Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697642701869.pdf (Australia)
SENATE SUBMISSION Submission from: Andrew Helps Organisation: UNEP Global Mercury Partnership Subject: The rehabilitation of mining and resource projects as it relates to Commonwealth Responsibilities in Australia 1.

About the Author.

I have been an Environmental Disaster Manager since 1966.

I am the only surviving co-author of the original Victoria State Disaster Plan (1966-67).
I was the co-author of the first draft of the Victorian EPA Act (1967) I was a peer reviewer of the Kyoto Protocol Green Paper.
I have run major environmental remediation projects in a number of countries in Asia for bodies such as the World Bank (WB) International Finance Corporation (IFC) and the Global Environment Fund (GEF); Some of my projects include: Japan 1983-1988 developed and installed a civilian nuclear safety system that allowed the speedy and orderly evacuation of impacted communities in the event of a nuclear accident.
China 1986-1989 develop and install a civilian nuclear safety system that allowed the speedy and orderly evacuation of impacted communities in the event of a nuclear accident.

Korea 1985-86 develop and install a civilian nuclear safety system that allowed the speedy and orderly evacuation of impacted communities in the event of a nuclear accident.

USSR 1987 with permission from the Australian Government via CoCOM, provide technical and logistic support after a nuclear emergency.
Australia 1988 Austrade gold export award for emergency management software.

Australia 1989-1992 Project manager for a number of high tech contracts ($A eq 900 million) within the ANZAC Ship project.

Vietnam 1992-1996 Establish a modern putrescible waste equipment manufacturing facility in Vietnam to make waste compaction equipment for local and export use - plant profitable from day 1.
Vietnam 1992-1996 team lead a number of major projects for a number of global NGO’s in the area of toxic materials e.g mercury, lead, munitions, PFOS, agent orange.

China 1996 2002 a number of projects in waste management, biogas, chemical fertiliser replacement , cement kiln emissions, ChlorAlkali and VCM plant remediation.
Australia late 2002 - early 2009 Work to Introduce into Australia modern high temperature high pressure anaerobic digestion technology to produce granulated organic fertiliser Since 2009 I have been focused on establishing a catchment level mercury remediation project (EPBC 2010/5477).

As this project was being developed it became apparent that there was need for a community advocate to advise communities in the vicinity of operational Gold and Antimony mines on toxic and carcinogenic metals.
This work which started 2011, and grew into a major workload within 6 months.

SUBMISSION SYNOPSIS.

Page 1 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 Much of Australia’s original wealth was built during the gold rush period 1850 to 1890.
Whilst this massive growth of community wealth took Australia to a globally significant position in public health and infrastructure the legacy pollution issues with un-remediated mine sites are causing significant public health issue to this day.
As the primary author of the first Australian Government EPBC controlled action permit for a catchment scale mine pollution remediation project, I feel there are a number of major issues that will need to be overcome before historical mine remediation can take place on a wide scale in Australia.

Current estimates are that Australia has in excess of 140,000 abandoned un remediated historical gold mines.

2.
2.

The rehabilitation of mining and resource projects as it relates to Commonwealth responsibilities, for example under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) with regard to: 2 (a) the cost of outstanding rehabilitation obligations of currently operating projects.

Comment.

The question is somewhat ambiguous as it clearly also covers responsibilities under the Regional Forests Agreements (RFA) Act 2002.
I would believe that the cost of rehabilitation under the RFA should be subject to a separate and very urgent Senate Enquiry as the long term impacts of rehabilitation failure under the RFA is starting to have critical impacts on rainfall and environmental stability especially in Victoria where the forest resource has now been effectively exhausted.

To my knowledge there are no currently operational mines in Victoria that have any rehabilitation responsibilities under the EPBC Act.
In Victoria there are four major mine operations that are currently causing significant public health and environmental impacts: 1.

Stawell Gold mine - currently under care and maintenance.

This mine has no EPBC permit as it was in operation prior to the introduction of the EPBC Act.

The mine was subject to an EES process for an extension which was refused by the previous Victorian Liberal Government.

Just before Christmas last year the mine locked its gates and sacked the bulk of its staff.
Recently the mine has approached the Labor Government about an “EES light” for the same proposal.

The NPI data for this mine has demonstrated horrible pollution over a long period and the Victorian EPA (who maintain the NPI data base for Victoria) failed to inform the community of this pollution at the quarterly ERC meetings.

This mine has a massive unstable tailings dam that contains a range of carcinogenic metals (Arsenic at 3 kg/ton) and cyanide.
When this tailings dam fails due to a lack of maintenance, it will cause a massive pollution event right through some of the most productive areas of Western Victoria and totally destroy a RAMSAR Wetland.

It is currently estimated that the mine has between 16 and 20 million tons of tailings in this dam.

This mine has no responsibilities to the Commonwealth under the EPBC Act and no responsibility to gain an EPBC clearance if the Victorian government approves the current “EES light” proposal.
The mine still does not have a publicly available disaster plan for the eventual break of this dam.

2.

GBM Mining, Bendigo Gold Mine and Woodvale Evaporation Ponds Bendigo.

Page 2 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 There is a least 50 years of operational history with this mine and the 160 Ha evaporation ponds at Woodvale.
This mine has no Commonwealth responsibilities and is currently trying to avoid the few responsibilities under State Law.

The ponds are heavily polluted with Salt and Arsenic.

It is estimated that there is in excess of 200 tons of Arsenic in the ponds.
The State government contracted a consultant do a study of the ponds to test Arsenic levels but the consultant made the assumption (or lacked the knowledge to collect and transport the samples to the lab in the right manner) that the Arsenic in the ponds was organic Arsenic As(V).
My experience in Asia indicates that much of the Arsenic would be in the As (III) form which is 60 times more toxic than the As (V) form Should the Woodvale tailings pond breach or more likely be deliberately breached by the owner, it will have a massive impact on the downstream Murray River RAMSAR Zones and all the river communities and irrigators.
The Victorian mine regulators seem to be unable or unwilling to apply Victorian law to this mine and the currently held rehabilitation bond is only $ 6 million for the two mine sites and current estimations are that the Woodvale Ponds site will cost in the region of $60 to $100 million to remediate on its own.
There is air sampling taking place at this mine site but the Victorian EPA allows the mines laboratory to heat the dust samples to 850 degrees centigrade to allegedly remove water and items such as bird poo from the samples.

Many of the highly dangerous carcinogenic metals in this dust gasify at less than this temperature and thus the dust reports are totally deceptive and misleading.

3.

Costerfield Antimony Mine.


This mine has operated on and off since the 1860's and hence it also has no EPBC responsibilities.

The waste water from this mine contains levels of Antimony that require the water to be treated on site to make it safe (Vic EPA Category A controlled industrial waste).

Currently the mine has in excess of 700 megalitres a year of this CAT A “water”.
To put this issue into context, the Australian drinking water standard (ADWGL) for Antimony is 3 ug/L (USEPA is 0.78 ug/L -3.8 times lower).

The ADWGL for Arsenic in Australian drinking water is 10 ug/L (USEPA is 0.052 ug/L -192 times lower).

(See my comments on the NEPM disconnect later in this document) For about 2 years VicEPA allowed this mine to truck this CAT A water under permit and to dump the CAT A water into a large abandoned mine void on top of a hill overlooking Heathcote (Vic) township.
This Act by itself required an EPBC permit but the mine did not seek such a permit.

VicEPA did not put in place any precautions to understand if the Cat A Waste was leaking from the mine void or to understand the magnification of the toxic metal in the waste as the water fraction evaporated.
It was not until the Residents, at a public meeting in Heathcote, produced satellite data that indicated the mine void was leaking towards the main drinking water supply dam for the city of Bendigo that the EPA even mentioned this issue.

EPA had the view that the “dilution factor” would negate any risks to the community.

In 2012, the mine purchased some farmland 5km from the mine site and started a process to permit a massive evaporation dam.
On behalf of the downstream farmer I referred this proposal to the EPBC Section but they would not call the matter in despite that massive amount of highly toxic material in the dam and it position in the upper reaches of a Goulburn river tributary.

Bendigo Council failed to issue a planning permit for the site in the statutory period and the mine was forced to go to VCAT to seek a permit.
After a lengthy hearing VCAT approved the development with some stringent conditions including PVC lining Page 3 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 of the dam and construction to ANCOLD guidelines.

The engineer gave evidence that the dam would last for 1,000 years.
On the 5th of October 2016, the mine notified residents that it would have to carry out a “controlled discharge” to the Wapentake Creek due to the rainfall event.

This was despite the fact that the dam was below the designed holding capacity as advised by the regulator Earth Resources Victoria.

In the first demonstration of regulatory enforcement for a long time the mine was prevented from carrying out this “controlled discharge” and has continued to treat water via its Reverse Osmosis plant.
This event would not have happened if this Category A waste storage facility was subject to tight EPBC conditions 4.

Gippsland Lakes (Lakes Entrance Dredging) EPBC 2011/5932 On 8th of September 2011, the Victorian Government received permission from the Federal Environment Department to increase the dredging depth at Lakes Entrance (the entrance to the Gippsland Lakes RAMSAR zone).

This permission allowed the dredging depth to be increased to 5 meters from 2.5 meters.
As this dredging is effectively sand mining it comes within the scope of this enquiry.

The effective doubling of the Lakes entrance bar depth to 5 meters is having a dramatic effect on the Gippsland lakes RAMSAR zone with ocean fish species now being seen deep inside the lakes.

The most evident species are sharks and rays in areas that were previously brackish or fresh.

There is an urgent need for a salinity barrier to stop this incursion.
This barrier should have been a condition of EPBC 2011/5932 and the failure to put this condition into EPBC 2011/5932 will probably leave the Commonwealth exposed for some or all of this cost.

2(b) The adequacy of existing regulatory, policy and institutional arrangements to ensure adequate and timely rehabilitation.
Looking at the Victorian experience and talking to communities across Australia who contact me via the UNEP mercury partnership process, I would express the view that the whole mining process across Australia is slanted towards mine management and shareholder returns.

Regulatory, policy and institutional arrangements are something that should be carefully avoided unless the regulators start to take legal action.
2(c) The adequacy and transparency of financial mechanisms, including assurances, bonds and funds, to ensure mining and resource projects are rehabilitated without placing a burden on public funds.

The key issue is that most mines across Australia operate on very slim margins and it is very rare to see a set of mine accounts that present an accurate picture of likely long term mine remediation costs.
Victoria for instance has in excess of 30,000 historical gold mines that have not been remediated and all of these mines have legacy issues with mercury and other carcinogens.

26 of the 29 River catchments in Victoria are mercury and arsenic polluted due to hard rock and alluvial mining.

If you look at the situation with the GBM/Unity mine in Bendigo the depth of the problem become immediately apparent.
The Victoria government is believed to have control of a $A 6 million remediation Page 4 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 bond for this mine.

As discussed in a previous part of this document, estimated remediation costs for just the Woodvale evaporation ponds will be in the region of $60 to $100 million.
Then you have the Unity Mining site in Bendigo itself and there is not yet even an estimation of remediation of this mine site which is heavily polluted with Mercury, Arsenic, Cyanide, Lead, Cobalt, Vanadium, Barium and Thorium and probably more would be found if there was ever proper analysis of the site.

As discussed previously, the Stawell gold mine has a massive toxic tailings dam that is already leaking.
The State Mining regulator apparently has a $6.4 million bond and current estimates are that this would only allow maintenance of just the tailings dam for about 3 years.

The Stawell community wonder how or if the cleanup will be conducted once the inevitable tailings dam failure occurs.

The Commonwealth’s prevarication on PFOS remediation of defence bases is causing concern in rural communities where major mines are at a point where their resources are exhausted.
The Stawell community believe that when the tailings dam fails, all the agricultural areas will be left in what will become a carcinogenic metal waste dump extending for some 60km.

I am sure that during your enquiries you will find similar situations in every State.

I would ask that an outcome of your enquiry should be a recommendation that a national remediation pool be established.
2 (d) The effectiveness of current Australian rehabilitation practices in safeguarding human health and repairing and avoiding environmental damage.

Since 1966, I have never seen a properly remediated end of life mine in Victoria.

The common practice is to put a mine on “care and maintenance” and then look to divest the asset during the next peaking of the mining cycle.

It is important to note the very long mine life of the very rich mines such as Broken Hill, and Kalgoorlie.
The NEPM Health Based Investigation levels in Australia are dramatically out of step with international best practice (USEPA).

Attachment #1 to this submission shows the relative NEPM/ADWGL standards for soils and drinking water compared to USEPA standards.

I have yet to deal with an EPA or Mining Regulator in Victoria that has any knowledge of the very low airborne carcinogenic trigger points for many of the metals usually found in mine waste dumps.
In 2012, Victoria changed the legal status of mercury from being an element to being a mineral to avoid having to address the issues across the State with mercury at abandoned mine sites and the downstream waterways.

A very senior officer of the Victorian EPA told me that mercury did not have a gaseous phase and that its metallic form was harmless in the environment.
It is common practice for mines in Victoria to use plastic funnels and used wine bottles to collect dust samples at statutory measuring points around the mine site.

Every month the bottles are collected by the mine (a conflict) and sent to the mines own chosen laboratory where the samples are cremated at about 850 degrees centigrade to “remove carbon, bird poo and water from the samples”.
The laboratory then analyses the cremated remains and many of the carcinogenic metals that have low vaporization temperatures (e.g Arsenic chloride) have Page 5 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 disappeared.

The mine then chose perhaps 4 or at best six of the metals in the analysis to report to the residents at the ERC meetings.
The laboratory process to test these metals test for 17 metals at the one time and this analysis is never presented to the residents.

So you commonly see areas that have apparently been remediated within the mine site where dust is blowing of the remediated area and is clearly being picked up by the boundary sampling bottle/funnel test points.

There have been a number of incidents in Victoria where Vanadium was known to be in the ore body but the mine was not reporting it in the dust sampling.
(I see common reporting of Vanadium levels in Asia even in the poorer parts but I have never seen a mine report in Victoria that show Vanadium levels).

USEPA has list of Airborne toxicants which identifies Arsenic as a carcinogen at a level of 0.00065 micrograms per cubic meter of air (ug/m3).

Vanadium is at 0.00034 ug/m3.

When you consider that Vanadium levels in many auriferous (gold) ore bodies are often 8 to ten times the Arsenic levels this represents a major risk to workers and the community.
2 (e) The effectiveness of existing abandoned mine programs, with regard to repairing environmental damage and safeguarding human health.

I was the manager of the only Federally permitted catchment scale remediation project (EPBC 2010/5477).

This project was for the Upper Goulburn River in Victoria.

This river catchment was and still is a major gold producing area in Victoria.

This was the first EPBC clearance issued for a catchment scale remediation project.
The project was approved by the Commonwealth and approved by Vic EPA.

A month after the project was approved and the investors had contributed the working capital, there was a change of Government in Victoria.

The investors who contributed capital were investors who had an interest in mine site remediation and had been long term mining industry investors.
We had started field sampling work in the catchment when we were summoned to the offices of the Government Department (DSE) that controlled the polluted area.

2 (f) Whether any mining or resource companies have engaged in conduct designed to avoid fulfilling their rehabilitation obligations.

I can speak only of Victoria in the Australian context.

The historical gold mines were almost always abandoned when the ore ran out or the gold price collapsed.
In catchments such as the Upper Goulburn, there has not been any rehabilitation requirements until the last 20 years.

The recent developments at Stawell will be watched with interest as the enormity of the rehabilitation task is well beyond the capital resource of the company.

Unity Mining at Bendigo has recently made public comments that would indicate it is in a process to try to avoid the massive rehabilitation liabilities.
2 (g) The potential social, economic and environmental impacts, including on matters of national environmental significance under the EPBC Act, of inadequate rehabilitation.

There is about 110 years of social, economic and environmental effects of gold mining in Victoria.

These effects are caused by the use of mercury as an amalgamation tool in mining from the very start of mining in the state.
Page 6 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 Our work to date indicates that there are about 30,000 historical mines in Victoria that need assessment along with the associated river and stream catchments.
The imminent ratification of the Minamata Convention on mercury is going to cause the Victorian government to face some time lines on how much longer the State can allow the massive tonnages of mercury lost by the mining process to remain in the environment.

2 (h) The potential social, economic and environmental benefits of adequate rehabilitation, including job opportunities in communities affected by job losses in the mining and resource sectors.
The social impacts of removing legacy gold mining mercury from the environment are well known and understood and this recognition has flowed into the Minamata Convention on Mercury.
If you use the USEPA published data for mercury emissions from coal fired power stations (Driscoll et al) and apply that data to the Victorian population base the result is a very safe assumption in Victoria at the moment about 20 babies a day are being born at risk of impaired neurological development due to exposure to mercury in the Womb.
From our work in heavy metal testing at abandoned mine sites across Victoria, it is very clear that the historical miners were recovering only gold from the ore bodies as they did not have the technology to recover other valuable metals that were incorporated in the same ore bodies.

Remediation of abandoned historical gold mines across Australia has the potential to be the largest new employment project ever.
In many areas this work will, for the first time, create long term employment for indigenous Australians in or close to their homelands.

The bulk of the skills for this work already exist in the Mining Industry as does all but the specialised mercury recovery equipment.

In addition, Australia has the opportunity to create a major export industry for the supply of the equipment to remediate mine sites and industrial sites across Asia.
Victoria has just closed down the Hazelwood Power Station with significant job losses, the saw mill at Heyfield is in the process of shutting down due to a lack of timber resources coupled with wild fire losses.

The Gippsland lakes are heavily polluted with mercury and other carcinogenic metals which are a legacy from earlier gold mining operations.
Six of the seven major river system flowing into the Gippsland Lakes are mercury polluted for historical gold mining operations, power stations and the ChlorAlkali plant at APM Maryvale.

In the Upper reaches of the Thomson river sits the historical gold mining township of Walhalla.

Very conservative assumptions based on published historical data indicates that a in the region of 4,000 tons of mercury was lost into the environment at this site.
2 (I) International examples of effective rehabilitation policy and practice.

Both the USA and the EU have numerous examples of mercury polluted sites being rehabilitated to make them safe.

California has a major project underway to remediate historical gold mining areas - many of these areas are similar to mining areas in Victoria.

The Author of this document has been involved in remediation of a number of 8th to 12th century Chinese gold mines.
In the mid 1990's I walked down a valley in tropical Asia that had been impacted by a 12th century gold mine.

This valley had not had a full term live mammalian birth for Page 7 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 over 300 years due to gaseous and methyl mercury pollution across all the food chains in the Valley.
Once special pumps were imported over 200 tons of mercury with a gold content of an average of 9% was recovered from the deepest pool in the downstream river.

After 15 years work this valley now supports a small elderly farming community.

The valley will never support a normal self replicating community.
At the small scale end of the remediation spectrum there is a least 1 Australian with the skills and competency to make mercury recovery equipment that can be used in the most basic of third world societies and to teach the equipment recipients how to use this equipment.
With the Minamata Convention coming into force globally in the next year and an increased focus on heavy metals and chemicals in export foods, Australia really needs to create a number of centers of excellence to train the people who over the next 50 years will lead the way in removing this highly toxic metal/gas from our environment.

2 (j) Proposals for reform of rehabilitation of mining resource projects.
In 2009 I took the personal risk to establish a catchment level mercury remediation project in Victoria.

I know the particular catchment very well as I had led a team of SES volunteers in the late 1980's to assess all the abandoned mines in this catchment with a view to preventing further accidents involving artisanal prospectors.

During this period, I was SES mine rescue co-ordinator for Victoria and I led the response to Long Tunnel mine accident at Walhalla earlier in the decade.
The incumbent Brumby Government was keen for this pilot project to go ahead because as a Government they had a good understanding of the issue with abandoned mines and the feral toxic metals that these mines contain.

I built the business plan, with the help of VicEPA we went through the controlled actions approval process and developed the operations manual for the project - the first manual of its type in the World.

VicEPA graciously made their offices available for viewing the EPBC permit documents.
Following the change of government to a liberal Government in late November 2010, the polluting government agency that controlled all the mine sites (DSE) decided that our project should be shut down and I was privately told the Government did not want the community to know the true extent of the problems with mercury and other carcinogenic metals.

This was a unique situation in that DSE was and still is one of the largest individual toxic metal polluters in the World.
The project had the required federal permit, it had VicEPA clearance to do the work, a clearance backed by 3 VicEPA reports from the 1970'/80's that urged urgent remediation of this catchment.

Myself and the project technical director attended a meeting at DSE that had 9 DSE people in attendance.

We were told that: 1.

2.

3.

4.


We would have to conduct a full public EES for every individual site in a river, stream or mine site we even walk into; We would have to pay an “access fee” every time we took a soil or water sample and pay these fees monthly to DSE.

That we were not to damage any “forest product” or use roadways or track in DSE property.
That the EPBC permit had no basis in law and that DSE would never allow Page 8 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 any person to gain an understanding of the extent of toxic metal pollution in this catchment.
By the time we had meet these emissaries of the new government we had already raised funds from a group of ethical mining investors and started a heavy equipment procurement process.

I sought advice from a leading QC (now a judge) on the issue and was advised that what DSE was doing had no basis in law, that DSE were the polluter and effectively they were conducting a large scale cover up.

We kept sampling in the catchment and the results were very alarming.
We were finding levels of mercury in stream sediments that were similar to the California gold fields, the fish and crustaceans were polluted with both mercury and Arsenic.

One particular mines crusher fines pile that had been exposed for over 120 years still had a level of mercury over 100 times the USEPA industrial soil limit.
The house that we had bought as a base camp was being watched, and the local Council tried to prosecute us for conducting a business in a residentially zoned house - when this came to a climax the Council officer admitted they had been subject to pressure from the Victorian Government Solicitors Office.

If this ruling had been allowed, then every farmer in the Shire would not be able to do farm book work in their farm residence.
The prosecutions officer from DSE contacted me and demanded that I meet his officer the next day for an interview.

The next day on a remote country road, 3 DSE officers, I of whom was carrying a handgun, proceeded to interview me under formal caution for the offence of damaging forest product - blackberry vines on a track.

In the end I got a formal caution for this ‘offence’ and was told that if I cut or damaged blackberries again they would be seeking a jail sentence.
The then Deputy Victorian Government Solicitor (VGSO) persuaded the VicEPA to delegate its powers in this matter to his office.

The EPA could delegate its powers to what were called protection agencies but the VGSO was not a protection agency.

The irony was that Hg Recoveries was a protection agency under the Act.

I wrote up a brief of evidence for misconduct in public office by the EPA Chairman, the EPA CEO and the Deputy Victorian Government Solicitor.
I submitted the brief to the Chief Magistrate and he suggest some minor changes and then authorised the brief.

I served the summonses once a day for a committal mention hearing was set.

At the committal mention hearing, a solicitor acting for the Director of Public Prosecutions (DPP) stood up and tried to take over the cases and discontinue them.

The magistrate would not allow this because of the obvious conflict that the DPP had with the charges involving the Deputy Victorian Government Solicitor.
It took two more hearings before the Magistrate was forced to concede that the DPP could act under State law even with such a blatant public health risk conflict.

At this point it was decided to shut the project down, we had lost in total about $8.2 million in cash expenses and had about $61 million in demurrage and force majeure claims outstanding.
With the State Government prepared to act in a gross conflict situation to prevent the extent of historical mine pollution becoming public, there was no obvious way forward until such time as the Minamata Convention came into force globally.

2 (k) Any other related matters.


Page 9 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72 The Minamata Convention present some major skills export opportunities for Australia as long as Australia does in fact ratify the convention.
It seems unclear at this time that Australia will ratify the Convention in a timely matter and this failure may mean that Australia cannot sell its existing mercury remediation technology.

I have been working with the UNEP for the last 11 months to write a remediation manual for the Mercury based ChlorAlkali plants across Asia.

There are large numbers of these plants in Asia along with mercury based PVC plant sites.
ChlorAlkali plant sites are very expensive to remediate often in the region of $US 250 million to $US 350 million.

Whilst Prime Minister Turnbull gave me an assurance in public in 2012 that “any government that I lead will immediately ratify the Minamata Convention” I am not sure that the Prime Minister will honour that undertaking.

Australia has a good core skill set in mine remediation almost totally focused towards very large mines with EPBC responsibilities.
This core skill set needs to used to develop skills and methods to remediate historical mines and to remediate small to medium size abandoned mines.

I look forward to being able to answer any further questions that the Inquiry may wish to ask me.

Your Sincerely Andrew G. Helps Page 10 Document 8109 10/4/2017 AUSTRALIAN SENATE SUBMISSION Rehabilitation of mining and resources projects as it relates to Commonwealth responsibilitiesSubmission 72