Jabiluka Mill Alternative

Appendices

Appendix 1 - List of Public Respondents to the Jabiluka PER

Of the 2,204 submissions received during the public review period, 2,132 were form letters. Two types of form letters were used by the public, with the Department receiving 1,583 of the first type (Form Letter 1), and 549 of the second type (Form Letter 2).

Form Letter 1

The issues raised in this letter are summarised below:

• Concerned about the absence of key baseline data, lack of product life cycle assessment methodology, discretionary nature of the requirements placed on the proponent and the failure of the process to deal with opposition to the project by the Mirrar traditional owners.
• Protection and management of reserved areas, the implications of Australia's involvement in the international nuclear industry, and indigenous rights must be fully addressed and seen to be addressed.
• The PER for the proposal continues to be inadequate in the level, scope and detail of assessment. Justification for the PER is based on the presumption that the Ranger Mill EIS covers most of the issues. It does not. It was viewed as 'seriously deficient' by Environment Australia and other organisations.
• The PER is not appropriate for the assessment of a wide range of issues including radiological exposure, impact upon World Heritage, and social impacts upon Aboriginal communities.
• The scope of the PER is insufficient given the nature and context of the proposal. The guidelines specifically exclude discussion of the 'appropriateness of uranium mining' and the broader nuclear fuel cycle, including the generation of long-lived highly radioactive wastes.
• Consideration of a 'No Project Option' is absent. This undermines the objectivity of the assessment process as it implies that the project will go ahead in spite of critical evaluation.
• The proponent, ERA, is incapable of independently assessing its own environmental impact.
• The close of public comment for the PER Draft Guidelines was on Monday 1 June 1998. ERA had printed and distributed copies of its PER by Friday 5 June 1998. Failure by the Ministry of the Environment to ensure that the proponent allow for proper review of the public comment before publishing the proposal contradicts the spirit if not the letter of the EP(IP) Act.
• The Environment Minister should direct a Commission of Inquiry into the JMA proposal under the provisions of the EP(IP) Act.
• Works should not be conducted on the Jabiluka Mineral Lease while any form of Commonwealth EIA process is operative.

The Submission Numbers which correspond to Form Letter 1 are listed below:

0002-0019, 0021, 0024-0040, 0043-0150, 0152-0175, 0177-0186, 0188-0201, 0203-0214, 0216-0217, 0219-0221, 0223, 0225-0226, 0235-0256, 0258-0280, 0304, 0320-0322, 0324-0325, 0328-0333, 0355-0361, 0364, 0367-0380, 0401-0405, 0407-0408, 0432-0443, 0450, 0468-0568, 0570-0634, 0636-0637, 0639-0673, 0675-0692, 0694-0739, 0741-0781, 0783-0787, 0789-0851, 0853-0872, 0874-0913, 0999-1021, 1032-1033, 1080-1130, 1335, 1341, 1347-1351, 1353-1356, 1358-1412, 1414-1425, 1427-1450, 1452-1458, 1460-1483, 1485-1492, 1507, 1510-1511, 1567-1574, 1576-1627, 1630-1983, 1985-1993, 1995-1998, 2001-2005, 2007-2022, 2024-2030, 2032-2043, 2045-2189, 2191-2192, 2203.

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Form Letter 2

The issues raised in this letter are summarised below:

• Concerned that the proposed mine will create environmental damage, risk workers' health, provides no extra jobs, has faulty economic claims, has a flawed EIS and will bring the total radioactive tailings buried in Kakadu to 60 million tonnes.
• Concerned about safety in relation to the extraction of uranium ore and the transportation of uranium oxide.
• ERA claim that Jabiluka will bring $3.8 billion over 28 years. This accounting excludes the environmental costs associated with the industry and the social costs of the mine.
• The environmental cost of a uranium mine in a World Heritage area listed for its natural and cultural values is too great.
• Kakadu is a refuge for 120 species of reptiles and amphibians, with 50 species of fish and over a quarter of Australia's terrestrial mammals. To jeopardise the future of this refuge is completely irresponsible.
• Kakadu has been inhabited by Aboriginal People for over 40,000 years. The country has some of the oldest and best preserved archaeological sites. The proposed Jabiluka Uranium mine threatens the traditional relationship of people, land and culture.
• The Mirrar have always opposed uranium mining and intrusive non-Aboriginal development.

The Submission Numbers which correspond to Form Letter 2 are listed below:

0176, 0218, 0222, 0224, 0227-0234, 0281-0303, 0305-0319, 0323, 0326-0327, 0334-0354, 0362-0363, 0365-0366, 0381-0400, 0406, 0409-0431, 0444-0449, 0451-0467, 0914-0998, 1022-1031, 1034-1079, 1131-1334, 1336-1338, 1513-1566, 1575, 2204.

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Appendix 2 - Public Examination Places for the Jabiluka PER

State Library of New South Wales	Sydney
State Library of South Australia	Adelaide
State Library of Victoria	Melbourne
Northern Territory Library	Darwin
Queensland State Reference Library	Brisbane
State Library of Tasmania	Hobart
State Library of Western Australia	Perth
Jabiru Library	Jabiru (NT)
EPA Library	Canberra
Environment Protection Division	Darwin (NT)
The Internet (Summaries Only)	www.north.com.au/era

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Appendix 3 - Issues Raised in Submissions on the Jabiluka PER

Development Proposal and Alternatives

• PER is not an appropriate level of assessment. An EIS would have been appropriate.
• There was insufficient time to provide detailed comment on all aspects of the proposal.
• There is a lesser level of confidence that the JMA proposal will not directly effect Kakadu than the RMA. It would be unfortunate if the "best" environmental option could not be adopted for a mine adjoining a world heritage area.
• The "do nothing" option has not been adequately addressed.
• The BPT assessments, including the weighting given to different factors and the alternatives considered in the assessment, are not provided for evaluation.
• The Jabiluka Number 2 orebody has not been fully defined (open at depth) suggesting that more ore may be mined. What implications would there be on the Jabiluka facilities and the surrounding environment?
• In the PER (as in the EIS) the proponent does not propose to extract the gold resource contained in parts of the uranium orebody. If in the future gold is proposed to be extracted, further assessment of the proposal will be required.
• There are concerns over the sourcing of construction material and its acid producing potential, especially that sourced from the decline and tailings pits.
• Concerns over the potential release of contaminants and their impacts resultant from the ventilation shafts. No modelling information was presented in the draft EIS.

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Water Management - Surface Water

• The water quality baseline data for Swift Creek shows turbidity, conductivity and pH to be low. These values should be adopted as criteria for release of non-TCZ waters from the proposed mine site into the Swift Creek catchment in order to preserve the downstream aquatic environment.
• Need to manage the surface runoff from the waste rock stockpiles to ensure water quality (suspended solids) is not adversely affected in Swift Creek.
• The monitoring program should include more exposure and control sites in Swift Creek and an external control site.
• ERA should undertake a hydrological analysis of mine activity on creek flows, in particular, effects on draw down of the water table, recharge of ephemeral creeks feeding Swift Creek and of Swift Creek itself.
• Although the tailings repositories and base of the stockpiles are established above the estimated maximum flood height, it is not clear how this maximum flood height was established. Further work is needed following the collection of additional data.
• There are very real concerns amongst aboriginal people about the effects of contamination on the Magela Creek system.
• The SCZ does not appear to contain the drainage from part of the north face of waste Stockpile #2. The northern diversion channel also directs runoff to this area.
• Has the waste rock from the pits been adequately characterised to ensure that it will not release contaminants while weathering in the stockpiles or mill pad.
• Construction activities will increase potential for turbid runoff (which may contain other contaminants) into surface drainage systems which do not normally contain high suspended solid material.
• From fig 4.8 and fig B2.1 it appears that the ammonia and hydrogen peroxide storage, the flocculant storage, the workshop and the vehicle wash areas drain into the SCZ rather than the TCZ. For potential contaminant containment, these should be directed to the TCZ.
• Water wastes from laundry facilities will need to be further addressed with respect to location and contaminants (ore dust, oils etc).
• The adequacy of the design of the sediment traps in the SCZ has been questioned.
• The mineralised waste stockpile could produce acid runoff which will drain into the tailings pits. How will this affect the cemented paste tailings.
• Concerns over possible water seepage into the surface waters systems and ultimately into the Ramsar wetlands and the effects this may have.

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Water Management - Ground Water

• It is noted that the tailings pits will require preparation such as grouting to ensure their ability to prevent groundwater contamination. Details of such preparations are not adequately described and decision makers should obtain such information.
• The surveys described in appendix C all indicate the high permeability of the soils within the Jabiluka Project Area. Thus there is a concern of groundwater contamination prior to water entering the pits. All surfaces in the TCZ should be modified to reduce infiltration to the maximum extent possible.
• Due to access restrictions, ERA has not been able to provide extensive hydrogeological data for the vicinity of the proposed tailings impoundments. This needs to be addressed prior to completion of final designs.
• Containment of contaminants in the underground paste fill and in the tailings pits is of key importance to the project. Adequate ground water monitoring must be undertaken.
• Appendix D indicates that there will be movement of ground water from the pits towards Swift Creek. Travel times are likely to be in excess of 10 years for the shallow aquifer and in excess of 50 years for the deep aquifer. This suggests that the stability and seepage monitoring of the pits would need to take place for more than 5 years after rehabilitation in order to detect movement and initiate remedial action.
• The history of discharges of radioactive wastes at Ranger and the radioactive contamination of ground water at Roxby Downs, undermine any confidence that the industry will be cleaner and safer in the future.
• There does not appear to be enough information on the ground water aquifers, particularly those intersecting the tailings pits, vent shafts and mine decline. Contamination of ground water is a possibility over time.
• A number of vegetation types rely upon natural springs and seeps in the area. Continual high volume pumping may affect the groundwater levels and ultimately alter vegetation patterns. A number of "Significant Soaks" exist in the area (ie. Boyweg) which may be affected by groundwater pumping (ie drawdown of water table or recharge to the site).

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Tailings and Waste Rock Management

• The NLC welcomes the adoption by ERA of several positive concepts for the protection of the physical environment, namely:
  • the adoption of below ground tailings containment in the mine workings, which should ensure the long term containment of the tailings;
  • the use of paste technology for dewatering and neutralisation of the tailings prior to disposal; and
  • the use of a total containment zone (TCZ) for all water borne contaminants arising from the mining operation.
• The NLC is concerned that considerably more ore reserves may be discovered at Jabiluka and that this will require the tailings pits to be enlarged or the excavation of a further pit. Any decision be based on the quoted ore reserves and that these decisions will require re-assessment should the mining of further reserves be proposed.
• An alternative which warrants further investigation by ERA would be the use of the Ranger Mining Project Pit #1 as a tailings depository for tailings generated by the Jabiluka Mining Project.
• Rehabilitation earthworks and revegetation of the unmineralised waste stockpile arising from Pit #1 is planned to take place within a few years after commencement of construction. The PER should have contained extensive information on the design of the rehabilitation landform.
• There is an abundance of arsenic in the Jabiluka orebody. Arsenic should be included in the suite of elements to be analysed in the monitoring programs.
• Stockpile #2 crosses a catchment boundary. The sediment trap proposed will not be adequate to cover all catchments of the stockpile. The northern face drains into a natural stream which flows into Swift Creek.
• No chemical analyses seem to have been carried out for the unmineralised waste rock.
• The depth of capping over the tailings pits must be sufficient to prevent exposure of tailings by erosion. Also sufficient cover must be maintained to keep radon emanation to acceptable levels.
• High sulphate concentrations are known to cause corrosion of certain cements. ERA makes no assessment of the possible impact over time on the properties of the cement paste fill.
• There are serious long term tailings management issues that have not been adequately analysed.
• The fact that tailings are highly radioactive, with some 80% of the radiation of the original ore, indicates that they should be isolated for thousands of years.
• Tailings dams are not an acceptable form of long term containment for uranium tailings in a tropical environment.
• Potential of acid generation from mineralised waste rock and from the tailings is of concern.
• More information is needed on the long term stability, permeability and leachability of the cemented paste tailings. This is particularly important in an acid ground water situation.
• The behaviour of the paste fill material under deep water disposal conditions is not known at this time. (Appendix D)
• Appendix D states that at pit 2 the paste permeability might be the same or slightly higher/lower than the surrounding rocks (D.3.3). This will affect the post-mining movement of ground water around or through the cemented paste and hence the long term leaching potential.

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Radiation Management

• Although it is extremely unlikely that radiation doses to residents of Mudginberri arising from mining in the region will approach the applicable dose limit, there are significant concerns regarding the accuracy of the radon dispersion and dosimetry models used in the PER.
• The JMA PER contains a dose rate contour map based on an aerial survey. There can be significant differences between airborne radiometric surveys and ground based surveys. It is important that pre-mining gamma dose rate be measured reliably as post-mining assessment will rely on this data. Ideally the aerial data would be confirmed by a ground based survey.
• The long term effects of increased exposure to radiation by undigenous people living in the region have not been examined in detail.
• The extent of contaminant hazard from the mine ventilation stacks has not been adequately discussed.
• About 80% of the radioactivity of the original ore remains in the tailings. Tailings management is critical to long term management of radiation hazard.
• The main radiation hazard is from inhaled or ingested particles containing alpha radiation. There is not enough information on this or on bioaccumulation in the food chain.
• The most dangerous of the radioactive decay products in tailings is gaseous radon-222. The release of radon gas into the atmosphere is greatly hindered by any material or water covering. A stable cover is required for long term management.
• There is no safe lower limit of radiation exposure.
• Details on monitoring programs have not been presented in enough detail.
• Radiological and other monitoring programs have focussed on acute rather than chronic effects.
• No data on permissible inhaled dust in the draft EIS.
• No assessment of radiological consequences of any accident scenarios.
• General concerns over radiation exposure.

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Transport Management

• A raised haul road will impede terrestrial animal movement particularly towards the wet lands. Not enough detail has been placed on animal movements over the haul road.
• The PER does not adequately cover contingency plans for accidents on public roads, both within and outside of Kakadu National Park.
• The design of the wet and dry culverts were raised primarily dealing with flood event and culvert design for a 1 in 10 rather than a 1 in 25 year event.
• Concern over the amount and impacts of construction traffic and product/chemical transport on the Oenpelli Road and Arnhem Highway.
• Concern over transportation of construction personnel over the Magela Creek during the wet season and that alternatives were not adequately presented.
• A commitment to wash all vehicles (including light vehicles and empty trucks) from/to Jabiluka is required. It is currently unclear.

Flora and Fauna Management

• The PER makes little mention of impacts on vegetation (and hence fauna) by changes in ground water regime due to draw-down effects from both the underground workings and the tails disposal pits. The hydrogeological information in appendices D and E should be taken into account by the decision makers and continued monitoring of the vegetation will be required.
• The Ranger-Jabiluka access road should be located so as not to impact on the extensive patch of Allosyncarpia ternata in the riparian zone of 7J Creek.
• Mine induced road kills are not estimated in the report.
• The rehabilitation species chosen appear limited by what is available from local seed suppliers. The PER should state that only local native species will be used. As it stands the use of other species is not actually ruled out.
• Long term chronic effects (or acute) on birds which congregate around the tailings dam (Ranger) and Retention Ponds (Ranger and Jabiluka) needs to be further addressed (ie toxic effects).

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Infrastructure Impacts

• The proposed use to septic tanks and transpiration trenches has the capacity to cause significant adverse environmental impact, particularly since the precise soil conditions are not adequately documented.
• During the initial construction period there will be increased traffic on the Oenpelli Road and Arnhem Highway. The issue of impact on public roads is not adequately addressed.
• Extension of restrictions on the Boyweg site are likely to change the location of the temporary access road and vent shafts.

Social Impacts

• The impacts which the development of the Jabiluka Mining Project will have on the aboriginal owners and residents of the area affected is relegated top a position of little importance and the PER offers only a brief, unsupported and shallow analysis of such likely impacts.
• KRSIS found that the lack of aboriginal control over development of the Ranger Mining Project and Jabiru has had deep seated and profound implications in terms of disempowerment and demoralisation amongst aboriginal people in the region. Lack of input to Jabiluka could make this situation worse.
• Development of the Jabiluka Mill Alternative some 16 years after consent, involves a significantly longer mine life. This means that all adverse social impacts of the project will be extended by as much as 25 years.
• Development of the JMA would afford significantly less benefits to the aboriginal people than was envisaged in 1982:
  • Employment and training opportunities will be drastically reduced;
  • The amount of financial return will be decreased by as much as 50%: and
  • The period of alienation from both the Jabiluka and Ranger Project Areas is significantly increased.
• There continues to be no perceptible movement by Commonwealth and Northern Territory governments towards implementation of KRSIS recommendations.
• Section 8.14 outlines that "previous investigations conducted in the lease area have indicated that items of significant value will not be impacted by the mine and road development". This would appear to be inconsistent with views expressed publicly by some traditional owners.
• General lack of discussion of social impacts with the aboriginal landowners.
• The project is contrary to the wishes of the Traditional Owners.

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Heritage and Cultural Values

• The Boyweg site constitutes a sacred and dangerous zone which is sensitive to disturbance. Additional restrictions placed on the site are not "interim" and will necessitate the relocation of vent shafts.
• Recommendation 56 of Senator Hill’s recommendations stated that a Cultural Heritage Management Plan is to be completed before commencement of construction. This does not appear to have been done.
• AAPA have not yet issued a clearance certificate for the Boyweg area. This can affect the temporary access and location of vent shafts.
• The PER notes that stage 2 of a cultural site survey (in relation to the haul road and stockpile #2) has yet to be completed by ERA. The survey needs to be completed prior to construction of the road.
• There is a risk that perceived fears about the operation of a mill and storage of tailings immediately upstream of the Swift Creek crossing on the Oenpelli Road, could diminish the overall cultural values of the Swift Creek area downstream of the mine site and adjacent floodplain.
• There are a number of significant sites which may be affected by vibration, dust, groundwater etc from mine activities. Details on monitoring proposed for the construction period have not been presented.
• There is a general lack of discussion on sacred sites significance.

Other General Issues Raised

• The Six Monthly Progress Report, required by the Minister for Resources and Energy, is referred to throughout the PER and would have been usefully included as an appendix. Government response to the report would also have been useful.
• Arrangements should be established to report the results of monitoring programs to the aboriginal people and to respond to their concerns on impacts of the project.
• An insufficient amount of time was made available for public comment on the Jabiluka proposal (ie 4 weeks).
• There appears to be limited involvement of aboriginal people in the present Jabiluka environmental assessment and approval process.
• Mining within the bounds of a National Park (or World Heritage Property) goes against the principles of World Heritage where activities are likely to damage the values of the property (ie the mine is not compatible with the values and will risk tourism activities).
• Uranium mining is not safe, creates radioactive wastes and is not the most cost-efficient energy source. Australia should adopt a anti-nuclear stance.
• General objections to uranium mining.

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