It's Not An Evaporation Facility Yet... Or Is It?

The unbelievable continues.

In around a week's time the 5 km of plastic pipe line that connects the two separate mining licenses thus magically transforming them into a single mine site, will be connected. The mine is then to be allowed to flood the still unconstructed evaporation facility.

This is a totally new proposal. In four days of VCAT hearings no such proposal was mentioned.

Seems like it's a new idea that's just occurred to everyone.

The Work Plan approved on 6 October 2014 had this to say at section 4.3 Construction about the conditioning of the clays :

Water cart (filled with groundwater from the Augusta Mine) will be used to suppress dust and condition the clay and soil

And this regarding the purpose of the pipe line in section 4.5 Operations

Groundwater shall be pumped from a tank or dam at the Augusta Evaporation Facility to the Splitters Creek Evaporation Facility on an as needed basis, in order to optimise evaporation rates and maintain sustainable mine dewatering rates...

and at section 6.7 Air Quality

Water will be pumped to fill the Storage Dam and all terraces on commissioning. 

A water cart shall be utilised during construction to prevent dust emissions. High wind conditions may require certain construction activities to cease where dust emissions cannot be adequately controlled.

Water is to be pumped to fill them ON COMMISSIONING... not to condition the soil, not to suppress dust... ON COMMISSIONING in order to "maintain evaporation rates and maintain sustainable mine dewatering rates"...

The recent ERC meeting minutes record that

After the pipeline is installed and operational water will not need to be trucked out to the site traffic will reduce (p. 6).

Dust suppression for Splitters Creek has used storm water from Brunswick tailings dam. The permit allows the use of mine water for conditioning of the clay which will be used in future and piped in from the pipeline currently being constructed (p. 4).

The "permit allows for the use of mine water to condition the clay" but the work plan says it is to be done by the use of (a) water cart(s).

Why the change of details? Has a Work Plan Variation been approved? If so, why?

Aaahhh, perhaps because there is also this on page 3 of those minutes...

As the maximum throughput [for the Reverse Osmosis plant] has not yet been reached, water management is still tight and construction of the new Splitters Creek evaporation facility will aid water storage but not available till mid-February.

Wrong!

This is exactly what is happening right now. The mine is about to be allowed to use the unconstructed evaporation facility as if it were completed in order to allow the unconstructed permeable clay-lined terraces to "aid water storage" for a mine that the regulators have permitted to extract more groundwater than it can cope with.

That is, DSDBI, EPA, G-MW, CoGB have given the go ahead for the still-to-be-constructed evaporation facility to serve as an ersatz water storage and evaporation facility by allowing the terraces to be flooded. This is ostensibly to "condition" the clays. But that was to be done, according to the work plan - in section 4.3 above - by the use of water cart(s).

The reason the clays need to be conditioned is so that the terraces and terminal dam achieve an impermeability of not greater than 10-9 m/s (the rate at which water can flow through). This is done so that the toxic groundwater may be stored safely and not enter the aquifer through the terrace walls during the evaporation process and contaminate the water. The toxic material in this water kills vegetation and drives wildlife away (if it doesn't kill them, too).

This toxic mine water contains high levels of heavy metals and so when the evaporation facility has performed its function it must be capped and sealed for all time so that the deadly elements and chemicals do not enter the environment. 

The VCAT members were so concerned about this issue on behalf of the objecting residents (concerned themselves about the future of their chemical-free farm) that they imposed the addition of a high-density polyethylene (HDPE) liner in the terminal dam to stop contamination of the aquifer and the soils below the facility.

This precautionary measure, instituted in the VCAT decision, will be all but destroyed (along with the aquifer and neighbouring property's soils) if water is allowed to be flooded into the terraces and terminal dam.
 
Water will be pumped to fill the storage dam and all terraces on commissioning.

This is the sign placed on the Heathcote Pit regarding the same water. Toxic water. Category A Industrial Waste.

Did the EPA-Appointed Environmental Auditor recommend this? The work plan was current on the day before construction commenced on Lot 2 and it would not appear that a work plan variation had been lodged by the time of the ERC Meeting.

When (and it is when, not if) this water contaminates the soil below the terraces and the dam, it will prevent any future leakage from the facility from being identified - it will always be capable of being claimed that such leakage is merely contamination caused by the initial clay "conditioning".

Just you wait and see! This sort of thing has happened before.