Questioning the long-term future of the St. Mary’s River and surrounding community in the shadow of the proposed Cochrane Hill Gold Mine.
Preface: With the recent announcement of the friendly takeover of Atlantic Gold by another Australian mining company St. Barbara, it becomes imperative that the community speak out. See information on the takeover Atlantic Gold
Dr. Spencer is an Emergency Medicine Physician, Mechanical Engineer, Assistant Professor in Medicine with Dalhousie University, and Entrepreneur with two start-up companies in the Halifax area. On a personal note, the St. Mary’s River in Guysborough County has been a very important natural resource enjoyed by 4 generations of Dr. Spencer’s family. They have had a seasonal residence on the river just downstream from Cochrane Hill, for many years. In fact, his connection to the natural environment of the St. Mary’s River was an important contributory reason when he moved his medical practice from Ontario back to Nova Scotia. “My father’s generation enjoyed fishing salmon on the St. Mary’s River and as a child I accompanied him many times. Due to a combination of human-created adverse environmental consequences, and within a very short time-frame relative to the natural history of the species, wild Atlantic Salmon have become scarce. Responsibly fishing salmon fosters a connection with the natural habitat, and unfortunately, I cannot share this experience with my children on the St. Mary’s River as this species remains at imminent risk. This is just one of many examples of how broad human interaction unintentionally (and often irreversibly) impacts the environmental future of a region.
Dr. Kevin Spencer: Along with other community members, I am trying to become educated in order to responsibly weigh in on the issues. I have several questions that I believe are shared by you and other community stakeholders. I hope they encourage your further consideration of the scope and seriousness of all the issues at stake.
I believe this mining operation has the potential to seriously and irreversibly disrupt the surrounding natural environment, and derail years of efforts to preserve this environment for our future. The project proposes drawing and discharging huge amounts of water from a nearby lake and the river. The open-pit excavation will disturb and expose “naturally occurring radioactive materials” (NORM) and heavy metals. The groundwater “radius of influence” related to the open pit encompasses a wide swath of the natural watershed. When profitable operations complete in 6 or 7 years and the company moves on, there will be vast amounts of harmful tailings in (hopeful) containment left behind for perpetuity. If there was even a single spill or other event that allowed harmful materials to enter the river, this could have catastrophic effects and cause irreparable damage to fish, birds, animals, the river and surrounding area, including wildlife habitat important to at-risk species (e.g. wood turtle). The short-term jobs and few economic benefits of this project do not justify the serious and long-lasting environmental risks. I believe allowing this large open-pit gold mine near the St. Mary’s River is unacceptable.
1.The single worst issue in my opinion is really the tailings dam and stored material. There were originally five locations for the tailings dam management facility (TMF).
- Why were the two locations north of the road rejected and not included as potential alternatives to the current location?
- What analysis went into choosing the current TMF location?
- What analysis is going into the two alternative locations? The resource estimate for Cochrane Hill has been increased with ore zones located at depth under the current pit location and ore resource extensions to the east. Has the TMF modelling taken into consideration this increase in resource volume. Not one aspect of the current guidelines for the preparation of the EIS takes this resource increase in consideration.
- What detailed TMF management plan has been developed?
- What is the normal operating level of the tailings pond? What is it as the mine progresses from year to year and fills up?
- Has climate change been factored into the modeling of the management of the TMF.
- What are the “acceptable levels” of inorganic, organic, metal, hydrocarbon discharge, volatile organic compounds discharge to surrounding surface waters.
- Are mine tailing containments a “sure-thing”? Are there examples of mining tailing containment breaches with associated ecological disasters and economic recoupment problems?
- What dam failure modeling has been undertaken to determine the environmental impact of dam breaches.
2. What is the current legacy of gold mining in general, in Nova Scotia, and in the Sherbrooke region?
- Will new Cochrane Hill mining operations, blasting, water table disruptions, etc. exacerbate and disrupt the piles of toxic material left over from the last operation there?
- How will (and how long will) the tailings and chemicals related to this new Cochrane Hill operation persist in the environment?
- How will the future generations judge the legacy we now create from this proposed large, open pit mine in close proximity to an important river system, and on the heels of these prior environmental calamities?
3. How likely is it that environmental compliance and monitoring would be comprehensive and bulletproof, both during project operations, and for monitoring the leftover waste and tailings for the decades (or perhaps hundreds of years) after the gold extraction is completed and mining company has moved on from the St. Mary’s River watershed?
- What is the cost associated with comprehensive monitoring and who pays for it?
- How reliable will the monitoring actually be?
- Is it audited? Is it independent? Is the monitoring frequency adequate?
- How in-depth is the monitoring? Soil samples? Hydrodynamic studies through various seasons and after significant rainfall events or drought events?
- What is triggered if monitoring detects problems? What is the response? Who pays for that? How robust is the response? Is it simply broadening of the containment, or is offending material removed or otherwise remediated in a definitive way?
- Will comprehensive monitoring continue in perpetuity? See reclamation blog.
- The tailings will remain in perpetuity, we know that former mining sites are not adequately monitored currently, what is tangibly different here?
- Atlantic Gold’s project description summary (page 17) states “…two years will be needed to complete regrade and re – vegetation of the site, after which monitoring will continue until deemed no longer necessary – typically two to three years post – reclamation”. Does this seem largely inadequate considering what is at stake? How long (hundreds of years?) would these tailings expect to persist in a toxic state?
Of relevance, the Nova Scotia Provincial Auditor General Michael Pickup published a report in late 2017, indicating a failure in the government monitoring and enforcement of industrial projects to ensure they comply with their environmental terms. This sets a skeptical precedent. Pickup Report . Environmental Monitoring Comments Section.
- Knowing that compliance, monitoring, and enforcement is historically insufficient as evidenced by the Auditor General’s report for the Province, how can we be certain that appropriate compliance, monitoring, and enforcement will occur for this project?
- If the company doesn’t comply, what enforcement options exist?
- What is the probability that enforcement would actually change outcomes? A fine doesn’t repair the damage.
- What is the probability that this will become the next “Boat Harbour” fiasco for the Province?
- What happens if the mining company folds?
4. What is the mining company heritage and reliability? We know they are a business motivated primarily by profitability (and that’s ok, that’s business). Are they a solid, established, ethical company? Does their leadership have a good track record? Is Sherbrooke’s interest and environmental stewardship anywhere near the forefront?
- How long has this company been operational?
- How economically stable are they?
- Where are they actually based? The origin seems confusing and complicated: “Australia – based Atlantic Gold has entered into an agreement to merge with natural resource company, Spur Ventures, which is head quartered in Vancouver, Canada. Under the terms of the agreement, Spur Ventures will acquire all shares of Atlantic for $30.2m by way of a scheme of arrangement. The merger will pave the way to fund the development of Atlantic’s Touquoy Gold project in Nova Scotia, Canada.”
- Where do the profits flow?
- Where do their employees come from?
- Where do the directors, executives, and board members reside?
- What are the backgrounds and accomplishments and failures of the executives?
- Where does the main distribution of shareholders live?
- What is the probability that they will complete this mining venture and cleanup as required?
5. Has minimally appropriate environmental modelling been completed? .
- Various points in Atlantic Gold’s 35-page Sept 2018 project description summary suggest “planned modelling” and “modelling that is underway”.
- Has this company demonstrated a commitment to comprehensive environmental modelling? How much are they willing to invest in this modelling? Did they try to push this project through with a superficial look at environmental issues?
6. Has the groundwater and surface water baseline conditions been adequately evaluated? Is the analysis of water movement and flow for the region comprehensive enough?
- Regional water flow is profoundly important for understanding the industrial risks to the river system. Have there been robust hydrogeological investigations covering the full compliment of seasonal and weather variations and that include drilling and sampling and molecule migration assessments, to adequately map ground water flows, for the region of the mine and the full radius of influence of anticipated groundwater depressions?
- If not, how can you understand the hydrology in detail without this, and how can you have a robust emergency response plan if you don’t know where the molecules are going?
- If so, have the hydrological models run various scenarios, including extreme flood conditions, hurricane and hundred-year-storm events, drought events? If not, why not?
- Does this include the lake regions that water is being drawn from, and the regions expected to hold the tailings?
- How will dewatering of the open pit, and blasting in the area, adversely affect the watershed?
7. How will all these new activities affect the stores of toxic tailings that are left over from the last gold mining activities?
8. Has or will the environmental assessment include climate change models?
9. Has the potential for earthquake activity been considered? “There is still a tendency to underestimate the consequences of failure due to earthquakes during operations and to adopt an earthquake loading that is too low, especially in areas of minor and moderate seismicity” (Morgenstern, 2011).
10. How will critical habitats and species at risk be affected?
- Wood turtles?
- Other at-risk species?
11. How is NORM being addressed? (Naturally occurring radioactive material).
12. What is the anticipated adverse financial and safety effects related to the “haul route” (i.e. Highway 7), and to other supply routes for the mine? The company business model claims use of existing infrastructure as a compelling project feature. Access to this haul route saves them costs, but I do not see a plan to cover the costs incurred to taxpayers for using this route, or discussion about the risks of 7 years of continuous and heavy truck traffic on this route.
- What is the anticipated Roadway life consumed by the mining project?
- i. The use directly related to this project alone will probably necessitate resurfacing of the highway, which is a taxpayer liability. For reference, wear and tear from one 18-wheeler is equivalent to that from 9,800 cars.
- The project description summary states “8-axle 58,500kg C-Train Double Haulers” will be used. These are large, custom, tractor trailers that also have an additional large dolly trailer in tow. Do the stakeholders (property owners and businesses) along the “haul route” understand what is being proposed here?
- Atlantic Gold indicated (pg16) that they intend to apply to NSTIR for exemptions to the current weight restrictions on two sections, at Mooseland Rd, and for 51km of Highway 7. If there is a weight limit to keep the road intact, and the intention is to run their regular daily trucks over this route for 7 years continuously, but not pay for resurfacing, then why would an exemption be considered or approved by taxpayers?
- Weekly “gravity concentrate” transports are noted separately and are noted to require security. Is this due to concerns about toxicity, or due to concerns about high-jacking? What are the risks?
- If we assume 0.5 lb of explosives (i.e. dynamite) used per tonne rock mined, and we are mining 43 million tonnes of rock, we are looking at 21 million pounds (10,000 tonnes) of explosives that need to be shipped to the Cochrane Hill mine site, and then exploded over the course of the operations. The project description has one line indicating explosives are subcontracted out, without further detail.
13. What is the risk related to shipping, storing, and using all this explosive?
- How much explosive would ship with each associated transport truck shipment? This sounds like a lot of explosives and at 10,000 tonnes, it is. For reference: The Halifax Explosion ship Mont-Blanc was apparently laden with 200 Tons of TNT. The Hiroshima nuclear bomb is roughly comparable to the amount of explosive going into Cochrane hill, by these estimates.
- What is the transport route? What is the collision, accident, and rollover risk?
- What would it cost to fix or resurface the highway after all these trucks?
- I asked for a ballpark quote from an established construction company, for resurfacing 120 km of the “haul route” of Highway 7. The answer was approximately $40 million. I understand the mining operation is not going to pay for resurfacing of Highway 7 or other supply routes, at completion of project, or at any point, is this correct? This cost needs close attention in any economic assessments. First, increased traffic loadings would shorten time interval to the next resurfacing. Also, moving resurfacing expenditures nearer to the present would increase the real cost for resurfacing because of the time-value of money. If the funds required to resurface highways sooner were not available to highway agencies, pavement condition would worsen, and highway users would be subject to added cost and discomfort (and increased personal vehicle wear and tear for regular users of the affected roadway) Road maintenance costs in-between resurfacing intervals would also be increased.
- What are the safety probabilities?
- Will anyone die or get hurt from all these trucks? Truck related vehicle accidents, collisions, and rollovers can be expected to occur. How has the mining company presented these risks?
- Considering the narrow shoulder, winding road, limited passing lanes, high speeds (80km/h), weather and road surface effects, traffic densities, double hauler tandem trucks, and the various hazardous toxic and explosive materials being transported, what is the estimated loss of life to be anticipated over the duration of the project? What cost to society (financial and otherwise) comes with these types of issues?
- What will be the vehicular accident rates, ranging from minor (i.e. stone chips, roadway debris related car damage) through to major (such as loss of life), related to highway 7 industrial use over the course of the mining project? Once calculated, is this risk acceptable to the community stakeholders?
- What is the effect of particulates and dust on properties lining the route, including toxicity related to the dust from transported materials?
- How severe is the toxicity of the transported materials and what are the cleanup strategies in event of spill or accident? Large portions of the “haul route” border rivers, streams, and ocean.
- What are the noise effects, air brakes, etc.?
- What is the safety related to pedestrians, pets, children, and school buses along the highway 7 route?
14. How disruptive to local residents will it actually be, to excavate, crush, and then process 43 million tonnes of rock over 7 years, which is 22,000 tonnes of rock per day? It appears the mine will operate 24 hours a day, 7 days a week. Is this correct?
15. Noise: Local residents within 5km of Cochrane Hill are generally aware the new nearby quarry operations, which are easily heard during operation and arguably do disrupt the peacefulness of the river valley. How will the noise compare from this mining operation, which is many magnitudes of scale larger?
16. Blasting: As noted above, we are probably looking at something like 21 million pounds of explosives to be used over 7 years.
- How will this impact the local residents?
- How many blasting pulses will occur over the course of the project?
- Blasting is quoted in their summary to be expected 2-3x a week, with diesel powered hammer drills running regularly in-between.
- How far away will blasting be felt?
- Will this blasting activity be expected to crack or damage foundations, wells, and other residential infrastructure? What is the radius of concern for this? Is the mining company liable for associated damage?
- What is the radius of high and moderate risk associated with projectiles from blasting, and which residences fall within that?
- Occasionally blasts are larger than expected and rocks go flying impressive distances. What is the occurrence frequency of such anomaly events?
In summary, I hope these questions are considered by the Councillors as part of their decision on a position. I believe all these questions, and the questions of other stakeholders, should be answered before any further consideration of Atlantic Gold’s proposal to mine Cochrane Hill. I also believe all community and government stakeholders should be given every opportunity to become educated on the scope and implications of this project.
Kevin Spencer, MD, P.Eng.