To download a word doc to print and send or fax:
Sign on Submissions_Kintyre_Cameco_Mitsubishi
Approvals and Wildlife Division
Department of the Environment, Water Heritage and the Arts
GPO Box 787
Canberra ACT 2601
Epbc.referrals@environment.gov.au
Fax 02 6274 1789
The Chair
Environment protection Authority
Western Australia
Perth WA 6842
Fax 08 6467 652
Re: Kintyre uranium project
I am concerned about the approval and development of the Kintyre uranium mine due to the likely cumulative impacts on a number of environmental and social aspects. The environmental referral released by Cameco Australia lacks scientific data and baseline studies. Such studies are vital for the proper assessment of environmental risk and prediction of long-term outcomes. I call on the EPA to initiate a Public Inquiry into uranium mining in WA, as this environmental referral raises a number of questions and issues which are relevant to future proposals for uranium mining in WA, including impacts on the environment of the Rudall River National Park, water resources, communities, workers and global implications through the production of weapons-usable fissile material and high level radioactive waste.
The Kintyre uranium project should at the very least be subject to approvals under the EPBC Act. This requirement would have previously been standard procedure but current Government discussion on regulations throws doubt on this vital part of the process. In addition the proposal should be subject to an open and transparent public inquiry addressing cumulative impacts, transport, water consumption and contamination, refer to the challenges and failures of uranium mining in Australia thus far, and address the wider global implications of weapons proliferation and radioactive waste production and management.
Tailings management
Tailings dams at Australia’s existing uranium mines have a track record of to leaching into the environment. Tailings at decommissioned uranium mines pose ongoing environmental threats and are a cost burden to tax payers. Considering the elements that will be present in tailings that are radioactive for thousands of years, there needs to be a stronger commitment from Cameco Australia to take responsibility and to be accountable for long term maintenance and rehabilitation of the Kintyre site.
Cameco Australia are considering putting tailings in mined pits, this involves temporary storage on the surface before disposing of tailings in pits. The major concern is for finer tailings and possible contamination of groundwater. There needs to be further surveying of groundwater flows through pits so as to mitigate any contamination of groundwater. Considering the number of applications for uranium mining, there should be a State and National review on tailings management based on the known risks and longevity of the risks. ERA’s Ranger uranium mine in the Northern Territory should be considered, with over 100 known leaks and spills and ERA’s commitment to isolate tailings from the environment for 10,000 years.
Water
The amount of water required for this mine proposal is relatively high for the amount of uranium expected to be produced. There should be further analysis of the value of the water resources in the region, underground flows and groundwater recharge. These factors should be considered in relation to possible groundwater contamination.
There should also be an analysis of the cumulative impacts on water resources in the region, especially considering the other operating mines in the, including the Telfer and Nifty gold mines, Rippon Hills and Woodie Woodie. Cameco Australia have suggested that pit dewatering provide the bulk of water requirements, further studies should be conducted to establish how much dewatering water will be available per day and the radionuclide content of that water.
Stygofauna
There is limited understanding about Stygofauna and groundwater dependent ecosystems (GDEs) and how they may be affected by mining and radiation. These ecosystems and species should not be sacrificed for the development of a project with short term profitability and long term impacts. Stygofauna and GDE’s should be studied further with baseline data collection prioritised to monitor any impacts on these species and ecosystems.
Flora and Fauna and conservation values
The Kintyre uranium deposit was excised for the Rudall River National park, now the Karlamilyi National Park. It was the only arid river system in Australia contained within a National Park this is now compromised due to the excision. The area has high biodiversity values, including (as reported by ENVIRON Australia Pty Ltd) 92 bird species, 66 reptile species, 51 mammal species – 21 which are of conservation significance and a few that are critically endangered.
The Karlamilyi National Park including the environment at the Kintyre site, are biologically diverse and unique as a ‘transition zone’ where the Great Sandy Desert, the Eastern Pilbara region and the Little Sandy desert meet. With the rare biodiversity values of flora and fauna in the Kintyre site, a review of the decision to excise the area from the national park should be conducted, to establish under what conditions, agreements, rationale the area was excised.
Radiation Management
This project’s impacts pose public health risks through radiation and dust pollution. Cameco Australia has used language throughout the referral document which denies the human health risks associated with the proposed Kintyre uranium mine; this raises concern for the seriousness of which they intend to enforce radiation management plans and safety. There needs to be more rigorous base line studies of background radiation at different areas including Punmu, Punngurr (Cotton Creek), Nifty, Telfer, Balfour Downs and Wandanya. There should also be further studies and evaluation of wind charts in the region and pathways for dust pollution from the Kintyre site.
Considering the stage of development there should be more information in the Environmental Referral about the current protective clothing worn by workers during exploration and monitoring programs for workers. That this is not included raises concern about the capacity of Cameco Australia to comply with the required safety regulations set for uranium mining. The establishment of a National Radiation Dose Register for uranium mine workers is still not operational raising concern for the health and safety of workers. Federal Resource Minister Martin Ferguson promised this register would be operating by the end of 2009 but is still only being trialled in one mine.
Radiation dose limits need to be reassessed in light of recent scientific research on the risks associated with radon progeny including polonium. The International Agency for Research on Cancer (IARC) has publicly stated that ‘radon gas deliver’s twice the absorbed dose to humans as originally thought’, and consequently, the IARC is currently reassessing the permissible levels. Nuclear practitioners and expert bodies including the Medical Association for the Prevention of War have indicated that previous dose estimates to miners need to be approximately doubled to accurately reflect the lung cancer hazard. I also note here that the International Physicians for the Prevention of Nuclear War at their International Meeting in Basel in August 2010 unanimously declared that based on health standards uranium mining should be banned internationally.
Transport
The risk assessment for transport in the environmental referral does not exist. There has been no consideration of the total km of transport of the proposed yellow cake product. Cameco is confident that their record and BHP’s record on transport incidents is very good that there will be no accidents. However, this is not a satisfactory risk analysis. No other uranium mines have to transport uranium oxide approximately 4,300km’s.
The suggestion of temporary storage at Parkeston north east of Kalgoorlie is unacceptable as it is within a few hundred meters of residents at Ninga Mia Aboriginal Community; there have already been Government admissions, that transportation of yellow cake through Kalgoorlie is too dangerous (Norman Moore, ABC news, May 21st 2010). If it is too dangerous for Kalgoorlie then it is too dangerous for Ninga Mia.
There should be some further assessment of the distance to Darwin and Port Adelaide from Kintyre with a ‘per kilometre’ risk assessment, identifying road and rail accidents in WA, not the track record of Cameco Australia and BHP Billiton. There is no mention of current truck accidents or train derailments in WA, SA or the NT. Truck accidents and train derailments occur and it is again negligent for Cameco Australia not to consider these realities at this stage of project development.
Global Implication of Uranium exports from Australia
In the ERMP there must be an analysis of the broader global implications of uranium exports from Wiluna. This should include a total life cycle analysis with consideration of the proliferation of Weapons of Mass Destruction (WMD) and the production and management of long lived high level radioactive wastes. It is irresponsible for the producers of uranium, such as Cameco Australia, not to take responsibility for the by-products of the nuclear industry, weapons usable fissile material and long lived radioactive waste.
In summary, the issues around tailings management, water consumption and contamination, stygofauna and GDEs, radiation management, transport, and global implications from the production of WMDs and radioactive wastes are issues that should be considered on a mine by mine basis but also must be evaluated as a whole industry’s impact and WA’s role in facilitating the mining and exports of uranium. Again I call on the EPA and the Western Australian Government to hold a Public Inquiry in to the overall impacts of uranium mining in WA.
Yours Sincerely
Name:
Signature:
Date:
Address:
Fax 08 6467 6522
Filed under: Uncategorized
