From: mitchellodge@impulse.net.au Sent: Sunday, 18 August 2002 10:01 PM To: ecita.sen@aph.gov.au Subject: Enquiry into Environmental REgulation of Uranium Mining Pat Finegan 11 Koomba St. Bendigo Vic. 3550 Ph. 03 54 444 595 The Chairperson Senate Environment, Communications, Information Technology and the Arts References Committee Re: Enquiry into Environmental Regulation of Uranium Mining. I would like you to consider my submission in this matter. Australia has a long and rocky history in Uranium mining. By it's very nature this industry is in the main established in fairly remote areas of our continent which adds to the difficulty in dealing with any accidents and also can lead to the possibility of greater secrecy surrounding the process of reporting. Mining of any sort has always been high risk both commercially and in terms of physical safety. Of course the introduction of Worker's Compensation payments can be traced to the disgraceful and neglectful actions carried out over many years in the Mining Industry. The extra physical risks involved in the Mining of Uranium have added greater dimensions to the need for regulation. Whilst in the past it was mainly the protection of the workers on the job which focused attention, now the environment, the social and health effects upon the Aboriginal community, the public at large, the whole world in fact can and does suffer serious ramifications from the establishment and extension of this industry. Dr. Rosalie Bertell in her book "No Immediate Danger" on page 22 states Radioactive lead, a daughter product of the radon gas released by uranium mining, is a cause of lead poisoning and brain damage, just as any lead. Then further on P. 217 uranium ore emits penetrating gamma radiation as well as radioactive radon gas. And of course on P.84 The radon gas released from the mine and mine tailings is heavier than air and can spread 1,000 miles from the source in winds of 10 to 15 m.p.h. before half is disintegrated . These statements reinforce the need for greater regulation and the need to tread carefully when dealing with any agency which is intent in making profit at any expense, no matter what the consequences may be. I welcome your interest in the matters of regulation and consider such an enquiry long overdue. However you would no doubt be aware that the Uranium mining Industry has inherent dangers and has a proven history across the world of ignoring public interests. The concern that I have therefore is that this exercise may only result in the accumulation of further statistics indicating that pollution has occurred without any satisfactory consequences being put into place for the breaking or disregarding these regulations. Of course the issue of whether the resources are put into place to properly oversee that these regulations are adhered to is one to which you could rightly address yourselves. In this submission I have drawn on research gleaned from The Friends of the Earth organization and it's many resources. I would like to thank Dr.Gavin Mudd, Bruce Thomson and Dave Sweeney who have made lots of information available to me. The Gundjehmi Aboriginal Corporation submission to the 26th World Heritage Committee also provided some excellent material. The Web site of the Mirrar People has also informed my understandings. Any mistakes in the document would result from my misinterpretation of their findings and I apologise to my sources but I take full responsibility for them. Honeymoon:-In the early 1980's a student from the Coburg Teachers College approached me regarding Honeymoon. In my ignorance I presumed that she may be somewhat cash strapped and was requesting some assistance towards her own marriage. However she was able to inform me that there was a mining company wanting to introduce a new system of extracting Uranium from the underground water table in South Australia. I have subsequently lost track of that young woman's whereabouts but have become aware that although this system was considered to be unsuitable in the Australian outback, that now a Canadian company, Southern Cross Resources has obtained a 5 year licence to export Uranium using the In-situ leach process of extraction. This process requires that a solution of sulphuric acid be pumped into the water table (aquifer) where it combines with any Uranium found there, and under continued pressure they are brought to the surface where the Uranium is removed and the waste pumped back into the aquifer. Given the nature of a water table, which of course, is hidden from view, any break down in the process may not be apparent for some time, it would be difficult to fix and could result in a major leak before action could be taken to bring the process back on track. As much of our Great Artesian Basin relies upon water which has seeped from the Great Dividing Range over centuries, and has not been reliably mapped, any leakage of radioactive materials into this wonderful resource could likely prove to be a disaster for pastoralists, their cattle and sheep, Aboriginal communities and of course our own unique indigenous flora and fauna. Already a leak has occurred which has been reported upon in the assessment report for the Environmental Impact Statement in November 2001. On page 62 the report raises the question as to whether 'excursions may be more frequent than Southern Cross Resources expects' Not a very auspicious omen. Perhaps even more ominous because this leak allowed two previously separate aquifers to mix their contents. The big unresolved question facing the Nuclear industry is that of the disposal of their waste. In the instance of this mine, it is proposed that all radioactive wastes and heavy metals be re-injected directly back into the groundwater reserve (The Basal Sands Aquifer) with the assumption that these materials would return to a natural state over time I understand that there has not been any remedial chemical analysis carried out to research this finding. I am led to believe that there has been no access by any independent group to carry out research. This surely in a country which prides itself on being the upholder of the 'fair go' principle is an anachronism and a denial of the public' 'right to know'. It is clearly an abrogation of the 'transparency' principle, something which has been highlighted recently in America as being absent from the Board rooms of large corporations. Since February 1999 there have been 7 'incident' where leakages occurred, including the one mentioned above which, incidentally was not reported for nearly two years whilst the government approval process was in train. With the danger of being thought to be flippant, it would seem to me that the honeymoon is over for Southern Cross resources and it is time that it's reckless and irresponsible method of mining be terminated as soon as possible. Beverley:- Another mine using the In-situ Leach process for the extraction of Uranium. According to the records reported to Primary Industry and Resources S.A. there have been 28 leakages since February 2001, with only one 'incident' being reported for each year in 1998, '99 and 2000. The surface spillage of 61,000 litres at this site in January this year is reprehensible, Had it occurred in less favourable circumstances the effects would have been much more far reaching environmentally. Incidentally, there are no other mines using this process of In situ leaching with Sulphuric acid amongst the O.E.C.D. nations. Olympic Dam:- This mine has been at the centre of controversy since it's inception. This is a large underground mine and hence employs a large work force. The nature of the mine exposes the workers to the usual mining hazards as well as the radiation hazards. There are a number of incidents on public record which include fires (two at almost the same place in spite of recommendations to provide safer working situations), 'pond spills', 'process spills', 'Diesel leaks', an underground explosion accident, 'sulphuric acid spill' resulting in two workers being seriously injured, an explosion in the new acid plant, fatality as result of crushing accident, 23 workers being overcome by fumes in the smelter area. Radioactive scrap metal was discovered in Adelaide. Back in 1994 a leakage of 5 Billion litres of tailing liquid was reported as occurring over a two year period. It is apparent that some of these 'incidents' are quite serious and often in Industrial situations the culture that it is 'necessary to be tough' can often lead to a down grading in the areas of safety, or perhaps to put it more succintly, there is a culture of 'looking after your job' where, to report an incident can be seen to be likely to bring a 'mark against your record'. Jabiluka:- This project has been the subject of constant conflict and public concern since it's conception. Most of all it is opposed by the local Aboriginal community . "The Mirrar People still say no to the Jabiluka Mine. They understand that they are protecting their sacred sites and it is only reasonable that their wishes be respected. I am sure that St. Patricks cathedral in Melbourne would not be subject to a mining claim, no matter what the evidence. In September 1999 construction of this mine was halted and it has been placed on an 'environmental care and maintenance' footing. The site has already been plagued by water management problems. Ranger:- There have been over 110 environmental incidents at this facility since it was opened in 1982. The delays in reporting incidents is similarly a concern as it is in all the other Uranium mines. It is reprehensible that a tailing water return pipe leak should go unreported for over three months. This happened in the year 2000. As recent as this year the levels of uranium in the creeks flowing into the Kakadu National Park showed increased levels. The companies over the year of managing these mines have shown scant regard for the consequences of their actions and could be accused of having a cavalier attitude to the issue of protection of the environment. The run off into the creeks earlier this year caused by the alteration to a stockpile,was the result of careless and flagrant breaches of the regulations in force at the time. Even though the monitoring carried out by the Supervising Scientist indicate that there was no harm to the environment or human health, that such an incident could have occurred at all indicates that the supervision and/or the instructions given were inadequate. Surely the understanding that these mines are within 'cooee' of a National Park should have alerted the Company to the fact that they would be under strict public scrutiny. Hence one would think that the standard of supervisions of workers and the monitoring of the processes would be strengthened even if just to protect their own back. Yet what do we have? 110 reported environmental incidents in twenty years. The Gundjehmi report covering incidents occurring at both the Jabiluka and the Range mines indicate that over a two month period the Mirrar had received news of five issues of concern. 1) ERA (Energy Resources Australia) neglected to report elevated uranium levels at Jabiluka by five (5) weeks 2.) Elevated uranium levels were detected some three (3) kilometres downstream of the Ranger mine at gauging station 009 3.) Elevated uranium levels were detected at Ranger Retention Pond 1 4.) ERA incorrectly placed 84,500 tonnes of Uranium at the Ranger mine 5.) A former employee has alleged inadequate environmental (mis)management at Ranger, the contamination of the surrounding World Heritage Area and a subsequent cover-up, and misleading reporting to regulatory authorities of environmental incidents at the mine Summary:- My concern about this process of putting more regulation into place doesn't address the issue of the fact that this is in fact a dangerous industry and there are extremely strong arguments against it's legitimacy. Surely there is already an excess of data which proves that this industry is unsustainable, environmentally, socially and financially. The next question then is When is it going to be relegated to the stockpile of history? The fact that the end result of the products mined doesn't receive any consideration also concerns me deeply. Dr. Helen Caldicott, in her recent book 'The new nuclear danger' clearly outlines that uranium is being used to pollute countries in the middle east with disastrous results to the civilian populations. Even though the argument may be postulated that our uranium is not being used, it most certainly allows uranium from other countries to be used. However I am told that I must face the fact that there is an Uranium industry in this country and that you are asking for advice regarding regulating the industry. Consequently I would ask the Senate enquiry to recommend: - That all spills/leaks/accidents/incidents be thoroughly investigated and publicly reported - A reporting regime which includes all chemical and radiological constituents of potential health and/or environmental concern - If spill samples are not available, then the most recent relevant monitoring data should be used in conjunction with initial reporting of the occurrence until more detailed soil and/or water analyses are available - The an 'online Database' be established for incidents at each site, to be administered and made available through each state and territory EPA organization - Community Consultative forums or Committees be reconstituted to ensure political and corporate independence, and play a pro-active role in operation and incident investigation and reporting at all sites - The Commonwealth provide proper funding (time and costs) of two positions on the forum/committee for each site - An overhaul of the present environmental regulatory regime, to provide greater transparency and independence - greater involvement of traditional Aboriginal owners in the establishment and oversight of any new environmental monitoring and reporting regime - more statutory monitoring points at all operations and a greater frequency of monitoring - event based monitoring, whereby weather events trigger immediate response monitoring - That the so called 'limit' for uranium concentrations detected at Kakadu National Park downstream of the operations be reduced from 5.8 parts per billion to 0.5 parts per billion - Return unprocessed ore down the Jabiluka decline, which can then be concreted in and revegetated Yours sincerely Pat Finegan