From Workplan for Underground Mining 4200/5380:
Signed and dated 1/7/03 by :)
7.5
Dust Suppression Measures
Dust
suppression requirements will be relatively minor since most activities will
take place underground. The impacts on residential properties will be minimal due
to their [sic] being very few in close proximity.
7.5.3
Ventilation Rise Collars and Underground Works
Mine
exhaust air will be discharged from at least one ventilation rise into the
atmosphere. Exhaust air will contain particulates in the form of dust, blasting
products, including CO2, CO, SO2, NOX and
ammonia gases (NH4). The key contaminants in terms of potential
effects on downwind air quality are considered to be CO, NO2 and
dust.
Given
the low levels of population and the distance from the ventilation rise to adjacent
houses (four properties at about 400m to 500m) particulates, fumes and odours
will disperse rapidly and dilute to negligible levels.
During
the construction stage the decline will be ventilated by an exhaust fan and
duct system that will discharge to the Portal Works Area. This location
has no residential properties closer than 500m and dispersion and dilution of
dust, fumes and odours will be rapid and complete.
7.5.4
Odours from Groundwater
Groundwater
pumped to the Evaporation Pond may contain odorous sulphide compounds. To
prevent nuisance odours this water will be aerated as it is discharged into the
Evaporation Pond to oxidise the compounds and remove any odour.
***
So let's
have a closer look at this piece of "planning" dross ..."[R]elatively minor" "dust suppression requirements"; minimal impacts because there are few residential properties in the area... have a think about that for a moment.
That's what happens when you put bean counters in charge of things. Things get averaged out. People get averaged out... into "residential properties"... What were the direct impacts estimated to be on the people on the "residential properties" that are "in close proximity"? Were they minimal?
"Relative" to what?
Can we see the reports?
And no
thought given to the viable and, in some cases, extremely innovative and
successful agricultural properties in the area. Properties that produce
meat. For people to eat. And export. To eat. With dust and fumes and at least
five named "key contaminants" floating over and into them.
Were any
considerations taken of dust mitigation for the construction phases of the mine
aboveground? You'll look hard without finding them.
This is an
interesting extract because it lists some of the chemicals and compounds that
are still, 11 years later (well until June, 2014 when particulate monitoring was at last installed again), being pumped out of unmonitored vents uncapped shafts like this; day
in day out:
This is a photo taken by Costerfield farmer Neil Harris earlier this year. It came as a great surprise to the regulators and the folk from Golder Associates. Why? It's all down here in the Workplan.
***
So, from out of these holes come unknown (because they are
unmonitored) quantities of "dust, blasting products, including CO2,
CO, SO2, NOX and ammonia gases (NH4)".
The admitted "key contaminants" are carbon monoxide, nitrogen dioxide
(long-term exposure to NO2 at concentrations above 40–100 µg/m3
may decrease lung function and increase the risk of respiratory symptoms[1]) and dust.Hang on! Dust? That was gonna stay underground. Wasn't that why we only needed "relatively minor dust suppression".
Was any examination done of the "potential effects on downwind air quality" from these "key contaminants"? How extensive was it? What did it conclude?
Can we see the reports?
But now for the most stunning piece of sophistry and obfuscation - and scientific illiteracy - we've observed in a long time. These people are in charge. It needs repeating in full:
Given the low levels of population and the distance from the ventilation rise to adjacent houses (four properties at about 400m to 500m) particulates, fumes and odours will disperse rapidly and dilute to negligible levels.
That's right. You read it here first. Population density is a driver of dust dispersal. It says so right there. Given there are not many people and they live a quarter of a mile away, the dust and fumes will disperse and dilute. But not only that, they will disperse "rapidly". This forms part of the Regulators' justification for not bothering to monitor the emissions adequately, "relatively", of course. This is unscientific rubbish that betrays an ignorance of the very concept of cause and effect on the part of the approving officer(s).
And this gibberish obviously denotes some concept of fact for someone close to this project because a paraphrase - a more emphatic paraphrase - appears immediately below:
This location has no residential properties closer than 500m and dispersion and dilution of dust, fumes and odours will be rapid and complete.
Complete. It will be rapid.
So here we have a statement that is about as adamant as you can get, from the approving regulators, that dust, fume and odours will quickly and totally disperse and dilute within 500m of the mine portal. How was this determined? Certainly not with the AUSPLUME formula which doesn't have a variable for population density. For how long did DSDBI test emissions from the mine to assess their "rapid and complete" dispersal and dilution after 500m? Well, we'll return to this question soon too.
Can we see the reports?
This lop-sided
plastic funnel in a bottle on some stakes in the ground is what we get from our
regulators. This is what substitutes for science and environmental monitoring
in Costerfield. Now apparently some such system is an approved Australian
Standard (AS). You can purchase these pieces of
equipment, ready-made and AS compliant for not much money at all.
Relatively.That's a real one, right below. Our gauge has been bodgied up with gaffer tape and cable ties - presumably to keep the birds from depositing nitrogen samples; the real system has a "birdring" affixed to do this.
Unfortunately, even it can't estimate wind speed.
(Unless you stand next to the funnel, wet your finger in your mouth and then lift it into the air. The colder the finger, the faster the wind. That's science right there.)
This has been the extent of dust monitoring for years in Costerfield. The one above is actually an advanced model. Usually they don't have a gauge for wind direction. But anyone can see which way the wind usually blows here...
We wonder how accurate this one can be, given that any dust in the prevailing wind would fly over its non-standard elliptical funnel mouth.
Who checks this "monitor"? Oh, Mandalay... they check their own dust deposition levels. Self-monitoring is always such a good system. Remember the Longford gas explosion? You can always rely on a business to faithfully report its own shortcomings. The shareholders love it!
During the recent antimony alert in Costerfield figures were requested from Mandalay for dust deposition. Not available. Ants in the bottle one month. And bird droppings in another.
And, believe it or not, a laboratory error. Seems like these people all go to the same script writer.
Ask us. We've yet to post these documents but we have them.
And it's not like no one has ever noted the inadequacies and asked for better equipment or monitoring... it's never the regulators who do this though; always the local residents:
6 Quarterly Environmental Monitoring Report – Q3 2009
Dust
[Local
Resident] B*** then noted that sprinklers where [sic] not turned on at
waste dump area and that there was a lot of dust in the are[a] around the mine.
B***
then suggested that larger wine flagons be used for dust recovery as his bottle
was overflowing due to rain this quarter. M** explained that AGD had to use
smaller bottle[s] at three sites this quarter as the supply company had not
seen [sic: sent] the appropriate bottles on time. Bob explained that
dust collection equipment used by AGD is in line with Australian Standards.
Olivia [AGD] added that the method was widely used around Australia.
[Local farmer
and resident] G** asked if more sophisticated equipment was available for
testing dust. Olivia explained that there are a number of dust measuring
devices available and that the cost of these units are [sic] quite high.
AGD aim to install a weather station on site in order to improve the current
monitoring program.
Peter
Hargreaves [CoGB Town Planning Officer] requested an update by the next meeting
on the proposed weather station, work plan and budget. Brian Leehy indicated
that he is in favour of the weather station but concerned by previous nil dust
recordings.
G**
would like a measurement done on how much water [is] used by sprinklers as [he]
has asked previously but never been done. [Emphasis added.]
That would be an order for a couple of sherry flagons for Costerfield.
Five years ago, Peter Hargreaves, the Planning Officer for COGB requested an update on the "proposed weather station"...
Can we see the report?
It will become apparent as we move through the evidence, that ignorance, willful or otherwise, of the specific weather and climatic conditions in Costerfield has resulted in an increasing inability to deal with the groundwater removed to facilitate underground mining. (The first "Water Balance" produced to illustrate inputs and outputs incredibly failed to include rainfall across the site as an input. Seriously. )
The mine just did not want to know. And neither did the regulators? Listen in on this exchange:
From the Mandalay ERC Minutes, 21st November, 2007:
6 Quarterly Environmental Monitoring Report
[Local
resident] B** presented rainfall figures for the 2001, 2002, 2003, 2004, 2005
and 2006, which he indicated as being in agreement with data collected by AGD,
and stated that rainfall in that period had been at or above average rainfall for
the area. Despite this low rainfall is being used as a reason for the fall in
water tables.
Greg
Speirs [COGB] referred to data that he had collected in Heathcote for the last year
and the previous 7 years. He noted that while rainfall had been only marginally
below the average 550mm, for Heathcote, McIvor Creek flows had been
significantly less than in previous years.
Why counter claims specific to Costerfield with figures from Heathcote? How can this in any way be a sustainable argument? Costerfield had higher than average rainfall. The mine is in Costerfield. No wonder they don't know what to do with the water.
At least as early as 2007, then, it was obvious that some sort of weather monitoring equipment was required. The previous extract from the 2009 ERC Minutes (still no action) illustrates the absolute lack of response to this obvious requirement from the regulators over the ensuing two years. And then there is dismissive attitude from Mandalay that they should be asked to deign to invest in any "quite" costly equipment. And there is still no weather monitoring station in place today.
So back briefly to 2003, and we know that there were issues to address from 1998 because of the letter from the Deputy Premier's Office; issues that required that a "strategy" to deal with the "historical environmental health issues" - of which mine activity was "unlikely" to be the "sole cause" but was admitted to be "additional" - be incorporated "in the approved Work Plan" before mining could recommence. Included in Permit 2448 are conditions 8(ii) and (iii) covering dust monitoring and the "regular" checking of water tanks. [Emphasis added.]
The 1998 mine was open cut. The 2003 mine is - eventually - underground. That was obviously the extent of the "alternative mining strategies which will not lead to increased health risks". Put it underground and then conclude that only minor "dust suppression requirements" were required.
But what about:
Mine
exhaust air will be discharged from at least one ventilation rise into the
atmosphere. Exhaust air will contain particulates in the form of dust, blasting
products, including CO2, CO, SO2, NOX and
ammonia gases (NH4). The key contaminants in terms of potential
effects on downwind air quality are considered to be CO, NO2 and
dust.
And it's not like no dust was forthcoming. Indeed, in 2007 we can read:
From the Mandalay ERC Minutes, 21 November, 2007:
Tom de Vries – AGD Operations-General Manager
5 Operations Report
Water
Management
Tom
de Vries advised that there is an excess of water underground and indicated
that while the main focus was to transfer water to the evaporation pond other
options such as treatment and disposal (as is done by Bendigo Mining) and the
use of thickeners to enable reuse are under consideration.
Tom
de Vries added that a clear environmental plan was required for the site and
that more work is required.
6.2
Air Quality & Dust
DISCUSSION
Visible
dust from the mine
[Local resident] B**
asked what about the possibility of uplift dust over one location to a more
distant location.
Colin
Burns [AGD] stated that this can happen with respirable dust but not with deposited
dust which is relatively course.
B**
stated that dust from the mine is visible when he has walked down to the mine
on several occasions.
Colin
Burns stated that dust seen by B** is suspended dust and much finer than
deposited dust. Suspended dust can be at a higher concentration further from
the source but this is not the case with deposited dust.
B**
asked if the dust was coming from a dust bowl.
Colin
Burns stated that the amount of dust produced varies depending on how many
sheep there are in the paddock.
[With regards the above strikeout text: the inference drawn from Tom de Vries' statement that no Reverse Osmosis was planned, is wrong; the reference to Bendigo Mining's RO, while not exactly a boast-worthy example, is obvious and clumsy of us to miss. We have pointed out this mistake before but leave evidence of our own misreading in the interests of full disclosure.]
Here it is primarily the dust that concerns us.
Dust is visible over the mine by residents. Its presence is admitted by Colin Burns of AGD. In fact he even knows what kind of dust it is. It's"respirable", "suspended " dust... but it's relative to the number of sheep in a paddock...
And then there is this:
"Suspended dust can be found at a higher concentration further from the source."
Was this a conclusion drawn from events, from previous experience, in 1998 when residents were accused of sabotaging water tanks with antimony and arsenic because the Regulators would not admit/did not have a clue about what was happening? Suspended dust can apparently, according to Colin Burns, speaking with some authority, "uplift from one location to a more distant location".
Here is a recent quote from DoH senior medical adviser Dr Danny Csutoros from the McIvor Times, 13 August, 2014:
"We had a couple of samples that didn't make sense - a couple of people who were way out of the area with high antimony."
Perhaps these people had been contaminated by uplifted suspended, respirable dust. We won't know because a funnel and flagon only (just) detects deposited dust. No ongoing monitoring of respirable dust has been conducted by AGD or Mandalay Resources or the regulators during the decade of this mine's latest incarnation. And according to the manufacturers of the dust deposition equipment: There is no direct method of conversion between deposited matter and TSP or PM10.
That is, there is no way to determine the level of particles (PM10) which comprise, along with the even smaller PM2.5 particles, the preponderance of"suspended" "respirable" dust.
And there is no way that many important determining factors can be examined by using these funnels and flagons. From the manufacturers:
Their
main advantage is that they do not require an electrical power supply, they can
be deployed in remote areas and can be left in the field for long periods of
time. However, their disadvantage is they do not provide data on a day by day
basis, information on dust concentrations, nor relate dust levels to wind
direction or particular events. If there is a major dust problem it will not be
known until the end of the monthly cycle.
This is not a remote area, power is available and we want to know about wind direction and dust concentration. We actually want to be able to trace specific "dust problems" before the end of the monthly cycle. Well surely the regulators did.
(Sometimes dust gauges were left unchecked for much longer than a month... see the comment from local resident B** above - "overflowing with rain for this quarter" for evidence of this. See here, for admissions, in ERC Meetings, by Mandalay Resources that they had not been following Australian Standards. More admitted breaches that should have invoked fines from the regulators.)
Supposedly, no one can say with certainty where the latest dust that has caused issues in Costerfield is sourced. Why not? Because the regulators were satisfied with dodgy Heath Robinson constructions and data gaps. For a decade and more.
Who is making these decisions to do the least that can possibly be done? On what basis? On whose authority?
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