INTRODUCTION & GENERAL COMMENTS

Overall, the Roxby Action Collective (RAC) believes the EIS to fall short of fulfilling both the detail and spirit of the original guidelines issued jointly by the Commonwealth Environment Department, Environment Australia, and the South Australian Department of Housing and Urban Development.

The EIS is poorly written with many critical assumptions and detail regarding assessments of the tailings, uranium markets, Mound Springs, effects of radiation, economic impacts and so on, are not clearly articulated or at worst omitted entirely.

We believe that this has prevented the public from properly assessing the long term environmental, social and economic impacts of Olympic Dam. RAC will comment on these specific issues raised in the EIS.


1) ENVIRONMENTAL POLICY COMMITMENT

WMC has a broad ranging Environment Policy which covers it's ongoing operations, including Olympic Dam (known also as Roxby Downs). One of the key principles of this policy is to "Conserve important populations of flora and fauna that may be affected by our activities".

However, it is pointed out in the EIS in Table 7.18 that there has been "Total loss of endemic fauna" or "decline in all endemic fauna". This is clearly not conserving important populations of flora and fauna and thus the commitment of Olympic Dam to this policy must be held up in question. Reductions of spring flows are predicted in the long term, and one can only conclude that this situation has little hope of being reversed unless immediate remedial action is undertaken in the Borefield A area.


2) URANIUM SUPPLY AND DEMAND

The section dealing with the global supply and demand of uranium is from a single source only, the Uranium Institute (London). RAC believes that such an assessment lacks independence and therefore much credibility. It fails to point out that the spot price of uranium has been consistently falling since late last year when military stocks of nuclear materials entered the market. With the price falling to new all time lows, the viability of uranium production must be taken into account, yet there is no discussion of these issues in the EIS.


3) GREAT ARTESIAN BASIN & THE BOREFIELDS

One of the key assumptions used in the assessment of impacts on the Mound Springs is that the Great Artesian Basin (GAB) as a whole system, which encompasses much of Queensland and New South Wales and parts of the Northern Territory, is in hydrogeologic equilibrium. It is also argued that the portion of the GAB in South Australia is in hydrogeologic equilibrium. That is, the inflow of groundwater is approximately equal to the total discharge via artificial bores, vertical leakage to the regional water table and spring flow.

The data presented in the EIS currently shows a figure of 425 ML/day for inflow (calculated from pressure levels in bores in the north-eastern section of the GAB in SA) and total discharge rates adding to 425 ML/day. If these figures are justifiable, then the assumption of equilibrium would appear to be valid. However, it is not pointed out in the EIS that the figure for vertical leakage is not based on any field hydrogeologic data, only as the difference between calculated inflow rates and known discharge rates (measured pastoral bore flows, artificial extraction by ODO and Santos, spring flows).

Further, when the expanded levels of extraction from the Borefields are presented, the total discharge significantly exceeds the estimated inflow - initially to 444 ML/day and then to 452 ML/day.

Detailed research by Keane (1997) on a water balance of the GAB as a whole, the SA portion of the GAB and impacts on the Mound Springs has clearly shown that estimates of the different components of the water balance have been decreasing since European exploitation of the GAB began late last century. The numerous published data show decreasing rates of spring flow, vertical leakage and pastoral bore flows, while in the last two decades since the arrival of Olympic Dam and Santos the artificial extraction has been steadily increasing.

It is also argued in the EIS that water can be strategically harvested by careful location of the new borefield to capture water that would otherwise be lost to the regional water table and evaporation. However, the proportion of water lost to vertical leakage and then evaporation is only relevant in the shallow margins of the basin, not in the deeper more productive parts of the basin where Borefield B is (and presumably Borefield C will be) located (Woods, 1990). Also, it is not mentioned in the EIS that as the borefields begin to increase their extraction, not only will lower artesian pressures lead to lower quantities of vertical leakage, but also lower artesian pressures for other hydrogeologic components such as pastoral bore flow and spring flow.

Habermehl (1980) argued that the GAB was in approximate equilibrium, but did warn against large scale exploitation saying that "provided that no new major developments occur which will affect this situation, discharge and potentials will not change significantly". Large scale development has occurred in a concentrated area of the South Australian portion of the GAB and essentially this important advice of 1980 is being ignored and the springs are now experiencing reduced flows, a pattern which is predicted to continue.

The data presented in the EIS and the work of Keane (1997) show that the assumption of equilibrium is fundamentally incorrect and unjustifiable in future hydrogeologic assessments.

It is also unclear to what extent the numerical computer model incorporates the whole SA portion of the GAB, the whole GAB or a small subsection. No information is given at all in the EIS concerning ODEX1 thereby denying the public the chance to properly assess this section of the EIS.

The EIS also repeatedly refers to a new Borefield, presumably called Borefield C, but fails to include studies showing the likely location and extraction rates. This is of fundamental importance to the overall hydrogeological impacts on the Mound Springs and the Great Artesian Basin generally. Such a borefield would need to be located even further into the GAB if long term drawdown limits set in Special Water Licence 2 and more severe impacts on the Mound Springs are to be avoided.

There is no discussion of alternative strategies for process and potable water supply.

Also, it is argued that the Bore Rehabilitation being undertaken by the SA Dept. of Mines and Energy, is leading to considerable savings of artesian water due to capping of uncontrolled bores and water efficiency schemes. However, it should be noted that there is only one uncontrolled bore in the vicinity of the Borefields and very few bores that have required rehabilitation in this area generally (Sampson, 1996).

Such a poor assessment does not add much faith to the assertions that, despite the sustainable supply of water being recognised as one of the three principal issues raised by the Expansion Project, the long term supply of water from the borefields in the GAB are indeed sustainable.

The EIS is fundamentally flawed in it's assessment of the hydrogeological impacts on the Great Artesian Basin and the ecologically unique Mound Springs. Olympic Dam must make public the results of it's 50 year modelling predictions and immediately begin investigations for Borefield C.


4) TAILINGS RETENTION SYSTEM SEEPAGE INQUIRY

The EIS presents an overly positive view of the SA Parliamentary Inquiry into the massive seepage from the Tailings Retention System (TRS), despite that report making some highly critical comments about operations at Olympic Dam and design faults in the TRS as it was finally built.

For example :

page 63 - "The Committee finds that there were deficiencies in the monitoring and reporting systems in place at Olympic Dam...."

page 73 - "The Committee finds 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."

page 87 - "The Committee finds that, 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."

page 87 - "The Committee finds 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."

page 87 - "The Committee finds that it was only when the leakage was too big to ignore or to 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 original defective design concept."

page 87 - "The Committee finds that the monitoring systems designed in part to detect leakage from the Olympic Dam tailings retention system were defective...."


5) WATER COSTS

ODO argue that since they pay for all of their own water supply infrastructure costs they should not pay for their profligate use of Great Artesian Basin groundwater, water which has been dated to nearly two million years old in the area of the Borefields and Lake Eyre (Torgersen et al., 1991, Bentley et al., 1986, Sibenaler, 1996).

Such an argument is illogical given that consumers across Australia not only pay for infrastructure costs associated with their water supply, but also for their use of that water.

Using the figure of $0.88/kl from the EIS, which residents of Roxby Downs are charged for their water, and the current mine usage of 13.5 ML/day, the foregone cost of this water amounts to $4.34 million - a substantial sum of money indeed.

Pastoralists in the region are charged for their use of GAB water. Given the tremendous monetary value of the water usage by Olympic Dam, it is unreasonable to avoid the issue of paying for the water any longer.


6) MOUND SPRINGS

There has already been devastating impacts on the unique Mound Springs in the Lake Eyre region directly attributable to Borefield A. Hence Borefield B was moved further into the GAB where impacts on the springs would be less severe.

However, even with reduced extraction from Borefield A and the new location of Borefield B, the long term predictions for flow rates from the majority of springs, relative to 1996 levels only, actually show declining flows (cf. Figures 4-14 to 4-17). There is no data on pre-borefield flows presented for comparison and thus an overall assessment is not possible.

Berry & Armstrong (1995) investigated the recovery of the springs in the region directly surrounding Borefield A if this was decommissioned. It still showed decreasing flows at the most significant springs.

The springs are true ecological treasures as well as being important mythological and cultural sites for the region's traditional owners. These points are recognised in the EIS (cf. sections 7.4.1 & 6.3.2) but still the EIS has the underlying assumption that flow reductions are an acceptable trade-off for the ongoing development and operation of the Olympic Dam Project.

The Roxby Action Collective are firmly opposed to this view and believe that radical measures must be taken to prevent further damage to the heritage and environmental values of the springs.

We therefore call for the unequivocal closure of Borefield A and immediate commencement of studies for the new Borefield C, deeper still into the Great Artesian Basin than the newly commissioned Borefield B. This is the only way to work towards the long term protection of the springs and the fragile arid lands ecosystems and wetlands they support.


7) PROJECTED WATER DEMAND FOR THE EXPANSION PROJECT

Since the studies of Borefield C were not included in the EIS, there is a significant discrepancy between the projected water demand for the 350,000 t/a level of production and the required supply of water. Based on figures in the EIS (which are conveniently in different sections), the use of water will be of the order of 1.570 kl/t or reduced to 1.24 kl/t and expanded production levels up to 17 Mt/a, giving water demands of the order of 58 to 75 ML/day.

The borefields have only been assessed to 42 ML/day, and thus it is impossible to determine the likely long term impacts on the Great Artesian Basin and Mound Springs.

This is a significant shortcoming, and as such shows that the EIS fails to address one of the three principal issues raised by the Expansion Project.


8) LAND USE

The EIS recognises that the Mound Springs are a viable tourism attraction with unique opportunities for the public to learn about arid land ecosystems, the Great Artesian Basin, and the extensive Aboriginal and European heritage of the area.

Fundamental to the success of this tourism is the long term viability of the springs and their associated wetlands ecosystems. Given the dramatic impacts already seen in the vicinity of Borefield A, and the predictions of further impacts in the long term from Borefield B, one must seriously question the assertion in the EIS that there will be no direct impacts on other legitimate land uses in the region.


9) TAILINGS RETENTION SYSTEM

As with the majority of the EIS, this section departs from the guidelines and fails to explicitly state the numerous assumptions used and the uncertainties involved in any data presented.

There is no discussion of the long term (of the order of tens of thousands of years) seismic stability of the tailings; nor of the long term moisture covering the tailings to prevent radon release; nor of the geotechnical properties of the various materials used in construction of the tailings; nor of the long term climatic influences on the radiological and physical stability of the tailings; etc.

Perhaps the most telling failure in this section is that Olympic Dam have only designed the TRS for a design life of 200 years and a structural life of 1,000 years. This is despite the Uranium Decay Series (Figure 2.17) showing the effective half-life of some of the radionuclides will be present in the tailings for tens of thousands of years. This is most likely due to the fact that it is impossible to engineer a system which will have to perform on a time scale far longer than recorded human history!

This situation is not acceptable.


10) MISCELLANEOUS COMMENTS

The radiation section of the EIS clearly fails to recognise critically important scientific studies that have been done on the long term health effects of low levels of exposure to ionising radiation, such as those experienced by workers at Olympic Dam. Please refer to the Reference list for full details.

For example, from Kohnlein (1997) (part of the FoE Australia Submission; http://www.foe.arc.net.au/kohnlein2.html) :

"Nevertheless, arguing from scientific facts and independent epidemiological studies clearly show that the repair systems of the mammalian cell is never 100% exact and that there is no harmless dose threshold. That this has still not been accepted by most national and international commissions suggests that official estimates are no longer a scientific process but rather a political one."

These studies, by Kohnlein, Nussbaum, and others, have shown that low doses of ionising radiation are more harmful than currently thought and existing standards need to be further lowered to adequately protect workers and the general public from unwanted and un-necessary risk.


11) CONCLUSIONS & RECOMMENDATIONS

The main findings of this submission can be summarised as follows :

The EIS fails to conform to the guidelines and as such does not represent a satisfactory assessment of the proposed Olympic Dam Expansion Project.

The EIS contains many factual errors in data and does not explicitly quote the assumptions used for the EIS.

Impacts on the ecological values and integrity of the Mound Springs have been unacceptable. Borefield A must close immediately and detailed strategic studies begin for a new Borefield C located even deeper into the Great Artesian Basin than the current Borefield B.

Studies for long term alternative sources of water should also be instigated in order to relieve pressure on the Great Artesian Basin.

That Olympic Dam be charged for their use of ancient fossil water from the Great Artesian Basin.

That Olympic Dam be forced to accept responsibility for the long term management of the tailings, well beyond the current design life of 200 years and structural life of 1,000 years.

BEIR V. National research council. Health effects of exposure to low levels of ionising radiation. Washington, DC: National Academy Press 1990.

Bentley, H W, Phillips, F M, Davies, S N, Habermehl, M A, Airey, P L, Calf, G E, Elmore, D, Gove, H E & Torgersen, T, 1986, "Chlorine-36 Dating of Very Old Groundwater 1 - The Great Artesian Basin, Australia", Water Resources Research, Vol. 22 No. 13, pages 1991-2001.

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.

Cardis E, Gilbert ES, Carpenter L. et al. Direct estimates of cancer mortality due to low doses of ionising radiation; an international study. Lancet 344,1039 - 1043,1994.

Geiger JH, Rush D, Michaels D, Baker DB, Cobb J, Fischer E, Goldstein A, Kahn HS, Kirsch JL, Landrigan PJ, Mauss E und Mclean DE: Dead reckoning: A critical review of the Department of Energy's Epidemiological research. Washington DC: Physicians for Social Responsibility 1992.

Goldman M. Cancer risk of low-level exposure, Science 271 1821 - 1822,1996.

Habermehl, M A, 1980, "The Great Artesian Basin", BMR J Aust. Geo. and Geophys., Vol. 5, pages 9-38.

Keane, D, 1997, "The Sustainability of Use of Groundwater from the Great Artesian Basin, with Particular Reference to the South-Western Edge of the Basin and Impact on the Mound Springs", Environmental Engineering Final Year Investigation Project, RMIT, Melbourne.

Nussbaum RH, Koehnlein W, Belsey E. Die neueste Krebsstatistik der Hiroshima-Nagasaki-Ueberleben- den, Med. Kiln. 86,90 - 108,1991.

Nussbaum RH, Koehnlein W. Inconsistencies and open questions regarding low-dose health effects of ionising radiation, Environ. Health Persp. 102,656-667,1994.

Nussbaum RH Koehnlein W. Health consequences of exposures to ionising radiation from external and internal sources: challenges to radiation protection standards and biomedical research, Medicine & Global Survival 2,198 - 213,1995.

Woods, P H, 1990, Evaporative Discharge of Groundwater From the Margin of the Great Artesian Basin Near Lake Eyre, South Australia, PhD Thesis, School of Earth Sciences, Flinders Uni.