Submission: To the Chair and Members of the Goschen IAC Panel

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Our initial advice to the panel is that the proponent has provided a narrative which is inconsistent across the various Technical Reports they have exhibited.

There is some useful information, or in some cases data, in some individual Technical Reports.

However, where a Technical Report includes a description of the project, or the description of a part of the project, that description may be immediately in conflict with the project description in an adjacent Technical Report.

It is reasonable to conclude that the author of a Technical Report may have created their own narrative for the project where the proponent has failed to reasonably describe the project to the consultant who prepared the Technical Report.

The description of the project, as best as it might be interpreted from the Technical Reports, or is otherwise described in the exhibited documents, is unclear.

This project description, again, is substantially different to the project described in the company prospectus lodged with the ASX.

The project description in various marketing documents (which also includes statements by the CEO), yet again provides further alternate descriptions of the project. These further alternate project descriptions include a relocation of the mine pits from Areas 1 and 3, as described in the exhibited documents, to Area 4.

The rationale for the pit relocation is that the recently re-evaluated ore body in Area 4 will provide for “a quicker cash return”. The CEO describes that the opportunity will be taken to “follow the line of strike”.

This alternative project description also includes descriptions or comments on various forms of processing plants to separate rare earth concentrates. The separation of a rare earth concentrate requires construction of a complex and substantial industrial plant which incorporates advanced technologies and is not, at this stage, common in the Australian industry.

Background of Mining in Victoria

The industry in Victoria is currently in a low phase which will likely see the cessation of the mining of traditional minerals. The costs of the inputs to mining, that is electrical energy, diesel fuel, ANFO (explosive) and labour have increased exponentially since Covid-19.

• In 2024 it is now more expensive to conduct mineral sand mining as most of the
  shallow, easily accessible ore bodies with low strip ratios are now depleted and mining
  now requires comparatively deep excavations. Deeper excavation generates an increased cost for stripping along with the increased cost to manage the drying of
  tailings returned to deeper pits.
• ERR have progressively withdrawn most of their regional staff over the last decade.
  ERR are now in effect a Melbourne based bureaucracy with very few competent staff
  that have the ability or knowledge to engage with field operations at a mine site.
• In 2020, the Victorian Auditor General’s Office (VAGO) released a report into mine
  rehabilitation. Rehabilitating Mines | Victorian Auditor-General’s Office This report
  concluded that negligible rehabilitation activity has occurred at mine sites in Victoria
  and that bond monies are not well managed.
• An issue that was not addressed by VAGO is that the assessment of the quantum of
  bonds is very much left to the industry rather than ERR or an independent assessor.
  The BDEC estimate that bonds as assessed could be considered as falling between
  5% and 10% of the realistic amounts that would be necessary to achieve rehabilitation.
  ERR are rarely able to demonstrate the recovery of bond monies after the failure of a
  mining company. The most recent example are the four sites abandoned by the
  Bendigo mining project.
• Examination of the GeoVic website pages, which lists companies and bond
  determinations, suggests a history of actions by ERR to manipulate the bond liability
  before companies to reduce the financial stress on those companies.
  https://earthresources.vic.gov.au/__data/assets/pdf_file/0004/580180/Earth-
  Resources-Regulation-Rehabilitation-Bonds-Held-as-at-20200729.pdf
• It is uncommon for ERR or EPA to take effective compliance action against a mining
  company for failure to manage air, surface or groundwater pollution.
• The State budget for 2022/24 includes $52 million for the management of discharge
  to surface of mine water polluted with heavy metals at Bendigo. Industry welcomes
  state government funding to fix Bendigo’s rising groundwater problem | Bendigo
  Advertiser | Bendigo, VIC
• The three respective mining companies whose mining operations have contributed to
  the discharge of polluted mine water have walked away without attracting any financial
  penalty by ERR. Conversely, it is not uncommon for ERR to use State financial
  resources while involved in legal disputes over the ownership or recovery of mining or
  exploration licences.
• ERR have established memorandums of understanding with the EPA and other
  mining regulators within Victoria to as much as possible exclude those regulators from
  entering a mine site without ERR’s agreement.
• Mining Quarry operations in Victoria are in a different economic situation and will
  continue at an increased pace to support the State’s program of infrastructure
  development which includes roads, railways, and the built environment.
  4
  The BDEC requests the panel now consider the following five significant matters:

1. The Commonwealth Critical Minerals Strategy and Sovereign Risk.
2. Planning matters with respect to the Victorian Planning and Environment Act 1987, the
   MSDR Act 1990 and other planning controls.
3. Economic Sustainability of the Project.
4. Management of Mine Pits and an informative draft Work Plan.
5. The risk to Human Health from Radiation.
6. Commonwealth Critical Minerals Program and Sovereign Risk
   VHM have established a marketing agreement with Shenghe, a government owned refinery
   in China, to accept 60% of VHM’s production for the first three years.
   https://www.greencarcongress.com/2023/01/20230116-shenghe.html
   VHM_Prospectus_Shenghe_Announcement
   Export of product to China for the refining of Rare Earths is in direct conflict with Australia’s
   critical mineral strategy. Aust_Gov_CMStrategy_national_interest
   https://www.industry.gov.au/publications/critical-minerals-strategy-2023-2030
   The_Australian_Astron_marketing_uranium
   5
7. Planning matters with respect to the Victorian Planning and Environment Act
   1987, the MRSD Act and other planning controls.
   In Technical Report K, Land Use and Planning, the consultant AECOM, on behalf of the
   proponent has identified some of the various Acts and Regulatory Controls that would relate
   to this project.

• AECOM however has failed to identify further Acts such as the Commonwealth Climate
  Change Act 2022 and the Victorian Climate Change Act 2017.
  Several VHM Technical Reports, and separately the 2023 VHM prospectus describe various
  iterations of an extensive and technically complex industrial plant for the separation of rare
  earths and the manufacturing of several additional products. VHM, their consultant AECOM,
  and other parties in various reports seek to make the claim that the holder of a mining licence
  is exempt, under the MSDR Act 1990, from the planning controls that might otherwise apply
  under the State Planning Act 1987.
  By this claim AECOM seek to diminish the objectives of (a) to (g) of the Planning and
  Environment Act 1987.
  On page 11 of the Technical Report K, the land use assessment requires that the risk of loss
  of farmland is assessed if there are multiple developments in the region. There are at least
  six mineral sand/rare earth separation mining projects at various stages of planning/permitting
  within the Mallee/Wimmera cereal cropping region. When the VHM project is added this
  would have a cumulative effect causing a greater overall loss of farmland.
  Additionally, there are some dozens of exploration licences which have current field activities
  seeking to quantify mineral sand reserves which may again risk further farmland loss.
• VHM/AECOM have failed to prepare the required land use assessment.
  Specifically, the MRSD Act permits the taking and processing of ore without the controls that
  would normally be applied in the Planning and Environment Act 1987. However, much of the
  activity that occurs in the area that AECOM has described as the processing plant is that of
  an extensive, complex, and highly industrialised plant for the various stages of refining and
  manufacturing rare earths and rare earth concentrates. This activity is not simply the
  processing of ore by milling and chemical leaching as occurs in traditional mining but is
  significantly the refining of a product, supplied by mining companies, in a complex industrial
  plant. Therefore because of the complex interactions that a refinery can have with the
  surrounding environment, with at least eight waste streams including a radioactive waste
  stream, this proposed plant needs to be permitted under the controls of an industrial zone as
  described in the Planning and Environment Act 1987.
• AECOM have avoided a discussion in regard to the planning control that would be
  required for a separation plant of the scale proposed by VHM.
  6
  The MRSD Act 1990, in Section 14.4, describes that a Mining Licence is restricted to a
  maximum land area of 260 hectares (one square mile). This historical clause is designed to
  constrain a mining development to a defined area and so restrict the ultimate area of polluted
  land and the cost of rehabilitation. An example of the failure of the regulator, ERR, to manage
  this requirement of the act is found at the abandoned Bendigo Mining project, which over 4
  sites has now consumed approximately 4 km2 of residential and farm land.
  The_Kangaroo_Flat_Gold_Mine_Bendigo
  A further example is the operational Fosterville gold mine which has now, without ministerial
  approval, extended to consume approximately 28 km² of high value farm land.
  An examination of legacy mineral sand mine sites in Victoria suggests that most sites have
  extended into an area which is a multiple of the permitted 260 hectares without regulatory
  control and most exhibit limited rehabilitation. Pit_23_Balmoral_Western_Victoria
  There is no evidence that VHM have made an application to the Victorian Resources Minister
  to seek an exemption from Section 14.4 of the Act or that an exemption has been granted.
  7

1. Sustainability (economically) of the Project
   The proponent on this occasion has failed to provide sufficient advice to demonstrate that their
   project will be sustainable (economically) as is a requirement of the MRSD Act 1990 section
   15 (6b).
   Without a demonstration of economic sustainability, the community can hold no assurance
   that those actions required by the proponent to avoid or mitigate negative environmental
   outcomes over a proposed 20-year project life could be supported by the proponent or that
   the site would be rehabilitated.
   The proponent has provided an economic assessment by the company Deloitte.
   https://www.vhmltd.com.au/wp-content/uploads/2023/11/Attachment-IV_Economic-
   Assessment_Exhibition.pdf
   Deloitte has employed pseudo economics in the preparation of this assessment.
   Deloitte’s assessment fails to provide a balanced descriptive model of the company’s proposal
   and fails to follow the established norms of accountancy.
   Specifically, the Deloitte assessment:

• Does not address the risk that the Commonwealth will legislate to force compliance
  with the Critical Minerals Strategy and therefore deny access to the proponent’s market
  in China for rare earths.
• Does not provide an offset for the substantial risk that high production value farmland
  will be lost for cereal production into perpetuity.
• Does not consider the risk that China could periodically deny access to China for
  Australian mineral product as they have done previously with coal, iron ore and
  agricultural products.
• Overestimates the value of income derived from HMC by valuing zircon as first grade
  zircon, rather than the zircon at Goschen which will be downgraded as it is polluted
  with chromium and radionuclides.
• Does not provide offset costs for reconstruction of minor and major roads after road
  transport operations cease. Road reconstruction will likely be a requirement by local
  and state government.
• Does not allow for the extended periods of production loss when drought has denied
  all licence holders access to water.
• Does not allow for loss of production when mining activity is compromised by mine pits
  which have suffered water entry from creek or riverine flooding.
  8
• Has not adjusted the project income for the long-term decrease in zircon value.
  Zircon_sand_pricing
• Has not adjusted income for losses caused by logistical delays when road and rail
  routes are congested by grain exports, or if there are delays in shipping of HMC due
  to congestion on common transport routes that are used by competing mineral sand
  mining projects.
• Has not adjusted for loss when the Port of Melbourne has been unable to provide
  sufficient container capacity due to seasonal agricultural production or because there
  is competition for storage capacity with other mineral sand mining companies.
• Has not described the cost to establish carbon offsets for the company’s carbon
  footprint as will be required in 2030 and 2035 under the Commonwealth and State
  Climate Change Acts respectively.
• Has not correctly assessed the capital cost of an extensive and complex processing
  plant to separate rare earth concentrate, and additional products.
• Has not allocated a credible cost to the lodgement of a bond for mine rehabilitation.
  Iluka have a similar scaled proposal to VHM’s proposal near Horsham. In a report to
  investors Iluka allocated $460 million in their costings for site rehabilitation.
  Iluka_rehabilitation_cost
  It can be demonstrated that ERR as the industry regulator have failed at the task of
  determining the economic sustainability of mining companies in Victoria as a pre-requisite
  before issuing a mining licence. ERR’s assessment is not transparent to the public. Consider
  the current economic circumstance of each these significant mining companies in Victoria:
• The Bendigo Mining Project gold mine has been abandoned for more than a decade
  without rehabilitation and ERR have been unable to locate the bond money that was
  originally lodged by the mining company for rehabilitation.
• The Latrobe Valley coal projects have either closed or are winding down and ERR
  have been unable to negotiate a closure model with the companies or secure the
  adequate rehabilitation funds required to rehabilitate the site.
• The Stockman’s copper mine proposal, despite holding a mining licence, has stalled
  without establishing an adequate rehabilitation bond.
• The Ballarat gold project is in administration. ERR does not hold a bond sufficient for
  even cosmetic rehabilitation.
• The Fosterville gold mine has a depleted ore body. The company has failed to
  complete an EES which the planning minister determined in 2021 as a requirement to
  further expand the mine. The mine is likely to wind down or be abandoned in the next
  two years with a rehabilitation bond less than $7 million dollars, which is less than 3%
  9
  of the required funds to rehabilitate an extensive and complex industrial site of more
  than 28 square kilometres.
  The scoping brief for the Goschen EES requires the proponent to provide alternatives to their
  project. These alternatives should be considered to determine if they have an environmental
  and/or economic advantage.
• VHM have not provided any alternate models to their project, other than to justify the
  sequence of mine pit development.
  VHM have failed to provide an economic or environmental analysis of the model described in
  the scoping brief as the ‘do nothing model’.
  The ‘do nothing model’ could be developed by comparing the VHM mine carbon footprint with
  the carbon which could be offset from green energy generated from wind turbines constructed
  with rare earth product from VHM. This ‘do nothing model’ would need to be adjusted to
  include the loss of agricultural product during the life of the mine and the consideration that
  productive farmland could be lost into perpetuity.
  The BDEC wish to describe some alternatives to the way this proposal, and mineral sand
  mining projects in general, might be developed.
  Currently there are six proposals for the development of mineral sand or rare earth mining
  projects in the Wimmera/Mallee landscape. There is little evidence that ERR, or the Minerals
  Council of Australia (MCA), have engaged with the six proponents in order to achieve a
  planned development of the resource. These six projects have very similar scaled footprints
  and from the interpretation of the data available in the public space host ore bodies with similar
  mineral profiles and commercial values. The manner in which the companies have chosen
  to develop their resource and realise commercial returns are quite different.
  The_Rare_Earth_Wars
• WIM Resources have suggested that they will be exporting HMC, primarily for the
  commercial realisation of the value of the zircon, rather than the value of the rare earths
  or titanium components. China is the long-established destination for Australian zircon
  to be refined.
• The Astron project at Donald suggests that it will provide a range of products that can
  be separated from HMC including rare earth concentrates. The VHM processing
  plant is less well defined, but it might be broadly considered to follow the Astron model.
• Iluka have a proposal near Horsham which has been defined in some detail in a
  shareholder advice publication. This proposal features a very different description to
  the other projects as to how the mine pits might be developed and rehabilitated. The
  Iluka product is not based on the sale of a zircon rich concentrate, but rather Iluka
  expects it can provide a concentrate to its proposed refinery in Western Australia for
  10
  the ultimate production of elemental rare earth product and titanium product. Iluka
  have not ascribed any value to the zircon component in their ore body.
  There are a number of project alternatives that VHM, or the industry as a group of mining
  companies, could have considered.
  One alternative is that the companies could have approached the state government, seeking
  construction of the remaining section of the standard gauge rail line to Portland or another
  deep-water port. Additionally, the companies could seek that the Port of Portland was
  developed to provide the handling and storage capacity for the volume of shipping containers
  that would satisfy the logistics of several mineral sand mining companies.
  A second alternative is that a number of companies could consider is to transport heavy
  mineral sand concentrate to a central hub in the Mallee Wimmera region from where it could
  be further transported on standard gauge rail to the Port of Portland.
  If the six companies in Victoria were to combine their mineral resource, that resource might
  be sufficient to consider a mine model with a 3% HMC lower cut-off limit, rather than the
  proposal by VHM which has a cut-off limit of 1%. A 1% cut-off limit has proven unsustainable
  in previous mining operations.
  A central transport hub for mineral sand concentrate should not be established at Goschen on
  high production value cereal cropping land and should not be established within the floodplain
  of the Wimmera or Avoca rivers.
  A third alternative is the companies combine their mineral resource and establish logistics to
  ship a concentrate to one of the two rare earth refineries that are proposed in Western
  Australia. Iluka have planned a refinery which has been partially funded through a
  Commonwealth government grant program. Lynas, as a competitor, have commenced
  construction of their own rare earth refinery in Western Australia.
  It is not possible to transport HMC to a Victorian port via bulk handling, unlike grain, due to the
  risks to human health from the inhalation or ingestion of HMC dust containing radionuclides.
  To further consider the economic basis, the BDEC would like to describe some of the many
  factors present in mineral sand mining, processing, shipping and marketing which may
  become determinatives in the viability or sustainability of a company in the circumstance of
  VHM.
  Zircon is classified as a critical mineral under the Australian government’s minerals
  classification system. However, the decision by the federal government to include zircon
  along with the previously listed critical minerals was a political decision. This decision came
  after lobbying by the Australian mining industry rather than from technical considerations on
  the necessity for zircon for use by the defence industries or for use in the infrastructure to be
  established for the generation of green energy.
  11
  Zircon is not rare within Australia and could be sourced from coastal or inland stranded beach
  deposits. There are hundreds of locations where zircon mining could occur. A zircon mining
  project is primarily dependent on the availability of a Social Licence and the quality and
  accessibility of the ore body. Iluka_zircon_viability
  Zircon is not usually refined to produce the metal zirconium. Zirconium has poor mechanical
  qualities and no other significant physical properties. Zircon is usually commercialised in its
  mineral form or as a compound. Most Murray and Wimmera deposits share a common
  feature, that is they are likely to be downgraded by prospective purchasers due to the
  presence of radionuclides, uranium and thorium and also the presence of chromium.
  Unless the impurities can be removed it will not meet the classification of first grade zircon, as
  is required for the ceramics industry or for use as a paint pigment.
  A company Kalbar, sought to develop a mineral sand mine in Gippsland through the
  Fingerboards EES. During consideration of the EES, evidence was provided that Rio Tinto
  had previously explored the Fingerboards area and did not consider the project viable as the
  zircon was likely to be downgraded in quality. Glenaladale_material It is reasonable to ask
  if VHM have researched proposals such as Fingerboards and carried forward the research
  into their proposal.
  VHM, similar to the Fingerboards location, would produce HMC which is considered relatively
  high in radionuclides. It appears VHM have not provided a chemical representation of the
  HMC they expect to separate. However, an average of 0.15% thorium and 0.08% uranium
  content appears to be common for HMC sourced from several sites across the Murray and
  Wimmera.
  HMC with radionuclides at this level might be described as ‘a poor man’s yellow cake’.
  Zircon is not a high value mineral compared to, for example, minerals that might be used for
  the refining of metals such as nickel or palladium. As the HMC from the Murray Wimmera is
  likely to be downgraded and the radionuclides negate the incorporation of this zircon into
  domestic products such as paints and ceramics this zircon might be purposed as an abrasive.
  A common use for zircon is as an abrasive to shape or polish metal. As an abrasive zircon
  would compete against other common natural or manufactured abrasives such as
  carborundum and aluminum oxide. A manufacturer then is likely to select an abrasive on cost
  effectiveness rather than any unique technical quality.
  Market conditions could determine that VHM might be required to store one or two years
  production of HMC at the processing location until market conditions are opportune for the
  sale and shipping of the product. Zircon_sand_pricing Titanium_forecast Titanium_Index
  Under the Safeguard Mechanism (Crediting) Amendment Act of 2023 VHM will qualify as a
  controlled emitter of greenhouse gases. After 2030 during the life of this proposal, the
  company will be required to source green energy or otherwise purchase offsets if there are
  components within the project, such as the road transport of HMC to port that are not able to
  12
  be powered by green fuels. The Victorian Governments climate change act 2017 places
  additional controls on greenhouse emissions.
  VHM could source electrical energy from an in-house PV farm from year 1 and along with a
  suitable battery storage system this could provide 95% of the project’s energy requirements.
  A PV farm and battery could be expected to have a similar working life to that of the projected
  20 year life of the mining project and provide energy at a more economic price than on site
  diesel generation or electrical grid energy. https://www.nrel.gov/docs/fy21osti/79236.pdf
  If the company chooses not to establish in-house green electricity at the initial stage of the
  project, it would suggest that the company might not be suitably capitalised to allow
  sustainable operation of the project. Going for “green gold:” WA mine taps solar, wind and battery
  to reach 100 pct renewables | RenewEconomy
  We previously describe how the economic analysis by Deloitte is unrealistic and not evidence
  based. A further consideration is the relationship between the companies assessed JORC
  value of the ore body (the total mineral estimate) compared to the quantity of mineral that is
  able to be accessed. Similarly, the JORC value of the ore body could be reduced where a
  legal right of access to a private property cannot be obtained.
  In the VHM project description most of the mining is proposed to occur on freehold land.
  Landowners may deny the proponent access to various freehold properties as the footprint
  develops.
  The company at this time does not hold land titles to significant areas of the site, only
  agreements as to a possible path to purchase.
  The company may have to negotiate compensation for access to farmland under the criteria
  described in the MRSD Act in the Supreme Court. The landowners may be able to
  demonstrate to the Supreme Court that the project maybe unsustainable in the second half of
  the project life. Therefore, the proponent would then be unable to satisfy commitments for
  the mine pits to be rehabilitated, and the land returned to productive farmland. The Supreme
  Court may then decide to deny access. A denial of access reduces the JORC estimate of the
  ore reserve and therefore the project’s viability.
  VHM propose to return their tailings to the mine pit hydraulically. These tailings will remain
  wet and can be considered mobile for an extended period, likely to be some years. This will
  require a separation between pits to avoid the collapse of an existing wet pit into the pit under
  development. It is not possible to mine this area between the two pits (a wall with a trapezoidal
  cross section) at a later time due to the compromised stability of the pits in which tailings have
  been deposited. A substantial quantity of the JORC estimated ore body is in this interstice
  area and lost to production.
  As the pits holding returned tailings will remain wet for an extended period of time and delay
  the return of overburden, VHM’s description of progressive rehabilitation will not be achieved.
  13
  Substantial overburden stockpiles will be stored at the surface for many years, as is the
  practical reality of any mineral sand mine hosting deep mine pits. The area under the
  overburden footprint will be excluded from that area available for the development of mine
  pits. It may not be economic to double handle overburden to access the area beneath the
  overburden stockpile and this outcome would reduce the JORC estimate further.
  The spirals used in the gravity (centrifugal) separation of the HMC component at the
  processing plant can only recover that component of the HMC with a particle size within the
  separation limits of the spirals physical geometry. The sand particles larger than the cut-off
  limits and the slimes smaller than the cut-off limits will be returned to the mine pit. Therefore,
  the companies access to a further component of the JORC estimate is lost.
  Potential_impact_pathways
  VHM have described that mine pits will be excavated to a depth placing them adjacent to
  groundwater. It is likely that groundwater will enter some pits due to the effect of groundwater
  mounding or from misadventure. Groundwater cannot be extracted to the surface if it is saline
  as there is no obvious cost-effective process to recover the salt. Therefore, no further activity
  to extract ore can occur when groundwater has been encountered. The VHM model to return
  tailings to the mine pits requires the decanting and recycling of mine water. That decanting
  cannot occur if the mine water is compromised with highly saline groundwater. Salt is a
  pollutant if introduced to agricultural land.
  A portion of the JORC estimate of the minerals resource will not then be able to be realised
  when groundwater is encountered.
  If VHM’s mine model ultimately only allows access to between 50% and 70% of the JORC
  mineral assessment which can be ultimately realised as HMC, this is a serious substantial
  cost impediment when considering the sustainability of their mining project.
  Several further elements should be considered in the economic sustainability of the project.
  Consideration must be given to the accessibility and the reliability of the water supply.
  VHM suggests they will source all of their new (or make-up) water requirements from GMW
  via Kangaroo Lake. The proponent has suggested a water requirement of about 4
  gigalitres/annum. To justify this requirement VHM would require an extremely efficient
  process for the recovery of the mine water used to return coarse sand and slimes to the mine
  pits. In addition, VHM would need to recover water from the stockpiled HMC.
  The proponent has described the annual processing of ~ 5 million tonnes of ore. The
  processed ore will be returned to the mine pits in a hydraulic operation which will require
  approximately three tonnes of water for each tonne of tailings that are returned to the mine pit.
  The BDEC will offer discussion on the efficiency of recovery of mine water returned to the pits
  in Section 4. Management of Mine Pits and an informative Work Plan.
  Even if VHM were able to achieve a more than optimistic recovery of 50% of mine water from
  the mine pits this would account to an annual loss of 7.5 gigalitres.
  14
  In addition, there are losses from the entrapped water in the HMC. The entrapped water is
  ultimately evaporated to the atmosphere so that the HMC can dry and be placed in Bulka bags
  and containerised. The losses from the process of drying the HMC and any additional losses,
  such as the requirement for dust suppression throughout the mine site, would require an
  additional 1 to 1.5 gigalitres of water.
  The accumulated water loss, which needs to be matched by an equivalent delivery from GMW,
  is then in the order of 8.5 to 9 gigalitres.
  The GMW supply system cannot provide security of water supply to VHM.
  A sand mining company would find it impossible to continue its operation over the period of
  an extended drought without water security.
  VHM would be required to source water for dust suppression and for progressive rehabilitation
  during a drought even if it was unable to continue production.
  In Technical Reports exhibited by the proponent for the recent Fingerboards EES the company
  (Kalbar) recognised the significance of water security. The Fingerboards proposal included
  the construction of a 3 gigalitre ‘turkey nest’ style dam to provide water security for one year,
  along with a plan to seek additional water from an aquifer.
  In the case of VHM the provision of water security could require the construction of a dam with
  a capacity in excess of 10 gigalitres at a most significant capital cost. The publication a
  ‘History of droughts in Victoria’ illustrates the lack of water security before VHM.
  The_millenium_drought_BOM_map
  As previously mentioned, the saline groundwater at the proposed VHM mine location cannot
  provide an acceptable water source to the project as it would introduce saline water into the
  agricultural environment and there is no economic process available to remove the
  accumulation of salt. It would likely be cost prohibitive for VHM to decommission the mining
  project for one or two years and then recommission the project. VHM have not included a
  dam to improve water security in their proposal and this would suggest they are not well
  capitalised and unable to manage risk.
  Another economic risk before VHM is the requirement for medium term storage of HMC on
  the mine site.
  In the case that VHM requires the capacity to store up to 2 years of production of HMC until
  market conditions have stabilised this would equate to storing approximately one million
  tonnes of HMC. This requires that the proponent is sufficiently capitalised to be able to
  continue the financing of production of HMC until a further contract becomes available.
  A further consideration in the economic sustainability of the project is the production value of
  the land to the farming community for broad acre cereal cropping. The consideration should
  be made that mining companies in Victoria, under the lack of governance provided by ERR,
  have a record of minimal achievement of rehabilitation of farmland and this land is likely to be
  lost for agricultural purposes into perpetuity. This production and economic loss should be
  factored in the economic argument.
  15
  The risk of harm from the introduction of flocculant into the agricultural environment has not
  been scientifically established. Flocculant will be introduced to the farm soil and subsoil
  through the process of using mine water as a dust suppressant on the soil and subsoil
  stockpiles and haul roads. The flocculant in its native condition is possibly benign in an
  agricultural environment but the break-down products of the flocculant and particularly their
  capacity to react with the metals occurring in the ore body and groundwater create a condition
  of uncertainty.
  VHM have not published a dosing rate at which the flocculant will be used in the various stages
  of ore transport, processing, and the return of tailings. However, using the published dosing
  rates of other Victorian mineral sand mining projects, during the predicted 20 years life of the
  mine, more than 40,000 tonnes of flocculant will be introduced into the agricultural
  environment. If the mine land was hypothetically able to be returned to use for agriculture,
  during the next 20 years post mining, the quantity of cereal produced from this land is likely to
  be some thousands of tonnes less than the tonnage of flocculant already in that environment.
  One example of the loss of farmland to a mining project is at the Fosterville gold mine site in
  Central Victoria. This project has already consumed 28 square kilometres of farmland, much
  of it productive Campaspe River flat. This land can never be returned to agriculture due to
  the heavy metal (arsenic) contamination of the land surface.
  VHM could be expected, under its MRSD Act obligations, to be required to pay compensation
  to the farming community for loss of production of cereal crops. This compensation would
  likely be for an extended period, unless VHM are able to develop new mechanisms to dewater
  their mine pits in a timely manner. The Supreme Court could ultimately determine that the
  mine site is unable to be returned to its original use for agricultural production and findings
  may then be made against VHM for the loss of the capital value of the farmland.
  Iluka, an experienced mineral sand miner, in their description of the development and
  rehabilitation of mine pits in the company’s proposal at Horsham describe that their mine pits
  will remain open during the approximate 30 years of life of the mine. Iluka will dry their fine
  sand tailings (slimes) on the surface and ultimately return the tailings to the mine pits after the
  30 year period of mining.
  Iluka appear to offer a transparent and credible description of a mineral sand mining operation,
  including the description of the rehabilitation operation and the cost of that operation. Iluka
  estimated that it’s rehabilitation liability would be $460 million. A junior company such as
  VHM without an established history in the industry would find it difficult to attract investment
  to enable them to lodge a bond of a similar amount prior to commencing their operation.
  16

1. Management of Mine Pits and an Informative Work Plan
   The proponent has not constructed a test pit. A test pit is ‘de rigeur’ for all civil or mining
   projects of this scale. A test pit would provide requisite data for engineers preparing a draft
   Work Plan.
   This data provides a wealth of information. It includes geotechnical information on the
   properties of the various geological layers encountered in the pit and allows the geometry of
   the pit walls to be determined and thereby maintain the integrity of the pits.
   This data would include the depth at which groundwater flow is encountered and the rate of
   movement of that groundwater.
   This test pit would also provide samples of clay or other materials that could be characterised
   and possibly used for construction of dams and roads etc.
   The test pit would provide samples of ore which could be processed in a trial plant to obtain
   HMC and samples of slimes. These can be to determine the likely recovery of water for
   recycling and the likely rate of settlement of the slimes after they have been returned to the
   mine pits.
   A significant volume of ore would now be available and it could be sampled and then company
   could refine its JORC estimate.
   The VHM generic schematic of the mine pit model presents the fallacy that is commonly
   presented by sand mining companies, a “rolling pit”.
   The rolling pit model presents the aspiration of excavating on the leading pit wall while
   returning tailings on the retreating wall for the desired outcome of rapid rehabilitation. This
   model, although unrealistic is presented in an attempt to seek a Social Licence for the project.
   Two companies in Victoria have recently placed their projects for mineral sand mines before
   the public.
   In the case of Kalbar, the company exhibited documents to the Fingerboards EES. The
   company had recognised that they could not return wet tailings to the pits which were an
   average depth of 40 metres, without de-watering the tailings first above ground. The company
   proposed that de-watering would occur both in tailings storage facilities (TSF’s) and by the
   incorporation of centrifuges. Using the two de-watering methods, along with a complex base
   of pit drainage system to aid water recovery, and HDPE liners the company envisaged that it
   could rehabilitate the mine pits over a period of several years. TSF_Fingerboards
   Iluka, at a site south of Horsham placed a technical description of their mine model before the
   public in an investor guidance report. Iluka is an experienced company and has in excess of
   17
   40 years’ experience with mineral sand mining projects. Despite their experience Iluka has
   had considerable difficulty in completing rehabilitation at many of its project sites.
   Iluka describe in this current proposal that they would hold and accumulate all wet tailings in
   above ground tailing storage facilities where they would be dried over the 30 year life of the
   mine. Iluka then propose to return the tailings to the extensive mine pit during the final stage
   of mine rehabilitation.
   The model which VHM has placed in the exhibited EES documents is in conflict with the
   common method by which mineral sand mining companies return their tailings to their mine
   pits and also in conflict with the science of physics.
   VHM mine pits extend close to 50 metres deep. The company would have to rely on several
   mechanisms to dry wet tailings they have placed in the pit as the tailings would hold 2 to 3
   parts water.
   The first mechanism is natural evaporation to the atmosphere. The PAN evaporation rate for
   the latitude and location of Lalbert is ~ 1.8 m/year. The depth and structure of the pits at
   Goschen will reduce the speed of wind flow over the surface of the tailings. The pit walls will
   shade the tailings for a period each day from solar radiation. The effective PAN evaporation
   rate would then be approximately 1.2 m/year.
   The second mechanism for de-watering is seepage of the mine water through the base of the
   pit into groundwater. VHM have claimed that they wish to decant and recycle 80% of the
   mine water that is placed into each pit so that they can reduce their water consumption.
   However, the company has not provided a substantial base of pit drainage system or a liner
   to enable this desired recovery of mine water.
   The company has described that it will divide each mining pit into a number of cells.
   The company’s desire is to construct a beach with a slope of 3° in each cell. The intent is to
   allow wet tailings to flow slowly over this beach and allow the sand component to settle across
   the beach while the water component flows through to a sump at the tail of the beach.
   A beach of a similar design to this is used in the tailing storage facilities of the significant gold
   mines in Victoria, Stawell and Fosterville. The TSF’s are developed to heights of 30 or 40
   metres above the natural landscape. The tailings stored in these TSF’s are generated from
   rock which has been ground or milled. Although the particles at these gold mines are not
   natural sand, they do drain and dry at a similar rate to the VHM tailings. This beach design
   used by gold mines has a purpose-built drainage system which allows for the recovery of mine
   water. It is effective in that it allows the companies to decant and recycle most of their mine
   water. However, the beach system is not effective at drying the tailings. The larger part of
   the stored tailings remains wet and therefore mobile, in the order of 60% or more. These
   tailing storage facilities then cannot be capped in situ as a method of encapsulating the tailings
   and rehabilitating the site. The TSF is unable to accept the weight of overburden or other
   capping material.
   These TSF’s are capable of being raised at the rate of approximately 2 metres per year, that
   is they are able to decant and recycle sufficient water to extend the height of the TSF by 2
   metres each year. FGM_Tailings_Dams
   18
   In the case of the VHM project, as their tailings are in a deep pit, they are less exposed to
   atmospheric drying and therefore the comparative rate of placing wet tailings by the beaching
   method is more likely to be around one metre each year.
   The third mechanism that could allow the tailings to be dried is if there is a substantial rate of
   discharge through the base of the pit to groundwater. This would require the base of the pit
   to have a low permeability. A high discharge to groundwater would be contradictory to the
   company’s stated aim of recovering 80% of the mine water.
   The demonstrated history of mineral sand mining is that the effective way to dry mine tailings
   is by the use of above ground mechanisms such as tailing storage facilities before the tailings
   are placed into deep mine pits.
   There are several problems that are introduced if the company was to attempt to substantially
   dry tailings within the mine pit. The first is that the VHM model requires the construction of a
   number of dam walls along the operating length of the pit to effectively divide the pit into cells.
   These dam walls would be constructed from clay sourced during the excavation of the mine
   pits. The clay layer recovered is likely from the thin layer which lays immediately beneath the
   topsoil. This clay layer serves as the source of water retention to sustain the farmers growing
   crop.
   The clay cannot be recovered after it has been used in the construction of dam walls in the
   mine pits as it will have a residual hydraulic pressure placed against it from the adjacent pit.
   A substantial volume of clay will be required to construct these dam walls as they will be
   required to withstand a hydraulic head of wet tailings up to 15 metres. If these cell walls (dam
   walls) fail and there was a surge of tailings into the adjacent pit (a mud surge), there would be
   the immediate risk of loss of life of mine workers.
   A further problem is that the differential drying periods of the tailings in the various pits would
   be reflected on the surface as uneven.
   To further consider the beaching method proposed by VHM is that the sand particles will
   differentially settle from the water flow. The course particles will settle closer to the head of
   the beach while the fine particles will continue towards the tail or downstream end of the beach.
   This will lead to an uneven surface of the mine pit.
   VHM, through their various technical reports, has described the commingling of tailings
   streams. This commingling would include the coarse sand and slimes and presumably some
   of the other waste streams from the Hydromet and other stages of the process and refining
   plant. The materials would be mixed and returned in similar concentrations and to the same
   layers as the original geotechnical structure of the ground. This is a false premise.
   There is no straightforward mechanism to combine the course sand and slimes. All of the
   various materials which are returned to the mine pit have been treated at one or more stages
   by the application of flocculent. The purpose of the flocculent is to attract the individual sand
   particles into larger, structured particles, so that the sand tailings will more readily release their
   retained water and the retained water can ultimately be decanted. The returned materials
   that have been treated with flocculant will have quite a lower permeability to the natural sand
   formations in the original geology. This lower permeability and the fact that these tailings are
   19
   in close, or in some cases intimate, contact with the groundwater flow is likely to create new
   pathways for the movement of groundwater.
   If groundwater now has the opportunity to flow at less depth it would be difficult to predict the
   possible effects on agriculture, including for instance salt uptake by crops such as lucerne
   which has a root system extending to a depth of 20 or 30 metres.
   The geotechnical report J on page 45 contains a chart which attempts to describe the
   settlement of a mine pit over several years as it is progressively filled and ultimately stabilises.
   This chart describes that the pit, after some 1000 days, will settle some 6 metres and return
   to the original land surface profile pre mining. This outcome would be outside the rules of
   physical science.
   The disturbance of the excavation and subsequent replacement of the geological layers will
   create a less dense structure and result in a positive increase in surface height, even after the
   loss of an equivalent 0.5 metres of height from the removal of the HMC component is
   accounted for. A further positive adjustment is required as the increased particle size of
   flocculant treated tailings will not allow the tailings to pack to the same density as the original
   sand structure. It would be reasonable to consider that an average gain in height at the pit
   surface would be at least 2 metres and possibly beyond 3 metres. This outcome would create
   unacceptable changes to the flow of surface water. During periods of high rainfall and surface
   water flows these flows would be directed to adjacent lower topography that had not been
   impacted by mining pits. Adjacent farms would be affected by localised flooding from the
   movement of surface water. Many of the local roads are unformed and the natural material
   is graded to create the road surface. This is partly due to the unavailability of local quarries
   to supply roadbuilding materials. The surface of these roads is ultimately lower than the
   natural surface due to the constant grading operations. Image_of_sunken_road The
   depressed road surface then becomes a floodway for the movement of surface water during
   a period of rainfall and quickly becomes impossible for vehicle access.
   A resultant height increase at a rehabilitated mine pit of an average of 2 or 3 metres is likely
   to be managed by grading the surface height at the centre of the mine pit to 6 metres and then
   20
   grading across the surface at a reducing level to match the original road fence lines. The
   mounded area at the centre of the pit would create a high risk of wind generated soil erosion
   due to the higher wind speeds at the elevated area. Agriculture would likely be unsustainable
   on these rehabilitated mine pits if the sloping surface creates water flows that reduces the
   opportunity for rainwater to permeate the soil.
   The mine model proposed by VHM is different to some long-established norms of the mineral
   sand mining industry in Victoria and Southern NSW. This relates to both the operation of the
   mine pits, but also the inclusion of an extensive and complex mineral sand separation plant or
   refinery.
   VHM have only provided a description of what their proposed Work Plan might contain, rather
   than the detailed information which would inform the drafting of the final Work Plan.
   This description, of the model for the mine pit suggests that the VHM would have great difficulty
   in drying the slimes returned to the pits on the timelines that would be required for mine
   rehabilitation. This then indicates that at the end of the mines working life many of the mine
   pits will be open and the area of the mining licence would remain disturbed.
   The regulator, ERR, should have intervened to require VHM to provide sufficient detail in the
   draft work plan so that it can be suitably considered by the IAC panel.
   The Draft Work Plan should also describe, in sufficient detail, all those elements and structures
   that are required for short term and long term storage of handling of HMC and REMC. The
   Draft Work Plan should include the requirement for the rehabilitation of those areas at the
   processing site where leaching of flocculants and heavy metals has occurred and those
   required elements, such as for instance, the process for dust suppression if water is
   unavailable during a drought.
   The Draft Work Plan should provide sufficient detail of the company’s processing plant to
   describe the separation or refining of HMC to provide rare earth concentrates and other
   products, as is described in other exhibited Technical Reports and the company’s prospectus.
   This activity is proposed in the first three years of the site operation. This information is not
   present in the Draft Work Plan.
   If new practices are proposed for Goschen, the proponent should be required to employ a
   mine development consultant to prepare a Draft Work Plan of sufficient detail as is required
   for an EES investigation.
   This Draft Work Plan would enable the community and regulators to be suitably informed to
   consider risk prior to the consideration by an IAC panel.
   21
2. Risk to Human Health from Radiation
   The Draft Work Plan provides very little information about the processing plant.
   The description in the Draft Work Plan has the inclusion of a Hydromet but various descriptions
   of the plant, including in the prospectus, describe that in the second or third years that plant
   would be extended to provide a rare earth carbonate.
   This plant might then be reasonably described as a refinery rather than a separation plant.
   Such a plant would be a complex and extensive industrial installation.
   The schematic below is from the Radiation Technical Report page 65. The consultant appears
   to have not provided advice as to how the radiation emissivity for the HMC was derived. Was
   the emissivity calculated or measured, and if measured was the provenance of any HMC
   sample described.
   The significant issue with the Goschen Radiation Technical Report is that the health risk advice
   has only been provided for members of the public, that is for persons beyond the mine site.
   This could be at a local receptor, such as a farmhouse perhaps a kilometre or so away, or a
   driver passing the mine site in a vehicle. Unsurprisingly, these situations do not create a
   significant health risk.
   The information that is missing in any form is a health assessment for mine workers or other
   persons on the site. This is most critical for workers in the vicinity of the processing plant,
   where products such as HMC or rear earth concentrates might be exposed, that is, in some
   22
   form of open top tank or during the maintenance of pipe work. The radiation risk to mine
   workers may be the most significant risk on the mine site.
   The proponent has failed to establish that worker safety, specifically the risk of harm to human
   health from radiation exposure during the separating, storage, and handling of HMC, REMC
   or rare earth separation plant waste streams has been sufficiently identified, quantified or
   mitigated against. The second significant location of radiation exposure is the stockpile of
   HMC or the stockpile of rare earth concentrate.
   VHM suggest that these stockpiles will be held in some form of bin or container until, by some
   undescribed mechanism, the product has been placed into 20ft shipping containers which
   would then provide a metal enclosure as the product is shipped through the Port of Melbourne
   To China. VHM_Prospectus_Shenghe_Announcement
   HMC, and possibly in this case, rare earth concentrate, is transported hydraulically to
   stockpiles to permit drying in the open air. HMC for instance will be delivered to the stockpile
   with two or three parts by volume of water. The stockpile is then allowed to drain and
   subsequently dry by wind and solar action to reduce the moisture content to 3 or 4% for
   shipping.
   The HMC stockpile, depending on the actual particle size, will drain and reduce its moisture
   content over some weeks to around 50~70% moisture retention. This is the natural moisture
   retention for the HMC particle size.
   If the company requires to reduce the water content below the natural moisture retention to 3
   or 4%, it would require manipulation of the HMC by exposure to wind and solar drying to
   reduce the content to the desired level for shipping.
   At a level of 3 or 4% moisture content, even in winter, unless there is actual precipitation or
   water sprays are in use to control dust, a HMC stockpile can generate dust during wind events.
   The BDEC offer as evidence the images of a HMC stockpile in W.A.
   The images above are used with permission and were presented at the Fingerboards EES.
   These images are typical of the wave pattern that appears on sand dunes in inland Australia.
   The images of the HMC indicate that the mass of the generated dust is likely to be in the order
   of tonnes rather than kilograms for each stockpile.
   HMC dust is a significant human health risk to mine staff, or members of the public beyond
   the mine site, due to the risk of inhalation or ingestion of the HMC dust as the radiation source
   is now internal to the human body.
   23
   A further risk is that, at whatever moisture concentration the company is able to achieve, HMC
   will need to be mechanically handled by loaders (a large front-end loader) to place it into a
   hopper to fill Bulka Bags. Bulka Bags are a large synthetic bag which can hold around 1
   tonne of HMC. These bags are then typically loaded by forklift and stacked into 20ft shipping
   containers. Approximately twenty Bulka bags can be placed into each 20ft shipping container.
   There is a suggestion by the company that all road transport of HMC will occur by contract
   drivers and those contract drivers will access the HMC stockpile by a loader to prepare their
   own shipment of Bulka Bags.
   For efficiency it is quite unlikely this would occur. More likely an individual worker will, during
   a shift, be tasked with the loading of up to 1500 Bulka bags. When a loader approaches a
   stockpile of HMC that stockpile will be possibly 20 m high and perhaps some hundreds of
   metres in length. It is not possible for the driver to manoeuvre a loader onto the top of a HMC
   stockpile which has not been compacted. The technique will be to continuously drive the
   bucket into the stockpile until the bucket holds sufficient material to load the hopper. During
   this process, the worker on the loader will be in the immediate vicinity of the HMC as the
   stockpile will be immediately in front of, and at times each side, of the loader.
   On occasion a section of the stockpile may collapse on top of the worker and loader.
   JRHC, in the Radiation Technical Report, describe that the human health risk to workers can
   be established at a later date, rather than being a consideration of the IAC. That would be by
   and during an assessment by the Victorian Department of Health, or their consultant, when
   the company requests a radiation licence. This process would create an unacceptable risk.
   Until the human health risk to workers can be established by a diligent radiation consultant,
   the preparation of a draft Work Plan for the EES cannot be prepared. This Draft Work Plan
   would describe the radiation exposure that workers would receive while in the vicinity of the
   processing plant. The radiation exposures would need to be calculated for workers loading
   or otherwise handling HMC, or otherwise in the vicinity of the HMC, stockpile for example while
   installing dust suppression sprinklers on the HMC stockpile.
   A further risk is that if the consultant preparing the Radiation Technical Report has not been
   diligent, there is a considerable opportunity that the same consultant is likely to be engaged
   by the Department of Health to prepare their radiation assessment as there are a limited
   number of technical consultants in this field in Victoria.
   VHM have described that HMC and the rear earth concentrates will be stored in some form of
   containers or bins while waiting shipment.
   This is not the case, to manage the marketing of a bulk low value product like HMC it is
   possible that onsite HMC storage maybe required for one to two years.
   This is the same marketing model, as for instance, a farmer might use to store grain until there
   is an advantage in the market. The Port of Melbourne will only provide rent free storage of
   shipping containers for up to 5 days. VHM are likely to be required to construct a village of
   shipping containers at the mine location, or otherwise hold HMC as a bulk stockpile until
   access to the port is available. The logistic difficulties in access to the Port of Melbourne have
   been demonstrated during periods of high grain shipment.
   At this stage, we have little information as to what the concentrations of HMC in the air, as
   dust, might be. The concentration has not been correctly addressed in the Air Quality Reports,
   24
   G and G1. However, if you visit the processing precinct of a typical mineral sand mine, you
   will find a layer of HMC dust over the buildings, vehicles, and workers clothing alike.
   It is reasonable to suggest that HMC dust in the air, on days with a drying atmosphere, could
   possibly be in concentrations of several milligrams per cubic meter rather than measured in
   micrograms per cubic meter.
   There is some limited science literature that suggests that the HMC particle size dust becomes
   visible in the air at around one gram per cubic metre.
   A Radiation Technical Report was prepared for the Fingerboards EES. That radiation
   assessment was considerably debated before the panel and the panel sought two forms of
   peer review of the Radiation Technical Report.
   https://www.planningpanels.vic.gov.au/__data/assets/pdf_file/0036/597852/fingerboards-
   mineral-sands-project-inquiry-and-advisory-committee-report.pdf
   The mining engineer and the physician who were expert witnesses for the community were
   critical of that Radiation Report.
   The BDEC submit that the circumstances to provide workers safety in all environments should
   be a consideration of an EES and particularly if that environment is the most hazardous
   environment of the project site.
   The consultant for Goschen, JRHC, may have attempted to avoid assessment of worker
   health because of the contested nature of the technical report provided for the Fingerboards
   EES.
   It is necessary that the proponent be required to provide a Radiation Technical Report which
   includes the radiation risk to workers. To provide a degree of separation any consultant’s
   sourced should be from academia or interstate.
   Other radionuclides such as radium which are likely to be present but have not been assessed
   should be included in this Technical Report. If HMC is suspended, as dust, it can be inhaled
   or ingested which considerably increases the radiation risk to the human body.
   Sufficient detail of the design of the separation plant should be available in the Goschen Draft
   Work Plan such that a correct assessment can be prepared for workers health.
   The BDEC would finally wish to make comment on several Technical Reports and in addition
   climate change.
   Comment on Air Quality Report. Appendix G
   Inland Australia is well known as a source of dust generation. With the change to minimum
   till agricultural practices for cereal production the days when the “Mallee comes to town” have
   reduced significantly. However, the Australian mainland can still generate a dust cloud
   capable of affecting visibility at the Auckland Airport.
   25
   The source of dust storms in South Eastern Australia is now more likely to be from erosion
   caused by grazing stock or mining operations rather than cereal cropping.
   Dust_storms_images
   Mining companies offer the narrative that they have processes in place to minimise dust and
   rigorous procedures to monitor that dust. The attached image is from the Costerfield mine
   site where the EPA were eventually required to issue controls against the company to change
   its practices. The dust plume leaving the mine site was at times visible from a 20 km distance
   and on days with a particular weather condition an inversion layer allowed the captured dust
   plume to extend and be visible 6 km from the mine site. Costerfield_Mine_Dust_Images
   The Costerfield mining company and the environment review committee claimed that the
   monitoring procedures had detected only minimal quantities of fugitive dust, well below the
   trigger for reporting. This scenario, where the community has a different view on the presence
   of dust to that of the mining company, is a common occurrence at mine sites around Australia.
   This scenario is now being re-run at the Cadia gold mine in Central NSW where the company
   denies the presence of fugitive dust but where the plume is clearly visible across the wider
   landscape. The EPA has been tasked with determining the source of heavy metals detected
   in community blood testing. Cadia_Mine_Dust_Images
   The VHM Air Quality Consultant has chosen to model emissions at Goschen using the NPI
   manual. NPI_estimations
   Unfortunately this manual was developed using empirical formula developed at coal mining
   sites where the coal face is constantly wet and the overburden is likely to be derived from rock.
   If the air quality consultant uses the NPI manual and accepts all the mitigating conditions that
   are available in the manual, such as the moisture content in the ore or the degree of dust
   suppression from water provided by the proponent, fugitive dust emissions from this massive
   civil undertaking could be modelled as daily emissions in kilograms rather than tonnes in
   actuality. Perhaps the NPI model should be tested against observations at any working
   mineral sand mine.
   Fugitive dust from ore bodies or mine pits is an amenity issue, but it can also be a human
   health risk dependent on the quantities of small particles and particularly the presence of
   crystalline silica. However, dust generated from HMC stockpiles, or the handling and loading
   of those stockpiles, is a more significant risk because of the presence of radio nucleotides,
   heavy metals and rare earths. While the particle size of HMC is in the most part above 20 (or
   30 µm dependent on the plant) and the particles are reasonably dense, HMC stockpiles and
   the handling of HMC will generate dust in accordance with the wind speed and cause harm to
   human health. Workers, and members of the public beyond the site, can be harmed if the
   HMC is inhaled or ingested. Dust_Control_Theory
   It is almost impossible to manage the moisture level of HMC to mitigate windblown erosion
   and hence airborne emissions.
   The proponents suggest they wish to condition the HMC to 3 or 4% moisture content prior to
   shipping. In this condition of dryness any unforeseen change in atmospheric conditions may
   allow generation of dust.
   26
   An observant person who has visited a Mineral Sand mining site during a drying atmospheric
   condition is well aware of the dust load in the atmosphere. This is exacerbated during high
   temperature and/or wind conditions. Buildings, vehicles and workers and their clothing carry
   a visual dust load. These observations are contradictory to the assessment of dust as
   provided in the air quality report and perhaps suggests that the use of the NPI manual by the
   air quality consultant was not a reasonable approach to estimate the dust loading for a mineral
   sand mine in the Mallee.
   Comment on the Surface Water and Groundwater Report – Appendix H1, H2 and I
   Consideration should be given of the fact that water in this environment is a finite resource,
   and that the quantity of water VHM are proposing to use might well be better used in both a
   commercial and social sense for the conduct of an agricultural activity. Any water allocation
   by GMW to this project, or water purchased on the open market, will likely be at the expense
   of the local dairy farmer rather that the corporate water user.
   The surface water report fails both the proponent and the community without sufficient robust
   advice to understand the water management of the project. The proponent is then not well
   placed to manage risk and therefore their capacity to develop and maintain a Social Licence.
   The authors of the report appear to lack understanding of the high intrinsic value of beneficial
   water sources in the low rainfall environment of the Mallee. Also, the necessity to protect
   farmland from the accumulation of salt and to avoid any increase in the salt loading of
   watercourses. The report fails the proponent in their capacity to develop water security for
   the project and therefore sustain production during the period of a drought or an extended dry
   period.
   The flooding events in Victoria and New South Wales during 2022 provide evidence that any
   location within a floodplain in South Eastern Australia is at risk of riverine flooding at levels of
   one or two metres above historical records.
   The Technical Report fails to make a realistic assessment of the risks of climate change and
   dismisses any consideration that the mine site could be flooded by riverine flooding from the
   Avoca River or flooding from the Lalbert Creek, a distributary of the Avoca River. The flooding
   of operating mine pits would remove them from production for several years if mine tailings
   become saturated.
   In flood conditions the flows from the Avoca River into Lalbert Creek may be modified by flood
   debris in the lower Avoca River system or protection levees established for the Murray Valley
   Highway. Lalbert Creek could receive flows redirected from the Avoca River dramatically
   above any historical circumstance.
   The consultant uses an implausible model for climate change which only varies the model for
   a 1% AEP (one in one-hundred-year flood occurrence) by several percent. The design of
   infrastructure which has the capacity to cause harm to human health or harm ecological values
   now requires that a 0.1% or 0.01% flood occurrence needs to be considered in the
   establishment of flows and inundation levels. These are a one-in-one-thousand or one-in-
   27
   ten- thousand year occurrence. This requirement is the considered position of the Institute of
   Engineers Australia.
   The groundwater technical report does not include an assessment of how groundwater
   recovered during the excavation and operation of mine pits will be managed. If saline
   groundwater is decanted along with mine water and both are introduced into the process water
   circuit, mine water that has been compromised by saline groundwater will ultimately be used
   for dust suppression and other mining activities and salt will be captured on farmland.

• VHM have not prepared a salt balance.
  Neither the surface water report or the groundwater report has described how flocculants, or
  their breakdown products, are distributed throughout the mine surface water system or the
  likely fate of the flocculant. VHM have not provided the dosing rate for flocculant or the volume
  of flocculant that will accumulate in the surface water management system.
  In a typical mineral sand mining project the quantity of flocculent introduced into the
  environment during the life of the mine is far in excess of 10,000 tonnes.
  The consultant has not assessed the environmental risk from the increasing concentration of
  flocculant in mine water when that mine water is used for dust suppression.
  The Groundwater Technical Report has mentioned the effect of mounding on groundwater
  flows. However, the report has not considered the change to groundwater flow by the altered
  strata through which some of that groundwater flows. The change to strata occurs when mine
  pits are backfilled with material which is different to that from the original strata, or material
  whose characteristics have changed due to processing or the application of flocculant.
  Changes to strata are contrary to the preferred rehabilitation process of returning ground
  structures to as far as possible their original structure.
  https://www.youtube.com/watch?v=f9V6-ylF_is
  The scoping brief for this EES requires that the proponent consider cumulative risk.
  The consultant, AECOM, has failed to assess the cumulative risk that abandoned mining
  projects, along with active mine sites such as Fosterville and Costerfield, have placed before
  the Murray Darling basin. The risk is that if mine pits, tailing storage dams or processing
  plants discharge during catastrophic events such as flooding, earthquake, rupture of tailings
  dams, equipment failure at processing plants, etc. they will cause environmental harm.
  This risk must be added to the risk of VHM’s processing plant or mine pits failing
  catastrophically to determine the cumulative risk.
  The consultant has suggested that the mine sites can be operated so that there will be no
  discharge of surface water or pollutants. History would demonstrate that this is not the normal
  circumstance for any mine site. There is a high or extreme risk that there will be discharges
  of surface flows containing chemical pollutants such as acids from the processing area of the
  mine site.
  28
  VHM, and their consultants, in the determination of their EPBC responsibilities towards the
  RAMSAR listed Kerang Wetlands, have suggested that firstly there will be no release of
  surface flows from their mine site. Secondly, they claim that if there was a flow it would
  migrate into the Lalbert Creek system and therefore there is no possibility that the Kerang
  Lakes could be affected.
  The demonstrated trajectory of all the substantial mining projects in Victoria is that if they are
  provided with an EES and subsequently a mining licence, that after the issue of the mining
  licence the site is effectively closed away from scrutiny by the local community.
  All future developments on the site will invariably be handled between the operator and ERR
  by work plan variation. The site development and footprint will advance using this process.
  An example of this type of development occurs at the Fosterville gold mine where the original
  project was approved as a relatively small open cut mine pit through an EES investigation.
  Three decades later this site has developed into a massive underground mining operation with
  an extensive processing plant that has consumed some 28 km² of farmland without any further
  planning approvals other than local government building permits. There have been at least
  45 Work Plan Variations issued to the respective mine owners.
  If this development model is translated to the Goshen project, it is likely that after the issue of
  the mining licence the proponent will seek Work Plan Variations to vary the scale or the
  location of the mine pits or the scale and location of the separation/refinery plant.
  VHM documents as exhibited describe that the mining operation will occur on and across both
  slopes of the Cannie Ridge. If mining pits or the processing plant are located on the eastern
  slope of Cannie Ridge and there is a catastrophic failure within the mine site, the discharge
  would impact either of two creek systems. If the discharge is into Back Creek then that flow
  will continue into the Avoca marshes and subsequently into the wider Kerang Lake system.
  VHM should be required to exhibit technical assessment reports that consider the risk if their
  pollution enters the adjacent RAMSAR listed Kerang Lakes Wetlands.
  VHM consultants should be required to determine the flora and fauna values of those wetlands
  along with the risk of harm from pollution to those flora and fauna populations. Water_salinity
  Comment on Climate Change and Greenhouse Energy Production
  The company has marketed its proposal, and it’s claim for a Social Licence, very much on the
  basis that it will advance the opportunity for Australia as a nation to be able to incorporate the
  rare earth products that VHM will provide within green energy projects. These projects include
  low carbon power generation projects and the electrification of transport. The company’s
  marketing proposals describes that due to their role in production of rare earths this warrants
  that they be offered a Social Licence by the wider Australian community and that the affected
  community at the mine location should accept the presence of the project in the national
  interest.
  29
  VHM itself has made no attempt to utilise green energy at this stage to power its mining
  operation. VHM has not quantified how its rare earth products would be incorporated into
  green energy projects. VHM has not provided a carbon balance model that would describe
  that the carbon footprint of the mine proposal could be offset by the establishment of green
  energy projects, such as wind turbines, that would provide a commensurate capacity for the
  generation of green energy.
  Rare earth minerals are primarily incorporated into wind turbines rather than PV farms or other
  forms of green energy production.
  A typical wind turbine incorporates two tonnes of the three rare elements with enhanced
  magnetic properties into its construction. This turbine, over its lifespan, generates at an
  average rate of one gigawatt.
  VHM requires a constant energy input to, for instance, provide diesel or gas to its onsite
  electrical generators, diesel for mining equipment, diesel for the road transport fleet, fuel oil
  for marine shipping of product to China, and for operation of the rare earths refinery at
  Shenghe. There is also the requirement for a conversion factor to consider the energy that
  was required to manufacture the VHM mining and transport fleet and the manufacture of the
  industrial plant at Shenge.
  VHM’s energy requirement to operate their mine should be compared with the cumulative
  energy output that might be available from the incorporation of rare earth elements into wind
  turbines constructed from VHM products.
  The BDEC expects to discuss a model for energy comparison during its submission before
  the panel.
  Submitted by Ian Magee
  Mining spokesperson for the BDEC
  31/01/2024
  30
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  DUST CONTROL & MINE WATER SOLUTIONS
  02 6062 3300
  •
  HOME
• Dust Control Resources
• Dust Control Theory
  DUST CONTROL THEORY
  This page discusses some of the key concepts to dust control in mining starting with dust
  prevention through to dust suppression. Note that this is a very brief introduction to highlight the
  concepts only.
  Dust Particle Sizes
  The size of a dust particle is important as it provides a guide to its behaviour and occupational
  risk:
• smaller and lighter the particles will travel further in the wind
• particles below 25 micron are not visible to the human eye
• particles below 10 micron are easily be inhaled into the lungs
• particles below 5 micron can get permanently lodged in the lungs increasing the
  potential for respiratory illness
  55
  The following image illustrates some different dust particle sizes.
  Image taken from: http://www.filtercorp.biz/
  A key point here is that visible dust is not a major concern for health, but it is the smaller particles
  that are generated at the same time. These may not be visible but will travel further and are the
  major health issue for the community. As a result most dust monitoring is usually focused on the
  PN10 dust (less than 10 micron) particles.
  Dust Extinction Moisture (DEM)
  The Dust Extinction Moisture (DEM) level provides a guide on the moisture level required to
  minimise dust when processing material. In practice the graph of dust vs moisture level of a
  material is more useful as it illustrates the impact of adding moisture to the ore. This allows
  organisations to select an acceptable dust level and an associated target moisture level. The
  graph produced to determine a DEM are usually logarithmic.
  dust
  Read more at: http://www.amsj.com.au/news/health/settling-the-dust-how-much-is-too-much/ |
  Australasian Mine Safety
  56
  Image taken from: https://www.amsj.com.au/settling-the-dust-how-much-is-too-much/
  It is important to understanding the behaviour of the material with different moisture levels. For
  example when increasing the moisture level of some materials they will become sticky or clump
  before they reach their DEM. For these materials this stickiness will cause cause problems with
  handling of the material, and hence the target moisture level will need to be higher than where
  this becomes an issue.
  Material Handling Design
  The design of material handling systems can impact the amount of dust generated. The following
  are some of the key points in material handling design:
• avoids the direct impact of material on chute surfaces – guide the stream
• minimise material free falling – again guide the stream
• when transferring material between belts try to match the material velocity with the
  belt speed
  This is a very complex topic using fluid dynamics principals. When designing a new materials
  handling system we could encourage you to consult a specialist in this area.
  Dust Lift Off
  The Dust Lift off velocity is particularly relevant to stockpiles and tailings dams. Understanding
  the velocity or wind speed at which dust will lift off allows better management of dust control. For
  example if the weather forecast for the next day has a wind speed above the dust lift off velocity
  then proactive actions such as wetting or crusting can be undertaken to minimise dust lift off.
  It is important to note that smaller particles will lift off the stockpile at lower wind speeds than
  larger particles. This is an issue as the smaller particles (PN10 – less than 10 micron) are the
  particles of concern and are too small to be visible. So by the time you see dust coming off a
  stockpile the smaller particles on the surface have already been blown away. It is worth noting
  that the larger particles on the stockpile do protect the smaller particles so once they start to
  move and lift off more smaller particles are exposed and blown away as well. The following table
  provides a guide of wind speeds for particles of different sizes and densities.
  57
  Material Density 1 Micron Particle 10 Micron Particle 100 Micron Particle
  Coal 800 kg/m3 0.8 m/s 2.6 m/s 8.3 m/s
  Dirt 1300 kg/m3 1.1 m/s 3.4 m/s 10.6 m/s
  Iron Ore 2200 kg/m3 1.4 m/s 4.4 m/s 13.8 m/s
  Lead 3200 kg/m3 1.7 m/s 5.3 m/s 16.6 m/s
  In practice it is recommended to get samples tested to determine the dust lift off speed. The
  following image demonstrates this.
  Image taken from: http://ro.uow.edu.au/cgi/viewcontent.cgi?article=2949&context=eispapers
  Dust time in air and dust travel distance
  The time dust particles hang in the air and the distance they travel is important to understand
  because visible dust (> 25 micron) falls to the ground quicker and does not travel the same
  distances as PN10 dust. The following table provides theoretical fall time in air and travel
  distance for dust particles of different sizes and densities. The table uses a 10m starting height
  for the dust particle and a 1m/s wind speed (3.6 km/hr).
  Material Density
  1 micron
  1 m/s wind
  10m off ground
  10 micron
  1 m/s wind
  10m off ground
  100 micron
  1 m/s wind
  10m off ground
  Time Distance Time Distance Time Distance
  Coal 800 kg/m3 4.8 days 400 km 70 min 4.1 km 41 sec 40 m
  Iron Ore 2,200 kg/m3 42 hrs 150 km 25 min 1.5 km 15 sec 15 m
  Lead 3,200 kg/m3 29 hrs 100 km 17 min 1.0 km 10 sec 10 m
  The table can be used to estimate travel distances for sources of dust because a change in
  height or wind speed impacts the time in the air and the travel distance proportionally. For
  example, particles from a source which creates a plume of dust 5m high or a 5m high stockpile
  will have half the time in the air and half the travel distance to that shown in the table. If you want
  to understand the travel time of a particle in 3m/s (10.8 km/hr) wind then multiple the values in
  the table by 3.
  58
  Matching Water Droplet Size with Dust Particle Size
  Dust particles join with water droplets of the same size much more efficiently. This is due to the
  air stream that occurs at the surface of the dust particle and water droplet. The larger the
  particle/droplet the thicker the air stream and the further it protrudes from the surface. When
  there is a mismatch in particle/droplet sizes it is much harder for the smaller particle/droplet to
  push through the air stream of the larger particle. The following image demonstrates this.
  Image Source: http://www.spray.com.au/Literature_PDFs/B652_Dust_Control.pdf
  Water droplet surface area & droplet numbers
  Airborne dust suppression using fog or mist relies on the surface of a water particle impacting the
  surface of a dust particle. Maximising the water particle surface area helps the dust suppression
  performance. To maximise the surface area you need to minimise the droplet size. The following
  table illustrates the surface area for 1L of water. Similarly the likelihood of collision is related to
  the number of droplets – the higher the number of droplets the higher the chance of a dust
  particle impacting a water droplet and falling to the ground.
  Droplet Size Droplet Surface Area Droplet Number
  10 micron 600 m2 1.9 trillion
  30 micron 200 m2 71 billion
  100 micron 60 m2 1.9 billion
  300 micron 20 m2 71 million
  1 mm 6 m2 1.9 million
  59
  Water droplet size by spray nozzle type
  Water droplets discharged from nozzles have sizes usually in a typical bell curve (curve max is at
  centre and falls away at sides). Dust particles also come in a range of sizes and their distribution
  can be very different to a bell curve as the following real example shows.
  The selection of spray nozzles for an application should take into consideration the dust particle
  size distribution. The following extract from the Spraying Systems: A Guide to Spray Technology
  for Dust Control illustrates the key considerations when selecting a nozzle.
  It is important to note that matching the nozzle droplet size to the dust particle size is only
  applicable where the nozzle discharge is close to the dust source. A good example of this is Fog
  Cannons where the discharge droplet size needs to be larger as the droplet reduces size as it
  travels due to water droplet break up and evaporation.
  60
  Hydrophobic Dust Material
  Some dust types are hydrophobic – the dust particles repel the water droplets. Dust can be
  hydrophobic to various degrees. When dust is hydrophobic it is harder to increase the material
  DEM and also makes mist or fog based dust suppression less effective.
  Wetting agents and agents with ionic charges can be used to reduce the hydrophobic effects of
  dust. A simple test can be used to see if wetting agents will make a difference. Have 2 glasses of
  water and put a couple of drops of wetting agent (eg quality dishwashing detergent) into one and
  gently mix it without creating froth. Sprinkle a small amount of fine dust on the water surface of
  both glasses and see if there is any different in the time the dust takes to sink. If the dust just sits
  on the surface and does not sink then it is hydrophobic.
  If you have a particular dust control application you would like to discuss or would like more
  information then please call us on +61 2 6062 3300 or send an email to sales@wetearth.com.au.
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  62
  Water Salinity
  Salinity refers to the amount of salt in water (expressed as total dissolved solids, TDS).
  Most common salts in Victorian inland waters are derived from common salt, gypsum, and
  lime (calcium carbonate or sometimes magnesium carbonate). Salinity is expressed in
  electro-conductivity units abbreviated as EC. (1.6EC =1mg/L, (milligrams per litre);
  mg/L=parts per million (ppm). Salinity is also expressed as parts per thousand. 1ppt =
  1,600EC.
  Categories of TDS given in Water Victoria (1989) are:
• Freshwater less than 800EC
• Marginal 800-2,400EC
• Brackish 2,400 – 8,000EC
• Saline more than 8,000EC
  Adverse biological effects begin to occur in freshwater rivers when salinity exceeds
  1,500EC. Almost all adult native freshwater fish species can tolerate quite high salinities
  (16,000EC) with some species able to withstand sea water (56,000EC). In order to maintain
  this salt/water balance, active and passive transport of salts and water, both into and out of
  tissues takes place.
  Fish in freshwater have an internal salt concentration greater than that of the external
  medium and large volumes of fresh water enter the body via osmosis through the gills and
  oral membranes. In order to maintain their salt concentration, they actively absorb salts
  through their gills and also reabsorb salts from their kidneys. Their urine is therefore very
  dilute.
  Marine fish have an internal salt concentration less than that of the external medium.
  Water moves out of their body by osmosis and they dehydrate. To compensate for this,
  they drink large amounts of water, which in conjunction with salts is absorbed by the gut.
  Salts (Mg, SO4 & CL) are filtered out of the blood by the kidneys while Na, K & CL are
  excreted by the gills. Their urine is very concentrated. The survival of freshwater fish in
  saline conditions therefore requires them to be able to maintain their correct level of
  internal salt concentration or osmolality. All teleost (bony) fish, both marine and
  freshwater, maintain their internal osmolality at about the same level (7-13g/l TDS).
  If a freshwater fish exposed to saline or brackish water does not have the necessary
  biological mechanisms to control internal water and salts, then its osmotic balance will be
  upset and the fish will die.