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.

 

And then there is this from EPA Victoria's A Guide to the Sampling and Analysis of Air Emissions and Air Quality:

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.