Hecla Greens Creek Mining Company's Surface Exploration Plan of Operations - 2017 through 2021
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Hecla Greens Creek Mining Company’s Surface Exploration Plan of Operations - 2017 through 2021 Submitted to the United States Forest Service, Juneau Ranger District, Tongass National Forest, Alaska. Prepared by Hecla Greens Creek Mining Company. April 15, 2016 Photo of helipad on Gallagher Ridge overlooking Hecla’s Greens Creek Mine, taken by exploration personnel. For More Information Contact: Chris Wallace, Environmental Manager Hecla Greens Creek Mining Company P.O. Box 32199, Juneau, AK Phone: 907-790-8473 Email: cwallace@hecla-mining.com
Plan of Operations for Hecla Greens Creek Mining Company’s Surface Exploration Plan 2017-2021 Table of Contents Table of Contents ............................................................................................................................ ii List of Figures ................................................................................................................................ iv List of Tables .................................................................................................................................. iv List of Abbreviations and Acronyms .............................................................................................. v Chapter 1 Introduction..................................................................................................................... 1 1.1 Project Title and Name of Applicant .................................................................................... 1 1.2 Project Location .................................................................................................................... 1 1.3 Project Overview................................................................................................................... 1 1.4 Project Schedule .................................................................................................................... 2 1.5 Purpose .................................................................................................................................. 3 1.5 Conformance with Statute and Regulations .......................................................................... 3 Chapter 2 Applicant Information..................................................................................................... 7 2.1 Applicant Contact Information ............................................................................................. 7 2.2 Surface and Mineral Ownership............................................................................................ 7 2.3 Right of Entry........................................................................................................................ 7 Chapter 3 Geology and Mineralization ........................................................................................... 7 Chapter 4 Exploration Activities ..................................................................................................... 8 4.1 Access ................................................................................................................................... 8 4.2 Helicopter Use....................................................................................................................... 8 4.3 Geologic Mapping............................................................................................................... 10 4.4 Soil Surveys ........................................................................................................................ 11 4.5 Geophysical Surveys ........................................................................................................... 11 4.5.1 Heli-Airborne Electro-magnetic (EM) surveys ............................................................ 11 4.5.2 Ground EM surveys ...................................................................................................... 13 4.5.3 Ground IP surveys ........................................................................................................ 14 4.5.4 Ground Gravity surveys ............................................................................................... 14 4.5.5 Heli-Airborne Gravity Gradiometry surveys ................................................................ 14 4.5.5 Borehole EM surveys ................................................................................................... 15 4.6 Diamond Drilling ................................................................................................................ 15 4.6.1 Drill Site Preparation .................................................................................................... 15 4.6.2 Drilling Water Supply .................................................................................................. 17 4.6.3 Drilling Activities ......................................................................................................... 20 4.6.4 Materials and Drilling Additives .................................................................................. 21 4.6.5 Hole Abandonment ....................................................................................................... 24 4.6.6 Drill Site Reclamation .................................................................................................. 24 4.7 Spill Prevention and Waste Disposal .................................................................................. 25 4.7.1 Spill Prevention Control and Countermeasures (SPCC) .............................................. 25 4.7.2 Fuel transport and storage ............................................................................................ 25 Chapter 5 Mitigation and Monitoring............................................................................................ 28 5.1 Introduction ......................................................................................................................... 28 5.2 Air Quality and Noise ......................................................................................................... 28 5.3 Geotechnical Stability ......................................................................................................... 29 Page | ii
5.3.1 Erosion.......................................................................................................................... 29 5.3.2 Slump control ............................................................................................................... 29 5.4 Water Resources ................................................................................................................. 30 5.4.1 Surface Water ............................................................................................................... 30 5.4.2 Ground Water ............................................................................................................... 35 5.5 Geochemistry ...................................................................................................................... 37 5.6 Aquatic Resources............................................................................................................... 38 5.7 Soils..................................................................................................................................... 39 5.8 Vegetation ........................................................................................................................... 39 5.8.1 Ground Cover and Shrubs ............................................................................................ 39 5.8.2 Trees ............................................................................................................................. 40 5.8. Invasive Species ............................................................................................................. 43 5.9 Wetlands.............................................................................................................................. 43 5.10 Common Wildlife ............................................................................................................. 45 5.11 Threatened and Endangered Species ................................................................................. 45 5.12 Land Use ........................................................................................................................... 46 5.13 Scenic Resources............................................................................................................... 47 5.14 Recreation ......................................................................................................................... 48 5.15 Subsistence ........................................................................................................................ 49 5.16 Cultural Resources ............................................................................................................ 49 5.17 Socioeconomics ................................................................................................................ 49 5.18 Monument Resources ........................................................................................................ 49 5.19 Inventoried Roadless Areas (IRA’s) ................................................................................. 50 5.20 Solid Wastes...................................................................................................................... 50 References ..................................................................................................................................... 51 Appendix A – HGCMC’s Standard for Helicopter Operations ..................................................... 53 Appendix B – HGCMC’s Standard Task Description for Line Cutting........................................ 64 Appendix C – HGCMC’s Temporary Water Use Authorizations ................................................. 66 Appendix D – HGCMC’s Driller Environmental Checklist ......................................................... 71 Page | iii
List of Figures Figure 1-1. Location Map .................................................................................................. 5 Figure 1-2. Areas of interest for drilling activities. ............................................................ 6 Figure 4-1. Location of infrastructure ................................................................................. 9 Figure 4-2. Typical disturbance for outcrop mapping...................................................... 10 Figure 4-3. Example of soil auger and typical sample......................................................11 Figure 4-4. Heli-EM survey. ............................................................................................ 12 Figure 4-5. Ground EM survey. ....................................................................................... 13 Figure 4-6. Drilling pad construction site in timbered area. ............................................ 16 Figure 4-7. Flyable backhoe. ........................................................................................... 17 Figure 4-8. Drill site layout.............................................................................................. 18 Figure 4-9. Map of streams designated for temporary water use. ................................... 19 Figure 4-10. Typical Diamond Drill Setup at Greens Creek............................................ 21 Figure 4-11. Mud filter cake influencing drill waters. ..................................................... 22 Figure 4-12. Location of Jet-A fuel tanks and pumps for fueling helicopters. ................ 27 Figure 5-1. Watersheds of the Greens Creek area. ........................................................... 34 Figure 5-2. Drill site after 38 years of regrowth. ............................................................. 41 Figure 5-3. 2013 orthophoto of drilling sites showing regrowth. .................................... 42 Figure 5-4. USFWS National Wetlands Inventory relative to AOI’s. .............................. 44 Figure 5-5. Hill slope showing historic drilling sites. ...................................................... 48 List of Tables Table 1-1. Maximum yearly surface disturbance by exploration activity. ......................... 2 Table 4-1. Typical drilling additives for HGCMC surface drilling programs.................. 23 Table 5-1. Summary of air pollution and noise sources................................................... 28 Table 5-2. Surface water risks and protective measures. ................................................. 30 Table 5-3. Spill reporting requirements. .......................................................................... 33 Table 5-4. Groundwater risks and protective measures. .................................................. 37 Table 5-5. Land types within the AOI’s. .......................................................................... 40 Page | iv
List of Abbreviations and Acronyms Acronyms and Abbreviaions ADEC Alaska Department of Environmental Conservation AK State of Alaska AKDNR Alaska Department of Natural Resources AMD Aviation Management Directorate (formerly OAS) ANILCA Alaska National Interest Lands Conservation Act of 1980 ANSI American National Standards Institute AOI Area of Interest CBJ City and Borough of Juneau CFR Code of Federal Regulations DOT US Department of Transportation EIS Environmental Impact Statement EM Electro-Magnetic FAA Federal Aviation Administration FSH Forest Service Handbook FWMP Fresh Water Monitoring Plan gpm Gallons per minute GPS Global Positioning System HDPE High Density Polyethylene HGCMC Hecla Greens Creek Mining Company in Inches IP Induced Polarization IRA Inventoried Roadless Area kW Kilowatt LCZ Lost Circulation Zone LUD Land Use Designation NEPA National Environmental Policy Act NFPA National Fire Protection Association NPDES National Pollutant Discharge Elimination System NSF National Sanitation Foundation International OAS Office of Aircraft Services OSPAR Oslo Paris Convention PLONOR Pose Little or No Risk psi Pounds per square inch fluid pressure SIO Scenic Integrity Objective SPCC Spill Prevention, Control, and Countermeasure sqft Square feet TWUA Temporary Water Use Authorization USFS United States Forest Service USFWS US Fish and Wildlife Service Page | v
Chapter 1 Introduction 1.1 Project Title and Name of Applicant Hecla Greens Creek Mining Company (HGCMC) is the applicant for this mineral exploration program identified as the Greens Creek Surface Exploration Plan of Operations – 2017 through 2021 (exploration plan), and will be responsible for the activities pertaining thereto. 1.2 Project Location HGCMC proposes to conduct mineral exploration activities adjacent to their operating Greens Creek Mine within the Greens Creek Land Exchange and on their Federal lode mining claims located on Admiralty Island, AK (Figure 1-1). HGCMC’s land package totals over 24 square miles, referred to herein as the ‘project area,’ with the southern half being the Land Exchange and the northern half being Federal lode mining claims. Within the project area, smaller ‘areas of interest’ (AOI) have been identified. Drilling activities will be limited to the two AOI’s shown on the map in Figure 1-2. Geophysical surveys, geologic mapping and soil sampling will extend outside the AOI boundaries, but will remain within the project area. These AOI’s have been considered within the 1983 Environmental Impact Study (EIS) completed for HGCMC’s mine and mill. The 2003 and 2013 Greens Creek Tailings Facility Expansion EIS’s envisioned exploration activities as part of impact analyses. Many smaller wildlife and botany surveys have also been completed in these areas for the permitting of past drilling programs. 1.3 Project Overview The exploration plan will explore over the next five years for silver, zinc, lead and gold rich volcanogenic massive sulfide mineralization as is present at the Greens Creek Mine. Past work has identified geologic and geochemical targets which require further work in order to determine whether minable resources are present or not. Some of the targets require further field mapping and soil sampling while others are ready for geophysical surveying or drill testing to provide subsurface information. Table 1-1 summarizes activities within the exploration plan. Of the proposed activities, diamond core drilling is most essential. As some targets reach 4,000 feet in depth, drilling equipment must be capable of that depth. Only road based drills, or larger, flyable core drilling rigs can complete holes that deep. Road based rigs have been excluded as a possible alternative to avoid road construction. Helicopters will be used for transporting crews, equipment and supplies to minimize impacts. To protect sensitive species, HGCMC will contract third party plant and wildlife surveys for each drilling site before entry, and submit the findings to the Forest Service for review. Where sensitive species are identified, appropriate buffer zones will be Page | 1
maintained to minimize disturbance. Reclamation activities will immediately follow drilling, according to best management practices, to ensure surface and ground waters are protected, erosion prevented and natural vegetation restored. A yearly activity and reclamation report will document these efforts to the Forest Service, and provide status on reclaimed drilling sites for two years. Exploration targets evolve every year as geologic information is continually gathered and analyzed. Therefore, the exact location of each drilling site is not known more than a year in advance. However, core drilling activities will be: 1) limited to specific areas of interest, 2) committed to less than 5 acres land disturbance per year and 3) described in terms of procedures and annual reclamation. By presenting all potential activities in this manner, it is desired that this 5-year plan of operations be considered in an Environmental Assessment. Table 1-1. Maximum yearly surface disturbance by exploration activity. Exploration Activity Description Maximum Disturbance Core drilling Clearing drilling sites of trees Less than 5 acres Less than 0.12 acres of total Core drilling Building pads and sumps excavation within drilling sites, reclaimed annually 6 inch diameter holes to 'C' soil Less than 550 samples, or 0.01 Soil sampling horizon acres, reclaimed immediately Up to 3-square feet of moss Less than 50 locations, or 0.01 Geologic mapping removed from outcrop if needed acres 2.5 foot wide footpath cleared of Ground geophysical Less than 10 miles of footpath brush and small (< 2-inch) trees surveys cleared and branches Airborne None None geophysical surveys 1.4 Project Schedule These activities are planned for a period of five years, beginning in May of 2017 and ending in September of 2021. Typically the field season does not begin until May and ends before September, but if the economic environment and weather provide an opportunity to start earlier or end later, operations may start as early as March 1 and continue until October 31. Page | 2
To keep within Forest Service Handbook guidelines, yearly notifications will be made to the Forest Service by December 15 regarding the location of each planned drill site for the next year (FSH 2509.22_10). At the same time, an activity and reclamation report will be submitted for the current year’s activities. 1.5 Purpose As of 2015 the Greens Creek Mine has mined 264,046,360 ounces of silver, 2,278,374 ounces of gold, 1,631,200 tons of zinc and 638,989 tons of lead over its 27-year history. Currently, the mine has 8 to 12 years of minable resources. In order to support further mining, additional resources must be found. Though underground exploratory drilling has been successful in adding to the mine’s life historically, that drilling can only effectively test areas less than 2,000 feet from existing mine infrastructure. Targets further afield must be tested by surface drilling. This proposed exploration plan will allow for testing of existing mineralized targets and generation of new targets not accessible from underground operations. If mineable horizons are intercepted in drilling, the objective would be to turn these into mineral reserves for the mine. The Greens Creek Mine is Juneau’s largest private employer, with 415 employees and an annual payroll and benefits of over $68 million in 2015. Annual purchasing from Alaskan businesses has averaged over $45 million per year over the last five years. It is estimated that the Greens Creek Mine generates an additional 390 indirect jobs in the Alaskan economy. Only through exploration efforts such as those proposed in this application can the mine continue in providing this support to the community. 1.5 Conformance with Statute and Regulations The proposed exploration plan is supported by the 2008 Land and Resource Management Plan for the Tongass National Forest (Forest Plan), the Greens Creek Land Exchange Act of 1995 (Public Law 104-123, 104th Congress), the Alaska National Interest Lands Conservation Act of 1980 (ANILCA, 16 U.S.C. 3770, Sections 1010 and 1110(b)) and United States Mining Law (30 U.S.C. Chapter 2). The exploration plan will be regulated through the Forest Service under 36 CFR part 228, subpart A, to minimize adverse environmental impacts to surface resources. The Forest Service’s Juneau Ranger District of the Tongass National Forest and the Admiralty Island National Monument Ranger District administers and regulates mineral exploration activities for the project area. Various laws and plans guide their management including: 1. The 2008 Forest Plan provides standards and guidelines for permitting and performing activities. 2. ANILCA, sections 810 and 811 protect subsistence activities. Page | 3
3. The Endangered Species Act of 1973 provides protection for endangered species, though no federally listed threatened or endangered species are known to exist in the project area. 4. The Magnuson-Stevens Fishery Conservation and Management Act protects freshwater and marine habitat essential to fish. 5. The National Historic Preservation Act, section 106, requires the Forest Service to consider historic resources, including archeological resources, when reviewing permit applications (36 CFR 800). 6. Executive Order 11988 protects floodplains. 7. Executive Order 11990 protects wetlands. 8. Executive Order 12962 protects recreational fisheries. 9. Executive Order 13112 protects against the spread of invasive species. 10. Under Executive Order 12088 and Section 313 of the Clean Water Act, the Forest Service (Region 10) has coordinated with the Alaska Department of Environmental Conservation (ADEC) in the 1992 Memorandum of Agreement to protect water resources on Forest Service System lands in Alaska. That agreement set forth the “Forest Service Alaska Regional Water Quality Management Plan” which identifies the Forest Service as the regulatory authority responsible for monitoring and protecting water quality on National Forest System lands in Alaska for purposes of the Clean Water Act (as amended in 1987). The agreement also specifies responsibilities and activities for the Forest Service and for ADEC as described within the Alaska Nonpoint Source Pollution Control Strategy and Clean Water Act of 1990. 11. The 1992 Memorandum of Agreement also sets forth the Forest Service’s Soil and Water Conservation Handbook (Chapter 10) as the Best Management Practices (BMPs) basis for developing procedures to protect water resources, including riparian areas and wetlands. All activities proposed herein are designed in accordance to these plans, laws, regulations and BMPs. Page | 4
Figure 1-2. Areas of interest for drilling activities. Page | 6
Chapter 2 Applicant Information 2.1 Applicant Contact Information Chris Wallace, Environmental Manager Hecla Greens Creek Mining Company P.O. Box 32199, Juneau, AK Phone: 907-790-8473 Email: cwallace@hecla-mining.com 2.2 Surface and Mineral Ownership All activities will be within HGCMC’s 24 square mile land package. The Greens Creek Land Exchange, comprising the lower half of the land package, allows for mining and exploration activities (Congress 1996). HGCMC owns seventeen patented lode claims over the Greens Creek Mine, within the Land Exchange. The northern half of the land package is comprised of 440 contiguous unpatented federal lode mining claims which HGCMC controls (Figure 1-2). 2.3 Right of Entry HGCMC currently has the right to enter the Greens Creek Land Exchange for mineral exploration as authorized by the Greens Creek Land Exchange Act (1995) and its associated Greens Creek Land Exchange Agreement (1994). Under the General Mining Act of 1872, HGCMC personnel have the right to enter public lands such as the 440 federal lode claims for exploration purposes, but cannot perform disruptive work such as drilling unless granted permission by the Forest Service. Chapter 3 Geology and Mineralization The Greens Creek deposit is a polymetallic, stratiform, volcanogenic massive sulfide deposit with a relatively high precious metal content compared to other deposits of its type. The host rocks consist predominantly of Triassic marine sedimentary and Carboniferous basaltic rocks, which have been subjected to multiple periods of deformation. The latest intense ductile deformation occurred in Middle Cretaceous as the Alexander terrane collided with the North American continent. That deformation was followed by large scale, right lateral strike slip faulting. Some of the larger strike slip faults have more than 1,000 feet of displacement. Mineralization occurs discontinuously along the contact between the marine sedimentary sequence and the basaltic sequence of rocks. Sulfide accumulations typically mined include pyrite, sphalerite, galena and tetrahedrite/tennanite minerals. On the flanks of the sulfide accumulations barite, carbonate and quartz gangue minerals are abundant. The original basaltic host rocks are altered hundreds of feet from the mineralization centers, with carbonates and sericite mica being the predominant alteration minerals. Page | 7
Chapter 4 Exploration Activities 4.1 Access As the Greens Creek Mine is presently in operation, all necessary piers, docks and roads are in place and available for support of the exploration plan (Figure 4-1). No new roads are anticipated as a part of the exploration plan, so the Greens Creek and Mansfield Peninsula Inventoried Roadless Areas (IRA’s) will not be affected (2001 Roadless Rule, Forest Service 2000). Equipment and fuel will be transported to and from the Greens Creek marine terminal at Hawk Inlet by oceangoing barges. The equipment is then transported via tractor-trailer over an existing unpaved haul road eight miles to a storage yard (‘860’ laydown) near the mine portal. As the road is used daily for ore concentrate and tailings haulage, it is well maintained with guardrails on steep slopes and bridges. Exploration personnel will be transported via boat from Auke Bay to the pier at Young Bay. From Young Bay a bus transports personnel to either Hawk Inlet or to the Greens Creek Mine. The existing man camp at Hawk Inlet will house all staff needing to stay overnight. A few managerial staff will take the bus and boat to and from Juneau every day, but the majority of the crews, including the drilling contractor, will stay overnight at the man camp. As with the road, the man camp is managed under HGCMC’s Plan of Operations (Forest Service 1983, 1988 and 2013). Crews will be transported from the man camp to their working area either by the helicopter or by pickup truck on existing roads. 4.2 Helicopter Use As no new roads are anticipated for the exploration plan, access to drill stations and other fieldwork is either by foot from the existing roads or by helicopter. Personnel, materials, core samples, fuel and equipment will be transported by OAS/USFS certified pilots using either a Hughes 500 or 600 series helicopter or the larger Eurocopter AS350 (A-star, B-2 or B-3) helicopter. Typically the A-star is used when moving drilling rigs to and from drilling sites, while the smaller Hughes helicopter supports day-to-day operations. Typical in-flight times will be 1 to 3 hours per day depending on support required. Moving drills or constructing drilling pads requires 3 to 7 hours per day depending on site location and weather. As the fieldwork is remote, the helicopter is the primary mode of transport in case of safety or environmental emergency. As such, a helicopter and pilot will remain in the project area day and night. At times the pilot will fly into Juneau for supplies, or to switch out aircraft, which is a 20-minute flight. Page | 8
Communication with the helicopter pilot(s) will be via handheld radios through a repeater located centrally within the claim block (Figure 4-1). All staff will be required to have a Figure 4-1. Location of infrastructure Page | 9
radio on their person or at their working site. The pilot and one other exploration manager will monitor the radio 24 hours per day, seven days per week. All exploration personnel will be instructed in helicopter safety. The pilot will provide an orientation briefing at the helicopter prior to any use of the helicopter. Instructional videos regarding helicopter safety and slinging operations will be viewed by all exploration personnel. No person will participate in sling operations until they have been task trained by competent personnel. Appendix A contains HGCMC’s helicopter safety manual. 4.3 Geologic Mapping Helicopter supported geologic mapping will be conducted during the summer months. Only day hikes will be taken with small packs, with no planned overnight camps. No trash, equipment or samples will be left overnight. Traverses begin and end at existing helicopter landing sites or at existing roads. Crews of two geologists hike through the forest and along streams, taking advantage of game trails when available. No axes or saws will be used to blaze trail. At rock outcrops the geologists make observations and often collect a small specimen for further laboratory work. The specimens will typically weigh less than 1 pound. Once a traverse has been made it is rare that it will be made again that year, so topsoil is not disturbed. Two-way radios, compasses, maps and GPS units will be taken in the field for positioning and in case of emergency. Bear spray and ‘bear banger’ signal cartridges will be carried as bear deterrent. Firearms will not typically be carried in the field. No motorized tools or vehicles will be used in the field for this work. Only the geologist’s rock hammer will be used to scrape dirt or moss off outcrops (Figure 4-2). Figure 4-2. Typical disturbance for outcrop mapping. Page | 10
4.4 Soil Surveys Like geologic mapping activities (section 4.3), no motorized tools or vehicles will be used for soil surveying. Field technicians will be flown to the sampling area by helicopter. The samplers follow designed grids using GPS and compass on soil lines spaced 400 to 1,000 feet apart, depending on the nature of the target. A hand augur is used to collect soil from the ‘C’ horizon every 100 feet along the soil line (Figure 4-3). Approximately 1 pound of soil is collected in a labeled sample bag. Flagging is Figure 4-3. Example of soil auger and typical sample. placed close to the sample location. Tools will be cleaned, and the augured hole filled and topped with the removed vegetation before moving onto the next sample location. 4.5 Geophysical Surveys Several types of geophysical surveying have been used at Greens Creek. Only two borehole EM surveys have been conducted by HGCMC over the last five years, while no airborne or surface EM studies were completed in that time. Though geophysical surveys are uncommon for the Greens Creek claim block in a given year, one or more may occur as needed over the next five years. Therefore, airborne, ground and borehole surveys will be included as possible activities. 4.5.1 Heli-Airborne Electro-magnetic (EM) surveys If an airborne EM survey is commissioned, a helicopter pilot and geophysical technician will base their activities out of the Hawk Inlet facility. Depending on weather, the helicopter may fly up to the FAA specified 8 hours in a day. When flying the survey, the pilot will keep the geophysical instrument approximately 100 feet above treetops. The instrument typically hangs 100 to 150 feet below the aircraft, so the helicopter is 200 or more feet above the treetops. The flight path would likely be on parallel lines separated by 200-400 feet with crossing lines separated by 1000-2000 feet. Flight speed varies according to topography, but would typically be more than 20 miles per hour at Greens Creek. Page | 11
Any survey flown should be completed in less than five flying days. Notification of any airborne survey will be made to the Forest Service at least two months in advance. Figure 4-4 provides an example of a typical Helicopter EM survey. (Geotech Ltd.’s VTEM system.) Figure 4-4. Heli-EM survey. Page | 12
4.5.2 Ground EM surveys Ground EM surveys require the placing of a thin insulated wire in a large overland loop over a target area (Figure 4-5). Loops may be up to 5 miles in length, but typically much smaller. As the wire loop must be installed by hand, line-cutting crews will be flown by helicopter into the survey area with chainsaw, brush ax and machete to cut a 2.5-foot wide path where the loop is to lay. No live trees larger than 2 inches in diameter will be cut. Fallen logs will be cut so that a person can walk through or step over them safely. Small brush and plants will be cut using a machete or Sandvik brush axe to within several inches of the ground. (Appendix B contains HGCMC’s line cutting procedure.) Once the EM loop is in place, a field geophysicist transmits an electric wave through the loop which causes a magnetic field to interact with the earth. That field causes weak currents to flow in the subsurface according to the rock’s Figure 4-5. Ground EM survey. properties. A synchronized receiver coil then picks up the decay of the magnetic field created by the earth as the induced currents with in it attenuate. The receiver coil is carried on a backpack by a field technician on traverse lines over the loop. No line cutting is required for the field technician with the receiver coil. The size and number of loops and the spacing of lines traversed with the receiver all depend on the size and depth of the target as well as the conductivity of the subsurface rocks. While the dimensions of these loops are not known presently, the total amount of line cutting for an entire year’s exploration program will not exceed 10 miles. A ten-mile program would consist of: 1) a crew of two cutting the lines for approximately 35 days, 2) a crew of two placing and retrieving the lines for approximately 10 days and 3) a crew of three running the transmitter and receiver during data collection for approximately 20 days. For ground EM surveying, a generator is required to provide the signal for the loop. The power requirements of the generator are small, so it will typically be a portable 5 kilowatt (kW) sized model. Generator noise is typically 70-80 decibels under full load. The Page | 13
generator and 10 gallons of gasoline fuel will be kept at least 200 feet from running streams and in secondary containment. 4.5.3 Ground IP surveys Induced Polarization (IP) surveys measure the capacity for subsurface rock to hold a charge by transmitting carefully controlled current into the ground via electrode stakes and measuring the potential field gradient voltage in nearby stakes. Similar to ground EM surveys, IP surveys require equipment to be carried into the field and insulated wires placed over ground; therefore, line cutting is required. Line spacing is determined according to target properties and required resolution, but as mentioned in section 4.5.2, no more than 10 miles of line cutting will be carried out for any given year. For IP surveying, a generator is required to provide the transmitted current. The power requirements of the generator are small, so it will typically be a portable 5 kW model. The generator and 10 gallons of gasoline fuel will be kept at least 200 feet from running streams and in secondary containment. 4.5.4 Ground Gravity surveys Ground gravity surveys do not need line cutting or generators. A crew of two hikes a line as in soil surveying (section 4.4). At predetermined positions along the line the gravimeter and differential GPS equipment is removed from daypacks to take a reading. The crew occupies each station on the line for a few minutes to allow the instruments to stabilize and take their readings. No digging or cutting of vegetation is required to use the instruments. No generator is required as for the EM and IP surveys, as the instrument passively measures the earth’s gravitational pull. As the line is typically only hiked once, the impact to plants and soil are minimized. 4.5.5 Heli-Airborne Gravity Gradiometry surveys Though past gravity surveys have been ground based at Greens Creek, recent advances in airborne gradiometry have made this technique attractive. Similar to the Heli-Airborne EM survey discussed in section 4.5.1, a helicopter would be flown over the target area on lines spaced 200 to 400 feet apart. The gradiometer would not hang from the aircraft as in the EM survey, but stay onboard. The helicopter would fly the survey lines approximately 100 feet above treetops at a rate typically more than 20 miles per hour. If one of these surveys is commissioned, a helicopter pilot and geophysical technician will base their activities out of the Hawk Inlet facility. Depending on weather, the helicopter may fly up to the FAA specified 8 hours in a day. Any survey flown should be completed in less than five flying days. Notification of any airborne survey will be made to the Forest Service at least two months in advance. Efforts will be made to schedule the survey around other sensitive studies the Forest Service may have ongoing in the area. Page | 14
4.5.5 Borehole EM surveys Exploration activities may include borehole EM surveys. These surveys utilize an existing borehole to measure electro-magnetic responses at depth to an energized loop on the surface. The insulated wire at surface is placed as for the ground EM survey (section 4.5.2), but instead of having a person walk a receiver over the loop at surface, the receiver is sent down the borehole, taking readings at different depths downhole. Based on the intensity and timing of the response received, conductive rock can be sensed and located even though the drillhole may not have intersected it. Since this survey requires the same sort of loop as for the ground EM survey, line cutting will be needed. The loop size and dimension is determined according to target properties, but as mentioned in section 4.5.2, no more than 10 miles of line cutting will be carried out for any given year. A generator is required to provide the transmitted current. The power requirements of the generator are small, so it will typically be a portable 5 kW model. The generator and a maximum of 10 gallons of gasoline fuel will be kept at least 200 feet from running streams and in secondary containment. 4.6 Diamond Drilling 4.6.1 Drill Site Preparation Before any drill site clearing or construction takes place, the site must be approved by the Forest Service. This will follow a strict path of approval. Exact locations for each drilling site are submitted to the Forest Service by December 15 on the year before drilling. The Forest Service will review those sites in order to prescribe third party field studies, such as goshawk surveys. The third party report will be submitted to the forest service at least two weeks prior to drilling. After the Forest Service has reviewed the studies and given notification to proceed, then drill site preparation can begin. A 2 to 4 person crew, including a project geologist, is flown by helicopter to the drill site. Exact placement of the drilling pad, helipad and sump will be chosen to protect the environment and crews. The drill site will be kept to the smallest size needed to accommodate the drilling activities. If the drill site is subalpine, trees typically need to be cleared. If a natural clearing is appropriate for helicopter landing and available within 500 feet of the drill site, it will be used to avoid cutting trees for a separate helipad. Given the height of the trees and topography, the drill site clearing area will vary. While some locations will only require clearing of 0.2 acres, other areas with taller trees or difficult topography may require up to 0.8 acres. The sum total of drill site clearing for any one year will be less than 5 acres, which is reclaimed annually. That acreage includes disturbance where no tree cutting is required. As Figure 4-6 shows, cut timber will be sometimes used for constructing the drilling pad, though most of the pad is made of rough-cut, untreated lumber. The drilling pad is formed on nine cribbing platforms approximately 4 by 4 feet across to keep the platform Page | 15
up off the ground. The platform is constructed with three 12 by 12 inch beams overlain by 8 by 8 inch beams and topped with 2 by 12 inch decking to form a very stable drilling pad 20 by 20 feet square. Immediately to and downslope from the drilling pad one or two small sumps will be constructed. The size and depth of the sumps depends on the amount of drilling planned for the site, topography and depth to bedrock. Sumps will be created to minimize areal extent while maximizing stability of the drill cuttings. Once constructed, the sump is lined with an impermeable geotextile (HDPE) so that all drilling fluids and cuttings will be kept within the drillhole, sump and mixing tank system. Figure 4-6. Drilling pad construction site in timbered area. Depending on the number of trees, depth to bedrock and topography, drilling sites may take between two and ten days to construct. The only motorized equipment used on every drilling pad is a chainsaw. While chainsaw work is frequent during the first day or two, it rapidly diminishes as soon as the timber is cut and moved into place. No pesticides or herbicides will be used at the drill sites. If the drilling site allows, a 15 horsepower, flyable backhoe will aid in digging the sump (Figure 4-7). Sumps vary in size, depending on topography, trees and depth to bedrock. Typically they are four feet deep and approximately 15 feet to a side. All excavated materials will be placed to the side, so it can be replaced over the excavation in the order in which it was removed. Vegetation removed will be kept separate from the soils. As the sumps will be built with an impermeable liner, most of the water used in drilling must be recycled. If the formation rock is mostly free of clays, the sumps allow sufficient settling to occur so that settled waters can simply be pumped back into the mixing tank and reused downhole. Page | 16
Figure 4-7. Flyable backhoe. If drilling produces thick or clay-saturated return water, a mechanical clarifier will be used. Regardless of recycling rates, fresh or ‘make-up’ water must be obtained for diamond drilling activities, as water is lost to the formation rock. Figure 4-8 shows a typical drill site layout with water and sump relationships. 4.6.2 Drilling Water Supply Approximately 5 to 30 gallons per minute of ‘make-up’ water is required per drill during routine drilling conditions. This will be obtained via a motorized pump located at the nearest usable stream. The pump, fuel tank and fittings will be inspected every shift, and spill kits will be kept at the pump. The pump and fuel will have secondary containment, and managed according to section 4.7. The ‘make-up’ water will be sourced from stream reaches approved within a Temporary Water Use Authorization (TWUA) issued by the State of Alaska Department of Natural Resources (ADNR). HGCMC currently holds six TWUA permit, authorizing the use of 29 streams on the HGCMC claim block (TWUA’s F2015-109, 110, 111, 112, 113, and 114). These streams, which are approved through 2020, are highlighted in Figure 4-9. Withdrawal procedures and diversion maximums are set within the TWUA’s. (Appendix C contains TWUA F2015-109 as an example.) To withdraw the water a 2-inch intake hose is submerged in the creek after covering the intake with 1/8 inch stainless steel screen. The screened intake is also placed in a 5- gallon bucket, with holes drilled into it. Covering the intake in this manner will reduce the risk of aquatic species entrapment, and minimize disturbance of bottom sediments. After use, the screen, bucket and intake hose will be washed of organics and soil before being taken to another withdrawal location. Page | 17
Figure 4-8. Drill site layout. The bypass water (not used by the drill) will be discharged at least 100 feet downhill of the drilling pad. To ensure no erosion at the discharge point, a bucket will be placed over the outlet to slow flow and the bucket will be placed on well-vegetated ground of shallow slope. The outlet location will be inspected twice daily for signs of plant stress and erosion. If either is noticed, a new outlet location will be chosen. Page | 18
Figure 4-9. Map of streams designated for temporary water use. Page | 19
4.6.3 Drilling Activities Once a drill is flown to a drilling site, crews typically assemble the drilling parts in less than a day. The drill is powered with a 6-cylinder diesel engine that uses approximately 80 gallons of fuel per day. The engine runs approximately 20 hours per day with an average of 90-100 decibels for the drill and engine. The 3-cylinder water supply pump runs 24 hours per day at 85-90 decibels and consumes approximately 30 gallons of diesel fuel per day. Figure 4-10 shows an operating drill on a Greens Creek drill pad. For a single season, one drill can usually drill 30,000 feet. A maximum of three drill rigs will be used for 90,000 feet in one season. If a 90,000-foot program were drilled, eleven drilling personnel and one helicopter pilot would be committed for approximately five to six months. Several geologists and core-cutting technicians would also be hired, but would primarily be logging and cutting core at the Hawk Inlet facility. Coring operations begin by installing HQ3 (3.77 inch) casing through the overburden and into the first 20 feet of bedrock. The casing is then set with either bentonite or cement, to separate the overburden from drilling waters introduced or encountered during the remainder of drilling. This casing keeps the poorly sorted and unconsolidated sediments from absorbing drilling water and potentially destabilizing steep slopes. Once through the overburden, HQ (3.77-inch) coring is completed until the hole is completed or until ground conditions require reducing to smaller NQ coring (2.97-inch). Muds and polymers described in section 4.6.4 will be used to stabilize the hole and apply a ‘filter cake’ of clay on the borehole’s surface. The filter cake limits the amount of drilling fluids lost to the formation rock (Campbell and Gray 1975). Drill contractors will be required to submit daily reports detailing activities. For each shift the drilling crew must also complete an environmental and safety review as detailed on a pre-shift checklist included as Appendix D. That review includes checking of fuel tanks, containments, spill kits, fire extinguishers and sumps. Page | 20
Figure 4-10. Typical Diamond Drill Setup at Greens Creek 4.6.4 Materials and Drilling Additives In order to complete drillholes, bentonite muds and polymers need to be used. These products stabilize the borehole, remove cuttings and help separate drilling waters from the surrounding formations and groundwater. Figure 4-11 illustrates how these additives influence the flow of drilling fluids in a borehole. The right hand side of the borehole shows water escaping to surrounding rock formations while the left side shows water returning back to surface for reuse. Page | 21
Figure 4-11. Mud filter cake influencing drill waters. All of the drilling additives will be environmentally safe and certified by either the National Sanitation Foundation (NSF) International / American National Standards Institute (ANSI Standard 40) for use in potable water wells or by the Oslo Paris Convention list of substances considered to pose little or no risk to the environment (OSPAR PLONOR 2013). Though no rod lube (used to lubricate and protect the drilling rods) has been certified by the NSF, only natural, fatty acid, fully biodegradable and/or non-toxic lubes will be used. The typical drilling additives are listed in Table 4-1. Page | 22
Table 4-1. Typical drilling additives for HGCMC surface drilling programs Drilling Additives Manufacturer Environmental Certification Chemical family EZ-MUD DP GOLD® Baroid NSF/ANSI Standard 60 PHPA3 Silicate, spun N-SEAL™ Baroid NSF/ANSI Standard 60 mineral fiber POLY-BORE Plus™ Baroid NSF/ANSI Standard 60 PHPA3 QUIK-GEL® Baroid NSF/ANSI Standard 60 Sodium Bentonite QUIK GROUT® Baroid NSF/ANSI Standard 60 Sodium Bentonite NSX-Lube® Baroid Not toxic under 40 CFR 372 sec 3131 Blend QUIK TROL GOLD® Baroid NSF/ANSI Standard 60 PAC4 Soda Ash Baroid OSPAR PLONOR2 Sodium Carbonate 1 Does not meet criteria of 'hazardous waste' as defined by the US EPA (Section 313 of SARA, 1986) 2 Oslo Paris Convention list of substances Considered to Pose Little or No Risk to the Environment 3 Partially hydrolyzed polyacrylamide/polyacrylate (PHPA) copolymer 4 Polyanionic Cellulosic Polymer While drilling bedrock, the driller keeps 300 to 400 psi fluid pressure on the bit where the rock is being cut. In normal bedrock drilling conditions, an additive such as QUIK-GEL® viscosifier is mixed into the drilling water to keep approximately 15-25 pounds of product for every 100 gallons of water (Baroid 2011a). If the fluid pressure is noticed to drop or if drilling waters return slower than normal, the driller recognizes that the drilling fluid is being lost to the formation in what is called a Lost Circulation Zone (LCZ). As LCZ’s may signify broken or faulted rock, they are immediately addressed by the driller. Faulted rock may break off onto the drilling rods, trapping the rods in the hole. Alternatively, the rock could fall out when the rods are pulled to change a worn down cutting bit, and bridge off the hole so that a new hole must be started. As this is a costly risk, products such as N-SEAL™ and QUIK-TROL GOLD® are added to lower the water loss and promote hole stability in LCZ’s. Depending on the nature of the LCZ, up to 70 pounds of N-SEAL™ or 4.75 pounds of QUIK-TROL GOLD® may be added for every 100 gallons of water (Baroid 2012 and Baroid 2011b). These controls are applied until fluid losses are back to normal. In the unlikely case where a borehole begins to produce water due to a confined groundwater system, products such as QUIK GROUT® or cement may be applied to seal the LCZ or producing formation. If the artesian conditions are not quickly resolved, the hole is sealed and abandoned. Mechanical packers are kept at the drill to stop artesian waters until the seal can be made. Page | 23
4.6.5 Hole Abandonment The Alaska Department of Environmental Conservation (ADEC) is the State of Alaska’s lead agency for Water Quality Standards and has set forth the Alaska Department of Natural Resources (ADNR) as a lead for determining mine related guidelines. Together with ADEC, ADNR requires exploration drill programs to abandon boreholes according to the Hardrock Exploration permit which ADNR issues. In that permit it states: “All drill hole casings shall be removed or cut off at, or below, ground level. All drill holes shall be plugged by the end of the exploration season with bentonite hole plug or equivalent slurry, for a minimum of 10 feet within the top 20 feet of the drill hole. The remainder of the hole will be backfilled to the surface with drill cuttings. If water is encountered in any drill hole, a minimum of 7 feet of bentonite hole plug or equivalent slurry shall be placed immediately above the static water level in the drill hole. Complete filling of the drill holes, from bottom to top, with bentonite hole plug or equivalent slurry is also permitted and is considered to be the preferred method of hole closure during which they are drilled, unless otherwise specifically approved by the DMLW.” (DNR Alaska) All HGCMC surface boreholes will be reclaimed according to this guidance by the ADNR. After the hole has been completed, it will sit for two hours before being sounded for water. If the water table is encountered, the borehole will be backfilled with drill cuttings or bentonite to just below the water table. Appropriately sized bentonite hole plug will be trimmed to the water table using a hose for a minimum depth of 7 feet. The hole will then be filled with drill cuttings up to 20 feet from surface. All holes will have the casing removed and be capped with hole plug for the top 20 feet of the borehole. 4.6.6 Drill Site Reclamation All tools, trash and dimensional lumber will be removed from the drill sites as they are completed. Non-recyclable lumber will be burned within HGCMC’s Forest Service prescribed burn pits at the mine site, and trash handled according to HGCMC’s permitted solid waste disposal plan (see section 5.20). The drilling platforms will be completely disassembled, with timbers lying either directly on the ground or resting only two high. If a drilling platform is to be used the following year, it will not be disassembled. However, no drilling platform will remain constructed for more than two years. All sumps and any bare ground will be reclaimed the same season as drilled, regardless of plans to re-use a drilling platform the following year. Excavated topsoil and organically enriched topsoil will be placed over the excavation in the reverse order it was removed. Native vegetation, set aside during excavation, will be used to top the filled excavation. If an area of bare soil cannot be coved by native soil and vegetation, it will be covered with seedless straw or coconut fiber (coir). Before 2016, seedless straw was used to cover bare earth, but the Forest Service has requested in the 2016 Greens Creek Surface Exploration Decision Memo that coir matting be used instead when available and Page | 24
practical. To follow this guidance, bare earth not overlain with natural vegetation will be covered with coir matting when available and practical. Seedless straw will only be used as a last resort. Though no seed mix has been applied to reclaimed drill sites in the past, HGCMC will reseed disturbed areas with a seed mix if the Forest Service so prescribes. Fill materials will be mounded slightly (2 to 3 inches) above ground surface to allow for future settling. Sites will be contoured to prevent erosion and mimic, as closely as possible, the original topography, but maintain less than 15% grade. Sump geotextile will be cut back to ground surface, with excess fabric removed from the drill site. All reclamation shall take place in the year that disturbance was made. The only exception will be a drilling pad, not including its sump, if it is to be used the following year. Photos will be taken of each drill site before any disturbance takes place and after reclamation is finished. Those photos will be submitted to the Forest Service as part of a yearly activity and reclamation report, to be submitted by December 15 of each year. Drill sites will be visited two years following reclamation to determine if winter snow loads or spring melt have damaged reclamation efforts and if invasive plants are present. If noxious weeds are present, they will be pulled by hand and removed from the site in garbage bags for landfill disposal. Herbicide will only be used if the weeds cannot be eradicated by hand pulling and only at the direction of the Forest Service. These visits will be documented in the yearly activity and reclamation report to the Forest Service. 4.7 Spill Prevention and Waste Disposal 4.7.1 Spill Prevention Control and Countermeasures (SPCC) HGCMC handles petroleum products according to a professionally engineered and approved Spill Prevention Control and Countermeasure plan as required by the Code of Federal Regulations (CFR) Title 40 Section 112. Though petroleum handling precautions and countermeasures are described in the SPCC plan, the following discussion addresses those aspects of the plan directly applicable to the exploration plan. 4.7.2 Fuel transport and storage Jet-A helicopter fuel is transported to the mine in 6,341-gallon portable tanks of US DOT Type IM 101. One tank is kept near Hawk Inlet and another is stored closer to the mine portal at the ‘860’ laydown as shown in Figure 4-12. The helicopter fuels directly from these two sites. The locations were chosen in order to maximize efficiency in mobilizing crews from the man camp at Hawk Inlet and drilling supplies stored at the ‘860’ laydown area. Both tanks and pumps have secondary containment made with chemically resistant polyethelyne liners. Spill response kits are kept next to the pumps. Type 2 Diesel fuel for the drill and water pumps is managed by mine personnel according to the SPCC plan. The fuel is stored in Greens Creek Mine managed tanks and transported using their fueling “lube” truck. At the ‘860’ laydown, 30-gallon, double walled, aluminum, flyable fuel tanks will be stored in secondary containment. The lube Page | 25
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