ENVIROMENTAL MANAGEMENT PLAN
An applicable, relevant and appropriate Environmental Management Plan (EMP) has been developed to mitigate and minimize the environmental consequences. The EMP incorporates measures that include protection, mitigation, and enhances measures. A separate monitoring plan has been developed to assess the effectiveness of the management plan. The environmental mitigation measures in this EMP include:
Planting new vegetation around production facilities, and along access roads, and pipelines will mitigate the impact on terrestrial resources. The plant siting will also consider alternative locations, for pipeline routes and plant installations to minimize impact on terrestrial resources. Particular attention will be paid to vulnerable or conservation-worthy plant and animal species that will be affected.
The depths in the mining area of alluvials and shallow saprolitic material will not exceed 18m. Mine walls will be designed and sloped to preclude slopes failures and slides. No excavated soil will be stored at the crest of the slopes. Sumps will be excavated into mined out area on the floor of the mine and all groundwater flow and precipitation will be channelled into those. Measures will be implemented to prevent surface runoff from entering the open pit and from adding to the volume of groundwater inflow and direct precipitation.
Overburden soil removed from above the ore horizon will be stockpiled for land reclamation. To minimize excessive land consumption and the associated clearing of forested areas, all stockpiles will be sited within the mine itself. Further, no stockpile will be sited within 100m of any waterways.
Stormwater runoff and water from the mine pit will both be channelled to sedimentation pond. That pond will be designed to provide a detention time of 48 hours. Discharge from the sedimentation pond will be via a spillway and will be channeled through a sediment control structure of matrix stone, sand and grass to remove sediment prior to discharge to the surface water bodies in the site area. In some instances, water from the sedimentation pond will be discharged to augment water in the washing and tailing circuit.
The mine will be developed to ensure minimum disturbance to streams and creeks in the area. In instances where this cannot be avoided, sediment control structures and practices will be used to prevent the inflow of sediment to surface water. These control practices will include sediment traps or screens to control run-off and sedimentation.
Surface runoff from the workshop and other vehicle service areas will be channelled to an oil/water separator. All water from the oil/water separators will be skimmed prior to discharge. Site clearing operating will progress in a gradual and phased manner to ensure there are no large increases in surface runoff.
All tailing ponds will be sited in the areas of low soil permeability to ensure minimum discharge to groundwater. In addition, the bottom of all tailings ponds will be above the high groundwater level and tailing ponds will be designed with the minimum surface area required to satisfy capacity constraints. Tailing ponds will also be surrounded by berms to prevent uncontrolled discharges to surface water and to preclude surface runoff from entering the tailings area. Tailings ponds will be sited partly above and below existing ground level. The part of the tailings pond above ground level will be designed to prevent slope failure and the associated release of tailings to the environment.
All water discharges from the tailings pond will be recycled to the wash plant. The tailings pond area will be patrolled to prevent fauna from straying into the ponds. Tailings ponds will be periodically cleaned and the material recovered from the ponds will be used for both road construction and for the reclamation of mined out areas.
Hazardous Material Management
All hazardous materials will be located in secure storage facilities on-site to prevent accidental release and protect against rainfall that may result in contaminated run-off and leaching; all storage areas for hazardous material will be concreted to provide an impervious surface and to prevent uncontrolled discharges to groundwater. Material Safety Data Sheets (MSDS) will be kept on site and all measures to contain spills of hazardous materials shall be in accordance with the procedures therein. No rainfall would be allowed to percolate through areas where hazardous materials are stored and no uncontrolled run-off will be permitted from these areas. Stormwater from the area around the storage facilities will be channelled to the sedimentation pond. Incompatible substances that can react upon mixing to generate heat, fire, gas, explosion, or violent polymerization would not be located within proximity of each other.
Solid waste from the operation of the camp will be recycled, composted or disposed of in secure areas. All plastic and glass containers will be recycled and taken off site. All food waste and organic matter will be composted and the composted material will be used as fertilizer from revegetation of the reclaimed areas.
Septic waste will be managed by a series of septic tanks on site. Discharge from the septic tanks will be channelled through a granular filter bed prior to discharge. Septic tank contents will be emptied by a licensed operator and will be trucked to Georgetown for disposal.
Ashes from burning vegetation will be added to the overburden soil and will be used for land reclamation. The coarse fraction of the tailing waste will be used for the construction of sediment control structures onsite. The fine fraction of tailings will be used to maintain both site access roads and roads within the mine itself.
All open-pit and stock pile areas will be reclaimed. Special erosion control measures would also be implemented around reclaimed areas to ensure minimum soil loss prior to vegetation taking hold in the reclaimed areas.
Air Quality, Dust & Noise
Water will be sprinkled on roads, other conveying routes and stockpiles to control dust emissions. A dust bonding agent such as molasses may be used if its use reduces the frequency with which the road should be sprinkled with water. The noise emissions would be limited by appropriate soundproofing of individual pieces of equipment. Equipment will be fitted with special exhaust systems (mufflers). Additionally, the miners will be required to wear personal noise-protection gear, e.g., ear protectors.
Employee Health & Safety
The impacts on health and safety will be mitigated by establishing a program to identify and eliminate all shallow pools and ponds in the area. Pesticides that are non-toxic to humans, fish and livestock will also be used for habitat and vector control. A body will also be established to provide health advisory and support health services and to monitor disease vector and disease incidences.
During the operation of the facility, emphasis will be placed on providing a safe and healthy environment for the workers. A healthy and safety plan will be implemented to ensure compliance with the regulations of the OHS Act 1997.
Occupational Safety & Health plans will be implemented in the following areas:
- Industrial Accident prevention and management
- Occupational Hygiene
- Illness & Infectious disease prevention and management
- Sewage and Waste Disposal
Industrial Accident Prevention and Management
Industrial accident prevention and management will be effected via the company safety program. This will commence during the construction of the new facility and last through the operating phase until the cessation of operations. The program will include the following:
Hazard Monitoring and Reporting
Monitoring of hazards and work conditions will be the prime responsibility of the safety representative who will be elected from among the workers. He will be responsible for:
- Performing Safety Inspections on and off the operations site on a regular and programmed basis (at least once per month) for the detection of unsafe conditions or any potential hazards and for reporting of these hazards to management.
- Recording of all accidents minor and loss time accidents in a ledger as required by the Ministry of Labour.
- Remitting of reports of industrial accidents or fatalities to the Ministry of Labour when required.
- In addition to the abovementioned, all employees will be educated about their responsibility to participate in the creation of a healthy and safe environment by:
- Reporting unsafe and hazards conditions when detected.
- Performing work in a safe manner by following the correct work procedure.
Training & Education of Employees
In confirmation with the objectives of safety programs will be implemented:
- Basic first aid programmes (all employees)
- Advanced first aid programmes (all employees)
- Accident investigation & reporting seminars (supervisory personnel & safety reps.)
The basic first aid program will be extended to all employees and would be geared to ensure that in the event of an accident or injury, someone with first aid knowledge will always be present to render initial assistance until further medical attention can be made available. Qualified personnel will run seminars to impart the necessary theoretical as well as practical skills required. These courses will be scheduled depending on the employee strength and attrition.
The advance first aid program will constitute an upgrading course from the basic first aid program in which selected employees including supervisors and the Safety representative will be exposed to advanced first aid knowledge and techniques which will enable them to participate in the recognition and the initial management of serious injuries and illnesses e.g., Fractures, Spinal Injuries, Malaria, Typhoid Fever etc.
Industrial Accident Protocol
Serious injuries will be referred to a medical practitioner and medical institution. The medical institution and practitioner will preferable be chosen from the nearest Town/Village to the operations and contact will be maintained by radio/radiophone at all times. In the event of an industrial accident the following protocol will be followed:
The main environmental occupational hazards to which employees will be exposed during the operations phase of the mining entity are:
The terrain in which the mining operations will be sited as principally sand (silica) and clay (silicate). The mining process consists of excavation, transportation, washing and extraction of gold from the host material. No blasting or grinding of hard rock is programmed. As a consequence the production process does not result in the dispersion of high concentration of particulate matter into the atmosphere. Any particulate matter dispersed into the atmosphere will be fugitive wind blow dust from the excavation and transportation of sand and clay via the conveyor systems being used. Sampling revealed that more than ninety percent (90%) of the fine crystalline silica particles are more than 2 microns in size. ILO and WHO guidelines state that the danger from the silica particles occur for diameters less than 5 microns and especially those with a diameter between 0.5 and 3 microns since those particles when inhaled can reach the alveoli and lead to lung impregnated disease. Development of respiratory disease due to inhalation of respirable dust has been shown to be in direct proportion to the total load of dust inhaled over a time period. This in turn is a function of:
- The dust particle size
- The concentration of particles in the atmosphere
- The duration of exposure
The concentration of dust particles in the air is not expected to be consistently above acceptable international standards since it is basically fugitive or wind blown dust. The development of respiratory disease due to inhalation of dust is very low and will probably need exposure time far in excess of twenty five years to develop.
Notwithstanding the abovementioned, the following measures will be implemented in order to decrease or eliminate respirable dust inhalation and prevent any adverse effects on workers:
- Provision of dust respirator with filters to employees exposed during the land reclamation, excavation and transportation phases of the operation.
- Siting of living quarters at a convenient distance from the operations site and on the leeward side of same.
- Minimal denudation of vegetation around campsite.
- Chest X-Rays of all employees once/yearly in order to detect any incipient pulmonary disease such as persistent coughing and/or shortness of breath,
These measures will assist in elimination or reduce further the very low risk of the development of lung impregnated disease by employees exposed to dust.
Employing workers in the excavation and transportation phase of the operations are also exposed to wind blown/fugitive dust being blown into the eyes and causing eye irritation and conjunctivitis. These employees will be provided with clear goggles and eye wash lotion which will at all times be available for washing the affected eyes.
The following measures will be implemented to address worker health and safety related to noise associated with the operation:
Fuel Oil Management
Fuel oil storage areas will be located well away from areas of fire hazard such as where welding operations will be performed. All fuel will be trucked to site by secure fuel trucks and transferred into fuel storage tanks that are founded on impervious concrete surfaces. The fuel tanks will be housed within bermed enclosures. The enclosures will be sized to retain the contents of 80% of the tank in the event of tank failure. Discharge from fuel storage areas will be channelled to oil-water separator prior to being discharged to surface water.
Spill Contingency Plan
A spill contingency plan will be developed to respond to any spills of oil and other hazardous substances. The only hazardous material to be used by the mining and processing operation is fuel oil. Contingency plan must, however, also address the likelihood of tailing spills or spills of material transported by pipelines within the plant area. The Spill Contingency Plan will have the following distinct components:
The vulnerability analysis will identify all resources and sensitive receptors that can be impacted by any spills or stored materials. This analysis will not consider any communities since none are within close proximity of the site. This information will be used to identify specific locations, waterways, plants, etc., that are likely to be susceptible to any spills. The risk assessment will then compare the hazard and vulnerability of each media likely to be impacted by any spills. The best method of controlling the spill will be developed after the risk assessment has been completed.
Response action will be developed to address the risks identified by the risk assessment. The response action will consist of the following:
Socio-economic Impact Management
The company will develop a public relations program that promotes respect for rights of indigenous people. In addition, the company will actively recruit employees from the communities around the area and will encourage the involvement of community residents in the environmental monitoring programs to ensure compliance with accepted norms. The communities will also be encouraged to make use of forest resources in the area in so far as that use does not impact the mining operations. The company will also sponsor skills training programs, and scholarships for residents of the area to enhance the skills of the local employment pool.
No restrictions will be placed on traffic flowing through the area that uses the access road constructed to the mine site. Restrictions will be imposed on traffic flows into active mining areas. Project vehicles only will be permitted into mining areas. Signs will be posted along the access road indicating to road users that Cuyuni River Resources will not accept liability for accidents on the access road and also indicating that road users are responsible for providing their own insurance cover for accidents on the access road.