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2021 Environmental Performance

Consistent with our permit requirements and the corporate policies of NOVAGOLD and Donlin Gold LLC, a very high level of environmental performance has been maintained at the project site. This continued throughout 2021.

When the project site was active in 2021, the environmental team conducted daily inspections of all ongoing site activities as well as monitoring for potential releases to land and water. These areas include water and wastewater management, air quality, hazardous and other solid waste management, fuel storage and use (and associated spill risk), and the protection of biological resources around the site.

Compliance, Spills, Waste Management, and Reclamation

In 2021, Donlin Gold LLC received three notices from the State of Alaska for non-compliance incidents in 2018 and 2019. These were associated with the administrative requirements of its storm water management permit. They were not considered significant. Two of the notices involved not completing, and reporting on, an annual storm water inspection in 2019; daily and weekly inspections were performed as required throughout the operating season. The other notice involved not providing required training for all key staff in 2018 when there were no camp operations. None of these involved any improper discharges or effects on water quality. There were no instances of non-compliance with any permit requirements for 2021 activities and Donlin Gold has never been cited or fined for any non-compliance with environmental regulations, standards, or permit requirements related to effects on the environment.

In 2021, no hazardous waste was generated at the project site. Twenty-seven tons of non-hazardous waste was generated at Donlin Gold during 2021, 21 tons of which were disposed of in a state-permitted off-site landfill and the remaining six burned in a state-permitted on-site incinerator. Per state permit requirements, Donlin Gold also stabilized and reclaimed all of the 2021 drill sites and associated drill access roads after work was completed in those areas.

The Donlin Gold project uses diesel, Jet A aviation fuel, gasoline, and propane for camp operations and minimal quantities of other hazardous chemicals. Strict protocols are in place for secure management of these substances. NOVAGOLD sets annual environmental targets relating to spills at the project site. In 2021, the company successfully achieved its goal of no spills to water and no more than one spill of 10 gallons or more to land. There were no spills that rose to the level of being reportable to government agencies. Consistent with Donlin Gold LLC policies, all non-reportable spills were fully remediated to leave no trace on or below the ground surface.

Power Generation and Emissions

Due to Donlin Gold’s remote location, on-site diesel-fired power generation and heaters are used to support current project site activities. In 2021, Donlin Gold’s Scope 1 GHG emissions totaled 1,084 metric tonnes of CO2 equivalent (CO2-eq), a reduction from 1,500 metric tonnes of CO2-eq produced in 2020. No Scope 2 emissions were recorded due to the stage of development. This decrease in annual emissions is noteworthy. Annual changes fluctuate, however, based on the different levels of field work and camp activities at the Donlin Gold project site, which vary depending on priorities established each year by the Donlin Gold LLC board. With an approximately 40 percent larger drilling program planned for 2022 compared to 2021, it is expected that GHG emissions could exceed those recorded in 2021; however, we expect these emissions will still be minimal. Overall, given the annual variability and consistently low emissions levels, it is neither appropriate nor material to set GHG emissions targets for Donlin Gold at this stage of the project. Also, with the low levels of site activity – including power generation in 2021 – there were virtually no emissions of other pollutants, including sulfur oxides, nitrogen oxides, mercury, and total particulate matter of less than 10 micrograms diameter per cubic meter.

Baseline Environmental Conditions Studies

In 2021, Donlin Gold LLC continued a long-term aquatic monitoring program for the Crooked Creek watershed, including surface water quality, fish distribution and spawning, and estimation of fish, macroinvertebrates, and periphyton populations. Baseline sediment and fish tissue sampling was added for the 2021 program. Also in 2021, Donlin Gold LLC continued fish studies in the Middle Kuskokwim River, including our multi-year program to characterize rainbow smelt spawning locations and migration timing. Potential barging impacts on rainbow smelt and associated subsistence harvests have been identified by communities as a key concern for the project and were addressed in the FEIS. New for the 2021 program was a study to understand the timing of rainbow smelt egg hatching and larvae travel through the river system. In this effort, Donlin Gold LLC continued to partner with local residents to collect the rainbow smelt data. The information will ultimately be used to further refine the barging plan, including any necessary mitigation measures.


Potential project-related effects from mercury emissions have also been a significant community and government agency concern. This is in part because mercury levels in water and fish are already elevated within the Y-K region, and mercury can affect aquatic life and human health through subsistence uses. Substantial analysis was done for the FEIS to characterize existing mercury levels, determine how they could be affected by deposition from the project, and define potential impacts on the environment and local stakeholders. In 2021, the project conducted additional intensive sampling of water quality and sediments throughout the Crooked Creek drainage to better define how much of the existing mercury is from natural sources (e.g. erosion) versus atmospheric deposition.

Fish Habitat Restoration

In 2021 Donlin Gold LLC began aquatic habitat restoration work in areas of the Crooked Creek watershed, near the project site, that had been degraded by historic placer mining activities conducted by other parties. This effort will continue in 2022 with the goal of restoring, enhancing, and creating new aquatic habitats that can support salmon and resident fish populations. During 2022, Donlin Gold LLC and NOVAGOLD will further pursue partnerships for additional off-site biodiversity enhancement and protection projects in the Kuskokwim River watershed.

Water Use

Donlin Gold used approximately 444,866 gallons of ground water to support camp operations during 2021. This volume increased substantially from 2020 (184,000 gallons), but it is still very low for facilities associated with the mining industry. Like the low but variable GHG emissions, water use at the project site changes on an annual basis depending on camp needs such as domestic supply, core cutting, and washdowns. With increased field activity in 2022 and a longer field season compared to 2021, we expect that the camp water use volume could increase further, but should remain at relatively low volumes. The project site is in a remote part of western Alaska where water scarcity has not been a concern. In addition, all water withdrawals and uses are authorized by the State of Alaska. The permitting process provides for protection of other local water uses, including ensuring no adverse impacts to streams and aquatic life. Finally, as noted previously, the plans for the full-scale mine operation maximize re-use to limit water supply needs.


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