environmental.assessment@gov.sk.ca
Alvin Yuen
Senior EA Administrator
Environmental Assessment Branch
Saskatchewan Ministry of Environment
3211 Albert Street
Dear Mr. Yuen,
Re: Environmental Assessment of Fortune Minerals - Metals Processing Facility, 2010-064
I would like to comment on the presence of actinolite, which is a type of asbestos, in the ore Fortune
Minerals plans to mine in the Northwest Territories, partially process, then bring to the Langham area
in the form of filtercake, and leave as a component of the waste to be left permanently at the site. I
believe Fortune Minerals, their consultants and the Ministry have not properly assessed the danger this
asbestos would pose to the health of workers, neighbours and future generations. I believe that the
danger is sufficient grounds to deny Ministerial approval of the project under the Act.
Actinolite is is an amphibole silicate mineral. It is fibrous, and its name, from the Greek word for “ray”,
refers to its sharp, pointed crystals. The Saskatchewan Occupational Health and Safety Act regulations
defines “asbestos” as the fibrous form of crocidolite, amosite, chrysotile,
anthophyllite, actinolite, tremolite or a mixture containing any of those minerals. (PART
XXIII, clause 330). It is a recognized carcinogen. Once inhaled, it is impossible to
remove asbestos particles from the lungs. Because of its crystal's shape, actinolite
asbestos is more hazardous to health than chrysotile asbestos, which until recently was
being mined in Quebec.
In the document “SMPP Storage Facilities” which is posted on the Fortune Minerals website, under the
heading “Process Residue” the company says “The primary mineral constituents of the residue are
projected to be Gypsum, Scorodite and Actinolite.”1
In Fortune Minerals' EIS Main Document there is only one mention of actinolite. This is found in a
table on page 41. The table shows that actinolite makes up 19.1% of the acid leach recovery of the
cobalt and gold residue stream. The EIS says “the process residue will consist of three components: 1)
acid leach recovery of cobalt and gold residue; 2) copper re-leach iron (Fe) and gypsum residue; and 3)
iron precipitates from the bismuth CLER process, in the ratio of 53:41:2, respectively.” and it goes on
to say“the three process residue components will be coarsely mixed during transportation to, and
placement in, the PRSF.” It does not specify the technique by which the streams will be mixed or the
risks associated with the mixing process, nor does it mention that actinolite is a type of asbestos.
On page 5 of Appendix A - Conceptual Development Plan Process Residue Storage Facility it says
“The process residue to be contained within the PRSF will be from multiple residue streams having
varying characteristics. The resulting residue will be a fine filter cake made up of particles generally <
[less than] 15 microns. The primary mineral constituents of the residue are projected to be Gypsum,
Scorodite and Actinolite.”
1
SMPP Storage Facilities http://www.fortuneminerals.com/files/SMPP_Storage_Facilities.pdf
In Appendix S – Public Consultation Supporting Information, two media reports from February and
Mary 2011 are reproduced on pages 51 and 63. In them, Rick Schryer, Director of Regulatory and
Environmental Affairs for Fortune Minerals mentions that 2% of the plant's process residue will be
actinolite, but he does not explain that this is a form of asbestos.
The plant calls for production of 158,000 tonnes of waste per year over 18 to 25 years. At 2% actinolite
this would comprise 3,160 tonnes of asbestos per year, or a total of 56,880 to 79,000 tonnes over the
duration of the project.
Actinolite asbestos has been listed on Annex III of the Rotterdam Convention2 since 2004. Annex III is
a list of pesticides and industrial chemicals that have been banned or severely restricted for health or
environmental reasons by two or more Parties and which the Conference of the Parties has decided to
subject to the prior informed consent (PIC) procedure. Annex III references the fact that Europe
undertook an independent risk assessment which confirmed that all forms of asbestos
can cause lung cancer, mesothelioma, and asbestosis; and that no threshold level of
exposure could be identified below which asbestos does not pose carcinogenic risks.
There has been no opportunity for prior informed consent by Langham and Dalmeny
area people regarding actinolite because Fortune Minerals has not properly
disclosed information about the substance.
In Asbestos-related lung disease, an article published in the medical journal American Family
Physician, the authors state, “The inhalation of asbestos fibers may lead to a number of respiratory
diseases, including lung cancer, asbestosis, pleural plaques, benign pleural effusion, and malignant
mesothelioma.” The article continues, saying “Diffuse malignant mesothelioma is an aggressive tumor
derived from mesothelial cells, most commonly of the pleura. It is uniformly fatal, with a median
survival time of six to 18 months from diagnosis. Among persons who have worked with asbestos, the
lifetime risk of developing mesothelioma is high, although the condition is relatively uncommon, with
approximately 2,000 new cases per year in the United States. However, even relatively low-level
exposure has been associated with an increased risk of developing mesothelioma.”3
The US EPA Integrated Risk Information System classifies asbestos as a human carcinogen. It says
“Observation of increased mortality and incidence of lung cancer, mesotheliomas and gastrointestinal
cancer in occupationally exposed workers are consistent across investigators and study populations.”
http://www.epa.gov/iris/subst/0371.htm
Numerous public health authorities state that asbestos is a known carcinogen, any exposure at all is a
health risk, that asbestos particles cannot be removed from the lungs, that children and adolescents are
particularly at risk from exposure, and that illness generally does not appear until 10 or more years
following exposure. Since the Fortune Minerals project is expected to last 18 to 25 years, most cases of
asbestos-related cancer will not become apparent until after the company leaves.
2 Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and
Pesticides in International Trade. See http://www.pic.int/
3 Asbestos-Related Lung Disease by Katherine M.A. O'reilly, M.D., Anne Marie Mclaughlin, M.B.,
William S. Beckett, M.D., And Patricia J. Sime, M.D., Am Fam Physician. 2007 Mar 1;75(5):683688. http://www.aafp.org/afp/2007/0301/p683.html#abstract
Saskatchewan people are rightly concerned about illness caused by inhalation of asbestos.
Howard's Law, amendments to the Public Health Act, 1994 to provide access to information relating to
asbestos in public buildings, was passed unanimously by the Legislature on April 18, 2013. In the
Assembly our Premier stated that he supported the bill. The new law requires public buildings to
publicize their status regarding asbestos on a website.
Saskatchewan's Occupational Health and Safety Regulations have numerous measures dealing with
asbestos. The Regulations defines “asbestos process” as “any activity that may release
asbestos dust, and includes the storing or conveyance of materials containing
asbestos” among other things. (Part XXIII, clause 303) Thus Fortune Minerals
project should be subject to these regulations. The company plans to convey
asbestos-containing materials from the NICO mine site via rail and/or truck;
transfer this material and store it on site; pulverize it in its re-grinding mill;
pass it through numerous processes to extract metals; mix it with other waste
streams; load it into trucks or a conveyer mechanism to dump it in permanent waste
storage facilities; spread it with bulldozers within the waste cells; cover the
accumulated material with a layer of soil once the waste cells are filled, plant
grass on the soil and then after a few years of monitoring, abandon the site.
The Environmental Assessment Branch review of the Fortune Minerals EIS found that it did not
adequately address health risks as required in the Project Specific Guidelines (PSGs) and asked the
company to complete a Human Health Risk Assessment with particular consideration to air and
groundwater impacts. (Addendum, page 8)
In its response, Fortune Minerals, via its consultant, does not evaluate the health impacts of actinolite.
Is does discuss the health impacts of arsenic, saying “The operable exposure pathways for the industrial
worker included incidental ingestion and dermal contact with the process residue, and inhalation of air
emissions.” Since arsenic and actinolite both occur in the cobalt and gold cyanidation processes, and
both occur in the same residue stream, if workers are exposed to one, they will be exposed to both
carcinogens. This also raises the question of synergistic effects of simultaneous exposure to two
carcinogens – would their cancer risks be added together or multiplied? The fact that assessment of the
actinolite hazard has been omitted is troubling.
The EIS assumes away the impacts due to exposure to dust from open residue storage cells, based on
the expected moisture level of the waste when it is moved from the processing building and the
company's planned, albeit vague, dust suppression measures: “The exclusion of the dust inhalation
pathway is dependent on the dust mitigation controls established by FML during the period of time that
the containment cells are open.” (page 15, Appendix C, Addendum)
Fortune Minerals' consultant does not seem to be 100% confident of this assumption, however, saying:
“The predicted concentrations in air were based the results from the air dispersion modelling
(SLE, 2012), which considered air emissions from the SMPP facility, transportation, diesel fuel
generator and start-up broiler and did not include dust emissions from the process residues,
as it was assumed that the high moisture content of the process residue, along with operational
activities such as continual placement of process residues in the containment cell, wetting the
process residue and utilizing dust suppressants will minimize the particulate emissions from the
PRSF. However, this uncertainty should be addressed by an air quality monitoring
program to obtain measured air concentrations in the area surrounding the SMPP facility. The
HHRA [Human Health Risk Assessment] should be revisited once measured data is
available and if appreciable dust fall is generated from the process residue, then this exposure
pathway should be quantified in a revised HHRA.” (page 28 Appendix C, Addendum,
emphasis added).
Fortune Minerals does admit that there will be some dust produced as a result of moving waste
materials from the processing area to the waste cells. It makes the outlandish claim (see quote below)
that these dust particles are too heavy to blow away, even though it has already told us that the size of
particles in the waste residue is generally less than 15 microns. (Appendix A, page 5) A 15-micron
particle is so small it would be barely visible to the human eye. In the past month (November 2013)
wind gusts of up to 63 km/hr were recorded at the Saskatoon weather station. A wind that strong is not
unusual and would surely be able to blow such tiny particles a considerable distance.
The dust emissions from the activities at the SMPP will result in the deposition of some
airborne dust out of the atmosphere. The main dust generation sources will likely be from wind
erosion and movement of vehicles and large equipment on-site. There could also be some
fugitive dust emissions from the transport of the process residue to the PRSF and the
placement of the residue in the containment cells. However, due to the larger particle size
and high gravitational settling velocity, the dustfall will be deposited near the source and
therefore it is not expected to be dispersed far from the SMPP site. (Page 91, EIS Main
Document, emphasis added)
The assumption that there will be no appreciable dust from the uncovered waste cells is weak and
dangerous. If approved, this project will introduce tens of thousands of tonnes of pulverized asbestos
material (along with arsenic and other hazardous chemicals) into the environment near Langham that
will remain, and remain hazardous, forever.
Maps in the Addendum show predicted distribution of particulate matter (soot and dust) from the site
during operation and indicate that there will be heaviest deposition on the farmland around the site4.
The model used to create the map did not consider additional dust from the surface of the uncovered
waste cells. The projected “dust footprint” includes the southeast corner of Langham, an area where
houses are being built for new residents.
Dust that falls within town limits will cover surfaces that young children play on and touch, and will
likely lead to some of it getting into their mouths and lungs. Children and adolescents are at increased
risk for cancer caused by exposure to asbestos. Saskatchewan's Occupational Health and Safety
regulations prohibit workers under 18 from working where they could be exposed to asbestos. Children
and other residents of Langham and area would not be able to avoid exposure to airborne pollution
from the Fortune Minerals plant, and would not be covered by occupational health and safety measures
that would apply to workers in the plant.
Over the 18 to 25 years of the plant's operation, dust from the waste cells will build up in the nearby
agricultural soils. Each time the farmland is worked the asbestos dust particles will be disturbed and
potentially blow in windy conditions. Dust that falls on plants during the growing season will be blown
around when crops are combined. Farmers doing field work would be exposed. Yet, the EIS health
study excluded farmers from its consideration based on unrealistic assumptions regarding the
company's extremely vague dust suppression plans.
Maximum 24-Hour Average (second highest) Ground-Level Concentration Contours for
Particulate Matter under normal operation before refined emission rates (Figure 11, Addendum page
292.)
4
The waste cells will be open to the air while they are being filled. The company plans to have two cells
at a time on the go to allow material to settle between dumped loads. There will be two or more cells
open to the air for the entire 18 to 25 years of operation. Most of the time there will be at least 2 cells
open, and probably there will be periods when 4 cells are open after a pair has been filled and before
they have settled enough to install the “engineered cover system.” The surface area of each cell ranges
from 3.7 hectares (9.14 acres) to 6.2 hectares (15.3 acres). The surface area of waste exposed to the air
(and thus to winds) at any one time would range from 18.3 acres (cells 1 and 2) to 52.8 acres (cells 7, 8,
9 and 10).
Fortune Minerals has not decided exactly how the material will be moved from the processing
buildings to the waste cells – perhaps by truck, maybe with a conveyer mechanism. Regardless, some
of the material will stick to the machinery, dry out and blow around. Some of it will get onto the boots
and clothing of workers and be tracked into their vehicles and homes. Health literature on asbestos
shows that family members of exposed workers have a higher risk of cancer than the general
population.
Fortune Minerals' “engineered cover system” for the waste cells is basically a one-foot thick layer of
soil with grass planted on it.5 The decommissioned cells will look like a hill or set of hills about 6 feet
high and will become a permanent feature in the local geography. Animals will dig holes in the soil
covering. The forces of erosion will act upon the raised landscape. Time, rain, wind and gravity will
wear it down. Future weather conditions – including prolonged droughts and more intense storms that
are predicted effects of climate change -- will affect how quickly this will occur, but erosion cannot be
prevented. Future generations would have to rebuild the sides and replace the covering regularly to
prevent the toxic contents from being released. It is highly likely that at some point maintenance will
stop and the surface covering and/or side berms will be worn away or even excavated. The toxic,
carcinogenic contents will then begin circulating in the air, water and soil. The people who will become
sick as a result will have gained no benefit at all from Fortune Minerals.
People who live in Langham, Dalmeny and the surrounding rural area have not given consent to have
their air, land and water contaminated with asbestos particles. Children are even more vulnerable, as
they are powerless to make decisions about where they live. Future generations will be faced with a
situation they had no part in creating but will be obligated to manage, just to prevent harm. In the
distant future the knowledge of what is contained in these strange hills may be forgotten, but the danger
will remain.
Is this the legacy our generation will leave?
Sincerely,
Cathy Holtslander
1516 Cairns Ave.
Saskatoon, SK
S7H 2H6
CC - Hon. Ken Cheveldayoff, Randy Weekes, MLA, Reeve Judy Harwood, Mayor Bev Panas, Mayor
“A store and release cover consists of a single or multiple soil layers with a vegetated
cover.” (page 13, Appendix A.)
5
Allan Earle.