Please Advise the Costerfield Community, Dr Pigdon

We commit to making any response from the Regulators 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.

On Thursday 8 January, 2014, pressure testing of the 5km pipeline that EPA approved to carry untreated toxic waste water from the mine site to Lot 2. This pipeline apparently means that this toxic waste water doesn't leave the mine site.

According to the Mayor, this water was to be flood irrigated into the terraces, effectively turning Lot 2 into an evaporation pond/storage dam months before it was completed.Residents were concerned about the leaking of this water through the soils and into the groundwater and from their into the creeks and surface waters. Flood irrigation is not proceeding.

Instead, this toxic waste water - disingenuously referred to as "groundwater" in the Work Plan - is to be pumped 5km to a holding dam onsite and from there, distributed about the 30+ hectares of construction by water cart. This is to be done in order to "condition" the clay to enable permeability conditions for the terraces and terminal dam to be met.

This is, however, actually a further measure to facilitate the mine in disposing of toxic waste water that it has been allowed to over-accumulate by the regulatory authorities. It is also a discharge of highly toxic heavy metals and other materials directly into the Costerfield environment.

[* 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.]

And so we have some questions for the EPA Officer who has had a special relationship with this project and this toxic groundwater for some time.

We ask similar questions of the DSDBI's Manager Operations North West Region, Mr Colin Thornton, here.

***

Dear Dr Scott Pigdon,

Please advise the Costerfield Community where it may obtain a copy of the latest PAN your office has issued with regards to the discharge of heavy metal-laced toxic groundwater - hazardous mine water; Category A Prescribed Industrial waste - to the soils and clays of Lot 2 South Costerfield-Graytown Rd supposedly to enable the “conditioning” of the terraces and terminal dam of the proposed Splitters Creek Evaporation Facility.

Please advise the Costerfield Community how much of this toxic waste water is to be discharged into the Costerfield environment via water cart for this "purpose" and please then advise how much antimony, arsenic, boron, barium, cadmium, cobalt, chromium, copper, lead, manganese, nickel, selenium, tin and zinc are to be discharged along with it.

Please advise the Costerfield Community what volume of water is to be used for this so-called "conditioning" and how the level of emissions to water reportable to the National Pollutant Inventory is to be calculated.

(Please advise the Costerfield Community that you are aware that Mandalay Resources reported its emissions figures to the Commonwealth's National Pollutant Inventory (NPI) and that these figures show emissions of 1,400 kg of antimony, 4.7 kg of arsenic and 7,300 kg (6,200 kg fugitive and 1,000 kg point) of PM10 particulates (at a rate of 0.84 kg/hour, 24/7) to the Costerfield air.

Please advise the Costerfield Community that you are aware that these figures represent enough antimony to pollute over 82 billion cubic metres of air to the EPA limit of 0.017 mg/cubic metre, enough arsenic to pollute 27 million cubic metres to the EPA limit of 0.00017 mg/cubic metre, and enough PM10 particulates to pollute 91 billion cubic metres of air to the EPA limit of 0.080 mg/cubic metre.

Please advise the Costerfield Community that these figures were produced prior to the mine's increased production rates and expansion into the Cuffley Lode and prior to the operation of the new crusher.)

Please advise the Costerfield Community that this toxic waste water is not permitted to be sprayed along the roadsides, is not permitted to be employed for dust suppression purposes, is not permitted to be sprayed by evaporative sprayers, requires a Pollution Abatement Notice (PAN) for discharge into Hirds Pit which must then bear a "Health Hazard - Mine Water" sign,  but is environmentally sound and not requiring of a PAN when it is sprayed about Lot 2 and thus into the surface and groundwaters of the Wappentake Valley. Please advise why this is so.

Please advise the Costerfield Community why no mention is made of the use of this toxic  mine water for these purposes in the CoGB Planning Permit or the VCAT decision, yet its specific use has been incorporated in the Work Plan by DSDBI.

Please advise the Costerfield Community where it may find information on the use of antimony-laden toxic waste water as a best practice component of clay conditioning for clays and soils.

Please advise the Costerfield Community that you will immediately provide it with all documentation completed by EPA that permits this obvious discharge to the environment.

Please advise the Costerfield Community that the spraying of toxic groundwater/mine water/Category A Prescribed Waste is an accepted and environmentally sound method for the conditioning of the soils and clays. That it is best practice.

Please advise the Costerfield Community that you will immediately require Mandalay Resources to desist in this obvious attempt to dispose of this heavy metal-laden toxic groundwater/hazardous mine water/Category A Prescribed Waste, which you and your Department have allowed to over-accumulate, into the Costerfield soils and groundwaters.

Please advise the Costerfield Community that you will immediately consult with DSDBI's Mr Colin Thornton to set in train the process whereby Mandalay Resources are required to employ fresh water (from the Heathcote standing pipe or elsewhere), and soil and clay conditioning compounds of acceptable composition and quality, for the desired purpose. 

And while you're at it please advise the Costerfield Community that you will immediately forward to them a copy of the notice to the EPA by the site Auditor under s53Z(b) of the EPA Act 1970 that demonstrates that the EPA-Appointed Auditor has been legally appointed.

The Costerfield Community awaits your very prompt reply.