[letterhead]
Province of British Columbia
Ministry of the Environment, Lands and Parks
Environmental Assessment Branch
To: John Marczyk Date: July 28, 1995
Project Assessment Coordinator File: 44500-30
Re: Huckleberry Mines Ltd. Project Report
Further to my letter of July 7, 1995, regarding the ministry review
of Huckleberry Mines Ltd., Project Report, please find attached
detailed comments and terms of reference which address deficiencies
relating to waste characterization and discharge quality.
The ministry has not had an opportunity to thoroughly review the
July 19, 1995, letter from Peter Campbell with the recalculated ABA
data, however a preliminary comparison with the results in the
Project Report has indicated that it will not substantially change
the need for additional information to address the strategic issues
identified by the ministry.
Further, Huckleberry Mines Ltd in its response to the review
comments of the Project Report Review has committed to monitoring
and treatment of any discharges from the East Zone Pit if a
discharge exceeds discharge quality objectives. This commitment
alone does not adequately address this issue. Further information
to predict the quality of the discharges and the feasibility of any
proposed treatment system will be required before a decision on
project approval can be made. The attached terms of reference
detail the need for additional kinetic testing. This information
together with hydrological data should be used as a basis for a
conceptual design of the proposed treatment system. The ministry
requires assurances that such a system can be accommodated within
the economics of the project, keeping in mind that, as proposed,
treatment will be necessary in perpetuity.
Similarly, the company has committed to ongoing monitoring of
exposed potentially acid generating (PAG) waste rock used in the
construction of the South Saddle and East Dams, and that in the
event that exposed PAG rocks shows signs of acid generation,
appropriate measures will be taken to ensure that this does not
result in adverse impacts. The ministry will need assurances that
impacts will not occur or adequate mitigation measures exist based
on further information requirements set out in the attached.
It is hoped that the information provided will facilitate a useful
and productive discussion at the Huckleberry meetings in August.
Please direct all questions regarding these terms of reference
to...
Garry Alexander
Project Review Manager
cc: [not listed for this post]
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[letterhead]
Province of British Columbia
Ministry of the Environment, Lands and Parks
MEMORANDUM
To: Garry Alexander file: 44500-30/Huckleberry
From: Craig Stewart Date: July 10, 1995
Subject: HUCKLEBERRY PROJECT APPLICATION REVIEW COMMENTS
The HUCKLEBERRY PROJECT REVIEW was submitted for review during
June, 1995, as partial fulfilment for a decision leading to a
Project Approval Certificate under the Environmental Assessment
Act. The documents submitted have subsequently been reviewed and
compared with previously submitted documentation and comments. The
company has obviously placed considerable effort in formulating the
Project Report and should be commended for their efforts, however,
there are several outstanding issues that warrant further study.
Based upon the review and proposals put forth by Huckleberry Mines
Ltd., it is my consideration that there are sufficient outstanding
strategic issues to reject the issuance of a Project Approval
Certificate at this time and to request further information and
clarification as described in this document.
The comments contained in this document are divided into 4 section:
* Strategic issues affecting the issuance of a Project
Approval Certificate,
* Comments pertaining to the documents submitted,
* Permit issues and,
* Terms of Reference for further work.
[last three items not provided for this post]
1/ SUMMARY OF STRATEGIC ISSUES
1. EAST ZONE PIT WATER QUALITY
A major concern with the Huckleberry Project Report is the
potential for a discharge of minewater via seepage and/or spillover
from the East Zone pit. These discharges may contain unacceptably
high concentrations of metals and other contaminants from the
oxidation of the exposed East Zone pit wall material. This
material is predicted to be acid generating.
It is recognised that the prediction of the East Zone water quality
at this stage is a very difficult exercise, however, it is felt
that by using proper assessment methodology, a reasonable
approximation can be attained. Although the company has committed
to further study of the East Zone in terms of acid generation and
impacts on water discharge quality, the information thus far
provided is insufficient to form a reliable assessment of the
future discharge quality. In general;
* Kinetic tests do not provide the required information, either
due to their composition or their inadequate duration.
* Extremely conservative water balances will result in excessive
dilution in the predictive model which will not be realised
during actual mining operations. By using conservative
numbers, the total loadings may be appropriate however, the
concentrations may be significantly better than that what will
actually be attained.
* There is no recognition for the changing of cut-off grade and
its impact on the final water quality. Note that the majority
of the East Zone pit wall will be within mineralization and it
will only be economics which will dictate the quality of the
material left behind. Several models should be run to assess
the changes in water chemistry based on various cut-off grades
and pit wall exposure scenarios.
* It is noted that there are concerns with the East Pit plug dam
in terms of stability. One of the options stated was the
lowering of the dam crest to reduce the hydraulic pressure
from the flooding of the East Zone pit. This in turn will
expose a greater volume of mineralised waste rock for
oxidation and acid generation. The impacts of this increased
waste exposure must be considered in determining water quality
at closure.
2. USE OF POTENTIALLY ACID GENERATING (PAG) WASTE ROCK IN
TAILINGS IMPOUNDMENT CONSTRUCTION
The company has proposed the use of PAG material in the
construction of the main tailings dam for TMF-2 as well as the
smaller south saddle and east dams. Although the majority of the
PAG material is to maintained in a flooded condition following a
certain lag time, (in some areas several years), there is the
concern of maintaining the water levels in perpetuity. In the
event of construction problems resulting in the exposure of the
PAG, remediation would prove to be difficult if not impossible.
The use of PAG material for construction purposes is generally not
considered an option.
3. JUSTIFICATION FOR CONSTRUCTION OF TMF-3
The ministry requires justification to construct TMF-3, the result
of which significantly increases the imprint of the mine
development, results in greater run-off and increases the liability
at closure. The Project Report does not demonstrate that this is
the best course of action from an environmental perspective. the
rationale would appear that TMF-3 is necessary for higher grade ore
recovery during initial mine development. The company will be
required to state reasons why the original design of a single
tailings management facility (TMF-2) presented in the pre-
application is no longer applicable and provide the environmental
and economic rationale for the construction of TMF-3.
Some of the major concerns with the construction of TMF-3 include:
* Destruction of an additional 100+ hectares of various habitats
with negative impacts on Creek 9 and the destruction of
numerous wetland areas within the TMF-3 itself.
* Increased water capture within the project area which will
require collection, monitoring and discharge.
* A discharge is now required from years 7-13 of the project
development due to the increased catchment area. This
discharge will be directly to Tahtsa Narrows via a pipeline.
* Further habitat alteration/destruction due to increased
infrastructure associated with TMF-3; borrow pit(s), roads,
pipeline, etc.
* Increased liability and maintenance at closure as TMF-3
represents a significant structure which will require
maintenance and monitoring over time.