18 July 1997
INTRODUCTION
The Environmental Impact Statement (EIS) was ordered by the Commonwealth on 1st October 1996 under required uranium export permits for the WMC proposal to expand the capacity of the Roxby mine to 350,000 tonnes per annum (tpa) of copper plus "associated output of the uranium, gold and silver co-products" .
Friends of the Earth Australia lacks the enormous resources that were available to the proponents in preparing this EIS. We do not have the money, personnel, time or access to information that were available to the proponents. This puts us, and similar community groups, a serious disadvantage when it comes to responding to such a document as this EIS. However long unpaid hours have be put in by various members of our organisation. In general we feel it important to say that the EIS appears to be little more than an expensive public relations document. The glossy pictures and coloured graphs are more appropriate for persuading the Australian public and their elected representatives of the positives of the project than providing an accurate cost benefit analysis of the project. The 'executive summary', in particular, looks more like material for a school project than an objective representation of the expansion project.The EIS appears to be more a propaganda instrument than a true cost benefit analysis.
We generally found the document, though large and glossy, often:
It is the opinion of Friends of the Earth that the EIS has failed to meet the Terms of Reference, has failed to prove the project is either necessary or desirable and that it shows the proponents to be poor managers. We therefore recommend that the Expansion Project not be allowed to proceed.failed to provide important information; did not account for data and information it presented; use "soft", emotive and vague language in stead of quantitative data; promoted benefits without discussing costs, thus breaching the Terms of Reference for the EIS; presented unsubstantiated and vague data and references; used poor presentation of scientific data; presented irrelevant information, particularly in regard to phases of expansion; failed to address issues regarding public accountability and poor consultation processes with Aboriginal people and other community groups; failed to address major management issues associated with tailings management and water management.
The guidelines of the EIS for the Proposed Expansion of the Olympic Dam Operations preclude that process from considering a number of aspects associated with the world nuclear industry of which this mine is a part.What are the full economic, social, environmental and occupational health and safety consequences associated with the complete life cycle, ie 'cradle to grave', of the uranium mined from Roxby downs.
WMC have estimated that at a production rate of 200,000 tpa of copper, the production of uranium from Roxby will be 3,700 tonnes per annum or approximately 7% of world production. Under the accelerated expansion of Roxby (from the current 85,000 tpa) announced on the 12th February 1997, that rate will be reached in late 1999. The intended second level expansion early next century to 350,000 tpa Roxby will produce approximately 12% of world uranium production. This uranium will enter the world nuclear cycle, but the EIS does not address the life-cycle of the uranium mined from the Roxby Downs mine or Australia's involvement in, and responsibility for, the nuclear fuel cycle which result as a consequence of the WMC operations. Serious issues associated with transport, refinement, use in reactors and safety aspects of operations, waste management of end products and decommissioning of reactors are not addressed by the EIS.
The EIS should address the full economic, social, environmental and occupational health and safety consequences associated with the complete life cycle, ie 'cradle to grave', of the uranium mined from Roxby Downs.
The various stages of the expansion are confused throughout the EIS. The output of the mine is currently 85,000 tpa. The original EIS in 1983 covered production up to 150,000 tpa and construction to achieve this level of production by the end of the century has already begun. The new EIS for the Olympic Dam Expansion Project should only cover the increase in production from 150,000 tpa to 350,000 tpa. The proponent (WMC) has defined the stages of the expansion as follows:The EIS confuses data and information related to different stages of the planned expansion. This need clarification. In particular the economic impact assessment is not valid.
It should be noted that Phase 1 includes current expansion approved under the 1983 EIS ie 85,000 tpa to 150,000 tpa., along with some of the expansion required under the Terms of Reference to be covered by this, the 1997, EIS ie 150,000 tpa to 200,000 tpa.. However frequently, in the EIS, reference to 85,000 tpa is omitted and this phase is referred to simply as expansion to 200,000 tpa. This can easily be misconstrued as expansion from 150,000 tpa to 200,000 tpa.Phase 1 of the expansion is for 85,000 tpa to 200,000 tpa; Phase 2 of the expansion is for 200,000 tpa to 350,000 tpa.
With reference to Phase 2 it should be noted that, despite the fact that the 1996 amendments to the Roxby Downs (Indenture Ratification) Act 1982 are phrased in terms of 350,000 tpa, it is frequently pointed out in the EIS that this second phase has not been agreed to by the WMC Board. It can only be assumed therefore that this EIS is an attempt to get approval for a non-existent project. An EIS for a project for which there is no intent is a distortion of the environmental assessment process, a waste of public funds and would, in this case, give approvals 10 years in advance which is not due process.
Economic impact of the project are assessed in Chapter 13 using the above two phase expansion, with the emphasis being on Phase 1. But the major part (85,000 tpa to 150,000 tpa) of the so-called Phase 1 has nothing to do with this EIS. Only a minor part of Phase 1 (150,000 tpa to 200,000 tpa) is relevant to this EIS and this part is not separately considered in the economic impact (see the section on Chapter 13 for more discussion).
The two phases of the project should be defined in the EIS as 150,000 tpa to 200,000 tpa and 200,000 tpa to 350,000 tpa, respectively, and all reference to the 85,000 tpa to 150,000 tpa stage should be deleted except in relation to the project background and existing operations.
Since the 200,000 tpa to 350,000 tpa phase has not been approved by the WMC Board, it should not be included in this EIS.
CHAPTER 1. PROJECT OBJECTIVES AND BACKGROUND
The EIS states (p 1-5) "As of February 1996, the South Australian Government had received $45 Million in royalties since the beginning of production at Olympic Dam in 1988. This compares with Government's 440 million capital investment in infrastructure support during the initial establishment of the project."There are inconsistencies in royalty and capital investment figures. The EIS compares dollar values from different periods without equating to constant dollar figures.
This statement is misleading in two ways:
The EIS should contain an accurate comparison between Government expenditure on infrastructure and royalties in constant dollar terms.Firstly, it is conflict with information given in October 1989 by the then Minister for Mines and Energy, John Klunder, that $46 million had been committed by the South Australian Government Secondly, the dollars referred to are not constant dollars, eg. 1988 dollars, and therefore are not, as claimed, directly comparable.
It is noted that (p 1-10) "In October 1996, an agreement was made between WMC and the State government on WMC's and the State's obligations for expansion at Olympic Dam to 350,000 tpa. These obligations were incorporated into the Roxby Downs (Indenture Ratification) (Amendment of Indenture) Amendment Act 1996. The Amendment Act was passed by State Parliament in December 1996."
These obligations are prior to the EIS and hence may compromise the outcome of the EIS process, particularly the decision as to whether or not to allow the project to proceed.
The EIS should comment on all aspects of the Roxby Downs (Indenture Ratification) (Amendment of Indenture) Amendment Act 1996 which impinge on the EIS. For example, what would be the State's liability if the assessment of the EIS led to a decision not to proceed with the project?
In the section "1.4.3 Uranium: Use and markets' (p 1-17) no mention is made of the significant market in uranium for nuclear weapons.
Section 1.4.3 of the EIS should include all players in the uranium industry, including the nuclear weapons sector.
Forecasts from the Uranium institute are referred to but no information is given about the credentials of the Institute.
They are in fact an industry body based in the United Kingdom but representing companies from around the world that have interests in the nuclear industry. WMC is a member of the Uranium Institute. As such, use of unsubstantiated forecasts by this group represent conflict of interest and must be viewed cynically.
The Uranium Institute is an industry body with vested interests in promoting the industry. Forecasts from the Uranium Institute should be deleted from the EIS.
The section "1.5.2 The uranium market" (p 1-21) it is stated that if addition uranium were not produced at Olympic Dam then uranium demand would be met from other sources. We note that this implies the nuclear industry does not need the Olympic Dam Project. In section "1.5 Consequences of not proceeding with the project" (p 1-21) the estimated benefits from the project confuses work carried out under the 1983 EIS (up to 150,000 tpa) and that proposed to be carried out under the first stage of this EIS (150,000 tpa to 200,000 tpa. For example :
The EIS should provide figures on employment, GSP, GDP, royalties, taxes and balance of trade which pertain only to the expansion from 150,000 tpa.job creation during the construction phase is grossly exaggerated; increase in GSP during the construction phases is grossly exaggerated; job creation during the production phase is highly exaggerated increased in GSP and GDP during the production phase are highly exaggerated; the increase in royalty receipts by the State is highly exaggerated; increases in tax revenue for the State and the Commonwealth are highly exaggerated; increases in annual revenue from the sale of copper, uranium oxide, gold and silver and in Australia's balance of trade are highly exaggerated.
In the section "1.5 Consequences of not proceeding with the project" (p 1-21) the costs but not the benefits of not proceeding are given For example no mention is made of the negative effects of the project:The section on economic consequences of not proceeding with the project does not provide information on the benefits of not proceeding with the project or information on the negative effects of the project.
These negative effects would be avoided if the project did not proceed, not to include them breaches the requirements of the 'Terms of Reference' of the EIS.on balance of trade that occur during the construction phase or of the long periods of production that are necessary to recoup this deficit; on the agriculture sector of the economy.
The EIS should include both the negative and positive economic effects which are avoided if the project does not proceed.
In section "1.5 Consequences of not proceeding with the project" (p 1-21) the EIS introduces the extremely vague concept of "minimising". This term is of little utility unless it is accompanied by a limit or maximum. For example, a tailings storage facility (TSF) which is designed to minimise seepage should state that the seepage will be no more than, say, 5% of the liquid stored in the facility.
The EIS also gives the impression that the tailings storage facility has always been designed to minimise seepage. Judging from the findings of the ERDC inquiry into the leak from the tailings retention system at the Roxby Downs mine (see the section of this submission on Chapter 8), either this impression is wrong or "minimal seepage" is a meaningless term.
Vague and/or subjective language, meaningless provisos and soft promises should be removed from the text.
The EIS should give :
In section "1.5 Consequences of not proceeding with the project" (p 1-24) no mention is made of the radiation exposure and health risks avoided if the project does not proceed., again, not to include them breaches the requirements of the 'Terms of Reference' of the EIS.a quantitative definition of minimal/minimise; the date from which the TSF design and management minimised the seepage. There is no mention of health benefits avoided if the project does not proceed.
The EIS should contain an estimate of cancers, birth defects, etc avoided if the project does not proceed.
CHAPTER 2. EXISTING OPERATIONS AND ENVIRONMENTAL MANAGEMENT
The section on waste management refers to three tailings storage cells, subaerial deposition, decant systems, supernatant liquor ponds, and lined evaporation ponds (p 2-23). it is our understanding that these are relatively recent and that for most of the operational life there was only one cell, subaerial deposition, decanting, supernatant pond, and evaporation pond liners were not used, and that this led to severe leakage from the system.
The fact that multiple cells, subaerial deposition, decanting, and supernatant liquor ponds were referred to in the 1983 EIS and that they are again referred to in this section of the present EIS can easily lead to the conclusion that these practices were the norm. This is misleading.
The EIS should give more details, including dates, about the operations and environmental management used in the past at Olympic Dam.
CHAPTER 3. DESCRIPTION OF THE EXPANSION PROJECT
In the EIS it is stated that (p 3-1) "it is not proposed to import and treat ores or concentrates for the recovery of uranium." The Indenture amendments, however, do not rule out such a possibility and in fact the Indenture allows for uranium ores/concentrates from sources other than the from the Olympic Dam Operation to be processed. at the Roxby Downs mine.There are inconsistencies between statements in the EIS and the what is permitted under the Indenture in regard to importation and processing of uranium ores and concentrates from sources outside the mine.
The EIS should state that "uranium ores or concentrates will not be imported and processed".
CHAPTER 4. WATER MANAGEMENT
WMC's Olympic Dam Operation's (ODO) current operations and the intended expansion of the uranium/copper mine is entirely dependant, for the processing of ore and the town's water supply, on withdrawal of artesian water from the Great Artesian Basin (GAB). In the 12 months to March 1997 an average of 14.2 million litres a day (ML/day) was withdrawn from Borefield A, situated 100 km north of the mine, of which 1.5 ML/day is used by the town of Roxby Downs. WMC was granted legal approval for its second borefield, Borefield B situated approximately 200 km north east of the mine and which began extraction operations late in 1996, to increase combined water withdrawal to 42 ML/day. At this maximum rate the amount of water used by the mine would increase from 10 ML/day to up to 37 ML/day, with consequent requirement for an expanded tailings water system.
The EIS misrepresents concerns about use of water from the Great Artesian Basin (GAB) (p 4-7). The issue is not that WMC receives its water cost free but that it has free access to the water from the GAB.WMC should not have free access to Great Artesian Basin (GAB) water. Water cost comparisons are misleading and do not investigate the relationship between subsidy rates and conservation incentives.
The fact that water at Roxby Downs is expensive is irrelevant to the EIS. What is relevant is that all public resources, such as water from the GAB, should be paid for and should also be accounted for as a public cost in the EIS. Transport to and from Roxby is expensive but this does not mean WMC should expect it to be subsidised. Like transport, water is one of the costs which contribute to the economics of the project. Subsidies create inefficiency and poor use of resources. Uneconomic projects should not be propped up by government subsidies. Comparison with water consumers in cities and regional centres is also misleading. These consumers pay a supply charge and a quality charge. These charges cover the costs associated with the water supply and the quantity charge is an incentive to conserve water. On the other hand, according to the EIS, residents of Roxby Downs receive subsidised water, paying $0.88/kL compared to supply costs of $2.40/kL (Table 4.2). These subsidies discourage water conservation.
Discussion in the EIS on water costs reads like an attempt to justify poor business practice. It has no place in the EIS. An analysis of water costs should include all the costs to the Australian community incurred by the project. Costs to all sectors including agricultural and tourist industries should be included. For example, we note predictions of pressure loss in a number of mound springs and pastoral bores in the region (Figures 4.14, 4.15, 4.16, and 4.17 and Table 4.8), what costs will this create for tourism and agriculture. As well as direct costs to the public in the form of subsidies, loss of amenity should also be investigated. It is of particular importance that costs incurred by the project on Aboriginal communities be included eg. what are the costs incurred due to loss in flow rates in mound springs?. Water conservation (p 4-9) is best encouraged by charging the full price, including the cost of water from the GAB.
The section on water costs should be deleted and redone giving an analysis of full public costs.
The claim (p 4-9) that "Figure 4.6 also demonstrates the effectiveness of water minimisation programs after 1993É", is not borne out by the data in Figure 4.6, which shows that per person water consumption is about the same in 1997 as it was in 1990.
The claim that "Figure 4.6 also demonstrates the effectiveness of water minimisation practices after 1993" (p 4-9) should be deleted.
The data in Table 4.7 is said to be approximate but no estimate of the uncertainty is provided.
The EIS should provide uncertainty measures for all data.
Given that effects of drawdown in the region of Borefield A appear to have onset with greater intensity than the proponent predicted (see below), little confidence can be placed in the model used in this EIS in regard to projected combined impacts of Borefield A and Borefield B on potentiometric heads and the mound springs.
The model used by the proponent to determine trends in future potentiometric head and the associated affects on mound springs lacks independent review.
We note that Figures 4.14, 4.15, 4.16, and 4.17 indicate constant declines in flow rates of all mound springs after the year 1999, and that most, including the very significant Hermit Hill Spring complex (see below) have either fallen below current flow rates or are showing a significant trend in that direction by the year 2010. This should not be allowed to occur.
The EIS should contain an independent review of the model used by the proponent to determine trends in potentiometric heads in the region and consequent impacts on mound springs in the region.
The EIS should provide a range of scenarios for trends in potentiometric heads in the region and consequent impacts on mound springs in the region, including worst case scenarios.
The EIS should review the effect of closing down Borefield A on the integrity mound spring flow rates in the region, eg. Berry & Armstrong (1995).
Figure 4.22 shows a cone of depression centred between the mine water disposal pond and the solid waste disposal area, some distance from the mine area. Why is the centre at this site rather than in the mine area? Is there a significant channel through the ground to the mine? If there is a channel, is it located close (eg. 0.5 to 1 km) to the tailings storage facility? Is it possible that this channel was caused by the leak from the tailings retention system and, if so, will it get bigger?Figures and statements about the cone of depression associated with mine water raise questions.
The statement is made (p 4-42) that flow is towards the centre of the cone of depression. By definition, flow is towards the centre of the cone of depression, albeit by a circuitous route, as for example in the SW segment where the flow deviates by some 45° from the line to the centre of the cone of depression.
The EIS should explain, and give the significance of, the location of the cone of depression.
It is predicted (p 4-43) that the rate of mine inflow will increase from 3.2 ML/d to about 7.3 ML/d. The reason for this is not obvious. The EIS suggests that this is a natural ongoing process but gives no evidence to support this suggestion. No historical data on mine inflow rates is supplied by the EIS. Is the proponent anticipating greater leakage from the tailings retention system into the mine?
The EIS should give adequate justification for its predicted increase in mine inflow rate.
The EIS should contain data on the analysis of all water, including rain water, underground water, mine water, tailings liquor and Great Artesian Basin water. The analysis should include radioisotopes and should be accompanied by measures of the variability and uncertainty. Chronological data, especially for the underground water and the mine water should be provided.
Borefield A operates under Special Water License No.2 (SWL) granted on 9/5/86. There is a specified Designated Area for Borefield A which is 2,700 km sq in area (maps on pp. 4-2 and 4-3). This Designated Area is very much larger than Borefield A itself which merely contains the 9 water production bores. SWL No.2 places conditions on WMC to 'limit' the extent of drawdown (the degree of reduction in potentiometric head or watertable head) of artesian waters that they cause on the GAB, as measured at the boundary of the Designated Area of Borefield A. The legislation sets that drawdown limit at 5 m but that same legislation contain a clause that enables the limit to be reset.
The Clause 13(8)B(ii) of the Indenture states that: "...the abstraction of water...will not reduce the potentiometric pressure by more than 5 metres (or such other pressure reduction as may be agreed between the Joint Venturers or an associated company and the Minister for Water Resources) at the boundary of the designated area". This legislation gives WMC a legal right to cause a drawdown impact of up to 5m at the boundary of the Designated Area and subject to agreement, above 5m.
The current set of conditions for SWL No.2 were approved by the then Minister of Mineral Resources in June 1993 (this authority now comes under the Minister for Mines and Energy). They were made in response to an application by WMC in January 1993 for an increase in allowable drawdown from 2m to 5m. The 2m limit was the drawdown limit at the boundary of the Designated Area under SWL No.1.
The application was approved by the Minister under the following conditions :
Essentially, because drawdown limits are negotiable, there is no legal constraint on the degree of drawdown effects within the Designated Area of Borefield A, and due to the vast time scale for recharge, with age of this fossil water up to 1.5-2 million years and lateral movement of approximately 1-5m per year, this regional drawdown effect is near permanent in our time. Within the Designated Area of Borefield A the drawdown to February 1996 (the most recent publicly available monitoring information) varied from 2.8m at MB4 to 32.7m at GAB14A in the centre of the borefield, with the average drawdown over 29 bores at 16m.the drawdown at the boundary of the Designated Area between boreholes GAB8 and HH2 shall not exceed 4m; the drawdown at the boundary of the Designated Area, as measured at Jackboot Bore shall not exceed 5m (located on the north-east boundary).
That the drawdown limit under SWL No.2 was set at 5m is an indication of the fragility of any set drawdown requirement under the legislation. When the 2m drawdown limit set under SWL No.1 was not going to be met, WMC were able to renegotiate the drawdown limit. It is inappropriate that the company can renegotiate legal requirements when it suits their purposes.
WMC should not be allowed to 'negotiate' a higher drawdown limit thus evading a breach in legal drawdown requirements.
In March 1994, 9 months after setting the 5m limit at Jackboot Bore, the drawdown was measured at 4.9m (ODO Environment Management Programme Annual Report 01/03/94-28/02/95 p.128). As this figure is expected to increase over time with water extraction, it can be projected that WMC were about to exceed their legal compliance for the drawdown effect of Borefield A. In spite of a requirement that Jackboot Bore be monitored every 3 months, there has not been a follow up "shut in pressure measurement" undertaken in the 2 years to February 1996, the most recent monitoring data publicly released by WMC.
The ODO Annual Reports are dismissive of this situation. Claiming that "..influences at Jackboot are a combination of pastoral use and water extraction from Wellfield A" (1995, p.128), and that "A shut in pressure was not obtained from Jackboot Bore during the monitoring period as a total shut-in at this bore causes disruption to stock watering supply" (1996, p.144). The SWL conditions make no such qualification on WMC legal compliance, referring to the measured drawdown per se at Jackboot bore. It appears WMC monitoring practices do not allow assessment of their required legal compliances.
WMC and the SA Government have documented drawdown affects from the Borefield A as coming very close (4.9m to a 5m limit) to being in breach of the requirements yet a follow up assessment was not undertaken in a period of 2 years.
The EIS should contain:
Close to the Roxby borefields are a number artesian springs known mound springs. These are naturally occurring wetlands that are formed when fossil water from the Great Artesian Basin is vented at the ground surface. The springs are isolated habitats forming an archipelago of aquatic islands in an arid sea (Ponder 1986). Many individual springs and spring complexes exhibit a high degree of endemism often at higher taxonomic levels such as genus, family or order (Ponder 1986, Reader et al 1985, Boyd 1990, Harris 1980, Zeidler and Ponder 1989). The springs are shallow and often small in area without an adequate flow of ground water they would rapidly dry up and be irreparably damaged. When the borefield was first proposed by WMC, concerns were raised by environmentalists about the effect of pumping at the borefield on the springs and the nearby artesian bores.
The importance of the boundary between boreholes GAB8 and HH2 (see above) is its close proximity to the Hermit Hill Spring (to the west of the boundary and in the eastern part of that spring complex), acknowledged to be 3rd in conservation ranking of mound springs in SA (Rangl.J. 14(2):157-73) and of special spiritual association to the Aboriginal community. The application for a 5m drawdown limit was restricted to an approval of 4m in this area so as to 'protect' the artesian water supply to this mound spring complex. The drawdown at monitoring bores GAB8 and HH2 was 2.8 m and 1.0 m respectively, the drawdown at the Designated Area boundary between these two bores (determined by the average between the two values) was 1.9m. This figure must be seen in the context of the low potentiometric pressure at Hermit Hill Spring of 8m and the, soon to be realised, combined drawdown effect of Borefields A and B. While the impact of Borefield A is partially shielded by a fault line through the GAB, Hermit Hill Springs are fully subject to impact from drawdown caused by Borefield B, which is up-flow and to their north-east.
Given that actual rates of drawdown were, and apparently continue to be, inconsistent with those predicted by the models presented by WMC for Borefield A, little confidence can be placed in the potentiometric modelling used by WMC in this EIS. This is very pertinent to the credibility of the proposed operations in Borefield B and does not give cause for assurance in how WMC address the protection of the ecological integrity of Mound Springs that are dependant on a natural GAB water flow regime.
WMC have asserted that Borefield B was required for the intended increase in production from 85,000 tpa to 150,000 tpa. However WMC had reached, and possibly passed, the legal drawdown effect of Borefield A prior to the application for a special water licence to allow development of Borefield B. It would seem from this that Borefield B was required to maintain the production levels of 85,000 tpa. The EIS should indicate whether Borefield B is necessary to maintain production at 85,000 tpa, or for an expanded production. In addition, given the drawdown limits were reached so quickly at Borefield A, what assurances can be given that Borefield B will not follow a similar trend, and if it does what is the expected feasibility for the establishment of other borefields in the future.
The EIS should indicate whether Borefield B is necessary to maintain production at 85,000 tpa, or for an expanded production.
The EIS should provide an independent analysis of all borefield modelling used by WMC with specific investigation into why Borefield A reached its limits quicker than predicted and how this relates to models for Borefield B and any potential future borefields.
The EIS should contain as comprehensive as possible a cost benefit analysis of scenarios at different rates of drawdown, including rates of the order of, and greater than, those experienced at Borefield A.
Environmental monitoring reports prepared by the proponent admit the possibility that saline water from the borefield's upper aquifer may actually be drawn into the lower aquifer, contradicting WMC's repeated assurance that the artesian and overlying aquifers are in no way connected. As a result, pumping regimes in the borefield had to be altered.Inconsistencies in claims by the proponents regarding their management of GAB activities.
Inconsistencies in reports and claims made by WMC require investigation. Such inconsistencies mean that confidence cannot be placed in the information presented by the proponent or in their management of the Olympic Dam Operation.
CHAPTER 6. ABORIGINAL CULTURE AND RELATIONSHIPS
The chapter is grossly misleading. It gives the impression that the company has good relations with Aboriginal communities, there is little, and in most cases no, reference to Aboriginal disenchantment with its operations.WMC consultation processes with Aboriginal people has been poor and inconsistent.
On p 6-2, the following dot point is made:
"Negotiations with Kokotha People's Committee (KPC), did not result in agreement for the confidentiality of cultural information"This is the only indication in the EIS of any Aboriginal group having dispute with the company, yet there is compelling evidence of a great deal of disenchantment amongst Aboriginal people in the region with the activities of the company.
Local Aboriginal community leaders have approached FoE Australia with concerns that WMC have supported and consulted with some Aboriginal people who are approving of WMC activities while ignoring the concerns of those that do not support their activities.
Many Aboriginal people have voiced disapproval over the activities of WMC. Two local Aboriginal communities in particular, the Kokotha and the Arabunna, have raised concerns about damage done to their sacred sites and about inadequacies in the consultative processes between WMC and Aboriginal people.
The Kokotha are traditional owners of the region where the mine is situated and the Arabunna have ties to the mound springs area where WMC extracts water from the Great Artesian Basin.
In South Australia the Aboriginal Heritage Act was established to facilitate the identification and protection of sites of cultural significance to Aboriginal people. The Part 2 Sec.9 of the Indenture overrides the Aboriginal Heritage Act. and prevents declaration of protected areas unless WMC agree. One consequence is that only sites identified in an EIS are offered any protection. At the time of the original EIS of 1983, an anthropologic report prepared by the Kokotha Peoples Committee was refused inclusion on the grounds that it was presented too late, even though it was presented three months prior to that EIS being published. As a result, many sites were denied legal protection (Rosewarne 1995). In addition, the lease arrangement established by the Indenture prohibits the Kokotha people access to sacred sites except in the presence of company personnel, there by violating the sanctity of these sites (MAUM 1991). So far numerous sites have been destroyed, including one which has been desecrated by the main mining shaft (MAUM 1991).Disagreement between WMC and Kokotha people
WMC have refused to accept the rights of Kokotha people to retain confidentiality of sacred sites and have demanded a form of assessment of Aboriginality of several leaders in communities in the region (Rosewarne 1995). Both these actions represent a considerable insult to Aboriginal people and represent totally unacceptable behaviour on the part of WMC. The Kokotha have expressed their dissatisfaction with the activities of WMC by actively resisting the mine, for example they blockaded the Canegrass sacred site in 1983 to prevent a road through to the bore holes.
The EIS should, without reference to specific confidential matters of significance to Aboriginal people, outline the disagreement between themselves and the KPC (as referred to in the EIS), and any other Kokotha people, explaining what the problems were and if and how they were resolved.
The consultation processes between WMC and Arabunna people has likewise been very poor. The concerns of the Arabunna center on damage to sites of cultural and natural significance, in particular the mound springs and sites damaged by the construction of pipelines. To summaries some of the WMC's record regarding consultation with Arabunna people and Aboriginal spokesperson in the region :
Flawed consultation processes between the company and Aboriginal people have exacerbated tensions amongst the Aboriginal communities in the region. The most serious consequence of this tension was a riot in Marree in January 1995 which resulted in one death and several people being very badly injured. Appeals by environmental groups and the Arabunna people to the Federal Government to hold an investigation into this violence appear to have been resisted.they have consistently avoided serious consultation with Arabunna people; they have consistently avoided serious consultation with spokesperson and elders identified by Aboriginal communities in the far north of South Australia; there are indications of anthropologists working for WMC who have drawn up territorial boundaries which appear to favour Aboriginal groups supportive of the company; there is evidence that WMC have helped set up and resource Aboriginal groups favourable to their activities; it is believed they have supported and helped facilitate initiation ceremonies in the region that are offensive to Arabunna and some other groups in the area. Flawed consultation processes between the company and Aboriginal people have exacerbated tensions within the Aboriginal communities in the region
The EIS should review the activities of WMC that have exacerbated conflicts between Aboriginal people in the region.
Aboriginal leaders have expressed frustration to FoE Australia at WMC stating that the WMC consultation process is evidence that they are meeting their obligations in regard to addressing the concerns of Aboriginal stakeholders, while in fact they are ignoring the legitimate concerns of many Aboriginal people. In additions some Aboriginal leaders have expressed concerns over anthropological work undertaken in the region, in particular, the activities of a John Bannon and a Steve Davies and their relationships to WMC should be investigated and outlined in the EIS.
The EIS should specify the processes WMC have instigated to ensure all Aboriginal concerns are addressed. It is not enough to announce a policy and state that consultation occurs, there needs to be verification of this consultation and of the measures WMC undertakes to ensure action is taken to protect Aboriginal sites and accommodate Aboriginal wishes and concerns.
The EIS should provide a list of Aboriginal groups and individuals consulted.
The EIS should specify processes WMC have instigated to ensure all Aboriginal concerns are addressed.
The EIS should specify the verification processes for ensuring adequate and appropriate consultation with Aboriginal stakeholders.
The EIS should indicate what disagreements exist between WMC and Aboriginal people, explaining the problems and outlining and existing and/or potential dispute resolution measures. this should include identification of all disputes and disagreement, current and historic, between WMC (including those when the operation was conducted under joint venture contracts) and Aboriginal groups, individuals, elders and spokespeople, explaining the problems and outlining dispute resolution measures.
The EIS should contain far more comprehensive description, though not site specific, of the measures WMC will execute to ensure action is taken to protect Aboriginal sites and accommodate Aboriginal wishes and concerns.
CHAPTER 7. BIOLOGICAL ENVIRONMENT
Ecological sustainable development is introduced (p 7-1) in connection with biological diversity. ESD is a very broad concept and arguably central to good environmental practice. it should be introduced at the earliest stages of the EIS, eg in Chapter 2 "Existing Operations and Environmental Management".Ecological Sustainable Development.
Ecological Sustainable Development is not given a prominent enough role in the EIS.
The tables listing impacts on mound spring fauna elude to a telling tale of severe impacts. Table 7.18 in particular shows the true impacts the borefields are having on the fauna of the springs. At all springs there is a "decline in all endemic fauna" or, in some cases "Total loss of all endemic fauna". It is also pointed out that on many springs there is insufficient data on which to judge long term trends. This is not acceptable.
The EIS should contain independent reviews of the monitoring program and suggest remediation programs for severely affected springs.
CHAPTER 8. TAILINGS MANAGEMENT
Roxby Downs is not a straight forward uranium mine, the design of the refinery and mill is much more complicated. The plant contains a grinding mill, a copper sulphide/uranium flotation separation unit, a uranium leaching plant, another uranium leach circuit to extract residual uranium from copper slag and copper sulphide, a smelter, a copper refinery, and arrangements to extract silver, gold and residual uranium from copper anode slimes and slag. While most of the radiation is confined to the uranium circuit, there is also radioactivity in the copper slag and anode slimes.
The plant produced approximately 2.7 million tonnes of tailings in the year (Mt/a) 1996-97 (p 8-2), this is expected to rise to between 6.6 and 6.8 Mt/a when production is at 200,000 tpa (p 8-11). Based on the figures given in the EIS (p 8-17 to 8-18) this would equate to approximately 180 million tonnes for what is assumed to be the lifetime of the mine, or 390 hectares, of tailings, equal to about 150 football fields each 30 metres high, which will contaminate the environment for hundreds of thousands of years. (We note that for expansion to 350,000 tpa the proponent gives the tailings storage capacity at 330 Mt)
Analysis of the liquid in the evaporation ponds should be provided.Chemical and radionuclide analysis of evaporation ponds.
The EIS should provide and analysis of liquid in the evaporation ponds.
Preparation of the floor of the tailings storages is inadequate. The quality of the clay at the site is not discussed. There is a wide variation in types and quality of clay, especially with respect to waste water permeability.
Further there is insufficient attention given to the problem of the dolines.
The EIS should contain information on the suitability of clay used to contain various types of liquid wastes.
The EIS should address the problem of the dolines.
A 1 m thick clay layer is said to minimise potential liquor migration through the walls (p 8-3). This is a useless statement. Surely a 2 m thick layer would be even more effective, so how can 1 m be said to minimise the leakage?Reference is made to minimising the seepage through the tailings storage facility walls. This is a subjective term with vague meaning. There is a lack of quantitative data on seepage rates.
The phrase "minimal practical seepage" is again used on p 8-27.
It is stated that modifications made to the TSF have fulfilled the objective of ensuring minimum seepage from this facility (p 8-5). Minimum seepage is zero. Does this mean that there is now no seepage from the TSF?
Vague and/or subjective language, meaningless provisos and soft promises should be removed from the text. In this case what is the meaning of minimise?
The EIS should contain current and projected rates of seepage from the TSF.
Supernatant is said to collect "in a central pond" (p 8-3) yet Figure 8.2 appear to show that the supernatant collects against the a wall on the side of the tailings cells.
Delete "central" when referring to the ponding of the supernatant in the tailings dam.
A "massive leakage of water" occurred at the Roxby Downs uranium mine tailings retention facility and, despite the knowledge of this occurrence by WMC, it was not publicly acknowledged until 1991, "when the situation was too big to ignore" (ERDC finding p:6). The leakage caused a "groundwater mound" which the proponents say they did not investigate "intensively" until 1993-1994 (EIS p 8-5).
It is noted that the proponent has not been able to identify the relative contribution from the tailings storage cells, the mine water disposal pond and the wash water evaporation pond to the rise in groundwater under the tailings retention system (p 8-5).
It was the gravity of this event that led to establishing the ERDC inquiry.
The findings of the inquiry clearly supported the assertion that the leak had occurred as a result of mismanagement and due to the inherent hazards of the tailings deposition methods. The ERDC found "Éthat, although admitting difficulties of interpretation, the operators were reluctant to accept that a leakage from the tailings retention system was occurring, despite mounting evidence to that effect" (ERDC p:6).
The ERDC found "that, confident of the benign impact of any seepage, the operators were reluctant to admit deficiencies in the design and difficulties with the operation of the tailings retention system which were contributing to the leakage from it and that this reluctance coloured their reporting of operations at Olympic Dam and delayed measures necessary to understand the leakage and reduce its impact" (ERDC p:6).
The ERDC found "that it was only when the leakage was too big to ignore or explain away and only in response to hard prompting from regulatory agencies that ad hoc operational changes were converted into radical remedial action to alter the defective design concept" (ERDC p:6).
The ERDC found "that there are several deficiencies in the design of the initial system at Olympic Dam. The most important of these defects was the failure to provide for a decanting of the excess liquor which ponded on the surface of the tailings storage cells". It was also found "Éthat the concept of unlined evaporation ponds was a deficiency of the design of the initial system and that the decision to remove the course particles from the tailings exacerbated these design deficiencies and made management of the system more difficult" (ERDC Presiding Member's Forward).
The ERDC noted "that the Olympic Dam tailings retention system did not receive the degree of informed supervision of its various components it required to operate efficiently as designed and that this inadequate supervision by the operators of the tailings retention system, particularly the system as extended in 1991, contributed to the massive leakage from it" (ERDC p.5).
The proponents failed to prevent the original massive leakage and it appears they have failed to rectify the leak. The EIS states (p 8-7) that remedial measures to prevent leaks from the tailings retention system undertaken 2 to 3 years ago Òare becoming effectiveÓ. In other words they are not yet effective and the tailings retention system still leaks. Further the proponents have been unable to identify the relative contribution to the "groundwater mound".
These failures raise serious questions about the ability of WMC to effectively manage the project.
Given the poor management practices that allowed the leak from the tailings retention system to occur and the inability of the proponents to identify and rectify the causes of the leak, the Expansion Project should not be allowed to proceed.
The findings of the Environment Resources and Development Committee substantiated that the tailings design was inherently flawed and should not have been approved as appropriate technology in the first place, and that a primary contributing factor to the leakage from the tailings retention system was the mismanagement of the mines operations (see comments above).
The response to Recommendation 4 of the ERDC is inadequate. The leak from the tailings retention system occurred because changes were made to the proposal contained in the 1983 EIS. The proponents response in this EIS enables this problem to be repeated.
The response to Recommendation 9 of the ERDC is inadequate. Since neither source of the leak nor the location of the leaked material have been found, then the monitoring system is patently inadequate. The proponent does not respond adequately to the call for an independent expert systems of environmental audit which is contained within Recommendation 15 of the ERDC. The proponent merely states that an external audit has been implemented.
Details of the ERDC criticisms should be included in the EIS.
The EIS does not provide adequate responses to Recommendation 4, Recommendation 9 or Recommendation 15 of the ERDC.
It is evident from the ERDC findings and from a November 1995 review of its own practices (WMC 1995), that WMC did not construct the original tailings retention system according to specifications set out in the 1993 EIS. Their failure to adhere to the original design specification exacerbated the leakage problem (ERDC 1996). The public cannot have confidence in this EIS if WMC are allowed to breach the requirements as they did with the 1983 EIS. The processes outlined in the new EIS do not ensure State, Commonwealth, Aboriginal and conservation requirements will be adhered to.Failure by WMC to meet requirements and design features set out in the 1983 EIS or to adequately respond to ERDC criticism and recommendations, create doubt about their intent in regard to this EIS. Design and management of the tailings storage facility do not meet international best practice.
Design and management of the tailings storage facility is inadequate and not consistent with industry best practice. The storage cells should be lined with appropriate clay and synthetic liners in such a way as to meet specific criteria, eg., less than 5% loss of liquid into the ground under the cells.
The EIS has failed to show the proponent can meet State, Commonwealth, Aboriginal and conservation requirements or international best practices in respect to the design and management of the tailings containment, therefore the Expansion Project should not be allowed to proceed.
The EIS states in relation to the tailings retention system (p 8-6) "The seepage lies within the influence of the mine cone of depression, and therefore flows towards the mine."
Figure 4.22 shows, however, that the centre of the cone of depression is very close to the tailings retention system.
The EIS should provide an explanation of the apparent discrepancy between it implication that leaks from the tailings retention system would be returned to the mine and Figure 4.22 which suggests that this is not the case.
Though it is inappropriate for the EIS to discuss expansion beyond the 200,000 tpa, we note that the EIS states there would be no need for additional evaporation ponds if the project expanded to 350,000 tpa (p 8-20). We understand massive additional quantities of water would be required for such an expansion. The EIS does not adequately address the lack of need for further evaporation ponds during a 200,000 tpa tpa 350,000 tpa phase.Statements about the lack of need for evaporation ponds for an expansion from 200 000 to 350,000 tpa appears to lack validity.
It is inappropriate to make unsubstantiated comments that lack adequate details about potential infrastructure or management arrangements for expansions beyond the 200,000 tpa.
The claim that the cone of groundwater depression is a safeguard against groundwater pollution (p 8-27) is debatable:
The EIS fails to substantiate the claim that the cone of groundwater depression is a safeguard against groundwater pollution.the groundwater under the tailings retention system will be polluted irrespective of the cone of depression; as discussed elsewhere, the cone of depression is centred close to the tailings retention system; the reaction of the waste water with the ground is likely to produce a precipitate (gypsum) which acts as a plug and therefore causes a diversion of the waste water from its original direction of flow.
The information on radium grades and radon release rates at the Olympic Dam Operation given in the EIS does not follow conventional presentation for scientific data and thus does not reflect accurately the variability in the data. This tends to give an impression of lower grades and lower release rates, an impression which is favourable to the proponent's position. The statement that the average radium grade is 6.98 Bq/g and the standard deviation is 1.65 Bq/g (p 8-29) is nonsensical. It suggests a poor understanding of correct data presentation. With such a high standard deviation, a maximum of 2 significant figures is justified. The figures should read 7.0 and 1.7 respectively. Similarly radon release rates should be presented as 1.3 Bq/m2.s) with a standard deviation of 1.7.Statements in regard to radium grades and standard deviations do not reflect variability in the data accurately.
The EIS should present data in a manner which reflects the variability in the data.
The average radon surface release rate (1.3 Bq/m2.s) should be compared with the natural background, which is about 50 times lower.
The EIS fails to make direct comparisons between radon release rates associated with the tailings and the natural (pre-exploration) rates.
We note the high standard deviation of the radon release rates and the admission that the measurement method used is unreliable. Considering that the proponent has been working at the site for over 10 years, we find this situation to be highly negligent.Standard deviations for radon release rates are very high and measurement methods are unreliable, this is unacceptable.
As it cannot be demonstrated that reliable (eg., to within 10%) measurements can be made of all radioisotopes, the Expansion Project should not be allowed to proceed.
Considering that the radiation hazard will persist for many thousands of years, we consider that the statement ÒIt is unlikely that the region would become more densely populated in the foreseeable futureÉÓ (p 8-29, see also p 8-31) is naive in the extreme.. The proponentÕs own experience is evidence of the inadequacy of such a statement; the population in the region has gone from about 10 to several thousand in less than 20 years as a result of the Olympic Dam mine.
For the purposes of considering rehabilitation and radiation hazard, the EIS should assume that the region will be populated sometime in the thousands of years that the hazard will continue to exist
The value of the average natural flux of radon from Australian soils is quoted but not the value for the mining lease prior to the commencement of work. Only the latter is relevant to this EIS.
The EIS should give the natural flux of radon for the mining lease prior to the commencement of work on the lease site.
Figure 8.9 gives an average radon decay product concentration but no information is given about how the averages were determined. Are the averages over all directions? To what time of the year do the values refer?
Use of averages in the EIS should be accompanied with a description of how the averages were obtained and over what parameters (time, direction, distance) the data was averaged.
The term "design life" as distinct from "structural life" (p 8-31) requires explanation.
The EIS should define what is meant by "design life" and "structural life" of the project.
Reduction of radon release by a factor of 3-4 (p 8-31) still leaves the release rate at about 20 times higher than normal. The aim of rehabilitation should be to return the environment back to the condition it was in before the project first commenced (ie. before exploration at Olympic Dam) or better.
The EIS should be modified to include rehabilitation back to the original (pre-exploration) condition or better.
Many people, especially those in mining communities (including Roxby Downs, see p 11-1), use water which has to be treated and desalinated before it can be used. The fact that the water in the local aquifer is unfit for human, stock or crop use (p 8-31) should not therefore be used as an excuse for allowing it to be polluted.
The EIS should be modified to take into account future needs of water. In particular, underground water should not be polluted, or if it is it should be rehabilitated. If this cannot be ensured the Expansion Project should not be allowed to proceed.
Considering that the TSF will remain a hazard for many thousands of years, the statement "Accidental intrusion into the TSF in the future is not a credible event" is unrealistic. Similar accidental intrusions have occurred over much shorter time spans, for example polluted locations left un-managed by WMC at their Yeleerie site.
The EIS should include precautions against accidental intrusion into the TSF over the time span that the TSF continues to be a hazard.
The Chapter on Tailings Management lacks a great deal of detail in regard to construction plans and programs of management for any constructions, operations, monitoring and regulatory procedures in regard to the proposed extension of the tailings retention system. In addition
the EIS does not provide a comprehensive Waste Management Program which apart from addressing some of the issues outlined above should also demonstrate a clear aim to minimise the production of waste and incorporate cleaner production processes.
Details of construction plans and programs and a detailed Waste Management Program should be included in the EIS.
CHAPTER 10. RADIATION
Radiation exposure regulations deal with individual doses, but this section, in all but one figure (Figure 10-15), reference is to averages.Radiation exposure dosage measurements used by WMC and presented in the EIS are dangerously unsuitable.
The EIS should contain data and figures showing the distribution of individual doses for the various occupations in the mine, processing plant and administration (c.f. Figure 10-15)
The EIS refers to ventilation air "that is relatively free of radon decay products", but gives no data on the quality of the ventilation air.
It is noted that the mean concentration of radon decay products in the mine Purple Stope area (Figure 10.3) is up 75 times the normal, above ground concentrations.
The EIS should contain data on the radionuclide composition of ventilation air and compare it with natural (pre-exploration) air.
No mention is made of the recent (February 1997) criticism by Worksafe Australia to the effect that the proponent has underestimated, by a factor of two, radiation doses from radon decay products.
The EIS should respond to criticisms by Worksafe Australia to the effect that the proponent has underestimated, by a factor of two, radiation doses from radon decay products.
The proponent states that radiation exposures in the areas of the smelter and calciner may be reduced by careful planning and design (see p 10-14 and 10-17). The proponent should state whether or not the exposure will be reduced and by what means.
The EIS should outline all the procedures for reducing radiation exposures in the areas of the current smelter and calciner and the planned smelter and calciner.
In Figure 10.16 the Annual Dose axis has a rate of increase of 0.76 mSv, therefore the value of 0.5 should read 0.05.
Data should be checked to make sure it is presented correctly.
It is in the interests of the nuclear industry to play down the risks associated with the industry. The asbestos industry similarly played down the risks of asbestos and at regular intervals quoted studies supporting its position (the smoking industry has used similar tactics). The fact that the proponent can selectively quote research which supports its non-linear dose-risk hypothesis (p 10-22) is therefore not without precedent. It is a different matter, however, for the proponent to convince the international radiological protection community of the validity of this hypothesis. So far, despite the resources available to it, the nuclear industry has been unsuccessful.
The EIS does not estimate the health effects for various exposed groups but gives rather abstract information on the risk of death at various ages (p 10-23). The information given in the EIS is inadequate and misleading.
More useful data is given by Worksafe Australia (Uranium Mining and Milling in Australia, Vol. 2 - Research Papers p 69, Canberra, 1997) who calculate the expected excess lung cancers, fatal solid cancers and fatal leukemias for a 47 year working life. For example, for 371 miners at Olympic Dam for an average of 4.4 mSv per year alpha radiation, :
For the expanded operation covered by the EIS, the above figures suggest that excess fatal cancers in the workforce at Roxby Downs will be of the order of 10.the excess lung cancers is estimated to be 3; using conservative ICRP risk estimates, the excess solid cancers is estimated to be 2 and excess fatal leukemias are estimated to be 0.1.
Bearing in mind that the Worksafe data can be considered to be conservative (with some researchers suggesting even higher risk rates from low level radiation), that the assessed risk to ionising radiation are constantly being increased, and the mine is expected to be in operation for much longer than 47 years, then the number of excess fatal cancers in the workforce may well be of the order of 100.
The calculations from Worksafe were available to the proponent in February 1997 and should have been included in the EIS.
The EIS should include estimates, using the best available data and information, of the excess cancers which are predicted to arise from exposure to ionising radiation. These estimates should include various scenarios, eg. a doubling of the assessed risk every 12 years.
Scenarios based on models of higher risk levels which are suggested in current research should also be provided.
It is stated that people living in the vicinity of Olympic Dam do not eat the indigenous plants and animals (p 10-26) and therefore these do not contribute to radiation doses. Bearing in mind that indigenous plants and animals were eaten in the past, then what evidence is there for the contention that they are not eaten at the moment, or that they will not be eaten during the period this mine and its products and wastes affect the region. Given the long term nature of the tailings radioactive waste the it is a nonsense to assume that native plants and animals from the area will not be eaten.The long term nature of the tailings radioactive waste creates a pollution problem for food substances from the area.
The EIS should substantiate its claim that native plants and animals not being eaten by people over the period covered by the EIS and in fact for the lifetime of the tailings waste.
Figure 10.22 is labelled as showing uranium concentrations but the units suggest that it is a rate of uranium deposition per square meter.
Presumably the values given are averages, but no information is given as to how the average was obtained. Is it an average over all directions? Is it an average over a year?
Information about averaging processes in regard to uranium concentrations in dust and deposition rates presented in EIS is poor. It should be clarified and include parameters of time, direction and distance.
Information such as that given in Figure 10.22 should include relevant baseline (pre-exploration) data.
The EIS should compare any calculated current values with baseline (pre-exploration) data.
Figure 10.23 is described as a rate but shows the amount of dust deposited per square meter. The correct units are mg.m-2.yr-1.
Figure 10.23 is predictable confusing and uninformative. A more useful graph is one which compares downwind with upwind from the mining site.
The statement that "annual changes in dust deposition rates do not appear to be a result of operational factors." (p 10-29) is therefore invalid.
The EIS should pay more attention to presenting data in a way which will enable contributions due to the project to be detected.
The statement that "annual changes in dust deposition rates do not appear to be a result of operational factors." (p 10-29) should be deleted.
Figure 10.24 is claimed to show the concentration of uranium in dust. It is not clear, however, whether it actually shows concentration of dust uranium in the air. Does the Figure 10.24 refer to the amount of uranium per cubic meter of air?Information presented in Figure 10.24 is confusing and inconsistent with other claims in the EIS.
It is claimed that the influence of the mine on dust "becomes undetectable beyond a distance of approximately 5 km". (p 10-31), but Figure 10.24 shows uranium dust concentrations as being about 30 times background at a distance of 7 km. from the operation.
Inconsistencies in the EIS regarding the effects of the operations on dust need to be clarified.
Figure 10.28 needs to specify the time of year and the year in which the measurements were made.
Figure 10.29 does not state the direction, or whether it is an average over all directions. In order to detect differences due to mining operations, downwind measurements should be compared with upwind, rather than all directions (p 10-34). Predictably, comparisons with all directions makes it more difficult to detect the influence of the mining operations.
The data in table 10.6 does not include a measure of the spread and uncertainty of the data.
All data should include background references, and measures of spread and uncertainty.
The radiation dose data presented in Figure 10.30 is inconsistent with that presented in Table 10.6. The data differs by an order of ten.
Data should be checked to make sure it is presented correctly.
Because no measure the reliability of the data is given in relation to dose data, the claim that radiation dose does not correlate with the mine production (p 10-35) is invalid. The correct conclusion is that the data is incapable of showing any correlation.
The claim that the radiation dose is not correlated with the mine production (p 10-35) should be deleted.
Figure 10.32 and 10.33 do not specify the year at which operations are said to have commenced or how the "pre-operational mean' was determined. Bearing in mind that there was considerable activity on the site, including exploratory drill holes, the Whenan shaft (1980), and a pilot processing plant (1984) before "production" is said to have commenced (1988), then the year to which these quantities refer is very important.
The year and method of determination of the so-called "background" and "pre-operational" uranium concentration levels should be included in the EIS.
The peak in the uranium concentration in the Axehead Dam is some 12 months after the concentration peak at the Olympic Dam. no explanation is given fir this difference.
The EIS should discuss the difference in time between peak uranium concentrations at the Axehead and Olympic Dams. The difference should be discussed in terms of mining activity, weather and the leak in the tailings retention system.
The EIS refers to difficulties in radiochemical analysis (p 10-38) but gives no measure of the effect of such difficulties on the uncertainty of the data.
Table 10.8 gives seemingly accurate data (sometimes to three significant figures) but gives no measure of the uncertainty in the data.
No measure of the uncertainty of the data is given in Figure 10.34 and 10.35.
Measures of uncertainty in data should be provided.
By analogy to asbestos, with a material as dangerous as radioactive material, dispersion should not be acceptable management (Table 10.9). Dispersal is at odds with the more rigorous principle of isolation and containment.
The dispersal principle should be deleted from Table 10.9 and should not be allowed as a management practice.
The EIS uses the 1987 Commonwealth Code of Practice on Radiation Protection in the Mining and Milling of Radioactive Ores to define non-designated employees as those whose annual radiation dose rate is unlikely to exceed 5 mSv/a. This level is inconsistent with the 1990 recommendations of the ICRP which found that ionising radiation is 4-5 times more dangerous than when the 1987 Code was proclaimed.
The definition of non-designated employees should be those whose annual radiation dose is unlikely to exceed 1 mSv/a.
Clause 34 of the Indenture contains a 'non-discrimination' clause, which prevents the state government from imposing on the joint ventures virtually any condition they deem unfair , including environmental requirements or radiation protection other than those specified in clause 10 of the Indenture (clause 10 states the project has to comply with the Codes of Practice on Radiation Protection in the Mining and Milling of Radioactive Ores, other Commonwealth government and IAEA codes of practice, and NHMRC and ICRP codes). The government is thus effectively prohibited from imposing more stringent standards from bodies such as the US Environmental Protection Agency, the Nuclear Regulatory Commission and Britain's National Radiation Protection Board and is also forbidden from varying the clauses of the Indenture.
The EIS should comment on all aspects of the Roxby Downs (Indenture Ratification) (Amendment of Indenture) Amendment Act 1996 which impinge on the EIS. Including discussion on any restrictions on standards that Governments can impose in relation to environmental requirements and radiation protection.
The section on "Radiation safety: Management structure" (p 10-45), refers only to the number of people in the Radiation, Environment, Safety and Quality Department, and does not give the number of people employed full time on radiation safety.
The EIS should give the number of people employed full time by the proponent on radiation safety.
CHAPTER 11. PROJECT INFRASTRUCTURE AND THE TOWNSHIP
It is noted that the EIS states "the levels of total dissolved solids in the untreated Great Artesian Basin water are too high for potable use, and therefore potable water is provided at the plant and Roxby Downs using a reverse osmosis desalination plant."There are inconsistencies with the description that water from the local aquifer is too saline to be of use, yet saline water from the Great Artesian Basin can be made useful using a reverse osmosis process.
This contrasts with earlier statements about groundwater around the project site (p 11-1). This saline groundwater is also not potable, but the proponent then goes on to say that it is useless.
The EIS should explain why saline water from the Great Artesian Basin can be made useful using a reverse osmosis process but the local saline groundwater cannot be made useful using the same technology.
CHAPTER 12. SOCIAL ENVIRONMENT
Chapter 12 of the EIS contains material which relate to the 1983 EIS. This material should not be presented in this section (see comments elsewhere in this submission especially the Introduction and under Chapters 1 and 13).Information not relevant to the EIS is presented.
Material relating to production up to 150,000 tpa is not relevant to the environmental assessment of the Expansion Project and serves only to inflate perceptions of the importance of the Expansion Project.
Information relating to production up to 150,000 tpa is not relevant to this EIS and should be deleted from this section.
Current actual workforce levels are lower than those predicted in the 1983 EIS . Indeed, as stated (p 12-8), the 1983 EIS predicted higher workforce levels those now projected for production up to 150,000 tpa. This is ascribed to technological improvements. No comparative figures are given. According to estimates made in the EIS, the 1983 EIS overestimated the workforce by about 1300, or about double the value now predicted.
As will be shown in the section of this submission on Chapter 13, these errors are not unique. Assuming that the proponents did not deliberately overestimate the economic impact, then these errors cast considerable doubt on the expertise of the proponents. The 1983 EIS was prepared by the predecessors (WMC, BP and Kinhill-Stearn Roger) of those who prepared the current EIS.
Furthermore, there is no evidence in this EIS that technological improvements have been taken into account in predicting the workforce requirements for production above 150,000 tpa.
Given differences between employment levels predicted in the 1983 EIS, those actually realised, and the levels predicted in this EIS here need greater examination of the model used in this EIS is required.
The EIS should give direct comparisons between the estimates of workforce levels made in the 1983 EIS, the actual results in 1997 and the current projections for 150,000 tpa.
In relation to predictions of workforce requirements, the EIS should describe what, if any, allowance has been made for technological improvements.
Why are only three examples of induced local employment been given (Table 12.7)? Are these representative or highly selective values?
The proponents should state whether the examples given in table 12.7 are representative and they should give a reference for a more comprehensive listing.
CHAPTER 13. ECONOMIC IMPACTS
Under the Indenture unlike other mining projects- royalties will be paid on the companies profit after the ore has been sold at 2.5 percent for the first five years and 3.5 percent thereafter. There is no guarantee the state will receive any return on its investment, especially when royalties will only be paid when the project has been running at 85 percent of its full design capacity for sixty consecutive days. Very few mining projects do that and the project could literally run for years without paying a cent because it didn't quite manage to meet the required running capacity. For example maintenance shutdowns, industrial action or cynical business decisions could legally prevent the state from receiving hundreds of millions of dollars.Economic benefit to the State is not assured as royalties are dependant on ore sales. Economic benefits to the State and in particular the Northern District are not proven in the EIS The benefits outlined in the Chapter appear to be more propaganda than realistic analysis.
It is noted that the Expansion Project will have negative effects on the agriculture sector (Tables 13.7 and 13.8) during both the construction and production phases.
It is noted that the construction phase of the Expansion Project leads to a large balance of trade deficit which will take up to 81/2 years of production to rectify (13-11).
The statement 'The injection of more direct employment, and its flow-on effects, into the Northern Statistical Division could compensate for losses in population and employment experienced in recent years' is so vague as to have only propaganda value.
It is obvious from the proponents own data (Tables 13.3 and 13.4) that the mine at Roxby downs has had no perceptible beneficial effects on SA and particularly not on the Northern Division.
Furthermore the proponent admits that they are unable to demonstrate with their economic model any beneficial effects on employment in the Northern Division (p 13-3).
Paragraph 3, the first sentence in paragraph 4 and the first two sentences of paragraph 5 on p 13-3 (and going over onto p 13-4) should be deleted.
Some language used in the Chapter is vague, subjective, contains meaningless provisos or soft promises, such the terms, 'as far as reasonably practicable' and 'encouraged', used in the second paragraph on p 13-4.
Vague and/or subjective language, meaningless provisos and soft promises should be removed from the text.
As stated in the Introduction the emphasis in the economic analysis is on Phase 1 as defined by the proponent. But the major part (85,000 tpa to 150,000 tpa) of Phase 1 has nothing to do with this EIS. Only a minor part of Phase 1 (150,000 tpa to 200,000 tpa) is relevant to this EIS and this part is not separately considered in the economic assessment.
Most of the construction work up to 200,000 tpa does not apply to this EIS but to the 1983 EIS (85,000 tpa to 150,000 tpa). Construction started in early 1997 and is expected to take two years (p 13-5). The EIS is therefore seriously misleading. It gives the impression that some 1,350 construction jobs and up to 5,500 jobs in Australia will be created by the phase 150,000 tpa to 200,000 tpa of the Expansion Project (p 13-9), whereas very few if any jobs will result from the construction needed for the 150,000 tpa to 2000,000 tpa expansion. The economic impact assessment presented in this EIS is therefore largely irrelevant and exaggerates the so-called benefits attributed to the Expansion Project.
The economic modelling of the Expansion Project should be carried out for the production from 150,000 tpa to 200,000 tpa and all reference to production from 85,000 tpa to 150,000 tpa should be deleted.
Investment and employment levels for the stage 85,000 tpa to 150,000 tpa (p 13-7) should not be included.
It is stated that '...the economic impacts of the first expansion phase are estimated by comparing expenditure and output of the expansion modelled against a base-case of 1996-97'. This tends to give both a qualitative and quantitative erroneous assessment of the economic impact. FoE example, a 'typical year' at full production (200,000 tpa) is compared with a base-case of 1996-97 (p 13-10). Since the Expansion Project involves production from 150,000 tpa then the base-case should be 150,000 tpa and not the 1996-7 production which was 85,000 tpa.
The economic impacts discussed in the EIS should use 150,000 tpa as the base-case.
The modelling results for the expansion from 200,000 tpa to 350,000 tpa are irrelevant because the WMC Board has not yet decided to go ahead with this expansion. There is no 200,000 tpa - 350,000 tpa project and therefore there should be no environmental assessment of this expansion.
All reference to the expansion from 200,000 tpa to 350,000 tpa should be deleted from the EIS.
What little economic analysis that has been done is based on a highly suspect computer model. It is noteworthy that the model is not validated by applying it to the current level (85,000 tpa) of production. A cursory inspection of the 1983 EIS indicated that the economic analysis for the initial project was highly erroneous, erring on the side of exaggerating the perceived benefits, sometimes by as much as a factor of 2.
Roxby has been promoted as an economic bonanza for the depressed State economy . However, uranium production has been cut to 1900 tonnes a year from an original forecast of 3000 tonnes per year. Similarly, job forecasts have been revised downwards from 5000 direct jobs in 1979 to 2430 in 1982 and 2380 in 1988.
The EIS should address the inconsistencies in production rates and employment levels between those forecast in the original, early 1980's, documentation, including the 1983 EIS, and those rates and levels that were eventually realised. The models and predictions supplied in this EIS should incorporate these realised trends in rates and levels, and figures should be presented based on this analysis.
Data supplied in the Chapter is inconsistent, for example, there is only a 20% increase in jobs predicted for the 135% increase in production from 85,000 tpa to 200,000 tpa yet there is a predicted 45% increase in jobs for the 75% increase in production from 200,000 tpa to 350,000 tpa (p 13-12). This of added relevance given that improved technologies over the time period of these expansions could be expected to result in lower employment rates during the 200,000 tpa to 350,000 tpa phase compared to the 85,000 tpa to 200,000 tpa phase.
By presenting irrelevant, misleading and/or inconsistent information and failing to provide a valid economic impact assessment of the project, the EIS does not meet its Terms of Reference. This is damning considering the emphasis given by both the proponent and the State Government to the supposed economic benefits of the project.
The EIS should contain evidence of the validity of the economic model, in particular it should be applied to the current level of activity (85,000 tpa) at Olympic Dam and the predictions compared to empirical data. If such a test cannot be carried out then the entire Economic Impact section of the EIS should be deleted.
The impacts on public revenue (p 13-6) discuss only the benefits, no mention is made of the costs involved through resources in various government departments (Housing and Urban Development, Environment, Health, Mines and Energy) which are devoted to the project. Nor does it include costs incurred by governments in relation to safeguarding project uranium against use in nuclear weapons. This is failure to meet the Terms of Reference of the EIS.
The impacts on public revenue should include all costs incurred by government departments and agencies as a result of the project.
Calculation of the impact on the public Service Borrowing Requirement (PSBR) mentions only revenue such as royalties and payroll tax (p 13-11) and appears to ignore costs incurred by government departments and agencies.
The impact of the project on the Public Service Borrowing Requirement should include costs incurred by government departments and agencies.
The sensitivity of the results of the model used in the EIS in regard to the values of the parameters used, is not reported and presumably was not carried out.
The modelling results should include a sensitivity analysis covering reasonable variations of all key parameters.
The economic modelling assumes that all product is exported (p 13-11) whereas Table 13.5 suggests that of current annual sales of $350 million, only $270 million (or 77%) is exported.
The assumption that all product is exported should be replaced by a more realistic assumption, eg 77% of product is exported.
CHAPTER 14. REHABILITATION AND DECOMMISSIONING
No mention is made of the financial arrangements which will ensure that full rehabilitation is carried out if the project should be abruptly cancelled or if WMC becomes financially insolvent.Financial arrangements for rehabilitation are nor ensured.
The EIS should include financial arrangements that ensure full rehabilitation irrespective of the future of the project or the mining company.
The EIS has sections on existing rehabilitation procedures and constraints and states that final rehabilitation procedures and completion criteria would be included in a decommissioning plan that would be submitted to the South Australian Government (p 14-3).
Given that the project has an indefinite lifetime and no commitment to an expansion beyond 200,000 tpa has been given, then it would be prudent to include final rehabilitation and decommissioning plans assuming completion of production in the year 2020. Such plans should be updated as necessary.
The EIS should contain final rehabilitation and decommissioning plans based on a project lifetime of 20 years.
The fact that the tailings are acidic is referred to as a rehabilitation constraint (p 14-3). Neutralisation of tailings, however, is a very simple process, which should be known to the proponents.
Reference to the acidic nature of the tailings in paragraph 3, p 14-3 should be deleted.
The last three paragraphs of "Section 14.3: Rehabilitation Constraints" have nothing to do with constraints to rehabilitation and should be deleted or relocated to an appropriate section.
The last three paragraphs of section 14.3 have nothing to do with constraints to rehabilitation and should be deleted.
CHAPTER 15. MANAGEMENT AND MONITORING - ENVIRONMENT AND WORKPLACE
Under the heading of "Greenhouse gas emissions" in Table 15.7, there is no mention of renewable energy.Table 15.7 should contain information about use of renewable energy.
The EIS should address the question of reducing greenhouse gas emissions through the use of renewable energy sources such as solar hot water, solar process heat, photovoltaics and wind energy.
The Table 15.8, under Section 8.10, it is stated that "permanent marker' will be erected on the tailings storage facility. Permanent could be construed as meaning "forever" or at least as long as needed, which in this case means thousands of years. Of what material would the "permanent markers" be constructed?
The EIS should more adequately describe the nature of the "permanent markers" to be erected on the tailings retention system (Table 15.8 Section 8.10).
PUBLIC ACCOUNTABILITY
WMC have a veto over public release of any information relating to the Olympic Dam Operation. The Clause 35 of the Indenture provides for a right to both WMC and the SA Government to refuse public disclosure of information unless both parties pursuant to the agree to its release. This can apply to environmental monitoring or occupational health and safety information, and to information from Government on the performance and legal compliances of WMC. The Roxby uranium mine can not be said to be publicly accountable while such legal privilege remains. In late 1996 the Act was amended, however this privilege was retained.Review of the confidentiality powers conferred to WMC and the South Australian Government Issues of public accountability in regard to impacts, including potential impacts, of the Olympic Dam Project on environmental, social and economic sectors.
The EIS should include an assessment of the confidentiality powers have been used to date, and include a full list of occasions, topics and information withheld or sought to be withheld by either WMC of the State Government. An assessment of the influence of the confidentiality powers on full disclosure and public accountability over the life of the operations of the mine should be included.
The clause 13(1) of the Indenture requires WMC to provide the Minister for the Environment with a 10 year projected schedule of water requirements. This was to have occurred in January 1993, and appears to be the decision process regarding Borefield B, however this schedule has not been made public.
Legal privilege granted to WMC under Clause 13 of the Act places an obligation on the State to facilitate WMC access to artesian water to satisfy the mine water requirements, to grant them Special Water Licenses, and to supply that water free of any charge in respect of the development of or use of any of the water sources or borefields (wellfield and borefield are interchangeable terms). When taking into account the amendments to the Act in 1996 placing obligations on the State regarding the expansion of the mine (obligations made prior to outcomes of the Commonwealth ordered EIS), the effect of these legal 'rights' are that WMC can extract up to 42 million litres of fossil water each day every day for the next 40 years. Legal rights to WMC under the Act take precedence over regulatory arrangements to manage environmental impacts of the mine, the Great Artesian Basin and the Mound Springs are only secondary considerations.
In the process of granting procedural approvals to Borefield B the Environment Impact Assessment Branch of the Department of Housing and Urban Development released a report on 21/8/95, the: "Survey and Assessment Report, Supplementary Environmental Studies, Borefield B Development" Kinhill Engineers Pty Ltd for the Copper Uranium Division, WMC (Olympic Dam Operations) Pty Ltd. Submissions to the department closed on the 29/9/95.
The Report contains very little coverage of the legal aspects of the proposal other than to say that "WMC would negotiate rights for the required Borefield and pipeline easements in accordance with the requirements of Clause 13 of the Indenture" (p.i). The original 1983 EIS had considered expansion of the water supply for Roxby, to allow for expansion of production of copper and 'associated products' up to 150,000 tons per annum. However only a conditional approval was granted to proceed with the Borefield development, the EIS did not grant approval for the locations of Borefield B, or of the pipeline corridor between Borefield A and Borefield B (Assessment of the Environmental Impact of the Olympic Dam Project, DEP Nov. 1983 p.89).
The report based its 'assessment' of impacts on the GAB and on the Mound Springs from the expanded water usage by WMC on a 20 year model projection of impacts. However MESA had available to them 2 documents, which they acknowledged in a response to an FOI request on 13 September 1996 as not being publicly available documents. These are :
"Hydrogeological investigation and numerical modeling, Lake Eyre Region, Great Artesian Basin" by WMC in August 1995 that predicted % flow losses for Mound springs up to the year 2021, and "A working document consisting predominantly of computer generated plots of drawdown and recovery predicted to result from 50 years of pumping" produced by MESA.These longer term projected impacts of Borefield B were not made public.
Late in 1996 legal obligations were placed on the State to facilitate WMC access to water for the next 40 years, again, without public release of this information.
The potential impact of the Roxby uranium mine on the GAB and on the Mound Springs is not subject to public scrutiny.
The EIS should review the confidentiality powers granted to WMC and the South Australian Government. Including the an assessment of the confidentiality powers on full disclosure and public accountability over the life of the operation.
The EIS should address the issue of public accountability in regard to impacts, including potential impacts, of the Olympic Dam Operation on environmental, social, and economic sectors, for example, the effects on the Great Artesian Basin and Mound Springs.
The findings of the ERDC inquiry acknowledged that the Roxby operations needed to be 'more open to public scrutiny' (ERDC p.9). The EIS does not adequately outline how this recommendation is to be met, particularly in regard to public access to information and stakeholder consultation processes.Implementation of the ERDC call for Olympic Dam Operation to be 'more open to public scrutiny'.
The EIS should describe how WMC intend to implement the ERDC advice that the Olympic Dam Operation be 'more open to public scrutiny'.
REFERENCES
Berry, K A & Armstrong, D, 1995, "Hydrogeological Investigation and Numerical Modelling Lake Eyre Region, Great Artesian Basin", Western Mining Corporation Ltd., Exploration Division - Minerals, HYD T004.
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