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

Friday, 30 January 2015

Sabotage or Vandalism?... If It's Either...

It has come to our attention that on Friday 23 January, 2015, as Mandalay Resources personnel and contractors were pressure testing the 5km pipeline at Splitters Creek prior to its commissioning and use to convey toxic mine waste to the Lot 2 construction site to be employed for dust suppression* and "clay conditioning", a "rushing" sound was heard in the pipe.

[* At the recent ERC meeting it was confirmed that dust suppression is now being accomplished with the use of Reverse Osmosis treated water. A vast improvement and something that should have been done from the beginning.]

Upon removing a gate valve it was found that a 150mm diameter 500mm long treated pine log had been inserted into the pipe and had been pushed, by the force of the water, to the valve.

The pipes were laid in the Crown Land adjoining the South Costerfield-Graytown Road between 17 and 20 November and were welded together by 2 December, 2014. That time frame governs the log's placement in the pipe. Or so it would seem.

This apparently irresponsible act has been labelled "blatant... sabotage". We have no doubt that judgmental gazes are being cast in our direction as the perpetrators of this seemingly thoughtless behaviour. This possible vandalism is something we deny any knowledge of.

And we would be somewhat puzzled, indeed, should the automatic response be to cast aspersions on the Community, as it has been our stated and consistent position throughout our copious communications and blog posts that our quarrel is with the regulators and not the mine, its personnel or operations.

We have noted the authorities' (and a previous mining company's) tendency in the past to place responsibility for illegal and even accidental events on any group or individuals who may offer objections to the conducting of mining activities in Costerfield. This is a narrow view of the world.

More open minds would consider other possibilities to explain such potential vandalism. The police - who have apparently been notified - know the Costerfield area well and will undoubtedly take into consideration a great deal more than some who do not hail from the district are prepared to.

We are not saying anything that is not common local knowledge when we tell you that the mine - like any other employer of a large impermanent workforce - is graced by a number of disgruntled former employees whose dissatisfaction could drive them to mischievously place a log in a pipe. You can check the papers or ask around the district.

Local knowledge of the area, too, will help in broadening the scope of possible investigations for the police should they wish to pursue their inquiries.

The Costerfield area in general, the Crown Land and Wappentake Valley in particular, is a regular destination for kangaroo shooters - especially during summer - any of whom could have mischievously placed a log in a pipe.

The Costerfield area in general, the Crown Land in particular, is a regular destination for trail bike riders, fossickers and bushwalkers - especially during summer - any of whom could have mischievously placed a log in a pipe.

The word "sabotage" implies a specific end result being held in sight by the perpetrators. Presumably the stopping or delaying of the Splitters Creek project. Community members are not so naive as to think that such a thing is possible. This project is proceeding full tilt, and will proceed. Just look at it inexorably unfolding...

Our intention has always and only been to indicate and highlight the shortcomings of the regulatory processes by which this project - and others approved by the regulators - has come to fruition, in order that future mineral extraction processes and their accompanying projects are conducted according to Best Practice.

With this in mind we note that the conclusion reached that the pine log was placed in the pipe somewhere in the five kilometres between the Augusta mine site and Lot 2 South Costerfield-Graytown Rd seems to indicate a lack of Quality Assurance in the pipeline's construction. Wasn't an independent EPA-appointed Auditor retained to "oversee" these things?

Do no regulations cover the mandatory inspection, externally and internally, both visually and by push-through means, of such a pipeline prior to its welding?

The pipe lay for two weeks in forested Crown Land - in the bush.

Were no checks performed to ensure that wildlife had not entered the pipe before its assembly?

It is not uncommon, we are told, to find echidnas, native rats, feral cat kittens, snakes and lizards in pipes like these. Thus a push-through protocol for each individual length is followed prior to the pipe's welding.

Would we have been informed if a couple of red-bellied black snakes or an echidna had "sabotaged" the pipe line by seeking shelter and warmth and then being damply and disastrously and divisively propelled to the nearest gate valve?

Were no checks performed to ensure that "slugs of mud" had not accumulated in the pipes before they were welded?

Are we to assume that along the whole five kilometres of pipeline, not a single check for obstructions took place?

***

It is our understanding that when these 16m (or 10m) pipes are loaded onto a truck, short lengths of 150mm diameter pine posting are sometimes used on top of the pipes on the semi-trailer so that the ratchet straps that secure them do not damage the pipes. The pieces of pine sit in the valleys between the top pipes so that the straps do not chafe them.

Some carriers go the other way and insert the pine post inside the 160mm diameter top pipe to stop it collapsing when the restraining strap goes over.*

***

Do not get us wrong. We are very far from making light of what may in fact have been a potentially irresponsible and somewhat dangerous act (though not quite as dangerous as the rather sensationalist message doing the rounds would seem to imply; the gate valves are linked to sensors that cease flow along the pipe on encountering a change in pressure that just such an obstruction would cause; that's what they are designed to do - pressure testing).

However, to immediately label this a "blatant act of sabotage" is a rush to judgement which immediately and ignorantly discounts other possibilities - many other possibilities - that direct attention squarely away from our Community members. Shooters, trail bike riders, fossickers, bushwalkers. Other possibilities...

And if the attention is not focussed in our direction then this seemingly foolish act becomes common senseless vandalism rather than sabotage.

If it is, indeed, either of those things.

***

* At the recent ERC Meeting - where the offending log was allowed by the regulators to be irrelevantly produced for recording in the minutes; an Environmental Review Committee Meeting - those residents allowed to attend were told that the company that delivered the pipes used chocks and wedges for this purpose. At least things were followed up. No blame was cast on the Community.

However. "It didn't get there by accident," said the schoolmarmish Chair admonishingly; and also irrelevantly. 

All Cr Leach needed was a cane and we'd have all been given detention and whooped!

We've become almost used to such inanity from her by now.









Thursday, 29 January 2015

AS3580 at Splitters Creek

This article, "Ambient Monitoring Standards Are Falling", comes from Waste Management and Environment from September 2007. The shortcomings of ambient air quality and dust monitoring have been an industry issue for quite a while.

We've all - hopefully - seen the funnel in a flagon application of AS3580 that has served as something of an icon of this blog.


And we've noted that there are alternatives to Jerry-building your own non-compliant equipment. With bird-rings.



There are also more sophisticated instruments available. Some are able to measure "directional dust deposition". That might be handy if you want to know where dust has come from. Some provide real-time monitoring and the monitoring of particulates. Real-time monitoring enables operators to respond quickly to high dust emissions on, say, weekends, thus avoiding much angst and inconvenience to nearby dust-covered residents.

Our previous comments on monitoring have been chiefly directed towards the use of the above "equipment" to assess emissions from the mine itself, and from its crusher. But what about the construction site at Splitters Creek?

Here is some info from the New Zealand Ministry for the Environment's web page Where to Monitor? - Selecting Monitoring Sites, which reproduces and recommends the relevant sections of the AS/NZS 3580.1.1:2007, Methods for sampling and analysis of ambient air - Guide to siting air monitoring equipment:
6.5.3 Sample inlet considerations
Inlet heights should be sited at the breathing zone in order to represent human exposure. This is often not possible, because inlet heights have to be compromised to avoid the risk of vandalism or to accommodate the specific requirements of particular instruments. AS/NZS 3580.1.1:2007 provides guidance on acceptable inlet heights for different contaminants at different types of sites. Table 2 of this standard should be used to assess the acceptable range of parameters where it is not possible to monitor at, or near, the breathing zone.

Some considerations include:
·        keeping the inlet at least 20 metres away from tree drip-lines
·        ensuring an unrestricted airflow of 270 degrees around the sample inlet (or 180 degrees if at the side of a building)
·        ensuring a clear sky angle of 120 degrees.

So a question to be asked is: What dust is the gauge below expected to measure in its closeted position behind the wall of the terminal dam, and well within 20 metres of the drip-line of trees, that obscures a 120 degree "clear sky angle" and prevents "unrestricted airflow of 270 degrees"?


There are 100 km/h winds in Costerfield. The dust from a 30 hectare construction site is not as obedient as some people would wish under such conditions. These are dust gauges, not dust magnets, and the dust blows over them and onto other properties. And none of those properties have gauges to measure it.

We'll zoom in on that gauge in just a minute. First though, lets examine their effectiveness in Costerfield according to Dust reports from a couple of ERC Minutes.

This from the Quarter 2, 2013 ERC Minutes:



 This from the Quarter 3, 2013 ERC Minutes:


It's certainly "unavoidable" when your cable-tie bird-ring halo has slipped, as this one has.

 


Dustfall - deposition gauges - manual gravimetric
This technique has found application in areas where nuisance dust (coarse particles) is a problem. Particles settling from the atmosphere are collected via a funnel into a container (AS 3580.10.1). After a suitable exposure period (typically one month) the collected sample is returned to the laboratory for analysis. The method does not measure TSP, and if the objective is to measure TSP or particle fractions implicated in health effects then other methods that involve active sampling with size selective inlets should be used.


And there is arsenic in them thar hills, too. And arsenic is a Group A carcinogen. And arsenic is a Class 3 Indicator. And the EPA has a Hazard Summary for Arsenic Compounds which references the ATSDR and details the routes of possible contamination and ingestion of this highly - the most highly - toxic substance, and requires "control to the Maximum Extent Achievable (MEA) due to the potential health effects associated with exposure".







The approved Work Plan for MIN 4644 dates to 2006. It is now 2015. Arsenic. Antimony.

And so we ask: How much material has been emitted during the construction of the Splitters Creek Evaporative Facility? 



Especially since:

"Elevated levels of inorganic arsenic may be present in soil, either from natural mineral deposits or contamination from human activities, which may lead to dermal or ingestion exposure." (EPA Hazard Summary)

How much "active sampling with size selective inlets" has taken place?

Given that the EPA's Hazard Summary provides all of its exposure levels to this cancer causing substance according to their volume in air, that is in milli and micrograms per cubic metre, why are dust deposition gauges that measure dustfall according to milli and micrograms per square metre the only monitoring equipment to be employed at Splitters Creek?

And why are they confined only to the construction site?

How does this comply with EPA's stated intention of mitigation to the Maximum Extent Achievable as set out in Developing Action Plans for New Class 3 Indicators?


And what about the toxic heavy-metal laced mine water, with its elevated levels of arsenic and antimony, that has been sprayed around the site for "dust suppression" and "clay conditioning"? It is toxic water - a health hazard - and it has evaporated and left behind its toxic heavy metal constituents to be blown about the district.

But then again, the EPA has handed environmental monitoring of the mine and its infrastructure to DSDBI - the mining facilitator - and has effectively washed its hands of Costerfield.

And there is supposed to be a whole of government response to contamination taking place. How has all of this extra emission of dust and antimony and arsenic been accounted for in that very important exercise?

Recall the SEPP and its specific instructions regarding antimony.

The farmers in Costerfield grow food for people to eat.