FRONT 40 RECEIVES FRESH WATER HERO AWARD

Have you ever received shocking news that left you with that horrible gut-wrenching feeling in your stomach?

The founders of Front 40, a grassroots organization in Menominee County, Michigan, had that feeling when they found out that a mining company had leased thousands of acres of state-owned minerals on the shores of the Menominee River.

Local residents responded by organizing Front 40, an environmental group dedicated to ensuring that metallic sulfide mining operations are not allowed to adversely impact our rivers, lakes, groundwater and lands. The Front 40 name is in direct response to the “Back Forty” venture that was created by the mining interests.

Front 40 has played a critical role in creating public awareness of mining exploration currently taking place in Menominee County. They have informed citizens and elected officials of the reality of community economic issues typically involved with mining operations.

Front 40’s leadership on mining issues has resulted in several municipal resolutions against the Back Forty mine and increased understanding of the threats to water resources from open pit sulfide mining. Freshwater Future is pleased to present Front 40 with a Freshwater Hero Award for their work to prevent waters from being impacted from mining development.

A Michigan Mystery

A Michigan Mystery

On December 28, 2016, the Michigan Department of Environmental Quality issued a press release. Within hours a second, revised news release was issued. Although the subject was the same (the status of Aquila Resource’s mining permit applications), many statements in the first release were omitted in the second.

Including:

  1. “The department gave conditional approvals to…..”
  2. “…Faces significant remaining hurdles”
  3. “The Mining Permit is not effective, meaning no mining or site preparation may commence until the applicant acquires all necessary permits and has provided the MDEQ with the required financial surety.”
  4. “Additional information on requirements for approval of the Nonferrous Metallic Mineral Mining Permit (Mining Permit) is online.” Why were these statements removed? Was it because they aren’t true? No, each statement appears to be a verifiable fact! Were they removed because they contradict the mission statement of the MDEQ?No, the MDEQ’s mission statement is included for us in both releases. So, this is the latest big “mystery” surrounding the MDEQ. WHO AUTHORIZED THE CHANGES AND WHY WERE THE CHANGES MADE? We can only speculate about the reasons for their omission and only the MDEQ can solve this mystery. Contact Joe Maki, 906-250-4015, maki8@michigan.gov for answers.


Thank You

Front 40 would like to thank everyone who has supported us in our environmental fight against the Back Forty (proposed mine) Project.

That includes everyone who: wrote letters to the editor, attended forums, asked questions in public meetings, contributed financially, put out yard signs, spoke up at environmental meetings, wrote letters to DEQ, attended township and county meetings and voiced their opinions, spoke up in private meetings with friends and neighbors, wrote letters to government officials, helped in any way with our efforts to inform private citizens and elected officials about the realities surrounding metalic sulfide mineral mining.

Front 40 Environmental Fight has been involved in this effort for the last 12 years. We need your continued support and encouragement. We must continue this difficult, grass-roots work against a well-organized and well-financed adversary.

If we find ourselves hesitant to speak up and share our thoughts, we may benefit from the advice of Dr. Karam, a one-time Prime Minister of India, when he says, “Let difficulties know that you, too, are difficult.”

Let’s continue to voice our environmental concerns.

It is the feeling of Front 40 that, inasmuch as, the mining interest does not have all the pertinent information needed for the DEQ to approve/disapprove the mining application, a final decision should be delayed.

– Front 40

From the DEQ

The web address directing people to the web site that has the Back Forty Project updates and documents needs to be corrected as soon as possible in the Public Notice, including sending a correction for the publications.  The correct address is:

http://www.michigan.gov/deq/0,4561,7-135-3311_18442-359902–,00.html

Eagle Mine Buries Underground Collapse

Marquette, MI — Concerned citizens are publishing the details of an underground collapse incident at Eagle Mine, citing grave concerns with the company’s lack of transparency. The revelations follow several “Eagle Mine Community Meetings” in which the company failed to disclose the details of a significant incident that happened in 2016.

“I attended Eagle Mine’s meeting anticipating some honest discussion of their 2016 underground collapse. Instead, they demonstrated how to use a virtual fire extinguisher to fight a virtual fire. Their 2016 safety review mentioned only medical incidents: a contractor who fell from a ladder and sprained an ankle, an employee who experienced a heart attack, etcetera. Eagle claims that ‘providing transparent information is important to the way we do business,’ but Eagle Mine’s behaviour is anything but transparent,” said Jeffery Loman, Keweenaw Bay Indian Community tribal member and former federal oil regulator.

“Representatives of Eagle Mine failed to address the collapse until they were asked by a concerned citizen at a community meeting in Big Bay, at which point they tried to claim it was an insignificant and harmless incident,” said Nathan Frischkorn, a resident of Marquette.

“Eagle Mine’s failure to disclose a serious underground collapse is outrageous, in light of their request for more permits to expand mining into the new Eagle East orebody. Permitting hinges on public accountability. At the same time, Eagle Mine wants to remove more ore from the very highest levels of the Eagle Mine – a move which experts have long warned could cause the mine’s ceiling or ‘Crown Pillar’ to cave in,” said Kathleen Heideman, Upper Peninsula Environmental Coalition (UPEC) board member and a member of the Mining Action Group.

RUMORS SURFACE

Rumors of the underground collapse at Eagle Mine first surfaced in fall of 2016, when a story circulated that some “mine contractors” had quit over an underground incident they felt was “dangerous.” Responding to the direct question “Was there a partial pillar collapse?” Eagle Mine confirmed that an incident had taken place, but did not use the term “collapse” and provided only a few details:

“In early August, there was a fall of ground incident that occurred during aroutine blast in an active stope. The fall of ground occurred due to an unidentifiable natural horizontal feature that failed during a blast, causing a section of ore to fall. Eagle Mine safety standards require all employees to be on the surface during a blast, therefore no employees were underground or at risk at the time of the incident. The situation was identified by employees during the post-blast inspection. Eagle Mine notified the Mine Safety and Health Administration (MSHA) who conducted an investigation.  MSHA notification is required whenever an unplanned fall of ground occurs at or above the anchorage zone in active workings where roof bolts are in use.”

Documents received in May of 2017 from the federal MSHA via a Freedom of Information (FOIA) request filed by a local concerned citizen make it clear: the unplanned “fall of ground” was a significant “large block failure.”

  • Eagle Mine’s Wilhelm Greuer told the MSHA investigator, “this was a wake up call.”
  • A large portion of an underground stope unexpectedly collapsed. The mining term used by the company is an “unexpected fall of ground.” It was described by MSHA  inspector as a “substantial” event, and could have happened at any time.
  • While it is true that no one was working in the drift below the stope when it collapsed, a crew of Cementation employees had been installing rock bolts into the stope prior to the collapse. It could have been a fatal accident.
  • The “unidentifiable natural horizontal feature that failed” (as described by Eagle Mine) was actually a fault, a critical fracture or flaw within the orebody. Was it truly unidentifiable – or simply unidentified? The geological fault or crack ran diagonally through stope 1485 on level 215, which is a “secondary” stope (unit or compartment of ore) contained between two primary stopes, which were already mined out and backfilled. A large quantity of ore below the fracture collapsed without warning. Mining experts describe these fractures as “rock discontinuities” and have warned that the Eagle orebody is filled with hard-to-map “smaller-scale discontinuities that could weaken the rock mass.”
  • The blast that “triggered” the collapse actually took place elsewhere in the mine, in another stope. Eagle said the collapse took place in an “active” stope, but it was not targeted for blasting when it collapsed.
  • The stope dimensions were approximately 33 feet wide by 80 feet high. A working access drift (tunnel) had been widened to the full width of the stope, further destabilizing the ore block. MSHA’s report states “the back broke approximately 9 meters (30 feet) above the existing 20 foot cable bolts.”
  • According to the MSHA investigation, the bolts that were installed “represented approximately one-quarter of the capacity” that was actually necessary for supporting the ore block.

CONCLUSIONS

Alarmingly, MSHA concluded that “because the planar discontinuity (…) was unanticipated, and the failure block was too large to support with a reasonable bolting system, it must be assumed that similar discontinuities could be encountered, any time.”  For greater stability, MSHA recommended leaving ribs of ore in place between stopes to increase safety: “rib pillars should be left in place in secondary stopes to provide physical, standing support.” According to Parker, this mining method was recommended from the beginning. Why was this common sense safety practice (leaving ribs for better support) not done? Simply put, the company did not want leave behind valuable ore. Full-stope mining means taking everything – leaving no ore behind.

While questions were raised about the integrity of cemented backfill, MSHA concluded “this event is not considered a backfill failure issue.” In the wake of the incident, however, several changes were made to Eagle Mine’s backfill regime: changing the cement recipe, heating water before adding it to cement, and even the method of cement placement. Edges of backfilled stopes were found to contain voids and loose material, which may have further contributed to the instability of the ore block.

It is not clear whether MSHA’s recommendations were suggestions or requirements, or whether Eagle Mine has modified their mining practices to avoid future unexpected collapses.

“Criminally defective decisions made by the Michigan’s Department of Natural Resources and Department of Environmental Quality (DEQ) caused the permit to be issued despite obvious and serious legal and technical shortcomings. Eagle Mine’s permits were built upon false design and false data provided by amateur consultants who blatantly fabricated numbers, maps and sections which are in no way representative of the conditions in and around the orebody. The mine owners and their consultants still share responsibility for these errors, some of them life-threatening, all of them jail-worthy,” said Jack Parker, a veteran miner and mining consultant.

“Lundin and the Eagle Mine management have demonstrated to the general public what we have known all along: they will withhold information from the public if it might be damaging to their image. Lundin could have disclosed this information at the Eagle Mine forums held last fall or last week. They chose not to,” said Gene Champagne of Concerned Citizens of Big Bay.

“It is incomprehensible why Lundin would widen the access drift below the stope without providing additional support. The MSHA report indicates that the affected area was only 28% supported. Greed is indeed a powerful force. This was not the fault of some overactive employee trying to impress the bosses and become employee of the month, as suggested by Matt Johnson’s comment in the Big Bay meeting. Someone gave the order to widen that stope. The public needs to know who. This was an accident waiting to happen and possibly could have happened without a blast occurring and while our working neighbors and relatives were still underground,” said Champagne.

EAGLE WANTS TO TAKE MORE ORE

Prior to the collapse, Eagle Mine submitted a stability report to the MDEQ, seeking to revise the mine’s critical “Crown Pillar” design. Lundin wants to extract an additional two levels of ore from the top of the orebody. The Michigan DEQ reviewed and quietly granted their request, with no opportunity for public comment. Reports were made available only recently, after a request made by the Upper Peninsula Environmental Stakeholders Group.

Lundin Mining acknowledges in their most recent Technical Report on Eagle Mine that “due to the location of the mine under a significant wetlands area and overburden cover, a crown pillar is necessary for the Eagle Mine to prevent surface subsidence and/or large-scale collapse.” The precise thickness and strength of the mine’s “crown pillar” or rock roof has been a hotly debated issue for more than a decade. Several mining engineers, after examining drill cores and rock quality data, have concluded that Eagle Mine’s design is fundamentally unstable, based upon flawed or falsified stability data. Some stated under oath that a crown pillar less than 300 feet thick would be likely to collapse. Eagle Mine, with DEQ’s approval, has now thinned the crown pillar from 287 to only 95 feet, in order to extract more ore.

“Eagle’s secretive behavior, in the wake of the collapse, is alarming. Is Eagle Mine stable, as the company insists, or will unmapped faults prove catastrophic, as experts have warned? Nobody wants to see a serious collapse at Eagle Mine. That would devastate the headwaters of the Salmon Trout River, directly above the mine,” said Alexandra Maxwell, Yellow Dog Watershed Preserve administrator.

“No one in the Upper Peninsula should feel comfortable about the planned activities at Eagle until the financial responsibility assurances required by government regulators are at least an order of magnitude greater than what they are today,” said Loman.

“In light of last year’s significant underground collapse, which was hushed-up and passed off as a minor fall of ground incident, an independent professional review of the Eagle Mine’s data and design is needed. Ultimately, the Michigan DEQ must take steps to correct this unfortunate situation and forestall others. Mining of the Eagle East orebody must not be permitted until Eagle Mine’s design and rock data finally pass muster,” said Parker.

MORE INFO

Red Flag Review of Aquila Resources Back Forty Mining Application

Dear Mr. Maki, Mr. Casey, Mr. Sutton, Mr. Moritz, Mr. Creagh, and Mr. Fitch,

Attached please find a ‘red-flag review of Aquila Resources’ Back Forty Mining Permit Application Project ID: 14A021, conducted by Kendra Zamzow, Ph.D. and David Chambers, Ph.D, Professional Geophysicist of the Center for Science in Public Participation (CSPP).

Save the Wild U.P.’s goal in securing this external technical review is to ensure that Michigan Department of Environmental Quality staff and the Mine Permit Review Team assigned to this permit are made fully aware of critical flaws in Aquila’s Mining Permit Application.

Key issues raised by CSPP’s red flag review include: the serious risk of Acid Rock Drainage (ARD), significant underestimation of financial assurance, the lack of water treatment facility design in Aquila’s application, and the erroneous comparison of closure plans to that of the Flambeau Mine – the Flambeau Mine had no tailings and left no waste rock on the surface. Also, detailed information concerning the alkaline amendment of tailings and the waste rock facility design was omitted from Aquila’s application.

Dr. Zamzow’s report makes the following specific recommendations and actions:

Regarding Tailings & Waste Rock Management Facilities

  • “A comparison of the costs of a dry stack (86% dewatered) and the proposed 81% dewatering should be provided.”
  • “Examples should be provided that indicate tailings that are 81% solids can be pumped in cold climates.”
  • “Proposed alkaline amendment strategies should be well-fleshed out at this stage, and details of the preferred method(s) provided, including geochemical reactions over time that could reduce the function of the drainage layer.”
  • “Monitoring wells need to be placed to ensure the tailings facility embankment is not contributing acid or metal leaching to groundwater.”
  • “An impermeable cap should be placed on the embankments at closure.”

Regarding Water Management –

  • “Ensure that water can be safely shunted between containment areas to be adequately contained during water treatment plant downtime, heavy precipitation, or rain on snow events.”

Regarding Water Treatment During Mining Operations –

  • “Ensure the costs of filtering wastewater and trucking waste solids material to a landfill and/or a hazardous waste landfill are accurately accounted for.”
  • “The wastewater treatment plant should have already been designed in detail by this stage of permitting, including any wastewater pre-treatment at the tailings facility sump or prior to entering the plant.”
  • Regarding Pit Backfill pH Recommendation – “Discuss how alkaline material will be introduced to the pit backfill after the pit has been capped and revegetated, if limestone is not adequate to consistently produce a neutral pH and precipitate metals.”

Regarding Pit Backfill Metal Leaching Recommendation – 

  • “Given the potential for antimony, selenium, and arsenic to mobilize under neutral conditions, monitoring will need to occur at the TWRMF leachate sumps and at monitoring wells on and around the backfilled pit until hydrology and chemistry have stabilized.”

Regarding Water Treatment Post Closure: Recommendation –

  • “The TWRMF cap is designed to reduce infiltration, but given the extremely acidic nature of the material that will be enclosed, the cost of a WTP should be included in financial assurance for at least the 20 year post closure monitoring period.”
  • “It would be prudent to include the cost of a WTP until the pit has flooded and monitoring wells on show that there is no seepage into groundwater or surface water, and that pit backfill water chemistry has stabilized.”

Regarding Financial Assurance Recommendation –

  • “When reviewing the indirect and direct cost estimates for the Back Forty financial assurance, it is obvious that it has been significantly underestimated, especially with regard to the indirect cost calculations. At a minimum the indirect costs for the financial assurance at the Back Forty project should follow US Forest Service guidelines, and the direct costs should be reviewed by a qualified party to correct assumptions that underestimate the cost of reclamation that would need to be conducted by a regulatory agency.”

Additionally, serious red flag comments address Hydrology (upper weathered bedrock and concerns about the conductivity range), Surface Water Sampling: (“extremely minimal”, eight “snapshots” over several years, additional baseline chemistry needed), and Cyanide (“Aquila does not specifically say that they will sign the International Cyanide Management Code”).

Clearly, MDEQ cannot proceed with any permits for the Back Forty project unless all issues have been satisfactorily investigated and resolved.

Although the Public Comment period has closed, we ask that MDEQ staff accept this technical review. We request that all of the technical recommendations and questions raised in this report by Center for Science in Public Participation be incorporated into the MDEQ’s permit review process, and added to the Public Comment record for this permit application.

Sincerely,

alex-signature.jpg
Alexandra Maxwell, Save the Wild U.P. executive director
———————

Oh My another Mine

mine

Click to Enlarge

Just when you thought we could relax about mining in Wisconsin, the state of Michigan is reviewing a mining proposal, for copper, nickel and other metals, by Aquila Resources (aka Back 40 project), on our border.

The mine may as well be in Wisconsin, for the potential ill effects it could have on the waters we share with Michigan — the Menominee River and Lake Michigan. In fact, the mine will be located a stone’s throw from the Menominee River, the border river between Wisconsin and Michigan’s Upper Peninsula, and in full view from the river.

The state’s Dept. of Environmental Quality (the same agency that let slip the Flint, Michigan drinking water disaster) is reviewing the permit. In terms of public opinion, many people of the economically hard-pressed Upper Peninsula favor the development the mine would bring. Others want to stop it completely. The River Alliance has weighed in, pointing out that a mine failure would wipe out a multi-million dollar sturgeon restoration project we have been part of (not to mention most everything else in the river that would be damaged).

River Alliance of Wisconsin Executive Director Denny Caneff, comments on the proposed mine in a letter to the Department of Environmental Quality:

“We greatly fear this considerable investment to restore this iconic and highly-prized fish will be damaged by even a minor failure at the mine site and possibly entirely destroyed by a major accident there. The sturgeon produced by this habitat restoration project will obviously not be the only animal or plant that would be harmed by a failure at the mine. But given the considerable interest in this prehistoric fish, from a cultural, ecological and commercial perspective, the mine represents a direct threat to all that is being done to revive the sturgeon in not just the Menominee River, but in Lake Michigan as well.” 

One of the films featured in this years Wild and Scenic Film Festival deals with a similar issue in a different location.  An open-pit mining boom is underway in northwest British Columbia, Canada. The massive size and location of the mines – at the headwaters of major salmon rivers that flow across the border into Alaska – has Alaskans concerned over pollution risks posed to their multi-billion dollar fishing and tourism industries. For more information about the Wild and Scenic Film Festival visit: https://www.wisconsinrivers.org/events/display/item/wild-and-scenic-2016.

The Menominee River is being threatened by an open pit mine

If you are a smallmouth bass fisherman you probably know that the Menominee River is a terrific fishery. The river is a major part of the border between NE Wisconsin and the western edge of Michigan’s Upper Peninsula, ending its 116 mile long journey when it flows into Lake Michigan at Marinette, WI/Menominee, MI.

This is a world class smallmouth fishery, a must stop for any angler interested in top quality bass fishing. It’s also a scenic river with mile upon mile of untouched shoreline, beautiful wildflowers and abundant wildlife from bald eagles to deer, even black bear.

This exceptional river fishery is facing a horrific threat: The possible construction of an enormous open pit metallic sulfide mine that would be located dangerously close to its eastern shoreline. The mine would be located downstream of the White Rapids Dam in an area known as “60 islands “, one of the Menominee’s most prolific trophy smallmouth sections.

badgerfly1badgerfly2

Dick Dragiewicz at the Badger Fly fishing show in Madison, WI

To Cyanide, or Not to Cyanide – That is the question.

Quoting from a 1999 paper The Management of Cyanide in Gold Extraction by Logsdon, Hagelstein, and Mudder and released by the International Council on Metals and the Environment, “Cyanide is a general term for a group of chemicals containing carbon and nitrogen.  Cyanide compounds include both naturally occurring and human-made (anthropogenic) chemicals….”    Some naturally occurring sources of cyanide compounds are found in apricots, bean sprouts, cashews, cherries, peanuts, potatoes, lima beans, sorghum, and many, many more common items we see, often touch, and occasionally eat, including common table salt.  This brief report will focus not on the natural sources of cyanide but on human-made cyanide and its uses, particularly in mining and the extraction of precious metals.

In their 1999 paper, Logsdon, et.al., reported the 1996 annual production of HCN (hydrogen cyanide) gas was approximately 1.4 million tonnes, with the bulk of production coming from 3 companies, one of which is Dupont in the U.S.   A tonne is 1000 kilograms or approximately 2204.6 pounds, which means the 1996 production was around 3,086,440,000 pounds of HCN.  Of this production, it is estimated somewhere between 13% to 20% is used to produce sodium cyanide (NaCN), usually shipped to users in the form of solid briquettes in sealed containers, although sometimes it is shipped in liquid form in “specially designed tanker trucks.” (p.11, Logsdon, et.al.)   Included in any shipment of NaCN is a Material Safety Data Sheet listing the chemistry, toxicity, accident instructions, emergency contact information, and other information deemed appropriate by the manufacturer.  In addition to mining companies using NaCN in the extraction of precious metals, numerous other industrial uses for cyanide compounds abound:  nylon and acrylic plastic production, electroplating, steel hardening, synthetic rubber  production, anti-caking additives (such as in road salt), rodent control (with HCN), and at least one anti-cancer drug.

Even though twenty-first century humanity evidently needs products produced by using cyanide compounds, the word itself causes fear. This is because cyanide can be lethal for humans – and  deer, and fish and ….   In humans, ingestion, absorption, or inhalation can be deadly.   Logsdon, et.al., list the 1998 “Threshold Limit Values for Chemical Substances and Physical Agents” (published by the American Conference of Governmental Industrial Hygienists).  The lethal inhalation dose for humans is 250 parts per million of HCN gas in air.   The lethal skin absorption and mouth ingestion values are somewhat dependent on body weight.

Our concern as residents of Michigan and Wisconsin is the use of cyanide by Aquila in its Back 40 Project along the Menominee River.

In its November 12, 2015, application[2] (page 5) Aquila states:  “During full production combined annual production of gold and silver at the oxide plant will be approximately 1.4 million ounce ( oz. ).  The precious metals are recovered from the ore through use of a cyanide leach process to produce a precious metal bearing solution (pregnant liquor).  The cyanide leach process occurs within contained vessels located inside the mill buildings.  Further processing occurs to recover gold and silver from the pregnant liquor using a zinc dust precipitation process to produce a dore product for refining off-site.”

How much NaCN will be used? Table 5-6 in Aquila’s application lists an estimate of 166 tonnes per year for the oxide plant, for the 7 years ( from page 8 of the application) the mine is expected to be in production.  That’s slightly under 366,000 pounds of NaCN per year that will have to be brought to the mine site, unloaded, stored, used, and then eventually “destroyed” – for each of the years the mine is in operation.

In Section 8 of the Logsdon, et.al. paper, evaluating and managing the risks of cyanide include:  (1) Hazard Indentification (What physical, health, and ecological areas could be adversely affected by cyanide exposure); (2 ) Dose – Response (How much?  What will happen now?); (3) Exposure Assessment (How did this happen?); and (4) Risk Characterization (How can we prevent this from happening again?).  According to the paper Risk Assessment must include not only possible impacts on the general population and the environment, but especially for the workers who are “most likely to be exposed to the hazard.”  Transporting, receiving, unloading, handling, storing, and using NaCN are each possible exposure points.   A quick survey of the table of contents of the application and an admittedly quick reading of the 45 pages of Volume 1 of the application did not reveal any mention of worker training.  The only mention is a short paragraph on page 44 stating:  “Possible HSE (health, safety, environment) risks to on-site workers will be addressed by Aquila through a health and safety plan which is (sic.) complies with Occupational Safety and Health Administration (OSHA) and Mine Safety and Health Administration (MSHA) requirements.” Also, there is a bullet point on page 20 stating that MSHA safety standards during mine operations will be met.

Let us all hope that the systems engineering is accurate, that the systems function correctly, and that all stated requirements and standards for safety are followed and will indeed protect the workers, the environment, and all of us from contamination and worse.

Mark J. Lagsdon, MSc; Karen Halelstein, PhD, CIH; Terry I. Mudder, PhD, The Management of Cyanide in Gold Extraction, International Council on Metals and the Environment, 294 Albert Street, Suite 506, Ottawa, Ontario, Canada  K1P 6E6., 1999.  It should be noted that a search for ICME will be redirected to the International Council on Mining and Metals (ICMM) and that the web site for ICME will display the word “Obsolete.”

DEQ-OOGM D 2015 22054 2015-11-12 Aquila Resources Mining Permit Application – Volume I.pdf