Dubbo Project (formerly known as the Dubbo Zirconia Mine)

I object to the proposed mine on the grounds of the toxic pollution output, the radiation, the use of our scarce river water and the pollution that will be left when the company leaves

I don't approve of this mine due to the amount of pollutants that will be emitted from it - especially the radioactive pollutants. I live within earshot of the mine and I would not like it if me or my neighbours got covered in the fallout of the mining process

This is my submission as a pdf file.

https://www.dropbox.com/s/t5kczpgd5vplf5s/Zirconium%20mine%20comment%20Wayne%20Connor.pdf

Here it is as text...




In response to the public exhibition regarding the zirconium mine I'd like to make the following submission.


Dubbo is a thriving and dynamic regional centre that prides itself on quality of life as well as being a centre for leisure, education and business. We advertise 'time to smile' and offer a 'tree-change' to people from larger cities. We even market ourselves as a clean city, less pollution, less noise, less traffic and a better quality of life. (dubbotourism.com.au).

We also welcome business and development, but this needs to be weighed up with negative effects on health and lifestyle. The proposed Zirconium development will bring jobs and income to Dubbo, but this needs to be done in a way that will not disadvantage some residents of our city, especially those who live near the mine, use areas such as Toongi Hall, or live downwind of the mine. I want to address the issue of air pollution as part of the reason I live in Dubbo as opposed to a capital city is because of fresh air.

Despite the claims of the EIS that the mine's emissions will be within the EPA levels, I am personally concerned that these levels are still too high, especially given recent research such as the August 2013 Senate enquiry on "Impacts of air quality in Australia" which specifically targets dust emissions from mining. It shows adverse health impacts arise from much lower rates of dust and pollution than was previously thought.

My concern is simply this: the project as it stands will emit the MAXIMUM emissions possible under the EPA guidelines, but given recent developments in our understanding of dust and pollution that have not yet been incorporated into EPA guidelines, the mine should reduce its pollutants to the MINIMUM that is possible with today's technology.

In other words the mine should place public health (minimum emissions possible) above profit (maximum emissions allowed by EPA). I am not an expert at all in the mining industry, yet by reading just 3 papers: the EIS, the Senate enquiry, and a paper entitled ''International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining Prepared for NSW Office of Environment and Heritage June 2011' even I can see simple areas that mining dust could be reduced.

The EIS on public display compares the potential mine emissions withthe allowed EPA emission levels for various pollutants (eg SO2, NO2, dust particle levels etc). With those Emissions that exceed the regulations various mitigating factors are applied after which it is found that the mine will be within EPA guidelines (mostly). Those areas where the EPA guidelines are exceeded can be purchased by the mine and can be considered as part of the development itself and so need not be within EPA guidelines.

This all sounds fine but the entire process is about operating at the maximum allowed pollution levels, not about minimising pollution as far as possible. We know of cities around Australia where industries are producing dust and pollutants within EPA guidelines yet the air in not clean. Recently there has been increased concern about such pollution.




Given the excellent air quality of Dubbo, and the problems that are emerging after years of mining in areas like the Hunter Valley, it would be prudent to aim for lower emissions than the current proposal. It will be of no benefit to the people of Dubbo if we discover in 10 years that the mine is making people sick. If fact, given the information described in the recent senate paper, it is an OBLIGATION for the sake of public health that the mine aims for the MINIMUM emissions possible, not just the MAXIMUM emissions that fit within EPA Guidelines.


HEALTH AND AIR QUALITY

In August this year the Senate Community Affairs References Committee released it's paper entitled 'Impacts on health of air quality in Australia' where it claims the EPA guidelines need to be revisited in light of recent research. Recent research shows that there are negative health impacts of even small quantities of dust and other pollutants at levels much lower than was previously thought.

"Of importance is that the new evidence not only supports the previous scientific conclusions but also indicates that the effect can occur at air pollution concentrations lower than those used to establish the existing WHO health guidelines, particularly into relation to PM 2.5 and PM 10. So far no limit of exposure where there is no impact has been identified." (Ibid 2.20, p 9)


The senate paper says that there are definite links with dust and health: "Recent research has identified a strong link between PM2.5 and life expectancy." (Impacts on health of air quality in Australia , August 2013, 2.1.6 P8)

Moreover, this health impact has a measurable associated cost to it. "PM2.5 is believed to be the most health-hazardous air pollutant... The estimated health cost of a kg of PM2.5 emissions in Sydney is more than $235.23" (ibid 2.1.7, p8)


REDUCING EMISSIONS

Therefore it is not just a matter of getting below a certain EPA level and then stopping. Any further decreases below EPA guidelines are advantageous. This is particularly the case with Nitrous Oxide which is a significant output from the Toongi mine. "Available evidence suggests that, at least for particulates and for NO2, there is a linear dose response relationship over a large range of exposure levels. This means that, even at levels below the current targets, further health gains can be achieved by further reduction in pollutant levels. (Ibid 2.21, p9).

It is known that Nitrous Oxide and other pollutants at causing damage at much lower levels that were previously thought. "...epidemiology studies are now indicating there is no clear threshold for effect for the current NEPM pollutants, with exposures below the standards still representing a statistically significant and measurable health risk to the Australia population." (Ibid 3.22 p20).



Given this knowledge we have of the damaging effects of NO2, other gasses, and PM2.5 particles, even at very low levels, the mine should aim to reduce the pollution levels as much as is possible. There should be a further reduction in dust,and there should be zero emissions of pollutants such as NO2 and SO2 where possible.

By acting responsibly in this way the zirconium mine can lead the way in clean mining and thus enhance our economy but allow Dubbo to stay clean. The mine is predicting to bring in revenue of $500,000,000 per year (10 billion dollars total over 20 years). A greater portion of this revenue must be used to make the mine a clean mine that brings jobs to Dubbo without making Dubbo a dirty city.


Given the above information, the mine should:

Implement measures to SIGNIFICANTLY reduce the levels of dust to the minimum possible amounts by using Best Mining practices. ("NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining" 2011).
Where current technology allows, use scrubbers and/or other technology on all emissions to reduce the levels of SOx and NOx, Hcl, Radon and any other pollutants from the mineral processing to be zero.
Have zero SO2 emissions from Sulphuric acid plant - 100% Overall Sulphur Recovery - by recycling SO2 to a sulphur recovery unit. Why are we even considering SO2 emission levels when zero SO2 emissions is possible?
Identify major sources of NO2 and reduce these to zero where possible.



DUST MINIMISATION

The current mining plan and EIS does not aim for minimum emissions, it simply aims for emissions below EPA levels. "Whilst it is likely that the AZL would increase dust levels in the surrounding community to some degree, the controls and safeguards to be adopted would be designed to ensure that the levels of dust produced would satisfy all relevant amenity and health criteria." (P79)


Section 9.2.2 goes on to describe some ways in which this will be done with regards to dust.

"9.2.2 Onsite dust mitigation strategies have been included in estimating the emissions and include:
- adopting a Level 2 watering to achieve 75% control of dust from haul roads;
- water injection during drilling of ore and overburden;
- the stockpiling of material is watered to maintain a relatively high moisture content for the prevention of wind erosion;
- the use of water curtains at all crushers and miscellaneous transfer points; and
- the implementation of a bag house at the grinding mill." (EIS section 9.2.2)

This sounds good, but a lot more can be done to reduce dust. In fact these measures described are significantly LESS than those described in the document 'International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining Prepared for NSW Office of Environment and Heritage, June 2011'.

Given that ANY further reduction in dust below the levels described in the EPA will have a positive impact on health, and given that there are better known dust reduction strategies, it is imperative that every dust mitigation strategy that is known in the industry be applied as rigorously as it can be, with an aim to reduce the major dust emissions - wind erosion and haulage - at least ten fold.

This may include but not be limited to:

- covering of stockpiles (not just watering).
- veneering of stockpile.
- non use of front end loaders to move mined material.
- schedules for grading and gravelling of roads
- in addition to level 2 watering of unsealed roads (described in the report) the following:
- speed limits on vehicles to 30 km/hr on site (up to 85% reduction in dust on haul roads).
- grader speed limits of 8km hr. (emission factors for graders suggest a 75% dust reduction from 16 km/hr to 8 km/hr).
- using conveyers where possible instead of haul roads (reduction of dust by 95%).
- paving of roads where possible (reduction of dust by over 90%).
- all loading and unloading to be done in sheds.
- sprays that water more in high wind conditions.
- planting of large trees for windbreaks.
(See "Best Practices" p165).
These measures need to be documented and made part of the approval conditions.

OTHER COMMENTS

TOXIC SALT WASTE
Dispose of Toxic Salt Waste. 44 Truckloads of salt will be delivered to the mine each week. This salt will be used and the resulting salt will be slightly radioactive (classified as restricted solid waste). The mine operators have decided it it too expensive to dispose of this toxic salt (it will cost $33 million per year) so they are going to leave it behind! (6.1.5) The proposal is to bury 6.7 million tonnes of toxic salt in plastic and leave it there, hoping it won't leak into the groundwater. This is absurd. The cost of disposal of the salt should be factored into the development and he waste should be disposed of not left behind.

DUBBO CITY ENVIRONMENTAL SPONSORSHIP
Carbon offset payments. I understand that CO2 emissions from the mine will be offset by payments into a carbon offset/tax scheme. This pollutes Dubbo without benefiting Dubbo. I would like to see a scheme where an extra amount above the government rate (eg equivalent of 10% of the yearly co2 tax) is put directly into Dubbo to be used for environmental purchases and maintenance of parks, river care.

PUBLISHING OF RESULTS
According to the senate paper public understanding of health risks are almost as important as the health risks themselves. The results of air quality monitoring, and water monitoring bores (EIS 2.9.2.7), and radioactive dust results (4.4.9) should be publicly available on a website as close to real time as possible.

PUBLISHING OF EXCEEDENCES
There should be a requirement for timely reporting of all exceedances with the public release of these events within 3 months of the event. (Recommendation of senate paper section 3.13)


IDLING TRUCKS

An example of one of the mitigation strategies described in the EIS is this.

"4.3.6.5 Greenhouse Gas...
-Dedicate a number of trucks for the excavator to minimise truck idling times.
-Ensure that haul trucks are fully loaded to maximise productivity and efficiency." (EIS 4-64)

So, they are not having excess trucks for the excavator. So what! Basic economics and efficiency would say that you do not have more trucks than you need. They should not be passing this off as a CO2 reduction technique.

According to the senate paper, onsite anti-idling rules would help here so that trucks must turn their engines off if they are to idle for more than 5 minutes. Also The NSW EPA reports that 'retrofitting existing diesel vehicles with exhaust treatment devices is a cost-effective strategy to reduce air pollution emissions', and reported that they are currently working to with private enterprise and other stakeholders to retrofit fleet vehicles. (Senate paper 5.10).

With such a large truck fleet in operation it would be prudent to investigate NO2 exhaust treatment devices and onsite idling guidelines.


TOONGI HALL

"Figure 4.19 illustrates that R12 (Toongi Hall) is likely to be the most affected by PM10 emissions of the Proposal. 3)" (EIS 4.3.7.4)

"R12 (Toongi Hall), located to the west of the DZP Site, is predicted to be the most greatly impacted Non-Proposal related residence for all of the SO2 averaging periods for both the incremental and cumulative results."(4.3.7.5)

The analysis goes on to say "Figure 4.19 also indicates that each of the assessed receptors would be subject to an exceedance of the cumulative PM10 24-hour criterion on 2 days. However, given the background data set already contains two exceedances of the EPA 24-hour criterion, the Proposal is not anticipated to contribute to any additional exceedances. On this basis, the Proposal is anticipated to satisfy the EPA criterion (PEL, 2013)."

This is wonderful: how a logarithmic graph and some fancy mathematics can reduce tonnes of emmissions to zero!

If you read the graph back at 20 concentration, even though the gap is smaller, the days of increased concentrations are 20 more days. (It goes from approx 50 days to 70 days.) this is significant because as the senate paper shows it's not just about a predefined numerical cutoff but any increase and decrease in concentrations is significant. If this graph were properly thought about, it is the AREA between the 2 graphs that is important as this shows the total increase in PM10 emissions and this is significant given the Senate report saying that ANY reduction in particle emissions has a health benefit.

I have lived in Dubbo 10 years and used Toongi Hall 3 times for private functions.

Conclusion

So on top of all this data, as an occasional user of Toongi Hall, and resident of Dubbo, I want to also add my personal objection to any increases in dust or pollutants in the area, especially when the dust will be partially radioactive.

We live downwind (in summer) from the proposed Toongi mine. We have recently moved out of Dubbo to be on the outskirts of town for a healthier lifestyle and for cleaner air as my wife is sensitive to chemicals. After reading the public EIS I am strongly opposed to the mine. I think it places economics over common sense and I find the justification to be weak indeed. But given the momentum and business support I don't think the mine will be stopped it seems the best compromise is that the mine lower it's negative ecological and health impacts as much as possible and it must lower it's emmissions as much as possible even below EPA guidelines.


Wayne Connor

REFERENCES

The Senate
Community Affairs References Committee
Impacts on health of air quality in Australia
August 2013
http://www.aph.gov.au/Parliamentary_Business/Committees/Senate_Committees/~/~/media/wopapub/senate/committee/clac_ctte/completed_inquiries/2010-13/air_quality/report/report.ashx

NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining
Prepared for
Office of Environment and Heritage
June 2011 Final
http://www.epa.nsw.gov.au/resources/air/KE1006953volumeI.pdf

sorry i don t support the mine due to the dust and pollution as well as the transport of this material through dubbo by ether truck or rail

I am in support of the mine and can see potential for employment and growth but want fewer emissions and less dust. I would like to see more protection for ALL toxic matter that will go into the air, even if it is expected that only minimal will be released over 12 months - it is too much.

I don't support the mine because of the large amount of dust and pollution that will be produced.

I don't want to be breathing in radioactive dust! Do you??! A huge plus to living in the country is getting access to all this fresh air, why pollute it with harmful waste?

I am concerned with the impact that the Dubbo Zirconia Project will have upon the Macquarie River & water supply for Dubbo & it's surrounds.

I am not satisfied that the information provided in the EIS has diminished my concerns.

This is the reason why I do not support the proposed project.

I object to the mine project as I would like the Dubbo area to remain a low pollution region.

I object to this on the grounds of pollution, the dust, the radioactive risks and the waste disposal method

I support the mine but want fewer emissions and less dust-please take away the residue - do not bury it

If the proposal goes ahead i will find myself in a position where i will have to sell my house take my children out of the schools and leave my job and my husband his job due to the pollutants that will be in the air. I have children whose asthma will be effected by the pollutants and a husband with a asbestos related lung disease whom will be unable to hold his job if the quality of air is decreased affecting our income and health dramatically.....our only choice will be to leave the town which i came to to help my family with their health. Leaving behind anything radioactive is not something that should be considered good for the community.

I am extremely concerned by the description 'Slightly radioactive'. This will be detrimental to current and future Dubbo resident.

I support the mine but want fewer emissions & less dust & less pollution. I don't agree with the toxic salt being left behind.

I don't support the mine because of the dust and pollution.

As a concerned Dubbo citizen I wish to state my concern regarding the environmental impacts of the proposed mine. I do not feel enough has been outlined on how to protect the environment in a sustainable way for citizens now and into the future. In particular that the mine will release up to 700,000 tonnes of slightly radioactive dust into the air each year. The mine will produce up to 100kg/hour of Sulphur dioxide, 100kg/hour of nitrous Oxide (NO2), 23kg/hour of SO3, 29kg/hour of Hydrochloric Acid plus other toxic gasses, all directly into the air. Yes that was 100 kilograms per hour! The mine will leave behind 6.7 million tonnes of toxic salt buried in the ground because the mine operators have decided it it too expensive to dispose of this toxic salt (it will cost $33 million per year) so they are going to leave it there, sparred in plastic, hoping it won't leak into the groundwater.

I urge there to be more rigourous measures for the protection of the environment

I am against the mine proposal due to the amount of dust and pollution it will create in Dubbo. We are a great rural centre with lots of kids here, and I don't want their health jeopardized, nor the health of anyone in the community. While money and jobs are a great asset to Dubbo, they are not worth the negative health aspects for all.
The proposed amount of trucks using Obley Road is also a big concern, even with upgrades to the road. That will be too many trucks on a beautiful stretch of road with many, many children and families living on it. No longer will it be a peaceful part of our town.
Please do not go ahead with this mine. Thank you.

Dubbo is really growing as a town, in both population and reputation, often however, when people think of Dubbo they think of the Zoo... I am concerned that if this Mine was put here Dubbo would be thought of as that town with the smelly mine, "I wouldn't want to live there!" They'd think!
-The environmental damage this mine would cause is undeniably huge, not only has this area been heavily cleared for farming and logging but now with the prospect of a mine being brought here, any chance of survival of the few remaining animal species unique to this area will be gone forever.
-If this mine was brought here I'd be looking to move out and not come back!

In general, I support the mining industry as a valued part of our society and economy. However, companies that develop projects that generate a significant amount of waste (especially wastes known to be harmful to humans and/or the ecosystem) MUST accept that the cost of *effective* disposal of these wastes is their responsibility. Given the projected levels of gaseous wastes and radioactive dust to be released into the atmosphere, and especially huge amount of radioactive salt waste to be buried in a plastic bag, it is very clear the company behind this project is NOT planning to effectively deal with its own waste. The company (and any government authority that approves this project as it is) is clearly assuming the wider community of residents in the central west can simply wear the risks to health and the environment. Of course that makes the project more profitable for the company, but at an unacceptable risk and cost to the rest of us.

If this project was amended to *fully* and *effectively* deal with waste products to eliminate risks and costs for the surrounding communities and environment, I would happily support it. As it is, though, it is sadly another example of why the mining industry has developed a 'dirty' reputation.

I will only support the zirconia mine if the emissions of the mine are as low as possible. I want the pollution, whether it be air, ground, or underground pollution, to be treated safely, so that no fault can be found in this treatment. Dubbo has a great standard of living, and is an enjoyable place to live because of this standard. Let us not ruin it by having a mine just outside the city polluting our great city. The mine should spend the money it needs to, to ensure that the pollution produced is dealt with correctly, and not become detrimental to those living in the Western Plains region. Let's look to our future and not let money govern our decisions for the future.