NovaGold will implement a post-closure monitoring plan developed during the permitting process.

The post-closure monitoring program will be designed to continue the sampling of seeps monitored during operations.

A plan for post-closure monitoring of the site including a monitoring schedule and reporting frequencies.

Is the post-closure monitoring program adequate? viii.

The results of monitoring during the life of the Project would provide the information necessary to determine the nature of a post-closure monitoring program.

In the U.S., the regulatory structure for landfills specifies a 30-year post-closure monitoring period.

The Panel notes that BHP has made a commitment to post-closure monitoring but the details of this proposal are sketchy at this stage.

Further, BHP is committed to a post-closure monitoring program which would include water quality, lake and stream biology, hydrology, wildlife, revegetation and landform stability.

Only one small section in this huge document, Section 14.7 Post-Closure Monitoring, spells out in a general way as to what will be monitored after closure.

As for the supporting infrastructure (airstrip, road, buildings), the plan is to gradually remove structures and return their sites to their natural state as operations wind down and through the five year post-closure monitoring period.

Post-closure monitoring Post-closure monitoring shall be based on the information collected and modelled during the implementation of the monitoring plan referred to in Article 13(2) and above under 1.2.

A post-closure monitoring program will be developed in conjunction with Canadian and U.S. federal and B.C. and Alaska State agencies and the Tahltan Central Council during the permitting stage.

Within the framework of the authorizations granted under the environmental impact assessment and review procedure, operators are required, by government order, to establish financial guarantees in the form of a trust fund for the post-closure monitoring of disposal sites.

This Agreement shall terminate upon full and final reclamation and abandonment of the Project site, in accordance with the requirements of all Regulatory Instruments and the terms of this Agreement and completion of any and all post-closure monitoring and maintenance required in connection with the Project.