Mod 3 - Processing & Tailings Storage

I am commenting on this proposal in a private capacity.

I strongly object to the proposal.

I object to the proposed modification. Please refer to attached submission.

See attached.

See attached file

As a resident of Eurobodalla I object to this third modification to the Dargues Reef Gold Mine Development Application (the modification).
At worst, approving the modification s an economically dangerous choice:
A decision to allow the modification will cause foreseeable harm and decision-makers at all levels of government and industry will be held liable.
You have the evidence that says this is a bad decision so please accept the risks to environment and water supplies cannot be taken - put community and environment before profits!
The pictures below show the consequences of a very small incident, a minor human oversight - it has become a State of Emergency for Colorado, thousands of kilometres of rivers destroyed - lifeless. The water in the pictures is supposed to be clear.
Just because it's smaller scale over here doesn't change the fact the risks are not acceptable and the applications said that they would never do what t hey now apply to do - to save money. They already make enough profit and pay so little tax - PLEASE put tax and ratepayers before profiteers!
Accidents do and will happen, the consequences will be catastrophic for the ecosystem, riparian land owners, and the entire catchment. The residents of Eurobodalla will be without a water supply, the "Nature Coast" will need a new name.
It would be costly and probably ineffective to constantly monitor the operations to ensure the continued safety of those downstream. Frankly, if it is too heavily regulated to build it in Shoalhaven, because of risks to Sydney's water supply, how is it OK here? It's not, so you should have no trouble with this decision.
PLEASE DO NOT RISK IRREVERSIBLE DAMAGE TO THE UNIQUE AND PRECIOUS ENVIRONMENTS, COMMUNITIES AND ECONOMIES OF THE MORUYA RIVER CATCHMENT.






If you are prepared to consider the modification seriously then I request you also consider the following:
* The company's operational record does not inspire confidence.
* Unity has already shown itself to be prone to accidents on the Dargues Reef steep site, even though it has not yet begun to mine.
* The environmental track record at this site is appalling and there is no reason to think it will improve
* There were five pollution incidents in the six months they were in operation. Unity was prosecuted in the NSW Land and Environment Court where three of them attracted fines and costs totaling $200,000.
* Those living downstream and close to the site had to repeatedly quarantine their water supply, dispose of polluted water safely and repair pumps damaged by grit.
The following details factors that support my submission that the modifications must not be approved:
THE SITE IS INAPPROPRIATE
* The site is unsuitable for the construction and operation of a gold processing plant using cyanide as a leaching agent and a tailings storage facility for waste with a high heavy metal content that will remain for ever.
* The EA maps show it is on a hill above a village, on the edge of steep escarpment and at the headwaters of an important river system. Spring Creek, Majors Creek, Araluen Creek, and Deua/Moruya River are all used for domestic water supplies and agricultural purposes
* Pollution in these waterways would threaten the orchards and market gardens of the Araluen Valley and the water supply to Eurobodalla Shire.
* The Environment Protection Authority (EPA) agrees that the use of cyanide and full processing of gold on the mine site has significantly increased the risk of environmental harm.
* It is also located in a highly sensitive, biodiverse area of NSW, and threatens wildlife drinking the water in Conservation Reserves and National Parks. Heavy metal pollution could also be carried into Batemans Marine Park by the Moruya River.
* This mine is on a completely different kind of site to the Unity mine at Henty in Tasmania which should not be quoted as proof that this kind of processing plant at Dargues Reef will be safe.
THE MODIFICATION IS NOT NECESSARY
* Unity Mining has stated to shareholders and the ASX that the Dargues project is still viable if this Modification is refused but processing on-site would add to the `economic robustness' of the project.
* The EA confirms that the decision to process ore on site at Dargues Reef is a cost-saving measure
* A small gain in Unity Mining's shares could come at a large cost to residents, businesses and endangered species from the pollution risks that arise with construction of this processing plant.
* This site is inappropriate for such a high risk construction, especially when there are viable alternatives,
ENLARGED TAILINGS STORAGE FACILITY (TSF)
* If this plant is approved, dangerous heavy metals and cyanide residues left after the gold is extracted, will be stored forever as waste in a 16 hectare (40 acres) tailings storage facility. It will be built on steep land situated above a vital waterway and threaten people and businesses below.
* Recent studies show that cyanide trapped in gold-mine tailings causes persistent release of dangerous metals (eg.lead) into the groundwater and surface water. This TSF is located in a drainage line where any breach will lead to contaminated water draining into the Majors Creek, Araluen Creek, Deua and Moruya River water systems
* Downstream water used for drinking or agriculture could become contaminated with dangerous heavy metals
* At a minimum, assessment must be made of the consequences of small or large spillages of heavy metal material downstream of the site.
* More information on seepage from the TSF through the liner is required before Unity can dismiss either long term impacts from cyanide use or possible impacts at some distance downstream of the mine.
* There is no assessment of the risk of heavy metals in the Majors Creek, Deua River and Moruya River water systems.
* Further details of the likely chemical composition of the tailings and the impacts on groundwater or surface waters also needs to be added to the EA.

RISK ASSESSMENT OF TSF
Introduction of this process makes the composition of the tailings more poisonous and you agree with the EPA that a full risk assessment needs to be done which addresses all environmental risks associated with the TSF. This should include consideration of moving the TSF to a more appropriate part of the site, which happens to lie in the Shoalhaven River catchment.
Correspondence obtained through GIPAA reveals the unsatisfactory response from Unity that this is not justified as the company is "merely seeking to modify an already approved TSF layout." This implies the modification was always on the cards, just done in a way that sidesteps regulations rather than be upfront.
I am alarmed that another Unity response ignores the risks focuses only on difficulties for the company i.e. "The suggestion to relocate has no understanding of technical or financial implications. It was extensively considered and rejected during original EA.
Clearly Unity is insisting on this site for commercial convenience.
I am also appalled at the excuse that "Construction of TSF in Greater Shoalhaven River Catchment was not considered in the original DA because this catchment forms a component of Sydney drinking water catchment and any proposal there would have imposed additional regulatory requirements." This treats the residents of the Moruya River catchment as second class citizens and less worthy of protection.
Little attention has been paid in the EA to the possible impacts to human health and downstream aquatic organisms resulting from a catastrophic failure of the TSF such as a breach of the wall.
* Unity has acknowledged that the TSF may fail and discard the tailings solids as a result of poor construction, or seismic activity in excess of design criteria, or erosion as a result of failure of the emergency spillway but that these possibilities have not been included in the risk assessment done by the company.
* Unity merely says that the consequence category of a TSF breach is "significant" and that the design criteria are appropriate for this rating. This is not acceptable.
* A model of what could happen in a TSF failure needs to be included. The claim by Unity CEO that structures built in Australia do not fail because they are well built is incorrect. The Ranger's uranium mine tailings dam has spilled into the Magella Creek wetlands more than once. There have been various recent examples of such failures overseas.
DANGERS OF SPILLAGE FROM TSF
* The ridge on which the mines sits is frequently subjected to heavy rainfall that does not fall elsewhere. Long term rainfall records for properties surrounding the site reveal that Unity estimates of magnitude of stormwater levels are too low.
* EPA has asked for this additional local information to be fed into the original climate model which it regards as insufficient for accurate prediction of rainfall conditions. This still needs to be done.

The EA appears to allow for one to two spills per year but this is based on data that severely underestimates actual rainfall at the site.

Since there is no mechanism to divert for spill water from the TSF it would flow in Spring Creek and the Majors Creek system. This is not acceptable.

It is acknowledged that spillages can contain copper and mercury that exceed safe levels by two to five times in a 1 in 200 year, 72 hour rainfall event. The risk of a build-up of copper and mercury in the soil where crops that are irrigated with contaminated water is very real.
There is also a danger of build-up in the soil downstream from even minor spillages over a period of years.
OTHER RISKS
* The EA concentrates on cyanide risks but there are number chemicals used in gold recovery process. Details of discharge concentrations on all of these chemicals are needed for full assessment of the environmental risks of project.
* The company proposes to pump any polluted leakage back into the TSF. This assumes that the company will operate at or care for the site indefinitely. This will not be the case, whether the company ceases to be a commercial entity, is sold on or becomes bankrupt. Any construction must ensure that the site is safe without active and expensive ongoing management by the company and its successors or the NSW state government.
* The EPA says that sediment and erosion control needs to meet higher standards. The sediment dams must be an adequate size and the safe discharge of flocculent treated water should be a priority. Currently this treated water is pumped onto grassland but contamination of Majors Creek is possible due the sites unique combination of sudden severe storms, long periods of rainfall and soil porosity.
* The Modification needs to consider the measures that would need to be taken if there were to be a spillage of the cyanide products or its by-products, within the site but outside the bunded area.
ECONOMIC CONSIDERATIONS
* The livelihoods of the residents across the entire Moruya River catchment are dependent upon the health of their soil, air and water for farming, aquaculture, tourism and environmental conservation.
* Araluen Valley has niche market stone fruit orchards, located directly downstream of the mine within 8km of the mine's proposed tailings dam. These orchards, along with cattle production, are the backbone of the rural enterprises along the catchment.
* Currently, this productive valley and the Deua waterway generate significant income and support an increasing level of employment, which will be put at risk if the proposed modifications are approved.
* The 40,000 residents in Eurobodalla rely on an unpolluted catchment for the water supply essential to their livelihoods.
* It only takes one accident or bad work practice at the mine to destroy this water supply.
* There has been no study of the number of people at risk downstream, nor what the economic damage may be either from a series of small or from one major spill.
* Property and businesses worth millions of dollars is at risk. Who will pay for any damage? (you decision-makers will be sued because you know the risks).
* It is worth noting the warning in the auditor's report in the September and December 2014 quarters about the material uncertainty that may cast significant doubt about the Company's and Consolidated Entity's ability to continue as a going concern and therefore, the Company and Consolidated Entity may be unable to realise their assets and discharge their liabilities in the normal course of business.
The proposed changes to the existing development approval threaten far more jobs and income than the six to ten million dollars per year that Unity predicts will be added to the local and regional economy.
These are trifling figures when weighed against the worth of clean water catchments and food production downstream.
* Unity pushes the good record of their Henty Mine operation as evidence that they can construct a safe mine. The Henty site however was constructed as a showpiece by another company. The Dargues Reef proposal is the first real test of their ability to develop a mine.
* In 2014 Unity was also fined by the EPA in Tasmania for a spillage at Henty which had no contingency plan to deal with it.
* Unity's Bendigo mine site has been left under care and maintenance rather than being properly closed down and remediated.
* In correspondence received under GIPAA, Unity has argued against requests from the EPA to apply the higher standards in design and construction deemed necessary to protect water quality for the community.
UNITY CANNOT BE TRUSTED
The processing plant will fundamentally change the economics of mining in this area. Other gold prospecting licenses are active across the region. It would only need one more modification application to extend the Dargues processing plant to accommodate any such new mines.
Unity have repeatedly told news outlets and the local public that it is not contemplating using the proposed plant to process gold from anywhere but Dargues Reef. However, the Chairman's Address to Annual General Meeting in 2014 contradicts this saying that it would be irrational for Unity to restrict use of its proposed plant to just one mine site.
I know you have a tough job and I just ask that you put the long term considerations before the short term concerns of a profit driven entity.

Thank you for taking the time to read this submission. If you wish to discuss any aspects of it or would like more information, please do not hesitate to contact me.

Kind Regards
Wendy Hardman
0406 795 574

I object. Please see my objections in attachment

As a resident of Eurobodalla I object to this third 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 do and will happen. Please see attached for full comment.

As a resident of Eurobodalla I object to this third modification to the Dargues Reef Gold Mine Development Application. For the reasons below it is clear to me that 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. Please see attached for full submission.

PDF attached

As a resident of Eurobodalla I object to this third modification to the Dargues Reef Gold Mine Development Application. 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 site is unsuitable for the construction and operation of a gold processing plant using cyanide as a leaching agent and a tailings storage facility for waste with a high heavy metal content that will remain for ever. The Environment Protection Authority (EPA) agrees that the use of cyanide and full processing of gold on the mine site has significantly increased the risk of environmental harm. If this plant is approved, dangerous heavy metals and cyanide residues left after the gold is extracted, will be stored forever as waste in a 16 hectare (40 acres) tailings storage facility. It will be built on steep land situated above a vital waterway and threaten people and businesses below.
Please see attached for my full submission

As a resident of Eurobodalla I object to this third 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 do and will happen. This site is inappropriate for such a high risk construction, especially when there are viable alternatives. Recent studies show that cyanide trapped in gold-mine tailings causes persistent release of dangerous metals (e.g. lead) into the groundwater and surface water. This TSF is located in a drainage line where any breach will lead to contaminated water draining into the Majors Creek, Araluen Creek, Deua and Moruya River water systems. Please see attached for my full submission.

Uploaded below

I believe this proposal represents an unacceptable risk. Full submission attached.

On my submission I signed it off as D Spanner. Is it possible to have that rather than Name Withheld by Request?
Dallis Tanner

Refer attached

See attached.

See attached.

Dargues Reef Mine

There are many issues that have not been made clear in the proposal to mine gold and process the gold at Dargues Reef near Majors Creek NSW.

There is no funding documents to show how the environmental protection will be funded.

There are environmental risks involved in transporting cyanide and other harmful chemical to the site through a large town like Braidwood.

There are not enough environmental studies to prove that the mine will be safe from chemical spillage as it is near our water supply for Batemans Bay and Moruya.

We are a small company who live in 1 Jersey Rd Moruya. We run our small education business from this location. The mone could have its storage pits damage din fire or flood and then spill out into the pristine Deua River.

The Deua River is home to platypi and many species of fish including Bass. Water dragons, kingfishers, white cranes, black swans, ducks etc. All these species would be endangered by this mine.
The area around the mine is a site of significance for Yuin Aboriginal People. I am of Aboriginal descent and I object on grounds that the mine could pollute the Deua River which has Murramurang Brinja Yuin woman's sacred sites. These sites are protected under NSW Parks and Wildlife laws. It is a crime to damage sites. The Deua National Park has the Deua River flowing through it and it begins at Majors Creek near the mine. King Merriman of Mumbler Mountain is a revered elder from the Wallaga lake area who frequented the Deua River.

I am objecting to Modification 3 by Unity Mining, the full text of which is in attachment 3

See attached.