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Province of British Columbia Ministry of Environment and Parks ENVIRONMENTAL APPEAL BOARD Victoria British Columbia V8V 1X5 APPEAL NO. 88/03 WASTE J U D GEM ENT In the appeal of the Cottonwood Community Asociation under the Waste Management Act and the Environment Management Act against the decision of the Director of Waste Management, dated 26 February 1988 granting approval for Gold Ridge Resources Inc., to undertake an in-situ pilot scale injection-recovery test at a site near Wingdam, British Columbia, (Permit SE35253). A P P ELL ANT Cottonwood Community Association p.a. Box 4237 Quesnel, British Columbia V2J 3J3

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Province ofBritish Columbia

Ministry ofEnvironmentand Parks

ENVIRONMENTAL APPEAL BOARDVictoriaBritish ColumbiaV8V 1X5

APPEAL NO. 88/03 WASTE

J U D GEM ENT

In the appeal of the Cottonwood Community Asociationunder the Waste Management Act and the Environment Management Actagainst the decision of the Director of Waste Management, dated26 February 1988 granting approval for Gold Ridge Resources Inc.,to undertake an in-situ pilot scale injection-recovery test at asite near Wingdam, British Columbia, (Permit SE35253).

A P P ELL ANT

Cottonwood Community Associationp.a. Box 4237

Quesnel, British ColumbiaV2J 3J3

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APPEAL NO. 88/03 WASTE PAGE 2

HEARING DETAILS:The hearing was held on 17-18 May 1988, in Quesne1, British

Columbia, before a Panel of the Environmental Appeal Board. Boardmembers in attendance were:-

Mr. H.D.C. HunterMr. Duncan W. Hedd1eMrs. Marjorie Ryan

- Panel Chairman- Panel Member- Panel Member

Mrs. Susan Tyree of PRS (Professional Recording Services)acted as recorder of the proceedings.

APPELLANT:

Cottonwood Community AssociationP.O. Box 4237Quesne1, British ColumbiaV2J 3J3

Represented by Mrs. Betsy Van Halderen

RESPONDENT and PEmfIT HOLDER:

Gold Ridge Resources Inc.1083 Lodge RoadNorth Vancouver, British ColumbiaV7R lW7

Represented by Mr. Bryan T. Nethery, P.Eng.

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APPEAL NO. 88/03 WASTE PAGE 4

This appeal is against approval No. SE35253 dated26 February 1988 issued by the Director of Waste Management to GoldRidge Resources Inc. authorising a test injection of an aqueoussolution of a cyanide compound into the ground near Wingdam and therecovery thereof by pumping:

The appellants are concerned that the cyanide will entertheir wells and contaminate them. They are not satisfied thatunreasonable damage to the environment will not occur.

EVIDENCE:The respondent, Gold Ridge Resources Inc. opened the

hearings and presented its case in support of the approval grantedto it. Mr. Bryan T. Nethery, P.Eng., Wright Engineers Ltd. and Mr.Andrew Holmes, P.Eng., of Piteau Associates Engineering Ltd. gaveevidence.

The basal gravels in Lightning Creek, which flows from theBarkerville area to the Cottonwood River and hence to the Fraser Riverare known to be rich in placer gold. However, the gravels are deep,around 150 to 160 feet below present ground levels, they are thoughtto be about 8 feet thick and to vary in width. Little is known ofthe exact dimensions.

The basal gravels are overlain by a layer of silty sand,known as 'slum', which is relatively impervious. Above the slum is alayer of silty sand and gravel and above that a layer of gravel. Thebasal gravels are pervious and are saturated with water under asufficient artesian head so that at the test site near Wingdam thewater will rise through a drill casing to the ground surface. Thiswater under artesian head has foiled numerous attempts to get at thegold by conventional methods.

The use of cyanide to leach gold out of gold bearing rockor out of old tailings is not new and is frequently used on the

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APPEAL NO. 88/03 WASTE PAGE 5

surface. No one has yet used cyanide to leach gold from the gravelsstill in place underground. The respondent thinks this is feasibleand economic and is developing the process.

Like any new application of a known principle, developmenttests must proceed in steps. The proposed test is one such step andis intended to see if gold can be extracted safely and economicallyby this method. If the proposed test is satisfactory further testsand development will be required before a full scale operation can beundertaken.

There are two main aspects to this test:-(a) will the gold be recoverable by this method and(b) will the cyanide be recoverable from the ground

and can it then be safely destroyed.

There have been two tests already using brine. In the firsttest, the brine was not all recovered. This was thought to be. due tothe use of a very strong solution. A second test using a weakersolution indicated that the brine could be recovered.

Tests were also run in a laboratory to show that the cyanidewould be recoverable and could be safely neutralized. The first suchtest indicated that a very significant proportion of cyanide wouldremain in the ground. On the strength of this test the WasteManagement Branch recommended rejection of the application. TheDirector concurred and the approval was refused.

These tests appear to have been improperly performed, indeedwere dangerous to the laboratory technicians. These tests wereperformed by a well known and well respected company.

Other tests performed more properly by B.C. Research andDegussa Corporation indicated that a very high percentage of thecyanide would be recovered. On the strength of these further teststhe Director issued his approval.

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APPEAL NO. 88/03 WASTE PAGE 6

The tests will allow about 10 lbs. of the cyanide compoundto be injected into the gravels. It will remain there for a periodand will then be pumped out again over a period. There are testwells close to the injection well which will show the dispersion ofthe cyanide. An interceptor well upstream will reduce the pressurein the test area so that the flow of water will stop.

When the pumping out begins, the cyanide solution will berelatively strong, but as the pumping continues, the inflow of thesurrounding water to the injection well will cause the solution to beweakened. The rate of dilution is one of the objects of these tests.

The extracted solution will be put into fibreglass tanksand treated, on site, to reduce the cyanide concentration to anacceptable level. After treatment the solution will be put into atank truck. It will be carried about one-quarter mile to theexfiltration pond where it will seep through the gravel to LightningCreek. Test wells have been installed near this exfiltration pondto monitor the seepage.

The approval specifies the maximum strength to go into theexfiltration pond and the rate of inflow which is related to theflow in Lightning Creek nearby. The approval also requires thepumping to continue until the solution has been reduced to 0.3 ppm,which is less than one third of the concentration permitted to beplaced in the exfiltration pond.

Mr. Holmes provided two very important pieces of evidence.First he stated that the water in the gravels had a large percentageof iron in it and no dissolved oxygen and therefore is not potable.It was clear that none of the wells in the area were fed from thisaquifer. Secondly although the gravels were very pervious and thewater flowed through them readily, this was a relative term. Thebrine test indicated a flow velocity of about five metres per day.The rate of flow has no relation to the speed of flow in LightningCreek.

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APPEAL NO. 88/03 WASTE PAGE 7

Mrs. Betsy Van Halderen gave evidence herself and calledmany witnesses. Much of her evidence was directed against a fullscale operation rather than a single test. She also sought todiscredit the procedures leading to the approval. Plainly the firsttest results were suspect, but witnesses from the Federal Departmentof the Environment and from the Water Management Branch did notobject to this trial. Their lack of objection to the test did notin any way indicate that approval for a full scale operation wouldbe easy.

Mr. Topham, a school teacher in the area read extracts fromreports in the Ministry of Mines. They showed that many attempts hadbeen made over the last century to mine the gold. In every casetunnels or raises had been flooded and abandoned. The exact extentand location of these various tunnels, shafts and raises was notknown. Their presence would facilitate the escape of cyanide andspeed its transfer.

Mr. L. Struik of the Geological Survey of Canada statedthat little was known of the bedrock geology in the area. Little isknown of faulting or brittle structures all of which could cause arelative increase in permeability.

Mr. Myers, a mining consultant, gave evidence of thegeneral lack of knowledge of faults, tunnels, etc. in the area andpresented alternative methods of mining the gold.

Members of· the Association expressed their concerns at thepossibility of contamination of their wells and of contamination ofLightning Creek due to accidents.

The Board visited the test site and were impressed with itssize, a mere 20 metres by 30 metres. The company also demonstratedthe effectiveness of the interceptor well, by closing the discharge.The water levels in the test wells and injection well rose and began

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APPEAL NO. 88/03 WASTE PAGE 8to flow in minutes, but the injection well stopped flowing as soon asthe valve on the interceptor well was re-opened.

The exfiltration pond was also viewed. There is some riskin trucking the recovered solution from the site to the pond along apublic road.

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APPEAL NO. 88/03 WASTE PAGE 9

DECISION:It must be recognized that the appeal is against an approval

not a permit. The approval is for a single test or a series of testswith a stated limited amount of cyanide and for a short period. Theapproval itself stresses that there is no guarantee whether a furtherapproval or a permit will be granted. The company knows that thistest is only one step in a complicated process before any commercialmining by this method can begin. The Board is only concerned with theproblems of this one single test. It is however well aware of someof the problems which the company will have to address satisfactorilybefore it will obtain a full operation permit.

The Board is satisfied that .the local inhabitants will notbe put at risk by this test. However, they are entitled to assurancesthat their concerns are being watched.

The Board therefore rejects the appeal of the CottonwoodCommunity Association.

The Board directs the Director of Waste Management to amendthe approval given on 26 February 1988 in the following manner:-

1. Delete the third paragraph on page 1 of the approval andsubstitute: -"The test shall be carried out during the period from20 June 1988 to 01 October 1988 and the followingconditions shall apply."

2. Add as condition 8(k):-"Subject to obtaining the consent of the owner, the domesticwells of Mrs. McGuire, Mrs. Anderson and Mrs. Van Halderen,shall be monitored before the test begins, once every twoweeks after the test begins for six months, and once permonth for a further six months."

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APPEAL NO. 88/03 WASTE PAGE 10

3. Add as clause 9:-All chemicals on the test site or laboratory shall bekept under lock and key and the site shall not be leftunmanned at any time from the time cyanide is broughtonto the site until the pumpout test is completed.

4. Add as clause 10:-The analysis of the wells required by Clause 8(k)shall be given promptly to the well owner. A copy ofthe approved contingency plan shall be provided to theCottonwood Community Association and the Associationshall be notified when the pumping out is completed.

H.D.C. HunterPanel ChairmanEnvironmental Appeal Board

Victoria, British Columbia20 June 1988