We have a firm policy of never publishing any “agitprop” material. I will circumvent the rule by posting a propaganda piece I helped write, but providing skeptical commentary. In effect, I will argue against myself.
PDF version of the official piece: What is causing the environmental damage in Talvivaara. More blog posts on Talvivaara (Finnish only): Talvivaara.
WHAT IS CAUSING THE ENVIRONMENTAL DAMAGE IN TALVIVAARA?
By the Kainuu District of the Finnish Association for Nature Conservation (Suomen Luonnonsuojeluliitto).
The environmental problems of the Talvivaara mine are difficult to summarize briefly. They are systemic, and made worse by the actions of the authorities (in this case the Kainuu ELY Center, in charge of monitoring the mine). The Talvivaara mine has caused excessive environmental damage; the ELY Center has repeatedly approved this damage; whenever challenged in court, its decisions have been found to be invalid. However, these court rulings come almost a year after the fact, and are irrelevant because Talvivaara has done so much more ELY-approved damage in the meantime. The system has become a monster.
Commentary: Obviously “monster” is agitprop. But other than that, the later analysis shows that the basic mechanism seems to be true. The system is definitely in a self-perpetuating feedback loop, which is difficult to stop.
In practice Talvivaara has never achieved a “normal” mode of operation. All of the wastewater treatment has happened in violation of the original environmental permit, issued in 2007. This has created chronic problems, which has led to a loop of repeated and uncontrollable acute problems. The ELY Center is actively collaborating in the damage by refusing to sanction the mine in any meaningful way.
Commentary: “Active collaboration” is agitprop. But certainly the actions of the ELY Center are not making the situation easier.
The mine started with the premise of a closed water circuit, in which a water-purification plant ensures that no wastewater is emitted into the environment. Such a plant was already a requirement in the environmental permit in 2007. As of 2013, Talvivaara has no plant, and is emitting 1.3 million cubic meters of wastewater per year. Instead of purification, the wastewater is neutralized by adding lime to the acidic water, and precipitating some of the toxic metals in a gypsum pond. This creates sulphate salts. The salt water is then diverted into ponds and rivers. The sulphates have already permanently contaminated several small lakes near the mine, and are proceeding downstream toward larger bodies of water.
Commentary: The basic mechanism is true. No water purification is being done, although the permit requires a plant to be built at some point. Neutralization of an acid with lime produces salts, which contaminate fresh water. Rises in sulphate levels have been measured in lakes tens of kilometers away. However, there is legitimate dispute how significant that rise is, the amount of damage that has actually happened, and how permanent it is. We simply do not know yet.
The Vaasa Administrative Court of Finland made two significant rulings against the Kainuu ELY Center last week. In early 2012, the ELY Center decided that despite the environmental damage the mine was chronically causing, there was no need to shut it down. The Administrative Court has now ruled that the damage was significant, and extreme measures should have been considered.
Commentary: This may be reading too much into the decision. Technically speaking, the Court simply decided that the ELY Center decision was invalid, and has to be reconsidered. The amount of damage as such was not assessed by the Court; they ruled that the damage assessment made by the ELY Center was insufficient.
In June 2012, Talvivaara invoked a “state of emergency” under Article 62 of the Environmental Protection Act, which allows permits to be temporarily bypassed in case of a natural catastrophe. Talvivaara then diverted its wastewater past the gypsum pond, bypassing a crucial step in the cleaning process. The ELY Center approved the diversion. The Administrative Court has now ruled that in fact there was no state of emergency.
Commentary: These facts are not in dispute. The criteria for invoking Article 62 are quite stringent, and they were not fulfilled.
In both cases, the Administrative Court invalidated the decisions of the ELY Center. Unfortunately, this shows a fundamental breakdown in the system: coming almost a year after the fact, these rulings are essentially irrelevant. The damage that the ELY Center helped to create can no longer be undone, since so much new damage has been done in the meantime.
Commentary: Calling the rulings “irrelevant” is extreme, but little can be done to correct the damage. The situation is analyzed (in Finnish) in Talvivaara 4. The diagram below shows some features, even though it is in Finnish. Orange lines refer to technical problems; red lines refer to emergency solutions; red lines crossed over refer to emergency solutions that have been declared illegal. This is the simplest possible diagram that captures even some of the key problems.
There have been four further states of emergency (August 2012, November 2012, January 2013, and February 2013). Most seriously, there was a massive leak in the gypsum pond in November, which has made the pond unusable (it also leaked in 2008 and 2010). It appears that Talvivaara illegally diverted one million cubic meters of highly polluted and acidic metal raffinate into the gypsum pond, contributing to the leak. The authorities are investigating this.
Commentary: These facts are not in dispute. The breakdown of the gypsum pond (Kipsi-allas) in the diagram above in particular is a serious issue, since it makes it very difficult to achieve normal operations.
It has also emerged that Talvivaara has no water-management plan, which was a key requirement in the 2007 environmental permit. Talvivaara has blamed rainy weather in 2012 for its problems; however, rainfall was never considered in the design and risk analysis of the mine. There also seem to be fundamental problems in the bioleaching process, according to an external report.
Commentary: Not in dispute. The problems in the water and risk management are described for example in the February 15 independent commission report (Talvivaara-selvitys, Finnish only). The external report was done by SRK Consulting.
Company management has stated that the situation is almost under control. However, the same message has been repeated since the mine began operations, and Talvivaara has a track record of unreliable statements about its water management.
Commentary: Agitprop. The positive messages from the company are certainly true. Whether they are unreliable depends on whom one chooses to trust. However, the Talvivaara-selvitys did note that the problems with the water management are serious.
Even more worryingly, the mine now plans to almost triple its operations, and to begin extracting uranium from the ore. (The presence of uranium has been known since the 1960’s, but was conveniently forgotten by Talvivaara and the authorities in order to avoid public backlash when the mine was started). Based on the past track record of the company, this sounds like a recipe for disaster.
Commentary: Agitprop, in particular “conveniently forgotten”. In general, whenever an environmental organization mentions the word “uranium”, one can expect a torrent of antinuclear propaganda. However, the propaganda value is not pursued deeply here, and it is true that uranium was never mentioned when the mine was first built. The last question is phrased in a rhetorical way, but is a valid question. If a company seems completely unable to control its operations, is it a good idea to allow it to triple those operations?
Conclusions of the commentary: Most of the facts mentioned here are not in dispute. Some of the readings of the court decisions may be biased. Claiming that the ELY Center is actively collaborating in causing the environmental damage is certainly propagandistic. However, the actions of the ELY Center certainly are not helping. It is debatable whether the situation in Talvivaara is quite as apocalyptic as suggested here, but it is certainly not under control. Overall, the rhetorical tone clearly marks this as a propaganda text, but I would argue that there are no serious distortions, and that the interpretation is more or less supported by the facts.
Acknowledgments: Many people contributed to the text, including Johan Heino, Janne Kumpulainen, and Pertti Sundqvist.
