From: on behalf of Panel Registry Subject: FW: TNG registration of ...
From: on behalf of Panel Registry Subject: FW: TNG registration of ...
From: on behalf of Panel Registry Subject: FW: TNG registration of ...
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Stratus C<strong>on</strong>sulting Memorandum (4/16/2010)<br />
�� Given the underestimate in lag time to acid generati<strong>on</strong>, we believe there is a substantial<br />
risk that exposed wall rock in pit walls will generate large quantities <strong>of</strong> acid and<br />
c<strong>on</strong>taminants before the pit is inundated.<br />
�� Similarly, we believe there is a substantial risk that the PAG waste stored within the<br />
tailings impoundment can generate acid before it is submerged, or if the tailings<br />
impoundment becomes unsaturated in the future.<br />
Each <strong>of</strong> the factors that Dr. Maest will discuss support our c<strong>on</strong>clusi<strong>on</strong> that the Prop<strong>on</strong>ents have<br />
greatly underestimated the potential <strong>of</strong> this mine to generate substantial quantities <strong>of</strong> acid,<br />
metals, and other c<strong>on</strong>taminants.<br />
2. Mine Site Water Balance and Hydrogeology<br />
As we discussed in our previous report last November, we believe that the limited site-specific<br />
data <strong>on</strong> which the Prop<strong>on</strong>ents rely are not sufficient to support the probabilistic water balance<br />
models that they have generated for the Prosperity Project. Their recent resp<strong>on</strong>ses to our<br />
November report have not adequately addressed many <strong>of</strong> our initial c<strong>on</strong>cerns. In additi<strong>on</strong>, we<br />
believe that the Prop<strong>on</strong>ents’ models <strong>of</strong> c<strong>on</strong>taminant transport in groundwater fail to account for<br />
the large uncertainty in their underlying data, potentially resulting in unforeseen groundwater<br />
c<strong>on</strong>taminant plumes and discharge <strong>of</strong> c<strong>on</strong>taminants to Big Oni<strong>on</strong> Lake and, potentially, the<br />
Taseko River.<br />
Dr. Maest will summarize some <strong>of</strong> the shortcomings in the hydrometeorology modeling and will<br />
review remaining c<strong>on</strong>cerns, as well as provide examples <strong>of</strong> failures in hydrologic predicti<strong>on</strong>s at<br />
other mine sites (see Secti<strong>on</strong> 3). In summary, we are c<strong>on</strong>cerned that if the water balance does not<br />
adequately account for the wide range <strong>of</strong> potential variati<strong>on</strong>s in water input over time, there<br />
remains a significant risk that water levels in the TSF will not be maintained, allowing oxidati<strong>on</strong><br />
<strong>of</strong> mine waste materials when water levels drop during dry periods, and subsequent transport <strong>of</strong><br />
c<strong>on</strong>taminants via groundwater seepage and from releases during storm events.<br />
2.1 Maintaining Water Levels in TSF<br />
The Prop<strong>on</strong>ent has proposed inundating tailings and PAG rock in the TSF, where a static water<br />
level will need to be maintained in perpetuity. If an event such as a drought or unforeseen<br />
seepage causes water levels in the TSF to drop, sulfides in the waste material will oxidize,<br />
resulting in acid generati<strong>on</strong> and metals leaching. Specific criticisms <strong>of</strong> the Prop<strong>on</strong>ents’ plan for<br />
the TSF include the following:<br />
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