canadian environmental assessment agency agence … · 2013-07-29 · bursey and jenna mclean over...

NEW PROSPERITY GOLD COPPER MINE PROJECT

FEDERAL REVIEW PANEL

CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY

AGENCE CANADIENNE D'ÉVALUATION ENVIRONMENTALE

HEARING HELD AT

CARIBOO MEMORIAL RECREATION COMPLEX

GIBRALTAR ROOM,

525 Proctor Street

Williams Lake, British Columbia

Saturday, July 27, 2013

Volume 6

FEDERAL REVIEW PANEL

Bill Ross

Ron Smyth

George Kupfer

International Reporting Inc.

41-5450 Canotek Road,

Ottawa, Ontario

K1J 9G2

www.irri.net

1-800-899-0006

(ii)

TABLE OF CONTENTS / TABLE DES MATIERES

PAGE

Opening remarks by Panel Chair 3

Presentation by Dr. John Kwong 7

Presentation by Mr. Morin 85

Presentation by Mr. Watterson 138

Presentation by Bill Lloyd 196

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INTERNATIONAL REPORTING INC.

3

Williams Lake, British Columbia

--- Upon commencing at 9:14 a.m.

--- Opening ceremonies

CHAIRPERSON ROSS: Good

morning, everyone. First, thank you to the

Tsilhqot'in drummers for the opening ceremony.

Welcome to the third day of the topic-specific

session of the public hearing regarding Taseko's

application -- sorry -- proposed New Prosperity

gold-copper mine.

My name is Bill Ross. On my

left is Ron Smyth; on my right is George Kupfer.

Our legal counsels are David

Bursey and Jenna McLean over there. Secretariat

staff, identified by name tags, will be able to

assist you with any logistical or process-related

questions that you might have.

I would like to recap a few

housekeeping items again this morning.

As a reminder, please use the

south entrance on Seventh Avenue to the Gibraltar

room as the main access to the hearing. All other

doors -- I guess it's called this door -- are for

emergencies and access to the washrooms only. We

need to keep all doorways clear to comply with

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fire code regulations.

In the event of an emergency

the lights above me -- we've moved so I'm not sure

exactly where those lights are and I hope I never

see them -- in the event of an emergency the

lights above will flash or I will make an

announcement. In the event of a fire, please

vacate the building in a calm manner.

In the event of a medical

emergency, let Secretariat and Complex staff know

immediately. First aid supplies and attendants

are available in the Complex.

Purpose of the hearing. I

would like to reiterate the overall purpose of the

topic-specific sessions is to provide an

opportunity for experts who possess specialized

knowledge or expertise to present to the Panel the

results of their review of the potential effects

of the proposed project. The sessions are also

designed to allow an opportunity to assess the

technical aspects of the project.

The sessions, in addition, are

designed to provide opportunities for Taseko to

explain the project and respond to concerns and

questions raised by others.

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I would like to stress that

anyone may attend the topic-specific hearing

sessions and observe the proceedings.

Given the purpose of the

sessions, only those presenting a technical review

of the project and who have registered in advance

as an interested party may present or ask

questions at these sessions.

Today is a continuation of our

discussions on geology hydro geology which will

also focus on acid rock drainage and metal

leaching today.

The agenda with a list of

presenters is available to be picked up at the

entrance of the hearing room.

Briefly, the presenters we've

today are Dr. Kwong, on behalf of Natural Resource

Canada, Dr. Kevin Morin, and Dan Watterson on

behalf of the Tsilhqot'in National Government, and

Bill Lloyd on behalf of the Cariboo-Chilcotin

Conservation Society. The agenda may change

depending on the length of time it takes for

questioning. We ask participants show some

flexibility when they can present.

With respect to scheduling, we

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plan to sit until approximately noon with a break

this morning, an hour for lunch. We will resume

at one and continue until approximately 5, with

breaks as necessary in the afternoon.

Here is to good news. The

hearing will not go on tomorrow.

We will resume on Monday at

nine a.m. for the aquatic environment

topic-specific session.

I now ask that you turn off the

ringer on your cell phone or pager, and remember

that filming and photography are not allowed

without my prior approval.

Quickly, any questions about

the procedures? I haven't had any so far, so we

don't expect any today.

The first presenter this

morning is Natural Resource Canada, and Ms.

Coulson?

MS. COULSON: If I could, Mr.

Chairman. I would like to introduce NRCan's team

for those who were not in attendance for Dr.

Desbarats presentation on hydro geology yesterday.

My name is Jessica Coulson,

C-O-U-L-S-O-N. I'm a team leader at the

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environmental assessment division. To my left is

Dr. John Kwong, senior environmental scientist

from minerals and metals sector. To my right, Mr.

Rob Johnstone, also from -- deputy director also

from the minerals and metals sector, and Dr. Kwong

is here this morning to provide NRCan's views on

the topic of acid rock drainage and metal

leaching.

DR. KWONG: Thank you, Jessica.

PRESENTATION BY DR. JOHN KWONG:

Good morning, Mr. Chairman,

elders, chiefs, ladies and gentlemen.

My name is John Kwong. First

name John, J-O-H-N; last name Kwong, K-W-O-N-G.

This morning I'm tasked with

presenting an NRCan's view on the New Prosperity

EIS with respect to acid rock drainage and metal

leaching.

For the rest of the

presentation I will refer to metal leaching and

acid rock drainage as ML and ARD.

To put NRCan's assessment into

context, I will start with a brief review of the

current practices of ARD/ML prediction and the

limitations, as well as a susceptibility of

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porphyry copper deposits to produce ARD. Then I

will present a summary of NRCan's assessment of

the previous Prosperity EIS, followed by an

evaluation of the New Prosperity EIS on the same

topic before closing with a few conclusions and

recommendations.

Acid rock drainage, generally

characterized by low pH, elevated sulphate and

metal contents is the product of a natural

weathering of a sulphide-bearing rocks. The

released metals can originate from the oxidizing

sulfides or enhanced leaching of the associated

minerals when acidic conditions materialize.

Sulphide oxidation can occur

under all conditions, including low temperatures

-- say like -- provided as long as water and

oxygen with available to advance the process.

Environmental impact of ARD/ML

depends on its extent of occurrence, the degree of

neutralization, dilution and attenuation in the

receiving environment.

The challenge of any mining

project involving sulphide-bearing rocks is to

ensure that the disturbance and enhanced exposure

of various geological materials in the mining

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process will not lead to the production of a

ARD/ML that exceeds the capacity of a nature to

mitigate is detrimental effects.

This has led to the development

in a past two to three decades of a very static

and kinetic test methodologies for ARD/ML

characterization and prediction to inform devising

proper mind waste schemes to ensure minimum

environmental risks and impacts.

Acid base accounting, ABA, was

the earliest static test developed and still

remains as the most popular screening tool to

determine the ARD characteristics of a test

sample. The two key parameters involved in the

ABA analysis are acid generating potential, AP,

and neutralization potential, NP.

AP is determined based on the

total sulphur content of the test sample and NP is

measured by chemical titration.

Two criteria derived to

differentiate potentially acid generating or PAG

material from non-acid generating -- i.e., non-PAG

material -- are net acid generating potential,

NNP, and the acid neutralization ratio, NPR.

Any sample with an NNP greater

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than 20 kilograms per ton of calcium carbonate

equivalent is classified as non-PAG. Samples with

NPR less than one are considered as PAG material.

Those with NPR bigger than

three or four are considered as non-PAG. Anything

in between -- and those samples with values in

between with considered as having uncertain ARD

potential. This samples require further kinetic

testing to determine the geochemical behaviour.

In reality, few geologic

materials will NPR greater than 2 are certainly

observed to produce ARD in the field.

The limitations of ABA analysis

includes the following:

First, reaction kinetics are

not always considered. In other words, there no

information in the analysis to tell us when a PAG

sample will start to produce acid when exposed to

the weathering elements.

Second. Although sulphide

speciation are always incorporated into the

evaluation, the metal-to-sulfur ratio are

invariably ignored. List over-estimation of the

AP value.

Third. Carbonate

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neutralization potential are often measured, but

the effects of iron and the manganese components

are not always so. This would lead to an

over-estimation of the carbonate neutralization

potential.

Lastly, the possibility of a

metal leaching in the absence of acid drainage are

seldom considered.

Kinetic testing such as a

humidity cell and column leaching is used to

further characterize materials which, based on ABA

analysis, have uncertain ARD potential. The

testing is also often used to estimate the

sulphide oxidation and carbonate depletion rates

which are essential predicting the onset of ARD.

The leachate chemistry could

potentially be interpreted to reflect the effluent

composition and utilized to estimate the chemical

loading to the receiving environment.

The challenges associated with

kinetic testing are:

First, the test samples and the

test conditions in the lab are not the same as

that -- those occurring into the field.

Second, the data interpretation

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is not always straightforward. The kinetic

testing are often terminated when so-called steady

state is reached. However, steady state does not

mean that the same reaction of the same rate will

go on forever.

Furthermore, there's always a

temptation to interpret the water chemistry that

would lead to knowledge of the relevant

solution-mineral interactions involved.

Besides the ABA and humidity

cell testing, other supplementary tests often

conducted include shake flask extraction to

measure readily soluble constituents using

standard protocols, and a fast net acid generation

of NAG tests involving the application of the

strong oxidizing agent, such as hydrogen peroxide

to rapid oxidize the sulphide minerals in the

sample to assess if a test sample is able to

neutralize the potential acidity.

Samples at the end of the NAG

test that use -- pH 7, is considered as a non-acid

generating, and if a pH less than 7 is reached

then the test samples is considered as acid

generating.

Overall, in spite of all the

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continual improvement in ARD prediction

methodology, the inherent limitations in every

method means that that is always some degree of-

uncertainty regarding the prediction results,

although more detailed investigation generally

help to reduce the uncertainty. Therefore,

regular monitoring during mining and post closure

remain essential to validate the mine pre-mine

predictions on the potential occurrence and impact

of ARD and metal leaching.

Now, let's briefly look at the

susceptibility of a metal mines to develop ARD.

In 1993, based on the deposit

geology and mineralogy as well as the observed

occurrence of ARD in various mines, I ranked the

common ore departments occurring in the Canadian

Cordillera according to their proneness to

development ARD.

To the best of my knowledge,

the ranking has not been contradicted by any newer

work to date.

As shown in this slide, massive

sulphide deposits, such as those exploited at the

Sullivan mine, Myra Falls, Britannia readily

develop ARD upon mining while skarn deposits such

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as those occurring at Craigmont and Nickel Plate

are least prone to develop ARD.

Calc-alkaline phosphate

porphyry copper deposits, such as Gibraltar and

Island Copper is ranked medium. Amount of these

deposits, while porphyry Cu-Au deposits such as

Afton mine and Copper Mountain rank much lower.

New Prosperity deposit probably

lies between these two.

Calc-alkaline suite deposits

are generally associated with acidic intrusives

and undergone and have more intensive alteration

in predicting neutralization potential of a

(inaudible) bearing minerals that, thus, lead to

higher potential of acid generation.

In contrast, alkaline suite

deposits are typically more gold-rich and are

hosted by basic rocks and, therefore, lower acid

generation potential.

However, depending on the

degree of evolution of the intrusive body and this

emplacement depth, some porphyry copper-gold

deposits may be enriched to varied extent with

potentially deleterious elements such as arsenic,

antimony, mercury and selenium.

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Furthermore, no two ore

deposits even belong to the same float (ph) or

type are identical to each other.

Due care must be taken when to

extrapolate observations made in deposit to

another.

Now is the time to be saying

NRCan's assessment of the previous Prosperity EIS.

The main concerns with the --

identified in the previous EIS we take it to

determination of time to onset of ARD. And the

extrapolation of laboratory testing result to the

field might lead to uncertainties in water quality

predictions. The consideration for metal leaching

under neutral pH and low oxygen conditions was

lacking in the previous EIS.

Comparison of the prospective

performance of the tailings storage facility at

the project site with the exiting TSF at Gibraltar

may not be appropriate. This is for the past EIS.

Lastly, the assumption that

with time the tailings storage facility might be

able to support fish operation was premature.

By working iteratively towards

a resolution of potential issues of concern,

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particularly through working coordinated by the

B.C. Department Of Energy and Mines and Resources,

NRCan was satisfied that there were no significant

flaws in the ARD/ML assessment as described by the

Proponent.

However, there are two

outstanding issues. One related to

metal/metalloid mobilization under near-neutral

and oxygen-poor conditions, and the potential

occurrence of elevated levels of selenium in some

drainage.

To address the potential metal

leaching under near-neutral pH and varied redoc

conditions, NRCan recommended the Proponent to

either provide evidence prior to commencement of

mining that underwater disposal of mine waste

would not lead to significant metal leaching under

any conditions; or, commit to close monitoring of

the pertinent elements in all mine-derived waters

during operation and post-closure.

If necessary, mine effluents

should be treated to appropriate level prior to

discharge to the receiving environment.

To address this selenium issue,

NRCan recommended to Proponent to either conduct

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an appropriate geochemical study to identify the

sources of selenium and develop suitable

management plans to handle this suspect materials;

or, utilize an appropriate effluent treatment if

selenium levels become a concern during operation

or post-closure.

As for the New Prosperity EIS,

the key observations made by NRCan include the

following: There is little change in the

Proponent's approach to assess ARD/ML potential

and impacts, and the presentation on determination

of a carbonate neutralization potential and

prediction of ARD on set are unclear.

The Proponent appears to opt

for monitoring and effluent treatment when

required instead of conducting more research to

address outstanding issues on metal leaching under

neutral pH conditions and the selenium release.

However, overall, the

Proponent's ARD/ML assessment are compatible with

current common practices.

NRCan does not perceive

significant environmental impacts to derive from

ARD for the proposed project provided -- I

emphasize -- provided the Proponent is diligent in

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carrying out all necessary monitoring and adopting

appropriate adaptive measures to prevent, mitigate

or treat -- and/or treat -- any contaminate

release.

NRCan would recommend timely

reporting and analysis of monitoring results to

identify deteriorating trends be imposed on the

Proponent either by the Panel or -- as a

requirement to advance the proposed project.

This concludes my presentation.

I hope that the presentation, that information

provided are useful for the Panel and all

stakeholders concerned to determine whether ARD

and metal leaching are unsurmountable obstacles to

advance the proposed project. Thank you for your

attention.

CHAIRPERSON ROSS: Thank you,

Dr. Kwong. I guess the first group of interested

parties who are invited to pose any questions are

either government departments. Are there any

other government departments who wish to pose

questions?

Seeing none, I'll move onto

First Nations interested parties. Mr. LaPlante?

MR. LAPLANTE: Thank you,

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Mr. Chairman. Thank you, Dr. Kwong.

My question has to do with

better understanding you're -- these

recommendations and conclusions -- sorry, the

previous slide about the neutral pH metal leaching

and the recommendations around that.

I guess I'm still confused

about the consequences I guess of the options that

were presented to the Proponent. So one option

was prior to commencement, the other was careful

monitoring and a commitment to treatment.

I guess my question is: Is it

possible that, given the uncertainty around the

metal leaching concentrations, that

post-construction may be discovered that the

treatment that would be required would be perhaps

technically feasible but economically unfeasible.

Is that a possibility?

MS. COULSON: Perhaps could you

just repeat your key question for Dr. Kwong.

MR. LAPLANTE: I realize it may

be straying out of his area of expertise, but I

think it may be key for the Panel to understand

that this -- the recommendation that the Proponent

-- it's basically saying, go ahead but carefully

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monitor this.

But my question is: Is that

too late once it's discovered that there is

neutral pH metal leaching issue and that they have

refused to do that work up until this time? They

have had lots of time, I might add, but the point

is, is that once that is discovered it may be

economically unfeasible to conduct the treatment

that would be committed to, but we don't know what

the -- I guess the degree of the issue we don't

know -- there is uncertainty around just how bad

it might be.

So my question is, maybe you

can speak more to the technical feasibility. But

I'm curious, I want to take it a step further and

talk with the economic feasibility.

DR. KWONG: I think I can only

address the technical aspects of it. I am not

qualified enough to comment on the costs involved

because I do not know.

Technically, and often

practically, it's possible to air (unintelligible)

technology to treat any contaminants released

under neutral pH condition, and that the prior

technology would vary according to -- depending on

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the site conditions.

Some treatment methods may be

more causative than others, but how it would

affect the overall cost for the entire project,

that I cannot address.

MR. LAPLANTE: Thank you, Dr.

Kwong. Two follow-up questions.

One is a point of

clarification. You mentioned that it's possible

to treat it, but just to clarify -- and I know

there is uncertainty -- this is though water that

you can naturally capture?

DR. KWONG: Yes. And that is

why the monitoring is important. By proper -- if

one do the monitoring properly, properly, one

should be able to determine the evolving trend of

the water chemistry.

For example, if under certain

conditions or, say, if reducing environment,

reducing condition, start to develop in certain

portion or in a certain age, and not all the

available (unintelligible) -- let's take arsenic

or antimony, for example. Not all the arsenic and

antimony in the sediment would be released

immediately. What chemical reactions in nature,

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takes a certain time to proceed.

Or if the release of the

arsenic and antimony is (unintelligible) --

interaction, then it would depend on the change

involved in chemistry to enhance the speed of the

release.

So it is really important to

monitor and detect and look for pre-warning signs

about the potential release of the letters,

elements, and then you immediately use adaptive

measures to deal with the issue, and there are

available technology to prevent further metal

leaching or treated.

And once the metal release is

confirm, then the proper protocol would be to

collect the (unintelligible), the drainage, and

then treat them before the release to the actual

environment, so to be sort of the common practice.

MR. LAPLANTE: Okay. Thank

you.

I'm still perplexed, however.

I don't see there is a fundamental step of you

have to capture what you can treat. And given

what we've heard yesterday and the unknowns about

the ability to understand where all this is going,

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I'm really concerned that that monitoring program

may not even be able to detect where everything is

leaching.

I'm wondering, as an example

under the PAG waste rock, that is a potential exit

source for other environments, right.

But I'll move on. I'm just

concerned. I feel like there's a lot of rungs of

the ladder.

MR. BURSEY: Mr. LaPlante, is

there a question?

MR. LAPLANTE: My next question

is about the cumulative combinations of these

metals. I would like to know if the Proponent

adequately addressed kind of the effects of the

accommodations of metal leaching, whether or not

acid -- whether or not it's acid drainage.

DR. KWONG: To answer your

question, I think that you have to specify whether

you are considering sort of a -- a moving drainage

or sort of a confined water body. For example,

are you talking about tailings pond or whatever?

MR. LAPLANTE: I'm talking

about the system. We have a giant bore stockpile.

We have a waste rock dump. There are a lot of

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sources here so I think -- you can't look at it as

just one issue. It's all around the site and

downstream obviously.

DR. KWONG: And that is why

lots of the waste rock would be generated in a

mining project. The proper procedure to follow at

which the Proponent has done, is to categorize

those waste rocks according to the ARD and ML

potential. If your waste rock has already logged

ARD/ML potential, then the leachate you can get

from even precipitation, (unintelligible) the

waste rock pile.

What would be its chemistry, if

the chemistry is not detrimental to the receiving

environment then we don't have any concern.

However, if the waste rock are potentially acid

generating then that is a completely different

situation.

However, the Proponent proposed

to dispose all the potentially -- the packed rocks

under water, under water cover in the tailings

environment. That reduces the risk or the

probability of ARD and metal leaching. And that

is acceptable. That management method is

considered as appropriate to both NRCan and at

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BCMEM.

MR. LAPLANTE: Thank you. And

to be clear, my understanding is that -- and I'll

let our experts maybe speak to it more, but there

were -- there was the contemplation by Ministry of

Mines that there may be multiple types of

treatment required to deal with the multiple metal

species that could be leeched.

So is my understanding correct

that it may -- the technically feasible may have

to include more than one type of water treatment

in order to remove the metals?

DR. KWONG: That is true.

MR. LAPLANTE: And that -- I

take it a step further. That may have to happen

at multiple sites at the possible mine given that

there's multiple sources. Is that also true?

I'll give you an example to

clarify. Like, if the waste rock dump and the ore

stockpile were found to be leaching metal at

neutral conditions at an unacceptable level, that

may require water treatment prior to the discharge

of that water into Fish Lake, and then there may

also be one required at the tailings impoundment.

There also may be one required at Big Onion Lake.

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I'm trying to draw a picture

there may be more than one site where water would

have to be collected, if it can be collected.

DR. KWONG: There are two

possibilities. Yes, an option is that you set up

different treatment facilities. Response of the

mine. Or if you -- you can collect all the

drainage from different points on locations at the

mine and collect them to a single facility and use

various technology in that particular facility to

treat various contaminants.

MR. LAPLANTE: If you can

capture it.

My final question: Is there

expertise at NRCan to assess the economic

feasibility of potential requirement for

treatment?

DR. KWONG: I think that

question I will leave....

MR. JOHNSTONE: Mr. Chairman,

Rob Johnstone with the minerals metals sector.

The easiest way of responding

to that is that we wouldn't have the expertise to

comment on certainly various treatment options and

in the entirety of the project economics.

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you.

I guess that leads me, Mr.

Chairman, I think there is a really key piece

missing here. We don't have -- my understanding

is it's the Ministry of Mines that has that

expertise. Where were they here? How can we

finish this discussion when we can't get that

answer about that economics feasibility. So I'll

leave it.

I know you don't have that

answer, but I want to express our concern that we

can't fully understand the risks here given we

don't have the right expertise available to

yourselves.

CHAIRPERSON ROSS:

Mr. LaPlante, the Ministry Of Energy And Mines of

British Columbia has indicated it is at the other

end of an Ethernet connection, and if you have a

question for the Ministry of Energy And Mines, if

you could provide it to our Secretariat, we will

send an e-mail and the Ministry Of Energy and

Mines has committed to respond as quickly as it

could.

MR. LAPLANTE: We'll certainly

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take that into consideration. Thank you.

CHAIRPERSON ROSS: Thank you.

Mr. Pearse?

MR. PEARSE: Thank you, Mr.

Chairman. Tony Pearse with TNG. I have a couple

of follow-up questions for Dr. Kwong, if I may.

Dr. Kwong, could you please go

to your recommendations number one side. You've

given two alternatives for your first

recommendation, and I want to explore the first

one.

If the Proponent were to

undertake that recommendation, how would it go

about doing that? What would they actually --

prior to mining, how would they provide evidence

of underwater disposal of mine waste that would

lead or not lead to significant metal leaching?

DR. KWONG: One possibility is

that you conduct a different kind of -- instead a

column leaching, you can use lisimiter (pH),

creating. For example, you put typical tailings

under a water cover and then monitor both the

tailings pond water and the flux of metals or any

contaminants to the overlying water, and then --

that experiment may take longer than column

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leaching or (unintelligible) testing.

Based on the results that you

get and you try to figure out based on the

mineralogy and the geochemical of your solids and

the water chemistry, and then you try to

investigate what type of chemical reactions would

lead to the release of the elements of a concern,

and then depending on the nature of the element

there are different ways to deal with the effects.

For example, if it is simply

fluxing form the underlying tailings or submerge

waste rock, one effective method is that if at the

tailings water interface you have the

specification of iron oxide, particularly if that

is a microfilm, a biofilm developing at the water

base, the interface, that can effectively suppress

the effects of same to the overlying water.

But that does not prevent the

downstream porphyry -- I mean, the downward

perforation of the pour water as part of the

groundwater system, then it will be dependent on

the composition of the pour water and the rate of

-- perforation rate of as transport of the pour

water further down to determine whether you need

pump and treat to deal with the....

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MR. PEARSE: Thank you. So if

I understand what you said correctly, you are

saying these are essentially lab scale tests that

you can do?

DR. KWONG: Yes. And then in

your operation you follow-up with actual

monitoring to see if what you learn from the lab

testing can apply or can inform you to develop a

adaptive measure or not.

MR. PEARSE: I think if I

understood you correctly, you earlier indicated

that the work done by the Proponent in terms of

trying to assess neutral metal leaching was

deficient or not adequate, but you were not happy

with that work. Is that correct?

DR. KWONG: Nothing has been

done. As far as the previous EIS is concerned,

not much work or none -- no work has been done

with respect to metal leaching on under neutral

conditions.

The major concern, the major

focus has been addressed to ARD, in other words,

metal leaching under acidic condition,

(unintelligible) of acidic environment rather than

in neutral environment.

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MR. PEARSE: So these kind of

tests that you are talking about for the metal

leaching, are these tests -- I would assume

because they are lab scale tests that something

would typically be done at the same time ARD work

is done for a new mine at the assessment stage.

Is that a fair statement? Wouldn't you typically

look at this?

DR. KWONG: No, that is not

really typically done. Only forward-looking

operation would consider that.

MR. PEARSE: Sorry, only a

forward looking --?

DR. KWONG: Yeah, a forward

looking operator. In other words, some -- in

general, depending on the philosophy of an

individual, mining operations, some people are

more proactive than others. I mean, some

operation are more proactive than the others.

MR. PEARSE: I would love to go

down that road, Mr. Chairman, but I won't.

I do want to ask you, Dr.

Kwong, what would be the significance then --

let's say the company went and ahead and did this

work in the lab and found they had serious neutral

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metal leaching problems.

How significant, how big, how

serious could those problems be for the --

DR. KWONG: Without the results

I cannot predict really how serious it would be.

For example, if arsenic and antimony is a concern,

okay, if you are the release -- they are water

quality criteria, okay.

If the release is below the

acceptable water quality criteria in decades that

is not a concern, is not a serious problem. But

on the other hand, if the release invariably or

very often exceed the current water quality

criteria then something has to be done and -- so

without the (unintelligible) I cannot predict how

serious the problem would be.

MR. PEARSE: So why wouldn't we

just have the company go ahead and mine it and if

the water monitor -- go to option two here --

monitor the water and then it sounds like they can

deal with the problems as they come up. Why would

you have them -- what's the purpose of your first

bullet recommendation to do some of this work in

advance? How does that help?

DR. KWONG: I think that that

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is a respect to the cause. If you have to -- when

you -- if you do your work in the beginning, you

know how to prepare for the treatment, it may

eventually reduce the overall cause of the mining

project. But if you wait until the problem arises

it may, in the end, cost you more than if you have

done the preliminary work in the beginning. That

is why -- that is the difference.

MR. PEARSE: I'll leave it at

that. I did have one other question. We heard

from Dr. Desbarats yesterday the probability that

the PAG rock in the tailings impoundment may be

subject to weather fluctuations and water level

fluctuations annually, seasonally, whatever over

time. And I would like you to explore that with

me a little bit. What would be the implications

to the ultimate water quality in the impoundment

if we had these kinds of fluctuating draw downs of

water, exposure to air and so on with respect to

the ARD issue?

DR. KWONG: Based on the data I

presented, made available in the two EIS in the

previous Prosperity EIS and the current New

Prosperity EIS, the data suggests that the

tailings are not potential -- the butt of the

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tailings are not potentially acid generating.

However, waste rocks to be co-disposed in the

tailings impoundment are potentially acid

generating.

The effect would be dependent

on the change in the water level whether the PAG

rocks are exposed or not. If the fluctuation only

exposed the tailings, I do not expect there would

be serious consequences. However, if the water

level drops to such a level that it would expose

the PEG waste rock, then the impact on the water

quality would be significantly higher. And in

that case, treatment or whatever maybe to be the

involved.

MR. PEARSE: Okay. Let me just

sort of elaborate a little on that.

So during mining, I understand

at this time PAG rock will be in the order of one

to two metres above the level of the water as the

operations are coming up. Then at the end of

mining the water level is brought up to cover the

PAG rock. Right?

So you've got some exposure

during mining, two-metre layer of rock to the

atmosphere, the rain and snow falling on that. So

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you've got some contribution of ARD possibly

there.

But then in the long term with

these seasonal fluctuations, which would be quite

dramatic, and if, in fact, you've got a porous

conduit to the substrate and then leakage under

the PAG and leakage is much greater rates, you've

got the potential here for significant

fluctuations in the water table in the long term

post closure.

So have you considered those

contributions into your assessment of what the

impoundment water quality might look like?

DR. KWONG: That lends to the

importance of the prediction of onset of ARD. We

know that waste rock are to posted (pH) in the

tailings impoundment but not immediately

submerged. So we had to determine whether doing

that exposure period acid rock drainage has

already occurred or not.

If it has already started then

any ore oxidation process has been accumulated in

the portion of the environment where waste rock,

then it would have a significant effect on the

water chemistry, including the poor water

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chemistry in the underlying tailings.

On the other hand, if ARD has

not been, has not materialized before the submerge

of the waste rock in decades then the consequence

would -- are not expected to be significant.

MR. PEARSE: Thank you, Dr.

Kwong.

Do you have any examples of

where this co-disposal, PAG and waste rock, has

been done and where we have actually monitoring

results or success studies that look at how

effective this has been?

DR. KWONG: The disposal of

waste rock and tailings is a relatively new

concept. I am a few -- I'm not aware of any

monitoring data available at this stage. But I

think that a couple mines are considering using

the same approach. But I cannot recall off my

head what are those mines.

MR. PEARSE: That's my

understanding too. I think it's fair to say it's

kind of a novel technology that's --

DR. KWONG: Right.

MR. PEARSE: Correct?

DR. KWONG: Yes.

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MR. PEARSE: Thank you. I

think that's it. Thank you, Mr. Chairman. I

think Mr. LaPlante has got a follow-up.

MR. BURSEY: Sorry, Dr. Kwong,

your last answer, I don't know if it was recorded.

You said "yes" in response to the last -- sorry,

right here to your left. I'm not sure your last

response was recorded. It was a yes, right?

MS. COULSON: Could I just

interject? Could Mr. Pearse just repeat the very

specific question that he asked so Dr. Kwong is --

DR. KWONG: Yes. I think my

response was I said yes. It was relatively new

technology.

MR. BURSEY: It's difficult

sometimes because --

DR. KWONG: Unproven.

MR. BURSEY: You're turning to

look to him and you are turning away from the

microphones.

DR. KWONG: I see.

MR. PEARSE: Would you like me

to rephrase the question, Dr. Kwong, or do you

just want to repeat your answer?

MS. COULSON: I just want you

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to repeat the question, please.

MR. PEARSE: I said that it was

my understanding with what he said and it would be

fair to say that it's novel and unproven

technology, correct?

DR. KWONG: Yes. It's a novel

technology. Well, from that perspective, it is

unproven.

CHAIRPERSON ROSS: Mr.

LaPlante?

MR. LAPLANTE: Thank you, Mr.

Chairman. I have two follow-up questions based on

discussion.

The first one is: I'm curious

Dr. Kwong, are you aware of -- you had a list of

mine sites, and I'm not trying to get like a

detailed answer of what's happening where, but

would it be a fair statement to say that it's

common that at various mine sites around British

Columbia that there are water quality exemptions

as a result of metal leaching at neutral

conditions to specific metals at particular sites

depending on the chemistry there?

DR. KWONG: Would you repeat

your question? I think I missed one portion. I

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want to make sure that I catch all that.

MR. LAPLANTE: Certainly. My

question is: Is this a fair statement-- so is my

understanding correct -- is that it's fairly

common, and I don't know I'm not a geochemist, I

don't know how common, but that there are numerous

mine sites around British Columbia where there are

water quality exemptions as a result of metal

leaching at neutral conditions, and particular

metals, depending on the chemistry at a particular

mine site.

DR. KWONG: In my experience,

the answer is no. It is not really, really

common, it rarely occurs. As a matter of fact, if

you look at sort of a compliance to MMDR, most of

the Canadian mines, the compliance level in the

recent years from 2004 to 2011 (unintelligible) in

excess of 92 to 99 percent. So in other words, it

is rarely that the predictions of poor water

quality, the chances of predictions were wrong are

lot less than....

MR. LAPLANTE: Does that apply

also to the B.C. water quality guidelines? Maybe

you don't work with them. But in my experience,

I've seen exemptions being granted to companies --

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B.C. water quality guidelines.

DR. KWON: That I cannot

comment on. I'm not too familiar with this.

MR. LAPLANTE: My follow-up

question -- and this gets to the implications due

to this unknown about the amount of metal

leaching. Is that -- I guess this is a special

case. We have a receiving environment that needs

to stay perfect, more or less, right, and I guess

would it be -- is it fair to then -- I'm

questioning is it -- the fact that this is an

unknown, that we don't know the answer about the

amount of metal leaching at neutral, mean that it

may not just be an economic feasibility question

but that the project design may not be technically

feasible if it were discovered down the road that

the waste rock and ore stockpiles and other mine

infrastructure were indeed leaching metals that

could enter Fish Lake?

And would that not be an

environmental assessment question and not a

permitting or down-the-road monitoring question?

DR. KWONG: As I mentioned in

one of my slides, that environmental impact of ARD

and metal leaching, less (unintelligible) metal

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leaching, dependent on the extent of the

occurrence as well as the capacity of a nature to

mitigate the metal release.

So the testing of

(unintelligible) testing to just inform us what

could happen so that we can adjust our opinion

accordingly.

Eventually, it would dependent

on the rate of release of the (unintelligible) of

elements of a concern that would decide whether --

has -- (unintelligible) or irreversible impacts

would materialize.

But in, generally speaking,

nature (unintelligible) actions process occur in

nature progress slowly. You have lots of bonding

size to detect and decide to deal with it. The

only exception would be extreme (unintelligible),

no one can predict and that is sort of the reason

one has to consider.

MR. LAPLANTE: I guess my --

like, my question is around the technical

feasibility of what we see before us. Not what

might get done in the future and so like what if

there needed to be a full liner under the tailings

impoundment? What if there needed to be a full

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liner under the waste rock dump, under the ore

stockpile? Aren't these things we need to know

now?

DR. KWONG: I think your

question would address -- is more related to the

hydro geology sort of aspect of the whole thing,

which I'm not really comfortable.

MR. LAPLANTE: That's very

fair, and thank you for your answers, and I would

say they are combined perhaps, that these two

issues are very much related.

I have one final question. It

has to do with the lab kinetic tests. And I want

to confirm your -- you understand as well.

My understanding is that in the

last review there was certain of those tests that

showed acid generation that occurred immediately

and there was others that had not reached acid

generation. But that since the last Panel review

that they have showed early onset of acid

generation. Is that understanding correct?

DR. KWONG: (No response).

MR. LAPLANTE: And it requires

that you are familiar with some of the

submissions, I believe, that have been made like

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in the last -- as part of this EIS. I'm not sure

if you had seen that work, but I think that's a

really important issue we need to clarify.

DR. KWONG: Yes. That kind of

information just sort of change affect the onset,

the estimation of on set of ARD.

MR. LAPLANTE: And my question

is: Have we seen that happen? Were those kinetic

tests -- those were lab tests that were running

for multiple years. In the last review they

didn't show early onset of acid generation. It's

my understanding that they have since showed early

on set of acid generation.

DR. KWONG: It all depends on

what you mean by "early onset". If you're -- say

if the original prediction of onset is, say, 50

years and now that continuing -- (unintelligible)

you collect it in the case that it is 30 instead

of 50, then you have 30 years, you know, to

prepare or deal with it.

MR. LAPLANTE: But I think this

is a couple of years, and I believe the prediction

was a thousand years from companies. So we're

talking from a thousand to maybe 5. Would that

not be called early?

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LaPlante, I think you are going to present this

shortly, so....

MR. LAPLANTE: I'll leave it,

but I would like to understand if NRCan has

concerns around this. This concerns us and I

would hope it's concerning NRCan as well.

My last -- where I was going

with that is: Would that not affect the also the

economic feasibility of all this water treatment

if you needed to treat water earlier as opposed to

later in the mine life?

DR. KWONG: It would affect the

economics. But on other hand, as I said before,

I'm not in a position to comment on that because

it's outside of my area of expertise.


you.

CHAIRPERSON ROSS: Mr. Pearse?

MR. PEARSE: Thank you, Mr.

Chairman. We have a little bit of a tag team

going, we'll try not to prolong it. I did want to

pursue this one point with Dr. Kwong.

I think earlier you said that

the -- I'm back to the fluctuating water in the

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impoundment and layer of waste rock that's exposed

during operations, which I assume is a fairly

significant volume given the size of the facility.

You were talking about how the

onset of ARD is critical to what the water quality

impacts would be. How -- so I want to ask -- and

you also told us that you had issues with the

calculations used by the company in determining

what the onset would be. Is that correct?

DR. KWONG: That particular

problem raised with the Proponent, you saying the

term sulphide oxidation rate versus acid

generation rate interchangeably. But from a

scientific perspective, the two terms means

different things.

Sulphide oxidation. The rate

of sulphide oxidation does not depend on the

abundance of sulphide (unintelligible). But on

the other hand, given the same oxidation rate, the

more sulphide you have then the more acid will had

been generated and, therefore, the acid generation

rate will be higher.

So the complications or the

problems I have with the presentation in the EIS

is derived from the enter -- mixed use of the two

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terms which complicated the prediction.

MR. PEARSE: So if I understand

you right, what we're concerned with here is the

acid generation part, not necessarily the sulphide

oxidation rate. Did I get that -- from an

environmental perspective?

DR. KWONG: From environmental

perspective, ARD is derived from sulfur oxidation

but the amount of -- well, from a scientific point

of view, the sulphide oxidation rate is totally

dependent on the composition of that mineral,

regardless of how many -- how much of that mineral

is present, is oxidation rate is dictated by

temperature, the composition, the water chemistry.

On the other hand, the amount

of acid generated is dependent on available amount

of the sulphide present.

So if this sulphide is

undergoing oxidation the more of this material is

there, the more acid will had been generated. You

cannot really use the two term to mean

interchangeably.

MR. PEARSE: I think I've got

it. You mentioned temperature was normally part

of the determination. Can you tell us whether the

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Proponent used temperature to calculate or

determine the results of its humidity cells? Was

temperature something they looked at?

DR. KWONG: It is sort of a

common -- because as I said, you do all your

kinetic testing under lab conditions. The room

temperature typically, well, say (unintelligible).

But on the other hand in the

few, depending on where your mine is located, say

in northern Canada, eight months out of the full

year is frozen and, therefore, lower -- generally

speaking, the rate of a chemical reactions is

reduced by 10 times for every -- so 20 degrees

decrease in temperature and, therefore, the

reaction rate would be much slower under low

temperature conditions than low temperature,

therefore, is common practice to -- in order to

apply the lab results to the few to predict

effects in the field, you have a so-called

temperature adjustment factor.

MR. PEARSE: And they did that,

did they?

DR. KWONG: They did that.

MR. PEARSE: Thank you. Can

you tell me how of the humidity cells were acidic

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from basically the start of the test?

DR. KWONG: I cannot recall,

then not really that many.

MR. PEARSE: Not really that

many. There were some?

DR. KWONG: I think that the

Proponent may be help me out in giving the right

answer.

CHAIRPERSON ROSS: Taseko,

could you help us with this?

MR. JONES: Actually we

couldn't right at this moment. Our geochemical

guy is just not here who can answer that question

like that. He will be here on Monday.

CHAIRPERSON ROSS: Thank you

very much.

MR. PEARSE: We'll get that

answer on Monday, Mr. Chairman.

This probably will have the

same answer. Do you know how many humidity cells

are acidic today? Have you looked at the humidity

cell data from the early 2009 and seen what's

happened with those for those cells that are

continuing?

DR. KWONG: My evaluation of

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49

the ARD and metal leaching data, I took and sort

of overall (unintelligible) because -- if those

humidities specifically address certain types of

rocks, and let's put it this way.

You try your best to look at as

many samples as possible. But are these samples

really representative of what is actually

happening in the field? We don't know.

MR. PEARSE: We don't know.

DR. KWONG: Therefore, you have

to interpret the data from what you can from the

data to understand what could happen in reality.

That is my focus.

I do not need to be specific

attention. Say, if you say that two hour of 10

humid cell (unintelligible) acidic conditions,

then my question is, oh, what are the composition

of these two columns? Are they referring to

specific (unintelligible)? In that case then I

would look at focus on this particular rock types,

then I would not really -- and then the remaining

case, I would not be -- would receive less

attention from me because they are not going to

pose significant problems.

I would expect that the

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Proponent would be doing the same thing. The data

is going to inform you what to happen for various

rock types and, therefore, if -- say, in the final

open pit (unintelligible) -- this rock type would

potentially cause more problem than you would have

to determine, well, maybe this rock type will

ultimately have a bigger control of impact on the

(unintelligible) chemistry than the others. So

that is the kind of information I....

MR. PEARSE: Okay. I just -- I

think I got you but just let me clarify.

When you look at these cells

and you look at the information, you're not

actually looking to see how representative of all

the rock types they are. You are just taking

what's been presented in the cells and working

with that. Assuming that, they are

representative; is that correct?

DR. KWONG: No, that is not

correct. No. I would be looking at whether they

have include enough of the rock types in the

assessment. So then I have an overall picture of

what would be the final outcome over all of the

proposed project.

If -- even if you done 50 humid

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cell tests but on the same rock type and yet in

that deposit you got 12 different rock types, to

me that's not acceptable. Even though you have

done (unintelligible) enough.

Even though you have done it

lots of humid cell testing, but it does not give

me the information to cover all different rock

types in the deposit.

MR. PEARSE: Just to clarify.

This is a fairly large deposit, purported to be

one of Canada's largest, if it goes ahead. And

lot of rock types. And so are you telling us that

the humidity cells, the kinetics tests that are

run are sufficiently representative of the full

depth of the deposit in the rock types or did you

have any issues there?

DR. KWONG: At the stage of the

(unintelligible) -- we considered -- work done is

acceptable.

On the other hand, that's why

we emphasis repeatedly that continual monitoring

is important to evaluate the predictions at this

stage and adopt adaptive measures and also keep on

updating the water quality prediction as if the

mine is allowed to advance, then this kind of a

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measure and continual updating of a water quality

prediction is -- should be a requirement.

MR. PEARSE: One final

question, just back to the early onset question

again.

If I were to tell you -- and

I'm not going to tell you. But if I were to tell

you that, in fact, there were humidity cells that

were acidic, more or less, from the start of the

test and more have gone acidic on the way, would

that concern you more about the issue of the PAG

rock being exposed in the TSF, if we do have very

early onset ARD, we have a more significant issue

here to deal with.

DR. KWONG: That will be

dependent on the amount of that material. For

example, if you have this particular rock type

immediately generating acid rock drainage and then

you put it in the tailings impoundment, what is

relative proportion to the other material exposed

in the same impoundment and what other

neutralizing potential or excess neutralizing

capacity of the rest of the material? Would that

excess neutralization capacity be able to

accommodate the acid generated? So that is all

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53

balance in the equation.

So if that is not enough, then

you may have to think of an alternative method to

deal with this potential acid generating rock.

MR. PEARSE: And we do have

significant volumes of PAG being put in the

tailings well before water gets up to it and then

all through -- I don't know what year the water

actually gets up to the base of the PAG. Taseko

can tell us. But then through mine life you've

got -- you know, multiply the number of hectares

times two metres, you've got a significant volume

of waste rock exposed --

CHAIRPERSON ROSS: Mr. Pearse?

There is a question coming very quickly?

MR. PEARSE: Yes. I'm asking

Dr. Kwong to consider the significance of the

sizable volumes of rock that will be exposed to

air during the first few years of mining and then

subsequently that top two-metre layer, through

mining -- these are not insignificant amounts.

I'm really trying to get him to

tell us about whether -- what he thinks about that

in terms of water quality impacts. That's my last

question. Thank you.

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I was hoping for an answer.

MS. COULSON: Again, Jessica

Coulson. Would you mind repeating the question?

It was just a lengthy sentence.

MR. BURSEY: It's helpful if

there's a lot of premises and compound questions,

it's difficult for the witness to answer. So if

you simplify it, it's easier.

MR. PEARSE: In your

assessment, Dr. Kwong, of the implications of acid

rock drainage for the pond water in the

impoundment area, did you consider the significant

volumes of waste rock that would be exposed in the

early few years, virtually all of the PAG my

understanding is, will be exposed during the early

years until the water level actually comes up at

some point during mining and then for the rest of

mining there's at least a two-metre thick layer

multiplied by 30 hectares -- I don't know what

we're talking about, Mr. Chairman -- but a

significant area there.

So there's a significant volume

of PAG exposed to the atmosphere during mining.

So I just wondered if you had considered that in

your assessment of what the impoundment water

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55

quality might look like from ARD or neutral metal

leaching. Thank you.

DR. KWONG: My understanding is

that -- or based on the data made available in the

two EIS, that those PHE ARD -- the onset to ARD

for most of them would not materialize before they

would be submerged under the water cover before

the onset of ARD. And without the detail

composition of -- the composition of the so-called

perspective ARD, I cannot really -- I have no data

to sort of emerge what could be the water

chemistry -- except for the chemistry would be

like.


Any other First Nations interested parties?

MS. COULSON: Mr. Chairman, a

quick observation.

I noted that several of the

last questions were kind of going into the

territory of water quality. And I just wanted to

remind parties that my colleagues at Environment

Canada would be presenting in that area on Monday.


I should have done that, but I appreciate that you

did.

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Are there any interested party

groups who wish to question Natural Resources

Canada? Are there any interested party

individuals who wish to question Natural Resources

Canada?

Sir, please introduce yourself

for the court reporter and ask your question.

MR. YOUNG: Good morning. I

appreciate being here. My name is Gary Young, and

I live in the area. I'm retired and I don't have

an interest one way or the other with the proposed

mine.

I'm looking at something that

is a recommendation from NRC. It says, "The

Proponent should commit to close monitoring."

There are no conditions applied

to that. We don't know who is going to monitor

it. Is it going to be self-monitoring. Who would

pay for it? How would we get the results? Would

the results be available to the public? Et

cetera, et cetera.

It's a very open, open

statement and a word that has no conditions

attached to it. And I think that that is a very

important matter to address if the eventuality is

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57

that the Proponent is self-monitoring.


I think the recommendation was to the Panel to

consider.

As I recall, the next

questioning would come from Taseko. I think I

might be -- Mr. Gustafson, if you could give me a

estimate as who how long, we'll either have a

break before or after.

MR. GUSTAFSON: Mr. Chairman, I

don't know that we're going to be very long at

this time. We had anticipated that issues

touching on water quality and the aquatic

environment would be dealt with on Monday and our

expert will be here and able to brief us on that.

We do appreciate and understand

that Dr. Kwong has agreed to remain to answer

those questions. We may or may not have any

detailed questions and I will undertake to advise

just as quickly as possible if we don't and can

release Dr. Kwong so that he can get on with his,

I'm sure, busy schedule.

I do have a couple of questions

right now that --

CHAIRPERSON ROSS: Why don't we

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just go ahead then.

MR. GUSTAFSON: It will just

take a couple minutes I think.

Dr. Kwong, in one of your

slides -- and I believe it was number nine or 10

-- you had a ranking of -- I think that's the one

of various companies. You said that New

Prosperity ranges between these two, and I didn't

catch which two.

DR. KWONG: Okay. New

Prosperity has been classified as alkyl-alkaline

porphyry deposits. However, it share some

characteristics as copper-gold deposits.

So I ranked it. If I were to

rank the New Prosperity deposit I would rank it

between three and six. Six are alkaline porphyry

(unintelligible) deposits, such as in Copper

Mountain, then Gibraltar as a alkyl-alkaline

offering, which I read it as three in my table on

the slide.

MR. GUSTAFSON: Thank you.

That helps. And Mr. Pearse, in asking a question

of you -- I heard him to say that Dr. Desbarats'

evidence indicated that there were circumstances

in which the PAG would be not submerged.

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If I heard the question that

way, perhaps you had you heard it the same way as

well. That distinctly was not Dr. Desbarats'

evidence yesterday. And I just want to give you

the opportunity to comment based on your

understanding that the PAG will always be

submerged based on Dr. Desbarats' evidence.

DR. KWONG: That's my

understanding too.

MR. GUSTAFSON: What are the

implications of the PAG being continually

submerged?

DR. KWONG: If the PAG ws

continuous submerged then the impact on the water

quality in the pond in the TSF will be minimum.


Just one parting comment.

Mr. LaPlante implied that there

was perhaps some evidence that -- and I don't know

where he was attributing this to, whether it's the

company or somebody else -- that the possibility

of onset of ARD had been found to have been

reduced from a thousand years to two years, and

that was I guess a preface to his question.

And, Mr. Chairman, I just want

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60

to put on the record that we'll be interested to

have Mr. LaPlante establish the foundation for

that question at some point in these proceedings.

Those are my questions.


Mr. Gustafson.

Just before the Panel poses

questions, I think we'll -- I'm sorry? Go right

ahead.

MR. JONES: Thank you.

I just have what I believe are

two short questions. It relates to the question

that Mr. Pearse had I think about co-disposal of

tailings and PAG rock.

I believe your comment was that

it's a relatively new methodology or technology.

I just wanted to clarify whether you were talking

about co-disposal of tailings and PAG or whether

you were being more specific in terms of sub

aqueous disposal of PAG?

DR. KWONG: Well, the concept

of co-disposal of a waste rock and tailings at the

current stage is more or less always sort of --

the majority of the proposal will be under water

cover. Okay? But on rare occasions it would be

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61

-- they are variations in the approach.

For example, New Prosperity

would propose the waste rock to be submerged in

tailings impoundment, but not sort of a following

mixed with the tailings, but other schemes

involved the co-disposal actually dispose the

tailings to fuel up the pour space between the

waste rock. So they are variations of them.

MR. JONES: So I do have a

follow-up question because that's what I thought

we might be getting confused about, was this

methodology of mixing the co-disposal as a

distinct method from sub-aqueous PAG disposal.

And my follow-up question to

that was going to be in terms of -- is it not

common practice now, kind of state-of-the-art

practice in terms of taking a proactive approach

to the prevention of ARD metal leaching to dispose

of potentially acid generating material,

sub-aqueously. Is that not the best method

currently available to us?

DR. KWONG: Not necessarily,

because whether you can opine (ph) that technology

or not would be dependent on, for example, is your

tailings impoundment large enough to accommodate

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62

both of the waste rock and tailings. If you have

only a limited amount of space you co-disposal is

not an option. So that is no really something

standard option.

MR. JONES: Sorry, I'm still

trying to get this.

Assuming that you have this

space and water available to maintain water cover

over your PAG material, is that the best method

available to us to have them take a proactive

approach to the potential release of ARD metal

leaching?

DR. KWONG: Proactive

(unintelligible) yes. But then, as I said, it

would depend on the composition of your waste rock

as well. Okay. If arsenic release is a major

issue, frankly speaking, I think that some

(unintelligible) disposal would be preferable to

sub-aqueous disposal, because arsenic under

oxidizing conditions -- well, common oxidation

product will be an arsenic which is less toxic and

arsenic (unintelligible), which can be released

under (unintelligible) conditions under water

cover.

So dependent on your -- the

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63

composition of waste as well.

MR. JONES: Thank you. One

last question. It relates to -- again, it was

related to Mr. Pearse's question about the two

options that NRCan kind of proposed to Taseko in

terms of demonstrating the effectiveness of

sub-aqueous PAG disposal (unintelligible) or

monitoring.

And I understood your answer to

be more: It might be in the Proponent's best

interest to do that, to do the test work to give

you an early indication of whether you may have an

issue that you could address earlier and you are

going to save money if you can do that.

It was more an opinion. Would

it be appropriate for the Proponent -- or a

Proponent, an operation, to start that work sooner

rather than later but to be able to that I know

work into the early part of operations and

achieving the same thing? I guess that's my

question.

DR. KWONG: Yeah, that is

acceptable. That is why NRCan is committed to

options. The sooner you do it, it is to your

advantage.

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64

But on the other hand, since it

is unproven whether that would be a

(unintelligible) or not, we cannot really force

the operator to do it right away because I do not

really know the final outcome, right.

So the purpose of doing that is

to confirm your prediction and to confirm that it

would not be an issue, so that is to your

advantage.

MR. JONES: I understand. No

more questions.


Mr. Jones.

MS. COULSON: Excuse me, Mr.

Chairman, we just wanted to clarify one point

regarding Dr. Desbarats' presentation yesterday.

We just wanted -- on the issue

of whether the PAG would be exposed or not. Dr.

Desbarats just wanted to highlight the fact that

for one of NRCan's single simulations, based on

NRCan's conductivity estimates and Taseko's

average climate data, NRCan found that the PAG

waste would remain submerged. And Dr. Desbarats

is here should that require additional

clarification for the record.

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65


for that.

I think it's about time for our

break, so we'll take a 15-minute break, we'll come

back, and the Panel will pose some questions. You

that.

--- Recessed at 10:50 a.m.

--- Resumed at 11:10 a.m.

CHAIRPERSON ROSS: The first

item that I would like to deal with is to seek --

Ms. Coulson, to seek from NRCan clarification of

what exactly Dr. Desbarats said yesterday about

exposing various components of the tailings

storage facility. So if we could have that, that

would be very helpful to the Panel.

DR. DESBARATS: Alexander

Desbarats. Natural Resources Canada.

Thank you, Mr. Chairman for the

opportunity to clarify the results of my

modelling, which I presented yesterday.

Late in the modelling exercise

I investigated a variant of my groundwater flow

model in which I replaced the constant head

boundary at the top of the model with a recharge

boundary condition. And a recharge boundary

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66

condition is -- to remind people who may not have

been there yesterday -- is a type of boundary

condition which more realistically mimics the

input of rainfall and snow melt into the tailings

storage facility.

Now, for that variant of the

model I considered NRCan's base case estimates of

hydraulic conductivity, and Taseko's average

climatic data. And that climatic data includes

rainfall and snow melt, runoff from upslope areas,

run off from tailings beach areas and evaporation

from the pond.

Now, I ran one single

realization or simulation under those conditions,

and what I observed with my model was that areas

on the periphery of the impoundment adjacent to

the embankments beneath the tailings beach -- and

this material drains, the tailings material drains

to variable depths -- however, I clearly showed in

a cross-section or a slice to the impoundment that

the potentially acidic generating waste rock

remained submerged.

However, I would like to state

that this model was very preliminary and

exploratory in nature. A much more thorough

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67

investigation would require consideration of a

full range of climatic conditions.

That conclude what I had to

say.


very much for that clarification, Dr. Desbarats.

Next, do my colleagues have

some questions for Natural Resources Canada?

George?

MR. KUPFER: Dr. Kwong, leaving

aside the question of what costs might be involved

and whether those costs were acceptable to Taseko

or to anyone else, would you please confirm for me

that what you said was that technology does exist

to address ARD and metal leaching issues that

could arise from this project. It does exist?

DR. KWONG: Yes, it does. When

there's options, depending on what are the

elements of concern and treatment maybe perpetual.

For example, red dot deposit, you may have to

treat the water forever. But economics of the --

such that perpetual treatment cause is worth it,

according to the mine plan.

MR. KUPFER: Is it possible

that there could be a type of material that could

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68

not be treated as far as you know?

DR. KWONG: As far as I know,

no.

MR. KUPFER: Thank you very

much for that.

MR. SMYTH: Thank you, Dr.

Kwong for your presentation. On one of your

slides you noted selenium release. Do we know in

which metals the selenium is bound up in?

DR. KWONG: We do not know.

That is why we recommended the Proponent to do

more detail work to identify the source.

The reason why I pose the

question is in the shake flask as a results done

reported in the PV EIS two of the tests, the

leachate in the (unintelligible) test. They got

elevated concentrations of selenium.

And then according to the B.C.

Department of Mines' assessment for the current

EIS, they also anticipated sub-drainage may have

selenium elevation in excess of the B.C.

environmental guideline.

MR. SMYTH: My understanding is

selenium is bound up most commonly in sulphide

minerals.

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DR. KWONG: Yes. With respect

to ore deposit perspective, selenium is usually

associated either with coal mines, particularly

sulphide rich coal mines, and the second one is

most commonly observed is with massive sulphide

deposits, which are also sulphide leachate (ph)

because chemical properties of selenium is quite

close to sulfur.

MR. SMYTH: So the pyrite is

going to go into the tailings and if there is

selenium -- that the pyrite will end up in the

tailings.

Does selenium release require

acid rock drainage conditions?

DR. KWONG: Pardon me?

MR. SMYTH: To release selenium

from a sulphide mineral, does it require acid rock

drainage conditions for selenium to be released?

DR. KWONG: No. But it doesn't

require the oxidizing environment and

Environmental Canada in the presentation on Monday

will probably identify that further.

MR. SMYTH: Then going to Dr.

Desbarats' point that some of the tails might

indeed be dry, and they would be exposed to the

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70

air, those then would be a potential source for

selenium release; is that correct?

DR. KWONG: If the selenium is

associated with the sulphide. But on the other

hand -- well, some of the (unintelligible)

deposits, selenium can occur as an individual

mineral by itself.

MR. SMYTH: Right. Okay.

DR. KWONG: And then selenium,

if it occurs is an element of selenium is not

mobile. But if it occurs as a

(unintelligible)....

MR. SMYTH: Tricky stuff.

I would like to discuss the

pit. The pit walls will be exposed for upwards of

40 years before the pit floods. So you didn't

mention anything about potential for -- maybe I

missed it -- the potential for acid rock drainage

developing in the pit walls.

DR. KWONG: In the period EIS,

the Prosperity EIS, NRCan did raise that issue.

We commented water quality of the pit is

(unintelligible)....

MR. SMYTH: How come you didn't

bring that forward this time?

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71

DR. KWONG: Oh, because it is

not part of the -- take issue -- additional

information provided in the 2000 to the New

Prosperity EIS. That's not specifically, with no

additional information provided on the pit

chemistry. So we basically said -- NRCan consider

that that the previous comment still apply to the

current EIS.

MR. SMYTH: Therefore, for my

Panel colleagues and others, we would have to read

the previous submission.

DR. KWONG: The previous

submission from NRCan. Those submissions still

apply. That is why in my presentation I give a

brief summary of what we presented in the previous

EIS.

MS. COULSON: Just to

elaborate. In our final written submission,

there's a pretty fulsome summary of what we

provided in the first round review as well.

MR. SMYTH: So it's in the

written submission, your current written

submission. All right. So let's discuss it, if

it's in your current written submission.

So can you tell us when acid

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72

rock generation may generate in the pit walls and

how that might be mitigated?

DR. KWONG: To answer the

question, I think that we have to have a better

understanding of what is the -- eventually the

exposed rock, the pit wall is like because as the

proposed mining procedure -- the pit is keep on

expanding as time process, so what eventually is

exposed we do not really know. We don't have

sufficient information to predict when acid rock

drainage will occur. Starting to (unintelligible)

possibility. All depends on what would be the

eventual water chemistry like.

If it is -- comes to extent

that it cannot -- if dilution by natural

precipitation, it is not of good enough quality to

be discharged to the natural environment, then

perpetual treatment will be an option as one of

the mitigation option.

MR. SMYTH: I understand the

uncertainties about the pit. So let's move to

some real life examples of closed minds in B.C.

with abandoned pits.

Are you aware of any -- perhaps

Island Copper or others -- that pit walls are

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currently generating acid?

DR. KWONG: Well, lately I've

been working more in northern Canada than in B.C.,

so let me cite an example. Faro Mines. You've

got three open pits in Faro, and then all of the

acid drainage has to be collected and then treated

either within the pit itself or pumped to a

treatment plant and treated before discharged to

the specific environment.

MR. SMYTH: I'm trying to

conceptualize. You've got a 40-degree or

45-degree odd on slope, pretty steep slope. It's

probably sloughing off. Does all the water get

treated, all the water in the pit get treated, or

do you just take a layer of the surface water or

are you trying to capture it on the sides of the

pit?

DR. KWONG: As far as Faro mine

is concerned, the current -- the current treatment

method is you actually add lime or -- to the pit

directly, to neutralize the drainage and

specifically some metals, and also expiration of

trying to use microbial mediation, trying to

reduce some of that sulphide -- some of the

dissolve (ph) metals into sulphide.

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MR. SMYTH: In the Faro -- this

may not be Faro -- are those waters then being

released to rivers and streams or are there other

lakes or are they just captured.

DR. KWONG: It is captured

within the pit. But for the tailings impoundment

the water has to be treated before it discharge to

the receiving streams.

MR. SMYTH: But the plan for

this pit is it fills and then it discharges down

the Lower Fish Creek and into the Taseko River?

DR. KWONG: Right.

MR. SMYTH: So then a treatment

plant would be required.

DR. KWONG: A treatment plant

would be required if the water quality turn out to

be of such poor quality it has to be treated prior

to discharged.

MR. SMYTH: Thank you.

CHAIRPERSON ROSS: I can't

resist. Let me pursue that point just a little

bit longer.

Even at closure when the pit is

full there will be still some exposed areas. Is

it likely that they would generate sufficient acid

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to cause a water quality problem in the Pit Lake?

DR. KWONG: Yes, depending on

the extent of oxidation and how much sulfides are

oxidized at a rate of sulphur (ph) oxidation.

For example, if you have the

sulphide extend back to about say a meter, let's

say that. But the surface layer -- the exposed

layer would oxidize first, then you have

precipitation of (unintelligible) hydroxide, then

the sulfides behind the outer later -- slower

because you need the oxygen in the water to go in

there to -- and, hence, the oxidation further.

CHAIRPERSON ROSS: That's

helpful. Thank you.

My real question, which is

quite different, relates at a very high level to

what one ought to do in 2013 to avoid ARD. And I

understand that the most common practice is

sub-aqueous disposal. Not necessarily co-disposal

with tailings, but sub-aqueous disposal.

I guess my question, simply

put, is: Is that the best or are there

alternatives, not necessarily that might apply

here, but I'm just trying to get the big picture

first. Let me stop there. Is that best and what

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alternatives are there?

DR. KWONG: According to the

research done under the mine -- Mine Environment

(unintelligible) plan, the MEMCO plan -- it has

been proven that sub-aqueous disposal is one of

the most effective methods to be when ARD.

However, as I mentioned before,

it would be all dependent on the composition of

your waste rock. If they are elements involved

that are mobile or would be mobilized under

reducing condition, then sub-aqueous disposal is

not the best technology to be when ARD.

In that case, the Proponent has

to consider what is more important, whether ARD

would cause -- ultimately have more serious impact

or that particular element of concern.

Let's put it this way. For

example, uranium mines, okay. They don't really

have a serious acid rock drainage problem but they

do have an arsenic problem, and, therefore, they

have to use various methods to prevent the

leaching of arsenic from the mine waste and the

transport of arsenic through the groundwater

system into the streams.

So every mine is specific so we

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have to take -- site specific decisions to decide

what is the most effective way for treatment, or

prevention.

CHAIRPERSON ROSS: And for New

Prosperity, I infer that you don't think there are

enough of these other concerns to dissuade you

from the sub-aqueous disposal solution?

DR. KWONG: Correct.

CHAIRPERSON ROSS: I think I

used a double negative. I think it was clear.

There are a number of sources

of acid generating materials. I list a few for

discussion purposes. The non-PAG waste area, the

ore storage area, the soil storage area and the

tailings storage facility where PAG rock is

disposed.

Let me deal first with the

non-PAG storage. I know conceptually that one

separates PAG generating rock and disposes of it

sub-aqueously in the tailings pond, tailings

storage facility, and non-PAG generating rock

which goes to a different pile.

I have in mind that there's a

little person who runs up and tests the rock and

determines whether it's PAG rock or not, and says,

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78

okay, this rock goes in that truck and that truck

goes there.

Is the best way of doing this

literal testing, which is conceptually sound but

may not be operationally sound. Is it a

knowledgeable geologist who looks and says that's

the kind of rock that is non-PAG and so it goes

into that truck or -- how is that separation done

and -- you know where I'm going, it's how

successful can the separation be?

DR. KWONG: That will be

dependent on the experience of the person who are

charged with differentiating PAG from non-PAG

rocks.

For an experienced person, it

is possible, okay. I have a friend who is a

geologist in a mine in Sudbury. When I first

proposed the idea of just using mineralogy to

assess the (unintelligible) potential, he tried

that that out at his mine site. He said isn't

easy.

CHAIRPERSON ROSS: Sorry. It

is easy?

DR. KWONG: Yeah. And but he

said experience geology. No.

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79

And then for myself when I was

doing some field work in the Yukon I actually --

well, having no sort of a method of entertainment,

so I bet with my colleague, we go to a stream and

I said, oh, the pitch is within (unintelligible),

-- and then he posed another number. That end up

I'm 70 percent correct and he was 30 percent.

So it all depends on the

experience and (unintelligible) -- I remember

that, I first visit to Escape Creek Mine (ph). I

made a comment that, oh, this river (ph) is acid

generating. Then I got in a letter complaining --

a letter from the company complaining that I made

a judgment without -- without supporting data, and

then half a year -- no, three years later, I met

the same guy at a conference. He sort of

apologized to me. He said after $300,000 of a

testing we proved that you are correct.

CHAIRPERSON ROSS: So I won't

bet against you then.

Surely another issue that must

complicate the separation is the nature of the

rock itself because sometimes, as I understand it,

PAG acid generating rocks and non-acid generating

rocks are mixed up, and that means it's very hard

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80

to separate.

In any case, let me focus more

specifically on the New Prosperity site.

In your professional opinion

against which I won't bet, what percentage of PAG

rocks are likely to show up in the non-PAG rock

pile.

DR. KWONG: That I do not know.

As I said, that were dependent to person in charge

of a (unintelligible). There's likelihood that is

a possibility and, as a matter of fact, I think

that that is always an exception. You cannot

really hundred percent correct. Effect would be

dependent on how much of this PAG rock is being

disposed (ph) together with the non-PAG rocks. If

that amount is small then it would not cause too

much impact, and the reverse.

CHAIRPERSON ROSS: Let me then

move onto --

DR. KWONG: Something more, and

other thing. Some mining companies are doing --

they are routinely doing I guess to do a ABA

testing that's not -- well, routine --

(unintelligible) not going to take too much time

selectively collect samples every day and do those

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81

analysis on-site. And even a pH measurement would

help too.

So you can operate --

incorporate some of these measures to confirm sort

of their (unintelligible).


That helps.

Let me move onto your

suggestion of monitoring. If I look at the

non-PAG rock pile or the ore storage pile, is the

monitoring that you are talking about measuring

things in the seeps from those piles? Is that

what you would talk about, or are there other

kinds of monitoring that you had in mind?

DR. KWONG: The minimum would

be the monitoring of the seepage, and that is most

informative. If some element of the chemistry

start to change, then you know something is going

on within the pile (ph). The pile rise to

particular chemistry of the seepage. And once you

detect something is happening, then additional

actions may be taken. For example, you may have

to drill into the rock pile, select some samples

and see what is happening.


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82

Selenium. If determined there were some selenium

issues in one part of the mine or another, do I

understand that water treatment would be the

response to that? What would one do about finding

unacceptably large levels of selenium?

DR. KWONG: I feel I would

defer that question to -- refer to Environment

Canada because they would address the issue.

CHAIRPERSON ROSS: That's fine.

DR. KWONG: Because I know a

little bit about the chemistry of the selenium but

not an expert in the subject, and Environment

Canada has a much better qualified person to

address that question than me.

CHAIRPERSON ROSS: I think

that's all of my questions.

Do my colleagues have more?

MR. KUPFER: Just a comment.

It may not be obvious to everyone in the audience.

I want to ask a sample question to Dr. Kwong.

I'm sure you've reviewed, or

have you reviewed the British Columbia mines'

ministry's letter to us on the 19th, which

includes some comments that relate to the

discussion today? Just as a factual basis.

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83

DR. KWONG: I agree with most

of that assessment.

MR. KUPFER: Thank you. And I

want to comment for the sake of the audience that

there are some comments in that very extensive

letter that pertain to these subjects. Thank you.

CHAIRPERSON ROSS: I believe we

are now finished with our questions for you.

Thank you very much for your helpful contributions

to the review.

DR. KWONG: Thank you.

CHAIRPERSON ROSS: The next

presenters will be Dr. Kevin Morin and Dan

Watterson on behalf of the Tsilhqot'in National

Government.

Gentlemen, whenever you are

ready.

MR. MORIN: Thank you,

Mr. Chairman. It's Tony Pearse, I'm a technical

adviser to the TNG and we have two presenters on

this Panel. My job really will just be to

introduce them.

Dr. Kevin Morin will be talking

first and he estimates he'll be about 45 minutes -

just issues of timing here for your consideration

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84

-- then I expect Dan Watterson will be an hour.

What I had proposed do was

introduce and let Dr. Morin proceed with his

presentation, allow for questions and then

introduce Dan Watterson and he can go ahead, and

there may be an appropriate time for a break in

there depending on how close to lunch.

CHAIRPERSON ROSS: I'm thinking

we'll break after Dr. Morin's presentation and our

normal expectation is 45 minutes for the TNG

presentation. So I would appreciate it if your

two colleagues could make some efforts to be more

expeditious. But anyway, go ahead.

MR. PEARSE: Thank you

Mr. Chairman. Kevin Morin, who is going talk

about the geochemical aspects that lead into the

water quality issues, has more than 30 years of

experience fields of water contamination,

contaminate migration, hydro geology --

CHAIRPERSON ROSS: Mr. Pearse,

we have his CV. Perhaps we could attempt to

expeditious right now.

MR. PEARSE: Okay. I just

wanted to give a introduction so the audience is

familiar.

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85

He specializes in the design

and implementation of lab studies and mine

drainage related issues. He's author of over 100

publications and a registered professional geo

scientist in British Columbia, and the licensed

hydro geologist in the United States. We can

proceed with Dr. Morin.

PRESENTATION BY MR. MORIN:

MR. MORIN: Thank you for the

introduction, and good morning.

I would like to start off by

explaining exactly what I looked at during my

review. If we think of a simplistic environmental

assessment starting with a source of

contamination, and that contamination then

entering a pathway such as groundwater and surface

water, then flowing into a receptor like a like or

a stream it results and effects are environmental

impacts.

So, what I looked at were the

sources of water contamination at the proposed New

Prosperity project. Others, as we heard

yesterday, looked at some of the pathways such as

groundwater, and you'll hear about surface water

next week.

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86

And Mr. Watterson will be

talking about one of the groundwater pathways

after me.

I did not look at the

receptors, that comes next week under aquatic

environment. So when I talk about contaminant

sources I'm talking about the mine site components

like the waste rock, tailings, pit walls, or mine

roads, overburden, building foundations; basically

anything disturbance at the mine site becomes a

geochemical source term for water contamination.

And as you've heard already

some people in British Columbia called it ML/ARD,

but it involves a lot more than metal leaching.

There's non-metals. It can involved temperature

and other dissolved oxygen. Sometimes we just

call it geochemical source terms. That's what I

looked at, sources of contamination at the

proposed project.

On this diagram, this diagram

taken from the EIS, you can see some of the

geochemical sources of water contamination at the

proposed project. Most of them are labelled.

There's open pit, non-PAG stockpile. There's the

mine roads. There's also the ore stockpile

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87

footprint. It doesn't have rock in it, but it

will have rock, PAG rock, for at least a decade

and notice how close these are to Fish Lake.

One thing that's not labelled

is that brown blob in this diagram above Fish

Lake. Some of the run off drains down into Fish

Lake.

That's actually on the legend

end of the maps it's called a soil stockpile.

That's part of what my presentation is going to be

talking about. If I zoom out on this diagram to

the next one, not only there's one soil stockpile,

there's actually 5. I notice that two on the

right-hand side are out near close to Wasp Lake.

So imagine if those are

geochemical source terms of least contamination

the water will drain into Wasp Lake and damage

Beece Creek. And, so, my central major concerns

on the project are four; the first one,

geochemical source term predictions and water

quality, the second one ARD, the third, proposed

soil stockpiles, and the fourth, requirement for

water treatment.

So what I will do is briefly go

over each of these four and then conclude and put

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88

this all together into a summary.

So starting with the source

term predictions. It's important to note that in

the EIS the predictions for drainage from to a

number of these mine site components would violate

water quality guidelines and/or would be toxic to

aquatic life. So there's no doubt drainage from a

number of these components can kill aquatic life.

This includes the non-PAG stockpile, the ore

stockpile and the TSF pond.

So if I were to water down or

boil down my major issues on the geochemical

source terms the first one is, there's some things

that are not predicted. For example, water

temperature is not incorporated into predictions.

I'm not a biologist, but I understand that changes

in water temperature can affect aquatic life and

fish. And I'm sure you'll be hearing more about

this next week. In some cases pH was not

predicted and pH is an important water quality

parameter.

Number three, there are no

source term predictions for a nitrogen compound

called nitrite. When a mine is operating at full

scale it's blasting rock and when the explosives

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89

go off, most of that goes up into the air as

nitrogen gas but some of the explosive is left

over.

And when the rains come down,

coming out of the tailings, coming out of the

waste rock, coming out of the pit walls, will be

nitrogen compounds and the three compounds that

are often considered are nitrite, ammonia and this

nitrate. This is strange that there's no nitrate

predictions because the model used in the EIS was

Ferguson and Leesk(ph), 1988, which came from

Environment Canada.

This model has three

predictions that come out of it, one for nitrate,

one for ammonia and one for nitrite. So why

nitrate is not in the EIS I cannot explain, but I

know that that model provides it. And nitrate can

actually be more toxic to aquatic life at a lower

concentration than nitrate ammonia.

Without reasonable predictions

for nitrate, as well as nitrate ammonia which is

not predicted in some source terms, the full

impact of the New Prosperity project on water

quality has not been properly determined.

Fourth concern, the water in

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90

the TSF pond would be recirculated through the

mill around and around year after year. Now, as

this water passes through the mill, the mill adds

more contamination to the water such as sulphate,

metals, non-metals. This is like filling a

bathtub with the water previously drained from the

tub, bathing in it, draining it and re-filling the

tub to bath gain.

As a result, the tailings pond

does not start each year at some base line

condition, but instead igneous concentrations of

some of the parameters should increase through

time. You'll see them climbing year after year as

the year as the mill recirculates the water. This

is not predicted in the EIS.

Therefore, the full impact of

the New Prosperity project on water quality has

not been properly determined.

To understand again, to go back

to the source and pathway and receptor point,

here's an example of what happens when you

underestimate the concentrations and the tailings

pond.

Recirculation -- and this is

just picking on one, I'll come back to why the TSF

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91

pond is under-predicted. But recirculation of the

tailings pond was not properly considered,

therefore the concentrations in the tailings pond

were predicted to be too low for most years of

operation.

Because those tailings pond

concentrations are too low the seepage

concentrations they are predicting are too low.

Because the seepage concentrations are too low the

effects on the nearby creeks and down into Fish

Lake are underestimated and too low.

So this is that daisy chain

effect of source terms, pathways and receptors.

Getting it wrong in the source terms means that

everything below it is wrong.

Now I'm going to switch topics

to ARD which was already discussed for a while

this morning. The first sub-issue I'm going to

talk about ARD is something I called "scaling up"

or "upscaling".

We know that neutral drainage

is going to be a problem in New Prosperity, but we

also know that New Prosperity can, and has,

released acid rock drainage.

Now, what the New Prosperity

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92

project did was take the results of one kilogram

laboratory tests which were tested under

relatively steady conditions and scaled them up to

hundreds and millions of tons under variable

on-site conditions.

I ask you to think about that

scaling factor. One kilogram is used to predict

what a hundred million tons is going to do.

That's a scaling factor of a hundred billion. How

comfortable would you be taking something small

and scaling it up a hundred billion times? Do you

think that would be reliable? Would you be

concerned about the uncertainty?

Well, as Mr. Kuipers with talk

about next week, he will explain how often that

scaling up leads to under-predictions of source

terms. Concentrations are predicted to be too low

when the full scale mines are finally start to go

operate. Not surprising.

One thing that would help us at

this early stage before the EIS to help with the

scaling is to run some intermediate scale on-site

tests. This is under variable site conditions.

For example, these tests might contain one ton, a

hundred tons. Some might even go up to a thousand

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93

tons, and test them under on-site conditions.

Therefore, we take the one kilogram small sample,

scale it up to that intermediate one and say how

well did we do? Are we close? And we can

continue onto the full scale.

That intermediate on-site work

never been done for the New Prosperity project but

it was pointed out years ago how important it was

and it still hasn't been done.

So, again, we're hoping that a

scaling up of a hundred billion times is accurate.

Therefore, ARD predictions for

full sale mine site components in New Prosperity

are not reliable and underestimate ARD potential

as explained in the next slides.

This has also lead to AR

predictions in the EIS that contradict the actual

test work in the EIS.

The next sub-topic about ARD is

the criteria used to separate what is called PAG

and non-PAG rock which is kind of misleading

terms. But I'll use that since that is what is in

the EIS.

The initial predictions for ARD

and the old Prosperity had equations that said

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94

this rock will release ARD. This rock will not.

And that failed to predict what the test work

actually showed.

As a result of the discrepancy

the new EIS provides what's I call an "adjusted

criteria", but the term actually used for it are

preliminary, clarification, criteria, and the EIS

also says this preliminary adjusted criteria is

conservative, over-estimates the PAG tonnage and

allows for uncertainties.

If mining at New Prosperity

were ever to proceed I can tell you that the

wording in the EIS, that is "primarily

clarification", means the company is not happy

with that clarification, thinks that it's too

strict and will try to go back to the old one that

was proven to be wrong. So it was really

important for me, and to emphasize to the Panel,

that this criteria is absolutely critical to make

sure there is no acid releasing rock outside the

TSF.

I think not a preliminary

criteria that can be changed later during

permitting, but a final criterion should be

presented in the EIS.

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95

I understand some things might

happen during mining, maybe it could be adjusted

then, but by going into an EIS it contains a

preliminary clarification that means if the EIS is

approved the company can change back to the old

one when it wants to.

I believe there was some

discussion earlier this morning about the lag

time, how long it takes something to turn acid if

it's going to release ARD. We know this doesn't

always happen immediately, there's some lag time,

from the construction until the onset of ARD.

The problem was some of the

humidity cells started off acidic. Two of them

started off acidic. Two more turned acidic within

a few years. Now even if those are worse case

examples, we know some of the material can release

ARD almost immediately, one of those was basalt,

so the basalt can release it immediately. Other

rocks release within a few years.

Now, this lag time is

calculated in this EIS by equations that were

developed. Based on these equations the two

laboratory tests that started acidic should not

have become acidic for 2,000 years.

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Now, as I mentioned, this

preliminary clarification was adjusted to make it

fit the data better that still says the two tests

that started acidic would not be acidic for 1,000

years.

Details of that are in my

written presentation, written submission.

So there is a discrepancy

between what these equations say and what the test

work said, important to pay attention to that.

Under information response

seven Natural Resources Canada asked for

clarification and details of these liquidations.

After reviewing the company's response NRCan said

it had a problem with the lag equations. And I

believe Dr. Kwong said this morning he was still

uncertain on the details. And I agree with him.

Therefore, due to this inappropriate lag time

equation in the EIS the source terms and the

aqueous concentrations from the TSF and the over

stockpile PAG, which will have this material in

it, could be even further estimated than presented

above when I was talking about the source terms.

Geochemical loadings and

concentrations from some mine site components are

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97

expected to be higher than predicted, sooner than

predictions. Lag time predictions in the EIS for

ARD are confusing to the government and me, and

notably contradict the test work in the EIS. I

expected lag times will be much shorter than

predicted and more consistent with what the test

working is actually showing.

Now I'm going to switch over to

the soil stockpile. Maps from the EIS show

there's a soil stock file upstream of Fish Lake.

And there seem to be others along the TSF and two

out near Wasp Lake in the pristine Beece Creek

watershed. To me, that kind of disturbance

automatically makes them a geochemical source term

for ML/ARD prediction and assessment of water

contamination.

However, with these soil

stockpiles there is no testing, geochemical

testing, of the soil in those geochemical sections

in the EIS. So if you don't test the soil you

really can't make predictions for what's going to

come out of these little stockpiles above Fish

Lake and out near Wasp Lake.

Surficial run off. This is the

water running over the top. From the soil

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stockpile reports to Fish Lake and the TSF

assumed, and this is what the EIS assumed, it's

background run off concentrations, which means

that these soil stockpiles are basically invisible

to source term valuation. They're not going to be

have any effect on water quality. Although this

will be mined, this material will be picked up and

dumped with trucks and pushed around.

Some soil run off would also

enter Wasp Lake and/or Beece Creek. In addition

to the surface run off over these soil stockpiles,

there obviously will be some seepage. We were

talking about groundwater yesterday quite a bit.

However, the seepage from these stockpiles is not

mentioned anywhere in the EIS.

However, other sections of the

EIS outside of the geochemical and ML/ARD section

say that there will be an overburden stockpile,

which leaves me to suspect that at least on of the

soil stockpiles will contain overburden.

Other sections of the EIS link

the handling effects of soils and overburden

together. In other words they almost seem to say

soil and overburden are synonymous or somehow

connected together. In contradiction there's

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99

documents that say no, 100 percent of overburden

will go into the non-PAG stockpile and the main

TSF embankment.

Now, ML/ARD sections do

actually discuss what overburden is and they have

tested it and it's geochemically reactive and it

will can contaminate water and includes both PAG

and non-PAG material. In fact, some of what they

call overburden is actually rock, some of the

basalt that's been discussed in the last few days.

And one humidity cell containing this basalt was

acidic from the start. Maybe the soil is the

same. Maybe soil is overburden or some of it.

I'm not sure. I'm just know these soil stockpiles

can be source terms.

So, as a result, a major

geochemical source term called the soil stockpile

on the legends could contaminate Fish Lake and

Wasp Lake and Beece Creed through surface run off

and groundwater. This has not been properly

assessed in the impact assessment.

Stockpile soil and/or

overburden or what's actually going to be in these

can release toxic levels of metals and other

elements through drainage waters. So a proper

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100

assessment is required at the EIS stage, as done

for the other mine site components. We need this

for the soil stockpiles. Therefore, the full

impact of the New Prosperity project and water

quality cannot be determined with the information

the Panel currently has before it.

The last topic I'm going to

talk a bit about is requirement for water

treatment. For some mining projects treatment of

contaminated water is proposed. Treated(muffled)

concentrations from such plants do not

automatically meet water guidelines. They usually

don't. That's because treatment is not 100

percent effective.

As a result, environmental

impacts can still arise from the treated water

effluent and this justifies my view that treatment

plant discharge is another geochemical source term

at the site. Because New Prosperity has proposed

treatment of contaminated water therefore, my

review concludes that treatment plant as part of

geochemical source terms.

Interestingly, this isn't the

first time water treatment has come up for

Prosperity. This was a big issue back three years

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ago for the previous Panel. And the Federal and

Provincial agencies have stated that water

treatment would be necessary at New Prosperity as

an integral part of the mine plant. It's not an

option. I provided a number of quotations from

government agencies in my written submission to

show how emphatic they are.

However, the company continues

to say water treatment is just a water management

option. In one water treatment document annual

operating costs range from $4.3 to $14 million

dollars a year for a process called reverse

osmosis, a lot of people call it RO. The total

cost for the first 100 years of treatment using

this RO were estimated by the company at a half a

billion dollars to $1.5 billion.

The company estimated the net

present value of these scenarios at only $11 to

$20 million dollars because this treatment they

were talking about in the first document was

delayed for decades. It wouldn't have to start

for 20 to 40 years until after closure. However,

if treatment had to start earlier during

operation, the net present value would be much

higher.

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102

As the provincial government

pointed out, treatment costs would not be covered

by it's financial security because that is held

back in case of default. So the NPV, the net

present value, represents a cost in addition to

government security. And to clarify a little more

on that, I'm not sure why the provincial

government had to say to the company that bond

we're getting from you doesn't go to the treatment

plant. We're going to sit on that forever.

You've got to pay for something differently. So

something is going on, but I'm not on the inside

to figure out why the province had to clarify that

for the company.

A second water treatment

document explained the case studies of the

proposed water treatment plant, that full scale

treatment with a three circuit system has been

successful elsewhere. For example, this report,

the second one, states that membrane filtration,

which is similar to reverse osmosis, plus sulphide

precipitation was reportedly used successfully at

the Minto mine in the Yukon starting in 2010.

That sounds like good evidence that this plant

will work.

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However, other sources actually

reported problems with that treatment plant,

rather than success. For example, the mining

company itself wrote to the Yukon Water Board

saying no water treatment was undertaken in 2011

due to the inability of the site's water treatment

plant to meet updated effluent discharge criteria.

So that's not evidence that such a plant works

well.

As another example, this report

pointed out that a mine site in South Dakota, a

system similar to what is being proposed, that is

RO, reverse osmosis, was used to polish selenium

after treatment by iron reduction and

precipitation. Unless you go to those documents

and check it you won't know that most of the

selenium was removed by the iron reduction which

is not proposed in New Prosperity, and very a

little of it was removed by reverse osmosis, which

is proposed by New Prosperity. That's not

evidence they can remove all the selenium with the

full scale treatment plant.

Thus, there is no full scale

confirmation these proposed treatment circuits

will work successfully, individually or combined,

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104

or that they would be economical.

Statements in the New

Prosperity documents as to their success were

contradicted by other sources examining full sale

outcomes.

Proof of the full scale

effectiveness and feasibility of the proposed

treatment circuits rests with the company and

needs to be obtained in advance for the EIS stage.

The water quality of Fish Lake depends on the

continuous, reliable full scale success if the

project were to proceed.

The resulting effects on down

gradient water quality and cost for treatment were

expected by government agencies to be integrated

into the EIS and mine plan, however, this is not

done. So, therefore, there remain substantial

uncertainty around which locations would be

treated, when treatment would have to start, how

long treatment would be needed, whether full sale

treatment would be successful, and whether the

cost of the treatment would render the project

economically unfeasible or a burden to the TNG and

taxpayers.

Therefore the full impact of

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105

the New Prosperity project and water quality, with

or without water treatment has not been properly

assessed in the EIS. For water treatment the

downstream environment in Fish Lake would depend

directly on the treatment plant.

This type of treatment plant

remains unproven on a full operating scale fraught

with uncertainty, prone to periodic upsets and

failures and very expensive to the point of

possibly being economically unviable and a future

burden for others.

So, to conclude, I'm going to

pull my observations together into two topics; the

first topic is water quality and water

contamination.

It is critical to have a

realistic and reasonably accurate understanding of

the New Prosperity project source terms and their

potential implications for site water quality,

especially in the long term. To do this, the

Panel should have reasonably reliable predictions

of aqueous concentrations within the TSF and other

mine site components. These predictions in turn

effect predicted concentrations down the stream.

With this the information, if it's reliable and

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106

accurate, then we can check the proposed

mitigation measures, make sure they were properly

evaluated. Such information is not before the

Panel.

The New Prosperity EIS provides

unreasonably low predictions of the project's

effect on water quality, water contamination and

aqueous concentrations and seepage from the TSF

and other mine site components, as well as in

creeks Fish Lake and other lakes.

Now, focusing just on the TSF.

Some of the major reasons for these low prediction

in the TSF include, year after year recirculation

of the TSF pond to the mill would raise

concentrations higher than predicted ongoing

through time. Predictions are missing for water

quality primers like temperature, nitrate, in some

cases pH. A reasonable potential exists for rapid

ARD development in some PAG rock. Run off from

the soil stockpile is unreasonably assumed to have

background concentrations, when it likely contains

reactive overburden and/or soil.

Source terms for groundwater

seepage, also from the soil stockpile are not

given. With water treatment disposal of the water

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107

treatment waste, some of which are soluble, will

lead to higher than predicted concentration when

they're thrown in the TSF.

For Fish Lake in particular the

reasons for unrealistically low predictions of

water quality include concentrations and water

escaping the TSF as has been under-estimated.

Again, the soil stockpile, run off from the soil

stockpile is soon to have background

concentrations. Again, source terms for

groundwater seepage from the soil stockpile into

Fish Lake are not given.

Predictions are missing for

parameters like temperature and nitrate again, and

reasonable potential exists for rapid ARD

development in parts of the ore stockpile that

partially drains into Fish Lake.

Now I'm going to switch to

water treatment and just summarize my observations

on that.

The full impact of water

treatment on the New Prosperity project has not

been assessed in the EIS. The Federal and

provincial governments were expecting a meaningful

assessment, both environmental and economic. This

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108

is because water treatment was seen as, and still

is considered a requirement if this proceeds.

Instead, there is substantial ambiguity in the EIS

around where it would be treated, how long, when

it would have to start, how much it would cost.

In terms of technical

feasibility, the proposed treatment systems have

not been shown to be successful at lowering

aqueous concentrations of some contaminants at

safe levels in full scale operating treatment

plants at mine sites.

The Panel should have

reasonable information confirming the proposed

treatment can sufficiently reduce contaminates on

a full operating scale at stated costs. The Panel

does not have this information. The Panel should

have reasonable estimates of annual and cumulative

costs for water treatment that may have to begin

soon after mining starts. This is a critical

issue for project acceptability because the cost

of water treatment may cause the company to

default on it's environmental commitments.

Based on existing information

for the New Prosperity project full scale water

treatment could cost more than $4 to $14 million a

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109

year and more than a half a billion to $1.5

billion for the first hundred years. The Panel

does not have reasonable estimates integrated with

the mine plan.

As pointed out by the province

of British Columbia, the cost for treatment must

be secured independently by the company.

Government bonds and security for New Prosperity

cannot be used for treatment unless the company

defaults on its environmental responsibilities,

and thus the Crown, TNG and taxpayers approve that

liability. In other words, the company would have

to assume any costs of water treatment independent

of any closure security held by the Crown. And

perhaps a simpler way to say this is it's double

payment. The government is saying you're going to

pay us to water treatment in case you can't do it,

but you're also going to pay for the water

treatment at the same time. It's double billing

which doubles the cost of this.

Usually I'm quite wordy in my

submissions, but I tried really hard to create a

one-page graphical summary of most of my concerns

and I was amazed I was able to do it. It's a bit

crowded on there but that contains concerns most

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110

of my concerns.

And to finish off there is a

few points I would like to clarify and talk about.

The first, there was some discussion about Dr.

Kwong's rating of different sites and their

susceptibility to ARD.

He was mentioning that New

Prosperity would probably be between 3 and 6 in

his categories. He gave two examples of mines

that hit each of the categories 3, 4 and 5. It

turns out that one in each of those categories of

the two have ARD concerns even though there's 3, 4

and 5.

So even though say a category 5

mine in his classification might have a low

susceptibly to ARD 50 per cent of his examples of

ARD concerns.

And I think he would be willing

to admit that, yes, this doesn't say whether there

will or will not be ARD. This is simply a general

scale to let you know in advance before test work

whether could be a lot of ARD at that site, but

it's not 100 percent accurate.

Another point I want to touch

on is a nearby example of a tailings storage

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111

facility contaminating nearby ground water and a

lake. We heard Thursday night from Mr. Smyth that

there are a number examples that don't contaminate

ground water and a lake, and he mentioned Mount

Polley, and he is wrong on that one.

The last few annual reports

from the Ministry of Mines shows that some of the

monitored wells just outside the TSF and Mount

Polley have skyrocketed in their concentrations of

sulphate and copper. And, also, concentrations

are going up in a nearby lake very sharply. I've

seen, over 30 years, a lot of increasing

concentrations. I have not seen anything

skyrocket like it did at Mount Polley in one of

the monitor wells. So it was coming out fast and

coming out strong.

A final point, implications of

delaying environmental and economic issues to

eventual permitting. This was discussed here

before the Panel, and it's discussed elsewhere,

where you rank ideas which one should be addressed

at the EIS stage and which ones left for

permitting.

And I wanted to tell you a true

story that happened at Mount Milligan about this

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112

permitting delay. Mount Milligan is talked about

as a recent mine in B.C. There was EIS review.

There were a number of metals that were found to

be above water quality guidelines. They were

predicted to be too high, and they recorded

mitigation.

So the decision was what

mitigation? Water treatment plant? Cover it?

The decision was made to leave it to permitting.

So then the Ministry of the Environment then said

okay, it's left us to. So they said to the

company what mitigation are you going to do. The

company said, we predicted wrong during the EIS

stage. We were too high. We now are predicting

lower concentrations. There's no water quality

issues at all. Now, one would think that MOE

would go back to various stakeholders and say is

this okay. They didn't. They unilaterally

decided, good. Here's your permit if there's no

water quality problem.

So the two implication of

delaying something to permitting is one, you are

turning it fully over to the province which as

already approved the Old Prosperity project, and

to the company to figure out together. The second

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113

implications is one outcome is they will dismiss

the issue. They will revise it so it's no longer

a concern. Please keep that in mind when you

delay something to permitting. And that's it.

Thank you.


Dr. Morin. It's now 12:15 so I think we're going

to break for lunch and we'll start questioning

after lunch, about one hour from now. So 1:15.

--- Recessed at 12:15 p.m.

--- Resumed at 1:15 p.m.

CHAIRPERSON ROSS: Good

afternoon. It's now time to resume.

Just before we do, I would like

to make an announcement that has some bearing from

what the panel has done. The panel has heard a

great deal in the hearing about closure security

deposits.

This morning to panel wrote to

the B.C. Ministry of Energy and Mines seeking

clarification on a number of aspects of what it

does, what its practices are for new mines

regarding security.

We thought that might be

helpful not only for the panel but also for other

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114

participants in the process. To go right -- and

again I use the term -- to the horse's mouth --

and let's be clear which end we're talking

about -- to the authority to seek some guidance.

That is post on the registry at CEAR no. 763.

Mr. Gustafson, would you like

to say something.

MR. GUSTAFSON: Thank you, Mr.

Chairman.

I just wanted to mention that

we had heard many of the same questions ourselves

and do plan to put something on the record as part

of your closing.

CHAIRPERSON ROSS: It was very

clear to us throughout the hearing that that would

be helpful from the authority.

It's my understanding that you

propose at this time to pause and to take

questions on Dr. Morin's presentation. Is that

the plan?

MR. PEARSE: Tony Pearse.

That's correct, Mr. Chairman.


Mr. Pearse. In that case, the order is Government

of Canada, interested parties, do we have any

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115

questions for Dr. Morin?

I'm sorry, you are not with the

Government of Canada.

PUBLIC SPEAKER: Sorry.

CHAIRPERSON ROSS: First

Government of Canada. We'll get to other

interested parties later.

Not seeing any, I would move

onto, logically, any other First Nation interested

parties. Not seeing any, I would move onto group

interested parties, interested parties that are

groups. Ma'am?

MS. NOBEL: Jenny Nobel, Fish

Lake Alliance.

Just as a member of the public

with little to no experience in these matters,

there's been a lot of talk about waste treatment

and reverse osmosis and so on. If I'm

understanding that right, reverse osmosis is

supposed to trap contaminates before the water

goes away?

MR. MORIN: Yes. Reverse

osmosis is sort of a membrane filter, and they

push the water through it and the water goes

through but the contaminates, the chemicals stay

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116

outside and so the water is purified as it passes

through the filters.

MR. NOBEL: My question is:

What happens to the stuff that remains in the

filter?

MR. MORIN: They all those

contaminants, the waste product, and they have to

get rid of it. At this point they are proposing

to put it into the TSF. And when it goes into the

TSR it can redissolve there and raise the

concentrations there.

MS. NOBEL: Thank you for that.


Any other group interested parties? Any

individual interested parties. Taseko?


Again, with our position with respect to Dr.

Kwong, we will have questions for Dr. Morin once

our expert arrives.

Just to put on the record, this

is consistent with the understanding of how the

hearing was to be structured with acid rock

drainage metal leaching as being part of the

aquatic phase of the inquiry in the Panel's letter

of June 27th.

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At this time I do have a couple

of points of clarification coming from a layman's

perspective.

Dr. Morin, I wanted to talk a

moment about your comments on scaling.

As I heard you speak, I got the

impression that you said that the soils'

characterization done by Taseko was based on, or

limited to, the testing of one kilogram sample and

then skilled up I forget how many billions times.

Is that your understanding of what the company has

done for soil characterization?

MR. MORIN: Excuse me. No,

that is incorrect. I could find no soil

characterization on the geochemical side in the

ML/ARD section. In other words, I was interested

-- say when rain comes down onto a soil stockpile,

whether arsenic would come out, or cadmium, or

copper or something like that. So I looked for

soils in the ML/ARD section and could find no soil

testing at all.

MR. GUSTAFSON: I'm still

trying to understand what you meant to infer when

you said that the characterization or that the

testing was limited to a single one-kilogram soil

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118

sample and then scaled up. So, again, was it your

intention to imply that that was the limit of the

testing that the company had done?

MR. MORIN: My comment about

scaling up came from the humidity cells, which are

run in a laboratory, and humidity cells contain

about a one-kilogram of sample and they are put

into an enclosed container and air is passed

through them, and once a week they are opened up

and water is poured over them. Water is drained

off and analyzed, and based on that there is a

certain rate that comes out of it. How fast

copper is being released, or how fast arsenic is

being released from that particular one-kilogram

sample. Based on that rate, that is then upscaled

to the full scale waste rock dump.

So, for example, waste rock

dump is one million tons -- sorry, one hundred

millions tons. When that is being predicted from

a one-kilogram sample they have to take the rate

at one kilogram and scale it up one hundred

billion times to make a prediction for one hundred

million tons of waste rock, and that also applies

to overburden too.

MR. GUSTAFSON: That comment

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then relates to that one particular test and

doesn't mean to suggest that that's the limit of

what the company has done in terms of its soil

characterization and testing.

MR. MORIN: Well, again, there

was no soils characterization that I could find on

the geochemical side. So as far as I know, the

company hasn't done anything from that.

But as far as other tests,

there are things called acid base accounts, which

Dr. Kwong talked about, which uses I believe --

I'm not sure how much you use, but about a hundred

grams of sample. There is also what are called

shake flacks (ph), where some sample of rock is

put into a jar and shaken up. That's usually

about a hundred grams.

So I'm aware of other test work

being done. But as far as I know, these humidity

cells and I think a few columns are about the

largest that have been done. So, again, we're

dealing with billions -- a scaling factor of

billions of times up to the waste rock dumps.

MR. GUSTAFSON: Dr. Morin, I

guess it's my general understanding that in fact

there are soils characterization guidelines that

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apply for a project like this that call for a

whole range of soils characterization testing. Is

that correct?

MR. MORIN: I believe there

are. Like, for example grain size

compressability. There may have also been some

analysis done. But, again, I'm not interested in

what the analysis of the soil is. I'm looking for

predictions of source terms. When you take the

soil samples, if some have been collected, tested,

if you take that I want to know what will be

coming out of the soil stockpiles. And the EIS

says what will be coming out of those soil

stockpiles, is background concentrations. In

other words, the soil will have no effect at all

on water quality. That's all I can find.

MR. GUSTAFSON: We'll clarify

that, I think, in our closing.

One other area of

clarification, if I may. You referenced the

figure of a thousand years in relation to acid

rock drainage, and I wonder if you can just

clarify, please, from my understanding, what the

significance of the thousand-year figure is.

MR. MORIN: The thousand year

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figure came from the lag time equations that are

in the EIS, and I'll step back a bit and explain

it.

There were two humidity cells

that started off acidic right from the beginning.

Now that means they would be releasing ARD

immediately. However, when you do the acid base

accounts on them -- which is what the lag

equations use -- when you look at the acid base

accounts, those should have never, ever, at any

point in time, released acidic drainage.

So what happened is in the EIS

there was -- for the New Prosperity the criteria,

the preliminary criteria were updated, they were

adjusted to match the test work. So now the new

criteria, in fact, do say that these things will

turn acidic at some point in time.

When you use the equations in

the EIS that says it will turn acidic after a

thousand years, does that explain?

MR. GUSTAFSON: It helps. I

just want to clarify. Did you mean to suggest

that at one point the company's position had been,

or in something that had filed, that acid rock

drainage would not commence for a thousand years?

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MR. MORIN: No. Specifically

those two simples. I was trying to explain the

known (ph) limitations of an equation.

With an equation you have to

put numbers in and you get numbers out. So the

numbers I put in were for these specific humidity

cells already acidic. And what came out told me

they were not supposed to be acidic for at least a

thousand years.

Now, there might be other

numbers and they are probably brought with other

characteristics, you plug into that equation and

get different numbers. But the thousand years

applies to these two cells that were already

acidic when they started.

MR. GUSTAFSON: So if I

understood your answer correctly, the company has

never taken the position that acid rock drainage

would not start for a thousand years.

MR. MORIN: My understanding

the company said this situation tells us certain

things, and I don't recall anybody saying an

average value is put into the equation and here is

the average value that came out, all that is

presented by these equations.

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Then there's a few statements

in the EIS that says it could be centuries or

decades or something like that. Again, even

though the equations are given they are not used

quantitatively in the EIS to come up with

predictions.

So I don't think the company

ever said that ARD would never appear for a

thousand years. My point is that the equation is

wrong because it says these acidic cells should

not be doing that for a thousand years.

MR. GUSTAFSON: Thank you, Dr.

Morin.

Mr. Chairman, I think I'll let

the expert talk about validity of the equation.


Mr. Gustafson. Anything else, Taseko, at this

time? I'm assuming that's a no. Sorry. Thank

you, Mr. Jones.

Either of my colleagues.

George?

MR. KUPFER: You've indicated

in your presentation a number of things that you

would have liked to have seen, or that you

expected to be in any application for this kind of

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project to deal with this subject.

I wonder in terms of your list

of deficiencies, as you indicated them, what, in

your mind, is the most crucial and missing pieces

of information that would satisfy you or anyone

else as to the nature of the acid deposition in

the metal leaching.

Is there a priority? Which is

the most important thing is what I'm asking, in

your mind?

MR. MORIN: I think the easiest

way to answer this question -- I'm going to go to

one of my last slides here, my one-page graphical

summary.

Notice all the arrows pointing

into the TSF. Any one of those alone could cause

concentrations to be higher than predicted in the

TSF.

If two apply then the

concentrations are going to be even higher. So

your question is, would I rank those one higher

than the other on what's important. And no, I

think they are all important. There's also a

number of other issues that I thought I wouldn't

burden the Panel with. And the last Panel I

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actually submitted an 80-page written submission

with a lot of these details.

I thought I would pick out the

most important ones at this time. But there are

other ones that tie into this that show the

concentrations will be even higher. So short

answer is: I'm not sure I would put a priority on

these. All these are important.

MR. KUPFER: I have to admit, I

don't recall that 80-page submission, I'm going to

have to go back and look. Thank you.

MR. MORIN: To be clear, that

was from the 2010 Panel.

MR. KUPFER: I know, we've read

the material and somehow it skipped me.

MR. MORIN: Most of that, those

points still apply. I've only picked out the

major ones.

MR. KUPFER: Thank you.

MR. SMYTH: Thank you for your

presentation.

I've read your resume and I

understand that you've been involved in ARD

studies at a number of porphyry copper mines in

B.C. over the year.

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In this work, did any of the

reason project -- say those from the last 10 years

or -- so meet your standards for an ARD predictive

study?

MR. MORIN: I think I will

first make a point clarification. I just don't

look at ARD. Maybe the best way to explain it is:

For example in limestone. Limestone can contain

materials like cadmium and zinc and copper. So

even a limestone quarry can release toxic levels

of some metals, like cadmium and zinc.

I tend to see it as more

holistically than that. So I look at mine site

drainage chemistry. ARD is one aspect of it. But

really it could be alcamin (ph) drainage, like in

some diamond mines, could be mutual (ph) drainage.

I'm thinking the best way to

answer that is: In a few days Mr. Kuipers will

actually present to you what the standard is. In

other words, when these predictions are -- he did

a compilation of predictions and he went and

looked at the mine site after they were operating

compared them.

MR. SMYTH: I know you've

looked at porphyrias mine proposals in B.C. Did

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any of them get it right?

MR. MORIN: There's a very

encompassing question, right or wrong. Okay, I

would say no, and this is why I say no.

For example, with Kamis South

(ph) that was predicted to have ARD but they were

going to control that like pushing rock into the

pit and flooding it, which they did so they didn't

have ARD. And they were not predicted to have any

metal leaching.

But about two years ago they

were out in a nearby creek sampling and selenium

had gone sky high, well over toxic levels, and

they had to scramble to find out where this

selenium was coming from and what they could do to

control it.

So their chemist did a great

job of controlling ARD, but this unexpected

selenium leaching popped up on them in one creek.

So when you have a big mine site, there's lots of

creeks, lots of mine site components, and water

quality guidelines that have dozens of parameters,

the chance of a mine site ever meeting all those

everywhere is very slim.

MR. SMYTH: So there's lots of

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unknowns.

MR. MORIN: Lots of potentials

for problems to come up.

MR. SMYTH: And, therefore, a

rigorous adaptive management plan is the only way

to mine. If you didn't have that, we wouldn't

mine any more, would we?

MR. MORIN: I'm thinking back

to what a number of mine managers said to me. If

we knew the site was going to be like this, we

would have never mined it in the first place.

So I agree, adaptive management

would be important, but thee's also things to do

up front to identify what the problems could be or

where to look for those problems. For example,

how quickly could the problems arise. If they

might come up within one year then work has to be

ready to go right away.

If it's like a 30-year problem,

then there's time to adapt for it, to watch for

it. So there's a balance in there, I agree.

MR. SMYTH: I heard you say

that and I took note of it.

My colleague's question to you

was: What's the biggest gap then? You show this

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and you tell us that they are all gaps. They are

all important. I suppose that's a fair answer,

but is there any one that would keep you awake at

night?

MR. MORIN: No, there isn't

one. But my point was by showing this, none of

these are difficult to do. For example,

recirculation of the tailings pond through the

mill. That's easy to calculate. It just goes

around and around.

There was no nitrate

predictions. Well, it What comes out of the

model. Just put nitrate in with the other

parameters. There was no source terms for soil

stockpile. So these aren't big difficult things

to do.

MR. SMYTH: Okay. That's

helpful. Thank you.

CHAIRPERSON ROSS: Ron has lead

nicely into my first question, so I will first

quote you as saying, that's easy to calculate.

What's your best guess as to

the concentration of stuff in the tailings pond

after a bunch of recirculation?

MR. MORIN: I don't think that

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would be difficult to figure out. One could go to

various tailings impoundments and see what

concentrations are in those.

But the concentrations that are

in the EIS are so low that it's obvious from any

one of these factors that it's going to be higher.

If I had some time -- well, in fact, if I was

working on the project I would have predicted

that. In fact, I'm working on a project now and I

am predicting that.

CHAIRPERSON ROSS: But you

could calculate it and you have a bunch of

professional experience at what you have seen in

other places. So can you give me a

shoot-from-the-hip kind of an answer, because

we're going to write a report pretty soon and some

guidance would be helpful. You may not feel

comfortable doing it, and that's okay too. But I

think this is an important request.

MR. MORIN: I'm thinking of how

to give you a simple answer because it depends on

the elements. So I'm going pick one here.

For the TSF pond, the copper is

predicted to be 55 micrograms per litre, which is

.055 milligrams per litre. I expect it to be

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closer to one. So, we could go down through the

list.

Sulfate is predicted 1,000 with

all the recirculation, the treatment plant waste.

I expect to be around 2,000.

Selenium is given at 14

micrograms per litre. I would expect it to be

closer to 50, maybe a hundred.

So I could go through each of

these elements and give you a rough idea of what

I'd expect it to be. But, again, there's a way of

calculating it based on the test work that was

done for New Prosperity. Again, it was called the

Goldsem model. But it wasn't done or, if it was

done, it was not done properly. Does that help?

CHAIRPERSON ROSS: Sorry, I

should have said thank you, that helps a good

deal. I was looking at my next question.

MR. SMYTH: While Bill is

thinking, would an option then be not to

recirculate the water? Could the water just be

left in the TSF and extract more water from all

these aquifers and put fresher water into the

mill?

MR. MORIN: That is exactly

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what used to be done a long time ago. The problem

is when it comes out of the mill it's already got

contaminates in it. So they learned decades ago

not to release it, but put it into the pond.

Then they realized as they got

larger mines that the mills need so much

incredible amount of water that you would be

sucking up so much fresh water and contaminating

it, it was better just to take the contaminated

water and keep sending it through the mill and

having the contaminates increase.

I don't know the exact number

that this mill needs, but if we check the numbers

I think you would be amazed at how much water this

mill will use in one day. So to take it out of

the aquifers or out of the Taseko River, would be

way too much water to manager. Then when it came

out of the mill it probably would still have to be

treated for something.

CHAIRPERSON ROSS: I found the

arrow that connected my two thoughts that fit into

a question here.

You talked earlier about the

scaling up problem of going from a kilogram to a

hundred billion tons of stuff. What's expected

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professional practice at new mines in B.C. today

in terms of the humidity cell, one-kilogram

sample, and then presumably some larger sample and

then some larger sample and even eventually you

get satisfied and you could scale up meaningfully.

What do other good mining companies do when they

propose new mines in B.C. these days?

MR. MORIN: A very loaded

question by defining what a "good mining company"

is.

CHAIRPERSON ROSS: What's the

standard professional practice is what I'm looking

for.

MR. MORIN: I'm just trying to

think of some statistics to give you. Let me

start with my practice.

I would never take a humidity

cell and scale it up without the intermediate

on-site kinetic test. Never, ever. And I have

never done that.

Most other people in our

practice do that -- they do intermediate kinetic

tests. Diavik, for example, is a good one that

just started some of that a year ago. I think

there are about 50,000 tons.

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However, the B.C. government --

CHAIRPERSON ROSS: Diavik has

been operating for 13 years.

MR. MORIN: Yes, they just

started doing some kinetic tests because they are

planning on doing something else. I don't know --

I'm not familiar with the site but they are

running these kinetic tests to find out something.

Something about closure maybe, I don't know.

But in other words, some of

these sites do run them, others don't.

The B.C. government does not

have a set policy. They would like to see them,

but they were not required.

CHAIRPERSON ROSS: Okay.

Soil stockpile. Same question

as before. It's just going to be one of those, I

want your opinion. Same question as before.

Soil stockpile. Geochemical

source term. Have you got a guesstimate as to --

I guess in part it's similar to the question

George posed. You got a guesstimate as to whether

it's likely to be an acid source term or whether

it's going to have other things coming from it or

what? Give me your professional judgment.

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MR. MORIN: Okay. The problem

with my professional judgment lies in the

definition of what the company calls "soils".

Because some people -- or some other companies

consider soils to include overburden, like sands

and gravels. Other companies think soils are just

the organic part.

So if we start with just the

organic, the black part as organic carbon, then

yes, it will be acidic because most natural soils

are acidic, but not ARD. It's from the organic

acids in the soil.

But if it includes overburden,

we know from the test work in the previous EIS for

old Prosperity, which the new one refers to, that

the overburden -- some of it is net acid

generating and can release ARD, and the part that

is not can release elevated metals into water and

other elements.

So I know that the overburden

can cause an impact. How much of the overburden

is going to be in the soil stockpiles I don't

know. The soil stockpiles can release other

problems like dissolved organic carbon which could

run down into Fish Lake and the other lakes, eat

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136

up the dissolved oxygen in the lake.

Again, I'm not a biologist.

I'm using (muffled). And without dissolved oxygen

things die in these lakes. So I can envision

things that could come off the soil stockpile that

would cause very serious effects in the lakes.

But because I don't know exactly what this company

is considering soil and what's going into those

piles I'm kind of wavering on what I think is

going to come out of them. Does that help?

CHAIRPERSON ROSS: Yes, it

does. That's fine. I'll let you off the hook

this time.

MR. KUPFER: While Bill is

looking, would you please finish that sentence

again. The B.C. government has no set policy on

-- I'm sorry, I couldn't get that word.

MR. MORIN: Oh, on the on-site

kinetic test, whether you have to --

MR. KUPFER: Thank you.

On-site kinetic test.

MR. MORIN: The Federal

government has released a prediction manual that

said you should run these, but this manual is not

requirements, it's not a legal document that says

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mining companies have to follow this.

B.C. has also done that. They

released guidelines and expectations manuals, but

no where do they say: You must do this.

MR. KUPFER: Thank you very

much.

CHAIRPERSON ROSS: I think I'm

done here. Ron, anything else? George?

Okay, in that case, we're

finished. Thank you very much for your

presentation, answer, statement. That's been

helpful.

I should have asked this just

before. Dr. Morin, will you be around on Monday

when questions come forward or?

MR. MORIN: No, I'm sorry, I

will not be. I'm going back tomorrow but I will

be available for a phone call.

CHAIRPERSON ROSS: Okay.

That's good. Thank you. Mr. Watterson, I

believe. Go ahead.

MR. PEARSE: Mr. Chairman, Tony

Pearse. If I can briefly introduce Mr. Watterson?

CHAIRPERSON ROSS: Emphasis on

"briefly".

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MR. PEARSE: Yes. Everybody, I

think, has been introducing their experts so I

would like to that I can that liberty, if I can.

Mr. Watterson is a principal

hydro geologist with Watterson Geoscience. He's

got 28 years of geoscience environmental and water

resource experience. He's registered in British

Columbia and Alberta as a professional

geoscientist and Washington state as a licenced

geologist and hydro geologist. And he's worked in

British Columbia, Northwest Territories, Yukon,

Western United States, Africa and Mexico.

PRESENTATION BY MR. WATTERSON:

MR. WATTERSON: Thank you for

the opportunity to speak.

I was contracted by the TNG to

provide a comprehensive review of the EIS and the

supporting documents with respect to the 2012 CEAA

guidelines that were presented with respect --

they were published in response to the 2009 EIS,

and also with respect to the 2012 B.C. Ministry of

Environment baseline water quality guidance which

addresses the kind of studies that should be

conducted when doing baseline studies for proposed

mines and also just with respect to my

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139

professional experience in the use -- in these

matters.

And the objective was to

evaluate the project with respect to the data and

the assessment and certainties, and the potential

environmental risks from the project especially to

Fish Lake.

And by doing so, I developed

kind of a big picture understanding of the project

area hydro geology and interactions of the

proposed mine with that hydro geology.

So this is an almost

criminally-abbreviated list of the EIS guidelines

that are requested in the 2012 CEAA document.

They are in my paper for reference. If we want to

talk about them, I have them at the end of my

presentation.

But the point of the guidance

which are -- the point of the guidelines which are

quite comprehensive was to complete a

comprehensive assessment and presentation of the

project area hydro geology to identify the effects

of mining in a TSF seepage in particular on local

and downgradient groundwater quality and quantity

and to provide a numerical model which uses the

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140

site data and which incorporates all major site

features and finally to identify and describe all

necessary monitoring and mitigation features.

So that's kind of -- in a

really broad sense, that was the criteria through

which I reviewed the EIS. So it was a very big

area; big review. And so because of that -- and

I've only kind of hit the high points in my

presentation in the interests of not keeping

everybody here till next week -- but so the key

risk in the project, of course, is we've had a

number of very learned people talk about very sort

of specific aspects of hydro geology, whether it's

the faults from Dr. Desbarats, whether it's

discussions of the overall till characterization

by Dr. Smith, Dr. Morin and others talking about

the acid rock drainage.

My review is bigger in scope

than that. So the key risks are of course the

potential for solute to leak from the TSF and then

figure out where it's going to go. The next one,

of course, is NRCan has rightfully pointed out in

numerous information requests is the understanding

between Pit Lake -- the pit and Fish Lake

interactions, and then as Kevin has pointed out,

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there is potential groundwater quality impacts

from ores and waste rock and soil stockpiles. And

this was specifically pointed out in the EIS

guidelines, potential groundwater qualities

resulting from the open pit operations.

So those are the main sources

of risk from the project.

And what I found from my review

was four main categories of inadequacies I guess

is the best word. Inadequate baseline

characterization. There's oversimplified hydro

geology used for the modelling and effects and

then the -- effects analysis and then the

modelling itself was inadequate along with it's

sensitivity analyses and inadequate mitigation

planning. There are some others but these are the

main ones. So if we're going to look at starting

with some of the inadequate baseline

characterization, we've seen this figure before.

This figure shows the Fish

Lake, TSF, the area in red is the proposed PAG

stockpile area. So these little dots are test

pits. And so one of the things that seemed odd to

me when I first looked at this is for the PAG --

proposed PAG storage area, the most sensitive area

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on the whole project, they have six test pits; six

test pits for an area that's about four square

kilometres in size. And they say -- and that's

their characterization.

The scale of this is deceiving.

This is four square kilometres, the size of a

small town. Each of these test pits is about as

big as the table in size. And so that's what they

have used to characterize and base all their

analyses on for how PAG is going to behave in this

area is on data from six test pits. If you notice

off to the south, there's a huge area which has no

test pits at all.

This is a figure out of one of

the documents, Knight Peisold TSF Design Report.

It's turned around the other way. This brown area

is Fish Lake. This is a map of till, the

underlying material for the TSF over the area.

This is the north embankment, south embankment,

west embankment. This shows kind of the data

points that are used to generate this map. So if

you compare where they show where a till is in

this thickness with this figure here showing where

the test pits are, there's quite a big disconnect

between where they actually have data sources --

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sources of data -- and where they are showing

where a till exists.

This is a figure that shows the

wells that were used in the -- to do the hydro

geology analysis. Now there is an error in my

report because I misinterpreted this figure when I

wrote it. My report says that there are no

drilling bore holes within the footprint of the

TSF. That is incorrect. These red dots right

here are some wells. But it doesn't change the

point -- they really don't change the point of my

-- of this slide in my report in that here's a 12

square kilometre area which they are going to be

storing 400, almost 500 cubic millimeters of

tailings and there's not a single bore whole

inside the bulk of the area to tell what's

underneath. Not one.

So all these questions that

have been talked about, especially from Dr.

Desbarats' report the other day where he had to

extrapolate the geology between -- from the sides

of the TSF down towards the centre, is because

there -- they actually don't have any data there.

So we don't know what the conditions are like.

Dr. Smith -- you may recall

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from a couple days ago, Dr. Smith stated that in

his opinion for an area this size they would have

-- require 50 to 60 bore holes in order to do a

proper characterization job. And, again, we have

half a dozen on one end.

This cross section shows

another problem with the characterization effort

in that there is a significant distance between

data points. This is one cross section here,

basically east/west through the proposed TSF,

here's the top of the TSF win (ph) build line.

This is 600 metres from their scale right there.

So their hydro geology extrapolates from points

more than a kilometre apart and in an area that

has complex geology and hydro geology as you've

heard.

Also another part of this, you

can't really tell on this figure, but on all these

contacts between upper units and lower units,

there are question marks. And question marks in

geology terminations means this is our best guess;

we don't know; inferred.

They have units that they just

end. This is a glacial -- what's called a glacial

fluvial unit -- sands, gravels -- that's in this

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hole. They didn't drill deep enough and down here

to find it but there's no knowledge of where this

goes. There's just ends. There's no explanation

of what happens to this, nor for how groundwater

is going to behave when it's run- -- passing

through this.

Some of the other missing data

that's part of a normal hydro geologic

characterization and is also mentioned in the

guidance is there is no data for sediments beneath

Fish Lake. The lake bottom sediments and

characteristics are based solely on inference and

from indirect methods. Scroll back up to this

picture here. You can see there is -- we know

there is a few test pits down here, there's a

couple there, and there is some test pits on this

end and there is one bore hole in the middle on an

island.

All of the rest of this is

unknown, but a huge amount of the Taseko's

modelling and effects analysis is based upon the

presumption that this till actually extends

beneath the lake. But there is essentially no

data to show that.

Another thing, there are no

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data for any kind of fluvial sediments that extend

along the Fish Creek Valley and along the Taseko

River. They don't find any maps of surficial

sediments or basalt.

The seeps and strings (ph) that

lie along the Taseko River have not been mapped or

characterized. Groundwater and surface water

interactions especially along the Fish Creek are

not assessed, and there is an incomplete

understanding of how groundwater flows in the

upper bedrock. For example, in discussions that

we had yesterday about flow above the gypsum line.

There is really no data about that.

And there is -- and what this

all boils down to, is they really haven't

characterized the potential groundwater flow

pathways to any of the overburden or the basalt or

the bedrock. They -- as Dr. Desbarats mentioned

yesterday, they have just sort of all combined

them into one unit, and I'll talk about that some

more. But as we've seen, it's not all one unit.


Watterson --

MR. WATTERSON: Yes?

CHAIRPERSON ROSS: I think the

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147

purpose of this session is to deal with the

potential effects of the project rather than with

the sufficiency of the EIS. So when you get to

the potential effects that you talk about,

emphasizing those would be really helpful to the

Panel. Telling us that something is not

sufficient is, you know --

MR. WATTERSON: Okay, well, let

me just -- thank you for that comment. What I'm

saying -- the point of all this is that what the

Proponent has said about the professional -- about

the potential effects is based on incomplete

science.

CHAIRPERSON ROSS: We hope that

you will enlighten us as to how we can do a better

job based on your input. Thank you very much.

MR. WATTERSON: Okay.

Okay. So another problem with

the EIS, again which leads to their effects

predictions being off, is they did not use

available data. For example, there is a lot of

back and forth in the IRs about using the 1994

aquifer test data and they decided that they

didn't want to use it.

And it was -- unfortunately, it

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148

was the only aquifer test for the entire project.

There is data from the geologic committee --

geology and drilling data from many logs were not

used and other available data were not used such

as information about the faults and the

gypsum-lined bedrock.

This slide shows on the top

left, you may recall from the IRs the aquifer test

data in question where they say because of the

irregularities in the water levels, this data are

suspect and therefore we can't use it.

On the bottom left is a

basically a textbook computer-generated model of a

typical drawdown and recovery curve. You can see

the water level drops down quickly and continues

to decline. The pump is shut off and the water

level comes back up to static.

Over here are water levels from

the three observation wells that were used during

these pump tests. As you can see, the water

levels decline nicely. The pump is shut off and

the water levels return.

In a hydro geologic analysis

there is no difference between doing a test --

testing the data from the pumping well or testing

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149

the data from the observation wells. And so by

not using this data, they were missing an avenue.

This table shows the results of

the tests, and I know it's hard to read. From the

observation well, there's two tests. On the top

and the drawdown test, the first two -- the first

two -- the first two show the drawdown data, the

sections. Below this are the recovery data

analyzed very well -- various wells -- various

ways.

What's important to know this

in the permeability column is how similar these

numbers are. They are almost unique over two

different tests and multiple wells.

One of the key features of

doing a proper job of analyzing hydro geologic

data is its consistency and its reliability and

repeatability. This shows that the test data from

the observation wells is perfectly good and

perfectly reliable. You couldn't ask for better

data than this.

Another source of data that

they didn't use as has been talked about, this is

an older figure that shows the faults. It shows

the faults that go through the proposed mine area

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150

better than some of the newer figures. The key

issue in this is there is a significant

discrepancy between the fault data used in the

Knight Piesold geotechnical analysis and the Bruce

geotechnical analysis.

The Knight Piesold data as part

of their open pit modelling, their report says:

"We expect significant groundwater flow

from the two faults that extend through

this proposed open pit, and, therefore,

we have a lot of dewatering plans that

we need to make."

The Bruce geotechnical report

says, we don't see any reason for including

groundwater flow through the defaults, so we're

going to just not include that in our analysis.

So I'm not sure how those two

different 180-degree viewpoints can be reconciled.

So the next thing was the

oversimplified hydro geology used for the

modelling and effects analysis. And again as

described in detail between the various IRs and in

the hydro geology report, Bruce Geotechnical used

the packer and slug tests instead of available

aquifer test data.

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Unfortunately, using the packer

and slug tests alone, they have significant

limitations when they are doing hydro geologic

characterization. They can't be used to predict

groundwater flow over large distances over long

times. They can't be used to understand the

interconnections between different units. They

can't be used to show aquifer barriers or recharge

boundaries, and they don't provide unit

storativity characteristics, which is one of the

key factors to understanding aquifer and

groundwater behavior.

They took the highly complex

hydro geology and hydro geology of the area and

lumped them into 4 units for Bruce Geotechnical

and -- or 5 units for Knight Piesold.

So for all of the models, all

the overburden which often included basalt was

combined into one unit called till. There's a lot

of different ways of classifying this material.

Some figures show 5 units. Other figures show 10

units. It's very confusing about what exactly

they are talking about.

However, what you find when you

look at the data around the TSF -- and this is

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152

what Dr. Desbarats looked at -- is that the

average hydraulic conductivity for those materials

is about one times 10 to the eighth -- 10 to the

minus 4 centimetres a second, and the range

between 3 to 55 metres.

The conductivity used in the

model for the upper 100 metres of overburden

basalt is 1 or 5 depending upon Bruce Geotechnical

or Knight Piesold, times 10 to the minus 6

centimetres a second, which is two orders of

magnitude lower. That's a big difference.

This is just a quick table to

show these are the wells around the TSF; the

conductivity as measured by their testing; the

depth interval and the rocks. And, I don't know,

you probably maybe can tell on your handout in

here these are all very consistent numbers with a

mean of 1.8 times 10 to the minus 4.

And so what that means is that

between the mean of these data for test around the

TSF and the conductivity of the aquifer test are

very similar. They are consistent.

This is a couple of slides

really quick that shows some of the old wells that

show these high conductivities. These is a scale

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153

of 10 to the minus 3, 10 to the mines 4, 10 to the

minus 5 and these lines here show the intervals

over which the test is conducted. And these are

just a couple of wells in the TSF vicinity.

So you can see there's a

significant thickness here that was tested that

show a high conductivity and over here there is

another one. This is just a typical example of

the data that was available.

So they took the complex hydro

geology in this area and they lumped it down in

this case to three units and, again, showing --

this slide shows the significant distance between

the units, the extrapolation.

This slide shows that there's

possible groundwater flow pathways that are just

left unresolved. The question marks in all these

that show that we don't really know what's going

on between them. Again, the point of this part of

the presentation is they took very complex hydro

geology and lumped it down into really an

oversimplified conceptual model.

Here's another cross section

east/west. Here's the proposed -- top of the

proposed tailings facility. Here are some bore

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154

holes. You can -- to scale this is quite a long

distance.

This is the Taseko River Valley

down here. The springs are down there, and you

can see not only the question marks, not only the

extrapolated geology stratigraphy, but -- in this

particular cross section there's seven units. I'm

not sure what that -- how these relate to the

three or four that they used. Here's the fault

that was talked about, runs right through this

well, right there, between where the TSF is and

the seeps and springs. And, again, the point of

this is there is lot of data available that they

did not use.

You've seen this. This is

the -- that's Dr. Desbarats showed the other day.

This is the log for the well that was tested.

There is sand and gravel aquifers, there's

fractured basalt aquifers, there is an artesian

aquifer way down here at the bottom. This is the

reality of the stratigraphy in the Fish Lake and

TSF area. Not this. Not that. Or that.

This is just not right. This

is another old cross section through three wells

between -- four wells between Fish Lake, here's

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155

the open pit. And these look pretty good to me.

You could make some pretty good projections of

where sand and gravel and groundwater flow

pathways are. I don't know why this wasn't done

before.

Now moving on to the inadequate

modelling and sensitivity analysis. As I just

demonstrated, the modelling is based on the

oversimplified hydro stratigraphic units, and the

non-conservative estimates of conductivity.

One of the consequences of not

having enough data to adequately characterize the

site conditions is they used a model called

MODFLOW to model their -- to model the groundwater

flow and seepage effects. MODFLOW is the standard

method for doing this. However, there are some

significant limitations with MODFLOW that should

have been acknowledged and discussed in their

report. The biggest one is that MODFLOW is

designed for what's called porous medium, meaning

it's meant to sand and gravel, not fractured

bedrock.

So everybody uses MODFLOW

because that's the only tool really available, but

what's missing in the report is that there's no

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discussion of -- there's no recognition of the

limitations of the model and then how the data

they have and the scenario they set up fit within

how the model works.

That is commonly and standard

done as you say, Okay this is the best I got.

Here's where it fits, here's what we're life site

(ph) fits and here's where it doesn't fit and here

is how I'm compensating for that.

The other big problem with

MODFLOW is it -- when it does its solute

predictions, it only provides average flows.

Meaning there's no way for the model to predict

flow through a preferential flow pathway. So if

you have a big fracture, MODFLOW can't pick that

up or predict flow through it.

So another problem with the

model is their use of the sensitivity analysis.

Their sensitivity analysis was based on 5 times

their mean value, half an hour of magnitude and

they used 10 times one hour of magnitude to store

activity.

And so as Dr. Desbarats

discussed yesterday, that is not based on the

observed data. The observed data has a much wider

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range and if you use the actual data, you

become -- come up with much greater predictions of

seepage flow.

It's also -- there are better

ways to develop adequate sensitivity ranges. One

way is to identify the standard deviation of the

mean, and say that's your high and low range, high

and low ends, and then pick a number in between

that you think is reasonable and justify it. Say

this is what we think is best. But your range,

your -- should be one or two standard deviations

around the mean.

This picture shows a lot of the

data that was used and as you can see, the data --

the bulk of the data ranges from around here, out

layer, to down around here. So that's one, two,

three orders of magnitude with the data pretty

evenly distributed through there.

I'm not sure how they developed

their means and how they developed their -- the

justification for only using a half an order of

magnitude for their sensitivity range. But this

is what the data shows, that there's actually a

lot of data from a lot of different areas over at

least a three order of magnitude range.

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So when you take their data and

use it in their model, this model shows the

potential seepage flow at a hundred years with no

seepage capture wells.

So as you can see that it --

it's kind of hard to see. This line right here is

the main embankment. Here's Fish Lake. After a

hundred years using their estimates of

conductivity and no seepage capture wells, they

estimate the solute is going to be basically at

the south end of the Fish Lake and down to Big

Onion Lake.

Now, you have to remember --

and this is the same problem that Dr. Desbarats

discussed the other day -- they used very low

estimates of conductivity as it was pointed out in

a really over simplistic way: The higher the K,

the higher the flow. If you use the actual data

that's from the wells that I showed on the slide,

right around the TSF, this flow is going to be

greater.

This picture shows the proposed

plume, contaminate plume with seepage capture

wells at a hundred years using their 5 times the

average -- the mean conductivity data.

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159

Using their limited sensitivity

range this shows at a hundred years a significant

flow of water down to the Taseko River -- excuse

me. A flow of solute down to the Taseko River. I

can leave it to your imagination to picture what

this flow would look like using the higher

estimates of K, developed by myself or Dr.

Desbarats.

Their model also predicts

potentially significant increases and decreases to

surface flows and groundwaters around the area.

For example, some of the predictions show base

flow to Wasp Lake increasing 20 percent during

some times and decreasing 20 percent and there's

quite a few numbers in the report. It's actually

fairly difficult to sort out exactly what it all

is.

But none of the effects that

are discussed. And I presume the biologist would

have something to say if water level in --

groundwater flow to Wasp Lake or Big Onion Lake

increased or decreased by a significant percent

every year.

The effects of the TSF solute

that I showed in my pictures are -- on groundwater

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160

quality are not discussed, at least as far as I

could find in the report. The NRCan model shows

that the seepage volumes and concentrations and

travel times are likely to be significantly

greater than predicted by the Taseko model.

And finally, and, you know,

quite importantly there is no analysis of seepage

volume, quality and flow pathways past a hundred

years. If this is what it looks like at a hundred

years, what's going to happen at 150 years or 200

years?

So the numerical model does not

accurately portray current conditions nor does it

portray current effects. They have not completed

adequate sensitivity analysis that considers the

natural variations and overburden and bedrock.

As Dr. Desbarats demonstrated

the effects based on more realistic modelling will

be substantially greater. And it's already stated

in the report but it's worth emphasizing it again

that effective seepage control will be mandatory

to prevent contamination of Fish Lake and other

downgrading receptors.

So the last thing is that they

have not -- this is, again, required in the CEAA

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161

guidelines. They've requested adequate mitigation

planning, and so in the EIS there's no

identification assessment of worst-case scenarios,

no assessment of cumulative visual impacts, no

data caps for limitations analysis, and no

contingency plans.

The seepage control measures

are conceptual only. This figure shows 10 wells

along the main embankment but those wells are

conceptual only. There's no effort put into

actually aligning those wells' locations or

designs with actual geology or hydro geology.

And, in fact, the report says they are for bedrock

only. They don't include the concept of flow

through the sand and gravel or basalt at all.

There's no information on the

seepage collective sums designs provided at all.

Is it going to collect surface seepage or

groundwater seepage? If it's groundwater seepage

and based on their model, the top a hundred metres

is till. I'm not sure how that is supposed to

work.

And then as we have had

numerous discussions, the estimates of seepage

volume and quality are based on inadequate hydro

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162

geology and modelling.

There's also this figure also

shows they don't have any seepage capture wells

below the west embankment or the south embankment.

So to answer your question,

Mr. Chairman, the point of the presentation was --

is to compare their hydro geology characterization

with their predictions of the potential effects on

Fish Lake and remaining environment. And, again,

my topic is focused on -- because it's a big

elephant in the room -- the seepage from the TSF

and they haven't been able to characterize all the

groundwater flow pathways from the TSF to

surrounding receptors. Because they haven't

studied the overburden in any detail, there

really, really is no knowledge about induced

groundwater flow and dewatering the Pit Lake.

Fish Lake. They can't really talk about the

potential pit wall instabilities and its effects

on Fish Lake.

They have developed really

inaccurate estimates of seepage volume and quality

from the TSF. They don't have any understanding

of possible solute flow pathways through all the

various mechanisms that it might lead to TSF or

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163

any of the other potential sources of

contamination.

And so what all those result in

is the potential for significant environmental

degradation downgradient of these sources.

There are some other issues

that relate to them actually being able to have a

good understanding of site conditions is the

embankment damns will require permanent dewatering

to maintain their stability.

Okay. They will need to be

permanently dewatered. So what happens 50 years

from now if those dewatering systems fail? Is

there -- we saw their extrapolations of till

thickness for beneath the TSF. Is there

sufficient till actually in the area to line the

TSF if they need it?

I know that they have done mass

balances for the amount of till available to build

the damns, but there's nothing in there available

to see if there's enough to line the TSF if they

need to.

And as Dr. Desbarats discussed

the other day, the impact of seepage to deep

groundwater is unknown. And this hydro geologic

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164

evaluation doesn't concern any -- doesn't include

any aspects of all this that need to be considered

into perpetuity.

And that concludes my

presentation.


Mr. Watterson.

First, any questions for Mr.

Watterson from the Government of Canada?

Second, any questions from

other First Nations?

Third, any questions from

group interested parties?

Fourth, any questions from

individual interested parties?

Fifth, Taseko?

MR. JONES: Thanks, Mr.

Chairman. Actually, we have a number of

questions, so I'll turn it over to Mr. Crozier.

MR. CHAIRMAN: Thank you, Mr.

Jones.

Mr. Crozier?

MR. CROZIER: Thank you,

Mr. Chairman.

Mr. Watterson, I would like to

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start out by asking what you meant by your

comment, "an almost criminally abbreviated hydro

geological assessment." And who that was --

MR. WATTERSON: No, no, no.

That's going to be corrected. It was not a

criminally-abbreviated hydro geologic assessment.

It was a criminally-abbreviated list of the CEAA

guidance requirements for this hydro geologic

assessment.

MR. CROZIER: Thank you.

MR. WATTERSON: Yeah. Yeah.

No, I wasn't saying the assessment was criminal.

I'm just saying -- I can show you. Here are the

CEAA guidelines for this.

MR. CROZIER: I'm aware of

them. Thank you.

MR. WATTERSON: Okay. There's

a lot. So that's what I was referring to.

MR. CROZIER: Sure. In the

presentations yesterday, I believe I heard Dr.

Smith say that for projects at this stage of

design, 15 to 60 monitoring wells would be the

appropriate number of wells to use for an

assessment of this type. And at the higher end of

that, the 60 wells he suggested was something that

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you would see appropriate for a terrain that had

karst in it. Not 50 to 60.

MR. WATTERSON: Then I stand --

I thought he said 50. He may have said 15. Sorry

about that.

MR. CROZIER: Okay. Given that

Dr. Smith reviewed our work and discussed the

framework under which we did our work and found it

to be standard practice and found that it gave a

reasonable assessment of where the seepage from

the tailings storage facility may end up, how

would you explain your commentary?

MR. WATTERSON: Well, without

saying anything negative about Dr. Smith, I think

that it can be answered in the very first part of

Dr. Smith's report where he said that he took the

hydro geology data as is. His review did not

include any review of the hydro geology data.

He just took the report as it

stood and based all his findings from

recommendations from there. My report starts from

the square one, the baseline hydro geology data.

So that explains why my conclusions are so

different than his.

MR. CROZIER: So that explains

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why your comments about the data and the baseline,

and we'll certainly get into that in detail, sir.

However, I'm wondering about your comments about

inadequate sensitivity analyses and studies, given

that that was also found to be reasonable in Dr.

Smith's eyes.

MR. WATTERSON: I can't speak

for why he thought that was reasonable. When I --

in this kind of work I've done before and also in

my research that I made to make sure that my

statement was correct, I found no mechanism or no

supported rationale for taking a much narrower

range in the sensitivity analyses that actually

exist in the data. Especially when the data said

as shown in the figure, are as uniformly

distributed as that particular data set.

So that's my professional

opinion, is that you do your most conservative,

which is the highest conductivity values, and you

model with the least conservative which is the

lowest conductivity values and then you find a

number in the middle that you think is most

supported by data and other factors that you think

is reasonable.

And there's -- you can either

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-- on the small data set on a small project you

can do that intuitively or using professional

judgment. On a large data set, you use more

advanced statistics.

Like I said before, taking the

mean and one or two standard deviations on each

side of the mean is your most conservative and

least conservative values. I think that's the

best way to go.

MR. CROZIER: Okay. We'll come

back to that, I think.

Perhaps you could pull up one

of your earlier figures where you were showing the

cross section across the valley.

MR. WATTERSON: That one?

MR. CROZIER: That's correct.

MR. WATTERSON: Sure.

MR. CROZIER: Or any of those

similar holes.

MR. WATTERSON: We have that

one. We got that one. Is that one better?

MR. CROZIER: They will both

serve the purpose. So there's a number of bore

holes used there, and you made the comment that

some inferences are made with question marks on

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the lines.

Were you aware that there were

geophysical surveys done along those lines to

connect those bore holes?

MR. WATTERSON: Yes, sir.

MR. CROZIER: And so that

wouldn't form a reasonable basis for extending the

interpretations along those sections?

MR. WATTERSON: Yes, where the

geophysical lines exist. I don't have -- it's

hard to see but here, these red lines show where

the geophysical lines go. There's one that goes

along the base of the main embankment with a

couple of cross pieces. There's one right there.

There's one right there. There's one along the

south embankment and one here. There are no

geophysical lines in this big area right there,

and that's what I'm referring to.

MR. CROZIER: I see, but there

seems to be a reasonable number of seismic lines

run along the embankment.

MR. WATTERSON: Right. Well --

great. That's here. That's four kilometers away

from here.

MR. CROZIER: Yesterday Dr.

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Smith was discussing where you might potentially

lose hydrodynamic containment as the locations

where he would prefer to see investigations.

In short, I believe he stated

he'd prefer to see his bore holes under the

embankments where you are proposing to cut off and

curtail seepage in those locations. How do you

explain that compared to your concerns here.

MR. WATTERSON: Well, I'm

not -- I can't comment to Dr. Smith's rationale

for why he said that. But to me, the issue is you

have a several square kilometre area without any

data, either test pit data or drilling data, and

the presumption of the hydro geology and the model

is that that till is uniform and consistent and

even there. And there's no evidence to show that.

Now, I'm not saying it's not

there. Maybe somebody has walked the site and

said, Yeah, there's till here. That certainly

didn't make it into this report.

MR. CROZIER: It wasn't

discussed in the report. However, in other

portions of the EIS, there were certainly aerial

photographic interpretations done to extend the

mapping of various surface soils, if not, indeed,

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more recent ones than the 2009 assessment.

Could you back up on your

slides a little bit? I think you show a number of

other locations within the basin that were used

there.

MR. WATTERSON: These are my

three pictures that I have that --

MR. CROZIER: No, no, sir.

Just stop there. The one with the red box. The

next one. Certainly that shows test pit and bore

hole locations. I think if you look at the

isopach map that's presented on the next slide,

you'll understand that that is just bore hole

locations --

MR. WATTERSON: No, no. You're

right. You are absolutely right. This is not

showing all the test pits but when I gave my -- I

first introduced this, I showed if you compare

this area right here with that area right there,

there are no test pits.

MR. CROZIER: I don't think

that's what I heard you say.

MR. WATTERSON: Then I

apologize.

MR. CROZIER: Thank you for

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clarifying that.

MR. WATTERSON: I was comparing

this map that shows where a till is and it's

thickness with this map that shows the data

sources.

MR. CROZIER: I guess I'm

curious as to what approaches you would use to

interpolate between data points and test pits that

you have when you're investigating areas like

this; how would you go about doing that? Because

it's a common and frequent problem encountered in

the industry for any mining project where

you're -- the bulk of your data come from the

investigation of open pits along the embankment

lines that are proposed under the plant sites and

then at certain more critical locations where

you're concerned about potential loss of

hydrodynamic containment.

That was the approach that was

followed here for the investigation of this

project and certainly there are reasonable

geological principles -- surface mapping, air flow

interpretation and others -- that are used to

extend the understanding or extrapolate from those

data.

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Are you unfamiliar with those

types of methodologies?

MR. WATTERSON: Yes, I am.

MR. CROZIER: You are

unfamiliar with --

MR. WATTERSON: No, sir. I am

familiar with them, yes. I understand how the

process works. However, again, the -- there's two

aspects to my question. The first response is

again the scale, the sale of this. This is

two-and-a-half, three kilometers. That's a long

way with no data. That's a big area with no data.

And if I were put in the position of saying, Okay,

I have to say something conclusive about this

area, I would have said, well gets go out and do

some field truthing.

It would have been -- if you

had like a data point here and data point there

and data point there and a data point there and a

data point there, they may be a half kilometre

apart which is still a huge distance in a glacial

environment you would be able to say something

about, Yeah we have some confidence in this. But

there is no data.

And again, in taking that to

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its most relevant to this discussion is that you

have six test pits for the entire PAG and no

drilling at all. How can you say what's going to

happen below the PAG area when you don't have any

data?

MR. CROZIER: We have data. We

also have air photo interpretations and soil maps

and bedrock maps and those were used to do the

extrapolation. Certainly when the air photo

interpretation was done in the 2009 environmental

impact statement, there was ground truthing done

to confirm the results of the photo

interpretation.

MR. WATTERSON: You can say

what basalt characteristics are beneath this area?

You can tell me what the basalt characteristics

are underneath that area?

MR. CROZIER: Beneath that

particular area, sir, we have no data. However,

we have an abundance of test data in the

basalts --

MR. WATTERSON: That's true --

MR. CROZIER: -- showing what

the range of hydraulic conductivity is.

MR. WATTERSON: This is the

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175

important area.

MR. CROZIER: That's the bottom

of a valley where groundwater discharges into a

stream bed, and the flow of that water is along

the access of the valley towards Fish Lake. By

understanding the way that geologic materials are

deposited in sediment (muffled) fashion and by

understanding the way the basalts tend to -- or

volcanic faults flow downgradient, you can

understand the disposition of materials and

layerings conceptually.

And then the purpose of

constructing a model would be to extend your

understanding conceptually, and test that against

the measured hydraulic head that you have in the

area. That would be the approach that would seem

reasonable to me.

MR. WATTERSON: Okay. Then

why does your model not account for this? This is

what's real. This is all lumped as till in your

unit with a conductivity two orders of magnitude

less than what it really is.

MR. CROZIER: Let's come to

that one in a moment. Let's go to the pumping

test data first. Could you go back to the test

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curve?

MR. WATTERSON: Sure.

MR. CROZIER: We'll come back

to the packer testing data that we used in a

moment.

So in the upper left corner of

the presentation is the pumping test drawdown

curve in the pumping well. Over at the right is

the drawdown curves observed in observation wells.

Down below at the bottom is a nice

computer-generated response curve, that's great.

I would like to speak for a minute about the

concerns that BGC has with the pumping test.

They were primarily focused on

the fluctuations observed in the water level in

the pumping well. That calls into question the

confidence level that we have in the pumping rate.

There are evidence of a non-steady pumping rate.

So while you may have smooth

drawdown curves observed in your monitoring wells,

you still don't have confidence in your pumping

rate.

I would like to understand how

you might be able to calculate an estimate of

hydraulic conductivity in storage without having

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confidence in the pumping rate.

Are there solutions out there

to your knowledge that you can use that don't

involve the use of pumping rate?

MR. WATTERSON: No, there are

not. However, a reasonable approach would have

calculated conductivities from this data using a

range, say, 50 to 80, and that would have given

you a range of Ks that would match what whatever

variations in pumping rate were going on here, you

could have said, well, it's not very good but

based on these nice, smooth responses, these

fluctuations certainly did not make it to these

wells, therefore I can estimate Q -- I mean K

using a reasonable range of Qs and that would be

pretty good. Not perfect, but pretty good. I

wouldn't have tossed this data.

MR. CROZIER: We didn't toss

it. We just indicated that we didn't want to use

the estimates provided by Knight Piesold for

hydraulic conductivity in storage.

Did you read our site

information request response where we in fact do

what you suggested where we looked at a different

range of probable or possible pumping rates and

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did exactly that calculation?

MR. WATTERSON: Yes, I did.

Again at the end of it we decided not to use it.

MR. CROZIER: At the end of it

we found that the ranges that we felt were most

likely lay in the same range of hydraulic

conductivity estimates from packer testing, albeit

at smaller scales in the area, and that was our

decision. We didn't discard this.


MR. CROZIER: I'm just curious

if you considered looking at a drawdown versus the

ratio of T over T prime plot.

MR. WATTERSON: No, I did no

independent hydro geology analysis of this at all.

If the raw data were available, I'm not sure that

they are, then that's something that could be done

but I did not do that.

MR. CROZIER: So if the raw

data were available, you would be comfortable

doing that?

MR. WATTERSON: I would be

comfortable doing it. I'm not quite sure why I

would.

MR. CROZIER: Okay. So if the

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raw data weren't available for you to go back and

look at the pumping test data if you had concerns

with the pumping rate, would you be comfortable

relying on that data?

MR. WATTERSON: I don't

understand your question.

MR. CROZIER: Well, the

concern -- the fundamental concern that we have

with this data set is that there is no detailed

record of the pumping rate. The only pumping rate

that we have is provided at the bottom of that

figure where it says "Constant pumping rate Q = 80

gallons per minute." That's it. There's no data

to support that.


MR. CROZIER: There's no data

to explain fluctuations in those evident in the

pumping well. Which are, for the Panel's benefit,

approximately 25 percent of the drawdown.

In ours discussions with NRCan,

we reviewed this pumping test curve and we also

presented data from similar projects and similar

sites where we did have control of the pumping

rate and what tends to happen in those situations

is when you see fluctuations like that, it's

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180

typically caused by a variation in pumping rate.

So if you've got a fluctuation

of 10 or 15 percent in your water level column,

you probably have a comparable fluctuation in your

pumping rate.

The other thing that we

discussed in that review of our data was that for

the hydraulic conductivity that's backed out in

this analysis which is 10 to the minus 4

centimetres per second -- or to more fairly

compare it to the work that we presented, 10 to

the minus 6 metres per second -- to obtain a

40-metre drawdown on a well of that size in

minutes would be unexpected. Typically what you

see for hydraulic conductivity is the order of 10

to the minus 6 is draw downs in wells like that of

3 or 4 metres -- not 40, not 60. We can --

MR. WATTERSON: I guess we can

talk hydro geology all day long. I would like to

remind the Panel that that isn't -- I think my

opinion is that there is good data here that could

be used and for whatever reason, Taseko chose not

to use it.

The problem is as shown by Dr.

Desbarats and this data, there's lots of other

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181

independent data that come to the same result.

MR. CROZIER: Let's go for a

moment to the plot that's just a little further on

or maybe it's further back that shows all of our

packer testing data.

MR. WATTERSON: I don't have

that.

MR. CROZIER: It's actually in

there. Keep going. Keep going. That one.

What's shown on this plot is

all of the packer testing data and slug test data

that we obtained from the site. Could you comment

for me on what I heard Dr. Smith say yesterday, is

that packer testing results in basalt and

fractured rock typically vary across three or four

orders of magnitude.

MR. WATTERSON: Well, that is

correct. I'm not sure the word is "typically" but

I think a better word is they "can."

MR. CROZIER: I believe I heard

Dr. Smith say yesterday that if the range of that

variation was two or three orders of magnitude,

that he would be concerned. He would say, Wait a

minute. Something funny is going on -- or

something's up. I can't recall the exact words.

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182

MR. WATTERSON: I remember he

said that. Before I go way further out on this

limb, what is your question? We have the data.

He said what he thinks. What's your question?

MR. CROZIER: My question is:

Would you consider the range of variation in

hydraulic conductivity up there to be

representative of our fractured rock median:

MR. WATTERSON: Absolutely.

MR. CROZIER: What would drive

that variation in your mind?

MR. WATTERSON: There's a

number of things that determine the conductivity

values of fractured bedrock. There's the size of

the fracture, it's in-filling, it's orientation,

if it's a sharp fracture or all busted up, how far

it extends, if it's just a local fracture or goes

quite a difference away. There's many things that

can affect that number.

MR. CROZIER: Okay. And the

reason there's many things that can affect that

number is because it's a point scale measurement

essentially.

MR. WATTERSON: No. The reason

there's many things that can affect that number is

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183

the nature of the fracture itself.

MR. CROZIER: Did you

understand what I said by point scale measurement?

MR. WATTERSON: Yes, I did.

MR. CROZIER: For the Panel's

benefit, when you are testing a shorter interval

or a longer interval of a bore hole, you are only

testing a meter, maybe two, around that interval

that's being tested. So that's a point scale

compared to a larger pumping test scale.

Upscaling point scale

measurements to the larger scale is a common issue

facing the industry. Would you agree with that

statement when we're dealing with fractured rock?

MR. WATTERSON: Is a common

issue. You mean like problem or --

MR. CROZIER: How to upscale

it. How to go above it.

MR. WATTERSON: Yes, I would

agree with that.

MR. CROZIER: You indicated

earlier you didn't understand how we had

approached the parameters that we came to.

MR. WATTERSON: I don't. What

I meant was I don't understand how you -- the

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184

rationale for why you chose only a half an order

of magnitude for your sensitivity analysis when

the data clearly show a nice distribution of at

least three, maybe four.

I mean, there's no pattern,

there's no -- other than this gradually decreasing

conductivities with death, this looks pretty much

like it could draw a line right here and a line

right there and say that's your realistic range.

What I don't understand is how you selected only a

half an order of magnitude to do your sensitivity

analysis.

MR. CROZIER: You indicated

perhaps we should take the standard deviation of

the mean.

MR. WATTERSON: Around the

mean -- that depending on the sensitivity and the

hydro geology, some do two standard deviations

which would probably give you all the way out here

and all the way down there. But certainly the

standard deviation around the mean.

MR. CROZIER: So we calculated

a geometric mean, that was our approach.

MR. WATTERSON: Right. And

then I would say your -- and that's the point.

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185

The upper range of your sensitivity, the least

conservative would be the bottom end of the range,

the bottom standard deviation, and the most

conservative would be the high end, one standard

deviation on this side. That's what I would

expect.

MR. CROZIER: That's one

methodology, sir.

MR. WATTERSON: Yes.

MR. CROZIER: There are others.

The methodology we then used was to take that

geometric mean for the materials that we had in

our model, which incidentally were 5 units, not 4.

MR. WATTERSON: Sorry.

MR. CROZIER: And adjust them

until we were able to match the hydraulic head

measurements that we had for the system.

MR. WATTERSON: Okay. Yes. I

may be old-fashioned, but I'm a firm believer in

using real data rather than trying to take a

amalgamation of data and using mathematics to fit

something else.

As Dr. Desbarats demonstrated

using these conductivities which are the real

characteristics of the rock around the TSF, he

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186

measured certain flows. It's not extrapolated to

the wider scale model. It's not based on heads

anywhere else. I think you should have run your

model using real numbers.

MR. CROZIER: I would like to

jump in there just for a second and state I

believe Dr. Desbarats calculated an arithmetic

mean and a harmonic mean at the geometric mean and

used those values to estimate his parameters.

So he did a similar approach to

us whereby he calculated a mean of the data set

and applied it in his modelling. I fail to see --

or could you perhaps explain to me how we are not

doing the same approach; how we are not working

with the real data if you accept that approach by

Dr. Desbarats.

MR. WATTERSON: My issue with

the work that you did was -- is -- boils around

taking the data and calibrating it to head values

around the project area and then adjusting the

conductivity so your result the models fit the

head data and by doing so lowering your

conductivity by two orders of magnitude below what

they really are.

Your model is fine for a

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187

project area model. That's not a problem. The

problem is and the problem that Dr. Desbarats had

is when you tyke that model and shrink it down to

the level of size of the TSF and use the volumes

that are around the TSF, your model significantly

under predicts the flows.

MR. CROZIER: Certainly you

have provided an interesting range of some of the

data around the tailings storage facility that are

available on that table. It's not all of the

data.

But let's back up for a second

because I think you just told me that you didn't

agree with the approach of taking a data set,

developing a conceptual model, and putting that

model into a numerical representation and then

calibrating it to observed heads. I think what I

heard you say there was that you don't agree with

the industry-standard practice for model

calibration. How would you address that?

MR. WATTERSON: No. You're

leaving out the second part of the statement. I

said I don't agree with that approach when it

results in a number that is significantly lower

than the real numbers. These are the rocks that

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the seepage will be passing through. That's what

I disagree with.

MR. CROZIER: That's one subset

of the data. That's your hand-picked look at the

data around the tailing storage facility.

MR. WATTERSON: That's off of

these.

MR. CROZIER: That's correct.

That's where the data in our plot that you had up

earlier came from as well. That shows the real

distribution of data, it's not a subset.

MR. WATTERSON: No. This is

the subset around the TSF. It's not all of the

data. It's not --

MR. CROZIER: Thank you. It's

not all of the data.

MR. WATTERSON: No. It's not

all of the data. This is around the TSF. These

are the rocks that the seepage will flow through.

MR. CROZIER: It's not even

all of the test results.

MR. WATTERSON: It was on your

logs. It was on the data I have. These wells

right here.

MR. CROZIER: You don't have

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the 2009 data on there?

MR. WATTERSON: This is what is

in your 2012 report and it says very specifically,

"The wells and bore holes based on Figure 3-1 are

what was used in this analysis." This is the

figure. Very specifically. They got the report,

and we can find that quote.

MR. CROZIER: The data that

were used included on our part the data from the

2011 --

MR. WATTERSON: Well, then I --

sorry.

MR. CROZIER: You missed that?

MR. WATTERSON: It didn't say

that in the report. It's very specific - the

wells on this figure -- and in fact -- and in fact

there is a whole lack of wells and data points

that you didn't use. Shall I list them: 92-20,

92-21, 92-22. There's a lot that you didn't use.

So my point is -- again, and that's part of my

discussion that there was a lot of data that were

available that weren't used for whatever reason.

MR. CROZIER: You're referring

to the bedrock logs that we didn't include in the

report?

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MR. WATTERSON: I don't know.

It doesn't say. It says, we don't include these.

We're not using these wells.

MR. CROZIER: No, it said we're

not using those wells. It said that we didn't

have the logs for them and --

MR. WATTERSON: That's another

set. That's a whole other set. I could read

those off also.

CHAIRPERSON ROSS: I'm thinking

that the merit for the Panel of continuing this

discussion diminishing, so if we could get to a

quick conclusion that would be helpful. I'm not

sure exactly how best to encourage it, but I'm

hoping this will do the job.

MR. JONES: Mr. Chairman, I

think we have so many concerns with what's been

presented that we could go on for quite a while,

and perhaps that's not of any added value to the

Panel. So maybe our best approach should be, in

the interest of time, to just deal with this in

closing.

MR. GUSTAFSON: Perhaps this

might be an opportune for a short break that will

allow us to consolidate our remaining questions

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and we can come back and hopefully wrap it up

efficiently.

CHAIRPERSON ROSS: So be it.

15 minutes.

--- Recessed at 3:00 p.m.

--- Resumed at 3:15 p.m.

CHAIRPERSON ROSS: Ladies and

gentlemen, I think we're about ready to proceed.

Taseko, can you help us to

proceed now?

MR. JONES: I think one last

question.

MR. CROZIER: I believe I heard

you say that you were concerned that there was a

lack of a following the effects assessment that

was conducted.

MR. WATTERSON: That is

correct. I found no significant discussion of

effects in the hydro geology report and there was

no reference to effects in the hydro geology

report where I could find it in another part of

the document.

MR. CROZIER: I see. Were you

aware that the results of the hydro geological

modelling were carried into, for example, the

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water balance model and the water quality, effects

prediction model?

MR. WATTERSON: Yes, but --

yes, I figured that out after looking for it, but

I could not find any clear statement that says the

groundwater -- the effects from groundwater

seepage on Big Onion Lake will be this.

MR. CROZIER: But you did find

an effects assessment about what was going on in

Fish Lake in terms of water quality?

MR. WATTERSON: Yes and no.

Again, I could not find any clear, clear

discussion that linked the results in the impacts

analysis with the water quality in Fish Lake.

Now, I have -- since I wrote

this, I have found that there are some data tables

that show that and -- but with respect to the

bigger picture, which is the meeting the

objectives of the 2012 -- yeah, CEAA guidance, I

found no clear discussion of there's going to be

this much groundwater seepage, it's going to go

here and have these effects.

MR. CROZIER: Thank you, I

think we'll just leave it there for now and come

back to some of these things at closing.

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CHAIRPERSON ROSS: Nothing else

from Taseko? Thank you.

From the Panel point of view,

I'll ask if my colleagues any questions at this

time?

MR. KUPFER: Thank you. Very

enlighten exchange and discussion.

MR. SMYTH: I have no

questions.

CHAIRPERSON ROSS: The first

observation I would make is that I guess by the

end of the discussion about bore holes, we had

been saturated, but the discussion about them was

really quite helpful, and, as were the other

questions, exchange.

I have only one question, and

it relates earlier to your comment about seepage

flows in areas where there were faults. And you

indicated that -- I'm not entirely sure I followed

you. You indicated that the existence of faults

didn't seem to be used to predict the flows or

something like that. So could you help me a

little bit with that? And I've got a follow-up.

MR. WATTERSON: Yes, I can.

There's a couple parts. The first part is there's

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a fairly significant disconnect between the

conceptual behavior of groundwater flow and faults

in the area between the Knight Piesold analysis

and the open pit and Bruce geological analysis for

the larger project area, hydro geology.

The Knight Piesold analysis

very clearly states that there are faults that are

going to intersect the open pit, and we'll have to

take active dewatering measures in order to

prevent that water in-flow from affecting the pit

stability and all those geochemical things.

So their position is initially

discussed in the very beginning of the reports

back through the nineties and continued up to the

present day, is that faults in the area are water

bearing and they product significant enough flows

that it has to be managed.

CHAIRPERSON ROSS: My question

is: In your opinion, what take home message

should we take about those flows?

MR. WATTERSON: Well, my first,

my first was that between that concept that the

faults are water bearing and then the Bruce

geotechnical says no the faults are not water

bearing and they have no effect on groundwater

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flow is that -- the first take home message this

is a major disconnect which significantly

undermines the credibility of the analysis of the

area for getting groundwater flows pathways,

bottom line.

So now if we take that with the

-- with that paper and the discussion by Dr.

Eberhardt about how significant the flows are, the

potential for faults for groundwater flow

pathways, that I think just emphasizes that, that

the flows could be a significant flow pathway, but

we don't know because they haven't looked.

Again, if you look at the

figure it's right there in the cross section going

right through the well, right beneath -- and west

tailings wall. I don't know if it is a

significant flow pathway or not, but the tailings

are going to be right (ph) gradient of the

springs. So that's the take home message.

CHAIRPERSON ROSS: All right.

Thank you, Mr. Watterson, Mr. Pearse. We'll move

along now. Thank you very much.

MR. WATTERSON: Thank you.

CHAIRPERSON ROSS: The next

speaker we have is Bill Lloyd of the

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Cariboo-Tsilhqot'in Conservation Society.

PRESENTATION BY BILL LLOYD:

MR. LLOYD: Thank you, Panel,

for allowing us the voice here.

I apologize for my nervousness,

but I've never done this before. Might have to

bear with me a little bit.

My name is Bill Lloyd. I'm

addressing you on behalf of the Cariboo-Chilcotin

Conservation Society. As a director, I've agreed

to address mining and other watershed issues on

their behalf. I've got a work history in the

mining industry and a bit of mining education

which kind of gave me the short straw to get that

portfolio, I suppose.

But at the same time when we

make this presentation -- I know this is a

technical hearing and I want to make it brief and

I want to make it from a layman's point of view in

the sense that we aren't experts but we are

concerned about the long term effects of this

project.

That perhaps from our point of

view we could help the Panel look at a couple of

small issues regarding end-of-mine life.

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As far as the Cariboo-Chilcotin

Conservation Society, we're a volunteer, small

group. Most of us have lived and worked -- most

of the board of directors has lived and worked in

this town for many years. And in my case, my

grandchildren go to school here and they are the

fifth generation of my family that's worked here.

Our mandate, I guess if you

could call it that, is to deal with resource

issues from a sustainable and environmental

responsible perspective rather than an

election-to-election perspective. So we look at

this project on the long term, not the 20 years of

mine life.

So what I would like to do is

to look at a couple issues that concern us as far

as the end-of-mine life plan is concerned.

Perhaps the first thing I

should get into is an observation -- maybe I

should start off by saying the two issues we're

going to look at are the fault structure effect on

the end-of-mine life plan that runs through the

pit, and a brief look at the end-of-mine life plan

proposed by Taseko.

I believe the Panel has been to

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the site, is that correct? When you observe Fish

Lake you probably noticed that it goes through a

narrow canyon that exits to the river and -- you

know, I'm sure you realize that that creek did not

make that cut through there. Not being a

geologist, but I would assume that is some kind of

a fault structure that it runs through.

If you observe that creek at

low flow periods it's quite obvious that the upper

upper reaches of the creek will have a

considerable amount of water in them, and when you

get to the bottom where it reaches the valley

floor it goes -- it's quite reduced.

Last year in October that

particular creek was dry at the bridge on the

Taseko Road. So I think that maybe those physical

characteristics that we see there are telling us

something which might be of value when we look at

the fault structure of this -- that's running

through the pit. I mean, we know that the pit is

in a fault zone, it's delineated or paralleled on

two sides by the Yellicon fault and the Fish Lake

fault. We have two major faults going through the

pit.

When the pit is excavated those

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fault zones are going to be exposed for thousands

of metres and up one side and down the other to

the bottom of the pit wall.

As we learned from Dr. Smith

and Dr. Eberhardt, those fault structures can act

as conduits, or act as barriers. And further to

the discussion in the previous two days we

obviously don't know which they are and what

particular location, and that's the nature of

faults, as we all know.

But at the same token we could

have a water wearing structure on this side. We

had like a positive conductive zone in the fault.

On that side we could have a negative conductive

-- maybe an exit for that same water, right (ph).

So when you fill the pit up and

you've got that exposed for so long and so much of

that fault exposed, obviously as the pit fills up

you got hydraulic pressure into those fall zones.

Now, I realize that nobody has

any way of knowing what's going to happen there,

even the Proponent, and I don't think there is any

way of probably mitigating that issue. But it's

just an issue that I've spent many hours in the

EIS and quite a bit of time on the ground up

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200

there.

It's not an issue that was

really dealt with properly, I don't think, in the

EIS in the sense it's not really brought to

anybody's attention.

Our concern is that as the pit

fills up, and the pit ultimately is a couple

hundred metres below the river, there is a

likelihood -- not a likelihood, but there's a

possibility that the pit could fill up to a static

level above the river, and if it has enough exit

water through those fault zones we have an acid

rock drainage situation from the pit walls and no

way of --

CHAIRPERSON ROSS: Could you

speak closer to the microphone, please?

MR. LLOYD: Sorry.

I think that is a concern -- I

don't think it's (muffled) because I've worked

underground where we've had water entry through

faults and have tried to repair it through shot

crete (ph) and hydraulic grouting and it's not an

exact science.

When you look at the way a pit

is developed, I'm not aware of any way that that

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201

can be dealt with in a proper manner as you kind

of -- because there's no way of knowing what parts

of that fault are going to be water bearing or

water -- exit level or -- points until you start

to fill the pit up.

This is one concern we have.

And I guess if we say that those fears are

unfounded completely and we -- the pit does fill

up, then we have to look at Taseko's end-of-pit

life proposal which says that due to -- well,

simplification I guess.

Basically what they are saying

is they are hopeful that this pit will, due to

heavy metal deposition and zonal layering, will

fill up and -- zonal layer activity, you might

say, until the poor water at -- sorry, the

overflow at the end when it does get 47 years or

whatever, when it does fill up, is going to be,

you know, ready for the receiving environment,

which is the Taseko River.

They say in their report that

they have -- water treatment is a contingency

plan.

Well, you know, we're involved

with Gibraltar on their discharge to the Fraser

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202

River and whatnot. Right at the moment Gibraltar

Mines has a pit similar to this that's filled to

capacity, and they are going to dewater that pit

so they can continue mining.

And that pit, the effluent in

that pit is very toxic and it's going to require

major water treatment plant to deal with it at the

cost of many millions of dollars.

If we looked at what was

presented today and how this pit ranks as far as

-- which we didn't get a clear picture -- as far

acid rock drainage is concerned, it would be kind

of a stretch to think that we're not faced with

somewhat similar situation at Taseko Mines or at

Prosperity.

So if we look at the

end-of-mine life plan, if we have to put -- if a

water treatment plant is going to have to be

installed, the power line, that's going to be your

-- 47, which obviously this is not an exact

science. But whenever it happens, and water

treatment plant is put in. I notice in the EIS

that the power line is de-commissioned in the year

24.

We already have dewatering

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203

wells and monitoring wells around the TSF and

perhaps around Fish Lake that are supposedly going

to go on in perpetuity. All of a sudden we have

treatment plant at the pit rim that possibly has

to go on in perpetuity, and maybe water treatment

on the rest of the site.

We're kind of looking at the

hundred-year program here and thinking, you know,

we wonder about the consequences of this on the

long term. How is it going to affect our

grandchildren, great grandchildren and so on.

What I'm trying to say is our

basic perspective here is that this -- when you

look at the economic gain for 25 years, or

whatever, our position would be that is it worth

the risk?

And this is just two things

that we could point out. We obviously have made

written submissions to your folks, and, you know,

we have a lot of other concerns. But I was just

trying to keep this brief and trying to keep it

within the aspects of this particular forum. So

thank you very much.


Mr. Lloyd, for your presentation. And on a

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Saturday we're always pleased when people keep it

brief.

First, questions from

Government of Canada? Second, questions from

First Nations interested parties? Third,

questions from group interested parties? Fourth,

questions from individual interested parties?

Fifth, Taseko any questions?

MR. JONES: No questions

Mr. Chairman. I've got to say personally after

two days of technical stuff, it's nice to here a

layman's approach.

CHAIRPERSON ROSS: Panel

members, do we have any questions? George?

MR. KUPFER: One could say you

must have been very successful, everybody is still

listening and smiling so you did an effective job

for your first performance. Thank you. You

raised two important issues and they deserve to be

on the table. Thank you.

MR. SMYTH: I've got no

questions. Thank you.

CHAIRPERSON ROSS: Mr. Lloyd,

thank you very much for your presentation.

The next step in the process is

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205

to ask Taseko to reply to presentations that have

been made during this session. And so turn it

over to you folks.

CHAIRPERSON ROSS: We need to

make the slides work. Jason and/or Liv?

MR. JONES: We do have a

closing remarks primarily around pit stability,

TSF seepage and maintaining Fish Lake water level.

But I think there's also a few clarifying things

that may be of value to the Panel. So there was a

couple things we got thrown in here, but I think

we'll just start with Mr. Crozier talking about

TSF seepage.

MR. CROZIER: Mr. Chairman,

members of the Panel, everybody else. Thank you.

I think we've heard a lot about

seepage over the last couple of days, seepage

modelling, pumping tests, tills and basalts and

hydraulic conductivities, the values of hydraulic

conductivities for tills and basalts.

We've heard from the Panel

expert Dr. Leslie Smith, Dr. Eberhardt. We've

heard from the NRCan expert, Dr. Desbarats. We've

heard from Mr. Dan Watterson.

There's been a lot of very

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206

detailed discussion, and some conflicting opinions

have certainly been offered about which model to

believe, which seepage rates are appropriate for

use as the basis for the environmental impact

assessment. And I thought it would be useful to

clarify some of the matters that have come up over

the past couple of days in terms of the approach

taken by the Proponent.

So it looks like up at the left

there our slide is a little bit cut off on the

projector. On the left of the figure is a

schematic representation of the seepage rates used

in the EIS by the Proponent.

Schematically, if you look at

the central figure under the NRCan heading, the

tailings storage facility would be represented by

the square box, the main embankment would be the

triangle to the left and the triangle to the left

would capture the south and west embankments of

the facility, just schematically.

So the Taseko approach was to

use the results from two models to evaluate

seepage. The 2-D seepage modelling results from

Knight Piesold, the TSF designers that have

significant worldwide tailings dam experience that

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207

stretches back more than 70 years. The results

they calculated were used to evaluate the

potential seepage through the tailings embankment

and shallow foundation.

So, with reference to that

figure on the left, the two arrows that exit

through the sides to the top box and the triangle

-- the one that exits through the sides of the top

box and trying -- one that exists down through the

corner, and under the triangle stating 28 litres

per second. Taseko estimate for seepage that

would pass through and under the shallow

foundation of the main embankment.

And, similarly, on the other

side of the diagram, which is the combined seepage

through the south and west embankments. The

parameters used in this assessment were based on

testing results from underneath the tailings

storage facility to represent the foundation

conditions specific to the foundation of these

embankments. That follows standard design

practice in the industry for larger earth fill

embankments.

The total value carried forward

through embankments in the shallow foundation was

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208

55 litres per second into the environmental impact

statement.

For those of you new to

geotechnical design practice for large

earth-filled embankments, seepage through the

embankment is expected and design for this

includes completing the two-dimensional seepage

analyses.

Parameter selection is

generally conservative to allow for adequate

design and sizing of the filters used to collect

the seepage that may pass through main embankment

and drain it to seepage collection ponds.

However, as Dr. Desbarats

pointed out yesterday, the 2-D seepage modelling

does not allow seepage below 200 metres.

Basically there's no-flow boundary in that model

that's used. Nor does it provide an assessment of

potential migration pathways from the facility.

The limitations of this

two-dimensional assessment were addressed using

the 3-D modelling results. An estimate of 15

metres per second was used to design -- the design

case based on the out flow from the tailings

basin, that's the 15 litres per second shown in

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209

the bottom.

In terms of the water that then

reports from that 15 litres per second to the deep

groundwater zone, the estimate is 13-and-a-half

litres per second.

So the combined total estimate

from Taseko carried into the EIS was 70 litres per

second.

We heard yesterday NRCan

suggest that these results be disregarded.

I would like to talk a little

it about the NRCan model now. The NRCan seepage

model prevents flow through the embankments by

virtue of the way it sets up its boundary

conditions.

We know that's not the case in

reality but it is a conservative way of looking at

the amount of foundation seepage that you might

get. By setting your embankments as no flow

boundaries you effectively drive all of the

seepage that could occur at that facility down

into the foundation.

The NRCan estimate, based on

their base case of seepage from the tailings into

the shallow groundwater zone is a hundred litres

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210

per second for their base case.

I believe if you look at the

bottom, I've converted the 7,000 to 10,000 metres

cube per day that NRCan recommends be considered

for seepage into the shallow foundation into the

litres per second, that range is 81 to 116 litres

per second.

The asterisk there showing 65

litres per second, that's the estimate that you

get when you convert the results from the recharge

boundary condition that Dr. Desbarats has put

together, which compares favourably to the 70

litres per second that was used by Taseko.

The NRCan model also had a look

at how much seepage might pass under the

foundation of the main embankment. Their estimate

is 59 litres per second for their base case, and

the combined seepage under the south and west

embankments is 30 litres per second.

Their assessment of the amount

of water that would report to the deep groundwater

zones is 20 litres per second.

So we heard a little bit

yesterday about how the Taseko estimates were out

by an order of magnitude, 10 times, 11 times.

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When you look at these in larger numbers, that is

simply not the case. The combined estimate

carried forward by Taseko is 70 litres per second.

That's a NRCan recommendation, 81 to 116 litres

per second.

We heard Dr. Smith yesterday

say, or recommend, that for your consideration we

will -- or foundation seepage should be bracketed

at 20 to 100 litres per second.

And when asked where he felt

the real seepage value would be, he felt it would

be towards the upper end of that rage. When you

look at both the Taseko and NRCan values they are

both towards the upper end of that range.

In terms of hydro geological

seepage rates, a factor of two or less agreement

(ph) is really quite good between modelling

outputs.

We heard from Dr. Smith

yesterday. There are sound bases for the

parameters used in all the models given, the

purposes of the modelling stated by each of the

modelers, and that based on his review of the work

completed today, that the modelling approach used

was reasonable for understanding where seepage

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might -- where it might migrate to.

Couple of questions yesterday

about design practice, and what you do in ARD

areas.

Tailings and potentially acid

generating materials will be stored within the

tailings storage facility, consistent with

reasonable and prudent design practice with

construct and operation of the TSF, a monitor and

interception system is included in the design

should it be necessary.

We also heard from Dr. Smith

that a well-conceived optimized monitoring

interception well system could achieve a

interception efficiency at 80 to 90 percent using

wells, and potentially higher with optimize

seepage collection pond locations.

The value used by Taseko for

estimating seepage efficiency for interceptions

wells is 60 percent. We heard that that was

conservative. That value is based on practical

experience working in the contaminated sites,

industry that that BGC has gained and that I've a

acquired personally over the last 15 years of my

practice.

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The value for 60 percent was

used to account for the fact that you are not

going to be able to identify all the seepage

paths, should they occur right away. It's going

to take time and it's going to take an adaptive

management approach, that we also heard from Dr.

Smyth as being a reasonable approach. If you can

commit to it, you can get higher interception

recovery values.

That's about all I wanted to

say and the seepage. Thee's a couple of other

points of clarification that I thought might be

helpful.

The Panel asked Dr. Eberhardt

yesterday what the effect would be of excavating

sands and basalts with the till from the open pit,

homogenizing that mix of materials and using it in

the core zone of the dams.

Dr. Eberhardt suggested that

it's the overall hydraulic conductivity would

likely approach that of the till. And while I

agree with that assessment, I think that's a

pretty good guess on his part.

Fundamentally, you would never

do that to construct a core zone. The materials

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that would placed in a score zone would be

selectively borrowed and they would be placed in

a core zone which specific design specifications

controlling the particle relation, the percent

fines content, the compactive effort that would be

used to compact that material in place to achieve

a certain density.

And there would be limits on

maximum particle size. There would be limits on

what kind of compaction -- percent compaction you

need to achieve. All of this is standard

geochemical design in construction practice, and

it's used to achieve low hydraulic conductivity

core materials placed in the dams. There's real

precedent for this all over the place. It's done

every day.

So you would never borrow

basalt and sand and till and place that in your

core zone. You would selectively excavate to get

the material (muffled) that you need to achieve

the results that you want.

We've already heard some

concerns raised about data density and how you

extrapolate between things. That came up earlier

today.

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Dr. Smith, when asked by

Mr. Tony Pearse, indicated that an acceptable

basis for EA assessment would likely range from 15

to 60 locations. We also heard from Dr. Smith

that he would prefer the locations of these wells

along the embankment, alignments and around the

perimeter of the mine facility for the New

Prosperity project.

There are in the order of 30

wells in exist currently at the site and over 60

head targets were used to calibrate the model. So

I think we're in the middle towards higher end of

the range that Dr. Smith would consider

appropriate.

I'm going to turn it over to

Scott for addition comment.

MR. JONES: I was asking going

to turn it over to Mr. McManus.

MR. MCMANUS: There was a lot

of discussion about how is this going to be paid

for, what's the liability going to be if the mine

goes down early, do the taxpayers pick up this

cost, what's the property estimated.

And I saw the letter that

Livain sent to the Ministry Of Mines -- and thank

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you very much for doing that. That means that

they are going to clarify the law, and I don't

have to attempt that.

That said, I think one of the

things that people seem to be missing is when we

say that it cost $300 million to do this different

plan. It is quite a different plan. It's not

just moving the tailings. We also take into

account the additional rigor which is required

when making sure the seepage flows from the

tailings foundation, are captured very well. We

don't know exactly what it's going to be but we

take that into account.

We take into account the

collection system, seepage ponds, the pumping, the

fact that that pumping is probably going to need

to be there for long time. I don't know about in

perpetuity. That's a really long time.

So we take our best estimate of

what the whole site would look like over time. A

lot of that cost is in extra mining equipment to

move the rock that extra two-and-a-half kilometres

up to the dam; plus there's also pump systems and

everything required to move the tailings.

Whether or not there's a

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treatment system -- there is collection. So all

of that collection infracture would be include, or

is included in our extra cost, the $300 million.

We do consider that and we've

said we consider that there's going to be perhaps

treatment that is treated as a sensitivity

analysis.

So we look at -- that would be

an additional operating cost if the treatment

facility has to go in. It also would be

considered as part of the bonding, reclamation

bonding. Clarification from the province on that,

how that works.

Somebody said in here today

that that is kind of a double. We have to pay for

it plus we have to have a bond for it, and that's

true. We are not real pleased about that all the

time but that is the way it works.

So I presented on opening day a

comparison of the 2007 -- what the economics were

like at that time and what the economics were like

in 2010 when we reconsidered whether to resubmit

an environmental assessment on the New Prosperity

project which preserved the lake where it is.

That new assessment, that new

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economic assessment included all of those other

parameters, plus another sensitivity analysis,

plus that program, because of the other changes in

the world such as long term price of copper and

gold, foreign exchange, increase of materials and

commodities that we have to buy as well as what we

can sell. The New Prosperity project, just

because of all the exchanges together, is more

robust than it was as Prosperity.

A little bit -- and I think the

Ministry will confirm this on how bonding works

and I am an expert in this. I've been doing it

for 30 years now. I've been actually -- I was the

manager at Walmis (ph) for the last six years.

Big coal mine in British Columbia. And took it

through to closure. The closure plants I'm very

aware of what closure costs. A cole mine is a

little bit different than this, but thee's a

number of components you are reclamation.

So your disturbed area needs to

be taken back to a capability which is equal to or

comparable to prior-to-mine life. There's

demolition. You have to remove all of the

structure, infrastructure. There's capital cost

of infrastructure which you have to put in place,

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and things such as water treatment. We didn't

need that a Walmis, but we knew that that was

something we had to look at, make a contingency

for that.

Then there's long term

operations. And whether you have a treatment

plant or not, you have long term operations of

monitoring and continuing to maintain the site in

a condition that it does not effect the

environment, that's part of the permit.

In British Columbia when you

write your first mining application you have to

put in a closure plan. So closures planned from

the beginning. And the bonding is set -- get more

clarification on this again -- by the chief mines

inspector. Under the Minings Act.

And those funds are held in

place, and what I was referring to, or what the

EIS was referring to when we talk about the

release of those bond amounts is I think it's

section 10-6, 14 and 15 of the code, which says:

"Upon closure of the mine as the

company, as the Proponent or the

bondholder complete certain sections --"

so you are bonded for reclamation. You complete

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the reclamation. The Ministry comes and looks and

says you've met your obligations they released

that part of the bond.

In the case of a treatment

plant, and we have this situation at Gibraltar.

Part of our bond is for the construction portion

of the treatment plant. We've also got bonded for

operation of the treatment plant.

If you build a treatment plant

which is contemplated in your bonding which may

occur in the future -- we've talked to the chief

inspector about this and he says yeah, if that's a

component of your closure planting you've built it

then we no longer have to keep the capital

portion.

So I don't know if that helps.

I'm trying to clarify that -- we are saying the

same thing as the Ministry.

Is there anything else? Then

I'll pass it back to Mr. Scott.

MR. JONES: Thanks, John.

I just want to make a few

comments about the slope stability, and we

certainly heard from Dr. Eberhardt about the

nature of open pit design and the level of

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information to have a feasibility level design.

We talked about the ability to accumulate

knowledge and experience the rock mass and

behaviour of that rock mass as you move through

each phase of the pit, so by the time you get to

starting your mine, your final wall, you are able

to bring to bear all that knowledge and experience

that you've learned in the early phases.

In effect, I think it's fair to

say you can't know everything with absolute

certainty about the open pit until basically you

are finished with it.

But if you identify those

plausible conditions and you investigate the

threat or the likelihood of those plausible

concerns at the appropriate time, whether it be

pre-feasibility, feasibility, detail design or

throughout operations, as long as you do that at

the appropriate time that you can bring to bear

proven mitigation measures in advance to address

that, that is certain the way open pit mining

works and that's what we do.

I think at this stage we're

very confident that we have more than enough

understanding of the rock mass and have done

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enough design work to be very confident that the

project is feasible. And we've done that with our

own practical experience, team of engineers and

other professionals and supported by some of the

best consultants in the world.

So while there remain some

plausible conditions, that will be investigated

pry to detail design, at this stage of the project

-- and in my mind at this stage of the project

it's proof of concept for purposes of determining

whether there's the likelihood of a significant

adverse effect -- I would say we're there.

Yes, there's more information

to be gathered and assessed for detailed design,

and for Taseko's own decision-making in this whole

process as the project moves forward, as well as

for permitting, I think that we have evaluated the

likelihood, likely conditions, and certainly the

moderate to significant consequence events,

conditions, and we certainly have the flexibility

to investigate further and apply mitigation and

design and operations to address anything else.

So, again, that conclusion is

certainly based on many years of operating

experience and our knowledge of those techniques

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that are available to bring to bear in that

refinement or optimization of the final pit wall.

I did say I wanted to bring a

couple of points of clarification and I raise

these ones because there seemed to be a bit of

conversation around these, so I just offer these

for the Panel's benefit, hopefully.

We talked about the 200-metre

buffer around the pit. Certainly heard Dr.

Eberhardt's comment that buffer, in his view --

the concept of a rule of thumb and you shouldn't

use a rule of thumb unless it's a complex

evaluation then a rule of thumb is perhaps

appropriate.

I just wanted to make the point

that, well, we use a 200-metre buff. When you

look at our slope stability analysis, the extent

of the failures that those demonstrate is 50 to

100 metres. So, in effect, we've got double the

buffer that the analysis would suggest at this

point.

There was some discussion about

the potential for the flattening of the pit to get

-- push the crest of the pit closer to the lake.

And I just wanted to show a slide here. I'm not

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sure that everyone is aware of this. You will

remember this slide that showed the 43 degree

design slope and the flattening of 38 degrees.

Under this scenario, we still end up with a

220-metre buffer in here.

But I think it's important to

remember, because we kept talking about the slope,

the crest of the pit getting closer to the lake.

You can also move the crest, maintain the crest of

the pit at that distance from the lake, as long as

you do that before you get to the final push back.

You don't have to flatten

towards the lake. You can adjust the design of

the pit in the final phase to maintain the

appropriate distance from the lake.

I think Dr. Eberhardt, when he

responded to that, he said effectively you could

not mine quite as deep, which would do the same

thing.

The effect of doing that if you

wanted to maintain the same depth, obviously, you

could lose a little bit of the reserve here at the

bottom. But it's a very small amount and comes at

the end of the mine life. I just wanted to make

sure you're aware that of that.

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We also talked about the coffer

dams and the west dam which is currently located

200 metres from the design crest. And I think I

just wanted to point out -- I think I responded

that the location of that particular dam was

conceptual location, and the basis of that

location was to put it 200 metres from the crest.

And then we moved it slightly to avoid some

archaeological sites.

Well, we certainly have the

ability to move it 100 metres farther during

detailed design. Bear in mind, too, we're talking

about a structure that's 5 metres high. This is

not a big structure.

There were a couple things that

came up today that I thought might be worth

touching on and, one was the question about the

separation -- the segregation of potentially acid

generating material and non-acid generating within

the pit operations. And I think the question was

related to a little guy going out there and

sampling.

We treat that exactly the same

way we treat ore control, which is key to our

business. You don't want to be sending waste to

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the mill and you don't want to be throwing ore in

the waste dump. So it's the same approach. It's

sampling of the blast hole cuttings, doing the

analysis, coming back out after the blast and

actually outlining where that material sits,

whether this is non-acid generating material or

potentially acid draining material, treating it

just like you would a split between (muffled). We

bring to bear the same knowledge and experience

and techniques to do that.

I think the only difference is

in the mill, if you're sending waste to the mill

it will show up in your assay stream -- of the

mill. We're not sending this to a mill, so the

way we deal with that is sampling at the location

that it's placed. So routine sampling on the

non-acid generating waste stock pile to ensure

that the next (muffled) is not going there.

That's the only difference.

One more thing that I think I

have to clarify, and that was the question that

came up about soil and overburden. The question

of what is the soil, it was one of the previous

speakers concerned about soil should be considered

as a source term.

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I just wanted to clarify that

the soil that we're talking about is topsoil. It

is topsoil to be used in reclamation. The

overburden component is stored with the waste

drop. So there's a non-acid generating component

of overburden and an acid generating component.

The non-acid generating component is stored with

the waste rock, and the potentially acid

generating overburden goes to the tailings storage

facility.

So I think those were my points

that I thought might be of value in terms of

clarifying. And, John, I was going to ask you to

touch on the regulatory component in terms of

permitting and compliance.

Thanks, John.

The permitting exercise in

British Columbia is an adaptive management plan

exercise. You put forward a permit application

which covers pretty much all aspects of what the

mine is going to be, the open pit, the

geotechnical designs, your water treatment, or

your water protection, your closure plan,

reclamation, wildlife management, current use,

geography, climate, geology. All of that is in

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your initial operation.

Then you go through an exercise

with the Ministry where they go back and forth and

say, well, we like this but we don't like that.

We need something more here.

Eventually you're mine is at

permit which allows you to proceed to construction

and operation. It also has an operating system

component which is for health and safety, road

widths, speeds, you have traffic. What you are

through-put in the mill is going to be, what type

of equipment that you use.

Once you do that, that isn't

just the next 20 years you do exactly that. You

have -- there is a continuous inspection phase.

There's reporting, monitoring of everything that

you've said you were going to put in and whether

you do it or not. As you monitor you always learn

something and you need to adapt to it, whether

it's -- sometimes you can make the pit wall

steeper. Sometimes you have to make them flatter.

Sometimes there's less of this or more of that.

So you update your permit with

the Ministry of Mines through a series of

amendments so -- the Mines Act permit is actually

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a live document. It's not something that you

screw into a box and never touch it. You are

always added.

Same thing with reclamation and

closure plan. We have to re-submit reclamation

reports annually. Once every five years we update

and submit a whole new closure plan which takes

into effect whether there's sometimes just new

recollections. Actually, a lot of times there's

regulations and how do we, as the mine operator,

propose to meet the regulations and how do we do

that and then it's permitted or not permitted and

you work on it.

So that goes through not just

to closure, through the whole operation phase. It

goes through to closure then it continues after

closure.

So a mine at permit isn't like

a driver's licence where you say, okay, once a

year you get your driver's licence then you apply

for a new one. You are constantly in contact with

the Ministry of Mines and your other permits --

environment permit with the Ministry of

Environment is similar.

I'm sure you know these things

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as the Panel, but I just need to make sure that

you've heard it from us. I wanted to be clear

about that.

MR. JONES: Thanks, John.

Trevor was going to talk about maintaining the

water level in Fish Lake.

MR. CROZIER: I was going to

provide a number of additional clarifications that

I thought might be of benefit to the Panel given

some of the questions that were asked. And some

of the assertions that we've heard from reviewers

of our work who aren't intimately familiar with

the details of our work.

First, with regards to the top

layer used in our numerical model. I've heard a

number of comments or concerns that we're lumping

the basalt unit here in with the till, with the

top layer of our model. That's incorrect.

The units that we've lumped, if

you will, into the top layer of our model are the

basal till in yellow and the silt clay mix in this

top zone.

The basalt and the units deeper

down in this section which shows the open pit here

and Fish Lake over at the left, are part of the

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second layer our model which is the high hydraulic

conductivity of the model that we use.

That's the first comment that I

had with relation to this section. This section

actually is AA. It runs from here through here.

This shows the pit and this shows Fish Lake.

Some other interesting units

that are shown here -- this slide is the

overburden contact. Beneath that the rock units.

Above that is a number of units including silts,

tills, basalts.

As I just explained, the basalt

doesn't get captured in that top layer. So it's

just till or units like silt and clay which have

comparable hydraulic conductivities to till. Very

low hydraulic conductivities.

The next comment that I think

is relevant -- we've lot of concerns about faults

and what they might do to Fish Lake, what they

might mean for groundwater flow to -- Mr. Lloyd

just expressed concern about flow down the Taseko

River.

These red lines are the

inferred traces of the east and QD fault. You can

see they don't extend to surface. These faults

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are overlain by the overburden deposits.

The other thing you can see is

they're showing up as discreet features in this

section. What that means is they are not running

under Fish Lake. Fish Lake is over here. These

faults run out like this approximately

north/south, so they are not actually underlying

Fish Lake based on the direction that we

interpreted from the available results.

I just wanted to touch on that

again. This is the log (muffled) 94-164. This is

the pumping well. Don't worry, I'm not going to

get into another argument about pumping wells,

pumping curves or anything like that. Not just

yet anyways.

What I wanted to show is in

this well the column that's been logged is plain

gravel, which is a till unit, and then clay. That

20 metres is what would be interpreted as the top

layer of our model. This underlying, very complex

sequence of fine sand and gravel, basalt -- strong

and broken basalt -- brown clay, red clay, green

rock, red clay, gravel conglomerate, all of this

would be captured in the -- down to the first

hundred metres would be captured in that second

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layer of our model, which is the high hydraulic

conductivity layer of our model.

So what does that mean? Have

we adequately represented this complex

stratigraphy by that top layer, or that second

layer, by lumping them all together? What are we

doing.

So I wanted to present the

results of the hydraulic conductivity packer

testing data that we have between Fish Lake and

the pit. So that's what these data are.

So the blue are holes that are

actually in the open pit, and the drill holes in

black, those data points are in between Fish Lake

and the open pit. This yellow box shows you the

range of values that we've used for that upper

layer, that till layer.

As you can see, it only goes

down the 30 metres, and it ranges from about 2.7

times 10 to the minus seven down to about 1 times

10 to the minus eight. This middle bar, that's

our model set parameter. That's the one that

comes out of calibration.

The grey rocks down to one

hundred meters, is the second layer of our model.

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You can see where all the packer testing results

are plotting. There's a fair range in there.

Again, the central line is the

best fit, the best estimate parameter, and the

sensitivity range that we've used at the high end

is over here.

So we input value one times 10

to the minus 6 meters per second. What you'll

notice is that captures the majority of the packer

testing data that are out there, and that's --

when do you the quick math on meters per second to

centimeters per second, that's of the order that

Mr. Watterson was talking about when he was

pointing at the real data earlier today.

These data points over here in

blue, they are actually packer tests that are

within holes that are drilled in the pit, so those

may provide the basis for some of the concerns

expressed in earlier design reports, not the

current interpretation of the data, and the data I

might add and the designs.

But earlier geochemical

engineers may have looked at these and said, look,

there's some fairly high hydraulic conductivity in

the pit, we need to be prepared to deal with that

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water should we have significant in-flows.

That would have been the

approach that's been taken. We heard Dr.

Eberhardt say that it's a managed uncertainty.

Being prepared to implement a dewatering system

that could address in flows like that, it's

prudent, it's reasonable design practice.

Down in the second layer here,

100 to 200 meters, again we're capturing the

majority of the data, and down deep the hydraulic

conductivities are quite low. You can see there

is some uncertainty involved with packer testing

data points and calibration.

One of the things commonly of

issue is once you start getting down into 10 to

the minus 7, 10 to the minus 8 range, you start to

lose resolution on your packer testing results

because you're not able to inject very much water

into the foundation, it's very tight. So you

start to have difficulties measuring flows. So

your confidence on those ranges go a little

further. Might be two times 10 to the minus 8,

which are these guys; might be one times 10 to the

minus 8, it might be lower. But it's very low

hydraulic conductivity.

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I just wanted to offer that

clarification.

We've also heard of concerns

about faults and -- to use some language I heard

yesterday: What does no evidence of significant

permeability in the faults mean? And similar

statements.

Well, in this case what it

means is we've got packer testing data from three

data points, sourced from two holes. What you'll

see is those hydraulic conductivities are really

at the very low end of the range that we're

considering -- two times 10 to the minus 11 meters

per second; one times -- or two times 10 to the

minus 8, 8 times 10 to the minus 9.

So that leads us to believe

that the hydraulic conductivity in those zones --

and by the way, those tests were constructed

across intervals that were between 5 and I believe

14 meters long. So we tested a fairly long

section of the rock in those areas and learned

that they were fairly low hydraulic conductivity.

Does that address concerns that

were raised with regards to the potential for

fracture zones adjacent -- potentially gouge (ph)

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central zone, as Dr. Eberhardt was talking and

we've heard a number of people get concerned

about. No.

But that's a source of

uncertainty that we're left to deal with.

One of the other ways of

looking at that source of uncertainty is to

consider the age and activation history of the

faults. The QD and the east faults, we know they

are covered by overburden, and we know the last

activation of those faults that's been estimated

is before an episode of vein intrusion and

precipitation.

So what that means is there's

potential for both the intrusions of materials

associated with the mineralogy and precipitation

of things like gypsum or calcite or other

minerals. There's the potential for those

fracture zones to be healed by those intrusions.

Another interesting thing to

consider is that the QD and east faults run

north/south, approximately, whereas one of the

vein sets that's come in runs east/west. So what

that means is east/west veining could be healing

portions or sections of that fault, be cross

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cutting them if you will. So it's going to be

potentially limiting conduits or long conduits of

flow.

So that's a little bit

circumstantial. But that's one way of looking at

the fact that we've got reasonable basis to

believe that large fractures always don't exist.

Dr. Smith and Dr. Eberhardt

both confirmed yesterday that, depending on the

fault, you might have really high hydraulic

conductivity, you might have no hydraulic

conductivity. You might have hydraulic

conductivity that's comparable to what's going on

in the rock.

While there is uncertainty

there, the approach that we took was to go with

the data that we do have and to anticipate that we

would need additional (muffled) detail design

stage to confirm or address potential uncertainty

related to those questions.

I've already talked about the

fact these two faults -- the QD and the east --

don't daylight (ph) at surface. Significant

thickness of overburden materials, and they don't

run under Fish Lake.

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Mr. Lloyd in his discussion

earlier this afternoon raised a concern about the

potential for these faults to run down the Taseko

River. When you follow the currently interpreted

alignment of those faults, they don't actually

intersect that canyon section downstream of the

pit.

I also wanted to touch a little

bit on some of the statements that have been made

about our interpretation of the pumping test data.

We didn't consider it invalid. Our concern is

related to the lack of confidence in the constant

pumping rate. Without that constant pumping rate

you can't calculate (muffled) -- of hydraulic

conductivity and storage.

That's the extent of our

concern. There's other insights that be can

gained from the results of that pumping test. As

it pertains to depressurization and pit

dewatering, what you can look at is that within

the pumping well you're able to achieve 60 meters

of drawdown over a roughly two-day period during

both tests.

And in adjacent monitoring

wells you achieve drawdowns of between 9 and 12

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meters at radial distances of 10 to 31 meters.

What does that mean? Well,

that means that you can be reasonably confident

that at the pumping rate they were using, you are

going to be able to depressurize and control water

flow in that unit.

When you think about the fact

that based on opinion experience the drawdown

achieved in that well indicates you've got

substantially lower hydraulic conductivity

interpreted results, and you may be pumping at 40

gallons a minutes, or 20 gallons a minute when you

average it out. That means that you've got a

really, really good basis for thinking you can

depressurize those units. You are not going to

have a significant in flow. You are going to be

able to control that water flow.

This is a figure -- I apologize

for the charts and the lines. But it's sourced

from Driscoll, which is a very thick book on

groundwater and wells and how to interpret pumping

tests.

One of the interpretations that

can be done with the pumping test data that we do

have that doesn't consider pumping rates -- so you

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can get rid of that source of concern in the

analysis -- is to have a look at what the residual

drawdown is, compare it to the ratio of the time

that you drew the well down while you were

pumping, divided by the time it takes for that

well to recover.

And what that analysis can do

is it can give you an idea whether or not there

was a barrier boundary effect that was encountered

by your pumping test. A barrier boundary effect

is a limit or extent to the aquifer, so once you

run into it you start to draw the water levels

down much faster.

The other thing you can look at

is whether or not it's an aquifer of limited

aerial extent, depending on where things plot.

A theoretically perfect pumping

test would follow very close along this line. A

curve that shows significant recharge effects to

the aquifer would plot here anywhere above 2 on

this ratio when you get back to two zero residual

drawdown.

Any of the lines that plot

below this theoretical position would indicate

that you've got incomplete recovery due to limited

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extent of the aquifer.

So these are the results. They

are from appendix 36-H of the 2009 EIS showing

that plot residual drawdown and the ratio of T

over T prime for pumping test one.

CHAIRPERSON ROSS: Mr. Crozier,

I think I'm sure you said it, but I missed T and T

prime. Would you repeat that --

MR. CROZIER: "T" is the time

that you pump, and "T prime" is the time that the

well recovers. So what you are looking for is

differences in recovery time and shapes in the

curve, and that can inform you on what is going on

with the recharge.

So for pumping test one, got a

couple of curves from the observation wells, and

what they show you is that in one case it's

theoretically near perfect, and the other case

you've got slightly greater than one.

What that means is, when we go

back up a page. These guys in here, that's where

you're changing the storage. So what you might be

doing is drawing the pressure down in the unit

that can consolidate and supply water to a more

conductive unit above it. So leakage from silt

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clay to a sand and gravel unit.

When you go to the second test

and you examine the recovery, what you see the

every single one of those lines plots down here

below this zero point. What that clearly

indicates is an aquifer of limited aerial extent.

That's consistent with Dr.

Eberhardt's review and interpretation of the

geology as we heard yesterday for that sand gravel

units -- or those sand units.

That couple with the ability to

depressurize or draw the water double down quickly

over a relatively short period of time, really

paints a strong favourable position for being able

to control water in those units.

The other thing it also

demonstrates is there's no recharge, or limited

recharge being supplied to the well of the

aquifers during the test, at least during the

period it was pumped.

So that is another way of

saying there's no direct connection between the

pumped well and Fish Lake. It's another way of

saying there's not a high recharge capacity

evident in this pumping test.

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So that kind of forms the basis

for us not being -- not going too much further

with that pumping test calibration. It also

supports the way we've lumped the parameters

together. We're not seeing evidence of the

significant through going aquifer that could act

as a pathway for migration or other things like

that.

That's pretty much the limits

of the clarifications I wanted to provide on our

interpretation today.

MR. JONES: Just a couple of

little things. I just didn't want to leave it

hanging.

There was some discussion

yesterday about a potential undertaking to look at

supporting the seepage collection efficiencies you

might see in a seepage collection pond, and that

was kind of a recommendation that Dr. Smith had

related to his review.

I just want to say, we're still

seriously considering that. We just haven't had a

chance to finalize our thoughts, and we would

certainly get back to the Panel in the next couple

of days on that.

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CHAIRPERSON ROSS: For greater

certainty, it was also a request from the Panel.

MR. JONES: Got it.

I think the last thing I wanted

to say was: We know this project inside out.

We've been working on it for quite a while now,

and I realize there's a large body of information

-- as I'm sure you guys are aware too.

I just want to say, look, we

stand behind everything that's in that, provided

it's taken in the context that it's provided.

Certainly if there is something

that you guys can't find or that we can't respond

to quickly or put our fingers on it, absolutely

we're happy to undertake to find whatever it is.

I think that's all we had to

offer, subject to whatever you might like us to

offer in addition.


Mr. Jones.

Do we have any questions,

gentlemen? I think we might be done then for this

session.

I usually do something that

says thank you all for your input. The

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information we have received has been anywhere

from helpful to extremely helpful and we very much

appreciate that.

Tomorrow, as I've indicated

earlier, is a day off and Monday morning at 9

o'clock we'll return with -- I think it's aquatic

environment, day one. Do we have a closing

ceremonies? Yes.

I thank you for your

contributions, and we'll have a closing ceremony

now.

--- Closing ceremonies

--- All the foregoing non-English words, when

spellings not provided, are represented

phonetically.

--- Whereupon the hearing was adjourned at

4:35 p.m., to resume at 9:00 a.m. on

Monday, July 29th, 2013.

**************

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C E R T I F I C A T I O N

I, SANDRA BRERETON, a certified Court Reporter in

the Province of Ontario, hereby certify the

foregoing pages to be an accurate transcription of

my notes to the best of my skill and ability.

Je, Sandra Brereton, un sténographe officiel dans

la province de l'Ontario, certifie que les pages

ci-hautes sont une transcription conforme de mes

notes au meilleur de mes capacités.

Sandra Brereton,

Sandra Brereton, CSR, RPR

Certified Court Reporter.

canadian environmental assessment agency agence … · 2013-07-29 · bursey and jenna mclean over...

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