Wednesday, July 13, 2011

In response to the SMEC report by DEC & MMJV 13.07.11 Lae Inter Hotel

Honourable Sam Basil, MP Bulolo & Deputy Opposition Leader.

July 13, 2011

Thank you fellow leaders, Ministers, Mine-affected community reps, MMJV reps, chairman, ladies and gentlemen.

As the Member for Bulolo, I am pleased that the Department of Environment and Conservation through the Inter-Agency Environmental Expert Committee (IAEAC) are willing to come down to the level of the Provincial and Local Level Government and even to where my people live to engage with us on the issues affecting us.

That positive step took almost 22 months. I personally delivered the petition prepared by the local people through the UoWRC to the DEC in September 2009.

Naturally Chair, I am not very impressed with the duration and time it took for DEC to finally comedown to us as IAEAC. The Government through the bureaucracy must be seen to be responsive to the people’s concerns.

The longer DEC takes, the more my local people along the Upper/Middle and even the lower reaches of Watut who access and use the Watut River will suffer from all the negative and maybe even dangerous byproducts that MMJV Mine is producing and discharging daily into the river system.

I believe this committee was solely formed as a result of the September 2009 petition to DEC. What I also understand is that DEC, after the September 2009, engaged an independent consultancy firm, SMEC to carry out an Independent Environmental Performance Audit of Hidden Valley Gold Mine. That Audit also involved an Assessment of the Mine Derived Sediment. It took the entire 2010 for DEC to work with MMJV to get their act together before this face-to-face meeting with the people. I believe DEC would not have responded to the issues or formed the Expert Committee if there was no petition from us.

Chair, I was given a copy of the SMEC reports just last week Friday and had a quick look at the reports.

Let me highlight some observations from the report.

The Report was first prepared on June 6, 2010, then went through a total of 3 revisions with resulting in the finalized version on November 19, 2010. The main key objectives of the audit were:

a) To assess mine performance with regard to permitting compliance and Environmental Management

b) To assess offsite impacts due to historic and current mine activities;

c) Therefore, enhance DEC’s capacity to effectively monitor and regulate the future operation of the mine as well as provide the basis for the formulation of an appropriate response to the Watut River Community

Chair, the SMEC report confirmed that from the two Permits (Waste Discharge & Water Extraction) issued in April 2006 to March 2010, there were a total of 10 non-compliances and 30 partial compliance conditions out of the total 73 conditions. This is 54.8% non or partial compliance to the permits issued by DEC.

Not only that, the Environmental Management Plan (EMP) which was granted with 11 conditions in April 2006 was not updated by March 2010 audit. The EMP did not significantly meet ISO 14000. This is an international standard on Environmental Management aspect.

The report confirmed that the environmental management is not properly coordinated and there has been generally poor response in resolving permit non-compliances.

What I and my people fail to understand is how despite the EMP for MMJV project not being compliant to ISO 14000, DEC saw fit to allow the project to go ahead. Permit No. WD-L3 (50) was also not followed.

The EMP was said to have been updated since August 2009. Coincidently, that might have been triggered again by the petition put in by the UoWRC (Sept 2009).

The report confirmed that the soil and surface water and erosion management requirements were not fully implemented across the site. There were significant erosion issues associated with unstable slopes and waste dumps. There is no permit limit or adopted target for suspended solids concentration in water drainage off the site.

DEC has again failed to establish clearly the target for suspended solid concentration in water drainage off the site. That alone should result in disallowing MMJV to discharge waste excessively off site.

The report also pointed out that the waste management was not done in accordance with the Waste Management Plan. There was no waste register or evidence that waste minimization and re-use programs were fully implemented across the site.

The landfill was poorly located and managed, and posed an ongoing environmental risk.

This significantly throws away the principle of sustainable mining practice. So where have all the hazardous and toxic mine wastes generated over the years gone to? Where were they disposed? It does not take a rocket scientist to work out they were disposed into the Watut River! There was no thorough ground water monitoring done to assess the bioavailability of hydrocarbons, VOC, PCB, and other environmental persistent chemicals.

Chair, the SMEC report confirmed that these waste treatment systems appear to be overloaded and unable to treat wastewater to permit standards. There was potential for downstream pathogenic and nutrient contamination, which poses a health threat to downstream inhabitants.

This indicates high potential of raw wastewater discharge downstream. Riverine communities and alluvial miners can and may still be easily be affected. Highly raw pathogenic contamination of the river system which can easily affect/influence the river health balance. That in turn is highly unhygienic and harmful, especially when the river communities use the river for drinking, laundry and washing cooking utensils daily.

This also has the potential of aggravating skin irritation and affects small sores or cuts on the epidermal layer of the skin especially on the foot or below the waist line. Issues raised by pregnant women bathing or crossing the river resulting in other health concerns can also be clearly linked to this.

It was also reported that there have been a number of recent studies examining ecological impacts. These include undertaking flora and fauna monitoring. A wide range of recommendations have been proposed, however, there was no consolidated program to implement recommendations and monitor their effectiveness.

I wonder what the extent of the ecological monitoring program is. Ok Tedi Mining undertakes studies even to the Mount of the Fly River and the nearby Kiwai Island. Although, MMJV is not permitted to dump their waste tailings onto the Watut River, the extent of the mined sedimentation that is already end up in the river system will obviously reach the junction of Watut/Markham River and ends up at the Huon Gulf. As the duty of care to the environment and also in line with the principle of best sustainable mining practice, that should be the extent of their ecological monitoring program.

The report revealed that MMJV’s monitoring program includes fortnightly air quality monitoring at three monitoring stations located at Manki, Upanda and Hikinagowe villages. None of the monitoring stations were operational during the time of the audit due to local disputes. Monitoring data collected at Manki village station was sighted – and this indicated no monitoring program since January 2009.

The report also mentioned that the hydro-Meteorology monitoring data was last reported in the April-June 2009 Environment Monitoring Report. This included river gauging and stream flow data for Pihema creek off take site for the second quarter of 2009. It also reported meteorological data including rainfall, humidity, barometric pressure, solar radiation, wind speed and direction, and evaporation. Monitoring data has not been reported since June, reportedly due to the resignation of the site Hydrologist.

The audit found that monitoring, quality assurance and training procedures have been poorly implemented. The data management system is not effectively monitored and controlled, with no data recorded since June 2009. There have been a number of reported non-compliances with Permit conditions; however there was no evidence to indicate that appropriate remedial actions have been undertaken. This is a clear non-compliance to this very important monitoring program.

It seems most of the non-compliance happened in 2009 prior to the submission of the UoWRC petition. Again the question of, if the petition was not submitted, would MMJV continue with its non-compliance? This is a seriously poor practice that has been allowed without any penalty being imposed.

This might possibly mean MMJV management can still report non-compliant data convincingly to DEC and they can still accept non-compliant annual reports without checking.

A major issue is the monitoring and management of sediment discharges. Historic data indicates high concentrations of sediment in receiving waters. There is currently no Permit requirement or management targets adopted for suspended solids.

DEC has not clearly established a permit limit for suspended solids. How can they impose control and compliance if they don’t have a benchmark to work with? Does that still mean that we can use WHO criteria or Australian guideline?

Chair, even the water samples taken during the audit showed elevated levels of arsenic, cobalt, lead, manganese, iron, mercury and free cyanide in excess of Permit requirements. That is normally the case, when wastes are discharged into the stream continually. They can easily be traced immediately downstream and near the source of discharge. As you move further downstream, due to dilution and buffering capacity of the flowing river, the traces disappear.

That evidence alone indicates the sub-standard method of waste management being practiced by MMJV where Toxic chemicals being discharged directly into Watut River. What is DEC doing?

Offsite Impacts/Issues

Based on a review of relevant documentation, including MMJV’s annual and quarterly compliance reports, it is likely that mine activities have significantly contributed to high sediment loads in the Watut river, particularly in the Upper and Middle sections of the river. Major sources of sediment relate to pre-stripping/sidecasting activities, un-engineered waste dumps and landslides. A recent study (Pickup and Hargreaves 2009) concluded that approximately 20-30 metric tonnes of waste rock material have entered the Watut River system as a direct result of mine activities. The study also found that mine derived debris moving down the Kaveroi and Upper Watut channels has severely scoured the valley walls, resulting in increased risks for slumping of additional sediment and rock into the channel, and generation of mudflows during large rainfall events.

This confirms all the concerns about river sedimentation. It is a very sad fact and I believe DEC should squarely be liable as well for not responding immediately. Sedimentation has resulted in mass starvation of vegetation and plants along the river bank and aquatic life.

The report also indicated that suspended solid levels in the Watut river began to increase in mid 2007, which coincides with the timing of intensified mine construction. Up to late 2009 suspended solids concentrations were consistently in the range 5,000mg/L to 12,000 mg/L. This trend reversed in around mid 2009 when dumping (side casting) to the Eastern Dump ceased, leading to less, but still significant (>2,000 mg/L) sediment discharges to the river.

Obviously, mining activity at the upstream was the prime contributor to high level of sedimentation and as a result elevated suspended solid levels as indicated. Results greater than 2000mg/L is still significantly high. Water samples taken during the audit showed elevated levels of arsenic, cobalt, lead, manganese, iron, mercury and free cyanide in excess of Permit requirements.

Consequently there is potential for ecological and health related impacts on downstream inhabitants. No doubt, and again, mining activity at the upstream was the prime contributor to high level of sedimentation including elevated levels of arsenic, cobalt, lead, manganese, iron, mercury and free cyanide. The levels exceeded the limits specified in the Permit.

Now, the operation was NOT suspended by DEC, WHY? There were inconsistency observed within the internal systems of MMJV and yet the mine was allowed to operate. What standard are we using?

Also, due to elevated BOD and nitrogen levels in sewage effluent there was a high potential for pathogenic contamination of downstream waterways. This poses a serious health threat to downstream inhabitants. High nitrogen levels found in the effluent can cause algal blooms, oxygen depletion and degradation of waterways. Not sure whether DEC has notified the Health Dept about this. The Health Dept. should immediately engage an independent assessment on this issue. Obviously, the Health minister should explain this to his people at Lower Watut and Huon Gulf himself.

Chair, a number of studies have been undertaken to assess biodiversity impacts from mine related operations. Generally all studies conclude that biodiversity has been affected to varying degrees by high sediment loads and metal accumulation. The most recent study (Hidden Valley Aquatic Biology Gap Survey, 2010: Hydrobiology Pty Ltd (Environmental Services, DRAFT) confirmed that the biodiversity of the upper Watut River has been severely impacted by elevated sedimentation levels, with increased metals availability also a possible contributory factor to these changes in the river during the mine construction phase.

The study has clearly indicated the impact to biodiversity due to high sedimentation with increased metal bioavailability to plants and aquatic life. Has DEC impose any penalty yet to MMJV? Delay tactic and yes, of course, leave the environment to recover itself over time!

Didn’t the mine operator mentioned in their approved EMP that they will as much as possible minimize any damage to the environment, in this case, the biodiversity?

SMEC report also highlighted that other than some anecdotal data and the claim made by the Union of Watut River Community in the petition, there was no report or data available to confirm that mine-derived sediment has caused reduction in income of the river communities.

In contrast a decline in fish population is, however, evident from the study conducted by Hydrobiology. This may not have had any impact on the people’s income as there is no evidence of commercial fishing in the Watut River. There is no evidence of reduction in crop production due to high sediment in the river.

To manage this, MMJV has engaged Dr John Burton to carry-out the socio-economic survey in order for them to understand that knowledge gap.

The report also mentioned that other than a few anecdotal records there were no data on mine-related health issues in the Watut River communities available during the SMEC study. However, based on audit findings the mine may be impacting on river communities in the following ways:

- Depletion of fish resources and a source of protein rich food;

- Some metals released into the waterway can cause skin related diseases.

- Consumption of fishes with elevated level of metals may also pose threats to human health; and poorly treated sewage effluent can potentially result in a range of health related issues such as diarrhoea, dysentery and stomach ache, and in some cases more serious diseases.

SMEC may not have the data/report or the statement may have been told to them by mine operator. The fact is they haven’t done any study on this. That is why to manage this; they have engaged Dr Keith Bentley to do a market basket survey as part of the Health Risk Assessment in order for them to appreciate that knowledge gap.

SMEC confirmed in the report that the Environmental Impact Statement prepared for the MMJV was undertaken based on the sediment load being distributed equally between the Bulolo and the Watut River systems. However as part of the works and the placement of the mine sites this has been amended to show that there is now a 90/10 split between the Watut and Bulolo Rivers. This increase in potential sediment load to the Watut River and potential environmental and social impacts were not assessed prior to construction of the mine.

That leaves us to still question, why the DEC Minister had a secret flight to meet with MMJV management and to see the issues first hand without notifying Morobe Provincial Government, Bulolo District or me the local MP.

Chair, this are very serious – and dangerous flaws. Their impact and implications are long-lasting on the water source health and even lives of the people. They signal a lack of confidence in MMJV as a trustworthy development partner and investor. But worse of all, the attitude of the Department of Environment and Conservation together with the Minister involved, to these issues completely goes against the democratic idea of governance. Instead of democratic governance being for the people – this is completely against the people.

This is the reason why there is growing pressure for the Government to relinquish its option on equity in mining projects to landowners, LLGs and the districts and assume the role of being regulator and tax collector more.

I hope my presentation based on the hard work of many experts and professionals will cause all stakeholders to do the right thing – for all our collective benefit – and especially the people living along the riverine areas from near the mine site all the way to the coast of Huon Gulf.

Thank you very much.


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