1 : Overall Lack of Hydrogeological Informationthere is a decisive lack of detailed qualitative and quantitative information on regional groundwater movement; there is a lack of clarity concerning data requirements; it did not conclusively prove the Beverley orebody aquifer was completely isolated from surrounding groundwater systems; references are made to old exploration boreholes that leaked and went unnoticed, and still fails to adequately address current management of these old boreholes and preventing the escape of the highly toxic leaching solutions via these boreholes; there is a lack of geochemical data to justify assumptions on groundwater chemistry; it exaggerates current groundwater quality of the Beverley orebody (Namba) aquifer; the groundwater monitoring regime is poorly designed; the excess solutions from pump testing are to be re-injected back into the orebody aquifer with no plans for rehabilitation; it underestimates the potential problems of flash flooding inundating parts of the Beverley site; it underestimates the risks of high background radiation levels given the identified atmospheric inversions that are known to occur; poor environmental design of the Field Leaching Trial; the FLT contains extremely high concentrations of dissolved uranium; excess waste water solutions are to be re-injected into the Beverley aquifer; it ignores the possibility that the re-injected solutions could mobilise higher concentrations of radionuclides and heavy metals orders of magnitude above background levels; there are no plans for rehabilitation of groundwater after trials, even if full scale mining were not to proceed; solid wastes were planned to be disposed of at the old Radium Hill underground workings; the original design for the detention pond was unlined; numerous assumptions are made without the scientific data presented to justify such assumptions; etc etc etc etc etc etc etc........
The DEF does not discuss in necessary detail the source of groundwater within the Beverley aquifer and it's long term flow and eventual discharge zone. The Beverley orebody zone aquifer, known as the Namba Formation, "...is not considered to comprise a significant aquifer and accordingly, there is no region-wide quantitative assessment of its hydraulic properties" (page 4-7) (1). Quantitative information on recharge, discharge, and flow rates is critical to evaluating the likely significance of any environmental release to surrounding groundwater resources and environment.
Qualitatively the regional recharge mechanism for the Namba Formation aquifer, where it includes an aquifer locally at Beverley, is not clear but its potentiometric surface at the Beverley site is similar to that in the adjacent Willawortina, and it has a very low gradient across or along the mineralised channel (page 4-12) (1). At the Beverley site, "discharge from the Namba is likely to be slow and to the south" (page 4-12) (1). Discharge from the namba and Willawortina systems would be expected to be ultimately to the east towards Lake Frome (page 4-12) (1).
A conceptual regional hydrogeological model is presented (Figure 4.4) to describe the overall flow regime from the Flinders Ranges through the plains to Lake Frome.
Regional Groundwater Flows (Fig. 4-4) (1) - click for larger version (~ 232 kb).
This diagram shows :
The environmental consequences of an escape of leaching solutions and the resultant mobilisation of numerous radionuclides (such as uranium, radium and radon daughters) and heavy metals (such as lead, arsenic, molybdenum or selenium) would thus be extremely serious.possible recharge to the Namba aquifer via recharge along the major Poontana Fault and from the Paralana High Plains; eventual discharge into the Willawortina Formation and then to Lake Frome.
As presented, the DEF does not allow adequate assessment of the risks of environmental releases and impacts on other regional users of the Lake Frome groundwater resources.
2 : Lack of Clarity of Data Requirements
The main reasons stated for a trial of uranium extraction by In Situ Leaching at Beverley are (pages 1-1, 1-2) (1) :
- "establish the environmental consequences of in situ leaching specifically at the Beverley site";There is no point at all throughout the DEF that states the exact parameters the FLT is designed to elucidate. These would include flow and hydraulic parameters for the Beverley aquifer, dissolution rates of the uranium mineralisation, solute transport parameters of different elements and their behaviour with aquifer sediments, chemistry of the leachate solutions, and the efficiency of the uranium extraction process plant.
- "provide environmental information required for input to the Environmental Impact Statement (EIS).....and which cannot be obtained from laboratory studies, very small scale testing or from other sites";
- "provide information on general operational parameters, both for establishing feasibility of commercial mining and for EIS purposes, again specifically at the Beverley site".
All of these parameters add significantly to the uncertainty of the environmental safety of in situ leaching technique at the Beverley site. These risks should not be undertaken outside of an open, transparent public consultation process. The FLT should be undertaken after the approval of the full EIS.
3 : No Conclusive Proof the Beverley Aquifer is Isolated
The nature of the sedimentary geology of the Beverley area is quite complex and "considerable variation in the lithology should be anticipated on the scale of the Beverley deposit" (page 4-3) (1). It is acknowledged that such complexity alone cannot guarantee isolation, and the DEF does recognise that the "mineralisation occurs within a semi-isolated aquifer zone that resembles a concealed fluvial system" (page 3-1, emphasis added) (1).
The uranium mineralisation at Beverley is contained within palaeochannel sands. It is known that these sands "thin laterally (to clay) across the channel to both the east and west", however, "the extent of the palaeochannel to both the north and south is unknown, although the sands appear to continue for at least 0.5 km in both directions beyond the mineralised zone at Beverley" (page 4-3) (1). Although these sands are generally covered by a thick sequence of clays and sandy and silty clays, old exploration boreholes "were not backfilled or grouted upon their abandonment" (page 4-4) (1).
Problems of groundwater flow between the different sand layers of the Beverley aquifer has also been recognised (page 4-8) (1).
It is quite clear that there can be no guarantee that it will be possible to prevent escape of leaching solutions within the Beverley orebody zone, and hence to the wider underground environment.
4 : Leaking Exploration Boreholes
During the 1970s and early 1980s a total of approximately 1,000 exploration bores were drilled into the Beverley site (page 1,000) (3). To say that this "drilling was intensive" (page 3-1) (1) is perhaps an understatement, however activities during this time were "not always properly documented" (page 3-1) (1) with "surface evidence of many of the drill holes has disappeared over the intervening decades" (page 3-1) (1) (page 1,000) (3).
Plan of old exploration boreholes and current infrastructure at Beverley (Fig. 4-5) (1)
- click for larger version (~ 302 kb).
How can all such boreholes be identified in order to be tested and, if necessary, rehabilitated to strict modern standards designed to protect the underground environment ?
It was noted that there were many significant problems with much of the early field hydrogeological testing performed at the Beverley site (1) :
- "pumping tests, conducted on partially penetrating wells show a certain degree of hydraulic leakage" (page 4-8);Although it was "expected that unplugged exploration boreholes drilled in the 1970s will have collapsed and sealed off" (page 6-5) (1), a new hydrogeological pump testing program was undertaken as part of the DEF (2) "to stress unplugged exploration boreholes" (page 4-13) (1).
- "it is unlikely that leakage through old exploration boreholes would have been noticed in the earlier tests which were designed to obtain data on the major aquifer properties" (page 4-8);
- "the B2 clay layer was perforated by drilling activities undertaken by former proponents, and the boreholes were not sealed to modern standards" (page 4-8);
Collapsing and sealing are two quite different concepts :
- collapsed boreholes could conceivably still have an open conduit along the drillhole and thereby act as a mechanism for escape of solutions;
- sealing of boreholes could occur via settlement of the soil profile, shrinking and swelling of clays of the Willawortina Formation or regional geological movement. This would result in an effectively impermeable barrier where there was once an old borehole.
If old exploration bores have collapsed and/or sealed, what has caused this to occur ? Given this, how then is it possible to guarantee the safety of current and future bores ?
The hydrogeological testing conducted for the DEF (2) tested new bores near a total of two old exploration bores, leaving about 998 old boreholes to confirm the status of.
Clearly, there is cause for concern that old boreholes could provide for escape of leaching solutions into the wider environment.
5 : Lack of Geochemical Data
The DEF does not include a complete set of geochemical data on groundwater quality of the Beverley (Namba) aquifer, the underlying Great Artesian Basin nor the overlying Willawortina Formation aquifers. The only data included is uranium (U), radium (Ra), radon (Rn) and Total Dissolved Solids (TDS, or salinity) (Tables 4-3 to 4-6) (1). No information or data is presented on major ions sodium (Na), potassium (K), calcium (Ca), magnesium (Mg), iron (Fe), sulphate (SO4), chloride (Cl), bicabornate/carbonate (HCO3/CO3), fluoride (F), pH (acid/alkaline) or redox potential.
There have been documented problems of precipitation of solids like gypsum (CaSO4), jarosite (KFe3(SO4)3.9H2O) and several others for the proposed conditions of the FLT (6), yet the data that could be presented to demonstrate the probability of this occurring at the Beverley site is withheld from the DEF.
Without this information, it is not possible to determine possible environmental effects on groundwater quality and the likely geochemical behaviour of leaching solutions, such as precipitation and/or dissolution of different minerals within the Beverley aquifer.
6 : Exaggeration of Groundwater Quality
The groundwater quality of the Beverley orebody (Namba) aquifer is exaggerated. The results of only twenty groundwater analyses are presented in Table 4-3, results which the DEF admits are highly variable and have questionable laboratory quality or field sampling methodology (page 4-11) (1). When the presented results are compared to the more extensive data set published in the 1982 Draft EIS, it would appear that the DEF arbitrarily selects higher results, especially for uranium and TDS.
| (mg/l or ppb) | ||||||
| (Bq/l) | ||||||
| (Bq/l) | ||||||
| (mg/l or ppm) | ||||||
# - Average U is 6 mg/l excluding the extreme outlier of 96 mg/l.
@ - only one sample tested.
The stock bores of the Willawortina Formation and springs of the region have TDS ranging from 758 to 8,080 mg/l with an average of 3,009 mg/l (Table 4-5) (1). The groundwater quality of the Beverley aquifer, apart from it's radionuclide content, is therefore usable for stock purposes and is well within the variability of the Willawortina aquifers.
Given that the DEF does recognise the groundwater quality is variable (such as on (page 4-14) (1) where it is stated that the groundwater quality of the North Beverley orebody zone is of lower salinity than that in the Central orebody zone), it is unclear as to the exact reason for exaggerating the current groundwater quality.
One possible reason for the difference would be to decrease the rehabilitation standard after the process of in situ leaching (ISL) has finished, or enable such expense to be avoided in the first place and thereby merely walk away from the site leaving concentrations of radionuclides and heavy metals up to an order of magnitude higher or more - which is precisely what the DEF plans for the current Field Leaching Trial.
Heathgate do have a vested interest in assuming the groundwater has no potential use in the first place, and the assumption of "totally unusable" (page 4-10) (1) needs rationalisation, which is clearly not forthcoming within the DEF.
7 : Poorly Designed Groundwater Monitoring Regime
The most significant risk to surrounding groundwater environments is the escape of radionuclide-laden leaching solutions into the Willawortina Formation, where it is acknowledged that "over twenty stock watering wells of relatively low yield (are) within the (Beverley) area" (page 4-9) (1). Only seven of these bores have been sampled (page 4-10) (1) and tested for chemical quality, with no regular analyses over time to define background variability, temporal trends and regional spatial variability.
One bore, VSH1, intersected a total of five aquifer zones, yet the bore was screened across all five zones as a single borehole (page 4-10) (1). Although samples obtained during drilling would be representative during this time, any future samples would be the result of mixing of five separate aquifers discharging into the effectively single borehole and thus any leachate solutions entering the lower aquifers would be highly diluted and possibly remain undetected for significant periods of time.
Problems were also encountered at other bores - 37/04 was "reportedly not in hydraulic continuity with an aquifer, and it's water sample is considered suspect" (as well as bores WC30, W143, W200, W201 and WC35) (page 4-10, Table 4-7) (1); while the groundwater sample from bore 38/07 only yielded enough water for an "indicative sample only" (page 4-10) (1). Much of the data presented in Tables 4-3 to 4-7 are from the earlier Draft EIS, in which the quality of data is "considered to be of variable quality with a possibility that low yielding bores were not fully developed when sampled" (page 4-10) (1).
The ability of the current groundwater monitoring program in the Willawortina Formation to quickly detect any escape of leaching solutions is highly questionable, and many new well constructed bores would need to be established to provide a significant level of protection to surrounding stock bores.
8 : Irresponsible Water Management Proposals
The FLT proposes to :
utilise a newly constructed array of bores for disposal of excess solutions unsuitable for FLT purposes; pump excess water from pump testing of the Northern ore zone back into the Central ore zone; since the Northern zone groundwater is of lower salinity (page 4-14) (1); pump excess water from pump testing of the Central ore zone into the disposal array (page 4-14) (1).
The possible effects on groundwater quality of this pumping and re-injecting of groundwater across different zones of the Beverley deposit are not discussed in any adequate detail.
9 : Underestimates Potential Problems from Flash Floods
If a flash flood were to occur, the potential for environmental releases of radionuclides is serious. However, despite the severity of such failures, only a one in one hundred year (1/100) probability of a flood is assumed for modelling the risk of a flash flood problem at the Beverley mine site (page 4-18) (1). Clearly, for the risks inherent with uranium facilities, a 1000-year flood interval must be used as the minimum for best environmental practice.
It should be noted that the Central FLT borehole array is on the edge of the 1/100 year flood inundation zone. Upon visiting the site on December 14, 1997, various Adnyamathanha and representatives from Environmental groups observed that many of these new boreholes were uncapped, providing for the entrance of extranneous water into the bore and thereby the groundwater (click here).
Plan of Modelled 100-Year Floodplain (Fig. 4-5) (1)
- click for larger version (~ 308 kb).
The SA Parliamentary Inquiry into the Tailings Seepage at Olympic Dam highlighted that the above problem was a significant contribution to the problems in identifying the seepage there for several years (7).
How can Heathgate therefore guarantee that if a 1/100 (or worse) flood were to occur that problems of rainfall infiltration into bores would not happen ?
Allowing bores to remain uncapped and unprotected is clearly not best environmental practice.
10 : Effect of Atmospheric Inversions on Radiation Dose Unresolved
It is noted that the general area tends to have "above average" levels of background radiation, and "certainly exhibits significant variability with localised higher values" (page 4-19) (1). With the values converted to annual doses, these correspond to 1.3 to 3.0 mSv/year, which exceed the allowable level of public exposure to ionising radiation. Since this is ambient background radiation, though, this is independent of the Beverley site.
However, it also noted that "in desert settings, the effect of low-level night-time atmospheric inversions is often very distinct, and causes increases in radon daughter concentrations of perhaps an order of magintude" and that "such inversions are known to occur at Beverley" (page 4-20) (1). The effect of this diurnal cycle of increasing concentration of radionuclides on radiation dose is not discussed at all (page 4-20) (1), which is especially important given the generally high radiation in the region.
11 : Poor Environmental Design of the Field Leaching Trial
The design of the Field Leaching Trial (FLT) of In Situ Leaching (ISL) at Beverley is deficient due to :
the DEF stressing that ISL requires the individual characteristics of each deposit be investigated under field conditions to improve technical knowledge and reduce commercial risk, yet fails to point out which characteristics the FLT would elucidate (page 5-1) (1); Heathgate's refusal to commit to a specific chemistry for the FLT; (and) the failure to describe in detail the different FLT techniques to be trialled, and thus the respective environmental management issues for each technique; the assumption of low levels of carbonate, trace elements and heavy metals which could interfere with leaching chemistry (page 5-3) (1); suphate leaching chemistry being preferred because of it's use in current conventional uranium mines (with Olympic Dam being quoted (page 5-3) (1).
These assumptions and lack of detail are critical in assessing the potential environmental risks associated with the operation of In Situ Leaching at Beverley. In approving the DEF for the trial, the South Australian government have given Heathgate Resources carte blanch to experiment in whatever way they see fit with groundwater of the Beverley aquifer. As such, the groundwater of that aquifer can now considered a sacrifice zone.
The assumption of low levels of carbonate, trace elements and heavy metals is not justified without environmental data, which is not presented in the DEF. In groundwater chemistry, it is not simply the level of an element or mineral within the aquifer sediments that determines the likely concentration of that element in groundwater, it is the combined effect of groundwater chemistry interacting with the aquifer sediments to dissolve or precipitate the elements involved.
Under the highly acidic and oxidising conditions proposed for the FLT, many trace elements and heavy metals are readily dissolved into the groundwater in very high concentrations, especially when compared to the natural groundwater which is near neutral.
It is quite conceivable that low levels of a particular element could increase by several orders of magnitude within groundwater despite their relatively low levels within aquifer sediments. The necessary data on levels of these elements within the aquifer sediments and current levels in groundwater (before the commencement of ISL) are not presented in the DEF. In the context of the Beverley deposit, the FLT would therefore be taking unparalleled risks with groundwater quality and without a justified scientific basis.
The reference to conventional uranium mines using sulphate leaching is misleading in the extreme - mines like Olympic Dam operate large scale processing plants at the surface. These are engineered chemical facilities with a high degree of control and accessability. Any problems can be readily identified and, if necessary, remedied.
The process of ISL occurs completely underground where it is not possible to observe in detail the chemical processes occurring within the aquifer sediments and groundwater, except via regular samples of groundwater quality. In this way, any escape of leaching solutions will only be detected after it has occurred, and generally not before. This makes it quite problematic in becoming alerted to problems of precipitation of minerals and subsequent blockages of bores and potential offsite migration of leaching solutions.
The comparison of an above ground processing facility with an underground facility is misleading.
The weak commitment to the Beverley deposit is also evidenced when the DEF discusses the consequences of not proceeding with the FLT : "The company will not proceed to commercial development without the benefit of FLT information" (page 5-3) (1).
If Heathgate are committed to high quality environmental assessment, then why not have a separate EIS for the trial ?
This is clearly not what one could call a clear commitment to best environmental practice.
12 : FLT Contains Extremely High Concentrations of Dissolved Uranium
It is worth pointing out that the proposed FLT is estimated to contain the following concentrations of uranium for different extraction proposals :
| Process | Pregnant Sol'n | Recycled Sol'n |
|---|---|---|
| Ion Exchange Extraction Process * |
| Process | Pregnant Sol'n | Pregnant Organic | Stripping Circuit |
|---|---|---|---|
| Solvent Exchange Extraction Process # |
The maximum allowable uranium concentration for drinking water is 20 mg/l or 20x10-6 g/l (8). The above concentrations used in the mining process to extract the uranium are thus up to a million times higher than drinking water standards.
Considering that background uranium concentration in the Willwortina Formation aquifers is generally low (ranging from 0.7 to 96 mg/l, with an average of 32 mg/l page 5-8 (1)), any escape of the process solutions would have a potentially devastating impact on existing water quality and the beneficial use of the groundwater by pastoralisst and others.
13 : Excess Solutions to be Re-injected into the Beverley Aquifer
The DEF states there are two major options for the disposal of excess solutions and waste water from the FLT page 5-12 (1) :
The DEF states it prefers the first option - disposing of the various waste waters by re-injection back into the Beverley aquifer (page 5-12) (1). The disposal water will be made up of various solutions from the trial. The excess pumping (bleed) solution (5% of pumping flows, or 16 Ml (4) over 12 months) or is estimated to contain (page 5-12) (1) :re-injection into the Beverley aquifer; or evaporate the water and dispose of the resulting sludge.
Discarded process solutions (12,000 litres per week or 624,000 litres over 12 months (page 5-8) (1) ) are estimated to contain (page 5-12) (1) :5 mg/l uranium; 5 mg/l (0.5%) free sulphuric acid; trace amounts of selenium, molybdenum and other naturally occurring metals (emphasis added); 250 Bq/l radium; 2,000 mg/l bicarbonate (if a bicarbonate leach is used); pH remains unspecified.
The discarded process solutions be mixed with the bleed solutions to dilute the concentrations before disposal by re-injection into the Beverley aquifer (page 5-12, 5-13) (1). However, this is not the case. The extremely high concentration of the discarded process solutions will significantly increase the overall uranium concentration :50 g/l or 50,000 mg/l uranium; 100 g/l or 100,000 mg/l free sulphuric acid; hydrochloric acid at up to neat solutions; 300 to 3,000 Bq/l radium; relatively minor concentrations of trace metals (emphasis added); pH would be controlled to avoid precipitation of solids during injection.
| Source | Quantity (l) | Uranium Conc. (mg/l) |
Uranium Mass (mg) |
|---|---|---|---|
| Bleed Solution | |||
| Process Solutions | |||
| Disposal Water |
The maximum possible concentration of uranium in the "diluted" disposal is therefore 1,882 mg/l. The limited data presented in the DEF for the uranium content of the Namba aquifer is in the range of 0.001 to 3.1 mg/l with an approximate average of 0.57 mg/l.
To dispose of water with a uranium content over 3,300 times the average groundwater quality is unequivocally environmentally unacceptable.
Heathgate are using the Beverley (Namba) aquifer as their radioactive waste disposal site without any independent or critical assessment of it's suitability for isolating the radionuclides for tens of thousands of years from the surrounding environment. Given the problems highlighted above, significant uncertainties exist about the ability of Heathgate or anyone to guarantee that this isolation will indeed remain.
Perhaps even more relevant is that the disposal of such high quantities of uranium proves the Beverley Project is severely inefficient. The total quantity of uranium proposed for re-injection is estimated to be over 31 tonnes, twice the amount produced by the FLT !!
The economic viability of such a project must be seriously questioned.
14 : Ignores Potential Problems of Re-injection of Excess Leaching Solutions
The disposal water is noted to have significant quantities of acids (page 5-12, 6-7) (1). It is this acid which mobilises the uranium into solution during the mining process. However, disposing of this waste water containing these excess acids could therefore potentially mobilise further quantities of radionuclides, trace elements and heavy metals into solution, thereby exacerbating the groundwater quality of the Beverley aquifer.
No information is presented within the DEF to justify problems of precipitation, except bland statements made with no scientific reference to geochemical processes likely to act upon the re-injected water (eg - page 5-13) (1).
The DEF also points out the volume of the aquifer affected by waste water disposal to be 16 Ml (million litres), which at a nominal 5 m aquifer thickness and 30% porosity, would equate to 53,000 m3. Firstly, this calculation assumes no water is present in the aquifer before disposal, which is clearly not the case or else Beverley would not be suitable for application of the ISL technique. Secondly, the figure of 16 Ml fails to account for the discarded process solutions of 0.624 Ml. Although this is minor in comparison to the volumes from the bleed stream, the concentrations of uranium and other chemicals in this stream become extremely important in the effects on groundwater quality from the disposal array, as pointed out above.
The more important point, however, is that the above calculation in the DEF is extremely oversimplified. Firstly, the disposal array injects water under pressure. This would create a locally higher level of hydraulic head, meaning that there will be a hydraulic gradient away from the disposal bores. This will allow transport away from the immediate vicinity of the disposal bores, leading to potential impacts on groundwater quality outside of the zone mentioned in the DEF.
15 : No Rehabilitation of Groundwater Quality After the Trials
It is recognised that after the FLT at Beverley, the groundwater of the Namba Formation (the mineralised aquifer) "will have altered groundwater with increased or decreased pH....enhanced metals content and altered salinity" (page 6-7) (1).
The DEF then points out that the poor quality of the water renders and "is not therefore a water resource in the normal sense (useable by stock or people)" (page 6-7) (1). Heathgate then state that "it is therefore not proposed to undertake any post-FLT treatment of the B3 (Namba) aquifer" (page 6-8) (1).
As it has already been pointed out, Heathgate have a signifcant vested interest in arguing this point of view. However, Heathgate have not been able to conclusively prove the Beverley (Namba) aquifer is permanently isolated from surrounding groundwater systems which are used as a resource (in their narrow definition). Therefore the potential for contamination of surrounding groundwater systems is very real.
The environmental amenity of the groundwater is also critical. What precludes the use of such water in the future with improved technological advances in water treatment ?
To merely walk away from their environmental responsibility is a serious breach of trust of the community and a travesty to future generations.
16 : Solid Wastes to be Disposed of at Radium Hill
The DEF suggests there are two main options for disposing of solid wastes at the end of the FLT (page 6-19) (1) :
The radioactive wastes will consist of contaminated equipment, FLT filter backwash sludges and possibly salts from evaporation of the bleed stream (such as gypsum or calcite scale, with levels of radioactivity peaking at 80 kBq/kg Ra226) (pages 5-13, 6-19) (1).disposal to shallow-ground burial pit on site; disposal off-site.
The DEF then states it prefers to dispose of solid radioactive waste at the Radium Hill Shallow-Ground Radioactive Waste Disposal Site, operated by Mines and Energy, SA (MESA). Radium Hill was one of Australia's first uranium mines in the 1950s, with the ore treated at the Port Pirie uranium treatment complex for sale to the USA and UK weapons programs of the time.
The ability of old underground mine workings to be able to meet the desirable criteria for disposal of radioactive waste is in serious doubt, especially given the horrendous conditions the mine was operated under (see the Radium Hill Photo Gallery). Certainly, the regulatory status of Radium Hill as such a facility is not known publicly.
Heathgate should be establishing their own radioactive waste repository on the Beverley site. It should be fully engineered to the highest possible standards of environmental protection currently available and regularly re-assessed as to it's performance for tens of thousands of years.
17 : Original Design for the Detention Pond was unlined
A final point to note Heathgate's commitment to best environmental practice is that the original design for the detention pond for initial pump testing and operation of the FLT was unlined (page 3-2) (1) (2).
Surely, with the massive seepage at Roxby, similar problems at Ranger, and many instances across Australia and the world where tailings seepage has affected groundwater quality, Heathgate would as a matter of best environmental practice design and construct a lined detention pond in the first place ?
It highlights the fact that Heathgate Resources, with the multi-national might of General Atomics behind them, believe they do not have to adhere to basic environmental standards as dictated both by community expectation and government regulation.
18 : Etc etc etc etc etc etc etc........
What if Heathgate use both a sulphuric acid leaching chemistry and a bicarbonate leach chemistry at the same 5-spot pattern ?
This issue has not been addressed at all in the DEF.
The End Result
It is recommended that :
the Field Leaching Trial cease immediately; the above concerns and criticisms be answered in a rigorous scientific manner, with full access to the necessary data; a full EIS be prepared for the trial project; there be a full public evaluation of the trial; based on the results of the trial, public evaluation and government assessment, a new EIS be prepared for a full scale facility.
Page developed by for SEA-US Inc.
Page last updated September 2, 1998.
References :
2 - Heathgate Resources Pty Ltd, (1997b), Supplement to Declaration of Environmental Factors (D.E.F.) in Support of a Proposal to Undertake a Field Trial of Uranium Extraction by In Situ Leaching at Beverley, South Australia - Pumping Test; Prepared by Heathgate Resources Pty. Ltd., September 25, 1997.
3 - Transcript of the Senate Select Committee on Uranium Mining and Milling (SSCUMM) hearing in Adelaide, January 24, 1997.
4 - mg/l is micrograms per litre (10-6g/l); mg/l is milligrams per litre (10-3g/l); g/l is grams per litre.
5 - South Australian Uranium Corporation (SAUC), (1982), Beverley Project : Draft Environmental Impact Statement (dEIS), July 1982.
6 - Reference - pages 263-264, Appelo & Postma (1993), "Geochemistry, Groundwater & Pollution", A. A. Balkema, Netherlands.
7 - Parliament of South Australia; Environment, Resources and Development Committee - Roxby Downs Water Leakage; Nineteenth Report of the Committee, April 1996.
8 - Australian Water Quality Guidelines, (reference pending).
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