September 11, 2015

The Honourable Dan Crummell

Minister of Environment and Conservation
4th Floor, West Block
Confederation Building
St. John's, NL A1B 4J6
Dear Mr. Minister:
Thank you for your letter of August 26, 2015 in response to my letter of August 7,
2015 concerning the North Spur stability problem at the Muskrat Falls hydro project on
the Lower Churchill River in Central Labrador.
On a technical but important point I should point out that your reference on page
1 to sensitive marine clays should properly state sensitive glacio-marine clays as it is
the latter class of particularly sensitive clays that are present at the North Spur and its
adjacent up slope area.
I note that at page 2 of your letter, you state that Nalcor plans to avoid human
activity such as pile driving that could induce landslides by which I assume that all
parties now apparently understand how risky the situation at the North Spur really is.
In the second paragraph of you letter, you emphasize that the geotechnical
investigations have been undertaken according the CSA guidelines. Also you have
acknowledged that the North Spur is part of the reservoir containment structures. This
is correct. However, the North Spur dam will contain quick marine clay, a very
unstable material, and the CSA guidelines do not cover such a structure for the reason
that no such structure has ever been built which includes quick clay within the dam
structure.
This basic non- applicability of the CDA Guidelines is not offset by characterizing
the kilometer long 50 m high North Spur as a reservoir rim; and I should say that in
any event the North Spur constitutes 50% in length of the entire Muskrat Falls reservoir
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containment system hardly a rim.

In the third to fifth paragraphs, you outline the measures that will be taken to
improve the safety of the Spur dam. The question is will they be sufficient? For
example:

Will all the sensitive clay be removed? Or will the clay removal be confined to
certain areas.
Will there be a backup to the cut-off wall? Cement-bentonite sand cut-off walls
are very difficult to construct with 100% impermeability. They usually contain
several permeable holes formed during the backfill process when sand sloughs off
the vertical wall. A backup usually consists of grouting or an upstream blanket.
Will the cut-off wall be excavated through sensitive clay? A difficult task.
Are the lower slopes of the dam sufficiently flat to distribute the load onto the
lower quick clay?

In your 6th paragraph, you mention that the North Spur dam break is not the
worst case scenario in regard to downstream impacts. This point is debatable. The
warning time for a slow erosion North Spur break may well be significantly longer that
for the concrete dam break.
However, this does not take into account that should the North Spur fail, the
erosion cut will remove all support that the North Spur currently provides to the very
large sensitive clay deposit on the North Bank and its adjacent upslope area, exposing
the bank to a massive landslide likely to engulf the powerhouse on the south bank,
and cause a large tsunami wave moving rapidly downstream to inundate Goose Bay
and Happy Valley.
This scenario has not been studied, and is likely to be far more dangerous than
the concrete dam failure. Also, since there have been many recent collapses on the
North Bank, the risk of such an occurrence is far higher than a failure in the concrete
dam. This scenario has not been investigated at all.
These concerns are heightened by the potential in this area for Downhill
Progressive Landslides as described by Dr. Bernander.
In your 7th paragraph, you assert that my breach assumptions were incorrect,
since they did not take into account the cement-bentonite-sand cut-off wall halting the
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downward erosion of the breach. This is partially correct. However, the cementbentonite-sand wall will only provide a temporarily non-erodible surface, eventually
crumbling when the downstream material erodes out, removing support for the wall.
The result will be a slow erosion down to about or below sea level. The warning time
for Happy Valley - Goose Bay Mud Lake in such a slow erosion case may well be
significantly longer than that for the concrete dam break case.
However, even the slow erosion case constitutes a very significant project risk
that must be considered.
I have been informed by an experienced hydro engineer that the consequences of
a North Spur failure, from a financial perspective would be unimaginably catastrophic
due to the very large expenditure required for a repair due to erosion of the Spur clay
foundation down to below sea level. The cost would be so high, that a more
economical alternative would likely be to abandon the site and spend the repair
moneys on a re-design and construction of the Gull Island Dam, taking advantage of
the lower tailwater level resulting from a dam break in the North Spur to increase the
capacity.
Turning now to your second last paragraph wherein you state that The
engineering design for the North Spur stabilization works has been reviewed by three
different independent third parties, who have advised that the design is adequate.
I cannot find any corroboration for this statement and would appreciate being
directed to where I might find a public source for such opinions.
The Muskrat Development is being built without an independent Review Board.
This is unusual, since most large hydro projects have review boards to ensure that all
aspects have been foreseen. Moreover, the North Spur has unique challenges with a
dam being built on a quick clay foundation, with quick clay included within the dam
structure.
An independent Review Board should be immediately appointed comprising the
most qualified engineers with experience in soft clays. To my knowledge these would be
Dr. S. Bernander, and Professor (retired) N. Morgenstern who recently served as Chair
of the Panel investigating the failed Mount Polly Dam it was found to be due to an
undetected layer of soft clay below the dam.
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In closing, I urge you to immediately advocate within cabinet and generally

support the establishment of such a Hydro Review Board.
Sincerely,

Cabot Martin
151 Waterfordbridge Road
St. Johns , NL
A1E 1C7
Cc Mr Jamie Chippett Deputy Minister Department of Environment and Conservation.

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