ENVIRONMENT - Badrakh Energy

ENVIRONMENT

Every mining operation requires the development of infrastructure and use of raw materials and resources, especially water and energy. And the impact of mining on the natural environment is constantly assessed, minimized, controlled and monitored.

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In 2022, Badrakh Energy reaffirmed its dedication to upholding the highest international standards by signing the Responsible Mining Code initiated by the National Mining Association of Mongolia. This action not only underscores our commitment to the environment, but also positions us as exemplary in the industry.

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Badrakh Energy conducted all the necessary environmental and social studies and risk assessments before launching the Zuuvch Ovoo ISR Pilot test project performed in 2021-2022.

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Sustainable development is defined by ensuring environmental protection in every step of our activity.

Before the project begins

Before any project begins, the company develops plans for review, and achieves the necessary approval and permitting by authorized government agencies before the start of work on-site. We obtain the following permits for our operation:

EMP – environmental management plan
Radiological monitoring program
Water Conclusion – water usage permit
Water use contract
Waste management contract
Waste water conclusion
Fire conclusion
Chemicals permit

Badrakh Energy operates in accordance with approvals provided by the Ministry of Environment and Tourism, the Ministry of Mines and Heavy Industry, the Ministry of Education and Science, the Water Authority, the Water Basin Authority of Galba Oosh Dolood and NEMA (National Emergency Management Authority) and the Environment and Tourism Department of Dornogobi. These regulatory agencies provide permits and conditions annually for our operations, as well as review and approve projects, and conduct audits, and inspections to ensure the company is meeting its commitments.

The Health, Safety-Radioprotection, and Environment Department of Badrakh Energy collaborates closely with professional agencies and organizations to ensure that environmental programs adhere to regulatory standards, maintain consistency, and accuracy, and are effectively implemented.

BADRAKH ENERGY HAS PERFORMED THE FOLLOWING ENVIRONMENTAL SURVEYS:

2009

Environmental and socio – economic baseline study of Dulaan Uul uranium exploration project

2009 – 2013

Radiation protection activities performed for uranium exploration and study in 2009 – 2013

2010

DEIA report on ISR pilot project in Umnut deposit

2011

Report on air quality and soil monitoring in the vicinity of pilot project for uranium mining by ISR technology in Umnut deposit of Cogegobi LLC
Report on nuclear and radiation safety during ISR test of uranium mining

2010 – 2011

Report on the results of the environmental baseline assessment study performed during the pilot project of uranium mining by ISR in Umnut deposit of Cogegobi LLC

2012

Environmental and socio – economic baseline study of Zuuvch Ovoo (11946X) exploration site
Results of report on environmental assessment study conducted during ISR test performed in Umnut deposit of Cogegobi LLC

2012 – 2014

Environmental baseline study of Zuuvch Ovoo
Environmental Protection Plan and Environmental Monitoring Program Reports of Dulaan Uul and Zuuvch Ovoo sites from 2012 – 2014

2014

Radiation safety monitoring plan
Report on the archeological conservation research carried out in the exploration licensed area of Dulaan Uul in Ulaanbadrakh soum of Dornogobi Province

2014 – 2015

Ecological risk assessment

2014 – 2016

Paleontological study of Zuuvch Ovoo, Dulaan Uul

2014/11 – 2016/03

DEIA – Environmental Management Plan of Zuuvch Ovoo

2015

Land quality assessment
Environmental audit

2015-2016

Detailed environmental impact assessment report of the ISR pilot test in Zuuvch Ovoo uranium deposit

2015-2017

Assessment and remediation study on Khar Yamaat saxual forest in Ulaanbadrakh soum of Dornogobi province

2016

Environmental assessment state study on Zuuvch Ovoo
Independent environmental control and monitoring

2017

Disaster risk assessment survey of Zuuvch Ovoo project

2017 – 2018

Chemical risk assessment

2018

Radiological assessment of workplace of Zuuvch Ovoo pilot test and recommendations for radioprotection
Independent environmental control and monitoring
Implementation of offset program-consulting service and study

2018 – 2019

Study of mammals and birds

2019

Independent environmental control and monitoring
Implementation of offset program-consulting service and study

2020

Land quality assessment
Environnemental audit
Third Party Review of Documents Pertaining to Reported Cattle Deaths in the Umnut license area of Dulaan Uul, Mongolia

2022

Radiation safety and workplace radiation assessment

2022 – 2023

Environnemental audit
Environmental assessment report of Dulaan Uul and Zuuvch Ovoo

DURING THE PROJECT DEVELOPMENT STAGE

Detailed environmental impact assessment (DEIA)

The DEIA can be considered as a guideline for environmental protection of the project area. The DEIA provides a detailed understanding of the associated environment (biodiversity inventory, socio-economic status of the region), and identifies all preventative or mitigating measures necessary for reducing risks at the source. An action plan for mitigation is developed and implemented and, when needed, offset measures can be proposed. It also includes the principles of remediation to be deployed at the end of the mine’s life and environmental monitoring.

The DEIA is subject to regulatory review and approval and a yearly financial deposit to assure the remediation plan is carried out after mining activity, in accordance with the Law on Environmental Assessment of Mongolia. The five-year-DEIA update reflects the changes of activities, all new environmental data, social aspects and technological updates for environmental protection.

Additionally, it considers identified environmental issues, changes to the physical facility or facility processes, adjustments in project scope or schedule, scientific advances or regulatory requirements.

ENVIROMENTAL MONITORING

Environmental monitoring is maintained and reinforced from construction to operation. And an environment management system has been implemented on site.

Mechanisms are set to systematically monitor the soil, water, and air and, including the food chain of herders, particularly in areas near where people live, work and travel.

We also had different independent monitoring and surveys conducted with the relevant authority, which proved that our activity doesn’t impact the environment, especially underground water, plant, soil and livestock health.

A special PEMP was dedicated to the Zuuvch Ovoo ISR Pilot to monitor the herders’ water well, located near the project site. This program proves that there is no impact due to the ISR Pilot project.

Badrakh Energy was named as a “Best Practice” by the workshop entitled “Best Practice on the Participatory Environmental Monitoring” held in April 2019 by the Ministry for Environment and Tourism of Mongolia.

Environmental research and analysis

Environmental research and analysis actions carried out since exploration stage:

Report of the study on animal species, population, migration, movement and habitat of ungulates (mammals) and birds
Report of the environmental audit at the uranium project implemented by Badrakh Energy
Justification and plan of establishing the tree cultivation site and carrying out reforestation through planting saxauls.
According to the monitoring results and independent assessments, no negative impact on environment has been identified from Badrakh Energy operation during the pilot production stage.

Monitoring of radiation

Monitoring of radon in the air

Badrakh Energy, which engages in radiation-related activities, follows the requirement of “monitoring the concentration of aerosols and radioactive gas in the workplaces and other facilities of the organization” and has performed monitoring of radon in the air every two weeks, every month and every two months, depending on the risk levels.

For example, in a warehouse of uranium- charged resins where radon cumulation can be the highest, the highest result registered is 149 Bq/m3. This figure is 7 times lower than 1110 Bq/m3, which is the maximum authorized limit for people working with radioactivity.

Monitoring of radiation in the environment

Badrakh Energy commissioned the Nuclear Research Laboratory to perform an analysis of radioactive isotopes and heavy metals in the soil, groundwater and surface water, to monitor the background radiation level in the environment, comparing it with the permissible level under the relevant standard, and make an observation.

WATER

A precious natural resource, water is essential to the well-being of the communities and environment where Badrakh Energy operates, as well as to the smooth- running of Badrakh Energy’s mining operations.

Groundwater and aquifer in the Zuuvch Ovoo area

Advanced exploration for Zuuvch Ovoo began in 2011. This involves detailed delineation of the deposit in order to measure the quantity, grade, and geometry of the uranium ore bodies, as well as hydro-geological studies and the geological environment. Water is a vital natural resource, and understanding where it is and how it moves underground is essential in protecting this resource. By using geological maps and taking samples of underground and surface water for analysis, hydrogeologists are building a detailed picture of how water flows underground.

– Aquifers are underground permeable layers that are mostly made of sand, where groundwater is stored and moves slowly over time

– Groundwater is part of the water cycle and is heavily dependent on the climate. Groundwater conditions in the Zuuvch Ovoo area have been studied since 2006, through a network of 200 monitoring wells

– The groundwater is not suitable for drinking, according to national and international standards

– This poor groundwater quality is partially due to the fact that groundwater has been slowly interacting with minerals in the aquifer over thousands of years.

– ISR technology consumes up to 5 times less water than underground or open-pit mining technologies.

Biodiversity

To deal with the erosion of biodiversity related to mining projects, the “mitigation hierarchy”, also known as the “avoid – minimize – remediate/ restore – offset” sequence, has been in place from the first phases of the project, in accordance with the recommendations of the environmental impact studies.

Our objective is to work towards no net loss of biodiversity. Although the impact on the environment from the project is very small, the company is taking steps to reduce the impact on biodiversity from the work on the site by:

– Ensuring the field work area occupies as little space as possible and preventing it from spreading over a large area

– Preventing accidental spillage of oils from vehicles and soil pollution

Taking preventive and protective actions, such as protecting and isolating the flora, namely, the saxaul plant on the project site.

REMEDIATION

Mining operations require the development of infrastructure (supply of energy, roads, facilities) for the processing of uranium ore, which has an impact on the natural environment and needs to be assessed, minimized and controlled. In order to anticipate risks, remediation is considered right from the exploration and development phases of mining projects.

Although some remediation work is carried out throughout the active period, most of the technical work takes place when mining operations are completed. The employment-related and social implications of the closure of a site are considered as far upstream as possible, in coordination with the competent authorities and in consultation with all internal and external stakeholders.

Optimal planning and implementation of the rehabilitation works plays a crucial role in maintaining the confidence of local communities, authorities and all stakeholders involved. It is key to the long-term acceptability of our activities and our «license to operate» in the communities and in the host countries where we are made welcome.

Remediation plan for the project

– Well field: plugging the wells, dismantling the piping network and rehabilitation of land

– Industrial facilities: dismantling, demolition and rehabilitation of land

– Water table: restoration by natural attenuation, based on various hydrogeological studies and studies demonstrating the effectiveness of natural attenuation with regard to the aquifers in the areas mined

– Revegetation: plantation of saxauls (protected local trees) in rehabilitated areas and in neighboring areas as part of an environmental offset project

Ongoing monitoring of water tables through a network of 88 piezometers. A dedicated budget scheduled to perform all site remediations

Monitoring & Remediation work control

Every year Badrakh Energy submits its environmental monitoring plans to the Ministry of the Environment and Tourism and the remediation work is carried out systematically on completion of exploration activities. These action plans are audited by local authorities and then by the regional environmental protection department before the Annual Environmental Monitoring Report is submitted to the Ministry of Environment and Tourism.

Case studies

Case study 1: Saxual compensation project for Zuuvch Pilot

As part of the preparation of the Zuuvch Ovoo ISR pilot site, the detailed environmental impact study determined that a number of saxauls situated in the pilot area would be impacted. Therefore Badrakh Energy opted for unique compensation.

Upstream of the project, the majority of the facilities will be built outside the high density saxaul zones and Badrakh Energy will ensure strict management of the tracks.

The company has offered to replant saxauls and other endemic species over a surface area equivalent to that affected by the pilot (5 ha). The compensation measure will be carried out in an area close to the pilot and compatible with the sustainable recovery of the trees, in a location chosen in agreement with the stakeholders and respecting local traditions. Thus, in order to create a positive societal and environmental dynamic, stakeholders will be involved and the work will be carried out by local companies and professionals specializing in the replanting of trees in arid regions.

After four years of studies, the planting started in 2019- 2021 and should last till 2022. The monitoring of the plants’ growth will continue for four to five more years.

The Billion Trees project

Badrakh Energy has joined the national program to plant 1 billion trees initiated by the President of Mongolia. The company is committed to planting 5 million trees during the period of mine exploitation