And we do so in order to encourage open disclosure and a responsible and accountable Government and its regulatory authorities.
Golder are only testing for 8 metals? When how many can be tested for? SHOULD BE TESTED FOR.
The Costerfield Community itself has undertaken testing for 32 elements!
Here is our latest email to those responsible for this debacle.
Dear Kylie,
I
am deeply concerned with DSDBI’s email which has been sent out to allegedly "inform” residents of the Golder “Stage Two Work” at
Costerfield.
A
suite of ‘eight undisclosed elements’ is neither sufficient nor appropriate
to assess the many and varied risks that exist for the Costerfield and
Heathcote communities from both past and present operations of the
Costerfield mine.
Whilst
I realise this mine consistently uses a “short” list of elements for
its own commercial reasons, it is simply not good enough for the
government contracted consultants hired by the primary Regulator to also
be using a similar list!
This
“short list” does not include other “heavy metals” known to exist at
concern levels in soil and water in the vicinity of the mine and its
dust-deposition and waste water disposal areas.
Any
new soil testing program must also include vanadium levels across this
region as the US ATSDR has a Chronic Inhalation Level for Vanadium of 0.0001
mg/m3 and values around the mine have often been measured at
levels of 120 mg/kg level (1.2 million times the inhalation level
maximum).
Then
there are the titanium levels problems which are often in the region of
4,000+ mg/kg; ATSDR has an Inhalation Level of 0.00008 mg/m3 (50 million times the inhalation level maximum).
[red text: these are erroneous figures. Inhalation figures cannot be calculated from soil figures quite so neatly.]
No speciation work has been undertaken to date for these two elements to establish what form they exist in but they certainly require urgent investigation; it is crucially noteworthy that the Golder Phase Two work will not cover these elements since it is limited to only eight elements!
No speciation work has been undertaken to date for these two elements to establish what form they exist in but they certainly require urgent investigation; it is crucially noteworthy that the Golder Phase Two work will not cover these elements since it is limited to only eight elements!
Whilst
the mine has provided superficial data for only two months regarding
the content of dust moving offsite, e.g., (antimony, arsenic and
silicon), there are many other dangerous elements known to exist in this
ore stream.
Despite
all of the historical data for mercury use on this site to recover
gold, Golder have not even bothered to include this Internationally
controlled highly toxic element in their work. This failure by Golder is
of particular concern since random surface tests on an historical
tailings dump outside the mine site has shown average mercury readings
of 10 mg/kg – and children presently play on this particular dump!
US ATSDR has a Chronic Inhalation Level for mercury of 0.0002 mg/m3 (Neurological damage). 10 mg/kg mercury converts to 82 mg/m3 in the air or enough mercury to take 27,347 m3 of air to the ATSDR limit of 0.0002 mg/m3, (which would cover 1.36 Ha to a height of 2 meters).
It is a pity that the DSDBI chosen consultant did not have the data from the first part of the project to pick up on this issue.
Arsenic Pentoxide
(the major form of arsenic found at the mine), is now on the PAN International list of Hazardous Pesticides (CAS number 1303-28-2); is Golder now going to include this issue, as a consequence?
Next
there are the issues with Lead Nitrate, used as a flocculant on site
(“production additive” in mine speak) which is a Class 6 Toxic, Class
5.1 Oxidising Agent, soluble in water, is categorised as
‘probably carcinogenic to humans’ by the IARC. Consequently, it must be
handled and stored with the appropriate safety precautions to prevent
inhalation, ingestion and skin contact. Due to its hazardous nature, the
limited applications of Lead(II) Nitrate are under constant scrutiny.
Lead Nitrate is suspected of causing neurological impairment in children
and may cause harm to an unborn child, and a possible risk of causing
infertility;
Next, Sodium
Dibutyl Dithiophosphate, an organophosphate of similar toxicity to many
globally banned pesticides, Class 8 Dangerous Goods, Hazchem 2R –
decomposes to sodium hydroxide or hydrogen sulphide, pH of 13; Endocrine Inhibitor.
If
the Golder scope of work had been circulated outside of the agencies which have all had a hand in the ‘regulatory failures’ at this mine,
then you would have undoubtedly ended up with a scope of work that was
‘much better informed’, particularly from overseas experience with this
type of mine and the suite of toxic substances that can be expected in
these ore bodies and historical tailings piles.
I was pleased to see that John Mitas has today, finally, clearly articulated “risk evaluation for possible additivity and synergistic effects”. I look forward to a full disclosure of Golders proposed methodology to carry out this evaluation.
The
usual starting point for this type of evaluation is to carry out the
basic hazard index (Nordberg et al) work that is routine even in the Third World these days, but for some reason was not carried out in the
first part of the Golder work.
We have just completed XRF retesting many of the Costerfield samples
previously collected and have compared these results with ICP-MS data
with very high correlation demonstrated between these two analytical
procedures.
There
are in fact 32 elements of interest in the soils and tailings dumps
around the extremity of the operational mine and Golder is only going to
test for 8!
In
short, it is neither acceptable nor scientifically robust, for the base
suite of eight elements the mine tests for, to be adopted as the sole
basis for the so called "independent study”!
If
you don’t look, then you certainly won’t find these problem areas. But then, by following this myopic undertaking you can’t then be said
to be held accountable for what really exists as substances at concern
levels existing in this environment!
Such
a move by Golder and the various supporting government departments
would not be excusable for any ensuing pending legal actions resulting
from confirmation of these broader and highly predictable contaminants
impacting residents, tourists, animals or the environment.
I
therefore respectfully suggest that the Golder scope of work be
expanded to include the full suite of potentially toxic elements – this
will actually save money for the Government because the standard 17
elements by ICP-Ms (and cold vapour AAS for the mercury) will not have
to be ‘trimmed’ down manually to just the chosen 8 elements and Golder
can save labour by just publishing the laboratory results as supplied by
the Laboratory.
Kylie, I look forward to your prompt response to these critical issues.
I am in the city tomorrow if you want to discuss this face to face.
Regards
Managing Director Hg Recoveries Pty Ltd ACN 144 752 885
Level 13, 350 Collins Street Melbourne Vic 3000
A member of the UNEP Global Mercury Partnership
Partnership Areas: Mercury in Gold Mining,
Mercury Air Transport and Fate, Mercury in Products,
Mercury Waste Management, Mercury Supply and Storage
Heavy Metal Specialists
We commit to making any response from the Government available on the blog immediately.
And we do so in order to encourage open disclosure and a responsible and accountable government and its regulatory authorities.
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