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Section IV <br /> Summary and Discussion <br /> This section of the review is the Division' s evaluation of on-the-ground <br /> performance, compliance and any requests for revisions. <br /> Revision <br /> 1 . During the liability transfer (TR-12) ponds T, B, C, E and G were <br /> transferred to the Foidel Creek Permit along with Haul Road B and C. <br /> Design and Certification Documents were not submitted at that time. It <br /> also appears that bond estimates for removal were not included. TCC <br /> should submit a revision incorporating the design and certifications for <br /> these facilities. Bond associated with these structures will be <br /> discussed in Section V. <br /> 2. Foidel Creek is currently using water from Spring 114 to supply water <br /> used in the mining process and as emergency fire suppression. The water <br /> right and/ or need to obtain a well permit for this spring was not <br /> discussed during the permitting of Spring 114 as a freshwater supply. <br /> Please provide documentation showing TCC' s recorded right to utilize this <br /> water. If this information is not available, TCC will need to submit a <br /> revision incorporating these rights and the well permit document into the <br /> permit. Also, it appears that the original approval to use Spring 114 <br /> was for fire suppression. . It is the Division' s understanding that this <br /> source may now be used in various mining activities . If this is the <br /> case, TCC should provide a comprehensive discussion of how the water is <br /> utilized underground and the potential impact of this use . Specifically, <br /> potential impacts to groundwater aquifers , and to the Fish Creek surface <br /> drainage must be analyzed . A revised PHC may be required. <br /> 3. The mine has conducted a considerable amount of exploration drilling <br /> recently both within and outside of the permit area. There are specific <br /> rules that apply to both types of exploration. TCC has in the past <br /> submitted minor revisions outlining the proposed drilling along with <br /> measures to comply with Rule 4.21 . <br /> The Division requests that TCC submit a technical revision to their <br /> permit application which addresses all applicable portions of Rule <br /> 4.21 . More specifically, TCC should address sediment control , topsoil <br /> protection , vegetative re-establishment, road construction and removal , <br /> etc. The permit currently contains information similar to this , but has <br /> been revised several times , and is not comprehensive or cohesive. When <br /> this information is incorporated into the application, future revisions <br /> will need only to refer to that section for compliance with performance <br /> standards plus provide specifics for the revision ( i .e. location, depth, <br /> bond, etc. ) . <br /> Exploration conducted outside of the permit area can proceed as it has in <br /> the past, with a separate application and bond . <br /> -9- <br />