ToR VVM Kvanefjeld - ENG
ToR VVM Kvanefjeld - ENG
ToR VVM Kvanefjeld - ENG
Environmental Impact
Assessment
Kvanefjeld Multi-Element Project
TABLE OF CONTENTS
1 INTRODUCTION 1
1.1 The EIA Process 1
1.2 The Project 2
1.3 Scoping workshops 2
1.4 The Terms of Reference (“ToR”) 3
2 SCOPING AND ENVIRONMENTAL STUDY PLAN 4
2.1 Initial Terms of Reference Approved July 2011 4
2.2 Developments since July 2011 4
2.3 Current Status July 2014 7
3 REGULATORY FRAMEWORK 9
3.1 The political situation in Greenland 9
3.2 Legislation in Greenland 10
4 BRIEF DESCRIPTION OF THE PROJECT 11
4.1 Initial Terms of Reference Approved July 2011 11
4.2 Current Project Brief (Scenario 2) 12
4.2.1 The Mine 13
4.2.2 The Processing Plant 14
4.2.3 The Tailings Storage Facility 15
4.2.4 The Port 15
4.2.5 The Accommodation 15
4.2.6 Other Infrastructures 15
4.2.7 Expected Workforce 15
4.3 Alternative Case (Scenario 1) 16
5 THE EIA PROCESS 19
5.1 Approach to the EIA 19
5.2 Scoping phase 19
5.3 Environmental Study Program 21
5.4 EIA report 22
5.5 Environmental Management Plan and Environmental Monitoring Program 24
5.6 Public Consultation 24
5.7 Study Area and Temporal Boundaries 24
6 THE ENVIRONMENTAL STUDY PLAN 26
6.1 Previous Baseline Sampling 26
6.2 Additional Studies to be Implemented 28
6.3 Proposal for a Table of Contents for the EIA report 37
ANNEX 1: NOTES TO DRAFT TOR FOR EIA, JUNE 2011 42
ANNEX 2: COMMENTS TO AMENDMENT TO THE TOR FOR EIA AND DRAFT PLAN OF
STUDY EIA OF KVANEFJELD MULTI-ELEMENT PROJECT 2013 43
ANNEX 3: STAKEHOLDER CONSULTATION 44
ANNEXES
1 Notes to Draft ToR for EIA, June 2011
2 Comments to amendment to the ToR for EIA and draft plan of study 2013
3 Stakeholder consultation
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LIST OF FIGURES
LIST OF TABLES
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1 INTRODUCTION
On 9 December 2010 Greenland Minerals and Energy (“GME”) Ltd was given permission to
conduct feasibility studies into the Kvanefjeld Multi-Element Project (“Kvanefjeld”, “the
Project”) by the Bureau of Minerals and Petroleum (“BMP”). The feasibility studies, inclusive
of an Environmental Impact Assessment (“EIA”) for Kvanefjeld, are a pre-requisite for
obtaining an Exploitation Permit.
In January 2011 the BMP issued updated Guidelines for Preparing an EIA report for Mineral
Exploitation in Greenland’ (“Guidelines”). This document has been prepared in accordance
with these Guidelines.
In January 2014, it was announced that the BMP was to be renamed to the Mineral Licence
and Safety Authority (MLSA). The MLSA is the overall administrative authority for licences and
mineral resources activities, and is the authority for safety matters including supervision and
inspections.
The Ministry of Industry and Mineral Resources (MIM) is responsible for strategy-making,
policy-making, legal issues, marketing of mineral resources in Greenland and socioeconomic
issues related to mineral resources activities, such as Social Impact Assessments, Impact
Benefit Agreements and royalty schemes. The Ministry deals with geological issues through
the Department of Geology.
The Environment Agency for the Mineral Resources Activities (EAMRA) is the administrative
authority for environmental matters relating to mineral resources activities, including protection
of the environment and nature, environmental liability and environmental impact assessments.
An EIA is required to identify and analyse all potential environmental impacts of any proposed
mining activities and determine preventative and mitigating measures for negative impacts. In
addition the EIA must also incorporate conceptual plans for the final decommissioning and
reclamation of the project. The EIA to be prepared for the Kvanefjeld project will;
Identify and analyse environmental impacts in all Project phases from before mine start
to beyond closure,
Help to develop measures to address and mitigate adverse environmental impacts,
Help to preserve environmental values, and
Help to realize sustainable development opportunities.
In accordance with the Guidelines the following issues will be covered in the EIA:
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Conclusions
References used in the EIA process and Glossary of terms and abbreviations
The EIA will cover the entire region that might be affected by the project. If the Project includes
use of areas outside the mining area for e.g. roads, harbours, airstrips and shipping routes,
effects of these will also be covered.
The purpose of this document, which has been prepared by Orbicon on behalf of GME, is to
provide a detailed plan of the Environmental Impact Assessment (EIA) process for Kvanefjeld
for consideration by the MRA.
A number of other studies and assessments, for example a Social Impact Assessment (“SIA”)
and a Bankable Feasibility Study, will be carried out during 2014 and 2015 in order to finalise
the design and prepare applications for the permits and licences that will be required to
develop the Project.
In 2007, Greenland Minerals and Energy (GME) A/S acquired the licence to explore the
Kvanefjeld project area. GME A/S is a subsidiary of Greenland Minerals and Energy Ltd, an
Australian company listed on the Australian Securities Exchange. Greenland Minerals and
Energy Ltd owns 100% of the shares in GME A/S.
The Project area is located in South Greenland approximately 10 km from Narsaq and
approximately 35 Km from Narsarsuaq. The main commodities of interest in the Kvanefjeld
ore-body are rare earths elements (REEs). There are also sufficient levels of uranium and
zinc in the orebody to produce commercially viable by-products.
The Project includes the development of an open pit mine, a processing plant, a port, mine
accommodation, tailings facility and roads connecting the parts of the project.
As the public should be involved throughout the EIA process and informed continuously as
the Project moves through the development phase and into production, stakeholders were
consulted as part of the scoping phase.
Initial Scoping Phase: (up to July 2011)
As a part of the initial scoping phase, four stakeholder workshops were held in Greenland.
During these workshops GME took the opportunity to present and discuss planned EIA
activities.
The objectives of these workshops were to present the Project to participants and to receive
input from the stakeholders on issues to be covered in the SIA, and EIA, processes.
Prior to the holding the workshops, the methodology for the workshops and the list of
stakeholders invited to participate were approved by the BMP. The key findings from the
workshops were presented to the BMP in Nuuk on 7 April 2011.
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In August 2013 two workshops were held with Government Institutions to present an
alternative project design, present the status of the EIA/ SIA processes and to receive input to
the EIA/ SIA processes based on the alternative project design.
Since August 2013, GMEL has conducted a number of constructive and informative
workshops with representatives of the Mining Licence and Safety Authority (MLSA), the
Ministry of Industry & Mineral Resources, the Environmental Agency for the Mineral
Resources Area (EAMRA) and the Kommune Kujalleq, to discuss the various development
options available. This is discussed in detail in Section 2: Scoping and Environmental Study
Plan.
In July 2011, after extensive consultation GME received approval for the Terms of Reference
for the Environmental Impact Assessment (EIA) and the Social Impact Assessment (SIA).
In the three years since, as further information became available on the design, location and
size of the Kvanefjeld Project, additional workshops and meetings have been held with key
stakeholders. Based on discussions with the MRA, it has been agreed that the Terms of
Reference should be updated to reflect the latest understanding of the Project.
The Amended Terms of Reference (July 2014) for the EIA of the Kvanefjeld project incorporate
the results of the original scoping phase and the outcomes of the most recent stakeholder
engagement phase. It contains a summary of the field work and studies completed to date
and an updated plan for the preparation of the EIA. Comments and input from the stakeholders
received during the workshops have been incorporated in these ToR.
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A detailed plan for the EIA process, including plans for environmental studies, must be
forwarded to and approved by the Mineral Resource Authority (MRA) prior to the start of the
EIA process.
In February 2011, public meetings were held in the southern Greenland towns of Narsaq,
Qaqortoq and Nanortalik to advise the general public of the process to scope the terms of
reference for the EIA and SIA. Then through early April a series of public meetings and
stakeholder workshops were held in Greenland’s capital, Nuuk, along with Narsaq and
Qaqortoq; the main two towns of southern Greenland that are in close proximity to the
Kvanefjeld project area. These events were followed by an Open Day in Qaqortoq, and public
meetings in Narsaq and Nanortalik in early June. The June meetings provided the opportunity
for the Company to provide an overview to the public on the outcomes of the stakeholder
workshops, and the preferred development scenario options to be evaluated.
The workshops held in Nuuk in June were attended by representatives from a range of
government departments including Finance; Health; Social Affairs; Fishing, Hunting and
Agriculture; Business and Workforce; Internal Affairs, Nature and the Environment; Culture
Education and Science; the National Museum; Institute of Natural Resources; and the National
Association of municipalities. The Nuuk workshops were also attended by representatives
from the Employees and Employers Unions, and the Fisherman and Hunters Association.
The workshops held in the south Greenland townships of Narsaq and Qaqortoq were attended
by a greater proportion of local non-government organisation groups in addition to local
government representatives. Local government representation included the Mayors
Department, Social Services and Finances. Non-government representation included the
Women’s and Elders Associations, along with the Sheep farmers, Environmental, Local Trade,
and Tourist Associations.
The workshops provided a forum for Company representatives to present on the status and
future plans for the Kvanefjeld project, which was followed by in-depth discussions in regard
to the scope and coverage of both the EIA and SIA. Following the workshops, the draft terms
of references were compiled and made available for public review.
Following a review process by both the BMP and DCE (Denmark’s National Environmental
Research Institute; advisor to the BMP on environmental sustainability) the ‘terms of reference’
for both the EIA and SIA on the Kvanefjeld multi-element project were approved in July 2011.
Since the initial approval GME has concluded a number of work programs in Greenland that
contribute to feasibility studies and environmental and social impact assessments on the
Kvanefjeld project.
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Figure 2.1 An overview of the Narsaq Peninsula, south Greenland, and the broader Kvanefjeld
project area. The Ilimaussaq Complex is comprised of extremely alkaline and unusual rock
types that have been actively eroded into the surrounding environment. JORC code mineral
resources have been established at Kvanefjeld, Sørensen and Zone 3.
The environmental baseline studies have been conducted in conjunction with Orbicon, GME’s
primary environmental consultant. In 2013 a botanical survey was completed and marine biota
along the fjord at the base of the Narsaq valley were sampled for analysis of ecotoxicological
and uranium and thorium series radionuclide analysis. Freshwater and stream sediment
sampling stations were revisited to build on data gathered in previous years, with samples
also to be analysed for ecotoxicology and radioactivity. Terrestrial sampling stations were also
revisited with samples of both soils and lichens collected. The baseline sampling was
repeated in 2014.
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Comprehensive background radiation monitoring was also undertaken in the broader project
area along with the town of Narsaq, and builds on data gathered over several years.
Short term (several days) passive monitoring of radon and thoron was conducted and long
term (three month) monitoring devices will be collected sequentially over the coming months.
Water and soil samples were also collected for radionuclide analyses. High volume air
samplers have recently been installed for the purpose of dust and air monitoring.
A gamma radiation survey was also conducted in 2013 to repeat the surveys carried out in
previous years. New additional points in the Narsaq valley were included to provide more
detailed coverage from the town of Narsaq to where ore material outcrops on the Kvanefjeld
plateau.
c. Geotechnical Mapping
Geological and geotechnical mapping programs were undertaken in areas that are currently
being investigated as potential infrastructure sites. These programs set out to assess
foundation conditions including rock and soil types, as well as identifying potential geohazards
and areas that require further geotechnical drilling. The outcomes provide important
information to support the selection of infrastructure locations.
In south Greenland, the majority of the populace live in the three major towns, however, a
considerable proportion lives in settlements outside of these townships. In August 2013, GME
personnel undertook a tour of these regional settlements to present overviews of the
Kvanefjeld project, and to provide a forum in which people could put forward questions. The
settlement tour was aimed to ensure that all local stakeholders in south Greenland are
included in the ongoing dialogue surrounding the potential development of the Kvanefjeld
project.
Eight settlements were visited where presentations were made and followed by informal
discussions (Figure 2.2). The presentations focussed on the potential development scenarios
for the Kvanefjeld project, and the work programs involved in the environmental and social
impact assessments. The meetings were all well attended, with the most frequently asked
questions focussed on employment opportunities, and the environmental and social impacts.
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Figure 2.2 An overview of southern Greenland highlighting the three major towns of Qaqortoq,
Narsaq and Nanortalik, and the communities visited on GMEL’s recent settlement tour. The
Kvanefjeld project is located approximately 10km to the northeast of Narsaq.
GME is currently working on economic calculations of the costs of carrying our processing
wholly or partly in Greenland as opposed to abroad.
The MRA have advised that it follows from the section 18(3) of the Mineral Resources Act that
the extent to which the licensee must process exploited mineral resources in Greenland may
be laid down in a licence.
In order to be able to make this specific assessment about the possibility of carrying out
chemical processing in Greenland, the different scenarios should be clarified in the application
material, including the EIA and SIA reports and in the Terms of Reference.
After extensive consultation, GME and the MRA have concluded that the Terms of Reference
should consider the following three development scenarios:
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Scenario 3 Through additional chemical processing The number of jobs is unknown at this
the TREO is refined into a product where point, but the figure is, other things
first the light and then the heavy REEs are being equal, higher than the 787 jobs
separated from each other, if this has not stated in Scenario 2.
already taken place in Scenario 2. The
individual REEs will through additional
chemical process be segregated into a
number of REE elements and will be sold.
This is a highly complex series of
processes that requires access to
proprietary technology. This process is
best carried out in mature industrial parks
that are located in close proximity to end
users.
The Ministry of Industry and Mineral Resources is of the immediate opinion that the processing
requirement in Greenland would naturally include Scenario 1 and 2. However, there will be a
need in relation to Scenario 3 for a sensitivity analysis in order to make, on an equal footing
with Scenario 1 and Scenario 2, an informed decision as well to assess the socioeconomic
and environmental effects.
The processing of minerals often involves complex chemical processes and may thus cause
environmental impacts. It is not known on the basis of existing data which and to what extent
the processing of the minerals at Kvanefjeld will have environmental consequences. This will
be identified through the preparation and public consultation of an EIA report which specifically
concerns a chemical processing plant.
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3 REGULATORY FRAMEWORK
The Act on Greenland Self-Government was granted to Greenland on June 21, 2009 and was
an extension of powers enacted in the Home Rule act of 1979. Through the Home Rule and
Self-Government Acts Greenland has the right to elect its own parliament and government,
the latter having sovereignty and administration over the areas mentioned in the Self-
Government Act such as education, health, fisheries, environment and climate. Some of the
achievements of the Self-Government Act were the recognition of Kalaallit (Green-landers) as
people, in international law, the opportunity for Greenland to become an independent state,
as well as the opportunity to take on the jurisdiction of more areas (such as natural resources
and justice affairs).
Greenland is a part of the Kingdom of Denmark. The influence of the Danish state in Greenland
has de-creased since 1979 when the Home Rule was introduced. With the inception of the
Self-Government Act there is the possibility that Green-land will take over the jurisdiction on
more areas, however these areas are still under Danish jurisdiction:
Justice affairs, including police, criminal procedures and the courts of law
Defence and National security
Financial sectors and monetary system e.g. the curren-cy used in Greenland is Danis
Kroner DKK
Civil right law e.g. family and succession, citizenship matters etc.
Foreign affairs
The Greenlandic Parliament, Inatsisartut (the legislative power and assembly), is put together
by 31 members elected by Greenlandic people for a four-year term meeting through sessions
twice a year. A Premier is elected by Inatsisartut. The Greenlandic Cabinet is put together to
form nine ministries by the elected Premier. The ministries, Naalakkersuisut, form departments
which are run all year round. Inatsisartut works out laws and appropriations that
Naalakkersuisut must conform to and also supervises Naalakkersuisut’s activities
(www.nanoq.gl).
Greenland is a member of the Nordic Council and Nordic Council of Ministries. This
membership, together with other Nordic Countries and autonomous regions, facilitates
parliamentary cooperation among the members particularly in relation to nature and
environmental issues.
The Nordic Council has prepared an Environmental Action Plan, 2013-2018 which focuses
greater resource efficiency and reduced environmental impact through inclusive green
development, climate change and air pollution, protection and utilisation of biological diversity,
and chemicals with adverse impact on human health and the environment.
Greenland is also member of the Inuit Circumpolar Council (“ICC”) and has been a member
of the Arctic Council since 1996.
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This section lists the regulations and guidelines relevant for the project, particularly for the
issues and areas of interest for the Environmental Impact Assessment.
The main legislation under which this project will be developed and operate will be the
Greenland Parliament Act no. 7 of 7 December 2009 (the Mineral Resources Act) which came
into force on January 1, 2010. This Act regulates mineral resources and mineral resource
activities. In addition, the project will be developed and operate under the Amendments to the
Mineral Resources Act (2012) Greenland Parliament Act No. 26 of December 18, 2012,
effective 1 January 2013.
In addition, the following international guidelines and standards will be included in the
assessment.
UN conventions:
Occupational radiation protection in the mining and processing of raw materials, IAEA
Safety standards series No. RS-G-1.6, Vienna 2004. 95 p. (supersedes IAEA Safety
Series No. 26); and
Establishment of Uranium Mining and Processing Operations in the Context of
Sustainable Development, IAEA Nuclear Energy Series No. NF-T-1.1.
Best practice in environmental management of uranium mining. International Atomic
Energy Agency, 2009.
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For the original, approved Terms of Reference (July 2011) GME had proposed to develop
Scenario 2, and the following project brief was provided.
The Project will consist of an open pit mine, a processing plant, a port, mine accommodation,
a tailings facility and roads connecting the parts of the project.
GME is considering two potential scenarios with locations for the accommodation facility,
processing plant and port. One scenario is construction of the processing facilities within the
Narsaq valley and a new port immediately to the north of Narsaq in Narsap Ilua (West). The
other scenario is construction of processing facilities approximately 15 to 20 km northeast of
Narsaq and a new port to the east of Illunnguaq opposite Nunarsarnaq (East). Figure 4.1 and
Figure 4.2 illustrate the two scenarios (East and West).
Significant further investigation and community consultation and engagement was carried out
to confirm the preferred location.
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The mine An open pit mine, from which the ore is extracted
Where metals are extracted from the ore using
The processing plant hydrometallurgical techniques to produce saleable
products
Where residues from the processing plant are securely
The tailings facility
stored
For ships delivering supplies to the mine and
The port transporting products from Greenland to the
Company’s customers
The accommodation For mine workers when working at the mine
To ensure power supplies, effective communications
Associated infrastructure
and safe access to the mine
Based on the agreed, updated scoping and environmental study plan discussed in Section 2,
GME proposes to develop Scenario 2 as the preferred development plan. Scenario 1, the mine
and concentrator only, will be addressed as an alternative case in EIA. A sensitivity analysis
will be presented on Scenario 3, which considers further chemical refining of the TREO into
separate light and heavy rare earth products.
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The current development plan differs from the project brief presented in the Approved Terms
of Reference (July 2011) and the key differences are highlighted below:
After extensive community and key stakeholder consultation the preferred location for
the Project’s accommodation, port and processing plant is in Narsaq valley (referred
to above as Scenario West);
The mining rate and associated processing facilities have been reduced from 7.2 - 10.8
million tonnes per year down to 3.0 million tonnes per year;
The process flowsheet has been modified and the whole of ore: pressure alkaline leach
process has been replaced by a mineral beneficiation: atmospheric acid leach stage;
Labour requirements for both the construction phase and the operational phase have
been revised upwards;
The preferred options for the location of the residue storage facilities have been
identified.
A brief, non-technical description of Scenario 2 is provided below and the layout is presented
in Figure 4.3:
Figure 4.3 Layout for Scenario 2. The extent of the waste rock dump and tailings facilities in
the figure is after 39 years of mining
The plan is to locate the mine at Kvanefjeld on the Ilimaussaq Intrusive Complex
approximately 10km from the town of Narsaq and approximately 35 km from Narsarsuaq in
southern Greenland.
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The processing plant will be located at the upper end of the Narsaq valley. It is currently
expected that the plant will operate for 365 days per year and it is proposed that the plant will
be designed to treat 3.0 million tonnes per year of ore.
The key advantage to the Kvanefjeld project is the unique rare earth and uranium-bearing
minerals and the purpose of the processing plant is to extract these products from these
minerals. These minerals can be effectively beneficiated into a low-mass, high value
concentrate, then leached with conventional acidic solutions under atmospheric conditions to
achieve particularly high extraction levels of both heavy rare earths and uranium. This
presents a simple process route with low technical risk that effectively concentrates uranium
and REEs to a form that can be sold.
It is currently proposed that the processing plant will consist of sections for crushing, grinding,
flotation, leaching, filtration, uranium extraction and for the concentration of REEs.
Water will be used in the processing plant and after it has passed through the plant it will be
treated before either being recycled back to the plant or returned to the environment.
Concentrations of contaminants in the discharges to the environment shall comply with
established threshold values and requirements.
It is planned to place the saleable products in drums and containerise them at the processing
plant and to transport the containers of drummed product from the processing plant to the port
on trucks. The plan will then be to ship them to customers around the world.
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The material left over once it has passed through the processing plant is called tailings (a
mixture of fine crushed rocks and water). The majority of the sulphides, the fluorine and the
rare earth elements will all have been removed or stabilised by this stage in the process. A
portion of the uranium and thorium that is not recovered is disposed of in the same
mineralogical form as the parent material.
The tailings storage facility will store the wet tailings from the flotation process. A number of
alternative locations for the tailings storage facility, e.g. valley deposition, lake deposition and
deposition in the fjord system/deep sea, are being evaluated. The location of the tailings
storage facility will be influenced by environmental considerations and by the chemistry of the
tailings. The current preferred options are to either use the lake Taseq or to locate the facility
adjacent to the mine waste rock stockpile.
In addition to the processing plant tailings, other waste streams may be generated and these
will need to be recovered, treated and recycled if practical to do so. Otherwise they can be
diverted to the tailings storage facility. While not all of these potential waste streams have yet
been identified, they will include, for example:
The port facilities will consist of a wharf for ships up to 32,000 DWT (Dead Weight Tonnes)
and a service wharf for receiving equipment and products with a smaller capacity. The port
will also have storage facilities for saleable products and ship loading facilities. GME is
considering alternative locations for the port within Narsap Ilua.
The accommodation will include a canteen, a laundry and opportunities for leisure and spare
time activities. GME is considering alternative locations for accommodation, either within the
town planning boundary or further up the valley.
Roads from the port to the mine, processing plant and other items of infrastructure
A source of power, fossil fuel fired initially and then hydro-power
Water supply and storage for the processing plant, potable water and fire protection
Buildings and support facilities including accommodation
A helipad for staff and emergency medical evacuation
Heating and heat recovery
An IT and telecommunication system
Sewage and waste management
During the construction phase, GME expects a workforce up to 1171 people at the maximum.
The construction period is expected to run for approximately 2 years.
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During operations, GME estimates a total workforce of 787 people and the aim is to recruit
approximately 3/5 locally from either within Narsaq or from the rest of Greenland. The optimal
rotation scheme(s) will be discussed and agreed during the SIA process and further if needed
in order to maximise the amount of local workforce.
In 2013 an alternative project design was developed by GME. This project design includes
the development of an open pit mine, a concentrator, a port, mine accommodation, tailings
facility and roads connecting the parts of the project, and is referred to as Scenario 1.
The original project layout (Scenario 2) included a refinery plant near to the concentrator
facility and open pit mine. The decision to consider locating the refinery offshore or remotely
at another location in Greenland was a major amendment resulting from stakeholder
engagement, assessment of social and environmental benefits, as well as economic viability.
Further consultation with stakeholders and local authorities will help to determine the final
location of the Refinery. The current proposed site layout breaks the project into three main
locations, connected by process infrastructure and services.
The first location would be co-located at the Kvanefjeld mine site at the top of Narsaq Valley
and would consist of the crushing, milling and flotation circuit (the concentrator).
The second location is the Port and mineral concentrate packaging facility situated at Narsap
Ilua. Concentrate from the first location would be directed here via a pipeline, and the Port
would be accessed from Narsaq by a 2.5km sealed road.
The third location is the new Accommodation Village for fly in- fly out (FIFO) employees, and
would be situated on the northern outskirts of the Narsaq township.
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It is planned to treat the Kvanefjeld ore by using a conventional froth flotation process to
beneficiate the ore and to produce two different mineral concentrates. The first flotation stage
will produce a high grade zinc sulphide concentrate, followed by a second flotation stage which
produces a phosphate mineral concentrate.
The gangue minerals left behind after flotation will be dewatered and stored in the tailings
facility. The recovered water will be recycled back to the concentrator, where it will be treated
to remove fluoride as fluorspar (CaF2), which can be sold, along with the zinc sulphide
concentrate, to international customers. A small quantity of excess water will be produced
that cannot be recycled back to the concentrator. This water, once treated to remove fluoride,
will be returned to the environment at a discharge point adjacent to the concentrator, in
Ikersuaq Bredefjord. Concentrations of contaminants in the discharges to the environment
shall comply with established threshold values and requirements.
The phosphate mineral concentrate which contains both uranium and rare earth minerals, will
be pumped via pipeline to the concentrate filtration and packaging plant located adjacent to
the port.
The phosphate mineral concentrate is rich in valuable metals. It is expected that this product
will be bagged, containerised and transported to an off-shore Refinery. The location of the
Refinery is yet to be decided (see Figure 4.6)
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It is expected that the plant will operate for 365 days per year and it is proposed that the plant
will be designed to treat up to 3.0 million tonnes per year of ore.
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Orbicon have produced this document at the request of GME. GME will continue to engage
suitably experienced and competent advisors to assist in the completion of the EIA once these
amended ToR have been approved. External international and local experts will be involved
in the analysis of specific matters such as radiation effects, ecology, hydrology and
geochemistry.
The Guidelines set out the framework for, the contents of, and the minimum level of baseline
information required for an EIA.
During the planning and development of the EIA process, a number of references and sources
will be considered in order to achieve international mining industry best practices for the EIA.
These sources will include, amongst others;
International Finance Corporation and World Bank Guidelines including the Equator
Principles
European Commission – Reference Documents on Best Available Techniques
Arctic Council – Arctic Environmental Protection Strategy [EIA Guidelines 1997]
Relevant Danish institutions such as DCE, GEUS and the DEA
Arctic Council - Working groups
United Nations – for example the Framework Convention on Climate Change
SLiCA
The International Council on Minerals and Metals (ICMM),
The International Atomic Energy Agency (IAEA), and
The International Reporting Initiative for Extractive Industries
The EIA will be based on a participative approach, involving the stakeholders as much and
effectively as possible at all stages of the process. A high degree of communication will be a
significant feature of the entire process.
Reference will be made to the Greenland Water Quality Guidelines for freshwater and
seawater, developed in 2011. As Greenland has not yet developed guidelines that describe
standards for environmental contaminants, dust and noise guidelines from sources outside
Greenland will be considered in the process of establishing standards for environmental
contaminants, dust and noise. Approval will be sought from the MRA prior to using guidelines
from outside of Greenland.
The initial assessment of the environmental, and social, issues likely to arise from the
implementation of the Kvanefjeld Project was first discussed and reported in the “Preliminary
Project Strategy – Kvanefjeld Multi-element Project” by Coffey Natural Systems in September
2009.
A second study, the “Socio-economic Desktop Study for the Kvanefjeld Multi-element Project”
was carried out by Grontmij Carl Bro in July 2010.
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The main environmental issues identified by the above studies for the project can be
summarised as follows:
Effects of discharges to water (surface waters, fjords and groundwater) including
stormwater runoff from disturbed areas (such as the waste rock dump) and discharges
from the open pits, process plant and the TSF.
Potential for contaminants to enter the food chain (eg fluorine, heavy metals and
radionuclides of concern such as radium).
Management of biodiversity issues (terrestrial and aquatic), including the
presence/absence of rare and/or threatened species.
Effects of atmospheric emissions such as radon gas, dust, combustion products and
other gaseous emissions.
Effects of radiation from radioactive sources within the project area.
General waste management.
Where to safely deposit the tailings in a short and long term perspective.
The possibility of alkaline drainage, that has to be neutralised.
Rehabilitation of areas disturbed by the project and decommissioning of the tailings
management system.
The significance of these will vary between construction and operational stages of the project.
For example, downstream sedimentation is likely to be of more concern during construction,
although it will remain an issue throughout the life of the project. Destruction of any significant
habitat or sites of archaeological/cultural significance, if present, would be associated primarily
with initial clearing works during construction. In contrast, potential impacts on downstream
water quality due to poor quality water discharges would continue beyond construction and
may encompass both the entire operational life of the mine and a considerable period after
closure.
In March 2011, a Strategic Environmental Assessment workshop was held in Perth, Western
Australia. The workshop was attended by representatives of Grontmij and Orbicon and the
social and environmental aspects of the project were assessed. The outcome of the workshop
formed the basis of a “Project Brief”, which described the project in lay or non-scientific terms.
The next step was to commence the Stakeholder Engagement process. Four stakeholder
workshops were conducted as part of the Social Impact Assessment;
During these workshops GME took the opportunity to present and discuss planned EIA
activities.
Prior to holding the workshops, the approach to the workshops and the list of identified
stakeholders were both approved by the BMP.
Invitations to attend the stakeholder meetings were sent to all agreed stakeholders together
with a Project Brief describing the project in lay or non-scientific terms. This was done with the
objective of promoting more informed participation in the workshops themselves and to
provide opportunities for stakeholders to ask clarifying questions of, and to express concerns
to, company representatives and both the SIA and EIA consultants during the workshops.
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Currently, GME is working with two development options, scenarios 1 and 2. The scoping
phase took as its starting point Scenario 2 and looked at two layout options (East and West).
Stakeholders were invited to discuss opportunities and concerns that they may have had for
each.
In August 2013 two workshops were held with Government Institutions to present Scenario 2
and the then status of the EIA/ SIA processes and to receive input to the EIA/ SIA processes
based on the alternative project design.
Since August 2013, GMEL has conducted a number of constructive and informative
workshops with representatives of the Mining Licence and Safety Authority (MLSA), the
Ministry of Industry & Mineral Resources, the Environmental Agency for the Mineral
Resources Area (EAMRA) and the Kommune Kujalleq, to discuss the various development
options available.
Additional stakeholders have been identified during the stakeholder workshops in 2013,
especially the Police department.
Based on responses from the workshops, common concerns and opportunities were
identified. The ToR set out in this document have been developed in part from the responses
from the workshops. This feedback has been supplemented from a number of sources
including;
Furthermore, Greenlandic research documents and studies such as SLiCA (Survey of Living
Conditions in the Arctic) were used.
Annual baseline sampling in the Kvanefjeld – Narsaq area has been carried out since 2007.
The sampling has followed a protocol developed by the Danish National Environmental
Research Institute (DCE), and has been approved by the BMP.
A summary of environmental baseline studies carried out from 2007 to present is provided in
6.1.
The environmental study program will include a number of additional baseline studies as well
as project related studies which were identified in the Approved Terms of Reference (July
2011). These studies commenced in 2011 and will be completed in 2014.
Detailed proposals of each Environmental Study Program have been submitted to MRA for
approval. These submissions included details such as maps indicating sampling stations and
study scope, description of timing of studies, parameters for measurement, methodology and
equipment.
As needed, the environmental study programs are updated in consultation with the MRA.
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Data obtained from these studies are submitted to DCE and will be stored so that it is available
to the MRA and DCE.
A summary of the additional studies required to complete the Environmental Study Program
is provided in Table 2.1, Section 5.2, along with details of these studies.
The aim of the EIA is to identify, predict and evaluate the environmental effects of the planned
mine project. This includes the construction, operation, closure and post-closure phases.
The EIA will be prepared to comply with the scope and structure specified by the Greenland
authorities in the Guidelines for preparing an Environmental Impact Assessment Report for
Mineral Exploitation in Greenland from 2011.This includes guidelines for discharged water:
GME will follow the threshold values for radioactive and non-radioactive contaminants in all
environmental samples (atmospheric, aquatic and terrestrial) established by Greenlandic
Authorities, when available.
All issues associated with the proposed Project that can potentially have adverse impacts on
the environment will be identified to ensure they are addressed before final decisions are
made. This includes the geographical location of mine facilities as well as potential negative
impact from the mining activities and processing of ore.
The EIA will include a detailed description of the proposed mine project and will discuss the
environmental implications of different locations of mine facilities as well as different mining
techniques (such as open pit mining versus underground mining and in-situ leaching).
tailings facilities (locations, dam construction and stability, liners, water control systems
such as spillways, decant towers, alarm system for control of water level);
tailings and waste characteristics (radioactive and non- radioactive contaminants as
well as flotation and processing chemicals that remain with the tailings);
tailings and waste preparation,
tailings and waste discharge and deposition, tailings consolidation, tailings surface
water treatment, decant water treatment, seepage control, tailings and waste rock
covers, emergency preparedness and response for the case of e.g. containment
failure, cover failure, and, a program for monitoring and surveillance of tailings facility
and other regulatory requirements.
accidental release of radioactive and non-radioactive products as well as reagents for
the production in connection with shipping in Greenlandic waters.
discussions of the environmental advantages and disadvantages of using hydropower
or a diesel-fired power plant.
GME is well aware of the seriousness of an increase in fluoride in the environment due to the
mine project. GME has therefore taken fluoride into account when designing the mine which,
for example exclude water with high fluoride content to flow into Narsaq valley and the river.
The mine design, all water streams and discharges to the environment will be detailed in the
EIA based extensive laboratory studies and modelling work.
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In the assessment part of the EIA all potential impacts will be discussed and assessed. This
includes for example potential contamination of the rivers and lakes with fluorine and
radioactive dust contamination of the surroundings (including sheep farms).
For each identified potential impact from the mine project the source (from the mine project),
will be identified as well as the pathway (the way a contamination potentially can be dispersed)
and the receptor. The main receptors will be land, air and water and the associated flora and
fauna of these elements. Human receptors will be discussed in the EIA including the radiation
issue.
the activities related to the proposed mine that are the source of emissions, disturbances
or other effects;
the likely emissions, disturbances or other effects;
the receptors that can be impacted by these effects;
the pathways between the sources and the receptors;
the potential impact to the receptors and how they may vary for the different stages of
the mine life; and
ways to mitigate the impacts.
1. Mine activities that could potentially cause an impact will be identified from the project
description of the new mine and are summarised in a Risk Assessment matrix. This
matrix will be prepared by systematically looking at each project element or activity in
all stages of the mine life (construction, operation, closure and post-closure).
3. The receptors considered susceptible to impact will be sourced from the environmental
baseline description.
4. The pathways between the sources and the receptors will be sourced by modelling of
air, water, soil, food, etc.
The EIA will also contain a number of conceptual plans that will be developed further in
cooperation with the Greenland authorities once the EIA has been approved. This includes:
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The environmental management plan will be developed on the foundation of knowledge of the
environment, local use values and potential environmental impacts.
The plan will propose mitigating measures developed to reduce or eliminate potential
environmental impacts. A description will be provided of the anticipated effectiveness of these
mitigating measures and where residual effects exist, these will be described. Residual effects
will be supported by necessary monitoring methods and compensatory measures.
This plan will describe in detail how the mitigating measures will be organised and who is
responsible for carrying out mitigating and monitoring measures.
A plan for acquiring data will be included within the Environmental Monitoring Program.
The Environmental Management and Monitoring plans will be finalised in 2014, however they
will developed during the project lifetime, in consultation with the community and MRA.
Public consultation is essential throughout the EIA process so that community concerns can
be integrated. A series of public consultation meetings will be held to present and discuss
relevant information about the EIA process. Objections and comments will be considered by
GME and feedback provided to the public.
Community consultation will be addressed within the EIA document and extensively discussed
in a document complementing the EIA, the ‘White Paper’. The White Paper will document
public consultation comments, and explain how public comments have been incorporated into
the EIA and subsequent management plans.
All data collected in connection with the EIA including baseline and monitoring studies are
made available to the public.
Following review by the MRA, the final EIA report will be made available for public consultation.
The environmental studies cover the areas directly impacted by project, including options to
the west and east. This will include ancillary facilities and will include downstream
environments and the towns and settlements where the impacts and benefits are expected to
be more noticeable.
The environmental studies will assess the following phases of the project:
Construction phase;
Operations phase, and
Closure and rehabilitation phase.
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Maps will be provided describing environmental study areas in detail within each
Environmental Study Program proposal document. These proposals have been approved by
MRA before commencement.
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Terms of Reference, EIA Kvanefjeld Multi-element Project
This Environmental Study Plan is drafted in accordance with the new EIA guidelines (January
2011) issued by the BMP and provides information about the planned contents of the EIA
report and the approach to be taken when preparing the report. In addition to that, the plan
provides a description of the environmental studies that have been carried out and the studies
planned for the coming years which will form the basis for the environmental assessment of
the mine project.
The proposed Table of Contents for the EIA report. (section 6.3)
Public consultation is essential throughout the EIA process so that community concerns can
be integrated. Community consultation will be addressed within the EIA document and
extensively discussed in a document complementing the EIA, the ‘White Paper’.
Annual baseline sampling in the Kvanefjeld – Narsaq area has been carried out since 2007,
to study and document the natural levels of heavy metals, radioactivity and other elements.
The sampling has followed a protocol developed by the Danish National Environmental
Research Institute (DCE), and has been approved by the BMP and has included fresh and
saltwater, sediment, lichens, soil, leaves, grass, fish and mussels.
The baseline sampling in 2007 – 2010 mainly took place in the Narsaq Valley and the adjacent
areas because this was where it was believed that the mine facilities would be constructed.
Since the Approved Terms of Reference (July 2011) baseline sampling has continued, with a
focus on the Scenario 2 layout.
The number and position of sampling stations, which have also been approved by DCE,
covers the entire coastline as well as rivers, lakes and terrestrial area within the area of the
Scenario West plus a reference station further away (Figure 6.1).
All the collected water samples have subsequently been analyzed by DCE and Risø National
Laboratories while the other samples are stored in a freezer at DCE. The results of the
sampling have been documented in a number of reports and notes listed below.
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2007
Kvanefjeld project, Greenland. Report on the environmental baseline sampling, September
2007. Orbicon October 2007. 33 pp
Kvanefjeld water 2007. National Environmental Research Institute. Test Report No. 236.
February 2008.
2008
The Kvanefjeld Multi-element Project, SW Greenland. Report on the environmental baseline
sampling. August 2008. Orbicon March 2009.
Kvanefjeld water 2008, Test report no. 289. National Environmental Research Institute
January 2009. 3 pp.
2009
The Kvanefjeld Multi-element Project, SW Greenland Report on the environmental baseline
sampling, August 2009, Orbicon, October 2009. 15 pp
Radioactivity in water sampled in 2009 from Narsaq area, Greenland. Risø national
Laboratories. 3 pp.
Kvanefjeld water 2009. Test report no. 344. National Environmental Research Institute. 9 pp
2010
Analyses of radon-222 and radium-226 in samples of Taseq lake water collected August 2010.
Risø National Laboratories. 1 pp
2011
Ilua Valley, Nunasarnaq and Kuannersuit archaeology – a survey. Greenland National
museum and Archives. 18 pp.
Kvanefjeld Water 2011. Test Report No 474. National Environmental Research Institute,
December/ January, 2011/ 2012.
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2012
Narsaq Drinking Water System. 2012. Orbicon, 31 pp.
Kvanefjeld Multi-element Project – the natural environment of the study area. Orbicon. 51
pp.
2013
Baseline sampling August 2013 Kvanefjeld Multi-element Project South Greenland. Orbicon.
2013. 6 pp.
2014
Baseline sampling June 2014 Kvanefjeld Multi-element Project South Greenland. Orbicon.
2014. In prep.
Figure 6.1 Sampling stations for 2013 and 2014 marine sampling in Brede Fjord
Table 1 provides a summary of the additional studies that are proposed for the EIA. This
includes a number of additional baseline as well as project related studies. All these studies
will be carried out in 2014-2015 so that the results can feed into the EIA report.
Each study is summarised with an objective, approach, schedule and final outcome.
Detailed proposals of each Environmental Study Program will be submitted to EAMRA for
approval. Detail will include maps indicating sampling stations and study scope, description
of timing of studies, parameters for measurement, methodology and equipment.
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If needed, the environmental study programs will be updated in consultation with the EARMA.
Study Schedule
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Objective:
To compile background data of ambient concentrations of air pollutants, including particulate
matter (PM).
Approach:
A permanent monitoring station for PM10 and PM2.5 is established at Narsaq town, with filter
and real-time measurements continuing after the baseline period.
The following data will be collected:
PM10 and PM2.5 filter samples (24-hour and 14-day)
PM10 and PM2.5 continuous monitoring (hourly)
NO2, SO2, O3, NH3 passive samplers (monthly)
Dust deposition (monthly)
Element composition of PM10, PM2.5 and dust deposition samples by PIXE (Proton
Induced X-ray Emission)
Radionuclides in dust and radon in air.
Outcome/ deliverables:
Report summarising baseline results.
Study report will be a key reference in providing a comprehensive description of the ambient
environment before mining.
Ambient conditions during various weather conditions will assist in air emission modelling.
Information will be an essential reference assessing potential environmental impacts and
designing methods of mitigation.
Schedule:
A detailed proposal including maps with the position of
sampling stations and lists of items to be collected will be
forwarded to the EARMA shortly.
Baseline measurement were initiated in 2011 and will
continue throughout 2015.
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Objective:
To predict impacts on ambient air quality in areas surrounding the project, in particular work
areas and residential areas.
Approach:
Modelling analyses most likely using the CALPUFF system will be carried out. The modelling
will include all major emission sources. Deposition rates will be predicted based upon
available hourly meteorological data. The modelling results will further be based on receptor
locations.
Climate monitoring and studies conducted by GGL from 2010 to 2015 will be incorporated
into models.
Study of background ambient air quality will be relevant to selection of standards and
emission rates. Study conclusions will establish parameters for emission quality and
monitoring methods.
Outcome/ deliverables:
Report including several scenarios including estimates of emission factors and rates.
Supporting maps showing spatial distribution of predicted air quality will also be developed.
Predicted air quality will meet ambient air quality standards. These standards must be
supported by EAMRA.
Schedule:
Final project layout and meteorological and topographic studies must be complete before the
design of the modeling study can be finalised. A detailed proposal will be forwarded to the
BMP for consideration.
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Objective:
To develop an understanding and assess any potential acid rock drainage and/ or metals
leaching associated with waste rock/ lean ore and tailings from the Project.
To determine if water from the tailings pond is toxic to aquatic organisms (such as trout).
To assess the long term stability and rehabilitation capability of waste rock, tailings and
regolith.
Approach:
The following test types are proposed:
Acid-base accounting
Shake-flask test
Sequential extraction
Toxicity test
Total trace element content
Full metal screening
Radon release
Humidity cells testing.
Outcome/ deliverables:
Report presenting and discussing results, suggesting management considerations if required.
Information will form a foundation of knowledge that will enable GME to assess potential
environmental impacts and designing methods of mitigation such as tailings, waste rock dump
design, monitoring and environmental management.
Schedule:
A number of tests have already been conducted on both the flotation tailings and chemical
residue including acid-base accounting (ABA), shake flask extractions, humidity cells testing,
particle density, and particle size analysis. A detailed testing protocol will be forwarded shortly
to the EAMRA.
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Objective:
To characterise the hydrology of the Project area. This includes developing a conceptual
understanding of the hydro-geological features of the project area and the pathways of
potential contamination of aquifers and risk of transport of contaminants.
Approach:
A hydrological model will be developed for the Project area based on the ongoing stream flow
measurements, historical data and physico-chemical measurements.
The model will be based on data collected from hydrological stations at major rivers and
streams throughout Scenario East and West including Narsaq River.
Outcome/ deliverables:
Report discussing the hydrogeological features of the Project area, seasonal fluctuations and
potential contamination risks from contaminant transport.
Schedule:
A detailed proposal including maps will be forwarded to the EAMRA shortly.
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5. Noise Study
_________________________________________________________
Objective:
To characterise impact of the Projects major generators of noise during construction and
operation.
Approach:
Model spatial distribution, intensity and frequency of noise from major sources such as blasting
at mine site, the crusher and air traffic (helicopters and fixed winged aircraft) using the
SoundPLAN program.
Outcome/ deliverables:
Noise model predicting the magnitude and extent of noise produced by the Project.
Schedule:
A detailed proposal will be forwarded to the EAMRA shortly.
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Terms of Reference, EIA Kvanefjeld Multi-element Project
Objective:
To understand the impact oil spills may have on terrestrial, freshwater and marine
ecosystems.
Approach:
Desktop study that compiles the existing knowledge in the field of impact of oil spills on Arctic
ecosystems with special reference to the Narsaq area. A key source of information will be
the DCE Environmental Oil Spill Sensitivity Atlas for the South Greenland Coastal System.
Outcome/ deliverables:
To understand the impact oil spills may have on terrestrial, freshwater and marine
ecosystems and determine the most effective actions to minimise any impact or manage an
incident.
Schedule:
The study will be carried out in 2015.
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7. Local Use
_________________________________________________________
Objective:
Documentation of local use of the Project area. The study provides data that will facilitate
resolving any conflicts between the Project and the present utilisation of the area.
Approach:
Interviews with relevant stakeholders, including fishermen, hunters and sheep farmers. The
study was carried out in close liaison and cooperation with the SIA team.
Outcome/ deliverables:
A report has been prepared that summarises the findings. Important fishing and hunting areas
are shown in maps.
Schedule:
The survey was carried out in 2014.
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The main report will commence with an Extended, non-technical summary (“the Executive
Summary”. The Executive Summary will describe in short the project and a conclusion
including preferred options compared to alternative solutions, important potential
environmental effects, mitigating actions, decommissioning and remediation, uncertainties
and public concerns. The Executive Summary will be presented in Greenlandic, Danish and
English.
The structure of the rest of the report will follow the format proposed below:
1. INTRODUCTION
2. EIA METHODOLOGY
3. EXISTING ENVIRONMENT
Terrestrial
Geology
Topography (including flood plains, landform)
Soils
Geochemistry
Aquatic
Hydrology (including drainage)
Bathymetry
Water resources, including freshwater and seawater quality
Sea Ice
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Radiation
Background radiation (sources of natural radiation), radon levels
4. PROJECT DESCRIPTION
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Radon (estimation of the amount of radon that will evaporate from the mine,
tailings and from the waste rock deposit; calculation of concentrations in the air
in Narsaq and other places dependent on wind direction and speed)
Possible release of chemicals and radionuclides to the environment and the
impacts hereof (including runoff from mine ore stockpile, waste rock, pit water,
mineralised materials)
Taseq water dispersal (such as seepage from embankment and dispersal by
wind)
Alkaline drainage (testing if there are any problems with that and if this is the
case, give methods to mitigate any problems)
7.2 Environmental Management Plan (EMP) (to manage impacts for construction,
operation, closure and post-closure) including risk assessment
Implementation
Management plans
Procedures
Responsibilities
Training
Emergency preparedness
Emergency planning and response (fire, radiological event (mineral processing
spill, product packaging, contaminated sites) and transport of product) and
unplanned disaster including oil spill event on land and during shipping in the
Greenlandic fjords
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8. ENVIRONMENTAL MONITORING
8.2 Conceptual monitoring program (for all mine phases), including parameters to be
monitored, sample location, sample type
(air, land, and water including here also effluents released to the environment),
suggested frequency, duration, assessment criteria, QA/ QC, sampling location,
data management, reporting
9. PUBLIC CONSULTATION
10. CONCLUSION
11. GLOSSARY
Appendices
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Terms of Reference, EIA Kvanefjeld Multi-element Project
Municipality (Kommune The objective is to involve the Validate the baseline data at household 2014
Kujalleq) communities of the Municipality level
(Kommune Kujalleq) and to collect
information and perceptions (fears,
expectations, etc) for input into the
EIA.
Development of MRA, and other relevant The objective of the involvement of Define how to monitor and develop 2014
Impact Analysis Authorities as well as focus selected groups is to assist with the possible mitigation measures in
and Mitigation groups and key informants identification of the potential main consultation with the MRA
Measures (focus groups to be areas of impact and the possible
appointed later) mitigation measures.
Development of MRA, and other relevant The objective of the involvement is Development of EMP and monitoring 2015
draft EMP Authorities to define and agree on the extent of plans will be developed in consultation
the EMP and the standards to be with the Community and MRA
adopted with the regulatory
authorities, and the requirement for
programs for monitoring and
evaluation
Draft EIA Report MRA, Key stakeholders, The objective of the involvement is 2015
and Public General Public to present, clarify, validate and
Hearing receive feedback on the findings of
the impact analysis,
recommendations and draft
Environmental Management Plan
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