- It Is Time To Commission a Panel of Risk Finance and Underwriting Experts To Review Financial Capacity of British Columbias 10 existing Mine Operators
- Canada & Canadian Owned Mines In Foreign Countries Determine The Unacceptably High Risk & Loss Profile of Mines Globally
- SEDIMENTS KEY ISSUE AT MT. POLLEY AND ONE THE B.C. GOVERNMENT SEEMS TO BE AVOIDING
- Historic Rejecton Of Maine DEP’s Extraction Industry Oriented Rules Part of National Push For Responsible
- Lessons For Maine Mining Statute & Regulations & Maine’s Bald Mountain in Tailings Dam Failure This Week at Mt. Polley British Columbia and Major Spill at Buenavista Del Cobre on the U.S. Border in Mexico
Eric A. Tuttle on Rock pile, stunted growth are… Eric A. Tuttle on Rock pile, stunted growth are… Eric A. Tuttle on Rock pile, stunted growth are… Eric A. Tuttle on REPEAL OF MAINE’S MINING STATU… lindsaynewlandbowker on REPEAL OF MAINE’S MINING STATU…
- 350 Maine
- Adjacency Impacts
- Bakken Crude
- bakken flammability
- Bald Mountain Aroostook Maine
- bangor daily news
- bannaism of maine
- Black Hawk Mining Co.
- block caving
- block caving prohibition
- block caving risk management
- block caving subsidence
- Bowers Mountain
- Bowker Associates
- Bowker Associates Science & Research In The Public Interest
- Buenavista Del Cobre
- Callahan Mine Brooksville Maine
- Callahan Mine History
- Callahan Mine NPRS-S ploy
- Callahan Mine Superfund Site
- Canada Dominance in Mining
- Canadian Mining Dominance Globally
- carbon emmissions
- Center For Science in Citizen Participation
- Center For Science In Public Participation
- Charles Roy Fitzgerald
- David Chambers
- Downeast Lakes
- Earth First
- Enbridge 9 Pipeline Reversal
- Energy East Pipeline
- Environmental Risk Management
- Expedited Permitting
- Financial Capacity Standrds Mines
- First Wind
- Forest Ecology Network
- Fred M. Beck
- Fred S. Beck
- GO NO-GO Technical Framework
- Go NO-GO Zones
- Heather Parent
- Highly Valued Natural Resources
- History of Mining In Maine
- Houston Kempton
- Huncleberry Mine
- Imperial Metals
- in situ leaching
- in situ leaching prohibition
- Irving OIL
- James Palmer
- JD Irving
- John Seal USGS
- JS Cummings
- Lac Megantic
- LD1750 Maine 126th Legislature
- LD1772 126th Maine Legislature
- LD1851 Mine 126th Legislature
- Lindsay Newland Bowker
- Maine Audubon
- Maine Mining Regulations
- maine mining rule rejection
- Maine Mining Statute
- massive sulfide risk management
- Metallic Mining
- Metallic Mining Risk Management
- metallic mining zoning ordinances
- mining definitions
- Mining In Tidal Estuary
- Mining Regulation
- Mining Risk Management
- Mining Watch Canada
- Mining Watch Maine
- Mt. Polley
- Mt. Polley Sediments
- NPR-S Plot
- Perpetual Treatment Policy
- politics of mining
- Portland Montreal Pipeline
- portland press herald
- Ralph Chapman
- Red Chris Mine
- Restore North Woods
- Robert Moran
- Robert Seal
- Robert Seal USGS
- rolling pipeline
- Scenic Impacts
- Science for Sale
- Sierra Club
- Tailings Impoundments
- Tailings Storage Facility Failures
- Tailings Storage Facility Risk Management
- Tar Sands
- Troy Jackson
- TSF Failures
- volcanogenic massive sulfide
- Wind policy
- Zoining and Landuse for Metallic Mining
- zoning & landuse for sulfide mining
Background & Analysis: Total Volume Of Mt Polley TSF Failure Significantly Higher
RevIsed Estimate Puts Toxic Sediments at 60% of Total Spill Volume
Mt Polley was already the largest TSF failure in recorded history. (http://www.wise-uranium.org/mdaf.html) Canadian press now reports that the release was not 14.8 million M3 but 24.8 million M3. The difference, significantly, is in the revised estimate of highly toxic sediments from an initial estimate of 4.6 million M3 to 14.8 million M3 (and the addition of 0.6 million M3 of construction waste). This represents a 300% initial under reporting/underestimating of sediment release.
Whether it is significant or just a number remains to be seen but that also means that sediments were 60% of the total release not 29%. Just intuitively that seems to suggest the possibility that the pressures on the face of the 112’ man made wall and resulting breach originated in/ or through the sediment layer.
Resident Of Likely With Sediment Clouded Water From Quesnel Lake
Sediments were the major issue raised by Brian Olding Associates in its 2009 review for Imperial and First Nations of the permit application for annual discharge 1.4 million cubic meters of waste water per year. http://s3.documentcloud.org/documents/1262983/final-report-mpmc-master-ta-review-jun21-2011.pdf . The TSF had been doing double duty as a temporary holding pond for mine and drainage waters, a common practice. The Olding Associates report concluded that the risk of contamination of receiving waters was too high without a “polishing pond” for sediments prior to discharge. “Sediment or associated contaminants could enter Hazeltine Creek unless there is an effective sedimentation pond between the Tailings Storage Facility (TSF) and Hazeltine Creek. (T)he sedimentation/polishing pond that is mentioned in the TA Report should be a condition of the discharge permit. “
Olding Associates also found that the data presented in the discharge permit application tended to under assess and/or not accurately measure the risk to receiving waters and habitats of the requested 1.4 million M3 annual discharge.“Throughout the TA Report, predicted chemical concentrations in Hazeltine Creek are based on annual or monthly mean values of effluent discharge to Hazeltine Creek. This approach can mask the potential for short-lived high concentrations of potentially harmful chemicals to exceed water-quality guidelines and potentially be harmful to the aquatic life of Hazeltine Creek. To correct this in a precautionary way, maximum concentrations of chemical parameters such as Sulphate, Selenium, Copper and Cadmium need to be calculated for minimum ( emphasis added) flow rates in Hazeltine Creek”
The B.C. Government was slow to release raw data on sediments. Recently released, the raw data , a combination of post failure grab samples and averages from a sampling program of TSF sediments 2010-2014 shows that sediments which are presently laying in the immediate vicinity of the spill have a contaminant profile consistent with the pre breach average profile of sediments within the TSF. Post failure grab samples reported in this raw data do not show those characteristics at other sample sites but do show some exceedances which could be pre-failure or could have resulted from operations and not be related to the failure.
Before the raw data was released, the provincial government had released this August 15th analysis of sediments and visual inspections.http://www.env.gov.bc.ca/eemp/incidents/2014/pdf/aug16/Memo-Quesnel-Lk-Sediment-Quality-Aug-10-revised.pdf
“Quesnel Lake near mouth of Hazeltine Creek in water 1 and 2.5 m deep. The lake bottom appeared to be covered in tailings and no aquatic plants were visible”.
It is not clear whether the two grab sample columns labled “Outside Tailings Dam Breach” are this observed “dead zone” at Quesnel Lake. These two columns show exceedances as follows as compared with the “Impoundment Average 2010-2014” and “Outside At the Breach” ( all measurements in ug/g dw)
Sample Sites Inside AVG At Breach.
Arsenic 12 12.4 12.32 11.7
Copper 646 723 931 918
Manganese 757 705 652 525
Selenium 1.2 1.1 1.04 1.4
Sulfur 3410 3320 ——– 2750
Vanadium 161 162 180.54 145
No further studies or results on sediment impacts are listed at the provincial government website as completed or in progress. No footnotes or commentary are offered on the consistent pattern of lower measurements “At the breach” as compared with the two sample sites.
Unfortunately no geographic coordinates were provided with the raw data which would have facilitated spatial analysis. This Mount Polley Mine Corporation (MPMC) map of sample sites appears at the Ministry of Environment (MOE) website but does not clearly correlate with the raw data on grab samples released a few weeks ago http://www.env.gov.bc.ca/eemp/incidents/2014/mount-polley/pdf/20140903/621717-006_SEDLocPlan_140829.pdf It does,however show the location of these MOPC sediment sampling results reported to MOE , http://www.env.gov.bc.ca/eemp/incidents/2014/mount-polley/pdf/20140903/QusnelLake_SEDMaster_20140826.pdf
“Environment Canada’s data on Imperial Metal’s mine tailings show mercury compounds, a neurotoxin that can cause degenerative disease, ramped up from 435 kilograms in 2012 to 3,114 kg last year – a seven-fold increase in one year.”http://commonground.ca/2014/09/the-mount-polley-mine-disaster/ (No exceedances of mercury are shown in the raw data either in the area immediately next to the breach or in any grab sample sites.)
Vanadium is not regarded as a serious (human) health hazard, is found in most soils and common in foods including olive oil, eggs, apples and soya beans . It does strongly bio accumulate in mussels and crabs causing inhibitions to certain enzymes.(http://www.lenntech.com/periodic/elements/v.htm#Health%20effects%20of%20vanadium )
Large metallic mineral deposits have natural releases of toxic metals which are established in background water quality studies pre-mining. Different parts of a deposit can have a very different profile of metals and very varying levels of environmental risk. Mining operations and advanced explorations can create new pathways. Exceedances shown in the raw data need further explanation and analysis to assess what is attributable to the failure beyond what is immediately at the breach.
The day after the failure, Brian Olding, the consultant to Imperial & First Nations on the 2009 re analysis of Imperials permit application to discharge 1.4 million M3 per year said “More water was coming in over the year than they could deal with…They just kept building the walls up higher and higher every year and it got to the point where that was untenable.” http://www.theprovince.com/news/Polley+Mine+tailings+pond+growing+unsustainable+rate+says/10091105/story.html
Olding & Associates had also urged a structural reassessment which Imperial did not agree to. “I requested a structural engineering company be involved, and that was nixed. They did not want to deal with that problem at that time.”( op.cit Province.com/news)
Today (September9) a non compliance directive on continued unauthorized discharges was issued to Imperial/Mt.Polley
At an inspection on Sep 4 it was discovered that Mont Polley Mining Corporation (MPMC) was discharging effluent into Hazeltine Creek.Order 107461 directed the installation of passive and or active sediment control systems designed to a 1 in 10 year 24 hr rainfall event.
Interflow & Salmon Spawning Impacts
Scientist Carl Walters is keeping a close eye on the “interflow” which has suspended the sediments released in TSF failure in a layer under the top warm layer of water and above the deeper cold waters. http://www.macleans.ca/news/canada/new-information-gives-salmon-expert-pause-on-mine-leak-impact/
This situation, Walters said, can worsen for the coming sockeye run given three possible conditions:
- It is common for a strong west wind to blow through the area for a day or two every few weeks this time of year, and if this happens the warm surface water will be pushed east away from the lake outlet where it can be carried out of the system, and the polluted water may surface and run downstream past Likely.
- Samples of the polluted water have shown that it has copper levels that are “close” to levels that can impair the salmon’s directional sense of smell, which the sockeye may need to move up Quesnel Lake and find their primary spawning areas in the Horsefly and Mitchell Rivers. As they move into the lake, they may seek deeper, cooler water and so will encounter the polluted, colder, dense water of the interflow layer cake. “This is especially worrisome for the Mitchell River fish that need to make a left turn about 20 km up the lake into the lake’s north arm and travel 60 km up that arm,” he said.
- About 20 km up the lake from the outlet, there is a shallow area called a sill, across which the lake water usually flows westward. That flow concentrates small plankton that feeds young salmon, but the polluted water has spread eastward enough to reach the sill, which could affect both the young fish and its food supply.
“I still don’t think it will be a serious problem, but I just can’t say for sure,” said Walters. “But at this point all we can do is to keep our fingers crossed that the polluted layer will be diluted enough by the time the main body of fish arrives so as not to be a major problem for them.”
” more than 175 years of experience sourcing precious metals tells us that there are certain places where mining cannot be done without forever destroying landscapes, wildlife and communities. We believe Bristol Bay is one such place. Tiffany & Co. was one of the first jewelers to sign the Bristol Bay Protection Pledge, and declare that should the proposed Pebble Mine be developed, we will not source gold from it”
Rio Tinto walked away on April 7th without even bothering to sell its shares
“Rio Tinto’s decision to walk away from the project without finding a buyer for its interest is the latest major blow to the project. In 2011, Mitsubishi Corporation sold its interest, and in 2013, Anglo American withdrew from its 50 percent partnership in the project, leaving small Canadian mining company Northern Dynasty Minerals the 100 percent owner of the embattled project. http://switchboard.nrdc.org/blogs/jreynolds/thank_you_rio_tinto_british_mi.html
Minnesota’s Northmet recently received a not very encouraging EPA EC-2 ( environmental concerns which require further information to resolve). Although touted by Polymet as an “upgrade in their rating” ( from EU1, an unsatisfactory indicating the project should should not proceed) it is hardly a “good to go”. Northmet, like our own Bald Mountain, was proposed by a limited liability company with no mining operations experience of any kind. Northmet was also premised on the use of unproven closure technologies and untried scale of existing slurry wall technology.
At both the Pebble and Northmet the fidelity of a well informed grass roots, native people’s coalition brought an informed independent scientific best practices analysis to bear against the false , misleading, and unsupported claims of would be mine developers.
As with our own engagement here in Maine the technical assistance and guidance of Dr. David Chambers ( www.csp2.org) and other scientific experts dedicated to informing grass roots stakeholders was a key factor. Dr. Robert Moran, Jim Kuipers, Anne Maest are among the many other leading scientists arming stakeholders with independent expert scientific analysis of environmental risks inherent in specific potential mine sites. Other scientists like Houston Kempton and Dr. Andy MacG. Robinson have addressed policy in constructive ways although primarily serving the mining industry, rather than the public sector.
Commissioned through and directed by Bowker Associates Dr. Chambers produced two major technical reports with a specific bearing on DEP’s draft rules. Both reports are technical advances in framing public policy founded on “Responsible Mining” standards and practices. The most recent of these reports, an expert reassessment of envionmental risks of mining Bald Mountain was transmitted to Maine’s Joint Standing Committee on Environment and Natural Resources in advance of the first legislative work session on the rules. An earlier report offering a technical “Go No Go” framework for responsible mining was transmitted to BEP via DEP & Executive Analyst Cynthia Bertocci in advance of the BEP’s January 3rd meeting. Chairman Foley, according to Ms. Bertocci, did not allow BEP members to see the report because it was not submitted during a pubic comment period. Both reports were widely distributed to official “interested parties”, and to stakeholders and legislators.
Maine’s historic rejection of the rules and the two year delay on implementation of the mining statute is a direct result of this and other excellent scientifically informed grass roots testimony offered by ordinary citizens who committed their professional expertise and skills over a sustained period to informing Maine’s mining policy.
Legislators , advocates and stakeholders in Maine are not “starting from ground zero”.
All are starting from two years of faithful and diligent collaborative discernment on the modern science and technological realities of sulfide mining and how to express that in policy that speaks the values that bind us together as Mainers.
The resources most centrally at issue, the State’s ground and surface waters, and under federal law, the state’s “navigable waters” are owned in common by all the people. They are not privately owned or controlled unless it can be shown there is no hydrologic connection with “waters of the state”. So even where law and policy fail in expressing clear standards, informed stakeholders expect protection and remedies in policy. Stakeholder unrest translates to political risk which translates in turn to investment jitters.
In Maine, there is a 100% certainty that the rules that come before the legislature in February 2016 will be a full and well informed expression of “Responsible Mining” and that the statute itself may be considerably strengthened or completley replaced over the next two years.
The first example of that has already been accomplished with enactment of LD1671 which forbids the use of motorized metal dredging in certain designated key fish breeding habitats. The mining rules just rejected by the legisature specifically allowed motorized dredging without limitation
“1.B. Removal of ore from great ponds, rivers, brooks and streams, and coastal wetlands as defined in 38 M.R.S. § 480-B, except that gold panning and recreational motorized gold prospecting are permitted pursuant to 38 M.R.S. §§ 480-Q(5) and 480-Q(5-A) and are exempt from the requirements of this Chapter “
LD 1671 became law with bi- partisan support and multi stakeholder collaboration lead by Jeff Reardon of Trout Unlimited and supported by Maine Audubon . The Act sustained a veto by Governor Paul LePage.
Other such natural resource specific changes in statute will be made over the next two years which will directly affect the new rules and most likely prompt reworking of the mining staute itself to better clarify that mining owes the same level of envionmntal proection to the states waters as any other activity, that mining doesn’t have its own separate and lower standards of natural resources protections.
It is very unlikely that our extensive and exceptionally well informed stakeholder group on mining will simply wait to see what DEP does next or wait for someone to officially convene a stakeholder group to reframe Maine’s mining policy. A well informed and deeply committed grassroots stakeholder group is already formed and will continue the work that is needed to frame a responsible mining framework for Maine.
Maine’s historic action at the same time as scientifically empowered grass roots efforts in Alasaka and Wisconsin have scored gains for “responsible Mining” signal a change of tide. It will no longer be possible for industry lobbyists, no matter how much money they have behind them, to peddle false information in support of their extraction based endeavors. They will have to become collaborators and partners in discerning environmental feasibility site by site in accordance with the best science and the best practices available.
Maine’s Governor, Paul Le Page, will most likely veto both bills. That will still leave the 1991 rules in effect per the terms of the mining statute. The veto of LD1772 cannot enact the rules rejected by the legislature. Also,since the legislature has “taken action” under the applicable legal definition, DEP does not have authority under MAPA, Maine Administrative Procedure Law ( PL 2011 c.244) to enact the rules. The veto of LD1851 would, however, allow those provisions of the mining statute which remove mining from all other applicable environmental law to go into effect in June of 2014. It is these provisions of environmental law, that Boliden and Black Hawk, both also clients of Pierce Atwood, were unable to resolve and these are the provisions of law most eagerly sought by Pierce Atwood on behalf of current client JD Irving in drafting the 2011 mining statute.
It is not clear what remedy is available should the Governor’s expected veto of LD1851 not be overridden by the legislature.
Nontheless, Maine’s two year discernment on metallic mining is now well informed and moving clearly in the direction of responsible mining