MOD 15 - Various including tailings dam embankment upgrade

Comments and objections included in the attached.

To DPE,

I am writing to in relation to current Modification of Cadia Valley operations. (CVO)

Since the Tailings dam collapse in 2018 I have taken more notice of how CVO manage and communicate the way they run their mining operation.
From the point of view of CVO it’s about “Tonnes of Ore processed” and having a safe work place.
The mining engineering that has taken place at CVO is quite amazing. These are the views of some mining services contractors that visit and work in many mine sites around Australia. Also to this it has been mentioned that it’s scale is getting more difficult to manage. Maybe having Newmont taking it over might be a good thing.
When I talk about scale, in many community meetings they convey different strategies on how they are going to fix the tailings dam. There SHOULD be experts in DPE telling them how and when to fix it. YOU are the regulator?
It has taken a lot of time from the community to make the EPA aware of the issues with CVO. Over the years EPA staff have ignored these issues. I’m glad some this dead wood has been moved on.
The EPA have finally listen to the community and taken action. With 6 charges and 4 Guilty pleas to date, it’s shows CVO are not in control of their operations.
Also CVO putting out a 2000 page document at a very busy time of year it shows sheer arrogance to the community. How businesses of this size have the same time of Public submissions to other much smaller operations shows another flaw in the planning process.
Lets look at Vent shaft dust, I was at a community meeting at CVO, I ask the acting CEO that night:
“ Why didn’t you put filters in during earlier modifications ?”
Answer: “ We didn’t think we needed them” and “ Nobody else does it”.
Which Department or Regulator is at fault here??
When looking at the allowable levels that CVO are allowed to emit. The easiest solution for them is just get a BIGGER fan.
Thus mg per cubic metre.
Also with sperate new fan extraction sites it just give CVO more scope as accumulation to put more dust into the community.
I’m putting in a link to how the Canadians view dust pollution.

https://www.canadianminingjournal.com/featured-article/a-guide-to-air-pollution-monitoring-in-mining/

We need to do better in Australia.

The DPE look to be the regulator of the design of household rainwater systems.
The most current BASIX I have found is 2015. DPE label on it. Looking at a few houses in the Forest Reefs area that are built with all current guidelines. These houses are less than 3 years old, the water quality of them was not what you would expect . Having First Flush systems installed from the start. Does this tell a story that DPE need to improve the rainwater guidelines or decrease the dust from the neighbours??


I believe that the requested mod 15 should be declined until both Cadia and the DPE have taken the concerns of the local community seriously and clear actions required within any approvals to address:
- Real reductions in pollution levels including holding Cadia to a restriction of 20mg/m3 in dust particulates per vent, and a strict limit on total emissions including general dust, heavy metal contaminates and diesel particulates.

Thanks.

With recent guilty pleas in the Land & Environment Court and many EPA fines, the continued operation of CVO is what should be being assessed.
There remains at least 11 outstanding reports in regard to Mod 14: no extensions should be considered until ALL outstanding reports are completed and all investigations around compliance are closed.

• It seems to be quite poor timing of the Modification (late November) on part of community with more than 2000 pages to review and comment on. A conveniently very busy time of year for people to sit down and read the document with a thorough understanding and limited time to submit difference of opinions and concerns.
• How can CVO be allowed to proceed with Mod 15 when in excess of 11 reports remain outstanding from Mod 14.
• We have a concern for the Hydro-cyclone sands technology as there is very limited information on this, far more information required for the community to make comment on, particularly if this to be CVO’s preference for the next Environmental Impact Statement (EIS) – Cadia Continued Operations Project (CCOP)
• We have found there to be no information on the rehabilitation plan of tailings dam. This is apart from the Final Landform pictures showing tailings dam will be used for agricultural grazing land. This is a contradiction as for many years the community has been told by CVO that this area cannot be used for agricultural grazing.
• Interestingly the realignment of Panuara Rd – heavy vehicle route changes, how will this impact local residents and local businesses? What happens when stock trucks cannot cart through to CTLX or visa versa.
• There needs to be a visual improvement and tidy up MUST be completed on VR14 (collapsed and filled in vent on Cadia Rd) with screen planting of trees and shrubs. Why was this done so close to a main road? It is ugly and frankly embarrassing for us when we have guests to our residence having to drive past this. In the past it was a beautiful road to drive along, this has all sadly changed.

Please find submission attached.

To whom it may concern
1.Issue: Local road network - deterioration in local roads through the ongoing lack of funding.
My submission relates to the ongoing use of the local road network that services Cadia Mine (CVO).
My family and I have lived at Spring Terrace for the past 20 years. In that time we have experienced the deterioration of Orchard, Forest and Whileys Roads and Worboys Street in Spring Hill. We use these roads regularly and are aware of the traffic generated by the mines activities on a daily basis. This traffic comes in the form of light traffic from workers at the mine commuting daily and also the heavy vehicles providing goods & services to the mine, in particular the aggregate (crushed basalt) transported from the nearby Shadforth quarry to the mine.
This transport route being Orchard, Forest and Whileys Roads and Worboys Street in Spring Hill, clearly lacks enough funding to be fit for purpose. In particular Whileys Road and Worboys Street in Spring Hill are within Orange City Councils area and are in very poor condition with no foreseeable plans by Orange City Council to rebuild them. Rebuilding of Forest Road near Spring Hill village has been undertaken however it is incomplete through the lack of funds and where recent work has been undertaken (in the past 2 to 3 years) the road surface has already started to fail.
For the safety of all road users, that is the public and the CVO workforce, more funding is required for these roads as they cannot withstand the ongoing demands placed upon them under the current funding model. More money needs to be spent urgently.
As to heavy vehicle movements along this route, this needs to be stopped and heavy vehicles re routed via the Mitchell Highway, The Southern Feeder Road in Orange and along Cadia Road. These roads are built to take heavy vehicles, unlike Forest and Whileys Roads and the streets in Spring Hill that were originally built as country roads, not designed to withstand the current demands placed upon them.
2.Issue : Creation of facilities at CVO for the drivers of heavy vehicles.
As long term residents of this area, we have experienced issues with truck drivers using local layovers in Forest Road for rest areas. The drivers have used these areas for ablutions (there are no facilities), changing tires, and leaving rubbish Etc.
I recommend that CVO develop toilet and rest facilities (on their site) for the drivers of these heavy vehicles servicing CVO.
Thank you.

I wish to object to this submission on the grounds that a number of recommendations in MOD14 are yet to be met, so I am recommending that these are fixed first before any move forward. As well, CVO has lost the confidence of the community with their blatant lies and misinformation continuously panned out to the community. We, as farmers, have to abide by rules and respect our neighbour's right to a healthy lifestyle, why can't the mining industry? (esp CVO in this case)

I object to the modification on the grounds outlined in the attachment

I object to this submissions timing. This submission was lodged by Cadia Valley Operations (CVO) on 24 November 2023, with submissions due by the 14 December. The timing of this submission conflicts with upcoming Christmas season, which doesn't allow anywhere near enough time for the typical lay-person, such as myself & many others also affected by this modification, to review the document, which is quite long, intricate and complicated. I would think that the purpose of public consultation is to allow the community to be able to review the document & be able to submit their opinions, limit us, by putting this modification out for exhibition for such a short time at the busiest time of year is just not practical or fair!

Already knowing that CVO has pleaded guilty to three of the five air pollution charges from the EPA, I object to CVO being allowed to proceed with MOD 15. Also knowing that CVO have not as of this time, completed all the conditions from Mod 14 (over 11 reports are incomplete), it is not acceptable that they are being allowed to lodge yet another modification.

MOD 15 will result in more noise impacts on myself and other residents living near the mine. We live in a rural area for its peace and quiet, and this modification will further impact our ability to enjoy our rural lifestyles. For example, the proposed changes to the tailings dams (NTSF and STSF) and the construction of a trial tailings embankment, along with the change to working hours for TSF construction into the evening, will result in increased noise to our residence, as well as increased light pollution which we already have to endure. In addition, the realignment of Panuara Road will likely result in further noise and disruption to the local community, with increased traffic, heavy vehicle route changes and further deterioration on our local roads.

Please find an attachment with my submission.

Objection to Proposed Change in Working Hours for TSF Construction

I am writing to express my strong objection to the proposed change in working hours for the Tailings Storage Facility (TSF) construction, allowing for operations to extend into the evening while complying with noise criteria outlined in PA 06_0295. The shift to evening construction poses significant concerns due to the potential increase in noise disturbances during night-time hours.

Of particular concern is the assertion that the construction noise during evening hours would surpass the usual operational noise generated by the mining company. It's crucial to emphasize that construction noise, especially related to the TSF construction, carries a substantially higher decibel level compared to the regular operational noise emitted by Cadia mine. This raises alarms about the potential disruption and disturbance caused to the surrounding community, especially during hours typically designated for rest and relaxation.

Furthermore, the proposal lacks clarity on the duration of this change. There is no mention of whether this extension of evening working hours is temporary or if it is an indefinite alteration to the company's operations. The absence of an end date raises apprehensions about the long-term impact on the local residents' quality of life and well-being.

I urge the proposed extension of working hours for the TSF Construction be reconsidered and to consider the following:
Community Impact: Recognise and address the adverse effects this change might have on the community's tranquillity and quality of life, especially during night-time hours.
Transparency and Communication: Provide clear and transparent communication regarding the duration and necessity of this change in working hours.
Mitigation Measures: Implement strong mitigation strategies to minimise noise disruptions and ensuring strict adherence to noise criteria outlined in PA 06_0295.

I ask for this proposed change in working hours for TSF Construction be reconsidered with due consideration to the concerns raised by the community.

5.2 CVO has been operating for 25 years and there is
No long-term growing. Local trees and shrubs in the tailings.
No long term trial to determine the extent of contamination taken up by plants and animals ,domestic. or native
NO time frame for any of the rehibilation
No progressive rehabilitation of th CVO sight,other than the SW West Rock bump which is now to be demolished to make way for the failed TSF

Attachment D. Illegible incomplete map

The next phase must nor be started until this is complete



Anna Fitzhrdinge

There are numerous elements that while affecting the local community for hundreds of kilometres around are described in such an oblique manner, at great length, with a deadline before Christmas, that a cynic might think the company was trying to get this passed quietly through.

Considering the level of disruption that has been caused and the inadequacy of reparations, this is completely unreasonable.

I’m also extremely concerned by the oft repeated comment that decisions are not open to appeal. In this new age of people power as evidenced by the mass protest at Newcastle’s coal port, trying to get community support rather than sneaky attempts to turn this part of the world into a series of badly designed gold mines causing earthquakes, physical and mental health issues, damage to property prices, livestock, water supply and air quality is a foolhardy move. I do not approve of this company nor agree with its attempts at repairs. There is no transparency.

Thankyou

Submission of objection attached

Dear Ms. Mazaheri,

Attached is the following documents supporting the CCSN's submission for CVO's - "Mod 15 - Various including tailings dam embankment upgrade".

1. CCSN - Mod 15 Response 14.12.2023
2. Appendix A
3. Appendix B
4 . Appendix C
5. Appendix D - x5
6. Appendix E
7. Appendix F
8. Appendix H

A total of 12 attachments.


Kind regards,


The Cadia Community Sustainability Network Inc.

Please see attached preliminary comments on Mod 15.

I object to Director O'Donohugh's advice of todays date 14/12-23 that the application must be read and determined on the papers before the Department whereas the Department is on full notice of the Proponent's CCOP 21 proposals which are intricately align with this application.
The Department must take notice of the Proponents CCOP21 Proposals as known to the Department in assessing the Mod 15 Application.

I am writing as a concerned resident to object to the Mod 15 application from Cadia Valley Operations.

My objections cover:
1. The timing of the release and limited time for the application to be thoroughly understood and in need objected to.
2. The lack of acknowledgement around the recent air pollution issues and continuing court actions.
3. The inclusion of additional high velocity vent shafts with the potential to significantly increase the pollution being spread across the neighbourhood.
4. The continued reliance on past dust modelling and health reports which are blatantly incorrect and misleading.
5. A continued lack of any realistic rehabilitation plans for what is a massive operation.
6. It appears likely that the irrigation of the tailings facilities will add further pollutants to the environment through the use of unfiltered mine water.
7. The use of cyclone sands technology which I highly questionable and has been warned against by industry experts.
8. The continued smell emissions from the Molybdenum plant which have gone unexplained.



1. The timing of the release and limited time for the application to be thoroughly understood and in need objected to.


To start with this modification application is an excessively large 2,000+ page document which has been presented to the community with a ridiculously small amount of time to attempt to gain any thorough understanding of it.

We were unable to attend the one general residents meeting that Cadia Valley operations held which we understand provided some very brief information sessions. We were then given 24 hours notice for ‘drop in’ sessions held at times which would require time away from work. This all being done at a very busy end of year time when many other commitments are already planned, and also during another covid wave which saw some people unable and others concerned about attending any meetings.

Surely any material modifications should be provided to the community with sufficient notice to allow for independent specialists to be consulted.
The recent behaviour seen by Cadia Valley Operations has left me with little to no trust in the business and an unwillingness to accept that ‘it all sounds fine.’ The devil is in the detail with most of the reports that they have provided to the community this year (sage health report, lead isotope report, dust report) and to many serious concerns have been brushed over in the summary information sheet provided with this mod request.


2 & 3. The lack of acknowledgement around the recent air pollution issues and continuing court actions and the inclusion of additional high velocity vent shafts with the potential to significantly increase the pollution being spread across the neighborhood.


The community surrounding Cadia Valley Operations have serious and ongoing concerns about the air pollution from both the dried out tailings dumps and the VR8 upwards vent shaft. These issues have taken several YEARS of community objections to Cadia Valley Operations and the EPA and really little to no action took place until the community started testing our own water and having blood and hair testing to start to understand the impact of the mining pollution on our homes and families.

This modification fails to provide any acknowledgement of the seriousness of these ongoing concerns and only appears to continue to increase the volume of contamination being blown into the air and across the local area.



4. The continued reliance on past dust modelling and health reports which are blatantly incorrect and misleading.

The Todoroski report incorporates blatantly incorrect and misleading conclusions around the volume of dust emissions from Cadia Valley Operations and the area affected by them. Cadia Valley Operations has pled guilty to charges of air pollution which are clearly outside of the limits suggested by the Todoroski air report and yet Cadia Valley Operations continue to rely on this report and the DPE still appears to be accepting it’s conclusions.

How many times does this report need to be proved wrong in court before the DPE stop accepting it as environmental evidence from Cadia Valley Operations?

Similarly the Sage Health assessment completed this year was based on inappropriately sampled water collections, and while it rightly points out that there is an unacceptable health risk to the communities surrounding Cadia Valley Operations if they drink their tap water, it inappropriately and incorrectly suggests that this is not due to any contamination in the community’s tanks, as they in many instances sampled the tops of tanks, not the bottom of tanks where the contamination settles, and it appears they have sampled tanks which had been cleaned out by Cadia Valley Operations after the cleaning not prior to – leaving no value in the outcomes.

The continued suggestion that there is something alarmingly wrong with the plumbing in the majority of houses surrounding Cadia Valley Operations, rather than a problem with what has been blown into our tanks is ludicrous.

Significant work needs to be redone around all of the environmental and health reports produced by Cadia Valley Operations contracted experts. This work needs to be completed by truly independent specialists without any re-drafting by Cadia Valley Operations prior to release to the community, DPE and EPA.


5. A continued lack of any realistic rehabilitation plans for what is a massive operation.

The scale of Cadia Valley Operations is mind boggling, and there appears to be no reasonable, realistic or scientific plan to rehabilitate the site.

Progressive rehabilitation should be starting now, and there should be no modifications approved without this requirement built in.


6. It appears likely that the irrigation of the tailings facilities will add further pollutants to the environment through the use of unfiltered mine water.

The plan to irrigate the tailings dumps will clearly utillise a massive amount of water through the summer months. It has been advised that water from the pit will be used in this process, though the community concerns and suggestion that this needs to be filtered before being spread around were literally laughed off by management at the time.

Where is the long term strategy? Where is the 1000 year rehabilitation plan?

Sprinkling a little soil over mine tailings will not provide an environment for permanent forms of flora to thrive and the outcome of this strategy will have the local community paying the price for hundreds if not thousands of years.



7. The use of cyclone sands technology which I highly questionable and has been warned against by industry experts.

The modification request includes an expansion of the use of cyclone sands technology. While the timeframe to attempt to comprehend this arrangement is as mentioned above far too limited, it I understood that many industry experts warn against the use of this technology.

It is understood that the use of these cyclone sands can significantly increase the damaging impacts of any dam wall failures, such as the failure seen at Cadia Valley Operations in December 2018. This failure has not been rectified 5 years later, and through the course of the last year Cadia Valley Operations advised the local community that it could not be fixed.

With regular earth tremors occuring in the surrounding area, another future dam wall failure would need to be an assumption within the planning process. Surely this should point to the need for dry tailings storage systems and progressive rehabilitation.

Cadia Valley Operations should not be permitted any modification request which do not fully address this realistic probability.


8. The continued smell emissions from the Molybdenum plant which have gone unexplained.

We have reported two recent occasions of strong sulfur smells at our home 14 kms from Cadia Valley Operations, and one from the Panuara Tennis Club. Our understanding is that this smell is caused by the burning off of sulfur at the Molybdenum plant, though this issue has not been addressed by Cadia Valley Operations.

It is unclear what other contaminants could also be emanating from the Molybdenum plant, though Molybdenum has been found in the health testing (blood and hair) of a large number of local residents who live within an impact zone suggested by the Zephyr report. Again more evidence of contamination and a complete lack of any transparency from Cadia Valley Operations.


Conclusion
It must be acknowledged that Cadia Valley Operations have lost their public licence, and the application for modification 15 does not go close to rectifying this situation.

There are serious detrimental environmental and human health impacts which will either continue or worsen if the request at hand proceeds.

I request that you decline the current mod 15 application until community concerns are resolved to an appropriate standard.