2019-01-17_REVISION - C1982056 - Laserfiche WebLink

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b. Freeboard shall be no less than .3 feet. The discussion in Section 4.6 of Exhibit 49EE and the cross-sections in Appendix C do not show how the designs meet the above requirements. Please revise the design to incorporate these requirements. See December 2018 Adequacy items for additional requests for clarification on design submitted 11/13/2108 Response: The information referenced in the text discussion and provided as Appendix G of the design report addresses stormwater design requirements for the 6MN Reservoir and the associated diversion channel (larger watershed area) but is not specific to the System in its revised configuration. This original hydrologic design information has been supplemented by additional hydrologic designs specific to the System, including the planned diversion ditches. This supplemental design information accompanies these responses for insertion in the Exhibit 49EE of the PAP. 12. Please update Map 23c to depict the new surface disturbance area associated with the proposed passive water treatment system. Not yet addressed Response: Map 23C, Mine Plan — Surface Disturbance and Monitoring, has been revised to show the System footprint, as new surface disturbance. Copies of the revised map accompany these responses for replacement in the PAP. 13. Rule 2.05.4 indicates that the application shall contain a reclamation plan for reclamation of lands within the proposed permit area. In order for the treatment cells and the 6MN Reservoir to be retained as permanent features TC must provide the permanent impoundment demonstration required by Rule 4.05.9(13). Until these demonstrations have been submitted, TC must supply a reclamation plan for the passive water treatment system and the 61VN reservoir in accordance with Rule 2.05.4. The reclamation plan submitted on proposed revised page 2.05-106 and 106.1 does not provide a detailed description to demonstrate compliance with Rule 2.05.4. Appendix I of proposed Exhibit 49EE shows the post mine configuration of the Passive Water Treatment System and 6MN Reservoir. However, Appendix I depicts very little reclamation or modification of the system features and does not depict how TC intends to provide `flow through" the cells and reservoir embankment. Regardless, until the permanent impoundment demonstrations have been approved, the embankments of Cells 1, 2, 3, 4 and the 6M7V Reservoir must be backfilled and graded into the ponds and the north and south diversion must be reclaimed. The area affected by these activities will need to be topsoiled and revegetated. Please update the reclamation plan narrative and provide an updated post mine configuration of the proposed project area in accordance with Rule 2.05.4. Partially addressed. Please provide an updated post mine configuration of the reclaimed reconstructed drainage for the proposed project area. Response: We recognize that a permanent impoundment demonstration and permit revision for retention of the Passive Treatment System and 6MN Reservoir will be required to leave these facilities as permanent postmining structures. Given that we are not prepared to provide this information at this time, the related permit text and supporting materials have been revised to detail the reclamation plans and configuration for these features. Copies of the revised text and supporting materials accompany these responses for replacement in the PAP. 14. Proposed pages 2.05-106 to 106.1 indicates that TC intends to retain both the passive water treatment system and 6MN Reservoir as permanent post -mining features. However, TC also indicated that they will prepare a permit revision for permanent retention of the treatment system and reservoir prior to final reclamation and bond release. Please remove the language on proposed revised page 2.05-106 that TC proposes to retain the passive water treatment system and the 6MN Reservoir as a permanent postmining feature. The language on proposed