FRIENDS OF THE EARTH AUSTRALIA SUBMISSION IN RESPONSE TO ALLIGATOR ENERGY’S APPLICATION FOR A RETENTION LEASE OVER THE BLACKBUSH DEPOSIT (SAMPHIRE URANIUM PROJECT)
To: Mining Regulation Branch
SA Department for Energy and Mining
September 2023
LIST OF RECOMMENDATIONS
- The SA Department for Energy and Mining should reject Alligator Energy’s application to conduct a Field Recovery Trial at the Samphire lease due to inadequate provisions for solid and liquid waste management.
- Alligator Energy should be required to lodge a financial bond with the SA government to ensure that adequate financing is available for rehabilitation if the Field Recovery Trial proceeds.
- The Field Recovery Trial should not be approved because Alligator Energy has no credible plan for disposal of solid low-level radioactive waste.
- The Department for Energy and Mining should consider promises vs. delivery at the Beverley and Honeymoon mines. Undoubtedly spills were far more frequent and voluminous than envisaged. At a minimum, Alligator Energy should be required to have a credible plan to manage radioactive liquid spills far in excess of one cubic metre.
- There may be technical or logistical reasons why Heathgate may reject the offer of eluate and Alligator should be required to come up with credible contingency plans for eluate disposal before a Field Recovery Trial is allowed to proceed.
- The Department for Energy and Mining should investigate issues raised by the Heathgate whistleblower and its implications for other mining projects including the proposed Field Recovery Trial at the Samphire lease.
- The Department for Energy and Mining should conduct or commission a thorough comparative assessment of the options for managing liquid waste rather than assuming that dumping contaminated liquid waste in groundwater is an adequate solution.
INTRODUCTION
Friends of the Earth Australia opposes uranium mining for various reasons including the weapons proliferation risks associated with the industry, and the intractable problem of high-level nuclear waste management. Those issues are beyond the scope of the SA Department for Energy and Mining’s consideration of the Samphire project application. Nevertheless we call on the Department to reject Alligator Energy’s application to conduct a Field Recovery Trial at the Samphire lease due to inadequate provisions for solid and liquid waste management.
It is more than likely that the Samphire mine will not proceed to commercial production due to:
- The modest size of the uranium deposit (18.1Mlbs U3O8 at a 250ppm cut-off grade (combined Inferred and Indicated) from 11.4Mt @ 720ppm U3O8).[1]
- Stubbornly low uranium prices over the past decade, notwithstanding a price increase in 2023 which may or may not be sustained.[2]
- Near-zero prospects for significant worldwide uranium demand increase.[3]
- The largest worldwide producers ‒ Cameco and Kazatomprom ‒ have put large uranium mine projects into care-and-maintenance in recent years and the re-entry of those large projects will put downward pressure on prices and severely limit the prospects for small start-ups such as Alligator Energy.
- Alligator Energy notes that the company plans “to undertake a Feasibility Study in 2024, with all activity requiring further State and Federal Government approvals, and the securing of project financing amongst other key matters, before a mine could be developed.”
The Samphire project was abandoned a decade ago and will likely be abandoned again. This highlights the need for full rehabilitation of the site if approval is granted for a Field Recovery Trial.
Recommendation: Alligator Energy should be required to lodge a financial bond with the SA government to ensure that adequate financing is available for rehabilitation if the Field Recovery Trial proceeds.
SOLID WASTE
A 2003 SA government audit of radioactive wastes stated that the Radium Hill waste repository contains some contaminated equipment from test work conducted at the Honeymoon site in the early 1980s.[4] The same audit noted that the Radium Hill waste repository “is not engineered to a standard consistent with current internationally accepted practice.”
Dumping contaminated solid waste at the sub-standard repository at Radium Hill is not an option for Alligator Energy. What plans does Alligator Energy have for the disposal of solid wastes contaminated with radionuclides and other toxins?
Alligator Energy’s Retention Lease Proposal states that low-level radioactive waste generated during the Field Recovery Trial will include:
“Soil wastes generated within operational areas that have been in contact with process fluids or material from the mineralised zone, are waste streams derived from processing, and/or are waste materials that do not meet specified radiological clearance limits.”
The Retention Lease Proposal also provides the following information on solid low-level radioactive wastes:
The Retention Lease Proposal goes on to state:
“Low level radioactive wastes will be securely stored on site during the leach trials in compliance with the Radiation Protection and Control Act 2021 and associated regulations the specific requirements that will be detailed in the site Radiation Management Plan and Radioactive Waste Management Plan (RMP/RWMP).”
The Retention Lease Proposal envisages disposal in a “licensed disposal facility”. To the best of our knowledge, SA does not have a “licensed disposal facility” for low-level radioactive waste, in which case Alligator Energy has no credible plan for disposal of low-level radioactive waste.
Recommendation: The Field Recovery Trial should not be approved because Alligator Energy has no credible plan for disposal of solid low-level radioactive waste.
RADIOACTIVE LIQUID SPILLS
A feature of ISL mining is surface contamination from spills and leaks of radioactive solutions. The SA Department of Primary Industry and Resources listed 59 spills at Beverley from 1998-2007 and presumably there have been many more since 2007.
Alligator Energy’s Retention Lease Proposal states that spills of low-level radioactive liquid waste are anticipated to amount to no more than one cubic metre. It further states: “All low-level radioactive waste streams will be transferred to the liquid waste storage vessel, then directed to the liquid disposal zone where disposal will occur.”
Recommendation: The Department for Energy and Mining should consider promises vs. delivery at Beverley and Honeymoon. Undoubtedly spills were far more frequent and voluminous than envisaged. At a minimum, Alligator Energy should be required to have a credible plan to manage radioactive liquid spills far in excess of one cubic metre.
LIQUID WASTE AND ATTENUATION
Alligator Energy’s Retention Lease Proposal states that eluate (containing ~6000lbs of dissolved uranium) from the ion exchange stripping process will be the end product and will be stored in tanks onsite. Alligator proposes retaining the stored eluate for approximately one year post the end of the Field Recovery Trial to allow sufficient time for a formal decision on whether or not to proceed to a full-scale mining operation with the two options cited being: eluate retained onsite for future Alligator Energy production or donated for precipitation at one of SA’s producing ISR mines.
Recommendation: There may be technical or logistical reasons why Heathgate may reject the offer of eluate and Alligator should be required to come up with credible contingency plans before a Field Recovery Trial is allowed to proceed. Alligator talks about plural in-situ recovery (ISR) mines although it surely knows that only Beverley is operating.
Alligator Energy’s Retention Lease Proposal states:
“If field natural attenuation monitoring cannot be verified within 5 years, a reassessment of the model against field parameters will be undertaken and model rerun (if required). Natural attenuation monitoring for model verification will be undertaken until model validation is accepted by relevant regulatory agencies. In the event, model validation cannot be achieved, Alligator will undertake active groundwater restoration methods such as groundwater flush or sweep.”
Further detail is required on groundwater restoration options. The Retention Lease Proposal is unacceptably vague.
Alligator Energy will have precious little interest in groundwater restoration if a decision is made not to proceed to commercial mining. The company may not have the resources for groundwater restoration. The company may not even exist in five years’ time. All this points to the need for a financial bond to be lodged with the SA government to ensure that adequate resources are available for full site rehabilitation including groundwater restoration.
BEVERLEY/HEATHGATE WHISTLEBLOWER
A former Heathgate worker contacted Friends of the Earth in 2022 and provided the following information:
* Heathgate breaks every rule in the book and Beverley may be the worst-run mine in SA.
* Regulation is deficient in many respects within and between the SA EPA, Safe Work SA and SA Water.
* Heathgate should have been hit with one or more $30,000 fines by Safe Work SA but Safe Work SA has been negligent.
* Gross mismanagement by Heathgate has led to high staff turn-over ‒ in particular with respect to staff responsible for worker safety.
* Lids have come off uranium drums at the Beverley plant and also on one or more ships transporting uranium to the USA. The handling of uranium spillages at Beverley has grossly violated safety protocols.
* Problems arising from a revolving door between regulators and Heathgate.
* Heathgate isn’t prepared to spend the money required to fix problems at Beverley, and there is little or no pressure from regulators.
* Problems with radioactive monitoring badges, e.g. not replaced if lost.
* Culture of acceptance of safety lapses, anyone speaking up may be fired. NDAs are part of the problem.
Clearly the concerns raised by the former Heathgate employee raise concerns regarding other mines including the Samphire proposal, in particular whether regulatory deficiencies will have adverse consequences.
Have there been ICAC and/or Office of Public Integrity investigations into aspects of Heathgate’s operations at Beverley? If so, what lessons if any were learned and how is that knowledge impacting assessment of other projects including Alligator Energy’s Samphire project?
Recommendation: The Department for Energy and Mining should investigate issues raised by the Heathgate whistleblower and its implications for other mining projects including the proposed Field Recovery Trial at the Samphire lease.
HISTORY OF IN-SITU LEACH URANIUM MINING
In-situ leach (ISL) uranium mining involves pumping an acid solution (or an alkaline solution in some cases) into an aquifer. This dissolves the uranium ore and other heavy metals and the solution is then pumped back to the surface. The small amount of uranium is separated at the surface. The liquid radioactive waste – containing radioactive particles, heavy metals and acid – is simply dumped in groundwater.
A 2004 CSIRO report states:[5]
“As stated in the Beverley Assessment Report, the bleed solutions, waste solutions from uranium recovery, plant washdown waters and bleed streams from the reverse osmosis plants are collected prior to disposal into the Namba aquifer via disposal wells. These liquid wastes are combined and concentrated in holding/evaporation ponds, with excess injected into selected locations within the mined aquifer. The injected liquid is acidic (pH 1.8 to 2.8) and contains heavy metals and radionuclides originating from the orebody.
From being inert and immobile in the ore body, the radionuclides and heavy metals are now mobile in the aquifer.
The 2004 CSIRO report endorsed the dumping of liquid waste in ground-water yet the information and arguments it used in support of that conclusion were tenuous. The CSIRO report notes that attenuation is “not yet proven” and the timeframe of “several years to decades” could hardly be more vague. The 2004 CSIRO report states in its Executive Summary:
“The use of acid rather than alkaline leaching and disposal of liquid wastes by re-injection into the aquifer is contentious. Available data indicate that both the leach solution and liquid waste have greater concentrations of soluble ions than does the pre-mining groundwater. However as this groundwater has no apparent beneficial use other than by the mining industry, this method of disposal is preferable to surface disposal. Although not yet proven, it is widely believed and accepted that natural attenuation will result in the contaminated water chemistry returning to pre-mining conditions within a timeframe of over several years to decades.”
Elsewhere the 2004 CSIRO report notes uncertainties associated with attenuation:
“The EIA for Beverley and Honeymoon suggest that natural attenuation will occur, however, exact timeframes are not given. The issue of predicting attenuation is made more complex by not fully understanding the microbiological or the mineralogy of the surrounding ore bodies, before and after mining, and how these natural conditions will react with the altered water quality introduced by the injection of leachate, and re-injection of wastewaters. Following general practice, geochemical modelling was undertaken with a series of assumptions where data were not available. Although these assumptions are considered reasonable by the review team, some technical experts have a differing opinion. In any case the results must be considered approximate.
The monitoring results from Beverley are limited by the short duration of mining and operation, and there are currently no completely mined-out areas for which the water chemistry can be followed after mining to verify the extent of the expected natural attenuation. However, pH results for an area that was trial-mined in 1998 and then left until full-scale mining of the same area was due are shown in Figure 13.
Note that whilst other data are available for these wells there are not consistent trends in other analytes. There has been little recovery of groundwater chemistry towards background in the test-production wells other than a favourable change for pH. There are presently no equivalent monitoring data for the northern area, which is presently being mined.”
Even if full attenuation does occur over time, it is unlikely to occur in the timeframe of post-mine-closure monitoring proposed by the mining proponent. The 7/1/09 Beverley Four Mile Project Public Environment – Report and Mining Lease Proposal document states:
“Heathgate proposes an initial period of five years from the conclusion of commercial operations to complete the decommissioning of facilities. A monitoring and maintenance program is proposed to run for a further two years, for a total of seven years from the final conclusion of mining activities. The total monitoring period will be reviewed with the regulatory authorities and may be extended.
“Facilities will therefore be fully decommissioned within seven years from the conclusion of the commercial operation. This period includes a post-completion monitoring period for vegetation maintenance, groundwater sampling, drainage repairs and other activities to ensure the long-term permanent rehabilitation of the site.
The 2004 CSIRO report states:
“Natural attenuation is preferred to adjusting the chemistry of the wastewater prior to re-injection as the latter would result in the need for additional chemicals on-site, generation of contaminated neutralisation sludges which would have to be disposed of, risk of potential clogging of pore spaces in the aquifer and associated higher costs.
Those are not insurmountable problems. Moreover there are alternatives to adjusting the chemistry of waste-water then reinjecting it into the aquifer, such as evaporation followed by management of solid wastes. As the CSIRO report notes:
“10.6 Alternatives to Liquid Waste Re-Injection
“Suggestions made during the community consultation process included not re-injecting the liquid wastes into the aquifer, and neutralisation of waste before re-injection.
“Not re-injecting the waste into the aquifer would require either sophisticated water treatment and/or the installation of much larger evaporation ponds. Both would generate solid wastes to be disposed of in a solid waste repository. When the wastes dried out they would become a possible dust source, which could increase the potential radiation exposure of workers, in particular in relation to dust inhalation, but also from radon inhalation and gamma exposure. Environmental radiation levels at the surface would also increase. These are presently negligible issues associated with the existing ISL practices.
“Neutralisation of the waste liquid prior to re-injection would precipitate out some metal salts, which would need to be filtered before re-injection, and be disposed of in a solid waste repository.
“Also following re-injection it is likely that the re-injection bores would rapidly clog owing to precipitation around the bores, as the injected water and existing acidic water in the aquifer interact. Clogging of re-injection wellfields and associated problems with pipelines and pumps may increase the risk of spills due to operational problems with equipment and increased maintenance.”
None of the issues raised by the CSIRO amount to compelling reasons to support dumping liquid waste in groundwater. Some of the reasons cited are absurd and cast serious doubt over the credibility of the CSIRO review ‒ for example dust suppression is simple and inexpensive.
Recommendation: The SA Department for Energy and Mining should conduct or commission a thorough comparative assessment of the options for managing liquid waste rather than assuming that dumping contaminated liquid waste in groundwater is an adequate solution.
The 2003 Senate References and Legislation Committee report into the regulation of uranium mining in Australia reported “a pattern of under-performance and non-compliance”, it identified “many gaps in knowledge and found an absence of reliable data on which to measure the extent of contamination or its impact on the environment”, and it concluded that changes were necessary “in order to protect the environment and its inhabitants from serious or irreversible damage”. On ISL mining, the 2003 Senate report stated:
“The Committee is concerned that the ISL process, which is still in its experimental state and introduced in the face of considerable public opposition, was permitted prior to conclusive evidence being available on its safety and environmental impacts.”
“The Committee recommends that, owing to the experimental nature and the level of public opposition, the ISL mining technique should not be permitted until more conclusive evidence can be presented on its safety and environmental impacts.”
“Failing that, the Committee recommends that at the very least, mines utilising the ISL technique should be subject to strict regulation, including prohibition of discharge of radioactive liquid mine waste to groundwater, and ongoing, regular independent monitoring to ensure environmental impacts are minimised.”
In relation to the Beverley mine, Assoc. Prof. Gavin Mudd notes: “The critical data which could answer scientific questions concerning contaminant mobility in groundwater has never been released by General Atomics. This is especially important since GA no longer maintain the mine is ‘isolated’ from surrounding groundwater, with desires to expand the mine raising legitimate concerns over the groundwater contamination legacy left at Beverley.”
Assoc. Prof. Mudd states:
The mining technique of in situ leaching (ISL), often referred to as solution mining, is becoming an increasingly favoured method for the extraction of uranium across the world. This is primarily due to its low capital and operating costs compared to conventional mining. Little is known about the environmental impact of this method, and mining companies have been able to exploit this to promote the method as “environmentally benign”.
The ISL process involves drilling ground water bores or wells into a uranium deposit, injecting corrosive chemicals to dissolve the uranium within the ore zone, then pumping back the uranium-laden solution.
The method can be applied only to uranium deposits located within a ground water system or confined aquifer, commonly in palaeochannel deposits (old buried river beds).
Although ISL is presented in simplified diagrams by the nuclear industry, the reality is that geological systems are inherently complex and not predictable.
There are a range of options for the chemistry of the mining solutions. Either acidic or alkaline chemical agents can be used in conjunction with an oxidising agent to dissolve the uranium.
Typical oxidising agents include oxygen or hydrogen peroxide, while alkaline agents include ammonia or sodium-bicarbonate or carbon dioxide. The most common acidic chemical used is sulphuric acid, although nitric acid has been tried at select sites and in laboratory tests.
The chemicals can have potentially serious environmental impacts and cause long-term changes to ground water quality.
The use of acidic solutions mobilises high levels of heavy metals, such as cadmium, strontium, lead and chromium. Alkaline solutions tend to mobilise only a few heavy metals such as selenium and molybdenum. The ability to restore the ground water to its pre-mining quality is, arguably, easier at sites that have used alkaline solution chemistry.
A review of the available literature on ISL mines across the world can easily counter the myths promulgated about ISL uranium mining. Whether one examines the USA, Germany, Russia and associated states, Bulgaria, the Czech Republic, Australia or new ISL projects across Asia, the truth remains the same – the ISL technique merely treats ground water as a sacrifice zone and the problem remains “out of sight, out of mind”.
ISL uranium mining is not controllable, is inherently unsafe and is unlikely to meet “strict environmental controls”. It is not an environmentally benign method of uranium mining.
The use of sulphuric acid solutions at ISL mines across Eastern Europe, as well as a callous disregard for sensible environmental management, has led to many seriously contaminated sites.
Perhaps the most severe example is Straz pod Ralskem in the Czech Republic, where up to 200 billion litres of ground water is contaminated. Restoration of the site is expected to take several decades or even centuries.
Solution escapes and difficult restorations have been documented at ISL sites in Texas and Wyoming.
Australia has encountered the same difficulties, especially at the controversial Honeymoon deposit in South Australia during pilot studies in the early 1980s and at Manyingee in Western Australia until 1985.
The Honeymoon pilot project used sulphuric acid in conjunction with ferric sulphate as the oxidising agent. The wells and aquifer experienced significant blockages due to the minerals jarosite and gypsum precipitating, lowering the efficiency of the leaching process and leading to increased excursions. The aquifers in the vicinity of Honeymoon are known to be connected to aquifers used by local pastoralists to water stock.
Journal articles, conferences papers etc. on ISL mining (and other issues) by Assoc. Prof. Mudd are available online.[6]
A 2007 Friends of the Earth Adelaide report noted:[7]
Field trials” of acid in-situ leach (acid ISL) uranium mining have already occurred at the Beverley uranium mine and the proposed Honeymoon site in north-eastern South Australia. Given the history of leaks and spills that occurred at Honeymoon and Beverley during their “trial” phases, there is significant cause for concern around further such “trials”. Six spills were recorded at the Honeymoon trial mine in 1999, including one “excursion” of 9,600 litres of “process fluid”, which had a significant uranium and toxic radon gas content, and another in which sulphuric acid injected into the groundwater as part of the mine process unexpectedly traveled upwards, contaminating a higher aquifer. None of these spills were revealed to the public until after the project had been granted state and federal approvals.
During the trial at Beverley through 1998, 500 litres of extraction fluid were spilt, the accident not revealed until 5 months after it occurred. Beverley also experienced a major underground leak of radioactive mining solution to groundwater in 1999, also not confirmed until after state government approvals in 2001.
While one purpose of conducting a “trial” may be to determine the extent and nature of a groundwater system, the injection of acid and radioactive mine waste into aquifers is not an acceptable way of doing this. The South Australian community has a democratic right to participate in decision-making regarding activities with significant environmental impact such as mining. The history of leaks, spills and accidents that characterise ISL mining emphasise the urgent need for full environmental assessment to be conducted before the commencement of any mining, “trial” or otherwise.
The 2007 Friends of the Earth Adelaide report also pointed to severe problems with ISL mining overseas:[8]
Both acid and alkaline ISL mines across the world have left a track record of contamination of surrounding groundwater systems, some of which are the main water supply for communities, with attempts to rehabilitate the groundwater often unsuccessful. Some of the European cases include:
- Königstein (Germany): as of 2005, there was still 1,900 million m3 of radioactive and heavy metals contaminated water within the mining zone. This pollution lies within an aquifer that supplies Dresden with drinking water;
- Devladovo (Ukraine): the surface of the site was heavily contaminated from spills, and groundwater contamination is spreading downstream from the site at a speed of 53m per year. By 1995 it had already traveled a distance of 1.7km, and will reach the village of Devladovo in the next 12 years;
- Bolyarovo, Tenevo/Okop, Haskovo(Bulgaria): very high concentrations of sulfate ions are found in surface water and in the wells of private owners as a result of accidental spilling of solution. All uranium mining and milling in Bulgaria was closed down by government decree in 1992, after over 20km2 of the country was contaminated by uranium industry activity.
The contamination at these and many other sites, including the high concentrations of major ions, heavy metals and radionuclides, has not attenuated significantly over time (as uranium mining companies claim), and instead often migrates through groundwater to pollute other areas.
US geochemist and environmental scientist Richard Abitz comments on his own experience attempting to rehabilitate groundwater at ISL uranium mines in Ohio, Texas and Wyoming. When the mining chemicals are injected into groundwater, he observes, uranium contamination “goes through the roof”. “Once it is in there, the damage has been done”, he says. “It takes hundreds, perhaps thousands of years to transform aquifer water back into a drinkable condition”, and “regardless of the millions of dollars and years of efforts, the water has never been restored.”
Australia’s own problematic experience with ISL uranium mining (limited to the Beverley mine, and the Honeymoon and Manyingee, WA, “trials”), combined with the experience of ISL overseas emphasise the serious risks and impacts of this mining method. That such mining should be permitted in South Australia on a “trial” basis, without environmental impact or public consultation is a grave concern that demands legislative amendment.
[1] Alligator Energy, 2023 Retention Lease Proposal, Executive Summary
[2] https://www.cameco.com/invest/markets/uranium-price
[3] https://reneweconomy.com.au/is-nuclear-power-in-a-global-death-spiral/
[4] Radiation Protection Division, SA Environment Protection Authority, September 2003, ‘Audit of Radioactive Material in South Australia’
[5] Taylor, G.; Farrington, V.; Woods, P.; Ring, R.; Molloy, R. (2004): Review of Environmental Impacts of the Acid In-Situ Leach Uranium Mining Process.- CSIRO Land and Water Client Report.
[6] http://web.archive.org/web/20100228164521/http://civil.eng.monash.edu.au/about/staff/muddpersonal More recent ISL papers can be obtained directly from Assoc. Prof. Mudd: https://www.rmit.edu.au/contact/staff-contacts/academic-staff/m/mudd-dr-gavin
[7] Friends of the Earth Adelaide, November 2007, Driving without a license: uranium mining ‘trials’ in SA, http://archive.foe.org.au/sites/default/files/TrialBriefNov2007.pdf
[8] Friends of the Earth Adelaide, November 2007, Driving without a license: uranium mining ‘trials’ in SA, http://archive.foe.org.au/sites/default/files/TrialBriefNov2007.pdf