About the Talon Tamarack Mine
Talon Metals corporation is registered in the British Virgin Islands and is engaged in a joint venture with Rio Tinto on the high sulfide nickel-copper mining project located in near Tamarack, Minnesota. The proposed mine in Tamarack is an underground mine that threatens both the local environment and communities downstream of the Mississippi river, St. Croiz river and the St. Louis river. More information on the details of the mine is available at tamarackmine.org/mine.html.
Summary of Concerns
Water
There are many serious unanswered questions relative to groundwater impacts due to mining operations. Millions of gallons of water per day will flow into the underground mine through various openings, cracks and fissures in the bedrock as the mine fills with ground water. In fact, Page 228 of the 2021 Talon Preliminary Economic Analysis (PEA) indicates average pumping requirements of over 2.3 million gallons a day with levels reaching as high as 2.6 million gallons per day. The Talon December 2024 mine plan admitted (Line 2248) that this estimate is based on only 4 hydraulic bore holes in the area in 2020 before any mine plan was developed. As such its possible that none of these holes are in the current project area. Thus, the estimate is highly speculative and the actual pumping requirement may be much higher. Since most of the water pumped is a result of seepage from the aquifers above the mine, pumping of water out of the mine also depletes the aquifers, potentially significantly lowering surface and well water levels.
On page 228 of the 2021 PEA, Talon notes that groundwater inflows are based on an average inflow of 9.9 gpm per water bearing feature with one water bearing feature per 216m of drill data as measured through past logging. As mining occurs, large caverns (stopes) will be created increasing the surface area and associated number of water features. Talon indicates that some of these stopes would be filled with a mixture of gravel and some cenemt as a binder. But this mixture is not water proof and as such, the stopes greatly increase the number of exposed water features and thus creating a significant amount of additional water that must be pumped out. In addition, multiple blasting events per day will create added stress on the surrounding bedrock likely opening new fissures that will leak more water. How much beyond the 2.3 million gallons a day must now be pumped? Will it be 5 million gallons? More? Talon Metals refuses to answer this question. They don't know had evidently do no plan to do more testing an analysis to provide better estimates.
This is dirty water (contaminated by sulfide dust as well as direct contact with the sulfide ore). Talon has indicated they may use a Reverse Osmosis filtering system to filter this water. However, will be systems be engineered to treat the actual amount of pumped water? Particularly when they don't know how much water? And where to they put all this water? They have proposed the use of an unnamed stream through the wetlands to the Tamarack River. But this will disrupt the wetland and in the winter when this area freezes, the mine water could cause significant local flooding. If the water is not properly filtered (e.g. more water than their filters can handle) the entire area could be contaminated.
Based on soil data from the Natural Resources Conservation Service, depth to water in surficial soils in the mine area (447 acres) is less than 1 foot in approximately 77% of the Project Area. Approximately 302 (out of 447) acres of wetland are present within the Project Area. Thus the mine target area is a large wetland that will be significantly affected by mining operations.
The Michigan Eagle Mine is an underground nickel-copper mine similar to what is being proposed for Tamarack. Consider the document: www.eaglemine.com/_files/ugd/c6167e_568f076601bc48e7a02b54f222b4165a.pdf. This Eagle Mine Anomalies Report listed over 20 monitoring situations that show levels of pollution and water chemistry changes outside the planned benchmark range. For example, one water level monitoring point showed the water level was 2.8 feet below the minimum baseline level. The mine attributed this drop in water levels to two main sources; pumping of the mine services well and groundwater infiltration into the mine. This drop in water levels is then due to an average pumping requirement of 80,000 to 150,000 gallons a day from the mine and service wells. If a 2.8’ drop is seen at these pumping rates, what happens when Talon estimates over 2,300,000 gallons pumped per day?
In addition, the Eagle mine listed at least 20 monitoring events that show levels of pollution and water chemistry changes outside the planned benchmark range – some with sulfate levels that exceed Minnesota's wild rice standards by a factor of 1500.
Water quality in the area must be preserved! To date, sulfide mining has a 100% track record of failure to protect water quality in water-rich environments.
Surface Areas NOT Lined
Talon now plans to "enclose" in buildings most operations related areas and ore storage facilities. But floors may be just gravel (said to be “impervious” by Talon). However, gravel is NOT impervious to water flow and even asphalt will crack and leak over the life of the mine. Flooding, roof leaks and water usage for dust management will still contaminate the soil under the buildings.
At the Eagle Mine in Michigan, the TDRSA (Temporary Development Rock Storage Area) is lined with both a primary and secondary lining. Lining surface areas is a best in class technique and originally, Talon said that they will be "better" than the Eagle Mine. They have since proven that statement wrong.
Air Quality
Vented airborne dust from blasting and mine operations is contaminated with sulfides and other toxins. Both the mine itself as will as the buildings must still be ventilated but Talon has only committed to "reduce particulate matter" AND NOT to filter out airborne toxins. Indeed, they have not reported on what toxins exist in the dust (they know since they have drill hole data). We note that the Michigan Eagle Mine monitors for at least 33 different toxic substances. Nevertheless, there is no provisions in the Talon plan to identify or filter specific toxic substances from their mine and building vent stacks.
Asbestos can be present in taconite mines increasing the risk of asbestos exposure for workers. Talon makes no statement that they are even looking for asbestos in the mine dust ( https://cancer.umn.edu/news/connection-between-iron-range-miners-and-asbestos-related-disease).
Since sulfates and other toxins are not well filtered out of the air vents, accumulation will occur in the local area causing storm water to be contact water and poluting the local environment. Currently, Talon does not include stormwater in their estimate for how much water should be filtered.
Community Impact
The mine plans to blast 2-3 times a day to free ore from the bedrock for extraction. These blasts will be heard and felt for many miles around the area. Since over 8000 blast events may occur over the life of the mine, it is likely that builing foundations will be affected. This area is comprised of sand/gravel fill and as such, is very susceptable to settling under conditions where the ground is shaking. Will Talon take responsibility for this damage?
Blasting operations produce toxic gaseous products including carbon monoxide (CO) and the oxides of nitrogen (NOx) http://stacks.cdc.gov/view/cdc/161251/cdc_161251_DS1.pdf.
Parts of Oklahoma now have the same earthquake risk as California due to “blasts” from fracking. This could easily be the case around the Talon mine as well. A new study found a scarily direct link to fracking (https://www.businessinsider.com/earthquakes-fracking-oklahoma-research-2018-2). A large increase in small tremors (similar to the blasting) due to fracking have resulted in significant road and building damage. In Oklahoma. Indeed, fracking may have damaged hundreds of traditional vertical wells ( https://www.hppr.org/hppr-environment/2017-09-24/in-oklahoma-fracking-may-have-damaged-hundreds-of-traditional-vertical-wells). As a result, Oklahoma tightened regulations to curb fracking earthquakes ( https://www.eli.org/vibrant-environment-blog/scoop-stack-causing-cracks-oklahoma-tightens-regulations-curb-fracking.
Real estate values will drop - who wants to buy property next to a toxic mine where blasting may heard and felt any time of day? In addition, the large Talon holdings for mineral rights in the area (about 32 square miles) will impact landowners also likely affecting property values.
Since Talon is wholly owned by a non-US company, what happens when Talon leaves? What if they go bankrupt? Is the community left with the mess to cleanup? Any cleanup (which will likely be required) will end up using tax payer dollars. Why are US taxpayers supporting foreign extractive industries?
Rail Transport
Ore will be hauled to North Dakota via rail transport for processing, Each 120-car unit train would haul approximately 13,900 tons (12,600 tonnes) every 4.1 days on average. Ninty trains per year. Talon is currently expecting to use conventional gondola railcars with covers made of solid and impervious material. The BNSF Railway would exchange the loaded unit train with a unit train of empty enclosed railcars returning from the processing facility in the on-site rail yard on a regular basis. About 30 of the empty unit train cars would be loaded each day and consolidated on the release track until the next 120-car unit train is filled and released for shipment.
However, all of these rail cars have seep holes to shed water and as such, will leak toxic sulfide ore along the long route to North Dakota. With these trains running continously for 7-10 years, a great deal of toxic material could be leaked and then distributed by rain water into the environment. Finally, since the ore will likely be wet (given the large about of water in the mine, the ore could freeze in the winter making it impossible to unload.
Wetlands Will Be Destroyed
Approximately 302 acres of wetland are present within the Project Area. Wetlands will be destroyed around project structures and the rail line from Tamarack. Talon specifically says “Construction and operation of the Project would result in the direct impact of approximately 71 acres of upland and wetland wildlife habitat and could further habitat fragmentation in the Project Area." In addition, Talon says “the wetland complex in the Project Area may have been used as burial sites, raising the possibility of inadvertent discoveries."
Other Issues
Talon defers any analysis of hazardous waste to the EIS. Thus Talon apparently does not know what hazardous waste products will be produced nor how to mitigate the effects. Talon has no hazardous waste plan nor do they discuss issues related to cross contamination of hazardous waste. Of course, they should have a hazardous waste list prior to EIS as how can you identify the environmental impact without this information? And mitigation may change the mine plan affecting other parts of the EIS work
Talon defers any analysis of wildlife in the project are to the EIS Thus Talon does not know very much about the wildlife in the project area. However, they need to know this prior to EIS otherwise, how can you evaluate the impact of operations before such information?
More detail supporting these concerns can be downloaded here in PDF format for distribution.
Responsible Mining
Mines have a large impact on the local environment as well as the local economy. Mines may employ local residents and may get more directly involved by financing local suppliers and thus promoting local trade and growing the local economy. Mining operations also pay a significant amount of money to the state in taxes and royalties.
Nevertheless, mining operations have the potential to negatively impact the local economy and environment in ways that can severely affect the health of the community that may not have mitigations. These health impacts may not only be life impacting but may persist in perpetuity. In addition, high sulfide mines have historically required a great deal of cleanup usually largely funded by tax payer dollars. Are the health and tax implications worth it?
We define "Responsible Mining" not as cooperation with a mining company, but rather as the set of responsibilities incumbent upon the mining entity associated with the impacts on the community and environment. Generally, we expect the mining entity to address the concerns of the community and mitigate environmental impacts to the satisfaction of all parties. Depending on the local context, it may be that mining in a specific location is not responsibly feasible.