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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 />