Editor,
The Telkwa Coal Project mine proposal being promoted by Allegiance Coal Limited is a major mine development. Within the legal framework of British Columbia, an Environmental Assessment process and Approval are required before any “operational permits” are issued to this company. There have been four decades of varying mine development proposals at this site, none of which proceeded to a BCEAO/BC Environmental Office Approval, let alone “permits.”
Acid Rock Drainage
Due to previous site inventory work — lab test results and field trials — we know that many rock types within the mine waste rock stream at this site contain sufficient sulphide mineralization to generate ARD (acid rock drainage). In simple terms, the minerals will oxidize into sulfide-state and when any water (rain, snowmelt, groundwater) flows to those locations, ARD will be the result. In addition, heavy metals such as manganese will be entrained within the acidic flows. Acidity levels will be sufficient to adversely affect the Telkwa and Bulkley Rivers if mitigation strategies are not effective.
Mine Site Inventory
Field trials on site were completed during the 1990s using silt stone, green sandstone and mudstone that are waste products at this mine site. The small deposits went acidic within 18 months. Another waste product identified has been the Coarse Rejects and the “wash stream waste,” both of which tested as acid generating. Several million tonnes of mine waste will be produced throughout the Telkwa Coal mine life; that mine waste will remain after the company is long gone.
Containment of Hazards for Rivers’ Safety
One of the primary principles with the B.C. ARD guidelines is that mine site ARD must be contained through ponds and/or collection systems. The principle of containment cannot be guaranteed at this mine site. At Telkwa Coal the coal seams are layered between aforementioned mudstones, sandstones, sand and gravels. This site condition means that flooded open pits, collection ponds and/or tailings impoundment pond water levels may not be maintained through time, since sand and gravel lenses will provide drainage pathways to both the Bulkley and Telkwa Rivers.
Mitigation
If water covers are the “mitigation” for ARD-risks to prevent oxidation of sulfide minerals, and, due to site geology, water covers cannot be guaranteed, ARD will proceed due to wet-dry cycle and groundwater discharges.
Major mine developments are mine waste storage facilities, forever. Waste rock, coal spoils and coal-wash rejects are the hazards. Included into this is the knowledge of past proposals have included eight open pits within the mine site footprint. Those pit walls will also become a hazard for ARD, since they may not retain a water cover over all sulphide-rock type layers year round.
Trade-off, jobs for long term damage?
I have assessed and reviewed three different mine proposals at this Telkwa Site. All of them represented several levels of high hazard conditions with no “trade-off” compensation that would balance the damage done nor the risks to our watersheds.
Sincerely,
Glenda Ferris
Houston