|
8. Additionally, following the basis for including this land in the permitted area, please refer to the requirements of
<br />an approved mining plan as described in Rule 6.3.3(1), and specifically in paragraphs (f), (i), (k), and (1), which
<br />deal with stockpiles, groundwater, stormwater, acid-producing materials, and disturbance to the hydrologic balance.
<br />9. The EPP for this site has been referred to in previous paragraphs. It would be beneficial to review its
<br />requirements as set forth in Rule 6.4.20, and specifically in paragraphs (1)(a)(v), (2), (4)(a), (6)(a) and (b)(ii), (7)(a)
<br />through (f), plus all of the paragraphs under (8) through (12), and (14). These paragraphs describe the requirements
<br />for thorough and rigorous documentation of the ore material, the stockpile facility, the surface and groundwater,
<br />and control and monitoring plans. (Portions of these requirements are reiterated in Sections 103(4.9) and 116.5(5)
<br />of the Act.)
<br />10. If the stockpile area will continue to be used, and is therefore made part of the permitted area, it will be
<br />considered to be a facility under the EPP for this DMO. As such, the future use of the area requires that it be
<br />prepared in conformance with the standards outlined in Rule 7.3.1(4) and (5), and certified pursuant to Rules 7.4.1
<br />and 7.4.2.
<br />The Division recognizes the fact that access to the 6 level portal is difficult for most vehicles and impossible for
<br />large vehicles, and that the land area available on which to operate on the 6 level pad is limited. The operation
<br />would benefit by the use of a separate stockpiling facility which has easier access and more room to operate.
<br />However, this obvious need is not justification for the use of an area as part of the mining operation which is not
<br />part of the permitted land, nor in a manner which does not account for potential release of pollutants.
<br />In past years, observations made at this site by the Division were that significantly fewer sacks were stored there,
<br />and they were regularly and promptly hauled to the out-of-state processing facility. The Division did not feel that
<br />this constituted a significant impact. Stockpiling and hauling operations changed in 2001, resulting in more ore
<br />stockpiled there and for longer time, substantially increasing the potential impacts. The Division no longer
<br />considers this to have no significant impact.
<br />I hope the points listed above adequately explain why the stockpile site must be considered part of the affected land
<br />and the need for proper facilities there. At this time, there maybe several options which could be considered for
<br />future ore stockpiling needs, including no future use of the area, and various degrees of future use of the area.
<br />The first option is: the operator may restrict all future stockpiling to permitted azeas, such as on the 6 level pad, and
<br />tram the filled sacks down to Vickers Ranch to be loaded directly and immediately onto haul trucks bound for
<br />processing. No offsite stockpiling would be carried out, no additional land would be affected, and no facility
<br />design, construction or certification would be necessary. No technical revision or amendment to the permit is
<br />necessary.
<br />The second option is: if ore stockpiling is desired for land within the present permitted area, on a portion which is
<br />not presently approved for stockpiling, it may be approved for a change to such future use via the technical revision
<br />process.
<br />The third option is: if.stockpiling at this site is desired, for periods of less than 180 days, certain items must be
<br />addressed to prevent release of pol]utants, and the land must be added to the permit by an amendment. It has been
<br />observed that weathering and possible leaching has occurred to sacked ore placed at the site for less than 180 days.
<br />These sacks were IeR uncovered and were placed on permeable ground. It is necessary to ensure that in future ore
<br />storage, prior to its tramming and placement here, all ore has been allowed to thoroughly drain dry, that it be
<br />sacked, that it not be placed on wet ground, that it not contact uncontrolled stormwater, and that it be under a
<br />durable, weather-proof cover that is maintained secure during the entire period of storage. The area of land to be
<br />affected must be described, marked on the ground, and not exceeded. It must be set back from the water surface an
<br />approvable distance.
<br />
|