COMMISIONER: Good morning. It being 10.30 we...

COMMISIONER: Good morning. It being 10.30 we will convene. Topic six is the environmental impacts, lessons learnt from past mining and milling practices in South Australia, case studies for Port Pirie Rare Earths Treatment Facility and Radium Hill. Might just start with a context statement about what we are attempting to achieve in this particular section. The commission’s 5 terms of reference expressly require it to give considerations to the environmental impact of the potential expansion of exploration and extraction activities. That much of the exercise is to be conducted by considering what has occurred elsewhere, largely overseas, and what might occur were those activities to be carried out in Australia. Our terms of reference expressly 10 require us to give consideration to the lessons that can be learnt from past exploration and extraction activities in South Australia. The commission, before it considers any possible expansion of operations will examine South Australian history to see whether that might inform what we should do in the future. In short, the commission will pay heed to the past, lest mistakes 15 be repeated. The most significant of these past extraction activities was the radium and later uranium mine operated at Radium Hill in South Australia’s north-east and the associated processing works operated here where we are today in Port Pirie. 20 The question faced by the commission is what can be drawn from the way those activities were established, operated and closed, to better inform future practice. The commission already understands a number of the issues in the broad outline. It has already inspected the Port Pirie facility in April and the former Radium Hill mine site in August. Given that much time has elapsed 25 between the closure of both the mine at Radium Hill and the facility at Port Pirie, it is necessary to understand what changes have already taken place in the practical planning development conduct and ultimate decommissioning of mining and processing activities. In conjunction with their contemporary regulation and licensing. The commission is not tasked by its terms of 30 reference with an inquiry in to what ought to happen now at these particular sites, or whether more, if anything, should be done. That said, it must understand the complexity of any issues that now exist, to form a view as to what might be done during any expanded operations to avoid those issues in the future. 35 To discharge its functions, it will speak to those that were present when the Radium Hill mine was established and operated, those responsible for now managing the sties and also an independent expert that has undertaken a study at Radium Hill in the context of his work to understand the environmental 40 impacts of closed mines. I now invite counsel assisting Mr Jacobi. MR JACOBI: Mr Kevin Kakoschke worked at the Radium Hill uranium mine for nine years. Since that time has been a TAFE lecturer in mechanical engineering and a consultant to the manufacturing industry. He is the author of 45

.SA Nuclear 08.10.15 P-536 Spark and Cannon

several books concerning Radium Hill, including We Were Radium Hill and Off The Barrier Highway. He is the president of the Radium Hill Historical Association which seeks to preserve the cultural heritage of the Radium Hill site. 5 COMMISSIONER: Can I suggest you come forward a bit. We won’t bite I promise. MR JACOBI: Sorry, just to repeat, he is the president of the Radium Hill Historical Association which seeks to preserve the cultural heritage of the 10 Radium Hill site. The commission calls Mr Kevin Kakoschke. COMMISSIONER: Kevin, welcome. Can we start – what we are trying to do here is to put in to context what happened at the mine at the time you were there, you were part of it and Mr Jacobi now will lead you through a bit of 15 context, so that we can see what it was like during the time. MR KAKOSCHKE: Mm’hm. Good. MR JACOBI: Just wondering whether you could describe first, the period of 20 time that you worked at Radium Hill? MR KAKOSCHKE: Having just left school, turned 16, fortnight later I signed up at the University Life on the 3 March 1953 to work at Radium Hill as an apprentice fitter and turner. I progressed through the ranks and was there when 25 it closed in December 1961 and involved with the mentors, my mentors who were the mining, mechanical, electrical, civil engineers and metallurgists. MR JACOBI: How long after you commenced, had the – perhaps I should ask this, in terms of when you started, how much of the planning and other work 30 had already commenced at Radium Hill? MR KAKOSCHKE: When I commenced at Radium Hill, my quarters were a tent and the implementation of the building of the main mill area was commencing and I was a little bit involved in that on the periphery really. I 35 didn’t have anything to do with the design or anything like that but I was just one of the workers on the initial building of some of the aspects of the plant, the crusher house and some of the items in the mill. MR JACOBI: In very broad outline, since the mines closure in the late – early 40 1960s, have you had a continuing involvement with Radium Hill? MR KAKOSCHKE: Really I suppose I would have to say yes. More so in the last 14 years but initially after it closed, I had a close relationship, went up there a couple of times because a couple of my brothers were involved in the 45


clean up and my father-in-law was in charge of all the clean up immediately after it closed. MR JACOBI: Did you make visits in the 1960s, 1970s, 1980s? 5 MR KAKOSCHKE: Yes. So used to have to go up to Cobar, the Cobar mines at least once a year and generally would call in to Radium Hill just to see what’s left there. MR JACOBI: Perhaps if we can go to the – watching on the first slide and 10 perhaps you can give us a broad indication of where the Radium Hill mine is located relative to the other geography in the area? MR KAKOSCHKE: Yes. Well, Radium Hill, as you can see on the slide, is in the north-east of South Australia, southeast from Olary around about 12 mile, 15 18 k’s off the main Barrier Highway and the railway line. It’s in a land of mulga, saltbush and bindi eye and around about seven and a half inches of rainfall a year, but the evaporation rate is seven and a half feet, so we had a massive water problem right from the start. 20 MR JACOBI: In terms of its distance from other main settlements, as the position stands now, how distant is it from other main settlements that are located nearby? MR KAKOSCHKE: Basically because all the facilities that were built up over 25 the period of time, the other settlements along the Barrier Highway and a lot of the station properties, we were the regional centre, north-east regional centre. They used to come in to Radium Hill because around about 1,000 people were living there. We had all facilities, eventually we had all facilities. You name it, we had it and the surrounding areas would come in, whether it be rifle 30 shooting, tennis, football whatever. MR JACOBI: Yes. Mr Kakoschke in terms of, as it stands at present, in terms of the main population centres, how distant are they from where the mine is now? 35 MR KAKOSCHKE: Well, the main population centres I tend to think would have to be Peterborough and Broken Hill. Olary, Mingary, Cockburn, Manna Hill and Yunta – well, Yunta’s only got 58 people there, so that’s the biggest. Olary’s got six, so yes. 40 MR JACOBI: And in terms of the railway line in to New South Wales? MR KAKOSCHKE: Railway line to New South Wales, that was used after the railway line in to Radium Hill was constructed and that was a narrow gauge 45


line of course but that was surveyed January 1953 and the first train called the Atomic Comet moved in to Radium Hill on the 3 October 1953. MR JACOBI: But in terms of the distance from the standard gauge, as I understand it, the now standard gauge line going in to New South Wales, what 5 is the distance of that relative to the Radium Hill mine site? MR KAKOSCHKE: Well, a lot of the waste from Radium Hill was used as ballast in 1965, the line from Radium Hill into Cutana Siding was the first state government built standard gauge railway line in South Australia, and from then 10 they branched east and west to do the railway line from Peterborough to Cockburn. MR JACOBI: Approximately how far is it away from the mine? 15 MR KAKOSCHKE: The line is approximately 18 to 19 kilometres, about 12 mile. MR JACOBI: Can I just come to the first phase of the mines operation, because I understand you have some expertise in relation to that. This is at a 20 time about 50 or 60 years before your involvement at the site. I think the next slide picks that up. Can you just give a broad outline in terms of the first phase of the mine's life? MR KAKOSCHKE: Well, the first mine was found by Arthur Smith there 25 and that's his mate, Douglas Mawson. He pegged the claim on 20 March 1906. He thought he had a tin or wolfram deposit. Professor Bag and Chapman in Adelaide, they determined that it was radioactive and Douglas Mawson realised that it would be a new mineral and he named it davidite containing radium and uranium. 30 MR JACOBI: In terms of the first phase of the mine's operation – I think the next slide might pick that up in terms of the scale. MR KAKOSCHKE: Well, as it turned out, the papers at the time eulogised 35 over the enormous hype about radium. Forget about uranium at this stage. They mentioned that foreign nations will be obliged to seek from us the power with which to heat and light their cities. Then other articles really over themselves, its core value and resources should be exploited by the people for the people of Australia. That's how they eulogised about how critical it was for 40 Australia's future. Also, samples of it were sent to Madam Curie in France for further investigation, research and commercial viability and also Lord Rutherford in England. MR JACOBI: For how long did it operate? 45


MR KAKOSCHKE: The first mine operated with Arthur Smith up until approximately 1908 and then it was taken over. Mawson had a claim there but when he found the Antarctic the publican at Broken Hill jumped his claim. It then worked on till 1914 and some of the stuff was sent to Germany. In 1910 5 they were using the uranium element for hardening steel, which I thought was quite unusual at that early time. MR JACOBI: Can we come to the next phase of the mine's development, the phase where you were there. I think we've got a circus plan in the next slide. 10 I'm just wondering if you can give a broad overview of the layout of the mine site as it stood then. MR KAKOSCHKE: Those letters that you see there, that is the line of load and the various shafts associated with them. The regional shafts were these 15 just along here: Main, Whip, Brown and Smith shaft. With the facilities built up the old camp was down in here. That's the tent where I was first, a tent and a couple of cubicles, but then everything else was built in. MR JACOBI: Just for the transcript I think you've pointed out the area south 20 of the transformer station. MR KAKOSCHKE: Yes. Down here this was later on the concentrate dam. When the mill got going this was the concentrate dam where the 20 per cent solid slurry from the milling process was pumped in there. The water was 25 reclaimed and used back into the milling operations. MR JACOBI: Can I just stop you there. In terms of the concentrate dam, that was used to store the product that was ultimately transported away from Radium Hill. Is that right? 30 MR KAKOSCHKE: Yes. The concentrate dam, that was the main one from the operations. From there after it got going with the railway line in, et cetera, then railway trucks would come in, an air-operated scraper would be used and they would fill the railway trucks with the concentrate. It would be wet down 35 usually before they would load it. That was into 12-tonne railway truck. MR JACOBI: Can I take you from there to the tailings dams which I think are further south. Are you able to describe their layout and the nature of the planning that was involved in them being laid out? 40 MR KAKOSCHKE: With the tailings dam, once again, the waste sands or fine – just like mud – from the flotation cells would be pumped out there and the pipe carrying that waste would have holes in it and where you wanted the slurry to go, those plugs would be taken out of the pipe and it would gradually 45


be built up into a mound, like a big dam, and the centre would be holding the water as a product of the medium from which it was used to get it out there. MR JACOBI: Again for the transcript, the witness has indicated the two large rectangular tailings dams to the south of the transformer station. Were you 5 present at the time that the tailings dams were constructed? MR KAKOSCHKE: Well, that one in particular. MR JACOBI: That's the southernmost one. 10 MR KAKOSCHKE: Yes, that's first. The first one, an experimental station, was called the pilot mill. That was built in 1952, just a little bit before me. They used a concentrate dam there. The product was put in 44-gallon drums and whipped back down to Thebarton for further research and analysis. The 15 little tailings dams were alongside of that. MR JACOBI: Could you describe the method of construction of the tailings dams, both the bases and the walls? 20 MR KAKOSCHKE: The bases were the dirt that we walk on, no real pre-preparation of a base. The walls of the dam were the actual residue from the slimes or the concentrate being pumped in that area. It formed its own banks as such as it was built up, draining towards the inside from where the water was reclaimed. 25 MR JACOBI: So I'm right in understanding that the waste material itself was used to construct the dam walls. MR KAKOSCHKE: Yes, same as the concentrate dam. The concentrates 30 were used to construct the dam walls of the concentrate dam. MR JACOBI: So just to come to that particular dam, the walls there were not made of tailings; they were actually made of concentrates themselves? 35 MR KAKOSCHKE: Yes, the walls were actually made of concentrates. MR JACOBI: Was there any engineering design that you're aware of at the time that they were constructed as to how they were built or how they were designed? 40 MR KAKOSCHKE: They were designed by the length of pipes that we reckon would be sufficient to let the slurries out to build up sections of the dam. So this is about right. 45


MR JACOBI: I'm just interested in also at the time that the planning was done for the industrial operation. Were you aware of any discussion as it stood at the time of any environmental factors that were taken into account in its design? 5 MR KAKOSCHKE: I can't recall anything being said about the environmental factors. That's my initial time there. MR JACOBI: Over your time there in terms of the expansion or development of the industrial activities was there discussion of environmental 10 considerations? MR KAKOSCHKE: The environmental consideration was basically related to two points: (a), on the surface, the dust; and (b), on the ground, the humidity and also the smoke fumes, et cetera, from when you're blasting. It was quite 15 warm. MR JACOBI: I'll come back to the dust in just a minute. Perhaps we can go to the next slide. I'm just wondering whether you could identify the key aspects of the mine layout or the industrial areas that are shown in that slide. 20 MR KAKOSCHKE: The head frame, 131 foot and seven-sixteenths inches high or 42 metres high, that was the head frame. The wind house operating the skips to – the material from underground was located here. This was the Brown shaft head frame, the compressor house there. This just here was a fan 25 and that was brought in from Wimmera, by the way. MR JACOBI: Just for the sake of the transcript, the first object you've indicated is the large white V-frame and I think the fan that you're locating is located immediately beneath that in the centre of the image. 30 MR KAKOSCHKE: Yes. That's the fan here. That was to cool the compressors and, if necessary, these were an alternative power source. MR JACOBI: Perhaps if we come to the next slide in terms of the township, 35 how close was the township to the mine itself? MR KAKOSCHKE: Basically the township was around about a good three K's away from the main industrial area. In the township there was 160 houses built and also there was 220 two-man cubicles which was just away to the left 40 of that slide. The housewives used to complain that they were getting dusted lungs. So the project put in place procedures for bitumenising the street. The streets were bitumenised with waste finds from the mine area. MR JACOBI: We might perhaps come back. I think you mentioned the dust 45


twice and I think the next slide picks some of the images of that up. What were the difficulties with dust in terms of working in the conditions as they stood then? MR KAKOSCHKE: Well, in summertime you'd be wearing shorts and one of 5 the problems with that is the dust and the sand - the wind would be blowing - it'd sting your legs and it was quite awkward really, and also if your single guy like I was first, you had to wash your clothes because they'd be sticky and grimy from the dust. In the town site there would be red dust. Down in the mind site area it'd be red, but it would mix with the bluish, greenish tinge from 10 the waste materials from the mine area. So we had technicolour dust down in the mine area primarily. MR JACOBI: I'm perhaps coming to that. In terms of the tailings themselves, did they remain wet or did they dry out? 15 MR KAKOSCHKE: Well, they tried out, because we reclaimed the water because water, to get it in from Broken Hill, was costing 23 shillings a thousand gallons. So every drop that you could save, you're saving a hell of a lot of money. And so the water, even though it may have been a salt content, 20 about 2,735 parts per million, it was re-used back in the mill for the various operations requiring water. They dried out. MR JACOBI: And so the bluish tinge that you've described, was that blow from the tailings themselves? 25 MR KAKOSCHKE: Blow from the tailings, and also some of the other spoil heaps right through that area, because of the mining and the dumps, were stretched for over a kilometre. 30 MR JACOBI: And perhaps relative to the mine layout, where were the spoil heaps located? MR KAKOSCHKE: The spoil heaps. Generally from the early days they were located adjacent to the particular shaft or winze. Later on, when the mine 35 was in full operation in my time, when we had a big mullock dump, of course rock, and from that also, from the mill, the finer crushed rock was in another area. So you had those two or three locations of waste rock and also crushed rock. 40 MR JACOBI: Yes. So we had spoil of both crushed rock and also the milled ore. MR KAKOSCHKE: The milled ore and some that wasn't processed. It was just plain mullock. 45


MR JACOBI: And perhaps we can deal with the industrial safety as it applied within the mine, and I think that brings us to our next slide. I'm just interested, overall, perhaps without respect to the particular image, what were the main concerns with respect to the safety of those who worked within the mine? 5 MR KAKOSCHKE: The main aspect of safety was the personal harm through accidents, and great emphasis was put on through, firstly, dust. Everything had to be wet down so you didn't get dust. Boring was done with the wet. Boring into faces, you had the drilling going and also exhaust fans so they would drag 10 away all the dust and all the fumes, and even though, in the early stage, I think if the gamma count were over - well, the readings were over 300 units, but later on, in 1954 they put a huge capacity exhaust fan in just near main shaft and that would take out 100,000 cubic feet of air a minute and that was exhausting all the fumes, et cetera, from down below. 15 Apart from that also is the person safety, and that ranged from personal gloves, et cetera, glasses, and also the battery from your battery acid, well, electrolyte. If you bent over, some of them damn batteries would leak and would come onto your back near your bum, sort of thing, and you wouldn't notice it until it 20 started itching and it was too late. MR JACOBI: Can I take you to the issue of discussions about radiation as a worker? To what extent was there any discussion or focus upon that in terms of safety? 25 MR KAKOSCHKE: It doesn't matter. Initially, radiation, it didn't matter, because we're getting good money. Later on, we had a bit of a check, but that was somebody else's problem. It wasn't our problem. It's unusual in that we didn't think of it that way. 30 MR JACOBI: Do you know to what extent measurements were made and related to workers? MR KAKOSCHKE: Yes. We did have measurements laid. Before the big 35 exhaust fan was put in, it was around about that 300, what, millisieverts. After that was put in down - less than 20. A dramatic difference, a drop-off. Also the radon gas, dramatic drop-off when the extra ventilation systems were put in. From the mine face venturi tubes everything was ventilated. Two reasons: (a) dust, (b) heat, and also the fresh air coming in, stale air going out. 40 MR JACOBI: Were there any limits on the time that you were permitted to work in the mine, bearing in mind radiation or other issues? MR KAKOSCHKE: Our only issues of working in the mine was immediately 45


after firing, that you had to let the smoke, dust and everything clear before you went in. Usually it was a half hour. MR JACOBI: And in terms of your principal work, were you principally working on the surface or down in the mine? 5 MR KAKOSCHKE: Yes. Well, principally on the surface, but when I was designing up the underground loading station and the main underground pump station and everything, I'd go down and I'd do spot checks on how much water was being made in a mine or how the rock was rilling on the ore faces and so 10 on like that, so, yes - primarily on the surface though. MR JACOBI: And was there any difference in terms of discussions about radiation protection for you working on the surface? 15 MR KAKOSCHKE: No, very rarely mentioned really, because, as we thought, as we knew, it wasn't an issue. MR JACOBI: Perhaps we can move to the slide beyond and deal with the nature of the conditions working within the mine itself. In terms of the main 20 method for extracting the ore, how was that done? MR KAKOSCHKE: Yes. The ore and the stope averaged about a 6-degree angle to the vertical, and also approximately 4 feet wide, climb up by a 1-inch rope or a chain ladder up onto a stage which we had previously had nearby. 25 You hook on and then you'd be working with that work drill which you lugged up there previously. That weighed approximately 60 pound. Air lines and also water lines to hold the operation. Each shift you would bore your holes. There's one around about there, I think. You'd bore your holes and each shift you'd knock out on average about 20 tons of ore. 30 MR JACOBI: And perhaps if we can just come to one other slide inside the next one in terms of the way that the ore was removed, in terms of mechanical and human involvement? 35 MR KAKOSCHKE: Yes. Here are the human boggers. I didn't say that other word. Human boggers, and they are sinking a shift from one level to another and they would hand shovel, or bog, the broken material into a small skip to be hauled to the surface. You notice they are working in water, mainly because there's nothing below and they were using water to suppress the dust when 40 they're drilling, . So the water had to go somewhere and they would pump that out with an air (indistinct) pump so that - yes, and then they would drill, bog bore and fire. That was the procedure. Notice the safety aspects: no gloves, no shirt, no gloves. Yes. 45


MR JACOBI: Was there any request to wear that sort of equipment at the time? MR KAKOSCHKE: We're supposed to have worn safety boots galoshes. One guy, he'd go down - they used to call him Yank - but he'd go down and he 5 had everything on to start off with. When he's down below (indistinct) to dry he'd strip everything off, even his boots, and he'd do - barefaced, no shirt, nothing, because he's tough. That's the way it was with some of the guys. MR JACOBI: Now, perhaps we can come just to the means of shipping, and I 10 think a couple of slides on we've got a slide that picks that up. Can you explain what is shown in that particular image there of the rail line and the rail tracks? MR KAKOSCHKE: Yes. These were getting filled. This particular one was getting filled. It looks mine rubble and also the waste slimes where it was put 15 through the thickener as waste finds like sand, and that was taken out generally for the roads, even on the Broken Hill highway between, I think, around about Manna Hill and Coburn. It was taken out and used for the highway. The concentrates was loaded up with the scraper into the trucks. Those trucks, that size there, held about 12 ton and the trains would be able to haul about 15 of 20 those truckloads and - yes. MR JACOBI: Were they covered? MR KAKOSCHKE: No, no. Generally they were damp when they were 25 loaded, but it depends how long they stood there. The trains went out on the Tuesday and the Friday evening. So if they were loaded on the Wednesday morning, then they drive out by the Friday evening. That’s just the way it was. MR JACOBI: If we come to the time of about 1961 when the facility was 30 closed, I’m just interested in understanding, were you present at the time that it was shut down? MR KAKOSCHKE: Yes. I worked there until the end and I got transferred down to the mine department in Adelaide in the design area. When it closed 35 down, everything that was movable was removed. The equipment from the mining area, that was bought in some case from – by other mines, other bodies and some of that even went to Fiji, Emperor Mines in Fiji. The houses, they were bought by many private people and also by the State Government Housing Trust and put all around over the state. Everything was cleared up. If 40 anything was rubbish, wasn’t required, the big costeans and shove everything in there and then cover them off. A costean is like an oversized trench and they were put in there to be carted away - so they wouldn’t have to be carted away, wouldn’t be an eyesore. The only thing standing in the town site by the way, is the walls of the Roman Catholic Church and they were saved by divine 45


intervention. MR JACOBI: Can I just take you to the tailings dams themselves and do you recall what was done as at the time of decommissioning with respect to the tailings dams? 5 MR KAKOSCHKE: Yes. The pipe was removed. The pipe at the top of the dam whereby the slurry was circulated around the top of there, that was removed and the dam itself was left to the elements. 10 MR JACOBI: Now I think we’ve got a slide that might pick it up in terms of – I understand you didn’t take this photograph but I’m correct in understanding that you went there in the 1970s? MR KAKOSCHKE: Yes. Yes, I used to call in on my way through to Cobar. 15 MR JACOBI: And are you able to describe the condition of the tailings dam when you saw it in the seventies? MR KAKOSCHKE: In the early seventies it wasn’t as bad as this photograph 20 depicts but you could see in some sections the wind erosion was really blowing everything to the north-east and the south-east because there’s nothing holding it together and you get some of them bloody winds there, they were really strong and that was dried and it just waiting for a wisp of a breeze to come along and it whip it away. 25 MR JACOBI: Now we’ve got – I think the next image, some works were done, as I understand the position, in the 1980s. This is a photograph taken by you? 30 MR KAKOSCHKE: Yes. MR JACOBI: Are you able to describe the tailings dam after that work was done? 35 MR KAKOSCHKE: Yes. This is the tailings dam, the side of the tailings dam. They were consolidated. I have seen a (indistinct) cover with a two-metre thick fill but as you can see, the bloody colouring there, that’s not two metres thick there to show the size of the dam. They dug great trenches or costeans along the side and from the fuel they carted that up and put it over the 40 banks and on top of the dam and down this end is where the low-level radioactive waste site is. MR JACOBI: In terms of other decommissioning activity, I think we’ve got an image that shows the head frame; I’m just interested to understand are you 45


aware of whether the nature of the plan for the decommissioning of the site, as it stood in the early 1960s? MR KAKOSCHKE: The plan really was get out of it as soon as possible because it’s costing money to be there because the contract has finished, 5 there’s no money coming in. That’s the bottom line. I was nearly going to say another word. Now with the head frame, that’s one of the last things to be removed from the industrial area. Reason why because it was a challenge how to bring it down and Jim Spears and Bill Paul(?) – Jim Spears had the salvage contract and he brought it down in sections and some of it’s just out the road 10 here at Bordertown here. So that was towards the end of the decommissioning, everything, the buildings as you can see, there’s no building around. They’d already gone and somebody bought them, as bought most of the other movable items. 15 MR JACOBI: And do you recall there being any discussion about environmental considerations as it stood when the decommissioning occurred in the early 1960s? MR KAKOSCHKE: No, no one was called in on the – give (indistinct) points 20 on the decommissioning and environmental consideration, not at the beginning. MR JACOBI: Perhaps we can move on to the second to last slide, which I think shows an aerial view, perhaps first of all you can identify the time that that was taken. 25 MR KAKOSCHKE: Yes, 1955. Bruce Webb, he’s a geologist, he took this photograph. The town laid out, elements of the town, the single mens’ two man cubicles and the industrial area. With the industrial area, just where I got the light there now, that would be the original pilot mill concentrates dam. 30 Only a little thing. MR JACOBI: But I think – can I just take you immediately to the bottom of the picture - - - 35 MR KAKOSCHKE: Yes. MR JACOBI: - - - and you see a large, dark, almost I think smooth cone like pile. 40 MR KAKOSCHKE: Ye. MR JACOBI: What is shown there? MR KAKOSCHKE: This pile here in the centre there is the tailings of the 45


non-uranium bearing crushed rock. Over here on the left hand bottom corner is - - - MR JACOBI: That’s the rectangular object on the bottom left, yes. 5 MR KAKOSCHKE: Yes, that’s the slimes dam that we’re referring to earlier and inside you can see where the water has pooled. Up here, just in this spot here, that was the concentrates dam and the railway line went along past that for these trucks to get fuel. 10 MR JACOBI: Do you know recall how large the tailings dam was? The site coverage? MR KAKOSCHKE: Not off hand but I would imagine it would be around about the five acres. 15 MR JACOBI: And I think we can show the relative difference now because we’ve got an image from 2006. I’m just wondering whether you could point out the main features again by reference to that image. I think if we go to the left of the large white object, which as I understand is one of the tanks, you can 20 see a yellow patch to the immediate left of that. MR KAKOSCHKE: Yes. That is the existing slime stand today, as you see it, well there’s a dam there today anyway, as it is there. And as it shows up, I took this shot trying to emulate the one that was taken in 1955, so I can get the 25 visual comparison from the air. So that is the slimes dam there. The ore bin there, that big 1,400 tonne ore bin and the head frame ore bin is there. Now the significance of this shot is that over in this area here, you see a bluish, greenish tinge - - - 30 MR JACOBI: Yes. MR KAKOSCHKE: - - - predominantly there, that’s downwind from the prevailing winds and that’s blown from the heaps around the mine area here. 35 MR JACOBI: Sorry. Just so we’re clear on the prevailing winds, are the prevailing winds - - - MR KAKOSCHKE: Coming in from - - - 40 MR JACOBI: - - - essentially blowing from the left - - - MR KAKOSCHKE: - - - this direction. MR JACOBI: - - - or the right of that image? 45


MR KAKOSCHKE: Yes. South-west to north to north-west. They were the prevailing winds over that period of time and that’s downwind from those. Another interesting point about that, if you don’t mind Greg, February 1997, they had 13 inches of rain or 325 millimetres in one day in here. You’ll see 5 down in the bottom slide here, from that line along there to the bottom of the slide - - - MR JACOBI: (indistinct) 10 MR KAKOSCHKE: - - - you’ll see it nice and red - - - MR JACOBI: Mr Kakoschke just stop for the transcript. I think you’re indicating a line that runs in a darker passage in about the bottom third of the image. 15 MR KAKOSCHKE: Correct. MR JACOBI: Yes. And what is the significance of that? 20 MR KAKOSCHKE: The floodwaters of that deluge swept all the surface area away including the surface dust and you’ll note from there, it going back to the mine area, you get a gradual grading of colour and that indicates the dust blown from the mine area. It didn’t reach up anywhere near the slimes dam is. 25 MR JACOBI: All right. MR KAKOSCHKE: That area, it’s quite safe. MR JACOBI: So just so I can be clear about one thing and this is perhaps the 30 last question, because I think we’re running short on time, is that in terms of those – the waters, the waters in that event, how far do you say they reached? Are they – do they reach that boundary of that bottom third line, or did they go further up? 35 MR KAKOSCHKE: No, they – that’s where they reached because it gradually rises to the mine area, so it’s safe, as far as deluge is concerned, more so than any plain where something may be located. COMMISSIONER: Mr Kakoschke, thank you very much for your evidence. 40 We’ll adjourn until 11.20 when we’ll have representatives from the Department of State Development and also the Environmental Protection Authority with us. MR KAKOSCHKE: Do you mind? I just mention, quite a bit of the 45


information we’ve gone through is contained in the latest book called Off The Barrier Highway, a whole chapter devoted to Radium Hill as such and other places right up to that area. ADJOURNED [11.10 AM] 5 RESUMED [11.20 AM] COMMISSIONER: It being 11.20 we'll reconvene. I welcome Mr Greg Marshall and Mr Tony Ward from the Department of State 10 Development and Mr Keith Baldry and Mr Graeme Palmer and Dr Artem – I'm going to get this wrong but, Artem, good to see you again – Borysenko from the Environmental Protection Authority. MR JACOBI: The mining regulation division with the Department of State 15 Development is responsible for regulating mine operations in South Australia, including environmental assessments of new mine proposals and ensuring compliance with conditions of tenements and achieving approved environmental outcomes over the full mine life. DSD owns the former Radium Hill mine and the Port Pirie Rare Earths Treatment Facility sites. 20 Mr Greg Marshall, who is on the left from the far left, closest to us, is the director of Mining Regulation and has had significant involvement in DSD strategies to manage those sites. Mr Tony Ward, who is to Greg's immediate left, is the manager of Extracted Areas Rehabilitation Fund, EARF, and Mine Completion. 25 The Environment Protection Authority is the independent environment protection regulator in South Australia. In addition to administering legislation concerned with environment protection, most notably the Environment Protection Act 1993, and community safety, it provides advice on 30 environmental management practices to industry and government, including in relation to the Radium Hill and Port Pirie sites. Mr Keith Baldry, since joining the EPA in 2004, has held a number of directorial roles and is currently the director of Mining, Radiation and Regulatory Services. Mr Graeme Palmer, who is to Mr Baldry's immediate left, was the former manager of the Radiation 35 Protection Branch and Dr Artem Borysenko is the laboratory manager at the Radiation Protection Branch. We call all of them to the commission. COMMISSIONER: Gentlemen, welcome and thank you very much for joining us in Port Pirie today. Mr Jacobi. 40 MR JACOBI: Perhaps at the outset, Mr Marshall, we can start with you. We've given something of an outline in terms of the department's responsibilities but I'm just wondering whether you could give a broad outline of DSD's current responsibilities and then we can go to the predecessor 45


organisations that existed prior to the Department of State Development. MR MARSHALL: The Department of State Development's current responsibilities in relation to regulation of mines is the department, or DSD for short, has responsibility for administering the various pieces of mining 5 legislation in the state, the principal one being the Mining Act, and also it has responsibilities for regulation of the petroleum and geothermal sector as well, but in relation to minerals the agency has responsibility for administration of mineral tenure, mining leases and the grant of those, administration of royalty and also the environmental assessment of new mining operations and ensuring 10 ongoing compliance against legislative requirements and conditions of approval for current mining operations in the state, ensuring mines perform environmentally responsibly and close effectively. The department also has responsibilities for management of former mines in the state, particularly the ones that have defaulted to government to actually manage and remediate. 15 There are a number of those in the state, including Radium Hill and Port Pirie. In terms of the predecessors, so prior to the Mineral Resources Division being in the Department of State Development resources were previously in the Department of Manufacturing, Industry, Trade, Resources and Energy and then 20 prior to that was in the Department of Primary Industries and Resources or PIRSA and then prior to that was called various other names like Minerals and Energy or the Mines Department. MR JACOBI: Can I just pick up on the mines having – that is, the former 25 mines – having come to be within DSD's responsibility. I'm just wondering whether you could explain how they come within DSD's ambit. MR MARSHALL: The ones we're currently looking after actually are on land that's in the care and control of the Minister for Mineral Resources through that 30 particular section of Crown land being assigned and in the care and control of the minister or the minister actually owning that piece of land. So an example of the minister actually owning freehold title of the land was Brukunga mine site in the Adelaide Hills, a former pyrite mine. So the minister was responsible for that property. Radium Hill and Port Pirie were on Crown land 35 and that Crown land was assigned to the minister, I think, in 1975. MR JACOBI: That's in addition to the fact that the state government was in part responsible for operating both the Radium Hill and Port Pirie facilities. 40 MR MARSHALL: Correct. MR JACOBI: Perhaps if I can pick up with you, Mr Baldry, the EPA's responsibilities as they currently stand in relation to mining operation and sites such as the sites that we're dealing with, a broad outline of that. 45


MR BALDRY: The Environment Protection Authority has two principal pieces of legislation, the Environment Protection Act 1993 and the Radiation Protection and Control Act 1992. So in an operational facility usually both acts would apply and we would issue licences under the Environment Protection 5 Act and the Radiation Protection and Control Act for uranium mining. The situation with regards to Port Pirie and Radium Hill is that we license them both under the Radiation Protection and Control Act and the Department of State Development is the licence holder for that. So we're the regulator under the Radiation Protection and Control Act of the two sites. 10 MR JACOBI: Now, the authority has somewhat unique status as a government entity as it's created under its own act. I'm just wondering whether you could explain the nature of its independence and how that operates. 15 MR BALDRY: The EPA has a board of environment protection authority, the authority, and that carries functions that are independent of government, including the granting of authorisations under the Environment Protection Act and enforcement actions carried out under that act. So whilst we are of government, we are independent in decision-making for some aspects. 20 MR JACOBI: I think the explanations you've provided is you're both regulators in one sense but I'm wondering, Mr Marshall, if you can explain the relationship of the EPA to DSD in terms of these particular two sites. 25 MR MARSHALL: In relation to Port Pirie and Radium Hill the department is responsible for managing those sites and for ensuring adequate controls and environment protection for both those sites. In the case of these two sites the EPA is the department's regulator for those sites through the registration of those sites under the Radiation Protection and Control Act. 30 COMMISSIONER: Can I just interrupt there, Mr Marshall, and perhaps I should know the answer to this question. Can you explain the circumstances where responsibility in 1975 was transferred back to the state government? 35 MR MARSHALL: I think the answer to that goes back further than that with the way in which those operations were first established. So in the dawn of the nuclear age in the 1950s all Australian governments saw the strategic importance of uranium deposits, both for military purposes and civilian purposes. So the government in those days sought to take control over the 40 exportation of uranium deposits. They established schemes for encouraging uranium exploration to find deposits, and when the South Australian government sought an opportunity to export the Radium Hill deposit they established a piece of legislation called the Uranium Mining Act in 1949, which provided for the State government to actually own and operate a 45


uranium hill at Radium Hill and a treatment plant at Port Pirie. So it's been a government operation from the very start, or from that phase of the life of Radium Hill, because as you heard from the witness, activities at Radium Hill have been occurring since 1906, but in the 1950s, given the 5 strategic nature of uranium deposits, the government took control over there, established a government-controlled operation, and then took responsibility of the legacies of those sites. MR JACOBI: And have ongoing responsibility for that. 10 MR MARSHALL: Correct. MR JACOBI: And presumably at various other times leased out the operation to other operators. 15 MR MARSHALL: I don’t recall Radium Hill ever being - - - MR JACOBI: No. I was - - - 20 MR MARSHALL: But certainly the Port Pirie site has been allowed to be used for other operators. MR JACOBI: Okay, and so perhaps just picking up one more thing, Mr Baldry, in terms of the predecessor bodies, in terms of the regulator, I'm 25 just wondering if you could explain the regulation history with respect to radiation in South Australia before the creation of the EPA. MR BALDRY: Okay. So the EPA started in 1995 and the Radiation Protection Branch of the EPA joined the EPA in 2002. Prior to that, it was 30 with the Department of Health. So from 1992 until it joined the EPA, the Radiation Protection Branch existed administering the Radiation Protection Control Act, and prior to that it - there was an advisory function within the South Australian Health which didn't have regulatory powers but provided advice to government on radiation. 35 MR JACOBI: Could you just expand on a little on what you mean by not having regulatory powers? MR BALDRY: Well, the Radiation Protection Control Act came into being in 40 1992 and prior to that, there was - in fact, Graeme Palmer is probably better placed. He was nearer to this. MR PALMER: Prior to the Radiation Protection Control Act, radiation protection came under the Health Act. So there were provisions within Health 45


Act to licence people to operate x-ray machines and handle radioactive substances and also register x-ray machines and radioactive sources, but the main impetus in those days for radiation protection was protecting the health and safety of people and were mainly directed toward medical radiation, industrial radiation and so forth. So it's not until the Radiation Protection 5 Control Act was made in 1982 that there were real provisions for controlling radiation on uranium mines and uranium treatment plants. The Health Commission, I think - well, the Health Commission has always been a body of people, a committee. Previous to the late 1970s, the 10 Department of Public Health was responsible for administration of the Health Act radiation protection provisions. The South Australian Health Commission was formed towards the end of the 1970s, I believe, and that became two things: a body of people, and a department. So there was the department - I don't know how many people were there, but the Radiation Protection Branch 15 sort of came into being towards the end of - as a regulator of uranium mines and so forth, when the Radiation Protection Control Act - towards the end, 1980 and 1982, when the regulations and the Act came into being in 1982. The regulations weren't made until 1985. So we still administered part of the 20 Health Act, I believe, until 1985 in terms of regulating x-ray machines and things, but the real controls came into force in the early 1980s. MR JACOBI: Perhaps I can pick up on that. You heard Mr Kakoschke's evidence this morning, I think, in terms of the state of the radiation protection 25 that was in place in the 1950s and early 1960s. I'm just wondering whether you can identify, from your experience, sort of the key milestones in terms of regulation and regulation change since that time. MR PALMER: Well, I think the main milestones might be the transition from 30 protecting people, and the intention was that if you protected people you protected the environment, but there was more effort in terms of - and I don’t really know what the Health Department did in terms of surveillance. I believe it was probably the Mines Department at the time were responsible, I guess, for the health and safety of workers on the uranium mines rather than the Health 35 Department itself. So there was surveillance of radiation doses and surveillance of radon exposures in the mine, but that wasn't - - - MR JACOBI: In what time period? 40 MR PALMER: Well, during the mining operations and during the operations at Port Pirie and Radium Hill. There was, I believe, surveillance of radiation exposure levels and of course there was a study of the outcomes of uranium miners that was published by the Health Department, their immunological department, and people from the Radiation Protection Branch contributed to 45


that particular study. That was really looking at data that was taken from dose rates and radon levels in the mine when it was operating, but I don't know who actually took those measurements. MR JACOBI: So we have records from the 50s and 60s when mining was 5 taking place at Radium Hill of dosage levels? MR PALMER: Yes. Well, there was sufficient information there to actually do a study of outcomes like lung cancer rates of miners. 10 MR JACOBI: Do we have that data? MR PALMER: Well, I don't know that we've got the data. Might have to look back into the archives whether the EPA still has the specific data. It's probably within the Health Department more, and the University of Adelaide, 15 that were conducting the actual study. So that data should be available somewhere else, but I don’t believe that the EPA has that specific data on those rates and radon broader exposures. MR JACOBI: I'd just like to follow that through. If we were measuring that 20 information at that time, were we aware of the impact of uranium on personal health? Presumably that was the reason we were - - - MR PALMER: Yes. Studies go back to, you know, the early 1900s or, say, the 1920s and 30s, there were studies of exposure levels in uranium mines. 25 That's my understanding. MR JACOBI: All right. We'll pick up on that data once we conclude today. I'd see like to see it. We've heard quite a bit about Radium Hill this morning already, and I'm just interested perhaps if we can deal with the Port Pirie 30 treatment plant. Perhaps this is you, Mr Marshall and Mr Ward. But I'm just (indistinct) get a broad outline of the activities that were carried out and over which time periods they were carried out at the Port Pirie plant. MR MARSHALL: Sure. So as Mr Kakoschke said in his evidence, there was 35 uranium concentrate railed from the Radium Hill site to Port Pirie for treatment. The treatment process there involved an acid leach of the uranium concentrates to bring the uranium mineral into solution, and then there was a purification process involving iron exchange and various other sort of tanks called counter current decantation tanks to purify that solution. So they ended 40 up with a leachate that just had the uranium mineral or the uranium oxide just in that solution, and then there was a process of precipitating out that uranium mineral into a product called yellow cake, or uranium oxide. The waste produced during that process was the residue from the leaching of 45


the concentrates, and I think it was commonly called tailings, but it was a leached material from the acid process and that material was placed out in clay lined ponds adjacent to the treatment facility. MR JACOBI: Now when was that activity carried out and when did that 5 conclude? MR MARSHALL: So that occurred over the life of the Radium Hill mine from the mid-fifties to 1961. 10 MR JACOBI: And the activities after 1961? MR MARSHALL: So after that the – just get the timing right here. So in 1968 there was a company called Rare Earth Corporation – actually this gets back to ownership to. So there was a period where that site was actually owned by 15 another entity, it was owned by Rare Earth Corporation, so the government did actually sell that property to Rare Earth Corporation for a period in 1968. Their operation was centred on processing a mineral called monazite. So monazite is a radioactive mineral that is a produce produced from the mining of heavy mineral sands. The sand you find on shorelines on beaches. And 20 monazite, I think is a – or the radioactivity in monazite is from thorium and the process that was undertaken there was called process monazite cracking to extract rare earth from the monazite. So that again, created more residue from that process and that was deposited on site too, and some other residue dams. I can’t recall when that actually finished but that came to an end and the site was 25 actually purchased back by the South Australian government after the Rare Earth Corporation finished their activities. There was a period where there was – the site was used for recovering lead from batteries, from 79 until 86 and in 1988, there was a company called 30 SX Holdings, planned and developed and established equipment on site for the extraction of rare earths from the existing residues in the dams on the Port Pirie site and one of the minerals that they were mainly interested in was scandium which was sourced from the radium (indistinct) and was contained in the residues of tailings left on site there. The scandium price, when that started, 35 the scandium price was quite high but the scandium price is quite volatile and by the time they got around to commissioning the plant, I think the scandium price was at a level that wasn’t economic to carry on with the plant, so the SX Holdings operation didn’t actually ever get commissioned and they didn’t produce. 40 MR JACOBI: A key feature of the Port Pirie site are its tailings dams. MR MARSHALL: Yes. 45


MR JACOBI: And I’m just wonder in fact whether you could explain the size of those dams? What they contain? MR MARSHALL: So the tailings dams, I can’t recall the actual area of the site but they contained about 200,000 tonnes of tailings material and they were 5 essentially the waste that was – or the left over from processing the concentrate from Port Pirie, sorry from Radium Hill. So it’s like the invaluable minerals that were contained in the ore, that was in the ore that was mined from Radium Hill, so it would actually include some rare earth minerals and like scandium and some other rare earth minerals that I can’t pronounce the name 10 of, they’re in the bottom of the periodic table. And there were some heavy metals in there as well. MR JACOBI: And this might be a question that Mr Baldry can also address but in terms of what are considered to be the key environmental issues that 15 arise from the operations that were conducted at the site? MR BALDRY: The environmental issues today? MR JACOBI: Yes. 20 MR BALDRY: Given the location, I think that the possibility of movement of materials to groundwater in to the marine environment would be the principle concern. In previous years, prior to slate being placed on top of the material there would be concerns about airborne dust being raised from the tailings and 25 also radon emissions from the material as well. COMMISSIONER: I assume proximity of community would be a concern because of the dust? 30 MR BALDRY: Yes. I think that it’s obviously not a location you’d choose today but the proximity to both the marine environment and the local population would be the concerns. MR JACOBI: And putting to one side the issue of radiation, which I think is 35 picked up in the answer then, is there also an issue arising given the nature of the other materials that are contained within the tailings? MR BALDRY: Yes, from an environmental perspective that sort of heavy metal content would be the principle concern, in terms of chemical toxicity. 40 MR JACOBI: Coming back and Mr Marshall, in terms of the information that’s now available, and I understand that some review has been done of documents that have been held by DSD, are you able to make any expression or view about the overall planning? That is, at the time that the activities were 45


established either at Radium Hill or Port Pirie? The sort of planning that went on to take in to account environmental considerations? MR MARSHALL: We’ve reviewed many of the documents on record that the department still has available to it and it was difficult to find any reference to – 5 or planning those operations, taking environmental impact in to account. So I think that was reflective of the times when the commencement of mining operations, or in the planning of mining operations there were no environmental impact statements in those days to do an assessment of impacts on the environment in the early phases of the operation. So the planning of 10 those operations was very much focussed on having – establishing an effective well managed operation from the point of view of delivering the project objectives and doing that safely. So I think it was pretty clear that there was consideration for the safety of employees and workers during those days but we’ve not found any evidence that there was any sort of environmental impact 15 assessment process undertaken. Nor was there any consideration during the planning of the operations, how the site would be closed to a point where you could say there was – the site, the project was complete from the point of view of closure – of either site. 20 MR JACOBI: By closure you mean decommissioning? In terms of at the time that the projects were planned? MR MARSHALL: Well, both decommissioning, in other words, in shutting down the operations but also in closing the site to a point where we would call 25 it mine completion which is where the site would have been brought in to a state that no longer needed ongoing management and monitoring. MR JACOBI: I think this might – the next one might be for you, Mr Palmer. In terms of the radiation involvement at the time that the activities were carried 30 out, what was the extent of the radiation regulation or activity at the time that these activities were undertaken? MR BALDRY: Well, I’m not aware of the Health Department at the time, or Department of Public Health being involved in radiation monitoring but - - - 35 MR JACOBI: Did it have regulatory power at that time? MR BALDRY: It had regulatory power but those powers were mainly directed towards radioactive substances and x-ray apparatus used in the 40 industrial or primarily in the medical area. MR JACOBI: Sorry. I should have been clearer. Did it have regulatory power in relation to the activities that were being carried out on those sites? 45


MR BALDRY: I don’t believe they did. I mean I’d have to study the – try and find a copy of the old regulations but I don’t believe they – they could have extended the regulatory power that way but if, at that time, the Mines Department were basically taking responsibility for regulation in terms of doses to the workers, then the Health Department, I would – maybe took a 5 back seat if you like, so to speak. Because I think always had regulatory powers to protect the health and safety of people from exposures to radiation but it may have been that the Mines Department at the time actually took on that responsibility. 10 MR JACOBI: Is there a contrast to the position as it stands today under the Environment Protection Act and under the Radiation Protection and Control Act? MR PALMER: Well, under the Radiation Protection and Control Act I guess 15 there certainly is a contrast because we have specific regulations and provisions in the act for regulating uranium mines. I don't believe that there were licences, for example, for uranium mining under the Health Act. Licences were only for people, basically, and for registering either x-ray machines or radioactive sources – sealed sources, we call them – and 20 capsulated sources used in industry, or also registering premises which are places like universities or health departments where radioactive chemicals or radioactive agents are used for diagnosis or treatment of patients, that sort of thing. So the short answer is not until the Radiation Protection and Control Act was made do I believe the Health Department or South Australian Health 25 Commission have specific powers for regulating uranium mining or mineral processing activities. MR JACOBI: Perhaps back to you, Mr Marshall. I want to come now to the practical management of the circumstances that would have presented 30 environmental risk. Perhaps we can come to Radium Hill first. I'm just interested to understand how – we've heard a little bit from Mr Kakoschke this morning about how tailings were managed. I'm just wondering whether you can give any insight, based on work the department has since done, about how tailings were managed at the Radium Hill site. 35 MR MARSHALL: The operation of the tailings dam was pretty much as Mr Kakoschke described it. The tailings impoundment was actually constructed of tailings as it was deposited. I think the initial starter wall – there would have been an initial starter wall created to contain the first lot of tailings 40 deposited which were deposited through a pipe that went around the circumference of the tailings impoundment and the tailings deposited through what we call spigots or holes in those pipes to create a beach of tailings where the water and the tailings then separated from the tailings, like waves on a beach, and then the water recovered for going back into the process. 45


As the tailings were deposited it would make the facility higher and then there would be an ongoing process of making the tailings wall or the impoundment by winning tailings material and then constructing the wall. I think the technical term for that is upstream construction. So the method of depositing 5 or storing tailings would be very consistent with many other operations around Australia and the world. MR JACOBI: I think Mr Kakoschke explained that as at the time of closure the tailings dam was essentially left. Is that consistent with your 10 understanding? MR MARSHALL: Yes, it is. MR JACOBI: Stepping aside from tailings, we also heard some evidence 15 about the fact that the rock was used for other purposes. I'm just wondering whether you could explain where you understand that rock might also have been used. MR MARSHALL: I don't really have any more information to add to what 20 Mr Kakoschke mentioned about the use of the waste rock. The other term used was the heavy-medium reject which was that conical pile at the end of the plant used for road-making material and railway ballast. MR JACOBI: We've seen some evidence with respect to work that was done 25 in the early 1980s with respect to the tailings dam. I'm just interested to understand, perhaps from both you and Mr Baldry, in terms of getting a bit of an understanding about what was done in the early 1980s with respect to securing the tailings dam. 30 MR MARSHALL: I think it was recognised by that time that the dispersion of the tailings was occurring through primarily wind erosion but some water erosion as well during rain events. You can see that dispersion of the tailings from aerial photographs that show the plume or the hue of grey tailings downwind of prevailing wind of the tailings facility. So the department, a 35 former version of the Mines Department, undertook to win soil material from the immediate area surrounding the tailings dam to place a cover over the walls and a cover over the top of the tailings dam to contain the tailings material from further dispersing through wind and erosion. 40 MR JACOBI: Are either of you able to speak to the design of the nature of what was then done at that time in terms of securing the sailings dam? MR WARD: Well, I understand that it was covered. The decision was made to cover the sides with three metres of that material and one metre across the 45


top. There was a suggestion of using rock armour but that was found to be beyond the budget and it was not used. So what's left there today is what was really done in that period of 1981. Where there's approximately three metres, less some erosion, on the sides and one metre across the top, that pretty well encased the remaining tailings there and has prevented further wind erosion of 5 that tailings. MR JACOBI: What's the significance of rock armour? MR WARD: Rock armour would stop the wind from eroding the sides of it. 10 The sides are naturally very steep. They're normally at what we call an angle of repose which is about 37 degrees. At that steepness there is the difficulty of vegetation growing. Some does but it's difficult. There is a tendency for it to erode under the influence of water and/or wind. Rock armouring would prevent that erosion or substantially reduce it. If you were going to have 15 something sitting up high then you need some sort of rock armour or a different type of soil. In today's climate a tailings dam will be designed and constructed with a clay wall and rock armour and, in many mines, there is a combination of waste rock and the tailings that were contained within that to ensure that there is no erosion of the sides of that. 20 MR JACOBI: Is there a difference in terms of the angle of repose to that? MR WARD: Well, it can be sometimes but if you've got rock armour at 37 degrees it will generally remain stable. The disperse of soils will not 25 necessarily remain stable. MR JACOBI: Perhaps just in terms of Port Pirie briefly, we've heard some evidence about the environmental risks. I'm just wondering whether there's a distinction between the risks that are presented by the plant site and by the 30 tailings site and whether there's a distinction that we need to bear in mind with respect to that site. MR MARSHALL: I think the main risk associated with the plant site is just remnant radioactive material that could be dispersed or creates an exposure 35 risk. I guess my colleagues at the EPA can talk about that. Just focusing on the plant, in the mid-2000s we recognised that there were still buildings from the former operation there (indistinct) operation and the water tower was still on site and there was quite a bit of material there that encouraged vandalisation and pilfering on site which meant that it was just attracting people to go on site 40 and, therefore, creating exposure. So we undertook to demolish all those buildings and remove all that basically to remove the attraction of unauthorised entry on that site. There's some areas on site there in the plant area where slag has been placed to 45


minimise the risk of dispersion or pathways from radioactive material in the former plant area. On the tailings dam itself or on the tailings facilities at Port Pirie, as Keith has already mentioned, the risk there is associated with the risk of affecting groundwater through base seepage in the tailings facility and then also the risk of exposure to radioactive materials through airborne wind 5 dispersion or radon. MR JACOBI: I'm wondering whether anyone is able to speak to the expansion or development of the tailings facilities at Port Pirie. 10 MR MARSHALL: Sorry, in what - - - MR JACOBI: As I understand it, there were initially tailings facilities developed for the uranium treatment plant and then there was an alteration to those tailings dams or there was additional tailings dams added - - - 15 MR MARSHALL: Yes, there were additional tailings dams added to the area during the Rare Earth Corporation's project for taking the residue from their monazite cracking project. 20 MR JACOBI: Are there key differences with respect to the risks that presented between the tailings dams used for one purpose and used for the other? MR WARD: One risk or one event did occur on the Rare Earth's tailings 25 dams. They were to the north of the plant and adjacent to the other six dams from the uranium. They were actually constructed at a lower level of the wall which was in fact inundated in the 80s from a king tide/storm surge. So those walls were raised up to the same level as the other six dams and I believe they were then covered as well in that process of covering it with the lead slag. 30 MR JACOBI: So I'm right in understanding that the buns around all the tailings dams are now consistent? Is that right? MR WARD: Are now consistent, at the same level. 35 MR JACOBI: Can I just deal with the topic of decommissioning in a systematic way in terms of perhaps Radium Hill first. We've heard some evidence this morning about the way that decommissioning was managed in the 60s. I'm just wondering whether you've got anything that you want to add, 40 Mr Marshall, to the way that the Radium Hill site was decommissioned and closed. MR MARSHALL: I think Mr Kakoschke's description of the process of decommissioning is – we would agree with that. So it was very much about 45


removal of useful plant and equipment from the mine and the mineral processing site for later use on other operations which is common amongst mining operations. Our understanding of what happened in the town is consistent with Mr Kakoschke's evidence. Clearly, from later events it was clear that the controls necessary for ensuring that the site remained safe and 5 stable weren't completed during that early decommissioning stage. MR JACOBI: I'm interested in that. In terms of the regulations that stood in the early 1960s with respect to decommissioning was there any requirement that required consideration be given to the way that a mine site would be 10 decommissioned? MR MARSHALL: None that we're aware of. MR JACOBI: From the EPA and the radiation point of view, are you aware of 15 there being any requirement that existed at that time in terms of the way those materials were handled? MR MARSHALL: I'm not, no. 20 MR WARD: I may be speaking a little out of school but I'm not sure that – we tend now to demand a lot more and we also tend to look back at some of these earlier operations through the lenses of today's understanding. I've said amongst people that I suspect the people involved in the formation of Radium Hill and Port Pirie wouldn’t be able to spell the word "environment" and I'm 25 not being facetious there. It was never a subject at school in the 60s. The whole emphasis that I have seen in looking at this process is one of – we have four governments involved, Great Britain, America, the Commonwealth, the State. This is really an imperative. We have the Cold War atmosphere. We have an importance to get this job done. All the pictures indicate that that mine 30 and the process work was run in a workmanship-like manner. In fact, it's neater than some of the mines today. But the focus was technical excellence, getting the job done and the environment, the decommissioning was not something – it seems strange to us 35 today but it actually just wasn't considered. I mean, this came as a shock to the miners that it would end, but it did. So the whole environment of looking at this mining process both at Radium Hill and Port Pirie is from a vastly different perspective when it was constructed. I think that's just something that perhaps adds a way of looking at this and as to why some of these things weren't taken 40 into account. MR JACOBI: I understand that Port Pirie has a somewhat more recent history than Radium Hill itself has in view of what has been explained. 45


MR WARD: Yes. MR JACOBI: I'm interested to understand just in practical terms what was done when it was decommissioned both at the end of 1961, as I understand it, and also when the Rare Earth Corporation's activities ceased and the land was 5 sold back to the state government. This is in practical terms. MR MARSHALL: I don't have a huge amount of detail on that other than it seems that there was a desire to keep much of the plant there because of the potential for ongoing use and for recovery of materials from the tailings dam. 10 So the history of that site suggests that there was – rather than sort of planning to remove and completely close the site, there was always the suggestion that this site could be used for something else. Therefore, many of the facilities were kept for an after use. One of the useful purposes that site performed in recent times is there was one particular large shed that was used on site for 15 storing what was a waste product that – at that time was Pasminco, now Nyrstar – was stored. It was a waste product that came in from their operations in Hobart at the Risdon smelter called paragoethite. It was stored on site there in one of the big sheds and was for reprocessing in the Port Pirie smelter. So there has been this history of leaving equipment there for the benefit of such 20 purposes. MR JACOBI: I think your evidence is that, as the position stands now, that's no longer the case. That (indistinct) has been stripped away. 25 MR MARSHALL: Yes. So one of the things that we did in recent times was we got ANSTO to undertake an economic study of the potential for reprocessing the tailings at the Port Pirie site and to determine the likelihood of an economic operation establishing there. That was determined to be unlikely. 30 MR JACOBI: You mentioned in the evidence the coverage of parts of the slag from the operations nearby. I'm just interested in understanding when that occurred and what the primary purpose of doing that was. MR MARSHALL: So the date of when that occurred - - - 35 MR WARD: It occurred in the mid-80s, 1980s. I don't have the exact year but it occurred in the mid-80s and the purpose of that was twofold. One is to prevent dust from being blown off the tailings and, two, to reduce the radiation level to anyone walking over that. So it's quite effectively in actually reducing 40 that radiation level and it's effective in reducing the dust because it's quite a coarse. granular material. So those are the purposes of doing that in the 80s. There were some other rehabilitation efforts with clay and dirt on some of the areas but it was mainly the slag was used to cover those areas, dams 2 to 5 and a bit of 5 and 6 and there were two openings left at dams 1 and 6 for water that 45


flows in, rainwater as such, to evaporate, because if we covered everything then it may become saturated. So it was left to those two areas to drain, to evaporate. MR JACOBI: I want to come to deal with the legacies as the position stands. 5 COMMISSIONER: Can I just finish with the decommissioning. It seems to me that the state has had to pick up responsibility for rehabilitation in the mines when ownership is transferred. Is there requirement in the current legislation for some sort of surety for mining operations for decommission? Is that part of 10 the licence today? Do you keep some sort of bank guarantee so that there is confidence when mining operations complete that the state doesn't have to pick up responsibility when entities close? MR MARSHALL: I'll answer that. It's a requirement under the Mining Act. 15 Section 62 of the Mining Act gives the minister authority to require from a tenement holder where a mining operation has occurred, required to lodge a rehabilitation bond to provide financial assurance to the state government against the rehabilitation liability for the mine. So the policy principles against which that section of the Act is administered is that the bond amount requested 20 from the tenement holder is the amount that’s been assessed as the estimated rehabilitation liability for those operations. That is actually reviewed during the life of the operations. COMMISSIONER: When a mine is given approval then, is the manner in 25 which it’s to be decommissioned covered in that initial mining approval? Or is the decommissioning something that’s considered later on in the operation of the mine? MR MARSHALL: So the current legislation under the Mining Act requires 30 that the mine completion arrangements to be sort of outlined at least in the conceptual level for the – during the assessment of a new mine operation, before the decision is made to grant a mineral tenure for that operation. During that assessment the impact both during the operation and the impacts at closure are assessed. The plans presented by the proponent on closure are assessed and 35 conditions are put around that. Then if that operation is approved and a mineral tenure is granted for that project the operator for that project is required to submit a programme for environmental protection and rehabilitation and that programme has requirements in place for during operations for the protection of the environment and also requirements and 40 therefore how the site will be decommissioned and closed. As the operation, mining operations change over their life, operations are extended, the processes are improved, those operations – the closure aspects of that are – there is ongoing opportunity for reviewing those plans. 45


COMMISSIONER: Is it public knowledge, the extent of the bond required to rehabilitate a mine after it has finished its life? MR MARSHALL: Well, the requirements for the bonds are – I guess they’re public by virtue of the requirements of the Act. Did you mean the - - - 5 COMMISSIONER: The dollar amount? MR MARSHALL: The actual rehabilitation liability estimates are included in the programmes for environment protection and rehabilitation and that’s 10 required through the guidance material or the – what we call determinations that set out the mandatory requirements for all those people. The actual – any member of the public, in terms of the actual bonding arrangement, any member of the public can inquire that information through inquiring with the department through the mining registrar and for a particular operation, the bond 15 requirements can actually be – the advice on that can be got through that pathway as well. COMMISSIONER: Thank you. 20 MR JACOBI: Before we get to the position as it stands today and in terms of what studies and other works have been done, I’m just interested to understand what monitoring was done in the period from the sixties to present day at the Radium Hill site, of the condition of that site? 25 MR WARD: I can’t answer that directly as to the extent, I haven’t been able to determine that but the information – sort of the picture I have is that very little information, very little monitoring was done, formal monitoring was done during that period from the time it closed. Obviously, we do have inspectors that do look and during the seventies the condition of the tailings dam became 30 an issue. Some of the other things that were done was to fill in the openings and the shafts and that’s not something you do once, you generally have to come back to make sure that they haven’t subsided, so that’s an ongoing inspection level. There’s little evidence I have of ongoing or any radiation monitoring during that period. So the principle inspections was, is it safe? 35 And when we saw the tailings blowing around, blowing in the breeze, then it was time to do something about that, at that stage. MR MARSHALL: I think from what we’ve been able to establish, the actual monitoring of the site, from the point of view of public safety in relation to the 40 mine workings, became more routine once the radioactive waste repository was established on the tailings facility and the tailings had actually been covered with soil, so there was a need to monitor the erosion on the soil and monitor the security around the low-level radioactive waste repository that had been established on the tailings facility. 45


MR JACOBI: In practical terms, how was that monitoring done in terms of once the capping work had been done? MR MARSHALL: Through visitation and site inspection from department 5 personnel. MR WARD: Visually, to look. Secondly, there are some stakes in there, very rudimentary but measured whether there’s been an erosion around the stakes. But primarily it’s a visual inspection, can I see anything eroding? So it is 10 rudimentary in that sense but nevertheless that’s quite valuable, if you look and see and can’t see anything, reasonably comfortable that not much is occurring. MR JACOBI: The shift to Port Pirie facility - - - 15 MR MARSHALL: I’ll just finish off on the Radium Hill too, so there have been various radiation surveys done over the site there to measure radon, gamma and dust over the period of time. The most recent exercise was as part of the process for the department developing a management plan for the site and characterising the site. So in between 2004 and 2009, there were 20 radiological risk assessments done on Radium Hill and Port Pirie where the previous data for radiation - - - MR JACOBI: I will come to that. 25 MR MARSHALL: Yes. MR JACOBI: (indistinct) in a minute. MR MARSHALL: Okay. 30 MR JACOBI: Can I just – can I come to just deal with Port Pirie in the same way in terms of the way that the Port Pirie site was monitored after perhaps – during the 1970s and thereafter? 35 MR WARD: There were some more, because we had people working there during some of that time, there was a greater involvement in looking, viewing that site. But there wasn’t a lot of radiological monitoring to my knowledge but there was monitoring of the operation. I think the fence eventually was put up in 1978, if my memory is correct, and that fenced off the area to provide 40 security. Prior to that it hadn’t been fenced. So that was done to try and limit the access to people. And then it was just ongoing monitoring. A lot of the rehabilitation work, by that I mean the spreading of the slag, was done in the eighties and that was an ongoing monitoring operation of that site and then that dropped off but reviewed in 2004, 2010 when the ACOM did a far more 45


complete study. MR JACOBI: Perhaps we can pick up and deal with that intense (indistinct) studies done and perhaps Mr Baldry, what was the motivating force behind the studies that were done during the period from 2004 to 2010? 5 MR BALDRY: Australia signed the joint convention on the management of radioactive waste in – it was ratified in 2003. MR PALMER: Yes, about 2001 or two, we signed the joint convention on 10 spent fuel management and radioactive waste management. The signing of that convention then required some time shortly after there for Australia to report to the joint convention in respect to Australia’s compliance with that joint convention and each state radiation authority was asked to contribute to the national report that was prepared by the Australian Radiation Protection and 15 Nuclear Safety Agency. In preparing that report, it was asked, were there any legacies – well, we had to address whether there were legacy sites and states and territories needed to demonstrate how they were complying with the joint convention, particularly one of the articles, article 12 of the convention that required states to look at legacy sites and determine whether remedial action 20 should be required and so forth. So with that being said, it identified that Radium Hill and Port Pirie, while the EPA, and previous to that, the Health Department or - it was actually the Department of Human Services just before when we referred to the transfer to the EPA. While we did occasional monitoring and checks to determine any radiation risks, if you like, there was 25 also - it hasn't been mentioned so far - a scrap dealer who occupied the site for some time and was basically wandering around the site breaking up batteries and causing a mess by himself, but he was evicted from the site under the provisions of the Radiation Protection Control Act where it was considered that it was a dangerous situation, that he could expose himself. But to move on - 30 what was I? MR JACOBI: We were at the point of explaining the link between the joint convention - - - 35 MR PALMER: Yes. MR JACOBI: and (indistinct) MR PALMER: So it then highlighted the fact that while the EPA regulated in 40 respect to keeping some surveillance of what was happening at Radium Hill and Port Pirie, there wasn't an actual licence put on the site. At that stage, our Act didn't actually provide for licencing that sort of facility, so we registered the facility under the Radiation Protection Control Act. The only interesting distinction is that registration is normally applied to nuclear medicine 45


departments or university laboratories, however it covers any site where unsealed radioactive material is contained or used. So under that particular provision of the Act, section 29, which allows us to register a premises, we registered the premises of both Port Pirie and 5 Radium Hill in the name of the minister at that time, and by registering them at that time, we placed conditions on the registration that initially required them to assess the sites, if any immediate things could be done, but also then to determine what steps might need to be taken, if any, to rehabilitate the sites. 10 MR JACOBI: I'm right in understanding, aren't I, that the licence conditions required a series of studies to be undertaken over a period of time? MR PALMER: That's right, and the purser produced initial reports that were presented under that registration to the EPA. A little while after then - I'm not 15 quite sure what year it was, probably 2012 - the Radiation Protection Control Act was revised, so we had a provision within the Act that we could licence places like Port Pirie and Radium Hill, or any other facility that didn't specifically fall into the category of a uranium mine, for example. Uranium mine provisions have been in the Act since 1982, but they didn't actually 20 contain provisions, for example, to licence a facility like the Port Pirie facility, but we could have when it was operating. In fact, the rare earth's plant was registered as a premises. So that provision was there, and there was really no difference in terms of how 25 we regulated Radium Hill and Port Pirie when it changed from a registration of premises to a licence for past practices. That's basically how we express it. MR JACOBI: Now, in terms of the studies that were done, what were the broad areas that were covered in terms of what was analysed? 30 MR PALMER: Basically the containment of existing structures and surveys of the radiation levels around the sites. I'd have to refer to the conditions on the licence, but certainly the available reports on the purser website (indistinct) for Port Pirie and Radium Hill report - the first phase reports, which basically 35 complied with the EPA's requirement under the licence to provide those reports, they contain all of that information that's relevant. MR BALDRY: I think the two aspects they provide is the radiological conditions of the site, and that's in terms of the various methods by which you 40 could be exposed to radiation, the gamma radiation or the inhalation of dust, or for the Port Pirie site, the potential for groundwater to contain radioactive materials to get into the environment and then people to be exposed that way, to actually assess the levels, and then make an assessment based on how people live in both areas, what the potential exposure in terms of a radiation dose 45


might be for a representative person or a worker, a member of the public. MR JACOBI: Can we come to those issues of radiological risk, and perhaps we can deal with Radium Hill first and we'll deal with Port Pirie in a minute. I'm just interested in terms of studies that are undertaken, what the results were, 5 in broad terms, with respect to the nature of the radiological risks that would be presented to what you described as these characteristic scenarios. MR BALDRY: The broad conclusion is that there's no risk presented to either the public or to a worker who might be on the Radium Hill for a particular 10 reason, and that's based on the radiation levels that are and the amount of time you could expect someone to reside in the area. The longer you stay there, the higher dose would be from any residual activity. COMMISSIONER: Are there warning signs at the site? 15 MR BALDRY: There are at the tailings facility. I guess principally that would be to explain it's not an area you want to be digging into. There's certainly no requirement based on the usage of the site to actually warn people to stay away because there's controlled access to the pastoral leases anyway. 20 MR JACOBI: In terms of what was assessed for its potential radiological impact, are you able to explain what was assessed in those States? Was it just the mine sites or was it other areas? 25 MR BALDRY: Certainly around the mine site and the roads, and I think the former township there as well. MR JACOBI: Perhaps we could come to the Port Pirie site, the same issue in terms of what were the assessments with respect to the radiological risks that 30 will be presented by the Port Pirie site. MR BALDRY: The broad conclusions are the same in that there's no risk to any member of the public or any worker who was in the Act. It does identify that there are elevated areas of dose rate where if you spent all your time on the 35 tailings dams you could exceed some of the reference level which would make us take action, but given that nobody is going to do that, the conclusion is that no reference level is going to be exceeded and therefore it's safe to the public and anybody accessing the area under reasonable circumstances. 40 MR JACOBI: Could you explain what you mean by a reference level? MR BALDRY: Okay. We base radiation protection standards on intentional requirements and these are set by the International Atomic Energy Agency, and what they basically say is that if you've got a legacy site, such as Port Pirie or 45


Radium Hill, you should make an assessment of what the exposures are likely to be, and this was done, and then you should set a reference level between 1 and 20 millisieverts, and to put that into context, the average background radiation dose that we all get is between about 1 and 5 millisieverts, and so - - - 5 COMMISSIONER: Per year? MR BALDRY: Per year, yes. So if any of the assessment showed that a person could exceed 1 millisievert, then we'd be required to set a reference level based on what could be done with the site to reduce those levels or 10 manage that. Because there's no circumstance where that will happen, there's no requirement for us to set a reference level and no requirement for us to intervene to further protect the public or workers. COMMISSIONER: I think it would be useful for everybody if you would 15 walk through the basis of that reference level, the background, the additional activities and how they are location specific. That sort of general explanation, I think, would be useful. MR BALDRY: Okay. Well, background radiation comes from different 20 places. You get cosmic radiation, you get radioactive materials in everyday foodstuffs and you also get the radioactive material that's naturally in the ground and naturally occurring radioactive material both gives a gamma radiation – that's sort of gamma rays coming from the ground – but also it produces radon gas and other radiological decay processes that creates material 25 that you can breathe in and also gives an exposure. When you add all of these different sources up, depending on where you are, you get probably between one and five because there are different places where the – the levels are different in different areas. The reason that uranium miners go to particular places is because there's more uranium in that place but it generally is 30 everywhere. COMMISSIONER: Can certain locations in the world be higher than five? MR BALDRY: It can go up to 250 millisieverts per year in some locations, 35 for example in India, and it's very typical to go up to 10 millisieverts. So there's a huge range of natural background radiation. So the levels we're looking down to one millisievert are pretty low. We know that there's no effect of background radiation on human health. So we can confidently say that looking at radiation exposures in this range is safe for the public and the 40 workers. ' What has happened at Port Pirie and Radium Hill is due to the nature of the activity. We've gathered up this naturally occurred radioactive material and put more of it in one place. So the radiation levels are elevated at both the 45


tailings dams in particular at Port Pirie and the areas where the tailings and some of the waste rock was at Radium Hill, but even if you took that away, particularly at Radium Hill because it's a higher level of uranium near the surface, you'd still be left with higher levels of natural background radiation at that location than you would in other places. 5 MR JACOBI: I'm just interested to understand the significance of the slag that has been placed on the site with respect to radiation protection. MR BALDRY: One of the sources of radiation, because it's only an issue if it 10 – if it just sat there on its own it wouldn’t be a problem. It's when you've got radiation and people in the same place. The emission of radon gas from the surface could potentially be windblown to where people are. We've seen that if you have tailings that dry out, dust can be blown. So the advantage of putting the slag from the lead smelter on top is that it contains it, stops it being dust 15 blown. Trial and experiment showed that it significantly decreased the amount of radon that was being emitted, probably because it kept the tailings in a moister condition than would otherwise be the case. MR JACOBI: I want to come to, with respect to both sites, the issue of the 20 possible to mobilise materials through surface water. Perhaps we can deal first with Radium Hill. We've heard this morning about the nature of the rainfall around the Radium Hill area. I'm just interested to understand how that is thought to present a risk with respect to the movement of materials and, if it is, how is that managed. 25 MR MARSHALL: I guess the obvious risk in relation to rain events at Radium Hill is the impact of the rain events on the soil cover over the tailings dam through erosion. So clearly when the soil cover was designed at the time in the 80s when that project was undertaken there was a compromise about 30 how much money was spent on it, to the extent that there was soil placed on it which meant that, rather than it just being a measure that could be just left there and not monitored forever and maintained forever, there was going to be ongoing need for maintenance and monitoring to account for the risk of things like rain events and erosion. So the way that is managed from our perspective 35 is to actually go and inspect the site and monitor the condition of that soil cover. If there is erosion there's maintenance necessary to maintain its integrity. MR JACOBI: Has there been research done with respect to groundwater near 40 the tailings dams at Radium Hill? MR MARSHALL: Yes. There was a groundwater risk assessment that was done as part of the studies that you asked Graeme Palmer about. So there are a number of monitor wells around the site where the groundwater is being 45


monitored, both in terms of levels and in terms of quality. As we understand it, apart from the fact there are no users on site anyway so that the groundwater is not useful for pastoral use, from that perspective there is no pathway to people that might be affected by any mobilisation of contaminants. I'm just trying to recall whether actually – I don't think that there was any sort of – I don't think 5 there was any evidence of there being an effect on groundwater from - - - MR WARD: I don't think groundwater was an issue at Radium Hill because of the very high evaporation rates and generally lack of rainfall. If it does rain very heavily, as we've been told, it doesn't necessarily soak right through. It 10 just flows off. So there's this massage run-off but it's not an area that you get a lot of rain that simply soaks through the tailings. So there has been little evidence. I can't recall exactly what the timings were but I don't recall there being an issue with groundwater movement or transposition from the Radium Hill site but I'd have to check that to be absolutely sure but I don't believe there 15 is. MR JACOBI: In terms of the surface water mobilisation, I think you might have already covered it in terms of the capping but has there been monitoring of the way that surface water might mobilise or potentially mobilise? 20 MR WARD: No, I can't say we've done that. Again, I can't recall anything on that. It wasn't seen as an issue to my knowledge, going through the documents. MR MARSHALL: The focus is on the soil cover being the main control there. 25 So if that control is in place and the integrity of that is okay, well, it's seen that surface water won't mobilise the tailings. MR JACOBI: Perhaps coming to Port Pirie, again the same issues. In terms of groundwater at Port Pirie – and this is for you, Mr Baldry – is there evidence 30 that there was mobilisation of either the metals or the other materials into groundwater at Port Pirie? MR BALDRY: Yes, there was evidence of mobilisation to groundwaters. It's not clear what will then happen to these heavy metals that are in the 35 groundwater, as to whether they will then make it to the marine environment. One of the complicating issues is the fact that you've got a lead smelter that's next door and has been operating for a very long time and dominates the heavy metal content in the local environment. So the contribution from seepage through from tailings to groundwater is almost certainly not significant in 40 comparison to the context that's in a lead smelter. MR JACOBI: Is there evidence of the potential to use those groundwaters in any event? Are they groundwaters that are accessible and useful to humans? 45


MR PALMER: I don't believe so. I think there's evidence that the contents of the groundwater, if you wanted to use it, it's so salty and it's not – it isn't useful water. However, if you wanted to use it you'd probably need to put it through an osmosis system or something like that to purify it in any case and that would target the radionuclides or heavy metals that might be there. It isn't envisaged 5 that somebody would really want to use that water but it could be used if it was treated. COMMISSIONER: Has it been seen necessary to dig some monitoring wells to track if any of this contaminated groundwater is going into the marine 10 environment from the tailings dam itself? MR PALMER: I’m not sure; I need to look at the - - - MR MARSHALL: Yes, there were - - - 15 MR PALMER: I think in the reports that were done by AECOM - - - MR MARSHALL: So there are some monitor wells that are actually off site so the monitoring that was done as part of the groundwater risk assessment both 20 looked at migration of – in to groundwater on site and off site, so it was an attempt to determine whether there had been any off site migration and the monitoring didn’t provide any conclusive evidence where you could sort of conclude that there had been off site migration. So there wasn’t like an anomaly that sort of made it obvious, yes this was happening off site. But 25 there was quite a lot of effort to try and determine that. The evidence from the monitoring was sort of inconclusive as to whether there was any off site migration of contaminants from the site in to groundwater off site. COMMISSIONER: When was that last conducted? 30 MR MARSHALL: That was in the mid-2000s. COMMISSIONER: And is there a view that it might need to be done again, if the first conclusion was that it was inconclusive? 35 MR MARSHALL: Yes, that would be part of an ongoing monitoring programme. MR PALMER: There are also several aquifers. 40 COMMISSIONER: Yes. MR PALMER: So it’s not just between one going that way, it’s also vertical - - - 45


COMMISSIONER: Yes. MR PALMER: - - - movement as well. The area that the tailings are constructed on is quite a heavy marine clay, so that the tendency for any rapid 5 movement is non-existent. It’s a very slow process and certainly as Greg has said, that will be part of that ongoing monitoring. COMMISSIONER: In terms of the ongoing monitoring, do you have a standard operating procedures in terms of what monitoring should be 10 conducted, or is this something that’s left up to the individual who is given the responsibility to do the assessment report? MR WARD: What I was going to say was that we do have a series of ACOM reports that we will be using as the basis for determining the risk and therefore 15 on the basis of that we will then establish what the further ongoing monitoring may be. There has probably been a pause, if I’m realistic about it, because the initial report was there’s no immediate risk to people. So therefore it hasn’t had necessarily the urgency. But nevertheless it is very clearly on our agenda to take those reports, determine which is the high-risk areas and then to 20 determine a plan. So there is no procedure but there is a format within the reports of what we need to look at. That will then be discussed with the regulators, the EPA and by agreement we will come up with a programme for monitoring that both in the short, medium and longer term. 25 COMMISSIONER: So what is the EPA view on this? MR BALDRY: The human health risk assessment done in the ACOM reports assumed – let’s say in the worst case the highest levels found were migrating off site. So even if there was no evidence of it, let’s say if that happened then 30 what is the most exposed individual and it’s probably somebody who would be fishing and catching a lot of fish, consuming a lot of fish caught in that environment. That showed that even under the worst-case conservative assumptions, that there was no human health risk. 35 COMMISSIONER: Right. MR BALDRY: So that gives the EPA confidence that DSD does not need to take immediate action in order to further quantify what the actual levels in groundwater are and how they’re changing over time. However, DSD is 40 correct, like over time that would form part of the long-term monitoring plan. COMMISSIONER: So you don’t have a view in mind about when this might need to be done again? Because as you, point out, you don’t believe there’s a risk to human? 45


MR BALDRY: I mean you can pick a figure to say, well it’s the sort of thing that might be done every five years but - - - COMMISSIONER: That’s what I was trying to get at. 5 MR BALDRY: Yes. MR PALMER: Yes. All I was going to add was that the licensed person or licensed organisation would prepare a radiation management plan and that’s 10 the stage that while we have got data on the stage of the environment and there are uncertainties, that information that DSD has, at this stage, which we have a lot of that information as well, would be used to formulate their radiation management plan. And then the EPA would assess the radiation management plan and if there were areas where the EPA considered more work needed to be 15 done or greater monitoring, then we would talk to the licensee and they would normally modify their plan, or argue against it, if we were out on a limb by some extent and it was unnecessary. But I can’t see that happening. But the normal process for uranium mines or other – these are legacy sites, but normal process is that companies submit a radiation management plan, or radiation 20 management radioactive waste management plan and the EPA assesses it. But if there are difficulties or we see deficiencies at all in that plan then we ask for those things to be reviewed. COMMISSIONER: Those sorts of plans would be for instance available for 25 Olympic Dam tailing ponds? MR PALMER: Yes. Yes. They are. COMMISSIONER: Okay. 30 MR JACOBI: I think just might be one more question before we break, and that is in terms of the reports that we’ve been discussing and in terms of – what is the nature in terms of their public accessibility? 35 MR MARSHALL: So the process we’ve been going through is in accordance with the licence conditions, as a phase process, and the initial phase or phase one of the projects was to do, I guess, issues identification phase. Those reports from that phase one exercise are on the DSD website. Those reports led to the scope of works for doing the risk assessment data, a gap analysis 40 phase of the project, or we’ll call it phase two. Those projects – those reports are currently not publicly available so we haven’t put them on our website because we’re still going through this process of developing management plans. But hope, as we go through that process, they will ultimately become publicly available. 45


COMMISSIONER: We will adjourn until 1.45, thank you gentlemen. ADJOURNED [12.47 PM] 5 RESUMED [1.47 PM] COMMISSIONER: We'll reconvene, 1.47. I remind the witnesses they are still under oath. Mr Jacobi. 10 MR JACOBI: I thought we might pick up this afternoon, from the perspective of everything we discussed this morning, in addressing what are the lessons that have been learned from the activities carried out by the sites. I just wonder whether perhaps we could start (indistinct) perhaps you, Mr Baldry, in terms of what you think are the key lessons that emerge from the Radium Hill and 15 Port Pirie sites. MR BALDRY: I mean, the main lesson is to have an actual regulatory framework that covers activities and covers the human health and environmental impacts. It's something that's developed over a considerable 20 time, since the time of the Radium Hill and Port Pirie activities, and I think having a regulator that has responsibilities for overseeing the actions and holding the operator or licensee to a certain standard is - that would be the main thing that we have in place now. Once you have that in place, once you have a legislative system that gives a regulator powers, they can make the 25 assessment and put things in place and hold operators to account. MR JACOBI: Do you think that there's a unique distinction, perhaps with respect to these sites, in terms of the fact that they were, in essence, operated by the government and that represents a distinction perhaps to other activities 30 that might be carried out today? MR BALDRY: Well, yes, in general most activities in the mining space would certainly be a private - it would be a private or publicly owned company rather than a government operation, but there's no reason you can't effectively 35 regulate government so long as there's a clear distinction between the regulator and the licence holder. For example, I feel quite confident in being independent. Even though both the EPA and DSD are of government, then we are - in separate departments we're reporting to different ministers. We've got our own accountabilities. It is possible to have an arrangement where you can 40 effectively regulate government entities, but in all other circumstances, in all operational situations in South Australia now, yes, we'd be regulating non-government companies. MR JACOBI: Mr Ward, I think that might pick up a theme that you picked up 45


this morning in your evidence about the fact that there was a social and political context associated with the operation of Radium Hill in particular. I'm just wondering about whether DSD has a view with respect to that issue of separation between regulatory control and the operators at the sites. 5 MR WARD: Yes. Having sort of an independent regulator, I think, is essential in ensuring that there's accountability and for ensuring environmental standards are actually set and there's a regulator to ensure those standards are being adhered to during the life of the operation, which wasn't the case during the Radium Hill and Port Pirie operations. 10 COMMISSIONER: Can I just go back to Mr Baldry? Can you explain to me the process by which you are independent? MR BALDRY: The Radiation Protection Control Act is administered by the 15 Environment Protection Authority and we have clear responsibilities in that. We have responsibilities set out as public servants to administer that Act and that requires us to have the public interest in mind when we are discharging our responsibilities under that Act. 20 COMMISSIONER: And you report through the minister? MR BALDRY: Yes. So the minister delegates responsibility for administration of the Act to the chief executive of the Environment Protection Authority, and that's onwardly delegated to myself and the radiation protection 25 team. COMMISSIONER: And your reporting is through the minister? MR BALDRY: Yes. On an annual basis we will report, as all government 30 departments have to do, have to produce an annual report. So that report is publicly available and is one of the things that we provide the minister. COMMISSIONER: And that's your report to the minister, not the minister's version of what he or she thinks issue going on? 35 MR BALDRY: Yes. That's signed off by the chief executive of the EPA. COMMISSIONER: Okay. And I just follow that up with, how do you keep the regulatory environment best practice? How do you keep yourself up with 40 what's happening in the world? MR BALDRY: The most effective way, we find, is sort of benchmarking nationally and internationally. So there are a number of - well, all the jurisdictions in Australia have radiation protection regulatory bodies within 45


governments, and we will meet four times a year to discuss nationally consistent approaches. For issues such as uranium mining, we find we have to look a bit further afield because there aren't too many other uranium mines in Australia. So we will benchmark ourself internationally with countries such as Canada who are held in similarly high esteem as Australia as international best 5 practice. We're quite concerned that we are regulating as best practice regulators and that the operators in South Australia are operating to best practice international standards. Part of my job is to actually understand what those standards are 10 and to make sure that we're meeting them. COMMISSIONER: So you would be familiar with what the Saskatchewan equivalent of the EPA does in terms of monitoring uranium mining in that State? 15 MR BALDRY: Yes. Clearly their government structure is slightly different from ours, but in terms of the best practice approaches to surveillance of operations and control of operations and standards that need to be met, then, yes, we'll ensure that we're at least as good as they are. 20 COMMISSIONER: And that's something you do regularly? MR BALDRY: Yes. I personally will contact people in the Canadian Nuclear Regulatory Commission through contacts with the International Atomic Energy 25 Agency, and we also look at international publications and latest developments in uranium mining. We actually work with DSD in terms of what constitutes best mining engineering practice and come to the conclusion that if - we should be able to demonstrate best practice in Australia and in South Australia for uranium mining, and that's the main objective - - - 30 COMMISSIONER: Everyone else is doing it, so I would hope so. MR BALDRY: Yes. 35 COMMISSIONER: Yes. Okay. MR JACOBI: I'm just wondering whether, Mr Marshall, you've got a comment to make in terms of your position as a regulator in terms of ensuring that DSD standards are consistent with those that are applied in other 40 jurisdictions. MR MARSHALL: Sure. As I mentioned in my introduction this morning, the Department of State Development is responsible for administering the Mining Act, and the Mining Act, I guess, is the principal bit of legislation for 45


regulating the industry. It's under the Mining Act that new mine operations are assessed from an environmental impact point of view. And then there's the regulatory framework for ongoing compliance of any approved operations is administered through the Act, and as I talked about before, the provision of rehabilitation bonds is done under that Act, and closure arrangements. 5 So in relation to keeping up with best practice regulatory principles, the South Australian government has a memorandum of understanding with the province of Saskatchewan for exchange, both, of geoscience information. That's about understanding the geology that uranium deposits can be found in, and also for 10 exchange of regulatory information or keeping up with best practice regulation. So we had a recent exchange last year to explore that and came to the conclusion we're very aligned with the regulatory processes in Saskatchewan, notwithstanding the jurisdiction arrangement, departmental arrangement in Saskatchewan are a little bit different than in Australia, but we'll have an 15 ongoing arrangement with Saskatchewan for exchange of regulatory information. We also initiated some exchange with the Nuclear Regulatory Commission in the US, because we'd been using standards that had been developed through the 20 USNRC for the regulation and monitoring of in situ recovery operations, because they have quite extensive experience in that, and some of the standards that they've developed through their experience we've adopted for South Australian operations. 25 MR JACOBI: You mentioned closure requirements and I'm just interested to understand, we (indistinct) this morning that there was no plan for decommission with respect to either of the facilities that we've been discussing. I'm just interested to understand the extent to which it's now a requirement to have such planning for decommissioning both with respect to a facility such as 30 that undertaken at Port Pirie and with respect to a mine that would be similar to that conducted at Radium Hill. MR MARSHALL: So you probably need to deal with those both separately. So if there was a new uranium mine commenced in the State, in (indistinct) 35 there's a requirement for the planning and design for all aspects of closure to be included in the program for environment protection and rehabilitation and for those aspects to be updated during the life of the operation, and that's a requirement of the Mining Act and the regulations, including what we call completion outcomes and completion criteria for determine whether those 40 completion outcomes have actually been achieved. MR JACOBI: Are the criteria themselves required to be updated as knowledge changes? 45


MR MARSHALL: Yes. They are reviewed, yes, but the standards - and this is probably (indistinct) relationship between that regulatory process and EPA that - many of the standards that form the basis for those criteria for determining whether a particular standard has been achieved, a lot of those standards are derived from EPA environment protection policies and radiation 5 protection standards for uranium mines. MR JACOBI: What I was interested to understand is, if at the time that the mine commences it's thought that only a particular state of affairs can be achieved but it's subsequently realised over the next 20 year perhaps that 10 certain other outcomes could be achieved, can they be added to or changed by the regulator? MR MARSHALL: So if there's opportunity to improve environmental performance on a site, yes, we would be pursuing those opportunities to 15 achieve a better environmental outcome. COMMISSIONER: I've asked this question before, but I'd really some more specific information. Perhaps I didn't phrase the question - so let me blunt. In terms of Olympic Dam, what surety does the government have that there is 20 sufficient funding available to remediate the mine? You could use any example. What is the level of confidence that funding exists in good times and bad for the activities to be remediated and the state not to have that responsibility? 25 MR MARSHALL: I'll start with Olympic Dam. Olympic Dam has been developed under its own piece of legislation called the Roxby Downs (Indenture Ratification) Act and that act in itself provides for environmental regulation in there. In that particular case the Mining Act doesn't apply. All other uranium mines in the state are being developed and approved under the 30 Mining Act. So the provisions for bonds under the Mining Act apply for those mines that are under the Mining Act. The current indenture for the Olympic Dam operation does not include provisions for bonds. You might recall there was an assessment of the expansion of Olympic Dam 35 and during that time there was a new indenture developed and passed through parliament. The environmental regulation aspects for Olympic Dam were – there were extra provisions put in that new indenture, including a provision for providing for rehabilitation bonds. Whilst that indenture has gone through parliament, that has not yet commenced because of BHP not proceeding with 40 the expansion plans that were assessed at the time. COMMISSIONER: Understood. So the bonds, explains the structure of the bonds. This is physical cash? 45


MR MARSHALL: So once the amount has been determined the department or DSD request the tenement holder to lodge a bond and that can be in the form of cash or a bank guarantee. MR JACOBI: I think we separated out dealing with the Radium Hill mine 5 from the Port Pirie facilities. I just want to come back to dealing with how we ensure that there's a provision for rehabilitation with a facility such as Port Pirie. MR MARSHALL: The other way a facility like that could be established 10 would be through an application under the Development Act. There is another pathway there because it's not a mine. There have been some facilities in the past that have been established under the Mining Act under a tenure called a Miscellaneous Purpose Licence where activities are directly related to a mining operation. The other pathway for development for that sort of processing 15 facility would be under the Development Act. The Development Act has its own provisions and therefore an environmental impact assessment and development of guidelines for what is required for assessment of a facility like that, and that would be the opportunity to make sure the standards for closure were incorporated in that assessment and then subsequent for the ongoing 20 approval. MR JACOBI: Mr Baldry, do you have anything you'd add from the EPA's perspective? 25 MR BALDRY: If you had an operation such as occurred at Port Pirie then that would require a licence under the Environment Protection Act. The Environment Protection Act also has a provision for financial assurances in the way as the Mining Act. So if you had an operation that for some reason didn't fall under the provisions of the Mining Act we still have an opportunity under 30 the Environment Protection Act to make sure that financial assurances are in place for rehabilitation. MR JACOBI: Would it have been sought if somebody had come forward and sought to develop a facility such as that at Port Pirie? Are financial assurances 35 routinely sought? MR BALDRY: They would be applied only in the high-risk situations. The EPA has thousands of licences. So it's only on specific rare occasions that we would think the risk is high enough to warrant a financial assurance, but in a 40 case such as Port Pirie where you're creating a longer-term legacy then that might be one of those occasions. MR JACOBI: I direct this to both of you. How is the value of those assurances set? 45


MR MARSHALL: The scope of what needs to be done for closure is set out in the detail in the program from Environment Protection and Rehabilitation and through an understanding from DSD what the miner needs to do to do the rehabilitation. So that forms the scope of the works. That needs to be costed. 5 The cost of doing those works is then estimated by using unit cost rates that the government would be most likely to have to pay to actually do those works. So the department, they've gone through a process of getting independent information about those unit cost rates from quantity surveyors and other consultancies to incorporate into a rehabilitation liability estimator or 10 calculator, spreadsheet, that cover every aspect of the mine that would be rehabilitated. MR JACOBI: Putting to one side Radium Hill and thinking about Port Pirie, are you of the view that if one applied modern standards that the Port Pirie 15 wouldn’t be sited where it is if that application was made now? MR MARSHALL: If you were assessing an application now through an impact assessment process you'd be identifying all the environmental values that need to be protected from the proposed development. You'd be assessing 20 potential – and you'd be assessing the risk of that operation having an impact on those values, both during operations and at closure. Given, I guess, the proximity to a town and to the marine environment, the likelihood of an application successfully going through that process would probably – I personally say it'd be unlikely. 25 MR BALDRY: It wouldn’t happen. MR MARSHALL: No, it wouldn’t. 30 MR JACOBI: Sorry, Mr Baldry, do you want to expand on that? MR MARSHALL: Mr Baldry being more blunt than I am. MR BALDRY: It's quite obvious that the potential environmental impacts in a 35 marine tidal environment right next to a residential population would mean that you would not approve the siting of such a facility in the location that it is now. There are legacy sites that can be managed but the objective when approving operations is always that you don't end up with a legacy site. So it must be possible to operate and rehabilitate and close without leaving the situation that 40 Port Pirie tailings now finds itself in. MR PALMER: There are also operational aspects. So with a uranium mine, for example, Roxby Downs township is quite a way away from the mine and it's demonstrated that there's no risk to the community there but you wouldn’t 45


put a chemical plant as close to places occupied by the public. Even though you will control the emissions from the area, they become a more critical group the closer you place the mines or treatment plants to a populated area. So for operational reasons you wouldn’t want to place it – even in terms of the slight increase in exposure to the public. It might be marginal but a plant could add 5 an extra .5 millisieverts to the public if you had them right next to a facility that was operating. COMMISSIONER: Could I ask a general question. We heard in earlier evidence today how important it was to open the Radium Hill mine and the 10 pressure – perhaps the pressure or the willingness of the government to assist in that. How should we be confident that the same level of encouragement to get more mining activity won't produce a similar outcome in the future? How confident are we that pressure isn't put on organisations such as yours to short-circuit activity to encourage future mining activity and growth with a 15 view to the short term rather than the longer term? Now, I appreciate there's a different level of knowledge now than the 50s but we keep talking about independence. Explain to me how we would – you would – resist that temptation to look at the short-term activity at the long-term environmental impact? Don’t rush. Anyone would be good. 20 MR MARSHALL: Just wondering who you were looking at. COMMISSIONER: Walk me through the steps. This is not an accusation; I just want to get a sense of how we protect ourselves in the longer term? 25 MR MARSHALL: Yes. So apart from the point of view of just making sure from Department of State Development’s point of view, making sure that the environment is protected for any new operation, it’s recognised that the environmental performance and closure of mines - and that will influence 30 public acceptance of mining being a legitimate activity in the state. So Department of State Development, being an economic development agency, is interested in the economic development of mines and the exploitation of the state’s mineral resources for the benefit of the state, from a social and economic and environmental point of view. But in order to achieve that and 35 the community has to have acceptance of those – of mines and for the community to be – have that acceptance, they have to be confident in the environmental performance and the regulation of those operations. So - - - COMMISSIONER: So would that logically mean that those documents might 40 be available to the community to look at? MR MARSHALL: Well, that is – yes, thank you for that. A necessary part of making sure that the community is confident, or the broader community is confident in what is happening in the mining industry, transparency is 45


absolutely mandatory. So the decision-making and the documents related to the regulation of mines in the state are all publicly available. So all the programmes for environment protection are on the DSD website for the uranium mines in the state and the other major mines. Compliance reporting is made publicly available, so that the public can see how mines are complying 5 with their regulatory obligations. COMMISSIONER: Mr Baldry, do you have a view? MR BALDRY: Yes, I think that – well, clearly the objects of both Acts that 10 we administer state that we are to have the economically sustainable development in mind when we’re making these approvals but – yes, I would repeat that point that the transparency is something that is different now. It’s an expectation from the community that government’s transparent in its decision-making and they are quite right in that, and it’s something that we 15 tend to be limited, only by technology, in terms of making things available. It is certainly a desire to make the basis of our decision making clear and open to critique and question. And so we’ve got the approvals process where all documents are made publicly available and in fact for the more significant developments, there’s a requirement for public involvement in the decision 20 making process. All those documents are available and then when you’re looking at the operation of the facility, there is routine reporting required. Those reports are all made public. So for example, for a uranium mine, all of the annual and other reports that we require under the licence, will be made available. We require people to publish on their websites and in terms of the 25 closure, that would be the same. We would expect that all the documents will be available for scrutiny. I also think that in terms of pressure, there is recognition now that there’s no point in unsustainable development. There’s no point in the short term 30 approval of things which give longer term problems because it devalues – you look at uranium mining in South Australia and hold it up as an example, if it ceased to be that example then we would find it very difficult, quite rightly, to get public acceptance of further uranium mining. So it’s in the interests of everybody to not cut the corners and not bow to the short term pressures but to 35 make sure that we only approve sustainable mining operations. That applies to other approvals as well. There’s no point in having financially or environmentally unsustainable businesses operating in South Australia. Doesn’t add benefit to anybody. 40 MR PALMER: In fact under radiation protection legislation, it’s the responsibility of everybody up to the minister, to ensure protection of people and the environment from the harmful effects of radiation. The ALARA principle to keep doses as low as reasonably achievable is one of the cornerstones of our legislation. So we all have responsibility not to approve 45


something if it’s going to affect the health and safety of the people and the environment. COMMISSIONER: Thank you. 5 MR JACOBI: We’ve heard this morning about the waste management disposal techniques that were used at both sites and I’m just interested whether you could identify what you consider to be the key lessons in terms of waste management and disposal that emerge and then how those particular waste management techniques would be applied now? 10 MR WARD: I was going to say, particularly around the tailings issue, the tailings dams are now – have a much greater focus, not just because of radioactivity but because of the potential for acid mine drainage, which is a long term issue far beyond the life of the mine. So an assessment of that 15 particular characteristic of the ore and the tailings needs to be made and the design of the dam, or the design of any waste storage facility needs to take those things in to account. For some things, that means it has to be fully sealed up. For others it needs to be under water. So there’s a combination of those depending on the ore. So this goes far beyond just radioactive mines. So 20 there’s a need to construct properly designed, engineered structures to hold tailings and they are generally of a pervious clay layer, sometimes lined, similarly with the walls and rock armouring to hold them together, or some other form, so that they can last the long term. So there’s quite a substantial difference in to what we’ve seen both here in Port Pirie treatment works and in 25 the Radium Hill tailings disposal. MR JACOBI: Is what you’ve described, would that also be required at a processing facility? That is a facility similar to that that was carried out at Port Pirie? 30 MR WARD: Well - - - MR JACOBI: Just in terms of the design of the tailings? 35 MR WARD: probably haven’t had a lot that have been separate from the mine, mining and processing operation but yes, it would be required. Generally the tailings come from a processing facility and they have to be constructed as such. So if that were to arise again, where there’s a separation of the mining and/or treatment, then you would require exactly the same at both sites. 40 MR JACOBI: I think one last specific issue, and that is in terms of operational environmental management. I think what we’ve heard, certainly from Mr Kakoschke in terms of the way that it was operationally managed, this is both the – particularly at Radium Hill, I’m just interested to understand how 45


the operational environmental management, that is not decommissioning, not start up, how that’s now managed under state law? MR MARSHALL: For tailings management? 5 MR JACOBI: Yes, particularly for tailings but also for other aspects of the mine’s operation? MR WARD: Well, perhaps I’ll address that. There are requirements – we have requirements for dust monitoring, so understand that we have the whole 10 spectrum, somewhere in the middle of nowhere and it probably doesn’t get the severe attention. But for critical and large sites, there’s the requirement for dust monitoring, for taking steps to minimise the dust generation and that can mean anything up to real time, dust monitoring with alerts occurring, SMSs, right through to static monitors and in fact a combination of that. And then an 15 assessment of what the dust load that that particular mine is actually contributing to the environment as opposed to the general atmosphere. Because in summer most of our dust comes from elsewhere but determining how that – so that’s the dust aspect. The monitoring of the tailings would be – need to be monitored, how they’re going, any water issues. Another key 20 aspect, erosion, so they’re all key aspects that are now monitored and complied with and that’s part of the compliance reports for many mines. MR MARSHALL: I will just add to that, so for all the tailings dams in the state, we would expect that the proponent would present a design for the 25 tailings dam. It would demonstrate long-term stability, including under earthquake loading. That that design would be independently certified. That the construction of that tailings dam wall, during the life of the operation, would be independently audited and monitored to ensure that it was being constructed in accordance with the design and that those audit reports be 30 provided to the department. COMMISSIONER: Gentlemen, thank you for your evidence. I realise you are busy men and I appreciate taking a day to join us in Port Pirie. We will now adjourn until 2.45 when Dr Paul Ashley will give evidence. 35 ADJOURNED [2.20 PM]


Date post:	12-Aug-2018
Category:	Documents
Upload:	phamkien
View:	218 times
Download:	0 times

COMMISIONER: Good morning. It being 10.30 we...

Documents