Antinuclear

• A series of reviews and changes within the EPA and the Department of Mines and Petroleum (DMP).
• A DMP-appointed panel has been established to advise on uranium mining regulations and standards yet the process has been secretive and exclusive; serious concerns have been raised about the independence of the panel; the panel has yet to publicly release any of its findings; and the Government has yet to act on any of the panel’s findings.
• The EPA is reviewing the mechanisms for protection of stygofauna.
• New mine closure plans are just starting to be rolled out.

Uranium mining management has been inadequate around Australia; mining management has been inadequate in WA; and an effective regulatory regime for uranium mining has not been established in WA. Three a priori reasons for concern about Toro Energy’s proposal to develop a commercial uranium mine at Wiluna.

Those concerns are heightened by Toro’s application − the Environmental Review and Management Programme (ERMP). The application in its current form should be rejected on the basis that there is incomplete information, baseline studies are deficient and management plans are still pending. This level of information is relevant to the public interest and is not present in the ERMP that has been made publicly available. Toro Energy’s application should not be assessed let alone approved until serious data gaps have been addressed.

Remarkably, Toro Energy acknowledges that it has not fully verified the accuracy or completeness of its own application, and does not accept responsibility or liability for its application. This is clearly unacceptable and EPA assessment should be deferred at least until such time as Toro Energy takes responsibility for its own application.

Specific concerns with the ERMP application and the proposed mine at Wiluna include the following:

• A mining agreement with Traditional Owners has not yet been negotiated, and the Heritage Mapping Survey which will inform negotiations has not yet been completed. There are also local community concerns and complaints about the way Toro has scheduled and conducted public meetings and consultation processes.
• Lake Way is home to a unique population of Stygofauna − a newly-discovered species of subterranean crustaceans.
• Transport plans are presented as a “preliminary draft” and yet the company plans to transport a toxic and radioactive product many thousands of kilometers from Wiluna to Adelaide and/or Darwin.
• The mine rehabilitation plans are incomplete and Toro Energy’s preliminary costing for rehabilitation is being kept secret.
• Toro Energy Ltd acknowledges the need for a formal risk assessment in relation to security risks yet this has not been carried out.

Uranium mining and tailings disposal in this region would occur below the water-table and be connected to aquatic ecosystems. There is a risk of contaminating the aquatic ·         ecosystems with changes in water chemistry, including the mobilisation of radioactive compounds. Toro Energy plans to line the sides of the tailings pits (former shallow open pits) but not the base of the pit, this will lead to leakage of tailings into the ground.

• The legal requirement for tailings management at the Ranger uranium mine in the NT is effective isolation for at least 10,000 years. This requirement should be a minimum standard for any proposed uranium mine in WA including Wiluna.
• No calcrete uranium deposit has been mined in Australia and there is only one calcrete deposit presently being mined worldwide. There is a lack of expertise and experience in engineering and mine design for these deposits.
• Toro Energy has not factored in recent advice from the International Commission on Radiological Protection that radon is twice as carcinogenic[1] as previously thought. Toro Energy has recklessly and irresponsibly promoted fringe scientific views that low-level radiation is harmless or beneficial; conversely, the company has done nothing to promote the mainstream scientific understanding that even the lowest doses of ionising radiation can induce fatal cancers and other diseases.
• Toro Energy has not demonstrated a comprehensive understanding or analysis of the cumulative impacts of water extraction for the proposed mine.
• Toro Energy has made the false assumption that the Wiluna region has naturally elevated radiation levels and has failed to submit accurate and complete evidence on the radiological environment at Lake Way and its surrounds.

Toro Energy downplays the significant global implications of its uranium mining and export proposal. We urge the EPA to address the global implications given the failure of corporate governance and the failure and limitations of Commonwealth regulation of the industry. An important, recent example of these problems has been the failure of the uranium-exporting companies operating in Australia to do anything constructive about repeated, widespread safety breaches and data falsification in Japan over the past decade − including the failure to adequately prepare for and respond to earthquakes. Instead, the mining companies supplying Australian uranium to Japan − BHP Billiton, ERA (Rio Tinto) and the Commonwealth regulators have turned a blind eye to those well-documented safety problems….. more at   Wiluna ERMP Submission_Final.doc

TABLE OF CONTENTS

1. Introduction

2. Mining in WA: Management Failures

3. Insufficient Data

4. Toro Energy’s Disclaimer

5. Radiation Risks

6. Uranium Transport

7. Social Impacts − Aboriginal Heritage Issues, Jobs, Public Opinion

8. Local Environmental Impacts:

8.1 Biodiversity

8.2 Stygofauna

8.3 Calcrete Deposits

8.4 Water

8.5 Radioactive Tailings Waste

8.6 Cumulative Impacts

8.7 Energy Consumption and Greenhouse Emissions

8.8 Closure and Rehabilitation

9. Global Implications of Uranium Export from Wiluna

High-level Nuclear Waste

Nuclear Accidents

Weapons Proliferation

Appendix 1: West Australian Nuclear Free Alliance 2011 Statement

Appendix 2: Radiation risks to uranium miners’

Appendix 3: ‘Uranium industry’s record raises doubts’ (The West Australian)

Appendix 4: Technical comments by Dr Gavin Mudd

 Wiluna ERMP Submission_Final.doc