Mod 3 - Processing & Tailings Storage

No matter how small the risk, it is completely unacceptable to have cyanide storage, treatment and enlarged tailings storage within the proposed water catchment.

There are multiple examples in NSW, Australia and internationally where well engineered and planned systems have failed with disastrous consequences - some in very recent times.

There a risk of failure in the system from lightning strike, extreme weather events, human error, vandalism, etc in the short and/or longer term. The potential for material to leach from or otherwise affect the site will endure long after the applicant has moved on.

If established, there may be strong pressure to approve use of the site for treatment of ore from other mines, which would further increase the potential hazard.

Toxic material or pollution in the creek could have disastrous consequences downstream for the Araluen Valley, the Deua River ecology and the drinking water for Batemans Bay and Moruya.

Approval of this modification would result in a complete loss of faith in the NSW planning system by myself and many, many others, especially given that there are less problematic solutions such as off-site treatment.

Pip Giovanelli, Bells Creek.

Using cyanide in a village near a watercourse is just stupid... The likely risk is too high and relies way too heavily on prevention of human error which is not always possible

I write in support of residents of Majors Creek and surrounding communities who oppose the modifications to the Dargues Reef gold project proposal, which include onsite processing of ore using cyanide. I have several friends and family members who live in the region, including two households in Majors Creek village. As a Canberra resident, I have fond childhood memories of spending time in the nearby Araluen valley visiting generations of family on my mother's side, and as an adult I have enjoyed many wonderful years at the Music at the Creek Festival, reignited by the local community in 2014. The health and wellbeing of the Majors Creek community and surrounding region--physical, social and environmental--is in grave danger if the onsite processing using cyanide goes ahead. I concur heartily with the concerns raised by Jackie French in her article 'Don't destroy my beloved valley' (http://thehoopla.com.au/cynanide-heart-beloved-valley/). In Jackie's words, `One spill, one accident, has the potential to destroy it all.'

As a resident of the Eurobodalla I object to the third modification to the Dargues Reef Gold Mine.
The site sits at the head of one of the most pristine waterways in NSW, and is totally unsuitable for this kind of operation.
As someone who has worked in the field of human health for over 20 years I am deeply concerned about the permanent health impact that this modification poses to the more than 40,000 people who rely on this water way for drinking water.
It is not worth the health risk to the shire residents and it's visitors to make this modification, when the mine has operated for years now without the need to process on site. As well as this, there will be significant risk to the environment (flora and fauna), and the modification will significantly impact on the livelihood of the small scale farmers that work the land along the river. Small scale farming is a booming industry in our shire and is providing a livelihood for a growing number of young families in the area. Small scale farming is seeing this shire being recognised as one of the leaders in this new wave of farming by win National awards (Sage gardens and Farmers Markets). Risking this livelihood and the prestige that it is bringing to our shire is illogical and unproductive.
The company has an unsatisfactory track record in being able to manage spills and tailings, as shown in there management of spills at the Dargues Reef site and other sites in their management interstate, meaning that the risk of contamination of our beautiful Deua river is high.
Please do not risk our river for this unnecessary modification. The risk is too high and the potential loss is too great.
Yours Sincerely,
Melanie Turner

As a resident of Eurobodalla and landwoner on the Deua River which provides my household water for my family I object to the modification to the Dargues Reef Gold Mine Development Application.
* The main danger with this project for those living in the Moruya River Catchment is the assumption that there will never be failures in the design or running of the proposed processing plant. Accidents have and will happen.
* I am appalled that, as with the original development application for the mine, there is no
reference to or assessment of the risks posed to the drinking water supply for the almost 40 000
residents of Eurobodalla Shire who rely on water drawn from the Deua River system.
* the proposed modification creates a pollution
risk that is unacceptable to residents along the entire Moruya River catchment. The potential cost
to our community is too great and Unity is ignoring the threat to our well-being.
In the rain event just this week, Majors Creek received 152mm of rain so far, compared to only 82mm at Braidwood yet according to Unity Mining representatives, they have used Braidwood rainfall figures for their modelling.
Please do not allow on site treatment at this mine.

Submission on Dargues Reef Mine - Modification 3
Application number 10_0054 MOD3

How interesting it is to be composing this submission as the Mt. Jerrara Dam south of Wollongong is failing due to torrential rainfall from an East Coast Low Pressure System of the kind we are regularly experiencing in this era of climate disruption.

I have two main objections to Modification 3.

Firstly, the original approval for the Dargues Reef gold mine was based on a proposal to mine for gold, not to process gold using cyanide. This modification must be rejected, otherwise what is the point of having an exhaustive and expensive approval process?

Secondly, the risks involved in using cyanide to separate gold from ore are too great compared to the extremely limited and short-term benefits of the mine. The risks will be borne by the public and the huge costs of cleaning up - to the extent that it is possible - by the taxpayer.

The benefits will go to a privileged few.

The risks include (but are not limited to): damage to the livelihoods of many farmers, threats to the water supply of settlements along the Deua River, and catastrophic damage to ecosystems all the way along the creek and river.

Today we not only witnessing, locally, the power of nature to throw our human systems into chaos, but if we turn our eyes further afield we can observe two gold-mining-related environmental catastrophes playing out at the moment.

On August 5th 2015 a toxic plume emanating from an abandoned gold mine near Silverton Colorado began its journey downstream and thence through three states of the USA. Three million U.S. gallons of polluted mine waste water and tailings flowed into a tributary of the Animas River in Colorado after EPA officers tried to drain a tailings dam which had been leaking into waterways for years. In places the plume was 80 miles (128 kilometres)long. the clean-up (such as is possible) is ongoing.

One week later a chemical warehouse exploded in the huge city of Tianjin, Eastern China, killing dozens of people and releasing the highly dangerous sodium cyanide (mainly used for gold mining) into air, land and sea. "Safety violations and corporate negligence" are reputed to be the cause of this disaster.

The risks of using cyanide in gold mining are well-known, indeed the use of cyanide for this purpose is prohibited in many more enlightened societies than ours. The risks and costs are spread far and wide, as illustrated above.

The economic benefits of using cyanide on-site to process the gold from this mine are restricted and even doubtful and are heavily outweighed by the possible costs to the environment and to local human settlements. The precautionary principle must come into play and this application for modification to approval should be rejected by the Department of Planning and Environment.

Judith Turley
25/8/15

I believe this action is inappropriate as it pollutes a river, that I enjoy using, for absolutely no reason.

i disagree with the use of cyanide near our water catchment.

Submission on EA FOR THE DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054 July 2015




To Whom it may concern,

I wish to register my objection to the current application for modification to the Dargues Reef Gold Mine Development Application.

As a resident of the Eurobodalla Shire I find it frightening that such a drastic change to the operation of the mine, and one with the potential for such devastating environmental impact on the catchment, should be assessed as only a modification to the existing Development Application.

The proposed future activities at the Dargues Reef Gold Mine are far and beyond those that were approved in the original DA.

I believe that the risk, through tailings containment failure, of environmental damage and contamination of the catchment by heavy metals is unnacceptable, and that the health of the catchment, its wildlife and human inhabitants and the marine environment it feeds should take greater priority than the economic advancement of a private mining company.

EXTENSIVE RISK ASSESSMENT OF TSF REQUIRED
I would urge that recommendations from the EPA be followed such that a full risk assessment, addressing all environmental risks associated with Tailings Storage Facility, be completed before any assessment of this modification can progress.

I would have hoped that such assessment would be compulsory for an application that includes the storage of dangerous heavy metals and cyanide residues left after the gold is extracted.

Failures of these storage facilities can and do occur. I am concerned that Unity has little reference in their risk assessment to the consequences and possible impacts to life and livelihoods resulting from a catastrophic failure of the TSF such as a breach of the wall.
The danger of spillages and leaching also need to be examined in much greater detail than Unity have provided, and should include climate modelling for the local conditions of that site as it is subject to higher rainfall events than surrounding areas.

I find it unacceptable that Unity's proposal includes no mechanism to divert for spill water from the TSF from flowing into Spring Creek and the Majors Creek system.

I also find it unacceptable that, in the current application and the original DA, there have been no references to or assessment of the risks posed to the drinking water supply for the almost 40 000 residents of Eurobodalla Shire who rely on water drawn from the Deua River system.

I cannot see how this modification could be approved when it places the health of the Deua River system at risk. Unity cannot claim that the proposed modifications can be constructed and operated in a manner that would satisfy reasonable community expectations, since anyone living or deriving a livelihood downstream of this project would expect to be able to safely use, drink from and enjoy the river environment, now and in to the future, and Unity cannot guarantee this.

My name is James Royds, I manage and live with my family on my mothers 750 acre grazing property which adjoins the Dargues Reef mine site to the north east. My family has owned and maintained this land for 7 generations.

I was not opposed to the mine proposal submitted by Cortona and initially accepted by Unity. My understanding of the on site processing to concentrate form and subsequent trucking of concentrate off site for final processing was a proposal I was comfortable with. Benefits to me of this proposal were a relatively inert Tailings Storage Facility (TSF), and benefits to those in Braidwood supporting a small number of local Truck drivers.

In all my interactions with the companies involved a clear commitment was made not to use cyanide in the on site processing of ore.

I strongly urge you to reject the current modification 3.
It breaches a commitment made to the community, and requires an inadequate TSF to hold toxic tailings, details of which will be apparent to you from other submissions, whilst providing no additional benefit to the community of Majors Creek and surrounds. The only benefit of this proposal is to the companies bottom line.
Thank you for your consideration
James Royds

Dear Sir/Madam,

I am a rate-paying resident and residential property investor in the Palerang council zone and am strongly against the proposal by Dargues Reef gold mine to undertake cyanide processing at its operations near Majors Creek.

There are many agricultural, residential and recreational users of Majors Creek, Araluen Creek, Deua River and Moruya River and I do not believe that the short term economic benefit with this added risk of contamination to these waterways outweighs the livelihood and quality of life of the thousands of residents downstream.

My understanding is that this mine was approved in 2011 with a clause prohibiting the use of cyanide processing at the mine. I feel that now the miner has a `foot in the door' they want to change the goal posts. Unity Mining is a company and Dargues Reef gold mine is an operation which has a track record of failing N.S.W. environmental standards (such as in September 2014 at Major's Creek). I am not satisfied that there would be safe long term management of toxic waste at the site, including after the mine had reached the end of it's viable economic life. I believe if pollution occurs after the mine has ceased extracting gold then the cost of cleaning up the mess will fall on the tax payer and not the company that caused the problem.

The gold price was about US$1,900/oz in 2011 has slumped to about US$1,130/oz today. This type of market volitility has historically tempted miners to cut costs and take short cuts. I believe this adds to the risk of Unity Mining causing major, long term environmental damage.

I own an investment property in Braidwood and so I benefit directly from the strong rental market bought by a major employer in the region such as the Dargues Reef gold mine but I am very willing to sacrifice such a financial windfall in the interest of a clean and healthy environment for my neighbours.

Allowing Unity Mining to use cyanide at the Dargues Reef gold mine is irresponsible and is not providing rate payers with the security and environmental sustainability we expect from government. In 2015, I want my government to make decisions that protect the long term health of our families, our community and our environment. Not making decisions that are solely based on short term profits (both mine and those of Unity Mining).

I object strongly to this change in Dargues Reed Mine's operation, and I urge you to reject it.

Yours sincerely.

Unfortunately I have not had time for extensive review of the materials, history and environmental work on this site.

I am a former Director of an Environmental Consulting firm and have significant experience with Tailing Storage Facilities, biological surveys and risk assessments.

Clay-lined TSFs are common and are problematic. In my experience, every TSF will leak (sooner or later - typically within 5 - 10 years of construction).

It will then release sediments and possibly metals to the environment (via both surface water and groundwater). There are hundreds of TSFs across Australia in this situation right now.

In that context, the proponent's aim to process on-site and build a TSF may potentially create a significant risk to amenity, wildlife, land use and livelihoods.

Any amendment to the existing DA needs to consider downstream impacts via a thorough risk assessment and community consultation process.

We only have one source of groundwater large enough to supply the region. Short term financial gain is not worth the potential risk to that supply.

I would like to put in a submission against modification 3 to the Dargues Reef Gold project. As a resident of Majors Creek for the past 13 years, my husband and I made a decision to buy a property in the village of Majors Creek to raise our family as we saw a village that provided social cohesion and a safe place to raise our children within a lovely environmental context.
The proposed modification to the Dargues Reef approval with the introduction of on-site processing involving cyanide is not acceptable.
The principles of Ecologically Sustainable Development require the social and environmental impacts to be given equal weighting to the economic impact. Having read the EA that accompanies the proposed modification, the social and environmental impacts appear to have been glossed over and the perceived economic benefits are given as the main reason to approve this modification.
But these supposed economic benefits are only applicable to the company and shareholders as it reduces the cost per tonne for the extraction of the gold, and therefore creates more profit for the company and therefore shareholders.
There is no tangible benefit to the Majors Creek community, or to my family as we chose to live in Majors Creek for a lifestyle and neither myself nor my husband are seeking work at the mine, nor own shares.
The risk to our family, lifestyle and property are completely unacceptable, especially as the supposed tangible economic benefits are short lived and then the community will be left with the high risk of a tailings facility forever and a day.
I am also concerned that under the original approval, the EA stated that the material would be transported to Parkes for processing. It is now become apparent that this is not possible and had never been formally approved prior to the lodgement of the original application. To me, at best this indicates that the original EA was flawed and at worst, the public and the NSW government was purposely mislead to gain the original approval, and now we are seeing development creep, and as a member of the Majors Creek community, I am fearful that this modification will be the start, if approved, of material being brought from off-site to be processed at this site. This has been indicated by Unity Mining to their shareholders in their other explorations in the area.
I believe that the risk associated with this proposed development is too great, and the economic benefit does NOT outweigh the environmental risk. Precautionary Principle and Inter-generational equity - both key principles of ESD, demand that the NSW Government refuse this modification. Thank you.

The on site processing of ore using cyanide significantly increases the consequences of contamination of the watershed of the Araluen and Moruya rivers. Contamination has already occurred and the owners of the mine have been found guilty and fined. To trust their planned control measures to protect against contamination, if this proposal were to go ahead. would be folly.
The consequences are too great and the modification should be refused.

To Whom It May Concern,

My name is Jake Smith. I am resident of Bermagui. I am a keen nature enthusiast. I have lived in the area on and off for my entire life of 38 years. I have explored the bush all through this region, in the mountains and along the coast. I consider myself to live in one of the most beautiful habitable environments on earth.

I am therefore stronly opposed to the modifications proposed for Dargues Gold Mine in Majors Creek, NSW, that would remove the conditions from their original consent that allow them to process ores with cyanide.

To be blunt I am absolutely appalled at the prospect of the suggestion of potentially introducing cyanide, an extremely toxic chemical, anywhere in the local environment, let alone in the catchment of the unique and pristine Araluen Valley.

These soughts of chemicals should never be used no matter how safely controlled the profiting industries promise. One has only to look at Fukashima to see how these "guaranties" and "promises" cost civilians and the environment.

Why can't the financial corporate giants of this world with all their money, with all their capacities, find clean and sustainable methods to operate their industries? Instead they exploit and ruin the environment for their needs and profits! And it's we the common people who suffer the loss and damage to our lands.

Jake Smith

I submit I have read your proposal and environmental safeguards and I am satisfied they meet with community expectations. I live in North Queensland but also own property in Majors Creek.

To Whom it may concern,

I am writing to express opposition to the proposed cyanide processing plant so close to both the public water supply and natural habitat of some 23 endangered species at Major's Creek.

Given the spill in 2014, approving the development would only raise the threat of a repeat incident. Given the unique value of the resources, the area cannot afford such a risk to its environmental systems.

I hope that the serious threat posed to the community and eco-system of Major's Creek are appropriately considered, and that the application is rejected.

Regards,

Chris Endrey

As a resident of the Eurobodalla living on the Deua River I wish to express my sincere hope that we continue to be free to enjoy the clean water that the river supplies not only me and my closest friends but the whole town. I love the river and spent time in its beauty every single day. I drink it, water the food that i grow to eat and to sell at the local market and swim in it. It brings me joy and I powerfully hope that every person who is involved in making this incredibly important decision is aware of the importance of the freedom and basic human right of access to the cleanest of water. I wish the same for all of you and your families and loved ones.
Thank you for taking the time to read this.

I am a horticulturalist with interest in the well been of the river i pump water from. I live on the Deau River and i would like to continue to trust the water i use to grow food plants for my family as well as the animals we graze for our own meat production. I am also very concerned about the quality of the river water for its own natural ecosystem.
I would like to ensure that this river remains the way it is so mining of any sort is not healthy for this river system which is the water supply for the Eurobodalla shire council .