Answers to the second series of questions and comments from the MELCC dated December 16, 2019

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Renard Mine Mine

Answers to the second series of questions and comments from the MELCC dated December 16, 2019

Ref. No.: 61470.050-100 (Version 0)

Additional Document — Environmental and Social Monitoring Program (Ref. 3214-14-041)

August 2020

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Renard Mine

Answers to the second series of questions and comments from the MELCC dated December 16, 2019

Ref. No.: 61470.050-100 (Version 0)

Additional Document — Environmental and Social Monitoring Program (Ref. 3214-14-041)

August 2020

Submitted to:

Deputy Minister of the Environment and the Fight against Climate Change Édifice Marie-Guyart, 30th Floor (Box 02)

675 Boulevard René-Lévesque East Quebec City QC G1R 5V7

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PROJECT TEAM

Les Diamants Stornoway (Canada) Inc.

Martin Boucher Vice-President, Environment, Health, Safety and

Sustainable Development

Mélissa Karen Bruneau, MGP Environment Superintendent

Maryse Godin Environment Coordinator

Norda Stelo Inc.

Vital Boulé, M.Sc., Biology Technical Director, Environment Project Manager

Catherine Vallières, M.Sc., Biology. Environmental Specialist Operations Manager

Yves Racine Cartographer, Database Technician

Mélissa Dubé, Administrative Assistant Publishing

Translator

Lottie White, C.Tr. English Translation

August 7, 2020 Catherine Vallières, M.Sc., Biology

Operations Manager

Date

Digitally signed by Catherine Vallières DN: c=CA, o=CENTRE DE CERTIFICATION DU QUEBEC, ou=CORPORATION, cn=Catherine Vallières,

serialNumber=catherine.vallieres(norda.com) Date: 2020.08.11 08:53:01 -04'00'

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Les Diamants Stornoway (Canada) Inc.

Renard Mine - Additional Document — Environmental and Social Monitoring Program (Ref. 3214-14-041)

Ref. No.: 61470.050-100 (Version 0) - i - August 2020

LIST OF TABLES

Table 4.3.1 (update) Surface water and sediment quality monitoring stations in the reference areas .... 2

Table 4.3.2 (update) Surface water and sediment quality monitoring stations in the area exposed to mining activities ... 2

Table 4.5.2 (update) List of parameters and frequencies for mine effluent monitoring ... 7

Table 12.1 Choice of reasons for leaving - interview ... 15

Table 12.2 Questions associated with other reasons ... 15

Table 12.3 Selection of proposed answers ... 16

LIST OF MAPS

Map 4.3.1 Surface water and sediment quality monitoring stations ... 3

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Ref. No.: 61470.050-100 (Version 0) - 1 - August 2020

1 BACKGROUND

This document contains additional information requested by the Ministry of the Environment and Fight Against Climate Change (MELCC) in its second series of questions and comments, which was dated December 16, 2019, and addressed to Martin Boucher, Vice-President, Environment, Health, Safety and Sustainable Development, of Stornoway Diamonds (Canada) Inc. These questions and comments concern Renard Mine’s Environmental and Social Monitoring Program filed in May 2019¹ and the 2015- 2016² and 2017³ environmental and social monitoring reports.

2 ANSWERS TO QUESTIONS AND COMMENTS FROM THE MELCC

2.1 Physical Environment

2.1.1 Surface water and sediment quality

QC-1. In answer to QC-9 in the questions and comments document dated January 5, 2016, the proponent indicated that stations AQR34 and AQR15 would be transferred from Table 4.3.1 (surface water and sediment quality monitoring stations in the reference areas) to Table 4.3.2 (surface water and sediment quality monitoring stations in the area exposed to mining activities). The location of these stations does not appear to be appropriate for verifying baseline surface water quality because the surface water could be influenced by drainage water from the processed kimberlite accumulation area. The proponent also indicated that two reference stations would be added upstream of the mine site outside the zone of influence. The exact location of these additional stations was to be determined on site as part of the next surface water quality monitoring campaign in spring 2017. The proponent should explain why these corrections were not made to the monitoring program and should make the necessary changes to ensure the results for the reference and exposure areas can be properly compared.

Answer to QC-1

This was an oversight on our part. The corrections have been made to tables 4.3.1 and 4.3.2 below, where stations AQR-34 and AQR-15 were moved to Table 4.3.2 (surface water and sediment quality monitoring stations in the area exposed to mining activities). In addition, two new control stations were selected and added to Table 4.3.1. One of these was installed upstream from Lake F3294 (AQH08-(ES)) and the second, at the head of Lake F2602 (AQL05-(ES)). They will be sampled in the next surface water and sediment monitoring campaign. An updated version of Map 4.3.1 is attached hereto.

1 Les Diamants Stornoway (Canada) inc. 2019. Renard Diamond Project – Environmental and Social Monitoring Program – Renard Mine by Les Diamants Stornoway (Canada) inc., February 2019, 308 pages and 3 appendices.

2 Les Diamants Stornoway (Canada) inc. 2017. Renard Diamond Project – Environmental and Social Monitoring Program – 2015-2016 Monitoring Report by Les Diamants Stornoway (Canada) inc., September 2017, 131 pages and 2 appendices.

3 Les Diamants Stornoway (Canada) inc. 2018. Renard Diamond Project – Environmental and Social Monitoring Program – 2017 Monitoring Report by Les Diamants Stornoway (Canada) inc., August 2018, 131 pages and 2 appendices.

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August 2020 - 2 - Ref. No.: 61470.050-100 (Version 0)

Table 4.3.1 (update) Surface water and sediment quality monitoring stations in the reference areas

Type of monitoring point

Station

name Description

Watershed other than that of the mine site

AQD3 Misask River, near the bridge at km 641 of route 167 North

Upstream of the mine site

AQH5 Watercourse downstream from Lake F3293, located just upstream of Lake Lagopede

AQH3 Station located in the west bay of Lake Lagopede, upstream of the mine site

AQH7 Station located close to the shores of Lake F3293

AQR77 Watercourse flowing near the lake trout spawning area in the west sector of Lake Lagopede

AQH08 Station located upstream from Lake F3294 AQL05 Station located at the head of Lake F2606

Raw water intake AQR40 In the south bay of Lake Lagopede, raw water intake for the production of drinking water

Table 4.3.2 (update) Surface water and sediment quality monitoring stations in the area exposed to mining activities

Targeted

infrastructure Name Description

Airstrip

AQP3 Body of water located at the end of the airstrip, downstream from a sedimentation basin

AQP4 Small permanent watercourse to the north of the road and to the west of the airport road, draining water close to the terminal Explosive storage

area

AQH1 In the north bay of Lake Lagopede

AQH2 At the confluence of Lake F3294’s outlet and Lake Lagopede’s north bay

Upstream of the modified processed kimberlite area (MPKA)

AQR34 F3297 water body

AQR15 Watercourse at the confluence of F3295 water body and its main tributary

Domestic effluent (permanent treatment plant)

AQR63 Lake Lagopede, in the distal area of the treated effluent’s dispersion plume, where the dilution factor has reached 1:100 AQR64 Lake Lagopede, in the proximal area of the treated effluent’s

dispersion plume, where the dilution factor has reached 1:10 Mine effluent

(temporary treatment plant

AQR10 In Lake Lagopede, close to the R-9 site

AQR11 In Lake Lagopede, in the little bay in the northeast part of the lake, close to the R-4 site (station moved to the area’s deepest point) Mine effluent

(MWTP)

AQR65 Lake Lagopede, in the distal area of the treated effluent’s dispersion plume

AQR69 Lake Lagopede, in the treated effluent’s dispersion plume (at the deepest point of Lake Lagopede’s north basin)

Lake Lagopede, downstream from mine and

domestic effluents

AQR66

Lake Lagopede, in a distant area downstream from the presumed distal limit of the treated domestic effluent’s dispersion plume and downstream from the distal limit of the treated mine effluent’s dispersion plume (permanent treatment plant)

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QC-2. In section 4.3.5.2 of the environmental monitoring program received in May 2019, it states that an annual surface water and sediment quality monitoring report is submitted to the Administrator every year for information purposes. The objective of this report is to generally track changes in surface water and sediment quality throughout the year and compare the results with baseline data obtained as part of the environmental baseline study. It is also used to compare data from the exposure area to data from the reference area. Since 2015, however, no annual surface water and sediment quality monitoring report consistent with the report specified in section 4.3.5.2 has been filed by the proponent. In the 2017 monitoring report, the proponent indicated that the report would likely be submitted soon. The proponent should explain and justify the delay in filing the annual surface water and sediment quality monitoring report. And if necessary, the proponent should propose a revised frequency for filing the monitoring report and give reasons for the revised filing.

Answer to QC-2

Mining operations began in 2017 at the Renard mine. From the start of operations, Stornoway has ensured that:



surface water and sediment quality have been monitored annually. In the case of surface water, quarterly sampling, i.e., four times a year, is carried out, as specified in the ESMP. Sediment sampling is done once a year in the fall;



the data collected has all been duly compiled and preserved;



a summary of the surface water and sediment quality results is included in the comprehensive annual monitoring report submitted every year to the Administrator.

For the moment, comprehensive monitoring reports for the mine site have been filed for 2015-2016⁴, 2017⁵ and 2018⁶. These are public reports that are posted to Stornoway’s website.

A more detailed monitoring report will be filed with the Administrator in the second quarter of 2020. This report will outline changes in surface water and sediment quality measured at the Renard mine site in 2017, 2018 and 2019. It will also compare the results with baseline data in addition to comparing data from the exposure area to reference area data. Stornoway thereafter proposes to submit this comprehensive monitoring report every three years. Filing a report every three years is considered to be

4 Les Diamants Stornoway (Canada) inc. 2017. Renard Diamond Project – Environmental and Social Monitoring Program – 2015-2016 Monitoring Report by Les Diamants Stornoway (Canada) inc., September 2017, 131 pages and 2 appendices.

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more effective than filing annually because it is difficult to detect trends in water and sediment quality degradation and improvements with data collected over a single year.

2.1.2 Mine effluent (EDO) and hydrology

QC-3. The proponent needs to remove the EDO value specified for monitoring phosphorus in mine effluent in ENVS-3.3.5, because no EDO can be calculated for this parameter in the case of lake discharge. A very small increase in phosphorus concentration can however lead to eutrophication in Lake Lagopede. The quantities of phosphorus discharged should therefore be minimized, and the parameter monitored in mine effluent.

Answer to QC-3

A note was added to Table 4.5.2 indicating that the value specified for phosphorus is not an EDO but rather a “reference value.” In addition the note indicates that “No EDO can be calculated for total phosphorus in the case of lake discharge. A very small increase in phosphorus concentration could lead to eutrophication in Lake Lagopede. The quantities of phosphorus discharged should therefore be minimized.” The updated version of Table 4.5.2 is provided below.

QC-4. Chronic toxicity tests conducted on mine effluent in ENVS-3.3.5 involve Pseudokirchneriella subcapitata and Cladoceran Ceriodaphnia dubia. These tests must be conducted four times a year at the same time as testing for other parameters.

Answer to QC-4

Stornoway takes due note of this requirement and it will be incorporated into the next version of the ESMP. The updated version of Table 4.5.2 is provided below.

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EMM study (section

4 to 6 of Schedule 5) Internal monitoring

Frequency Frequency

Usage Criteria

Allowed monthly maximum

average concentration

Maximum concentration

allowed for a grab sample

Continuousl y Weekly Monthly Quarterly (7) Continuously 3 times/week Monthly Weekly Monthly Average Acceptable

Monthly Concentration

Maximum Acceptable Concentration

Continuously 3 times/week Weekly Monthly Annually Continuously 3 times/week Weekly Monthly Quarterly Quarterly

Physico-chemical Parameters

Flow m³/day - - - - X⁹ - - - X - - - - X³ - - X X - - X X (except

MIR2-C) - - - - X⁴

pH pH unit CALC - - X⁶ - - X - - >6,5 - X 6,0 à 9,5 - X X - - X X - - - - X⁴

Alkalinity mg/L of CaCO3 CALC ⁱ - - - X - - - - - X³ - - - - - - X - - - - X X⁴

Conductivity µS/cm - - - X - - X² - - X - - - - - - - - X - - X⁴

Hardness mg/L of CaCO3 - - - X - - - - - X - - - - - - X - - - - X X⁴

BOD5 mg/L CALC 3 - - - - - - - - X³ - - - - - - X - - - X⁴

COD mg/L - - - - - - - - X³ - - - - - - X - - - X⁴

Total Suspended Solids (SS) mg/L CALC 6^a 15 30 - X⁶ - - - - - 15 - X 15 30 - X - - X - X - - - X⁴

Total Dissolved Solids (TDS) mg/L - - - - - - - - X - - - - - - X - - - X⁴

Total solids (TS) mg/L - - - - - - - - X³ - - - - - - X - - - X⁴

Dissolved oxygen mg/L CALC ^j - - - X - - - - - - - - - - - -

Temperature °C CALC ^k - - - X⁸ ^- X X - - - -

- - - - - - - X X¹⁶(MIR2,

A and B) - X

(MIR2-C) - - X⁴

Turbidity NTU CALC ^l - - - X - - - - X³ - - - - - - X X¹⁶(MIR2,

A and B) - X

(MIR2-C) - - X⁴

Nutrients and Ions

Total ammoniacal nitrogen (NH₃+NH₄) - Summer mg/L of N CALC 1,2^f 5,92 - X - - - - X X⁴

Total ammoniacal nitrogen (NH₃+NH₄) - Winter mg/L of N CALC 1,9^f 9,42 - X - - - - - X⁴

Non-ionized ammonia (NH3) mg/L of N - - 0,5 1,0 ^- X⁸ ^- - - - -

Total Kjeldahl Nitrogen (TKN) mg/L of N - - - - - - - X - - - X⁴

Nitrates + nitrites mg/L of N - - - X³ - - - - - - X - - - - X X⁴

Nitrates (NO3) mg/L of N CALC 3 - - - X - - - 14,34 - X - - - - - - X - - - X⁴

Nitrites (NO2) mg/L of N CALC 0,02^g - - - 0,08 - X - - - - - - X - - - X⁴

Total phosphorus (trace method) mg/L of P CALC - - - X - - - (0.075**) X X⁵ - - - - - - X⁵ - - - X^4,5

Chlorides mg/L CALC 230 - - - X - - - 1149 - X - - - - - - X - - - X⁴

Fluorides mg/L CALC 0,2 - - - 0,8 - X - - - - - - X - - - X⁴

Sulfates mg/L CALC 500^h - - - X - - - 2495 - X - - - - - - X - - - X⁴

Total Extractible Metals and Metalloids (Trace method)

Aluminum mg/L CALC 0,087^b - - - X - - - 0,132^b - X⁵ - - - - - - X⁵ - - - - X X^4,5

Arsenic mg/L CPC(O) 0,021 0,3 0,6 X^6,10 - - - 0,105 - X⁵ 0,2 0,4 - - X - X⁵ - - X - - X^4,5

Barium mg/L CALC 0,038^c - - - 0,17 - X⁵ - - - - - - - - - - X^4,5

Beryllium mg/L CALC 0,00014^c - - - X⁵ - - - - - - - - - - X^4,5

Cadmium mg/L CALC 0,000049^c - - - X - - - 0,00022 - X⁵ - - - - - - X⁵ - - - - X X^4,5

Calcium mg/L CALC ^m - - - X^3,5 - - - - - - X⁵ - - - X^4,5

Total chromium mg/L CALC 0,013^c,p - - - X - - - 0,064 - X⁵ - - - - - - X⁵ - - - X^4,5

Cobalt mg/L CALC 0,1 - - - X - - - X^3,5 - - - - - - X⁵ - - - X^4,5

Copper mg/L CALC 0,0013^c,d 0,3 0,6 X^6,10 - - - 0,005 - X⁵ 0,3 0,6 - - X - X⁵ - - X - - X^4,5

Iron mg/L CALC 1,3^e - - - X - - - 3 - X⁵ 3 6 - - X - X⁵ - - X - - X^4,5

Magnesium mg/L - - - X^3,5 - - - - - - X⁵ - - - X^4,5

Manganese mg/L CALC 0,26^c - - - X - - - 1,28 - X⁵ - - - - - - X⁵ - - - X^4,5

Mercury mg/L CALC 0,00091ⁿ - - - X¹³ - - - X⁵ - - - - - - X⁵ - - - - X X^4,5

Molybdenum mg/L CALC 3,2 - - - X - - - X^3,5 - - - - - - X⁵ - - - - X X^4,5

Nickel mg/L CALC 0,0074^c 0,5 1,00 X^6,10 - - - 0,034 - X⁵ 0,5 1 - - X - X⁵ - - X - - X^4,5

Lead mg/L CALC 0,00017^c 0,1 0,2 X^6,10 - - - 0,00057 - X⁵ 0,2 0,4 - - X - X⁵ - - X - - X^4,5

Potassium mg/L - - - X^3,5 - - - - - - X⁵ - - - X^4,5

Selenium mg/l CALC 0,005^q - - - X - - - -

Sodium mg/l - - - X^3,5 - - - - - - X⁵ - - - X^4,5

Thallium mg/l CALC 0,072 - - - X - - - -

Uranium mg/l CPC(WO) 0,02^r - - - X - - - -

Zinc mg/L CALC 0,017^c 0,5 1,00 X^6,10 - - - 0,077 - X⁵ 0,5 1 - - X - X⁵ - - X - - X^4,5

Élément radioactif

Radium 226 Bq/l CPC(WO) 0,6 0,037 1,11 - X^6,11 - - - -

Organic Compounds

Phenolic substances mg/L CPC(O) 0,005 - - - X - - - - - - X - - - X⁴

Hydrocarbons (C10-C50) mg/L CALC 0,01^o - - - 0,05 - X - 2 - - - - X - - - X - X⁴

Toxicity Test

Acute toxicity (trout and daphnia) TUa FAVe 1 - - - X¹² - - - - 1 - X - - - X X - - - X - -

Chronic toxicity (on one species of fish, invertebrate,

plant and algae) TUc CALC 1 - - - - -

X¹⁴

(2 x / years for the first 3 years)

- - - 1 - X - - - - X¹⁵ -

Table 4.5.2 (update) List of parameters and frequencies for mine effluent monitoring

Parameter Unit Requirements Frequency

Directive 019 Surface water quality

criteria for the protection of aquatic

life (MDDEFP, 2013)

Other global CA conditions (MDDELCC, 2014)

Frequency

Intermediate MWTP

(MIR2-A) Final (MIR2) and intermediate (MIR2-A, MIR2-B, MIR2-C) mine effluents

Frequency Depollution attestation

- -

- ^- X⁸ ^- X - - - -

Mine Affluent (MIR-4) and Water from Ditch

F125

6,0 à 9,5

Effluent monitoring (section 12 to 25) Frequency Allowed limit (Schedule 4)

Allocated Concentration

Effluent Discharge Objectives EDO -

Frequency MMER

Combined final effluent (MIR2)

- - X

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MDDELCC, 2014. Modification of the certificate authorizing the Renard Diamond Project (Global CA 3214-14-041) - Monitoring conditions issued on June 9, 2014. 5 pp.

MDMER: Metal and Diamond Mining Effluent Regulations Notes

Cells highlighted in yellow with red writing indicate modifications performed in January 2020.

(9) The owner or operator of a mine shall record, in cubic metres, the total monthly volume of effluent deposited from each final discharge point for each month during which there was a deposit (section 19(1) of the MDMER).

(n) This criterion for quality was defined using data on inorganic mercury (HgII) but it is applied to total mercury. If a significant portion of the mercury in the water column takes the form of methylmercury, this criterion for quality will not be protective enough. In addition, this does not take into account the transformation of inorganic mercury into methylmercury, or the bioaccumulation of the latter in the food chain.

A factor of 0.85 allows conversion of this quality criterion, expressed in total extractable metal, to dissolved metal (U.S. EPA, 2002).

(o) Using data presented in U.S. EPA (1976b), the Ministry opts for an operational quality criterion of 10 µg/L for petroleum hydrocarbons.

(p) There is no criterion for total chrome. Chrome is generally present in the aquatic environment in the form of Cr(III). The criterion for chronic aquatic life applicable to Cr(III) is therefore here applied to total chrome.

(i) The sensitivity of an environment to acidification varies with alkalinity:

Sensitivity Concentration (mg/L CaCO₃) High --- < 10

Average --- 10-20 Low --- > 20

(m)The sensitivity of an environment to acidification varies with the concentration of calcium:

Sensitivity Concentration High --- < 4

Average --- 4-8 Low --- > 8

An indicator for the sensitivity for alkalinity also exists.

(j) Concentrations of dissolved oxygen must not be less than the following values:

Concentration of dissolved oxygen Cold water biota Hot water biota Temperature

°C % Saturation mg/L % Saturation mg/L --- --- --- ---

0 54 8 47 7

5 54 7 47 6

10 54 6 47 5

15 54 6 47 5

20 57 5 47 4

25 63 5 48 4

In waters inhabited by sensitive biological communities, the presence of an additional physical or chemical stress may require the use of more restrictive limits.

In hypolimnetic waters, the natural concentration of dissolved oxygen is sometimes lower than concentrations mentioned above. This state must not be aggravated by the addition of biodegradable materials which would cause a reduction in oxygen, in the environment.

(k) Any artificial reduction or increase in temperature must not:

- change the temperature of the water across a section of river or portion of a lake with the resulting foreseeable displacement, or a change in the current or potential aquatic populations;

- alter certain local sensitive areas, such as a spawning bed;

- kill living organisms near a discharge point.

In addition, the environment must not be subject to abrupt changes in temperature brought about by, for example, the sudden stoppage of a thermal discharge in the cold season.

(l) In clear water, such as Lake Lagopède, the quality criterion is defined by an average maximuum increase of 2 NTU in relation to the natural or ambient value (not influenced by a point source affecting the turbidity of the water, by significant rain, or meltwater) according to context.

CPC(WO) : Contamination Prevention Criteria for water and aquatic organisms, CPC(O) : Contamination Prevention Criteria for aquatic organisms, FAVe: Effluent final acute value, CALC: Chronic aquatic life criteria.

MDDEFP. 2013. Critères de qualité de l'eau de surface. 3e édition. Québec. Direction du suivi de l'état de l'environnement. 510 pages and 16 appendices. Updates made to the criteria from the document's date of publication are available online, at: http://www.mddelcc.gouv.qc.ca/eau/criteres_eau/index.asp]. Page retrieved on June 29 2018.

(h) The criterion for sulfates is calculated for a receiving environment whose hardness is less than 100 mg/L CaCO₃ and for which the concentration of chlorides is less than 5 mg/L.

(c) Criterion calculated for a receiving environment whose average hardness is 10 mg/L CaCO3, a minimum value which is used to calculate quality criteria for metals.

(e) The quality criterion for iron may not be protective for the mayfly (Ephemerella subvaria) if this species is as sensitive as some data indicates.

(g) The criterion for nitrites is calculated for a receiving environment whose average concentration of chlorides is 0.26 mg/L in accordance with data in the ESIA (Roche, 2011).

(2) The conductivity measurement specific to mine effluent must be done on the same days as the sampling of the water in Lake Lagopède (according to the modification of the comprehensive CA - Monitoring conditions of June 9, 2014)

(3) The quarterly monitoring of these parameters, i.e. of parameters for which only annual monitoring is required by Directive 019, is done on a voluntary basis, in order that their monitoring is stricter.

(b) The criterion for aluminum was defined for waters of low hardness and a pH of approximately 6.5. Given that the environment meets these conditions, an EDO for aluminum was calculated. When this criterion is used, surface water data must be corrected to reduce the proportion of non-bioavailable particle-associated metals. A correction factor of 0.66 is used for surface water data which have a concentration of suspended solids < 5 mg/L. As such, concentrations of aluminum measured during monitoring must be corrected using this factor before comparison with the EDO.

(5) During quarterly and annual monitoring, metals and phosphorus are analyzed using the trace analysis method.

(4) The quarterly monitoring of these parameters for mine affluent and in the waters of Ditch F125, i.e. of parameters for which only annual monitoring is required by Directive 019, is done on a voluntary basis, in order that their monitoring is stricter.

(8) The weekly monitoring requirement for these parameters will come into force in 2021. The non-ionized ammonia concentration will be calculated using temperature, pH, and total ammoniacal nitrogen measurements recorded in the effluent sample. See section «modifications not in force» of the MDMER for more details.

** The value considered for total phosphorus is not an EDO but rather a guide value. No EDO can be calculated for total phosphorus when the discharge is in an lake. A very small increase in the concentration of phosphorus can lead to eutrophization effects in Lake Lagopede. The discharge of phosphorus must be minimized.

(10) The frequency of conducting tests relating to the concentrations of arsenic, copper, cyanide, lead, nickel or zinc at a final discharge point canbe reduced to not less than once in each calendar quarter, each test being conducted at least one month apart, if that substance’s monthly mean concentration at

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The frequency of conducting tests relating to the concentration of radium 226 at a final discharge point can be reduced to not less than once in each calendar quarter, each test being conducted at least one month apart, if the concentration of radium 226 at that final discharge point is less than 0.037 Bq/L for 10 consecutive weeks (section 13(2) of the MDMER). he

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The chronic toxicity monitoring is requested starting on the 15th month following the obtention of the authorization for the operation of an industrial establishment (obtained on 15 November 2020). The two chronic toxicity tests that have to be performed at the mining effluent are those on the algae Pseudokirchneriella subcapitata and on the Cladoceran Ceriodaphnia

(d) The criterion for the water quality of copper represents toxicity in an environment where the level of organic dissolved carbon (COD) is on the order of 2 mg/L. This criterion may be overprotective in environments where the level of COD is higher.

(f) The criteria for the protection of aquatic life from ammoniacal nitrogen are determined for a temperature of 20ºC in summer, and 7ºC in winter, and for a minimum pH value of 6.5. For the sampling of drinking water, a concentration in the environment greater than 0.2 mg/L may undermine disinfection.

(a) The criteria for suspended solids (SS) corresponds to an increase of 5 mg/L in relation to the natural concentration. The latter was assessed at 1 mg/L using the average of concentrations measured in surface water in the local zone of study (Roche, 2011).

(16) The depollution attestation requires weekly monitoring of MIR2 at the minimum. However, SWY records these parameters continuously, which is more than required by the Ministry.

(12) A grab sample of effluent must be collected at least once a month (no less than 15 days apart) from each final discharge point and determine whether the effluent is acutely lethal by conducting acute

(13) The recording of the concentration of mercury in effluent may be discontinued if that concentration is less than 0.10 µg/L in 12 consecutive samples (section 4(4) of Schedule 5).

(14) The sublethal toxicity tests are conducted on each fish, invertebrate, plant and algea species two times each calendar year for three years and each test shall be conducted on an aliquot of effluent sample collected at least one month after the collection of the sample used in the previous tests (section 6(3) of Schedule 5). After three years, the tests shall be conducted once

(6) An effluent grab sample must be collected at least once a week and samples must be collected at least 24 h apart.

(7) Effluent characterization is carried quarterly on an effluent sample aliquot collected weekly at each final discharge point and at least one month following the last characterization.

(1) These EDO were established for the first three years of the project's operation. After which an EDO monitoring report will be submitted to the MDDELCC so as to assess the project's acceptability, and determine the standards with which to comply for the project, as well as the self-monitoring program. The parameters, standards, and EDO monitoring frequencies in Table 4.5.2 should be adjusted as needed, following the MDDELCC assessment.

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QC-5. Annual monitoring parameters required under Directive 019 on the Mining Industry are currently under review. Some mining effluent parameters need to be added while others should be withdrawn, and monitoring frequency could also be changed to quarterly monitoring. These adjustments will provide consistency among the various general monitoring requirements (annual monitoring under Directive 019, EDO monitoring and monitoring by companies subject to the industrial waste reduction program).

The monitoring proposed by the proponent is consistent with its proposed changes to current annual monitoring under Directive 019. However, to anticipate future changes, we suggest that the proponent make the following changes to the monitoring program for stations MIR2A, MIR2B and MIR2C.

 Monitoring of chemical oxygen demand (COD), biochemical oxygen demand (BOD5) and phenolic compounds will no longer be required and the proponent may remove these parameters from the monitoring program if they are unlikely to be found in final effluent. In the event the situation in this regard changes (e.g., accumulation areas being restored with residual fertilizing materials), they could be reinstated as part of monitoring;

 Nitrites and nitrates should be analyzed separately.

Answer to QC-5

Stornoway takes due note of these suggestions, but would prefer to continue monitoring these parameters as in the past. Note that nitrites and nitrates are already analyzed separately. The updated version of Table 4.5.2 is provided above.

QC-6. The EDO monitoring report referred to in Section 3.5.5.1.2 of the monitoring program must comply with the principles set out in the “Lignes directrices pour l’utilisation des objectifs environnementaux de rejet relatifs aux rejets industriels dans le milieu aquatique”

[guidelines regarding the use of effluent discharge objectives for industrial discharges into the aquatic environment] (MDDEP, March 2008) and its addenda “Comparaison entre les concentrations mesurées à l’effluent et les objectifs environnementaux de rejet (OER) pour les entreprises existantes” [comparison of measured effluent concentrations and effluent discharge objectives (EDOs) for existing companies] (MDDELCC, 2017). The spreadsheet for comparing monitoring results and EDOs as indicated in the addenda is available at:

http://www.environnement.gouv.qc.ca/eau/oer/chiffrier-comparaison.xlsx. This exercise is to be repeated every five years thereafter.

Answer to QC-6

Stornoway takes due note of this comment and will submit the report in question to the MELCC in the second quarter of 2020.

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2.1.3 Groundwater

QC-7. Groundwater monitoring reports do not provide the water levels measured in observation wells. These results should be provided and the proponent is required to indicate if they are aligned with the hydrogeological modelling results presented in the impact assessment.

Answer to QC-7

Water level measurements in observation wells will be included in the next groundwater monitoring report and will be compared with baseline data as well as with hydrogeological modelling results to assess whether anticipated impacts are representative of reality. This report is scheduled to be submitted to the Administrator in 2020.

2.2 Biological Environment 2.2.1 Terrestrial and avian fauna

QC-8. In measures to protect avian fauna in Section 4.11.4.5 of the environmental and social monitoring program filed in May 2019, the proponent makes no mention of the common nighthawk that nests in open unobstructed environments and could well nest directly on the ground in the mine site. The proponent does not indicate which protection measures will be put in place if a common nighthawk nest is discovered. In view of the species’ special status, it is essential that appropriate protective measures be in place in the event the species is found on the mine site. These measures should be included in the next update to the environmental monitoring program.

Answer to QC-8

First, Stornoway would like to inform the MELCC that no common nighthawk (Chordeiles minor) has been sighted at the Renard mine site since the start of terrestrial and avian fauna monitoring. Furthermore, the species was not identified in inventories conducted as part of the environmental baseline study for the project.

Despite this, as requested by the MELCC, measures will be put in place on the mine site to minimize potential impacts of mining activities on this species, which is likely to be designated as threatened or vulnerable in Quebec. The species is in fact designated as threatened in Schedule 1 of the Species at Risk Act. However, its legal status is currently under review, since the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) re-examined its status and designated it as a species of special concern in April 2018⁷.

The measures below will be included in the next update to the environmental monitoring program.

7COSEPAC. 2018. Common Nighthawk (Chordeiles minor) COSEWIC assessment and status report. committee on the Status of Endangered Wildlife in Canada, Ottawa, xi + 58 pages.

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Ensure workers are aware of the potential presence of bird nests in work areas, more specifically common nighthawk nests on the ground in stripped areas;

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In the event a nest is discovered on the work site, all disruptive activities will be stopped in the nesting area until breeding is complete (i.e., until hatchlings leave the nest area permanently, which may be in a few days or a week or more, depending on the species and stage of development);

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Protect any nests found by establishing a buffer zone based on an appropriate protective distance for the species until hatchlings leave the nest area permanently. The appropriate protective distance may vary significantly depending on the species;

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No nests shall be identified using signage tape or other similar material, since that would increase the risk of predation. If necessary, signage tape may be placed around the buffer zone.

QC-9. More exhaustive monitoring of black bear sightings on the mine site, including sightings at the trench landfill site (TLS), are needed to assess the impact of the mine on this species.

The issue of frequent presence of black bears at the TLS is well known, but does not appear to be clearly logged in the wildlife sightings log (despite the fact that Section 4.11.3.5 of the environmental and social monitoring program submitted in May 2019 noted that these sightings were logged). In addition, a number of bears are killed every year on or near the mine site by Cree in the area. This harvest is not logged since it is considered to be subsistence harvesting. This information should however be made available so as to enhance general understanding of the mine’s impact.

Answer to QC-9

Stornoway will adjust the way the wildlife sightings log is used so as to track black bear sightings at the TLS more accurately. It should be noted that Stornoway has already put a system of surveillance cameras in place to detect the presence of bears at the TLS.

Like the MELCC, Stornoway believes it would be desirable to log all black bears that are harvested by the Cree on and in the immediate vicinity of the mine site. Some hunting and trapping statistics are available from the Cree Trappers’ Association (see Table 4.2 in the 2019 wildlife monitoring report⁸ for further details), but not all harvesting that occurs in the territory is covered. The harvesting of black bears, as well as all other animal species, by the Cree is often done without Stornoway’s knowledge and it is not the type of information the Cree share with the mining company. Stornoway proposes to raise land users’

awareness of the importance of sharing their harvesting data, particularly black bear data, so as to acquire a better understanding of the impact of the mine on the black bear population.

8 Norda Stelo. 2019. Renard Diamond Project: Suivi de la grande faune (2019). Rapport présenté à Les Diamants Stornoway (Canada) Inc. Version 1. Juillet 2019. 64 pages + annexes.

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In addition, there is no proof that bears are actually harvested by the Cree. Black bear sightings at the TLS seem to increase significantly for a while then suddenly disappear. This drop in sightings could be due to natural factors, such as the appearance of new sources of food nearby. Bears are opportunists and the mining company believes that the berry season, for one, contributes to bears periodically abandoning the TLS.

2.3 Accumulation Area Monitoring

QC-10. The monitoring reports submitted by the proponent do not include results for the modified processed kimberlite containment (MPKC) area in section ENVS-3.3.14. The proponent is required to submit an annual report as specified in condition 14 of the amendments to the certificate of authorization dated August 3, 2017.

Answer to QC-10

Stornoway has undertaken extensive monitoring of the MPKC, including daily, weekly, monthly, quarterly and annual inspections. A summary of the results of these inspections is published in the Renard mine’s comprehensive monitoring report, which is submitted annually to the Administrator. To satisfy condition 14 of the General CA, a more extensive independent report on the results of MPKC monitoring will be produced and attached to the next comprehensive monitoring report for the Renard mine (covering 2019), which will be submitted to the Administrator in 2020.

2.4 Social Environment

2.4.1 Land use by trapline M11 users

QC-11. Under the monitoring program, the monitoring of land use by trapline M11 users was to be carried out in early 2017 in compliance with the provisions of the social monitoring program (ENVS-3.1.2). The proponent should indicate whether the semi-directed interviews were actually carried out as planned. If so, the proponent should provide a summary of the methodology and findings. If not, the proponent should explain why the interviews were not held and review the schedule for conducting these interviews.

Answer to QC-11

Meetings with tallymen

Throughout 2017 and 2018, regular meetings were held with M-11 tallymen and some members of their family. A dozen formal interviews were held each year along with a number of phone calls in 2018. The purpose of these meetings was to discuss project developments, challenges, and job and contract opportunities. The meetings also provided an opportunity to address their questions, issues and concerns. These meetings were for the most part held at Stornoway’s Mistissini office.

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Meeting with M11 and M16 tallymen with regard to big game monitoring

Interviews were held with M11 and M16 tallymen in November 2017 and March 2019, following winter monitoring of big game, which is done every two years. The objectives of the interviews were to gather input from the main trapline users as regards the big game monitoring activities that had been planned and carried out, and record their perceptions of the status of big game populations and any changes they made to their hunting patterns since the mine and the extension of Route 167 opened. The results of these interviews were presented in the 2017 and 2019 big game monitoring reports for the Renard mine^9,10, and are summarized below.

Interviews were conducted on November 1, 2017, with M11 tallymen (Sydney Swallow, Emerson Swallow, Gordon Swallow and Nannie Swallow) and M16 tallymen (Norman Matoush and Matthew Matoush), with assistance from Stornoway’s facilitator and translator Minnie Coonishish. Benjamin Jacob, a Stornoway Environment representative, Natalie D’Astous, the person in charge of the March 2017 surveys, and Vanessa Viera, the person from Norda Stelo in charge of carrying out the big game monitoring, were also in attendance. The main points of discussion raised by the tallymen in the November 2017 interviews were as follows:

(1) Concern regarding the increase in black bear and wolves sighted near the TLS;

(2) The adverse effect of predators and helicopter flights on moose populations on the M16 trapline;

(3) The tallymen’s desire to control predators by stepping up hunting pressure.

The perception of the abundance of the moose population differs between M11 (Swallow family) and M16 tallymen (Matoush family). The Swallows have observed that the moose have returned to the mine study area, whereas the Matoush family is concerned that in the past two (2) years the moose have scattered well beyond the road that runs through their trapline. As reported in 2015, the presence of the road may have contributed to altering the behaviour of moose and wolves documented in the mine road area. The combined impact of the mine road and a change in the level of predation could explain the perceived change in the distribution of moose.

As for the caribou, M11 and M16 tallymen maintain that the number of caribou in the sector has decreased since the early 2000s, although recent sightings of small groups and caribou carcasses have been reported on trapline M11, and three (3) caribou were killed on trapline M16 in 2017.

9 Norda Stelo. 2018. Renard Diamond Project: Suivi de la grande faune (2017). Rapport présenté à Les Diamants Stornoway (Canada) Inc. Version 1. Mai 2018. 64 pages + annexes.

10Norda Stelo. 2019. Renard Diamond Project: Suivi de la grande faune (2019). Rapport présenté à Les Diamants Stornoway (Canada) Inc. Version 1. Juillet 2019. 64 pages + annexes.

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Finally, according to the Swallow family, the mine has had no adverse impact on the local big game population. The Matoush family for its part is concerned by the low numbers of moose in their trapline, which it partially attributes to aerial exploration in recent years. Both families are concerned about the increased predator populations, particularly the wolf population, and are in agreement about increasing local hunting pressure to control the local population of this species.

In 2019, interviews were conducted on March 12 at the mine site, and March 26 in Mistissini with M11 tallymen (Sydney Swallow, Jonathan Swallow and Emerson Swallow) and M16 tallymen (Matthew Matoush, Coom Matoush, Mary Moutoush, Henry Matoush, Philip Matoush and John Matoush). Various Stornoway representatives were in attendance, including Rodney Petawabano, Stornoway’s Cree relations coordinator, and Maryse Godin and Mélissa Karen-Bruneau, two representatives from the environmental team. The interviews with the tallymen were conducted by Norda Stelo biologists Vanessa Viera and Sarah-Claude Lachance, who conducted the big game monitoring activities.

Generally speaking, the tallymen confirmed that their knowledge of the territory and wildlife resources were consistent with the densities and distribution of species surveyed in 2019. The main points raised during the interviews conducted on March 12 and 26, 2019, were as follows:

(1) Ongoing uncertainty with respect to the large number of bear and wolf sightings near the TLS area;

(2) The abandoned Eastmain mine site that has not been restored;

(3) The adverse impact of predators on the moose population in M11 trapline, including the discovery of an active den near the TLS;

(4) Poaching and vandalism at camps near the mine access road (Route 167), which are easily accessed.

2.4.2 Integration of Cree workers

QC-12. Under the monitoring program, the monitoring of the integration of Cree workers was planned for early 2017 in compliance with provisions of the social monitoring program (ENVS-3.1.3). The proponent should indicate whether the semi-directed interviews were actually carried out as planned. If so, the proponent should provide a summary of the methodology and findings. If not, the proponent should explain why the interviews were not held and review the schedule for conducting these interviews.

Answer to QC-12

It should be noted that during the construction period, the project was delayed with commercial production and start-up commencing in January 2017. A majority of the Cree integration management programs were therefore set up in 2017 and 2018. These programs have all evolved with revisions made as needed in response to ongoing monitoring and analysis. Based on our past experience with multicultural environments, we have learned that semi-directed exit interviews are the ideal way of

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obtaining a true picture of job satisfaction from employees, along with their suggestions for improving the way we manage diversity in a multicultural setting. Tables 1 and 2 list the topics and questions addressed in employee exit interviews, whereas Table 3 lists the selection of proposed answers. Note that online exit interviews provide employees who are leaving an opportunity to add their comments.

Table 12.1 Choice of reasons for leaving - interview Exit Interview Questionnaire (Reasons)

Work-life balance

Lack of career advancement Work environment

Employee benefits Excessive workload Salary conditions

Conflicts with co-workers Company culture

Work hours

Lack of management leadership

Promotion opportunities offered by new company Responsibilities/tasks not aligned with my skills Career transition

Returning to school Retirement

Offer of annual vacation

Table 12.2 Questions associated with other reasons Other Questions What will your role be in the new organization?

What could Stornoway have done to retain you?

What areas could Stornoway improve upon?

What positive aspects will you retain regarding your time at Stornoway?

Do you have any suggestions for improving less positive points?

Would you agree to return to work at Stornoway?

Would you recommend Stornoway to a friend?

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Table 12.3 Selection of proposed answers Selection of Answers Employee induction and integration

Employee benefits Work load

Clear role and responsibilities Internal communications Work-life balance

Equipment – tools required for the job Pay equity

Continuing education Performance management

Career advancement opportunities Recognition of my skills

Work relationships and environment Compensation

Support from my supervisor

In 2019, 15 Cree employees left the company, ten left voluntarily and five involuntarily. Nine of the voluntary departures involved a new job primarily in Mistissini so as to achieve a better work-life balance, and the tenth person left to return to school.

According to the interviews, the Cree employees appreciated career opportunities available to them, ongoing training, the induction program and the integration systems and work schedules. One employee indicated that compensation was an area Stornoway could improve upon.

Easing integration and the management of different cultures

It is a well-known fact that the first step in integrating and managing cultural differences is to deconstruct prejudices and stereotypes. In addition, since managers are the standard bearers of a company’s mission and values, it’s clear we need to train our supervisors in the art of integrating and managing cultural differences within their groups.

Stornoway therefore ensures:

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that teams include representatives from minority groups;

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the health of its employment systems, including policies, decision processes and practices that affect all aspects of people’s careers in the company;

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the development of a culture that values integration, covering all types of behaviours including communication, informal social relationships, the ways in which decisions are made, standards, etc.

Stornoway has a positive influence over its managers by:

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setting up integration logistics;

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strengthening policies and procedures created in keeping with integration values;

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using training, which is key to integration;

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applying management and supervision systems that focus on individual behaviours;

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focussing on group strengths, because they influence individual behaviours at every level of the organization;

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strengthening managers’ solid commitment toward our values because that’s what shapes corporate culture;

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prioritizing blended teams so as to create ties among the various cultural groups;

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conducting exit interviews to identify ways of improving employee integration, development and retention.

Induction program

The induction program is key to mobilizing new employees and helping them develop a sense of belonging within Stornoway. A mechanism has been put in place to transmit all necessary information to new hires.

In this regard, one of the tasks assigned to the community relations section in the human resources department is to participate with the Renard mine development team in the integration process for all employees.

The community relations team is actively involved in recruiting, it works to enhance an understanding among the Cree of how the mine operates, it is involved with tallymen, and it keeps personnel informed about the Mecheshoo Agreement.

A structured induction and integration process impacts length of employment, employees’ dedication to Stornoway, as well as their mobilization and adherence to the company’s values.

We have in fact observed that the more structured the induction process the faster the new employee whether Cree or non-Cree will reach a satisfactory level of performance.

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The community relations team from the human resources department is also involved in exit interviews with Cree employees with a view to obtaining information that will help the company improve human resources management and intercultural relationships.

Multi-disciplinary integration

The hierarchy of skills (soft skills, hard skills, and transferrable skills) help ensure operational effectiveness and sustainability.

Stornoway and the Training and Employment Committee are proud to partner with organizations that train young people to take on tomorrow’s trades in the region. Supporting education is a cherished value for the Stornoway team.

Starting from the principle that on-the-job training is an investment that benefits both the employee and the company, Stornoway has established and maintained a learning-and development-oriented culture.

As of March 2015, Stornoway has gradually built an ongoing training system offering a continuous measurement of improvements. The system promotes efficient, continuous and sustainable growth of the workforce. The training team is proud of the results achieved to date. To obtain an accurate picture of employee needs, exit interviews were initiated when production started and the process was reviewed in 2019 in an effort to make the interviews more flexible and better adapted to the context.

It was also determined that the success of efforts to integrate our Cree personnel is enhanced when employees serve as instructors. Based on past experience and comments made during exit interviews, the community relations team and trainers in partnership with managers of the major departments at the mine have worked on training Cree employees for instructor positions.

Stornoway has put in place a management culture that promotes complementarity by taking different profiles and cultures into consideration. It has also sought to ensure sound advancement for all employees through a development program (mine department) that enables employees to choose the training they’d like on the basis of their profile, their past experience, their career aspirations, available opportunities and their personal objectives within Stornoway. Exit interviews have in fact shown that employees want the opportunity to learn new functions and achieve their career goals within Stornoway.

Indeed it would appear that employees all have common goals: keep on growing and sharing what they’ve learned, be part of the decision process and be kept in the loop. It should be noted that since the launch of production in 2017, we have observed that promoting Cree employees to key positions has eased the integration of many others into underground training programs and to joining the team of miners! This strategy has resulted in free-flowing communication between Cree and non-Cree employees, promoted retention through the twinning of cultures and generations, and has helped

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employees cope better with the new aspects of their work environment, optimize their performance, promote synergy among coworkers, and achieve or exceed expected productivity levels.

Overall in 2019, our Cree personnel earned 17 promotions and transfers, and two of them assumed responsibility for being underground instructors.

Stornoway instructors assume an essential responsibility. They enable Cree employees in training to learn better because the Cree instructor explains aspects of the trade in greater depth in the Cree language. They make it easier too for non-Cree employees in training to fit in with the blended team more easily.

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Answers to the second series of questions and comments from the MELCC dated December 16, 2019

Renard Mine Mine

Answers to the second series of questions and comments from the MELCC dated December 16, 2019

Ref. No.: 61470.050-100 (Version 0)

Additional Document — Environmental and Social Monitoring Program (Ref. 3214-14-041)

August 2020

Renard Mine

Answers to the second series of questions and comments from the MELCC dated December 16, 2019

Ref. No.: 61470.050-100 (Version 0)

Additional Document — Environmental and Social Monitoring Program (Ref. 3214-14-041)

August 2020

PROJECT TEAM

TABLE OF CONTENTS

LIST OF TABLES

LIST OF MAPS

1 BACKGROUND

2 ANSWERS TO QUESTIONS AND COMMENTS FROM THE MELCC

2.1 Physical Environment

2.1.1 Surface water and sediment quality

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2.1.2 Mine effluent (EDO) and hydrology

2.1.3 Groundwater

2.2 Biological Environment 2.2.1 Terrestrial and avian fauna

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2.3 Accumulation Area Monitoring

2.4 Social Environment

2.4.1 Land use by trapline M11 users

2.4.2 Integration of Cree workers

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