Submission on the ERMP – Wiluna Uranium Project – Toro Energy
THE SCOPE OF THIS ASSESSMENT IS INADEQUATE. My reasons for this contention are as follow.
THIS ASSESSMENT DOESN’T DEAL WITH CUMULATIVE IMPACTS
This is the first stage of a much more extensive project. The company has multiple targets on numerous tenements across the north-eastern goldfields, and evidently intends to process widely distributed satellite ore bodies at the mill covered by this assessment.
I submit that assessment of this project should not proceed until two conditions have been met, first, a full public inquiry as provided for under the Environmental Protection Act (EP Act) into the wider environmental and public health consequences of commercial uranium mining in Western Australia, and second, full disclosure by the company as to the actual scope of the project.
GLOBAL IMPLICATIONS OF URANIUM EXPORT FROM WILUNA
While I understand the limitations of the EP Act, it is highly problematic that the full impact of the nuclear fuel chain cannot be considered.
The Western Australian government, which is currently benchmarking uranium regulations with ‘world’s best practice’, should require global implications of Australian uranium mining to be assessed as part of any uranium mining approval process.
Uranium exported from Wiluna will at best end up as high-level nuclear waste. At worst it will end up as fissile (explosive) material used in nuclear weapons, or in a nuclear disaster such as that unfolding in Fukushima, Japan (uranium from the three operating uranium mines in Australia has very likely been used at the Fukushima plant).
No country has a permanent repository (dump) for high-level nuclear waste let alone a better solution for this toxic waste than extremely long-term storage. Toro states that it has played ‘an active role in work by Australian companies, through the Australian Uranium Association, in the development of a global stewardship network for uranium’ (letter to shareholders, 6 June 2011). It must be asked whether the outcome of this ‘stewardship’ process will be a renewed push to establish an international high-level nuclear waste dump in Western Australia. An international nuclear consortium called Pangea Resources secretly developed just such a plan in the late 1990s − it was exposed when a corporate video was leaked.
The nuclear ‘safeguards’ system, which aims to prevent the misuse of ‘peaceful’ nuclear materials in nuclear weapons, is seriously flawed. The recently-retired Director General of the International Atomic Energy Agency, Dr. Mohamed El Baradei, has stated that the Agency’s basic inspection rights are ‘fairly limited’, that the safeguards regime suffers from ‘vulnerabilities’ and ‘clearly needs reinforcement’, and that the safeguards system runs on a ‘shoestring budget’.
THE INFORMATION PROVIDED IS INCOMPLETE
WATER: The company does not yet know exactly where it will source 35 million tonnes of groundwater over the proposed 14 year life of the mine (based on 2.5 GL per year). Nor has Toro taken an interest in the downstream consequences of infusing such an extraordinary volume of water with radionuclide and heavy metal contamination before dumping it in an arid ecosystem.
TRANSPORT: The company does not yet have a coherent proposal for transporting the radioactive concentrate thousands of kilometres to the port of Darwin, with the preferred ‘preliminary draft’ option apparently being road transport at least as far as Adelaide. The Conservation Council of Western Australia has estimated approximately 2.4 truck accidents per year based on past statistical experience and the proponent’s evident wish to send 36 B Double road trains loaded with radioactive concentrate to Darwin every year.
CONSENT: A formal agreement with Aboriginal Traditional Owners has not been signed. The company is well aware of the hugely divisive nature of the project amongst Aboriginal people in the region.
HERITAGE: The mandatory heritage mapping survey has not yet been completed, indicating that Toro does not intend to let the violation of Aboriginal heritage values stand in the way of its project. The company also has not completed archaeological and ethnographic studies and does not have a comprehensive Aboriginal Heritage Management Plan.
SECURITY: The company has not yet undertaken a formal assessment of security risks, despite acknowledging potentially high risks during the transport phase.
AIRBORNE CONTAMINATION: For reasons of limited power supply, the company decided not to undertake high volume air sampling for much of the 2010 sampling period. It will therefore have very limited baseline data against which to judge the impacts of radioactive dust and radon fallout on its future workforce.
PROXIMITY IMPACTS: The company does not appear to appreciate the localised impacts of mining across ephemeral watercourses, and the potential risks it accrues in cutting major excavations across these channels. Local and downstream pollution in major rainfall events are given only cursory treatment.
Even more importantly, the post-closure impacts of having replaced natural geology with a series of containment cells for finely milled radioactive powder do not appear to have been considered.
MINE CLOSURE: The company has elected to keep estimates of future mine closure liability a secret and has not submitted a final rehabilitation plan. This is doubly remarkable given the company intends that post-closure liability pass to Australian taxpayers only 10 years after mining ceases, despite the millennial cancer hazard its waste residues pose.
TORO’S DISCLAIMER
Toro’s application states that the company has relied on information provided by third parties and ‘Toro has not fully verified the accuracy or completeness of that information except where expressly acknowledged’. Toro goes on to say that that the company ‘gives no warranty or undertaking, express or implied, in respect of the information contained in this ERMP [Environmental Review and Management Plan] and does not accept responsibility and is not liable for any loss or liability whatsoever arising as a result of any person acting or refraining from acting on any information contained in the ERMP.’
The EPA should refuse to assess Toro’s application until the company has both fully verified the accuracy and completeness of its own application and accepted responsibility for its own application.
RADIATION AND HEALTH
Toro states that the average radiation dose for miners at Wiluna will be 5.1 millisieverts (mSv), with 3.8 mSv of that from radon progeny. There is no evidence that Toro has factored in recent advice from the International Commission on Radiological Protection that radon progeny are twice as carcinogenic as previously thought. Thus the true dose for miners will be closer to 10 mSv − approximately half of the permitted average dose for nuclear industry workers but 10 times the permitted dose for members of the public.
To its great shame, Toro is one of the mining companies which have funded speaking tours to Australia by fringe scientists who argue that low-level radiation is beneficial to human health. The company has done nothing to acknowledge the overwhelming weight of scientific opinion that there is no threshold below which radiation is harmless or beneficial. As nuclear radiologist Dr Peter Karamoskos states: ‘To promote such marginal views without any counter-balance is self-serving and irresponsible … Recent research has heightened rather than lessened concern about the adverse health impacts of low-level radiation.’
JOBS
Toro promotes its Wiluna project on the basis of local employment opportunities, claiming that the project would provide ‘full-time employment during construction for up to 350 people and 170 during the operational phase’ (see the overview of the project, at the beginning of the ERMP).
However, Toro’s ERMP states at Appendix D to the application that the project will involve ‘a relatively small workforce’ − two 12 hour shifts daily, each with 20 workers. Clearly the project will generate little employment. Moreover, it can be anticipated that most workers will be fly-in/fly-out workers rather than supporting local employment.
Nationally, about 1200 people are employed by the uranium mining industry in Australia (www.world-nuclear.org/info/inf48.html ). Thus the industry accounts for a paltry 0.02% of national employment and an equally underwhelming 0.3% of total export revenue. Mining is capital intensive and comes in at number 19 in the Australian Bureau of Statistics’ top 20 industries in order of employment (http://tiny.cc/0fxgu ).
PUBLIC OPINION
A poll of 400 voters in the marginal Liberal-held seats of Riverton, Jandakot, Swan Hills and Mount Lawley in April 2011 found that 46% of voters oppose uranium mining in WA, with only 34% in favour and 20% undecided. A similar poll in October 2010 recorded opposition to uranium mining at 40%, with 42% in favour (Campaign Capital, Capital Report, July 2011, ‘Opposition to uranium mining increases post-Fukushima’, http://www.campaigncapital.com.au/ ). The popularity of this industry is in fast decline along with the share price. The government and uranium miners have no social licence to establish uranium mining in Western Australia.
LOCAL ENVIRONMENTAL IMPACTS
BIODIVERSITY: Uranium mining and tailings disposal in this region will occur below the water table and will be connected to the above and below ground aquatic ecosystems following the cessation of mining, if not during the operation phase. There is a significant risk of contaminating the aquatic ecosystems with changes in water chemistry, including the mobilization of radioactive compounds.
This ERMP indicates that there are at least two new species of brine shrimp (Parartemia) and a unique genus of Ostracod endemic to this system. The ERMP has not demonstrated that the locally endemic part of the stygofauna is protected outside the sphere of impact.
Given that the major risks are associated with both the intermittent surface and subterranean aquatic systems it seems totally illogical that the baseline radiation ecology was based on terrestrial flora (mulga/Tecticornia shrubs) and a meaningless sample of ‘station roadkill’. The ecosystem that should have been examined for its current background exposure to radioactive elements and radiation moves from cryptogamic /microbial mat producers, to aquatic macro-invertebrates and stygofauna, to aquatic birds.
Heavy rainfall in the eastern Murchison during February/March 2011 provided a hydro-period and the opportunity for in-situ investigation of the aquatic biota. The Chair of the EPA was alerted to this fact (and of the necessity to utilize the conditions) at that time. An understanding of the radiation ecology of the Lake Way-Marmion system would seem to be essential to assess and manage uranium mining. The aquatic macro-invertebrates and stygofauna should have been ‘road-tested’ as potential key ecological indicators. This work was not done despite the opportunity being available.
CALCRETE DEPOSITS: The Wiluna proposal and other similar proposals for uranium mining in Western Australia where there are calcrete deposits raise additional concerns. There has not been a calcrete uranium deposit mined in Australia and there is only one calcrete deposit presently being mined worldwide (Langer Heinrich in Namibia by Australian company Paladin Energy). There is a lack of expertise and experience in engineering and mine design for these deposits. This type of deposit should be examined more closely for potential risks to the environment and human health specific to the nature of calcrete.
In addition, calcrete ores are more difficult to process than those at, for example, Ranger. Due to the high limestone content of calcrete soils and rocks, conventional acid-based processing is not viable and it is necessary to use alkaline chemicals to dissolve and extract the uranium. This means a larger process plant, more difficult ore processing, and more energy, water and pollution emissions. For comparison, the Langer Heinrich mine in Namibia has had numerous start-up problems with its processing plant, and has consistently failed to meet design production targets – a fact Paladin has effectively masked by constantly ‘expanding’ the processing plant to address the major technical problems and increase annual production.
Nothing in the ERMP provides confidence that Toro has the necessary expertise to properly design, build, operate and decommission a complex industrial facility like a calcrete uranium processing plant.
RADIOACTIVE TAILINGS: The legal requirement for tailings management at the Ranger uranium project (based on the Environmental Requirements from their authority to mine uranium, issued under the Atomic Energy Act 1953) is effective isolation for at least 10,000 years, including no solutes causing environmental impacts. The minimum standard should be the same for Wiluna. The tailings and radioactive waste management regime for any proposed mining at Wiluna should ensure physical, chemical, biological and radiological isolation from the surrounding ecosystems for no less than 10,000 years.
To date in Australia there has not been a uranium mine which has been successfully rehabilitated to the point where radiological conditions are stable such that no ongoing monitoring and maintenance is required. I submit there should be both a commitment and demonstration of a matching financial and technical capacity from Toro Energy to do ongoing monitoring and maintenance until the tailings pose no risk to the environment. This is in line with the precautionary principle and intergenerational equity, which Toro Energy claims to have as underlying environmental principles.
ENVIRONMENTAL RADIOACTIVITY: The background or baseline section on environmental radioactivity shows that the broader Wiluna region is not elevated in radiation at all, except for the small zones of uranium ore in the calcretes (i.e. the Lake Way and Centipede deposits). Unfortunately, Toro makes no specific commitments using these natural levels as target values for closure and rehabilitation, setting qualitative goals only for post-mining conditions. This is unacceptable and Toro should set explicit quantitative criteria for rehabilitation standards, such as radon emanation rates, gamma radiation, radon progeny in air, heavy metals and radionuclides in soils, waters and biota, amongst others.
CUMULATIVE IMPACTS: Toro’s application fails to provide information on the cumulative impacts of its planned operations in the region. A cumulative study should consider existing mines in the region and any future plans by Toro to mine in the region. There are a number of adjacent tenements in the region held by Toro and the company is not making their future ambitions in the area clear. Any application to mine future deposits should be subject to rigorous environmental assessment, not tacked on to this already insufficient ERMP.
SOCIAL IMPACTS: Toro states there is public support for more mining activity because of possible economic development. Wiluna has a number of operating mines close to town and in the region. Despite current mining activity, some sections of the Wiluna community still suffer from extreme poverty, homelessness, unemployment, violence and other social problems (as highlighted in Toro’s social impact assessment). Toro makes no credible evaluation of the existing problems and their causes and therefore cannot accurately assess how it can avoid further negative social impacts from a uranium mine at Wiluna.
ABORIGINAL HERITAGE: Archaeological and ethnographic sites registered with the Department of Indigenous Affairs (DIA) that are listed as ‘closed’ often indicate a high level of significance. In the Aboriginal heritage summary Toro says that there are seven ‘closed’ sites within the project area. The protection of these sites should be given precedence over mining. The negotiation over the protection of these sites will occur between the DIA, Central Desert Native Title Service and the Native Title claimant. At this stage of the assessment process it is disappointing that Toro has not already completed the archaeological and ethnographic studies and does not already have a comprehensive Aboriginal Heritage Management Plan.
SUMMARY
Toro has put into the public domain an incomplete Environmental Review Management Plan. Remarkably, the company acknowledges that it has not fully verified the accuracy or completeness of its own application, and does not accept responsibility or liability for its own application.
The EPA should require more information from Toro before even considering the application. Moreover the Western Australian government should initiate a full and independent public inquiry.
November 1 2011
