D’Entrecasteaux National Park – too magnificent to mine
Lake Jasper – largest freshwater lake in South West WA deserves protection
Introduction: The Jangardup South mining lease M70/1385 application by Strategic Sands P/L, which is a wholly owned subsidiary of Strategic Energy Resources Ltd, consists of 498 ha of land excised from the D’Entrecasteaux National Park in 1996 and some private property. As a result of the excision, the land was downgraded to 5 (1) (g) reserve to facilitate Cable Sands (WA) Pty Ltd’s then application to mine mineral sands adjacent to Lake Jasper and through the adjoining Gingilup-Jasper Wetlands System
The 5 (1) (g) reserve status of the area has not changed the high ecological value of the environment. It is part of the important Gingilup-Jasper wetland system and the excision area runs to within 300m of the summer shoreline of Lake Jasper and within the lake’s winter flood zone and catchment. Lake Jasper is South West WA’s largest freshwater lake and surveys rank Lake Jasper third among the 27 south coast wetlands for biodiversity and abundance. The proposed mine will virtually cut the National Park in half and destroy a significant part of the lake’s western catchment.
Over half of Australia’s wetlands have been destroyed since European settlement. Polls consistently show that a big majority of Australians do not want exploration or mining in National Parks or conservation reserves.
Hydrology: Lake Jasper (4 km2) is one of WA’s few pristine freshwater lakes.
Lake Jasper’s recharge area occurs to the north and west of Lake Jasper corresponding with the proposed mine area. Much of the area defined by the current mining lease M70/1385 application lies in the catchment of Lake Jasper and in the associated Gingilup-Jasper Wetland system. The Environment Protection (South West Agricultural Zone Wetlands) Policy outlines the protection of wetlands requires activities that would degrade or destroy wetlands such as
- discharging water into wetlands or excessive pumping or drainage of water from wetlands;
- carrying out excavation or mining operations in wetlands;
- damaging or clearing emergent or fringing native vegetation of wetlands;
Watertable: Lake Jasper is hydraulically connected to the shallow groundwater system, at a depth of between 2-15m. There is little hydraulic connection to the deeper Yarragadee Formation.
Permitting a mineral sands mine within the Gingilup-Jasper Wetlands and to within 300 metres of the lake may breach the confining clay layers which hold the lake’s water, leading to dramatic loss of lake water. Loss of water depth by even 30 cm will lead to significant damage to fringing vegetation and consequent associated ecological impacts.
Soil: Mineral sand mining destroys soil chemistry and the soil profile. The structure and species richness of the Gingilup Wetland ecosystem depends on existing soil structure. No mineral sands mine in a wetland area like the Gingilup Wetlands has been rehabilitated to its original species diversity. Cable Sands Mininnup Beach rehabilitation effort only achieved approximately 10% of the original species and that was in an environment far less complex as the Gingilup-Jasper Wetlands. Strategic Sands or SER has no experience in revegetating species rich and ecologically complex areas.
The area of mining lease M70/1385 is known to have extensive acid sulphate soils (ASS). The former Jangardup mineral sands mine operated in an area with less extensive ASS but the former mine is now experiencing significant acid sulphate problems. An acid sulphate plume exists beneath this former mine and as the contaminated groundwater migrates south and west has the potential to impact on Lake Quitjup and nearby farms. BHP’s Beenup mineral sands mine closed after only 2 years of operation after the acid sulphate problem became crippling. There is now a toxic legacy with another acid sulphate plume of groundwater under that former mine migrating towards the Scott River.
Amenity Impacts: Mineral sand mining pits, dams, dredge ponds, tailing areas and process equipment, are incongruous with the aesthetic values of National Parks especially next to a popular tourist and recreational area that is Lake Jasper.
Dieback: The south coast wetland systems are particularly vulnerable to dieback. Every effort must be made to protect flora in areas still free of dieback. Despite current hygiene practices, where clearing, road construction and mining activities occur they introduce dieback.
Aboriginal Heritage: Yoondadadup Lake Jasper area provides an important cultural link to the past for local Aboriginal people. The Aboriginal connection with the area has resulted in 3 Native Title Claims.
Archaeology: Lake Jasper is Australia’s only known underwater prehistoric Aboriginal site, dated at 4,800 years old. Archaeologists from all over the world visit this area.
Economic Impacts: Mineral sands miners like to claim economic benefits. They ignore it is a only short-term prospect, ignore the substantial subsidies received, (road, infrastructure, power, land, tax breaks and royalty holidays), ignore the toxic legacies (acid sulphate groundwater plumes and radioactive waste) left for the State and local communities to deal with, that they put sustainable industries such as tourism, recreation, honey & wildflower production at risk and that they degrade biodiversity.
Given the many dangers and potentially negative impacts of mining within the excised area of the D’Entrecasteaux National Park, and the fact that similar mineral sands mines have left major toxic legacies for the State and local communities to deal with, the Government should adopt the precautionary principle to this mining proposal and refuse it. The land excised from the D’Entrecasteaux National Park in 1996 should be returned to the national park as was intended when Cable Sands did not proceed with its mine proposal.
The above map clearly shows the full extent of the Gingilup-Jasper Wetland System and the proposed mine-site would cut it in half.
Further information on the D’Entrecasteaux Coalition’s campaign to protect Lake Jasper, please contact Geoff Evans 9848 1644 or 0488933828 or Andy Russell 9776 1559
Mineral Sands Mining Toxic Legacy in South West
Acid Sulphate Groundwater Plumes under former mines
Jangardup Mineral Sands Mine
Mining at Jangardup began in 1994, with production ceasing in 2004. The site has been in a monitoring and maintenance phase since closure. The site was formerly classified as “remediated for restricted use” under the Contaminated Sites Act 2003 in December 2015 by the Department of Environmental Regulation (DER).
The high risk of Potential Acid Sulphate Soils (PASS) within the Jangardup area was identified prior to the start of mining. The modelling carried out by the proponent suggested that acid soil issues would be managed. The EPA accepted this.
By 2012 the sulphuric acid levels in the groundwater had reached such a level around the former mine site that the potential to have the site listed under the Contaminated Sites Act existed.
In 2012 following further monitoring Cristal Mining (the company responsible for maintaining the former minesite) claimed that an active source for the contamination could not be identified but suggested that agricultural practices (nitrate/ammonia contamination) may be responsible and that monitoring bores themselves may be the problem. Cristal Mining refused to admit that mining was the cause of the acid sulphate groundwater plume. It was unclear how nearby agriculture was to blame given that the necessary nitrate and ammonia/ammonium testing was not carried out to prove the comment. Indeed, the former Department of Water (DoW) was unimpressed by Cristal Mining’s argument noting that most of the monitoring bores were not downstream of the farming irrigation sites where fertiliser use is expected and that animal wastes was unlikely to produce sufficient nitrate levels to increase oxidation of the local caprock (which can produce sulphuric groundwater) and that irrigation at the crucial point did not begin until March 2011 after the date deterioration in water quality at the former mine site was found The DoW concluded that it was more likely that acidification was attributable to past mining practices. (DoW to EPA, May 2016).
In December 2014 the Office of Environmental Protection Authority (OEPA) did not see the need to register the site under the Contaminated Sites Act as it considered the toxicity low, argued further monitoring was required to observe the spread of the sulphate plume and furthermore registration would unreasonably affect the value of the land owners property. There is a requirement under the Act to register sites if they pose, or are likely to pose a risk to the environment. Potential impacts on Lake Quitjup or downstream farm land were minimised.
The AQ2 report, Jangardup Drilling and Sampling of New Monitoring Bores, (August 2015), stated that mining activities have altered prevailing water quality around the mine site but sought to share the blame by claiming surrounding agricultural practices have contributed to the acid sulphate plume despite the DoW having rejected such claims.
The AQ2 report indicates that monitoring is to continue until the groundwater in the mined area is comparable to that of the unmined area, with a target SO4 concentration of 60 mg/L. It should be noted that this 60mg/L is not a low value when compared to background levels. It is an arbitrary value, unlikely to be based on any reasonable science.
The Groundwater Monitoring Review, Jangardup Mineral Sands Operation Post-Mining Environmental Management (RPS, 2018) report found that sulphate concentrations ranged from 2 mg/L (JGMB10 and AQMB3I) to 770 mg/L (COD1B) in 2017, with only 5 of the 14 sampled bore locations recorded concentrations below the target value of 60 mg/L. The maximum value found of 770 mg/L was a decrease in comparison to the maximum value found in 2016 (890 mg/L). Some monitoring bores appear to be showing an increasing trend. (This information suggests that the acid sulphate plume is migrating to the south-west of the minesite towards Lake Quitjup)
The 2018 report shows that several bores are showing evidence that the acidification of the groundwater has released high levels of minerals from the surrounding soil such as aluminium, zinc, magnesium, iron and arsenic.
The report states that:
Based on the trends seen in 2017, it is expected that groundwater quality will improve across site over 2018. However, any improvements in groundwater quality will be minor and it is unlikely that the 2018 groundwater quality results will demonstrate compliance with all criteria, particularly the sulphate trigger value.
For now it seems that the process is simply to monitor the movement of the acidic plume, and the associated elevated levels of minerals, like aluminium and zinc, and hope that it dissipates enough that it has no impacts on down-gradient farmland and Lake Quitjup (used as a biological reference point due to its relatively pristine environment). It appears no pro-active measures are to be put in place to protect the environment or public health.
Beenup Mineral Sands Mine
BHP Titanium Minerals (BHPTM) operated the Beenup mineral sands mine near Scott River (17km NE of Augusta), Western Australia for two years between 1997 to 1999. The mine was expected to operate for several years but collapsed after two when acid sulphate levels became so critical that it began effecting mining equipment.
In 2009, BHPTM reported potential contamination in groundwater beneath the mine site and since then has been required to monitor groundwater quality and movement off-site.
BHP Titanium Minerals Beenup Rehabilitation Project Mandatory Auditor’s Report, (June 2018) (written to release the company from further groundwater management) concluded that sulphate plumes associated with historical mining activities are present in groundwater and were caused by disturbance of Acid Sulfate Soils (ASS) during mining activities undertaken at the Trial Pit, Dredge Ponds and Bulk Sample Area.
May 1996 the construction of Mine Development Storage Area (MDSA) and dredge pond.
With regards to sulphate concentrations, the report notes that historical and current monitoring indicates sulphate concentrations in groundwater within the (Upper and Lower) Beenup Beds in excess of the Australian Drinking Water Guidelines, but below the DoH (2009) domestic non-potable use guidelines. Acid Sulphate levels range from 160 mg/L in the Upper Beenup Beds to 300 mg/L in the Lower Beenup Beds.
The BHP Titanium Minerals Beenup Rehabilitation Project Mandatory Auditor’s Report (2018) was critical of past modelling of groundwater flow and solute transport (despite a peer review of the modelling in 2008) and with ‘new’ modelling was able to present a ‘positive’ picture on the future impacts of the acid sulphate groundwater plume heading toward the Scott River. Groundwater from the Bulk Sample area of the mine was now modelled to first reach the freshwater of the Scott River after about 52 years, with acid sulphate concentrations rising to up to 8.5 mg/L after about 140 years. This is much longer than was originally predicted and may be a result of the low rainfall period or that consultants do not fully understand the local groundwater/geology dynamics.
May 1997 MDSA dam – recently raised walls orange yellow indicator ASS.
A review of the raw data in the Beenup Mine Rehabilitation Review of Groundwater Monitoring Results, July 2014 to June 2015 (Rockwater, 2015) indicates that depending on the location of the individual bores there were fluctuations – increases as well as decreases in acid sulphate levels indicating that the evolution of the acid groundwater plume was continuing. The BHP Titanium Minerals Beenup Rehabilitation Project, Assessment of Sulphate Plume Movement to June 2017 to September 2017 (Rockwater, 2017) tries to presents a brighter picture indicating in general terms ‘reduced acidity levels (pH >4) and steady SO4 concentrations.’
The BHP Titanium Minerals Beenup Rehabilitation Project Mandatory Auditor’s Report (2018) continues the rosy outlook stating that based on the no observed effect concentrations (NOEC) and the freshwater aquatic population protection guidelines in Table 6 (only two examples provided), it is highly likely that the 4 mg/L that would reach the Scott River in 50 – 100 years will not cause adverse impacts to receiving aquatic populations. It needs to be pointed out that use of NOEC is under increasing criticism, due to substantial statistical problems that are inherent to this concept: the problem of recognizing small eﬀects in scattery data and the need to know all data on toxicokinetics (absorption, distribution, individual species metabolism and excretion, period of exposure, biotransformation). A statistically non-signiﬁcant eﬀect does not imply that biologically signiﬁcant eﬀects are absent. It is a poor estimator of ‘‘safe’’ chemical concentrations. In addition, the BHP report does not reference any studies to support its NOEC conclusions. It should be noted that there are no established Australian environmental trigger levels for acid sulphate.
What does all this mean? Notwithstanding that the 2018 report was aimed at releasing the company from further groundwater management, it also shows the poor level of understanding of environmental conditions and that models are only as effective as the amount and accuracy of information put into them. When it comes to acid sulphate soils and its interaction within the local environment and the movement of groundwater there is usually inadequate knowledge and understanding. The BHP Titanium Minerals Beenup Rehabilitation Project Mandatory Auditor’s Report findings are likely to found deficient in the near future.
June 1997 MDSA and Dredge pond – diversion drains toward Scott National Park.
Despite academics and local environment groups warning BHP of the dangers and impacts of mining in the area, BHP went ahead. In this instance the EPA approval of the mine showed that it was totally out of its depth in regards to scientific assessment and arrogant in ignoring local community knowledge. A low or poor level of understanding of local environmental conditions and impacts of disturbing the delicate ecological balance should result in the precautionary principle being invoked.
Click to download the Strategic Assessment (under section 16(e) of the Environmental Protection Act)
- Public outreach programs aimed at disseminating information about the social and cultural importance and ecological magnificence of the D’Entrecasteaux National Park and the likely impacts of any proposed mine.
- Establish liaison with local Aboriginal groups, Members of Parliament and local community groups to promote the protection of Yoondadadup Lake Jasper and the Gingilup-Jasper Wetland ecosystem
- Lobby the proponent, Strategic Sands P/L- a wholly owned subsidiary of Strategic Energy Resources Ltd – to withdraw the mining lease given the significant dangers such a mine poses to the Gingilup-Jasper Wetlands and Lake Jasper.
- Research and prepare submissions to relevant organisations and campaign through the media to highlight concerns about mining next to Yoondadadup Lake Jasper
- Campaigning on the broader issue of mining in National Parks.
- Fundraising to finance these activities.
Click to download the Information Package Final Master 08022019
There is much to be done so if you want to assist in some small way or donate, please go HERE.
if you require more information please contact our office.
Office Phone Number 08 9848 1644 and 08 9776 1559
Visit Yoondadadup Lake Jasper