Hg Recoveries Pty Ltd
A
Member of the UNEP Global Mercury Partnership
Partnership Areas: Mercury in Gold Mining, Mercury
Supply and Storage, Mercury Air Transport and Fate, Mercury in Products.
Heavy
Metal Specialists
(ABN 87 144 752 885)
(ACN 144 752 885)
Date: 1/12/2014 File: 7750
Ms Kylie White,
Executive Director,
Earth Resources Regulation Branch,
Corporate, Planning and Compliance Services,
Department of State
Development, Business and Innovation.
CC: Tony Robinson EPA
Dear Kylie and Tony,
MANDALAY
RESOURCES - SPLITTERS CREEK FACILITY
MULTI-AGENCY
REGULATORY FAILURE
I am writing to both of you today to make sure you have
correct data as you start the task of briefing a new Minister for your
respective Departments and the other members of your Costerfield “working”
party also having to cope with new Ministers.
The minutes of the ERC Meeting on the 6th
of November 2014 were released to the residents last week (Reference#1 above).
For your convenience, I have attached a marked up version of these minutes with
key points of concern highlighted. Some key points that you need to focus on
are:
1.
Page 3, Item 5, Bullet Point (BP) #4. The
problems of using RO plants to ‘treat’ this type of mine water are well known
from similar problems in China. I told Mr Mattiske last year that the water
would need pretreatment to remove dissolved silica but he ignored this advice.
2.
Page 3, Item 5, (BP) #5. I can understand
the EPA’s concerns but the problem is that, based on past experience, the mine
will just dump the highly toxic water into the environment.
3.
Page 3, Item 5, Bullet Point (BP) #11. The
argument about dumping water into an ephemeral creek system is false, There is a whole range of data (Ecological
Society of America, American Institute of Biological Sciences, US Geological
Service etc) that demonstrate that these creeks can flow all the time and it
does no harm and much ecological good to have these creeks running all the
time. It is wise to focus on the fact that the mine only has about 4 years of
ore reserves left.
[Edit by Wappentake Valley Community: The Wappentake Creek is NOT ephemeral.]
4.
Page 4, Item 5, Bullet Point (BP) #15. This
statement has been proved a lie due to the testing released late week. It is
straight mine water being used to suppress dust and this constitutes breaches
of the EPA Act in regards to pollution of land water and air. EPA needs to
prosecute this matter to demonstrate its bona fides to the community.
5.
Page 4, Air Quality Management bullet point
12. For Golder to take a further 8 months to deliver the second of their highly
conflicted reports is not good enough. There has still been no full scale testing of ALL the heavy metals coming out of this mine by Golder or the Departments. The community has a right to know the full suite of risks that it
faces and your Department has failed in this duty. The community still do not
have access to a proper risks matrix issued by the Government despite the
Government's duties to the community under the OH&S Act.
6.
Page 4, Air Quality Management bullet point
13. As has been demonstrated over the previous months, you can have all the
permit conditions that you like but what the community needs is enforcement. Neither the Government regulators nor the City of Bendigo have ever shown the slightest inclination to actually enforce dust emissions controls. The residents have never had a single dust analysis that complies with SEPP (Mining and Extractive Industries) for this level 1 mine.
7.
Page 4, Air Quality Management bullet point
14. Why is it that Golder are not retained to do the monitoring at Splitters
Creek? There is supposed to be an “EPA approved” auditor on site but there is no evidence that this person has been
onsite because if they had been then some of the more flagrant breaches that have taken place would have been stopped and the auditor would have been taking
water samples for testing. In the end the residents had to take these samples.
8.
Page 5, Splitters Creek Evaporation Facility
bullet point 3. The complaints have actually been totally ignored.
9.
Page 5, Splitters Creek Evaporation Facility
bullet point 4. Where is the testing of the liquid the two water carts are
laying down? The EPA auditor had a duty to do this task and report to the
residents and the Council and the Auditor has failed this task.
10.
Page 5, Splitters Creek Evaporation Facility
bullet point 5. The residents have absolutely no confidence in Mr Chalkley and
again this is a task for the so-called EPA Independent Auditor.
11.
Page 6, Splitters Creek Evaporation Facility
bullet point 4. The so-called EPA “Independent Auditor” should have noticed
that the soils on the Splitters creek site are tending towards hydrophobic and
this soil state coupled with the mine water at a high level of alkalinity means
that the water that is sprayed on the soil that is being removed will not serve
to dampen the soil. This is an exercise in getting rid of the mine waste water
rather than dust control.
12.
Page 7, Quarterly Environmental Monitoring
Report - Air Quality bullet point 1. This is a fraudulent statement. To comply with EPA prescribed limits you need to monitor the dust issues in accordance with the SEPP (Mining and Extractive Industries) for this level 1 mine. Instead the mine uses the badly flawed “Dust
Track” monitors that need constant calibration and do not test the range of
products required for compliance with the SEPP (Mining and Extractive Industries).
The comment that “Andrew explained why ash content was more important than the total insoluble matter to explain dust not being an issue at the mine.” The ash comes from organics in the dust and is irrelevant. The risk is from the insoluble matter which is metals and silica etc which gets into people and mammals bodies - as we have noticed with the sheep testing the farmers have already carried out. Just more misinformation from Mandalay.
The comment that “Andrew explained why ash content was more important than the total insoluble matter to explain dust not being an issue at the mine.” The ash comes from organics in the dust and is irrelevant. The risk is from the insoluble matter which is metals and silica etc which gets into people and mammals bodies - as we have noticed with the sheep testing the farmers have already carried out. Just more misinformation from Mandalay.
13.
Page 7, Quarterly Environmental Monitoring
Report - Air Quality bullet point 3.
Bugs are made from carbon and do not have PM10s in them
unless they have inhaled them.
14.
Page 8, Quarterly Environmental Monitoring
Report - Air Quality bullet point 8. High moisture levels in the air tend to cause particulates
to ‘grab’ water particles and fall to the ground. The particulates will
be coming from re-mobilized dust from the soil in a halo around the mine.
There are elevated levels of antimony and arsenic around the site from previously deposited dust.
15.
Page 10 bullet point 5. The question of
water quality used on the roads. Andrew Mattiske stated “it was not tailings water
but storm water from the old tailings dam. Not mine water at all.” The most recent Mandalay produced report on the contents of
mine water being used for dust suppression on roadways around the mine is the
analysis provided to Bendigo Council on 20/01/2014.
20/01/2014 Report 16/11/2014
Report
Antimony 25,600 ug/L 23,000 ug/L
Arsenic 53 ug/L 170 ug/l
Cadmium 0.1 ug/L 0.2 ug/L
Copper 2 ug/L 5 ug/L
Lead 1 ug/L >1 ug/L
Nickel 8 ug/L 11 ug/L
Zinc 5 ug/L 10 ug/L
So the residents now have another Mandalay miracle on their hands - the “storm water” from the “old tailings dam” can miraculously mix itself up with a range of metals so that it mirrors in the analysis of mine water from the 20/01/2014 report. Whoever mixed up this water managed to put 3 times as much arsenic in it.
So here we have the Chief Environmental Officer from the mine making assurances to the residents on the 6th of November 2014 that the water being used was “storm water from the old tailings dam”. On the 16th of November the residents take a sample from the spray bar on the truck putting water on the road and prove that the statement from Mr Mattiske was at best deceptive and misleading if not grossly negligent.
Kylie and Tony, you have new Ministers on deck by Friday of this week and there is no doubt that the various ministers with oversight of the agencies that are supposed to be regulating this mine will be much more focused.
So the residents now have another Mandalay miracle on their hands - the “storm water” from the “old tailings dam” can miraculously mix itself up with a range of metals so that it mirrors in the analysis of mine water from the 20/01/2014 report. Whoever mixed up this water managed to put 3 times as much arsenic in it.
So here we have the Chief Environmental Officer from the mine making assurances to the residents on the 6th of November 2014 that the water being used was “storm water from the old tailings dam”. On the 16th of November the residents take a sample from the spray bar on the truck putting water on the road and prove that the statement from Mr Mattiske was at best deceptive and misleading if not grossly negligent.
Kylie and Tony, you have new Ministers on deck by Friday of this week and there is no doubt that the various ministers with oversight of the agencies that are supposed to be regulating this mine will be much more focused.
I look forward to your response.
Andrew Helps
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