After months of persistence, the Australian Conservation Foundation finally forced the South Australian government in early 1998 to release all documents and correspondence relating to their approval of the Beverley Field Leach Trial DEF under Freedom of Information legislation. They were not happy about having to do it either. The comments contained in the documents perhaps raise a point of interest or two, but what is more intriguing is the extraordinary lack of critical and technical assessment of the DEF.Below is a summary of various SA and Commonwealth departments comments on the Beverley Trial DEF :
The only "minor" problems identified by various critiques were :accepting the view that old exploration boreholes have sealed (BRS, MESA (1), (2)); the Great Artesian Basin and surrounding groundwater resources of the north-western Lake Frome region are isolated from the Beverley palaeochannel (BRS, MESA (1), (2)); the use of sulphuric acid is an appropriate leaching solution (BRS, MESA (1)); no need for restoration of groundwater quality following the trial (BRS, MESA (1), EPA (1)); the solutions would undergo natural attenuation in the groundwater after the trial finished (BRS, MESA (1)); small volume of aquifer affected (BRS, MESA (1)); radiation protection measures are adequate (BRS); disposal of liquid wastes back into the Beverley palaeochannel is acceptable (BRS); disposing of solid wastes at Radium Hill is acceptable (BRS); surface impacts are negligible (MESA (1)); The only government submission that independently assessed the DEF was the Department of Housing and Urban Development (DHUD). They raised the points that (DHUD) :using sands and gravels from local creeks (MESA (1)); radiation exposures should include gamma and dust (MESA (1)); quantitative detail on radiation sources not included (MESA (1)); exact groundwater monitoring program unclear (EPA (1), EPA (2)); the source of recharge to the Beverley aquifer is unknown, and therefore the question of isolation from surrounding groundwater systems is questionable (MESA (2)); pumping tests needed to be run longer in duration (MESA (2)); problems of birds at the retention pond (EPA (1)). Heathgate were given the opportunity to reply to DHUD's critique, and made the following comments (HTHG) :
- the DEF lacked overall clarity;
- points out many contradictions in claims throughout the DEF;
- questions the integrity of old exploration boreholes;
- lack of scientific data used to justify certain assumptions made;
- suitability of liquid waste disposal back into the Beverley aquifer;
- problems of sands and silts in circulating solutions derived from bores;
- disposal of yellowcake unclear;
- lack of clarity of groundwater monitoring program;
- inadequate number of groundwater monitoring bores;
- lack of detailed measures to prevent excursions, including plans for cleanup;
- incorrect calculation of the aquifer area affected;
- bird problems at the retention problem;
- the use of the Great Artesian Basin bore is unclear;
- some references were missing;
- no mention of potential clogging of injection bores due to the buildup of silts and fines or the precipitation of different minerals.
- the trial is required since the capital investment for a full scale facility cannot depend on computer simulations extrapolated from laboratory studies;
- operational parameters include the "interactions between chemistry and flowrate", for both injection and recovery - eg - ore depletion curves;
- need flexibility in order to ascertain the most commercially viable techniques for the Beverley deposit;
- the "existing data is inadequate" for the design of a full scale facility;
- the Central and North Beverley sites were chosen since the geology and hydrogeology is better known and they have lower salinity than South Beverley;
- laboratory results cannot give operational parameters on the scale important to an ISL mine;
- early trials were only on closely spaced holes and lasted only days;
- no need for restoration of groundwater following the trial due to the original poor quality;
- old boreholes do not leak;
- the flowrate is intended to be the same as that from a full scale mine, but from one pattern at a time only;
- re-injection of waste water and excess solutions is ideal as :
- it avoids large evaporation ponds and surface impacts;
- it avoids permanent on-site storage if no project;
- the aquifer is isolated
- by controlling the pH of the injection water, no clogging can be expected;
- silt fines will "minimal to nil", since the bores are gravel packed;
- the number of monitoring bores was decided in consultation with MESA;
- the aquifer is only screened across 5 metres at the FLT pattern;
- volumes affected would add up to 68.4 Ml;
- gas guns for bird control are inappropriate since the operation of the FLT plant will involve the presence of personnel, and the constant noise and movement of vehicles and lights at night should be sufficient;
- usage of the GAB bore will have no discernable effect;
- clogging of the aquifer is "an operational issue rather than an environmental issue";
- phase changes (ie - mineral precipitation) are not anticipated and can be controlled by pH.
It is clear from the content of many of the documents obtained concerning the approval of the DEF that there has been no attempt by the South Australian government to do more than lip service in assessing the DEF. Many significant environmental and radiation risks were not well understood before the commencement of the Field Leach Trial and this should have resulted in the postponing of the trial until such time as those risks could be better understood and the public allowed to have their say. The Obvious Conclusions ?
There needs to be more information to address significant and fundamental scientific, technical and environmental concerns. In true nuclear industry style, they consistently argue "no impact" or "minimal risk" despite the obvious facts speaking for themselves. On one particular point, DHUD is proven to be correct and Heathgate have, well, due to threatened litigation, this wording has now been changed, but people can use their imagination as to Heathgate's dealings with the SA government and general public :
The DHUD submission on Beverley correctly questions the build up of silts and fines from bores, and Heathgate deny that this could be a potential problem. In the new version of their Beverley Project Profile, it is clearly stated that, with reference to the retention pond, "The solid wastes include the relatively small amount of sand that is produced with the pumped water" (page 10).But what else can one truly expect from one of the biggest, oldest and most relcalcitrant of nuclear mutlinationals.......When The General Speaks........
One can only expect the worst in the operation of the field trial, and perhaps the ancient Andymathanha elders understanding about "poisonous ground" will come true.......
References :BRS - Letter from the Bureau of Resource Sciences to MESA - technical comments on the DEF (7 pages), September 23, 1997;
MESA (1) - Internal MESA Memorandum from Ian Hopton to Jack Townsend (3 pages), September 23, 1997;
MESA (2) - Internal MESA Memorandum from Steve Howles to Jack Townsend (2 pages), September 29, 1997;
EPA (1) - Letter from the Environment Protection Authority (Max Hunter) to MESA (2 pages), September 29, 1997;
EPA (2) - Letter from the Environment Protection Authority (Jeff Reed) to MESA (1 page), October 24, 1997;
DHUD - Letter from the Department of Housing and Urban Development to MESA (5 pages), September 26, 1997;
HTHG - Letter from Heathgate Resources to MESA - response to DHUD comments (7 pages), October 13, 1997;
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