Please Advise the Costerfield Community Mr Thornton

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 commences 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.

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 there 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 5 km to a holding dam onsite and, from there, distributed about the 30+ hectares of construction site by water cart where it will seep through the soils and into the groundwater that lies only metres below the surface and from there into the creeks and surface waters. This is to be done in order to supposedly "condition" the clay to enable impermeability conditions for the terraces and terminal dam to be met.

This is, however, merely 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 DSDBI Officer who has had a special relationship with this project and this toxic groundwater for some time.

We ask similar questions of the EPA's General Manager North West, Dr Scott Pigdon, here.

 ***

Dear Mr Colin Thornton

Please advise the Costerfield Community that the Work Plan is being strictly adhered to at the Splitters Creek Evaporative Facility construction site and that you are aware that the ERRV/DSDBI Conditions include

Please advise the Costerfield Community that you are aware of the primacy by Royal Assent of the EPA ACT 1970 over any other legislation as per the original, and the most recently ratified iterations of that Act.

Please advise the Costerfield Community that, accordingly, the phrase “with due consideration to the EPA SEPPs (especially Air Quality Management) dust and noise controls” to be found in the Work Plan actually means, for DSDBI, “in full accordance with the EPA SEPPs (especially Air Quality Management) dust and noise controls”.

Please advise the Costerfield Community that the process DSDBI is following is in full accordance with the EPA SEPP (AQM) prescriptions, “especially” those regarding the Class 3 Indicators “arsenic compounds” and “silica” at the Splitters Creek Evaporation Facility construction site and also regarding the stated intent of Maximum Effect Achievable. If not why not? Please provide evidence to support your position.

(Please advise the Costerfield Community that you are aware that Mandalay Resources reported its emissions figures to the Commonwealth's National Pollutant Inventory 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/hr, 24/7), to the Costerfield environment.

[The most recent figures to "appear" on the NPI site show a doubling of PM10 particulates and now display PM2.5 figures of 1.4 tonnes. It is interesting to note all of the new "Cleaner Production Activities" and "Pollution Control Devices" that have been purchased and instituted since the previous figures were released...]

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 you are more familiar with dust in the environment and "especially" particulate dust than you have displayed previously.)

Please advise the Costerfield Community that the process DSDBI is following regarding noise is in full accordance with the EPA SEPP N-1 and EPA NIRV. If it is not why not? Please provide evidence to support your position.

Please advise the Costerfield Community that the process DSDBI is following is in full accordance with the EPA SEPP (Groundwaters). If it is not why not? Please provide evidence to support your position.

Please advise the Costerfield Community that the process DSDBI is following is in full accordance with the EPA SEPP (Surface waters). If it is not why not? Please provide evidence to support your position.

Please advise the Costerfield Community what volume of water is to be used sprayed for this so-called "conditioning" and how the level of NPI reportable emissions to the environment is being calculated. 

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 WHY it is that you, that is DSDBI, have stipulated and specified in the Work Plan that this toxic mine water, which is disingenuously referred to as "groundwater from the Augusta mine", but which is so toxic that it requires an EPA Pollution Abatement Notice and the posting of a Hazardous Water sign at Hirds Pit, which is so toxic it is not permitted to be sprayed along the South Costerfield-Graytown Road, which is so toxic it is not permitted to be employed for evaporative spraying and which is so toxic it is not permitted to be employed for dust suppression, may be sprayed upon the soils and clays and from there, potentially enter the surface and groundwaters - the aquifer system - at the Splitters Creek Evaporation Facility construction site.

Please advise the Costerfield Community that this hazardous mine water - this toxic waste water; this Category A Prescribed Industrial Waste - is the most suitable medium for clay and soil conditioning at the Splitters Creek Evaporation Facility construction site and that antimony-laden water application is recognised best practice for this purpose. Please provide evidence to support your position.

Please advise the Costerfield Community that this toxic groundwater is not being allowed to be pumped to the Splitters Creek Evaporation Facility construction site for the sole purpose of facilitating the mine in disposing of toxic groundwater that you, ahem, DSDBI have allowed to be “regulated” such that it has accumulated to an excessive volume. Please provide evidence to support your position.

Please advise the Costerfield Community that you are aware of the toxicity of the mine water - it has 25 mg/litre of antimony, >140ug/litre of arsenic and smaller concentrations of boron, barium, cadmium, chromium, copper, lead, manganese, nickel, selenium, tin and zinc - and that even in light of all of the above, you and your Department are quite prepared to accept full legal, environmental, social and moral responsibilities for the use of this hazardous toxic mine water to “condition” the soils and clays of the Splitters Creek Evaporative Facility construction site should any adverse outcome eventuate, be it with the physical health of any Costerfield residents, irreversible damage to the environment, or the loss of amenity, income or property value to any individual or business, caused by the application of this toxic water under your supervision.



Please advise the Costerfield Community that you will immediately require Mandalay Resources to desist in this obvious attempt to dispose of this 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 EPA's Dr Scott Pigdon 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. 

Oh and while you're at it, please advise the Costerfield Community that categorically NO blasting of any kind - no use of any explosives - has been conducted at any time* at Lots 1 or 2 during the construction of the Splitters Creek Evaporation Facility.

The Costerfield Community awaits your prompt reply.

Edit: No reply of course. But when there's a fire in a mine that has been subject to this much scrutiny, it's a wise course of action to inform the Minister immediately. Otherwise you end up doing a different job...


*We were assured by a Department of Health officer that no blasting took place. We're still not sure whether to believe him. He has a track record.