Committee Secretary Senate Standing Committee on Environment and Communications PO Box 6100 Parliament House Canberra ACT 2600
Dear Committee Secretary and Members
Re: The adequacy of the regulatory framework governing water use by the extractive industry.
Thank you for the opportunity to make a submission to this important inquiry
Introduction and overview
The Conservation Council of WA is the State's leading environmental group representing over 100 local environment groups.
We believe there is a lack of clear responsibility for regulating impacts on water quality, a lack of rigor and consistency in protecting the quality and availability of water resources, and a lack of strategic policy in the allocation of water resources at a state level here in Western Australia. As a result, our water resources are being placed at risk by the activities of extractive industries including mining and petroleum developments.
Water allocation Water allocation in Western Australia is done on a ‘first come, first served’ basis, and there is no current provision for statutory water allocation plans to be put in place. As a consequence, many groundwater areas have no strategic management framework or objectives to guide allocation decisions, regional groundwater studies are often not undertaken before allocation decisions are made, sustainable yields are not well understood, and planning for future water resource demands is not a feature of allocation decisions. Protection of water quality The regulatory regime applied in Western Australia for the protection of groundwater water quality is in our view inadequate for the maintenance of environmental values and the protection of human health. There is no single agency or regulator responsible for the setting and enforcing of groundwater quality standards or protections. Such protections are given effect through a multitude of different legislative and regulatory instruments, administered by a number of different agencies. As a result the protection of groundwater quality from impacts by extractive industries is highly variable.
Regulatory conditions for groundwater protection from threats by extractive industries are typically established through the requirements for licensing under the Environmental Protection Act; through Ministerial Conditions following Environmental Impact Assessment; under the Petroleum and Geothermal Resources legislation; under the Mining Act; under the Rights in Water and Irrigation Act; or through Management Plans or other subsidiary and delegated approvals required by one or more of the agencies responsible for administering these pieces of legislation. This complexity makes it very difficult to ascertain what standards or policies are being applied in different situations, and the lack of transparency under a number of these agencies and jurisdictions makes it impossible for the public to understand which regulator is responsible, and which standards are being applied for water quality protection.
Where they are gazetted, Public Drinking Water Supply Areas provide a level of protection by informing a rigorous approach to risk assessment linked to specific numerical water quality values. However these areas are often very small, and take on arbitrary boundaries (such as property boundaries) that do not align to the physical or hydrological extent or nature of the resource to be protected. As a result we have seen high risk extractive activities such as petroleum drilling and fracking approved within the recharge zones and catchment areas of borefields supplying public drinking water, and within very close proximity to the proclaimed Public Drinking Water Supply Areas.
The majority of extractive industries operate outside of Public Drinking Water Supply Areas, however this does not mean that the groundwater is not being used for drinking and stock watering. Indeed in large areas across the state, groundwater is the primary or only source of drinking and stock water, and is critical for the survival of communities, including Aboriginal communities. The location of many (if not the majority) of abstraction points or natural expressions of groundwater used for drinking in these areas (bores, wells, waterholes) are not known to regulators, making it difficult or impossible for them to properly provide for the protection of these resources when making regulatory decisions.
Water quality protections and standards applied outside the Public Drinking Water Supply Areas appears to be highly variable.
Advice from the relevant WA Government agencies is that the Guidelines for Groundwater Quality Protection in Australia provide the policy framework for assessing risk, determining standards, and therefore setting protection measures for groundwater in WA.
However these guidelines provide almost complete discretion for state regulators in setting numerical standards for permissible water quality impacts.
The following statements are direct quotes from the guidelines:
There are currently no water quality guidelines for Groundwater Dependent Ecosystems (GDEs) ‘that rely on the subsurface presence of groundwater’ (i.e. vegetation). In setting water quality objectives to protect these GDEs, parameters that are important for vegetation health should be considered, such as nitrogen, phosphorus, organic carbon, metals, salinity, dissolved oxygen and pH.
There are currently no specified water quality guideline values for protection of cultural and spiritual or industrial water use
Even where generic guideline values are available in NWQMS documents, water quality objectives may be locally defined to consider water quality issues specific to the groundwater system in question. This enables existing water quality, community values, potential and future uses to be considered within water quality objectives.
When it comes down to it, the Guidelines provide that groundwater protection standards for areas outside of drinking water protection zones are to be determined by local regulators taking into account a range of factors as they see fit, including existing and future potential uses of the water resources, as well as other matters such as economic considerations. In practice this means that there are no consistent groundwater quality protection standards that across the State, and regulators can ‘make it up as they go along’.
The most frequent way that this has been applied by WA regulators (especially for extractive industries under the Petroleum and Mining legislation) has been to apply ‘As Low As Reasonably Practicable’ (ALARP) as the guiding principle for setting standards for groundwater protection.
This ALARP principle bears no relationship whatsoever to the maintenance of ecological processes or protection of human health. It is entirely a construct of what is possible to achieve within a certain budget volunteered by a proponent. In our view this is deeply inadequate and flawed as a basis for setting regulatory conditions for the protection of water as a publicly owned asset.
Water use and uranium mining in WA Uranium mining and processing and the associated disposal of waste products presents significant and long-term threats to groundwater and surface water quality. In addition, uranium processing uses very large amounts of water. The regulation of threats to water resources and how they are managed in uranium projects therefore provides a useful perspective on these issues more generally.
Over the last eight years the CCWA has tracked and responded to every stage of the assessment of four proposed uranium mine developments in WA. This process led us to identify unique problems at each site relating to water consumption and risks of contamination that highlight broader deficiencies in the regulatory framework.
Uranium mines are assessed under the EPBC Act as a nuclear action. It is instructive to look at the conditions set by the Federal Government for these mines on factors like water where there is a clear threat but no clear protections in place. In some cases the Commonwealth conditions applied to these projects for the protection of water resources have been significantly different (stronger) than state conditions, whereas in other cases the conditions have mirrored state conditions or have been absent altogether. Conditions set by different Ministers for different project are inconsistent over time, and and are not always applied, or enforced.
The WA Department of Water and Environmental Regulation has regional water allocation plans that identify existing users, demands, threats and presents some vision for future management. All four of WAs proposed uranium mines, Wiluna, Kintyre Yeelirrie and Mulga Rock, are in areas that do not have a water allocation plan, and none of these areas is within or near a Public Drinking Water Supply Area, even though water near several of these proposals is used for drinking, stock watering and cultural purposes.
There are existing regional water allocation plans for the following regions:
● The NorthWest - including plans for the Ord, La Grange, Skuthorpe and Pilbara ● The Mid-West & Gascoyne - including plans for Carnarvon, Lower Gascoyne, Arrowsmith and Jurien. ● The Swan Avon - including Gingin, Gnangara and Middle Canning ● The Kwinnana Peel - including Cockburn, Rockingham - Stakehill, Murray and Peel ● The South West - including Kemerton, Lower Collie, Upper Collie, South West, Whicher and Warren-Donnelly ● The South Coast - including Esperance
Some of the state's major extractive regions and the regions where there are four proposed mines, like the Goldfields, East Murchison and East Pilbara region, do not have a current water allocation plan. Existing plans for other regions have many gaps - some plans only plan for surface water or groundwater but not both and with all allocation plans the focus is on allocation of water resources but does not delve into water quality and threats to quality.
In the East Murchison/Northern Goldfields there are two proposed uranium mines - Toro’s Wiluna uranium mine and Cameco’s Yeelirrie uranium mine. Also in that region are ooperating mines like:
Jundee Gold - 45km North East of Wiluna Rosslyn Hill Mining - 30km West of Wiluna Mount Keith Nickel Mine – 85km South East of Wiluna Bronzewing Gold Mine – 165 km South of Wiluna Wiluna West Iron Ore Project 40km West of Wiluna Matilda Gold Project – 5km East of Wiluna
The Magellan lead and Gidgee gold mines are also in close proximity but are in care and maintenance - there are potentially other mine sites in care and maintenance close by.
A study conducted by the Mid West Development Commission raised a number of regional issues from this level of mining activity. The study was not able to identify accurate figures for water consumption from each mine or the different aquifers that are being used in the region. We have heard reports from pastoralists that some of the bores on Albion Downs station have dried up and water quality at Yakabindie has seriously declined - it is believed that the impacts on water are related to mining and water consumption.
Without a regional assessment or requirements from mining proponents to look at regional water use, environmental needs for water on a regional scale and long term impacts from sustained water use by mining companies there is no way to clearly understand the long term impact of the extractive industry on water resources.
Recommendation: A comprehensive impact audit of water consumption in the area identifying impacts to water quality introducing long term recovery plans and environmental allocations of water and an assessment of drinking water quality and requirements.
Uranium Projects The Wiluna uranium project, Kintyre uranium project and Mulga Rock uranium project all have State and Federal environmental approval. There are conditions set, by the State Environment Minister, on the approvals that require the following plans for each mine
The Yeelirrie project has State environmental approval but not Federal approval. The State environmental approval has conditions that require the proponent to consult with the Department of Water and the Department of Mines to prepare: ● Hydrological Processes - Survey ● Hydrological Processes - Management ● Surface Water Management and Monitoring Plan ● Groundwater Management and Monitoring Plan
The Kintyre uranium project State approval has no conditions relating to water despite significant threats to the complex Karlamilyi river system which is connected to the two branches of Yandagodgee creek which runs either side of the proposed Kintyre uranium mine.
The Mulga Rock uranium project State approval has conditions that require the proponent to consult with the Department of Water and the Department of Mines to prepare a Groundwater Monitoring and Management Plan.
The Wiluna uranium project State approval has conditions that require the proponent to consult with the Department of Water and the Department of Mines to prepare: ● Surface Water Management Plan ● Groundwater Drawdown Management and Monitoring Plan ● Groundwater Reinjection Management Plan
The Federal approval for the original Wiluna project - open pit mines at Lake Way and Centipede and a processing facility near Centipede - has specific conditions relating to surface water and ground-water which includes the setting of trigger levels, target criteria, compliance criteria and environmental outcomes. These outcomes based regulations were set under the previous Government and former Environment Minister the Hon. Tony Burke.
The Federal approval for the Wiluna Extension - open pit mines at Milipede and Lake Maitland - does not include any conditions relating to water. This approval was granted by the current Federal Environment Minister the Hon. Josh Frydenburg. Minister Frydenburg has also recently given Federal approval for the Mulga Rock uranium mine which has virtually no conditions at all.
The difference in conditions set are stark and highlight that the interpretation of the Act is open to political ideology. This is further demonstrated by looking at conditions set in the Federal approval for the Kintyre uranium mine - assessed by Former Environment Minister the Hon. Greg Hunt which like the conditions set by Hon. Tony Burke also include trigger levels, target criteria, compliance criteria and environmental outcomes.
It is disturbing to see that the most recent set of Federal conditions are weak particularly where it concerns water and where there are shortfalls in the State conditions. There are insufficient protections for water.
Wiluna Uranium Project
During the Public Environment Review of the Wiluna uranium project we identified a number of problems with the proposal with regard to water. The problems outlined below show there has been a low standard of evidence and science in the assessment process, offering little confidence in the capacity and commitment of the proponents to ensure water is protected.
Hydrogeological Studies: The Supply Groundwater Modelling conducted by Aquaterra in 2010 was reviewed by Klohn Crippen Berger (KCB) - Appendix 10.45 to the Public Environment Review of the Wiluna Extension. In this hydrogeological and hydrological report review by KCB - a number of deficiencies are identified with the proponents studies, these are outlined below:
● “Initial calibration results provided a scaled room mean squared error of 13.6%, higher than the accepted 10% error for undeveloped catchments and 5% for developed catchments.” ● “Calibration hydrographs for bores in the West Creek Borefield and the Apex Southern Borefield were presented, however, SRMS error results were not presented.” ● “Steady‐ state calibration results exceed acceptable guideline values when the entire monitoring data set was included as the calibration data set. Removal of monitoring records was required to achieve acceptable model calibration.” ● “Transient calibration results did not include error statistics for the comparison of observed and predicted groundwater levels. Although mass balance results indicated that flow in and out of the model was relatively balanced, the lack of groundwater level calibration statistics indicate possible uncertainty in the calibration.”
In the KCB review of the Bore Completion Report – Millipede Uranium Project conducted by Pennington Scott in 2015 it is revealed that: ● MPD_2P1 – hydraulic conductivity estimate of 5.0 m/d (T = 105 m2/d), based on analysis of constant‐ rate test recovery curve. However, the constant‐ rate test drawdown curve displayed a boundary condition near the end of test which was not incorporated into analysis or discussed during the interpretation. RPS (2015) applied a different hydraulic conductivity value (35 m/d) in the groundwater model than the analysed result of this investigation. ● MPD_3P1 – hydraulic conductivity estimate of 10 m/d (T = 148 m2/d), based on analysis of the constant‐ rate test recovery curve. Variations in drawdown curve near the end of the test duration were not included in the interpretation of the aquifer parameter values. The hydraulic conductivity estimate (40 m/d) applied by RPS (2015) in the groundwater model differed from this investigation.
KCB reviewed the Centipede – Millipede Groundwater Impact Assessment conducted by RPS in 2015 see section 4.3, again KCB found that modifications were made on a number of occasions to support calibration. The limitations to the study identified by KCB include: ● “The developed numerical groundwater level was established for assessing a project at a level of a pre‐ feasibility study.” ● “Aquifer parameters associated with the infill tailings and waste rock materials were assumed.” ● “Transient calibration of the model domain was not conducted. This results in less confidence in the simulation results for seasonal conditions beyond the average conditions.” ● “A limitation not highlighted in the report was the lack of discussion associated with the hypersaline groundwater in the vicinity of the Centipede and Millipede deposits. The potential impacts associated with density dependent flow and migration of tailings infill seepage with more saline and dense groundwater was not discussed.” ● ”Justification for the reinterpretation of the Pennington Scott (2015) aquifer parameters were not provided.”
On the review undertaken by KCB of the Wiluna Uranium Project – Surface Hydrology Studies conducted by Aquaterra in 2015 KCB note that: ● “under PM P conditions all deposits are located within the floodplain of Lake Way and the local creek flooding, and could be impacted by flooding. ● Rainfall records are based on daily rainfall events. Therefore, the assessment of storm events shorter than 24 hours is unable to be undertaken.”
The KCB review of the Groundwater Studies – Lake Maitland Uranium Project conducted by Golder in 2011 4.5. raise that there is some uncertainty: ● “Uncertainty in the model results may arise when simulation of storm and/or seasonal events are undertaken, as comparison or predictive simulation results against the actual groundwater conditions have not been completed.”
The KCB review of the Lake Maitland Uranium Project – Hydrologic Studies & Site Water Balance conducted by Golder, 2011, 4.6 identified some limitations in the data inputs and assumptions:
● “100 years and, longer durations ARIs from 100 to 1000 years were undertaken. These calculated rainfall events were used to develop intensity‐ frequency‐ duration curves. Golder identified limitations to the calculated design rainfall events include: ○ Rainfall records for periods shorter than 24 hours are not available, therefore, short term duration design events are not validated; and, ○ For ARIs calculated for storm events less than 24 hours BoM assumes these represent more localised events <1000 km2, while durations of 24 hours and longer represent the entire lower catchment of the project site catchment.”
Some of the observations made by KCB are more significant than others. The question for the DoW is how much uncertainty is acceptable given the unique and long term risks associated with uranium mining and the future importance of water resources.
Key studies presented in Toro’s PER contain deep uncertainty and flaws and several surveys were not conducted at all for examples - there were no surveys under wet conditions. We have repeatedly presented the view to the EPA that computer modelling is limited. The KCB peer review study shows serious flaws and limitations in the company’s water studies and show that they are open to error and manipulation. We submit that these hydrological studies were deficient in multiple areas leaving a high level of uncertainty and should not have be approved.
Given that this proposal is for six mine pits on two lakes mining a radioactive material, proposing to divert and re-divert a creek system and eventually seeking to store fifty million tonnes of radioactive mine tailings on drainage line at the edge of a lake these reviews are critical to getting the project right (or less worse). This report provides evidence that these studies are flawed and do not provide the certainty required in order to approve this application.
Computer models in preference to real data, particularly in reference to surface water and wet conditions, cannot deliver a range of important information about the aquatic environment – see more details below.
KCB provided a summary of deficiencies that paint a very serious picture of uncertainty and lack of detail and real data: ● Two data points were removed to achieve compliant calibration statistics ● Calibration statistics for transient calibration were not included ● Analytical assessment and interpretation of the test pumping results were not appropriately conducted incorrect sections of the drawdown curve were selected for the analytical assessment ● Aquifer hydraulic parameters calculated by Pennington Scott were not adopted by RPS (2015) in the Centipede‐ Millipede Deposits groundwater model. The drawdown curves were reinterpreted by RPS prior to inclusion in the groundwater model. ● Numerical model was developed for assessing a project at a pre‐ feasibility level. ● Aquifer properties of pit infill material were assumed ● Transient model calibration was not conducted; therefore, simulated seasonal variability was not validated ● The potential for density dependent flow as a result of the hypersaline groundwater, particularly the potential to contribute to contaminant migration from the infilled pit, was not discussed in the report. ● The potential for density dependent flow as a result of the hypersaline groundwater, particularly the potential to contribute to contaminant migration from the infilled pit, was not discussed in the report. ● Evaporation records were sourced from the Meekatharra weather station 200 km west of the project site, although Class A pan evaporation mapping for the project site indicate similar values. ● Calibration of the numerical models were conducted to steady-state conditions only. Therefore, confidence in the modelling results is based on the assumed average conditions of the groundwater system. Uncertainty in the simulation results may arise when the simulation of storm and/or seasonal variability rainfall scenarios is undertaken. ● Rainfall records were sourced from weather stations with a minimum frequency of daily records. Therefore, calculated storm durations less than 24 hours were unable to be validated. ● Evaporation records were sourced from the Meekatharra weather station 200 km west of the project site, although Class A pan evaporation mapping for the project site indicate similar values.
There is not sufficient evidence to support the proponent’s claim that the risks can be managed.
Surface Water and aquatic environment: Toro Energy has been operating at Lake Way since 2007. There have been numerous occasions where there has been flooding and filling of the salina system at Lake Way and yet the company has relied on inconclusive conceptual computer models in preference to real data.
We wrote to Dr Paul Vogel on the 23rd of March 2011 alerting him to a significant rainfall event which filled the salina systems of Lake Way and Lake Maitland. We called on the EPA to recommend the proponents take the opportunity to measure their latent productivity and to detect endemic aquatic macro-invertebrates. We suggested that this opportunity would give the proponents a chance to develop hydrodynamic and geochemical models for these salina systems and an accurate characterization of their biodiversity values. We wrote to Paul Vogel again on the 16th of March in 2015 alerting the EPA to another significant rainfall event and the opportunity to review the test pit at Centipede. This was also an opportunity for Toro to conduct surveys at Lake Maitland under wet conditions.
On the 26 h March 2015 the Minister for Agriculture and Food representing the Minister for Mines and Petroleum provided answers to Questions on Notice asked in Parliament in reference to high rainfall and flooding at Lake Way. The questions were surrounding the opportunities presented by the rainfall to test. In response the Minister said this (Appendix 5 & 6):
“In the ESD, there is a requirement for Toro to complete the following environmental and hydrological studies: 1. surface water, hydrological and flood studies in relation to mining at Millipede, Centipede, Lake Maitland and Lake Way; 2. hydrological studies and laboratory testing to estimate the frequency, magnitude and duration of flooding events which may affect the project area during or following the active life of the mine; and 3. external review of all hydrological studies.
We note that while there has been an external review of hydrological studies these studies have revealed serious deficiencies in the studies and laboratory testing – see sections above and below. There is a serious lack of data and surveys on surface water as noted by Ecologia Environment Peer Review study conducted by Ecologia Environment on Aquatic Baseline - Appendix 10.37.
Toro instead suggest in their Environmental Management Plan that “Surface water monitoring in both lakes would commence during Project construction and continue throughout operations. The locations of this monitoring would be decided before the commencement of construction and reviewed before the commencement of mining and/or processing operations” Pg 8-5 - Appendix 4. This lack lustre commitment to monitoring is inadequate. Given that Toro had multiple opportunities to monitor and collect data and failed to do so puts the proponent’s claims, capacity and commitments into question.
The peer review study conducted by Ecologia Environment on Aquatic Baseline - Appendix 10.37 - studies for Lake Maitland identify that there has been an absence of studies conducted during wet conditions. Ecologia note the importance of such studies to understand the biodiversity – residential species, migratory species, dormant species, ecological function, physio- chemical properties, flooding regimes, increased pollution and identifying risks:
“The assessment has an important knowledge gap related to the fact that all wetlands are best studied during wet conditions following a substantial flood event. While such requirement was completely beyond the control of those conducting the aquatic assessment (Outback Ecology) due to no flood event taking place during the fieldwork period, the gap is still a significant one. The report recognises this fact, too, and makes recommendations towards it.
While sampling during dry conditions allows for mapping of the lake geomorphology, sediment chemistry and some taxa that inhabit it, it does not allow for: · a comprehensive list of resident taxa, · characterisation of biological assemblages and their succession in time, and · an accurate evaluation of a broader ecological function of the lake (e.g. use by migratory birds)
This is mainly because sampling during dry conditions limits data collection to a fraction of a real diversity and abundance, while collection methods themselves may influence the outcomes of sampling (Brandão et al. 2014). In addition, subsequent re‐ hydration of samples under laboratory conditions may provide different environmental cues for hatching than those in nature (Caâ Ceres and Schwalbach 2001). Therefore, some species that are very abundant under natural conditions may not hatch at all under laboratory conditions, while those relatively rare in nature, may be present, adding to a skewed view of species composition and function (Caâ Ceres and Schwalbach 2001). This is especially valid when evaluating the resilience of the ecosystem based on the species that inhabit it and their potential response to changes. Such changes include: · flooding regimes, which can result in inability of resting stages to hatch and existing eggs/ spores being buried in the sediment and thus not able to contribute to re‐ colonisation (Stephens 1990); · physico‐ chemical properties (e.g. changes in salinity or pH, leading to change of biota and/or destruction of resting propagules of original biota) (Stephens 1990; Faustová et al. 2004); or · increased pollution, presenting potential risk to resident biota and other organisms that depend on the ecosystem (e.g. migratory birds) (Wurtsbaugh and Jones 2012)
If such changes are likely due to the LMUP development, additional data collection during wet conditions will become essential to evaluate the lake’s ecosystem stability, and to design a long‐ term monitoring and management plan.”
Please note the advice from Ecologia is to collect more data during wet conditions to evaluate the lake’s ecosystem – which would then provide the information to design a long-term monitoring and management plan. This is significant because it highlights that the current shortfall in data means there is not sufficient information to design a long term monitoring and management plan.
Toro have numerous statement through the PER seeking to excuse why they did not conduct these in-depth studies. These reasons are not valid, particularly considering that there have been numerous occasions to conduct studies and time to develop strategies to overcome barriers to conducting surveys during wet conditions. Toro have not conducted surveys in wet conditions at either Lake Way or Lake Maitland. Toro have had tenements at Lake Way for around nine years and access to Lake Maitland for over two years – including during the 2015 rainfall event. These rainfall events that were opportunities now present a risk, and a risk that is not well understood due to the lack of data.
There was ample opportunity to collect data and the proponent’s failure to do so shows a lack of credibility and a lack of commitment to do what is necessary to ensure the protection of the environment in which they intend to operate a uranium mine.
Flooding and Surface Water:
In the Wiluna Uranium Project – Surface Hydrology Studies by Aquaterra in 2015 – Appendix 10 - the following aspects of the proposal are described which pose a serious risk to the environment in flood conditions. Not only are the pits at risk from flooding, so are the ore stockpiles all with radioactive chemicals and heavy metals. The bunding to protect mine infrastructure also has the potential to change water flows and cause erosion, the impacts of this are not well understood and have not been well defined or explored:
● “Three deposits are located within the 100 year floodplain of Lake Way and will require bunding for protection; however, under PM P conditions all deposits are located within the floodplain of Lake Way and the local creek flooding, and could be impacted by flooding.” ● “Development of project infrastructure at Lake Maitland will significantly impact flood levels and flow velocities within the lake. An immediate increase in flood levels by 1 m to 1.3 m during a 100 year ARI, and 1.5 m to 2 m during a PMP, upstream of the bunded project area is simulated. Flow velocities are predicted to increase from ~0.6 m/s to 1.5 m/s as a result of the project development.”
Aquaterra recommended that “Project infrastructure location of the floodplains of contributing creeks, or crossing creeks, will require bunding” and noted that “Encroachment of bunding onto the floodplains or creeks will result in flow restrictions and increase water levels upstream, therefore, bunding within the vicinity of the main channel should be limited and diversion channels for the main channel (for short periods of time) should be considered.”
The proposal however includes plans for bunding on the lake bed itself – Lake Maitland and in major drainage lines – like West Creek, and Centipede and Millipede. Diversion channels if considered would not be for short periods of time rather we expect they would be for the life of mine. The proposal also includes building haul roads through drainage lines.
Aqueterra noted that “The selected southern haul road route crosses several ephemeral drainage lines. Due to the relatively flat topography across the project areas, the structures proposed at the creek crossings include floodways, floodways with culverts or full flow culverts.”
Aquaterra also note the limitations to the study on rainfall noting that “Rainfall records are based on daily rainfall events. Therefore, the assessment of storm events shorter than 24 hours is unable to be undertaken.”
In the hydrological review by KCB - Appendix 10.45 - there were concerns raised about the impact on surface water flows during flooding – particularly at Lake Maitland where there are proposed pits in the central parts of the lake.
The proposals to bund and divert ephemeral creeks at Lake Way as well as bund Millipede, Centipede and the three pits at Lake Maitland when put together could have substantial impact on surface water flows during flooding. There is no clear picture of where water will be diverted from and to at each individual structure. The unknown aspects of surface water hydrology pose a significant risk in that the proponent does not have the necessary real data to base their designs on and have not presented these designs or this level of detail.
We are concerned about how contaminated water would be managed in event of flooding. Toro has stated that “In the event of large storms and the inability of Toro to contain all storm waters within the Project, Toro has reserved the right to discharge water onto the lake to enable operations to continue. In this case, surface water quality would be analysed for basic chemistry as well as for radionuclide contamination. Where the chemistry is at or below the guidelines for drinking water established in ANZECC 2000, approval would be sought to discharge water. Where the water exceeded a particular value it would be captured and used in the processing circuit or diverted to the evaporation ponds for disposal” - Pg 8-3 - Appendix 4.
This water management strategy is not very detailed and prioritises commercial operations over environmental considerations. It does not identify the diverse number of situations that could arise that would undermine this particular strategy.
In the situation that water ‘exceeds a particular value’ there are a number of questions that are not raised or answered in any of the reports: ● where would this water be on site – in pits, on the surface, in diversion channels, ● how would this water be captured ● if evaporation ponds are already full and overflowing where would this water be put ● what if processing were not occurring at that time due to the flooding and inability to move ore (or any other myriad of problems) where would the water go ● If both options for using contaminated water - in processing or storage in evaporation ponds were not viable at the time - and no approval given to discharge water – what would occur in that situation and what would be the environmental impact of that situation.
Change in weather patterns: In - Appendix 10.1 - Surface hydrology studies, the consultant RPS has given a very brief overview of rainfall in the Wiluna area. They have not included any analysis or discussion on the well documented changes rainfall patterns. For nearly ten years the Bureau of Meteorology in partnership with the CSIRO has produced a report called “State of the Climate” which offers insights and predictions about various climatic changes. Over the years they have consistently said that in inland parts of WA there is likely to be more intense rainfall.
The 2007 CSIRO and BOM report suggests that there is likely to be a combination of high rainfall events, increased rain but variable rain over summer and less rain over winter. They suggest that there will be increased intensity of extreme rainfall events.1
The 2010 State of the Environment report noted “the geographic distribution of rainfall has changed significantly over the past 50 years.”2
The 2012 CSIRO and BOM report noted that there is higher than normal rainfall across the Centre.3
Similar observations and predictions are made in the 2014 State of the Climate report produced by the Bureau of Meteorology and the CSIRO which state that “the frequency and intensity of extreme daily rainfall is projected to increase” and “tropical cyclones are projected to decrease in number but increase in intensity.”4
This combination could lead to unexpected rainfall that could impact on the integrity of the proposed mining infrastructure. When you combine the lack of real data on surface water hydrology, the lack of understanding about the diversion of water, the risk of erosion to bunds from increased water flow on top of the likelihood for rainfall to intensify in the region – it is clear that there are unquantified risks to the two Lake systems from this proposal and that more data and detail is required.
Cumulative Impacts from water extraction: In our joint submission into the original Wiluna proposal we noted that there is no water allocation plan for the Northern Goldfields/ West Murchison. In fact there isn’t a water allocation plan for the whole of the Goldfields and the Murchison.
In response to our submission the DoW and EPA referred to the Wiluna Water Reserve Drinking Water Source Protection Assessment conducted by the Water Corporation in 2004 (Appendix 7). In the 2004 assessment there was no consideration of mining as a land use or major consumer of water. There was a focus on the drinking water bores around Wiluna that did not consider regional water; there was no consideration on environmental allocations of water,
1Commonwealth of Australia 2007, State of the Climate Report. 2 Commonwealth of Australia 2010, State of the Climate Report. 3 Commonwealth of Australia 2012, State of the Climate Report. 4 Commonwealth of Australia 2014, State of the Climate Report. mining allocations or allocations for other land users. Nor was there consideration of water recharge in the area.
Following the original assessment of the Wiluna uranium proposal we lodged an FoI application to determine what information had been considered in the assessment of the water allocation aspect of the proposal. We received the correspondence from the DoW to the EPA (Appendix 8) stating that their advice is based on “a study of the Groundwater resources of the Northern Goldfields published in 1999 by the Water and Rivers Commission. The study mapped a continuous paleoechannel aquifer system extending across the Northern Goldfields, including the Wiluna area.” Also in the advice the recommended that the proponent find an alternative water source to the West Creek Bore.
We can see no evidence in previous assessments or the assessment of the Wiluna Extension that the DoW or the proponent has reviewed the current allocation in the region or the sustainable yield of the recharge rates of the aquifers. There does not appear to be any regional study on current water extraction rates or impacts. There are no clear indications on what the regions environmental water needs are.
The reliance on studies conducted in 1999 and 2004, 18 and 13 years ago, is concerning given the significant amount of mining activity in the region and significant water allocations for those mines over the last 18 years. The regional water yield should be considered in the context that there are also several mine projects in the region under assessment and others in Care and Maintenance that are looking to re-open. There is still no clear picture of how much water is currently being taken from the region for mining.
Through the DoW processes there has been ongoing granting of licenses based on outdated studies without any evidence on water balance in the region following 13-18 years of water allocations to mining. The EPA continually defers water related issues to the DoW – in this case we are not convinced that the DoW has sufficient or current information about water consumption and impacts in the Northern Goldfields to base their assessment.
The proponent has suggested that “Managing the cumulative impacts of water abstraction in the West Creek/ Wiluna South area is a matter that can be regulated by the Department of Water through its licensing powers under section 5C of the Rights in Water and Irrigation Act 1914.” PER 12-45
The Department of Water does not assess or consider water quality that is not classed as drinking water. Their scope as a Government agency does not include cumulative impacts on water quality. While they may consider volumes of water and water use, we are not confident that the DoW can or will assess or consider cumulative impacts on the water quality. As mentioned above we are also not confident that the DoW has sufficient evidence about water yields in the region to base their assessment on water allocations. Clearly this is a matter of significant public interest and assessment decisions need to be based on comprehensive and contemporary data.
Kintyre Uranium Project Surface Water: Baseline gamma survey of the project area and the downstream Yantakuji creek. Or upstream studies in the National Park to identify any variation from upstream of the project site to downstream have not been conducted.
In a paper written for the Native Title Conference 2012 titled Talking About Kintyre (see Appendix 5) there is a section which talks about the revision of an educational DVD made about the Kintyre project. The DVD contained information about surface water. In the first draft of the DVD it was claimed that during flooding or heavy rains surface water all drains to the north of the project area. On review of the DVD by stakeholders this section of the DVD was contested: “some Martu said the section of the DVD about surface water flow from the mine was incorrect”. The report states that “the Martu elders were adamant that during big floods, water from Coolbro Creek flows to Lake Dora.... that in flood time’s water from the proposed mine would flow into Rudall River then Lake Dora.”
The conference paper discusses how the collaborative project was a forum in which these issues were raised and that Cameco staff then accepted the local knowledge and amended the DVD to incorporate the local information about the surface water flows from the project. The new information about surface water in the DVD shows that surface water flows initially go north but then track southward back into the National Park, join with the Rudall River and then flow into Lake Dora.
While that process was useful and achieved a good outcome at the time, it is disappointing that Cameco has not presented the same information about surface water flows in the ERMP or used this evidence in their management plans. It is disappointing that Cameco has sidelined the valuable traditional and local knowledge about the movement of surface water. It is also disappointing that they evaded a very serious environmental issue and risk to the National Park and the drinking water of the Punmu community in doing so.
While Cameco has made reference to the knowledge of Aboriginal elders in ERMP Section 7 Pg 109 they have made contradicting statements elsewhere in the report “There is anecdotal evidence from Aboriginal elders suggesting that in years of significant flood events the discharge from Coolbro Creek ultimately flows along sand dunes in an easterly direction towards Rudall River. This is supported by contour data and landforms in particular the presence of claypans suggesting inundation of these areas.”
Cameco then use a contradicting statement to describe the surface water flows in the business end of the report: “The drainage in the upper reaches of the creeks occurs within relatively incised channels which widen to include significant flood plain storage in the area surrounding the Project area. The tributaries converge immediately downstream of the project site and flow north to the Coolbro Creek. Coolbro Creek then follows an easterly path into the Great Sandy Desert where the drainage eventually dissipates into the sandy environment” ERMP Appendix I Surface Hydrology Report.
At the beginning of this same Hydrology Report provided in ERMP Appendix I the consultants make this statement: “Due to the remote nature of the Kintyre site and the corresponding lack of hydrological data, particularly the absence of any historic data from large floods, the approach to assessing the potential nature and extent of flooding has relied on the development and interpretation of mathematical computer models.”
While the consultant has acknowledged the limitation of their understanding of surface water flows Martu have been clear. There is an abundance of local knowledge about the movement of surface water that Cameco has acknowledged but then ignored. Cameco’s information on management of surface water, mitigating the release of polluted water and the environmental impacts on the National Park, Karlamilyi River (Rudall River) and Lake Dora should be discounted based on the lack of certainty around the flow of surface water from Coolbro Creek and lack of understanding on which surface water flow they are basing their management plan.
We recommend that Cameco reassess the surface water flow based on local knowledge about the movement of surface water and identify risks associated with the movement of surface water back into the National Park and Lake Dora and write a corresponding management plan to mitigate those risks. This should be made available for public review and comment.
This would also involve conducting baseline studies on radiological environments with which to measure change in the environment by. This would include monitoring of the eastern branches of Karlamilyi River (Rudall River),` Lake Dora and the natural springs at Lake Dora and Punmu’s water supply.
Processing:
Cameco has stated they need a significant amount of acids for processing which raises serious concern about neutralising the acids and potential for Acid Metalliferous Drainage or Acid Mine Drainage (AMD). The lack of information and consideration on AMD poses a serious and expensive risk to the environment.
In a submission to the EPA in response to Cameco’s Public Environment Review Management Plan (ERMP) by Dr Gavin Mudd states “Fg 6.11 shows 4Mt of ore and 1Mt of low grade ore being processed. Assuming 0.49% resource grade, this gives 19.5kt U308 contained in the ore.
At a typical 90% recovery this gives 17.6kt of U308 produced. The 1Mt of low grade ore, assuming a grade of 0.1% U308 after radiometric sorting and 90% recovery, gives 0.9kt U308. A total of 18.5kt of U308 some 2.5kt less than the 21kt that Cameco suggest in the ERMP. This raises concerns about the accuracy of similar figures throughout the report. This highlights the need for full detail on schedules and management plans.”
Ranger uranium mine uses 14.5 tonnes of sulphuric acid per tonne of U308. Cameco propose to use almost double the amount of sulphuric acid - 27 tonnes - at Kintyre. The figures are based on information in Table 6.7 of the ERMP which states 111,000 tonnes of sulphuric acid will be used to produce approximately 4,000 tonnes U308 per year, i.e. 111,000 divided by 4,000 tonnes = 27 tonnes sulphuric acid per tonne of U308. See Appendix 6 – Dr Mudd.
Cameco propose to use less lime at Kintyre than is used at Ranger. The high use of acid and small use of lime raises concerns about the ability of Cameco to neutralise the acids in the tailings. This is important because of the potential for AMD.
We recommend that there is further information provided to the EPA, DoW, the Federal Department of Environment and the public on the expected pH levels of tailings and management plans and research in the effective neutralisation of acids from processing that would be stored as tailings.
Radioactive Mine Waste - Tailings:
Review of the current information available on the Tailings Management Facility through the body of the Environmental Review Management Plan (ERMP) and in Appendix E of the ERMP has raised the following concerns: ● There are no details on how Cameco intend to neutralise chemical usage, in particular pH ● There are no details on slurry solids content i.e. is it 50% or 60% solids in the slurry? ● The tailings dam is stated to hold 7Mt compared to project total of 5Mt shown in Fig 6.11 allowing for the processing of mineralised overburden. There is no estimate of how may Mt of tailings could be produced from the mineralised overburden. There is little evidence around the tailings capacity and future opportunistic production and increase volume of tailings. ● There is no reference or investigation on regional cyclonic and storm activity and the potential impact on the TMF. References for cyclonic activity are outdated - Dames & Moore, 1990; 1998. ● There is no demonstration that a 1m freeboard is sufficient to deal with extreme storm risk. ● ERMP Appendix E - Tetra Tech identified that there is a risk of failure of drainage control and a risk to surface water. See above the concerns we have about the modelling of surface water flows. ● There are no specific criteria or values for deciding on water management, especially with respect to levels of water on the tailings and water quality criteria. ● In ERMP Appendix E, Tetra Tech has provided some explanation of modelling and seepage from tailings in normal, wet and dry conditions. Wet conditions double the amount of seepage. There is no discussion about future rainfall and impacts on seepage and no discussion on the integrity of the system and future seepage rates, in 10 years, 20 years, 100 years, 500 years, etc up to 10,000 years.
Mulga Rock Uranium Project
Cumulative Impacts from water extraction from Kakarook:
Appendix D1 looks at the water take from the Kakarook bore. Rockwater consultants identify that “The volume of groundwater in storage in sandstone beds in the area of Kakarook North that has been drilled by Vimy Resources, is calculated to be about 167GL (93 times the annual water requirement for the proposed project).”
167GL divided by 93 = 1.7GL annually (which is less that the proponent states they intend to use in the PER) this would mean the consumption of 27.2 GL over the 16 year life of the project.
Rockwater consultants suggest that the rate of recharge is 1% of annual rainfall, there is no indication over what area that 1% recharge occurs. “The groundwater is recharged following high rainfall events when rainfall and runoff readily infiltrates the surface sand, and then moves down to the water table. During typical climatic periods, recharge rates are low, probably less than 1% of the average annual rainfall. The groundwater flows to the south. The water table is typically around 20m below the ground surface.” Appendix D1.
They separately state that the annual rainfall is 222.6mm - we can therefore assume that they are suggesting the annual recharge on average is likely to be around 2.3mm per cubic meter = 0.0023m. If we consider that recharge occurs over 4000 hectares - the project area (4e+7 square meters) this is 92,000 cubic meters or 92 million liters (ML) (1 cubic meter is 1000 litres). Based on this tid bits of information we assume that on average the total yearly recharge is 0.092 GL, or about 5% of the annual proposed borefield extraction. Yearly extraction will be 20 times the annual average estimated recharge and that this is expected to continue for 15 years. While the consultants have given some indication about the low levels of recharge and large volume of water to be extracted they have not clearly identified the long term impact on the environment from.
In the PER 12.3.2 Vimy identify that “Pan evaporation (around 2,650mm/yr) greatly exceeds rainfall throughout the year and thus the environment exists in a water deficit condition. Daily pan evaporation rates vary from 11-12mm/day (330-360mm/month) in summer to 2-3mm/day (75-100mm/month) in winter. The MRUP region therefore exists in a water deficit condition throughout the year, which will strongly influence the functioning of the ecosystem.”
The Appendix D1 hydrogeological investigations of the Kakarook bore, Rockwater state that “The planned pumping rate of about 4,900 kL/d may be more than the rate of recharge to the aquifer, and the aquifer through-flow.” Given the evidence or claims made above on recharge rates vs the rate of consumption it would seem that in fact yes the planned rate of pumping will be significantly more than the recharge rate - about 20 times more and possibly more than that. Rockwater go on to say this is sustainable because there are no other users in the area, that the rate of consumption will be finite and that there are other parts of the bore that can be used. We would argue that the taking water from a pristine environment that will take hundreds or thousands of years to recover is not sustainable - in fact it dramatically impacts on that water source and any future potential use of that water resource and the surrounding environment which is constantly competing for the small amount of water that exists.
There is another major user of water in the region the Tropicana Goldmine. The Anglo Gold Ashanti project proposal included plans for 14 million liters a day.5There is no assessment or discussion about the cumulative impacts of water consumption from both mines. While the bulk of the water for the Tropicana is taken from and area around 100km NE of the Mulga Rock proposal there is some indication that Tropicana have a bore at Mulga Rock “Extraction from Tropicana mine’s bore located in the Emperor pit (MSWB02) was included at a rate of 50 kL/d (the average for the period (July 2011 to November 2014);” Appendix D2. While this fact is presented in the Appendix there is no discussion about this in the proposal and no identification of this increase in water taken from the environment at the proposed site.
Given the large quantities of water either being taken, or proposed to be taken, in an arid region, which supports many priority and threatened species, unique flora, Priority Ecological Communities it does seem like an oversight to not investigate or outline any interconnecting aquifers or ecosystems.
There is so little that we understand about the flora, fauna, SREs, GDEs, and the Yellow Sandplain PEC - to take such huge volumes of water from this pristine environment without a clear understanding of the impacts on one of very few pristine environments is reckless.
Appendix D2 indicates there is a desalination plant, there is one other mention of desalination in the PER - there does not seem to be a consolidated plan. We are wondering whether or not there is a proposal for a desalination plant?
We are concerned that there is a lack of understanding about the impacts of the water consumption on the environment and the Yellow Sandplain PEC both at the mine site and the downstream environment at the Queen Victoria Springs A Class Nature Reserve.
For a commodity worth very little, for a project that offers a marginal amount of short-term jobs we are of the view that the long-term impact of water consumption outweighs any perceived benefits.
Downstream impacts on water:
5 Tropicana Gold Mine Public Environment Review - Appendix D4 http://www.tropicanajv.com.au/IRM/PDF/1171/D4PenningtonScottWaterSupplyInvestigation The proponent has suggested that there is low permeability - 0.02 to 0.7m/day (Pg 4) this is not actually low permeability, as implied. We are concerned that the proponent has miscalculated the permeability and underestimated the impact of seepage from tailings.
The groundwater flow direction is from north to south, towards the Queen Victoria Springs. Appendix D2 “The Queen Victoria Spring Nature Reserve lies down-gradient of the MRUP: the northern boundary of the reserve is 14 km south of the planned injection borefield and 24 km south of the Ambassador deposit.”
If the aquifers that will be impacted by the project are connected with the springs at ‘Queen Victoria Springs’ there is a possibility that water quality and quantity in the A Class nature reserve could also be impacted. For example, changing the pressure in the aquifer by pumping and/or injection could have a rapid and noticeable impact on spring flow (as pressure changes in an aquifer are transmitted rapidly, as opposed to the actual time required for flow of groundwater from point A to B). Thus, if a GDE assessment has not been conducted as part of the hydrogeological investigation, this is an area that requires further investigation. We have been unable to identify any clear studies or assessment of impact on downstream GDEs particularly in reference to the Queen Victoria Springs.
In the conceptual model figure (Fig 1.4) there is reference to an injection bore field, there is no clear discussion about how this will control the hydraulic gradients and contain seepage to within proximity of the site. Re-injection schemes around the world are a challenging feat of engineering, and they are notorious for suffering problems with clogging (of the injection bores and/or aquifer), loss of efficiency and even structural/ geological instability (e.g. re-injecting waste-water near faults seems to set them off). Given the lack of discussion about how the bore field will operate there are concerns about how it will be managed, what barriers or challenges there might be and therefore what risks and impacts could arise because of the bore field.
Flooding and Surface Water:
While it is true that the low rainfall in remote WA reduces the risk of tailings dam overflows, there have been some significant rain events in recorded history - e.g. ~115mm in 48 hours in 1974. When the risks are underestimated it can lead to problems. Large tailings like the one proposed - 106ha above ground can be problematic and the impacts on water should be considered in greater detail.
Appendix D9 – “The Trend Maps for rainfall given in the Bureau of Meteorology website under Climate Change and Variability indicate that total annual rainfall at Mulga Rock has increased by about 20 mm every 10 years from 1970 to 2014.” The consultants say this will have negligible impact on the project or the environment but do not describe how they arrived at this conclusion.
The consultants discuss high rates of infiltration in similar areas so describe the build up of surface water is unlikely – high levels of infiltration have other potential impacts on seepage from tailings which is discussed later, this is likely to be problematic with increased rates of rainfall.
The consultants suggest the only surface water risk is from flows from Catchment A, but claim that flows are unlikely to pose a serious risks. This is not discussed further in relation to mine closure, and changes over time. For the operational life of the mine we suggest some flood mitigation measures should be considered for a worst-case scenario, and indeed there should be some articulation of what a worst-case scenario would be. In the documents provided by Vimy there is no indication that they are considering any flood mitigation strategies at all.
In the case that we continue to get less frequent but more intense rainfall the risk of surface water build up over short periods is a real risk. These scenarios should be considered and in so doing should identify key risk factors. If there are issues with acidic rocks in the overburden or tailings and flooding occurs there could be some very problematic issues - not only of spreading radionuclides and heavy metals but could be the cause of Acid Metalliferous Drainage.
Tailings Management:
One of the EPAs objectives is to maintain the quality of groundwater and surface water, sediment and biota so that the environmental values, both ecological and social, are protected.
“The initial above-ground tailings storage facility will be lined and any seepage will move vertically downwards into the local aquifer.”- PER Page xi
“By the time tailings seepage or drainage reaches the mining lease boundary the composition of the plume of contaminants will be indistinguishable from natural variation within the existing ground water.” PER Page 388. In Appendix D2 it is stated that “Tailings seepage is 28.6 kL/hr (686 kL/d).” This volume of seepage seems quite high, it is not clear how that volume of tailings seepage will be retained or how quickly it will move and into which receiving environment.
The statement: 'Tailings seepage will likely have a lower salinity than the receiving groundwater environment and therefore density stratification will ensure that any tailings seepage plume is forced through the carbonaceous PRB, likely removing the excessive solutes and equilibrating the tailings water to that of the surrounding groundwater' (page 9) has all sorts of problems with it. The density contrast between groundwater of different salinity does not provide sufficient driving force to 'push' groundwater into particular aquifers/lithologies as they are proposing. When two fluids of different density meet, they mix and tend to form complex patterns of fingering. The different density fluids may eventually stratify under conditions of minimal flow/disturbance over long time-scales, but this is unlikely to be able to constrain the downwards migration of a plume of contaminated water, and it certainly can't 'force through' water into a particular lithology. The 'PRB' they refer to is not an engineered barrier, as implied, but simply the carbonaceous sediments in the aquifer, which are probably highly heterogeneous, not like an engineered barrier at all. If the proponent’s assessment that there is only a 'small' risk of impact from tailings seepage is based on this statement we would urge for the project to be rejected on the grounds that the safety of tailings is based on false assumptions.
The risk of tailings leakage is significant, not just because of the radionuclide content but because of he fact that Co, Cu, Ni, Mn, Zn and Pb are mobile and leachable from the tailings (page 9). All of these metals are significant toxicants and pose a significant risk to the environment and public health.
Unsaturated flow models are notoriously hard to calibrate and run, so predictions based on their seepage model (HYDRUS 2D & 3D) should be reviewed carefully. They have admitted that they don't have any hydraulic parameters for the tailings and some of the overburden material - this raises concerns about the unsaturated flow and seepage models.
The proponent relies heavily on the theory that the “carbonaceous material that exists at the surface of and below the water table” has acted as a barrier that captured the uranium in the geology in the first place. But provided no real evidence and dubious assumptions made about the permeability of the carbonaceous material, the changed structure of the tailings compared to the un-mined uranium ore and how it will act under changed conditions with changed chemical and mineral content. For example if there were exposure to above-ground elements (e.g. rain and oxygen) uranium may oxidise the organic matter and cause changes in redox state, which could render these elements more mobile. It is not clear how long or how rigorously they have tested exposure of this material to the elements this during their leaching assessment and it isn't clear from the D8 report.
There is a lack of work done on sensitivity analysis of the model. There is no clear assessment of the risks - or worst/ best case scenario in the event that there were variations to some of the key model parameters, or if the parameters had been underestimated or overestimated. Overall that leaves the model with a high level of uncertainty. Not withstanding this, they still predict more than 20 mega litres of seepage from the above-ground storage facility, which is a significant amount, particularly if it is highly contaminated with heavy metals. Given the uncertainty around the key model parameters this scenario could be worse. There is no identifiable assessment on the significance of the impact from higher levels of seepage and higher levels of heavy metals or radionuclides.
Based on the lack of modelling, failure to consider a number of significant aspects of the proposal that could have a detrimental impact on the immediate environment and the downstream environment and springs at the Queen Victoria Spring A Class nature reserve we urge the EPA to recommend the project is not approved.
Yeelirrie Uranium Project
Groundwater: Yeelirrie is in an arid area, with low groundwater recharge – the study estimates a recharge rate of approximately 2.6 GL/year; in addition natural ET consumes about 89% of this recharge, leaving approximately 0.4GL/year in net recharge.
The extraction rate due to dewatering of the deposit and other milling, tailings and processing needs is estimated to be approximately 53.4Gl, over the project life of ~20 years, that is approximately 2.5GL/year, 6 times more that the net recharge.
The additional water extracted by mining (water that is not met by the net recharge) will be derived from two possible sources: ● Storage depletion – loss of groundwater in storage from around the deposit. ● Capture of discharge – loss of groundwater inflow to Lake Miranda.
When groundwater is extracted above the recharge rate, some combination of these two sources always occurs (e.g. Konikow and Leake, 2015).
During groundwater modelling, Lake Miranda was assigned the property of having a constant head. This essentially supplies the lake with an infinite source of water, and prevents impacts on lake levels from mining from being accurately quantified. Given the high permeability of the aquifers, there is likely to be a strong connection between these and the lake, and given the high extraction volumes from de-watering, a large amount of water that would otherwise discharge to the lake would be captured by the de-watering. This runs the risk of drying out the lake.
In terms of the water derived from storage in the aquifers, the aim of the mining is to reduce water in storage and lower the water table in the deposit. However, the extent of the impact on groundwater levels is something that could be variable – e.g. the loss of storage may be highly localised, or it may extend into the surrounding region (where it could impact other users).
This variability also poses a significant additional risk to subterranean fauna and groundwater dependent ecosystems.
Having accurate values of transmissivity and storativity is critical to predicting the extent of the drawdown. It appears there is some field data to provide estimates of these values, but the heterogeneity and complex geology may be an issue and increase the uncertainty of this impact. Far more detailed study is needed in order to verify the proponent’s claims.
Model properties
It is noted that in the table of aquifer properties (table 4.3) that the vertical hydraulic conductivities are estimated as being constant fractions of the horizontal hydraulic conductivities. In some cases the horizontal and vertical conductivities are estimated to be the same (in the calcrete) while in the other units the ratio is 10:1. The use of a constant value for all units implies that this parameter (the vertical anisotropy) is not well known. The result of this is that the level of cross-connectivity between different layers is probably still quite uncertain.
The interception of this much water will starve any existing features that depend on groundwater discharge (such as Lake Miranda) of their current water. Impacts of cumulative drawdown from BHP's Albion well-field (to the east) and the Yeelirrie project may also be an issue, although the model appears to predict fairly minimal interaction between the two.
Water table drawdown estimates in groundwater modelling are always highly dependent on the model parameters used to simulate the future scenarios, which can be quite uncertain. The model parameters were unidentifiable in the Groundwater modelling study Appendix I1), making it difficult to comment on the accuracy of the future scenarios presented in the PER.
We remain very concerned that the dewatering and water drawdown from mining activity at Yeelirrie will have severe consequences on the subterranean fauna and we again urge the EPA to reject the proposal.
Youno Downs and surrounds :
Youno Downs is the neighbouring cattle station. The station has a number of watering points for cattle some of which have not been identified by Cameco and others that are likely to be impacted on by water drawdown. In the PER Cameco have not identified Youno Downs station as a water user (271 & 283). Of particular concern in Cameco’s proposed Northern bore field that is quite close to Youno Downs southern bore known as Dempsey. The drawdown from the Northern borefield is expected to b 5m - pg. xxxiii.
Dempsey is a watering point for Youno Downs cattle - the drawdown from the bore field may have a material impact on the ability to use Dempsey as a watering point for the cattle at Youno Downs station. The Dempsey bore is operated by a windmill and seems that the water level has stayed about the same over the 25-30 years that cattle have been run on Youno Down station. This indicates that there is water flowing and that there is some recharge. Any future changes to this are likely to be a direct result of Cameco’s extraction of water.
The cattle are of course attracted to water and its believed that cattle from Youno Downs sometimes cross the station boundary and visit the Eastern Mile Bore which is just 2km from the proposed open pit. If the bore were running the cattle are more likely to take the journey to the Eastern Mile Bore. There is no description of this in the PER. We would like to know if Cameco will fence the area? Also in the surrounding areas to the East there is a rockhole, about 8km east of the mine. Will Cameco monitor this rockhole to ensure that water being taken from the Eastern bore doesn’t reduce flows to the rockhole, a unique watering point for native animals in the area.
Rainfall - flooding frequency
Climatic changes reducing groundwater recharge
Cameco describe in detail the rainfall events in the past noting that there is a combination of high rainfall events, increased rain but variable rain over summer and less rain over winter etc. Cameco go on to explain predictions from BoM and CSIRO in 2007 about more increased intensity of extreme rainfall events. We note that similar observations and predication are made in the 2014 State of the Climate report produced by the Buraeu of Meteorology and the CSIRO which state that “the frequency and intensity of extreme daily rainfall is projected to increase” and “tropical cyclones are projected to decrease in number but increase in intensity.” [1]
Cameco make an important observation that less frequent more intense rainfall events will impact on groundwater recharge rates, as more rainwater will be lost to evapotranspiration. This is supported by evidence on pg 143 of the PER which shows after rainfall event soils beneath the surface are still dry. In this arid area absorption rates of water are relatively low and water tends to pool on the surface - this has certainly been our experience in the region.
While this has been acknowledged by the proponent in the section on climate change (section 7.4.1 pg 128) we have not seen how this evidence has been incorporated into future predictions about the recovery of groundwater over time (pg 283 & figures 9.44, 9.45 & 9.46). We have calculated net recharge rates of 0.4GL/year based on the information provided by Cameco. We would hope to see more details on expected recharge rates over time and how this impacts on the rehabilitation of subterranean fauna habitat and groundwater dependent ecosystems.
Erosion: It is acknowledged that more intense rainfall is likely to intensify the risks of erosion. This may pose a significant risk to ore stockpiles and runoff. On pg. 251 Cameco state that erosion is likely to “dropout downstream of the Project” There is however no further description about the risk and impact of erosion. Presumably the erosion will carry particles with it that will “dropout downstream of the project.” What exactly will drop out, what is the likelihood of radioactive particles or heavy metals to be transported through erosion and what is the cumulative impact over the life of the mine on the receiving environment?
Climate change - increasing intensity of rainfall events There are predictions from BoM and CSIRO, acknowledged by Cameco, that rainfall events are likely to become more infrequent and more intense. This change will affect the impacts during mining and post closure.
Cameco refer to ARI event as a 1:100 year event or a 1:1000 year event and suggest they have modelled for those scenarios and are confident the integrity of the infrastructure and design will withstand these events. What is not clear is what the exact worst-case scenario is that infrastructure has been design to withstand and whether or not the infrastructure or design features will remain intact for 50, 100, 1,000 or even 10,000 years. It is also not clear what data was used and what assumptions were made in modelling the scenarios.
In section 9.10.5.3 Cameco claim that in ARI flood event - any release of water from the site would have to be of a sufficient quality. What is not clear is what the parameters are for ‘sufficient quality’ how many ppm of arsenic, mercury, lead, acid, uranium, radium etc. constitutes as sufficient quality?
In these conditions we are concerned that frequency and intensity of rainfall events, dust storms, cyclones could exceed expectations and have a detrimental impact on: ● Drainage systems capacity (Section 9.4.5). ● Tailings ● Inundation of backfilled areas ● Metalliferous drainage from ore stockpiles
Cameco has demonstrated that “under the 1,1000 year ARI scenario, the post-closure backfilled pit area would be subject to inundation for the duration of the event and surface water would potentially infiltrate the closed landform.”
This is even more concerning given that post closure these backfilled areas will contain radioactive/ contaminated materials and soils. There may also be increased pressure on tailings inside the backfilled areas. There is no clear discussion about the impacts of this event and no scenarios provided. Should this event happen post closure for example 100 years after the mine has closed would the post mining design features be intact. How will water from the backfilled pit area interact? Will it leach from the bottom or the sides, will radioactive material float to the surface and interact with surface water.
As mentioned previously Lake Miranda is downstream from Yeelirrie, Lake Way and Lake Maitland. In a 1:1,000 year ARI Lake Miranda. There is no discussion on the cumulative impact of this type of event in the region and impacts on surrounding and downstream environments including Lake Miranda.
We again note the motion passed in WA Parliament that indicates very clearly that some of the materials we are talking about in the post closure site will remain radioactive and volatile for no less than 10,000 years. Conclusion
In the assessment of each of the four proposed uranium mines in WA there has been a reliance on poor science and outdated or incomplete data and and over use of computer modelling.
There are not strong regulatory frameworks for the protection of water quality, particularly for water which is used for drinking but that is not classed as ‘drinking water’.
There is a lack of understanding about regional water use, water quality and subsequently a lack of understanding about long term threats or recovery planning. There is anecdotal evidence of impacts to water quality and quantity at cattle stations which has been associated with mining, this has gone uninvestigated and unmanaged.
Uranium mining is different to other mining because of the radioactivity of the ore and waste products which pose a long term threat to water sources.
There is an inconsistency in applying conditions to mines that relate to water. In some instances the regulatory deficiencies around protecting water quality and managing water allocations is resolved by conditions but these are applied in an ad hoc way and are open to political influence. Protection of our most precious resource - water - should be tightly regulated with a focus on outcomes to improve water quality and evidenced based water allocation planning with allocations for the environment.
For further information please contact:
Mia Pepper, Nuclear Free Campaigner
Piers Verstegen, Director