Jawatankuasa Bertindak Menentang Penggunaan
Cyanide Dalam Perlombongan Emas di
Bukit Koman, Raub, Pahang
d/a No. 382B Bukit Koman
We, the residents of Bukit Koman have lived a peaceful and trouble-free life in our village for generations. However, now circumstances have caused us to become very concerned for our health and safety, as a result of the operation of a Carbon-in-Leach gold recovery facility in our village. As citizens of this country, we have a right to a clean, healthy and safe environment as well as full and frank disclosure of all information regarding any activity that will adversely affect this right. We have reason to believe that the operations of this gold recovery plant will adversely affect and impact our health and lives. We have consulted experts, who have raised very pertinent questions and concerns, all of which remain unanswered. The authorities on the other hand have stated that the plant is safe, and we are concerned they have done so without considering our concerns and those of our experts, and without proper and complete information regarding the gold recovery plant.
For this reason, we have decided to make the following demands, so that our concerns are met, our questions answered, and all pertinent information be made available to all parties.
1. A Steering Committee be set up to deal with issues and complaints raised by the local community, and as a central body to which all information that is requested be made available. The committee should comprise the following,
- Representatives from the community including lawyers;
- Representatives from the Department of Environment (DoE), Department of Minerals & Geoscience, Department of Occupational Safety & Health and Department of Health; and
- Representatives from Raub Australian Gold Mining Sdn Bhd (“the company”)
Such committees have been set up in other jurisdictions, and the rationale for doing so is that where there is a conflict between a community and a polluter, there should be a committee of experts to resolve a problem of environmental contamination (or potential contamination) that the government alone lacks the capacity to resolve. Further, such a committee will begin a process of open and transparent communication with the authorities and the company, so that the community may have access to all necessary information to be able to know what is going on that can potentially affect them.
2. A working group be set up under the Steering Committee comprising a panel of experts in mining, toxicology, occupational health & safety, health & environment and other related fields, to review the effects and impacts of the Carbon–in-Leach facility on the local environment and community, to assess the potential hazardous wastes and effluents from the plant, to review all existing or planned infrastructure to manage such wastes, to receive and review all technical reports and information received from the company or the authorities, pursuant to the demands in this document.
The tasks of this panel of experts will be further specified in a Terms of Reference (ToR) prepared by the Steering Committee.
3. The following documents, materials or information be produced to the Steering Committee:
3.1 The Environmental Management Plan, including detailed information about the location for the disposal of processed tailings and measures that will prevent the seepage of toxic contaminants into groundwater environment.
3.2 The Environmental Monitoring Plan, including detailed information about the location of sites for the monitoring of tailings leachate and groundwater quality so that the migration of contaminated leachate can be detected at the earliest possible time to allow necessary intervention for the protection of groundwater.
3.3 The Emergency Response Plan
3.4 The Rehabilitation Plan
3.5 The Detoxification Plan
3.6 The approval documents pertaining to the Effluents Treatment Plant approved in December 2008, including the conditions of approval, the design and layout of the plant, standards for treatment that are to be complied with by the company, and all or any other related documentation
3.7 Details of the air pollution control system within the facility, if any.
4. The company be required to put up a Rehabilitation Bond for the rehabilitation of the environment and safety of site after closure, in accordance with the Pahang Mineral Enactment 2001. The company must prepare a comprehensive valuation on rehabilitation and its administration and submit the same to the Steering Committee and the panel of experts. Sufficient funds or bonding authority (using international standards for assurance bonds) should be available for a third-party contractor to perform rehabilitation work. Sufficient additional funds should also be available in the bond for the Department of Minerals and GeoScience to adequately oversee the reclamation (or remediation) of the site so that no public expense would be required in the event of a financial inability of the company to continue. The bond should be updated on a yearly basis.
5. The company be required to provide financial assurance, in the form of a bond or other suitable form, to contain and clean-up the release of contamination and acid-mine drainage that may occur as a result of the mining activities, and for the treatment of persons who experience serious health problems upon exposure to contamination or discharge from the plant. The financial warranty should be set and maintained at a level which reflects the actual current cost of fulfilling the requirements of the Environmental Management Plan and the Emergency Response Plan. Such bonds are required by the laws in
6. The company be required to make available to the Steering Committee quarterly reports of the amounts of chemical brought into the facility (shipping documents etc).
7. Monthly monitoring of water quality (for arsenic, cyanide, lead, mercury, cyanide compounds, aluminium, antimony, arsenic, cadmium, chromium, copper, fluoride, iron, manganese, mercury, nickel nitrate, pH, sulphate, thallium, total dissolved solids, zinc, cyanide (total), cyanide (weak acid dissociable) be carried out by the Department of Environment (DOE) at the cost of the company. DOE should also monitor the additional standard analytes in drinking water of
8. Monthly emission discharge monitoring be carried out by the DOE, at the cost of the company, for, among others, sulfur dioxide, cyanide, mercury. The resulting reports must be made available to the Steering Committee within 30 days of being released. These should be accompanied by discharge limits for each constituent, and immediate (24 hours) public reporting of discharges in excess of those standards. There must be immediate investigation of significant community complaints on odours and noxious fumes.
9. Monthly monitoring and reports on the volume of discharge into tailings facilities and into receiving waters be carried out by the DOE or the company. The various discharge points should be identified. The reports must be made available to the Steering Committee within 30 days of being released.
10. Medical surveillance to be conducted by the Ministry of Health every 3 months on a sampling of the community in Bukit Koman and the report to be produced to the Steering Committee.
11. The company become a signatory to the International Cyanide Management Code (ICMC), and its operations be subjected to an independent third-party audit verifying that the plant meets the Standards of Practice, Production Practice or Transport Practice, thereby enabling it to obtain certification under the ICMC.