SUNNYSIDE COLD CORPORATION AN ECHO BAY COMPANY
P.O. Box 177 .Silverton, CO 81433 Phone (303) 387-5533 .Telecopy (303) 387-5310
SUNNYSIDE GOLD CORPORATION 6/26/92 Meeting MLRD and CDH Denver, CO
Subject: Hydraulic seals in the American Tunnel and Terry Tunnel portals
PERMITS
MLR 112 Permit
o File No. M-77-378 San Juan County, Colorado
- Issued to Standard Metals Corporation January, 1978. - Transferred to Sunnyside Gold Corporation in October, 1985. - Consolidated previous Amendments and Technical Revisions into a Consolidated Permit Application submitted January, 1987.
o Permit commitments related to hydraulic seals (attached).
- Consolidated Permit Application pages E:5, G:26 - G:27. - Questions and Responses, MLRD TechnicalAdequacy Review- Consolidated Permit Application - Question 9. - Schedule of Final Reclamation. - Portal Seal Conceptual Design.
CDPS/NPDES Permits CO-0027529 and CO-0036056
o American Tunnel Discharge - CO0027529
- Originally issued to Standard Metals Corporation and transferred to Sunnyside Gold Corporation.
o This permit contained credits for zinc loadings originating from sources not on mine property within the American Tunnel- Expiration of this permit and subsequent renewal date was March 31, 1987.
- Renewal permit dated October, 1987 removed the credit for zinc loading originating from sources not on mine property. Mill Area - Cont
o Contact with R.T.C. Precious Metals was made concerning general gold cleanup of mill. Requests concerning insurance coverage was requested and a revised contract is being prepared. o Initial contact was made with the San Juan County Historical Society concerning final disposition of the mill as a donation. The Historical Society is very interested and is researching the proposal. o Reclamation work is scheduled for 1994,
Mine Portal
o Reclamation work is scheduled for 1993.
Mine Waste Dump
o Minor cleanup along the stream is planned for 1992, as well as test pits to better define the scope of work, o Close spaced sampling of the stream continued.
Terry Tunnel
o Other than water treatment during the summer and fall of 1992, this area will be inactive.
Mine Water
o Evaluation of various flows in the American Tunnel is ongoing.
Miscellaneous Engineering
o No activity to report at this time.
Hydraulic Seals
o A joint meeting with the Colorado Department of Health, Permits and Enforcement Division and the Colorado Mined Land Reclamation Division was held June 26. Hydraulic Seals - Cont
The following people were present: Echo Bay: Peter Clarke Bill Goodhard Larry Perino
Colorado Department of Health: Pat Nelson - Senior Engineer Anne Ihlenfeldt - Water Specialist
Colorado Mined Land Reclamation Division: Bruce Humphry - Supervisor of Minerals Branch Jim Stevens - Geohydrologist Allen Sorenson - Reclamation Specialist Larry Ohler - Reclamation Specialist
o A brief introduction via slides was given to show the reclamation areas and work that has been done, is in process or planned. The main topic of discussion was on hydraulic seals. The purpose of the presentation was to introduce the concept to the state agencies as well as a request for guidelines in order for the project to proceed as smoothly as possible.
o General comments from the Mined Land Reclamation Division were: - Where does water level go once plug is installed. Are friction seals stable, i.e. Keying in of plugs to prevent any movement are preferable. - Stability of plugs during earthquakes. Plug failure due to corrosion.
o Colorado Department of Health: How are reestablished or increased flows from existing seeps that are environmentally harmful to be addressed? Initial concept is that these seeps may be viewed as point source discharges.
o SGC expressed their intent to continue to examine the hydraulic seal concept with more studies, o The major issue of property boundaries was briefly addressed as to current proposed seal locations and what changes in permitting need to be addressed in order for SGC to relinquish the NPDES permits if the program is successful, o Both the Colorado Department of Health and the Mined Land Reclamation Division requested formal requests for what will constitute the definition of a successful plugging effort. Combined with this response will be guidelines for monitoring of the program for evaluation. I
o American Tunnel Discharge - CO0027529 - Contd
Whole Effluent Toxicity (WET) Amendment incorporated into permit 8/29/89. Amended again effective 3/1/91 for WET terms acceptable to EPA.
o Effective June 1, 1993 WET acute test failures will be a violation of the permit.
o Terry Tunnel Discharge - CO-0036056
Originally issued to Standard Metals Corporation and transferred to Sunnyside Gold Corporation* A credit exists for metals loading from the Lake Emma influent. - The existing permit expired March 31, 1992 and is in the process of renewal. Acute WET test requirements will be included in the renewal permit.
STATUS OF OPERATIONS AND PERMITS
o Temporary cessation of operation status was granted by the MLRD effective August 17, 1991 due to declining orebody grade and declining metal prices causing operation of the property to be uneconomic.
o Reclamation commitments are being met with reclamation of sites not required for operation of the property. Tailings Pond #1 and filling of the Lake Emma hole are the major projects in progress for 1992.
o CDPS/NPDES permit requirements are being met through operation of water treatment plants year-round at the American Tunnel and seasonally at the Terry Tunnel. These treatment plants are adequate for maintaining, on a fairly consistent basis, compliance with existing permit parameters. Mandated changes in the permits (ie. June 1, 1993 compliance date for elimination of WET in the American Tunnel discharge and anticipated changes in the renewal permit for the Terry Tunnel discharge) will possibly require major treatment plant upgrades to maintain compliance. o MLRD Technical Adequacy Review - Consolidated Permit, Item 9.B. "Indefinite mine drainage treatment is not acceptable as final reclamation* Please devise an alternate reclamation plan. Passive mine drainage treatment trials may be desirable. Please discuss." The response submits hydraulic seals with a conceptual design as the alternate plan and was incorporated into the permit application submittal.
DISCUSSION OF PORTAL PLUGGING
o Technical feasibility
John Abel Jr. P.E. Letter report after pre-engineering site visit,
o Hydrology
Simon Hydro-Search report. Preliminary Characterization of the Hydrology and Water Chemistry of the Sunnyside Mine and Vicinity, San Juan County, Colorado.
o Property Issues
- Gold King Property. - Water entering American Tunnel from Gold King Property - see attachment.
GOAL
o Develop technical plans acceptable to MLRD, CDH and SGC that will allow for return of an approximation of pre-Sunnyside Mine hydrologie conditions without the requirement of perpetual water treatment. These plans would be implemented upon the decision to enter final reclamation of the property.
TIMETABLE
o Due to impending WET driven compliance standards at the American Tunnel discharge and probable similar conditions at the Terry Tunnel discharge (pending permit renewal terms) and the economic reality of maintaining a non-producing property, SGC needs to make informed economic decisions based on possible future economics of the orebody verses these costs. TIMETABLE - Contd
- June 1, 1993 is the date that WET driven standards at the American Tunnel will become effective. Studies are in progress to identify the cause of WET test failures and whether grounds exist for requesting permit modifications that will allow compliance with existing facilities.
The Terry Tunnel permit is assumed to have similar conditions and timetables as the American Tunnel permit (June 1, 1993) due to uncertainty of the final form of the renewal permit and EPA's role in finalization of the permit.
QUESTIONS
o Are there specific technical details that a plan submittal should address other than structural and location details?
o Would plugs on SGC property line (thereby restoring pre- Sunnyside Mine hydrologic conditions) meet the terms of the MLR and CDPS/NPDES permits for final reclamation and elimination of discharge?
LP/cjk CONSOLIDATED PERMIT
MINED LAND RECLAMATION
PAGES E:5, G:26 - Gï27 Talus slope stability. Talus slope stability may be affected in local areas where borrow is obtained. Friction angles for coarse grained rockfills has been analyzed by Marachi ’for various confining stresses. For low confining stresses, typically less than 100 psi, similar to the Lake Emma area, friction angles may be on the order of 45° (Appendix 1-B). hfinite slope stability analysis, therefore, indicates that excavations steeper than 1 horizontal to 1 vertical will probably exhibit ravelling until a slope develops that is similar to that which currently exists. By limiting the height of cuts large slope movement should not occur. Excavation of talus slopes will be done in such a manner that all vertical faces will be less than 10 feet. Slope movement associated with this height of slope, even if they occur, should notjeopardi2e the outlet by plugging the canal. As shown on the Exhibit C4b map, the only talus slope nearby the diversion is located to the west of the channel. Access road. The access road is pre-existing and serves other patented claims in the area. It will therefore remain open following reclamation of Lake F-mma.
Terry Tunnel The Terry Tunnel area will be reclaimed and revegetated at the end of the life-ofmine operations. As part of the reclamation program, all trash and refuse at the site will be removed or buried. Refuse existing at the surface will be picked up and placed in the existing ponds for burial. If necessary, the pond excavations at the site will be enlarged to facilitate burial'. AH refuse and trash will be buried with at least two feet of material prior to revegetation. Suitable material is available at the Terry Tunnel site for covering the refuse and trash to be buried. Material will be made available primarily by excavating and grading of the pond areas and embankment sideslopes. A main priorityfor reclamation at the Terry Tunnel site will be to reclaim the site without further disturbance of undisturbed areas for borrow or plant materials. Revegefation of this area will be conducted after final grading. Fertilizer and mulch will be. used as amendments. The seeding techniques and amendments to be used will be the same as described above for Lake Emma, except it is known that existing materials used as revegetation media are low in plant nutrients, and for that reason specific fertility testing of the final graded surface will be conductedjust prior to revegetation. Amlyses of samples' will be conducted by the State Soils Testing Laboratory at Colorado State University. Revegetation will employ the "Alpine Mixn seed mixture (at approximately 120 seeds per square foot, broadcast) and specific seeding methods described later in Table E-3. The mixture differs slightly from the mix proposed for the Lake Emma area owing to a difference in elevations. The road up Eureka Gulch is public and will remain in place after final reclamation. American Tunnel Upon final reclamation, the portal entrance at the American Tunnel will be sealed to prevent drainage (see Exhibit G). Disturbed areas within the current permit area will be reclaimed and revegetated. Surface facilities will be dismantled and removedfrom the site. Final reclamation of the American Tunnel site is not expected to take place for many years. After surface facilities have been dismantled and removed, and all other materials removed or
*Marachi, D U ., Chan, CJC., Seed, HM„ and Duncan, JM . 1969. Strength and deformation characteristics o f rock fill materials, report No. TE-69S to State of California, Dept. Water Resources, University of California, Berkeley. under other lakes and that cover distances below Eureka Gulch are substantial and not likely to collapse. Stability above underground openings, in general, will be governed by the depth cf overburden. In areas where the ratio of undisturbed overburden to width of opening (the workings average about 14-18 feet in diameter) is greater than 5, no immediate surface effects are expected. In areas where this ratio is less, subsidence over the long term may occur. Future mining plans may require removal cf material in areas where the overburden to width ratio is less than 5. At the present time, only the Lake Emma area is in this category. In this area backfilling after mining will be done. If other areas are encountered during the continuing development ofmining plans, the mining permit will be modified to present areas to be mined, methods cf mining and long term stability methods such as rock reinforcement, backfilling, and instrumentation. The only areas where current concern exists would be for the workings immediately beneath the Lake Emma area. These areas of thin roof will be removed based on current mining plans and backfilled as part cfreclamation, as specified in Exhibit E. Closure of adits. As discussed with the MLRD staff at the September 18, 1986 meeting, it is anticipated that, to alleviate the need for indefinite mine drainage treatment, a hydraulic seal will be installed in both the Terry and American Tunnels upon closure of the mine. The seal will act to prevent any substantial releases of underground waters from the tunnels to the ground surface. Portal closure is planned for the American Tunnel and Terry Tunnels. Detailed plans are not available at the present and will be developed prior to actual construction. Conceptual plans would be to place a by-pass pipe for the water flows with a valve in it. A rubble or concrete temporary bulkhead with supports into the bedrock would then be constructed as necessary. The valve would then be closed and a plug of concrete placed immediately qfter closure to provide an adequate factor of sqfety against blow-out under full head (refer to Appendix 2-F). The plug would be placed back in the tunnel so additional hydrostatic pressure will have limited effect on the overburden rock. Waters that currently discharge from the tunnels are thought to be from near surface sources, which irfiltrate into fractures/joints that penetrate the various workings within the mine. No specific data related to underground waters within the mine or the sources of these waters exist for the site. However, based on the physical ground conditions that exist at mining sites similar to the Sunnyside Mine, certain conclusions can be drawn regarding potential discharges of impacted mine water to the surface. Obviously, without any form of hydraulic seal, the tunnels will continue to discharge water from the mine workings. The source of the water in the workings has to be attributed to water infiltrating (recharging)from the near surface environment. With the hydraulic seals in place water m il accumulate within the underground workings until some equilibrium conditions prevail. It is conceivable that water that is stored in this manner may arise at the ground surface through the various near surface Joint/fracture system(s) associated with the mine. Likewise due to the physical (small exposure) and chemical (reducing environment) characteristics of the sealed mine, the quality of this water would be of a better quality than what is currently producedfrom tunnel discharges. Any attempt to evaluate the quantity and quality of water that may eventually seep from the mine would require a very in-depth and sophisticated investigative process. With regard to the Terry Tunnel, and again qualitatively speaking, flow from the tunnel occurred only after the failure of Lake Emma. The source of water to the tunnel is thus through infiltration of surface water to and through the disturbed rock associated with this failure. Therefore, with the planned reclamation of Lake Emma, the flow to the Terry Tunnel is expected to be reduced. However, since some of the surface/near surface water enters the mine through the coltuviaI mantle that surrounds Lake Emma, reclamation of Lake Emma will not intercept some of this type of inflow. TECHNICAL ADEQUACY REVIEW
CONSOLIDATED PERMIT
MINED LAND RECLAMATION
PAGES 43 - 44 RESPONSE Suitable material is available at the Terry Tunnel site for covering the refuse and trash to be buried Material will be made available primarily by excavating and grading of the pond areas and embankment sideslopes. Refuse disposal and reclamation is discussed previously under question D.15 of this document, and more fully in the Consolidated Pennit Application. A main priority for reclamation at the Terry Tunnel site will be to reclaim the site without further disturbance of undisturbed areas for borrow or plant materials. Based on analyses of samples collected from the Terry Tunnel site, presented in Tables D-2, D-4, the mine bench rock debris appears to be suitable material for reclamation has been identified at the Terry TunneL
9. A. Please specify Terry Tunnel and American Tunnel pond maintenance plans and sampUng schedules following reclamation. B. Indefinite mine drainage treatment is not acceptable as final reclamativi Please devise an alternate reclamation plan. Passive mine drainage treatment trials may be desirabk. Please discuss. C. I f the Terry Tunnel hui dry until shortly after the coUapse o f Lake Emma and If Lake Emma is to be properly reclaimed then continued ftowftom this tunnel should be minimal Additional work should be done to determine if these flows are surface water and whether sealing Lake Emma will eliminate flows. The operator should also investigate channelizing flows through the American tunnel to minimize site maintenance upon reclamation.
RESPONSES As discussed with the MLRD staff at the September 18,1986 meeting, it is anticipated that, to alleviate the need for indefinite mine drainage treatment, a hydraulic seal will b e installed in both the Terry and American Tunnels. The seal will act to prevent any substantial releases of underground waters from the tunnels to the ground surface. Portal closure is planned for the American Tunnel and Terry Tunnels. Detailed plans are not available at the present and will be developed prior to actual construction. Conceptual plans would be to place a by-pass pipe for the water flows with a valve in it A rubble or concrete temporary bulkhead with supports into the bedrock would then be constructed as necessary, l i e valve would then be closed and a plug of concrete placed immediately after closure to provide an adequate factor of safety against blow-out under full head (Refer to Appendix 2-F of the Consolidated Permit Application.) The plug would be placed back in the tunnel so additional hydrostatic pressure will have limited effect on the overburden rock. Waters that currently discharge from the tunnels are thought to be from near surface sources, which infiltrate into fractures/joints that penetrate the various workings within the mine. No specific data related to underground waters within the mine or the sources of these waters exist for the site. However, based on the physical ground conditions that exist at mining sites similar to the Sunnyside Mine, certain conclusions can be drawn regarding potential discharges of impacted mine water to the surface. Obviously, without any form of hydraulic seal, the tunnels will continue to discharge water from the mine workings. The source of the water in the workings has to be attributed to water infiltrating (recharging) from the near surface environment. With the hydraulic seals in place water will accumulate within the underground workings until some equilibrium conditions prevail It is conceivable that water that is stored in this manner may arise at the ground surface through the various near surface joint/fracture system(s) associated with the mine. Likewise due to the physical (small exposure) and chemical (reducing environment) characteristics of the sealed mine, the quality of this water would be of a better quality than what is currently produced from tunnel discharges. Any attempt to evaluate the quantity and quality of water that may eventually seep from the mine would require a very in-depth and sophisticated investigative process. With regard to the Terry Tunnel, and again qualitatively speaking, flow from the tunnel occurred only after the failure of Lake Emma« The source of water to the tunnel is thus through infiltration of surface water to and through the disturbed rock associated with this failure. ^ Therefore, with the planned reclamation of Lake Emma, the flow to the Terry Tunnel is expected to be reduced. However, since some of the surface/near surface water enters the mine through the colluvial mantle that surrounds Lake Emma, reclamation of Lake Emma will not intercept some of this type of inflow.
10. Please specify energy dissipation measures to be employed at the pond outlets/receiving streams "confluence!*
R e s p o n s e Hie response to this question is discussed under response to question D.16.
//. Sludge dispose! at TaiSng Pond 93 should be conducted such that reclamation may commence as soon as possible. Ptease devise a plan enabling this.
R e spo n se Sunnyside proposes to continue to use Pond No. 3 for the disposal of sludge from the American Tunnel settling ponds. Based on current estimates of sludge production, at the existing stable embankment height there is sufficient capacity, including freeboard capacity, in the impoundment for several additional years of disposal. Once this disposal capacity has been reached, the pond will be reclaimed
I t Please specify thefinal configuration of the Borrow Area atffacent to TaiSng Pond f 3.
R e sp o n se The borrow area will be graded to blend the edges of the disturbance area in with existing contours. Final configuration will approximate pre-disturbance conditions in terms of slope and aspect As described in Exhibit E, the area will be revegetated. The final slopes will be no steeper than 2:1 and are shown on Exhibit FI and range from about 2.5:1 to 4:1. RECLAMATION TIMETABLE
CONSOLIDATED PERMIT
MINED LAND RECLAMATION 1989 ] C 1990 1991 1992 1st 2nd 3rd 4tb 1st 2nd 3*d 4th 1st 2nd 3id 4th 1st 2nd 3rd 4th 1st 2nd 3id 4th 1st 2nd 3rd 4th B EMMA
Backfill lake basin « Construct comoacted clav liner • Roueh site eiadine 9 Fine eradine. seedbed weo • Seed, mulch, ferdtixe • Monitorina and maintenance 0
RY TUNNEL
Cons tract portal hydraulic seal Backfill adit Refuse cleaiv-Bpand disooeal Refuse burial and site endine Fine eradine. seedbed nre© Seed, mulch, fertilize Monitoring and maintenance
IRICAN TUNNEL
Surface fadlldes dismantling 1 & dirooul or removal Construct vorta) hydraulic seal Backfill adit Refuse area recontoorine & burial 0 0 0 Decommission settlinr t>onds Rooeh site cradinc Fine sradine. seedbed tret> Seed, mulch, fertilize Monitorina and maintenance
$ * Incompleto! or ongoing operations • » Completed operations RECLAMATION TIMETABLE
1 J99S 1 f 1996 I I 1997 1 I 1998
1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd 3zd 4th 1st 2nd 3fd 4 th 1st 2nd 3rd 4th 1st 2nd 3rd 4th E EMMA
Rarkfill lalra hatin Construct compacted dav liner Roush site ending Fine grading. seedbed otto Seed, mulch, fertilize Monitoring and maintenance 0 0 •
RY TUNNEL
Construct portal hvdraolic seal Backfill adit Refuse dean-up and disposal Refuse burial and site grading Fine ending, seedbed wro Seed, mulch, fertilize Monitoring and maintenance
RICAN TUNNEL
Surface farilitiea dismantling 1 &. disposal or removal Construct portal hydraulic seal Backfill adit Refuse area recontouring S t burial Decommission settling ponds Rough site grading Fine grading, seedbed prep Seed, molch. fertilize Monitoring and maintenance
0 «Incompleted or ongoing operations Completed operations RECLAMATION TIMETABLE — FINAL RECLAMATION — issation of Mining Operations Anticipated Final Bond R<
Year 1 “ I I Year! I C Year 3 Year 4 Year 5 Year 6
1st 2nd 3id 4th 1st 2nd ani 4th 1st 2nd 3ri 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th E EMMA
Roush site grading Fine PTMÜnff. aeedbed vno J3 I 1
RY TUNNEL
Construct nortal hydraulic seal • RackfiHadit • Refhse dean-oo and disoosal • Refuse boriai and site sradine • • • ! i 0 G 0 •
2RICAN TUNNEL
Snrfrr rf«*m*nrting | & dunosa] or removal $ • Construct nortal bvdtialic seal • • ' l 1 s « ♦ tVcnmmisrion settlingnonds • • Fine eradine. seedbed rreo • • Seed, mulch, fertilize • Monitoring and maintenance $ 0 0
0 «lacompïeted or ongoing operations 'C om pleted operations PORTAL SEAL CONCEPTUAL DESIGN
CONSOLIDATED PERMIT
APPENDIX 2-F
MINED LAND RECLAMATION Appendix 2-F
Portal Seal Conceptual Design JCR C onsultants, Inc. OF Geotechnical Engineering, JOB NO.. « M E fT w o . .DATE JZ j2 ,u Hydrogeology and Water Quality p r o j e c t . -----»V,
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AMERICAN TUNNEL /mit/mm
Flow In Gallons per Minute -»—»/— n ae prxmae Te n o tak Is track portal. of Tunnel end Amerlean The the of ate. outside approxim ]ust are and Fo ws aue wt a ym fo meter m flow pygmy a with easured m was Flow Tunnel American . 2 the of wall the on marked as NOTES EXPLANATION 2000 2000 n coe 2-3, , 3 - 2 October on y vln iga ad u Lws f SJCMV of Lewis Guy and Bingham Evelyn by track of end from dlstanee are Footages 1, 2 5 0 0 - - - 0 0 5 2 1500 1000 Fo Maueet Points Measurement Flow O 500 4/*t 0 0 5 8 -
MiMIJW______
L veins ashington, W obnd flow Combined n Sunnyslde and f Brenneman, of 0 0 5 4 - 0 0 5 5 - 0 0 5 6 - 0 0 5 7 - 1991.
runaround 0 0 7 0 nlw from Inflow otg fo Ed f Track of End from Footage
te sets steel with zone Fracture 0 0 5 - 0 0 5 1 - 0 0 5 2 - 0 0 5 3 -
______a Jan ony iig etr o*te» Venture Mining County n Jua San nrae Joint Increased Generalized ee o portal to here emaiiy from permeability Flow Profile Along the the Along Profile Flow mrcn Tunnel American lvro, Colorado Sllverton, SOJXKTS- OOCERS S R E C O -O S T S G O L D E -C S T K X J O rS K yr-erh Inc. Hydro-Search, mnr tllirtw Wb« W w t r i l l t r n ím m I
______rw IKE^ E K I draw* C55E3r3i95 t 1 * 1 0 1 1 4 * 4 s L ftO P * O N DWO iuo 10 Figuro Portal m / M / i o
SUNNYSIDE MINE
UNDERGROUND WORKINGS
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