(Ministry of Energy, Mines & Petroleum Resources) to

Archie/Lisa, Below are MEMPR geotechnical review comments on the Roman Coal Project. They were prepared by our geotechnical engineer Ramy Kamel. Kim Kim Bellefontaine, M.Sc., P.Geo. Senior Environmental Geoscientist Mining & Minerals Division B.C. Ministry of Energy, Mines & Petroleum Resources P.O. Box 9320, Stn Prov Gov't, Victoria, BC, V8W 9N3 ** Courier: 6th Floor, 1810 Blanshard Street, Victoria, BC, V8T 4J1 Phone: (250) 952‐0489 Fax: (250) 952‐0481 E‐mail: [email protected] ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ The Roman Coal Mine Project Environmental Assessment Report outlines a clear mine plan, mine sequence, general schedule etc. The application also contains a clear list of existing facilities at the Trend Mine that will be needed to support production at the proposed Roman as well as the new components required for the proposed. The proponent application indicated the following main Roman Mine components: • Open Pits: 3 linear pits, Large Central Gates Pit, flanked by shallower Gething Pit North and South. All pits have Northwest to Southeast alignment. • Conventional truck and shovel method of open pit mining advancing from northwest to southeast. • Waste Dumps: 3 major Dumps, North Dump and East Dump, both located north of the Pits. South Dump located south of the pits. • In Pit (Gates Pit) TSF • Salvage Soil Stockpiles: several scattered stockpiles located north and south of the open pits. • Plant Site which includes, Portable Treatment Sewage Plant, Maintenance Shop, Warehouse, Offices, Wash Plant, and Fuel Island. • Several Sediment Ponds (in pit Pond RP‐3 is a Tailing/Sedimentation Pond). • Various other infra‐Structures, Access Roads, and other Trend Mine Facilities that will support Roman Mine Operation. Comments: 1. The conceptual design parameters for the open pits seem reasonable. Wall stability, angles, bench heights and width assumption seems to be agreeable to industry practices. Full detailed design will be need at the Mines Act Permitting Stage. (Mines Act Permitting Requirement) 2. The design assumptions for waste rock dumps appears to adhere to the Mined Rock and Overburden Piles, Investigation and Design Manual Interim Guidelines by the British Columbia Mine Waste Rock Pile Research Committee. The initial waste dump foundation investigation does not reveal anything of concern. The design as presented is conceptual in nature and satisfactory at the EA stage. Full design, slope stability, failure mode, and run out analysis will be required for Mines Act Permitting (Mines Act Permitting Requirement) The concept for tailings management is to dewater and place tailings with potentially ARD generating (PAG) coarse coal refuse (CCR) in waste rock dumps for the first 2 years. After that time, tailings and will be deposited directly via a pipeline into the in‐pit tailings pond (RP‐3) in the west side of the mined out Gates Pit. PAG CCR will be trucked and deposited into the pit in a manner that will allow its complete submergence. The current water balance suggests that a positive water balance exists and that the pit could be in an overflow position by year 6 of operations. 3. The information presented for the in‐pit tailings disposal facility is very conceptual. There is concern that geotechnical, hydrological or mine waste sequencing issues could result in the plan being non‐feasible in practice and/or could result in discharges that are not currently assessed as part of the impact assessment. Additional details of volumes of waste to be disposed, waste scheduling, water balance, pumping rates, geotechnical information etc. should be provided to demonstrate that in‐pit tailings disposal is technically feasible, or contingency plans that include the assessment of potential effects, should be provided. (EA Information Requirement)