Black Bull Resources Inc., under an option agreement with CAG Enterprises Ltd., has completed initial exploration for its Flintstone Rock kaolin-quartz project in southwestern Nova Scotia. The property lies along the Tobeatic Fault Zone, at the southern margin of the South Mountain Batholith. Work to date has included trenching, geophysical surveys (IP), diamond-drilling and sample testing. The company has completed 29 drillholes to date and reports that the target alteration zone varies from 100 to 200m in width, exceeds 100m in depth, and exceeds 1200m in strike length. Black Bull Resources is negotiating with international mining producers to establish partnerships to move into production.

The company proposes a 6 kilometer long open-pit mine, which would enable it to extract, over the next 2 or 3 decades, 16,000,000 tonnes of quartz, 5,000,000 tonnes of material containing kaolin, and 250,000 tonnes of mica.

In October, 2001, Black Bull submitted an Environmental Registration Document to the Environmental Assessment Branch, Nova Scotia Department of the Environment and Labour, to which TWC has addressed a
Letter of Objection.

The Tobeatic Wilderness Committee sees this proposed mine as a threat to the TWA itself. TWC fears that, if allowed to develop the mine and establish some infrastructure and a few jobs, the company might eventually push to mine the remaining Tobeatic Shear Zone, most of which lies within the Protected Area, once the deposits outside the boundary are mined out. We forsee the inevitable emotional plea to DNR to "save jobs" by realigning the TWA boundary. 

 DNR has yet to provide adequate justification for the realignment of the Proposed Shelburne Barrens Ecological Reserve and the Proposed Indian Fields Provincial Park boundaries to accomodate the current exploration. 

Perhaps DNR reasons that Nova Scotia needs to protect open pit mines more than it needs to protect representative landscapes like the unique Flintstone Barrens.

What can you do?
The Tobeatic Wilderness Committee encourages you to express your opinion on the Kaolinite Mine issue to Minister Ernest Fage and your local MLA. See our CONTACT page for addresses, etc.

Kaolinite is a disaster in water because it is a very fine material and settles out extremely slowly. It is extracted using jets of water, and thus it is impossible to contain the contaminated water fully. Water flows into streams and then rivers. The clay slowly settles out and coats everything in the river: fish gills, snails, weeds and micro-organisms. It is lethal due to its physical coating property. Everything is affected.

"Stora Port Hawkesbury Forest Industries’ recent move into the production of this high-end paper product at its Abercrombie Point mill has generated the impetus for exploring the site, says Thomas. Location is everything because it is the user that will pay the freight. For Stora, having ready access to a commercial deposit of kaolin would give it an incredible cost advantage. Thomas says one of the closest commercially-mined deposits of kaolin is in Georgia...

" ...Indeed the kaolinite content in the rock quarried at the tin mine was so high, it created environmental problems during the mine’s start-up when water from the holding ponds began escaping into the Tusket River system. The water had to be treated with flocculents in order to precipitate the clay particles out of the water."
(For the complete article, see the Media Library, 2000)

On April 15, 2000, the Chronicle Herald ran the following story(See Media Library, 2000):

Mine Interests prepare bulk samples for testing: Geologists upbeat about kaolinite in Yarmouth County:

Nova Scotia's newest mineral exploration effort has entered a crucial stage. An open- pit Kaolinite mine in Yarmouth County will soon yield bulk samples for testing in the United States.

A kaolinite mine near the Tobeatic would be a disaster and action must be taken soon to deter such development.  That's because the province has taken several steps in the past years to insure kaolinite mining in Nova Scotia is viable. 

A few years back the province went to court, or developed legislation, to officially define kaolin as a mineral so that it falls under the mineral act.  The mines division of DNR has allocated much resources to encourage kaolinite exploratin within the province. 

Other deposits occur near Upper Musquodobit but as a surficial deposit rather than a bedrock deposit like that of the Shelburne Barrens. The Province has also delisted sections of the Shelburne Barrens candidate ecological reserve to encourage kaolinite development.  All of these steps suggest the Province wants kaolinite mining in Nova Scotia.

The general public must be informed of the dangers such development poses for the environment, fish populations, and our water supplies.

Martin Willison, one of his students (Leah Hagreen), and Chris Miller have conducted research within the Shelburne Barrens candidate ecological reserve.  The area was nominated for protection in 1974 through a multi-national initiative known as the international biological programme (IBP).  In those 25+ years, however, the area has not been formally protected through the Special Places Protection Act and has been victimized by interim development...in the mid-80's a highway was paved through the middle of the Barrens and more recently (1996-present) mineral exploration has been actively occurring with the boundaries of the IBP site.

A miniature IRM study was undertaken on the Shelburne Barrens in 1999 to examine the conflict between conservation and mineral exploration.  The tory government redrew the original boundaries of the park so as to exclude areas with the highest mineral potential.  This is a very scarry precendent for candidate ecological reserves in Nova Scotia.  Mineral exploration licences occur within numerous other IBP sites including Cape Split, Cape d'Or, and Melrose, among others.  The province prohibits forestry from such sites, but mineral exploration is no holds barred.

The kaolinite deposit of the Shelburne Barrens is linear in nature (6km long, 400m wide, and 100m deep).  A large proportion of the kaolinite lies beneath the Tobeatic Wilderness Area.  Extraction will most likely occur as open-pit mining.

Leah Hagreen conducted an ecological study on the Shelburne Barrens in the summer of 1998.  She concluded the development of a kaolinite mine in the region was potentially catastrophic.  The site is located at the headwaters
of several river systems and the reserve contains a rich limnological diversity which would be threatened by the extraction of the dusty deposits.  Kaolinite mining involves the use of much water which is of concern because the narrow ecological niches of Nova Scotia's rare coastal plain flora are degraded by the domestication of water levels.  A mine would also serve as a barrier to the movement of large mammals into and out of the Tobeatic, particularly the resident moose population. Eutrophication is of additional concern.

Similar kaolinite mines in England have been environmental disasters. Leah's literature research reveals the danger of developing such sites. The following quote is from England's environmental department.

"It is impossible for an industry such as china clay (kaolinite) to undertake its operations without having a significant impact on the environment".

©1998 Leah Hagreen
(View and Download complete Study)

Table 5-5: Summary of potential environmental impacts of kaolinite mining

• Excessive noise pollution from blasting, traffic, and processing plants, running 24 hours a day.  This can disturb wildlife, as well as the homes in the area.
• Introduction of large quantities of dust into the atmosphere, negatively affecting the growth of plants.
• Fragmentation of habitat and creating barriers to animal movement, through: creation of large, open pits; large waste rock piles; infrastructure; and, traffic.
• Waste rock to product ratios of 8:1.
• Direct influence on three sub-watersheds, and four lakes in the Shelburne Barrens
• Increase in the quantity of waters entering the stream beds, increasing erosion capabilities, and flooding habitat of coastal plain flora.
• Regulation of the stream flow over the year, therefore not allowing for natural variations.
• Introduction of suspended solids into surface waters, disrupting habitats, biota and flora.
• Alteration of water quality, disrupting biological relationships and aquatic life, such as: introduction of toxins; changes in pH; and, changes in ionic metal concentrations.
• Difficult reclaimation of site.
• Reclaimation introducing fertilizers into surface waters, causing eutrophication and displacing coastal plain flora.
• Plantations of homogenous vegetation, possibly with species that are not native to the area. 
• Potential for exotic intrusives to invade.

5-3-2   Environmental impacts associated with other anthropogenic activities

The development of trails and Highway 203 fragment habitat, and act as a barrier to the movement of animals such as moose and deer (Beazley, 1998).  Development has also led to the introduction of exotic invasive plant species, such as scotch broom and pearly everlast.  According to White and Keddy (1993), scotch broom is “one of five invasive alien plants that have had a major impact on natural ecosystems in Canada” (p.85).  This and other invasives establish themselves on sandy roadsides, barrens and open woods, having the greatest impact in areas that have experienced landscape modification.  Any further development in the area would only serve to increase the abundance of these types of plants, which could lead to instability in the natural plant communities, leaving them more vulnerable to other invasions. 

 ATV use has been extensive in the area, with trails reaching from the Indian Fields system through the TWA to Kejimkujik National Park.  This has been particularly destructive to the wetland habitats along the Roseway River floodplain.  Wetlands dominated by Ledum sp., which are common to the Shelburne Barrens, are especially vulnerable, as these are slow to regenerate (Ross, 1991). Continual ATV impacts can compact the soils, diminishing the ability of plants to establish themselves (Ross, 1991). 
 

5-4   Summary
The Shelburne Barrens is a unique and diverse piece of wilderness, containing a unique ecosystem mosaic of bogs, barren lands, and old forests.  It holds the headwaters of the Clyde River system, as well as many shallow lakes and streams.  Many of the outstanding values in the Shelburne Barrens are contained within the southern region of the site, in Indian Fields Provincial Park Reserve (fig. 2-1).  The central component of this area is the chain of eight lakes which run through it.  The presence of these lakes acted to protect the surrounding vegetation from the extensive fires which have swept through southwestern Nova Scotia over the last few centuries, allowing for the development of old forests.  The shorelines of these lakes are also habitat for rare coastal plain flora, at least one species of which is endemic to the province. Wisheu et al.(1994), state that conservation of coastal plain flora will require the protection of the plants’ habitat.  “Efforts towards preservation of the coastal plain species should make habitat conservation a priority” (p.223).

Protection of these outstanding values requires the protection of the lakes which are at the heart of the area.  In order to protect these lakes, the boundaries for the Shelburne Barrens as a Special Place must include the watersheds which feed into these lakes.  “Drawing natural region boundaries at scales that encompass landscape features such as...watersheds provides a suitable framework to plan for individual protected areas” (Hummel, 1995, p.3). 
 

5-5    Conclusion and Recommendations 

5-5-1   Conclusion
The Shelburne Barrens fits all of the criteria for designation as a nature reserve under the Special Places Protection Act.  It was listed as top priority for protection by the Nova Scotia Museum in 1991, and has been a candidate site for 25 years. With only 27% of the land mass of Nova Scotia owned by the government, and continual pressure for developments of these lands, the province must choose to act if it plans on fulfilling its 12% promise.  The province cannot afford to lose one of its last large pieces of wilderness.

5-5-2   Recommendations

• Uphold the moratorium on development in candidate ecological reserves, and do not renew CAG Enterprises mineral claims for May of 1999.
• Put in place interim measures to protect all candidate protected sites until their status is decided.
• Make the Minerals and Energy Branch of the Department of Natural Resources recognize candidate protected sites.
• Purchase private lands or enter into land stewardships with private land owners of candidate sites.
• Increase the rate of site designation, while undesignated Crown Lands still exist.
• Integrate protected areas into larger management strategies to ensure adequate protection of lands and reduce conflicts.
• Discourage recreational use of the Shelburne Barrens, in particular the use of ATV’s.
• Designate the Shelburne Barrens as a Special Place immediately.

The complete text of Leah Halgren's comprehensive study is available here for viewing or downloading as Portable Document Files (PDF), and can be viewed using Acrobat Reader 4.0. If you do not have the Reader, it can be downloaded FREE from the Adobe Website.

A Survey of the Shelburne Barrens Candidate Nature Reserve, and the Environmental Impacts of Kaolinite Mining
©1998 Leah Hagreen

• Contents
• Introduction
• Site Description
• Methods
• Results
• Discussion
• Appendices
• Letter to DNR

November 12, 2001
Tobeatic Wilderness Committee's Letter of Objection
M. A. Mahtab, P.E., Consultant to TWC

The Environmental Assessment Branch
Nova Scotia Department of the Environment and Labour
P. O. Box 697, Halifax, NS, B3J 2T8, Fax: 902-424-3571

Dear Sir:

Subject: Issues relating to the Environmental Registration Document, White Rock Quartz/Kaolin and Mica Mine, Black Bull Resources Inc, dated October 26, 2001

We have reviewed the Environmental Registration Document (ERD) and have identified the following principal issues that we think should be addressed before the ERD is approved.

1. Drainage of water from wilderness area
The mine will provide a conduit for rapid drainage of the watershed upstream from the open-pit mine. With reference to Fig. 4 of Appendix E of the ERD, which is called Wetlands, it is easy to note that all the wetlands identified within the boundaries of the mine and upstream of the mine will be drained. In addition, the East Barclay Brook and the Barclay Brook will potentially dry up. Excavation of the pit is going to increase the flow of water into the newly formed depression for two reasons:

• Opening and enlargement of fractures in the ground around the pit, thus increasing the hydraulic conductivity (or coefficient of permeability) of the ground
• An increase in the hydraulic gradient (Darcy's Law, see Fetter, Applied Hydrology, Prentice Hall, 1994,)

The increasing drainage of water into the pit over the life of the mine, which is estimated to be over 20 years (see Fig. 3-3 of ERD) is likely to drain an area upstream of the pit which could be 20 times as large as the area of the pit (i.e., 1265 acres x 20=25,300 acres). This potentially drained area falls within the Tobeatic Wilderness Area. The consequences of this drainage will include the negative impact on the flora and fauna of the Tobeatic Wilderness which provides a habitat for several species at risk.

We note that the ERD has completely ignored the issue of drainage of the Tobeatic Wilderness watershed. There is no mention of monitoring of the water regime in this wilderness area. Consequences of any neglect in this respect will fall into the discussion under issue No. 4.

2. Use of water for mining and/or processing operations and subsequent contamination of the water regime
According to the ERD, Black Bull Resources expects to extract up to 150 Igpm of water from a series of wells in the mining lease area for the purpose of processing the kaolin and mica. The additional quantities of water which may be required for the alternative, wet mining of kaolin, have not been addressed. This extraction has several missing aspects:

• The location of the water table and the existence of underground aquifers has not been investigated. We note that tapping the same aquifer with several wells results in intersecting pumping cones. The composite drawdown from a series of wells will be substantially greater than the sum of drawdowns from individual wells (Fetter,1994).
• The impact of the use of a large volume of water extracted from an underground aquifer may be far-reaching and severe. The range of disturbance could go beyond the Tobeatic Wilderness Area and encroach on the Kejimkujik National Park
• As indicated in Section 8 of the ERD, Black Bull Resources plans to abandon the pit by turning it into an aquatic habitat with corridors for outflows and inflows. We note that this abandoned pit will be connected to the underground aquifer through the water wells and the fracture system which extends to a depth of more than 120 m. (Duncan et al., 1982, Report of Diamond Drilling on Mineral Explorations Licenses 4122 and 4124, East Kemptville Project, Shell Canada Resources). Therefore, the contaminants from the water stored in the pit will eventually be transported throughout the downstream watershed. The contaminants may include the following:
  • kaolin and mica particles and flakes
  • dissolved metals in the stored water
  • dissolved contaminants by means of percolation of water through the embankments constructed using the waste material, which provides a much larger surface area for dissolution. It would be appropriate to note here that the assay of water samples for examining the effect of percolation of acidic water was based on the extraction of about 1,000 tonnes of the product. However, the scale of mining is of the order of 10 million tonnes over the life of the mine. Therefore, the results of these assays do not have a meaningful application for the actual mining scenario
  • the outflow from the pit, particularly during surges associated with storms, will transport both suspended solids and contaminants into the water regime in the area with resulting deleterious effects on all aquatic and human life in the area

3. Omissions and discrepancies in the ERD
The information given in the ERD is unclear and imprecise in several instances:

• The mining and processing operations are not discussed in sufficient detail to form an opinion on the environmental impact
• Realignment of the #203 highway is not discussed
• The progressive mining and reclamation approach or "fill the hole in as you go" does not make practical sense for excavating an open pit in three benches of 10 m. each
• The employment figure of 200 persons from the local area, with a payroll of $8.5 million a year, we believe to be unreasonably inflated
• With reference to Section 5 of the ERD, Public Consultation, we note that Black Bull Resources did not carry out their promise of responding to the questions raised by the Tobeatic Wilderness Committee in the meetings with Black Bull Resources in Digby on April 10, 2001 and in Middle Ohio on May 29, 2001. We have heard nothing about a Community Liaison Committee.

4. Liability for damage, reclamation, and land management
In view of the fact that the ERD has not provided a clear picture of the potential damages resulting from the mining and processing operations, we feel justified in advising both the licensing authority and the mining company about their individual and joint liabilities with regard to the following:

• Destruction of the wilderness in this fragile area
• Overuse of the limited water resource in this ephemeral environment
• Contamination of the water regime over an area which is many times the size of the mine, depriving the inhabitants of their access to fresh water

We hope you will take the above issues into due consideration in examining the Environmental Registration Document submitted by Black Bull Resources Inc. We will be happy to discuss with you the details of any of the issues.

Yours sincerely,
Don Rice, Tobeatic Wilderness Committee
M. A. Mahtab, P.E., Consultant to TWC

Cc: Gordon Balser, MLA, Howard Epstein, MLA, Harry Delong, Superintendent, Kejimkujik National Park

Black Bull Resources Inc. White Rock Mine:
In March 2001 Black Bull Resources Inc. applied to the Department of the environment for permission to mine quartz/kaolin and mica at Flintstone Rock, Shelburne County, immediately adjacent to the Tobeatic boundary.

In April 2001, TWC met with Black Bull representatives to discuss the importance of a generous buffer area adjacent to TWA. Test wells are being drilled 40m from the Wilderness boundary. Such a buffer was neither generous nor adequate. Black Bull also stated they would not enter TWA, but TWC was unsuccessful in getting written confirmation of the statement.

On October 26, 2001 Black Bull Resources Inc. submitted an Environmental Assessment Registration Document for the proposed development and operation of the White Rock kaolin, quartz and mica mine near Flintstone Rock, Yarmouth County. TWC responded to the document in a letter to DoE, stating concerns over the following principle issues:

• Drainage of water from wilderness area
• Use of water for mining and/or processing operations and subsequent contamination of the water regime
• Liability for damage, reclamation, and land management
• Omissions and discrepancies in the ERD

In early 2002, the Environmental Registration Document filed by the company to mine kaolin, quartz and mica was rejected by the Department of the Environment. Objections by DoE staff were many, but the principal concerns were the potential for water drawdown affecting the Tobeatic ecosystem, and the suspension properties of kaolin particles in the water column.

In August 2002, the company filed a second ERD, this time focussing on quartz. The quartz however was to be mined from the same areas of kaolin deposits. DoE allowed only 14 days for NGOs and individuals to review, and despite objections, this time the mine proposal was allowed to go ahead. In TWC's opinion, this represents a 180 degree flip-flop by the Minister, as the concerns expressed by DoE staff in the refusal of the first ERD remain unaddressed.

The huge amounts of water required for the mining process will necessitate a serious water drawdown from the Tobeatic, which is immediately upstream. In fact, the proposal allows for a meager 15 metre (45 foot) buffer between the Tobeatic boundary and the proposed open pit. This flies in the face of accepted science requiring adequate buffers for protected areas.

Further, a miserly small sum of $85,000 will be set aside for aquisition of similar lands should mining impacts prove to be irrepairable (by comparison, a minimum $1,000,000 is required for public liability and property damage insurance on the average motor vehicle).