Nui Phao Mining Joint Venture Company Nui Phao Mining ......Nui Phao Mining Project ESIA/ESAP...

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Prepared for: Nui Phao Mining Joint Venture Company c/o Tiberon Minerals Ltd. 100 Yonge Street, Suite 1101 Toronto, Ontario, Canada M5C 2W1 Telephone: (416) 214-1877 Facsimile: (416) 214-0091 Prepared by: Knight Piésold and Co. 1050 Seventeenth Street, Suite 450 Denver, Colorado, USA 80265-2011 Telephone: (303) 629-8788 Facsimile: (303) 629-8789 June 2006 Project No. 702/00009.06 Nui Phao Mining Joint Venture Company Nui Phao Mining Project ESIA/ESAP Volume I – Executive Summary

Transcript of Nui Phao Mining Joint Venture Company Nui Phao Mining ......Nui Phao Mining Project ESIA/ESAP...

Page 1: Nui Phao Mining Joint Venture Company Nui Phao Mining ......Nui Phao Mining Project ESIA/ESAP Executive Summary Volume I June 2006 Prepared for Nui Phao Mining Joint Venture Company

Prepared for:

Nui Phao Mining Joint Venture Companyc/o Tiberon Minerals Ltd.100 Yonge Street, Suite 1101Toronto, Ontario, Canada M5C 2W1Telephone: (416) 214-1877Facsimile: (416) 214-0091

Prepared by:

Knight Piésold and Co.1050 Seventeenth Street, Suite 450Denver, Colorado, USA 80265-2011Telephone: (303) 629-8788Facsimile: (303) 629-8789

June 2006Project No. 702/00009.06

Nui Phao Mining Joint Venture CompanyNui Phao Mining Project ESIA/ESAP

Volume I – Executive Summary

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ENVIRONMENT POLICY

Our Commitment

Nuiphaovica recognises environmental management and the protection of the environment as equal in priority to all activities including exploration, development, operations and decommissioning.

In keeping with the principles of our Vision Statement and Company Values, Nuiphaovica will ensure responsible stewardship of the natural environment at all project sites, including the minimisation of pollution and adverse impacts in areas of operation.

Our Approach

To meet the above commitment, Nuiphaovica will:

Establish a sound environmental management policy framework which meets international best practice standards and conventions and all applicable aspects of the Vietnamese Law.

Identify the significant environmental aspects and impacts associated with our activities.

Undertake constructive consultation with communities in the area of influence of our operations with disclosure of existing environmental conditions and the environmental impacts of our activities.

Identify through risk assessment, the potential for accidents and emergency situations and develop, maintain and test emergency response plans to prevent and mitigate the possible associated environmental impacts.

Ensure effective monitoring and assessment of environmental conditions within our operations and surrounding communities

Handle and dispose of our wastes in such a manner as to avoid, reduce or control pollution.

Rehabilitate the site in a planned and timely manner, with rehabilitation works occurring during operations wherever feasible.

Communicate this policy to all employees, relevant contractors, visitors and suppliers to ensure that they understand and comply with their environmental responsibilities in a manner appropriate to their role in the organisation.

Conduct employee training at all levels of the organisation so that they can carry out their duties and responsibilities in accordance with requirements.

Conduct regular audits to assess and ensure internal compliance with this policy and provide adequate and appropriate resources to implement requirements.

Set objectives and targets to continually improve our environment management and performance.

Assign responsibility for delivery and review of this Environment Policy to all management and supervisory levels in the organization

Nigel Tamlyn, General Director, Nuiphaovica: Date: 1st Mar 2006

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OCCUPATIONAL HEALTH & SAFETY POLICY

Our Commitment

Nuiphaovica believes the development of a strong organisational safety culture is paramount in our business success.

In keeping with the principles of our Vision Statement and Company Values, Nuiphaovica is committed to safeguarding employees, contractors, visitors and community members against any adverse health and safety risks from company activities during exploration, construction, operations and decommissioning.

Our Approach

To meet the above commitment, Nuiphaovica will:

Establish a sound occupational health and safety policy framework which meets international best practice standards and conventions and all applicable aspects of the Vietnamese Law.

Identify the health and safety hazards and risks associated with our activities.

Undertake constructive consultation with communities within the area of influence of our operations with disclosure of the existing conditions and potential adverse effects as determined by the occupational health and safety risk assessment.

Ensure effective monitoring and assessment of health and safety conditions within our operations and surrounding communities, to ensure adherence to the principles in our Vision Statement.

Communicate this policy to all employees, contractors, visitors and suppliers to ensure that they comply with their health and safety responsibilities in a manner appropriate to their role in the organisation.

Identify, through risk assessment, the potential for incidents and emergency situations and develop, implement and test emergency response plans to prevent and mitigate occupational injuries.

Monitor identified occupational hygiene risks and implement programs to reduce the risks to employees.

Provide effective training for employees, contractors, visitors and suppliers to ensure that they understand and comply with their health, safety and emergency response responsibilities in a manner appropriate to their role in the organisation.

Encourage participation of all employees in the development and implementation of health and safety programs and procedures to continually improve our health and safety management and performance.

Set objectives and targets to continually improve our health and safety management performance.

Conduct regular audits to assess and ensure internal compliance with this policy and provide adequate and appropriate resources to implement requirements.

Nigel Tamlyn, General Director, Nuiphaovica: Date: 1st Mar 2006

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COMMUNITY RELATIONS & DEVELOPMENT POLICY

Our Commitment

Nuiphaovica recognises that excellent relations with our community are a fundamental element in the successful operation of the Company and the long-term prosperity of the Vietnamese people, particularly those from the immediate project area in Dai Tu, Thai Nguyen Province.

Through our Company values of honesty, fairness and genuine goodwill in all interactions with all stakeholders, Nuiphaovica seeks to continue the development of a mutually beneficial partnership with the community to maximise the sustainable benefits for all stakeholders.

We are committed to our principle of making a positive contribution to our community.

Our Approach

In meeting the above commitment, Nuiphaovica will:

Establish a sound community relations policy framework which meets international best practice standards and conventions and all applicable aspects of the Vietnamese Law.

Respect the culture, values and traditions of the communities in which we operate.

Openly and transparently share information regarding the impacts of mining or operational activities in accordance with international Community Consultation and Disclosure standards.

Actively consider community views to understand expectations and concerns, applying mitigation measures wherever required.

Give preference to members of the local community in selection for employment, training and technology transfer opportunities.

Wherever possible, utilise labour, services and materials from the immediate project area to encourage local business development and maximise the economic flow-on benefits from the Nuiphaovica operation.

Establish community programmes to support additional opportunities for sustainable community development throughout the life of the mine.

Maintain social and community monitoring programmes and provide accurate, clear and transparent project information to community members and government authorities.

Provide training and resources to ensure that all employees, contractors and suppliers engaged with the Company are aware of and comply with our Community Relations policies and commitments to the community.

Set objectives and targets to continually improve our community relations management and performance.

Nigel Tamlyn, General Director, Nuiphaovica: Date: 1st Mar 2006

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HUMAN RESOURCES POLICY

Our Commitment

Nuiphaovica holds its employees in the highest esteem and understands that their goodwill, loyalty and dedicated work effort is the key to the success of the Company.

The Company is committed to the creation of a work environment which fosters the full and satisfying expression of employees’ personal and professional goals within a mutually rewarding employment relationship.

Our Approach

To meet the above commitment, Nuiphaovica will:

Establish a sound human resources policy framework which meets international best practice standards and conventions and all applicable aspects of the Vietnamese Labour Law.

Treat all employees fairly, equitably and without discrimination in all matters of employment and training.

Adopt recruitment procedures which facilitate the employment of people from the immediate project area and the realisation of Nuiphaovica commitments to the community.

Ensure fair entitlements, benefits and remuneration, of a level which is in keeping with Vietnamese industry norms and standards and enables Nuiphaovica to attract and retain employees.

Ensure effective employee administration and records management systems which maintain individual privacy and dignity at all times.

Implement mechanisms for the fair and consistent monitoring, measurement and management of employee performance.

Provide avenues for the timely, confidential and appropriate resolution of employee grievances and complaints.

Foster a culture of teamwork and cooperation within Nuiphaovica and the development of strong relationships between employees across all departments.

Provide appropriate training to ensure each employee has the required skills, knowledge and behaviours to perform their allocated duties in a safe and competent manner and support employee career aspirations through the provision of employee development opportunities.

Set objectives and targets to continually improve our human resources management and performance.

Nigel Tamlyn, General Director, Nuiphaovica: Date: 1st Mar 2006

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Nui Phao Mining Joint Venture Company Limited

Nui Phao Mining Project ESIA/ESAP Executive Summary

Volume I

June 2006

Prepared for Nui Phao Mining Joint Venture Company

Limited c/o Tiberon Minerals Ltd.

100 Yonge Street, Suite 1101 Toronto, Ontario, Canada M5C 2W1

Telephone: (416) 214-1877 Facsimile: (416) 214-0091

Prepared by Knight Piésold and Co.

1050 Seventeenth Street, Suite 450 Denver, Colorado, USA 80265-2011

Telephone: (303) 629-8788 Facsímile: (303) 629-8789

Project 70200009.06

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Nui Phao Mining Joint Venture Company Limited

Nui Phao Mining Project ESIA/ESAP Executive Summary

Volume I

Table of Contents

List of Figures ................................................................................................................................ iv

List of Abbreviations and Acronyms...............................................................................................v

1.0 Introduction................................................................................................................................1

2.0 Project Setting and Significant Outcomes .................................................................................6

3.0 Environmental and Social Impact Assessment ........................................................................10

3.1 Regulatory Framework ................................................................................................10

3.1.1 Corporate Commitment ................................................................................11

3.1.2 Equator Principles and World Best Practise .................................................12

3.1.3 Vietnamese Regulatory Requirements..........................................................12

3.1.4 Environmental Compliance Targets .............................................................13

3.1.5 Environmental Impact Assessment June 2006 Update Report .....................13

3.2 Environmental Baseline ...............................................................................................13

3.2.1 Climate, Air Quality, and Noise ...................................................................14

3.2.2 Topography and Visual Resources ...............................................................14

3.2.3 Geology and Seismicity ................................................................................15

3.2.4 Soils...............................................................................................................17

3.2.5 Surface Water................................................................................................17

3.2.5.1 Hydrology ......................................................................................18

3.2.5.2 Surface Water Quality....................................................................18

3.2.6 Groundwater .................................................................................................20

3.2.6.1 Hydrogeology ................................................................................21

3.2.6.2 Groundwater Quality .....................................................................21

3.2.7 Flora ..............................................................................................................23

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Table of Contents (Continued)

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3.2.8 Fauna.............................................................................................................24

3.2.9 Aquatic Resources ........................................................................................25

3.3 Social and Economic Baseline.....................................................................................26

3.3.1 National and Provincial Context...................................................................27

3.3.2 Social and Political Organisation..................................................................28

3.3.3 Population .....................................................................................................29

3.3.4 Human Health ...............................................................................................30

3.3.5 Livelihood Activities and Employment Opportunities .................................32

3.3.6 Land and Natural Resource Use ...................................................................34

3.3.7 Infrastructure and Services ...........................................................................35

3.3.8 Vulnerable and Disadvantaged Groups ........................................................36

3.3.9 Public Attitudes and Perception....................................................................38

3.4 Project Description.......................................................................................................38

3.4.1 Land Disturbance ..........................................................................................38

3.4.2 Construction..................................................................................................39

3.4.3 Manpower Requirements ..............................................................................39

3.4.4 Infrastructure.................................................................................................40

3.4.5 Topsoil Salvage.............................................................................................41

3.4.6 Mining Operations ........................................................................................42

3.4.7 Mineral Processing........................................................................................43

3.4.8 Tailings Storage Facility ...............................................................................43

3.4.9 Freshwater Reservoir ....................................................................................45

3.4.10 Auxiliary Facilities......................................................................................45

3.4.11 Waste Management.....................................................................................45

3.4.12 Water Management.....................................................................................46

3.4.13 Closure and Reclamation ............................................................................46

3.5 Impacts and Mitigation Measures................................................................................46

3.6 Alternatives ..................................................................................................................49

3.6.1 No Action Alternative...................................................................................50

3.6.2 Proposed Action Alternative.........................................................................50

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Table of Contents (Continued)

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3.6.3 Project Alternatives.......................................................................................50

3.6.3.1 Mine ...............................................................................................50

3.6.3.2 Mineral Processing.........................................................................50

3.6.3.3 Tailings Storage .............................................................................51

3.6.3.4 Water Supply .................................................................................51

3.6.3.5 Transportation Routes....................................................................51

3.7 Cumulative Impacts .....................................................................................................52

4.0 Environmental and Social Action Plan ....................................................................................53

4.1 Management System Structure ....................................................................................53

4.2 Corporate Commitment and Management Responsibilities ........................................54

4.3 Training........................................................................................................................55

4.4 Impact-Mitigating Actions and Monitoring Plans .......................................................55

4.4.1 Nearby Neighbours .......................................................................................57

4.4.2 Downstream Water Supplies.........................................................................59

4.4.3 Worker Health and Safety.............................................................................61

4.4.4 Land Use Changes ........................................................................................62

4.4.5 Resettled Households....................................................................................63

4.4.6 Local Communities.......................................................................................65

4.5 Sampling, Interpretation, and Reporting......................................................................67

4.6 Transparency................................................................................................................68

4.7 Complaints Mechanisms..............................................................................................69

4.8 Cost and Implementation .............................................................................................69

5.0 Discipline-Specific Action Plans .............................................................................................75

5.1 Public Consultation and Disclosure Plan.....................................................................75

5.2 Resettlement Action Plan.............................................................................................75

5.3 Occupational Health and Safety Plan ..........................................................................76

5.4 Site Construction Plan..................................................................................................76

5.5 Waste Management Plan..............................................................................................76

5.6 Emergency Response Plan...........................................................................................76

5.7 Conceptual Mine Closure Plan ....................................................................................77

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Table of Contents (Continued)

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6.0 Conclusion ...............................................................................................................................78

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Figures

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List of Figures

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Figure Title

3.1 Distribution of Arsenic in the Soils 3.2 Baseline Surface Water Sample Locations

3.3 Baseline Groundwater Sample Locations

3.4 Vegetation Classification

3.5 Commune Boundaries in Project Area

3.6 Facility Layout Final

3.7 Schematic of the Mineral Process

3.8 Schematic of the Water Balance

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List of Abbreviations and Acronyms ARD acid rock drainage CDP Community Development Plan CMCP Conceptual Mine Closure Plan db decibel EHSC Environment, Health, Safety and Community EPCM Engineering, Procurement, and Construction Management ERP Emergency Response Plan ESAP Environmental and Social Action Plan ESIA Environmental and Social Impact Assessment GDP Gross Domestic Product ha hectare(s) IUCN International Union for the Conservation of Nature km kilometre(s) km2 square kilometre(s) kV kilo-volt(s) m metre(s) m3/hr cubic metre(s) per hour mg/kg milligram(s) per kilogram(s) mm millimetre(s) Mt million tonnes MONRE Ministry of Natural Resources and Environment NGO Non-Government Organisation Non-PAG non-acid-generating Nuiphaovica Nui Phao Mining Joint Venture Company Limited

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List of Abbreviations and Acronyms (Continued) OHSP Occupational Health and Safety Plan OTC oxide tailings cell PAG potentially acid-generating PAP Project Affected Persons PCDP Public Consultation and Disclosure Plan PMP probable maximum precipitation PPE personal protective equipment ppm parts per million RAP Resettlement Action Plan SCP Site Construction Plan SOP Standard Operating Procedure STC sulphide tailings cell TDS total dissolved solids the Project Nui Phao Mining Project TSF tailings storage facility US$ United States Dollar WBG World Bank Group WHO World Health Organisation WMP Waste Management Plan µg/m3 microgram(s) per cubic metre(s)

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Courtesy Tiberon Minerals Ltd.

Nui Phao Mining Joint Venture Company Limited

Nui Phao Mining Project ESIA/ESAP Executive Summary

Volume I

1.0 Introduction The Nui Phao Mining Project (the Project) is a proposed polymetallic open pit mining and mineral processing operation located in northern Vietnam. The Project is located within the Dai Tu District of Thai Nguyen Province. The site is approximately 80 km northwest of the capital Hanoi and about 150 km south of Vietnam’s northern border with China. The Project will be owned and operated by Nui Phao Mining Joint Venture Company Limited (Nuiphaovica), a joint venture among Tiberon Minerals Limited, Thai Nguyen Minerals Company, and Thai Nguyen Import-Export Development Company. Tiberon has majority ownership and is a publicly- traded Canadian company that is listed on the Toronto Stock Exchange. The Project is a conventional open pit mining and bulk flotation mineral processing circuit. Major Project components include:

• An open pit mine;

• Waste rock disposal facilities;

• Modern mine plant and facilities, including a crushing plant, grinding, thickening, flotation, and gravity recovery;

• A tailings storage facility (TSF) with water management ponds; and

• Ancillary facilities, including buffer zones, relocation sites, haul roads, accommodation facilities, and mine services.

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General Site Layout

The primary commodities to be produced at Nui Phao are tungsten and fluorspar. Both tungsten and fluorspar have many common uses in today’s society. Much of the world’s tungsten production is mixed with carbon to make a very strong, very resistant material called tungsten carbide, which is used to make wear-resistant cutting tools and drill bits. With its very high melting point and low vapour pressure, tungsten is currently the only material used to make the filaments in light bulbs. It is also used as steel alloy to improve strength and is alloyed with certain metals to make “super alloys” of extraordinary strength and heat resistance that are used in turbine engines for jet aircraft and energy generation. Fluorspar is used in the production of hydrofluoric acid, which is used in the electroplating, stainless steel, refrigerant, and plastics industries. Secondary metals produced including bismuth (used as an alloy in certain pharmaceuticals and chemicals and in ceramics, paints, and catalysts), copper (used in electric cables and wires, chemical and pharmaceutical applications, and alloys including bronze and brass), and gold (used in the dental, medical, and electronics industries as well as for making jewellery and coins) will be produced.

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Nuiphaovica plans to commence development activities in the second half of 2007 in anticipation of ramping up to full-scale mining operations in the first half of 2008. As such, there has been a significant amount of planning and engineering accomplished to date. Activities included in that planning were the commencement of environmental and social baseline studies by Knight Piésold Ltd. in 2001 and the development of a preliminary environmental impact assessment in 2003. The Knight Piésold assessment established the basis for another environmental impact assessment document that was prepared by the Vietnam Centre for Industrial Environment, which was submitted to the Vietnamese government in 2004 and approved in February 2005. This approval allowed the issuance of the Mining License by the Ministry of Natural Resources and Environment in June 2005. The Mining License gives Nuiphaovica the right to mine the mineral resources at Nui Phao.

Project Schedule

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Nuiphaovica retained Aker Kvaerner in 2004 to develop a feasibility study to define the economic viability of the Project based on the ongoing planning, engineering, and environmental efforts. Inherent to the feasibility study process are the inevitable changes, updates, and improvements to the engineering designs and plans. The Final Feasibility Study was completed in July 2005 and found that the Nui Phao Mining Project can be developed, operated, closed, and reclaimed at a profit and that the Project financial model is sufficiently robust to withstand reasonable sensitivities to commodity price fluctuations. With favourable feasibility study results and a valid Mining License, Nuiphaovica sought financing for the Project in the international lending community and is seeking investment risk guarantees from the Multilateral Investment Guarantee Agency (MIGA), a member of the World Bank Group. The engineering and planning modifications that have occurred as the Project evolved and the participation by new Project lenders and insurers resulted in the need to update the environmental and social impact assessment that was approved by the Vietnamese government. The Environmental and Social Impact Assessment (ESIA) and Environmental and Social Action Plan (ESAP) were developed to demonstrate Nuiphaovica’s commitment to presenting an integrated assessment of environmental and social impacts, risks, and opportunities for the Nui Phao Mining Project; to engaging the affected communities through effective public consultation and disclosure; and to managing its environmental and social performance throughout the life of the Project. It has been prepared to address World Bank and MIGA policies in conformance with the Extractive Industries Review process. These commitments are presented in three volumes as follows:

• Executive Summary (Volume I) – This Executive Summary presents a concise non-technical overview of the Project and its effect on the environmental and social conditions and presents the significant findings, recommendations, and actions contained in the ESIA (Volume II) and ESAP (Volume III);

• Environmental and Social Impact Assessment (Volume II) – The ESIA identifies the regulatory framework under which the Project will operate and describes Nuiphaovica’s development and operating plans. It also documents the current site conditions, identifies engineering and environmental systems that will be used to control environmental impacts, and identifies the Project effects and residual impacts on environmental and social resources. It addresses the cumulative effects of Project development and evaluates plausible alternatives; and

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• Environmental and Social Action Plan (Volume III) – The ESAP defines the management, mitigation, monitoring, and institutional measures that are needed to mitigate, offset, or reduce the environmental and social impacts of the Project to acceptable levels. It specifically establishes the actions that must be undertaken and identifies who is responsible to undertake them to ensure adequate mitigation of impacts. The ESAP also includes discipline-specific plans addressing public consultation and disclosure, involuntary resettlement, site construction, waste management, emergency response, and mine closure.

These documents present what Nuiphaovica believes is the appropriate level of environmental and social responsibility for the Nui Phao Mining Project. The Volume III Environmental and Social Action Plan and discipline-specific plans should be considered living documents that will be updated from time to time to reflect the current situation and knowledge base for the Project. Effective implementation of the plans and actions defined in the ESAP will ensure that the environmental and social standards achieved are in line with generally accepted international mining best practise.

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2.0 Project Setting and Significant Outcomes The Project is set against a backdrop of considerable historic and ongoing mining activities by others, which have already resulted in a variety of environmental and social impacts. It is also located in a region where elevated concentrations of arsenic and other heavy metals are naturally occurring in local soils. This high arsenic concentration is associated with the natural surface soils and is generally not linked with the geochemistry of ores produced by mining activities accomplished either by others or to be mined by Nuiphaovica. As such, the significant presence of elevated arsenic in naturally occurring soils in the Project region represents an important baseline condition and human health consideration that must be adequately integrated into all aspects of the Project design and implementation. Mining is an important industry in Thai Nguyen Province and alluvial tin mining is by far the most significant mining activity and primary mineral commodity in the local marketplace. Other resources include coal, iron ore, aggregate (for cement), gold, and clay (for brick making); but they are not as significant to the local economy. Established mining companies provide a local market demand for artisanally produced tin ore, encouraging illegal mineral exploitation by offering a variety of incentives to small miners and shaker table owners to produce tin feed to their mineral processing operations. Water quality in area surface streams has been locally impacted by artisanal mining activities. In some areas, these impacts are significant. Baseline investigations identified certain areas where land located downstream from active mining and/or shaker table operations that had been irrigated with impacted stream water was rendered completely sterile. These lands were reportedly used for agricultural production prior to the onset of the upstream mining activities but thereafter could only be used for brick making. Naturally elevated concentrations of arsenic and other heavy metals in the soils of northern Vietnam is a well known regional phenomena and is perhaps the most important background condition affecting the Nui Phao Mining Project. Baseline studies have documented elevated concentrations of arsenic, lead, and boron to be naturally present at levels that could pose health risks to local residents. Because of the concern for natural soil contamination and the human health risks it poses, Nuiphaovica expended considerable effort to profile the nature and extent of this naturally occurring contamination in the Project area. Elevated concentrations of arsenic, which is the most significant element of concern, appear to follow the topographic features that

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generally trend north to south and predominantly occur in the eastern portion of the Project area and proximate areas outside the Project disturbance footprint. Many of these areas are now used by local residents for the production of tea at the higher elevations and rice in the lower valleys. Food production from these naturally contaminated soils is an important consideration for the Project. While Nuiphaovica holds no authority or responsibility with regard to the food that people grow and eat from the land outside the Project footprint or from where they may acquire their food in general, the Company will implement measures directed at controlling the quality of food served to Project staff onsite. Nuiphaovica will also implement a soil cleanup programme within the Project footprint to reduce arsenic exposure to workers to acceptable risk exposure levels. Also, Nuiphaovica will provide its assistance to the local Vietnamese authorities in educating local residents on how to reduce their risk of arsenic exposure to the maximum practical extent as part of its community development initiatives. The development of the Nui Phao Mining Project will inevitably result in environmental and social impacts (Section 3.0), but without the Project, local conditions would be expected to remain largely as described above. With Project development and effective implementation of the environmental management systems (Section 4.0), residual environmental and social impacts can be reduced to acceptable levels. The key impacts and mitigation actions that are required to reduce environmental, health, safety, and social impacts to acceptable levels follow. They are grouped by significant major topic in order to focus implementation efforts on specific actions.

• Nearby Neighbours: Nuiphaovica, in close coordination with the Vietnamese government, has limited the number of households that are required to relocate as a result of Project implementation. As a result, there are certain residents who live in close proximity to certain Project components. It will be important to effectively manage and control impacts to these nearby neighbours by implementing specific safety programmes and controlling noise, dust, vibration, and night-time light;

• Downstream Water Supplies: In establishing an adequate water supply for the mine to operate, it will be necessary to interrupt flows in the Doi Ba valley to store the water in the fresh water reservoir during the initial start-up phase of the Project. Once operating, the Project is located in a region where annual precipitation significantly exceeds annual evaporation and so after that initial start-up, water will be discharged as part of normal operations. However, the discharge water will have been exposed

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to the mining and processing operations. It will therefore be important to limit impacts to downstream water supplies by controlling surface water base flow and quality impacts as well as the quality and quantity of available groundwater;

• Worker Health and Safety: Working around heavy equipment, machinery, and industrial chemicals poses certain safety risks to Project employees and visitors that must be effectively managed. Nuiphaovica will reduce impacts to Project employees and visitors by promoting worker health and safety and maintaining a clean and safe work environment, limiting occupational exposure to risks, and adequately managing wastes and emergency situations;

• Land Use Changes: Mining inherently requires that the land containing the mineral resource and certain areas proximate to the mineralized zone be utilized to support the mining operations. These land use changes to industrial use are short term and the impacts resulting from land use changes are mitigated by implementing an effective closure and reclamation programme that re-establishes the land to an appropriate post-mining land use;

• Resettled Households: Approximately 884 households will be affected by the land use changes associated with Project development. Involuntary resettlement and the economic displacement associated with land loss must be carefully managed in order to control adverse impacts to resettled households by implementing livelihood restoration programmes, restoring food security, and, to the extent practical and secure, making alternate agricultural land available; and

• Local Communities: The presence of a major mining project in local communities will increase the demand on health care, water supplies, waste disposal systems, power supplies, law enforcement and a variety of other issues. An influx of job seekers into local communities is also common. Nuiphaovica will work with the local communities to limit and/or offset impacts to local communities by promoting economic diversification, controlling job-seeker influx and demands on infrastructure, and limiting physical hazards and the effects of social evils to the extent possible.

These potential impacts and mitigation actions are further described in Section 3.0 and 4.0 of this Executive Summary, and in detail in the ESIA and ESAP (Volumes II and III). Project implementation will bring significant local, regional and national benefits to Vietnam as a whole and to the local residents who will be directly and indirectly affected by the Project. It will bring international recognition to Vietnam as a world-class producer of tungsten, fluorspar and bismuth minerals. The capital investment and operating financial base will stimulate the local, regional and national economy in terms of taxes and royalties paid on commodities

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produced, foreign contractor tax withholdings, value added taxes, and monies paid for goods and services that are purchased from within the country. The Project is projected to employ at least 1,500 workers during the construction phase and over 450 over its 16-year production life. The majority of these workers will be Vietnamese nationals who will receive wages that significantly exceed the typical compensation packages for the area. Mine employees will consequently contribute more in taxes and other payroll-related withholdings because of the higher-paying mining jobs, and will have more disposable income and purchasing power which in turn will stimulate secondary and tertiary economies for other goods and services in the region. In addition to the favourable economic impact, Nuiphaovica will also make a significant contribution to the capacity of the local workforce and community residents. Education and training programs that will teach marketable skills and trades as well as promote a culture of safe and healthy work habits and lifestyles will be a benefit to the mine operations and also to the local communities both during Project operations and long after the mine is closed. Initiatives such as those that teach local residents how to limit their personal exposure to arsenic or how they can limit the impacts associated with artisanal mining can go a long way toward reducing the environmental and human health effects of certain everyday activities. Couple that with the Project plans to permanently remediate arsenic-contaminated soils and historic mine disturbances within the Project area boundary and the effective implementation of economic restoration and community development initiatives, the net result will be a world class mining Project that not only provides sustainable benefits to stakeholders but also makes a positive contribution to the development and prosperity of the Vietnamese people.

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3.0 Environmental and Social Impact Assessment The ESIA contains the regulatory framework under which the Project will be carried out and a description of the Project in its geographic, ecological, social, and temporal context. It includes baseline data describing the relevant physical, biological, social, political and historical conditions and the environmental and social effects associated with Project implementation. Mitigation measures needed to control those effects to acceptable levels are presented as well as an assessment of the reasonably foreseeable cumulative impacts of the Project. It also analyses plausible alternatives, including the “no Project” alternative. The ESIA is focused primarily on the activities within the immediate Project area boundary. Several activities that support the Nui Phao Mining Project will be accomplished offsite which are peripherally addressed in the ESIA/ESAP as follows:

• Ports – The port facilities are owned and operated by others. Nuiphaovica will contractually oblige port facility owners/operators to conduct their operations in a manner that respects its environmental, health, safety, and community commitments and will conduct periodic audits to assess performance with contract obligations;

• Access Corridors – The roads and rail lines that provide public and industrial access between the Nui Phao Mining Project and its supply points are owned and operated by others. Nuiphaovica, through compliance with its Mining License, will take reasonable safety and training precautions and will coordinate with government authorities and other relevant parties as appropriate regarding impacts and mitigation that may be needed for the local transportation arterials; and

• Relocation Sites – Six candidate sites have been identified thus far for the resettlement of individuals and households that are displaced by Project development. Each of these sites will be the subject of a separate environmental impact assessment of their respective location. One such assessment has already been completed for Nam Song Cong, a site that resettled individuals have shown a dominant preference for to date and which is sufficiently large as to accommodate all of the resettled households if they choose to move there. Impact assessments for other candidate sites are also being undertaken.

3.1 Regulatory Framework The policy, legal, and administrative framework for the Project incorporates internal corporate policies and commitments, a commitment to world best practises including Equator Principles and World Bank Group (WBG) policies and performance standards, Vietnamese laws and

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regulatory requirements, and both Vietnamese and international environmental standards for compliance. 3.1.1 Corporate Commitment Nuiphaovica has established a corporate vision statement that commits to establishing the Project as a showcase model for mining and mineral processing, operating in a manner which maximizes the sustainable benefits for all stakeholders and makes a positive contribution to the development and prosperity of the Vietnamese people through employment and training opportunities. The Company seeks to win global high regard for social and environmental compliance as well as technical, safety, and human resources excellence. Paramount to achieving this vision is the consistent application of Nuiphaovica Company Values in all business activities, which includes:

• Complying with all applicable laws of Vietnam and the highest international ethical business standards;

• Honesty, fairness, and genuine goodwill in all interactions with our host community including District, Provincial, and other Vietnamese stakeholder groups;

• Utilising the most appropriate technologies for the timely and satisfactory delivery of production commitments to investors and customers;

• Responsible stewardship of the natural environment in all project sites and the minimisation of adverse impacts in areas of operations;

• Providing a healthy and safe environment for employees, contractors, and visitors at all project sites; and

• Creating a corporate culture that supports the development of mutually rewarding employment relationships and the achievement of employee professional and personal goals.

Nuiphaovica has established some fundamental principles for managing its regulatory, consultation, resettlement, environmental management, health and safety, labour, gender equity, corporate responsibility, capacity building, and community development objectives. In implementing these objectives, Nuiphaovica has established specific policies that clearly define its overall corporate commitments:

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• Environment Policy – Commits to responsible stewardship of the natural environment in all areas of Project operations and the minimisation of pollution and adverse environmental impacts;

• Occupational Health and Safety Policy – Commits to safeguarding employees, contractors, visitors, and community members against adverse health and safety risks associated with all aspects and phases of Project operations;

• External Relations and Development Policy – Commits to developing a beneficial partnership with the local community that maximises the sustainable benefits of the Project for all stakeholders; and

• Human Resources Policy – Commits to creating a work environment that is responsive to employees’ personal and professional goals, offering fair and equitable employment opportunities and preferential recruitment for qualifying local residents.

These policies are presented in the opening pages of this document and combine to establish the goals against which Nuiphaovica will measure its environmental, social, health, and safety performance for the Project. 3.1.2 Equator Principles and World Best Practise Common elements of a world best practise framework for international mining projects generally draw from the international lending community. It also incorporates guidelines and standards from several other international organisations. The Equator Principles provide a set of guidelines for managing social and environmental issues related to the financing of development projects in the extractive industries sector. The Principles tier off the policies and performance standards of the World Bank Group, suggesting them as an appropriate framework for defining world best practise in the international mining community. 3.1.3 Vietnamese Regulatory Requirements There are a number of government authorities that regulate mining activities pursuant to several national laws in Vietnam. The Ministry of Natural Resources and Environment (MONRE) is the primary executive body overseeing mineral activities and environmental protection in the country. MONRE is responsible for basic geological survey, issuing mineral licences, evaluations and approvals, approving environmental impact assessment reports of foreign investment development projects, monitoring, enforcing compliance with the Law on Environmental Protection, and dispute resolution. Key laws affecting mining and the Nui Phao Mining Project include the following:

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• The Law on Environmental Protection (1994); • The Mineral Law (1996); • The Construction Law (2003); and • The Land Law (2003) including elements regarding involuntary resettlement.

There are a number of laws at the Provincial and District level as well. 3.1.4 Environmental Compliance Targets There are a variety of numeric compliance targets identified in the Vietnam laws and regulations, lending institution policies and guidelines, and generally accepted international mining practises. Specific compliance targets have been established for air particulate, noise levels, soils and sediments, surface water, groundwater, Project effluent discharges, and toxicological profiles for human health. These targets establish the basis against which Project environmental and human health compliance can be tracked. 3.1.5 Environmental Impact Assessment June 2006 Update Report The Environmental Impact Assessment report (the EIA) was approved by the Vietnamese government in February 2005. The EIA acknowledged the ongoing engineering design process and required that a number of other studies be carried out as the Project progressed. A number of these studies have been completed and/or updated and provide additional engineering, environmental and social information on which this ESIA/ESAP is based. The significant findings of this report are in some instances more detailed than those presented in the EIA due to the availability of additional studies and information, but are within the scope of outcomes predicted by the original EIA. Nuiphaovica has submitted this report to the appropriate government authorities for information purposes to keep them informed of Project developments. 3.2 Environmental Baseline The environmental baseline information profiles the existing environmental conditions at the site and characterises those conditions prior to any Project development activities. It is based on data collected during field reconnaissance carried out between 2001 and 2005 and the environmental conditions cited in previous baseline studies, assessment reports, and memorandums prepared by Knight Piésold and others.

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3.2.1 Climate, Air Quality, and Noise The Project is set in a monsoon tropical climate with two distinct seasons. The hot season is from about May to September with daily high temperatures averaging around 27oC to 29oC; the cold season is from November to March when daily high temperatures are usually about 16oC to 20oC. April and October are transitional months with variable weather. Humidity is high year-round and precipitation is significant, averaging about 2 metres (m) per year. More than 75 percent of the annual precipitation typically falls during the hot season, and annual evaporation is only about half the annual precipitation. The monsoon patterns also dominate wind direction with northerly winds occurring during the cold season followed by an abrupt shift to southerly during the hot season. There is nearly always a breeze (about 3 m/s and 6 m/s) in the area and calm periods are infrequent. Air quality varies geographically within the Project area depending on vegetation coverage and land use activities and also seasonally with the hot and cold seasons. As with most projects having a distinct wet/dry season, airborne particulate and dust fallout can be significant, particularly in the dry season. Background airborne dust in the Project area exceeds the Vietnamese regulatory requirements for total suspended particulate load even before any Project activities are considered. The component of that dust load that may affect human health, particles less than 10 microns in diameter, is also high but just below the generally accepted international norms. Arsenic and lead particulate are also present in the baseline airborne dust. The Project is located in a relatively densely populated area, so background noise is considerably higher than in typical rural settings. Daytime noise levels in the mine area were measured from 48 to 56 decibels (db), which is within regulatory limits, but nighttime noise levels consistently exceed the 50-db limits at all locations measured. 3.2.2 Topography and Visual Resources The area is characterised by hills and low mountains with valleys associated with local perennial and intermittent drainage systems. The regional landscape consists of flat to low undulating terrain that rarely exceeds 100 m to 200 m above sea level. There are a variety of vegetation types that dominate the landscape, including rice fields in floodplain areas and hills covered in tea that is intercropped with plantation timber. Historical mining activities are an important element of the baseline landscape. Cleared and disturbed land associated with mineral extraction is visible on hillsides, roadsides, and agricultural land and includes both open shallow excavation

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and shaft mining. These often appear as striking red-coloured disturbed areas on hillsides visible from the roads. Industrial structures and overhead power lines stand out against the visual backdrop, as do local residences associated with a relatively high population density. Rural houses are generally loosely clustered along roads and within small villages throughout the communes. Other structures within each of the Communes and wider District include government buildings, temples, graveyards, schools and health clinics, and small businesses (along roads). Most residential, municipal, and industrial structures are supplied with electricity, but electric lighting is used sparingly. Roads are generally unlit. As such, nighttime light is minimal in most areas. 3.2.3 Geology and Seismicity The Nui Phao Mining Project is located in the central part of the Tam Dao region where the Ordovician-Silurian Phu Ngu Formation is widely distributed. The Formation consists of micaceous shale interlayered with sandstone, siltstone, silicified marble, dolomitic marble, and lenses of siliceous rock. The biotite Nui Phao and the two mica Da Lien granites have intruded this formation. Sedimentary rocks that have been subsequently altered and intruded in two episodes by granitic rocks underlie the Nui Phao site. The altered sediments are known regionally as the Phu Ngu or calc-silicate meta-sediments and occupy an area through the centre of the Nui Phao mineralised zone and the northern part of the Project site. The first intrusive event produced Nui Phao granite, which is exposed in the south part of the site. The second intrusive event produced Da Lien granite, which is exposed in certain areas on the north side of the proposed open pit. The granitic materials typically exhibit relatively thin residual soil veneers over rock, and the calc-silicate materials exhibit thick variable sequences of fine-grained residual soil. The main ore deposit is an intrusive-related polymetallic skarn and greisen. The Nui Phao skarn and associated greisen-style mineralization are characterised by an assemblage of W-Au-Cu-Bi-F-Be-bearing minerals that occur within and proximal to the two-mica biotite and muscovite granite. The Da Lien mineralization is hosted in massive sulphide. When sulphide minerals are exposed to oxidising conditions and water, acidic solution is produced. This acidic solution can in turn mobilise other metals. About 570,000 m3 of historic mine waste rock has been identified in the

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Project vicinity. This waste rock was produced by artisanal mining activities not related to Nuiphaovica and currently occupies about 136,000 m2 of land. Much of this waste rock is contributing to the visible acid rock drainage (ARD) effects in the downstream areas of Ha Thuong and Phuc Linh Communes and is largely responsible for the low pH and high conductivity seen in local surface waters. Material characterisation was conducted on the rock types that will likely be extracted by the Nui Phao Mining Project. Those rock types include:

• Granite – Test results suggest that this rock type is not acid generating and does not leach metals in elevated concentrations. This rock type is suitable as a general site construction material;

• Saprolite – Test results suggest that this rock type is depleted of sulphide within 40 m of the ground surface and therefore non-acid generating. It also has low metal leachate. Below the 40 m depth, about 25 percent of the saprolite samples tested exhibited sufficient residual sulphide that it should be managed as a potentially acid-generating material;

• Calc-Silicate – Static testing indicated that about 25 percent of the samples have the potential to generate acid and that the distribution of potentially acid-generating material is likely spatially associated within the ore zone. Leachate from short-term tests had alkaline pH and slightly elevated aluminium concentrations;

• Magnitite Skarn – Static test results suggest that this rock type is potentially acid- generating and that it has the potential to leach elevated concentrations of several metals; and

• Mill Tailings – Mineral processing at Nui Phao will generate two distinct tailings streams: oxide and sulphide tailings. The oxide tailings are benign with respect to acid generation potential and metal leachability. The sulphide tailings have a significant potential to generate acid and to mobilise several metals.

Vietnam is located between the Himalayan and Pacific seismic belts and is located at a junction of the Indo-Australian, Eurasian, and Pacific tectonic plates. There is the potential for moderate and large earthquakes of a magnitude up to 7.0 in northern Vietnam due to the complicated geological structure and tectonic movements in the region.

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3.2.4 Soils The soils in the Project area are tropical saprolites that are relatively low in nutrients and are known to contain elevated concentrations of arsenic and other heavy metals. Although the soils exhibit low fertility, they are still productive and able to support plant growth. The land for the most part is currently being used for agricultural and industrial purposes. Naturally elevated concentrations of arsenic and other heavy metals in the soils of northern Vietnam is a well-known regional phenomenon and is an important background condition of the Project. Five soil-sampling events serve to establish the baseline soil conditions that have documented elevated concentrations of arsenic, lead, and boron to be naturally present at levels that could pose health risks to local residents. Because of the concern for natural soil contamination and the human health risks it poses, Nuiphaovica expended considerable effort to profile the nature and extent of this naturally occurring contamination in the Project area. Elevated concentrations of arsenic, which is the most significant contaminant of concern, appear to follow the topographic features that generally trend north to south and predominantly occur in the eastern portion of the Project area as shown on Figure 3.1. Arsenic contamination is associated with the natural surface soils and is generally not linked with the geochemistry of ores produced by mining activities accomplished either by others or to be mined by Nuiphaovica. Since arsenopyrite is not found in the mineralogy of the Nui Phao weathered soils, saprolite, or even in the pyrrhotite of the deposit itself; it is more likely that the arsenic is associated with the complete weathering over geological time of an original arsenic-bearing host rock. The arsenic released during the weathering process would have been adsorbed onto iron hydroxide minerals and incorporated into the near-surface soils and saprolite unit producing the observed distribution. This is similar to the mechanisms responsible for the arsenic distribution in the Red River Delta near Hanoi. Since the arsenic is adsorbed onto sediments, it is susceptible to erosion and consequently accounts for the elevated arsenic concentrations in the suspended sediments of the river waters as well. 3.2.5 Surface Water The region is drained by the generally north-to-south flowing Cau River to the east and the Cong River to the west (Figure 3.2). All of the Project components are located in the Cau River watershed.

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3.2.5.1 Hydrology Main drainages in the Project area are the Upper Thuy Tinh Stream, Bat Stream, Tin Valley, and Doi Ba Stream, all of which contribute to the flow in the Lower Thuy Tinh Stream downstream of the Project area. Drainage from the Nui Phao Mining Project also flows north via North Road Stream to the Upper Cat Stream. To the east of the Project area is the Doi Nam Stream, which also contributes to the flow in the Lower Thuy Tinh. Approximately 2 kilometres (km) to the northeast of the Project area, the Lower Thuy Tinh joins the Lower Cat Stream (Suoi Cat). The Lower Cat Stream runs in a west-east direction and is joined by the Du (or Luu) River, a few kilometres prior to its confluence with the Cau River. The Cau River flows north of the town of Bo Dau and is joined by the Cong River approximately 40 km downstream of Bo Dau. The Cau River then continues east for approximately 50 km where it is joined by the Luc Nam River and then the Duong River near the town of Pha Lai. The Duong River then splits into a series of braided channels that empty into the Gulf of Tonkin in the area of the port of Hai Phong. Most small streams in the area are seasonal with low or no flow toward the end of the dry season (March-April), good flows in the wet season, and sporadic peak flows during monsoon episodes (June-August). Flooding is common in the month of July. 3.2.5.2 Surface Water Quality The baseline study area for establishing water quality was subdivided into nine sub-basins as identified on Figure 3.2. A summary of the surface water quality is presented below:

• Upper Thuy Tinh Stream in the Area of the Open Pit – The water quality in the Upper Thuy Tinh Stream above the proposed open pit is generally of good quality as there are no artisanal mining activities in this area. Bat Stream, a small tributary of the Upper Thuy Tinh, also has good water quality with circum-neutral pH (pH ~ 6.5) and low metal and arsenic concentrations. Water in the vicinity of the new open pit has elevated arsenic concentrations, but the water is not acidic. Downstream of the new pit in the area of the new plant site, the water is significantly influenced by existing historic mining in the People’s Pit and Thang’s Pit. The water in this part of the stream is characterised by acidic pHs (average pH 2.9), elevated arsenic and other metals;

• Upper Thuy Tinh Stream, Downgradient of all Facilities – The Upper Thuy Tinh Stream in the area downgradient of all proposed facilities is characterised by high levels of water contamination due to historic artisanal mining activities. The Alluvial

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Pond and other unnamed historic mining disturbances are located in this section of the Upper Thuy Tinh sub-basin. The surface waters in this stream are characterised by low pH, elevated metals and sulphate concentrations, and high total dissolved solids (TDS) relative to other surface waters in the area;

• Tin Valley – Water quality at the headwaters of Tin Valley is near neutral pH with low metal concentrations. Three fishponds are active at this location with tea farming on the side slopes in the upper valley reaches. Downgradient, there are 41 historic or presently active artisanal mines located on the east and west sides of Tin Valley. Some of these historic openings emanate low pH water with elevated arsenic, cadmium, chromium, nickel, and lead concentrations. Water quality at the base of Tin Valley Stream has low pH (pH 4.4) with elevated copper and arsenic. Cadmium, chromium, nickel, and lead values have typically been fairly low although metal spikes have been noted which appear to be associated with the intermittent workings of the artisanal mines;

• Doi Ba Valley in the Area of the TSF – The new TSF will be located in the Doi Ba Valley, which is tributary of the Upper Thuy Tinh Stream downgradient of all facilities. Water in the upper reaches of this basin has elevated metal concentrations, even in areas that are upstream of any known historic mining activities. According to locals, the water quality has been degraded by weapons decommissioning associated with the military base located upstream. Locals reportedly lost rice productivity when floods brought contaminated water to the area. Between the rice farming area and the downgradient water sampling location, there is significant artisanal mining. Water quality in the lower valley is generally low in pH and high in metals, TDS, and sulphate. The poor overall water quality in this part of the Doi Ba Valley appears to be directly influenced by artisanal mining activities;

• Doi Nam Valley to the East of the Project Area – In the upper reaches of the Doi Nam Valley, the water is slightly acidic (average pH 6) with low metal concentrations. Between the upper and lower reaches where the sampling occurred, there is significant artisanal mining and shaker table activity. The water in the lower part of the valley is acidic with high concentrations of sulphates, TDS, and metals. The water quality degradation appears to be the direct result of artisanal mining activity;

• Lower Thuy Tinh Stream, Downgradient of all Facilities – Lower Thuy Tinh drainage consists of lowlands that are typically used for rice cultivation in the wet season and dry crop cultivation in the dry season. The water within the Lower Thuy Tinh Stream is a combined flow from the Upper Thuy Tinh Stream, Tin Valley, Doi Ba Valley, and Doi Nam Valley. Surface water resources in this area are relied upon for irrigation, husbandry, and some domestic uses such as washing. Additionally, ore processing and tailings reprocessing are currently occurring within this area (Ha Thuong Tin Mining Enterprises in the Kho Muoi Road area – Wards 6 and 7), and this part of the Thuy Tinh Stream is characterised by high levels of surface water

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contamination due to historic mining activities, resulting in acidic metal-enriched waters. In Phuc Linh Commune, some areas have lost agricultural productivity entirely due to water contamination, and households have switched to mining topsoil for brick making as income. The water quality in this part of the basin is characterised by acidic pH (average pH 4.4) and elevated arsenic, iron, and manganese;

• Upper Cat Stream to the North of the Project Area – While there is no indication of previous tin mining in Upper Cat Stream, there are a number of abandoned gold mines. This area was quite active until District authorities forced their closure. These artisanal operations were of limited extent with no remnant waste piles. The water quality in the Upper Cat Stream is circum-neutral with elevated concentrations of arsenic, nitrates, and oil and grease. Rice and tea are grown in this reach but are of poor quality;

• Lower Cat Stream Downgradient of the Project Area – The Lower Cat Stream is

downgradient of the confluence with the Lower Thuy Tinh and Upper Cat Streams and up- gradient of its confluence with the Luu River. Predominantly consisting of lowlands, the area is typically used for rice cultivation in the wet season and dry crop production in the dry season. Water resources are used for irrigation, husbandry, and some domestic activities. Water quality in the Lower Cat Stream represents a mix of water from the Upper Cat and the Thuy Tinh watersheds, including the influence of the historic disturbances. Water quality in this location is characterised by neutral pH with low sulphate concentrations, relatively low TDS concentrations, and high levels of arsenic although iron and manganese concentrations were lower than in the Project area. Concentrations of nitrites and oil and grease were also elevated in this reach; and

• The Cong River – The Cong River is a relatively large river system to the immediate

southwest of the Da Lien Prospect area. Surface water was collected on the Cong River downstream of an old tailings pond, which is situated in a household garden on the bank of the Cong River. When water levels rise in the river, the contents of this tailings pond are washed into the river. The water samples from this section of the Cong River were generally low in sulphate and TDS with higher arsenic concentrations reported in the dry season. No Project-affected water is tributary to the Cong River.

3.2.6 Groundwater Groundwater resources in the Project area have been defined as a low-permeability saprolite which functions as an aquitard. Below this is a higher permeable layer of weathered bedrock that is the water-bearing unit that extends over much of the Project area. This unit is underlain by low-permeability bedrock that likely only contains fracture flow.

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3.2.6.1 Hydrogeology The saprolite overburden, which is a predominantly silty/clayey soil formed by the decomposition of the underlying bedrock, ranges from 40 m to 100 m in depth. The saprolite overlies fresh meta-sedimentary bedrock with shallower overburden on the hills overlying fresh granite bedrock. The saprolite and fresh rock both have low hydraulic conductivities, in the order of 10-8 m/s or lower, although the interface between these two layers may have a higher hydraulic conductivity. This interface unit is where the groundwater is located. Several wells drilled into the bedrock in the main valley floor exhibited artesian conditions. While drilling through the overburden (saprolite), the holes were dry, but after drilling into the bedrock, the water levels rose over time. From these observations, it was concluded that the saprolite acts as an aquitard, confining a transition zone/upper bedrock aquifer. It was further concluded that the saprolite is a non-water-bearing unit except possibly locally in low clay content areas. The potentiometric surface is inferred to be generally within 0.4 m to 2.6 m of the ground surface in the base of the valleys and rises in the hillside in the area of the open pit. The groundwater elevation is relatively flat in the main valley with a slight gradient to the east. The shallow groundwater levels are a result of a rise in the potentiometric surface from the deeper aquifer that is confined between the granite bedrock and the impermeable saprolite. Near the main tailings dam, located about 30 m above the valley bottom, groundwater was at 27.5 m below ground surface. 3.2.6.2 Groundwater Quality Three programmes were conducted to assess baseline groundwater quality. The baseline programme characterised the physiochemical parameters and metal concentrations and also established the background conditions inside the Project area and in Doi Nam Valley (Figure 3.3) as presented below:

• Upper Thuy Tinh Stream in the Area of the Open Pit – Groundwater quality in the Upper Thuy Tinh Stream drainage basin in the area of the open pit is represented by the samples obtained from the following groundwater well and pit: O406 and Thang’s Pit where groundwater has been intercepted by historic mining activities. Groundwater well O406 is approximately 50 m deep and is located in the upper reaches of the Upper Thuy Tinh Stream drainage basin. Arsenic concentrations from

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well O406 samples were below the limits of all the relevant standards and guidelines, including the drinking water standards. However, groundwater in this well exceeded the standards for iron, manganese, and cadmium on at least one occasion. In contrast, Thang’s Pit, located downgradient of the proposed open pit area, is approximately 40 m deep and has intercepted groundwater. The groundwater in this pit is characterised by very high concentrations of metals with excessively high concentrations of arsenic, iron, and manganese resulting from geochemical reactions of the groundwater with the pit wall rock. This groundwater has also exceeded the standards for antimony, boron, lead, nickel, and cadmium on at least one occasion;

• Upper Thuy Tinh Stream Drainage Basin Downgradient of all Proposed Facilities – Groundwater in the Upper Thuy Tinh basin downgradient of the proposed facilities is measured at wells MA405 and KP3. Groundwater well MA405 is a 57.7-m-deep well located between the lower reaches of the Upper Thuy Tinh Stream, downgradient of several likely contamination sources. The groundwater in this well had relatively high metal concentrations with notably higher lead concentrations than Thang’s Pit. Groundwater in this well exceeded the standards for arsenic, iron, lead, manganese, nickel, and cadmium on at least one occasion. Groundwater well KP3 is approximately 18 m deep and is located within the Upper Thuy Tinh drainage basin to the east of the proposed pit. The groundwater in this well had relatively high concentrations of arsenic, iron, and manganese with lower concentrations of lead, nickel, cadmium, antimony, and boron;

• Doi Ba Valley in the Area of the TSF – Groundwater quality in the Doi Ba Valley is represented by the samples obtained from wells KP1 and T401. Groundwater well KP1 is approximately 18 m deep and is located in Doi Ba Valley adjacent to the main surface drainage. The groundwater samples from this well had elevated concentrations of arsenic, iron, manganese, lead, nickel, and cadmium. Antimony and boron were consistently below the method detection limits. Groundwater well T401 is 41.4 m deep and is located in the Doi Ba Valley adjacent to the main stream in this valley and downgradient from KP1. T401 is located near a known source of ARD contamination. The groundwater samples from this well had elevated concentrations of arsenic, iron, manganese, lead, and cadmium. Nickel, antimony, and boron were consistently at or below the method detection limits. In addition, groundwater in this well exceeded the standards for nickel on at least one occasion; and

• Doi Nam Valley to the East of the Project Area – Groundwater quality in the Doi Nam Valley is represented by the samples obtained from the KP2, KP4, and KP5 wells. KP2 is approximately 52 m deep and is located in the lower Doi Nam Valley. The samples from this well had low concentrations of arsenic, iron, manganese, lead, nickel, and cadmium. These concentrations indicate that this well is not affected by ARD contamination but did exceed the standards for arsenic, iron, lead, manganese, and cadmium on at least one occasion. KP4 is approximately 30 m deep and is located just to the east of the Doi Nam Valley, downgradient from a known Doi Ba Valley ARD contamination source. The groundwater samples from KP4 have the

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highest metals concentrations as compared to the Doi Nam Valley wells although the groundwater samples from this well generally had low concentrations of arsenic, iron, manganese, lead, nickel, and cadmium. However, groundwater in this well exceeded the standards for arsenic, iron, lead, nickel, and cadmium on at least one occasion. KP5 is approximately 30 m deep and is located at the western edge of the lower Doi Nam Valley, to the south of KP2. KP5 generally has low concentrations of arsenic, iron, manganese, lead, nickel, and cadmium. However, groundwater in this well exceeded the standards for arsenic, iron, lead, and nickel on at least one occasion.

Two additional groundwater programmes were accomplished with an emphasis on establishing quality data relative to human health standards. These surveys are summarised below:

• Community Well Survey (December 2001 and July 2002) – Dry and wet season groundwater quality was evaluated in several groundwater wells in the surrounding community. Dry season groundwater concentrations for arsenic exceeded all of the relevant Vietnamese and World Health Organisation (WHO) standards whereas the wet season samples exceeded none of the standards. Aluminium, arsenic, boron, chromium, copper, lead, and manganese concentrations were elevated in the most of the wells sampled in the dry season whereas manganese and iron were the only metals to exhibit consistently elevated concentrations in both the wet and dry season samples; and

• Drinking Water Survey (November 2003) – A more extensive community well survey was conducted partnership with the Thai Nguyen DONRE to assess arsenic concentrations in the drinking water supply for the local community. The drinking water survey included 586 household drinking water wells. Results showed that only 8 percent of the wells downstream of the Project area exceeded Vietnamese and WHO drinking water standards (10 μg arsenic/L) and only 2 percent had arsenic concentrations exceeding 50 μg/L.

3.2.7 Flora Vietnam has been divided into 16 distinct ecological regions, and of these, the Nui Phao Mining Project area falls within the Northern Indochina Subtropical Forest Eco-region. This large eco-region extends for approximately 114,000 km2 across the highlands of northern Myanmar, Laos, and Vietnam and includes most of southern Yunnan Province in China. Almost all primary forests of this eco-region in Vietnam have been cleared, and only very small fragments remain. In northern Vietnam and including the region surrounding the Project area, the vegetation biome is Tropical and Subtropical Moist Broadleaf Forest. This biome is characterised by the emergent canopy dominance by members of the family Dipterocarpaceae. These forests are composed of

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trees that are evergreen, hygrophilous, at least 30 m high, and rich in thick-stemmed lianas with abundant woody as well as herbaceous epiphytes. The Project area vegetation has been severely disturbed in recent decades by human settlement, agricultural practises, fires, and historic mining and exploration activities. Almost all of the original vegetation was cleared in association with these anthropogenic activities. Clearing was accomplished to open sites for agricultural production, mining activities, and harvesting of fuel-wood and for access to construction materials. The historic cover of Tropical and Subtropical Moist Broadleaf Forest has almost completely been replaced with disturbed or cultivated plant types, depending on topography (Figure 3.4). The current plant associations include early seral secondary growth on hilltops, secondary forestry plantations on hill slopes, and agricultural plantations on foothills and in valleys. No threatened or endangered species of plants were identified in the Project area. 3.2.8 Fauna The diversity and abundance of wildlife in the Project area has declined over recent decades, primarily due to loss of habitat and hunting. Large animals that require intact forest such as tiger, sambar deer, clouded leopard, gibbon, and langur have entirely disappeared from the area. Thirty species of mammals were identified in the Project area but are limited to only small animals that were able to adapt to human-influenced landscapes. Eighty-one species of birds were recorded in the area, and 27 species of reptiles and amphibians were identified in the region. Suitable habitat exists for three species of mammals, eleven species of birds, and nine species of reptiles exists proximate to the Project site that are either listed or threatened and endangered as defined by the Red Book, the International Union for the Conservation of Nature (IUCN) Red List of Threatened Species, and the Vietnamese Governmental Decree 48/2002/NDCP – Revision of the List of Precious and Rare Plant and Animal Species. Although the known range of these species encroaches into the Project area, habitat within the Project area itself is unlikely to support them and does not play a role in the conservation or preservation of these species.

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3.2.9 Aquatic Resources Baseline aquatic resources were identified through testing stream sediments and physiochemical water quality and performing a benthic/invertebrate site investigation. Sediment arsenic concentrations indicate that arsenic has been a water quality issue for some time, and the arsenic loading in the sediment bed has resulted in water that is clearly inadequate for the support of aquatic life. Iron concentrations are also extremely high in the sediments sampled; under oxidising conditions the geochemical relationship between arsenic and iron supports that the arsenic will adsorb to iron and settle out of solution (i.e., increased sediment concentration, due to precipitated iron and arsenic). Sediment copper and lead concentrations were elevated throughout the study area with the median concentrations exceeding the recommended guidelines. Cadmium, chromium, and nickel concentrations were elevated in the sediments in many of the samples from all areas within the Project study area. Water pH increased from the Thuy Tinh Stream area to Lower Cat Stream, which would result in the many of the metals precipitating out of solution and settling into the sediments in Lower Cat Stream. The results of a macroinvertebrate survey showed that the abundance and diversity of the benthic invertebrates to be relatively high in Bat Stream (a small tributary of the Upper Thuy Tinh) and Upper Cat Stream and very low in Lower Thuy Tinh Stream and the Lower Cat Stream. Sampling locations downstream from previous mining activity contained primarily arthropods, a relatively tolerant species. Sites with higher abundance and diversity of organisms contained more sensitive species including decapods and gastropods. Bivalves were found at all sites with only a few isolated exceptions in the Doi Nam Valley, Bat Stream, Thuy Tinh Stream, and the Lower Cat Stream. Sites where bivalves were absent are believed to be impacted areas by previous mining activities. Two fish species were captured during the benthic invertebrate investigation. One species was found in Bat Stream at sample location BEC3, upstream of any artisanal mining activity within the Upper Thuy Tinh Stream basin. Coincidentally, the benthic invertebrate population at this sample location was the most abundant within the study area. The other fish species was found at sample location BE6, at the base of the stream system in the Doi Nam Valley. The benthic invertebrate populations at this sample location indicate that there is substantial environmental stress in the area, but surface water data from the upstream sample location SW6c suggest that sections of this stream have water quality that could support aquatic life. No fish species were

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identified during the baseline investigations in the Thuy Tinh between the Project area and Lower Cat Stream. 3.3 Social and Economic Baseline The social and economic baseline information profiles the existing social, economic, health and political context at the site and characterises important conditions prior to any Project development activities. These data are based on various field reconnaissance carried out between 2001 and 2004 and the social and economic conditions cited in previous baseline studies, assessment reports, and memorandums prepared by Knight Piésold and others. The Project is located in the Dai Tu District of Thai Nguyen Province, approximately 20 km northeast of Thai Nguyen City. The study area focused on the Communes of Ha Thuong, Phuc Linh, Tan Linh, Hung Son, Tien Hoi, Cat Ne and Quan Chu plus Dai Tu Town, which is approximately 3 km from the Project site and the closest town centre. The Project site is primarily within Ha Thuong Commune with smaller portions within Hung Son and Tan Linh. Phuc Linh Commune lies northeast and downstream of the Project disturbance footprint and the Nam Song Cong resettlement site will affect Tien Hoi. These Commune boundaries are shown on Figure 3.5. Cat Ne and Quan Chu Comments are located a distance to the south of the Nui Phao Project Area and are associated with the resettlement replacement lands and the military base. Stakeholders within the study area can be divided into three general categories:

• Project Affected Persons (PAP) by resettlement activities (including those at relocation sites);

• Adjacent/Host Communes (Ha Thuong, Phuc Linh, Tan Linh, Hung Son, Tien Hoi, Cat Ne and Quan Chu Communes plus Dai Tu Town); and

• Regional/Indirectly Affected People. Resettlement impacted people are those who are directly impacted by resettlement and relocation processes, as identified in the Resettlement Action Plan (RAP). Adjacent communities are those residing in the seven above-mentioned Communes including Dai Tu Town. Regionally or indirectly impacted people are those residing in the proximate region but who are not included in

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the other two categories. Data that could not be gathered through interviews or consultations, such as national or regional data, were obtained through a range of literature sources. Information on the social and economic conditions within the study area was gathered through a series of site-specific interviews, surveys, and consultations with a range of stakeholders. These included interviews with government and community leaders, business owners, community members and focus groups, and detailed surveys of individual households. 3.3.1 National and Provincial Context Vietnam is a communist state (also known as the Socialist Republic of Vietnam) governed by a chief of state, President Tran Duc Luong (since 24 September 1997) and a head of government who is Prime Minister Phan Van Khai (since 25 September 1997). Hanoi is the capital and administrative centre of Vietnam. Vietnam is a developing country with a gross domestic product of about US$45.6 billion and a population of over 83 million and is the twelfth most densely populated country in the world. The per capita Gross Domestic Product (GDP) is US$3,000 (CIA, July 2005 estimate). Vietnam has experienced rapid economic growth in the last decade with the overall GDP having more than doubled since 1993. Three key socioeconomic trends underlie and explain Vietnam’s progress in recent years: (1) an increasing integration of agriculture into the market economy, (2) increasing job creation in the private sector, and (3) an ongoing process of government and institutional reform. While these trends have been important to the economic growth and poverty reduction, they have also contributed to increasing wealth discrepancy. Unequal access to knowledge, training, social networks, and economic opportunities have contributed to the increasing exclusion of poor and vulnerable groups. Thai Nguyen Province is located in the foothills of the Northern Mountains between the wealthier delta provinces surrounding Hanoi and the impoverished and remote provinces of the far north. The province has experienced a strong economic growth rate in recent years but still ranks in the lower half among the 61 provinces in the country. Most residents rely on individual farms for their livelihoods, but farmers are increasingly growing a variety of crops for the market. Tea is the most important cash crop, and Thai Nguyen Province exports its tea both nationally and internationally.

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The largest area of employment growth in Thai Nguyen has been in the private informal sector. Small-scale private industries in mining and construction account for much of the work. Mining is a major industry in the Province and generates extensive informal employment through independent artisanal extraction and processing activities for the recovery of a variety of metals. Thai Nguyen also has the second largest coal reserve in the country and has four large state-owned coal mines. 3.3.2 Social and Political Organisation Formal political and social institutions have a hierarchical administrative structure in Vietnam consisting of the Communist Party, State Executives (also called People’s Committees), and Unions (or Mass Organisations). The Party is responsible for overall direction, authority, and policy initiatives. State Executives are responsible for implementing policy and local participation in government is organised through the various Unions. Vietnam is divided into Provinces, Districts, Communes, and Wards. At the local level, the Commune represents the lowest tier of formal government administration. The Commune People’s Committee consists of locally elected Communist Party officials, union representatives, and appointed officers. The People’s Committee members are accountable to the State and responsible for implementing and negotiating policy directives in ways that are appropriate to their local areas. Subsidiary to the communes, Wards are not formal administrative units but in many ways they are the most important social institution for local people. Each Ward is typically a strong community with its own customs and traditions. An elected Ward leader sits on the commune People’s Committee and is tasked to communicate the issues of the Ward to the commune-level government, to inform the Ward of government policy, organise meetings, and to mobilise residents for local infrastructure maintenance. Unions are one of the most important channels of communication from the government to local people and play a critical role in implementing policy. The strength of unions is their ability to access a high proportion of the population through high membership and close integration with local communities and government. Unions have a centralised organisational structure with a national executive and lower levels distributed down through Districts and Communes. Though technically “non-government,” these organisations carry out government policies at various levels, mobilise around particular causes, and represent the interests of their members. In the study area, 93 percent of households reported participation in unions and clubs.

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Informal social groups, networks, and relationships are important social alignments in Vietnam. These include family networks, neighbourhood groups, and trade organisations. Informal organisations are often intimately linked with government organisational structure. Access to institutions helps people to gain political support, credit, and assistance in times of particular hardship. The relationship between government institutions and the citizens of Vietnam is different from most other developing and developed countries. Local residents have the opportunity to participate directly in policy decision-making through mass organisations and groups set up voluntarily by people at the grassroots level to manage such issues as natural resources and the development of sustainable livelihoods. The Government recognises the value of this grassroots participation and has passed a number of decrees seeking to strengthen this democracy and its partnerships with organisations working for the benefit of the people. 3.3.3 Population Thai Nguyen Province is home to over one million people, about 240,000 of whom live in the commercial and provincial capital Thai Nguyen City. The Project is located in northwestern Thai Nguyen Province in Dai Tu District. Dai Tu District has a population of nearly 165,000, of which about 30,000 individuals live in the Project study area. Within Dai Tu Town and the communes of Ha Thuong, Phuc Linh, Tan Linh and Hung Son, 60 percent of the people are between the working ages of 18 and 60. Eight percent are over 60, and the remaining 32 percent are under 18 years of age. Men and women are essentially equally represented in this population distribution. The population density in the District is 283 persons/km2, about 20 percent higher than the national average. Vietnam has 54 ethnic groups, 44 of which are represented in Thai Nguyen Province. In the study area, over 85 percent of the residents are Kinh people with the Cao Lan, Tay, Nung, Xan Chi, Dao, and Tho people also being represented. While some groups within the study area speak ethnic languages, all residents speak Vietnamese including those of ethnic origin. A recent study of ethnic minorities residing in the Project area concluded that these groups had only recently settled in the area and as such do not represent an indigenous group as defined by the World Bank Group. It is noted, however, that ethnic minorities’ social, cultural and economic characteristics and disadvantages will be taken into consideration in designing compensation

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measures, local disclosure and participation in several programs including community development initiatives. In Vietnam, Buddhism is the dominant religion, subscribing about 50 percent of the population. Over 80 percent of the people in the study area do not align themselves with a stated religion. Of those who reported to be religious, Catholicism is dominant and is mainly concentrated in Ha Thuong Commune where a Catholic church is well established. Buddhism was reported by less than one percent of respondents in the study area. Educational coverage in Vietnam is good, even among the poor. People within the study area have a high literacy level of about 95 percent, but overall education levels are relatively low with most people over 30 years of age having not completed high school. Only about one percent of the people interviewed in Ha Thuong, Phuc Linh, Tan Linh and Hung Son Communes have a university or post-graduate degree. This is contrasted in Dai Tu Town where 15 percent reported a university degree or higher. 3.3.4 Human Health The health condition of local residents has improved in recent years as a result of the economic development and improvements in local health care services. Expanded immunisation programmes and communicable disease prevention programmes have helped to control a number of common ailments and diseases, but there still remains a relatively high incidence of ailments reported in the study area. Forty percent of the households inventoried reported that they suffered from some sort of health problem. The most frequently reported serious health problem in the study area was skin disease; followed by endocrinal diseases, mental illness, rheumatism/arthritis, and respiratory disease following in descending order of frequency. The remaining 60 percent of households said they suffered no serious health problems. Despite the general improvement of health conditions, clinic leaders still describe certain trends of increasing ailments over the last ten years. These trends include increasing occurrences of skin disease, heart disease, and breast cancer in Ha Thuong; intestinal disease in Phuc Linh, Hung Son, and Tan Linh; respiratory disease in Phuc Linh and Tan Linh; liver disease in Tan Linh; and drug abuse, HIV, gonorrhoea, and flu in Hung Son. In both Ha Thuong and Phuc Linh, health care professionals cited environmental contamination as a significant contributor to the increasing health problems. Health care professionals and local residents both correlate the rising

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health concerns with the increased exposure to heavy metals and pesticides associated with local mining and agricultural practises, respectively. Other important health concerns in the study area include reproductive health in women of childbearing age and social evils including drug abuse, HIV/AIDS, and other sexually transmitted diseases. Existing environmental conditions, notably the naturally occurring arsenic in soils, have implications for human health. Baseline water and soil data were assessed in the context of its potential to affect human health, and additional studies were conducted on metal cycling in the food chain and human tissue analysis. Arsenic occurs naturally in local soil and water at concentrations that exceed human health standards at a number of locations within and proximate to the Project area. Certain land management practises such as farming, artisanal mining, and brick making may further expose certain individuals to elevated arsenic concentrations. Baseline studies also indicate that people may be exposed to arsenic through the foods they eat. Certain plant and fish tissues were sampled and tested for concentrations of metals to determine food chain bioaccumulation and the potential impact from these possible sources of exposure. Results indicate that arsenic has accumulated in the plant materials tested and that arsenic, cadmium, and mercury have accumulated in the fish samples tested. Of the fish tested, the arsenic concentrations were present at levels that suggest that consumption of any amount these fish would exceed established cancer risk tolerance levels. Samples of human hair, blood, and urine were obtained in cooperation with the Thai Nguyen Health Department to determine if local residents were being exposed to certain metals and, if so, to help develop recommendations for reducing exposure and improving community health. Biological exposure indices and human norms for arsenic were compared with the analytical results from samples obtained from a group of local resident volunteers. Results confirmed nearly all of the individuals tested have been exposed to elevated concentrations of arsenic. Analysis of soil, water, and biological samples for the spectrum of trace metals, general chemistry parameters, and bacterial contamination indicators combine to suggest that arsenic is the key element of concern in the study area with regard to human health due to its prevalence and toxicity. The main arsenic exposure route for the general population is through the consumption of foods or drinking water. Potential occupational exposure is generally through

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inhalation and dermal contact. Over extended periods, ingestion and dermal contact with low levels of inorganic arsenic can cause arsenicosis, the clinical manifestations of which include melanosis (dark patches on the skin), leukomelanosis (white skin patches), and keratosis (hardening of skin). Ingestion of inorganic arsenic can also increase the risk of skin cancer and cancer in the lungs, bladder, liver, kidney, and prostate, and ingestion of high levels can cause death. Symptoms such as skin disease identified and observed in the study area appear to be comparable to the clinical manifestations of arsenic exposure. According to local health clinic staff, the frequency of skin problems reported to the clinic has tripled over the last ten years. Bio monitoring of human hair, urine, and blood in certain individuals appears to corroborate the arsenic exposure and may corroborate the reports of health care professionals regarding the presence of clinical manifestations. Other ailments in the study area, including lung and other internal cancers, may be linked to long-term exposure to arsenic. 3.3.5 Livelihood Activities and Employment Opportunities Household interviews and focus group discussions were conducted to identify the livelihood activities and employment opportunities in the study area. Thai Nguyen Province and Dai Tu District are characterised by their agricultural-based economies. Since the 1990s, the area has experienced rapid development, including population growth, accelerated infrastructure development, industrialisation, deforestation, and agricultural diversification. Over 85 percent of the households in the study area draw their livelihood from farming. Tea and rice are the most important agricultural income sources with other important income sources coming from animal husbandry and fruit trees. Corn and cassava are grown in the dry season in paddy land for both human and livestock consumption. A variety of vegetables are also grown in gardens for household consumption. Many of those households produce excess agricultural goods for sale in the local marketplace. Seasonal patterns in rainfall and agriculture are important in driving aspects of livelihoods. Tea and rice are cultivated during the wet season. This results in a peak period for agricultural activity in May to June and September to October when the rice crops are harvested. During these periods, the high labour demands for rice and tea cultivation overlap, making it the busiest time of the year for local people. During the dry season, there typically is insufficient

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agricultural work to provide adequate income or food resources to meet household, so residents often seek wage labour to supplement their agricultural income. While farming is a significant livelihood in the rural areas, primarily for individual use, farming comprises only 16 percent of local incomes in Dai Tu Town. Other employment opportunities include handcrafter, worker, state cadre, commerce, service industry, farm product processing, police, or soldier. Only 7 percent of people surveyed reported themselves as unemployed. Small-scale mining activities are a significant economic activity in the study area with tin being the most significant mineral mined. Other mineral resources include iron ore, cement components, gold (Hung Son Commune), and clay for brick making. While present artisanal mining practises are not officially endorsed, mining is widespread in the region and involves an extensive informal network. These activities have resulted in significant contamination in local watersheds associated with both the chemicals used in mineral processing as well as ARD in areas where reactive sulphides have been exposed to air and water by mining. Brick making as a livelihood source has emerged as a direct outcome of the environmental contamination in the area. Several communities in Phuc Linh Commune have changed their land use from agriculture to brick making as a response to severe land contamination and resulting loss of agricultural resources. The average household income in Dai Tu District is approximately US$27/month. In contrast, Dai Tu Town is primarily non-farming and has a higher average household income of US$31/month. The average household income for Dai Tu District and Dai Tu Town are at or below the World Bank poverty rate of US$1/day. Monthly expenditures range from about US$6.5/month to US$139/month. Food is the most common household expenditure, averaging 50 percent of total expenditures. Other important expenses include children’s tuition fees and farming expenses for pesticides and fertilisers, electricity/gasoline, medicine, and husbandry. Additional expenditures are associated with club and union membership fees, brick making costs (Phuc Linh), shaker table running costs (Ha Thuong), and small businesses. Residents in the study area typically own their own homes. Livestock is the most common asset after housing. Motorbikes and bicycles are the main means of transport owned by surveyed

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households, and some households reported luxury items including electric fans and refrigerators. Most households reported having some kind of loan in place, usually sourced from union membership and/or family. 3.3.6 Land and Natural Resource Use Natural resource access and use is the most important aspect of livelihood security for communities in the study area. Land and natural resources are a critical source of household income through agriculture, husbandry, timber, and mineral exploitation. Beyond economic activities, natural resources and, in particular, agricultural land, provide income security and livelihood resilience to the area. Local communities also rely on surface water and groundwater for basic needs and livelihood activities. Thai Nguyen Province has a land area of about 3500 km2. Dai Tu District has an area of about 580 km2 of which 70 percent is used for agro-forestry. Land shortages directly threaten the ability of the population to improve or even maintain their current circumstances. Agricultural land that is converted to other uses typically cannot be replaced due the high population density and agricultural land scarcity. Permanent loss is therefore often associated with significantly increased vulnerability. The People’s Army of Vietnam has two military sites located within and near the study area. KV 10, located at the head of Doi Ba valley up gradient of the TSF, is comprised of 122 hectares (ha) of forested land and extends from Ha Thuong to Tan Thai Commune. This area has been used primarily for weapons and explosives storage, and burning or explosion in this area has destroyed some weapons and explosives. KV3, in Phuc Linh Commune northeast of the Project, is a military camp and training area. KV3 will not be affected by the Project. Modern water supply and sanitation facilities are severely lacking in the study area. Local communities are reliant on well water and surface water for basic needs and livelihood activities, resulting in vulnerability to both loss of water resources and changes in water quality. The conversion from forest to farmland has resulted in a significant decrease in forest cover. This trend has been linked with increased environmental degradation, including increased frequency and severity of flooding periods and changes to seasonal water supply.

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3.3.7 Infrastructure and Services The development and presence of physical infrastructure has been an important factor in the evolution of the local community. The development of roads and access to electricity, in particular, has significantly contributed to industrial activities and employment opportunities. Current infrastructure in the study area includes:

• Housing – Typically small single-story one- to two-room dwellings with dirt or tile floor. Some houses in Dai Tu Town are larger, divided into several rooms, and are often times multi-storied;

• Water supply – Nearly all households have access to water. Most have hand-dug wells; a limited few have drilled wells and some use communal water supplies. A potable water treatment facility is presently under construction in Dai Tu Town with future plans to connect most town facilities. Complete connection is unlikely to be completed for several years;

• Sanitation – Households utilise pit toilets and flush toilets connected to either small septic fields or open sewers that drain into local streams or agricultural fields. Flush toilets are most common in Dai Tu Town, and pit toilets dominate the rural commune areas;

• Irrigation Systems – Small dams, canals, and pumping stations are used for irrigation in Hung Son and Ha Thuong Communes;

• Power and Electricity – Thai Nguyen’s main power source is the 220-kV double line from the Song Da generation plant and the Pha Lai II coal-fired plant. The power station feeding the Dai Tu District is a 110-kV single line from the Thac Ba generating station, the A62 Power Station in Thai Nguyen. Power is distributed locally via a 35-kV overhead line in the Project area. Over 90 percent of residents in the study area have electrical power from the national grid. The main fuel resources used by residents are firewood, gas, and coal. Many residents along National Road No. 37 and in Dai Tu Town use gas and coal;

• Communications – Telephone, mail, radio, and newspaper services are available to all communes in the Dai Tu District. Express mail services, mobile phone, and internet service connections are also accessible;

• Roads – Access roads between communes are constructed of aggregates, and travel during rainy seasons is difficult. Less than one percent of roads in the Communes are sealed;

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• Railroads – The existing Quan Trieu-Nui Hong Railway runs directly through the study area and is used and operated by the national coal company for the transportation of coal from a mine located to the northwest of the Project;

• Transport and Traffic – Local transportation is mainly via bicycles and motorbikes. Public buses provide service from Dai Tu Town to Thai Nguyen City and Hanoi. Traffic accidents are a significant concern to local authorities;

• Education – Thai Nguyen City has ten universities and trade schools. There are two high schools in Dai Tu Town. Each commune provides primary and middle school services. Some schools are in need of improved equipment and facilities;

• Health Care – Dai Tu District has 266 registered health care professionals in 37 Commune-level health clinics providing emergency services and the treatment of minor health care problems. Each Commune has its own health clinic. Dai Tu Town has a hospital, but the facility is limited with no capacity for major medical surgeries or urgent care services. Seven hospitals in Thai Nguyen City specialise in tuberculosis, mental illness, and traditional medicine and in general are considered adequate for emergency medicine and some major surgeries. Advanced medical facilities and international level doctors are available in Hanoi;

• Police and Fire Protection – Law enforcement is covered with four divisions of authority through Provincial, District, Commune, and Ward services. There are about 100 police officers working at the Dai Tu District police station. Typically, there are two officers assigned per Commune and one per Ward. The nearest fire fighting service is in Thai Nguyen City; and

• Recreational and Public Facilities – Dai Tu District has eight football fields, two tennis courts, 80 badminton courts, a swimming pool, and a community centre. Public facilities in each commune typically include schools, health clinics, government buildings, and cultural halls of villages, prayer temples, and cemeteries.

3.3.8 Vulnerable and Disadvantaged Groups A key vulnerable group is the poor and, in particular, the extreme poor. The poor lack savings or assets that assist in coping through hardships, making them more vulnerable to changes such as natural disasters, market downturns, and loss of land or employment opportunities. The poor tend to be more severely impacted by these changes and take longer to recover. The poor often have lower levels of education and training due to the cost of such education resulting in their exclusion from employment opportunities. Additionally, the poor have less access to health services due to both formal and informal costs and typically suffer from more serious health conditions. Poor health exacerbates the vulnerability of poor families.

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Women are typically more vulnerable to livelihood changes due to fewer available employment opportunities and a higher reliance on agricultural activities. Additionally, women tend to have less access to education and training opportunities. Women of reproductive age, in particular, have been identified as a vulnerable group by government officials due to a high rate of reproductive health problems within this age bracket in the study area. Prostitution and domestic violence also contribute to women’s vulnerability. Ethnic minorities are disproportionately at risk of poverty and often live in the regions of slowest economic growth in Vietnam. Minorities have recently settled within the study area and are integrated into the local community. As such, these groups are not considered indigenous peoples. While social baseline data suggest that these groups are socially integrated ethnic minorities and may not be disproportionately vulnerable or disadvantaged, their unique social, cultural and economic characteristics and disadvantages will be taken into consideration in designing compensation measures for those affected by resettlement, and for local disclosure and participation in community development programmes. The loss of either land tenure or land access has been identified as a significant factor that affects the vulnerability and adaptability of households through loss of long-term income and food security. Loss of land can result in higher reliance on short-term, unreliable employment and can increase incentives for locals to be involved in environmentally damaging, dangerous, and unsustainable activities. In the study area, a number of cases were identified where loss of land or land access has forced people to shift their livelihood strategies to the exploitation of other kinds of natural resources, including brick making and artisanal mining. Resettled people who do not receive land equivalents are at a particularly high risk of future reliance on marginal activities. Environmental contamination creates conditions that increase local vulnerability and intensify impoverishment. These conditions may directly and indirectly increase households’ vulnerability to impoverishment through episodes of ill health, crop failure, agricultural price fluctuations, unstable employment opportunities, and natural disasters. Reductions or loss of agricultural productivity has caused some households in impacted areas to shift to different economic activities that further exacerbate resource sustainability, environmental contamination and human health issues in the local area, including artisanal mining and brick making.

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The majority of economic activities are physical, relying heavily on good human health, leaving the elderly, disabled, and infirm residents at an economic disadvantage. This group is particularly vulnerable to changes in livelihood activities that involve the loss of either land tenure or land access and increased reliance on the wage labour sector. 3.3.9 Public Attitudes and Perception A large percentage of the households surveyed consider their local environmental to have degraded in the past ten years. Many predict that this degradation will continue regardless of whether or not the Project is implemented. Artisanal mining and pesticide use on tea crops were the two most frequently reported causes for changes to the environment. Other factors included infrastructure development, inadequate management of solid waste, brick making, deforestation, and reforestation. Households were also asked to predict potential local impacts, both negative and positive, that could arise from the Nui Phao Mining Project. Nearly half of the residents interviewed predict that implementation of the Nui Phao Mining Project will have a positive effect in the local community. Job creation and economic growth were the two most commonly cited reasons. Other predicted benefits included improved living environment due to resettlement, improved infrastructure, increased revenues for the State, and improved environment. Negative predictions associated with Project implementation included the potential for increased water contamination, air and noise pollution, loss of land, increased competition for water resources, and a lack of jobs that can be filled by the local communities. Health problems, community disruption, “social evils,” inadequate compensation, disruption to communities, and in-migration challenges were also mentioned. 3.4 Project Description The Nui Phao Mining Project is a polymetallic deposit that will be mined using conventional open pit mining and mineral processing methods. The life of mine will be approximately 16 years based on an ore reserve of 55.7 million tonnes (Mt) and a mining and mineral processing production rate of 3.5 million tonnes per annum of ore. 3.4.1 Land Disturbance The Nui Phao Mining Project will directly affect 335 ha of land as follows:

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• Open Pit 91 ha; • Plant Site 20 ha; • Tailings Facility and Polishing Pond 111 ha; • Fresh Water Reservoir 10 ha; • Waste Rock Facility A 20 ha; • Waste Rock Facility B and C 75 ha; and • Low Grade Ore Stockpile 8 ha.

These disturbance areas are shown on Figure 3.6 and do not include the 110 ha buffer zone to the west of the open pit that was included as part of the resettlement programme boundary. The resettlement programme boundary therefore covers 445 ha, including the pit buffer zone requiring the residential relocation of 2,942 people (793 households) from the operational area and the 500 m buffer zone around the pit. Offsite development will include the road and rail realignment and relocation sites. 3.4.2 Construction Construction of the Nui Phao Mining Project will be accomplished under an Engineering, Procurement, and Construction Management (EPCM) contract. A Site Construction Plan (SCP) has been developed to address the specific actions and requirements to be executed under the EPCM Contract and the construction contracts. The SCP defines specific expectations that are applicable to the construction and development phase of the Project and requires that the EPCM Contractor prepare and administer comprehensive, proactive environmental, health, safety, and community relations policies for the contractors that will perform construction and development activities. The SCP obliges the EPCM Contractor to adhere to all commitments made in the ESIA/ESAP as well as the contractor-specific expectations defined in the SCP. Such responsibility will be extended to all construction contractors and suppliers. 3.4.3 Manpower Requirements Nuiphaovica has a conventional management structure consisting of both site and corporate management units. This organisational structure is further discussed in Section 4.2. The General Director of Nuiphaovica is ultimately responsible for all activities associated with the Nui Phao Mining Project. Peak manpower requirements during the construction period are estimated to be in the order of about 1,500 to 2,000 with the peak work force lasting up to six months. Once the mine is in operation, 474 employees will be required. A core expatriate staff will consist of approximately

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35 to 50 expatriates during peak times with as many as 70 to 80 staff members for short peak periods. The expatriate staff demand will be gradually reduced to two over the first four years of operations as Vietnamese staff takes on increasing roles of responsibility. Local residents will be preferentially considered for employment opportunities if they are: (1) directly impacted by the resettlement activities; (2) reside in the Communes of Ha Thuong, Phuc Linh, Tan Linh, Hung Son, Tien Hoi, Cat Ne and Quan Chu or Dai Tu Town; and (3) reside in Thai Nguyen Province and then other areas of Vietnam. Initially, most positions filled by local residents will be unskilled jobs but over time will include training programmes that allow employees to upgrade their abilities and skill base. Training will focus on skills and trades that are needed at the mine site such as welding, machinists, vehicle maintenance, and office skills. Nuiphaovica plans also to provide training and associated programmes as part of its economic restoration activities that benefit local residents even if they do not become employees of the mine. Programmes that have already been initiated under this initiative are introduced in Section 4.4.5. 3.4.4 Infrastructure The Project site is located approximately 80 km northwest of Hanoi and can be accessed by driving north on National Highway No. 3, which starts on the northeast outskirts of Hanoi, about 65 km to Thai Nguyen City, then 20 km west on National Highway No. 37 toward Dai Tu Town. A narrow gauge railway line presently passes through the Project site that is owned and used by Vinacoal to ship coal from the coal mine to various locations. Nuiphaovica will use the same narrow gauge rail line to transport concentrates from Nui Phao to the port of Quang Ninh or Hai Phong and also for importing Project supplies. The part of the rail line that runs through the Project area will be upgraded with loading facilities and relocated to the south of the Project area as shown on the General Site Layout. A 35 kV power line presently crosses through the Project area that will require relocation. Power feed to the plant site will be from an existing 110 kV power line that runs to the south of the Project area to the main substation located close to the main mineral processing area. From the main substation, power will be distributed around the site via pole line to the various Project components.

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Water will be supplied from a freshwater reservoir located south of the TSF. The average process water demand is estimated to be 931 m3/hour. Of this quantity, an estimated 853 m3/hour will be recycled from the TSF, and 78 m3/hr will be required as make up water sourced either from the freshwater reservoir or from the dewatering system in the open pit mine. An additional 15 m3/hr of potable water will also be required. A sewage treatment plant will be installed to treat domestic effluent from showers, toilets, sinks, and other grey water from the Project facilities. The plant will operate continuously and will effectively treat all sanitary wastes generated by the Project. Treated effluent will be discharged into the plant site sedimentation pond where it may be reused as process make-up water or released to the environment. A land-based telephone system will be the main mode of communication. In addition, a two-way radio system will be provided for communications within the mine, plant, and tailings areas; and a public address system will be provided for enclosed building. An air horn system will be used to warn people of blasting activities. 3.4.5 Topsoil Salvage Topsoil will be excavated and stored for future site rehabilitation. Soil stockpiles will be contoured during the operating phase so as to blend with the natural environment and stabilise with native vegetation. A perimeter trench, or other suitable sediment control device, will be constructed around the toe of each topsoil stockpile. At closure, these stockpiles will be excavated and used as cover material in the reclamation effort. As described in the baseline section, some soils in the area contain elevated levels of arsenic. This soil cannot be used for rehabilitation and will be collected and encapsulated in an engineered containment area within Waste Rock Facility B. The threshold value for arsenic removal is 1,000 parts per million (ppm) based on human health risk associated with occupational exposure. This will result in the removal and permanent encapsulation of about 2.7 Mt of arsenic-enriched soils. Execution of the arsenic remediation will be accomplished as described in the SCP and the Overburden Management Plan for Arsenic Rich Soils. For reclaimed areas, soils that have arsenic concentrations exceeding 50 mg/kg will be restricted from agricultural use post closure. Reclaimed land with arsenic less than 50 mg/kg will have no land use restrictions.

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3.4.6 Mining Operations The Nui Phao deposit will be mined as a single open pit with the operation of a fleet of new mining equipment consisting of large-scale drills, an excavator, a loader, and mine haulage trucks. Extraction of the 55.7 Mt ore reserve will require the production of 5.1 Mt of low grade ore that will be placed into stockpile and 110.2 Mt of waste rock and overburden that will either be used as construction material for tailings and reservoir construction, as aggregate for Project roads, or placed into one of three waste rock facilities. At a production rate of 3.5 million tonnes of ore per annum, the Project has an operating life of about 16 years. The majority of the overburden does not appear to require blasting and will be excavated to an overall slope of 35 degrees where the depth is less than 30 m or 30 degrees where the depth exceeds 30 m. In bedrock, which will require drilling and blasting, the pit will be excavated to internal pit wall slopes between 50 degrees and 55 degrees. A safety berm will be provided at the overburden/bedrock contact to catch any sloughing that may occur from the overburden and to provide access for cleanup. The pit will intercept water early in the mine life and will continue to intercept deeper aquifers as mining progresses. A dewatering system has been designed to handle groundwater inflows plus rainfall that could progressively result in as much as 140 litres per second being extracted from the mine in year 16. A model was developed to assess the drawdown cone at the final pit-dewatering rate, the results of which suggest a maximum cone of depression of 1.2 km from the pit centre. At closure, the water will be allowed to rebound, leaving a permanent pit lake. Overburden and waste rock to be produced by the mining process have been characterised as either potentially acid generating (PAG) or non-acid generating (non-PAG) waste and also for their potential to leach metals. Non-PAG material will be placed in one of three waste rock facilities or used as construction material for the tailings and water reservoir dams and as surface gravels in the general mine area. PAG material may be used as an internal dam construction material or deposited sub-aqueously within the sulphide tailings impoundment. The low-grade ore stockpile will contain PAG material that will be placed on a suitably lined pad where runoff water can be collected and treated as needed. At closure, waste rock facilities will be regarded and available topsoil placed and revegetated with an appropriate mix of plant species. The low grade ore will either be processed or excavated and placed into the STC, the liner system disposed of in an appropriate manner, and the area graded and vegetated.

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3.4.7 Mineral Processing The processing and concentrator facilities are designed primarily as open structures with the exception of the electrical rooms, the control room, shaker tables, and the concentrate drying and bagging area. All other equipment is provided with access lanes for a mobile crane to service them or individual monorails for maintenance where access for a mobile crane is restricted. At closure, all structures that are not needed to support the post-mining land use will either be dismantled and recycled or demolished and disposed of in on-site debris landfills. The process plant will produce separate concentrates of tungsten, fluorite and copper, and a bismuth cement product. It includes a three-stage crushing plant, crushed ore storage and reclamation, a two-stage grinding section followed by thickening; copper flotation, bismuth leaching from the copper concentrate, and copper concentrate dewatering and storage; bulk sulphide flotation; bismuth flotation, leaching, cementation, packaging; tungsten gravity recovery, upgrading, drying and bagging; fluorite flotation, concentrate dewatering and storage; and bismuth leach barren solution treatment. Figure 3.7 presents a generalised flow sheet of the mineral recovery process. The milling process will produce approximately 51.2 Mt of tailings in two distinct waste streams – sulphide tailings and oxide tailings, of which 15 Mt is sulphide tailings and 36.2 Mt is oxide tailings. Each of these two tailings streams will have distinctly different physical and geochemical properties. Sulphide tailings will be generated by the sulphide floatation circuit and are expected to contain on the order of 80 percent sulphide minerals, primarily pyrrhotite. Additional processing after the sulphide flotation process will result in the oxide tailings stream that is expected to be geochemically benign. Metalliferous sludge with soluble chloride from the bismuth leach solution treatment will also be produced. These wastes will be permanently placed into the TSF. 3.4.8 Tailings Storage Facility The TSF is located in the Doi Ba valley about 1 km to the southeast of the open pit. The TSF is comprised of four distinct components: an Oxide Tailings Cell (OTC), a Sulphide Tailings Cell (STC), a Fresh Water Reservoir located upstream of the tailings cells, and a Polishing Pond located downstream of the OTC (Figure 3.6). Within the OTC, an isolated lined pond area located on the west side will be reserved for disposal of the high-density bismuth effluent treatment sludge. Zoned earth fill embankments with thick saprolite cores, filters, transitions,

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and waste rock shells will separate each of these components. The main tailings dam, the secondary dam, and the separation dam will be stage raised over the mine life using materials obtained from the open pit to fully accommodate the 51.2 Mt of tailings that will be generated over the 16-year mine life. Both tailings streams will be delivered to the TSF in slurry form. The oxide and sulphide tailings will be managed separately and will employ different depositional strategies. The STC will fully contain all of the sulphide tailings produced by the Project. Sulphide tailings will be deposited under water via a mobile floating barge and spigot line in order to generate a relatively flat tailings mass that is fully submerged at all times during operations. This will limit the potential for oxidation of the stored reactive sulphides and consequent acid-forming reactions. Excess water from the STC will be recovered via a floating reclaim pump barge for reuse in the milling process. In addition to storing the sulphide tailings, the STC will also store all PAG overburden and waste rock from the open pit. The most reactive PAG rock and overburden will be placed directly underwater or submerged within a short time of its placement. PAG overburden, which is known to have lower sulphide concentrations, should be able to be stored above the operating pond level for several years without adversely affecting water quality. The STC is designed to maintain 2 m of water over the stored waste as well as the probable maximum precipitation (PMP) event without discharge to the OTC. The OTC will fully contain the oxide tailings and also the PMP event without discharge. Oxide tailings will be deposited from multiple discharge points along the perimeter of the OTC in order to develop sub-aerial beaches and to localise the ponded water away from the embankments. Bismuth treatment sludge will be disposed of in a dedicated and lined pond area on the northwest side of the OTC. Excess water from the oxide tailings pond will be recycled to the degree possible back to the oxide circuit in the mill or transferred to the Polishing Pond and Plant Site Runoff Pond for offsite release. At closure, about 1 million m3 of oxide tailings will be excavated from the OTC for placement in the STC. The oxide tailings will be placed using the same tailings deposition strategy as for the placement of sulphide tailings to provide a thick homogenous cover of relatively inert fill over

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the reactive sulphide tailings. The oxide tailings will act as a diffusion barrier and will allow the water cover to be removed and the STC reclaimed as a free-draining land surface. Tailings will be dredged from the OTC at the upstream face of the Main Tailings Dam, and the central portion of the dam crest will be lowered and regraded to function as a robust closure spillway. The dredging of the oxide tailings and spillway construction will enable the OTC tailings surface to be re-graded at closure and reclaimed as a free-draining land surface. 3.4.9 Freshwater Reservoir The Fresh Water Reservoir will collect runoff and direct precipitation from the catchment to the southeast of the TSF and will be the primary source of fresh water make-up for the process plant and to supply potable water needs for the employees. The reservoir will be left at closure as a permanent water source for the local communities. 3.4.10 Auxiliary Facilities Ancillary building construction for the Project will be a pre-engineered structure or concrete block construction facilities to accommodate the administration offices and warehouse building, truck repair shop and mine offices, assay laboratory, mess hall and kitchen, fire hall and first aid building, and gatehouse and security building. These facilities will be equipped as appropriate with water, sewer, electrical, communication, and other systems as appropriate. At closure, facilities that are not needed to support the post-mining land use will be either be salvaged for reuse elsewhere or demolished and buried in on-site debris landfills. 3.4.11 Waste Management Nuiphaovica will manage Project wastes in a manner that is considerate of environmental impacts and compatible with international best practice. Solid and hazardous waste landfills that are constructed onsite will meet generally accepted Vietnamese and international standards for containment systems and monitoring. The planned locations of such facilities are shown on Figure 3.6. Management and disposal facilities for each waste stream are described in the Project Waste Management Plan, which also defines the methods and procedures for the proper handling of all Project wastes, including:

• Mine process wastes, including mill tailings and process chemicals;

• Hazardous wastes, including waste oils, chemical containers, and medical wastes;

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• Industrial wastes, including inert wastes such as plastic, glass, industrial debris and construction materials; and

• Domestic (organic) wastes, including kitchen wastes, food and plant material and decomposable refuse.

3.4.12 Water Management A clear program for water management is needed to assure a continuous and reliable supply of potable and process water and to assure long-term submergence of sulphide tailings and PAG mine waste. Nuiphaovica has developed specific plans for addressing water supply and usage, providing for the appropriate management of surface runoff from site disturbances and for water abstracted from the open pit mine. These plans are presented in the Site Water Management, Final Feasibility Study Update and the Water Quality and Water Management Plan, Final Feasibility Study Update. A schematic of the water management system is shown on Figure 3.8. Based on current Project plans, it appears that water treatment will be required for the effluent from the bismuth circuit, and treatment may also be needed for runoff water from the low-grade ore stockpile. After settling of suspended solids in the various structures, water discharges from the TSF, open pit, and sediment control structures are expected to meet industrial effluent standards without further treatment. 3.4.13 Closure and Reclamation The objective of the closure and reclamation programme is to return mined lands to safe and stable landform that is compatible with the surrounding land uses. Concurrent reclamation of land disturbances will be accomplished as Project plans permit, and final closure and reclamation will be accomplished at the end of the Project life. A Conceptual Mine Closure Plan (CMCP) has been developed to further detail the elements of the closure and reclamation concepts presented earlier in this section. Based on current Project plans, the estimated cost to close and reclaim the Nui Phao Mining Project is US$9.1 million. Detailed plans and updated costs for Project closure and reclamation will be developed in advance of final Project closure. 3.5 Impacts and Mitigation Measures Mining projects inherently affect environmental and social resource values. Environmental and social impacts were analysed for the Nui Phao Mining Project by overlying the Project development plan onto the existing baseline conditions. For each resource identified in the

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environmental and social baselines, the Project development activities are briefly described within the context of each resource. The potential impacts are then predicted based on the perceived direct impact that the Project overlay will have on that resource. Engineering controls and mitigation measures are then identified for implementation in order to reduce the identified impact to acceptable levels. Environmental and socioeconomic impacts and mitigation measures were analysed for the following key environmental and social resources:

• Air Quality; • Aquatic Resources; • Noise; • Cultural Resources; • Visual Resources • Land and Natural Resource Use; • Topography and Land Forms; • Geology

• Livelihood Activities and Employment Opportunities;

• Soils; • Population; • Surface Water; • Public Health and Safety; and • Groundwater; • Flora;

• Infrastructure, Services, and Cultural Property.

• Fauna; The preceding table summarises the overall Project impacts for each resource discipline. The table presents three impact rankings for each of the following scenarios:

• To disclose Project impacts that would result if no mitigation measures were applied; • To disclose impacts over the short term with mitigation measures applied; and • To disclose Project impacts over the long term with mitigation measures applied.

Short-term impacts are those that will be realised during the construction, operations, and an active closure phase of the Project while Nuiphaovica is still resident at the site. Long-term impacts are those that will be realised after all closure and reclamation activities have been accomplished and Nuiphaovica is no longer attendant at the site. The impact assessment measured the potential effects on the physical and social environment as compared to the baseline conditions as described in Sections 3.2 and 3.3. The impact process included evaluating both positive and negative impacts on a scale that includes the following criteria:

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• A rating of neutral indicates that, with or without project development, there is no significant change in the baseline conditions;

• A rating of moderate indicates that there is a potential for the impact to affect the physical or social environment in an evident way as compared to the baseline conditions. Moderate impacts require mitigation and monitoring to evaluate the significance of the proposed action on baseline conditions; and

• A rating of significant are those impacts that when classified as negative are unacceptable and require appropriate mitigation to reduce their significance to either neutral (if possible) or moderate. A monitoring programme is required to assess the effectiveness of the mitigation. Additional mitigation measures may be necessary if those proposed are not sufficient. Positive significant impacts result from actions that will be taken as part of the community development plan that will promote sustainable development, or other measurable improvement to the socioeconomic well being of the people.

The impact assessment addresses the specific phases of the mine-life cycle from construction to closure. Nuiphaovica particularly recognises the immediate priority for the construction and operation phases and has provided a Site Construction Plan as part of the Environmental and Social Action Plan to provide more detail in this subject area. The above table identifies the environmental and social impacts by specific receiving media, offers a cross-reference to the specific discussion in the ESIA text, and also references the actions by which the mitigation measures will be implemented. This allows the ESAP to begin where the ESIA ends to carry out the systematic implementation of the mitigation and monitoring programmes and also the analysis of system performance, compare predictions made in the ESIA, and make adjustments as needed to ensure continuous improvement. Based on the above impact summary table, the following issues represent the key mitigation action items required to reduce environmental, health, safety, and social impacts to acceptable levels. The impacts have been grouped by significant major topic in order to focus the implementation efforts defined in the ESAP on actions that will:

• Reduce impacts to nearby neighbours by implementing specific safety programmes and controlling noise, dust, vibration, and night-time light;

• Reduce impacts to downstream water supplies by controlling surface water base flow and quality impacts as well as the quality and quantity of available groundwater;

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• Reduce impacts to Project employees and visitors by promoting worker health and safety and maintaining a clean and safe work environment, limiting occupational exposure to risks, and adequately managing wastes and emergency situations;

• Reduce impacts resulting from land use changes by implementing an effective closure and reclamation programme that re-establishes the land to an appropriate post-mining land use;

• Reduce impacts to resettled households by implementing livelihood restoration programmes, food security, and, to the extent practical and secure, the availability of agricultural land; and

• Reduce impacts to local communities by promoting economic diversification, controlling job-seeker influx and demands on infrastructure, and limiting physical hazards and the effects of social evils to the extent possible.

Controlling job seeker influx requires Nuiphaovica to collaborate closely with local government to implement management programmes that assist in directing in-migration patterns, and assist government in preparing target areas for in-migration (e.g., Dai Tu Town). Areas targeted to receive the anticipated influx of newcomers will be identified and a set of actions developed to ensure that newcomers are preferentially directed to these communities and that the communities will be prepared and able to receive them without experiencing hardship. Measures that discourage settlement in the immediate areas proximate to the Project site will include widely publicized recruitment and employment strategies that minimize the attraction of job-seekers to the Project area (e.g., locating recruitment centres and sessions outside of the local area, effective public disclosure on recruitment and employment policies). Community development programmes will also be used to develop and implement initiatives that aim to support general development and improvements in the standard of living of local residents, and thereby reduce adverse affects of population increases. Each of these mitigation categories will require specific actions to ensure their implementation and monitoring to document their performance. These mitigative actions are developed in the ESAP (Section 4.0). 3.6 Alternatives Alternatives analyses are conducted to evaluate the various siting, mining, and processing options relative to their direct and indirect effects on environmental and social circumstances. Inherent to

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the ESIA process, the proposed Project is compared to the No Action alternative as this alternative represents the existing baseline environmental and social conditions. 3.6.1 No Action Alternative The No Action alternative would leave the current site essentially in its existing condition. The high population density and low per capita income would remain the same with increasing land pressure and competition continuing to rise as the population grows in the area. Land degradation from artisanal mining would likely continue, as may the conversion of agricultural land to non-agronomically productive uses such as brick making. Employment opportunities in the region would remain unchanged. 3.6.2 Proposed Action Alternative The Proposed Action alternative is compared with the No Action alternative in the impacts, mitigation, and residual impact discussions as presented on the summary of impacts table. 3.6.3 Project Alternatives Several alternatives were considered during the planning process in arriving at Nuiphaovica’s proposed action. In each instance, alternative-screening criteria considered the potential for environmental and social impacts, regulatory compliance issues, and the ability of the alternative to meet corporate, community, and marketplace objectives. 3.6.3.1 Mine The Nui Phao deposit is located near the surface and will be mined using open pit methods because underground mining methods would not allow the safe and complete extraction of the mineral resource. 3.6.3.2 Mineral Processing Processing locations were selected in close proximity to the mine. Mineral processing methods were established though extensive metallurgical test work, resulting in the selection of conventional sulphide flotation techniques for the recovery of copper and bismuth mineral concentrates. Alternative recovery techniques for copper and bismuth were not tested, as conventional technologies that are sufficiently protective of the environment are preferred over more novel approaches. Testing was performed on bismuth effluent to reduce the recycle of chloride in the water.

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Tungsten is recovered mainly by gravity techniques using shaking tables with wash water. While this is a conventional technique, oxide flotation is often used for recovering tungsten. Tungsten recovery by an all-flotation technique was tested extensively for its capital cost benefits over a gravity circuit, but the gravity circuit was selected because the conditions necessary for successful tungsten flotation would adversely affect the fluorite flotation process. Other gravity techniques using spirals and centrifugal concentrators in combination with tables were also considered, but no environmental or metallurgical benefit was demonstrated to offset the additional cost. Fluorite is recovered from the tungsten gravity circuit tailings using oxide flotation techniques. No other fluorite recovery techniques were considered, as no alternative is available for the production of acid-grade, high quality fluorspar products. 3.6.3.3 Tailings Storage Five candidate tailings sites were evaluated in a pre-feasibility siting study. Three sites were found to be unsuitable due to insufficient storage capacity and/or because they posed an unacceptable risk to the mining operation. Two sites located southeast of the open pit were suitable, but the selected site was preferred over the other because of its closer proximity to the mine and mill. This site is amenable to implementing effective environmental controls, has fewer socio-economic impacts associated with involuntary resettlement, and has a lower capital and operating cost than the other viable tailings alternative. 3.6.3.4 Water Supply Supplementary water supply options include drilled wells, water reservoirs fed by stream diversions, and direct pumping from perennial rivers and streams. Nuiphaovica is currently investigating the possibility of pumping water from the Cong River to supply water to several relocation sites such as those that may be developed in Ha Thuong commune. In order to reduce the risk of insufficient fresh water supply to the mill, a take-off from the main line may also be led to the mill site to provide water. Current estimates of water requirements, should this alternative be required, would be on the order of 120 m3/hour. 3.6.3.5 Transportation Routes A transportation study was accomplished to evaluate the various access routes to the Project with a focus on minimising impacts to roads, limiting the potential for spills and accidents, and making use of existing but underutilised infrastructure and systems.

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3.7 Cumulative Impacts Cumulative impact analyses are based on anticipated future projects that will take place within the context of the Project area. These future projects or potential developments must be realistically defined and described at the time that the ESIA is undertaken. There is currently no known major development projects under consideration or pending regulatory review that are proximate to, reasonably foreseeable, or directly linked with the Nui Phao Mining Project. While Nuiphaovica has three gold exploration licenses, they are located in a different Province and are not in any way related to the Nui Phao Mining Project. As such, the ESIA represents the most current assessment of impacts associated with mining in this region. It is expected that a number of small and medium-sized enterprises will inevitably be established to provide goods and services to the Project and its extended supply chain. Nuiphaovica will encourage these programmes, and will provide training and assistance in their development as the represent sustainable opportunities for economic development of the area.

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4.0 Environmental and Social Action Plan The ESAP defines the management, mitigation, monitoring, and institutional measures to eliminate, offset, or reduce the environmental and social impacts of the Project to acceptable levels. It establishes the policies, commitments, and resources that are needed and assigns specific responsibilities to ensure effective implementation and continuation of the mitigation measures called for by the ESIA to reduce impacts to acceptable levels. It has been developed in accordance with applicable laws and regulatory requirements of the Government of Vietnam as well as the various environmental and social policies and performance standards established by the World Bank Group. 4.1 Management System Structure The ESAP takes over where the ESIA leaves off, focusing on the actions that must be implemented onsite to mitigate potentially significant adverse impacts to acceptable levels and also to maximise Project benefits. This ESAP is divided into a three-tiered management system:

• Level 1 is the overarching structure of the ESAP itself; establishing the management philosophy, corporate commitment, organisational responsibilities, and management systems that are needed to implement the training programmes, impact-mitigating actions, monitoring, and reporting required to demonstrate Project environmental and social performance;

• Level 2 includes the discipline-specific plans that expand on the impact-mitigating actions defined in the Level 1 ESAP, adds issue-specific detail to broad management disciplines, and further defines the concepts and actions that will be required to mitigate impacts to acceptable levels. Seven Level 2 plans are appended to the ESAP, which are discussed in Section 5.0. Two additional Level 2 plans for community development and economic restoration will be developed before the end of the year; and

• Level 3 presents standard operating procedures for accomplishing specifically defined tasks. These SOPs will be developed as Project construction gets underway and the need to establish clear safe job procedures for certain routine tasks becomes evident. Minimum level SOPs are identified throughout the ESAP to provide an indication of initial procedures required for effective management system implementation.

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4.2 Corporate Commitment and Management Responsibilities Nuiphaovica has established specific vision, commitment, and policy statements that define how it will conduct its business on the job site and in the local communities. Specific policy statements for the major disciplines of environment, occupational health and safety, community relations, and development and human resources are included as the lead-in pages to this document because they establish the targets toward which all ESIA/ESAP actions must focus. Responsibilities for the various programmes defined in the ESIA/ESAP are specifically assigned to the senior management team. The following organisation chart identifies the reporting structure and the specific responsibilities assigned to each manager. The General Director is ultimately responsible for all actions and implementation programmes called for by the ESIA/ESAP since all senior management staff report directly to the General Director.

Nuiphaovica Organisation Chart

Environment, Health and Safety Manager

Geology and ExplorationMine Engineering

RESPONSIBILITIES

Nuiphaovica Board of Directors

Thai Nguyen Import-Export Development CompanyThai Nguyen Minerals CompanyTiberon Minerals Ltd.

RESPONSIBILITIES

General Director

Mine Maintenance Manager

Deputy Directors

RESPONSIBILITIES

Information Technology Systems

Maintenance Area Training

HR Policy Compliance

AccountingPayroll

Port Supervision

Mill Area Training

External Relations Manager

Mine Area Training

RESPONSIBILITIES

RESPONSIBILITIES

RecruitingEHS Management System

MetallurgyLaboratory

Mill Production Power Supply

Maintenance Shop

Mining Manager Processing Manager

Finance ManagerHuman Resources Manager

Mechanical Systems

Process Engineering Maintenance Planning

General Site AdministrationReclamation

ResettlementWaste Management Medical Services/Supplies

Security

EHS ComplianceHR Regulatory Compliance

WarehousePurchasing

Public ConsultationStakeholder Liaison

RESPONSIBILITIESHR Management System

SurveyingDrilling and Blasting

Mine Production Mill Maintenance

Tailing Storage Facilty

Social Pgm Management SystemRESPONSIBILITIES

Environmental Training

Emergency Response

CommissaryEHS AuditsDispute Resolution

Employee RelationsSocial Program Training

Health & Safety Training

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4.3 Training Effective training of all employees is an important means to realising the corporate Vision and stated policy commitments. All employees will receive general health, safety, environmental, and social awareness training emphasising the employee’s responsibility for working safely and also complying with the environmental, social and occupational health and safety laws, regulations, and commitments as well as Nuiphaovica’s corporate policies and standards. Specific programmes will be developed for:

• Environmental Training – Will present overviews of Project environmental impacts, mitigation measures, monitoring and reporting programmes; principles of waste management and minimisation; procedures for responding to spills and emergency situations; and reclamation concepts and strategies;

• External Relations Training – Will review the commitments made in the Public Consultation and Disclosure (PCDP) and the RAP; present overviews of the social impacts, mitigation measures, monitoring and reporting programmes; orient workers to the company’s expected “social code of conduct;” and provide guidance on how to respond to community complaints or social unrest; and

• Occupational Health and Safety Training – Will address occupational hazards, safety procedures, evacuation routes, and fire fighting procedures, first aid, and emergency response situations. Task-specific training will be provided for each new job assignment.

All new employees will receive this training prior to receiving any work assignments. All employees will participate in annual refresher training classes to maintain currency with these principles. 4.4 Impact-Mitigating Actions and Monitoring Plans The summary of impacts presented in Section 3.5 represents the culminating effort of the ESIA process and establishes the priorities in defining the specific actions for the ESAP. The impact-mitigating actions and monitoring plans described in this section represent the Level 1 processes that are required to implement the mitigation measures called for by the ESIA to reduce potentially significant adverse environmental impacts to acceptable levels. For relevant impacts, reference is made to Level 2 discipline-specific plans (Section 5.0).

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Certain action plans are relevant to all phases of the Project, but some are phase-specific. The following table identifies the phases of the Project to which each of the actions presented in this section will be applicable.

Required Impact-Mitigating Actions by Project Phase

Section Impact-Mitigating Actions and Monitoring Construction Operation Closure Reducing Impacts to Nearby Neighbours 4.1.1.1 Tailings Storage Facility ■ ■ ■ 4.1.1.2 Waste Rock and Low Grade Facilities ■ ■ 4.1.1.3 Traffic Hazards ■ ■ ■ 4.1.2.1 Noise ■ ■ 4.1.2.2 Visibility ■ ■ 4.1.2.3 Light ■ ■ 4.1.3 Dust Suppression ■ ■ ■ 4.1.4 Blasting and Vibration ■ Reducing Impacts to Downstream Water Supplies 4.2.1 Base Flows from Site Development ■ 4.2.2 Sedimentation Control for Disturbed Areas ■ ■ ■ 4.2.3.1 Watershed Monitoring ■ ■ ■ 4.2.3.2 Source-Discharge Monitoring ■ ■ ■ 4.2.4 Groundwater Drawdown from Pit Dewatering ■ ■ Reducing Impacts by Promoting Worker Health and Safety 4.3.1.1 Natural Arsenic-Contaminated Soil Cleanup ■ 4.3.1.2 Occupational Noise Exposure ■ ■ 4.3.2 Managing Project Wastes Onsite ■ ■ ■ 4.3.3 Responding to Emergencies ■ ■ ■ Reducing Impacts from Land Use Changes 4.4.1 Site Closure and Reclamation Planning ■ ■ 4.4.2 Soil Salvaging for Future Reclamation ■ ■ 4.4.3 Post-Mining Land Restrictions ■ ■ Reducing Impacts to Resettled Households 4.5 Physical Resettlement (including compensation

measures) ■ ■ ■

4.5.1.1 Preferential Opportunities for PAP ■ ■ 4.5.1.2 Economic Restoration Programme ■ ■ ■ 4.5.2 Food Security ■ ■ ■ Reducing Impacts to Local Communities 4.6.1 External Relations and Public Awareness ■ ■ ■ 4.6.2 Preferential Hiring ■ ■ ■ 4.6.3 Local Procurement ■ ■ ■ 4.6.4 Community Development ■ ■ ■

Based on the impact summary presented in Section 3.5, the following issues represent what Nuiphaovica believes are the key mitigation action items required to reduce Project impacts to

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acceptable levels and the monitoring programmes that are required to document their implementation and performance. Impacts have been grouped by significant major topic in order to focus the implementation efforts on critical issues and/or receptors. 4.4.1 Nearby Neighbours The Project will affect a number of households through resettlement and withdrawal of land. The Vietnamese Government defined the resettlement area boundary that was withdrawn from public access to accommodate the mining Project in an effort to minimise overall Project land takes. Because the goal was to limit land takes to the maximum extent, there are many households located immediately outside the resettlement area boundary that will not be moved as part of the resettlement process. These residents have a significantly greater potential to be affected by the Project than other local residents due to their very close proximity to Project components and activities. Public Safety Residential areas in close proximity to mining operations are exposed to increased safety risks. These risks can be effectively managed as follows:

• Tailings Storage Facility – The TSF has been designed to international standards and exhibits factors of safety that meet or exceed international stability expectations for facilities of this type. In addition to specific monitoring commitments to ensure that the facility is constructed according to the engineering design, Nuiphaovica has engaged an independent panel of experts to monitor the construction of the facility to ensure its safety. Nuiphaovica will develop Level 3 SOPs for monitoring the facility on a routine basis, in between audits by the independent panel, to ensure that the facility is performing as designed;

• Waste Rock and Low Grade Facilities – The waste rock facilities have been designed for stability, and Level 3 SOPs will be developed and implemented to ensure that placement of waste into these facilities does not expose neighbours living close to these facilities to hazards associated with slope stability or falling rock. Placement of waste rock into the waste rock facilities will be under the direction of an appropriately qualified and trained person at all times to ensure safe and stable facility construction; and

• Traffic Hazards – Increased traffic at major points of Project access will require the implementation of effective traffic management policies and procedures to limit health and safety risks to nearby neighbours. Nuiphaovica will develop and enforce Level 3

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SOPs for safe driving, delivery scheduling, and hazard identification and emergency response to address these risks.

Public safety incidents with nearby neighbours will be tracked through specific monitoring programmes, public consultation, and public complaints. Aesthetics Neighbours living very close to the Project footprint are prone to be especially affected by aesthetic impacts associated with noise, visibility and nuisance light. These risks will be managed as follows:

• Noise – The activities associated with earthmoving, crushing, milling, equipment maintenance, and truck haulage are predicted to result in elevated noise at levels that exceed international guidelines, particularly in the plant area. While daytime noise will need to be managed, these noise levels will be especially noticeable at night. Level 3 SOPs will be developed to address delivery scheduling, vehicle maintenance, limiting high noise-producing activities to certain time periods, considering flashing backup lights on mobile equipment in lieu of backup alarms at night, and installing a noise attenuation berm or other suitable barrier along the eastern border of the plant site;

• Visibility – During daylight hours, plant infrastructure will be visible from certain vantage points. Buildings and major structures will be painted with a colour that blends with the surrounding landscape; and

• Light – Operations during night time hours will require lighting of major Project components to provide a safe work environment. The above-referenced noise attenuation berm will serve to intercept Project light to nearby receptors, and Nuiphaovica will use directional lighting where practical to reduce unnecessary light dispersion.

The public consultation and complaints programme will serve to identify local concerns associated with aesthetic issues and to identify additional mitigation measures that may be needed to address significant issues. Dust Suppression Nearby neighbours in close proximity to the Project activities will be most significantly affected by fugitive dust. Specific dust suppression programmes will be developed for controlling airborne particulate during soil and earthmoving activities including utilising efficient equipment; limiting

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trips; applying gravel, water, or stabilising agents; and limiting traffic speed. Level 3 SOPs and/or specific directives will be developed to define control programmes and responsibilities. Dust monitoring will be required during the movement of arsenic-contaminated soils in order to ensure that the activity does not expose nearby residents to unacceptable health risks from fugitive dust inhalation. It is noted that the Vietnamese government may require additional dust monitoring beyond that required for monitoring health risk. Blasting and Vibration Fly rock and vibration from blasting activities pose a risk to nearby neighbours. Nuiphaovica has included a 500-m setback around the maximum perimeter of the pit within the resettlement area boundary to limit these impacts to households. However, landowners will be allowed to continue to farm certain of these areas. Level 3 SOPs will be developed for notifying and clearing the area so that workers and the public are aware of when blasting activities will occur and for appropriate blasting procedures and timing. The public consultation programme and complaint process will serve to monitor the effectiveness of the control procedures. 4.4.2 Downstream Water Supplies Mining projects inevitably change the local hydrological balance. The Nui Phao Mining Project has the potential to affect the surface water quantity and quality available to downstream users and, while present studies indicate otherwise, also has the potential to affect nearby groundwater supplies due to drawdown associated with the open pit mining activities. Base Flows from Site Development During construction of the TSF, base flow in the Doi Ba watershed, which is tributary to the Lower Thuy Tinh, will be interrupted and collected for Project water use for a period of approximately 18 months. Timing of this interruption will take advantage of excess unutilised flow in the wet season, so it is expected that only one dry season (the important time) will be affected. Once the TSF is operable, water will be continuously discharged from the Project to re-establish the base flows. Impacts from this base flow reduction will be realised on the Lower Thuy Tinh Stream between the TSF and its confluence with Lower Cat Stream. The Thuy Tinh is an insignificant contributor to the Lower Cat, so mitigation downgradient of the confluence is not required. Nuiphaovica will work with water users in this stretch of the Thuy Tinh through the public consultation process to

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establish preferred methods for mitigating base flow reductions. Such measures may include selective release of Project waters, building one or more fresh water reservoirs in proximate watersheds, drilling groundwater supply wells, or providing alternate compensation for interrupted supplies. Sedimentation Control for Disturbed Areas Project disturbances have the potential to affect water quality available to downstream users associated with increases in sediment load without appropriate sedimentation control systems. Nuiphaovica will install appropriate sediment control structures downgradient from major Project components and will develop Level 3 SOPs to address drainage structure maintenance, cleanout procedures, the use of temporary control measures, and procedures for redirecting pond discharge during upset conditions. Water quality from the outfalls of each sedimentation control structure will be monitored on a regular schedule. Process and Site Water Discharges Water discharges from the TSF, sedimentation control structures, and the plant area are expected to meet the applicable standards for offsite discharge. The surface water monitoring programme will document the changes in water quality and quantity at key locations and, where possible, will profile the water conditions both up-gradient and downgradient from all Project-related activities to establish upstream and downstream controls. Consequently, the monitoring programme has been broken into two components:

• Watershed Monitoring – The Project footprint affects ten watersheds of varying sizes, each of which have been included in the watershed-monitoring programme. Samples will be collected at established locations for analysis of field parameters, chemistry, and flow;

• Source-Discharge Monitoring – This monitoring will directly track Project discharges to the environment. It will include direct offsite discharges from sedimentation ponds and from a single point discharge of the combined TSF and Plant Site Runoff Pond effluent. While not a direct discharge, the TSF Polishing Pond effluent will be monitored to identify changes in water chemistry as an early warning to compliance monitoring of the combined TSF and Plant Site Runoff Pond discharge; and

• Groundwater Monitoring – Nuiphaovica has installed a network of monitoring wells around the periphery of the open pit mine to monitor the effects of pit dewatering on groundwater resources and supplies. Also, selected residential water supply wells near

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the predicted pit drawdown cone will be monitored to complement the other programme. Two wells are positioned downgradient from the TSF to monitor tailings containment system performance.

Monitoring of watersheds, Project point-source discharges, and groundwater will be accomplished on a prescribed schedule based on the sensitivity of the situation being monitored and the data needs required for demonstrating compliance with established laws and international standards. 4.4.3 Worker Health and Safety Some soils within and proximate to the Nui Phao Mining Project contain naturally occurring elevated arsenic concentrations of arsenic and other heavy metals that are not directly associated with the ore deposit. In order to provide a safe and healthy work environment, Nuiphaovica will excavate soils with arsenic concentrations exceeding 1,000 mg/kg. Excavated soil will be hauled, placed, and covered in engineered cells within Waste Rock Facility B. It is also considered safe and sufficiently encapsulated to place these soils as selective fill material during the construction of the TSF. During this soil cleanup, it will be necessary to establish specific material handling and construction protocols and to establish dust monitoring to ensure a safe working environment. Dust control, the use of personal protective equipment (PPE), and maintaining effective sediment control measures will be required at both the place of excavation and place of disposal. Site access will be controlled during these activities, and workers involved with the cleanup must participate in a bio-monitoring programme to demonstrate the effectiveness of the controls and PPE. During remediation with PPE and after remediation without PPE, the arsenic exposure risk to site workers and nearby residents living proximate to the mine area are within the generally accepted range of risk for cancer and non-cancer potentials. An occupational noise survey will be accomplished once the Project is operational to identify areas where PPE is required to mitigate high noise exposures. Signs will be posted in those areas where workers must wear hearing protection. Hearing testing will be included as part of an annual employee health screening programme. Proper handling and disposal of Project wastes as well as implementing programmes to minimise waste generation is important to effective environmental management and in providing a safe and

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healthy workplace. In addition, improper disposal of petruscible wastes can attract rodents and other disease vectors that can adversely affect human health and the environment. The WMP (Section 5.5) is a Level 2 plan that provides a description of the waste repositories and processing facilities that are planned for the site and discusses the actions and procedures for handling and disposing of wastes in an appropriate manner. Establishing effective emergency response procedures along with employee training programmes can greatly reduce the severity and extent of impacts associated with accidental releases and upsets. These responses will limit worker and community exposure to hazardous situations or conditions and reduce the nature and extent of adverse environmental effects. The Emergency Response Plan (ERP) (Section 5.6) is a Level 2 plan that describes the programmes and procedures for responding to reasonably foreseeable emergencies and crisis situations. It anticipates spills or emergency situations that may occur based on current Project plans and provides direction on what to do and who is responsible to limit the severity of those accidents should they occur. 4.4.4 Land Use Changes Land pressure is significant in the Project region due to a high population density and land demand to support the mining operation. These competing demands make it important to implement effective reclamation strategies aimed at providing improved-productivity reclaimed land and, to the extent practical, land uses that provide sustainable food supplies. The CMCP (Section 5.7) presents a Level 2 discipline-specific plan for mine closure and reclamation. It calls for removal of buildings and structures, dry closure of the TSF, pit flooding, contouring and covering certain wastes with soil, and planting trees and other vegetation on reclaimed Project disturbances. Vietnamese law requires that a permanent closure plan be prepared prior to final termination of operations. Topsoil will be recovered for use in the reclamation process. Level 3 SOPs will be developed to define the process for clearing and grubbing vegetation, making waste wood products available to locals, salvaging and storing the topsoil, excavating a perimeter trench, and planting stockpiled soils with vegetation species to control erosion.

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Post-mining land uses will be restricted where natural soil arsenic concentrations exceed safe levels for residential and agricultural exposure. Based on a conservative screening level risk assessment, soils with arsenic concentrations below 50 mg/kg provide an acceptable long-term risk for residential and agricultural land. Nuiphaovica will identify reclaimed land that has arsenic concentrations exceeding 50 mg/kg. For those areas, land will be revegetated with forest products or other non-food-bearing vegetation. For those areas where the soil is less than 50 mg/kg, there will be no restrictions on the type of vegetation species that can be planted. Where arsenic concentrations in soils exceed 50 mg/kg, Nuiphaovica may implement demonstration areas to assess the viability of planting certain agricultural products on lands with varying arsenic concentrations in order to assess the metal uptake in each species being tested. This process may allow land use restrictions to be modified based on plant uptake and risk to humans through the food chain. 4.4.5 Resettled Households The Nui Phao Mining Project will require the residential relocation of 2,942 people (793 households) from the operational area and the 500 m buffer zone around the pit. Additionally, land required for relocation sites may require up to 331 people (83 households) to be resettled within their own communities. A further eight households will have their buildings affected by the relocation of cemeteries in Ha Thuong and for the army facility. Thus, a total of approximately 884 households have to be relocated or to rearrange their houses at relocation sites. It is noted, however, that these numbers will likely change as project details are further developed, relocation sites are assessed and confirmed, and as relocated resident preferences are further established. Residential relocation will involve the loss of residential land and houses. Involuntary resettlement of local populations can lead to disruptions to community structure and social networks, and loss of productive assets and income sources may cause long-term hardship, impoverishment, and environmental impacts unless appropriate measures are carefully planned and carried out. To minimise these potential impacts, Nuiphaovica has established its resettlement programme based on collaboration with the Vietnamese authorities with a focus on limiting the number of households that are disrupted through resettlement and on limiting the aerial extent of land that is taken out of agricultural production in favour of the new mining/industrial land use.

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Six candidate resettlement sites have been identified thus far through stakeholder consultation. Nuiphaovica is in the process of preparing environmental and social impact assessments on each of these resettlement sites and has completed one such study for Nam Song Cong, the largest of the candidate sites. It is noted that Nam Song Cong is sufficiently large as to accommodate all of the resettled households. It is located just south of the Cong River near Dai Tu Town. Income Restoration Loss of income associated with traditional livelihoods and the loss of access to agricultural land can be a direct outcome and significant impact associated with involuntary resettlement. This loss of productive assets and income sources will be mitigated through the implementation of:

• Preferential Opportunities for PAP – Where employment and training opportunities are preferentially directed first to the people who are directly affected by the resettlement activities and secondarily to residents of the communes of Ha Thuong, Phuc Linh, Tan Linh, Hong Son, Tien Hoi, Cat Ne and Quan Chu before other similarly-qualified candidates are considered from other locations; and

• Economic Restoration Programme – To restore and sustain household incomes through a combination of improved agriculture and alternate income sources. The updated RAP includes a preliminary economic restoration programme that will be further developed over time in cooperation with the Vietnamese government, lender/insurer representatives, social Panel of Experts, social programme expert, and other advisors. The programme will include detailed economic surveys of resettlement communities; identification of issues that affect food security, economic growth, or alternate incomes; the development of agro-economic models for intensification purposes; the development for alternate income and livelihood source models; and the preparation of detailed programme proposals including goals, objectives, implementation plans, budgets, schedules, and tools for monitoring and measuring success.

Nuiphaovica has already implemented the following economic restoration programmes with certain PAP who were directly impacted by the resettlement process:

• Pilot project for making toothpicks (13 PAP); • Mushroom farming (25 PAP); • Welder training (20 PAP); and • Garment programme (23 PAP).

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Preferential employment opportunities and the economic restoration planning for PAP are important commitments of the Project RAP. Food Security The loss of agricultural land is the primary economic impact to food security. This will have associated effects on crop yields from remaining land areas as land pressure increases and also on overall household livelihoods. Land-for-land resettlement is not feasible due to land shortages associated with local population density and needs to accommodate the mining operations. The economic restoration programme contained in the RAP will focus on income restoration programmes that re-establish food security through agricultural intensification programmes and alternative food supplies such as mushroom farming and aquiculture in the remnant pit lake. Also, initiatives to reduce post-mining land restrictions associated with arsenic in soils will further improve food security. 4.4.6 Local Communities Nuiphaovica seeks to establish partnerships with the affected communities, local interest groups, and other organisations in developing social programmes that will lead to ownership by the benefiting community. The philosophy is predicated on a sound community relations’ policy framework; respect for the culture, values and traditions of local communities; and transparency and multi-directional communications with all interested stakeholders. External Relations and Public Awareness Public awareness can benefit local communities to make better-informed choices regarding health, safety and waste management, and education. The Project can contribute to this education process by disseminating information through its public consultation programme on key local issues such as the health risks associated with arsenic-contaminated soils and drinking water and the adverse environmental effects of certain artisanal mining practises. Public Health Awareness In addition to providing information about the Project, the PDCP process can also advise on public health and safety issues, ways to limit arsenic exposure risk, ways to reduce environmental contamination, land rehabilitation techniques, skills training programmes, safety initiatives, and ways to protect against HIV/AIDS and other sexually transmitted diseases.

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Preferential Hiring As stated under the resettlement discussion, Nuiphaovica’s employment and training policies will preferentially benefit to those who are most affected by the Project: persons subject to resettlement and local residents of the directly affected communes. These commitments include preferential access to training opportunities, recruitment, and employment for individuals who officially reside in the communes of Ha Thuong, Phuc Linh, Tan Linh, Hung Son, Tien Hoi, Cat Ne and Quan Chu. Local Procurement In addition to preferential hiring of local workers, supporting local businesses provides direct secondary employment and is an important means of directly benefiting communities and building human and financial resources. Managers will develop and adopt business practises that aim to maximise local participation and benefit. Community Development Community development programmes will be selected and designed to address two main objectives: to complement the mitigation measures that are implemented to address potential social and economic impacts of mine operations and to achieve uplift and sustainable development to local target communities. Target stakeholders for development programmes will include the communes within which the Project resides, and also those communes that are affected by the resettlement process, including Ha Thuong, Phuc Linh, Tan Linh, Hung Son, Tien Hoi, Cat Ne, Quan Chu, and Nam Song Cong. Nuiphaovica will develop a Level 2 discipline-specific Community Development Plan (CDP) that defines the specific opportunities that the company has for investing in community development initiatives. The plan will address community development initiatives that may include agricultural intensification programmes, alternative skills development and training, formal education opportunities, micro-credit loans, medical infrastructure and service improvements, enhanced health care support, aquiculture programmes, drinking water supply, and other infrastructure improvements. It is noted that the CDP is intended to mitigate impacts to local communities and promote sustainable development in the region. It will be applicable to all communes that are directly affected by Project activities, including the communes affected by resettlement.

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Nuiphaovica will establish an independent steering committee that will take responsibility for developing and implementing the programmes defined by the CDP. The steering committee, which will be function as an independent entity but the programmes for which will be funded by Nuiphaovica, will be tasked with investigating other structures and mechanisms that may be more suitable over the longer term for administering the CDP programmes and funds as an autonomous and self-sustaining organisation with full fundraising capability. Nuiphaovica will establish and organise the steering committee and will provide funding for specific programmes as will be defined in the CDP based on Project profitability. 4.5 Sampling, Interpretation, and Reporting Each of the actions described in the previous section call for monitoring programmes that must be implemented to demonstrate actual site conditions and conformance with ESIA predictions. Based on the predicted environmental and social and the mitigation measures that are identified to reduce those impacts to acceptable levels, these monitoring programmes must be conducted in order to demonstrate that Project components will function within the limits of the environmental and social assessment. If the conditions identified through monitoring are outside established limits, then additional impact evaluation and mitigation programmes may be required. Sampling, data interpretation, and corrective actions are intended to track the performance of the various Project components and mitigative systems. When these programmes are implemented at the site, they will provide the data and information needed to identify, anticipate, and further mitigate the changing environmental and social conditions at the site over time. Threshold levels at which corrective actions will be taken were based upon process parameters in relation to mining operations or, in the case of environmental media, according to data collected during the baseline evaluations. If insufficient data were collected during the previous baseline evaluations, data collected from the proposed monitoring programmes will be used to define threshold levels for air quality and social impacts and to update the water quality thresholds if necessary. Quarterly reports will be prepared as required by the local authorities, and an annual report on the environmental, health, safety, and community programmes will be prepared. The Environment, Health, Safety and Community (EHSC) Annual Report will describe all significant EHSC incidents in the reporting period, summarise monitoring programme performance, define any

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violations of laws, reconcile land disturbance relative to the reclamation cost estimate, Project land disturbances and reclamation cost for the coming year, summarise new permits required or those due to expire in the coming year, and describe any changes to the EHSC programme in the coming year. As a means of independently confirming the adequacy of internal programmes, Nuiphaovica will submit to independent audits of its activities every three years. These audits will be in addition to the more frequent independent assessments of the social programmes by the POE and the tailings facility by the ITRP. These audits will provide an independent assessment of the adequacy and accuracy of the environment, health, safety, and community programme; advise on the status and effectiveness of each action plan in tracking actual Project performance; assess the effectiveness of each action plan’s ability to make changes in the management process when site conditions at the operating site deviate from those predicted by the ESIA; and recommend modifications to upgrade or improve any of the plans, monitoring, and/or remediation programmes if necessary. 4.6 Transparency Public consultation is an important means of maintaining transparency of health, safety, environmental, and social programmes. Nuiphaovica will proactively solicit input from local communities and other interested stakeholders through informal consultation meetings, disclosure activities, and other engagement and media interactions. Project information materials will be available, and meetings will be held as needed to keep local communities apprised of the activities that will be occurring onsite and the timing of their occurrence. Stakeholders will be advised of the environmental, health, safety, and community impacts associated with those activities and ways to limit their exposure to adverse impacts and mechanisms to enhance their access to Project benefits. Beyond public consultation, Nuiphaovica has organised an Information Network Group to provide grassroots multi-directional communication with the local communities on a continual basis. The Group distributes Project information such as fliers or meeting notices to local residents and directs inquiries about the Project to the Project Information Centre. The Project Information Centre is staffed by individuals trained to respond to questions from the public and address their complaints to the appropriate Nuiphaovica managers. The Centre is equipped with Project documents and information and provides notification of certain activities that will occur and what the effects are expected to be during Project execution.

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The EHSC Annual Report represents another vehicle of transparency that will be shared through the Project Information Centre and to government agencies and interested stakeholders. It may also be posted on a Nuiphaovica website. The EHSC Annual Report will disclose significant environmental, health and safety, and social incidents that occurred during the reporting period and will reconcile the performance of monitoring programmes, compliance issues, and anything that may be considered important to understanding the activities and performance of these programmes. 4.7 Complaints Mechanisms The PCDP describes the overall system for managing complaints and grievances for the Project. The aim is to register and adequately respond to complaints and grievances that arise from both the resettlement programs and PAP, and the community issues and concerns of Affected/Host Communities and other affected stakeholders. 4.8 Cost and Implementation An implementation schedule and budget was developed so that mitigation programmes occur at the appropriate times during Project development and execution and to ensure that adequate resources are allocated to mitigation and monitoring programmes. The provisional cost for the environmental, social, health and safety programmes is US$2.6 million with operating costs on the order of US$0.6 million. The ESAP will be integrated into the overall Project planning, scheduling, and budget decisions to help ensure that adequate levels of funding and supervision are allocated to each programme.

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NUI PHAO MINING JOINT VENTURE COMPANY LIMITED NUI PHAO MINING PROJECT ESIA/ESAP

ENVIRONMENTAL AND SOCIAL ACTION PLAN IMPLEMENTATION SCHEDULE AND BUDGET

Estimated Costs ($US x 1000)

Document Responsibility Description Reporting Timing of

Implementation Provision

Recurrent (annual)

ESAP Section 5.1 Section 5.2

Environment, Health and Safety Manager; External

Relations Manager

Sampling programmes, data collection and interpretation,

corrective action

Include with EHSC Annual Report

Ongoing as per Table 4.1 throughout

Project life 59 137

ESAP Section 5.3.1

Environment, Health and Safety Manager

Quarterly EHSC Report Submit Plan to

Government Agencies, as required

Quarterly throughout Project life

20

ESAP Section 5.3.1

Environment, Health and Safety Manager

EHSC Annual Report Submit to Govt/Lenders for review/approval as

required

Annually throughout Project life (due by April 30 each year)

10

ESAP Section 4.5.1.1 Section 4.6.1

Human Resources Manager; External Relations Manager

Priority hiring of Project Affected Persons and persons from 4

affected communes

Internal document, will be available for review on

request

Ongoing throughout Project life

5

ESAP Section 4.6.1

External Relations Manager

Public consultation programmes Include with EHSC

Annual Report Ongoing throughout

Project life 75 30

ESAP Section 4.6.3

General Director; all Managers

Procurement programmes aimed at sourcing materials/supplies from local providers if possible

Internal document, will be available for review on

request

Ongoing throughout Project life

2

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ESAP Section 4.5

RAP

External Relations Manager

Panel of Social Experts to review/audit RAP process

Submit to Govt/Lenders for review/approval as

required

Two times per year until resettlement is

complete 60

ESAP Section 4.1.1.1

Processing Manager Independent review of tailings

facility design and construction by ITRP

Include with EHSC Annual Report

Three times per year during construction

(to start) 120

ESAP Section 4.5

External Relations Manager

Complete environmental impact assessments on candidate

resettlement sites

Submit to Govt/Lenders for review/approval as

required

Ongoing until complete

100

ESAP Section 4.6.5

Environment, Health and Safety Manager

Relocation of cemeteries and religious facilities according to the

RAP (Note 2)

Include with EHSC Annual Report

Ongoing until complete

100

ESIA Section 2.7

Environment, Health and Safety Manager

Correllate changes beteween the approved EIA and this ESIA/ESAP

Submit report to Vietnamese Government

May 2006 20 5

ESAP Section 2.4

General Director Staffing of key positions Advise key positions on

organization chart updateJune 2006 25 5

ESAP Section 4.5

RAP

External Relations Manager

Update RAP boundaries with new footprint, modifications to existing

RAP (Note 2)

Submit to Govt/Lenders for review/approval as

required June 2006 75 20

ESAP Section 4.5.1.2

RAP

External Relations Manager

Develop and implement economic restoration programme (Note 2)

Submit to Govt/Lenders for review/approval as

required August 2006 150 10

ESAP Section 4.6.4

External Relations Manager

Prepare initial CDP Submit to Govt/Lenders for review/approval as

required September 2006 50 10

ESAP Section 4.2.1

EPCM Contractor; Environment, Health and

Safety Manager

Identify and provide alternate water sources to downstream users during TSF construction

Include with EHSC Annual Report

October 2006 150

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ESAP Section 4.3

EPCM Contractor; Environment, Health and

Safety Manager

Update OHSP to reflect site conditions and hazards during

construction

Internal document, will be available for review on

request October 2006 20 2

ESAP Section 4.3.2

SCP

EPCM Contractor; Environment, Health and

Safety Manager

Update WMP to reflect waste plans during construction

Internal document, will be available for review on

request October 2006 30 2

ESAP Section 4.6.4

External Relations Manager

Establish and organize steering committee for implementing CDP

Submit to Govt/Lenders for review/approval as

required October 2006 30

ESAP Section 3.0

Environment, Health and Safety Manager; External

Relations Manager

Safety and environmental trainingprogrammes

Internal document, will be available for review on

request November 2006 50 10

ESAP Section 4.1.1.1

Processing Manager Final tailings dam engineering

design by qualified geotechnical engineer

Submit to Govt/Lenders for review/approval as

required November 2006 250

ESAP Section 4.1.1.3

Environment, Health and Safety Manager

Level 3 SOPs for traffic controls and vehicle safety

Internal document, will be available for review on

request November 2006 2

ESAP Section 4.1.3

EPCM Contractor; Mining Manager; Processing

Manager Level 3 SOPs for dust control

Internal document, will be available for review on

request November 2006 2

ESAP Section 4.2.2

Environment, Health and Safety Manager; Mining

Manager

Level 3 SOPs for sedimentation control structure maintenance

Internal document, will be available for review on

request November 2006 2

ESAP Section 4.3.2

Environment, Health and Safety Manager

Level 3 SOPs for waste disposal activities

Internal document, will be available for review on

request November 2006 2

ESAP Section 4.4.2

Operations Managers and Environment, Health and

Safety Manager

Level 3 SOPs for topsoil salvage and storage

Internal document, will be available for review on

request November 2006 2

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ESAP Section 4.1.1.2

Mining Manager Level 3 SOPs for waste facility construction, safety, material

placement, geochem monitoring

Internal document, will be available for review on

request December 2006 2

ESAP Section 4.1.2

EPCM Contractor; Environment, Health and

Safety Manager

Construct noise/light/vision attenuating device east of plant

site

Include with EHSC Annual Report

December 2006 30

ESAP Section 4.1.4

Mining Manager Level 3 SOPs for notification of

blasting actions

Internal document, will be available for review on

request December 2006 2

ESAP Section 4.1.2.1

Environment, Health and Safety Manager

Level 3 SOPs for limiting noise impacts to nearby neighbours

Internal document, will be available for review on

request January 2007 2

ESAP Section 4.3.1

Environment, Health and Safety Manager

Implement employee medical monitoring programme (As, noise)

Internal document, will be available for review on

request January 2007 30 2

ESAP Section 4.6.4

External Relations Manager

Fund CDP Initiatives Steering committee to

track contributions January 2007 100

to be defined in CDP

ESAP Section 4.1.2.2

Processing Manager Painting buildings and

infrastructure a color that blends with surrounding landscape

Include with EHSC Annual Report

June 2007 15

ESAP Section 4.3.1.1

EPCM Contractor; Environment, Health and

Safety Manager

Cleanup of arsenic contaminated soils; Level 3 SOPs as appropriate

Include with EHSC Annual Report

December 2007 500 2

ESAP Section 4.3.3

SCP

Environment, Health, and Safety

Manager

Update ERP based on Project construction plans

Submit to Govt/Lenders for review/approval as

required December 2007 20 2

ESAP Section 1.1

Environment, Health, and Safety

Manager

Update ESAP to reflect as-built conditions at the end of

construction

Submit to Govt/Lenders for review/approval as

required January 2008 35 5

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ESAP Section 4.4

Environment, Health, and Safety

Manager

Update CMCP based on as-built Project layout (Note 1)

Submit to Govt/Lenders for review/approval as

required March 2008 20 2

ESAP Section 4.1.1.1

EPCM Contractor; Processing Manager

Tailings facility construction QA/QC by qualified geotechnical

engineer

As-Built report for inclusion in EHSC Annual

Report June 2008 400

ESAP Section 4.1.1.1

Processing Manager Level 3 SOPs for ongoing tailings deposition, monitoring, and water

management

Internal document, will be available for review on

request June 2008 3

ESAP Section 4.1.1.1

Processing Manager Prepare tailings facility Operation,

Maintenance and Surveillance Manual

Internal document, will be available for review on

request June 2008 40

ESAP Section 4.4.1

Environment, Health and Safety Manager

Level 3 SOPs for concurrent reclamation activities

Internal document, will be available for review on

request October 2008 2

ESAP Section 4.4.3

Environment, Health and Safety Manager

Implement demonstration plots for reclamation options on elevated

arsenic soils (if needed)

Internal document, will be available for review on

request March 2009 30 5

ESAP Section 5.3.2

General Director Independent EHSC Audit Submit Audit to

Nuiphaovica President and Board of Directors

Every 3 years 15

ESAP Section 4.4.1

Environment, Health and Safety Manager

Permanent closure plan (Note 1)Submit to Govt/Lenders for review/approval as

required

Year 14 (at least 2 years before

permanent closure) 125

Note 1: The estimated capital cost for closure and reclamation is US$9.7 million Note 2: The estimated cost for implementing all aspects of the Resettlement Action Plan and its component plans is in the order of US$26 million

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5.0 Discipline-Specific Action Plans The ESAP incorporates a number of documents for developing, managing, and reclaiming the mine. These Level 2 plans represent the next level of detail over the management systems presented in the ESAP. As with the ESAP, each discipline-specific plan is considered a living document requiring periodic updates to ensure that it accurately reflects timely site conditions. 5.1 Public Consultation and Disclosure Plan Nuiphaovica has prepared a PCDP that describes how it will collect and disseminate information with people who are interested in and/or affected by the Project. The programme set out in the PCDP aims to provide real opportunities for stakeholders to actively participate in Project development. The PCDP establishes the basis for how Nuiphaovica will conduct its business with the community and how complaints and grievances will be managed. If implemented as presented, the PCDP will ensure transparency in Project activities as they may affect the health, safety, and environmental conditions. 5.2 Resettlement Action Plan Nuiphaovica recognises that involuntary resettlement of local populations can lead to economic, social, and environmental concerns. Disruptions to community structure, social networks, and loss of productive assets and income sources may cause long-term hardship, impoverishment, and environmental impacts unless appropriate measures are carefully planned and carried out. The RAP presents the detailed programme for relocating individuals who will be displaced by Project development. It also includes an economic restoration programme for re-establishing the livelihoods of those individuals who are affected by the resettlement. A total of 793 households and 2,942 individuals will have to be relocated under the provisions of the RAP. These numbers will likely change as project details are further developed, relocation sites are assessed and confirmed, and as relocated resident preferences are further established. A budget in the order of US$26 million has been allocated for the resettlement process and for moving a government military base. It is noted that the RAP and its economic restoration programme is applicable only to individuals and communes that have had their homes and/or their land displaced by Project implementation.

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5.3 Occupational Health and Safety Plan Nuiphaovica believes that the health and safety of its employees, contractors, and visitors are a primary concern during all stages of mining activities including exploration, construction, operations, and decommissioning. To this end, Nuiphaovica has developed a dedicated Occupational Health and Safety Plan (OHSP). This OHSP has been prepared to detail the Nuiphaovica commitment to compliance with applicable laws and regulations of the jurisdictions in which it operates and the implementation of the procedures to provide a healthy and safe working environment for all employees. The OHSP also sets out training and equipment needs to carry out work safely and monitoring and reporting requirements to assess health and safety performance. 5.4 Site Construction Plan The SCP summarises the predicted impacts, proposed mitigation, and expected or required actions that may be encountered during the construction phase of the Project. It presents a broad management strategy that focuses only on the construction phase of the Project that will be handed over to the Engineering, Procurement, and Construction Management (EPCM) contractor and other contractors as appropriate to summarise their specific site responsibilities with respect to environment, health, safety, and community relations concerns. It obliges the EPCM contractor to establish its own policies and plans to conform to Nuiphaovica’s stated policies and extends the responsibilities and actions that Nuiphaovica has committed to in the ESIA and ESAP to be equally applicable to the EPCM contractor and its subcontractors during the construction phase of the Project. 5.5 Waste Management Plan The WMP details the handling, storing, and disposing of wastes that are generated by Project activities. The WMP also addresses the management of wastes designated for special handling including hazardous and emergency response wastes and sewage as well as the minimisation of waste through recycling programmes. The WMP will require updating as the Nui Phao Mining Project progresses to reflect site-specific conditions. 5.6 Emergency Response Plan The ERP was developed to outline the process for responding to emergencies, including accidental spills and releases, fires, explosions, and medical emergencies. It is designed to minimise employee exposure to risk and injury and limit potential impacts to the environment

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and the community in emergency situations. The ERP identifies training programmes for emergency recognition and prevention, methods and procedures for alerting onsite employees, resources for medical and emergency treatments, and procedures for containment and clean-up of accidental spills. 5.7 Conceptual Mine Closure Plan The CMCP outlines the general programme for closure and reclamation of the Nui Phao Mine. Nuiphaovica plans to concurrently reclaim disturbed areas where feasible and will reclaim Project disturbances to a suitable post-mining land use. The Plan adheres to generally accepted rehabilitation criteria and focuses on both physical and chemical stabilisation of the site. Reclamation strategies for disturbances have been included, and a reclamation budget of approximately US$9.1 million has been estimated based on these strategies and procedures for site closure and reclamation.

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6.0 Conclusion This Executive Summary presents the salient results of the Nui Phao Mining Project Environmental and Social Impact Assessment and Environmental and Social Action Plan. These Plans identify the specific actions that Nuiphaovica believes are required to ensure that the health, safety, environmental, and social programme performances are in line with international mining best practise. The ESIA has identified several potential environmental and social impacts, the mitigation measures for which may be broadly categorised as reducing adverse impacts associated with nearby neighbours, downstream water users, worker health and safety, land use changes, resettled households, and local communities. The ESAP has defined the specific actions that must occur to implement these mitigation measures and who is responsible for their implementation. It also defines specific monitoring programmes aimed at documenting the implementation and adequacy of control systems and mitigation measures and the reporting that is required to ensure transparency. With the effective implementation of the mitigation measures and monitoring programmes defined in the ESIA/ESAP and with periodic updates to the ESAP and discipline-specific action plans, Nuiphaovica can indeed limit the adverse impacts of the Nui Phao Mining Project to acceptable levels and conform to a standard that is generally accepted as international best practise in the global mining community. It is noted that all references associated with the information presented in this Executive Summary are cited in the ESIA, the ESAP, and each discipline-specific action plan text.

Page 93: Nui Phao Mining Joint Venture Company Nui Phao Mining ......Nui Phao Mining Project ESIA/ESAP Executive Summary Volume I June 2006 Prepared for Nui Phao Mining Joint Venture Company

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E

E

E

EE

E

EE

EE

E

E

E

E

E

E

E

EE

E

EEE

E

EE

E

E

E

E

EE

E

EE

E

E

E

EEE

E

EE

E

EE

EE

E

E

EE

E

E

E

EE

E

E

E

E

EE

E

E

EE

E

E

E

EE

EE

E

E

E

E

E

E

E

E

E

EE

E

E

E

EE

EE

E

E

E

E

EE

E

E

E

E

EE

E

E

E

E

E

EE

E

E

E

EEE

E

EE

E

EE

E

E

E

EE

E

E

E

EE

E

E

E

E

E

E

E

EE

E

E

EEE

E E

E

EE

E

E

E

E

E

E

EEE

E

E

E

E

E

E

E

E

E

E

E

E

E

E

E

E

EE

EE E E

E

E

E

E

EE

EE

EE

E

E

E

E

567000

567000

568000

568000

569000

569000

570000

570000

571000

571000

572000

572000

2392

000

2392

000

2393

000

2393

000

2394

000

2394

000

2395

000

2395

000

2396

000

2396

000

Base Data - Projection - Gauss Krueger, Pulkovo 1942, Zone 18

REFERENCE

³ LEGEND

0 250 500 750 1,000 1,250125

Meters

Arsenic (ppm)< 50

50.1 - 100

100.1 - 150

150.1 - 200

200.1 - 250

250.1 - 300

300.1 - 350

350.1 - 400

400.1 - 450

450.1 - 500

500.1 - 550

550.1 - 600

600.1 - 650

650.1 - 700

700.1 - 750

750.1 - 800

800.1 - 850

850.1 - 900

900.1 - 950

950.1 - 1,000

1,000.1 - 1,050

1,050.1 - 1,100

1,100.1 - 1,150

1,150.1 - 1,200

1,200.1 - 1,250

1,250.1 - 1,300

1,300.1 - 1,350

1,350.1 - 1,400

1,400.1 - 1,450

1,450.1 - 1,500

1,500.1 - 1,550

1,550.1 - 1,600

1,600.1 - 1,650

1,650.1 - 1,700

1,700.1 - 1,750

1,750.1 - 1,800

1,800.1 - 1,850

1,850.1 - 1,900

1,900.1 - 1,950

1,950.1 - 2,000

2,000.1 - 2,050

2,050.1 - 2,100

2,100.1 - 2,150

2,150.1 - 2,200

2,200.1 - 2,250

2,250.1 - 2,300

2,300.1 - 2,350

2,350.1 - 2,400

2,400.1 - 2,450

2,450.1 - 2,500

> 2,500

Mine Footprint

REV. 0 18APR'06 ISSUED FOR REPORT

ARC

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NUI PHAO MINING PROJECT

NUI PHAO MINING JOINT VENTURE COMPANY

DISTRIBUTION OF ARSENICIN THE SOILS

Project/Assignment No

Rev.VA702-9/1

0

-Ref. No

FIGURE 3.1

Note: Original figure created by Golder Associates 2005.

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NUI PHAO MINING PROJECT

VEGETATION CLASSIFICATION

REF NO. REV.PROJECT / ASSIGNMENT NO.VA702-9/1 - 0

FIGURE 3.4

Doi BaDoi BaDoi BaDoi BaDoi BaDoi BaDoi BaDoi BaDoi BaBasinBasinBasinBasinBasinBasinBasinBasinBasin

Tin ValleyTin ValleyTin ValleyTin ValleyTin ValleyTin ValleyTin ValleyTin ValleyTin Valley

Doi NamDoi NamDoi NamDoi NamDoi NamDoi NamDoi NamDoi NamDoi NamBasinBasinBasinBasinBasinBasinBasinBasinBasin

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

StreStreStreStreStreStreStreStreStre

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

StreamStreamStreamStreamStreamStreamStreamStreamStream

CongCongCongCongCongCongCongCongCong

RiverRiverRiverRiverRiverRiverRiverRiverRiver

BatBatBatBatBatBatBatBatBat

Stre

amSt

ream

Stre

amSt

ream

Stre

amSt

ream

Stre

amSt

ream

Stre

am

2 393 000N2 393 000N2 393 000N2 393 000N2 393 000N2 393 000N2 393 000N2 393 000N2 393 000N

18 571 000E18 571 000E18 571 000E18 571 000E18 571 000E18 571 000E18 571 000E18 571 000E18 571 000E

18 570 000E18 570 000E18 570 000E18 570 000E18 570 000E18 570 000E18 570 000E18 570 000E18 570 000E

18 569 000E18 569 000E18 569 000E18 569 000E18 569 000E18 569 000E18 569 000E18 569 000E18 569 000E

18 568 000mE

18 568 000mE

18 568 000mE

18 568 000mE

18 568 000mE

18 568 000mE

18 568 000mE

18 568 000mE

18 568 000mE

2 394 000N2 394 000N2 394 000N2 394 000N2 394 000N2 394 000N2 394 000N2 394 000N2 394 000N

2 395 000N2 395 000N2 395 000N2 395 000N2 395 000N2 395 000N2 395 000N2 395 000N2 395 000N

2 396 000mN2 396 000mN2 396 000mN2 396 000mN2 396 000mN2 396 000mN2 396 000mN2 396 000mN2 396 000mN

NUI PHAO MINING JOINT VENTURE COMPANY

Regenerating Broadleaf Regenerating Broadleaf Regenerating Broadleaf Regenerating Broadleaf Regenerating Broadleaf Regenerating Broadleaf Regenerating Broadleaf Regenerating Broadleaf Regenerating Broadleaf Evergreen Secondary ForestEvergreen Secondary ForestEvergreen Secondary ForestEvergreen Secondary ForestEvergreen Secondary ForestEvergreen Secondary ForestEvergreen Secondary ForestEvergreen Secondary ForestEvergreen Secondary Forest

Mixed Bamboo - Broadleaf Mixed Bamboo - Broadleaf Mixed Bamboo - Broadleaf Mixed Bamboo - Broadleaf Mixed Bamboo - Broadleaf Mixed Bamboo - Broadleaf Mixed Bamboo - Broadleaf Mixed Bamboo - Broadleaf Mixed Bamboo - Broadleaf Evergreen ScrubsEvergreen ScrubsEvergreen ScrubsEvergreen ScrubsEvergreen ScrubsEvergreen ScrubsEvergreen ScrubsEvergreen ScrubsEvergreen Scrubs

Mixed Tea and Forest trees Mixed Tea and Forest trees Mixed Tea and Forest trees Mixed Tea and Forest trees Mixed Tea and Forest trees Mixed Tea and Forest trees Mixed Tea and Forest trees Mixed Tea and Forest trees Mixed Tea and Forest trees (Acacia,Eucalyptus, etc) (Acacia,Eucalyptus, etc) (Acacia,Eucalyptus, etc) (Acacia,Eucalyptus, etc) (Acacia,Eucalyptus, etc) (Acacia,Eucalyptus, etc) (Acacia,Eucalyptus, etc) (Acacia,Eucalyptus, etc) (Acacia,Eucalyptus, etc)

Mixed Tea PlantationMixed Tea PlantationMixed Tea PlantationMixed Tea PlantationMixed Tea PlantationMixed Tea PlantationMixed Tea PlantationMixed Tea PlantationMixed Tea Plantation

Plantation of Acacia, Eucalyptus, Plantation of Acacia, Eucalyptus, Plantation of Acacia, Eucalyptus, Plantation of Acacia, Eucalyptus, Plantation of Acacia, Eucalyptus, Plantation of Acacia, Eucalyptus, Plantation of Acacia, Eucalyptus, Plantation of Acacia, Eucalyptus, Plantation of Acacia, Eucalyptus, Peltoforum, Cassia, etc.Peltoforum, Cassia, etc.Peltoforum, Cassia, etc.Peltoforum, Cassia, etc.Peltoforum, Cassia, etc.Peltoforum, Cassia, etc.Peltoforum, Cassia, etc.Peltoforum, Cassia, etc.Peltoforum, Cassia, etc.

Agricultural crops (rice, corn, Agricultural crops (rice, corn, Agricultural crops (rice, corn, Agricultural crops (rice, corn, Agricultural crops (rice, corn, Agricultural crops (rice, corn, Agricultural crops (rice, corn, Agricultural crops (rice, corn, Agricultural crops (rice, corn, sweet potato, cassava, etc)sweet potato, cassava, etc)sweet potato, cassava, etc)sweet potato, cassava, etc)sweet potato, cassava, etc)sweet potato, cassava, etc)sweet potato, cassava, etc)sweet potato, cassava, etc)sweet potato, cassava, etc)

Perennial trees in setlements Perennial trees in setlements Perennial trees in setlements Perennial trees in setlements Perennial trees in setlements Perennial trees in setlements Perennial trees in setlements Perennial trees in setlements Perennial trees in setlements (fruit trees, wood trees, etc)(fruit trees, wood trees, etc)(fruit trees, wood trees, etc)(fruit trees, wood trees, etc)(fruit trees, wood trees, etc)(fruit trees, wood trees, etc)(fruit trees, wood trees, etc)(fruit trees, wood trees, etc)(fruit trees, wood trees, etc)

LEGEND

Notes:

Scale: 1:15,000

1. Original figure created by Tiberon Minerals, 2005 as figure 3.17

2. Projection is Gauss Kruger-Pulkovo(1942) Zone 18

Realigned RailwayRealigned RailwayRealigned RailwayRealigned RailwayRealigned RailwayRealigned RailwayRealigned RailwayRealigned RailwayRealigned Railway

Realigned RoadRealigned RoadRealigned RoadRealigned RoadRealigned RoadRealigned RoadRealigned RoadRealigned RoadRealigned Road

Existing RoadExisting RoadExisting RoadExisting RoadExisting RoadExisting RoadExisting RoadExisting RoadExisting Road

Existing RailwayExisting RailwayExisting RailwayExisting RailwayExisting RailwayExisting RailwayExisting RailwayExisting RailwayExisting Railway

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NUI PHAO MINING JOINT VENTURE COMPANYNUI PHAO MINING PROJECT

COMMUNE BOUNDARIES IN PROJECT AREA

REF NO. REV.PROJECT / ASSIGNMENT NO.VA702-9/1 - 0

FIGURE 3.5

2,

50

50

50

50

0

50

50

150

300

250

250

100

200

1 50

150

1 50

150

150

200

200

150

100

100

100

2

2

3

2

2

3

22

3

3

3

2

3

2

2

2

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2

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3

3

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Lower CatLower CatLower CatLower CatLower CatLower CatLower CatLower CatLower Cat

LuuLuuLuuLuuLuuLuuLuuLuuLuu

Stream

Stream

Stream

Stream

Stream

Stream

Stream

Stream

Stream

RiverRiverRiver

RiverRiver

RiverRiverRiverRiver

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Lower Thuy Tinh

Stre

amSt

ream

Stre

amSt

ream

Stre

amSt

ream

Stre

amSt

ream

Stre

am

Doi BaDoi BaDoi BaDoi BaDoi BaDoi BaDoi BaDoi BaDoi BaBasinBasinBasinBasinBasinBasinBasinBasinBasin

Doi NamDoi NamDoi NamDoi NamDoi NamDoi NamDoi NamDoi NamDoi NamBasinBasinBasinBasinBasinBasinBasinBasinBasin

StreamStreamStreamStreamStreamStreamStreamStreamStream

Upper Cat

Upper Cat

Upper CatUpper Cat

Upper CatUpper Cat

Upper Cat

Upper Cat

Upper Cat

Stre

amSt

ream

Stre

amSt

ream

Stre

amSt

ream

Stre

amSt

ream

Stre

am

Tin ValleyTin ValleyTin ValleyTin ValleyTin ValleyTin ValleyTin ValleyTin ValleyTin Valley

BatBatBatBatBatBatBatBatBat

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

North

Roa

d

StreamStreamStreamStreamStreamStreamStreamStreamStream

RiverRiverRiver

RiverRiver

RiverRiverRiverRiver

CongCongCongCongCongCongCongCongCong

HOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONGHOANG NONG

BINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUANBINH THUAN

HUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SONHUNG SON

TAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINHTAN LINH

DAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWNDAI TU TOWN

PHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINHPHUC LINH

PHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINHPHU THINH

KHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KYKHOI KY

PHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LACPHU LAC

CU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VANCU VAN

AN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANHAN KHANH

HA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONGHA THUONG

TIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOITIEN HOI

BAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAIBAN NGOAI

Households

Relocated RailwayRelocated RoadExisting RailwayHwy. 37 / Existing Roads

Commune Boundaries

LEGEND

Mine FootprintRoad Relocation Footprint

Scale: 1:50,000

Page 98: Nui Phao Mining Joint Venture Company Nui Phao Mining ......Nui Phao Mining Project ESIA/ESAP Executive Summary Volume I June 2006 Prepared for Nui Phao Mining Joint Venture Company
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M:\7\02\00009\01\A\Report\March REPORT\Exec. Summary figures\Figure 3.7.xls Flow ChartPrint 4/21/2006 9:53 AM

Rev'd Apr/21/06

SCHEMATIC OF THE MINERAL PROCESS

FIGURE 3.7

NUI PHAO MINING JOINT VENTURE COMPANYNUI PHAO MINING PROJECT

REV.0

PROJECT / ASSIGNMENT NO. 702-9/1

REF NO.-Knight Piésold

C O N S U L T I N G

Page 100: Nui Phao Mining Joint Venture Company Nui Phao Mining ......Nui Phao Mining Project ESIA/ESAP Executive Summary Volume I June 2006 Prepared for Nui Phao Mining Joint Venture Company

M:\7\02\00009\01\A\Report\March REPORT\Exec. Summary figures\Figure 3.8.xls Water BalancePrint 4/21/2006 9:54 AM

Rev'd Apr/21/06

Notes:1) Original figure created by Golder Associates, January 2006.

Rev 0

SCHEMATIC OF THE WATER BALANCE

FIGURE 3.8

NUI PHAO MINING JOINT VENTURE COMPANYNUI PHAO MINING PROJECT

PROJECT / ASSIGNMENT NO. VA702-9/1 REF NO.Knight Piésold

C O N S U L T I N GREV.

0