CCNB presents to the Sisson Mine Environmental Impact Assessment Review Panel

Presented to the Review Panel of the Environmental Impact Assessment of the Sisson Mine project on June 22, 2014, in Stanley New Brunswick.

Good evening to those in attendance and panel members.

Since the beginning of the federal and provincial environmental impact assessments for this project, the Conservation Council has not taken a position on the mine. Instead, our efforts have been focused on trying to get Northcliff and now Sisson Mines Limited to prepare an EIA report that is of the highest quality—one that fairly and accurately details the positive and negative impacts of the proposed mine. Unfortunately, the EIA report prepared by Sisson Mines Limited shows it does not understand or appreciate the harm that can be caused by the mine and its wastes. As a result, the Conservation Council of New Brunswick is asking that Sisson Mines Limited not be given approval to construct and operate the proposed Sisson tungsten and molybdenum mine.

When we give private companies such as Sisson Mines Limited the opportunity to exploit and profit from public natural resources, we are placing our trust in them to do so in a way that brings benefits to local communities and our economy and doesn’t poison us and the environment.  One way resource companies can demonstrate they are worthy of this trust is by conducting thorough environmental impact assessments.

Think of an EIA like being a test for a driver’s license. We all know that driving can be dangerous. By passing your driver’s test, you have demonstrated you understand the rules of the road, appreciate the risks of bad driving, and have a certain level of skill and competence. Your driver’s license is a privilege, not a right, you have to earn it and it can be taken away.

For Sisson Mines Limited to earn the environmental and social license to construct and operate the proposed mine, its EIA needs to show that the company clearly understands the risks of this project and can competently carry out the project. The three examples I will discuss show how Sisson Mines Limited has not done this and as such should not be entrusted with a license to construct and operate this mine.

Example 1 – Implausible denial

Not assessing the impacts of a failure of the tailings pond dam – Wanting to know what would happen if the dam for the tailings pond breaks is not an unreasonable request. However, throughout the entire EIA, Sisson Mines Limited has refused to address this important issue. In its EIA report submitted to the federal government in 2013, Sisson Mines Limited did not bother to assess what would happen if the tailings pond dam broke because it said that this could not be considered a credible accident.

For the provincial EIA report it was asked to look at this issue again. Sisson Mines Limited’s response; a 10-page report with little detail. Clearly this is not sufficient and because Sisson Mines Limited has not provided enough information about this issue, the Department of Environment has now had to contract another company to review the design of the tailings pond.  The Conservation Council is not sure why Sisson Mines Limited continues to deny or hide from this potential catastrophe, but we feel it raises real concerns about the company’s willingness and ability to properly care about it in the future.

Several final thoughts on this topic.

  • Even though the failure of the Mount Polley tailings pond in BC occurred in August 2014 and the final version of the EIA report for the province wasn’t completed until February 2015, there is no mention of the Mount Polley catastrophe in Sisson Mines Limited’s tailings pond failure report.
  • An independent review of the Mount Polley tailings pond collapse concluded that in BC there is a 1 in 600 chance of a tailings dam failure in any year (Mt. Polley Report, p. 118). Sisson Mines Limited’s prediction: “the proposed TSF for the Sisson Project would have an annual probability of failure of between 1-in-1 million to 1-in-10 million” (from p.G-4). I know they do things different in BC, but not enough to explain this discrepancy.

I think an expert with 20 years’ experience hired by the Conservation Council to review parts of the EIA said it best,

“Tailings dam failure is a low probability event, but also an event with high consequences. These consequences have never been ignored in any other EIS/EIA I have reviewed. To in essence assert that ‘my engineering’ could not possibly fail, in light of existing statistics, is arrogantly assuming that it is always the other guy (or gal) that will make a mistake – but not me. This is exactly the attitude that leads to accidents…”

 

Example 2 – Lacking an air of reality

Failure to properly address waste water from the mine – Let’s be clear, this mine will generate water that is toxic. That is a fact of life for hard-rock mines. Knowing this, the question becomes, if this mine is permitted, can you manage and treat this water. Like the issue of a failure of the tailings pond dam, Sisson Mines Limited does not demonstrate it appreciates the risks of the mine’s wastewater and therefore that it should be trusted to operate the mine.

There are many examples of this, but I just have time to focus on a couple of them.

In the main text of the EIA report, the water quality of the effluent flowing from the waste water treatment plant is not discussed – you have to go to an appendix of an appendix for that information.

  • Based on 2012 details for the Mt. Pleasant mine here in New Brunswick = less than 3 mg/L fluoride in the effluent from its tailings pond.
  • During operations, with the waste water treatment plant as proposed by Sisson Mines Limited, the effluent will have an average fluoride concentration of 4.5 mg/L.
  • Therefore, this suggests a wastewater treatment plant that lowers fluoride levels will be needed for Sisson.

Levels of other contaminants such as arsenic are also much higher coming from the wastewater treatment plamt than is discussed in the main body of the EIA report. Essentially, what the EIA shows is that Sisson Mines Limited is relying on the Napadogan and other streams to dilute effluent and meet guidelines, rather than treat wastewater so that it meets guidelines before being released.

Finally, there is no air of reality to Sisson Mine Limited’s plans for its wastewater treatment or bonding requirements.

  • Early in the EIA report, it states 6 million m3/year flows from tailings storage facility to waste water treatment plant during operation (EIA report 3-131).
  • Appendix H to EIA report – After closure, 4.16 million m3/year flowing from open pit that needs treatment.
  • Where does this 2 million m3/year go after closure?
  • More importantly, in a response to an information request from the Canadian Environmental Assessment Agency, Sisson Mines Limited reported that post-closure there will actually be 10,799,970 million m3/year of water pumped from the open pit to the wastewater treatment plant (August 28, 2014) (p.14-13).
    • What is the right amount?
  • This is important for the environment – not enough treatment capacity, means environmental damage.
  • Important economically.
    • $800,000/4.16 million = $0.19/m3 * 10 million m3/year = $1.9 million/year, which more than doubles the treatment cost
    • Finally, there is the plant itself – fluoride needs to be treated, therefore a more expensive wastewater treatment plant needed.

The waste water treatment plant is one of the most necessary components of the project needed to protect the environment and yet Sisson Mines Limited downplays the risks and costs. This part of the EIA report fails the test, therefore Sisson Mines Limited has not demonstrated it deserves a license for the mine.

 

Example 3 – Unfounded over-confidence

Poor archeological research – The original EIA report written by Northcliff (now Sisson Mines Limited) in July 2013 and filed with the Canadian Environmental Assessment Agency confidently stated that is was “highly unlikely” that artifacts would be found on the site of the mine (p.8-625). Obviously, the later discovery of an 8,500 year old arrowhead or knife and 500-plus other artifacts on the mine site shows that Sisson Mines Limited should not have been so bold in its prediction. [SLIDE]

The problem is that the EIA report is filled with these types of assertions about the project—that all its potential impacts are “highly unlikely” or will be carefully managed. I don’t know about others, but I prefer an honest discussion of facts versus hype.

Conclusion

To conclude, you ask a new builder to draw up some plans and a budget for a home you want built. The estimate comes back and the price is surprisingly low. You’re happy until you notice the plans, among other things, don’t include the second bathroom you asked for, only the lowest quality materials will be used, like shingles that will have to be replaced in 15 years or less, or that there is no mention of the cost of building and other needed permits. Based on this, would you want this builder to build your dream home? Likely not. Instead you would look for a builder who would take the care to provide an accurate estimate and plans that meet your needs and wants.

That is how the Conservation Council feels about this proposed mine. The EIA report is the estimate. It shows that Sisson Mines Limited does not want to address legitimate public concerns about the project and downplays or misunderstands the potential environmental harm this mine could cause. Given this, we do not believe Sisson Mines Limited should be entrusted with our resources, and therefore should not receive a license to construct and operate this mine.

 

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