Member Info for scotalba

So the deadline for the the second water permits consultation period will be tomorrow 28 June, with the first permits consultation period having ended on 16 June, we wonder how long before a decision?

It will depend as to what has been submitted via the consultation period. Every response has to be read and each opinion considered for each specific permit before a decision is made. Lets hope for a quick turnaround, and news to follow ASAP.

Part three,A v-notched weir was installed 10m into the drainage adit. The CTD diver was then deployed at this site to record the water quality and changes in depth of the water passing over the weir. From this, the discharge flow from the Llechfraith drainage adit was determined.

· The Afon Cwm Llechen responds quickly to rainfall and exhibits significant changes in level. A second Van Essen diver was therefore used at one of the sampling points to record variation in river depth.

· All samples were assayed at the ALS specialist laboratories in Coventry, for water quality, namely elemental composition and electrical conductivity.

(4) In total, since its original application in January 2021 Alba has submitted a further 10 rounds of responses to enquiries received from NRW, with the current report being compiled to inform the NRW’s HRA being the 11th such submission.

Given the robustness of its dewatering proposals, the support of its highly experienced technical consultants and the confidence derived from the extensive supporting data compiled over the past 18 months or so, which has confirmed the relatively benign nature of the mine water, Alba is confident in the merits of its application and proposed scheme and remains hopeful of a positive outcome soon.

As we all know on the 29 October 2021. The permit was refused because of the bats and otters, Judge for yourself, if Alba how the management have done.

Part two. NRW issued its consent yesterday, 21 September, and Alba’s geologists were therefore able to collect the sediment samples from the estuary yesterday. As a result, it is expected that Alba’s report will be submitted to NRW in the next week or so, with a supplemental appendix being submitted once the estuary samples have been assayed at the ALS Laboratories (which normally involves a turn-around time of a few weeks). Given the time this process has taken to date, NRW has indicated to Alba that it will carry out its HRA as quickly as possible in order to proceed swiftly to a determination of Alba’s application.

Although Alba understands NRW’s concern as regards the potential impact of the discharge of water from any former mine into a watercourse, Alba has taken great care, and taken the best available advice, to devise a robust dewatering scheme and to ensure that any water discharged into the watercourse post-treatment in the manner proposed will not have a detrimental effect on the environment. Indeed, Alba’s and NRW’s concerns are completely aligned in that regard. It should also be noted that:

(1) The flooded lower workings are estimated to hold 800m³ of water, or about 1/3 of the volume of an Olympic-size swimming pool. With the water to be pumped at a flow rate of up to 4.2m³/hr (100m³/day), it is estimated that the lower workings would be dewatered within just eight days.

(2) Discharge from the drainage adit is not currently treated and has never been treated since mine abandonment in 1998. By contrast, Alba’s dewatering scheme involves:

· Water pumped out of the lower workings being first passed through two Siltbuster HB10 settlement tanks, operating in parallel and each with a capacity of 10m3/hr, with no settling reagents to be used.

· The electrical conductivity (EC) of the water being manually monitored on a daily basis (in Phase 1) and on a monthly basis (in Phase 2).

· Collected settled solids being assayed to determine if any gold or deleterious elements are present.

(3) A substantial amount of data has been compiled by Alba to date to support its application, including the following:

· 12 rounds of water sampling have been undertaken over the course of the best part of a year. Samples were taken from five sampling points, upstream of the mine, downstream of the mine and from the current discharge itself.

· The flooded Llechfraith Shaft has also been sampled and profiled. The water column in the shaft was profiled by lowering a Van Essen CTD diver, that was set to record water depth, temperature, and electro-conductivity every second. In addition, a profile was made of water temperature, electrical conductivity (EC), pH, dissolved oxygen (DO), and redox potential (ORP – which measures whether the water is reducing or aerobic), using an in-situ Aqua Troll 600.

· A v-notched weir was installed 10m into the drainage adit. The CTD diver was then deployed at this site to record the water quali

The report below shows some of what Alba has had to go through before the dewatering permit was rejected in 2021, because of the bats and otters. This just shows how complicated a process it has been, and also I think shows how well Alba have done so well.

Its been a long drawn out process, but when its all over with, it will be all stations go.

With the HRA future applications should be easier.

Dewatering Permits Report

In January 2021 Alba submitted an application to Natural Resources Wales (“NRW”) for a permit to dewater the flooded Llechfraith Shaft and discharge the treated water into the neighbouring stream. Alba’s ecological and environmental team has been led by Alba’s ecological consultants ENVSYS and Alba’s consulting geochemical engineer Dr Matthew Dey CEng MIMMM of Geochemical Engineering Solutions Ltd, UK, with support from Mr Alistair Black, Principal Hydrogeologist & Director, Groundwater Science Ltd.

Originally, Alba was informed that only a Discharge Permit was required. Then, in late May 2021 NRW informed Alba that a Transfer (or Abstraction) Licence would also be required. In June 2021 NRW indicated to Alba that a decision would be made within a few weeks. However, on 1 July 2021 NRW issued a formal notification (known as a Schedule 5 notification) seeking further information in relation to the proposed scheme. Alba provided the requested information on 8 July.

More recently, however, NRW has informed Alba for the first time that it intended to undertake a Habitat Regulations Assessment (“HRA”) and requested that Alba submit a detailed report to assist it in that assessment. This was discussed in a meeting in August between NRW and Alba.

Since then, Alba’s environmental and ecological team has been compiling a detailed report to inform the NRW’s HRA, the overall objective of which is to assist NRW in its assessment of any potential impacts of the dewatering exercise on the integrity of the Special Areas of Conservation (“SACs”) situated closest to the mine. Those SACs are the Lleyn Peninsula and the Sarnau SAC, which commences 1.14km to the south of the Llechfraith adit, and the Meirionnydd Oakwood and Bat Sites SAC, which commences 1.4km to the east of the mine. As part of this exercise, Alba’s report reviews the locations of these sites and their qualifying features in relation to the mine, identifies any apparent effect pathways and then gives consideration to the likely significance of any potential effects identified on both SACs.

While Alba’s report has been largely completed, its final sign-off has been delayed by NRW’s request that further sediment samples are taken at a location in the estuary approximately 1 km downstream of the mine, which has necessitated obtaining the relevant landowner’s (and indeed NRW’s) formal consent. NRW issued its consent yesterday, 21 September, and Alba’s geologists were therefore able to collect the sediment samples from the estuary

Last Post on this one,

I was under the impression that the two water licenses applications would be under the same NRW ref Number, this is not the case.

If its of interest, the ref Number to look out for for the -Full Water abstraction Licence application :consultation ends on the 28 June 2023 - is PAN-020353. I put it in the NRW public register search, but nothing came up as yet.

@Prentice

Agree 100% with you on the "comments"

Do let us know what you see and find when you visit.

For clarity on the type of permits and dates. To the best of my knowledge.

1. The (Environmental Permitting Regulations permit application) this I understand is the water quality permit consultation ends :16 June 2023

2. Full Water abstraction Licence application :consultation ends on the 28 June 2023

3. Species license...no consultation needed, unless it is deemed to be of great public interest.

We have also been told that the decision of all three applications will be announced simultaneously.

My thoughts, I would think very carefully before sending any comments to NRW on Alba's permitting issues. myself, I will not be commenting.

Something else to mention the Full abstraction Licence application consultation ends on the 28 June 2023.

The (Environmental Permitting Regulations permit application) as mentioned ends on the 16 June 2023.

I was very happy with the Vox and q and A,

I put the following questions to Alba/ George F and to his credit he answered them directly. I am happy with his answers and it ties in with the information I have been getting and putting on this message board. All very positive.

1. Are Alba's water permit applications now duly made assessed, I ask because the applications now appear on the NRW website as open for public consultation, but no information on the permit applications is available to be viewed.

2. Has the HRA been approved now, so no more information is required by NRW by Alba for the HRA/EPSL applications

This was public consultation link from yesterday in case it is of interest.

https://naturalresourceswales.gov.uk/permits-and-permissions/permit-applications-consultations-and-decisions/current-consultations-environmental-permit-applications/gmow-operations-limited-1/?lang=en

@Herbert @ devil

I think my man and dog are now away for the weekend, talked to them today, but nothing more to add apart from website has been updated. I am thank full that NRW updated the website before the long weekend and did not leave us hanging a few more days on updates.

I think DevilsDate has said it in a few words "This is absolutely HUGE news"

I did inform NRW that that they had stated the new permits applications were up for public comments. I did get a reply just before they updated them that they had now been updated. They did not mention the "Duly Made" words, although I did not directly ask them that question. I have been told that previously that "Details of all new water quality discharge applications are made available on the public register when an application has been deemed Duly Made" "Details of the abstraction application will be available on the public register once the application is validated" As you all know as far as I am concerned "Duly Made" says we will get the permits 100%, as to me its totally inconceivable NRW will not issue all the and permits licenses currently under application once Duly made has happened. For many reasons I believe this. Refusal would have happened prior to this stage. So for me its a very major milestone, and I will be having a cold beer for a little celebration this evening. Only thing that can derail Alba now would be the public consultation, I can not see that being a problem. In case anyone points it out, yes Alba were denied the permits after being "Duly Made" last time, but this is one of the reasons that supports my conviction that it will not happen again once Duly Made (no need to go into all that again) I really hope I don't have to type that Duly made word again, I am sick of it.

All just my opinion of course.

I just have to correct my self, I said "I am led to believe public consultation of the water permits would only start when it was certain that the European Species license would be granted" this comment is NOT correct. I meant to say, I am led to believe that public consultation of the water permits would only start when the HRA has been approved. I have been told that the European Species license will be determined along with the water permits, so that would have to be after the public consultation period.

So my thinking just to clarify is, if the water permits have been duly made, this should mean the HRA has been approved(that will mean the EPS is a slam dunk) so everything will be granted after the public consultation period.

Will the fact that the permits have been duly made warrant an RNS, I think it should, but will we get one, not so sure.

sorry to make things so confusing.

Have found this on Public data base, but no direct link as yet to any document information using the new application number. I don't know if anyone has seen this before or if it is a new addition to the NRW site. I am trying to confirm a few things with the powers that be. Will let you know if I here anything.

"New bespoke application for an environmental permit under the Environmental Permitting (England and Wales) Regulations 2016

Application number: PAN-019729

Regulated facility type: Settlement Tanks

Regulated facility location: Bontddu

NGR discharge point: SH 66 19

Receiving environment: Afon Cwm-Llechen

Effluent type: Treated trade effluent

Volume: 100 cubic metre per day

You can see the application documents free of charge, from our online public register. You can search for the documents using the application details, above. Or you can request a copy of the information from us. This may take time to process and there could be a charge.

If you have any comments send these by 16 June 2023"

Comments on the water application would need to be sent to NRW by 16 June 2023...

Looks like things are finally moving.

I have reason to believe information regarding water permits public consultation should be IMMINENTLY available on public data base.

It could be under new Application number: PAN-019729.

If this is the case, this means the permits are or soon to be "Duly made" this is big good news.

Again if this is the case, I would hazard a guess that the HR A/Species license has been or is as close as it can be to being granted, as I am led to believe the public consultation of the water permits would only start when it was certain that the European Species license would be granted. Also remember the Species permit application information is not published on the public register as there is no legal requirement to do so. So only NRW and Alba will know when the species license has been granted.

Agreed Robbie

I was not going to reply either, I think I will not post on this subject anymore, unless I get some new info.

As you say "best consultants in the business who routinely work with NRW, we can only provide what NRW ask for"

All we can do is wait.

At the start of the process to obtain a European Species License, Alba consulted with NRW and then produced a draft HRA .

This draft HRA is comprehensively studied by NRW and then feedback is given to Alba on the document, and the document is returned to Alba to finalize before final submission. During this period( we are in this period now), before final submission of the HRA, Alba and NRW are in constant back and forth consultation. To the best of my knowledge this was going smoothly and Alba had been providing all the information asked of them, until NRW decided to widen the reach of the HRA to take in the entire Clogau site rather than just the mine workings. This redirection by NRW has ment that Alba have had to produce alot more, data, plans ect to satisfy the new area for the HRA. NRW have been adding to the information required by ALBA as this process develops.

For example, NRW ask Alba , can we have a plan for a movie room so the bats can watch TV, Alba provide the plans, then NRW reply, thanks that is perfect, but now we also need a plan for where the pop corn machine will be situated. This approach by NRW has contributed to this application dragging on and on and on. The information Alba have been supplying has been what has been required at the time of asking.

I do think ALBA done everything they can for this ongoing HRA application and are not to blame at all or the length of time it has taken. NRW staffing issues have also to be taken into account, this has seriously delayed things, no fault of Alba. I do understand its very complex, and NRW have to get it right, that is the way.

@asllankukeli

A quick response to your post, on a couple of statements.

1. "Can we at least agree that its not all NRW doing. Like it or not, bats are protectes species , as such any palning aplication needs some sort of ecological report to mitigate any damage or disturbance.

GF and team did not know this initialy, however they were made aware last year By NRW.

1. Alba have always known " bats are protectes species , as such any palning aplication needs some sort of ecological report to mitigate any damage or disturbance" Along with other things , this what a HRA is all about, ecological reports to mitigate any damage or disturbance . To say Alba did not know this is not correct.

2. "GF and team took all the time they needed and hired all ecological experts they needed and submited a new report but still the mised things"" I disagree with this also, Alba have provided all that has been asked by NRW, unfortunately NRW have found it necessary to keep asking for more additional information that was not asked for in the first place. Alba can only provide what is requested at the time of asking. You can call this NRW this changing the goal posts, so really it is all down to NRW for this long overdrawn procedure.

To clarify:

Alba have only three ongoing applications:

One in relation to a European Species License

One in relation to a water quality permit

One that relates to a temporary water abstraction license

The issue at the moment is with the The Habitat Regulations Assessment. This is not a permit or license per say.

The Habitat Regulations Assessment needs to be assessed and deemed good by NRW before the European species License can be determined. You can get a European Species License without having a Habitat Regulations Assessment , but in our case we need one.

The original HRA that Alba was asked for only concerned the mine area where the dewatering was to take place, but NRW moved the goal posts some months ago and asked for a HRA to cover the entire Clogau Area where future works may take place. The only outstanding issue at the moment with the HRA is to with bats. New acoustic data was requested by NRW, that data has now been submitted. This is the only sticking point right now, and Alba are confident the new data will be all that is needed to complete the HRA, and then things can move forward.