Deq Form 100 886 Application For Relocation Of A Portable Minor Source Oklahoma
Deq Form 100 886 Application For Relocation Of A Portable Minor Source Oklahoma – The Aquila Back Forty mining permit amendment being considered by the Michigan Department of Environmental Quality includes a tailings dam (aka “tailings management facility” or TMF) that would be constructed using the hazardous “top” method. Several environmental groups, including the mining group of the Upper Peninsula Environmental Coalition, Menominee River Front 40, the Coalition to Save the Menominee River, the Center for Science in Public Participation in Wisconsin, opposed the Back Forty TMF design. Resource Conservation Council, Michigan Environmental Council and others.
The upstream beneficiation dam system is set to fail, environmental groups warn. Industry experts consider the above method the least common type of tailings dam construction due to its increased risk of dam instability.
Deq Form 100 886 Application For Relocation Of A Portable Minor Source Oklahoma
It is used because it is cheaper to manufacture, but it is not the “best available technology”. The walls of the TMF dam are “raised” and each successive lift is partially supported by tailings, as shown in the Back Forty TMF diagram above. This structure is fundamentally unstable and is part of what makes the “top” construction method particularly dangerous. The upper dam method is prohibited in many countries.
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Aquila PR manager Dan Blondeau tries to reassure concerned citizens that the tailings dam above the Forty Back is not failing. In communication with filmmaker Mark Doremus, Blondeau claimed that “the Back Forty tailings facility is NOT a pool and does not produce liquid tailings.”
“Then the Forty tails are drawn as a wet pipe. These ARE wet tails,” Heideman said. “The Next Forty Concentrator contains a pool.”
The permit amendment makes it clear that there will be a large pool of liquid waste deposited in the TMF facility – storm water:
It may be difficult to estimate the size of the pool, but “150,000 m3” (cubic meters) means that the lowered pool is about six times the size of the Lincoln Memorial Reflecting Pool in Washington DC. 
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In the Aquila Back Forty Dam Safety Manual, the amount of “overhead water” (flowing over the tailings) is predicted to be even higher – about 40 million gallons:
Blondeau claimed that “the maximum projected height of the Back Forty Dam is 130 feet,” but the permit states that the maximum projected height at closure is “42 meters” (138 feet high). How long?
“Blondeau doesn’t accept the monstrous size of the Forty Back Dam,” Heideman said. “124 acres of tailings — that’s like 50 city blocks or 100 football fields. The enclosure covers 25 times the area of Northern Michigan University’s High Dome,” Heideman said.
And that might just be the beginning. A mining group questioned whether Aquila was being honest in calling the Back Forty project a “7-year open pit”. Environmentalists believe Aquila is planning a phase of underground mining, although permit applications prohibit underground mining.
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From 2015 to early 2018, Aquila Resources described the Back Forty project as having “16 years of mining and 16.1 million ore lives, including both open pit and underground”. This claim was repeated in Aquila’s press releases, investor statements, presentations from the local community and correspondence with the Michigan DNR and the Menominee Indian Tribe of Wisconsin. In 2016, Aquila told its investors that they would send the underground license while they were drilling the open pit and the mill. Now the applicant is looking back and telling investors that the basement extension needs “further studies”…
Environmental groups claim that Aquila will continue mining underground for another 9 years, for a total of 16 years. If true, TMF will have to “place” more waste.
That’s why mining companies build tailings dams “over the top” – the structure can be “raised higher” if the miners need to store more tailings. TMF dams are often extended to additional heights, which significantly increases the height of the dam walls and the total volume of rock and wastewater contained in the structure. This gradual ascent method exacerbates the instability problem and has led to the catastrophic collapse of many tailing dams.
The permit amendment application for the Back Forty mine did not specify dam loading limits. It is a reasonable and predictable assumption that Aquila chose the controversial “upper dam” method because it could allow successive expansions by raising the dam wall (as in the image above). What may start as a TMF with “three raises” may grow exponentially with incremental change if permitting review is not environmentally friendly. The tailings dams of Brumadinho and Mount Polley were several times higher than originally planned.
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“Instead of talking about 100-year rainfall events, we should think about 10,000-year lifetimes,” Heideman said. “What are the real storm risks, the real earthquake risks, the groundwater risks from the failure of materials that have a limited life, like the plastic liners under the TMF?”
When the risks are roughly calculated for a 10,000-year lifespan—the number often used to estimate how long these tailing structures must maintain their integrity—experts say the chance of a tailings dam failure is significant and disproportionate. 
Blondeau claims that the Back Forty TMF design “uses tried, tested and proven engineering methods” because “similar facilities are already in use at the Malartic Mine and the MusselWhite Mine in Canada and the Neves Corvo Mine in Portugal.”
These mines – Malartic, Musselwhite and Neves Corvo – prove nothing. “Thick turkeys” have been used for less than 10 years. The type of mine, the tail and the casting method vary greatly – and the designs of TMF are very different:
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Malartik Mine has been operating since 2011. Thickened tailings contain “65-70% solids” and “little or no free water”. They form cone-shaped cells of different heights. Sulfur residues are used to “cover acid-producing tailings” (up to 3 meters deep), to remediate previously abandoned tailings. A sterile stone wall is built around the different cells to avoid overcrowding. This is very different from the Back Forty TDF, where the tailings are highly reactive, the waste discharges a large amount of water, and the TMF walls are constructed using reactive waste rock, not “sterile rock”. 
The Musselwhite mine in northwestern Ontario began operating in 1997 and “started spewing smoke in May 2010.” “Cold climates are a particular challenge for using a thick tailings system because there is very little experience.” To reduce the possibility of acid formation and metal leaching in the long term, the Musselwhite Mine announced plans to “remove sulphide minerals from the tailings stream with a flotation plant”. In 2009, the construction of the tail thickening began; This is to “extend the life (capacity) of the existing tailings treatment area. The thickener reduces the water content of the tailings by as much as 74% to allow dry tailings to be packed/compacted…”  This is from Back Forty TDF -which the tailings are very reactive, sulphides cannot be removed, is very different.
In 1988, the Neves Corvo mine, owned by Lundin Mining, opened. “Neves-Corvo has been developed as an underground operation utilizing multiple polymetallic sulphide ores” and “the mine tailings are stored in a 190 hectare tailings treatment facility (“TMF”) in the north by a cliff over a natural river valley. The plant was originally developed for groundwater-based tailings disposal, but in 2010 it was converted to a thick tailings facility “to increase storage capacity including a thick tailings plant”. underground” and “the expansion of the zinc processing plant and the amount of tailings produced, there is also a need to expand the thickness of the tailings”. In addition, “the underground voids are filled using paste fill (PF). of development rock, cement, and cyclonic process waste.” This differs from the Back Forty TDF: Nev es Corvo uses an upper tailings dam  but the disposal of thick tailings (started in 2010) has problems with tailings storage. not resolved: new use and “zinc processing plant expansion” followed. in more tailings; new “Feasibility study for TMF expansion … provides a comprehensive tailings development scenario.”
Read it next: After 30 years of mining, Lundin still trying to come up with a “comprehensive tailings development scenario” for Neves Corvo mine? Expanding continuous operations comes with demands
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“for the storage of excess waste and mining waste in the Neves Corvo tailings repository after the final disposal plan of 2015. In particular, the increase of waste waste up to 27 Mt and mining waste rock up to 10 Mt…”
At all of these mines, “thick” tailings management was used to address “capacity issues” caused by mining expansion – suggesting that these mines were not carefully planned or exposed to future mining phases. resulting in the deposition of less large tailings. Mining companies deal with TMFs
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