Summary: Health Impacts
Dr Paul Harvey, Environmental Science Solutions
- The EIS does not provide sufficient justification for the assumptions used or the conclusions reached. The EIS fails to adequately identify and quantify perceived, actual or potential impacts and therefore does not suitably assess the impact of the project.
- Currently, the EIS does not provide suitable information regarding access infrastructure, pipeline infrastructure of marine/port infrastructure. These components of the Project should be given greater attention in the EIS or should form part of a separate EIS process – the latter being the preferred option.
The key issues raised by the EIS from an environmental contamination and pollution perspective include:
- Water contamination arising from discharges associated with mining in the upper catchment of the Freida River.
- The impact of environmental contaminant discharges on downstream sensitive receptors.
- Suitability of the Integrated Storage Facility for storage and long-term containment of the mine tailings waste.
- The suitability of the proposed open-pit lakes that will be used at the end of operational phase.
- The impact on the existing natural environment (primarily including soil, vegetation, water quality, groundwater quality and noise) resulting from construction, operational and decommissioning phases of the Project.
Determination of predicted impact significance and likelihood
The impacts in the EIS have been assessed against either the “significance assessment” (qualitative using a ‘matrix of significance’ rationale) or “compliance assessment” (quantitative against existing standards). Compliance assessment has been used for noise; air and water quality.
The use of a matrix of significance approach is unconventional and creates uncertainty in all conclusions formed as a result of the analysis. There is no explanation given for the levels of determination from negligible to extreme for the matrix of significance. The appropriateness of this assessment for an EIS is of concern.
Open Pit Lakes
The following questions have not been adequately addressed in the EIS:
- Suitability of the environment, particularly hill slopes, for stability of long-term excavation.
- The onus of responsibility for ongoing management of the pit lake in perpetuity after mine closure.
- How will the water stored in the pit-lake interact under variable and changing conditions, particularly how will surface waters interact with ground waters?
- How will contaminants be managed in the event that the pit-lake is overtopped or is catastrophically damaged?
Pipeline and Roadway Infrastructure
The pipeline and roadway infrastructure proposed for the Project is not well assessed by the EIS. While mention is made of these features, there is very little assessment of their impact undertaken, particularly during the construction, operational phase and end-of-life phase of this infrastructure, and in the event of a major overtopping event or catastrophic failures of the infrastructure.
Water Quality and Impact Deficiencies
- The EIS is weak in its evaluation of the downstream impact on sensitive receptors, including the fluvial habitat and the local communities, resulting from the proposed discharge of contaminants.
- It is concerning that water quality is assessed in this EIS under a range of guidelines including the outdated PNG Standards for Drinking Water. The EIS correctly refers to more recent World Health Organization guidelines; however the EIS persists with using the PNG Standards for Drinking Water where it is convenient for the impact being assessed. This practice undermines the integrity of the analysis and impact assessment.
- Utilising international environmental trigger values in the absence of local environmental trigger values is not suitable for a formal EIS process. In the absence of suitable environmental trigger guidelines, the proponent should seek to resolve that knowledge gap by generating local environmental trigger values.
- The EIS does not provide a suitable body of information to demonstrate that the impacts of a potential breach in the ISF or an overtopping of the ISF have been considered. Table 9.1 of the Socio- Economic Impact Assessment does not consider loss of life as a potential impact resulting from an event where the ISF discharges in an uncontrolled manner downstream.
Mine Closure and/or Cessation
- In the event that the Project progression is halted, the EIS does not detail what contingencies will be in place to mitigate impacts arising from incomplete infrastructure.
- The EIS does not adequately address the impacts that may arise post-closure. Concern is raised regarding management of the mine and associated infrastructure in perpetuity particularly in the event of a catastrophic failure of the ISF at the end-of-life stages. This should be clearly assessed as part of the EIS.
- It is unclear what regulatory authority will be accountable for ensuring compliance with environmental protection regulations, as the EIS states that it is anticipated that “third party entities will own and operate the remaining project elements” at some point in time. It is also unclear as to who the legal financial entity will be in the event of an accident or incident at the Project.
- The emergency response management strategies are concerning as the management plans do not provide assessment of detailed scenarios or response mechanisms. End-of-life phase emergency response is also not considered. There is no provision in the EIS for who will carry financial responsibility for future maintenance of the ISF and critical infrastructure to ensure a catastrophic event does not occur, nor funding for the necessary emergency response should it occur.