Bald Mountain History & Study 1977-1998
This directory , which is still in development, is intended to provide an annotated bibliography with links to all the study of Bald Mountain in Aroostook County Maine since it was first discovered in 1977 by Mainer JS Cummings. It is intended to serve legislators, government and non-government agencies researchers and journalists. Its organization may change over time but will be grouped alphabetically by topic and within that by date from earliest to most recent. The documents I have created from the actual permit history at Bald Mountain are stored in google docs.
Steffen Roberson & Kirsten ( now SRK) has refused permission for this publication and asserted copyright protection but “facts” are not copyrightable nor are “facts” organized and copied in standard forms..bar graphs, tables, maps, or “facts” derived from measurement whether the measurement was by original means or not. All of the measurements and their presentation here are “facts” without copyright protection. Whatever privilege may have been agreed to contractually by the entity commissioning the report and the entity creating it no longer existed when the reports became part of an application for a permit with a public agency.
Lindsay Newland Bowker, CPCU ARM, Environmental Risk Manager
Science & Research In The Public Interest
15 Cove Meadow Rd
Stonington, Maine 04681
207 367 5145
ARD Generation Analysis
Steffen Roberston& Kirsten (B.C.) Inc. Report80701/2 “Report on the Acid Generation Characteristics of Mine Wastes For the Proposed Bald Mountain Project” Prepared for Boliden Resources Inc. August 1990
Here is a graphic depiction of that report applying globally recognized risk criteria to characterize the 29 samples which formed the basis of this SRK 1990 assessment of Bald Mountain
My analysis accompanying distribution of this report to legislators, journalists, environmental advocates and global recognized experts with whom I have been in touch for about 18 months accompanied email transmission.
At the outset of taking over the lease from Chevron, Boliden, who were very experienced in mining Volcanogenic Massive Sulfide deposits, based on past data and analysis of drill cores had anticipated mining the entire deposit top to bottom as an open pit up to 800’ deep. They indicated it would take 13 years and employ around 220 people none of whom, they were clear to say, were likely to be the then locally unemployed. After reviewing this report Boliden scaled back its plan to a much smaller 500’ depth pit with a 30 acre total surface area and commissioned the report below.
SRK’s own analysis of this data is in the first document of this series of documents on which NRCM based its report on DEP withholding vital information from legislators and from the public. SRK the world’s top mining consultant then and now, advised Boliden that their plan for a top to bottom , open pit extraction could not avoid off site environmental damages with any known technology.
Steffen Roberston& Kirsten (B.C.) Inc. Report80702/3 “Proposed Bald Mountain Project Report on Mine Rock Acid Generation Potential” Prepared for Boliden Resources Inc. March 1992
Here is the text of my email transmitting this report to DEP & LUPC key policy staff ( Heather Parent. Mark Stebbins, Samantha Horn Olsen) It provides a good plain english summary of what the report says.
Basic explanation of ARD generation and associated risks
Red Dog Mine Alaska like Bald Mountain is a VMS with no neutralizing potential and will essentially be a perpetual care mine generating acid and toxics into perpetuity.
“The closure plan at Alaska’s Red Dog Mine calls for 7-15 perpetual workers, treating over a billion gallons of water annually using 7,300 tons of shipped-in lime, and producing over 70,000 tons of sludge, at a cost of over $10 million every year, forever” (Pebble & Perpetuity March 2013 op cit above groundtruthtrekking.org)
This document reports the revocation of permits for Red Dog Mine in 2006 for violations of the Clean Water Act
Here is a consolidated report of all ARD generation analysis done at Red Dog since 1996
Interestingly there is a case history on the Red Dog prepared by the Federal EPA. Very telling for Bald Mountain. Failure to require adequate prior ground water study and geochemical analysis lead early on to problems that were never fully mitigated or controlled.
See under ARD above the MEND Manual. ARD analysis must be the cornerstone of each phase of a well developed mine. It should inform the plan.
Another major new deposit in this same chain, Artic Mine, is touted as the highest grade of copper ever found and is as yet unstudied. This official Alaska State report looks at the environmnetal risks attending mining sites in the same range .
William K. Price 2009 Manual on ARD prediction for Canada’s MEND Program
The most complete and authoritative guidance on management on identification and management of ARD risks.
Black Hawk Application ( as NNM Resources)
Black Hawk, a company with no mine planning. mine development, mine managing or mine closure experience, acquired the lease from Boliden for $2 million in 1995 and submitted a mining application in 1997 for a very small gossan only (gold & silver) open pit mine.
They submitted the prior work of Boliden and earlier leaseholders and did very little new work .
The Black Hawk Mining Application itself and the required Envionmental Impact Report are the second and third documents in this series of documents scanned to PDF by NRCM in support of their 2013 report accusing DEP of intentionally withholding this information from the public and from legislators
Notice of Incomplete Application March 31, 1998
This 20 page main letter to Black Hawk at Denison headquarters in Toronto co signed by mining coordinator Mark Stebbins and LURC permitting official Catherine Varney outlines the principal incomplete elements of the Black Hawk application and the unresolved issues of environmental impact. At p 6 Stebbins highlights the likely permanent impacts of lowered ground water levels that would occur over the three year period of active extraction from the small pit. It also flag silence on the management of arsenic.
We have and will be translating to PDF and posting here:
Additional Geohemical & Lab Work perfomed to further detail the specific area of the planned small pit.
Black Hawks letter of withdrawal of the application
Black Hawks Lease and royalty agreement
Boliden, a highly respected highly qualified Swedish mining company with experience in mining Volcanogenic Massive sulfides under tight environmental regulations took over from Chevron in 1989. Boliden was the very first company involved at Bald Mountain who actually had experience in mine assessment, mine planning and mine development. They invested a total of anout $20 million in Bald Mountain under permits to LURC. Their work never materialized to a full blown mining application. They sold in 1995 to Black Hawk, another company with no mining experience for $2 million. Boliden began with an expectation of mining the entire deposit top to bottom as an open pit and anticipated about 130-200 jobs(depending on official source..many different numberss in notes) over 13 years. On reviewing work commissioned of Steffan, Roberston & Kirsten ( see ARD Analysis above) in 1990 they scaled their plans back to a much smaller mine of about 30 acres in surface area and only about 500 feet deep. Notes indicate that Chevron, who had absolutely no experience in mining, had anticipated a huge sprawling open pit operation with on site milling. (Chevron’s predecessor, Superior also had a huge sprawling plan)
Bolidens first exchanges with LURC on taking over from Chevron. Note especially John Cesar’s(President of Maine subsidiary Boliden set up for the Bald Mountain project) Boldiens 1989 letter expressing Bolidens desire that LURC and DEP will write the regulations directed by the legislature in 1985.
This 1991 Correspondence between Boliden and DEP officials is a fascinating early history of Maine’s 1991 regulations. Most of these exchanges are about Bolidens difficulties complying with the requirements based on very low detection limits adopted in Maine’s 1991 regulations that had no correspondence in commercial laboratory standards. Further as Boliden points out Maine’s low detection limits not only made it impossible to find a lab but were standards with an error of 100% whereas the standard industry criteria that excellent labs were using had an error rate of only 28%. Boliden surmised that DEP had come up with these standards based on some sort of literature search without verifying whether any labs were actually capable of the measurements at the specified level.
Additional notes including handwritten LURC staff notes at the initial meeting between Boliden & LURC. See especially the handwritten notes of the working group meeting June 28, 1990. The name of the author/note taker isn’t given but is presumably an LURC staff person. Two important and note worthy descriptions. First it describes the rather huge sprawling operation Superior had planned ( Superior preceded Chevron and was an investor JS Cummings brought in). Ths is also the only source I’ve seen that describes any details of what Boliden initially had in mind on taking over from Chevron ( Superior’s successor). On site milling was anticipated with transportation of milled ore by train on the Bangor & Aroostook to a port for shipment to a refinery/smelter. In these notes 150 is the number noted as total employment for this initial mining plan by Boliden.
The initial Boliden letter referenced above is in this group ( John Ceasar advising they have acquired the lease from Chevron and expressing their expectation that DEP/LURC will issue the rules required by legislation)
All of these records were provided to me ( Lindsay Newland Bowker, Bowker Associates) by LURC in response to a records request. They were provided in pdf form and appear here as grouped by LURC for transmission. ( it was agreed the records would be transmitted in groups by year). The request was for all permit records on LURC/DEP’s relationship with Boliden.
Cummings, JS Letters to Legislators John Martin, Troy Jackson, Jeff McCabe
Mr. Cummings communicated with both John Martin and Troy Jackson at the time John Martin brought his proposal to “streamline” Maines Mining Laws to our Joint Standing Committee on Environmental and Natural Resources
Letter to John Martin (https://docs.google.com/file/d/0Bw0jCpuVRzgEemJoUFUtY0xlNGM/edit?usp=sharing )
Letter to Troy Jackson ( https://docs.google.com/file/d/0Bw0jCpuVRzgEQUk2TGdFU21uSHM/edit?usp=sharing)
While there is a certain amount of woundedness apparent in these communications that he was not consulted or included, he is also very clearly trying to make sure that legislator understand the challenges of the mountain itself, in particular the high levels of arsenic and the huge ratio of overburden to ore ( waste to productive rock ).
This year Mr. Cummings wrote to Jeff McCabe, as sponsor of a bill that would have amended the mining statute.
One of Maine’s largest and most influential environmnetal lobbyists and at least one reporter had a copy of the letter to McCabe and its attachments but chose not to release it and not to follow up on the accuracy of the reported high levels of arsenic at Bald Mountain. Mr. McCabe did not release or follow up on it.
It was read to me over the phone by one of the several who had possession of it and I did follow up with Mr. McCabe and all members of the Joint Committee who already had all of the letters.
Not one member acknowledged or replied.
JS Cummings Geochemical detection of volcanogenic massive sulphides in humid- temperate terrain : (using surficial methods) self published Bangor 1988
J.S. Cummings account of the unusual methods he used to identify almost all of the known sulfide deposits in Maine are set forth in his book. He has no copues himself and did not retain nay other significant documentation on his many important Maine discoveries. Three copies he donated still exist in libraries in Maine.
One of these is a circulating copy and you can arrange to have it available at one of many local libraries throughout Maine.
Cummings, JS The Lost Promise of Golconda Metals in The Maine Earth Re-Books 2012 ch 5 Deceit At The Highest Level 1989-1995
The Flambeau mine in Wisconsin is often touted as an exmaple of a successful open pit reclaimed VMS mine.
Flambeau is very small mine only 200 feet deep with a tiny surface area and with available limestone and other neutralizing potential of high quality within the deposit itself.. Bald Mountai is 800 feet deep with a significantly larger surface area. Additionally Flambeau had a much lower over all acid generation profile than Bald Mountain All processing was off site. Raw ore was shipped out for milling and refining.
The following document is an inquiry to Dr.David Chambers about his study of Flambeau and contains a link to it as well as a link to Kennecotts description of their mine plan.
Slack, John F., Flohr Marta J.K. USGS & Scully, Michael V. Hypogene Mineralogy and Paragenesis Of the Bald Mountain Massive Sulfide Deposit Open File Report 97-46 December 1997 http://pubs.usgs.gov/of/1997/0746/report.pdf ( Deposit geology)
Ground & Surface Water Quality
Fontaine, Richard A. Hydrologic And Meteorlogic Data Bald Mountain Area Aroostook County Maine June 1979- June 1984 U.S. Geological Survey Open-File Report 85-174 Augusta Maine 1989 ( a Joint Study of USGS and Maine DEP in anticipation of an open pit mine at Bald Mountain)http://pubs.usgs.gov/of/1985/0174/report.pdf Seal
Dr. Robert Seal.Pre Mining Analysis of Bald Mountain ( 1997)showing elevanted arsenic and lowered ph 12km down gradient of the deposit.
Ground & Surface Water Quality Monitoring
1990 Correspondence with Boliden Who Took Over from Chevron and took over the permit and sampling stations
Table of Contents Black Hawk Mine Application as NNM Resources 1997 ( link to be added available in pdf)
Maine Agency Comments on Black Hawk application 1998 (link to be added available in pdf
All photos posted here are in the public domain and may be used without permission. The coutesy of photo credits as indicated would be appreciated and, via comments email, a link to any use.
Valuing A Copper Deposit
VMS deposits like Bald Montain are not as competitive as the easier to mine porphyry mines of the southwest and Latin America. Porphyry deposits account for 60% of copper production globally. And are generally amenable to open pit mining, ie the ore body has a high enough grade (.6 is average today) and is close enough to the surface to make extraction profitable.
In comparison to Poryphry deposts, VMS deposits in general are smaller and deeper but have polymetallic charceristics ( metals like gold and silver) that can offset the high costs of deep excavation overburden.
In comparison to porphyry deposits VMS deposist are more likely to be acid generating and pose more complex environmental problems with toxic metal leaching. Bald Mountain, even among VMS deposits is a challenge for its anomalously high levels of arsenic , its high acid generation profile and the absence of any neutralizing material within or near the deposit. ( see above Boliden Application and the SRK reports developed on the geochemical profile of Bald Mountain)
Volcanogenic Massive Sulfides
2013 winnipeg address on why VMS deposits are not being developed
VMS deposit have accounted for about 27% of Canadas copper production historically. There are 350 known VMS deposits in Canada and 800 worldwide