British Columbia Mine Reclamation Symposium

Johnny Mountain Mine reclamation : unraveling the BC permitting process Chaplin, Jessy 2019

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JOHNNY MOUNTAIN MINE RECLAMATION: UNRAVELING THE  BC PERMITTING PROCESS   Jessy Chaplin, MSc., RPBio., P.Ag.  Seabridge Gold Inc.,  1235 Main Street, PO Box 2536 Smithers, British Columbia V0J 2N0  ABSTRACT Seabridge Gold Inc., is a Canadian based resource exploration company that purchased SnipGold Corp., to acquire 29,436 hectares (294 km²) of exploration potential in British Columbia’s “Golden Triangle”. The closed Johnny Mountain Gold Mine, constructed and operated from 1988-1993, is an existing Iskut Project liability, which the new owners are addressing. The mine history includes intermittent site closure activities. Current liabilities include historic landfill, mill building and mine openings. With the company purchase, the existing reclamation liability associated with the former Johnny Mountain Mine was inherited by the new owner. The immediate goal was to determine if Johnny Mountain Mine was in compliance with regulations concurrent with executing the 1999 closure and reclamation program to mitigate impacts of historical mining activity. Reviews concluded with recommendations to address outstanding non-compliance items and multiple office and field activities were planned and completed to bring the project into regulatory compliance. Three examples are used to describe the process. First, upgrading the Landfill was a critical path item in the schedule. This included implementing new 2016 BC landfill criteria into the design, addressing: a non-compliance order and amending the historic permit to allow deposition of inert waste. The second example describes how the Tailings Storage Facility (TSF) was brought into compliance with the 2016 updates to the Mines Act and Health, Safety & Reclamation Code for Mines in BC (Code) for tailings storage facilities. The third example was to scrutinize the site and investigate existing site infrastructure to determine if existing mine conditions were in compliance with the Mines Act and Code regulations. Keywords: SnipGold Corp., Seabridge Gold Inc., golden triangle, regulatory compliance, landfill update, Tailings Storage Facility, permits.   INTRODUCTION Seabridge Gold is a Canadian based resource exploration company. The company has 100 percent ownership of the Iskut Project and KSM Mining ULC, holder of the KSM Project in Northwest British Columbia, located within BC’s famous “Golden Triangle” and Tahltan traditional territory. In June 2016, Seabridge Gold purchased SnipGold Corp. to acquire the Iskut Project for the exploration potential. The Iskut Property consists of a contiguous block of 100 BC Mineral Claims, 2 Mineral Leases and 13 Crown Grants covering 29,436 hectares (294 km²). The Iskut Project area also includes the former operated Johnny Mountain Mine (JMM), the subject of this presentation, and the existing Bronson Slope deposit with measured mineral resources of 84,000 tonnes containing 1.14 million oz. of gold, 280.1 million lb. of copper and 6.10 million oz. of silver (Seabridge Gold Inc, 2018). The JMM was an underground gold mine and milling operation that operated from November 1988 to August 1990 and then from September to November 1993 when operations were stopped (Yeager, 2001). The facilities included eight underground openings, a mill building, a tailings storage facility, an air strip, a fuel tank farm, several ancillary buildings, waste rock piles, a landfill, a 10 km road from the Bronson Slope area situated adjacent to the Iskut River, a septic bed and a few other minor components. The milling process comprised conventional grinding and gravity separation (initially included a cyanide leach process which was stopped early on). JMM has been closed since 1993, and reclamation activities took place sporadically on the site from 1999 to 2015. In 2016 Seabridge Gold Inc. acquired SnipGold Corp. and their associated properties, including outstanding reclamation liabilities, and commenced reclamation activities.   REGULATORY CONTEXT Mining and exploration activities in BC are primarily governed by the Mines Act, and the Health, Safety and Reclamation Code for Mines in British Columbia (HRSC) (BC MEM, 2017).  The Ministry of Energy, Mines and Petroleum Resources (MEMPR) manages the responsible exploration and development of mining activities on provincial lands in British Columbia. The 2019/20 – 2021/22 Service Plan (BC MEMPR, 2019), states that the purpose of MEMPR is to facilitate a thriving, safe, environmentally responsible and competitive mining sector in order to create good jobs and economic growth in communities across the province (https://www.bcbudget.gov.bc.ca/2019/sp/pdf/ministry/empr.pdf). Tenure of exploration sites in the form of mineral claims or leases is established under the Mineral Tenures Act (MTA). The Mines Act is the principal legislation under which activities on a mine site are approved. Additional provincial and federal legislative acts and regulations interact with the Mines Act authorizations for various environmental approvals. Two of the primary acts are the Environmental Management Act (EMA), enacted through the Ministry of Environment & Climate Change Strategy (ENV) and the Water Sustainability Act (WSA) enacted through the Ministry of Forests, Lands, Natural Resource Operations and Rural Development (FLNRORD). EMA regulates the discharge of wastes to land (solid waste), air (emissions) and water (effluent).  The WSA regulates the protection and use, storage and diversion of surface water and groundwater. Other legislation in BC that may issues authorizations to support mining include: clearing of and marketing of timber (Forests Act), archaeological assessments (Heritage Conservation Act), construction of access roads (Forest Practices & Range Act) and tenuring of Crown surface land (Land Act).  Under the federal Fisheries Act, Fisheries and Oceans Canada issues authorizations for all industrial projects that involve construction within fish and fish habitats, most commonly access road bridges or stream crossings, and sets environmental effects monitoring (EEM) for mining projects that discharge prescribed amounts of effluent into fish habitat. Mines are also subject to the Metal and Diamond Mine Effluent Regulation (MDMER) under the Fisheries Act for discharges to water. In British Columbia, if a company holds a Mines Act Permit for approved mineral production, the company carries permit liability for the cleanup of the mine, and they are considered Responsible Persons, as defined under EMA. The company, SnipGold Corp. holds both a Mines Act and two EMA Permits, therefore, the liability for the historic mine discussed in this paper is held by the company. MEMPR establishes a financial security amount that the company is legally required to post until all reclamation liabilities have been fulfilled. SITE DESCRIPTION Seabridge Gold Inc. is a Canadian based resource exploration company. The company has 100 percent ownership of the Iskut Project and KSM Mining ULC, holder of the KSM Project in Northwest British Columbia, located within BC’s “Golden Triangle”. In June 2016, Seabridge Gold purchased the company SnipGold Corp. to acquire the Iskut Project for the exploration potential. The Iskut Property consists of a contiguous block of 100 BC Mineral Claims, 2 Mineral Leases and 13 Crown Grants covering 29,436 hectares (294 km²). The Iskut Project area also includes the former operated Johnny Mountain Mine and the existing Bronson Slope deposit containing measured mineral resources of 84,000 tonnes containing 1.14 million oz. of gold, 280.1 million lb. of copper and 6.10 million oz. of silver (Seabridge Gold Inc., 2018). With Seabridge’s purchase of SnipGold Corp., the existing reclamation liability associated with the former JMM was inherited. The immediate goal was to determine if JMM was in compliance with regulations prior to planning the reclamation program required to mitigate impacts of historical mining activity. Currently there are three provincial permits associated with the site:  1. Mines Act Reclamation Permit M-178, dated 17 June 1988 and amended 07 July 2004; 2. Environmental Management Act Permit PE-8415, dated 06 June 1990 and amended 11 May 2000; and  3. Environmental Management Act Permit PR-7927, dated 29 March 1989, amended 14 July 1999 and 02 August 2011 and May 31, 2018 to include upgrades to the main landfill.  The overall goal as described in the reclamation plan for JMM is to return disturbed lands and anthropogenic landforms to their original land use and capability of alpine tundra wildlife habitat (Yeager and Woznow 1999). Returning the area to its original land use will be accomplished by meeting the following objectives, as outlined in the Closure Plan for the Johnny Mountain Gold Mine, Reclamation Permit No. M-178 (Yeager and Woznow 1999): o develop a closure scenario that prevents potential impacts to surface and groundwater resources; o restore the natural appearance of the area after mining ceases through the re-contouring and re-vegetation of disturbed lands and anthropogenic landforms; o ensure that disturbances and re-developed landforms are stable from a long-term geotechnical and geochemical perspective; o re-vegetate the site through the development of self-sustaining natural succession processes; and o develop landforms and vegetative cover that provide a stable and productive wildlife habitat for resident and transient species utilizing the area. SnipGold follows the cycle of continuous improvement Plan-Do-Check-Act – to ensure that reclamation activities undertaken are fit for purpose, achieve the goals set, logically sequenced and fiscally responsible.  EXAMPLE 1: LANDFILL COMPLIANT Issues After the JMM closure in 1993, Skyline Gold Corporation (previous owner of the JMM site) conducted intermittent reclamation activities, notably in 2007, where many of the onsite buildings were demolished, burned and buried.  The resultant waste was buried at non-permitted sites at the mine and prompted the British Columbia Ministry of Environment (ENV) to issue an Official Warning Letter to Skyline regarding the “unauthorized burning and burial of waste” (BC MOE, 2008). Skyline was required to retain a qualified professional to oversee an environmental investigation of the burial sites and develop a remediation program.  BGC Engineering Inc. (BGC) was retained by Skyline on June 27, 2008 to address the ENV letter dated June 11, 2008 regarding unauthorized burning and burial. During the dates of August 27 to 31, 2008, BGC conducted an onsite investigation to address the ENV requirements of bringing the site into compliance with the EMA and its associated legislation. They reported that the landfill contents consisted of laundry appliances, metal cladding, plywood, ductwork and other debris that would be associated with the demolition of mobile shelters as were used in the mine camp(BGC Engineering Inc., 2008).The BGC onsite investigation found that the burial sites were not in compliance with the requirements of the 1993 BC Landfill Criteria for Municipal Solid Waste (First Edition) due to unsuitable cover material, lack of vegetated cover, presence of groundwater intersecting the buried waste materials, unsuitable base material, and no surface contouring (BGC, 2008). The Landfill was constructed in 1994 and is located on the west side of the tailings storage facility, near the northern dyke abutment (372446E, 6278477N), as shown in Figure 1. This site was intended to hold all inert solid waste materials resulting from the reclamation onsite (Greenwood, 2015). Subsequent to the 2008 BGC investigation, Sperling Hansen Associates (SHA) was commissioned by Skyline to complete a site investigation in 2011 to review options to develop a potential new landfill and consolidating the unauthorized burial sites (Sperling Hansen, 2012). This work was not completed. In mid-2017, SnipGold retained WOOD Environment & Infrastructure (WOOD) (formerly Amec Foster Wheeler) to support an application to amend the existing EMA Permit PR-7927, for the JMM landfill. They described the Main Landfill as contained within a natural depression in the hillside on the west side of the tailings pond. At the time of the initial inspection, SnipGold observed that the landfill contained inert solid refuse, however, much was uncovered (i.e., without a cover of soil or other material).  Permit Amendments SnipGold was required to amend permits for the JMM site to bring it up to current requirements. Key issues during the permit amendment phase included:  o The guidance document entitled “Landfill Criteria for Municipal Solid Waste (Second Edition)” published by the BC ENV in June 2016, was developed to outline Ministry expectations and best management practices for siting, design, construction, operation and closure of municipal solid waste (MSW) landfills (BC ENV, 2016). SnipGold Corp. was directed to follow this guidance, even though the document is neither directly applicable to industrial landfills, nor applicable for a reclamation site where the landfill will receive only inert solid waste for three years and then close permanently.  o Secondly, EMA Permit PR-07927 was amended on August 2, 2011, removing Section 1.1 Authorized Discharges - Inert Solid Waste Disposal, thus prohibiting deposition of inert solid waste into the JMM landfill. While SnipGold Corp. was applying to update the existing landfill design, it was required to apply to amend the landfill permit to once again accept inert solid waste.  o Thirdly, the landfill required immediate remediation work in 2017, to bring it into compliance to:  • meet Section 2.3 of the permit which required refuse to be compacted and cover material to be applied at least once per month while in use; and • bring the Landfill into compliance with the 2007 Official Warning Letter requiring excavation and re-burial into the landfill the contents of two unauthorized disposal [burial] sites at JMM (MOE, 2008). Key tasks in WOOD’s 2017 mandate were to design a landfill to meet current Ministry of Environment and Climate Change Strategy (MECCS) requirements and to provide a Technical Assessment Report summarizing the environmental effects of historic and proposed waste disposal activities at the JMM (WOOD, 2018). Additionally, Landfill Design, Operation and Closure Plans, including a site-specific erosion and sediment control plan was required for the Application (WOOD, 2019). An environmental monitoring plan (EMP) was developed by WOOD for the Landfill including annual groundwater level monitoring, measurement of field parameters, and collection of groundwater samples from down gradient groundwater monitoring wells (WOOD, 2019). 2018 Activities  In January 2018, ENV was contacted and the permitting process was begun. After a scan of the Technical Assessment Report, Regional ENV staff required SnipGold to officially apply to amend the sections of the PR-07927 which were out of compliance. Application was made March 21, 2018. Engagement with the Tahltan Central Government included capacity funding for the review, coordinated site visits and independent review of technical documents. A series of comment and responses with ENV ensued. A new ENV reviewer was assigned to the file mid-review. An amended permit was issued May 31, 2018, in time for the 2018 field season.  The landfill is located at 560 37’ 59.4” N, 1310 04’ 45.2” W, at an elevation of 1,100 meters above sea level (masl), on the west side of the existing JMM Tailings Storage Facility (TSF) and has been designed to encompass the original landfill location. Summer is a short period when JMM is snow-free, starting in mid-June to early July and the site is generally snow-free during the months of July and August. 2018 field season activities at the Main Landfill endorsed by ENV to bring the site conditions into compliance included completing improvements to the landfill foundation, construction of berms and ditches, and removal of ponded water. Demolition activities and disposal of waste in the Main Landfill are planned for the 2018, 2019, and 2020 field seasons. Operational cover soil will be added to the demolition waste as it is landfilled to reduce large void spaces and the surface will be graded to prevent ponding of surface water.   Figure 1. Johnny Mountain Mine Landfill Upgrade, showing Phase 1 and cells 1 and 2 which were constructed during the 2018 field season. North is the top of the photo.   Figure 2.  Landfill Phase 1. Gravel placed in Cell 1 to construct base levelling course (July 7, 2018). Figure 3. Landfill Phase 1. Heavy equipment levelling base course (July 9, 2019).  In 2018, landfill upgrades consisted of the following: Cells 1 and 2 of the landfill were constructed, filled, and covered with a temporary landfill cover, and runoff was directed to the tailings pond (Figures 2 & 3). Relocation of materials to the upgraded landfill included the materials from unauthorized Disposal Site #1 and #2, old septic tanks, and material from general site cleanup.  o Disposal Site #1 located south of the Mill Building included 690 m3 of materials consisting of the burned remains of the Chalet building, steel piping, steel trailer frames, concrete footings, steel cladding, beams, piping, and mattress springs.  o Disposal Site #2 – located north of historic tank farm, now the site for in situ hydrocarbon remediation, included 1,000 m3 of materials consisting of steel pipe, cables angle iron, storage hoppers, concrete mixing drum, old equipment and parts and numerous 20 lb propane tanks, insulation and PVC piping. o Demolition waste from Portal 12 (generated in 2017) was removed to the upgraded Landfill. In addition to the waste describe above, an estimated 1295 m3 of inert solid waste was removed from other areas of JMM, resulting in an estimated 2,985 m3 total waste placed in the Landfill in 2018 (Figure 4). All waste placed within the JMM Landfill during the 2018 reclamation season complied with Ministry of Environment - EMA Permit PR-7927 (Inert Solid Waste Disposal). Contractor NorthWest Response & Environmental Consulting (NW Response) and the SnipGold Corp. Field Supervisors monitored activities continuously to ensure that no hazardous waste or hydrocarbons were placed within the JMM Landfill during the 2018 season (NW Response, 2018). Operational soil/till material will be added to the demolition waste as it is landfilled to reduce large void spaces and the surface will be graded annually to prevent ponding of surface water. Additional demolition activities and disposal of waste in the Main Landfill are planned for the 2019 and 2020 field seasons. Following disposal of waste in 2018, a temporary landfill cover consisting of mineral soils, free of boulders and organic material, was placed over all waste material to a minimum depth of 300 mm. This material was placed and compacted to ensure that precipitation and overland surface water will flow towards the Landfill perimeter catchment ditches and then to the Tailings Storage Facility (Figure 5). The final landfill cover system is designed to meet or exceed the 2016 Landfill Criteria requirements for a hydraulic barrier cover system. The proposed design includes a composite hydraulic barrier consisting of a 40 -mil linear low-density polyethylene (LLDPE) in direct/intimate contact with a Geosynthetic Clay Liner (GCL) (Wood, 2018). These types of composite liner systems essentially block all precipitation from entering the waste when installed correctly, and if the system is adequately protected during placement of overlying cover materials. Soil covering the liner will protect the LLDPE liner from ultraviolet (UV) degradation and facilitate a vegetative cover to meet JMM reclamation objectives. This type of composite cover system is expected to have a service life far more than several 100 years and is unlikely to be adversely affected by climate change (WOOD, 2018). The final cover is also designed to manage surface runoff and minimize any associated erosion. Precipitation landing on the cover will flow via gravity to the perimeter ditches which will discharge to existing drainages that lead to Sky Creek and Johnny Creek. Since this water is not in direct contact with wastes, it can safely be discharged to the environment.   Figure 4. 2018 Compliance activity, heavy equipment covering historic landfill waste as per requirements in Section 2.3 Landfill Operation, of PR-7927. The condition states that Permittee shall compact the refuse and apply cover material at least once per month while in use.  Figure 5. Final 2018 landfill Phase 1 completed. Landfill surface with a minimum 300 mm cover over waste material. Landfill Next Steps The Main Landfill area is approximately 2.6 ha. The area was historically biogeoclimatic unit Mountain Hemlock moist maritime subzone leeward variant (MHmm2p), and site series Alpine Heather Meadows (HM) with a minor amount of Sedge Meadows (SS). The area around the landfill consists of old borrow sites which include exposed soil and naturally re vegetated areas. As part of the reclamation and closure of the site, the main landfill be permanently closed to store the inert solid waste in perpetuity. It will be capped with growth medium and re vegetated. Planned species include Partridgefoot, pink and white mountain-heather, crowberry, green alder and willow species (RTEC, 2018).  Figure 6. Johnny Mountain, with airstrip, tailings pond and mill building at the base of the slope. In the foreground, Bronson Slope deposit. Quartz Rise, a focus area for exploration activities, is to the left, along the slope rising above the tailings pond, to the top of Johnny Glacier. This airstrip is deactivated; access is only by helicopter or by fixed wing to the Bronson Airstrip, 10 km away.  EXAMPLE 2 SnipGold, with the assistance of various contractors, coordinated the completion of both a Dam Safety Review and Inspection on the TSF, changing the Engineer of Record and updating the paperwork and the facility to bring the facility into compliance with the 2017 updates to the Mines Act and Code for tailings storage facilities (BC MEMPR, 2016). Fortunately, historical records for the JMM TSF were maintained up to date by the previous owners, and the original Engineer of Record was available for interviews (Figure 7). The TSF itself is small, located in northwest BC (56°37’45’’N and 131°04’20’’W) at about elevation 1100 masl, between the Craig and Iskut rivers on an alpine plateau on the northwest flank of Johnny Mountain.    Figure 7. Tailings Storage Facility Schematic Johnny Mountain Mine, Skyline Gold Corporation, 2001 reproduced in the Dam Safety Inspection Report (KCB, 2018). The TSF comprises a wet cover tailings storage facility, constructed in 1987 and 1988, and covers approximately 11.5 ha, with an approximately 10 ha pond (Figure 8). It includes a closure spillway, seepage ponds and perimeter collection ditches (KCB, 2018). The TSF is a truncated ring dyke of four embankments of compacted glacial till with a sand and gravel under-drain, downstream slope ranging from 2.5H:1V to 1.9H:1V, upstream slopes of about 1.5H:1V and minimum crest El. 1097.6 m. The compacted till dykes were built on natural ground that formed an impoundment around a mountain lake or “tarn”. The embankments are between 3 m and 9.9 m high, with a nominal 5 m crest width (ranges from 4.7 m to 11 m) (Tosney, 2014). The Northwest and Southwest dams abut against the JMM landfill situated on high ground on the west side of the TSF (KCB, 2017).    Figure 8 View to north of JMM plateau, with TSF and Mill Building in foreground.  Historical records  In August 2014, a letter was sent out to all TSF owners in British Columbia, from the Ministry of Energy, Mines and Petroleum Resources Chief Inspector’s Office, directing all companies to provide information on their Tailings Storage Facilities (TSF), following the Mt. Polley tailings dam failure (MEM, 2014). Tasks included conducting a Dam Safety Inspection (DSI) and submitting the report by December 1, 2014. Secondly, the DSI Report was to be reviewed by an Independent, Qualified third party Professional Engineer, from a firm that had not been associated previously with the TSF. A dam consequence classification review was to be included in the third party review. SnipGold submitted a 2014 DSI, by the December 1, 2014 deadline. However, because the submissions lacked other details, MEMPR declared the work “incomplete” in another letter containing further Orders (MEMPR, 2015). Therefore, the DSI 2014 recommendations are carried forward into this report.  In the 2014 DSI, JRT Geotechnical classified the JMM TSF dam as a 'Low' consequence facility, according to the Canadian Dam Association (CDA) 'Dam Safety Guidelines' (CDA, 2013), (Tosney, 2014). The classification of ‘Low’ has not changed since the cessation of mining operations in 1990. In 2014, the following geotechnical recommendations were made: 1. As indicated in Section 3.2, it is recommended that localized cracks identified at various locations along the dam crest and the interior slope be specifically observed and monitored using photo comparison techniques, to determine if the crack propagation is significantly progressive, and if rehabilitation work is warranted in the future. In-filling of these cracks with sand or an equivalent is recommended but not urgently required. 2. As indicated in Section 4.2, given that the quantity of functioning piezometers has decreased since construction, and the reliability of others is questionable, JRT recommends the installation of approximately four (4) replacement piezometers to assist with ongoing performance monitoring. 3. As indicated in Section 4.3, given the uncertainties regarding the reliability of the current weirs, JRT recommends the installation of four (4) robust / permanent weirs at locations similar to those currently installed, to facilitate more consistent and repeatable weir flow measurements in the future. Compliance Reports Outstanding Upon acquiring the company in mid-2016, the new owners of SnipGold Corp. were responsible to complete the following tasks to bring the TSF into compliance:  • Summarize the Recommendations of the DSI and the Independent Third Party Review of the DSI in a letter, including commitments to complete the recommended work and providing a schedule for completion of the recommended works; • Prepare and submit an Emergency Preparedness & Response Plan (EPRP); • Prepare and submit a Dam Break Inundation Study; and • Test the EPRP consistent with the Canadian Dam Association, Dam Safety Guidelines (CDA Guidelines), prepare a report and submit it. • Commit to schedule and complete the recommendations for repairs and maintenance on the TSF as required by the Chief Inspector’s Orders in 2014 (MEM, 2014). Compliance Actions Completed 2016-2018 To bring the TSF into compliance with current standards, SnipGold Corp. organized the following:  • Contracted Klohn Crippen-Berger engineer Neil K. Hemrajani Singh, P.Eng., as the new Engineer of Record for JMM TSF; • As part of a changeover of the Engineer of Record (EOR), submitted a 2016 Dam Safety Review (DSR) as a replacement for a DSI for the year 2016. The Dam Safety Review was also due – it is a requirement every five years in the Code Part 10.5.4 - and it would provide a systematic review of the TSF for the new EOR. The 2016 DSR was submitted on March 30, 2017; • Plan, develop and install a maintenance and instrumentation update program at the TSF to bring the existing instrumentation to 2017 Code requirements as per the BC MEMPR Guidance Document Health, Safety and Reclamation Code for Mines in British Columbia Version 1.0 Updated July 2016 (BC MEMPR, 2016); • Scheduled the EOR to conduct a site inspection in August 2017 to conduct an Annual Dam Safety Inspection (DSI) as per 10.5.3 and 10.5.4 of the Code, to be submitted before March 31, 2018; and • Committed to submitting a working version of an Operations, Maintenance and Surveillance (OMS) Manual as per 10.5.2 of the Code by March 31, 2018.  Field Activities Completed 2016-2018 KCB was contracted by SnipGold to provide a field supervisor to supervise the recommended TSF repair tasks during the 2017 construction season. Tahltech (Geotech Drilling) was contracted by SnipGold to perform all drilling requirements for the installation of the piezometers using a sonic drill. Tahltan Nation Development Corp. was contracted by SnipGold to supply operators and labors as required during the piezometer installation using sonic drilling and TSF repairs. Rescan Tahltan Environmental Consultants (RTEC) was contracted by SnipGold to carry out the hydrology measurements at the TSF seepage collection ponds and to construct and instrument the weirs (RTEC, 2017). The 2018 works resulted in: • repair of stress cracks on the TSF embankment dam surfaces and erosion repairs to the upstream face of the TSF, due to wave action (Figure 9); • installation of five (5) Vibrating Wire Piezometers (VWP), complete with data loggers (Figure 10); • install robust weirs downslope of the TSF for seepage collection and measurement; and • General housekeeping details identified in the DSI.   Figure 9 shows the TSF embankment, with repaired crest and upstream slopes.  Figure 10 shows the TSF embankment with installed replacement piezometers (KCB, 2017).   General Housekeeping on the TSF, as recommended in the 2014 DSI included: • Removal of a materials storage “sea can” and P&H hoist crane from the TSF embankment; • Removal of old 45gallon drums and electrical cable from within the embankment; • Removal of woody debris and vegetation from the TSF permanent spillway (2017); • Removal and grouting of old piping inside the TSF (2017); and • Removal of small “islands” of tailings which were above the normal pond elevation (2018); The recommendations for physical works on the TSF from the 2014 JMM DSI were completed between 2016 and 2018. The activities included completing the three recommendations for TSF repairs. The site was inspected by MEMPR Geotechnical Inspectors on July 13, 2017 (MEMPR, 2017). SnipGold Corp. understands that it is currently in compliance and has met all the outstanding requirements to maintain the TSF in compliance with the Mines Act and Code. There has been no response from MEMPR since the 2017 Geotechnical Inspection Report, to the submission of JMM TSF related documents.  EXAMPLE 3  SnipGold Corp. investigated the remaining Johnny Mountain Mine site infrastructure to determine if existing mine conditions were in compliance with the Mines Act and Code (BC MEMPR, 2017). A Ministry of Energy Mines and Petroleum Resources (MEMPR) site inspection was conducted on July 13, 2017 by Dr. Paul Hughes accompanied by Doug Flynn Senior Mines Inspector, MEMPR and Carey deHoog, Operations Manager of MEMPR Smithers, accompanied by representatives from SnipGold Corp.  On July 21, 2017, SnipGold Corp. received the Report of Geotechnical Inspector, Dr. Paul Hughes, P.Eng., on the Inspection of Johnny Mountain Mine, Permit No. M-178. 1. Standing Order: Per Section 6.1.1 (1), Johnny Mountain shall not enter the underground workings for the purpose of exploration without a report prepared by a Qualified Person on the stability of the underground working and portals for the intended work. Underground exploration cannot occur without approval of the Mine Inspector.  SnipGold responded with a letter of commitment to adhere to the Order. In addition to this Order, the Mines Act and Code Part 10.6.4 states that underground openings shall be sealed to keep secure and to prevent inadvertent access. Actions to achieve this goal in 2016 and 2017 included reviewing historic records and plans to identify openings, site investigations to locate openings, and temporarily blocking known openings with soil and wood (Portals at Levels 10, 11 and 12), while allowing groundwater to drain freely. 2018 activities included removing portal structures and filling the openings with local materials. Figure 11 shows the removal of the Level 10 portal structure in preparation for re-sloping using local materials. For vertical shafts, the openings were permanently sealed with thick layers of expanding foam and covered with local materials (Golders Associates, 2019). Regulatory compliance in this example was achieved by following the Code, and keeping the Regional Mines Office and Tahltan Central Government informed on proposed and completed reclamation activities. The Mines Act permit for Johnny Mountain Mine did not require amendments, as the planned activities followed the approved 1999 Closure Plan. SnipGold experienced challenges with MEMPR and MECCS in achieving SnipGold’s goal of regulatory compliance at JMM. As a closed mine, many regulators were unfamiliar with the Project history, so substantial time was/is spent introducing and explaining the JMM Project to reviewers. SnipGold’s Applications were/are frequently considered “low priority” and “low risk”, leading to delays in Application reviews and almost indifference to the outcomes from the regulatory agencies. Between 2014 and 2019, there is an increased focus on process maps (flowcharts and checklists), with little regard to the quality or efficacy of Application contents.    Figure 11: 2018 photo of the remaining demolition at the Level 10 Portal, directly upslope of the Mill Building.  SUMMARY Three examples were used to describe the process of bringing Johnny Mountain Gold Mine into regulatory compliance. All planned activities were communicated to MEMPR and Tahltan Central Government through annual update meetings, site visits and reclamation reports. SnipGold’s efforts to bring JMM into regulatory compliance occurred in parallel with several MEMPR and MECCS important changes in policies, standards, criteria and guidance. Close communication with MEMPR and MECCS allowed the owners to navigate the requirements successfully, as both parties were committed to a satisfactory outcome. The Landfill Upgrade is a critical path item in the overall site reclamation plan and schedule. Quantifying the existing status and potential risks at the Tailings Storage Facility (TSF) are ongoing efforts. Each year, SnipGold gains site knowledge and scrutinizes the site to ensure existing mine conditions are in compliance with permits, the Mines Act and Code regulations now and into the future.  REFERENCES AMEC Foster Wheeler. 2017. 2017 Project Execution Plan Johnny Mountain Mine Reclamation. Prepared for SnipGold Corp. May 2017.  AMEC Foster Wheeler. 2017b. Johnny Mountain Mine Reclamation Project Site Investigation Report. Prepared for SnipGold Corp. November 2017.  BC Ministry of Energy and Mines, 2015. Letter to SnipGold Corporation, Re: Review of Submission in Response to Chief Inspector’s Orders Issued August 18, 2014. Prepared by Ministry of Energy and Mines, 2 p. BC Ministry of Energy, Mines and Petroleum Resources. 2016. (BC MEMPR, 2016). Health, Safety and Reclamation Code for Mines in British Columbia. Ministry of Energy, Mines and Petroleum Resources 361p. BC Ministry of Energy, Mines and Petroleum Resources. 2019. (BC MEMPR, 2019). Ministry of Energy, Mines and Petroleum Resources 2019/20 – 2020/21 Service Plan, BC Ministry of Energy and Mines. 2014. Letter to SnipGold Corp. Notification of Chief Inspector’s Orders Tailings Dams – Independent Review of Dam Safety and Consequence Classification. Prepared by BC Energy and Mines, 2 p. BC Ministry of Environment, 2008. Letter to Skyline Gold Corporation. Official Warning – Unauthorized Burning and Burial of Waste. Prepared by the BC Ministry of Environment, June 11, 2008, 5 p. BC Ministry of Environment, 2016. Landfill Criteria for Municipal Solid Waste (Second Edition). Prepared by the BC Ministry of Environment, June 2016, 76 p. BC Ministry of Environment,1993. Ministry of Environment Landfill Criteria for Municipal Solid Waste” (“Criteria”) First Edition, 1993. BGC Engineering Inc. 2008. Johnny Mountain Mine Site Environmental Assessment: 2007 Burning and Burial Areas. October 2008.162 p. Canadian Dam Association (CDA, 2013). Dam Safety Guidelines 2007 (Revised 2013)”. Golder Associates Ltd, 2019, SnipGold Johnny Mountain Mine Construction Completion Report- Vent Raises Closure Plug Construction. Prepared on behalf of SnipGold Corp.199p Greenwood Environmental, 2016. Johnny Mountain Mine Annual Reclamation Report 2015. March 2016. Prepared for SnipGold Corp., prepared by Greenwood Environmental Inc. 285 p. KCB, 2017. 2016 SnipGold Corporation Johnny Mountain Mine Tailings Storage Facility 2016 Dam Safety Review. Prepared for Snip Gold Corp. by Klohn Crippen Berger.115p KCB, 2018. Johnny Mountain Mine Tailings Storage Facility 2017 Dam Safety Inspection Report, prepared by Klohn Crippen Berger, prepared for SnipGold Corp., 141p  KCB. 2018a. Johnny Mountain Mine. Tailings Storage Facility Dam Breach Analysis and Consequence Classification Update. Prepared for Snip Gold Corporation by Klohn Crippen Berger.  NW Response. 2018. 2018 Summary Report Johnny Mountain Mine Reclamation Project: Removal and Transfer of Waste Materials from Burial Sites #1 and #2. Prepared for SnipGold Corp. by NorthWest Response Ltd: Smithers, British Columbia, 119p. RTEC. 2018a. Iskut Project: Annual Reclamation Report for 2017: Mines Act Permit Number M178. Prepared for SnipGold Corp. by RTEC: Vancouver, British Columbia. RTEC. 2018b. Iskut Project: 2018 Johnny Mountain Re-Vegetation Plan. Prepared for SnipGold Corp. by RTEC: Vancouver, British Columbia. RTEC. 2018c. Iskut Project: 2018 Johnny Mountain Tailings Pond and Portal Hydrologic Monitoring Summary. Prepared for SnipGold Corp. by RTEC: Vancouver, British Columbia. Seabridge Gold, 2018, Seabridge Gold-Finding Gold Annual Report, http://seabridgegold.net/pdf/18AR.pdf, 52p SnipGold. 2019. Johnny Mountain Mine Reclamation: 2019 Project Execution Plan. Prepared by SnipGold Corporation. Sperling Hansen 2012. Johnny Mountain Landfill Preliminary Design Report. Prepared for SnipGold Corp. June 2012. 37 p. Tosney, J.R. 2009. 2009 Johnny Mountain Tailings Storage Facility Dam Safety Inspection. Prepared by JRT Geoengineering. Wood. 2018. Johnny Mountain Mine Reclamation Project Main Landfill Technical Assessment Report (VE52655) 31 January 2018. Prepared on behalf of SnipGold Corp. 96 p. Wood. 2019. Post Construction Report - 2018 Main Landfill Upgrades Johnny Mountain Mine Reclamation Project British Columbia. Rev.0. Prepared on behalf of SnipGold Corp. Wood, 2019. Johnny Mountain Mine Reclamation Project 2018 Supplementary Site Investigation Report. Prepared for SnipGold Corp. January 2019, 1104p Woznow D.P. and D.A. Yeager. 1999. Closure Plan for The Johnny Mountain Gold Mine, Reclamation Permit No. M-178. International Skyline Gold Corporation, October 13, 1999. 120 p. Yeager, D.A. 2001. Annual Reclamation Report for 2000, Johnny Mountain Property, Reclamation Permit No M-178. Skyline Gold Corporation, July 23, 2001.   

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