5 Discussion 5.1 Level of current impact on the environment While knowledge gaps exist in relation to a number of pathways and stressors (eg organic toxicants), based on current scientific knowledge, there is no evidence to suggest that any of these pathways are resulting in adverse ecological impacts on the off-site environment within the ARR (ie outside of the Ranger mining lease) during the operational mining phase at RUM. Subtle biological responses of freshwater snails observed in in situ toxicity monitoring tests in Magela and Gulungul Creeks downstream of the mine (ie enhancement of egg production) continue to be investigated (Humphrey et al 2013). Macroinvertebrate communities in Georgetown Billabong appear to have been adversely affected since 2009 by increased concentrations of MgSO4 arising from the mine. This billabong, however, lies within the mine lease and in close proximity to the minesite. Notwithstanding the lack of evidence of adverse off-site impacts, there is an ongoing need to provide reassurance to key stakeholders and the broader community in relation to the actual nature and level of risks posed to the environment by current uranium mining activities and how the various mitigation measures being implemented by the mine operator are effectively reducing these risks to acceptable levels. The conceptual sub-models and narratives will assist in this ongoing task. 5.2 Existing and emerging knowledge needs As a result of this work, a number of and new/emerging knowledge needs for various stressor pathways associated with the operational mining phase at RUM were identified. Most of the existing knowledge needs have been identified as a result of recent research and monitoring, and are included in ARRTC’s 2008-2010 KKNs document. New and emerging knowledge needs are listed in Tables 5.1 and 5.2. For example, there is currently limited knowledge regarding the extent to which various organic toxicants on the minesite, particularly hydrocarbons and volatile organic compounds, may be transported off the mine site by surface water and groundwater pathways, and also the potential effects of these toxicants on biological receptors. The mine operator undertakes only extremely limited measurements of organic toxicants as part of current surface and groundwater quality monitoring on the mine site, while the Supervising Scientist Division has never monitored these toxicants. There has also been little work undertaken on possible effects of organic toxicants on biota. Areas of significant organic contamination (mainly hydrocarbons) are known to occur on the mine site (Hollingsworth et al 2005). While issues such as soil contamination on the mine site are generally seen as being more relevant to the mine rehabilitation phase, there could be potential for organic toxicants from these areas to be transported off the mine site by various pathways during the operational mining phase, and this may warrant further investigation. Table 5.3 summarises the information collated in Tables 1 and 2, and the knowledge gaps detailed in Section 4 on a KKN (current operations phase KKNs only) basis. A further emerging knowledge need identified during this work relates to the determination of potential impacts of ionizing radiation on non-human biota within the ARR. While previous work has been undertaken by the Supervising Scientist in relation to the bioaccumulation of radionuclides in mussels and other fauna and flora, this work has mainly focused on potential ingestion doses to human receptors. Historically, radiation protection has focused on impacts 146 to workers and relevant off-site human receptors. However, there has been a move away from radiation protection being solely anthropocentric and it is now accepted that there is a need to demonstrate that non-human biota are protected against ionizing radiation risks from radionuclides released to the environment by human activities including mining. This has been recognized internationally by the International Commission on Radiological Protection (ICRP 2007, 2009) and the International Atomic Energy Agency (International Atomic Energy Agency (IAEA) 2006, Howard et al 2012), and nationally by the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) (Doering 2010). The need to better understand the potential impacts on biota associated with mine-derived radionuclides within the ARR has also been recognised by the Supervising Scientist (International Atomic Energy Agency (IAEA) 2003) and more recently by ARRTC. An ongoing research project is examining the existing flora and fauna data for their fitness of use for environmental radiation dose assessment. In addition, the ARPANSA and the Supervising Scientist Division are jointly examining the implications of the need to demonstrate that the environment is protected from the harmful effects of ionizing radiation in an Australian context. A number of new knowledge needs were also identified in relation to the transport of weed propagules via surface water, atmospheric and human and non-human pathways. Weeds are a key issue for the operational mining phase as well as the post-mining (including rehabilitation) phases. The mine operator undertakes regular chemical control measures to limit the spread of weeds on the mine lease as well as annual surveys of the distribution and density of a number of priority weed species on the mine lease. Currently, however, there are no quantitative data on the spread of weed propagules either to or off the mine lease by the various transport pathways. The ongoing management of weeds on the mine lease is an important issue for both the operational and post-mining phases, and in particular, for the establishment of the final landform and associated ecosystem development. It is anticipated that these existing and new knowledge needs will be assessed as part of the review and revision of the ARRTC knowledge needs scheduled for 2012-13. Johnston & Milnes (2007) addressed six key issues when reviewing the mine-related research required to ensure protection of the environment throughout the operational and rehabilitation phases of mining at RUM. These issues were: Baseline research Surface water management Dispersion in groundwater Atmospheric dispersion Rehabilitation (physical components including surface hydrology, erosion and the dispersion of erosion products) Revegetation These key issues may potentially form the framework for modelling the pathways for the decommissioning and post-decommissioning phases of RUM. Radionuclide uptake by terrestrial animals and plants was identified in particular by Johnston and Milnes (2007) as a knowledge gap. Since then, the database on radionuclide uptake in terrestrial biota (the BRUCE tool) has been developed and the number of records significantly increased, which will enable the modelling of ingestion doses during the rehabilitation phase (Doering et al 2012). 147 5.3 Collation of information, and updating models and knowledge needs Collation of information from disparate sources was problematic during this project. Some information is in the ‘grey literature’ and studies undertaken by the mine that are not for public release. As a result, these types of information have largely not been taken into account, primarily due to the time and effort required to collate and document such information. Where information gaps were identified, a request was sent to ERA for information to address the gaps. For future conceptual models, screening ecological risk assessments and KKN review, a database of all literature relevant to each pathway and stressor should be developed and maintained in collaboration with ERA. As management practices change in an operational mine or post-mining landscape over time, conceptual models will become outdated. Similarly, as more research becomes available for pathways, stressors or receptors for which there were knowledge gaps, conceptual model updates may be required if key components are to change or the rationale needs to be reviewed (USEPA 1998). Further, additional sub-models may be required if key risks change. The spatial and temporal scale at which the conceptual models are developed will also determine whether updates are required. With increasing detail and numerous sub-models (as provided through this project) updates will be required more frequently if management practices change, compared with a higher level conceptual model. Since the commencement of this project on-site management at Ranger has changed, resulting in potential changes to stressor pathways. Conceptual models may be used to assess knowledge needs and establish research frameworks. This project has used conceptual models of stressor pathways and the ranking of importance of these pathways to undertake a gap analysis on the KKNs related to the operational phase of the minesite (Table 5.3). A similar process to identify knowledge needs for the post-mining phases of RUM should be undertaken and reviewed regularly as environmental conditions and management conditions change. It is suggested that the currency of the conceptual models for post-mining be a standing agenda item at ARRTC on an annual basis to ensure the research framework is adequately addressing knowledge needs. 148 Table 5.1 Gaps in knowledge about the importance of stressor-pathway combinations. ‘‘ and ‘‘ denote knowledge gaps associated with moderate uncertainty and high uncertainty in knowledge, respectively (summarised from Table 4.1). Stressors Inorganic toxicants Organic toxicants Radionuclides Pathways Surface water to surface water Airborne emissions Stormwater runoff from non-mine site areas of the lease Airborne dust and other particulates Radon-222 and decay products or progeny Transported sediments Weed propagules Exhalation and atmospheric transport of radon-222 and decay products 149 Surface water to groundwater Human and non-human vectors Land Application Areas infiltration and runoff Bioaccumulation and trophic transfer (terrestrial) NB: shaded cells represent combinations of stressors and pathways that do not occur. Table 5.2 Gaps in knowledge about the ecological impacts of stressor-pathway combinations. ‘‘ denotes a knowledge gap (summarised from Table 4.1). Stressors Inorganic toxicants Organic toxicants Radionuclides Pathways (biota) Surface water to surface water Airborne emissions Radon-222 and decay products or progeny Weed propagules Stormwater runoff from non-mine site areas of the lease Airborne dust and other particulates Transported sediments (biota) Exhalation and atmospheric transport of Radon-222 and decay products or progeny Surface water to groundwater 150 Human and non-human vectors (biota) Land Application Areas infiltration and runoff Bioaccumulation and trophic transfer NB: shaded cells represent combinations of stressors and pathways that do not occur. (biota) (terrestrial) Table 5.3 Gap analysis of Key Knowledge Needs for operational phase of RUM Phase Section Key Knowledge Need Status of knowledge 1.1.1 Surface water transport of radionuclides Adequate knowledge - water quality monitoring for radionuclides and the monitoring of radionuclide activity concentration in fish, mussels and bush foods is routinely conducted. Based on scientific research conducted over the past 30 years by the Supervising Scientist, the mine operator and others, a significant body of knowledge has been developed in relation to the main sources, transport mechanisms, and potential environmental risks associated with key mine-derived radionuclides via the surface water pathway. Knowledge Gaps: There is the need to explicitly include and assess the risk from ionising radiation to nonhuman biota, using existing SSD data. Adequate knowledge - Although airborne emissions of radionuclides other than uranium are not monitored directly, current air quality monitoring by SSD and ERA and ongoing research provide a high level of scientific certainty that radionuclides transported off-site via this pathway are not resulting in a detectable adverse effect on the environment in the ARR. 1 Ranger – Current operations 1.1 Reassess existing threats 151 1.1.2 Atmospheric transport of radionuclides Based on ongoing research, monitoring and associated modelling by both eriss and ERA, there is a high degree of scientific certainty that the radon-222 and radon decay products pathways are not resulting in adverse impacts on the environment or human health in the ARR. The monitoring of radon and dust exposure pathways has shown that the only significant contribution to radiological exposure of the public at Jabiru via inhalation is the inhalation of radon decay products. Although the contribution from the mine site has been shown consistently to be much less than the public dose constraint of 0.3 mSv per year and is of no concern according to current best practice standards, atmospheric monitoring will continue to provide re-assurance to the public that the risk from inhalation of mine-derived radionuclides remains very low. Phase Section Key Knowledge Need Status of knowledge 1.2.1 Ecological risks via the surface water pathway Adequate knowledge and further addressed through this project. 1.2 Ongoing operational issues 152 1.2.2 Land irrigation Knowledge gaps: There is currently no direct monitoring of weed propagule transport via the surface water to surface water pathway, stormwater runoff from non-mine site areas of the lease pathway, human and non-human vectors pathway, or from mine site waterbodies. Annual weed surveys by the mine operator provide data on the distribution and density of weeds on the mine lease. However, little if any data exist on the volume of weed propagules present in the seed bank on the mine lease or the quantity of weed progagules being transported on and off the mine lease via various pathways. Other knowledge gaps listed below relate to this KKN also. Adequate knowledge - ongoing surface water and groundwater quality and biological monitoring indicate with a high degree of scientific certainty that inorganic toxicants and radionuclides transported via the Land Application Areas infiltration and runoff pathway are not resulting in detectable adverse environmental impacts in the ARR. 1.2.3 Wetland filters No knowledge gaps were identified through this assessment. 1.2.4 Ecotoxicology Knowledge gaps: There is limited knowledge regarding the potential effects of suspended particulate matter on the biota within surface water systems downstream of the mine site. A field research project is underway to assess the indirect effects of turbidity on phytoplankton communities in Georgetown Billabong. However further quantitative data for other taxa groups are required. 1.2.5 Mass balances and annual load limits Adequate knowledge - mass solute balance model and review of annual statutory load limits for key mine derived inorganic toxicants has been developed (Turner & Jones 2010). Phase Section Key Knowledge Need Status of knowledge 1.3.1 Surface water, groundwater, chemical, biological, sediment, radiological monitoring Adequate knowledge - Turner and Jones (2010) confirmed with a high degree of confidence that the routine water quality and bioaccumulation sampling programs conducted by SSD in Magela and Gulungul Creeks are not omitting any metals that could potentially be of concern from either toxicological or bioaccumulation perspectives. Although toxicants entering surface waters from non-mine areas of the lease are not directly measured/monitored, the comprehensive surface water quality and biological monitoring programs in Magela Creek and Gulungul Creek incorporate potential inputs from the inorganic toxicants potential transport through the stormwater runoff from non-mine site areas of the lease pathway. Knowledge gap: The limited chemical monitoring of organic toxicants means that the level of scientific certainty regarding the actual levels of organic toxicants in the surface and groundwater systems downstream of the mine site is relatively low. - The mine operator only undertakes measurements of total petroleum hydrocarbons in RP2 as part of its on-site surface and ground water monitoring program. However, it has undertaken several studies of contamination, including organic toxicants, in soil and groundwater around the plant area. 1.3 Monitoring 153 6 Summary The main objective of this project was to assess eriss’s knowledge base in relation to stressor pathways applicable to the operational phase at RUM, and in doing so, produce a gap analysis which can inform future KKN reviews. A secondary objective of this work, providing a screening level assessment of the importance of stressor pathways, is to support the future development of a risk-based framework which could be used to prioritise future eriss minerelated research and monitoring. Key to this project was the review and collation of current scientific knowledge of stressor pathways associated with uranium mining at RUM including the results of past and current scientific research and monitoring undertaken by the Supervising Scientist, ERA and others. The knowledge base within eriss dates back to 1978. Collation and review of the associated material (reports and scientific papers) and eriss researchers’ understanding of stressor pathways relevant to their disciplines of study was a significant component of this project. In finalising the stressor pathways conceptual model for the operational mining phase at RUM, a number of tasks were undertaken: The stressor pathways conceptual model and associated sub-models for the operational phase of mining at RUM developed by van Dam et al (2004) and refined by van Dam and Bayliss (2010) were reviewed and updated. This review resulted in the identification of 32 sub-models for stressors and their associated pathways. Nine pathways (i. Surface water to surface water; ii. airborne emissions; iii. radon-222 and radon decay products; iv. stormwater runoff from non-mine site areas of the lease; v. airborne dust and other particulates; vi. surface water to groundwater; vii. human and non-human vectors; viii. LAA infiltration and runoff; and ix. Bioaccumulation and trophic transfer) and five stressors (inorganic toxicants, organic toxicants, radionuclides, transported sediments and weed propagules) were identified. Sub-models for the 32 stressor pathways were developed. This involved a significant change from the conceptual models developed by van Dam and Bayliss (2006). A 3-D perspective of the conceptual landscape of RUM was constructed. This enabled the direction of stressors from source through the environment to relevant biological receptors to be shown. Additionally, groundwater was added as an environmental compartment in the models. Supporting narratives for each stressor pathway sub-model were compiled which: describe the various model elements and their relationships and linkages to current chemical and biological monitoring activities; and document current scientific knowledge, certainty, level of impact and associated knowledge gaps. A screening level assessment of the importance of each stressor pathway was completed. Each stressor pathway sub-model was assessed in terms of its inherent environmental risks based on the size (volume/rate of release) of stressor sources on the mine site and the maximum (load) capacity of pathway mechanisms to transport these into the offsite environment. Five of the 31 stressor pathway sub-models were assessed as being of high importance during the operational phase of mining (inorganic toxicants surface water to surface water pathway; inorganic toxicants airborne emissions pathway; radionuclides surface water to surface water pathway; radon-222 and radon decay products pathway; and transported sediments surface water to surface water 154 pathway). For four of these five pathways the available comprehensive monitoring data indicate no detectable impact on the environment outside of the mining lease. For the case of the remaining pathway (inorganic stressors- airborne emissions) and impact on biota from the radon-222 and radon decay products pathway it was judged that there was insufficient evidence to say that there was no measurable environmental impact. A gap analysis of eriss’s knowledge base in relation to stressor pathways and KKN framework was carried out. The assessment identified some knowledge gaps which may be fed into the ARRTC KKN framework following further consideration. Key amongst these was a lack of knowledge about the fate of organic contaminants, for example, hydrocarbons and pesticides used on site; and inorganic contaminants from the mine site stacks, storage tanks and pipes. The specific issue for the organics is that these species have not been analysed, even at a screening level, in the water that exits the site. Hence no specific assessment can be made about potential for impact, despite this likely being a no or low impact issue. In the case of the inorganic contaminants, emissions from the stacks are monitored by ERA. One additional factor that could also warrant closer attention is the potential for transport of weeds off site, despite the existence of an active weed identification and control program. The range of relevant mitigation measures implemented by ERA to control and reduce potential risks to receptors associated with these stressor pathways was included in each sub-model narrative. While knowledge gaps exist for some pathways and stressors, there is no evidence to suggest that any of these pathways are currently resulting in adverse ecological impacts on the environment within the ARR. Results of ongoing chemical, radiological and biological monitoring undertaken by the Supervising Scientist continue to show that the environment of the ARR remains protected from uranium mining related impacts via the aquatic pathway (the dominant potential vector) and from airborne radionuclides in the case of human health protection. The stressor pathways conceptual models developed by this project, and the associated risk analysis, will assist in communicating the actual level of significance of these pathways to key stakeholders. A related but separate task will be to develop models of the stressor pathways uniquely associated with the mine closure and rehabilitation phases of mine life. This closure pathways conceptual model will inform and assist the development of closure criteria and the specifying of the monitoring framework needed to address them. 155 References Akber RA (ed) 1992. 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