This is a pro-regulation blog. We are not anti-mining. This is not an anti-Mandalay Resources blog.

Thursday 2 October 2014

Stage 2 Golder Issues



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.



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!

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

Andrew Helps

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

Face-to-face with Andrew would be good; upfront, honest and forthright communication with the Costerfield Community via the email forum would be even better. We have led the way, have we not?

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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