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TRUE NORTH PROJECT UPDATE
October 2001
Since the Alaska Department of Natural Resources (DNR) issued the project authorizations for the True North Project on December 20, 2000, Fairbanks Gold Mining Inc (FGMI) has hauled over 1.5 million tons of ore to the Fort Knox Mill for processing. During this time, DNR’s administration of the authorizations has included processing minor revision requests and conducting regular inspections of the project area. DNR has found FGMI’s operations currently to be in compliance with all authorizations.
This update addresses concerns sent to DNR by e-mail since August 1, 2001. The update is divided into the following categories:
General Compliance Concerns. Concern has been expressed that DNR is allowing FGMI to change their operations in ways that are out of compliance with their authorizations. A review of the facts shows that this is not the case. The right-of-way authorization does not cover the methods and means of FGMI’s entrepreneurial mining decisions, rather the authorizations are designed to anticipate the effects of the mining operations. By its nature, a mining operation needs to be able to adjust in reaction to unforeseen circumstances. Correspondingly, government agencies need the ability to work with the mining companies to administer the authorizations so that these adjustments can be accommodated within the intent of the original authorizations. For example, since one intent of the authorization here is to keep noise levels at nearby residences below a certain standard, the mining company should have a certain amount of flexibility to adjust operations as long as the noise standards are adhered to.
As a second example, there has been some concern expressed that the increased number of trucks is a violation of FGMI’s right-of-way permit for the haul road. The stipulations of the right-of-way permit do not restrict the number of trucks that FGMI can use to haul ore. Rather, the stipulations address the mitigation of the adverse effects of noise and lights from the haul trucks. With regard to noise, FGMI must still keep noise levels below the standards set in the right-of-way’s stipulations, even with the increased number of trucks. Furthermore, since light and noise were of particular concern during the evening and night hours, DNR has temporarily amended the Plan of Operations to authorize the increased number of trucks only from 7:00 a.m. to 7:00 p.m. DNR is administering the permit to meet the stipulations, as well as to minimize the effects of noise and lights on the nearby residences.
Additionally, while DNR anticipated that a reduction in the allowed operating hours (to meet the noise standard) could result in an increase in the number of ore haul trucks (Decisions Overview, page 67), this is certainly not the only possible scenario that could result in such an increase or other change in the plan of operations. It is just one circumstance that DNR anticipated. It certainly is not the only possible scenario and was never billed as such.
There has also been concern raised that these changes to the authorizations have been done without any public notice. As stated above, it is important for DNR to be able to work with the permittee to accommodate changing conditions at the mine site. DNR must have the flexibility to approve changes without public notice if those changes are within the intent of the original authorization. However, DNR will give public notice if the department determines that a change to the authorizations will significantly change the effect of the operation on persons or the environment.
Are the vendors and employees using the new haul road? Some individuals expressed concern that FGMI-related traffic has not shifted to the new haul road. The shifting of the FGMI related traffic from Fairbanks Creek is not an enforceable stipulation of DNR’s right-of-way authorization. However, DNR has been working with FGMI to ensure that every effort is being made to route all vendor and employee traffic onto the new haul road, as suggested in its right-of-way decision. DNR recognizes that the shifting of traffic to the new road has taken longer than it initially had anticipated. In part this was due to delays in construction of the road. Further, it seems that the vendors and employees were simply reluctant to change their habits. However, at DNR’s insistence, significant progress seems to have now been made. DNR has been copied on correspondence to vendors that directs their use of the new haul road as a condition of their contracts. FGMI is also stepping up efforts to reduce the incidental use of the old road by its employees. Recent DNR inspections show that the great majority of mine-related traffic is using the new haul road.
Last month, FGMI moved their Caterpillar 994 loader from Fort Knox Mine to the True North Mine using the Fish Creek and Pedro Dome roads. DNR received complaints that the loader should have used the new haul road. At the time that the loader was moved, Fish Creek Road was being maintained by FGMI and DOT authorizations were not necessary on either Fish Creek or Pedro Dome roads. The loader was moved because the smaller loader working in the True North Mine was down for repairs. FGMI used the Fish Creek and Pedro Dome road route because this 994 loader is a large and heavy piece of machinery, and will not fit under the underpass. Also, there was significant concern that the heavy loader would have damaged the asphalt on the Steese Highway if it had used the ramps to cross over the underpass. Such a move of this loader will be a very infrequent event, and DNR will work with DOT, as needed, and FGMI during future moves, if any, of the loader to decide on the appropriate route. DNR concludes that the very infrequent use of the public roads by a piece of mining equipment does not violate the authorizations.
What is the status of the Fish Creek Road? DNR has been asked about the status of the Fish Creek Road. DOT has conducted its inspection of the portion of the Fish Creek Road between the Steese Highway and Twin Creeks Road, and is now in the process of closing out the maintenance agreement with FGMI. DOT will be responsible for the maintenance only of that portion of the Fish Creek Road from the Steese Highway to the Fairbanks Creek Road.
How are dust problems being addressed? DNR received a number of e-mails concerning dust problems on the new haul road. The e-mailed concerns about dust can be divided into three main categories: Is the dust toxic? Does the dust settle make the Steese Highway overpass dangerous for the public? Are there visual concerns from the dust?
Is the dust toxic? No, the rock that is being used to surface the new haul road is not toxic, and will not produce toxic dust. The fill material that is being used for surfacing the road is granite from the Fort Knox mine. The granite was analyzed during the initial Fort Knox Mine permitting process and was found to be non-toxic. Also, all the granite is analyzed quarterly, and test results are submitted to DNR and DEC. Further, the Mine Safety and Health Administration has also evaluated the dust from the rock with respect to worker safety, and has found no problems with the material. Finally, this fill material meets or exceeds Department of Transportation standards, and will generate considerably less dust than the schist that both the Fairbanks Creek and the access haul road were constructed from.
The processes at the Fort Knox mill do not concentrate heavy metals in the material used on the haul road, they simply extract the gold from the ore. ADEC believes that the dust generated along the haul road is not unlike dust generated from any other gravel road in the area. The probability of heavy metals being carried to the water table by rain or road watering is not elevated as a result of the haul road. The road was built from materials naturally occurring in the area and previous groundwater sampling in the source area of the material showed no significant contamination due to heavy metal leaching.
Does the dust make the Steese Highway overpass dangerous? Some e-mails have indicated that dust settles out from the road onto the Steese Highway overpass and can make the road slippery. FGMI is washing the road at the overpass location. Also, road safety issues like this one falls under the jurisdiction of the Alaska Department of Transportation. DNR brought this issue to DOT’s attention. We were told that they saw no safety issue. Thus, DNR does not believe that there is any compliance problem.
Visual concerns. With respect to visual concerns about dust, DNR has required FGMI to take all feasible and prudent steps to minimize dust. Specifically, FGMI has chip-sealed the road, applies calcium chloride, and has watered the road frequently. FGMI continues to apply calcium chloride in an effort to minimize the dust generated from the haul road traffic. The high-floated section of the road has significantly reduced dust levels. Ore that had spilled on the haul road has been removed, so no dust is being generated from True North ore. In their inspections, DNR staff have observed far less dust from the new haul road than from the other local unpaved roads in the area. In the winter, FGMI plans to pack snow on the haul road during periods where dust becomes a problem. DNR inspectors will continue to look for dust problems, and we will work with FGMI to ensure that it continues the dust mitigation efforts.
How many trucks are hauling ore? We have received concerns that FGMI is using greater-than-the-allowed number of trucks to haul ore. FGMI continues to use their fleet of 9 60-ton trucks in addition to 10 contractor operated trucks. There is no restriction within the right-of-way permit or the stipulations regarding the number of trucks that may haul ore on the right-of-way. Under the plan of operations, DNR has authorized 10 contractor operated trucks for use through December of 2001, during daytime hours only (7:00 am to 7:00 pm). The only exception to this is to occasionally substitute for an FGMI 60-ton truck when it is down for repairs, but the total number of trucks operating during nighttime hours still must not exceed 9. The nighttime restriction is because of the lights. The major daytime issue is noise, which is addressed by the noise standard which all trucks, individual and cumulatively, must adhere to.
Some of the contractor-operated trucks are pulling tandem trailers. There is no restriction within DNR’s right-of-way authorization regarding the use of tandem trailers. Tandem trailers are allowed on most of the state highway system by DOT and are co-mingled with general traffic. As such, the tandem trailers do not present a significant safety issue. There may be some added maintenance issues for the right-of-way due to the use of the tandem trailers. However, since FGMI is doing all maintenance on the new haul road, DOT does not have an issue with the use of the tandem trailers on the new haul road.
Do all the trucks have the Donaldson “Silent Partner” mufflers? No. Only the FGMI 60-ton trucks are equipped with these mufflers. These 60-ton trucks have larger engines than the contractor-operated trucks, and must have the special mufflers to reduce noise levels to within the standards that DNR has required in the approved Noise Monitoring Plan. The contractor-operated trucks are quieter than their larger counterparts, and can meet the noise standards without the special mufflers. Each contractor-operated truck is required to be certified as meeting the 82 dBA standard set by the Noise Monitoring Plan. Additionally, as noted above the 60-ton trucks and the contractor-operated trucks together must meet the noise requirements of Stipulation #33 of the right-of-way decision. As discussed above, the right-of-way stipulations address mitigation of the adverse effects of noise from the haul trucks. The use of the Donaldson Mufflers is not required by stipulation.
Ore Spillage. DNR received some concerns that ore was falling off the trucks or that trucks were being loaded in such a way that ore could fall off, and that the ore could be dangerous to public vehicles driving on the road. The Alaska Department of Transportation has the expertise to evaluate public safety concerns. Once DNR received these concerns, the department immediately contacted DOT and asked DOT to send an inspector to verify the concerns. DOT’s first inspection on this issue occurred in July. DOT indicated to DNR that ore loaded into the truck beds was unlikely to cause a public safety hazard. However, they also indicated poor loading techniques were in some cases, resulting in ore on the vehicle chassis. This ore could vibrate off onto the public sections of the road. At DNR’s direction, FGMI has taken measures to eliminate spillage of ore from their trucks. This has been achieved mostly through improved loading procedures. In the last two months, DNR inspectors have not observed any spilled ore on the haul road, and have not received any complaints from the public about spilled ore on the haul road.
In order to reduce spillage, FGMI had considered installing sideboards on the 60-ton trucks, but abandoned this effort when they were notified that truck warranties would be voided if the sideboards were installed. In any case, the issue has been resolved without the sideboards.
Noise Monitoring. Noise monitoring at the residences was conducted in August, by Nortech, and supervised by the state’s consultant, HMMH. The monitoring was conducted at the Johnson and Walyer residences, both during the daytime and at night. The final report on this monitoring was submitted to DNR by Nortech on September 20, 2001. The report found that the noise levels from the True North Project ore haul trucks were at or below the standards set out in the right-of-way permit (Stipulation #33). At the time that this noise monitoring study was done, FGMI was running 60-ton ore trucks and the contractor-operated haul trucks. Even with the additional ore traffic, the noise at the residences fell within levels set in the right-of-way stipulations. To ensure continued compliance with the noise standards, in accordance with the noise monitoring plan, additional noise monitoring will be conducted this winter.
DNR had delayed its final approval of FGMI’s noise monitoring plan until the results of the noise monitoring were available (this was done because the results of the monitoring could have dictated some changes in the monitoring plan). Now that the initial noise monitoring has been completed, DNR has issued its final approval of FGMI’s True North Project Ore Haul Truck Noise Monitoring Plan. Copies of the plan are available for review at DNR offices in Fairbanks and Anchorage.
The noise monitoring plan requires FGMI to provide DNR with noise monitoring equipment necessary to provide ore haul truck verification monitoring. This equipment will enable DNR inspectors to conduct random checks on the noise levels generated by the ore haul trucks. These random checks will begin this winter. The use of these random checks will ensure that FGMI does not get advance notice of the noise monitoring and DNR can ensure that the noise levels mandated by Stipulation 33 are being met.
It is DNR’s intent that Stipulation 33 governs the ore hauling traffic. While the use of the language “True North/Ft. Knox related traffic” may have been unfortunate in that it could be subject to more than one interpretation, it has always been DNR’s intent that Stipulation 33 govern only FGMI’s use of the road, i.e., the ore hauling traffic. This is made clear by: 1) DNR’s reference to “FGMI’s use of the haul road;” 2) the fact that the Noise Monitoring Plan had to be submitted “prior to commencing ore hauling” (ie., the traffic that would be subject to the stipulation); 3) the fact that the plan had to look at whether “each haul truck” complied with the noise levels (as well as the trucks collectively); and 4) the fact that if the noise levels were not met, the ultimate control was prohibiting ore-haul traffic (ie., the traffic that is governed by the stipulation) during nighttime hours. Stipulation 33 does not govern shift change traffic, vendor traffic, or the ambient residents-related noise levels. See Decisions Overview at p. 45 (“will not be applied to the shift-change traffic that now occurs on Fish Creek Road that will be relocated to the new haul road”). Further, in accordance with the stipulation, the existing ambient levels are subtracted out when determining whether the ore haul traffic complies with this stipulation (Stipulation #33 noise levels are not to be exceeded “based upon the existing ambient noise”). What DNR is controlling is the increased impact to the surrounding residents (not the noise that already exists), as well as the sources over which FGMI has direct control (the ore haul trucks). DNR has issued its final approval of the Noise Monitoring Plan and finds that it is consistent with the terms of Stipulation 33.
Lights. On September 13, 2001, FGMI submitted to DNR the results of their research into further mitigation of the effects of the indirect light from the ore truck headlights. FGMI’s conclusion is that any mitigation effort that would lessen the light output of the headlights would not meet Federal Motor Vehicle Standards, and might compromise the safety of FGMI’s employees and other users of the haul road. However, DNR has requested that FGMI continue to experiment with other means of reducing light impacts, including extended light hoods on the headlights in an effort to minimize the indirect light shining on the residences.
Concern has been raised that there is direct light shining from the headlights into some residences, as evidenced by visible shadows in the residences. DNR observed light from the ore haul trucks at Chuck Johnson’s residence and Tom Walyer’s house in its initial light review/road alignment inspection. Based on its onsite inspection, it is DNR’s judgment that the truck headlights are oriented so that the bright inner beam shines down on the road in front of the vehicle even when the road is pointed in the general direction of the residences. Further, in the sections of road that point in the general direction of the residences, the road is nowhere at an uphill grade necessary for the headlights to shine directly at the residences (which are about one hundred feet above the level of the road). We acknowledge that it may be entirely possible for the indirect light from headlights to cause shadows.
In DNR’s determination, the road has been designed so that there is no direct lighting from truck headlights to any of the residences. While it would have been ideal for the residents if there had been absolutely no light impact on the areas surrounding the right-of-way, the use of the right-of-way will result in light impacts. Stipulation #32 is designed to eliminate direct lighting impacts to the residences; it is not designed to eliminate all impacts. Throughout the public process, DNR recognized that there would be impacts from headlights and taillights on the residences that would not be mitigated by Stipulation #32.
Late compliance. Under Stipulation #32 to the haul road right-of-way, FGMI was required to submit to DNR a report of the experiment/evaluation of measures designed to reduce the effects of lights on the residences in the area. FGMI did not submit the report to DNR until September 13, 2001. In order to ensure that FGMI complies in a timely manner with all future deadlines, DNR has instituted a calendaring system that lists future deadlines and milestones.
If any member of the public has complaints, comments, or questions about the True North Project, or would like to review any of the documents discussed above, they should contact either DNR (Tom Crafford, 269-8629, tom_crafford@dnr.state.ak.us) or FGMI (Security, 488-4653 x2875).
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