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2 - Environmental assessments of uranium mines (continued)

2.2 Ranger (continued)

2.2.4 Investigation of Alleged Deficiencies in Environmental Management at Ranger

As reported in the Supervising Scientist's Annual report 2001-02, on 5 April 2002, a former employee of ERA at Ranger uranium mine's environmental laboratory, wrote to the Commonwealth Minister for the Environment and Heritage, the Northern Territory Minister for Resource Development and a number of Commonwealth and Northern Territory officials. In his letter and attached report, concerns were expressed about a number of issues relating to environmental management and reporting by ERA at the Ranger mine between 1996 and 1998.

At the request of the above Ministers, an investigation of the issues raised by Mr Kyle was carried out and a report was submitted to Ministers in September 2002. It has since been published as Supervising Scientist Report 171.

The report covered the following issues raised in the former employee's submission:

• a tailings spill in December 1997;
• discharge of restricted release zone waters into Gulungul Creek;
• procedures in ERA's environmental laboratory.

Tailings Spill in Corridor Road

In December 1997, a tailings spill occurred at Ranger. With respect to this incident, it was alleged that ERA under-reported and misreported the extent of the spillage outside the Restricted Release Zone (RRZ), failed to clean up in a timely manner the spilled tailings material within the RRZ, and, by its inaction, probably caused an increase in uranium in Retention Pond 2 (RP2).

The investigation concluded that:

• It was not possible to be conclusive about the extent of the spill outside the Restricted Release Zone but there was no evidence that ERA under-reported or misreported the incident. Records show that ERA acted very quickly to remove this material and may have removed more soil than was strictly necessary, possibly resulting in a conclusion that more tailings was spilled than had been reported.
• Remedial action within the RRZ could not be completed until the dry season, many months after the incident. During this period, ERA took appropriate action, with the NT Minister's approval, to ensure protection of water quality.
• The tailings spill was not responsible for the increase in uranium in RP2.

Discharge of water from the Restricted Release Zone into a tributary of Gulungul Creek

It was alleged that ERA routinely discharged from the RRZ water containing high concentrations of uranium from the southern external walls of the tailings dam into the headwaters of Gulungul Creek, that the ERA Laboratory Manager refused permission for an investigation of the effects of this discharge, and that he instructed the former employee not to record a higher than normal result for uranium in Gulungul Creek waters. It was claimed that this result was obtained from two separate samples, each of which was analysed in triplicate.

The investigation concluded that:

• ERA did not discharge RRZ or tailings water from the mine to the external environment but acted properly in accordance with the requirements of the NT Minister for Resource Development with respect to water shedding from the outside walls of the tailings dam and the area south of the dam.
• ERA did conduct an investigation of the likely impact of these discharges on the water quality of Gulungul Creek and the results indicated that the uncontrolled discharge of these waters did not pose a threat to the creek. The former employee, being unaware of this study, conducted a second separate study but appears not to have informed his manager of the results obtained.
• The ERA laboratory records only reveal the analysis of a single sample for uranium from the Gulungul Creek monitoring point on the date in question. This sample was not subject to triplicate analyses but was subject to three sequential analyses to obtain a reliable result.
• The ERA Laboratory Manager was on leave at the relevant time and could not have given the instruction at that time that the result not be recorded or that the proposed investigation should not proceed.
• The uranium concentration currently entered in the ERA water quality data base for the Gulungul Creek sample in question is 0.1 µg/L not 7.4 µg/L as measured by the former employee. However, the database contained the latter result in February 1997, one month after the analysis was obtained indicating that the result has been changed. ERA procedures should have required a reanalysis of the sample prior to a change of result in the data base but we have found no evidence of such a reanalysis.
• Examination of the ERA data base indicates that ERA's policy of not deleting unusual results until a reanalysis has been carried out has normally been adhered to by the company and its employees.

Procedures in ERA's Environmental Laboratory

A number of issues related to the performance of ERA's chemical analysis laboratory were also raised. Specifically, it was claimed that laboratory management consistently refused to address technical issues that compromised the performance of the laboratory, that this led to an inability to honour the conditions of its licence to operate the mine, and that ERA did not rectify problems even when it was demonstrated that the problems were valid.

The investigation of these laboratory related issues was, to some extent, superficial in that it relied heavily upon the assessment of ERA's performance in these areas by the appropriate authority, the National Association of Testing Authorities (NATA).

The investigation concluded that:

• There is no doubt that many of the deficiencies identified by the former employee were present and that corrective action was needed.
• It appears that, in the cases described by the former employee, a dispute arose between him and the Laboratory Manager on what would constitute the best way to overcome the problems. The former employee clearly did not accept the conclusions of his manager, then or now.
• The analytical issues identified did not lead to the lack of detection of environmental detriment although, if fully correct, they may have led to inconsistent or incorrect analyses. There is, however, no evidence that ERA adopted a policy towards its analytical laboratory that would have undermined its environmental protection responsibilities or compromised its reporting responsibilities.
• ERA, in accordance with the Environmental Requirements, maintained a NATA registered laboratory. Following NATA inspections and recommendations, ERA responded to NATA providing details on steps taken to implement the recommendations.

Overall Conclusion and Recommendations

The overall conclusion of the investigation was that, apart from the previously reported breach of the Ranger Authorisation arising from the spillage of tailings outside the Restricted Release Zone on 19 December 1997, no evidence was found that ERA had operated otherwise than in accordance with its Authorisation and the Commonwealth's Environmental Requirements.

The report recommended that the Ranger Minesite Technical Committee:

1. Should, in its current review of the Ranger monitoring programme, assess the need for load estimation in the chemical monitoring of the Ranger mine, taking into account existing biological monitoring programmes.
2. Should consider, within the context of Best Practicable Technology, whether or not uncontrolled discharges of water from the region south of the tailings dam to the Gulungul Creek system should continue.

Implementation

The recommendations of the report were fully implemented. The MTC considered the need for load estimation in its review of the Ranger monitoring programme. It concluded that load estimation was not required in order to draw sound conclusions regarding the extent to which the environment was protected from the potential impacts of mine derived contaminants in waters. The biological monitoring programme, which integrates the effects of all stressors, provides the best data from which to make such assessments. However, load estimation was considered to be useful in the context of understanding the behaviour of the Ranger Water Management System, and in optimising that system.

As a precautionary measure, ERA pumped water from the region south of the tailings dam back to the tailings dam during the 2002-03 wet season whilst the MTC considered whether uncontrolled discharges from this area should be permitted. The conclusion reached by the MTC was that uncontrolled discharges from this area posed a negligible risk to the environment, and as such, would be permitted.

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