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7. SPILLS, SPILL PREVENTION AND EMERGENCY RESPONSE

What will you do to prevent a spill? Does Donlin Gold have an emergency response plan?

The most important action to prevent a spill is assessing the risk involved in an activity or operation and then working to reduce that risk. Spill risks will be reduced by means of engineering controls; for example, the use of double-hull barges, and careful marking of the navigation channel; and using specialized containers that maximizes structural integrity, just to mention a few. Other controls will include task specific procedures, employee training, equipment inspections etc.
While we aim for no spills, we are required by federal and state regulations, to be prepared to respond to a spill and other potential emergencies. This is achieved through the preparation of detailed contingency and emergency plans; personnel training; and making necessary supplies and equipment available:

  • Donlin Gold’s Contingency and Emergency plans will be detailed, and will meet or exceed federal and state requirements. The plans will include best management practices, and will be periodically reviewed and updated to meet the needs of the project.
  • Personnel will be trained to recognize hazards, and how to respond to an incident in accordance with pre-established plans. Regular training and practice drills according to each employee’s role within the spill and emergency response organization will maintain team readiness to respond, if required.
  • Spill response supplies, including safety supplies, will be available at or near locations where there is a greater risk of a spill. For example, at fuel transfer locations such as the Bethel Port or the Jungjuk Port, the fuel barges will be equipped with equipment to transfer fuel to on-board storage or to other vessels.

The Contingency and Emergency response plans have not yet been prepared for the project pending further project design development, but these will be prepared and approved prior to the start of operations. Donlin Gold is a member of Chadux; an oil spill removal organization that is already operating in the region.

Will training take place to help us better respond to emergencies should one occur in proximity to our village?

Donlin Gold will work with employees, contractors and local community authorities to ensure that appropriate emergency response capacity exists to safely address potential emergency situations. Safe handling, transportation, storage and use procedures designed to protect human health and the environment will be established by the company for all hazardous materials utilized. These procedures will incorporate requirements for training of employees and contractors about the specific hazards associated with the materials utilized and how to safely conduct operations and emergency response. Training exercises will also be conducted regularly in which emergency response teams are expected to demonstrate their ability to properly respond to a simulated incident. Training will include, but not be limited to incident command system and communication protocols, industrial firefighting, hazardous material response, spill response, emergency medical care for injuries and accidents, and wildfire fighting.

Donlin Gold is committed to support annual emergency response training in the TKC villages which are closest to the project. Donlin will collaborate with these villages and other local authorities to ensure that response to potential emergencies can be effectively and safely coordinated and, where required, joint training exercises will be undertaken.

How can you say that a major disaster or incident won’t occur here given the mining industry’s track record at Mt. Polley and the tailings dam failure in Brazil?

Donlin Gold and its parent companies are dedicated to being good environmental stewards with
a commitment to applying proven best practices to prevent and/or mitigate any incident that could potentially occur. Risks are inherent in any resource development activity. Each event is distinct and not comparable to another. Donlin Gold’s extensive environmental evaluations and baseline data collection, combined with our collective experience and that of third party expertise, are all key factors in being better prepared to plan, mitigate and respond should an event or incident occur. Moreover, the State of Alaska also has an experienced staff with a strong track record in overseeing large mining projects. Mines in Alaska, and the U.S. overall, have a very strong track record in operating modern mining operations without major incidents that pose risks to the environment and human health. Please refer to Section 6 – Tailings Management and Water Resource Protection for more information how we plan to mitigate dam failure risks.

How will mercury be handled, stored and transported?

Mercury waste will be handled according to strict, detailed procedures at each stage in the process. Onsite it will always be within secondary containment – the long-term storage will be in a covered, dedicated area with secure access. Offsite transport of mercury will be in U.S. Department of Transportation (USDOT) approved carbon or stainless steel containers specifically designed for mercury that will be able to withstand the stresses encountered during handling and transportation. Secondary containment also would be provided during transport. All drums will be placed in sealed conexes for truck and barge transport.

All mercury wastes will be carefully tracked through each stage of generation, storage, and transport. The mercury management plan has been developed based on Barrick’s experience dealing with mercury in Nevada and the Dominican Republic.

How will Donlin Gold reduce possible mercury air emissions?

At the Donlin Gold mine, mercury from the milling process would be captured at multiple points. Donlin Gold plans to install and operate state-of-the-art mercury emission controls, and any captured mercury would be stored onsite in a covered, dedicated area with secondary containment and secure access, or shipped off-site to a federally regulated facility. The ore processing facility is subject to emission limitations in its Clean Air Act permit. The mercury- capture processes Donlin Gold proposes to use are 99 percent efficient.

How will Donlin make sure that mercury will not impact the environment or human health?

Donlin Gold recently completed a human health risk assessment for mercury that shows no risk from mercury for residents and subsistence users in the project area.

Donlin has a four-pronged approach for managing mercury:

  • Use of best available technology: We plan to use the best available technologies to reduce
    the amount of mercury released to the environment; including air emission control equipment, advanced water treatment, and covers at closure. Conservative studies predict that there could be slightly increased levels of mercury in the environment during mining operations. However, Donlin Gold has done detailed analyses to show that these levels will be low and they are not projected to cause adverse impacts to human health or wildlife. These analyses will be fully described in the final EIS. Nevertheless, we will remain aware of new management practices and technologies to determine if there are feasible methods to further reduce mercury emissions.
  • Compliance with permits and environmental regulations: Permits required for the project are designed to ensure that water discharges and air emissions that do occur will not cause impacts to human health or the environment. We are committed to complying with permits and will regularly inspect mercury control equipment, reviewing mercury containment procedures and conducting monitoring to demonstrate compliance with permit requirements. We are committed to safely containing, storing, and transporting the mercury residuals (liquid and carbon from air emission control equipment) in compliance with state and federal laws.
  • Monitoring: We are developing an environmental monitoring program that may include regular sampling of air, soil, water, and fish within and downstream of the mine site. The environmental monitoring program will include all permit mandated requirements.
  • Communication: Donlin Gold will continue to communicate with residents in the region to provide information and answer questions related to mercury and other issues and to provide results of mercury management and monitoring programs.
How will cyanide be handled, stored and transported?

Donlin Gold will follow guidelines established by the International Cyanide Management Code (ICMC) on how to transport, store, and use cyanide, as well as manage waste streams containing cyanide. Dry sodium-cyanide briquettes will be shipped to the mine site in sealed steel ISO (International Standard Organization) tanks. The ISO-containers that we are proposing are state- of-the-art in the mining industry and their track record for preventing spills is very strong. The cyanide will be dissolved into solution at very low concentrations for use in gold extraction. Once the gold is removed, the cyanide solution would go through a detoxification process to reduce its concentration. It would then be discharged into the lined tailings storage facility, where it would be safely contained under natural condition. Ft. Knox has found that it reduces by 90 percent in the tailings pond during summer.

Under ICMC guidelines, our cyanide management will be subject to independent expert audit on a periodic basis with findings available for public review on ICMC’s website. Continued ICMC certification will be contingent on addressing any issues identified by the audits.