatut siunnersuutigineqartoq Qaqortorsuup Kangilia arlalinnik allanik timmissanik arteqarpoq tamarmik Kalaallit Nunaata Kitaani nalinginnaasut aamma siaruarluarsimasut. Suliniut ilamagineqarpoq taamaallat minnernik timmissanut sunniutit kinguneqassasut. Naasut aamma Uumasut Nunami uumasut tamaani taamaallaat ukuupput tuttu, ukaleq qaqortoq, terianniaq aamma umimmak (taaneqartoq kingulleq tamaani qaqutigoorpoq). Suliassat siunnersuutigineqartut kinguneranik uumasut taakku ilaat ilimagineqarput nuunnissaat (5 km minnerulluni). Suliniut ilimagineqarpoq taamaallat minnermik miluumasunut sunniutit kinguneqassasut. Erngup Tarajoqanngitsup Avatangiisai Suliniuteqarfimmit erngup pitsaassusaanik ooqattaarutinik misissueqqissaarnerup ersissippaa kanngussak (ooqattaarini tigusiffinni tallimani) aamma nikkeli (ooqattaarutini tigusiffimmi ataatsimi) pissusissamisoortumik pisartumik kimittusitsisartoq, tassani erngup tarajoqanngitsup pitsaassusaannut najoqqutassani nalingi qaangerlugit. Kimittusitsisarnerup nalingi saviminernut allanut najoqqutassat attuumassuteqartut nalingisa ataaniipput. Imermi tarajoqanngitsumi aalisakkat artit marluk Kalaallit Nunaanni amerlasoorujussuupput, eqaluk aamma kakilisak; artit marluk suliniuteqarfimmi kuussuarni aamma taserni nalinginnaasumik siumugassaapput.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Suliniut ilimagineqarpoq taamaallat pingaaruteqanngitsumik/minnermik aalisakkanut sunniutit kinguneqassasut aamma amerlassusaannut qanorluunniit sunniissanngitsiq. Imaani Avatangiisit Imaani avatangiisit suliniuteqarfiup eqqaani ilaqarput kangerlunnik marlunnik assut assigiinngissuteqartunik. Kangerlussuaq sermip nakkaanerinit tikinneqartarpoq, massa Itillip Kangerlua suliniuteqarfimmit imermik tarajoqanngitsumik aniasumik akuneqartartoq. Kangerlussuup naqqa annertuumik sunnerneqartaarpoq sermip nakkaanerinit takkuttunit aamma ulittarnerup tinittarnerullu sarfarneranit. Tamanna kinguneqarpoq immap naqqata allanngorarneranik ilaatigut qaarsueqarfeqarluni aamma allaat sioqqanik isortunik ulikkaartunik sedimenteqarlutik. Kangeluit marluullutik immikkoortinneqarsimapput illersorneqwartumik sineriaqartut sikunik ingerlaartoqaratik. Kangerlunni marlunni sinerissami aalisakkt artit amerlanersaat tassaapput uugaq, kanajoq aamma saarullik. Qasigiaq artiuvoq Kalaallit Nunaanni illersugaasoq aamma toqqarneqarsimavoq nungutaanissaminut navianartorsiortutut. Qasigissap pisariaqatippaa piaqqiorniarluni aamma mamaarnermi qassimasarfinnut ornigussinnaaneq; tamanna kingullermik allattorneqarsimavoq siusinnerusukkut qassimasarfimmi Kangerlussuup Timmisartoqarfiata eqqaani 1995-1997. Puisit aamma arferit artit arlallit allat siumugassaasorineqarput Kangerlussuup avammut sammernani. Suliniut ilimagineqarpoq taamaallat pingaaruteqanngitsumik/minnermik naasunut aamma uumasunut Kangerlussuarmi sunniutit kinguneqassasut. Suliniutip Itillip Kangerluaq sunnernavianngilaa. Kulturikkut kingornussat Sumiiffiit aqqaneq-marluk suiissuserneqarsimapput itsarnisarsiornermi pingaarutilittut aatsitassarsiorfiup aamma umiarsualiviup akornanni. Sumiiffinni taakkunani arfineq- pingasut Kalallit Nunaanni eqqissisimatitsinermut inatsisip ataani illersugaapput. Malugineqartariarpoq Arnangarnup Qoorua, inissisimasoq suliniutip 15 km missaanni kujataani-kangisissumi, qinerneqarnissaminut ilipannaateqartutut siunnersuutigineqarsimammat UNESCO World Heritage Area (Nunarsuarmiut Kingornuttagassaattut) 2003-mi, kulturikkut pingaaruteqarnera pissutigalugu. Ullumimut nunarsuarmiut kingornussassaattut nalilerneqarsimanngilaq aamma eqqarsaatitigaanni Qaqortorsuup Kangiliani suliniut aumilluunniit Arnangarnup ooruanut sunniuteqassanngitsoq, ineriartornermut aporfittut isigineqanngilaq. Suliniut ilimagineqarpoq taamaallaat minnermik itsarnisarsiornermi sinnikunut sunniutit kinguneqassasut.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Innarlernaveersaarnermi Iliuusissat Suliniut siullermik takutinneqarnerminit allanngortinneqarsimavoq Avatangiisinut Sunniutaasinnaasunik Nalilersuinermi paasisat kingunerinik. Taakku aallannguutit avatangiisinut sunniutit pinngitsoorniarlugit imaluunniit annikillisinniarlugit ilagaat: - Siusinnersukkut nalunaarsorneqarsimanngitsut orkidét tamaaniittut uppernarsineqarpuq, nalunaaqutserneqarput aamma ingalanneqarput; - Aatsitassarsiorfiup/umiarsualiviup oqimaatsunut aqqutaa itsarnisarsiornermi sinnikut sumiissuserneasimasut ingalassimaniarlugit naleqqussarneqarpoq; aamma - Nunat assigiinngitsut isumaqatigiissutaat attuumassuseqartut malillugit umiarsuit ballastimi imartaat taarserneqartassasut imarpiup qeqqani aamma kangerlummiunngitsoq. Avatangiisinut Ingerlatsinermi Pilersaarut suliniummut ineriartortinneqassaaq, aamma sammivissai sammisat/suliat tulliuttut: • Piiaaffiup ammasup ingerlanneqarnera • Angalaneq • Aatsitassiamik suliaqarneq aamma atqatigiinneq • Imermik pilersuineq • Allaffiit aamma ikiorsiilluni sanaartukkat attuumassuteqartut • Aserfallatsaaliunerit qulaani taaneqartunut attuumassuteqartut Avatangiisinut Ingerlatsinermi Pilersaarutip allaaserissavai navianartut Avatangiisinut Sunniutaasinnaasumik Nalilersuinermi suussuserneqartut qanoq ilillutik aatsitassarsiorluni suliniutip sanaartorneqarnerata, ingerlanneqarnerata aamma matuneqarnerata nalaani pakkersimaarneqassanersut. Avatangiisinut Ingerlatsinermi Pilersaarut ineriartortinneqassaaq Avatangiisinut Sunniutaasinnaasumik Nalilersuinermi suussuserneqartunit aamma misissueqqissaarnernik aamma ilagissallugit tulliuttut: • Iliuusissat Hudson-imiit aamma isumaqatigiissuteqarfigisaannit aalajangiunneqartut suliniutip killiffiini tamani peerniarlugit imaluunniit ingalassimaarniarlugit avatangiisinut sunniutit ajoqutaasut Avagtangiisinut Sunniutaasinnaasunik Nalilersuinermi suussuserneqarsimasut, imaluunniit annikillisillugit qaffassutsinut akerineqarsinnaasunut, • Piareersaatit iliuusissat taakku atulersinniarlugit pisariaqartut, aamma • Inuit, piareersaatit atulersinneqarnissaanut akisussaasut. Avatangiisinut Ingerlatsinermi Pilersaarutip ilagissavai tulliuttut tamaasa immikkut: • Peqqissisusermut aamma Isumannaassusermut Pilersaarut • Pujoralannik ingerlatsinermut Pilersaarut • Nipiliornermik Ingerlatsinermut Pilersaarut • Aatsitassarsiornermi sinnikunut Ingerlatsinermut Pilersaarut • Innuttaasut Isumannaassusaannut Pilersaarut

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

• Eqqakkanut Ingerlatsinermut Pilersaarut • Kuuttoornermut Qisuariarnnissamut Pilersaarut • Matuneqarneranut Pilersaarut Avatangiisinut Sunniutit Avatangiisinut Sunniutaasinnaasunik Naliersuinerup sillimaffigai avatabgiisinut sunniutit annertuut ingalanniarlugit imaluunniit annikillisinniarlugit iliuusissatut siunnersuutigineqartut. Avatangiisinut Sunniutaasinnaasunik Nalilersui-nerup inerneri eqikkarneqarsimapput nalunaarsuiffimmi tulliuttumi.

Immersugassiaq 1.1 - avatangiisinut sunniuteqarnerup eqikkarneqarnera VALUED ECOSYSTEM POSSIBLE EFFECT POSSIBLE IMPACT SIGNIFICANCE COMPONENT (VEC) Itsarnitsat sinnikui Kulturikkut eriagisassat Timitalimmik Annikippoq Timmissat Uuliakoorneq kemikalianillu Oqorsaataarunneri Annikippoq aniasoorneq Timmissat Ummaffeerunneq Timmissat ulluinik uninngaviinilu Annikippoq akornusiineq Itissutsip Sinnikunik eqqaaneq Taseq A-mi sinnikunik eqqaaneq Annikippoq allanngornera Eqalunniarneq Inuit suliaat Amerlassusaat aannikillineri imlt. Annikippoq Annertunerusumik kermikalianik akoqalerneq Mingutsitsisut Imeq Taseq A-mi sinnikunik eqqaaneq Annikippoq Aalisakkat Uuliakoorneq kemikalianillu Mingutsitsineq Annikippoq aniasoorneq Aalisakkat Qimerloqanngitsut Timitalimmik tastsip eqqaa sunnerneqarmat Annikippoq Aalisakkat Qimerloqanngitsut Eqqakkat, Atortussat eqqakkat Pingaaruteqanngilaq Aalisakkat Qimerloqanngitsut Sinnikut mingutsitinerat Annikippoq Aalisakkat Immami aalisakkat Timitalimmik mingutsitsineq pisuulluni Pingaaruteqanngilaq Naasut Aniasunit Pujoralatserineq Annikippoq Naasut Pujoralammik Alanngumiilerneq Annikippoq Uumaffiit allanngorneri Imeq Taseq A-mut sinnikunik eqqaaneq Annikippoq Inuup peqqissusaa Nipiliorneq Tusaaniarnermik ajoqusiineq Annikippoq Inuup peqqissusaa Pujoralak Anersaartornermik ajoqusiineq Annikippoq Inuup peqqissusaa Aniasut Anersaartornermik ajoqusiineq Annikippoq Piniarneq aalisarnerlu Nipiliorneq Akornuserneqarnermi uumasut nuunneri Ingasanngilaq Piniarneq aalisarnerlu Nipiliorneq Qulimiguulimmik akornusiineq Pingaaruteqanngilaq Qimerloqanngitsoq Qumerloqanngitsut Timitalimmik tatsip sunnerneqarnerani Annikippoq Qimerloqanngitsoq Qimerloqanngitsut Sinnikut eqqakkat Atortussat eqqakkat Pingaaruteqanngilaq Qimerloqanngitsoq Qimerloqanngitsut Sinnikut eqqakkat Atortussat eqqakkat Annikippoq Qimerloqanngitsoq Immami qimerloqanngitsut Timitalimmik mingutsitsinermik pisut Pingaaruteqanngilaq Tatsimi uumaffiit Erngup uumaffiusut allanngorneri Timitalimmik Pingaaruteqanngilaq Miluumasut Aatsitassarsiornermi sulinerit Akornusiineq sulinerlu Annikippoq Miluumasut Uumaffimmik anaasaqarneq Nuunneq nunap annertussusaa Annikippoq nipiliornermillu pisut Miluumasut Immami muluumasut Timitalimmik nipiliornermik pisut Pingaaruteqanngilaq Miluumasut Immami miluumasut Timitalimmik mingutsitsinermik pisut Pingaaruteqanngilaq Immami naasut Errortuutikoq Mingutsitsineq Annikippoq Immami naasut Errortuutikoq Naasut asiuneri Annikippoq Immami uumaffiit Immami pinngortitami Timitalimmik immap naqqata Pingaaruteqanngilaq

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

pissuseqatigiinneq allanngorneranik Immami uumaffiit Immami pinngortitami Timitalimmik Nerisassat annertusinerini Pingaaruteqanngilaq pissuseqatigiinneq Immami uumafiit Immami pinngortitap Timitalimmik nipiliorneq pissutaalluni Pingaaruteqanngilaq pissuseqatigiinneq Immami miluumasut Uuliakoorneq kemikaliamik Mingitsitsineq Annikippoq aniasoorneq Kuummi uumaffiit Erngup uumaffiata allanngornera Timitalimmik Pingaaruteqanngilaq Nunamik Sinnikunik eqqaaneq Taseq A-mi sinnikunik eqqaaneq Annikippoq arsaarinninneq Atortussat eqqakkat Imeq Taseq A-mi sinnikunik eqqaaneq Annikippoq Nunap ilusaa Aatsitassarsiorfimmi Timitalimmik Annikippoq Nunap ilusaa Ataqatigiinnermut Timitalimmik Annikippoq aaqqissuussinerit Ersarissuseq Sinnikunik eqqaaneq Taseq A-I sinnikunik eqqaaneq Pingaaruteqanngilaq Ersarissuseq Sinnikunik eqqaaneq, matoreerpat Taseq A-mut sinnikunik eqqaaneq Pingaaruteqanngilaq Erngup pitsaassusaa Aniasut Naasut amerlineri Annikippoq Erngup pitsaassusaa Errortuutikoq Pitsaassusaa annikillisoq Annikippoq Uumasut Pujoralak Nerisassat qallerneri Annikippoq Uumasut Nipiliorneq Qimaaneq Annikippoq

Sunniutit sakkortusiartortut Allanik ineriartortitsisoqanngimmat imaluunniit suliniuteqanngimmat suliniuteqarfiup iluani imaluunniit qanittuani, avatangiisinut sakkortusiartortunik sunniuteqassanngilaq. Inerniliinerit Nunap ilai nunanut assigiinngitsunut aamma nuna tamakkerlugu naasunut aamma uumasunut pingaaruteqartut suliniummit akornusersorneqassanngilaat. Suliniut auliniuteqarfimmi aamma attaveqatigiinnermut atortunit 5 km tikillugu tuttunut aamma umimmannut akornusersuilaarnermik kinguneqassaaq. Akornusersuineq taanna minnermik sunniuteqassaaq nunap ilaa siornatigulli qaqutigoortumik piniarfiusarmat. Ujaqqanik igitassanik tasernut qanittumiittunut inissiineq ilimagineqarpoq pingaaruteqanngitsoq tatsini aamma kuussuarni uumasoqarfinnut sunniuteqassasut, aamma pingaaruteqanngitsumik/minnermik imermi tarajoqanngitsumi uumasunut qimerloqanngitsunut sunniuteqassasut. Ujaqqat igitassat saviminermik annertuumik akoqanngillat aamma saviminermik kuutsitsivigineqarnea isigineqarpoq appasissutut. Suliniut naatsorsuutigineqanngilaq aalisartoqarfinnik sunniissasoq. Aatsitassarsiornerup kingorna, aatsitassarsiorfimmik matusinermut ilaassapput ataqatigiinnermut atortunik minitaqarani piiaanerit. Aqqusernup sinnikui immineerneqassappuq, massa kigartorneqassallutik naasoqaqqinnissaa siuarsarniarlugu.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Avatangiisinut ingerlatsinermi pilersaarutit aamma nakkitilliinermi pilersaarutit annertuut isumannaassavaat ajonartorsiutit nutaat aamma ilimginngisat piffissaq eqqorlugu aamma naleqquttumik isumagineqarnissaa.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

1.3 Danish

Indledning

Hudson Resources Inc. (Hudson) er en canadisk mineralefterforskningsvirksomhed, der udvikler White Mountain (Naajat) anorthosit-projektet (projektet). Projektet er placeret på Grønlands centrale vestkyst, ca. på breddegraden 66 ° 33'N (omtrent polarcirklen) og længdegraden 52 ° 10'V. Det er cirka 80 km sydvest for den internationale lufthavn i Kangerlussuaq og cirka 80 km fra den sydøstlige del af Sisimiut, den nærmeste by. Hudson har en andel på 100 % i efterforskningstilladelsen for det 95 kvadratkilometer store Naajat-område (EL 2002/06).

Hudson foreslår at etablere en mine- og forarbejdningsaktivitet på Naajat-området (figur 1.1). Projektet omfatter: ! Åben minegrube ! Forarbejdningsfaciliteter ! Tilkørselsveje ! Depotområde for restprodukt ! Havn ! Infrastruktur og beboelses-/lejrområde Hudson planlægger at udgrave ca. 285.000 tons malm om året og transportere 200.000 tons forarbejdet materiale til Europa, Nordamerika og Asien. Materialet er en hovedingrediens i fremstillingen af E-glas fiberglas. Ca. 85.000 tons affaldsmateriale vil hvert år blive sikkert bortskaffet på stedet.

Sammen med denne Vurdering af Virkninger på Miljøet (VVM), har Hudson desuden vedlagt en Vurdering af den Samfundsmæssige Bæredygtighed (VSB) og en forundersøgelse til ansøgningen om udnyttelsestilladelse fremsendt til Råstofstyrelsen i Grønland (MLSA). Hvis ansøgningen imødekommes vil den blive efterfulgt af en byggeperiode med start i af 2015. Driften forventes at starte i den anden halvdel af 2015 eller begyndelsen af 2016, og forventes at fortsætte i mere end 20 år. Driftens levetid er kun begrænset af tilgængeligheden og bæredygtigheden på de internationale markeder og muligheden for at afsætte anorthositmaterialet. Der er på nuværende tidspunkt tilstrækkelige ressourcer til mindst 120 års drift.

Denne VVM er blevet udfærdiget i overensstemmelse med de officielle retningslinjer fra Råstofstyrelsen i Grønland "BMP retningslinjer for udarbejdelse af miljøvurdering (VVM) for udnyttelse af mineraler i Grønland", 2. udgave, januar 2011 (BMP, 2011).

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Denne del består af det ikke-tekniske resumé (ITR) af VVM, som er blevet udarbejdet som en del af VVM-proceduren. Projektet

Licensområdet White Mountain strækker sig over ca. 95 kvadratkilometer. Projektets fysiske komponenter omfatter følgende: mine, havn, tilkørselsvej, forarbejdningsanlæg, beboelses-/lejrområde for de ansatte og bortskaffelsesområde for mineaffald.

White Mountain (Naajat EL) Project Location

52°30'0"W 52°0'0"W 51°30'0"W 51°0'0"W 50°30'0"W

66°56'0"N 66°56'0"N ¯ Kangerlussuaq

66°45'0"N 66°45'0"N

Mine Location Access Road

Sarfartoq EL Process Plant and Port Location (Hudson's Rare Earth Project)

66°34'0"N 66°34'0"N

Naajat EL

0 3.75 7.5 15 22.5 30

66°23'0"N Kilometers 66°23'0"N

52°30'0"W 52°0'0"W 51°30'0"W 51°0'0"W 50°30'0"W

Figure 1.1 - Projektlokation

Projektet vil udvinde malm fra en åben grube placeret ca. 5 km nord for Søndre Strømfjord. Minedriften finder sted med boring og sprængning uden behov for at fjerne overflademateriale eller affaldsklippe. Projektet forventes at skabe ca. 30 fuldtidsstillinger på minestedet under driften. Når der tages hensyn til, at driften vil ske med to skift, vil det være nødvendigt med ca. 57 personer, herunder 10 entreprenører stillinger. Minedriften vil finde sted 9 måneder om året, og forarbejdningsanlægget vil være aktivt 10 måneder

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

om året. Det er Hudsons målsætning af have en grønlandsk arbejdsstyrke på mindst 80 % af alle stillinger (eller 46 medarbejdere). Minens levetid forventes at overstige 20 år.

Figure 1.2 - Projektets placering ved Grønlands vestkyst Klippen vil først blive delvist knust på grubestedet inden materialet transporteres med lastvogn ad en 10 km ny tilkørselsvej til et forarbejdningsanlæg, som vil blive bygget ved Søndre Strømfjord. Der vil blive bygget en ny havnefacilitet ved anlægget. Havnefaciliteten vil blive bygget med sprængte klippestykker. Klippen, som anvendes til bygning af havnefacilitet og tilkørselsvej, er granit, som er dominerende i området; den er uskadelig, indeholder ikke sulfider og kun mindre metaller. Det forventes, at havnefaciliteterne vil læsse skibe i otte måneder om året, og vil i starten ikke være i funktion fra december til marts pga. potentiel isdannelse. Under forarbejdningstrinnet vil ca. 30 % af malmen (85.000 tons pr. år) blive kasseret pga. den magnetiske separationsproces, som er nødvendig for at fremstille et kommercielt produkt. Affaldsmaterialet indeholder ikke sulfider eller tungmetaller og er derfor ikke syredannende og kan sikkert bortskaffes under vand. Materialet transporteres med lastvogn til bortskaffelse i en sø, som ligger mellem minen og havnen. Søen er placeret ved begyndelsen af et søsystem, som ved afslutningen leder ud i Itilleq Fjord.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Søndre Strømfjord

Mineområde

Figure 1.3 - Projektområdet, som vender mod øst, set fra luften Projektfaciliteterne vil bestå af et beboelseskompleks, som kan rumme op til 40 personer (tilstrækkeligt til at dækket behovet for personale på stedet plus et overskud), kontorer, værksteder og et forarbejdningsanlæg, som malmen gennemgår traditionel knusning og magnetisk separation. Materialet transporteres med transportbånd fra forarbejdningsanlægget til en overdækket lagerplads i nærheden af havnen.

Energien til forarbejdningsanlægget, lastvognsværksted og beboelsesbygningerne leveres af to 400 kW dieselgeneratorer. En separat 25 kW generator er planlagt til at dække energibehovet i den åbne mine.

Ved minedriftens afslutning vil en nedluknings- og genvindingsplan blive implementeret (jvf. kap. 10).

Det eksisterende miljø

Projektområdet omfatter minen og alle infrastrukturer, som er knyttet til mineaktiviteterne. Undersøgelsen omfatter følgende overordnede kategorier: Det

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

generelle miljø, emissioner, vand og spildevand, ferskvand, brændselsudslip, terrestrisk økologi, ferskvandsøkologi, marineøkologi, kulturarv og rekreative aktiviteter. Inden for hver af disse overordnede kategorier er følgende typiske undersøgelsesgenstande medtaget: støj, støv, flora, fauna, habitat, jagt og fiskeri.

Rapporten konkluderer, at der vil være fra ubetydelig til mindre resterende effekt som et resultat af projektet. Et eksempel på nogle af disse effekter er vist herunder. Natur

Internationale og nationale bevaringsværdige steder

Naalakkersuisut har i samarbejde med internationale organisationer identificeret områder med biologisk betydning i Grønlands hav- og kystmiljø. Det beskyttede område, som ligger tættest ved de foreslåede aktiviteter, er på den modsatte side af Søndre Strømfjord, ca. 70 km øst for de nye havnefaciliteter.

Regeringen har identificeret flere "Vigtige områder for dyrelivet i Grønland", hvor mineral- og olieefterforsknings- og udvindingsaktiviteter er reguleret iht. til Råstofloven. Disse områder omfatter fuglekolonier og tilstødende bufferzoner. Naalakkersuisut har identificeret 11 områder, som er blevet udpeget til optagelsen på listen over beskyttede vådområder iht. Ramsar-konventionen.

Ingen af disse områder ligger i nærheden af Søndre Strømfjord, og projektet vil ikke på nogen måde påvirke disse.

Fugle

Der er blevet udpeget to beskyttede områder for havfuglekolonier (edderfugl), et i Søndre Strømfjord og et i Itilleq Fjord. Der er også udpeget andre beskyttede områder omkring kritiske rugeområder for blisgæs. Det nærmeste af disse områder ligger ca. 25 km fra minelokaliteten.

Projektet medfører ikke aktiviteter i Itilleq Fjord.

Blisgåsen yngler kun i området mellem indlandsisen på Maniitsoq og Upernavik, og betragtes som en truet art iht. Grønlands røde liste. Enkelte gåsepar med rede er blevet observeret i en sø nogle få kilometer fra gruben, og dalen, som ligger sydvest for projektområdet, er kendt som hvilelokalitet for migrerende blisgæs. Begge disse lokaliteter ligger på rimelig afstand af de foreslåede aktiviteter. Det foreslåede projektsted ved White Mountain rummer forholdsvis få andre fuglearter, og disse er alle almindelige og vidt udbredte i Vestgrønland.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Projektet forventes kun at have mindre resterende effekt på fugle.

Flora og fauna

Dyrelivet på jorden i området er begrænset til rensdyr, snehare, polarræv og moskusokser (sidstnævnte er sjældne i området). Som en konsekvens af de foreslåede aktiviteter forventes nogle af disse pattedyr at flytte til andre områder, men ifølge internationale studier vil flytningen være begrænset (mindre end 5 km).

Projektet forventes kun at have mindre resterende effekt på pattedyr.

Ferskvandsmiljø

Analyse af vandkvalitetsprøver fra projektområdet viser naturligt forekommende koncentrationer af kobber (på hvert af de 5 prøveudtagningssteder) og nikkel (ét prøveudtagningssted), der overstiger vejledende værdier for ferskvand. Koncentrationsniveauerne for andre metaller lå alle under de respektive vejledende værdier.

Der findes to arter af ferskvandsfisk, som forekommer i stort antal i Grønland, fjeldørred og trepigget hundestejle; begge arter forekommer almindeligt i elve og søer i projektområdet.

Projektet forventes kun at have en ubetydelig/ringe resterende effekt på fisk og vil ikke på nogen måde påvirke populationen.

Havmiljø

Havmiljøet omkring projektområdet har to fjorde, som er væsentligt forskellige. Søndre Strømfjord modtager isaflejringer, mens Itilleq Fjord modtager ferskvand fra projektområdet. Bunden i Søndre Strømfjord er stærkt påvirket af den tilførte is og tidevandsstrømmene. Dette resulterer i en meget varieret fjordbund med nogle områder med klippebund og andre med sandet sediment. Begge fjorde er klassificeret som havende en beskyttet kyst og er uden drivis.

De hyppigst forekommende kystnære fiskearter i begge fjorde er fjordtorsk, ulk og atlanterhavstorsk. Den spættede sæl er en beskyttet dyreart i Grønland og klassificeret som kritisk truet. Den spættede sæl er afhængig af adgang til rastepladser til reproduktion og fældning; dette blev sidst registreret på den tidligere rasteplads ved siden af lufthavnen i Kangerlussuaq i 1995-97. Flere andre sælarter og hvaler menes at dukke op i den ydre Søndre Strømfjord.

Projektet forventes kun at have en ubetydelig/ringe resterende effekt på flora og fauna i Søndre Strømfjord. Projektet vil ikke påvirke Itilleq Fjord.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Kulturarv

Der findes 12 steder af arkæologisk betydning på området mellem minen og havnefaciliteterne. Otte af disse steder er beskyttede iht. Grønlands bevaringslov.

Det skal bemærkes, at Arnangarnup Qoorua (Paradisdalen), som ligger ca. 15 km sydøst for projektet, i 2003 blev foreslået som potentiel kandidat til UNESCO World Heritage-status på grund at dets kulturelle betydning. Det er indtil dags dato ikke blev valgt til World Heritage-status, og da White Mountain-projektet ikke vil have nogen indflydelse på Paradisdalen, anses dette ikke at være et emne, som kræver uddybning.

Projektet forventes kun at have mindre resterende effekt på arkæologiske levn.

Risikoreducerende foranstaltninger

Det oprindelige projekt er blevet ændret som en følge af resultaterne i VVM. Disse ændringer, som skal medvirke til at undgå eller reducere potentielle miljøpåvirkninger, omfatter: - Tidligere uregistrerede orkideer i området er blevet identificeret, mærket og efterladt uberørte; - Forbindelsesvejen mellem minen og havnefaciliteterne er blevet tilrettelagt, så arkæologiske rester bevares; og - I overensstemmelse med relevante internationale konventioner, vil skibes ballastvand blive udskiftet på åbent hav og ikke i fjorden.

En miljøhåndteringsplan (MHP) vil blive udviklet for projektet, og den vil omhandle følgende områder/aktiviteter:

• Åben minedrift • Trafik • Malmforarbejdning og infrastruktur • Vandforsyning • Kontorer og tilknyttede støttefaciliteter • Vedligeholdelsesaktiviteter i forbindelse med ovennævnte områder

Denne MHP vil beskrive, hvorledes risiciene, som er identificerede i VVM, vil blive reduceret under opførelses-, drifts- og nedlukningsfaserne i mineprojektet. MHP vil blive udviklet på baggrund af resultaterne og analyserne i VVM, og vil medtage følgende:

• Foranstaltninger, som Hudson og dets entreprenører vil gennemføre i alle projektets faser for at eliminere eller undgå negative miljøpåvirkninger, som er identificerede i

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

VVM, eller for at nedbringe dem til et acceptabelt niveau, • handlinger, som er nødvendige for at implementere disse foranstaltninger og • personerne, som er ansvarlige for implementeringen af disse foranstaltninger.

MHP vil indeholde følgende planer:

• Sundheds- og sikkerhedsplan • Støvhåndteringsplan • Støjhåndteringsplan • Håndteringsplan for mineaffald • Plan for offentlig sikkerhed • Håndteringsplan for affald • Plan for respons på udslip • Nedlukningsplan • Plan for respons på udslip • Nedlukningsplan Miljøpåvirkninger

VVM har taget højde for de foranstaltninger, som er foreslået for at undgå eller reducere betydelige miljøpåvirkninger. Resultaterne i VVM er sammenfattet i nedenstående tabel.

Table 1.1 - Sammenfatning af miljøpåvirkninger

VÆRDSAT MULIG PÅVIRKNING MULIG KONSEKVENS BETYDNING ØKOSYSTEM KOMPONENT (VEC) Arkæologiske rester Kulturarv Fysisk Mindre Fugle Olie- og kemikalieudslip Tab af isolering Mindre Fugle Tab af habitat på jord Forstyrrelse af yngel og Mindre yngleområder for fugle Ændret bathymetri Deponering af mineaffald Deponering af mineaffald i søen A Mindre Røddingfiskeri Menneskelige aktiviteter Reduceret bestand eller øget Mindre indhold af kemikalier Forurenende elementer Ferskvand Deponering af mineaffald i søen A Mindre Fisk Olie- og kemikalieudslip Forurening Mindre Fisk Hvirvelløse dyr Fysisk pga. påvirket søområde Mindre Fisk Hvirvelløse dyr Deponering af mineaffald Ubetydelig Suspenderende stoffer Fisk Hvirvelløse dyr Deponering af mineaffald Mindre Forurening Fisk Havfisk Fysisk pga. kontaminanter Ubetydelig Flora Emissioner Fertilisering Mindre Flora Støv Skyggefremkaldende Mindre

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Ændringer i habitat Ferskvand Deponering af mineaffald i søen A Mindre Menneskelig sundhed Støj Høreskader Mindre Menneskelig sundhed Støv Luftvejssygdomme Mindre Menneskelig sundhed Emissioner Luftvejssygdomme Mindre Jagt og fiskeri Støj Flytning af dyreliv som følge af Moderat forstyrrelser Jagt og fiskeri Støj Forstyrrelser fra helikopter Ubetydelig Hvirvelløst dyr Hvirvelløse dyr Fysisk pga. påvirket søområde Mindre Hvirvelløst dyr Hvirvelløse dyr Deponering af mineaffald Ubetydelig Suspenderende stoffer Hvirvelløst dyr Hvirvelløse dyr Deponering af mineaffald Mindre Suspenderende stoffer Hvirvelløst dyr Hvirvelløse havdyr Fysisk pga. kontaminanter Ubetydelig Søhabitater Ændringer i Fysisk Ubetydelig ferskvandshabitater Pattedyr Mineaktiviteter Forstyrrelse og flytning Mindre Pattedyr Tab af habitat på jord Flytning pga. området størrelse og Mindre støj Pattedyr Havpattedyr Fysisk pga. støj Ubetydelig Pattedyr Havpattedyr Fysisk pga. kontaminanter Ubetydelig Marin fauna Spildevand Forurening Mindre Marin flora Spildevand Nedbrydning af flora Mindre Marint habitat Havøkologi Fysisk pga. ændringer i bunden Ubetydelig Marint habitat Havøkologi Fysisk pga. stigning i Ubetydelig næringsstoffer Marint habitat Havøkologi Fysisk pga. støj Ubetydelig Havpattedyr Olie- og kemikalieudslip Forurening Mindre Flodhabitater Ændringer i Fysisk Ubetydelig ferskvandshabitater Beslaglagt område Deponering af mineaffald Deponering af mineaffald i søen A Mindre Suspenderede stoffer Ferskvand Deponering af mineaffald i søen A Mindre Topografi Minelokation Fysisk Mindre Topografi Infrastruktur Fysisk Mindre visuel Deponering af mineaffald Deponering af mineaffald i søen A Mindre visuel Deponering af mineaffald, Deponering af mineaffald i søen A Ubetydelig Efter nedlukning Vandkvalitet Emissioner Eutrofiering Mindre Vandkvalitet Spildevand Nedsat kvalitet Mindre Dyreliv Støv Overdækket føde Mindre Dyreliv Støj Bortskræmning Mindre

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Kumulative effekter

Da der ikke findes andre udviklinger eller projekter på eller tæt ved projektområdet vil der ikke være nogen kumulative miljøeffekter. Konklusioner

Områder af international og national betydning for flora og fauna vil ikke blive forstyrret af projektet. Projektet vil medføre en vis forstyrrelse af rensdyr og moskusokser på projektområdet på en afstand på op til fem kilometer fra infrastrukturens komponenter.

Denne forstyrrelse vil have en mindre effekt på de i forvejen sparsomme jagtaktiviteter på området.

Deponeringen af mineaffald i de nærliggende søer forudses at have en ubetydelig effekt på sø- og flodhabitater, og en ubetydelig/mindre effekt på hvirvelløse ferskvandsdyr. Mineaffaldet har et ubetydeligt metalindhold, og udvaskningen af metal anses for lav.

Projektet forventes ikke at påvirke fiskeriet i området.

Ved mineaktiviteternes afslutning omfatter nedlukningen af minen fjernelse af alle infrastrukturelle komponenter. Resterne af vejen vil blive efterladt på stedet, men vil blive pløjet for at fremme genbevoksning.

En omfattende miljøhåndteringsplan og et overvågningsprogram vil sikre, at opkommende og uforudsete problemer vil blive håndteret rettidigt og hensigtsmæssigt.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

2 Introduction This report describes the EIA for Hudson’s proposed Anorthosite mining project at White Mountain located 80 km south-west of Kangerlussuaq, with the main objectives being to evaluate the potential impacts on the environment of the construction, operation and closure of the mine and associated facilities. The EIA is prepared in compliance with the official guideline of the MLSA, “BMP guidelines – for preparing an Environmental Impact Assessment (EIA) Report for Mineral Exploitation in Greenland” 2nd Edition, January 2011, (BMP, 2011).

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

3 Regulatory Framework The most essential documents when preparing an EIA report for mineral exploitation are the act on mineral resources and mineral resources activities (the mineral act) and the BMP guidelines for preparing an EIA Report for Mineral Exploitation in Greenland. Other national legislation on nature protection, navigation safety and the working environment can be of relevance or importance for a mining project as the mineral act and especially the BMP EIA guidelines require that exploitation activities are planned and executed in a safe and environmentally acceptable manner. All of the relevant national and international legislation, guidelines and other agreements related to environmental and safety issues, are included in Appendix 1 - Regulations and Guidelines.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

4 Description of the White Mountain Project

Hudson Resources Inc. (Hudson) is a Canadian mineral exploration company focused on developing the White Mountain Anorthosite Project. The project is situated on the central west coast of Greenland on the Najaat Exploration License No. 2002/06. With respect to the Najaat license, the Company has a 100% interest in the 95 sq. km. license area. The project is located at approximately latitude 66°33’N (approximately the Arctic Circle) and longitude 52°10’W.

Hudson is proposing to establish a mining and processing operation at the White Mountain project. The project will involve the annual mining of 285,000 tonnes and the shipping of approximately 200,000 tonnes of material to Europe, North America and Asia. The material will be a key ingredient in the manufacturing of E-Glass fiberglass. The project has excellent potential to grow in output as markets are established for the White Mountain material.

The mine would operate ten months per year (March through December) and would employ approximately 57 people full time. It is expected that the work force would be largely (minimum 80%) Greenlandic. The mine life is expected to exceed 20 years once long term off-take (purchase) agreements are established.

The design concept for the project is based on the following: • Open pit mine operating 40 weeks/year (March through November), one 12 hr shift/day, 7 days/week • 285,000 tpy nominal Run of Mine production = 136 t/hr nominal production • Portable jaw and cone crushers used at the mine site • Truck haul of primary crushed material 10 km to the plant site at the port • Tertiary crushing (VSI) crushing & screening plant to reduce rock to 0.841 mm • De-dust at 0.074 mm. Dust losses are estimated at 15% • Utilize magnetic separation to reduce the iron content. Magnetic separation losses are estimated at 15% • Processing plant to operate 24/7, 300 days/year (March through December). Plant throughput is 43.75 t/hr • Storage/loadout of final product. Eight month shipping season • Covered storage capacity for 30,000 tonnes at the port • 85,000 tonnes of magnetic waste and dust material to go to subaqueous tailings storage annually • Finished product bulk shipped to Europe in 25,000 tonne loads by ship eight times per year • The final milling, if required, and distribution would be carried out by a third party in Europe and/or the United States

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

The following sections provide a description of major project components and activities. The physical components of the Project include the following: mine, port, access road, processing facility, worker camp, and the tailings disposal area. Figure 4.3 below shows the locations of the Project components.

4.1 Location The White Mountain Project is located approximately 80 kilometers to the southwest of the international airport at Kangerlussuaq. Access to the project is possible by boat on Sondre Stromfjord, or by a 25-minute helicopter flight from Kangerlussuaq (Figure 1.1). Sondre Stromfjord is a large deep-water fjord and is navigable by boat from the coast up to its terminus at Kangerlussuaq. The coast is usually ice-free for most of the year. The center of the property is located 120 km north-northeast of the village of Maniitsoq and 80 km southeast from the town of Sisimiut. Locally the property includes two peaks, Qaqortorssûp Kangilia and Qaqatsiaq with altitudes of 1.300 and 925 meters, respectively. The area above 600-700 meters has very few biological organisms. In the middle of the property there is one major freshwater system comprised of several lakes, see Figure 4.1.

Figure 4.1 - Map View of the White Mountain Project (Naajat Property) in western Greenland

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

4.2 The Material/Ore The White Mountain anorthosite is of special interest because it has high concentrations of aluminum (30%), silica (50%) and calcium (15%), with low iron and little to no contaminants. These unique properties make it attractive for potential use in various industrial mineral applications. A complete assay of the major elements in the anorthosite ore is included in Table 4.1 Hudson has determined that the White Mountain anorthosite has three potential industrial applications:

• As a new source of feedstock to the high-end fiberglass (E-glass) industry; • As a new source of alumina to supply aluminum smelters; and • As a new source of filler material. Fillers are a significant component in the plastics and paints industries. Hudson’s White Mountain ore body is an anorthosite layered intrusion composed of high- calcium plagioclase with minor amounts (less than 1%) of clinozoisite and muscovite. Within the project area, the calcic anorthosite is lenticular in shape with an east-northeast trend, covering a surface area of over 20 square kilometers. Initial drilling on the project has defined an indicated mineral resource of 27.4M tonnes and an inferred resource of 32.7 M tonnes for material with a sodium (Na2O) level below 2.5%. The resource parameters are based on the material needed for the E-Glass (fiberglass) industry, which requires low sodium, low iron feed material. The resource remains open in all directions. The current resource is large enough to operate the mine for over 100 years.

Table 4.1 - Assay of all major elements in the Anorthosite

Class Max % Tonnes SiO2 Al2O3 Fe2O3 CaO MgO Na2O K2O

Na2O (‘000) % % % % % % %

Indicated 2.50 27.384 49.2 30.0 1.26 14.95 0.55 2.35 0.29

Inferred 2.50 32.724 49.4 30.1 1.22 15.01 0.52 2.34 0.26

Notes: 1. CIM definitions were followed for Mineral Resources. 2. The Qualified Person for this Mineral Resource estimate is Dr. Michael Dracker, Ph.D., CPG 3. Mineral Resources are estimated for blocks containing less than 2.5% Na2O based on feedstock requirements for E-glass manufacture Note: Hg (mercury) averages less than 0.006 parts per million (ppm) and is therefore left out of major element reporting.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

4.3 Mining Operations

4.3.1 Mining"Method" The property will be mined using open pit mining methods. There is no need for stripping of overburden or waste rock. Due to the topography of the deposit, benching into the hillside is the primary method of extraction. The pit is designed almost entirely within the Indicated Resource so that there is no waste rock in the walls. This enables a conservative slope angle so that slope stability will not be an issue. The material would be drilled and blasted using ANFO (ammonium nitrate and diesel). The operation would involve the mining of approximately 285,000 tonnes per year, roughly 1,000 tonnes per day for nine months. Mine trucks will haul ore from the pit face to a 2-stage mobile crushing facility located near the mine. The primary jaw and secondary cone crushers, feed conveyors, and discharge conveyors will be powered by diesel engines. After primary and secondary crushing, the material will be hauled 10 km by trucks to the processing plant located at the port area. The mining operation would be relatively simple and use the following equipment: one production drill, one excavator, three dump trucks, one grader, one front-end loader, one service truck, one fuel truck, one water truck, one mechanical truck and three passenger vehicles.

4.3.2 Processing"Facility" The processing facility is located at the port site. At the processing plant the material is fed into a tertiary crusher and a magnetic separator. The process plant in Greenland will operate on a 24 hr/day, 7 day per week schedule for 300 operating days/year (10 months). The processing plant will include the following steps: ! Dust removal to remove very fine particles (15% of the material is taken out at this point); ! Magnetic separation to remove small iron particles which naturally occur in the rock (as mica). Approximately 15% of the material is removed during this step; and ! The final product is then moved by covered conveyor to a large covered storage area at the port facility to be ready for shipping. Due to shipping season limitations and inventory balancing requirements, it is anticipated maximum storage requirements for the final product will be approximately 30,000 tonnes. This will require a building approximately 60 m wide by 100 m long located at the port site in Greenland.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

OUTSIDE PROCESSPLANT Bucket Elevator Plant Feed 152-BE-02 47 tph

Plant Feed Bin 151-BN-01 Air Classifier Crushed Ore Hauled Bucket Elevator 152-AC-01 From Mine 152-BE-01 Classifier Undersize 7 tph (max) VSI Feed ~ -200 mesh Plant Feed Stockpile Plant Feed FEL 106 tph 154-FL-02 (125% Circ. Load) +20 mesh

Magnetic Separator Feed Bin 153-BN-03 Vibrating Screen 152-SC-01 Magnetic Combined Waste Mags Separator 13 tph 6 tph (20%) Feed VSI Crusher 40 tph 152-CR-03 +200 mesh

Mags Conveyor Waste Magnetic Separator 153-CV-02 Hopper Screen undersize 153-MS-01 152-BN-02 47 tph -20 mesh Non-Mags (Product) 34 tph

OUTSIDE To Tailings Disposal (Ore Haulage STORAGE Product Stacker Return Trips) BUILDING 153-CV-04 Product Conveyor 153-CV-01 Reclaim & Shiploading 550 tph Reclaim Conveyor Feed Hopper 160-HP-01

Non-Mags Stockpile (in Storage Building) Reclaim FEL To Europe Reclaim Conveyor Shiploader Conveyor 30,000 tonne Bulk Carrier 160-FL-03 General Notes: 160-CV-05 160-CV-06 1. Material must be kept dry for whole process downstream of dryer. 2. Throughput rates shown are in metric tonnes per hour. 3. Throughput rates shown are nominal. Design capacities shall be 1.15x nominal.

HainsEngineeringCompany ProcessFlowDiagram P.Bubar HudsonResourcesInc. MineSite October10,2013 WhiteMountainProject ProcessPlant&Shiploading Rev.B PreFeasibilityStudy PFD2

Figure 4.2 - Process Design for the White Mountain Anorthosite It is planned to undertake processing in Greenland to produce a nonmagnetic product which is between 0.841 and 0.074 mm. This will be shipped to Europe and/or North America for distribution to the E-Glass producers. In some cases, further grinding of the material may be required, which may be carried out by Hudson or a third party outside of Greenland closer to the end users.

4.4 Infrastructure

4.4.1 Port"Facilities"and"Transport" A port facility will be established on the Sondre Stromfjord. The port will be constructed of blasted rock. The rock used for port and road construction is a granite which is prevalent in the area. It is benign and does not contain any sulphides or metals. A discussion and assays can be found in section 7.2 and HUD Technical Report 7. The port will include a storage building for the final product and a mobile ship loader. It is expected that the port will load ships eight months per year, and will not operate December through March due to potential ice conditions.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 4.3: - Plan View of the Project (Mine Site, Tailings Area, Road, and Camp/Processing Area)

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Material will be recovered from storage by front-end loader and conveyed out to the ship- loader conveying system for loading into ships. The conveyors will be covered to ensure the material remains dry and to control dust. The ship-loader will be equipped with a flexible tube dust suppression system and deflector plates to minimize dust generation and permit even filling of the holds. The design load rate for the ship-loader is 500 TPH with a projected effective capacity of 300 TPH after allowance for ship trimming. It is anticipated ships will be of the HandySize class (25,000 –35,000 deadweight tonnage). Assuming a typical 30,000 tonne load, loading time will be approximately 100 hours at 300 TPH, with an overall ship station time in Greenland of approximately five days.

4.4.2 Road" Approximately 10 km of road will be established in order to connect the harbour and port facility with the pit, Figure 4.3 above. The road is designed as a single lane structure with a width suitable for the 35 tonne haul trucks. Suitable by-pass areas will be constructed as appropriate to allow passing of vehicles. The road construction activities consist of drilling, blasting and crushing the rock to excavate to the required grade level and prepare sub-base and base material, with ditching and berms as required. See Section 4.6 for assays of the road construction material. The material does not contain any significant metals or free silica, and is therefore considered to be of low impact to workers and the environment. Work to date has involved blasting and crushing approximately 50,000 tonnes of rock to extract bulk samples. Approximate 8 km of road construction remain to be established.

4.5 Infrastructure and Camp Complex

Project infrastructure in Greenland, aside from the process plant facility, storage building and the quarry site, will consist of an accommodation complex, truck shop, diesel power plant and ancillary facilities. The accommodation complex will house approximately 30 staff.

The following facilities will be part of the mine: ! 10 km road connecting the pit, process plant and port facility; ! Housing complex for workers; ! Work shop and maintenance building; ! Fuel storage facility; ! Explosives storage facility; and ! Diesel generator building for all on-site power.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 4.4. Cross Section of the Storage, Load Out Facility and Port Arrangement.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 4.5 - The Overall Site Layout of the Camp, Plant and Port Facility

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Site roads will be located throughout the site to provide access to all operational areas of the mine. All buildings will be designed for a heavy-duty industrial environment, with an expected service life of approximately 20 years. The mine site staff dormitories will be used to accommodate the construction workforce during the construction period.

4.5.1 Power"Source" Power for the process plant, truck shop and accommodation buildings will be provided by diesel generators (750KW provided by two 400 KW units). The ship loader has its own internal source of power. A separate 25 KW generator is planned to meet requirements at the quarry. Sufficient fuel storage is planned to meet the requirements of all power units for at least two months. Fuel will be stored in spill protected double walled tanks equipped with pumps. Fuel supply to the main power unit in the port and camp area will be via dedicated line, while supply for mobile equipment will be via metered pumps. Fuel supply for the generator at the quarry site will be via a self-contained tank which will be refilled as required from a mobile service truck.

4.5.2 Explosives"Storage"Facility" A secured explosives storage will be established near the pit site, a safe distance from the mining area and mining activities (approximately 1 km). The explosives storage will consist of two 20’ security containers for storage of ANFO and one smaller 9´security container for the TNT. Figure 4 shows Hudson’s explosive storage facility currently on site for bulk sampling activities. The Container is constructed in accordance with Norwegian Directorate for Civil Protection (DSB) and complies with Det Norske Veritas’ understanding of §7-4 DSB922, including guidance to this instruction and is approved for use in Greenland.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 4.6 - Hudson Explosives Storage at White Mountain

4.5.3 Water"Supply"and"Treatment" Water supply will be drawn from a lake near the quarry site and carried by traced, insulated pipeline (Figure 4.7). The system will be split to provide untreated water for use in showers and toilets and treated water for potable water. Potable water will be passed through a particulate filter and UV sterilization system and then to a storage tank. Potable water will be withdrawn from the storage tank using a pressure system for distribution to the accommodation and kitchen facilities. The company will continually test to ensure the water is safe for human consumption. Projected water supply requirements based on a maximum of 36 on-site staff at 220 liters/person/day are 8,000 liters/day. Water consumption is anticipated to be concentrated over short time periods during the day, with peak demand estimated at two L/sec. The average daily requirement is estimated at 0.1L/sec. The water from Lake E currently drains into the Fjord and it is not expected that the water used for the project will have any effect on the water balance in Lake E. Potable water requirements for the lunchroom at the quarry site will be supplied using bottled water.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Location of Fresh Water Lake (Lake E) to be used for Drinking Water

446000.000000 447000.000000 448000.000000 449000.000000 450000.000000 451000.000000 452000.000000 453000.000000 454000.000000 455000.000000 0 0 0 0 0 0 0 0 0 0 0 0 . . 0 0 0 0 0 0 5 5 8 8 3 3 7 7 0 0 0 0 0 0 0 0 0 0 0 0 . ¯ . 0 0 0 0 0 0 4 4

8 Access Road 8 3 3 7 7 0 0 0 0 0 0 0 0 0 0 0 0 . . 0 0 0 0 0 0 3 3

8 Pit Location 8 3 3 7 7 0 0 0 0 0 0 0 0 0 0 0 0 . . 0 0

0 Process Plant and Port Location 0 0 0 2 2 8 8

3 Lake E 3 7 7 0 0 0 0 0 0 0 0 0 0 0 0 . . 0 0 0 0 0 0 1 1 8 8 3 3 7 7 0 0 0 0 0 0

0 Lake E Drains 0 0 0 0 0 . . 0 0

0 to the Fjord 0 0 0 0 0 8 8 3 3 7 Drinking Water Lake Catchment Basin 7

446000.000000 447000.000000 448000.000000 449000.000000 450000.000000 451000.000000 452000.000000 453000.000000 454000.000000 455000.000000 Figure 4.7 - Location of Drinking Water Lake (Lake E)

4.5.4 Sewage"Treatment"and"Discharge" Two sewage treatment systems will be installed, one at the camp site (40 person) and a smaller at the pit site (4 person). The systems will be bio-film reactors. This system is modular in design and specifically engineered for remote locations. Due to the relatively low temperatures at the site, the system will be placed in an insulated container, with possibilities for additional heating, hereby enhancing the bacterial transformations. The system is fully compatible with European regulations for wastewater treatment and meets European Water-framework Directive known as DIN EN 12566-3 for all reduction standards. The guaranteed performance specifications for the system are shown in Table 4.2.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Table 4.2 - Performance specifications for the sewage treatment system.

Domestic Waste Water Treatment System Model 40 PE

Performance Volume (inhabitants) (P.E.) Max. 50

Daily quantity of Waste Water M3/day 8

Energy consumption 230 AC (min-max) for technical functions (KWh/day) ̴ 10-25

BOD/ Concentration in outflow (mg/l) <75

Suspended Solids (mg/l) <5

Fecal Coliform Reduction (mg/l) <2

Meets requirement of Washington (USA) standard hygiene (cfu/100ml) <10 (WAC 246) , Category1- level A.

4.5.5 Solid"Waste"Disposal"

Organic refuse will be incinerated in an approved incinerator or composted, as permitted. Hazardous waste materials such as used oil containers, used oil, used oil and fuel filters, etc. will be collected and removed from site to an approved disposal facility at Kangerlussuaq. If such facilities are not available, hazardous wastes will either be incinerated at high temperature, with the ash material buried in an approved disposal site, or securely stored in containers for shipment to an approved disposal facility in Europe.

4.5.6 Tailings" Tailings (magnetic rejects) are conveyed to the storage bin. From there, the waste is backhauled approximately 6 km to the waste disposal area. Approximately 30% (85,000t/yr) of the mined material is expected to be waste. The plan is to dispose the tailings in Lake A, see Figure 4.8. To reduce the ecological impact tailings material will be sluiced in a tube down to the bottom of the lake to provide even dispersion. This method also ensures that no tailings dust floats uncontrolled on the water surface due to the water tension, and reduced the level of suspended solids in the lake surface. Leaching and mobilization tests have been completed to determine the stability of the material. Based on tailings mobilization tests, the tailings have been determined to be benign and can be safely disposed of under water. Tailings mobilization test results are included in HUD Technical Report 4.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 4.5.2. - Extent of tailings disposal in Lake A after 5, 10, 15 and 20 years

447000.000000 448000.000000 449000.000000 450000.000000

Legend 0 0 0 0 0 0 0 0

0 Road_Plan 0 0 0 . . 0 0

0 Lake Bathymetry 0 0 0 4 4 8 8

3 metres 3 7 7 -10 -20 -30 Estimated Tailings Extent Years 5 10 0 0 0 0 0 0

0 15 0 0 0 0 0 . .

0 20 0 0 0 0 0 3 3

8 20 Year Pit Outline 8 3 3 7 Benches 7 Outline 0 0 0 0 0 0 0 0 0 0 0 0 . . 0 0 0 0 0 0 2 2 8 8 3 3 7 7

447000.000000 448000.000000 449000.000000 450000.000000

Figure 4.8 - Location of Tailings Disposal Lake

4.6 Personnel Approximately 20 people are expected to be involved in the construction phase, which is expected to last approximately six months, starting in the first half of 2015, depending on permitting.

Approximately 30 full time positions are expected to be required at the mine site during operation. After taking into account rotating two shifts, approximately 57 people are required on a full time basis. The work season for the mining operations will be 9 months but the processing plant will run 10 months per year. Hudson’s objective is to have a Greenlandic workforce making up a minimum of 80% of all positions (or 46 employees). It is anticipated that with training and recruitment it could take a minimum of 24 months to achieve this target. Workforce capacity in Greenland will be assessed as part of the SIA.

A rotation of four weeks on followed by two weeks off is planned. On site workers will work 12-hour days, seven days per week. The final rotation schedule will be confirmed following further consultation with communities.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

4.7 European Facility Once the material is loaded on to a ship in Greenland it will be shipped to Europe and/or the United States where it will be offloaded and stored inside. Storage capacity for a minimum of 30,000 tonnes is required to meet demand while the mine is not shipping material for four months over the winter. At this stage the material may undergo a final processing stage called milling to reduce the mineral to a fine powder, which is then ready for feeding to the furnaces of the end-users who require a finer product. Based on discussions to date, some customers may not require a product which has undergone milling, and in this case, it will be possible to ship material directly to some customers from Greenland following storage and transloading in Europe and/or the United States. This final milling, if required, will be done using a ceramic ball mill to achieve a powder like final product (0.074 mm), see Figure 4.9. From the European facility, the material will then be loaded in to silo trucks, trains or containers for delivery to end users.

Figure 4.9 - Schematic overview of the European activities.

4.8 Alternatives Considered According to the Mineral Licensing and Safety Agency (MLSA) guidelines, the EIA shall describe the key alternatives to the proposed project.

4.8.1 Zero Alternative The “zero-alternative” is that the project not is implemented. In this case, there will be no environmental impacts outlined in this report. The Company has engaged in exploration activities with respect to the collection of large tonnage samples. Should the project fail to go ahead, the disturbed areas will be rehabilitated according to the guidelines of the MLSA. Concerning the social and economic benefits for the Greenlandic community, as described in the corresponding SIA, these will not occur.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

4.8.2 Energy Supply Alternatives The plan is to power the project facilities with a 750 kW diesel power plant, provided by two 400 kW generators. Hudson has reviewed the potential to supplement or replace this power source with run-of-river hydroelectric power and wind generated power. Neither option is viable for this project. With regard to hydroelectricity power generation, Hudson has conducted a field search for rivers and streams in the area and it was concluded that there are no streams or rivers available in the vicinity of the project that would have the flow capacity to support a run-of river hydroelectric facility. The only significant water flow in the area is from Paradise Valley across the Sondrestrom fjord from the project. The environmentally sensitive nature of the area and its location across the fjord make it an unsatisfactory hydroelectric power site. With regards to wind power, the wind is too inconsistent and unpredictable and too slow (see Figure 5.11), averaging well under the sustained 18 kph (5m/s) required for a viable wind turbine. If a wind turbine was used to supplement power, the project would still require the 750 kW diesel plant to guarantee power availability at all times. As the power requirements are relatively modest given the size of the project, it was determined that diesel generated power provides the best and only alternative for power.

4.8.3 Location of Port and Process Plant A port location was selected on the Sondre Stromfjord based on technical, environmental and socio-economic parameters. This location provides for the shortest road from the pit, resulting in the least environmental impact. The only alternative port site would be on the Itilleq Fjord on the west side of White Mountain. This would entail the construction of a much longer road (approximately 20 km) compared to the current proposed 10 km road, and, as the Itilleq Fjord is shallow at the end, it is not amenable to a port facility. Importantly, following consultation with the local stakeholders, it was determined that the Itilleq Fjord is widely used for hunting and fishing and a port at this site would have a significant negative social impact. The Itilleq Fjord is also an important fish habitat that should not be disturbed by development. It is also believed that the Itilleq Fjord area likely contains significant archaeological artifacts given its historical use. Hudson has also reviewed several alternatives for the location of the process plant. The areas examined were close to either the pit site or the tailings pond located six km from the port along the mine haul road. The port location was deemed superior as it is important to have the plant adjacent to the product storage building, which must be at the port. The two buildings will be connected by an enclosed conveyor system to limit any possible dust contamination. By grouping the port, accommodation and process plant facilities it also reduces the areas of impact by consolidating structures in one location thus minimizing the environmental footprint. It will also limit the amount of travel by roads

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

that workers will require to go to work each day. The current design allows workers to walk to work.

4.8.4 Deposition of Tailings Alternatives Several alternatives have been considered for the disposal of tailings on site. The first was land disposal. This option poses increased risk of dust contamination of the local environment from fine particles, and as such, subaqueous disposal was determined to be a more environmentally advantageous option. Several lakes were considered with Lake A being selected as the best option. It is at the head of a four-lake system which allows for natural clarification/sedimentation of the material before it is discharged to a small stream which flows approximately 14 km before discharging to the Itilleq Fjord. One additional option considered was tailings disposal in to the Sondrestrom Fjord. After consultation with experts this option it was determined to be unattractive as it is salt water and has strong currents.

4.9 Closure Plan The main objectives of the closure/reclamation plan are to: • Provide for the reclamation of all affected sites and areas to a state compatible with the original undisturbed area. • Return all altered water courses (if any) to their original alignment and cross-section. • Provide for the long-term physical and chemical stability of the project area so as to protect the public health and safety and ecosystem integrity. • Allow for natural re-vegetation and recovery of disturbed areas that is compatible with the surrounding natural environment and to allow for the future use by people and wildlife. The White Mountain Project is expected to have a mine life beyond 20 years, assuming markets and demand remain strong. At the conclusion of the project Hudson will implement the following closure plan and project reclamation: • Reclamation of the mine road and natural drainage and slope reconstruction along the road to allow for natural re-vegetation • Reclamation of the port site and covering with overburden, as needed, to allow it to naturally vegetate • Removal of all heavy machinery, process buildings and living quarters • Removal of all explosives to be inventoried and secured in a protective environment and/or an approved facility by the BMP • Removal of all remaining fuels, oil, grease and any used oil for reuse or disposal at an approved facility • Dismantle and removal of all structures • Dismantle and transport all fuel handling infrastructure to an approved facility or for reuse where applicable A detailed closure plan is shown in section 10.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

5 Environmental Baseline (Description of the area)

5.1 Physical Environment The physical characteristics of the project area include terrestrial, freshwater and marine environments. There is no ice cap located in vicinity of the mine site.

5.1.1 Terrestrial Topography The terrestrial landscapes in the Naajat area are characterized by rounded undulating mountains and moraine deposits. The area includes two large ridges, Qaqatsiap kangilerssua to the northwest and Qaqortorssuaq to the west. The ridges have an elevation of 1,330 and 1,299 meters respectively. To the south lies the impressive mountain Qaqatsiaq to 926 meters characterized by the very steep peak, Figure 5.1.

The coast near the project site consists of an undulating shoreline with relatively steep slopes continuing into the water. The bedrock at the shoreline is smoothed presumable as a result of ice scouring over time.

Figure 5.1 - Map of the terrestrial within the project area.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

5.1.2 River Continuum The freshwater resources in the area can be divided into three systems with respect to the recipient. The first water system is the rivers and lakes located in the Assivittase Valley north of White Mountain. This water system has a huge catchment area that is separated from the mining activities by White Mountain. The second “system” is the many minor rivers and creeks that drainage directs into the Sondre Stromfjord. Most of these rivers and creeks are seasonal and only water filled during the spring melt off. Beside all the small temporary creeks three smaller lakes also drainage directly into Sondre Stromfjord, Figure 5.2. The third water system is the most interesting with respect to the mining project as this system controls the drainage in the mining area. This river continuum includes five larger lakes including Lake A (the tailing lake), Figure 5.3. The drainage passage for the water is shown in Figure 5.3, the green arrows show the flow direction.

Figure 5.2 - Overview of the terrestrial topography within the project area.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Flow Meter Station 1

Flow Meter Station 2

Figure 5.3 - The water flow of the river continuum in drainage the mine area. The tailings is planned to be disposed in Lake A in the very top of the river continuum, at an elevation of 409 meters. Lake A has a measured water depth in the middle of 17.2 meters based on a 2007 drill hole. The volume is estimated to be approximately 1.37 million cubic meters.

Surface Volume Maximum Average Years to Annual Retention time (years)* Area (m2) (m3) Depth (m) Depth Fill with Outflow of (m) Tailings water (m3)

Lake A 128,978 1,366,487 17.02 10.6 24.1 -

Lake B 108,398 1,236,530 35.20 11.4 21.8 -

Lake C 110,089 1,045,188 ?? 9.5 18.4 450,000 8.1

Lake D 555,100 13,384,753 >60 24.1 236.2 1,750,000 9.7

*Lakes A, B and C taken together.

Table 5.1 - Dimensions of the lake system including the Tailings Lake A.

FP111 Global Flow Probe Digital water velocity meter

Specifications Options and Accessories

Range: 0.3-19.9 FPS (0.1-6.1 MPS) FP111 Flow Probe Accuracy: 0.1 FPS (3.7' to 6' handle) including carrying case. Note pole color of Averaging: True digital running average. Updated shipped instrument may be different than shown once per second. Display: LCD, Glare and UV Protected EnvironmentalControl: 4 button Impact Assessment (EIA) - WhiteFP111-S Mountain Flow Probe Anorthosite Mining Project Datalogger: 30 time and date stamped data sets (3.7' to 6' handle w/swivel) Features: Timer, Low battery warning, and End of including carrying case. Note data warning pole color of shipped instrument Sensor Type: Protected Turbo-Prop propeller with may be different than shown Themagnetic bathymetry pickup. of the lakes and the water flow out of the lakes are important in

calculatingWeight: the retention time of water with in the lakes. High retention time is equivalent Instrument: 2 lbs. (0.9 kg) (FP111), 3 lbs. (1.4 tokg) (FP211) a reduced spreading of contaminants butFP211 also Flow higherProbe accumulation of leaching elements. Shipping: 10 Thelbs. (4.5 outflow kg) (FP111), from 13 lbs. Lake (5.9 A goes directly(5.5' to 15' Lak handle)e B, including which carrying is morecase. Note or pole less color all of one lake.kg) ((FP211) From Lake B, the drainage is through a smallshipped instrumentcreek approximatelymay be different than shown. 300 meters long Expandable Length: 3.7 to 6 ft (1.1 to 1.8 m) in to Lake C. From Lake C the outflow at the northwest corner is through a small creek (FP111); 5.5 to 15 ft (1.7 to 4.6 m) (FP211) FP211-S Flow Probe approximatelyMaterials: 1,000 meters in length to Lake (5.5'D. toLake 15' handle D isw/swivel) the largest of the lakes in the system Probe: PVC located and anodized an aluminumelevation with of 397 meters andincluding has carryingan estimated case. Note capacity of 13.4 million stainless steel water bearing cubic meters of water. The total distance pole for color water of shipped flow instrument from the area of tailings Computer: ABS/Polycarbonate housing with may be different than shown. depositionpolyester overlay to exiting the lake system is five kilometers and the differences in elevation Power: Internal Lithium Battery, Approx 5 year life, between Lake A and Lake D is 12 meters. Non-Replaceable

Operating Temp: -4° to 158° F (-20° to 70° C) TheStorage water Temp: -22° flow to 176° in Fthe (-30° laketo 80° C) systems was measuredFlow Probe in 2014. Replacement Dams Parts: with weirs and flow measurementCarrying Case: The Flow equipment Probe is shipped were in a established JuneBA2000 1, 2014Digital Flow at Computerthe outflow of Lake C and D (paddedsee Figurecarrying case. 5. 3). Measurements were taken BG0000 with aProp/Bushing/Screw hand held Kit flow meter (Figure 5.4) Approvals: CE 00-155 FP111 Carrying Case and cross referenced with the pressure calculations00-082 collectedFP211 Carrying using Case the dams.

Figure 5.4 - FP111 Global Flow Probe Meter

Drainage from Lake D is via one outflow point, which is a small creek on the south end. This creek then flows west along a naturally occurring fault down to the Itilleq Fjord, over

a distance of approximately 13.5 km. The results, presented below in Table 5.2, detail a minimum of 5.2 years and a maximum of 9.7 years that water is retained in the lake system. Station 1 includes Lakes A, B and C. Station 2 includes the input from Station 1 and all of Lake D. Complete calculations are available in HUD Technical Report 6.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Constructed June 1, 2014 Near High Water Mark – June 14, 2014 No Flow – August 10, 2014

Figure 5.5. Flow meter station at outflow of Lake C.

Constructed June 1, 2014 Similar Flow Rate – June 14, 2014 No Flow – August 10, 2014

Figure 5.6 - Flow meter stations at outflow of Lake D.

Measuring Station Stream Maximum Annual Lake Volume Retention Time Flow Flow Rate Flow (days) (1000t/d) (tonnes)

Year 1 Year 20 Year 1 Year 20

Station 1 (Lake C) 75 12 450,000 3,648,205 2,348,205 8.1 5.2

Station 2 (Lake D) 100 35 1,750,000 17,032,958 15,732,958 9.7 9.0

Table 5.2 - Annual Flow Rate Exiting Lake C and Lake D

5.1.3 Lake Bottom Geology In 2007 Hudson drilled in the middle of Lake A and Lake B and at the edge of Lake D as a part of the geological survey. The drill core logs identified the lake bottom as anorthosite with some mafic banding. Drill core indicated little to no mud or sediment on

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

the lake bottom. Lake C was not drilled but geological mapping indicates that Lake C is underlain by anorthosite.

5.1.4 Bathymetry The Sondre Stromfjord is 180 km long and consists of two parts: an inner part, which is wide (about 4 km) and deep (up to about 275 m) and an outer part that is relatively narrow (about 1 km) and shallow (25–100 m). The outer shallow part is 100 km long and influences the exchange of water between the inner deep parts of the fjord with the ocean. Thus, the water mass in this inner part of the fjord is almost ligated from the offshore ocean. The narrow and shallow part occupies approximately half of the fjord and, does not resemble a typical threshold as found in many other Arctic fjords, (Nielsen, et al., 2010). In the intertidal zone the steep costal slopes are continuing into the water and result in water depths above 15 meter close to the coast.

5.1.5 Geology Hudson’s White Mountain Project is located next to Sondre Stromfjord in central West Greenland. This Archean (~3000 Ma) calcic anorthosite has been preserved as a nearly un-deformed “island” within the southern margin of the Proterozoic Nagssugtoqidian fold belt. Project geology shows the anorthosite is cut by minor northerly striking, un- deformed mafic dikes with near vertical dips and less than 25 meters thickness.

Figure 5.7 - Project geology – White Mountain anorthosite.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Within the project area, the calcic anorthosite is lenticular in shape with an east-northeast trend, covering a surface area of over 20 square kilometers.

Mapping and field investigations in 2012 by Hudson technical staff have shown the calcic anorthosite within the property to be an elongate layered body with a strong east- northeast structural trend and a north-northwest (25-40 degree) dipping plunge. The anorthosite appears to be the central portion of an Archean “island” block cut by un- deformed mafic dikes with only minor Proterozoic (Nagssugtoqidian) deformation, Figure 5.7.

Greater than 90 percent of the exposed anorthosite body is composed of nearly pure high calcium (bytownite) plagioclase with only minor zones of mafic dikes, shear induced amphibolite foliation, weak to moderate plagioclase crushing, and very minor muscovite and clinozoisite.

5.1.6 Climate The proposed project site is located in the Arctic region with mean monthly air temperature below 10 °C. As no meteorological data are present for the proposed mine site, the Company has chosen to use climate data from Sisimiut and Kangerlussuaq climate stations, as the proposed site is situated more or less in the middle between of these two stations. See: (http://weatherspark.com/averages/27554/Kangerlussuaq-S-ndre-Str-mfjord-Kitaa- Greenland) The climate regimes at the two stations are characterized by costal climate (Sisimiut) and continental climate (Kangerlussuaq). As the wind and precipitation on the Greenlandic West coast is controlled by low-pressure passages drifting north following the West coast the proposed project site (inland) has a climate regime most similar to Kangerlussuaq. Figure 5.9 compares the average of monthly rainfall amounts in Sisimiut and Kangerlussuaq in 2014 to the average climate data for the period 1961 to 1990. The chart shows that 2014 was a dryer than normal year. The Danish Meteorological Institute lists the annual and monthly precipitation for Kangerlussuaq for the years 2000 through 2014 and the 1961 to 1990 total average precipitation of 151mm. The average amount for the past 15 years is 166mm, 15mm higher than the historical average. The highest amount was recorded in 2000 at 218mm and the lowest amount was recorded in 2014 at 82mm. The standard deviation is 44mm. The average annual minimum and maximum temperatures lie within the range of – 22 ° C and +11 °C with Kangerlussuaq showing the greatest variability, Figure 5.8 below. The average annual precipitation varies between 4 mm and 52 mm for the two stations with the largest amount of precipitation falling in August in both places. The average annual

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

amount of precipitation is more than twice as large in Sisimiut (382 mm), which is situated on the coast, compared to Kangerlussuaq (150 mm) which is situated inland. The wind conditions in Kangerlussuaq are generally light, see Figure 5.10, with average monthly wind speed between 3.2 and 4.1 (m/sec) and the maximum wind speeds occur during the winter months with November having the highest wind speed of 19.6 (m/sec).

Climate$Data$ Sisimiut'1961+1990'+'Kangerlussuaq'1973+1999' $ $

20$ °C) 10$ 60$ 0$ !10$ 30$ !20$ PrecipitaEon$(mm)$

0$ !30$ Mean$air$temperature$( Jan$ Feb$ Ner$ Apr$ May$ June$ July$ Aug$ Sept$ Oct$ Nov$ Dec$ The most frequent wind direction is from the Northeast, as seen in Figure 5.10.

Figure 5.8 - Average air temperature (C) Kangerlussuaq, Sisimiut and precipitation (mm) Kangerlussuaq precipitation (mm), Sisimiut , source Danish Meteorological Institute.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Average"of"Sisimiut"and"Kangerlussuaq" Monthly"Precipita_on"

70% 60% Annual"Total" 50% '61%T%'90:%267mm% 40% 2014:%%%%%%218mm% 30% 2014% 20% 1961%T%1990% Precipita_on"(mm)" 10% 0% Jan% Feb% Mar% Apr% May% Jun% Jul% Aug% Sep% Oct% Nov% Dec% 2014% 13.5% 4% 9% 17.5% 9% 9.5% 3.5% 65.5% 41% 26.5% 12.5% 6% 1961%T%1990% 12% 12.5% 13.5% 17% 13.5%22.5% 34% 42.5%34.5% 25.5% 24.5% 15%

Figure 5.9 – Comparison of 2014 precipitation to long range average monthly amounts

Figure 5.10 - Wind directions over the entire Year

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 5.11 - Wind speed data from Kangerlussuaq for the period from 1974 through 2012. The climate regime at the proposed project site is classified as a polar continental climate regime similar to Kangerlussuaq with cold and dry winters with relatively weak wind and generally little precipitation throughout the year. Although snow can fall in summer, the area is usually ice and snow free from May to late September.

5.1.7 Noise The area is very remote with no human activities. The only noise derives from birds, wind and overflying airplanes at high altitude.

5.1.8 Dust Presence of locally generated dust is negligible, due to the relative high coverage of vegetation.

5.2 Terrestrial Environment

5.2.1 Vegetation The White Mountain project area belongs to the continental zone of West Greenland. The vegetation zone is low arctic. The terrestrial baseline surveys in 2012 and 2013 noted that the vegetation habitats are widespread, as in West Greenland in general. The

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

vegetation habitats are dwarf shrub heath, open heath, fen, grassland and lake. Beach vegetation and willow copse are sparse in the project area. The vegetation habitats snow bed and herb slope were not found at all (Feilberg, 2013). Overall the vegetation found in the project area is similar to the regional vegetation, as shown on the vegetation map in Figure 5.12. During the terrestrial baseline surveys in 2012 and 2013 there were observed 118 plant species. A list of all plant registration is available in HUD Technical Report 1. All of the observed species were found inside their known distribution in Greenland. However two species, Dryopteris fragrans and Calamagrostis lapponica var. groenlandica, were found near to their southern limit. During the field studies in 2013 an orchid plant was observed, the small Round-leaved Orchid (Amerorchis rotundifolia), Figure 5.14, which has not been registered in the area before. The orchid was found in seven locations in the area, and in large numbers, corresponding to an area covering over 3 km., see Figure 5.13. Previously, the species was only known in considerable numbers from minor areas near Narsarsuaq in South Greenland and a small area near Kangerlussuaq Airport ( (Boertmann, 2007) and (Feilberg, 2013).

Source (Tamstorf, 2001) Figure 5.12 - The Vegetation habitats in and around the project area.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Much of the biology of Amerorchis rotundifolia is unknown. It generally flowers in June, but information regarding pollinators, potential herbivores, preferred microhabitats, and mycorrhizal associations is lacking (St. Hilaire, 2002). The orchid uses both vegetative and sexual reproduction, the latter with seeds that are spread by wind. (Handley, 2005) A feature of Amerorchis rotundifolia, as common to terrestrial orchids, is the presence of a dormancy phase. The maximum dormancy of most orchids is usually less than three years (Handley, 2005). Dormancy is difficult to distinguish from mortality, especially in short-term studies (Menges, 1991) Due to the wind spreading of seeds, it is possible that the observed clones of the orchid within the project area derive from the plants in Kangerlussuaq. Having in mind that the area between the project site and Kangerlussuaq hasn’t been subjected to any detailed botanical mapping, it is possible that the orchid is found at numerous locations along the fjord, hereby establishing a natural spreading corridor. To protect the orchids, marking tape around the findings in vicinity of the mining activity has been established, and the workers have been given instructions to pay attention to these areas.

Figure 5.13 - Location of the small Round-leaved orchid (Amerorchis rotundifolia).

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 5.14 - Amerorchis rotundifolia at a moist heath near WM04.

5.2.2 Terrestrial Wildlife Several sources of information on terrestrial wildlife in and around the Project site are available. GINR conducted general wildlife surveys by helicopter across south-western Greenland in March 2005, 2006 and 2010, and included five study regions: Naternaq, North, Central, South, and Paamiut. The Project is located within the North survey region. In general, these surveys indicated that the terrestrial ecosystem of western Greenland has poor mammalian diversity. Wildlife species observed within the North Region included caribou/reindeer (Rangifer tarandus spp.), muskox (Ovibos moschatus), arctic fox (Alopex lagopus) and arctic hare (Lepus arcticus). Additionally, few terrestrial avian species reside in western Greenland year round, including ptarmigan (Lagopus mutus) and the white-tailed eagle (Haliaeetus albicilla). Specifically, during the 2005-2006 field studies 145 muskox, 8 fox, 37 hare, 605 ptarmigan and 1 white-tailed eagle were observed within the North Region ( (Cuyler et al, 2009). All of these species most likely occur within and in the vicinity of the Project Site (Cuyler et al., 2012).

5.2.3 Birds The proposed project site at White Mountain holds few bird species, which all are common and widespread in West Greenland. The key bird species observed within and near the project area are shown below.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

The observed species were:

• White-Tailed Eagle (Haliaeetus • Northern Wheatear (Oenanthe albicilla) oenanthe)

• Peregrine Falcon (Falco peregrinus), • Arctic Redpoll (Acanthis hornemanni)

• White Fronted Geese (Anser albifrons) • Lapland Bunting (Calcarius lapponicus) • Canada Goose (Branta canadensis) • Raven (Corvus corax) • Read-Throated Diver (Gavia stellata) • Ptarmigan (Lagopus mutus) • Great Northern Diver (Gavia immer) • Glaucous Gull (Larus hyperboreus) • Snow Bunting (Plectrophenax nivalis)

5.2.3.1 The White-Tailed Eagle The White-Tailed Eagle (Haliaeetus albicilla) eagle is Greenland's largest breeding bird. It lives primarily on fish such as cod and char, but also on sea birds such as eider. The white tailed eagle is present at several locations in the Sondre Stromfjord area where they typically nest on ledges on steep cliffs or hilltops at the fjord site. The white tailed eagle probably nests in the Itilleq fjord area, where one eagle has been observed twice. The adult white-tailed eagles typically remain in the area during winter, while young birds migrate to south Greenland (GINR, 2013). The white tailed eagle is listed as “vulnerable” on the Greenland Red List of threatened species (Boertmann, 2007).

5.2.3.2 The Peregrine Falcon The Peregrine Falcon (Falco peregrinus) are frequently found in the Sondre Stromfjord area where they typically nests on ledges on steep cliffs in the inland. The falcons probably nest in the Itilleq fjord area, where three falcons have been observed on one occasion. Peregrine Falcons mainly feed on medium-size birds. It is a migrant that arrives in May, presumably from South America, and departs in August-November, (Burnham & Mattox, 1984). It is listed as “least concern” on the Greenland Red List of threatened species, and lately the population has been found to be stable or increasing slightly (Boertmann 2007). The greatest threat to the peregrine falcon in Greenland is disturbance in the nesting area.

5.2.3.3 The Gyrfalcon The gyrfalcon is a circumpolar species and evaluated as “near threatened” on the Greelandic Red List, as the population has been stable the latest 15 years, (Boertmann, 2007). The gyrfalcon is larger than the Peregrine falcon and shows considerably more contrast in plumage and varies in color between pure white and dark grey, (Burnham & Mattox, 1984). The gyrfalcon is like the peregrine falcon a migrant, however seasonal

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

migration distance is less than the peregrine falcon. A study using GPS-tracking found that gyrfalcons are associated with sea ice far from land during the winter, presumably hunting sea birds, (Burnham & Newton, 2011). The diet of gyrfalcon in the breeding areas relied heavily on Rock Ptarmigan (Lagopus mutus) and arctic hares (Lepus arcticus). Combined, these species contributed 79–91% of the total diet. All Rock Ptarmigan were adults, and all but one arctic hare were young. (Booms & Fuller, 2003). The greatest threat to the gyrfalcon are disturbance in the nesting area and illegal collection of juveniles, (Boertmann, 2007). No gyrfalcons were observed in the White Mountain area during the the thee years of survey (2012-2014), thus the area is not expected to be a breeding area for the gyrfalcon.

5.2.3.4 The White Fronted Geese The White Fronted Geese (Anser albifrons) only nest in Greenland in an area between the Maniitsoq Icecap and the southern part of Upernavik. It is nesting in fens and tundra areas and winters in the British Islands. The Kangerlussuaq area holds an important spring staging area to the White Fronted Geese in Western Greenland presumably a consequence of the migration route across the ice cap (Glahder, 1999). A number of known resting locations have been identified, with one location in the valley west of the project site, Figure 5.15.

Project Area

Figure 5.15 - Map of the staging area for White fronted Geese in the Kangerlussuaq area

In June 2013, one breeding pair were observed at St.L-11 (approximately 2.5 km from the pit site). The White Fronted Geese is listed on the Greenland Red List of threatened species as Moderate endangered (Boertmann, 2007).

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

5.2.3.5 The Red-Throated Diver The Red-Throated Diver (Gavia stellata) is common in Greenland, where it breeds at small lakes and ponds, while it mainly forages in the sea/fjords. It is a migratory bird that winters in Northwest European coastal waters. The Red-throated Diver is on the Greenland Red List of threatened species listed as Least Concern (Boertmann, 2007).

5.2.3.6 The Great Northern Diver The Great Northern Diver (Gavia immer) is widely distributed in Greenland. Its northern boundary on the west coast is Upernavik and on the East coast up to Denmarks Fjord (Boertmann, 2007). In the Qeqqerta community a stock density of 3 pair on 350 square kilometers has been reported (Boertmann, 2007). It breeds in Greenland, where it is normally found in larger lakes holding stocks of Arctic Char. It leaves Greenland in wintertime and winters along the east coast of North America (Boertmann, 2007) The Great Northern Diver is on the Greenland Red List of threatened species listed as Nearly threatened (NT) (Boertmann, 2007).

5.2.3.7 Canada Geese Canada Geese (Branta canadendsis) are wide spread throughout the central parts of western Greenland, and have increased rapidly in recent years. The first specimen was observed in the 1950’s. Since then the Canada goose has become more common and was in 1990 described as the most common breeding geese on Disco Island. In 1988 the species was observed in an area close to Kangerlussuaq, not far from Hudson’s Naajat property, (Fox, et el, 1996). In 1999 an aerial survey with a transect crossing the Naajat area, was performed registering 33 single or pairs. This resulted in an estimate of 0.25 breeding pairs per sq. km, making the Sisimiut-Kangerlussuaq area the highest density of Canada geese known in Greenland (Malecki et al., 2000). However, in the same survey no breeding Canada geese were observed south of 66°45’ northern latitude thus, no Canada geese were observed to breed in the Naajat area (66°30’). Lately a few Canada geese have been found to breed as far south as Nuuk and Maniitsoq, (Fox, et al., 2011).

5.2.3.8 Other Birds The Snow Bunting (Plectrophenax nivalis), Arctic Redpoll (Acanthis hornemanni), Lapland bunting (Calcarius lapponicus), Northern wheatear (Oenanthe oenanthe), Raven (Corvus corax), Ptarmigan (Lagopus mutus) and the Glaucous Gull (Larus hyperboreus) are common breeders at low to medium altitude along the Sondre Stromfjord. These

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birds are common and widespread throughout south and west Greenland and not subject to any threats.

5.2.4 Mammals Terrestrial mammals found in the project area are caribou (Rangifer tarandus), muskox (Ovibos moschatus), arctic hare (Lepus arcticus) and arctic fox (Alopex lagopus). While caribou are found in the entire region, the muskox is mainly distributed in the area south and east of Kangerlussuaq (Johansen, 2008). The terrestrial baseline surveys in 2012 and 2013 included a registration of wildlife at all stations. The surveys showed that the presence of caribou, muskox and Arctic fox were scattered. Arctic hare were widespread in the area.

5.2.4.1 Caribou Caribou (Rangifer tarandus) are an important species to the Greenlandic society and are present in limited numbers within the White Mountain project area. The caribou population in the project area are part of the population at the Kangerlussuaq-Sisimiut (KS) area. The pre-calving population is estimated to about 98,300 animals according to a survey from 2010, conducted by the Greenland Institute of Natural Resources (www.natur.gl), (Cuyler, 2012). This KS-area population is bounded by natural barriers in the landscape (www.natur.gl). The diet is grass, dwarf shrub, fen, lichen etc. (Lund, 2000). About 90 km east of White Mountain is an important calving area (Figure 5.17).

Figure 5.16 - Caribou observed within the White Mountain Area.

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(www.NunaGis.gl).

Figure 5.17 - Caribou calving areas far from mine site

Project area

Figure 5.18 - The March 2010 distribution of the Kangerlussuaq-Sisimiut caribou in the NORTH region.

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According to Cuyler et al, 2012, the overall density of caribou is approx. 7 animal/km2 in high-density areas and 2.5 animal/km2 in low-density areas. The scattered distribution is seen in Figure, (Cuyler et al., 2012). As seen from Figure 5.18, the density of caribou in the project area is very limited. This correlates with observations made during the three field surveys where only a few caribous (< 15) were observed. The observations were made either by foot or from helicopter. Data exists only for those cells with colour. According to local hunters the main caribou population prefer the far side of the ridge north of the project and other areas closer to Kangerlussuaq.

5.2.4.2 Muskox The muskox (Ovibus moschatus) was introduced from east Greenland to a location south of Kangerlussuaq (Angujaartarfiup Nunaa) in the 1960s. They are primarily grazers adapted to a diet of sedges and grasses. They calve in early spring before the snow melts (Dunn et al, 2013). Muskox typically live in mixed sex and age herds or in small male bachelor herds. They move seasonally between ranges depending on the snow cover. The introduction was very successful and the initial stock (27 animals) is now expected to have grown to between 18,000 – 31,000 animals (Cuyler et al., 2012). The Muskox has spread from the original releasing area, so they now are abundant in all the area south of Kangerlussuaq but also in the area between Kangerlussuaq and Sisimiut. Figure 5.19 shows the area accessible for this stock. Random observations of the muskox and other terrestrial mammals in West Greenland were made in 2005, (Cuyler et al, 2009) and these observations are the best data available to describe the distribution and relative abundance of the muskox in the area. Based on these observations an index of abundance was calculated using the same stratification for animal densities employed to estimate caribou abundance (Cuyler et al, 2009). The observations were made in a large area, called the North Region, between Nordre Stromfjord and the Sukkertoppen Ice Cap, see Figure 5.19. Most of the animals are in the core muskox range south of the Kangerlussuaq airport. The latter is supported by the literature review (Johansen, 2008), who concluded that the highest densities of muskox were to be found in the area south of Kangerlussuaq and especially in the Sarfartoq valley.

Muskox are also present within the project area, although probably only strafing animals. During fieldwork in 2012 and 2013 no live animals have been sighted only remnants as shown in Figure 5.20. There has been quota hunting on the population since 1988, but it is not always possible to use the quota fully (Johansen, 2008).

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Angujortarfiu p Nunaa

(Cuyler et al, 2009). Figure 5.19 - Accessible area for Muskox in the North Region. Source:

Figure 5.20 - Remnants of Muskox within the Hudson project Area.

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5.2.4.3 Arctic Fox Arctic fox (Alopex lagopus) are widespread in West Greenland (Johansen, 2008). During the terrestrial surveys in 2012 and 2013 one arctic fox was observed. Their diet is fish, mussels, hare pups, bird eggs, young birds, etc. (Gensbøl, 2005). The knowledge about the abundance of arctic fox is limited (Cuyler et al., 2012). There are estimated to be about 2,100 arctic foxes in the North region (Figure 5.21) (Cuyler et al., 2012).

5.2.4.4 Arctic Hare Arctic hare (Lepus arcticus) are widespread in West Greenland (Johansen et al., 2011). During the terrestrial surveys in 2012 and 2013 there was one hare observed (Feilberg, 2013). This is not surprising because the hare is a shy animal. The arctic hare is a herbivore and the diet is woody plants, buds, berries, shoot tips, and grasses (Gensbøl, 2005). While knowledge about the abundance of arctic hare is limited, the population has been estimated to be 12,667 arctic hares (Cuyler et al, 2009). Figure 5.21 shows the location of hare observations in the North Region. The figure also shows the areas with high density.

(Cuyler et al, 2009).

Figure 5.21 - Locations of eagle, fox and hare observations in the North region, March 2005

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5.3 Limnetic (Open Water) Environment The limnetic, or open water, environment in the project area includes several lakes (considered as a closed ecosystem) and rivers (considered as open ecosystems). One major river system with many large and smaller lakes drains the project area. This river system arises from a small lake 1.75 km upstream of Lake A (See Figure 5.2). The rivers can be divided into two categories in accordance to the physical environment, with water velocity as the primary ecological driver: 1) High current velocity and stones and boulders; and 2) Low current velocity and fine sediments. The organisms living in each of these habitats are highly adapted to their environments. The species diversity is lowest in the turbulent habitat were only benthic algae attached to stones are found and most invertebrates graze on this algae coverage. In the rivers with low current velocity primary-production is mainly in form of benthic algae, mosses and macrophytes. The nutrient level is supplied with organic material from the surroundings, and the fauna now includes detritivores and carnivores also. Rivers downstream of these lakes will be strongly influenced by the water environment in the lake where the primary-production and temperature is higher than rivers with no connection to lakes, (Born & Böcher, 2001). The rivers found in the project area covers all of these river habitats. The lakes are closed or semi-closed systems where the retention time is controlled by inflow and outflow of water. Lakes with high retention time will, during the summer period, have increased temperature in the upper water layer due to sun radiation. This will occasionally result in a relatively high primary-production if the supply of nutrients is sufficient. The high production in lakes may cause very high abundances of midges and blackflies at the outlet from lakes, (Born & Böcher, 2001).

5.3.1 Water Quality The freshwater system contains a number of clear water lakes and creeks (see Figure 5.21). Some of the lowlands lakes have a slightly “brownish/yellow “ colour due to humus washed out from fens at higher altitude. The physical and chemical conditions of the freshwater were measured at five stations, Figure 5.22. The physics of the water were measured in situ. The temperature increase from the source to the outlet in 2012 was 4.2°C (from 8.7°C to 12.9°C) and in 2013 the increase was lower at only 0.9°C (from 5.3°C to 6.2°C). This difference is a consequence of interannual differences in precipitation, solar influx and air temperature. The temperature measurement at St. 31. was high because it was the surface water from Lake D. The pH values in the system were general slightly alkaline, but within the normal range for Western Greenlandic freshwaters (Johansen et al., 2011). The amount of total dissolved solids was on average 200 mg/l, four times the level in the guidelines, which was surprising and no logical explanation can be found.

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Figure 5.22 - Map showing the station of water samples in both 2012 and 2013.

Table 5.3 - Result of in situ measurements of physical parameters in the project area.

Station Year Parameter 20 21 22 23 30 31 WM7 2012 pH 7.72 7.87 7.46 7.93 7.33 - - Conductivity (mS) 0.571 0.776 0.307 1.06 0.179 - - Turbidity (NTU) 36.7 15.5 13.5 - - - - Total suspended solids (TSS 125.6 53.0 46.2 - - - - mg/l)** DO (mg/l) 12.09 13.26 12.63 10.06 - - - T (° C) 8.5 13 12.9 12.9 8.7 - - Total dissolved solids* (mg/l) 230 410 190 33 120 - - ORP* (mV) 77 132 81 116 114 - - 2013 pH - 7.2 7.66 8.24 7.41 7.03 7.03 Conductivity (mS) - 0.092 0.123 0.446 0.134 0.039 0.1 T (° C) - 4.7 6.2 6.2 5.3 8.1 2 *BMP water quality guidelines for TDS = 50 mg/l. **TTS value is converted with: TSS =3.4216*NTIU, (Brezenski, 2011). * - ORP – Oxidation-reduction potential

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The chemistry in the filtered and unfiltered water samples collected during the baseline was analysed. As expected, higher values for most elements were found in the unfiltered compared to the filtered sample. This is because elements incorporated into biological organisms were filtered out in the filtered samples. Naturally high background levels of copper in relation to the guidelines set by BMP were found at all stations and high levels of nickel were found at St.30 only. The source of these elevated copper values is due to the local geology outside of the anorthosite body (occurrence of copper levels >300ppm). The GEUS stream sediment sampling study (Figure 5.23) illustrates the high copper levels in the region. Higher levels (but still well below government guidelines) of cadmium, zinc and chromium were found at st.30. The concentration of these metals decrease slightly downward from the river continuum indicating that the source of these higher concentrations has to be found up-stream st. 30.

Table 5.4 - Result of water sample analyses from the project area collected in 2012. (As) Arsenic (Cd) Cadmium (III)) (Cr Chromium (Cu) Copper (Fe tot) Iron Lead (Pb) (Hg) Mercury Nickel (Ni) Zinc (Zn) s (P total) Phosphoru

Station

Detection limit (µg/l) 0.77 0.003 0.046 3.9 1.6 0.031 0.012 0.21 0.7 3

St 20 Unf

St 20 filtered

St 22 Unf

St 22 filtered

St 21 Unf

St 21 filtered

St 23 Unf

St 23 filtered

St 30 Unf

St 30 filtered

BMP water quality guidelines in 4.0 0.100 3.000 2.0 300 1.0 0.05 5.0 10 20 freshwater

All figures in µg/l

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Figure 5.23 - Stream Sediment data from GEUS showing elevated copper in the area.

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5.3.2 Vegetation In the wintertime, lakes and most rivers around Kangerlussuaq are covered with thick ice and the influx of light is limited. Thus, the freshwater vegetation is subjected to a very short intensive growth season having almost 24 hours of sunlight in midsummer. In deep wind exposed lakes the impact from ice may prevent colonization of vegetation. This may be the explanation for the sparse vegetation in the northwestern part of Lake D. The most abundant aquatic plant species in lakes in Greenland is the amphibious Common Mare’s Tail (Hippuris vulgaris) since it is well adapted to great fluctuations in water levels (Pedersen & Brodersen, 2003). This species is also found in the project area and is registered at station 20, Figure 5.24. The coverage of vegetation in rivers in the area is low. The most widespread freshwater vegetation in the rivers in the project area is the Willow Moss that has been found at all stations investigated. However, the coverage of this was moderate, and in all cases below 5% (Table 5.5). No endemic or protected freshwater plant species are found in the area.

Figure 5.24 – Common Mare's Tail at station 20.

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Table 5.5 - List of the registered freshwater vegetation in the project area.

Species Species (Latin) 2012 2013 20 21 22 23 30 21 22 23 31 Moss* Fontinalis ssp. <5 <1% <1% <1% <1% <2% <1% Common Mare’s Hippuris vulgaris <20 tail Greenlandic Potamogeton <5 pondweed groenlandicus Northern Ranunculus <1 <1% buttercup hyperboreus White-Water Ranunculus <1% <1% buttercup confervoides Variegated Equisetum <2% <1% <1% <1% <1% Horsetail variegatum Slender-leaved Stuckenia filiformis <80% <2% <30% pondweed Common Equisetum arvense <1% Horsetail *most likely the genus Fonitalis.

5.3.3 Fauna In connection to the baseline, five stations were examined to study the macro- invertebrate community. Freshwater is the habitat for many insect larvae. The most diverse and dominant order are diptera, flies and mosquitoes. They make up more than 50% of the insects species found in Greenland, (Zoologisk Museum, 2001). The two major families are Simuliidae ssp. (blackflies) and Chironomidae ssp. (non-biting midges). The highest number and diversity of macro-invertebrates was expected to be in the fish-free section of the stream. However, this turned out not to be the case. The highest diversity was found at Station 21 at the end station of migrating char. The habitat of this station is highly diverse and includes both minor sandy pools and large stony areas.

Stations, 2012 Stations, 20131 Order 20 21 22 23 30 21 22 23 30* 31 Diptera (Simuliidae ssp) + + + + + + + + Diptera (Chironomidae ssp.) + + + + + Oligochaeta + + + Tricoptera + Ephemeroptera (Baetis spp.) + + Hirudinea + Hygrophila (Lymnaea - family) + + + Veneroidae (Sphaeriidae - + family) *No surface water flow due to dry summer. Table 5.6 - Observation of invertebrate groups (Orders) in the Naajat area.

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In Greenland only one species of Ephemeroptera (Baetis Macani) has been registered. This species are spread throughout western Greenland, including the Kangerlussuaq area and the project area.

5.3.4 Fish The rivers in southwest Greenland remain ice-free for longer periods than other rivers in Greenland due to the region’s moderate climate. In Greenland two species of freshwater fish are abundant, the Arctic char (Salvelinus alpinus) and the three-spined stickleback (Gasterosterus aculeatus). The sticklebacks remain relatively stationary with only modest migration. Arctic char may migrate but do not appear to display a strong affinity to natal streams, as is common for many salmonids species otherwise ( Doris North Mine, 2005). Arctic Char The Arctic char is one of the most widespread and important fish in Greenland. Near the project there are two river systems that carry populations of Arctic char. The largest population is found in the Aussivit valley where the population has been registered as an important fishing area, Figure 5.25 (Nielsen et al., 2000). The juvenile char is characterised by the “parr marks” and lives entirely in freshwater in the first years. At the age of three, some, but not all of the juveniles change life strategy and become silvery and migrate towards the ocean for summer feeding since the food supply is higher there. The oceanic migration takes place during May-June. In the ocean the char normally stay in close proximity to the river mouth for the summer before they migrates back to the river to spawn and overwinter. These Char attain a maximum size of around 70-80cm. In the Post-parr period some of the juvenile fish remain stationary and live their entire life in freshwater lakes or rivers. Since there is less food in these environs, these Char attain a maximum size of approximately 25cm. Spawning takes place in September-October in habitats of gravelly or rocky substrates in lakes or quiet pools in rivers. The eggs hatch in April the following year. At White Mountain, an freshwater aquatic field survey focusing on arctic char was completed in 2012 and 2013 to establish the presence or absence of these, estimate their population, and determine if they were migratory char. A total of six stations were investigated for fish, Figure 5.26. Arctic char were only observed downstream of station 21. This indicates that the waterfall at station 21 prevents further upstream migration. This was confirmed by the electrofishing at station 21, where fishing efforts were made both up and downstream of the waterfall. A relatively high number of char (5-10) were caught in the pool just in front of the waterfall, whereas no char were found immediately upstream. The waterfall is shown on the right side in Figure 5.26.

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Figure 5.25 - Fishing area for Arctic Char in Itilleq fjord. The overall population estimate in the Itivdlinguaq river continuum downstream from station 21 was 0.26 individuals per m2 in 2012 and 0.55 individuals in 2013, Figure 5.27. Overall 8% of the arctic char caught in 2012 and 2013, were migrating char, and they were caught at St.22 and St.23 only. The elevation of Lake 40 is low (40m above sea level) and the water current is relatively slow. The river habitats are mainly sand, interrupted by areas with stones/gravel and a few minor pools. The water depth in this part of the river is generally less than 0.5 meters, on average. The highest densities of Arctic char were found at Station 23 (0.73 individuals per m2) close to the outlet into the ocean and at St. 22 (0.80 individuals per m2) a few hundred meters upstream of Lake 40, Figure 5.26. From Lake 40 the terrain elevation increases significantly towards St. 21.

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Figure 5.26 - The stations investigated for arctic char in 2012 and 2013.

Figure 5.27 - Population estimates of Arctic char in the project area. The numbers of char found in the project area are similar to densities found other places in Western Greenland, Table 5.7.

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Table 5.7 - Densities of Arctic char found in Western Greenland.

Area Stationary and juvenile Anadromous All Naajat , August 2012, pr. m2 0.17 0.09 0.26 Naajat , September 2013, pr. m2 0.50* 0.05 0.55 Sarfartoq, , August 2012, pr. m2 0.30 - 0.30 Robinson River, August 2012, pr. m2** 0.004-0.28 - - Narsaq, October 1981, pr. m2 1.09 0.4 1.49 Quengua, Narsarssuaq, main river 0.09 0.16 0.25 Quengua, Narsarssuaq, tributary 0.55 0.12 0.67 Nanortalik, Itillersuaq 1988 0.12 0.1 0.11 Qapiarfiusap serma, Maniitsoq 0.15-0.96 - - *0.34 Ind. m2 was juvenile less than 8 cm. **selected stations comparable to Naajat. Three-spined Stickleback The three-spined stickleback is the most common fish species in rivers and lakes in western Greenland. At White Mountain, all sampled stations, except Station 30, held a population of three-spined sticklebacks. This species was observed in high numbers in both creeks and lakes. The role of this species is important in lake ecology as it canalizes energy from the planktonic stage up the food chain to Arctic char and piscivorous birds.

5.4 Marine Environment The marine environment around the project area contains two fjords that differ significantly. The Sondre Stromfjord receives significant volumes of glacial material from the interior icecap. The Itilleq fjord is the recipient of the freshwater outflow from the project area. The harbour will be located in the Sondre Stromfjord. No activity will take place in the Itilleq fjord.

5.4.1 Water Quality The coast near the project site is characterized by an undulating shoreline with relatively steep slopes continuing into the water. The tide varies to a maximum of around 3.7m above sea level (dmi.dk, 2014). The marine water quality in the area surrounding the project varies greatly in terms of turbidity. Two large rivers, the Qinnguata Kuussua and the Akuliarusiarsuup Kuua, enter the Sondre Stromfjord nearer to the icecap. The water qualities of these rivers contain significant amounts of glacial sediment. Continuing down the fjord, more glacial rivers join in. On the southeastern side, melt water enters the fjord from the Qivittup Inaa glacier and numerous other glacial rivers from the Kangaamiut Sermiat. Northwest of Sondre Stromfjord no glacial rivers are present and only a few small creeks enter the fjord from the project area mainly during the spring melt off, Figure 5.3.

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Figure 5.28 - Overview of the area with the two fjords of interests. Itilleq is a smaller, clear water fjord that is the main recipient of the freshwater outflow from the project area. This fjord is also classified as a sheltered coast with no drifting ice. This fjord is not influenced by glacial water, but receives high amounts of nutrients from the Aussivit and Itivdlinguaq valleys.

5.4.2 Marine Sediment The seabed of Sondre Stromfjord is greatly influenced by the influx of glacial material and the tidal current which results in a highly variable seabed of bedrock and silt. In the Itilleq fjord, a large deposit of silt was observed at the river outlet formed by the tidal cycle.

5.4.3 Marine Flora Coastal vegetation is classified primarily on the physical environment and, in particular, on the influences from ice.

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5.4.3.1 Sondre Stromfjord The coast of Sondre Stromfjord is classified as a sheltered coast with no drifting ice. This is normally indicative of a highly diverse marine flora. However, due to the high amounts of suspended solids and sedimentation there are only a few seaweeds that have adapted to this environment. Thus, the combination of high turbidity and the steep slopes in the fjord reduces the area where light penetrates all the way to the seabed, resulting in a narrow band of vegetation mainly in the littoral zone and the upper part of the sub-littoral zone (Pedersen P. , 2011). The vegetation in the littoral zone was observed during the collection of mussels and bladderwrack for the baseline programme. The most abundant seaweed species, multiannual Bladderwracks (Fucus versiculosus) and Knotted Seaweed (Ascophyllum nodosum) occur in the upper and central part of the littoral-zone. In the lower part of the littoral-zone, this community changes and is dominated by the brown algae Fucus evanescens (Pers. obs.). In the Sublittoral-zone the Focus group is replaced by regular kelp (Laminaria ssp.), mostly Sugarwrack (Laminaria lattissima), which was observed to be very abundant. In this zone only a few red algae were observed (probably of the genus Polysiphonia). This was expected and likely a consequence of the combination of high turbidity in the water and the thin layer of sediment on top of the bedrock preventing these groups from settling.

5.4.3.2 Itilleq Fjord The Itilleq Fjord is also classified as a sheltered coast with no drifting ice. Since no glacial water enters this fjord, the turbidity is low and the diversity of algae is high compared with Sondre Stromfjord. In this fjord, Fucus species dominate the littoral zone together with Green Tarantula Weed of the genus Acrosophonia. The outlets from the two river systems into the inner part of the fjord increase the nutrient level. This triggers the growth of Ectocarpus ssp. and Pyaiella ssp., two genus of algae favoured by high nutrient levels. In the sublittoral-zone, Kelp (Laminaria ssp.) is found together with Bootlace Weed (Chorda filum) and Whip Weed of the genus Chordaria ssp.(pers. Obs Maks Klaustrup) In the deep parts of the fjord, occurrences of red algae are expected but this has not been verified. A list of the observed algae is presented in HUD Technical Report 5.

5.4.4 Marine Fauna

5.4.4.1 Invertebrates The most abundant marine macro-invertebrates in the two fjords are Common Mussels (Mytillys edulis). This species is distributed from the upper tidal line down to at least 20 meters depth. In the intertidal-zone, large densities of Barnacles (Balanus ssp.) and periwinkle (Littorina ssp.) have also been observed. Besides the blue mussels, there

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large densities of sea stars (Asterias rubens) and sea urchins (Strongylocentrotus ssp.), (Pers. Obs.) in the sublittoral zone. The abundance of sea urchins in some areas is considerable. There they manage to consume all the kelp and leave the bedrock free of vegetation. However, the densities in the area are not large enough to control the seaweed.

5.4.4.2 Marine Fish The most abundant coastal fish species in both fjords are Greenland Cod (Gadus ogac), Sculpins (Myoxocephalus scorpius) and Atlantic Cod (Gadus morhua). These species were all caught around the proposed site for the marine port in Sondre Stromfjord and at the river outlet at Ivivneq. Besides these species, migrating Lump Sucker and Capelin has been located and mapped in the Itilleq Fjord - but not in Sondre Stromfjord (Nielsen et al., 2000).

Based on this mapping, the outer and central parts of the Itilleq Fjord have been identified as important fishing areas for capelin and lump sucker. No spawning areas were found for either species.

Figure 5.29 - Fishing area for Capelin in Itilleq fjord, (Nielsen et al., 2000).

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Figure 5.30 - Fishing area for Lump Sucker in Itilleq fjord, (Nielsen et al., 2000).

5.4.4.3 Marine Mammals Only a few marine mammals are present in Sondre Stromfjord. This is probably due to the high content of post-glacial elements (suspended solids) in the water column. No marine mammals have been spotted near the project area. Harbour Seal (Phoca vitulina) are distributed along the sections of the Greenlandic coast which have sub-arctic marine environments, defined as south of 67°N on the east coast and south of 75°N on the west coast (Rosing-Asvid, 2010). Compared to the other Greenlandic seal species, only the harbour seal is dependant on access (in limited periods) to haul-out locations for reproduction and moulting. The stock in West Greenland declined rapidly after the 1950s. On the west coast, harbour seals congregated at several breeding and moulting localities until the 1960s. Most of these localities were abandoned by the early 1990s and harbour seals are now rarely seen in West Greenland (Teilmann, 1994). Of special interest for this project is the former haul-out location beside Kangerlussuaq Airport, which occasionally still host some seals (last registration was in the period 1995- 1997 where 7 seals were recorded by GINR (Rosing-Asvid, 2010).

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The harbour seal is now a protected species in Greenland and appears on the Greenlandic Red list as critical endangered. Ringed Seals (Phoca hispida), Harp Seals (Pagophilus groenlandicus) and Hooded Seals (Cystophora cristata) might appear in the outer Sondre Stromfjord. None of these are endangered. Common whale species such as the Harbour Porpoise (Phocoena phocoena), Minke Whale (Balaenoptera acutorostrata) and Humpback Whale (Megaptera novaeangliae) might also appear in the outer Sondre Stromfjord, although no references have been found.

5.5 Areas of Interests/Conflicts

5.5.1 Cultural Sites Greenland National Museum and Archives (GNMA) has in 2013 conducted a survey at the harbour site and along the planned road transect to the pit site. They found 11 sites hosting a total of 12 archaeological features, Figure 5.31, of which eight are protected by the conservation act. Subsequently, the road was adjusted to avoid Site no. 2, which was determined to be a shooting blind.

5.5.2 Local Hunting and Fishing The area around Kangerlussuaq is very important for hunting caribou and muskox. When the hunting season starts August 1st, many hunters from the nearby towns and villages come to set up camps in the area. Due to the much higher populations of game, most of the camps are situated on the southern bank of Sondre Stromfjord, with the largest (and most used) in the bottom of Angujortarfik. Occasionally, hunting parties will make day trips to the northern side of the fjord although the smaller population density of caribou and muskox in the area limits the visits (stakeholder-engagement, 2013). Many of rivers contributing to Sondre Stromfjord hold stocks of migratory Arctic Char, resulting in the presence of Char in the fjord. These are targeted by gillnets used by local hunters and fishers visiting the area. Itilleq Fjord is mainly visited by people from Itilleq and Sisimiut for hunting caribou and fishing for Char. The main hunting and fishing area is the Aussivit Valley (stakeholder- engagement, 2013) No information is available concerning commercial fisheries in the fjords, but it is expected that local people conduct some fishing near the towns and settlements.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 5.31 - Location of the Archaeological sites along the road and the pit.

Table 5.8 - List of the archaeological features registered during the survey 2013.

Id Description Conservation Status 1 Double hearth Protected

2 Shooting blind Protected

3 Hunter’s bed Protected

4 Circular structure of stones probably a lookout for game. Protected

5 A small hunter’s bed built between some boulders Protected

6 Cairn made from three stones put on top of each other Protected

7 A cairn made by placing an angular stone on a boulder, probably to mark a fox trap Protected

8 Fox trap partly disturbed Protected

9a Big tent ring made of spaced stones, some of which are barely visible. Not a protected

9b Cache placed on the NW side of a rock outcrop NE to the tent ring. Not a protected

10 Hunting camp comprising 4 tent houses Not a protected

11 Quadrangular tent ring with the measurements 3 by 4m Not a protected

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

5.6 Sensitive Areas and Protected Areas Measures have been taken by the Greenland Government, as well as, international organizations to identify, evaluate and protect areas of biological importance in Greenland’s marine and coastal environment (Figure 5.32). The Government of Greenland has identified several “Areas Important to Wildlife” where mineral and petroleum exploration and extraction activities are regulated in accordance with the Mineral Resources Act. These areas include bird colonies and adjacent buffer zones. The Convention on Wetlands (the Ramsar Convention) lists eleven sites in Greenland (http://www.ramsar.org). None of these sites occur in the vicinity of the project, the closest being 50km north of Kangerlussuaq. Two protection zones for seabird colonies (eiders) have been identified along Sondre Stromfjord and one in the Itilleq Fjord, (Figure 5.32). Additional protection zones have been designated around critical nesting areas for White fronted geese.

Figure 5.32 - Overview of protected areas in the Kangerlussuaq region. From Nunagis.gl

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

5.7 Traffic

The main ship traffic in Sondre Stromfjord occurs between June and September. It is mainly comprised of merchant ships with supplies to Kangerlussuaq (Royal Arctic Line with two to three scheduled vessels a year and other private commercial vessels depending on the needs of the town), fuel supply vessels (Polar oil and Statoil) and cruise ship vessels (15-20 per year). There are also a lot of smaller private boats visiting the area for hunting or fishing. (Christiansen, 2014).

Hudson will have eight ships a year sailing in to the project to pick up material. The ships will be of Handymax size capable of transporting 25,000 tonnes of product per load. The ships will sail March through early November depending on local ice conditions. Ships will follow the same routes the large vessels already use up and down the Sondre Stromfjord which are well documented.

Hudson plans to use the Sondre Stromfjord to bring in construction material and supplies during the construction phase. During operations, supplies will be primarily delivered by the bulk ships coming in to pick up product, and there should not be any need for additional vessels for supplies. Diesel is expected to be delivered two times per year by ship.

The Company will also establish regular boat transport for workers coming to and from the project from local communities. The exact logistics will need to be developed after initial hiring is completed to determine transport needs. In some cases employees will fly in to Kangerlussuaq on regularly scheduled flights, which will not cause any additional air traffic, and will be transported to site by boat. In some instances helicopter transport may be necessary but will be a mode of last resort.

Although considered unlikely, it must be assumed that with additional ship traffic there will be an increased risk of shipping accidents and potential for spills of fuel oils in to the Sondre Stromfjord. Strong tides in the Sondre Stromfjord would carry the oil significant distances and could contaminate shorelines.

An oil spill in Sondre Stromfjord has the potential to have a significant negative impact on marine life and bird populations in the fjord. Birds would likely be at the highest risk as they are highly susceptible to the effects of oil.

Given that the shipping route to be used is well charted and frequently navigated, with excellent port access, and that the ships will not be carrying any toxic cargo aside from diesel fuel, the likelihood of a maritime accident and potential risk of detrimental impact to the local waterways is assessed as low.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

6 Methods Used for Environmental Impact Assessment This section describes the methodology used to assess the potential Environmental impact related to this project. Special attention has been put on identification of potential pollution and disturbance impacts.

6.1 Purpose and Approach The purpose of the EIA is to determine whether the Project will have an effect on the environment, to identify the extent of these effects and to develop or specify the means to mitigate, or reduce where possible, the identified effects. Possible effects of the environment on the Project are also addressed. The environmental assessment methodology for the proposed Project has been developed to meet regulatory requirements for mining activities in Greenland (BMP 2011). The methodology entails a structured approach, which includes the following steps:

• Develop the scope of assessment, including: selection of Valued Ecosystem Components (VEC), identification of Project activities with potential to interact with a VEC, and establishing temporal and spatial boundaries for the Project.

• Predict and evaluate potential impacts of the Project on selected VECs.

• Identify mitigation measures and monitoring procedures that have been developed and incorporated in the Project design to eliminate or reduce potential adverse impacts to the selected VECs.

• Determine a level of residual impact significance based on the combined effect of an outcome or consequence of the Project activity on the VEC and the probability that this event may occur.

• Provide the means by which the mitigation measures will be implemented and residual impacts managed, through the provision of an Environmental Management Plan (EMP) and a Monitoring Program. With respect to selection of VECs, the project area only consists of a limited number of Ecological components. However, for the purposes of this study, it was decided to discuss ALL ecological components as Valued Ecological Components. Based on the above, the main effects from the establishment of White Mountain are identified and assessed according to criteria’s shown in Table 6.1.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Table 6.1 - A list over the identified and selected VEC's

Possible Receptor Phase Possible effect Possible impact (VEC) Construction Infrastructure Seizure of Land, Removal of important food Terrestrial mammals, sources, removal of birds, invertebrates, important habitats, Flora, marine fauna

Noise Scaring wildlife, Terrestrial mammals and birds

Underwater noise Scaring mammals and fish Fish and Marin mammals

Dust Covering Plants Flora, Terrestrial mammals and birds Emissions Global effect Climate Operation Oil and chemical Freshwater and Contaminate freshwater Benthic invertebrates spill marine ecology and marine areas Arctic char

Mining area Seizure of land Removal of important food Terrestrial mammals sources, removal of Birds important habitats, Deposit of tailings Seizure of Lake A Freshwater environment Macrophytes Invertebrates Suspended solids Freshwater environment Invertebrates (Midges) Fish (Arctic char and Three-spined stickleback) Contaminants Freshwater and marine Invertebrates (Midges) environment Fish (Arctic char and Three-spined stickleback) Habitat changes Freshwater environment Macrophytes Invertebrates Road traffic Dust Covering Plants Flora, Terrestrial mammals and birds

Processing facility Noise Scaring wildlife, Terrestrial mammals and birds Port Dust Covering Plants Flora, Terrestrial mammals and birds.

Mining area Seizure of fjord Covering water plants and Seaweed, Invertebrates , habitats Fish Shipping Noise, spills Contamination Sediments, Seaweed, sessile invertebrates and Fish

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

The impact significance has been evaluated by ranking the status and level of importance of issues and the magnitude of any potential impacts. In determining the significance of an impact, ‘magnitude’ is assessed against ‘importance’ to provide a range of significance from ‘negligible’ to ‘major’ as shown in Table 6.3. Magnitude is determined on the basis of species vulnerability, spatial and temporal incidence of impacts and the ability of a species or community to recover. Table 6.2 - Criteria for the assessment of impacts. Criteria Factor Note Spatial extent • International interests In physical and biological • National interest environment local area is defined as • Regional interest mining area • Local areas and areas immediately outside the condition • Only to the local area • Negligible to no importance Magnitude of the impact or change • Major The levels of magnitude may apply • Moderate to both beneficial/positive and • Minor adverse/negative impacts • Negligible or no change Persistence • Permanent –for the lifetime of the project or longer • Temporary – long term – more than 5 years • Temporary –medium-term- 1-5 years • Temporary –short term- less than 1 year Probability of occurring • High (>75%) • Medium (25-75%) • Low (<25%) Other Direct/indirect impact – caused directly by the activity or indirectly by affecting other issues as an effect of the direct impact; Cumulative –combined impacts of more than one source of impact

Table 6.3 - Ranking of significance of environmental impacts (DONG, 2006).

Significance Description

Major impact Impacts of sufficient importance to call for serious consideration of change to the project

Moderate impact Impacts of sufficient importance to call for consideration of mitigating measures

Minor impact Impacts that are unlikely to be sufficiently important to call for mitigation measures

Negligible – No Impacts that are assessed to be of such low significance that are not considered relevant to impact the decision making process

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

7 Environmental Impact and Mitigations This section discusses each of the identified mine activities that could lead to a potential impact on the natural environment (ie. land, air and water).

The spatial boundaries for the Project have been defined as shown in Figure 7.1.

The boundaries cover the infrastructural elements (port site, camp area, the road and the pit site) plus a significant outlying area depending on topography. There is also a defined spatial boundary at riverine St. 21, where the obstruction for migratory Char is located.

For each impact, there is a brief description of the type (e.g. noise from blasting, land clearance etc.) and the timing of any impact. This is followed by a description of the potential pathways and receptors of the impact. If possible, proposals for mitigation are given. The section is completed by an assessment of the severity of the impact to specific receptors.

Figure 7.1 - Spatial boundaries where potential effects from the mine project may occur.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

7.1 Mine Site The property will be mined using open pit mining methods. Due to the topography of the deposit, benching into the hillside will be the primary method of extraction. A sinking cut will not be required until at least Year 10 of operations (Hains, 2013). The areal extent of the mine will be 5.5 hectares (ha) after 5 years, 8 ha after 8 years, 10.75 ha after 15 years and 10.9 ha after 20 years. From year 15 to year 20 the pit mainly develops in depth. The successive areal development of the mine is shown in Figure 7.2. Figure 7.1.1. - Plan view over the pit in year 5, 10 ,15 and 20 years respectively.

447000.000000 0 0 0 0 0 0 0 0 0 0 0 0 . . 0 0 0 0 0 0 2 2 8 8 3 3 7 7

Legend Pit Outline Years 5 10 15 500 250 0 500 Meters 20 Road_Plan

447000.000000

Figure 7.2 - Plan view over the pit in years 5, 10, 15 and 20. As the pit location is characterized by almost bare ground with loose rubble and broken slopes with little to no vegetation, changes to the topography due to mining will have little visible impact. After 20 years, if the mine is closed, there will likely be a small lake created from surface water run-off measuring 250m in diameter and 25 m deep (see Figure 7.3.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Figure 7.3 - Cross Section of the Pit

Although the impact is permanent, the areas to be disturbed are small in relation to surrounding available land. The significance of the permanent changes to the topography at the open pit is therefore considered Minor.

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact significance Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Topography Physical Local Moderate Long- Daily Minor high Minor term

7.2 Infrastructure (Roads, Harbour, Heliport)

In order to move and process the ore, the project requires the construction of a port and a road linking the port to the mine site. This will result in some change in topography due to blasting of rock and seizure of land due to the road (estimated to be less than one square kilometre). Other influences due to noise and dust areas are described in sections 7.4 and 7.5. The 10 km haul road and port area will be constructed from rock, which is blasted from the port facility and plant location area. The geology of this area, and indeed a large portion of the surrounding area, is comprised primarily of granites and granodioritic gneisses. These are common rock types throughout Western Greenland and the first 3.5 km of the road will traverse them. The balance of the road will traverse anorthosite. A complete analysis of the rocks is included in HUD Technical Report 7.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

The dock structure will be approximately 100 meters long and will protrude in to the fjord by 30 meters to provide 13 meters of water depth for incoming ships. It will be constructed of rock fill with sheet pilings on the outer edge. The rock to be deposited in the fjord is the same material used for road construction and is non-hazardous.

As the port facility is of such a diminutive size, no changes in current patterns and related changes in biota are expected beyond the dock structure.

There will be negative visual impacts from the fjord during construction and once the project is built and in operation. Passengers in vessels passing by will be able to see the storage shed, fuel tanks and process building from the fjord. The tallest building will be approximately 20 meters in height. Buildings will be painted to blend in with the natural surroundings to limit visual impacts.

Figure 7.4 - Project View from the Sondrestrom Fjord

As the seizure of land is restricted to a limited area, the main impact will be visual. As the port facility is of such a diminutive size, no changes in current patterns and related changes in biota are expected.

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact significance Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Topography Physical Local Moderate Long- Daily Minor high Minor term

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

7.3 Tailings Disposal The tailings will be deposited subaqueously into Lake A, as described in Section 4.5.6 – Tailings. The main concern with subaqueous tailings disposal are the potential to release deleterious elements into the environment via disposition. A secondary concern is the effect adding tailings will have on the lake volumes and water flow rates (ie. retention times).

7.3.1 Tailings"Chemical"Composition" Since the final product requires a lower amount of iron than is in the anorthosite naturally, it must be removed by magnetic separation. The process plant will use magnetic separators to accomplish. The goal is to reduce the iron content while producing as little waste material as possible. The major elements in the waste material, the “tailings”, are very similar to the original anorthosite other than significantly reduced levels of iron (Fe2O3) and magnesium (MgO). Figure 7.3 illustrates the difference in the chemical make up of the two rocks products. Note the very, very low level minor elements both products.

35%% 1,000%%

30%% Ore%for%Shipping%

25%% Mag%Tails% 100%% 20%%

15%% Weight"%" 10%% 10%% "ppm"(log"scale)" 5%%

T%% 1%% Al2O3% CaO% Fe2O3% MgO% Na2O% Ba% Co% Cr% Cu%Ga% La% Li% Nb% Ni% Pb% Sn% Sr% V% Zn%

Figure 7.5 - Assays of Major and Minor Elements in the Tailings and the Product.

7.3.2 Tailings"Lake"Description" A lake located approximately six km from the process plant will be used as the tailings pond. The lake is referred to as Lake A for this report, Figure 5.3. Geologically the lake is underlain by anorthosite. Approximately 85,000 tonnes (56,500 m3) per year of tailings (280 tonnes/day) will be disposed in the lake. The total amount of tailings produced during a 20-year mine life will be 1,700,000 tonnes or approximately 1,133,000 cubic meters of material. The total volume of Lake A is estimated to be 1,366,500 cubic meters (refer to Table 5.1 - Dimensions of the lake system including the Tailings Lake A.). After

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

10 years of disposal the tailings material is estimated to fill 41% of the lake and after 20 years it will fill 83% of the lake by volume, Figure 7.6. Between one and five metres of water cover will be maintained over the tailings throughout the life of the project. The final determination of the minimum water depth will be determined based on best environmental practices after several years of observing the physical nature of the tailings in the Lake. It is important that winter ice is not thick enough to disturb the surface. As well, there must be sufficient coverage to ensure wind induced waves do not result in re-suspension of tailings (Mian, M.H. and Yanful, E.K., 2003; Yanful, E, Samad, M and Mian, H., 2004; Maniagnit, 2008). The bathymetry change in Lake A is permanent and may also change Lake B, especially if the mining period is prolonged. Discarding into a lake ensures that no eye catching visual impact can be identified as the tailings material will be submerged at all times. In the long-term (>5 years) post-closure, the sediment is expected to be colonized by submerged macrophytesFigure X.X.X . that- Pl a willn v ie stabilizew of exp e thecte d sediment tailing e xt andent decrease/prevent resuspension. in year 5, 10 ,15 and 20 years respectively.

449000.000000 0 0 0 0 0 0 0 0 0 0 0 0 . . 0 0 0 0 0 0 4 4 8 8 3 3 7 7

Legend Estimated Tailings Extent Years 5 10 15 20 Road_Plan

250 125 0 250 Meters

449000.000000

Figure 7.6 - Extent of tailings disposal in Lake A after 5, 10, 15 and 20 years.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

All the lakes in the freshwater system function as a buffer capacity for water during the spring melt off. The four lakes; A, B, C and D hold all together an estimated volume of approximately 17 million m3 of water. Within a 20 year period the water volume in Lake A will be reduced with the deposition of 1.3 million m3 of tailings. The impact on Lake A will be significant but the impacts on the freshwater habitat in the area, in general, will be low because there are many lakes similar to Lake A in the White Mountain area. Furthermore, the water flow from Lake B into Lake C is a bog, with small and slow flowing water, which will increase sedimentation and work as a small filter. The water flow out of lake C is estimated to be 450,000 tonnes annually (see Table 5.2 - Annual Flow Rate Exiting Lake C and Lake D). This represents 12% of the volume of Lake A, B and C, equivalent to a retention time of 8.1 years. After 20 years, the retention will fall to 5.2 years. Including Lake D, the retention time for the system is 9.7 years, falling to 9.0 years by year 20 of the mine plan. Thus, the overall impact from discarding tailings into Lake A with regards to changing bathymetry, habitat changes and visual impacts is assessed to be minor.

VEC Potential Residual impact assessment criteria Conseque Probabi Overall impact nce lity significa Magnitude Geo. Extent Duration Frequency nce

Impact phases: Operation, closure, post-closure

/Changing Discard Minor Local Permane Daily Minor High>75 Minor bathymetry tailing in nt % Lake A: /seizing area

/visual

Impact phases: Closure, post-closure

/visual Discard No change Local Permane Rare Minor High>75 Negligibl tailing in nt % e Lake A

7.3.3 Tailings"Impact"on"Fresh"Water" A major concern with respect to subaqueous tailings disposal is elevated levels of suspended solids and the release of contamination material to the lake and associated river continuum. In order to test the impact of this means of disposal, the Company conducted a turbidity test, column leach tests, and freshwater algae toxicity tests on the column test water. For the test, the tails were created by separating a magnetic fraction from the anorthosite using equipment similar to those to be used in the processing plant.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Turbidity Test The tailings material consists of particles ranging in size from 250 microns to well below 75 microns. The rate of sedimentation is higher for the large particles compared to fine particles. The sedimentation rate has been tested at the SRC (Saskatchewan Research Council) laboratory to examine the turbidity in a water filled container. Tailings material was added to a clear container and photos were taken each day for a period of 11 days, (Figure 7.7). The photos show that the levels of suspended solids decrease with time and that most but not all material are sedimented after 11 days. Thus, the elevated levels of suspended solids will be evident during the 10 months per year when the tailings are being discarded into the lake. As a result, reduced visibility is expected in both Lake A and Lake B as these lakes are essentially one lake. The tailings will be sluiced down to the lake bottom by a slurry pipe. This will help minimize the amount of sediment in the water and will limit the suspended material from entering Lake C as the outflow is surface water from Lake B. More importantly, the retention times in the lakes are very long which will isolate the sediment in the uppermost lakes. Together the four lakes are expected to function as a natural sedimentation and clarification reservoir, ensuring that no elevated levels of suspended solids will be found outside the Hudson Naajat property. Day 1 Day 5 Day 11

Figure 7.7 - Photos from the turbidity test. Gradually, as Lake A is filled with tailings the bottom of the lake will rise towards the surface. As discussed on section 7.3.2, between one and five metres of water depth will be maintained on top of the tailings material. It is important that the tailings are not re- suspended by some form of disturbance (ie. ice or wind on the surface of the lake).

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Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Further to this, tests of shaking the sedimentation container shown in Figure 7.7 in order to simulate a physical disturbance showed that only limited amounts of sediment were re- suspended. The impact on the aquatic organisms will be significant but the consequences will be minor as no endemic or rare invertebrates or macrophytes have been found. Furthermore, the only fish found are the ubiquitous three-spined stickleback, which has no special conservation interest. The overall impact significance from suspended solids is assessed to be minor. Column Leach Tests The column leach test is designed to test the mobilization of elements in water over an extended period of time. Since the tailings do not contain any sulphides they were not expected to result in any notable chemical leaching (HUD Technical Report 3 - Acid Generation Potential) . The column leach test proved this to be true. As a result, the tailings have been determined to be non-acid generating and no further acid rock drainage studies are deemed necessary. In fact, the pH at White Mountain tends to be more basic (pH > 7) than acidic (pH < 7). Freshwater measurements show background levels of pH between 7.2 and 7.9. The pH of the water from the leaching test averages less than 9. Because pH uses a logarithmic scale, based on the number of H+ ions, adding 1 part water with a pH of 9 (tailings, for example) to 10 parts water with a pH of 8 (Lake A, for example) will only increase the overall pH from 8.0 to 8.04. Even a 1:1 ratio will only increase the pH to 8.26. There are no firm thresholds at which pH has a direct toxic effect on aquatic organisms, but in aquaculture (at 25°C) values above pH 9.5-10 are considered as undesirable (Craig and D'Abramo, 2008). Therefore, even a 100% contribution to pH from the tailings will not have any toxic impact on the environment. This is supported from the findings of the algae test, reported below.

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Figure 7.8 - Tailings Mobilization test at SRC. Complete column test parameters and results are included in HUD Technical Report 4. The test apparatus is shown in Figure 7.8. In general, the test measures the quantity of each element that leached into the water column over a 20 week period. These amounts can then be modelled to predict the cumulative amount of each element that could enter the water system over the life of project. As expected, most of the mobilization of elements occurs during the initial flush and the first 10 days of the test. None of the elements leached in any significant way. As a result, no elements are expected to build up in the ecosystem since most of the leaching will occur in low quantities and within the first few months of submersion. Since mercury is an important contaminant to avoid, it was analysed separately. No mercury was detected above the minimum detection limit in either the flush water or any of the subsequent water column assays. This was to be expected since the amount of mercury in the host rocks (below 0.006 ppm) is less than 10% of the earth’s crustal abundance of 0.08 ppm (Jonasson, 1970).

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Element Maximum Lake ABC - Outflow Lake D - Year 20 Greenland Pre Mining Guidelines Filtered Unfiltered Estimated Increase Percent of (µg/l) (µg/l) (µg/l) (µg/l) Pre Mining Guideline

Arsenic 4

Cadmium 0.1 0.010 0.010 0.014 N/A N/A Set at D.L.

Chromium 3 0.28 0.27 0.54 N/A N/A Set at D.L.

Copper 2 7.53 8.30 8.37 11% 418% Exceeds Max

Iron 300 51.9 9.1 70.8 37% 24%

Lead 1 0.06 0.08 0.22 264% 22%

Mercury 0.05

Nickel 5 2.80 2.91 2.94 5% 59%

Zinc 10 1.60 2.47 3.18 99% 32%

Phosphorus 20 3.00 4.00 No Assays N/A N/A

Table 7.1 - Significant Results from the Column Mobilization Test The Greenland Water Quality Guideline (GWQG) establishes maximum concentrations of certain elements in drinking water. These elements were analysed in detail and the results are presented in Table 7.1. The analysis assumed the worst case scenario: 100% leaching efficiency over the 20 year mine life and if the element assayed below detection limit then the detection limit was used as a proxy. In reality, leaching will only occur at the exposed surface of the tailings disposition until such a time when it is buried beneath an added layer on top. Nonetheless, even under the scenario of complete contact with the watertable (ie. 100% leaching efficiency), none of the elements other than copper will come close to exceeding the GWQG after 20 years.

As discussed above in Section 5.3.1, the copper concentration in the lakes and rivers surrounding the project already exceeds the GWQG concentration of 2 µg/l. It is currently measured at approximately 7.5 µg/l and will increase to a maximum of 8.4 µg/l after 20 years of mining. The analysis reviewed the effect of variable annual precipitation rates on the build up of copper concentrations in the lakes. As described in section 5.1.6, 2014 was a particularly dry year. There are instances where the annual rainfall is up to 2.5 times the amount recorded in 2014. Figure 7.9 illustrates the effect of more or less water flowing through the system. If it didn’t rain or snow for the next 20 years, the copper concentration could

103

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

be expected to rise to almost 10 ug/l in Lake D. The more likely event is that it will rain a fair bit more over the next 20 years. This will result in a lower increase in copper contamination. The net result is that local precipitation does not have a material impact on the change in copper concentration in Lake D.

Figure 7.9 - Copper values in Lake D as a function of precipitation

If copper concentrations are high enough they can reach lethal limits, generally referred to as a Median Lethal Concentration (“LC50”). As described later in this report (Section 7.10.2, Section 7.11.2, and HUD Technical Report 3), the following are some LC50 values for several species in the area which show that the maximum copper concentrations expected due to the project are lower than the limits defined by the LC50 where half the population are expected to die. A significant number of deaths can still occur at lower limits. However, it is important to reiterate that there is already a healthy ecosystem surviving in an environment of naturally elevated copper concentrations and the effects from the mining operation will be expected to raise this concentration by only about 12% over 20 years..

Table 7.2 – LC50 Copper Concentration Values

LC50 Copper Value Project after 20 yrs (µg/l ) (8.4µg/l Cu) Midges 30 3.6 times lower than LC50 Mayfly 25 3.0 times lower than LC50 Char, fry and juvenile 100 11.9 times lower than LC50 Seawater species, most sensitive 28 -39 3.3 times lower than LC50

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Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

The impact from leaching of metals from tailings will be local and limited to lakes and river upstream from Lake40, Figure 5.2. The leaching is expected to continue as long as the mine is operating due to daily disposal and is expected to be reduced rapidly after closure and is not expected to be present post-closure. The overall significance of impact from contamination from tailings disposal is assessed to be minor. According to the BMP (2011) the GWQG value has to be met at one or more specified points downstream of the operation. Inuplan believes that a realistic measuring point where the GWQG should be met is at the waterfall at station 21, which is the end point for Arctic Char. Freshwater Algae Toxicity Test In order to test whether there is any toxicity in the tailings water, a toxicity freshwater algae growth inhibition test was conducted using an Algaltoxkit F Freshwater Algae Toxicity test kit. Complete test results and background are included in HUD Technical Report 9. The test used water that was made up to simulate the concentration of elements that could enter the water system as the tailings are deposited. In reality, the water would be heavily diluted by the surrounding lake water. However, in this test, concentrations of 6.25%, 12.5%, 25%, 50% and 100% (undiluted) were used. Two Litres of de-ionized water was agitated with 3 kg of tailings material (ie. one to one ratio by volume) for approx. one hour to create the test water sample. The undiluted assays were then compared with the flush water and average first 6 day water assay data from the column test in Table 7.2 which confirmed that the water was appropriate for the test.

(mg/L) Al Sb As Ba Be B Cd Cr Algae Test Water 2.21 0.0024 0.0003 0.0073 <.0001 <.01 <.00001 0.0018 Average Flush Water 2.22 0.0014 0.0013 0.0155 <.0001 0.0250 <.00001 0.0012 Average Column (up to day 6) 2.50 0.0025 0.0007 0.0090 <.0001 0.0300 <.00001 0.0015

Co Cu Fe Pb Mn Mo Ni Se Algae Test Water 0.0002 0.0029 0.120 0.0003 0.0097 0.0130 0.0014 0.0006 Average Flush Water <0.0001 0.0075 0.054 0.0006 0.0062 0.0260 0.0010 0.0003 Average Column (up to day 6) <0.0001 0.0035 0.073 0.0005 0.0062 0.0062 0.0009 0.0002

Ag Sr Tl Sn U V Zn Algae Test Water <.00005 0.0180 <.0002 0.0001 0.0099 0.0031 0.0008 Average Flush Water <.00005 0.0190 <.0002 0.0003 0.0475 0.0009 0.0099 Average Column (up to day 6) <.00005 0.0173 <.0002 0.0002 0.0031 0.0006 0.0025 Table 7.3 - Assay Table for Freshwater Algae Toxicity Test The 72 hour test was modelled on the OECD “Algal growth inhibition test” (Guideline 201) and the ISO “Water Quality-Freshwater Algal Growth Inhibition Tests with Unicellular Green Algae” (ISO Standard 8692). There was no unusual appearance or treatment of test organisms before their use in the test. There was nothing unusual about the test, no deviation from the test method or problems encountered.

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Table 3. N to ln conversion Concentration 0h 24h 48h 72h Mean 10000.000 118982.977 734060.264 1843717.820 Control ln 9.210 11.687 13.506 14.427 Mean 10000.000 152958.146 791833.892 1805307.663 6.250 ln 9.210 11.938 13.582 14.406 Mean 10000.000 321764.847 735129.413 1958750.301 12.500 ln 9.210 12.682 13.508 14.488 Mean 10000.000 309410.240 871544.867 1942950.659 25.000 ln 9.210 12.642 13.678 14.480 Mean 10000.000 588537.246 766887.089 1969204.199 50.000 ln 9.210 13.285 13.550 14.493 Mean 10000.000 209068.654 693036.632 1783647.503 100.000 ln 9.210 12.250 13.449 14.394

Table 4. Average specific growth rate (µ) after 72h Concentration Replicate 1 Replicate 2 Replicate 3 µ Std. dev. CV% EnvironmentalControl Impact Assessment1.727 (EIA) - White1.750 Mountain1.740 Anorthosite1.739 Mining Project0.012 0.69% 6.250 1.675 1.760 1.754 1.732 0.048 2.76% 12.500 1.760 1.771 1.747 1.759 0.012 0.69% 25.000 1.766 1.752 1.751 1.756 0.008 0.48% Table 7.4 represents the specific growth inhibition for each of the concentrations used. 50.000 1.765 1.751 1.767 1.761 0.009 0.49% Negative inhibition equals stimulation. As can be seen, there was stimulation of algal growth in100.000 test concentrations1.715 12.5%-50% with1.753 minimal inhibition1.715 of algal growth1.728 at 100 % 0.022 1.27% concentration. Table 5. Concentration vs. percent inhibition Table 5.1. Concentration vs. percent inhibition Concentration I% Concentration Replicate 1 Replicate 2 Replicate 3 Control 0.00 0.000 0.000 0.000 0.000 6.250 0.40 6.250 3.011 -0.569 -0.846 12.500 -1.16 12.500 -1.916 -1.160 -0.410 25.000 -1.00 25.000 -2.284 -0.099 -0.659 50.000 -1.26 50.000 -2.228 -0.034 -1.551 100.000 0.63 100.000 0.669 -0.131 1.431

72hTable ErC 7.4 -50 Concentration = vs. percent141.01 inhibition The95% confidence toxicity results limits = use the0.00 Effective Concentration0.00 (EC), which refers to the concentration of the test water which induced a response at 10%, 20% and 50% (halfway) respectively, between the baseline and maximum after a specified exposure time.72h ErC EC1010 = and EC20 are 121.32 additional values that the kit manufacturer included in the calculations95% confidence but limits are not= required0.00 by the ISO0.00 standard 8692 and OECD Guideline 201. EC50 value represents the concentration of test water where 50% of its maximal effect is observed, and in this case it is over 100% (141.01). 72h ErC = 128.24 The conclusion20 from the test is that none of the samples inhibited algae growth and the impact from contamination from tailings disposal is assessed to be minor. Tailings Freshwater Analysis Summary The conclusion is that if the mitigating measures proposed in this EIA report are implemented and the mining activities are carried out in accordance to good environmental practice then the significance of the impacts on the environment will be low. No significant contamination by toxic materials or other pollutants is expected to take place.

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact Magnit Geo. Duration Frequency significa ude Extent nce Impact phases: Operation, closure, post-closure Suspended Discard Minor Local Permane Daily Minor High>75% Minor solids tailing in nt Lake A Hudson Industries Effluent 25 July 2014 ALGALTOXKIT F /Contaminati Discard Minor Local Permane Daily Minor High>75% Minor on elements tailing in nt Lake A /Habitat Discard Minor Local Permane Daily Minor High>75% Minor changes tailing in nt Lake A

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7.4 Noise The White Mountain project will generate industrial noise from the pit, mobile crushing units, material hauling, the processing plant, power generation and ship loading. The majority of the noise will be generated at the pit site from blasthole drilling, blasting and two stages of mobile crushing, and from 35 tonnes haul trucks running to and from the plant at the port site. Additional noise sources will include the diesel-powered hydraulic excavator in the pit and two front-end loaders. The pit location is in a remote area approximately 5 km (direct line) from the port and is not visible from the Sondre Stromfjord. The mine will only operate 12 hours per day during the day shift, for nine months per year. The location of the pit provides substantial shielding of horizontal sound movements and no sound is expected to reach the port facility. The nearest community is 80 km away and will not be impacted by any project noise. At the port site, noise will be primarily produced by the power plant (comprised of two 400 kW diesel generators), and the process plant. The noise levels in the plant, which will operate 24 hours a day, ten months per year, will be continuous and at a steady level throughout the life of the project. The plant noise will be transmitted through the building walls made of corrugated steel panels. During transmission, some sound energy will be lost. The magnitude of the transmission loss will depend on the thickness of the wall panels and their structural properties. As the building will be insulated for arctic conditions transmission loss is expected to be significant. An overview of the predicted noise levels are shown in Table 7.5. Due to natural attenuation of sound in the atmosphere and the local topography, noise effects will be localized and immediately mitigated. There are no other industrial operations within the proposed project area and as such, there will not be any cumulative effects and a cumulative effects assessment is not warranted. No baseline noise studies have been undertaken as the project activities have been limited to date.

Table 7.5 - Noise Levels for Major Equipment at White Mountain

Noise Source Operating Noise Level (dBA Distance (m) Condition decibel A-scale) Pit Blast 110 100 Front End Loader Loading 85 7 Haul Truck Full load 91 7 Haul Truck Empty 87 7 Hydraulic Drill - Pit Drilling 100 7 Excavator Digging/scraping 90 7 1000SR Cone Mobile Crushing 119 5

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Crusher 400 Jaw Crusher Mobile Crushing 114 5 VSI Crusher in Crushing 71 1 Plant Generators Operating 78 15 Sources: Environment Australia and data provided by equipment vendors. In addition to the above, helicopter traffic will give rise to non-continuous, irregular and limited periods of noise production. With no local settlements it is not anticipated that helicopter movements will give rise to significant adverse impact. However helicopter traffic will be limited as Hudson’s plan is that the majority of all transport in and out the camp will be carried out by boat. Hudson will institute a noise-monitoring program as part of the Occupational Health and Safety Program for the operation. The details of the program have not been finalized as operations are not expected to begin before mid 2015. Hudson will have this program fully developed prior to the start of operations. Hudson will identify areas where noise is constant and more than 85 dBA (a threshold defined by Mine Health and Safety Regulations – Canada) and will take measures to lower the noise level and/or reduce the length of exposure, and separate the workers from the sources of noise where they exceed these decibels. Hudson and its contractors will comply with all applicable regulations, including the implementation of a hearing conservation program that will include the following:

• Education of employees • Noise surveys of worksites and equipment • Hearing protection for employees • Consultation with employees. Research into the effects of noise on animals is relatively scarce. The conclusions derived from studies to date are quite often contradictory and some are inconclusive. It would be reasonable though to conclude that the effects of introducing industrial noises on animals would be disruptive in the short term, and will affect individual animals differently. Noise can adversely affect wildlife by disrupting sleep patterns and thus effecting daytime task performance (Busnel, 1978)), by interfering with hunting and grazing, and by potentially interfering with communications between animals. Based on experience from numerous industrial facilities, including mines operating in the Arctic, it can be seen that most animals will adapt to the presence of industrial operations and related noises.

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According to (Busnel, 1978) an animal's typical initial reaction to a new noise source is fright and avoidance, but if other sensory systems are not stimulated, the animal quickly learns to ignore the noise source. In order to manage and reduce potential adverse effects caused by project noises, Hudson has identified each sound source and proposed possible mitigating measures. E. Reimers & J. E. Colman conducted a literature survey, that revealed that although caribou in most cases respond to anthropogenic activities, behavioural and physiological responses generally appear to be brief and moderate. Comfort distances (i.e. distances beyond which animal behaviour or activity are not influenced) are relatively short. (Colman, 2006) Hudson will prepare a Noise Management Plan, which will include the following mitigation measures for activities during Construction (C), Operations (O) and decommissioning (D).

Activity Project Phase Mitigation Measure Blasting C, O Ensure hole spacing maximizes blast efficiency to limit number of blast holes. Maximize explosives ratio. Proper stemming of blast holes. Limit blasting to certain times of day depending on wildlife sensitivities. Mobile Crushing (two O Maintain equipment and turn off when not in use. stages near pit) Material Hauling (35 C, O Maintain equipment. Utilize mufflers and sound tonne haul trucks) hoods. Ensure proper use of brakes. Operate with proper load size. Main Power Generators C, O Place equipment away from people and use berms (two 400 kW generators) to shelter noise. Use exhaust silencers. Shut down one generator when power draw is below 400 kW. Use additional acoustic screening if required. Additional Moving C, O, D Maintain equipment. Utilize mufflers and sound Equipment (front-end hoods. Ensure proper use of brakes. loaders, water truck, passenger vehicles) Ancillary Equipment C, O, D Maintain equipment in good working order. Place (compressors, small equipment in sheltered/bermed locations. generators, pumps)

Based on the above mitigating measures, the noise is expected to have the following impact:

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VEC Potential Residual impact assessment criteria Consequ Probability Overall impact ence significance Geo. Magnitude Duration Frequency Extent Impact phases: Construction Human Hearing Local Moderate Long-term Daily moderate likely/high Minor Health damages Wildlife Scaring Local Moderate Long-term Daily Minor Likely/high Minor (both away terrestri al and marine)

Hunting Relocatio Local Minor Short- Daily moderate Likely/high Moderate and n of term fishing wildlife due to disturban ce Impact phases: Operation Human Hearing Local Moderate Long-term Daily moderate low Minor Health damages Wildlife Scaring Local Moderate Long-term Daily Minor Likely/high Minor (terrestr away ial only)

Hunting Disturban Local Minor Short- Daily Minor Likely/high Negligible and ce from term fishing Helicopter

7.5 Dust The most significant environmental issue with respect to the mining and material handling of the White Mountain ore will be the production of dust. The White Mountain project will produce dust as part of the normal working conditions of an operating mine. The key areas where the potential for dust to be created are as follows:

Activity Estimated Portion of Dust Generated

Drilling and blasting in the pit 2-3%

Primary and secondary mobile crushers at the pit 5%

Haul trucks driving to and from the pit and plant + 90%

Loading of material in to the process building <1%

Loading vessels by mobile ship loader <1%

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Hudson has developed a Dust Management Plan (DMP), including several mitigating measures to be undertaken in order to minimize the amount and effects of dust on the surrounding environment (see Appendix 2). The DMP includes:

• No work at wind speed above 14 m/sec. • Vehicles (trucks/dumpers) not to be overfilled • Speed limits for vehicles • Watering of road surfaces and possible use of dust control reagents such as calcium chloride (if use approved by the government) • Enclosed conveyors with dust collectors at transfer points • Efficient blasting • Sighting of stockpiles taking into consideration prevailing winds The dust does not contain any free silica or metals in any concentration that would pose a health risk. During bulk sample processing of 120 tonnes of anorthosite at the Saskatchewan Research Council in March 2013, SRC tested the filters on dusk masks worn by workers, which showed silica levels were below the detection limit of 0.01 mg/m3 (see HUD Technical Report 10 for SRC report). With less than 115,000 cubic meters (285,000 tonnes) of material moved annually, the total impact of dust created during the mining operation is considered to be minor. ). The company will comply with the Greenland Air Quality Criteria on dust: 200 m from roads, 500 m from open pits and 300 m from ports of unloading.

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact significance Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Human Respiratory local moderate Long- Daily Minor Likely Minor Health term diseases

Flora Shadowing local moderate Long- daily Minor High Minor term

Wildlife Coverage local Minor Long- Daily Minor Low Minor of food term

7.6 Emissions Air emissions from the White Mountain project, aside from dust, will be comprised of emissions from mining operations and ore transport and processing, which will include the following:

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• Carbon dioxide (CO2), a Greenhouse Gas (GHG) produced from burning of diesel oil. • Oxides of nitrogen (NOx) primarily from diesel engines and rock blasting. • Oxides from Sulphur (SOx) resulting from sulphur in the diesel fuel.

All the emissions will be released in to the atmosphere, with CO2 being the largest emission. Both SOx and NOx are expected to be emitted in much smaller quantities, as by-products of fuel combustion in the mining equipment, vehicles and diesel generators, and as by-products of explosive use in blasting.

Oxides of Carbon (CO2)

The CO2 emissions will come from combustion exhaust from engines on major equipment in the operation. The anticipated annual diesel fuel consumption is shown in Table 7.6.

Table 7.6. Annual diesel fuel consumption for major equipment.

Type Load Number Fuel Consumption Engine size Annual Fuel Factor (%) of Units (L/hr) (Horsepower) Consumption (L/yr) Drill Rig (Sandvik DX780) 50 1 15 225 24,950 Excavator (CAT 349E) 40 1 20 400 26,610 Front End Loader (Volvo 70 1 26.5 300 56,100 L250G) Front End Loader (Volvo 70 1 15.1 31,960 L150G) Haul Truck (Volvo A35F) 85 3 30.3 440 233,650 750 kW Diesel Generator 75 1 161 Two 400 kW 971,320 Units Mobile Cone Crusher 75 1 60 325 90,720 (1000SR) Mobile Jaw Crusher 60 1 30 260 108,870 (XA400S) Skid Steer Loader 50 1 10 15,120 Ancillary Equipment 50 various 60 various 90,720 TOTAL 1,740,740

Based on CO2 emissions of 2.68 kg/liter for diesel oil (source: www.epa.gov), the project will produce a total of 4,665 tonnes of CO2 annually. Statistics Greenland shows that the total CO2 emission of Greenland was 676,000 tonnes in 2011. This would mean that the White Mountain project would account for less than 1% (0.69%) of Greenland’s CO2 output based on 2011 data. In this context it is important to note that the use of White Mountain anorthosite, as a replacement to kaolin (clay) in the manufacturing of E-Glass fiberglass, results in reduced CO2 and NOX emissions from reduced energy demand and less limestone, plus

reductions in the overall GHG footprint by reducing materials requirements.

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Oxides of Nitrogen (NOx) The project will introduce nitrogen into the local environment from diesel engines and during blasting due to residues of nitrogen based explosives (ANFO). The oxides of nitrogen produced annually from diesel engines on site (which includes all vehicles and power generators) is estimated to be 48.7 tonnes of NOx (based on 28 grams/liter x 1,740,740 liters). An analysis, including all calculations, are included in HUD Technical Report 2. Also in the analysis was an assessment of the amount of nitrogen entering the watershed from ANFO use. It was determined that the tailings rock will contain 81.6 kg of nitrogen annually. The impact of this will be to raise the amount of nitrogen in the lake to 75 µg/ liter after 20 years of mining. Even if one assumes an extreme case where 100% of the potential nitrogen from ANFO use went into the tailings lake, totaling 273.6 kg of nitrogen annually, this would raise the nitrogen levels to 251 µg/ liter after 20 years of mining.

Given the small amount of ANFO being utilized and the relatively dry environment with no known aquifers, it has been determined that nitrogen from blasting on the local ecosystem will have a minimal impact on any significant bodies of water in the project area.

Oxides of Sulphur (SOx)

The oxides of sulphur (SOx) are derived directly from the sulphur content of the diesel fuels used. In a combustion chamber, sulphur is oxidized forming sulphur dioxide (SO2) and, to a much lesser extent, sulphur trioxide (SO3).

Based on an average release of 4.7 g SOx/l diesel oil (source: www.env.gov.bc.ca) the total annual emission will be approximately 8.3 tonnes of SOx per year.

Table 7.7 - Annual emissions of CO2, NOx and SOx from combustion of diesel fuel

Fuel Emissions Consumption Diesel CO2 NOx SOx Tonnes/Year Tonnes/Year Tonnes/Year Tonnes/Year 1480 4665 48.7 8.3

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VEC Potential Residual impact assessment criteria Conseq Proba Overall impact uence bility significance Geo. Magnitude Durati Frequ Extent on ency Impact phases: Construction, Operation and Closure Human Respiratory Local Moderate Long- Daily High Low Minor Health Diseases term

Water Eutrophication Local Moderate Long- Daily Minor high Minor Quality term

Flora Fertilizing Local Low Long- Daily Minor high Minor term

7.7 Impact From Waste and Wastewater As discussed in section 4.5.5, organic refuse will be incinerated in an approved incinerator or composted, as permitted. Hazardous waste materials such as used oil containers, used oil, used oil and fuel filters, etc. will be collected and removed from site to an approved disposal facility at Kangerlussuaq. Hazardous liquid wastes (used oil, etc.) will be disposed in a suitable approved high temperature incinerator. Wastewater from the camps sewage treatment system will be discharged to the Sondre Stromfjord. As the system is relatively small (approximately 40 population equivalents (PE)), the annual contribution of Nitrogen (N) and Phosphorous (P) to the Fjord will be approximately 875 kg organic material, 40 kg of P/year and 177 kg N/year (Miljøstyrelsen, 2006). Neither of the above sources is expected to result in negative environmental effects, as solid and hazardous waste are disposed under secure conditions. The contribution of wastewater to Sondre Stromfjord is of such low magnitude, that it not is expected to cause measurable changes.

VEC Potential Residual impact assessment criteria Conseque Probability Overall impact nce significance Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Water Reduced Local Moderate Long-term Daily Minor Medium Minor quality quality

Marine Degradatio Local Minor Long-term Daily Minor Low Minor Flora n of Flora

Marine Contamina Local Moderate Long-term Daily Minor Low Minor Fauna tion

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7.8 Potential for an Oil and Chemical Spill into the Water Environment Hudson plans to use Arctic diesel as the primary energy source. Arctic diesel is a relatively light fuel, that possess the ability to evaporate quickly, allowing it to only be present for a few days in the environment. The risks for an incidental oil spill is closely related to the unloading operation from the fuel vessels and storage along the Sondre Stromfjord. Approximately 1,740 m3 of fuel will arrive by tankers and be unloaded at the port site. The fuel will be pumped from the vessel through a short pipeline to the spill protected double wall storage tanks. Birds are extremely vulnerable to oil spills in the marine environment. Most fatalities following oil spills are due to direct oiling of the plumage, but often many birds also die from intoxication, hypothermia, starvation and drowning. Marine mammals such as seals and whales are generally less sensitive to oiling than many other marine organisms. Oil can irritate the eyes and to some extent the skin of marine mammals. As they breathe in close to the surface, oil droplets can cause respiratory effects. The thick blubber layer of adult marine mammals will protect them from the hypothermia effects of oil spills. Feeding might be suppressed in case of oil spills, and ingestion can cause sublethal effects (NRT, 2004).

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact significance Geo. Magnitude Duration Frequency Extent

Impact Phases: Construction, Operation and Closure

Fish Contamination Local Moderate Short-term Daily Minor Low Minor

Birds Loss of Local Moderate Temporary Daily Major Low Minor insulation – Long- term

Marine Contamination Local Moderate Short-term Daily Moderate Low Minor Mammals

7.9 Impact on Ecological Environment The Arctic ecosystem contains in general fewer species than can be found in more temperate further south. Thus, changes in abundance of one or two species may introduce changes throughout the food chain. In this sense the ecological environment in Greenland is fragile and could possibly suffer from human activities, if not handled with care. This section describes the ecological elements found within the project area and its surroundings.

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The terrestrial environment in Greenland is controlled by the meteorological conditions. The plants experience a short growth season and primary production is generally low. The low productivity has a cascading effect up the food chain and only highly specialized animals have success surviving this shortage of food. Thus, only a few species of birds and mammals are found in Greenland.

7.9.1 Vegetation" As described in section 5.2.1 the vegetation habitats found in the project area are dwarf shrub heath, open heath, fen, grassland and lake, see Figure 5.12. Special attention has been brought to the orchid plant (Amerorchis rotundifolia), which has not been registered in the area before. The orchid was found in seven stations in the area, and in large numbers, corresponding to an area covering over 3 km, see Figure 5.13. Otherwise the species was only known in considerable numbers from small areas near Narsarsuaq in South Greenland and a small area near Kangerlussuaq Airport ( (Boertmann, 2007) and (Feilberg, 2013). The development of this project (mine site, roads, process plant) will affect the vegetation locally, but as the vegetation habitats in the project area are so common, and more or less similar to the rest of the region, only negligible effects are expected on this element. With respect to the orchid, it should be mentioned that only two colonies are in the direct vicinity of the proposed infrastructure element, see Figure 5.13. The buildings were relocated to avoid these colonies.

VEC Potential Residual impact assessment criteria Conseq Probability Overall impact uence significance Geo. Magnit Duration Frequency Extent ude

Impact phases: Construction, Operation and Closure

Vegetation Physical Local Local Long-term Daily Minor Likely Minor incl, due to Orchids disturbing of area or coverage with dust

7.9.2 Birds" Although a number of bird species have been observed, see section 5.2.3, most of these are very common in the region, and are not subject to special conservation measures. Only the white tailed eagle, the falcons, the raven, the Canada goose and the white fronted goose, are known to be particularly sensitive to noise or visual disturbances and will most likely avoid breeding within 1-2 kilometres from the mine area. It is not believed that the project will have an impact on the distribution of nesting pairs of these common species in the region.

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With respect to the white tailed eagle and the falcons, no nests have been observed in the vicinity of the project area and the project does not foresee any impact on these birds. The Raven is generally a low-density breeding bird in Greenland and the mine project is not believed to have a major impact on the distribution of nesting pairs in the region. The white fronted goose is, as mentioned in section 5.2.3, nesting only in Greenland, in an area between the Maniitsoq Icecap and the southern part of Upernavik and as such subject to conservation measures. GINR has identified a number of resting locations used during the white fronted geese’ migration between the wintering areas and the nesting area. One of these resting areas is situated in the valley Southwest of the project area, approximately 4 kilometres from the pit. The Canada goose have been observed to nest in the vicinity of Kangerlussuaq, and has recently increased in numbers. No Canada geese have been observed in the project area, so it seems unlikely that the mining activity could affect this species. The baseline surveys revealed that one pair of white fronted geese were nesting at the lake at St. L-11 (approximately 2 .5 km from the pit site). As both the resting and the nesting locations are protected against disturbance (visual, noise, dust) from the proposed project, no impacts on these areas are expected.

7.9.3 Mammals" Arctic Hare and Arctic Fox Arctic hare and Arctic fox usually habituate well to human activities where they are not hunted. Measurable impacts on these two species are therefore not foreseen. Muskox With respect to the muskox, the project area is considered outside the muskox’s main distribution range. This is supported by aerial surveys and the fact that only a few remnants have been identified in the area. The impact on this species from the proposed mine project are therefore considered minor. Caribou The disturbance from the White Mountain anorthosite project will be related to noise from blasting, traffic and machines, and visual disturbance from persons, buildings and traffic. In general, physical constructions of various kinds apparently have limited effects on caribou! behaviour or habitat use, unless it obstructs or limits access to an area. Recreational (including settlements) or other motorized and non-motorized activities appear to have impacts on avoidance and redistribution of caribou, (Johnson & Russel, 2014). These behavioural effects might decrease survival and reproduction including

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retreat from favourable habitat near disturbance sources and the reduction of time spent feeding causing energy depletion over time (Reimers & Edward, 2006). These findings were supported by a study reviewing 85 studies of long-term regional impacts on rangifer (caribou). 83% of them concluded that impacts from human activity were significant. The extent of the impact did vary with terrain, season, sex and sensivity of the herds, (Vistnes & Nelleman, 2008). Further studies from North America on caribou behavior concluded that calving caribous avoided the area within 5-6 km of the human disturbance, (Cameron, 1992). The background level of human disturbance in areas with low human activity and very limited industrial development, as in most of Western Greenland, is mainly due to hunting (Skogland, 1988). The White Mountain area is occasionally used by hunters to access the Aussivit Valley to the north of the project area but most of the camps are situated on the southern bank of Sondre Stromfjord, with the largest (and most used) at the bottom of Angujortarfik. Aerial surveys conducted by GINR in the area revealed low densities of caribou within the project area, (Cuyler, 2012). This finding was supported by very few caribou observations made during the three years of biological survey and other project related activities in the area. The Greenland caribou typically move around in small groups of 3- 10 animals (whereas in North America they form large herds). It is expected that the caribou will maintain a distance of >6m from the infrastructure components. However, this will only influence a few animals and will not obstruct any migration routes or calving areas. Thus, the overall impact from the project on the caribou is considered minor. In summary, the mining activities will cause localised disturbance of birds and terrestrial mammals, however the overall impact by mining activities is assessed as minor.

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact significance Geo. Magnitude Frequency Extent

Impact phases: Construction, Operation and Closure

Birds Disturbance Local Low Long- Daily Minor Likely Minor term

Mammals Disturbance Local low Long- Daily Minor Likely and re- term Minor location

7.9.4 Loss"of"Terrestrial"Habitat"" As a consequence of the construction and subsequent operation of the Project, habitat will be lost due to seizure of land and human generated noise. Some habitat restoration

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will occur upon decommissioning, reclamation and closure as Project elements are removed and disturbed areas allowed to be re-vegetated. The affected wildlife habitat types within the project area are common and found throughout the region, see Figure 5.12, and as such no habitat will be lost that is unique to the region or that is critical for the survival of a specific species or population.

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact significance Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Mammals Relocation Local Moderate Long- Daily Low High Minor due to term size of area and Noise

Birds Disturbing Local Minor Long- Daily moderate Low Minor of nesting term and resting areas for birds

Mitigation: none

7.9.5 Changes"of"Freshwater"Habitats" Tailings disposal into Lake A will change the habitat in the lake from being a relatively deep (>20 m) lake into a shallow lake. In general, during the summer shallow water lakes have a higher mean temperature than deep lakes. This leads to an increased outflow temperature of water from Lake A as it becomes shallow. The effect on the river continuum from increased temperature is however very limited, due to the large quantity of water in the three downstream lakes and to the shallow nature of the rivers connecting them. Thus, a change in water temperature at the outflow from Lake D is unlikely. Colonization of plants will also prevent re-suspension of the lakebed in the shallow water and it will be colonized with invertebrates. Ultimately, the habitat in Lake A will change as a consequence of the project. The changes will be local (only in one lake) and the magnitude minor because many similar lakes can be found in the area. The project will lead to elevated levels of suspended solids in Lake A and, most likely, Lake B. The two lakes downstream of Lake B will function as sedimentation reservoirs preventing suspended solids spreading into the river outlet from Lake D. It is not expected that the impact from suspended solids will have any effect on invertebrates or fish downstream of Lake D. The habitats in the rivers could theoretically change due to the sedimentation of solids. Special concern would be fine sediment overlaying the gravel at the spawning areas for

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Arctic char. The four lakes will function as sedimentation basins and it is unlikely that any suspended solids will be found downstream of Lake D. It is not expected that the impact will effect the arctic char because they at not present in the area. The nitrogen load to the river system from blasting (in the tailings) is expected to increase by an average of 4 µg/l per year. According to the Greenland Water Quality Guidelines the limit for discharge of nitrogen to aquatic systems is 8 mg/l. The level of nitrogen introduced by the project is so low that the nitrogen level exceeding 8mg/l is unlikely.

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact significance Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Lake Physical Local No Long- Daily Minor high Negligible habitats changes term

River Physical Local No Long- Daily Minor low Negligible habitats changes term

7.10 Invertebrates Midges are the most common invertebrate species and have been found in all rivers. The ecological role of the midges are important as they are the major actor in canalizing energy up the food chain. They eat the benthic algae and in turn serve as a food item for fish.

7.10.1 Effect"of"Suspended"Solids" The impact of elevated levels of suspended solids (SS) from the project will be limited to the area upstream from the outlet of Lake D. Benthic invertebrates are, in general, able to withstand temporary high levels of SS and recover quickly after exposure. They become increasingly affected over long term exposure. The effects from SS on the invertebrates are species specific and affect filtrators more than others. The effect includes; forced drifting, changed respiration and decreased settling of new individuals, (Robertson et al, 2006). Thus, the density of invertebrates is expected to decrease in Lake A and B, during the entire project period. The overall impact from the mining activities on invertebrates is negligible as the midges habitat can be found throughout west Greenland. Post-closure, re-colonization will be fast due to their high mobility.

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7.10.2 Effect"of"Contamination" High freshwater copper concentration is only chemical element of concern for invertebrates. Naturally high levels of around 8 µg/l of copper occur in the project area due to the local geology. It is expected that any addition of copper into the watershed from the tailing disposal will only increase the concentration by 0.4 µg/l to 8.4 µg/l (Section 7.3.3). High copper concentrations may impact both the benthic and planktonic invertebrates and a generally high mortality of tested aquatic species is greatest under conditions of low water hardness (as measured by CaCO3), (Eisler., 1997). The daphina is a planktonic invertebrate-group commonly found in Greenlandic lakes. Life-cycle exposures of four daphnia species to graded concentrations of copper show reductions in survival at more than 40 ug Cu/L and reductions in growth and reproduction at 40 to 60 ug Cu/L (Eisler., 1997). Studies have found that freshwater zooplankton assemblages show that increasing copper concentrations in the range 0 to 50 ug/L causes a reduction in total Zooplankton and changes in diversity. Within 4 days, copepods became dominant at the expense of cladocerans (including daphina), (Eisler, 2000). The impact from the mining activities on zooplankton in the area is expected to be minor because the accumulated (background and leaching) concentration will be below the level where significant effects on the zooplankton can be expected. The benthic invertebrate community in the lakes and rivers consists of midges. Midges are in general tolerant toward high copper concentrations and lethal effect (LC50) has been found at 30 µg/l (50 mg/l CaCO3). Less tolerant is the mayfly and large mortalities have been found at concentrations of 25 µg/l in ten days, (Eisler, 2000). The impact on the invertebrate community is expected to occur throughout the entire project duration but on a local scale and moderate in magnitude. The overall impact on the invertebrate community is assessed to be minor.

7.11 Freshwater Fish The freshwater fish community includes the Arctic char and the three-spined stickleback. The major impact on these species will be due to increased levels of suspended solids and contaminants.

7.11.1 Suspended"Solids" Freshwater fish can, in general, tolerate high levels of suspended solids (SS). Lethal effect is first seen at concentrations above 10,000 mg/l. (Robertson et al, 2006). Suspended solids in the tailings pond will however have a major effect on macrophyte production due to increased turbidity in the water. This will decrease

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production due to a reduction in available sunlight in to the lake. This means the macrophytes, benthic algae and phytoplankton will produce less organic matter, which will reduce some inputs in to the food chain. This will have a major effect in Lake A (tailings pond) and a minor effect in Lake D. The SS may potentially influence both Arctic char and the three-spined stickleback. The project is not expected to cause any elevated levels of suspended solids downstream of Lake D. The impact on the Arctic char from suspended solids from the project is negligible, because the char is only capable of migration to station 21, which is far downstream of Lake D. In the four lakes with elevated levels of suspended solids, there is a population of three-spined stickleback. It has been found that three-spined stickleback experience no lethal effect from suspended solids concentrations of 28,800 mg/l., however behavioural effects are expected at lower concentrations.

The overall effect on the freshwater fish from suspended solids is local and limited to the three-spined stickleback. The impact has been determined to be minor the three-spined stickleback is very tolerant to suspended solids and no elevated SS will occur in the area of the Arctic char population.

7.11.2 Contamination"of"Fish" As with the invertebrates, high freshwater copper concentration is only chemical element of concern for freshwater fish. Naturally high levels of around 8 µg/l of copper occur in the project area due to the local geology. It is expected that any addition of copper into the watershed from the tailing disposal will only increase the concentration by 0.4 µg/l to 8.4 µg/l (Section 7.3.3). No copper dose response experiments on Arctic char (Salvelinus alpinus) have been found but the very similar brook char (Salvelinus fontinalis) was investigated and it was found that concentrations from 3.4 to 17.4 µg Cu/L did not affect survival, growth, and reproductive of adults. However exposure to concentrations of 17.4 and 32.5 µg Cu/L showed noticeable effects on survival and growth of fry and juvenile. The LC50 was found to be 100µg Cu/l at exposure of 96 hours, (Eisler., 1997). The effect of copper on Arctic char is expected to be similar to that of the brook char. The effect from copper on the population of arctic char in the project area is expected to minor as the maximum levels of copper in the river continuum are below the LC50 threshold levels. Arctic char is a part of the human diet and high levels of copper in the fish meat may accumulate in humans as well. Accumulation of copper in the char is dependant on the metal concentration in the water and the duration of exposure. Thus, long-time exposure to low levels will have similar effects as short exposure to high concentration (Jezierska & Witeska, 2006). Accumulation of metals is also species specific and is more pronounced in specific organs such as the liver, kidney, gills digestive organs and spleen. Accumulation in tissue is normally very low, (Jezierska & Witeska, 2006). The

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impact from the elevated levels of copper is therefore assessed to be of no threat to human health.

VEC Activity and Residual impact assessment criteria Consequen Probabili Overall Potential ce ty significance impact Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Invertebrate Physical due Local Minor Long- Daily Minor Likely Minor to affected term lake area

Fish (Arctic Physical due Local Minor Long- Daily Minor Likely Minor char and to affected term three-spined lake area stickleback)

Invertebrate Tailings Local Negligible Long- Daily Negligible Likely Negligible deposit term

Suspended solids

Fish (Arctic Tailings Local Negligible Long- Daily Negligible Likely Negligible char and deposit term three-spined stickleback) Suspended solids

Invertebrate Tailings Local Minor Long- Daily Minor Likely Minor deposit term

Contamination

Fish (Arctic Tailings Local Minor Long- Daily Minor Likely Minor char and deposit term three-spined stickleback) Contamination

7.12 Marine Ecology The marine ecosystem in Greenland holds fewer species than temperate systems. The production is low and the organisms are adapted to the long periods with no or little light. Disturbance from human activities will mainly impact those organisms that are sessile or have special affinity for the area where changes may occur. In relation to the White Mountain project, several VEC’s have been identified: marine habitat, invertebrates and Arctic char. There have been identified two activities related to the mining process that could potentially influence the marine habitats:

• Construction of a harbour (Sondre Stromfjord). • Contaminants and increase of levels of nutrients (Itilleq fjord).

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The harbour will be constructed as a permanent wharf with or without a floating dock. The construction work and harbour operation will include seizing and re-profiling some of the coastline and intertidal area. It is projected that approximately 150m of coastline and 20-30 meters off the shore will be changed. This will cause loss of intertidal habitats. The seabed area that is expected to be seized has been surveyed with divers and no VEC organisms were found and the intertidal habitat is similar to habitats found along the northern coast of Sondre Stromfjord. The impact from the harbour facilities on the marine habitat is permanent but local and does not differ significantly from the existing environment. The overall impact from the port footprint is assessed to be negligible. The nitrogen load in the river system is expected to increase by about 4 µg/l per year. The fjord area at the outlet from the river is eutrophicated with the large amount of the nutrients algaes ectocarpus and pilayella. The magnitude of increase and load to the marine environment is very low and the effect on the marine habitat is negligible. According to the Greenland Water Quality Guidelines the limit for discharge of nitrogen to aquatic systems is 8 mg/l. The changes to the footprint on the marine area will be introduced mainly by construction of a harbour and by release and transportation of nutrients from the river continuum.

VEC Activity and Residual impact assessment criteria Consequ Probability Overall Potential ence significance impact Geo. Magnitude Duration Frequenc Extent y Impact phases: Construction, Operation and Closure Marine Physical due Local Negligible Long-term One time Minor high Negligible habitat to Seabed during the changes project. Marine Physical due Local Negligible Long-term Daily Minor high Negligible habitat to Nutrient increase Marine Physical due Local Negligible Long-term Daily Negligible high Negligible habitat to noise

7.12.1 Marine"Invertebrates" The invertebrates may primarily be affected by the elevated levels of copper; however, the general effect in the marine environment is expected to be lower than in freshwater (Wheeler et al., 2002). Some of the aquatic mollusks and arthropods possess hemocyanin that is a copper-containing respiratory pigment in the blood. Among marine organisms, the highest accumulations are generally found in mollusks tissues and lowest values were consistently found among the fishes and mammals (Citied in: (Eisler., 1997)). The most sensitive saltwater species to copper have LC50 (96 h) values from 28 to 39 ug Cu/L (Eisler., 1997). These tests are however performed in temperate climate where organisms in general is found to be less sensitive than cold-water species, thus organisms in the arctic may be sensitive at even lower concentrations. However, copper- temperature-salinity interactions are complex in some (most) marine invertebrate groups,

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(Eisler., 1997)”. It is therefore difficult establish more accurate values, as no studies has been performed under exact same physical conditions found in the White Mountain area. The BMP guideline is 2 µg/l and it is recommended in: ”Handbook of chemical risk assessment: health hazards to humans, plants, and animals” that, copper concentrations in marine ecosystems should not exceed 23 µg Cu/L (Eisler, 2000). The most abundant species in the intertidal zone are the common mussel (Mytilus edulis). The effect of copper on the common mussels includes valve closure that reduces the filtration rates and cardiac rhythm. This will reduce the uptake of copper through a reduction in mussel contact with the ambient water (Eisler., 1997). Thus, it was found that growth rate was affected negatively in common mussels introduced to 10µg Cu/L for 21 months (Eisler., 1997). The background levels of the water entering the Itilleq fjord were 8.6 µg Cu/L (St. 23.).The effect introduced from the project on the marine invertebrates is assessed to be negligible. as the copper levels may only increase very marginally and that no changes to the copper concentration in the seawater are expected.

VEC Activity Residual impact assessment criteria Consequ and ence Geo. Magnitude Duration Frequ Probabi Overall significance Potenti lity al Extent ency impact Impact phases: Construction, Operation and Closure Invertebrate Physical Local Minor Long-term Daily Minor high Negligible due to Contami nants

7.12.2 Marine"Fish" The effect of elevated levels of copper on fish has been found to decreases with increasing salinities (Blanchard & Grosell, 2006). Thus, the effect of copper on Arctic char in the is therefore expected to be lower than in freshwater compared to saltwater, making the char in the marine environment less affected by elevated levels of copper and the significance is negligible.

VEC Activity and Residual impact assessment criteria Consequ Probabi Overall Potential ence lity significance impact Geo. Magnit Duratio Frequenc Extent ude n y Impact phases: Construction, Operation and Closure Fish Physical due Local Minor Long- Daily Negligible high Negligible to term (Arctic Contaminants char)

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7.12.3 Marine"Mammals" Marine mammals may primarily be affected by the increased traffic and noise in the area. These impacts will probably result in avoidance behaviour of the marine mammals away from the impact source. Greatest impact on marine mammals is expected to occur during construction of the harbour but the area is small and the impact is expected to be negligible. Concerning impact from possible contaminants, the only outlet from the area is the waste water from the sewage treatment unit. This waste water is of such a quality, that no effects are foreseen. As the abundance of marine mammals in the inner Sondre Stromfjord, where the project is situated, already are very sparse, only negligible effects on these are expected.

VEC Activity and Residual impact assessment criteria Consequ Probability Overall Potential ence significance impact Geo. Magnitude Duration Freque Extent ncy

Impact phases: Construction, Operation and Closure

Mammals Physical due Local Negligible Long-term Daily Minor high Negligible to noise

Mammals Physical due Local Negligible Long-term Daily Moderate Low Negligible to Contaminants

7.13 Introduction of invasive non-indigenous species with ballast water It is well known that invasive and non-indigenous species can be spread worldwide by ballast water. When these species are introduced to new areas, they might be able to reproduce themselves and thereby represent a threat to the local ecosystem. In order to prevent the potentially devastating effects of spreading of potential harmful aquatic organisms, the International Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM Convention) was adopted in 2004. The convention will come into force 12 months after ratification by 30 States, representing 35 % of world merchant shipping tonnage. As of March 2013, 36 states representing 29,07% of the world merchant fleet tonnage, have ratified the convention, including Denmark. The convention prescribes change of ballast water in mid-ocean and is expected to be strengthened within the next few years with criteria’s for ballast water treatment.

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Realizing that the bulk-carrier Hudson intend to use to ship the anorthosite out with, is obliged to follow the international rules, including the BMW convention, the introduction of invasive or non-indigenous species are considered low.

VEC Potential Residual impact assessment criteria Conseq Probabi Overall impact uence lity significance Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Aquatic Introduction Regional Major Long-term Daily high unlikely Low of invasive Ecosyste or non- m indigenous species

7.14 Cultural Heritage and Human Activities

7.14.1 Cultural"Heritage" As described in Section 5.5.1, the Greenland National Museum and Archives (GNMA) has surveyed the area for archaeological remnants. The GNMA’s conclusion was that the proposed road between the pit site and port does not comprise any severe conflicts with mapped and protected archaeological structures, although a shooting blind, might conflict with the proposed road and the southern part of the pit area. GNMA suggested that it is preferable that the blind is not disturbed, but if redirecting the road is not possible, destruction of the blind can be considered, as it is not a unique structure. Hudson will take every precaution to protect the blind, and if possible, will move it out of harms way. Any action on the blind will be discussed with the GNMA prior to any decisions.

VEC Potential Residual impact assessment criteria Consequence Probability Overall impact significance Geo. Magnitude Duration Frequency Extent

Impact phases: Construction, Operation and Closure

Archaeological Physical Local high Long- Daily high low Minor remnants term

7.14.2 Human"Activities" As a consequence of the rather limited population density of caribou and muskox in the project area, very few hunters visit this area.

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Although many of the rivers contributing to Sondre Stromfjord hold stocks of migratory Arctic Char, and as such are subject to fishing activities by the local hunters/fishers, none of these rivers are situated in or in the vicinity of the project area. The river receiving water from the project area also holds a stock of migratory char, but due to a natural obstruction approximately 3 km downstream of the pit area, no char have been registered within the project area. Further downstream of this river, some fishing for char occurs, but probably only in a very limited scale (personal supply). Due to depositing of tailings further upstream, and the formation of suspended solids, this stock might be affected, although only limited. This river ends in the Itilleq fjord. Itilleq Fjord is mainly visited by people from Itilleq and Sisimiut for hunting caribou and fishing Char. The main hunting area is the Aussivit Valley, which also contains good fishing possibilities (stakeholder-engagement, 2013). Overall it is assessed that the impact from the proposed mining operation on human activities will only be minor, as the overall footprint is of such a limited geographical scale.

VEC Potential Residual impact assessment criteria Consequ Probability Overall impact ence significance Geo. Magnitude Duration Frequency Extent Impact phases: Construction, Operation and Closure Caribou Relocation of Local Moderate Long-term Daily Moderate High Minor and game Muskox Physical Hunting Char Reduced Local Moderate Long-term Daily Moderate Low Minor fishing stock or increased content of chemicals

7.15 Cumulative effects As the area is quite remote and no other activities are planned in the vicinity, no cumulative effects are foreseen.

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8 Environmental Management Plan The purpose of the Environmental Management Plan (EMP) is to minimize negative impacts of the mining operation during construction phase, operation phase and decommissioning phase. The EMP consists of several individual management plans, each dealing with specific potential activities and their impacts from the planned operation. In summary the EMP will be applicable to the following areas/activities of the mine project:

• Open pit mining operation • Traffic • Ore processing and infrastructure • Water supply • Offices and associated support facilities • Maintenance activities associated with the above areas The EMP describes how the risks identified in the EIA will be mitigated during the construction, operation and decommissioning phases of the mine project. The EMP will derive from the EIA findings and analysis and will detail:

• the measures to be taken by Hudson and it’s contractors during all phases of the project to eliminate or avoid adverse environmental impacts identified in the EIA, or to reduce them to acceptable levels, • the actions needed to implement these measures • the responsible for those actions. The EMP will include the following:

• Health and Safety Plan • Dust Management Plan • Noise Management Plan • Tailings Management Plan • Public Safety Plan • Waste Management Plan • Spill Response Plan • Decommissioning Plan

It is anticipated that the EMP will evolve during the life of the mine taking into account the feedback provided by the monitoring and operational progress.

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9 Environmental Monitoring Program Environmental monitoring is to be carried out during the construction, operation and decommissioning phases. The monitoring is focused on detecting potential adverse effects, not covered by the mitigating measures implemented. Based on the baseline surveys and the Impact Assessment a number of potential biotopes/fauna elements have been selected for this monitoring Program. The selected elements cover marine recipients, fresh water recipients and terrestrial recipients. The environmental monitoring programs for each recipient are described in details in the following.

9.1 Marine Monitoring Program The marine monitoring program covers collection of indicator species plus sediment at five stations, inclusive of the reference station, see Figure 9.1. At all five stations a full sampling set will be collected. The full sampling sets consists of:

• Livers from five large female sculpins (Myoxocephalus scorpius), together with information of liver weight and the length and weight of the female sculpin. • Meat from 20 common mussels (Mytillus edulis) from each of the three size groups (2-3cm, 4-5cm and 6-7cm) together with information of the length of each mussel (mm) and the total weight of meat from each size group. • A handful of new growths (tips) of bladder wrack (Fucus vesiculosus). • A marine sediment sample All samples shall be numbered and registered according to the instruction from DCE and kept frozen for later analysis, including at least: arsenic, copper, nickel, zinc, mercury, cadmium and lead.

Table 9.1 - The sampling positions or the marine stations.

Northing Station Easting (Lat_deg_dec) Lon_deg_dec. Marine M-1 -52.070580 66.556350 Marine M-2 -52.096313 66.538979 Marine M-3 -52.036523 66.577473 Marine M-4 -52,471320 66.524740 Marine Reference station -51,149600 66.843400

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Figure 9.1 - Map of marine sampling positions at the White Mountain project area As the indicator species to be sampled in the marine and intertidal environment all are slow growing, the sampling should be carried out once a year in August-September (end of growing season).

9.2 Fresh Water Monitoring Program The fresh water Monitoring Program covers the collection of water and sediment samples (quality), in-situ measurement of water parameters (pH, temperature and conductivity), assessment of macro-invertebrates and assessment of the stock of Arctic Char in the water bodies from immediately upstream of the tailings pond down to the outlet at the Itilleq Fjord, see Figure 9.2. At each station the following should be performed: • In-situ measurements of pH, temperature and conductivity • Collection of a filtered and an un-filtered water sample for later analysis of Arsenic, Lead, Cadmium, Chromium, Copper, Nickel, Zinc, and Mercury. In addition to these the content of Total Suspended Solids (TSS) will be determined. • Collection of a sediment sample • Quantitative and qualitative measurement of extent of aquatic vegetation. • Collection of macro-invertebrate communities • Fish habitat assessments (consisting of quantitative electrofishing) at all stations except at st.20 and st.31

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Table 9.2 - The sampling positions for water stations.

Northing Station Easting (Lat_deg_dec) Lon_deg_dec. Freshwater 20 66,55970 -52,16660 Freshwater 21 66,51880 -52,24910 Freshwater 22 66,51210 -52,26450 Freshwater 23 66,51850 -52,40450 Freshwater 31 66,54983 -52,18358 Reference station WM7 66,56930 -52,13620

Figure 9.2 - Overview of fresh water sampling stations Collection of water and sediment sample and the In-situ measurements of pH, temperature and conductivity, should initially be conducted every third month the first year of operation. Dependent on the results from the analyses, the frequency can be reduced in the following years. With respect to the monitoring of aquatic vegetation, the collection of macro-invertebrate communities and the fish habitat assessments (electrofishing) this will be performed once

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a year in August/September, where the Arctic Char are migrating to the spawning grounds.

9.3 Terrestrial Monitoring Program The terrestrial monitoring program encompass monitoring of the indicator species, the snow lichen ( F. nivialis), the small Round-leaved Orchid (Amerorchis rotundifolia) and the wildlife (birds and mammals). The snow lichen will be collected from a series of stations situated in arrays stretching NE, SE, SW and NW from the pit site. The sampling stations are situated in respective 1 km, 2 km and 4 km from the pit site when possible, see Figure 9.3 In addition to monitoring the lichens around the pit, an extra array of lichen monitoring stations have been added, hereby allowing monitoring of potential impact (dust) from the road and port site, see Figure 9.3 Furthermore, a new reference station will be determined and sampled. The exact positions to sample lichen are presented in Table 9.3.The lichens shall be analysed for at least: arsenic, copper, nickel, zinc, mercury, cadmium and lead.

Table 9.3 - The sampling positions for lichen stations. Northing Station Easting (Lat_deg_dec) Lon_deg_dec. LN1 66,58420 -52,10170 LN2 66,58730 -52,12490 LN3 66,59250 -52,16530 LN4 66,58930 -52,07250 LN5 66,59760 -52,06530 LN6 66,61480 -52,04970 LN7 66,57280 -52,08780 LN8 66,56410 -52,09530 LN9 66,54770 -52,11080 LN10 66,57870 -52,05820 LN11 66,57650 -52,04150 LN12 66,59968 -52,21131 L1 66,55297 -52,20795 L2 66,55610 -52,23112 L3 66,56127 -52,27153 L4 66,55804 -52,17870 L5 66,56631 -52,17148 L6 66,58356 -52,15592 L7 66,54152 -52,19405 L8 66,53311 -52,20149 L9 66,51645 -52,21707 L10 66,54746 -52,16438 L11 66,54495 -52,14391 L12 66,53944 -52,10034 L13 (Ref) 67,05531 -50,48295

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Figure 9.3 - Sampling stations for Lichens (F. nivialis) The wellbeing of the small Round-leaved Orchid (Amerorchis rotundifolia), will be subject to registration. As this orchid possesses the ability into enter into a dormancy stage, which can last several years, where it is difficult to distinguish whether it is dead or alive, the survey will only cover a registration on presence/absence. In addition to the above collections, the presence of wildlife in the area will be registered. This registration will be performed on a day-to-day basis by the workers on-site, who will report their observations to the site manager for registration. Frequency: The collection of Lichens will be carried out once a year, preferably in connection with the aquatic monitoring in August/September. Presence of the small Round-leaved Orchid (Amerorchis rotundifolia), will be conducted once a year. Registration of wildlife will be conducted on a daily basis by the local staff.

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10 Closure Activities A conceptual closure plan has been developed to cover decommission of all the project components. The overall objective of the mine closure plan is minimizing of the long-term physical footprint, to prevent or minimize adverse long-term environmental impacts and to create a self-sustaining nature. The end result should be at a state acceptable to the supervising authorities (the Greenland Government) and the community. The closure activities may also involve establishing new habitats such as lakes; again this will be done with full knowledge and acceptance by the supervising authorities The main objectives of the closure plan are to:

• Provide for the reclamation of all affected sites and areas to a state compatible with the original undisturbed area • Return all altered water courses (if any) to their original alignment and cross-section • Provide for the long-term physical and chemical stability of the project area so as to protect the public health and safety and ecosystem integrity • Promote natural re-vegetation and recovery of disturbed areas that is compatible with the surrounding natural environment and to allow for the future use by people and wildlife The general elements of the closure Plan are presented in the following:

10.1 Close Down and Decommissioning of the Mine Given the relative limited area affected by infrastructural elements (pit, road and process plant areas) and the limited number of buildings and equipment present, the decommission period is anticipated to last six months.

10.2 Pit Area

• Remove vehicles, pumps, crushers, generators and explosive storage and ship it out • Remove gravel pads and waste rock enhancing re-vegetation • Allow the pit to be naturally filled with water. Note: Depending on the life of the mine, there may be no actual pit, only benches in to the hill.

10.3 Tailings Pond

• Remove constructed facilities next to the lake and ship these out • Remove pipes in the lake

10.4 Road-Transect

• Remove culverts

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• Re-establish the normal drainage system in a natural way by precipitation • Remove possible gravel pads enhancing re-vegetation • Decommission pipelines, all pipes and equipment • Remove supporting structures for pipes

10.5 Camp Site

• Buildings will be salvaged and removed by barge or ship for reuse, recycling or disposal, • Demolish remaining buildings with demolition equipment and remove these by ship/barge • Remove all equipment and installations. • Road culverts will be removed where appropriate and the natural drainage system restored General Excess organic material will be incinerated on-site. After the closure the footprints from the mining activities will comprise:

• Tracks from gravel pads, staging areas and access roads at port and plant site, all being ripped to enhance re-vegetation, • A new lake as a consequence of the pit will be allowed to fill with The mine will cause more or less permanent disturbance of the vegetation, as colonization of the abandoned roads and quarry and other barren areas will be very slow. The total disturbed area covers all in all approximately 30 hectares.

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11 Public Consultation This section will describe the public consultations and the questions raised at these meetings.

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12 Conclusions The environmental consequences of the proposed mining project have been assessed with the result that the project can be implemented with only minor consequences for the environment. Concerning fauna and flora, no disturbing areas of international importance or caribou calving areas will occur. However the project will result in disturbance of caribou and muskox in the project area at a distance of up to five km from the infrastructure components. This disturbance will have a moderate effect on the already sparse hunting activities in the area. The deposition of tailings in Lake A is anticipated to be safe, as the tailings do not have any acid generating potential. The tailings material does not contain any significant metal content and the leaching of metals is regarded as low. During closure of the mine, all infrastructural elements, including culverts, will be removed The disposal of tailings in Lake A will be submerged with no visible or other impact, beside a reduction of the habitat for three-spined stickleback. The main long lasting impacts after mine closure are the remnants of the quarry. The remains of the road will be left in place, although ripped to encourage re-vegetation. A comprehensive environmental management plan and monitoring program ensure that emerging and unforeseen problems will be handled in a timely and appropriate manner.

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13 References, authors Doris North Mine. (2005). Doris North Gold Mine Project - Technical report. Doris North Mine.

Blanchard, J., & Grosell, M. (2006). Copper toxicity across salinities from freshwater to seawater in the euryhaline fish Fundulus heteroclitus: Is copper an ionoregulatory toxicant in high salinities? Aquatic Toxicology , s. 131-139.

Blossom, N. (2014). Copper in the Oceanic Environemnt. Hentede 29. 07 2014 fra http://www.chemet.com/file.asp?F=Copper+and+the+Ocean+Environment1.PDF&N=Cop per+and+the+Ocean+Environment1.PDF&C=articles.

BMP. (2011). BMP guidelines – for preparing an Environmental Impact Assessment (EIA) Report for Mineral Exploitation in Greenland”. Bureau of Minerals and Petroleum, Greenland.

Boertmann, D. (2007). Grønlands Rødliste – 2007. Danmarks Miljøundersøgelser og Grønlands hjemmstyre. 1. udgave, 1. oplag 2007, ISBN 978-87-990586-2-4.

Booms, T., & Fuller, M. (2003). Gyrfalcon Diet in Central West Greenland during the Nesting Period. The Condor , s. 528-537.

Born, E. W., & Böcher, J. (2001). Ecology of Greenland. Copenhagen: Aage V. Jensens Fonde.

Brezenski, J. (2011). TSS-turbidity relationship in yellowknife river in vicinity of proposed new NTPC bluefish dam. Northwest Territories Power Corporation.

Burnham, K., & Newton, I. (2011). Seasonal movements of Gyrfalcons Falco rusticolus include extensive periods at sea. IBIS, 153 , s. 468–484.

Burnham, W., & Mattox, W. (1984). The biology of peregrine and Gyrfalcon in Greenland. Meddelser om Grønland, Bioscience 14 .

Busnel, J. F. (1978). Effects of Noise on Wildlife. Academic Press Inc .

Cameron, R. R. (1992). Redistribution of calving caribou in response to oil field development on the arctic slope of Alaska. Arctic 45: 338-342 .

Christiansen, S. (2014). personal comm. Develop Manager Mittarfeqarfiit.

Colman, E. R. (2006). Reindeer and caribou (Rangifer tarandus) response towards human activities. Rangifer, 26 (2): 55-71.

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Cuyler et al., C. M. (2012). Status of two West Greenland caribou populations 2010, Technical Report No. 78, 2011; revised 2012. Christine Cuyler, Michael Rosing, Hans Mølgaard, Rink, Heinrich and Katrine Roundrup: Greenland Institute of Natural Resources.

Cuyler, C. R. (2012). Status of two West Greenland caribou populations 2010; 1) Kangerlussuaq-Sisimiut, 2) Akia-Maniitsoq. Pinngortitaleriffik – Greenland Institute of Natural Resources. Technicall Report No. 78.

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Appendix 1. Regulations and Guidelines National Regulations and Guidelines The national legislation and guidelines of particular relevance to the White Mountain mining project are presented in Appendix Table 1.

Appendix Table 1 - Summary of national legislation and guidelines.

Licensing and EIA Legislation and Guidelines

• Greenland Parliament Act No. 7 of 7 December 2009 on mineral resources and mineral resources activities (The Mineral Resources Act).

• Greenland Parliament Act No. 26 of 18 December 2012 amending the Greenland Parliament Act No. 7 of 7 December 2009 on mineral resources and mineral resources activities.

• BMP guidelines – for preparing an Environmental Impact Assessment (EIA) Report for Mineral Exploitation in Greenland, Bureau of Minerals and Petroleum,2nd Edition, January 2011.

Navigating in Greenland Waters Legislation and Guidelines

• Act on maritime safety (Consolidated Act No 903 of 12.07.2007).

• Order no. 417 of 28 May 2009 on technical regulation on safety of navigation in Greenland waters.

• Order no. 170 of 17 March 2003 on ship reporting systems in the waters off Greenland.

• Technical Regulation no. 169 of 4 March 2009 on the use of ice searchlights during navigation in Greenland waters.

Nature and Environmental Protection Legislation and Guidelines

• Greenland Home Rule executive order no. 31 of 20 October 1989 on Preservation of Arnangarnup Qoorua, Maniitsoq Municipality, West Greenland.

• Greenland Home Rule executive order no. 8 of 2 March 2009 on protection and hunting of birds.

• Greenland Government executive order no. 7 of 27 June 2013 on protection and hunting of wild reindeers.

• Greenland Government executive order no. 8 of 27 June 2013 on protection and hunting of muskoxen.

• Act No. 1048 of 26 October 2005 on the Greenland Working Environment

• Act No. 1382 of 23 December 2012 amending the act on the Greenland Working Environment.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

International Regulations and Guidelines According to the BMP EIA guidelines the environmental risks and impacts relating to a mining project have to be identified, assessed and minimized as much as it is possible and reasonably practicable, e.g. by using best available techniques (BAT) and best environmental practices (BEP).

Appendix Table 2 presents relevant important international treaties, conventions and guidelines on best techniques and best practices relevant to the White Mountain project.

Appendix Table 2 - International agreements and guidelines on BAT and BEP.

International Conventions

• United Nations Convention on the Law of the Sea (UNCLOS) 1982.

• International Union for Conservation of Nature (IUCN).

• Convention on Wetlands of International Importance especially as Waterfowl Habitat (RAMSAR) 1971.

• Convention on Biological Diversity (CBD) 1992.

IMO Conventions and guidelines

• Guidelines for Ship Operating in Polar Waters 2010.

• Convention on the Control of Harmful Anti-fouling Systems on Ships (Convention on anti- fouling systems) 2001.

• MARPOL Convention (Prevention of Pollution from Ships) 73/78.

• Convention on Oil Pollution Preparedness, Response and Co-operation (OPRC 90).

• Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (The London Convention) 1972.

• Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM Convention) 2004.

International Best Environmental Practice Guidelines

• Arctic Environment Protection Strategy; Guidelines for Environmental Impact Assessment (EIA) in the Arctic 1997.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

EIA Requirements The 2011 BMP Guidelines for preparing an Environmental Impact Assessment (EIA) Report for Mineral Exploration in Greenland provides a summary of the EIA process for mining companies operating in Greenland. The purpose of an EIA is to identify, predict and communicate potential environmental impacts of a proposed mining project for all phases from planning to post-closure, and to propose measures to address and mitigate potential impacts. The BMP guidelines require that the EIA covers all Project components (mine plus ancillary facilities such as roads, port, power source, etc.), phases (pre-mining exploration/planning through decommissioning and required post- closure monitoring), and the entire geographic region that could be affected by Project- related activities. Substantive public involvement is required for the EIA. Section 5 of this report provides more detail on the EIA process that will be undertaken for the Project.

EIA Submittal and Public Review Process The public must be involved in the EIA process and also informed about mine related activities once the mine is in production. At a minimum it is recommended to hold a public consultation meeting early in the EIA process. An additional informational meeting presenting relevant information regarding the EIA report, issues raised by the EIA, and potential mitigations for unavoidable adverse impacts is also recommended prior to final report submittal for government approval. The public consultation period following public disclosure of the EIA must be a minimum of eight weeks. Public objections and comments related to the Project must be addressed in the EIA process, and if they cannot be addressed, the reason must be explained. Following the public consultation, the EIA report must be revised accordingly and a final version produced as part of the basis for the final government approval. The formal public consultation process must be clearly detailed in a White Paper. The White Paper including the public’s comments and how they have been addressed in the EIA must be provided to the BMP in a separate document from the EIA.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Appendix 2. Dust Calculations Potential dust emissions resulting from hauling ore and tailings have been calculated for the White Mountain project. It is expected that this activity will produce over 90% of all dust on the site. This is due to the site having a relatively long haul road at 10.5 km and the fact that there are no large uncovered stockpiles of material to create major dust issues. (Reference http://www.msha.gov/NIOSH/RI9689DustControl.pdf) The key areas where the potential for dust to be created are as follows:

Activity Estimated Portion of Dust Generated Drilling and blasting in the pit 2-3% Primary and secondary mobile crushers at the pit 5% Haul trucks driving to and from the pit and plant + 90% Loading of material in to the process building <1% Loading vessels by mobile ship loader <1%

The following calculations for road dust emissions at White Mountain have been calculated based on US EPA AP-42 guidelines. The Government of Canada also utilizes these guidelines. US EPA Guideline AP-42: Compilation of Air Pollutant Emission Factors: Environment Canada Guidance for Road Dust Emissions for Industrial Unpaved Surfaces: http://www.ec.gc.ca/inrp-npri/?lang=En&n=5DF2CF83-1 The annual emission estimates can be obtained using the following generalized equation (USEPA, 2006):

Ex = VKT*EFx*ADJ*(1-CE/100) Where:

• Ex: Emission of contaminant x, kg; • VKT: Annual total vehicle kilometers travelled, km; • EFx.: Emission factor of contaminant x, kg/VKT; • ADJ: Adjustment factor for precipitation, snow cover and frozen days; • CE: Applied Dust Control Method’s efficiency, %. VKT Calculation: Cycle time per truck will be 32 min for a one-way haul of 10.4 km. Based on 285,000 tpy ore, requirement is 1.5 trucks at 85% fleet availability. Therefore total truck km are (12.00 hr x 60 min/hr x .85/32) x1.5 x 10.4 x 2 x 270 day =161,109 truck-km/yr for return trips.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Emission Factor (EF) for Emissions from Unpaved Road Surfaces USEPA has developed an empirical equation for vehicles travelling on unpaved road surfaces at industrial sites (for more details refer to AP 42, Chapter 13: Miscellaneous Sources, Section 2.2, (USEPA, 2006)). The emission factor in metric units (i.e. kilograms/VKT) is calculated by the following equation: EF= k (s/12)a (W/2.72)b Where:

• EF: Size-specific emission factor, kg/VKT; • s: Surface material silt content, %; = 8.3 (for “s” number refer to Table AP-42 13.2.2-1 (US EPA, 2006): http://www.epa.gov/ttnchie1/ap42/ch13/final/c13s0202.pdf). • W: Mean vehicle weight, tonnes; = 41.3 (Volvo A35F - 57,300 kg loaded, 25,300 unloaded) • k, a, b: Numerical constants for calculation

Constant PM2.5 PM10 TPM

k (kg/VKT) 0.042 0.423 1.381

a 0.9 0.9 0.7

b 0.45 0.45 0.45

PM2.5 - Particulate Matter less than or equal to 2.5 microns in diameter

PM10 - Particulate Matter less than or equal to 10 microns in diameter TPM – Total particulate matter. EF Calculations:

0.7 0.45 • EFTPM = 1.381* (8.3/12) x (41.3/2.72) = 3.629 kg/VKT 0.9 0.45 • EFPM10 = 0.423* (8.3/12) x (41.3/2.72) = 1.032 kg/VKT 0.9 0.45 • EFPM2.5 = 0.042* (8.3/12) x (41.3/2.72) = 0.103 kg/VKT Uncontrolled annual emissions (no adjustment for weather or watering):

• ETPM = 160,109 VKT x 3.629 (kg/VKT) x (1 tonne/1 000 kg) = 581.1 tonnes • EPM10 = 160,109 VKT x 1.032 (kg/VKT) x (1 tonne/1 000 kg) = 165.2 tonnes • EPM2.5= 160,109 VKT x 0.103 (kg/VKT) x (1 tonne/1 000 kg) = 16.5 tonnes Adjustment factor for precipitation, snow cover and frozen days: The adjustment factor ADJ in equation 1 is defined as:

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

ADJ = (270 – (30 + 150))/270 ADJ = 0.3333

• ADJ = (Working Days-(p+snow))/Working Days • Where: • ADJ: Adjustment factor for precipitation, snow cover and frozen days; • Working Days: The number of operating days per year; • p: Estimated Annual Working Days with precipitation exceeding 0.2 mm; • snow: The estimated Annual Working Days when the roads were frozen or snow covered and wet for winter. Note: Calculation assumes ground is unfrozen June through September and there are a total of 30 days where precipitation will exceed 0.2 mm from May to September which is conservative given the monthly precipitation and temperature data for the area). Dust Control Method Efficiency The reduction of emissions by applying dust control methods is accounted for by multiplying the already adjusted emissions for precipitation and snow cover by the efficiency factor (1-CE/100):

EControlled = EAdjusted due to precipitation and snow cover x (1-CE/100) Where:

• E: Emissions (tonnes); • CE: Control efficiency Assuming a gravel surface of 10 cm and watering twice a day (CE = 55 %). Adjusting (ADJ) for weather and control efficiencies (CE), the total annual particulates coming from the haul road are projected to be as follows:

• TPM – 87.2 tonnes (0.545 kg/km) • PM10 – 24.8 tonnes (0.155 kg/km) • PM2.5 – 2.5 tonnes (0.016 kg/km) •

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Appendix Table 3 - Summary of Results from the Unpaved Industrial Road Dust Calculator

Annual Annual adjusted Adjustment factor Dust control Total uncontrolled emissions for Emissions ADJ for natural methods Release Units emissions natural mitigation mitigations adjustement (*) (tonnes) (tonnes)

Total Particulate 581.107 33% 193.702 45% 87.166 tonnes Matter TPM

Particulate matter less 165.246 33% 55.082 45% 24.787 tonnes than 10 µm PM10

Particulate Matter less 16.525 33% 5.508 45% 2.479 tonnes than 2.5 µm PM2.5

(source Environment Canada). (*) The total release takes in to account the natural mitigations and any other applied dust control methods.

As demonstrated in

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Appendix Table 3, the total annual particulates coming from the haul road are projected to be 87.2 tonnes. This equates to approximately 2.9 grams/m2/month which is within the Greenland Air Quality Criteria of 4.0 grams/m2/month. Appendix Figure 1 and Appendix Figure 2 below illustrate the projected dust dispersion area at the pit and the process plant site. Dust is expected to be generated along the entire length of the road, in the area of the ore stockpile and during ship loading operations. The process plant and storage building are enclosed structures and will be equipped with dust control systems. The ship loader will be fitted with a dust suppression spout and dust extraction system to minimize fugitive dust during loading operations. The company will comply with the Greenland Air Quality Criteria on dust: 200 m from roads, 500 m from open pits and 300 m from ports of unloading

Appendix Figure 1 - Expected dust dispersion at the camp/port site To limit the transfer of dust in to the surroundings, Hudson will take all reasonable actions to ensure that fugitive dust emissions are minimized using the best management practices associated with the industry. Hudson has developed a Dust Management Plan (DMP) that will serve to minimize all dust emissions from the operation, so that the risk to human health and the environment is minimized. To accurately calculate dust potential, air quality monitors will be set up during the construction phase, and the results will be used to adjust the DMP prior to production start-up, if needed. The Dust Management Plan includes the following:

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Rock Drilling

• The rock drill will utilize a drill shroud to minimize the emissions of fine dust particles. The drill will also have an enclosed operator cab to protect personnel. The dust collectors will be maintained to the manufacture’s specifications. (http://www.cdc.gov/niosh/mining/UserFiles/works/pdfs/2012-112.pdf) Crushing and Screening

• Where possible, the height of lifts and discharge distances to the top of the stockpile will be kept to a minimum and aligned parallel to the prevailing wind to minimize dust generation

• Installation of dust control systems including hoods and flaps on both of the mobile crushers located at the pit

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Appendix Figure 2 - Expected dust spreading at the pit site Haul Roads

• A truck or trailer mounted tank will be located on site at all times and will be equipped with a spray bar to deliver water or another approved dust suppressant (such as calcium chloride in the winter months) evenly over the haul route surface. • Dust suppressant supply will be available to allow the tanker truck to fill and apply the full payload each hour, if necessary, during dry conditions. • The actual application rate will vary, depending on surface moisture conditions and traffic conditions, and will be triggered whenever the site manager or scale operator observes trucks producing a trailing cloud of dust greater than 1/3 of a trailer length. • The haul road will be re-graded approximately monthly during May to October, to ensure that loose fine material on the haul route surface is minimized. • Trucks and other mobile equipment will reduce speed as necessarily to reduce trailing dust clouds. The maximum speed will be 50 km/hr.

Environmental Impact Assessment (EIA) - White Mountain Anorthosite Mining Project

Truck Loading and Transportation

• Truck loading will be suspended if the site manager observes the material to be dry and dusty and the wind is at a speed greater than 50 km/h (14m/s) or otherwise sufficient to cause widespread visible emissions.

• The highest point of the material loaded into a truck will not exceed the vehicles tray walls unless it is covered.

Process Plant

• All process equipment in the plant will have dust suppression equipment and 100% of the dust in the process plant will be captured as it is a potentially valuable product for the company.

Wind Erosion of Exposed Faces

• Extraction will be suspended if the condition of the quarry face is dry and dusty and the wind is greater than 50 km/h (14 m/s) or otherwise sufficient to cause widespread visible erosion of the open face.

• Rock stockpiles will be located on the pit floor in close proximity to the extraction face or in the stockpile area.

• Wind forecasts will be monitored regularly during this phase of the operation to anticipate the need for these measures and allow for next day planning.