Submission to the Senate Inquiry

Environmental Regulation of Uranium Mining

Dr Dennis Matthews

The author has had a long involvement with the environmental impact of uranium mining in SA (see enclosed CV).

This submission will address each of the terms of reference of the inquiry in respect to the Beverley and Honeymoon acid in situ leach uranium mines, namely:

a)	the adequacy, effectiveness and performance of existing monitoring and reporting regimes and regulations;
b)	the adequacy and effectiveness of those Commonwealth agencies responsible for the oversight and implementation of those regimes; and
c)	a review of Commonwealth responsibilities and mechanisms to realise improved environmental performance and transparency of reporting.

My response to the terms of reference will include the background to the Beverley and Honeymoon uranium mines

In addition I will give the background to some of the environmental, and health and safety issues that underlie my concerns about the environmental regulation of uranium mining.

My perspective on environmental regulation of uranium mining is the result of a long history of interaction with the nuclear industry, and will be supported by reference to the environmental impact assessment process, public consultation (or lack of it), and the response of government and industry to invitations to publicly defend their positions on issues of concern to the public.

This Senate inquiry into environmental regulation of uranium mining is being held in the context of a protracted period of secrecy, misinformation and lack of public consultation by state and Commonwealth governments, by government departments, and by the nuclear industry. This period has its roots and antecedents in previous decades but was most manifest from 1996 to 2002.

1.  The Public Inquiry into Uranium

In 1996 a coalition of individuals and non-government organizations in SA was formed to campaign against the increasing environmental threat from uranium mining in SA. This coalition was called the Nuclear Issues Coalition (NIC).

NIC decided to hold a truly public inquiry into uranium.

The “Public Inquiry into Uranium” was held at Tandanya in Adelaide on March 3 1997. The hearings were chaired by Dr John Coulter a former South Australian Senator, medical researcher, President of the CCSA and ACF councillor.

Its terms of reference included:

a)	the suitability and effectiveness of the approval process applied to the mining, processing and export of uranium;
b)	the nature, efficiency and effectiveness of the present regulatory regime in monitoring, regulating and preventing:
•	on-site environmental impacts
•	off-site environmental impacts.

Despite the sending of personal invitations, no state or Commonwealth government minister, no Government department, and no uranium mining company or mining organization made a submission to the inquiry and only the Office of the Supervising Scientist was represented at the hearings on March 3 1997.

For example, Senator Grant Chapman was invited but, despite having recently chaired a Senate inquiry into uranium mining (The Senate Select Committee into Uranium Mining) did not accept the invitation.

Written submissions were invited, but not received, from:

Australian Mineral Foundation
Australian Minerals and Energy Environment Foundation (AMEEF)
Australian Radiation Laboratory
Pearce Bowman, Executive general Manger, WMC Copper Uranium
SA Chamber of Mines and Energy
Senator Grant Chapman
Senator Robert Hill, Minister for the Environment
Minerals Council of Australia
Senator Warwick Parer, Minister for Resources
Uranium Information Centre
WMC Ltd
Richard Yeeles, Manager Corporate Affairs, WMC Copper uranium

Verbal submissions were invited from:

Australian Minerals and Energy Environment Foundation (AMEEF)
Australian Radiation Laboratory
Pearce Bowman, Executive general Manger, WMC Copper Uranium
SA Chamber of Mines and Energy
Senator Grant Chapman
Minerals Council of Australia
Nuclear Waste Management Ltd
Office of the Supervising Scientist
Senator Warwick Parer, Minister for Resources
Uranium Information Centre
Richard Yeeles, Manager Corporate Affairs, WMC Copper uranium

Of the above only the Office of the Supervising Scientist accepted our invitation.

The Public Inquiry recommended:

•	That there be adequate assessment of the environmental, health, social, and cultural impacts of the uranium industry.
•	That there be constant monitoring of the environmental, health, social and cultural impacts of the uranium industry, and that this monitoring be overseen by an independent body.
•	That the public be privy to all of the information regarding the monitoring and that the public be consulted about any changes or extensions to the operations being monitored.

It also made recommendations in the areas of:

•	Health and safety
•	Management of uranium tailings
•	Mound springs and Great Artesian Basin
•	Nuclear fuel cycle.

2.  Environmental Impact

All uranium mining and milling activities in Australia, covering half a century, have had serious environmental impacts.

A major environmental impact of the Radium Hill mine in South Australia was its contribution to the UK nuclear weapons programme including the nuclear weapons tests that led to eviction of the indigenous people and to contamination from radioactive and toxic materials at Emu and Maralinga in South Australia.

The remediation of the worst contaminated sites involving plutonium dispersion was attempted half a century later. Wastes were put into unlined shallow burial pits and covered with a few metres of overburden. Much finely dispersed plutonium and other toxic materials escaped this remediation process. The consequent health risk for any person living in the area would be unacceptable.

Mining and milling of uranium ores at Radium Hill in South Australia from 1951 to 1961 produced radioactive tailings that were either stockpiled, used as ballast on railway lines, or stored in a tailings dam at Port Pirie (Atomic Energy, vols.4(4), p8, 1961 and 5(1), p21, 1962, SA Mines Department).

Wastes from the processing of uranium concentrate from Radium Hill and of rare earths at a site adjacent to the sea at Port Pirie from 1955-62 were stored in a tailings dam.

The management of the tailings dam deteriorated over the years to the point where children were playing on its surface. After six years of community pressure and after high tides breached the walls of the tailings dam in 1981, the dam wall was increased in height, the tailings were covered, the area was re-fenced, and a trench was constructed to drain the tailings into an evaporation pond (The Advertiser August 4 1982).

It took 30 years to take these stopgap remedial measures.

In 1982, at the Honeymoon uranium mine in South Australia, acid in situ leaching (acid-ISL) was trialed. In this process, acidic corrosive liquids are injected into the ore bearing strata with the aim of dissolving minerals, which are then brought to the surface through pumps. These pumps must be placed and operated in such a way as to prevent the leach solution from moving vertically and horizontally into other strata, especially aquifers.

The mining trials were vigorously opposed by the environment movement in South Australia. Eventually the trials were discontinued by the Government after it was found that blockages had occurred which affected the ability of the operators to control the movement of the leach solution. Despite a previous SA Government calling a halt to these projects, and despite there being no change in environmental concerns about acid-ISL the same process was given approval by subsequent governments and is now being used at the Beverley and Honeymoon uranium mines.

It is noteworthy that the problems that characterised uranium mining activities 50 years ago are the same ones which we encounter with present day uranium mines. These problems involve water use, water contamination, tailings or wastes (including run off), leaks and health and safety.

Just as with the earlier ventures, the companies involved, while freely admitting to past mistakes in the industry, deny that there is a current problem.

In an article entitled “Uranium mines to shed shoddy ‘50s” (The Australian May 4 1996), the uranium mine at Rum Jungle was described by a water quality scientist for the Northern Territory Government as “a very shoddy mining operation”.

The article described how the Rum Jungle uranium mine contaminated the Finniss River, how mine rehabilitation in the 80’s had failed, and how a five year monitoring and rehabilitation project begun in 1993 had been successful in restoring the area.

This represents a span of some 40 years between creation of a major environmental problem and its remediation, which, however, did not undo the damage already done.

According to the scientist, any future project at Jabiluka would be accompanied by continual supervision and rehabilitation.

Similarly, the chief executive of Energy Resources of Australia (ERA) claimed (The Australian May 25 1996) that a lot has happened in terms of state of the art technology for building uranium mills and tailings operations in the last 17 years.

These assurances are in stark contrast with recent experience at Roxby, Beverley and Honeymoon.

At Roxby, despite being a very recent operation by a very large and well resourced mining company (WMC) and despite monitoring by both the company and the South Australian Government, there was a massive loss of liquid into the ground beneath the tailings retention system (Roxby Downs water leakage, Parliament of SA, Environment, Resources and Development Committee, 19th Rpt, April 10 1996) and two multi-million dollar fires.

The leak at Roxby occurred over a period of several years and there are no plans to clean up the toxic, radioactive material that leaked from the tailings retention system. The company involved (WMC) was not financially penalised for its failure to prevent escape of the contaminated water.

The fires at Roxby occurred in December 1999 and October 2001. Both fires occurred in the solvent extraction part of the processing plant. No Government report has yet been publicly released on the larger 2001 fire. The location of the fire and the subsequent large loss of uranium production suggests that the 2001 fire involved radioactive materials.

Beverley has been plagued by above-ground leaks and spills.

Both Beverley and Honeymoon are deliberately polluting aquifers with acidic, toxic, radioactive liquid.

3.  Radioactive Wastes

Social and political processes invariably lag behind technology. Mining, processing, and manufacturing often produces intractable wastes whose management has not been allowed for because it is not in the interests of business to allocate resources to areas that do not generate profit.

We have many instances, including in recent times, of wastes that were irresponsibly dumped, leading to contaminated sites, and of materials that should not have been used, such as blue asbestos.

The first principle of waste management is to minimise the production of the waste, which requires incentives to not produce and disincentives to produce. The producers of waste should be made responsible for waste treatment/disposal. If governments take on the responsibility for non-government wastes then this will act as an incentive to waste production.

If governments take on both a regulatory and a management role then they run the risk of conflict of interest and of being ineffective. If government charges for its services then there will be a tendency for the government to encourage more waste production so that they can increase revenue.

For all radioactive wastes the most effective management is to minimise the amount produced.

For existing radioactive wastes the only acceptable management is to immobilise and prevent entry into the biosphere. Above ground, secure, long term storage is the only ethically, environmentally, and socially acceptable way of managing radioactive wastes.

In the past, radioactive wastes have been treated with a very cavalier attitude by both the private and public sectors.

By far the largest amount of radioactive waste in South Australia is at Roxby Downs. About 80% of the radioactive materials taken out of the Olympic Dam mine are left on the site. In 1996-97 some 2.7 million tonnes of radioactive tailings were dumped into an area of 190 hectares at the mine (Olympic Dam Expansion Project, EIS, May 1997).

These wastes contain the radioactive isotopes uranium-238, thorium-230, radium-226, lead-210 and polonium-210, with half lives of 4.5 billion years, 80,000 years, 1,602 years, 21 years, and 138 days, respectively. The wastes will therefore be a radiation hazard for hundreds if not thousands of generations of South Australians. The concentrations of these isotopes in the tailings liquid varies from 10 (radium-226) to greater than 100,000 (thorium-230) times that in the local ground water.

Radioactive liquid wastes were also dumped into a 73 hectares evaporation pond.

In 1998 WMC embarked on an expansion that doubled the tailings production rate, and it is proposing a further expansion that will result in a tailings production rate of 12.5 Mt/a. The tailings will eventually be 30-35 metres high and occupy an area of 720 hectares. The evaporation ponds will occupy an area of 123 hectares. Total area of radioactive wastes will be 853 hectares.

WMC predicts that the mine will have a life of about 100 years. After the mine is closed the radioactive wastes will stay, covered by soil and rock. WMC has said that these 35 metre high structures will have a design life of 200 years and a structural life of 1000 years. It is highly dubious whether such will be the case. In any case it is not long enough to protect future generations from the radiation hazard. It is also highly unlikely that institutional arrangements will exist that monitor the site for 100 years let alone 1000 years. Yet people have lived in Australia for over 10,000 years and can be expected to want to live here for another 10,000 years.

The same type of acidic, toxic, radioactive waste that is being produced and crudely stored at Roxby is being pumped into the underground water at Beverley and Honeymoon.

Radioactive wastes from uranium mining should be managed in the same way as radioactive wastes from any other source. They should be securely stored above-ground as close as possible to the site at which they are ;produced.

The preferential treatment given to the mining industry in allowing its radioactive wastes to be stored in tailings dams or pumped underground should be replaced by secure storage in properly engineered above-ground facilities.

4.  Health and Safety

The 1995 publication of the National Health and Medical Research Council (NH&MRC) “Recommendations for Limiting Exposure to Ionising Radiation and National Standard for Limiting Occupational Exposure to Ionising Radiation” is indicative of the problem of regulating exposures to ionising radiation.

The recommendations in the document were based on 1991 International Committee on Radiological Protection (ICRP) recommendations, which followed the 1989 US recommendations (BEIR V report), which followed the 1987 UK (NRPB) guidelines, which followed general acceptance of the 1987 re-assessment of data from Hiroshima survivors.

It took the NH&MRC Committee of experts 8 years to get to the stage of making recommendations.

There is a major problem with radiological protection committees in that they invariably amount to the fox watching the chickens.

In South Australia, prior to 1990, the committee was made up of experts who were all involved in some way with the use of ionising radiation, either the medical or industrial uses of X-rays or uranium mining. There were two exceptions, an environment expert, who was nominated by the Conservation Council of South Australia, and a university geneticist. Everyone else was employed by, or received research grants from, the industry that it was supposed to be regulating. A WMC shareholder participated in the discussions and decisions on WMC’s uranium mine at Roxby Down. At that time there were no members who represented either medical workers or uranium mining/milling workers.

This is a highly undesirable arrangement that can only hinder the proper functioning of such committees, which should be reconstituted such that the membership is independent from the industry that it is entrusted to regulate.

The recommended allowable exposure to ionising radiation has been steadily decreasing from the earliest days of radiological protection. There has not been a single case where the allowable dose has been increased. As our knowledge of the effects of ionising radiation increases so the risks associated with it have been found to be higher and higher.

There is a clear trend in the assessed risk yet the NH&MRC and other groups, whose brief it is to protect people from ionising radiation, have not taken this into account.

Information is continually being collected, assessed and reassessed by expert scientific and medical authorities. The data is scarce. It comes mostly from studies of the survivors of the nuclear bomb attacks on Hiroshima and Nagasaki. In the near future we can anticipate additional evidence to come from the survivors of the Chernobyl nuclear power disaster. Other sources of information are uranium and radium miners including those from Radium Hill in South Australia.

Each time that the expert organizations have reassessed the data they have concluded that low levels of ionising radiation are more dangerous than was previously considered.
 
On the average, the expert organizations have concluded that the actual danger is twice as worse as they thought 12 years before. If this trend continues then during the life of Roxby Downs the officially determined danger will have increased about ten times.

This trend has not been taken into account at any time except, in principle, by the ALARA (As Low as Reasonably Achievable) requirement. However, this legal requirement has not, in general, been enforced.

For example, in the year 1988/89 at Roxby Downs, 29 workers received doses of 20 mSv/yr and higher. At a public meeting at Roxby Downs in 1990, the radiation safety officer said that there would be no difficulty in meeting the new ICRP recommended maximum dose of 20 mSv/yr. If there was no difficulty in achieving a lower dose rate then the ALARA principle requires that steps be taken to do this. The fact that this was not done, until the announcement of new maximum dose standards, demonstrates that the ALARA principle was not being taken seriously at Roxby.

The 1990 ICRP recommendations contain an escape clause in the form of using a five-year average. A worker may get a 50 mSv dose in one year (or even one day) provided they received no more than 100 mSv in five years. In principle an employer could rotate a number of workers through a particular job, which would normally be done by one worker, in such a way that the 5-year dose to each worker is less than 100 mSv. Worker rotation in order to keep individual doses below the maximum permissible is illegal but the same effect may be achieved through a practice known as ‘multi skilling’.

Worker rotation is contrary to what is acknowledged world wide, namely that the total medical effect is proportional to the total dose; the total risk is exactly the same whether 100 mSv is received by 1 person or whether 2 people receive 50 mSv each. If the risk is such that one person in a thousand will get cancer then doubling the work force will still lead to one person getting cancer. What the "5 year average" escape clause does is to enable the total dose received by the group to be much higher than if only one person did the task and the chances of adverse health effects is proportionally higher.

The recommendations on maximum dose rates are based on an assumption that at low doses there is a linear relation between dose and effect on human health and that there is no safe dose. This is often described by the nuclear industry as a conservative assumption. This is incorrect, a conservative assumption would be that the risk was greater than that predicted by the linear model. Conversely, a non-conservative assumption would be that the risk is less than that predicted by the linear model.

Because of insufficiently rigorous safety standards many workers at Radium Hill and Port Pirie were exposed to excessively high doses of radiation both external and through ingested radon and radon decay products. The standards are now higher but because no account is taken of the downward trend in permissible doses, future generations will judge this generation as harshly as we have judged the previous one.

The effects of this trend have already been felt at Roxby, where workers were exposed to doses that within a year were judged to be unacceptable. When the mine started, workers were allowed an annual dose of 50 mSv. By the end of the mine’s life the allowed annual dose is likely to be only 5 mSV; it has already fallen to 20 mSv.

Radiation workers who are receiving more than 5 mSv a year are putting themselves, their children and their children’s children at risk.

It is inevitable that all aspects of the mining and processing of uranium will lead to increased exposure of the local community, especially the workers, to ionising radiation from radioactive uranium and the accompanying radium and radon. This danger also extends to children conceived by these people. This increased exposure is unavoidable unless the entire mining and processing is automated in such a way that there is zero exposure to ionising radiation.

Because it takes about 20 years for solid cancers produced by low levels of ionising radiation to become apparent it is not easy to trace the cause. It is imperative that long term medical records are kept of all workers, residents and their children, including those conceived after leaving the area. A mandatory National Register has been requested for over 25 years.

Uranium mines are unique in that they involve radioactive materials that pose an extra hazard to workers and the public. It is a glaring anomaly that details of radiation exposure are kept from public scrutiny. Such secrecy does not serve to protect workers or the public.

5.  The Beverley Uranium Mine

5.1  Introduction

Uranium was discovered at Beverley in 1969. Plans to mine the uranium were abandoned in 1974 due to low uranium prices.

The project was revived in 1981 and a Draft EIS was prepared in July 1982. 

Because the uranium exists in a porous water-bearing layer (aquifer), it was proposed to use cheap but potentially polluting acid-ISL.

Acid-ISL involves injecting sulphuric acid into the aquifer in order to leach out the uranium. The liquid is then pumped to the surface where the uranium is extracted.

Acid-ISL mining trials carried out in 1982 at Honeymoon in SA were discontinued after the occurrence of blockages, which affected the ability of the operators to control the movement of the leach solution.

In 1983 both the Honeymoon and Beverley projects were cancelled by the SA Government, which cited four reasons for its decision (The Advertiser March 23 1983):

•	Many of the economic, social, biological, genetic, safety and environmental problems associated with the nuclear industry were unresolved.
•	Endorsement of the Government’s position by a wide range of community groups.
•	Commitment to the Roxby Downs project.
•	Community disquiet at the nature of the ISL process.

The then leader of the Opposition, John Olsen, said that a Liberal government would allow the projects to go ahead according to procedures outlined in the Environmental Impact Statements.

The Beverley lease was purchased in 1990 by the USA-based nuclear giant General Atomics Inc. Its Australian subsidiary is Heathgate Resources Pty Ltd. The mine is 100% foreign owned, there is no Australian equity.

General Atomics is heavily involved in the nuclear industry, including:

•	production and distribution of training and research reactors
•	development of gas cooled nuclear power technology
•	building of nuclear reactors
•	marketing of uranium hexafluoride conversion services
•	marketing of uranium oxide and uranium hexafluoride
•	operation of by-product disposal services
•	salvaging uranium from nuclear weapons
•	development, production and restoration of open pit, underground and in situ mining
•	operation of a nuclear fusion research centre.

5.2  The Mining Trials at Beverley

In November 1997 the South Australian Government gave permission for “trials” of acid-ISL at Beverley. Heathgate claimed that uranium was a by-product of these trials, which produced 33 tonnes of yellowcake.

Permission for the trials was given on the basis of a Declaration of Environmental Factors (DEF) written on September 5 1997.

The SA Government official responsible for the DEF process and for recommending the trials was formerly employed at the Ranger uranium mine and is now working as a consultant for Heathgate Resources.

There was no public consultation on the DEF and the relevant documents were provided by the South Australian Government in February 1998 at the last moment under the threat of a Freedom of Information request from the Australian Conservation Foundation.

In a statement from the Minister for Resources, Rob Kerin, on February 24, 1998 it was claimed “There is nothing secret about the Beverley Project. We have consistently released information as requested by the Conservation Foundation.” First as Minister and then as Premier, Rob Kerin consistently denied the ACF access to documents about the trials.

The trials commenced on January 2 1998.

According to both Heathgate and the South Australian Government the 4 to 12 month trials were a key step in providing information for an EIS, but one month after the trial started it was announced (The Australian, February 12 1998) that the EIS would be released in March, that is less than three months after trials began.

The final report on the trials was submitted to the SA Government in July 1999, three months after the Government had given the go-ahead for commercial operation of the Beverley mine.

The proposed leach solution was claimed by Heathgate to be only slightly acidic, being about 1,000 times more acidic (pH 3.5) than the water in the uranium bearing aquifer.

In actual fact the leach solution used was 200,000 times more acidic (pH 2) than the aquifer water.

The trials required the use of 163,000 kilogram (kg) of concentrated sulphuric acid (or the equivalent of about 600,000 kg of battery acid) and led to greatly increased concentrations of radioactive and toxic pollutants in the aquifer water.

2,700 kilolitres (kL) of acidic radioactive toxic liquid wastes from the trials were pumped into the aquifer at a site adjacent to the mining operation.

These wastes contain radioactive uranium, thorium and radium. A full analysis of the wastes was not given in the DEF, but the wastes contain arsenic, aluminium, cadmium, chromium, cobalt, nickel, selenium and vanadium in concentrations 30-800 times those present in the underground water.

Arguments used by Heathgate and the South Australian Government to justify the trials were misleading. They claimed that:

•	Most of the uranium in the US is obtained by ISL.
•	Heathgate is not disposing of anything in the aquifer that was not already there.

The ISL process used to mine uranium in the US is not the same sort of ISL process being used at Beverley: The US uses an alkali solution, whereas it is an acid solution that is being used at Beverley. Only the former eastern bloc countries (Eastern Germany, Czech Republic, Bulgaria, Ukraine, Russia, Kazakhstan, Uzbekistan) and China have used acid-ISL to mine uranium.

When Heathgate talked about the ‘aquifer’ they included the solids that make up the aquifer. Environmental concerns, however, relate almost entirely to the liquid in the aquifer. Radioactive and toxic materials immobilised in solids underground are not a major concern. The same materials when dissolved are a serious threat to health, safety and the environment.

Heathgate claimed at a public meeting on February 28, 1998 at Davenport near Port Augusta South Australia that all liquid wastes revert back to solids when reinjected into the aquifer, but no evidence was given to support this claim. Four years after the original claim no empirical evidence has been publicly released to support the claim.

It is intrinsic to the acid-ISL process that it mobilises radioactive and toxic materials. These materials should be properly managed. This requires that all wastes be contained in evaporation ponds and that all of the residual solids be kept out of the groundwater. This is not the case at Beverley where the liquid wastes are being deliberately disposed of into the groundwater.

In 1995 the South Australian Government held an inquiry into the leak of waste-water from the Roxby Downs tailings retention system which put underground water at risk.

As a result of the inquiry, Western Mining Corporation was required to improve the management of its liquid wastes in order to prevent further leaks.

The wastes that Heathgate is disposing of into the underground water are very similar to the wastes that WMC is not allowed to leak into the ground. Both wastes contain radioactive and toxic pollutants.

Heathgate Resources lobbied governments, environment groups and the general public about the jobs and royalties and about the safe, low impact, environmentally sensitive nature of the Beverley project. The project is neither environmentally benign nor does it provide many jobs.

A project EIS should include pilot plants, mining trials, and exploration mining.

5.3  The June 1998 EIS

5.3.1  Criticisms of the EIS

The EIS for the Beverley uranium mine was released on June 29, 1998, six months after mining started at Beverley, and one year before the final report of the trials was submitted to the SA Government. According to Heathgate and the SA Government the trials were a key step in providing information for an EIS yet the final report was not written until one year after the EIS and it was not publicly released until two years after commercial operation was given the go ahead.

After six months of operation:

•	The actual gamma doses to plant operators appeared to be unknown. The EIS talked about expected gamma doses.
•	Inhalation of long-lived alpha emitting radioactive substances were estimated rather than measured.
•	Computer modelling was used to predict radon increases due to the mine rather than direct measurement.
•	The proponents seemed to be in doubt as to the concentration of radon and radon decay products.
•	Atmospheric dispersion modelling was used to ‘estimate’ average worker radon exposure.
•	In the section on trial mine outcomes there was only one page that related to environmental protection.

As shown in Table 1 acid–ISL results in greatly increased concentrations of radioactive and toxic substances compared with the original ground water.

Table 1.	Increases in concentration of pollutants
due to acid leaching.

Pollutant	Concentration relative to groundwater	
	Extracted solution	Injected solution	
Acid	200,000	300,000	
Aluminium	170	170	
Arsenic	25	20	
Cadmium	210	200	
Cobalt	38	37	
Chromium	29	1.5	
Nickel	5,000	5,000	
Lead	3.8	2.5	
Radium 226	13	11	
Selenium	250	260	
Uranium	510	36	
Vanadium	780	760	

The extracted solution is a potential environmental threat due to possible leaks outside the ore body and into other water bodies (excursions).

The injected solution presents a similar hazard but in addition it shows the magnitude of the environmental folly of the project. This solution is of very similar composition to the ‘bleed solution’ that is deliberately disposed of into the underground water at rates of about one million litre per week.

The ‘bleed solution’ was said to contain “trace amounts” of selenium, molybdenum, and other “naturally occurring” metals. The selenium concentration in the ‘bleed solution’ is 260 times higher than in the natural groundwater. Some of the other “naturally occurring” metals are in concentrations that are 5000 times higher than the naturally occurring concentrations.

The amounts of dissolved pollutants injected into the underground water are summarised in Table 2.

Table 2.	Amounts of pollutants to be
disposed of in the underground water.

Pollutant	Amount / kg	
Aluminium	18,300	
Arsenic	20	
Cadmium	20	
Cobalt	2000	
Nickel	1000	
Lead	30	
Selenium	130	
Uranium	7100	
Vanadium	380	

5.3.2  Omissions from the EIS

•	The EIS did not make use of the experience of the former aborted acid-ISL uranium mine at Honeymoon in South Australia.
•	The EIS selectively gave an example of one case of acid-ISL uranium mining in the USA. It made no mention of other cases including in Eastern Europe, where Heathgate’s project manager, Charles Foldenauer, is believed to have had experience with acid ISL.
•	A key claim by Heathgate at a public meeting on February 28, 1998 at Davenport near Port Augusta South Australia, that all liquid wastes revert back to solids when reinjected into the aquifer, was not addressed.
•	Average background radon levels were given but no indication of the range. The average level of 11 Bq/cubic metre converts to a radiation dose of about 1 mSv/yr. This suggests that just living at the site is a significant radiation hazard. No data was given for sites that are not near uranium bearing ores.
•	The EIS did not address either the appropriateness of uranium mining or the uses of uranium. This is equivalent to mining asbestos without regard to its appropriateness or to the problems caused by the use of asbestos.
•	Instead of giving the background radiation for the Beverley site, the EIS gave a world average, which it claimed was “received by everyone in the world”. This is ridiculous; there is a wide variation in background radiation, with many receiving less, and many receiving more, than the average.
•	The data given on background radiation was presented in such a way that it was very difficult to estimate doses to workers at the Beverley site. The general impression, however, was that workers would receive about ten times the dose from gamma and radon sources that they would have received if they had worked at normal sites.
•	It was claimed that monitoring would be regular but no information was given on how regular: Was it to be daily, weekly, monthly or yearly?
•	It was stated that the monitoring program was still being planned. The proponents had more than adequate time to devise a programme.
•	It was stated in the EIS that “Any remaining ponded process solutions would be treated and disposed.” But no information was given on the method of treatment or disposal.
•	It was admitted under close questioning at a public meeting in Adelaide on August 6, 1998, that a spill of polluted liquid had occurred. This was attributed by Heathgate to a fault in the plastic piping. No information was given in the EIS about this or any other spills and leaks that may have occurred.
•	It was claimed in the EIS that experience from the “trials” indicates that the personnel gamma doses would not be large but gave no data to support this claim.
•	No data was given to support claims in the EIS about the radiation dose by inhalation of radon decay products.
•	No data was given in the EIS to support the statement that employee gamma doses from the project are ‘suggested’ by the data from the trials to be in the range 1 to 2mSv.

5.3.3  Gross Contamination of the Underground Water

It is intrinsic to ISL mining that the groundwater is contaminated by the leach solution and by the substances that it dissolves.

Acid-ISL is particularly polluting because acid dissolves many more pollutants than alkali. This fact was given very little attention in the EIS with the use of acid rather than alkali ISL being justified in commercial terms; the relative environmental impact of acid and alkali ISL was given low priority.

Unlike most mining projects in developed countries where liquid wastes are evaporated and the resulting solid wastes are responsibly managed, the liquid wastes at Beverley are disposed of by pumping back into adjoining and mined-out aquifers. This is a practice that should be rejected by responsible governments.

The low priority given to preventing pollution of the underground water was justified by the proponents in terms of the initial radioactivity and high salinity of the underground water.

No account was taken of the fact that most water, including the Adelaide water supply, is treated before it is of acceptable quality. Nor should the fact that the underground water is saline and radioactive be an excuse for polluting it.

There are plans to supply Kalgoorlie in West Australia with water obtained by the desalination of seawater at a cost of $750 million (The Australian August 3 1998). This is as an example of the value of any water resource no matter how saline.

Future options for the use of a resource should not be put at risk by irresponsible activities today.

There are no plans to restore the aquifers that will be polluted by the mining solution and liquid wastes from the project.

An environmentally responsible government would:

•	Not allow discharge its liquid wastes into the underground water but would evaporate the liquid wastes and properly manage the solid residue.
•	Require restoration of the aquifer to its original quality by flushing with clean water, evaporating the polluted water and properly managing the solid residue.

5.3.4  Spills of Toxic Radioactive Liquid

It was stated in the EIS that Heathgate Resources would undertake measures including “prompt wet clean-up of spills capable of generating radioactive dust”. This contrasts with statements made 6 weeks after the EIS was released, namely that there was no need to clean up some 500 litres of liquid that leaked from a plastic pipe on March 12, 1998 (The Australian, August 8, 1998; The Weekend Financial Review, August 8, 1998; The Advertiser, August 11, 1998).

It was claimed in Parliament by the Minister for Resources, Rob Kerin, that “It is the water from the aquifer which was actually spilt.” Kerin admitted that “the water” contained 340 mg/litre of uranium (which is 830 times higher than in the natural groundwater) and that a “mild acid solution” had been added (the spilt liquid was 200,000 times more acid than the natural aquifer water) but made no mention of the greatly increased concentrations of radioactive and toxic pollutants.

This spill released about 5 million Bequerel of radium-226 and about 100 gram of uranium.

It was claimed by Heathgate that removal of contaminated soil would do more environmental harm than leaving it there.

It was claimed in the EIS that “long-lived alpha dust doses will be negligible given that spillages are captured when wet ….” Yet the only spill that had been made public during the EIS process was not cleaned up.

Considering that this spill was made public only under pressure, the doubt existed about how many other spills occurred which had not been made public and which were not cleaned up.

This question was answered just before the 2002 SA state elections when a major spill of about 62,000 kilolitre containing some 8 kg of uranium triggered the revelation that there had been 22 previous spills that had not been reported to the public.

4.3.5  Radioactive Wastes

The plan to bury solid radioactive waste in shallow, unlined trenches was inconsistent with the guidelines for the national radioactive waste repository.

There was even greater contradiction between the guidelines and the planned disposal of liquid radioactive wastes into underground water. This aspect of radioactive waste disposal was not even mentioned in this section of the EIS.

5.4  Heathgate Resources Response to Submissions on the 1998 EIS. The September 1998 EIS Supplement

5.4.1  Acid-ISL of Uranium

Most of the local environmental impact of the project arises as a result of the uranium mining process, acid In Situ Leaching (acid-ISL). The Supplement defended alkaline-ISL of uranium and acid-ISL of other elements such as copper but ignored the real issue of acid-ISL of uranium.

Heathgate appears unable to defend the environmental record of acid-ISL of uranium. Difficulties with acid-ISL of uranium elsewhere in the world, in particular the former Soviet Union, were attributed in the Supplement to “management philosophies”. No attempt was made to show that the management philosophy at Beverley is environmentally better than that in the former Soviet Union.

It was claimed that in the western world, acid-ISL of uranium is not used because of the dissolution of heavy metals associated with the uranium deposit. As Heathgate’s own data shows, the dissolution of heavy metals and other toxic elements (such as cadmium, selenium and vanadium) is also a characteristic of acid-ISL at Beverley.

5.4.2  Water Pollution

A key claim by Heathgate at a public meeting on February 28, 1998 at Davenport near Port Augusta South Australia, namely that all liquid wastes revert back to solids when reinjected into the aquifer, was not addressed in the EIS.

The Supplement also gave no actual data. Instead, the Supplement gave results of a computer simulation for a twenty-fold dilution of the mining solution with native groundwater. This simulation produced the anomalous result that a 20-fold dilution of acidic mining solution (pH 2) with almost neutral water (pH 7.3) led to about a 10,000-fold decrease in acidity (to pH 5.8). The simulation gave no data for radioactive pollutants such as thorium-230 and radium-226.

The Supplement did not address the issue of what happens to the liquid wastes disposed in the aquifer outside the mining area nor did it defend itself against the proposal that liquid waste should be evaporated above ground.

The EIS stated that elution and precipitation solutions were to be disposed of in the underground water at rates of up to 100,000 L/week. Despite 6 months of trials the compositions of these solutions were not given in the EIS. The Supplement also did not give this information.

The bleed stream was said in the EIS to contain trace amounts of selenium, molybdenum, and other naturally occurring metals. However, the selenium concentration is 260 times higher than in the natural groundwater. Some of the other “naturally occurring” metals are in concentrations that are 5000 times higher than the naturally occurring concentrations. The Supplement did not respond to this criticism.

5.4.3  Ionizing Radiation

It was stated in the EIS “… gamma doses of plant operators are expected to be …”. After 6 months of operation the actual gamma doses should have been known. The Supplement states that the external gamma dose that workers will receive was between 1 and 2 mSv/yr. This is compared with a (average) dose of 0.35 mSv/yr received by the general public. Elsewhere the average gamma dose to workers was said to be 1.32 mSv/yr. Therefore the workers at Beverley already receive four times the external gamma dose that they would have received if they had worked on some non-radioactive project.

Annual average worker radon exposure was mentioned in the EIS but not the individual doses. The Supplement did not correct this omission. The Supplement gave only an average, 0.46 mSv/yr, which, considering the nature of the “radioactive province”, appears anomalously low.

Despite 6 months experience the EIS still seemed to be in doubt about such matters as the concentration of radon and radon decay products which were “expected to be very small except perhaps at the time of, and within the immediate vicinity of, groundwater discharge.”

The average background radon concentration of 11 Bq/cubic metre given in the EIS converts to a radiation dose of about 1 mSv/yr. This background value is double the value given in the Supplement for Beverley workers. This leads to the anomalous conclusion that working at the uranium mine lowers the radon radiation dose.

The Supplement stated that an intensive radiation monitoring program will be implemented once operations commence. This implied that such a program did not yet exist. This conclusion is supported by the lack of data from the trials in either the EIS or the Supplement.

5.4.4  Conclusions

Despite constant predictions from the nuclear industry that the demand and price for uranium will rise, uranium prices have continued to fall. In 1998 it was less than $US10 a lb.

The only way a company can make a profit in such a depressed market is to cut costs. This is the driving force behind acid-ISL. By using a cheap method for dissolving the uranium, by doing it in the ground, by not properly treating the mining wastes, and by not rehabilitating the aquifers, it is possible to cut financial costs to the point where companies can make a profit.

In effect, the company is transferring the costs to the general public in the form of environmental damage. This irresponsible and archaic practice was only possible through the cooperation of a government that put a low value on the environment.

Neither the EIS nor the Supplement addressed either the appropriateness of uranium mining or the uses of uranium. This was equivalent to mining asbestos without regard to its appropriateness or to the problems caused by its use.

5.5  The January 2002 Spill at the Beverley Processing Plant

At about 6.30pm on Friday January 11, 2002 a pipe burst at the Beverley uranium mine east of the Gammon Ranges in South Australia.

In about four minutes 62,000 litres of radioactive liquid escaped from the pipe into the area around the uranium processing plant.

The leak was an acid solution containing a mixture of chemicals. Some of the chemicals were innocuous salts, others were radioactive and others were toxic.

The liquid was the result of pumping an acidic corrosive solution into the aquifer in order to dissolve uranium minerals contained in the porous water bearing layer, or aquifer.

Because of the acidic corrosive nature of the liquid it dissolved a variety of minerals.

After passing through the aquifer this liquid laden with its assortment of dissolved minerals was being pumped into a chemical plant for the extraction of uranium.

In his final report, released on January 24, the Chief Inspector of Mines, Greg Marshall, identified a chain of events, all of which contributed to the accident. The causes were:

•	Loss of power to the computer system that controls and monitors plant functions.
•	Backup power was cut off as a result of what appeared to be failure to follow correct procedure during maintenance. This has been challenged by Heathate Resources who are still examining a suspect circuit breaker.
•	Incorrect computer programming resulted in pumps continuing to operate after power to the control system had been lost.
•	Pressure switches failed to operate and shut down the pumps.
•	Piping failed at well below its rated pressure.

This is an incredible series of failures. It cast serious doubt on the effectiveness of current regulatory processes. A review of the regulation of mining is urgently needed. In particular, is it appropriate that the department that promotes mining in SA is also the department that has the responsibility for regulating mining, including safety and environmental aspects?

The net effect of the above sequence of failures was that a large section of pipe blew out under pressure and the mining solution burst out over the processing plant at the rate of 15,000 litres a minute.

Over 8 kilogram of uranium was spilt in about four minutes.

This was a major accident involving radioactive and toxic materials.

The SA Government claimed that the spill was not a hazard to the environment or to workers. This claim is controversial and has yet to be substantiated.

Fortunately the accident occurred during the day and near the processing plant.

If the accident had occurred at night it would have been much harder to respond quickly. Much more liquid would have leaked.

If the accident had not been near the processing plant the liquid would have flowed over bare ground without any hope of containing it.

At Beverley there are kilometres of pipes both above and below ground, hundreds of joints, many valves, pumps and other potential failure points.

This is a feature that is unique to the type of mining carried out at the Beverley and Honeymoon uranium mines.

At Beverley and Honeymoon the ore is dissolved underground by circulating corrosive liquid, which is brought to the surface and pumped across open ground to the uranium processing plant. This type of mining has the potential for the accidental release of tens of thousands of litres of radioactive solution.

The SA Government did not release news of the accident until nearly 24 hours later.

Government inspectors did not go to the accident site until nearly 48 hours after the accident.

When inspectors did arrive they reported that there was no evidence of radioactive contamination. The basis on which this statement was made has yet to be released.

Presumably, because of the short time that elapsed between arriving at the site and reporting back, they did not do exhaustive tests on the difficult to measure radioactivity from alpha emitters.

Alpha radiation is a form of ionising radiation that is readily shielded. It does not penetrate a sheet of paper. Alpha radiation is of little concern outside the body but inside the body it becomes the most dangerous form of ionising radiation released by uranium mining.

Internal exposure to ionising radiation from alpha emitters - such as uranium, radon, radium, polonium and many other radioactive isotopes found associated with uranium deposits - has the potential to produce cancers in vital organs.

One type of alpha emitter released by the burst pipe at Beverley was the radioactive gas radon.

The burst pipe would have led to a sudden increase in radon gas around the processing plant. Because the gas is about eight times more dense than air it is not readily dispersed. Its dispersal is strongly dependent on wind conditions.

Workers at the processing plant would almost certainly have inhaled increased amounts of radon gas in the first hours after the accident.

Radon undergoes spontaneous disintegration with the emission of alpha particles. This occurs relatively quickly. In several hours about half of the radon atoms have disintegrated. This process forms other radioactive particles which tend to form solids rather than gases. These radioactive particles stay inside the body for a long time and continue to bombard tissue and cells with ionising radiation.

By the time inspectors arrived, two days after the accident, the invisible cloud of radon gas had probably dispersed.

Heathgate Resources claimed that immediately after the accident there was a marginal increase in ionising radiation around the processing plant.

Measurements of ionising radiation around such a plant are subject to large variations. The so-called background radiation may vary by a factor of two or more. It is therefore possible to have a doubling of radioactivity and still be within normal variations of the background.

Measurements of background radiation don’t necessarily discriminate between the various types of ionising radiation. Alpha radiation may not even be included in the measurement.

According to Heathgate Resources most of the 62,000 litres of mining solution that escaped was eventually contained with “evaporation ponds”. There are no evaporation ponds at the Beverly mine.

The Beverley uranium mine was given permission by the then SA Minister for Mines, Rob Kerin, to dispose of its liquid wastes by pumping them into the underground water. Kerin did not consult the public when he made this decision. Kerin’s decision was later confirmed by the then Federal Minister for the Environment, Senator Robert Hill.

Senator Hill’s decision followed a period of public consultation during which the environment movement argued strongly against dumping liquid wastes into the underground water and in favour of the alternative of above ground evaporation.

The company argued for pumping liquid wastes into holding ponds and then into the underground water. This is what has been happening at Beverley for over two years.

The ponds at Beverley are holding ponds, not evaporation ponds. They are labelled and described as holding ponds in the company’s EIS.

Evaporation ponds are many times larger than holding ponds yet in the company’s literature and media statements the holding ponds are labelled evaporation ponds.

The spilt mining liquid was put into the holding ponds along with other mining wastes and has presumably now been pumped into the underground water.

Because the accident occurred on a mining lease the SA Environmental Protection Authority (EPA) had no jurisdiction and was not officially notified of the accident.

As a result of publicity surrounding the accident the SA Government stated that they would close down the plant until after an inquiry, yet the plant was back in operation 24 hours after the accident. Heathgate Resources and the SA Government claimed that the plant had to be operated at about half its normal rate in order to carry out tests.

5.6  Other Leaks

The massive leak that occurred on January 11 was not the first leak at the mine.

It has since been disclosed that 23 leaks had occurred previously. Some of these leaks involved thousands of litres of liquid.

According to the Mines Minister, Wayne Matthew, none of these other leaks involved radioactive materials. This is highly unlikely.

The only liquid at the mine that is not radioactive is water from the desalination plant. It was unrealistic to believe that all 23 leaks were from the desalination plant.

It was far more likely that they involved the uranium extraction plant. In which case the liquid contained 40 to 500 times as much uranium as the underground water, which already contains uranium in excess of drinking water standards.

This has since been confirmed.

Since the January 2002 spill there have been other leaks and spills. Heathgate Resources’ position is that there are bound to be such releases. This is not a position that the company propounded before it started mining at Beverley.

5.7  The July 1999 Final Report by Heathgate Resources to PIRSA on the 1998 Field leach Trial

The date on this report is July 1999. This is 13 months after the EIS was submitted (June 1998), 10 months after the EIS Supplement (Sept 1998), and four months after approval was given for commercial production (March 1999).

The trials were given permission by the SA Government in November 1997 through a process that did not involve public consultation. It involved a Declaration of Environmental Factors (DEF). The details of this arrangement between the Government and Heathgate were eventually made public by the Minister, Rob Kerin, in February 1998 under threat of a FoI action.

The FLT went from January to December 1998.

One of the stated objectives of the FLT was “to provide environmental and radiation monitoring data for input into the Environmental Impact Statement (EIS), and to demonstrate appropriate environmental protection and radiation control measures.”

This objective contrasts with the facts that the EIS was submitted half way through the trials and that almost no environmental or radiation data from the FLT was given in the EIS.

The FLT report (p 46) makes a point that the amount of liquid waste disposed of in the aquifer was much less than anticipated. This was partly due to lower flow rates (6 L/s instead of 10 L/s) and hence less throughput (153 instead of 315 megalitres). The expected liquid waste under these conditions was about 8 megalitres. The amount disposed in the aquifer was 2.7 megalitre (34%). The remainder was presumably evaporated or was still held in the holding pond, which had a 3 megalitre capacity. This probably means that about 2.3 megalitre of water was evaporated. The important point is that none of the pollutants were evaporated and all have been, or will be, pumped into the aquifer.

The section on radiation monitoring results is less than 1/3rd page. Only average exposures are given and these were estimated. More precise data on radiation monitoring needs to be released.

Except for acidity, the data given in the figures of Attachment 2 of the re[port was incomplete and presented in a misleading way. Most of the data was for 9 Jan to 3 May. The rest of the data (May to Dec) was compressed in a non-linear fashion.

It was unclear from the data whether the oxidant was oxygen or hydrogen peroxide. Table 15.1 showed that both oxidants were used from January to June but only hydrogen peroxide was used from June to December. According to the Report (p48) oxygen was ineffective and hydrogen peroxide was very effective, yet Attachment 2 showed uranium concentrations dropping steadily from June.

Comparison of the data in Attachment 2 with that given in the EIS shows the EIS used data from the FLT during periods that were unrepresentative of typical mining conditions. This had the effect of decreasing the concentrations of pollutants given in the EIS. Concentrations during typical mining conditions will be higher than those given in the EIS. Some estimates and comparisons are given below. The most toxic elements are marked with an asterisk. For most cases of these toxic elements the use of FLT averages leads to an underestimation of the concentrations by about a factor of two. Data for chromium was absent from the FLT report.

Comparison of lixiviant compositions.
June 1998 EIS vs 1999 FLT report.

	Units	EIS	FLT	FLT/
EIS		
		Average	Typical
(estd.)			
Conductivity	mS/cm	12	14	1.2		
pH		2.25	2	1.8	   (Ratio of antilogs)	
Acidity	mg/L	877	1,400	1.6		
Aluminium	mg/L	37	60	1.6	*	
Arsenic	mg/L	0.05	0.1	2.0	*	
Barium	microgm/L	39	40	1.0		
Boron	mg/L	1.1	0.8	0.7		
Cadmium	microgm/L	42	80	1.9	*	
Chloride	mg/L	1,980	1,900	1.0		
Chromium	mg/L	0.58			*	
Cobalt	mg/L	4.2	12	2.9	*	
Copper	mg/L	0.03	0.1	3.3	*	
Fluorine	mg/L	3.1	5.5	1.8		
Iron (soluble)	mg/L	26	60	2.3		
Lead	mg/L	0.15	0.15	1.0	*	
Magnesium	mg/L	303	340	1.1		
Manganese	mg/L	0.55	0.7	1.3		
Mercury	microgm/L	<0.1	1	>10	*	
Molybdenum	microgm/L	1.56	3	1.9	*	
Nickel	mg/L	2.04	4	2.0	*	
Potassium	mg/L	60	65	1.1		
Radium-226	Bq/L	9,880	10,000	1.0	*	
Selenium	mg/L	0.25	0.5	2.0	*	
Silica (as SiO2)	mg/L	126	300	2.4		
Sodium	mg/L	1420	1,450	1.0		
Sulphate	mg/L	3,910	5,000	1.3		
Sulphur	mg/L	1,330	1700	1.3		
Uranium	mg/L	211	300	1.4	*	
Vanadium	mg/L	0.78	1.2	1.5	*	
Zinc	mg/L	0.25	1	4.0	*	

6.  The Honeymoon Uranium Mine

6.1  Background

The release of the EIS for the Honeymoon Uranium Project in June 2000 came at a time of a declining nuclear industry faced by low prices for uranium and endeavouring to exploit concerns about global climate change resulting from the enhanced greenhouse effect.

Low uranium prices are primarily the result of the uranium market being flooded with cheap highly enriched uranium (HEU) from nuclear weapons. This uranium was purchased by governments at taxpayer’s expense. Its release at very low prices for electricity generation is a taxpayer subsidy to the nuclear power industry. It also demonstrates that the distinction between military and non-military uses of uranium is a myth. There is only one market for uranium and the market makes no distinction between military and non-military uses.

Because of the chronically depressed nature of the uranium market many uranium mines are being closed down. New mines can compete only by using the cheapest possible mining techniques. This means that mining has to be done on a large scale using automated equipment employing a minimum of workers; it also helps if the uranium is mined in conjunction with other elements. Alternatively, small deposits of relatively high-grade ore may be economically mined by using acid in situ leaching (acid-ISL). Even this inherently low cost method may be too expensive if environmental standards are rigorous. By far the cheapest method is acid-ISL in conjunction with shallow disposal of liquid wastes and no rehabilitation of the mined out areas. This was the approach proposed by Southern Cross Resources in its EIS for the Honeymoon Uranium Project.

The Honeymoon EIS was released at a time of strong community concern about the disposal of radioactive wastes in South Australia and of widespread opposition to Federal Government plans to take its radioactive wastes from Lucas Heights near Sydney and to either dump or store them in the South Australian outback. The preferred area, Billa Kalina, is in the vicinity of Roxby Downs and Woomera.

The SA Government has introduced legislation against the importation of radioactive wastes into SA and plans to build its own waste facilities.

Radioactive waste is a by-product of using uranium. Without uranium there would be very little radioactive waste. The first priority in managing any intractable hazardous material is to minimise its production. In the case of radioactive waste this means minimising the use of uranium, which in turn means minimizing the mining of uranium.

The Honeymoon Project not only contributes to the world’s radioactive waste but it directly produces large amounts of radioactive and toxic wastes which Southern Cross Resources is pumping into the underground water on its mining lease. This practice was condoned by the SA and Commonwealth Governments.

Uranium was discovered at Honeymoon in 1972. Plans to mine uranium at Honeymoon started in 1979 and a draft EIS was prepared in July 1982.

Because the uranium exists in a porous water-bearing layer (or aquifer), the cheap but polluting process of acid-ISL was used. Acid-ISL involves injecting sulphuric acid into the aquifer in order to leach out the uranium. The liquid is then pumped to the surface where the uranium is extracted.

Acid-ISL mining trials carried out in 1982 at Honeymoon were discontinued after the occurrence of blockages, which affected the ability of the operators to control the movement of the leach solution.

In 1983 the Honeymoon project was cancelled by the South Australian Government, 

The then leader of the Opposition, John Olsen, said that a Liberal government would allow both the Honeymoon and Beverley acid-ISL mines to go ahead according to procedures outlined in the EIS’s.

In May 1997, the Canadian-based company Southern Cross Resources purchased the Honeymoon project from Sedimentary Holdings. Sedimentary has a 34.6% share in Southern Cross Resources.

Guidelines for the environmental impact of mining at Honeymoon were released in March 1998. By then a “demonstration” plant had been operating for several months and in April 1998 the SA Government gave permission for “trials” of acid-ISL at Honeymoon. This resulted in a fourfold increase in the rate of mining, which continued for the two years prior to release of the EIS in June 2000.

There is little difference between “trials” and “commercial production” it is just a matter of size. The South Australian Government gave permission for a highly controversial project without allowing public scrutiny or input through an EIS.

Permission for the Honeymoon “trials” was given on the basis of a Declaration of Environmental Factors (DEF) written on October 31 1997 but not publicly available until after the SA Government had given permission for the trials in April 1998.

The Honeymoon DEF was a grossly deficient document, lacking basic information such as background radiation levels, estimates of radiation doses, and comprehensive chemical analyses. It appeared to be based almost entirely on the previous EIS, which was written 16 years earlier. In some cases the information was 22 years old.

The DEF stated, “A 1975 engineering appraisal indicated quite clearly that the deposit could not support a viable open cut or underground mining operation.” This statement implies that there has been no progress in mining technology in the last 22 years.

Incredibly for a uranium-mining project, the draft DEF contained no data on ionising radiation, either background levels or increased levels due to the project or doses to workers.

Southern Cross Resources justified the lack of ionising radiation data in the draft DEF on the basis that the DEF guidelines did not require such information. This is an indictment of the Government department that supervised the DEF.

Some material referred to in the DEF, such as a study by the Aboriginal Heritage Unit, is undated and un-referenced, and may be 16 years old.

The DEF made no reference to the problems with blockages and excursions of the mining solution encountered in 1981. The DEF contained no strategy for avoiding a repeat of the problems that contributed to the mine closure in 1982.

Production of uranium during the trials was about 60 tonnes a year and used about 250 tonnes a year of concentrated sulphuric acid (or the equivalent of about 1000 tonnes of battery acid). These trials went on for 30 months so that about 150 tonnes of uranium were produced before the EIS was released to the public.

The “trials” produced liquid radioactive wastes at the rate of about 9 million litres a year. These wastes have been pumped into the underground water. About 20 million litres of radioactive toxic wastes were pumped into the underground water before the EIS was released to the public. Southern Cross Resources wants to pump about 200 million litres per year of radioactive toxic wastes into the underground water.

During “commercial production” the amount of acid required will increase by at least a factor of 4, i.e. to 1000 tonnes (or the equivalent of about 4000 tonnes of battery acid) per month. The mine is planned to eventually produce up to 1500 tonnes of uranium a year.

6.2  The June 2000 Honeymoon EIS

The EIS claimed to have consulted with both the Conservation Council of SA (CCSA) and the Australian Conservation Foundation (ACF). The extent of this consultation can be judged by the fact that the EIS did not give the correct names of these organizations.

The company did not deal directly with community groups. When, as a pre-requisite to consultation, information was requested from Southern Cross Resources no response was received.

The EIS made no mention of how uranium produced by the project would contribute to the world’s radioactive waste. The terms of the EIS did not even allow such matters to be discussed.

According to the EIS, the Guidelines “specifically exclude any requirements to address policy issues about the appropriateness of uranium mining or the use of exported uranium in the nuclear fuel cycle”. This did not prevent the EIS from addressing these issues but it appeared that Southern Cross Resources was reluctant to address them.

Southern Cross Resources tried to justify uranium mining in terms of greenhouse emissions. Southern Cross Resources claimed: “In a global context, the project will indirectly contribute to a significant environmental benefit - reduction in ‘greenhouse gas’ emissions.”

Southern Cross Resources, however, seemed to have a poor understanding of the enhanced greenhouse effect, claiming “because of Honeymoon’s isolated location and prevailing weather conditions, greenhouse emissions will be quickly dispersed with no local or area effects.” The enhanced greenhouse effect is a global, rather than local, phenomenon and involves the upper, rather than the lower, atmosphere. Because it is energy intensive, mining makes a major contribution to the enhanced greenhouse effect.

The EIS was incomplete, foreshadowing “amendments” to cover deposits other than those dealt with in the EIS. These deposits could eclipse, both commercially and environmentally, those covered by the EIS. The company hopes to get permission for major extensions to its operations without any public consultation.

Despite 30 months of trial mining the company was unable to say where the water for acid-ISL would come from. The company hinted that, because the water in the aquifer that they are mining (the basal aquifer) is very salty, they may have to use water from the upper aquifer. This appeared to be an attempt to get permission based on using water from the basal aquifer and then to use water from the upper aquifer.

The amount of water that the project would contaminate with radioactive and toxic elements is already huge. If the company is permitted to use the upper aquifer water then the amount of water contaminated will double and better quality water (from the Upper Sand aquifer rather than the Basal sand aquifer) will be polluted.

As well as water used for making up the leach solution large amounts of water will be used for other purposes. The total usage proposed was about 660,000 litres per day, or about 240 million litres per year. There appears to be no charge for this significant use of a public resource.

Southern Cross Resources used nuclear industry forecasts to predict a shortfall in supply from 2010 onwards. The nuclear industry is notorious for its over-optimistic forecasts and has been consistently wrong in predicting uranium demand and price.

Southern Cross Resources also claimed that the only way to meet the predicted shortfall is to increase mine production. One of the main reasons why industry forecasts of uranium demand and price have been grossly optimistic is that they fail to take into account highly enriched uranium from nuclear weapons. The supply of fissile material (uranium and plutonium) from nuclear weapons is likely to increase into the foreseeable future. If this happens the price of uranium and the demand for new uranium will remain low.

Southern Cross Resources wants to dispose of its toxic radioactive liquid waste in the underground water at a rate of about 500,000 litres per day. Its justification for this is that “The already high levels of naturally occurring radionuclides and salinity in the basal aquifer means that it is unsuitable for watering stock or any other purpose.” This statement is nonsense. Not only is the water potentially useful but also lower quality water is being used throughout Australia, including SA, for human consumption. One of the major uses for such water is for remote communities and mining communities that commonly use reverse osmosis to desalinate underground water.

The Honeymoon project itself plans to use this process to supply drinking and cooking water; the project plans to treat by reverse osmosis 150,000 litres of Upper Sand aquifer water per day. This water’s salinity is about half that of the water in the aquifer being mined. If, as anticipated, water from the Upper Sand aquifer has to be used for making the leach solution then vastly increased amounts of water will have to be desalinated, approximately 5 million litres per wellfield pattern.

Southern Cross Resources claimed, “operation of the Field leach Trial disposal well has shown that most elements and compounds remain within the baseline range.” No evidence was given in Appendix 10 (Field Leach Trials) to support this claim. The baseline range was so large that a 100-fold increase in radioactivity could have occurred. The range for uranium was 0.02 to 7.3 mg/L and for radium-226 it was 30 to 450 Bq/L. Similar ranges exist for other toxic elements.

The proponents claimed: “Adequate sealing and monitoring of solar evaporative ponds would be difficult because of the relatively large area, approximately 10 ha, involved.” By contrast the Olympic Dam project at Roxby Downs uses evaporation ponds ten times this size.

Despite prolonged Field Leach Trials the proponents were unable to state what oxidants will be used. They stated that oxidants other than oxygen, hydrogen peroxide, sodium chlorate and ferric sulphate could be used. The oxidant has a major effect on what elements, other than uranium, are dissolved and hence on the pollutants which will be disposed.

They also claimed, “The leach solution will also mobilise to a minor extent Ra-226, silica, aluminium, copper and zinc.” According to Table 4.2 these elements are increased by factors of 5, 14, greater than 15, 350, and 550, respectively. No mention was made of vanadium whose concentration increases by a factor of greater than 200.

The acidic solution loaded with uranium, radium and numerous toxic elements pumped from production wells (pregnant solution) was described as “natural ground water”.

Southern Cross Resources claimed that “compliance with the goals and principles set out in the National Strategy for Ecologically Sustainable Development” was a guiding principle in the preparation of the EIS. This claim is inconsistent with the failure to address the contribution of the project to the nuclear industry and its associated ecological impacts.

The project will generate greenhouse gases at a rate of about 9,000 tonne per year.

The EIS contained no commitment to using renewable energy.

There was no section in the EIS on compliance with ecologically sustainable development.

The field leach trials were justified in terms of providing data for further mining. The section on the trials (Appendix 10) was only 4½ pages long and contained little data that could be used to assess the proposal.

There was no data on:

•	Chemicals used.
•	Uranium produced.
•	Water analysis in the vicinity of waste disposal wells.
•	Radiation monitoring.
•	Radiation doses received by employees.
•	Injection well scaling and blockage.
•	Excursions of leach solution outside of the designated area.
•	Changes in composition of the aquifers.
•	Greenhouse gas emissions.
•	Compliance with ecologically sustainable development.
•	Spills and leaks.
•	Radioactive wastes generated.
•	Radioactive waste management.
•	Water usage.
•	Energy usage.

Southern Cross Resources gave nine arguments in support of the mining proposal.

The first two arguments were invalid because they depended on speculation about the demand for uranium. In the past the nuclear industry has greatly over-estimated the demand.

The third argument depended on the use of environmental shortcuts and on large uncertainties in the details of the proposal:

•	The liquid waste disposal method used in the Field Leach Trial is environmentally unacceptable. Responsible disposal involving evaporation rather than pumping into the underground water supply will increase the project costs.
•	Use of the upper aquifer water and desalination rather than raw basal aquifer water will increase project costs.
•	The assumed market for uranium was speculative.

The sixth argument pre-empted the EIS process.

The seventh argument ignored the impact on traditional owners other than the native title claimants.

The eighth argument pre-empted the EIS process and was inconsistent with the absence of plans to rehabilitate the ground water.

The ninth argument was related to government policy, which does not necessarily accord with the attitude of the general public and which changed at the next State election.

There were only two valid arguments in favour of the proposal and these were the contribution of $30 million to the GDP and the generation (including assumed indirect employment) of 200 jobs.

These short-term benefits are offset by:

•	Pollution of underground water.
•	Use of large amounts of water, at no charge to the proponent.
•	Increase in greenhouse emissions and the effect that they will have on costs incurred by the Australian economy in meeting its greenhouse gas emission target.
•	Costs to health and safety of increased levels of radioactivity in the environment.
•	Costs to Australian agriculture of increased levels of radioactivity in the local environment.