From: on behalf of Panel Registry Subject: FW: TNG registration of ...

Stratus Consulting Memorandum (4/16/2010)
Dr. Jeff Morris will attend the fish and fish habitat sessions on Tuesday and Wednesday,
April 27�28. Dr. Morris is an aquatic toxicologist who has investigated the effects of heavy
metals on salmonids in both field and laboratory toxicity studies. If possible, Dr. Josh Lipton will
assist Dr. Morris via teleconference.
This memorandum is organized as follows: Section 1 critiques the Proponents’ tests and models
used to predict acid and contaminant generation from exposed rock at the mine. Section 2
critiques the hydrometeorology model, water balance, and hydrogeologic models. Section 3 then
discusses past experience and case studies from other mines, and Section 4 details the adverse
effects on aquatic life of copper and cadmium released into rivers. Section 5 presents the
qualifications of the authors of this memorandum. A list of references and materials relied upon
is provided at the end.
1. Contaminant Sources
In this part of the technical sessions, Dr. Maest will provide evidence that the Proponents have
erred in their estimation of acid and contaminant generation potential. In this section, we outline
the information that Dr. Maest will present, including flaws identified both in geochemical
testing and subsequently in geochemical modeling.
1.1 Flaws in Geochemical Testing
1.1.1 Humidity cell test flaws
We have identified several flaws in the humidity cell test (HCT) procedures and analysis. Each
of these flaws likely results in an underestimate of the quantity of contamination that this mine
will generate. Specific topics of the HCTs that Dr. Maest may discuss at the technical meetings
include the following:
�� The rock types used in the HCTs are not representative of the rock types at the proposed
project. Many HCT samples had sulfide values lower and neutralizing potential to acid
potential (NP:AP) ratios higher than those for rocks that are representative of pit walls.
�� Phase 4 HCTs are not useful for evaluating the importance of metal leaching, especially
for aquatic life concerns, because the detection limits are too high for many metals of
concern.
�� Kinetic tests were not conducted for long enough periods of time to reach the onset of
acid generation or maximum leachable contaminant concentrations.
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