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

Thursday, 25 September 2014

AS3580 at Costerfield



ERC Meeting
13 May 2010
Dust: B*** commented that in March there was a huge dust storm but was astounded that the dust measurement recorded the lowest ever dust recording. Explained that the organic matter is burned off. B*** not happy with the current measuring system. Explained that it is an Australian Standard measurement System. Scott Sandercock explained that there are probably other systems overseas but we use Australian Standard Systems here. B*** not happy with it and suggested that EPA should look at it. B*** questioned EPA if the system that AGD Operations has in place is set up correctly. 

Olivia assured EPA that the system meets Australian Standard. Olivia agreed with G** that more sites need to be around the mine area as some are too far away and is in process of getting them relocated. Olivia outlined that further weather station quotes need to be obtained and research on which is the most suitable for this site, but as yet has not had time.

Bob Disken stated that AGD Operations dust monitoring program is compliant. B** expressed his disappointment with government departments excepting [sic: accepting] an empty wine flagon and funnel is an appropriate measurement system. Bob Disken commented that until the standard changes the company is complying. B*** asked who sets the standards. Travis StClair will find out who sets the standard so that B** can take it up with them
 
The application of the standards has been an issue for quite a while, now, as this article from Waste Management and Environment Magazine dated 6 September, 2007, shows.
 
The application of Australian Standards 3580 Dust Deposition gauge at Costerfield.










For those suspicious people among you who think that the ludicrous funnel at the top may have been tipped by the photographer, have a look another look at this piece of equipment, leaving all that deposited dust unaccounted for...



What a disgrace. Still waiting on weather monitoring station quotes, too.

They could have gone to somewhere like compliancemonitoring.com.au one would have thought. These people look like they have a range of products purpose-built to meet the standards; lots of aspects of the standard, too.

And they're an Australian company.

Who's doing the monitoring now?

And another Australian company Getex handily summarises some of the basic requirements that it includes in the AS3580 compliant equipment it provides:




What is a Dust Deposit Gauge?
 
A deposit gauge consists of a 150 ±10mm diameter funnel supported firmly by a glass bottle which has a minimum volume of 4 litres. The funnel is supported using a rubber stopper with a groove to allow water overflow under excessive rainfall conditions.

A stand supports the deposit gauge such that the top of the funnel is 2 ±0.2m above ground level. The stand generally incorporates a container to protect the bottle contents from sunlight which may accelerate algae growth. The stand must be sufficiently sturdy to prevent any movement during high winds and to ensure the top of the funnel remains in the horizontal position. 
 ***
The manufacturers of compliant equipment know their products' shortcomings:

However, their disadvantage is they do not provide data on a day by day basis, information on dust concentrations, nor relate dust levels to wind direction or particular events. If there is a major dust problem it will not be known until the end of the monthly cycle.  

High volume samplers
 
Equipment such as High Volume Samplers (or TSP High Volume Samplers) can provide day by day data (an average dust concentration taken over a 24-hour period) and Continuous Particle Monitors can provide real – time data. Matched with event data and wind activity, Continuous Particle Monitors offer a real advance over other methods in managing certain sites, activities and dust emissions. Further advice on these items can be obtained from your GETEX consultant.    


The observant reader will note that the information supplied above is sourced from a page over 5 years old... 27 February, 2009.

Industry groups have known about the reluctance of the regulators to enter the 21st century for quite a while now, as this article from Waste Management and Environment magazine from 2007 makes plain.  

While we have already praised the foresight of the builders of the top-pictured equipment for including a wind-direction gauge (see the lean on the gaffer-taped plastic funnel? That's the way the wind blows! Let the dust fall where it may...), we note that usual AS3580 compliant equipment does not include provisions for wind speed and direction data collection.

And when you want to know if the dust is coming from a particular place, say a mine, then wind speed and direction would be handy things to know.

Perhaps a weather station could help with that...










Tuesday, 23 September 2014

No Rainfall Water Balance


No wonder they can't get things right out there.

This site water balance produced by the mine does not include figures for the rainfall expected to fall across the site. Calculations made by residents put this figure at an extra 25ML for the mine to deal with, thus changing all of the figures in the three columns to the far right that have been marked with asterisks.

The regulators didn't pick this up.
  

 




Uncontrolled Release of Tailings

Uncontrolled Release of Tailings  

DSDBI says "Leave spill in the bush. Clean up the roads."


From the AGD ERC Meeting Minutes, Quarter 2, 2009:


W** [AGD] explained that on Thursday 3rd September at ~7:45 there was an uncontrolled release of tailings where the tailings line had come apart. This resulted in tailings overflowing from the trench and into surrounding vegetation, covering approximately one hectare. W** noted that he had instructed his staff to shut down the tailings system immediately. DPI was informed and inspected the spill with DSE and EPA; recommendations were then developed by all three regulators. Two samples of the spill were taken and sent off for analysis of gold, stignite [sic: stibnite], arsenic and cyanide. Cyanide levels were lower than those possible of detection; as a result DSE advised to leave the spill material amongst vegetation and to clean up the roadways with loaders.

W** explained that the pipe burst due to a failure of the pressure warning system. B**
[DSDBI] noted that the problem was exacerbated by blocked channel pipes which should have directed the released tailings from the trench into the Bombay dam; instead it filled the trench and then flowed over the bund walls. EPA is still investigating the issue.

***

"[R]ecommendations were then developed by all three regulators"... sounds hopeful; something comprehensive's gonna be done in follow up, what with three highly qualified regulators on the job. What were their recommendations again?

Oh... right... leave it in the bush and clean up the road with 'delicate spill mitigation equipment', no doubt, (oh...sorry, that's right. Loaders!). Don't want to inconvenience the trucks. Hang on! "Roadways"... seriously, how big was this spill?

"Cyanide levels were lower than those possible of detection; as a result..." Hang on a sec! What about the levels of "gold, stignite [and] arsenic" that were tested for? Of cadmium and lead that weren't? Obviously the gold levels were low or they'd have dug it up again! And it's a safe bet they didn't find any stignite in there, either... ;)

  • What about the rest of the stuff? 
  • Why was cyanide the defining measurement ("as a result")? 
  • Where was the contaminated material taken? 
  • What were contamination levels on the road after the "clean up"? Now? 
  • What are the contamination levels in the "vegetation" now?

If I light an incinerator and burn household waste in my backyard I get fined. No second or third chances. No excuses.

If I speed and get caught I get fined. No second or third chances. No excuses.

Fines are a great way to create better businesses, according to the EPA - Fine creates better business.

Was a fine issued to AGD for this oxymoronic, ahem, "uncontrolled release"? 

(The euphemisms these people use... "ponds", "uncontrolled release"...)

For this environmental breach?
For this spill?
For this pollution?
If so, how much?
If not, why not, EPA? DSDBI? DPI? DSE?

"EPA is still investigating."
Can we see the reports?


The pumping system is going to be upgraded as part of the new extensions to the Bombay Tailings Storage Facility, isn't it? Part of the Permit? Another Work Plan Variation? The pressure release valves brought in to replace this failed system will still "release uncontrollably" the contents of the length of pipe they monitor should there be a breach, right? However long the pipe may be? Is that good enough?

What is world's absolute best practice for all of this? We're Australians, we'll take one of those, please.

In the Minutes for the ERC Meeting for Quarter 3 2009, a DSDBI Officer "noted that the temporary permit to pump into the Brunswick TSF does not exist anymore".

Can we see the new/subsequent permit or permits?







Public Health Information Bulletin - June 1998

This is a transcription of the Public Health Information Bulletin, dated June 1998. A copy in pdf format is available here.

Why is arsenic not even mentioned by DNRE in the recent Costerfield Update? Arsenic is far more toxic than antimony and it has been advanced that some of the problems usually associated with antimony poisoning may in fact be explained by arsenic.

"Some soils in Costerfield are likely to naturally contain raised levels of antimony."

Does this repeatedly qualified statement from the report below sound familiar? It should. It is the same excuse used in 2014 for the high levels of antimony in the area.

Does it reek of scientific uncertainty to you? It should... "some", "are likely", "raised"... these are all indications that something is very much less than certain... they are admissions of ignorance; otherwise why not tell us the facts? Which soils, where and by how much? Farmers are pretty good at understanding information about their soils.

Do my or my neighbours' soils contain "raised levels of antimony"?

Has the Department of Health tested them?

What information - gleaned from sixteen years of study and more into the Costerfield situation - can the Department of Health provide regarding the particular soil on particular properties that enables it to dismiss out of hand the impact of the mine and place the onus squarely on historical mining activities for the elevated readings in Costerfield water tanks? Sixteen years later...


Has the World Health Organization 2004 recommendation that, when arsenic and antimony are found in the same geology, examinations of synergistic and additive affects be conducted, been followed by the Department of Health?

It  certainly would not appear so. Who among the Costerfield community have the Department of Health contacted regarding these examinations for the purpose of taking of further samples?

Remember, the Bulletin below is from all the way back in 1998... they've had over sixteen years to prepare for and deal with this "health issue".

How much more do the people of Costerfield know, sixteen years later?

***
June 1998



Public Health Information Bulletin for the residents of Costerfield

This bulletin provides information on:

  • ·        the results of investigations of antimony and arsenic levels in Costerfield
  • ·        possible health risks associated with exposure to these substances.
  • ·        actions that are being taken.
  • ·        steps that can be taken to reduce exposure to you or your family and reduce any health risk.


Background
Over the past few years a number of concerns have been raised by the community in relation to proposed mining activities in Costerfield. One of these concerns was the possibility of wind blown dust contaminating rain water tanks. Other concerns have been raised in relation to possible health effects from tailings material left behind from mining going back to the 1860s.

Gold and antimony have been mined sporadically at Costerfield since the 1860s. Antimony is a substance that can be found naturally in gold deposits in certain geographical areas. Some soils in Costerfield are likely to naturally contain raised levels of antimony.

Arsenic is a substance that is also found naturally in rock, often near gold deposits. It is commonly found in mine tailings and mullock. Tailings are crushed rock that is left after gold is extracted while mullock is the coarse rock that is left behind after the gold is dug up. Arsenic is more widely spread than antimony and is found in mine tailings and mullock spread over large areas of central Victoria.

Result of Investigations
For several months, rainwater tanks at homes in Costerfield have been tested for any signs of arsenic contamination. Over the past month, water in these tanks and some soils (and mullock) in the area have also been checked for arsenic and antimony.

Water samples
Arsenic: Most water samples have shown levels of arsenic that were well below the current drinking water guideline of 7 parts per billion. As a few water samples tested by private consultants were above this value, the Department of Human Services (DHS) performed additional sampling to check these results. All samples checked by DHS for arsenic were well below the current guideline.

Antimony: Rain water samples from household tanks detected antimony levels between 2 and 15 parts per billion. These levels are slightly above the Australian Drinking Water Guideline for antimony of 3 parts per billion. However, only some were above the comparable guideline set by the World Health Organisation and the standard set by the US Environmental Protection Agency.

Soil samples
There has been some very limited recent testing of soil and mullock in Costerfield for arsenic and antimony. [Compare this with the Ministers 1998 Letter from just three months later where it is declared that "prudent" etc etc]

Arsenic: This testing found arsenic levels between 350 and 750 parts per million parts of soil.

Antimony: Levels of antimony were between 1000 and 28000 parts per million.

From tests that have been taken in the past, we know that levels of arsenic and antimony in surface soils and tailings around Costerfield may be higher in some areas.

[Can we see the results of these tests?]

Are these levels of arsenic a risk to health?
Arsenic has been shown to be associated with health effects in people who have taken high or moderate amounts and the health effects are related to the amount of arsenic that people breathe or swallow.

Based on the results that we have, DHS considers that:

  • ·        the level of arsenic in water is not a risk to health
  • ·        the concentrations of arsenic in soil would generally be a very low risk to adults but may be a greater risk to children if they eat or play in soil with high levels of arsenic.

 A pamphlet, Arsenic And Health: Are You Living In An Area With Mine Tailings?, is attached., This pamphlet discusses arsenic in mine tailings and ways of reducing exposure and any health risk.

Taking these steps will also reduce any health risk from arsenic in soil or dust that contain high levels of arsenic.

Are these levels of antimony a risk to health?
There is very little information on the health effects of antimony, apart from health effects of people breathing in high doses of antimony at work. Nearly all of the other information we have is from studies in animals. We have attached an information sheet that discusses what is known about exposure to antimony and health effects.

Based on studies in rats, a ‘safe level’ of antimony has been calculated. This is a level that could be taken into the body every day for long periods of time without causing health effects. Many safety factors are used to set this level. The ‘safe level’ has been used to set a guideline value for water, with even more safety factors.

Levels in water:
Levels of antimony found in rain water tanks in homes in Costerfield are only slightly above the guideline for water. DHS believes that the levels in drinking water may be a very low risk for adults, if any. However these levels may be a greater risk for children, especially if they swallow dust or soil that contains high levels of antimony.

·        Based on current information, DHS recommends that adults in Costerfield should not drink water with antimony exceeding the current Australian Drinking Water Guideline of 3 parts per billion. Young children in Costerfield should not drink water containing detectable levels of antimony.

·        However , DHS considers that the levels of antimony that have been found in drinking water are generally not a risk for cleaning teeth, washing dishes, showering, bathing, washing clothes, watering vegetables or other domestic purposes.

As levels of antimony in surface waters in creeks and dams may be much higher, it may not be suitable to use these waters for the domestic purposes that are mentioned above.

Levels in soil:
Based on the limited information available, it is considered that levels of antimony in the soil in some areas of Costerfield may be a health risk, especially for children who swallow larger amounts of soil than adults do. However, there are a number of uncertainties. There is little information on the levels of antimony (and arsenic) in soils on private properties in Costerfield. It is not known how easily antimony is absorbed by the human body and whether it causes health effects in people when swallowed in small amounts over long periods of time.

·        The attached leaflet, Antimony and Health, discusses ways of reducing exposure to antimony in soil, and therefore, reducing any health risk.

Levels in dust:
People can absorb substances from dust by breathing dust in or swallowing dust on their hands or their food. It is not known how much antimony or arsenic is in dust in Costerfield but it is likely to be related to the amounts of antimony in soil in the area. As children often put their fingers and hands in their mouths, they are likely to swallow more dust than adults do.

·        See attached leaflet on antimony for measure to reduce exposure from soil and dust.

What actions can I take to reduce the health risk?
The attached pamphlet, Arsenic And Health: Are You Living In An Area With Mine Tailings and the leaflet Antimony and Health: Public health information sheet for residents of Costerfield, discuss ways of reducing exposure to antimony and arsenic in soil and dust and reducing any health risk.

What actions are being taken by others?
The Department of Human Services (DHS), the City of Greater Bendigo Council, the Department of natural Resources and Environment (DNRE), and the Environment Protection Authority (EPA) will work with Australian Gold Development to develop a strategy for supplying water to residents in the Costerfield area who are at risk of having raised levels of antimony in their rain water supplies, from dust emissions in the area.

In the meantime (as an interim measure) Australian Gold Development has offered to provide bottled water for cooking and drinking to those Costerfield residents where testing has shown that water quality does not meet current Australian Drinking Water Guidelines. The company will also supply water to other concerned residents, close to the Costerfield area, especially those with children, until it is determined which residential properties are or could be affected.

The company has taken this action to assist in the management of any possible health effects from local drinking water. The company will notify people of this by letter.

Dust
DNRE are undertaking a comprehensive review of dust suppression measures to be implemented in any mining development to make sure that current problems are not made worse.

DNRE are also looking at any possible sources of current dust (for example tailings dumps, [link to McLennan Letter - so the locals do know what's going on, eh?] construction activities) to see if any further measures can be taken to minimise the amount of dust in the area.

Soil
DNRE is currently getting information on all soil sampling that has been undertaken in the Costerfield township area to determine the levels of antimony that are present in these soils. After this is done further sampling may be needed to estimate the exposure of residents to antimony.

[Can we see the reports?]

***

But then the mine closed, didn't it?

What are we supposed to believe that this indicates about the "estimate [of] the exposure of residents to antimony"?

There are specific references to antimony in water tanks in the EPA's SEPP AQM for goodness' sake!