Current Status of the Brewer: Receivership and Exploration

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RECEIVERSHIP:

The Brewer Gold Company mined over 12,000,000 tons of ore and waste rock from the Brewer from 1987 until 1995, when mining operations ceased.  From 1995 until 1999, Brewer Gold Company performed reclamation activities under the direction of SC DHEC (the "Department"). They were unsuccessful in achieving the goal of a fully-reclaimed, clean site, and ultimately informed Department that it intended to abandon the site. The Department obtained a court-issued injunction to stop Brewer Gold Company from abandoning the site, but Brewer Gold Company proceeded with abandonment of the property and associated wastewater treatment operations as it had intended. Since such time, Brewer Gold Company has not maintained any presence at or responsibility for the property, or shown any willingness to participate in or contribute to responsive actions at the property. Brewer Gold Company's corporate existence in South Carolina ceased on December 31, 2007, due to forfeiture. 

Brewer Gold Company utterly failed to comply with its remedial obligations at the site under state and federal environmental laws. Its abandonment of the property endangered downstream surface waters and thereby placed public health and welfare and protection of the environment at risk. 

Brewer Gold Company's abandonment of the property left the Department and EPA with no options for addressing water quality threats from the site other than using CERCLA response actions funded by EPA and the Department. However, although the Department and EPA retain access to the property for purposes of constructing, operating, and maintaining the wastewater treatment plant and otherwise carrying out the CERCLA remedy, they did not have the legal authority to manage long-term access to the property for other purposes or to make decisions concerning other uses or final disposition of the property, including exploration and future mining of the Brewer.

In order to address these issues, the Department, with EPA's support, sought appointment of a temporary receiver to manage access to the property for interested third parties.  Such a receiver would have the authority to facilitate leasing, sale, or other use or disposition of the abandoned property, including potential renewal of mining exploration and development at the property, and would promote resolution of Department and EPA's action to address continued environmental threats at the site.  The Court of Common Pleas for the Fourth Judicial Circuit of South Carolina granted the Department's request and appointed Brewer Gold Receiver, LLC, on February 4, 2019.

EXPLORATION:

After its appointment, the Receiver immediately set about to conduct a robust search for parties interested in exploring the Site to determine whether there are sufficient mineral resources on site to justify re-opening the mine, while simultaneously addressing the environmental issues present onsite to abate the threat of negative impacts to human health or the environment. After performing a thorough search for interested parties, several parties came to the fore to pursue the possibility of exploration. Together, these parties have exploration activities or active mines in the United States, Canada, Finland, Mongolia, Australia, New Zealand, and South Africa. The level of technical and professional competence exhibited by the interested parties was extremely high, and provided comfort to the Department, EPA, and the Receiver that things would be done correctly this time around. 

The Receiver orchestrated site visits for the interested parties to (a) review written materials and maps in the Receiver's possession, (b) review and analyze core samples and assays from prior drilling operations, (c) analyze the existing treatment systems designed to protect human health and the environment from the metal-laden, acidic groundwater present on site, and (d) otherwise allow the parties to become familiar enough with the site to determine how best to structure an offer to explore the property. 

In January 2020, the Department, EPA, and the Receiver selected Pancontinental Resources Corporation (“Pancon”), https://panconresources.com/, now known as Carolina Rush ("Rush") https://thecarolinarush.com/, in partnership with Environmental Risk Transfer, https://www.environmentalrisktransfer.com/, as the successful candidate.  Rush now enjoys an exclusive right to conduct exploration activities on site, and an option to purchase the site should they be successful in their exploration.  Rush has already utilized several types of geophysical investigation techniques (induced polarization/resistivity, calculated vertical gradient (CVG) reduced-to-pole magnetic data, and gravity readings) and has recently begun drilling shallow exploration borings (RAB drilling).  All of these activities are being conducted under strict supervision of the Department, EPA, and the Receiver to ensure compliance with all applicable environmental laws and regulations, and have taken place without disturbing implementation of the interim remedy under the Department's and EPA's authority and oversight.  This minimizes to the maximum extent possible the threat of negative impacts to human health or the environment and protects the natural resources in the area from harm.  

The data gathered from these activities will be used in conjunction with previously gathered data and analysis to determine preferred locations for drilling deep diamond core borings.  The diamond core borings will be key to proving the existence of mineral resources on the site.  The Receiver and Rush expect exploration activities to continue at least until December 2024, with the possibility of exploration extending into December 2030.