Mod 3 - Processing & Tailings Storage

I am writing to voice my objection to the proposal (Dargues Reef Mine Modification 3 application 10_0054 MOD3) by Unity Mining Limited to process ore using cyanide at Dargues Reef mine.

I visit my brother and stay on his property on the Deua River. I swim in the Deua River and drink from it. It is source of drinking water for many people including the whole town of Moruya which I frequent.

The entire area from Majors Creek to the coast is based around agriculture and tourism. The number of people, the land area and the scale of agricultural productivity that is threatened by this proposal is to say the least immense. Stacked up against this is a small mining company with a very poor track record on environmental safety.

To have ore processing using cyanide within the Deua/Moruya River catchment is risking the health and safety of a very large population. I don't believe that NSW Government can guarantee the public's safety. The NSW Government already has evidence that Unity Mining Limited cannot be relied upon as evident through their past breaches. Of course Unity Mining Limited claim they will be better in the future, but will they really be?

Should the tailing dam fail (and they are known to) then the catchment will be poisoned. To most reasonable people this would be unacceptable. Poisoning of the environment and particularly a water catchment is not something that can be easily reversed if reversed at all. The NSW Government puts itself at risk of being sued along with the applicant should this occur.

The cumulative effect over the long-term of low level toxins from heavy metals leaching into the environment within the catchment is of concern. These toxins are not going to go away. This ore processing operation if approved will be a small passage in the history of this area yet the toxins will remain. After time Unity Mining Limited will be gone and the NSW Government will be left with the clean-up bill and potentially an impossible clean-up task.

There is no doubt that the mine will create jobs in the short-term and so will the ore processing. However there will be no less jobs created if the ore processing using cyanide occurs away from the catchment as originally proposed. If anything there will be more jobs created through moving the ore from the mine to the ore processing site.

I ask you to carefully consider the total picture: short-term financial gain of a company with a poor environmental track record versus the health and safety of a large and highly productive agricultural area and thousands of people.

I ask you to reject this proposal by Unity Mining Limited to process ore using cyanide at Dargues Reef mine.

I vehemently object to this modification of an already dubious project. Modification will allow them to process the gold ore on site, using cyanide. Instead of the heavy metals lead, zinc, cadmium, uranium and other potentially deadly heavy metals being trucked, these heavy metals will sit in a tailings dam on the steep site at the top of the Major's Creek/Deua/Morura catchment, above Eurobodalla's water supply, and farms and businesses and households. My children and I have visited the area on a few occasions and the entire area is at risk. Please do not allow this ridiculous modification to go ahead. Thank you.

Three years ago Coastwatchers and SERCA won stringent conditions for a proposed gold mine to operate above our valley home. We thought we should be safe.
But the sediment dams failed in the first three day rainfall. In the six months before work halted in 2013, large drifts of sediment filled the deep holes of the gorge to about a third of their depth. Much is still there. The company was convicted in the Land and Environment Court for three pollution events.
Now the company wish to change the Conditions of approval of that mining venture by Modification to allow them to process the gold ore on site, using cyanide. Instead of the heavy metals lead, zinc, cadmium, uranium and other potentially deadly heavy metals being trucked, these heavy metals will sit in a tailings dam on the steep site at the top of the Major's Creek/Deua/Morura catchment, above Eurobodalla's water supply, and farms and businesses and households.
If --or when- there is an overflow, this tailings dam is only ten minutes away from us as the water rushes down the slope below the mine site and over the escarpment.
One major cyanide spill could be deadly to us, to our near neighbours and to the endangered wildlife of the valley. An accumulation of small spills will be deadly too, as the heavy metals gradually build up in the soil t of the riverside farms and orchards, to harm today's children and children as yet unborn.
Unity Mining does not pretend there will be no spills. It admits there will be, but says that they will be diluted by rain. This is unproven and even if it were to be the case it presumes the spills will occur when it is raining- a rash assumption in this area. The company ignores the fact that as they refused to test the creek on our property during and after the previous the pollution events they did not see that as the water slows and reaches the pools, the pollution can be even worse than on the steep land immediately below the mine site as the water slows and the heavy material settles or fills the pools.
Nor have the company seen how thunder storms break above their site, sending flash floods far greater than their estimate of 1 in 1,000 year events crashing down a dry watercourse.
Given the history of work on the site in 2013, a major failure or series of small failures seems inevitable. So called `world's best practice conditions' failed in 2013. Why will it be different now?
Cyanide processing or ore rich in heavy metals should not happen next to a village above a major farming and tourism area..
A cost-benefit analysis should be done to see what would be gained in exchange for running these risks. One insignificant cyanide processing plant threatens businesses ... including the production of my books ... that bring in far more money to NSW and Australia than would be returned to the public coffers by mining royalties or job creation.
Cyanide processing of ore containing lead, zinc, uranium, arsenic, copper should not be allowed in the water catchment system that supplies water to a hundred thousand people nor above a NSW State Conservation Area with twenty-three rare, vulnerable, endangered and critically endangered species reliant on it and is a major bird migration corridor.
Once the tailings dam is built above us by a company with five pollution episodes that affected the creek below their site for most of the six months they operated in 2013 I could not, and would not, ask others to risk coming to our property. But I will stay, because I am too much part of this land to leave.

The above letter from Jackie French has appalled me. I wish to strongly express my objections to this project and the profoundly damaging affect it has on our land, our fauna and flora, and our people. It is truly abominable.

Your site is not very clear for lodging of submissions. I do not know if I have done this correctly, so would warmly appreciate your forwarding this letter of objection on my behalf.

My thanks,

Tania McCartney

I am very concerned about Unity Mining operating the Daughes Creek gold mine without any consideration for the environment or the people living there. Changes of the Conditions of approval of that mining venture to allow them to process the gold ore on site, using cyanide, a deadly toxin, would be not just plain dangerous, but blindfoldedly allowing operation of the mine in future without any safe guarding. Instead of the heavy metals (lead, zinc, cadmium, uranium and other potentially deadly heavy metals) being trucked out, these heavy metals will sit in a tailings dam on a steep site at the top of the Majors Creek, Araluen Creek, Deua River and Moruya River catchment, upstream of Eurobodalla's water supply and many orchards, farms, businesses and households.

The tailings dam has already failed in 2013 and residents are fearful that it will happen again.

One orchardist has begun uprooting 25,000 peach and nectarine trees

Jackie French (author, Children's Laureate 2014/15, and 2015 Senior Australian of the Year) writes:

"One major cyanide spill could be deadly to us, to our near neighbours and to the endangered wildlife of the valley. An accumulation of small spills will be deadly too, as the heavy metals gradually build up in the soil of the riverside farms and orchards, to harm today's children and children as yet unborn.

Unity Mining does not pretend there will be no spills. It admits there will be, but says that they will be diluted by rain. This is unproven and, even if it were to be the case, it presumes the spills will occur when it is raining - a rash assumption in this area. The company refused to test the creek on our property during and after the previous pollution events so they did not see that as the water reaches the pools, the pollution can be even worse than on the steep land immediately below the mine site as the water slows and the heavy material settles and fills the pools.

Nor has the company seen how thunderstorms break above their site, sending flash floods
(of greater magnitude than their modelling and far more often than their estimate of 1 in 1,000 year events) crashing down a dry watercourse.

Given the history of work on the site in 2013, a major failure or series of small failures seems inevitable. So-called `world's best practice conditions' failed in 2013. Why will it be different now?"

This company has a poor history of environmental compliance, being convicted by the Land and Environment Court for three pollution events when the sediment dams failed and large drifts of sediment filled the deep holes of the gorge to about a third of their depth.
This modification will allow the heavy metals lead, zinc, cadmium, uranium to sit in a tailings dam on the steep site at the top of the Major's Creek/Deua/Morura catchment, above Eurobodalla's water supply, and farms and businesses and households.
An overflow/cyanide spill from the tailings dam would be deadly to anyone and anything lliving below the tailing dam.
You cannot have a tailing dam built in this location.

Australia's economy has for a long time relied on primary production and resource extraction. This is changing, as other 'industries' contribute increasingly to the economy. For instance, the arts & recreation sector now employs more people than does the mining sector (ABS); the former presents far less of a threat to the safety and wellbeing of people not employed in the sector than does the latter, and does far less damage to the environment. When you consider the argument often used that "we need this mine to provide jobs", it ignores the impact such a mine can (and often does) have on the jobs of others in the area, such as agriculture and tourism.
It is also important to bring up the issue of where the economic benefits of the enterprise are -- much of the benefit of mining ends up overseas.
Apart from the above arguments, there is the vexed issue of the poor environmental record of the proponent. If anything, environmental safety requirements should be tightened. A company that was not able to prevent polluted water from escaping in the past cannot be trusted to secure the safety of processes using cyanide, especially as it will be storing tailings containing cyanide. From its submissions, the proponent appears to have a cavalier attitude and flagrant (if not arrogant) disregard for the community in which it operates. It is wrong for a company and its owners/shareholders to profit at the cost of the local community and the environment. There is no defensible moral rule that places the making of money by individuals (whether as individuals or collectively within a corporate structure) above the overall welfare of society. Although the company has signed the Cyanide Code, this is a voluntary program developed by industry and does not seem to consider the possible effects of cyanide contamination over a number of years on local agriculture and water resources. There is also no indication that the proponent has considered the possibility of cyanide and heavy metals entering ground water, which is inherently difficult to monitor.
The Planning & Environment Department should not allow the requested modifications, especially the onsite processing of the gold ore..
If the department does approve the modifications, there should be a condition placed on the company that it implement ongoing monitoring of CN levels in local residents (with consent of individuals) and that it implement a program with local doctors to ensure that they are knowledgeable and proficient in helping individuals remove cyanide from the body using accepted and readily-available protocols (e.g. hydroxycobalamin, 4g IV in cases of CN poisoning).
I am happy to be contacted and to expand my submission if requested.

This mine will be a significant advantage to the community in Braidwood. it will bring jobs - badly needed - and more money into the community at the local shops, support business and in sponsorships which Unity already engages in.

This prosed 'modification' is the greatest threat to the catchment of the Deua River in living memory. Even without the inevitable future spills, its very approval will sound the death knell for the clean and green, nature based tourism industry, as well as our thriving local food sector. The river is literally the lifeblood of the Eurobodalla and particularly its food supply. The years of effort and many millions of dollars that have been invested in revitalising our local food system will be for nothing if this is approved.

The on site processing using cyanide extraction is a completely new level of environmental impact to the existing approval, and I believe should have required a full EIS. The construction of a tailings dam that will contain not only cyanide compounds but, more worryingly, heavy metals, has to be to a standard that will last forever. The potential for massive health and environmental damage and costs will not be lessened by time.

This 16 hectare tailings dam will remain like a sword of Damocles hanging above this pristine catchment. This company (Unity Mining) will disappear in the event of any major spill, and then the State and local authorities will be left with a huge problem. Cyanide can be diluted and flushed, and will degrade under ultra violet in time, but the heavy metals will remain. They will leach into the water systems through aquifers when the plastic liner eventually deteriorates (lifetime no more than 50 years).

The waterways cannot be remediated from heavy metal contamination.

This is the environmental legacy that this proposal will leave.

Cyanide processing of ore containing lead, zinc, uranium, arsenic, copper should not be allowed in the water catchment system that supplies water to a hundred thousand people nor above a NSW State Conservation Area with twenty-three rare, vulnerable, endangered and critically endangered species reliant on it and is a major bird migration corridor.

There are no benefits to any residents downstream of this proposal, only risks. Unity say that the risks will be managed, but their record on this very site shows how inadequate their practices are.

There are no second chances with this site.

As a consumer of food grown in this catchment, and a long time resident of Eurobodalla, I plead with the NSW Department of Planning and Environment to refuse this application.

I have family and friends in the region
and I think the mine will be a great asset that will generate jobs with minimal impact to the environment.

This is a very thorough and well-considered application that should be supported. Unity Mining has an excellent track record of working in environmentally sensitive locations and the Dargues Reef project will provide enormous benefit to the local community. This will ammendment will be great for the region and the state.

I am not anti-mine or anti-development. I believe that the current DA approved for Dargues Reef takes into account the environmental and social issues, and has adequate risk management in place. I welcome the local employment and boost to the economy.
However, I have grave fears about some of the proposed modifications.
Four years ago Cortona lodged their application to the PLanning Dept and after considering all of the public submissions approval was granted with conditions handed down by the Land and Environment Court. At this stage the miner was happy and the community generally relieved that we had a relatively low risk and cyanide free operation in our village. With some adjustments on our behalf we could try to live in harmony with the mine and get our lives back.
The mine was then sold to Unity Mining who assured the affected communities that they would continue to mine within the parameters of the DA and LEC conditions, and would definitely not undertake cyanide processing here.
Shortly after this came the announcement that they would be seeking 3A Modifications.When the Modifications were released publicly we were only given 6 weeks to assimilate 700 pages of mining jargon- nowhere near long enough for people with no scientific or engineering background.
This situation along with:
1. Very little consultation from the present owner,
2. The fact that most of the community no longer believe anything he says,
3. The recent corruption in government, particularly involving mining.
4. The realisation that the LEC conditions can so easily be made null and void.
5. The awareness that when money and power are involved, common sense often has no voice
I am left with no choice but to give common sense a go.

Environmental and Economic Issues
When Cortona lodged their DA they were obviously aware of the difficulties of final cyanide processing on this particular site, so elected to take the concentrate to an existing plant in Parkes. It made economic sense to them.
The current owner has all the necessary approvals to mine and process up to concentrate, the estimated 330,000 ozs of gold in Dargues Reef and haul it to Parkes or elsewhere for final processing.
The amount of gold remains the same, with or without these Modifications. The Government taxes and royalties remain the same, since the royalties are paid on the basis of the amount of gold taken out of the ground.
In terms of the local economy the extra 20 jobs are cancelled out when you take into account the loss of jobs for haulage contractors and their support industries (tyres,fuel,maintenance etc). IN addition, the processing plant in Parkes will not receive the income it would have received if the present DA was adhered to.
No-one gains except the miner. Though I understand the need for any business to maximise profits, the price to the environment and affected communities in this case is far too high.
To build a cyanide plant on this site, to greatly enlarge the tailings dam to accommodate the toxins generated from this processing makes no sense. It would be at the beginning of a pristine river system that flows through a National park, services agriculture and currently provides domestic water to 100.000 people on the south coast. A population that is bound to increase enormously in the coming years. Don't forget, once created, the toxic tailings remain forever. At some stage, even in the distant future this dam will fail, in effect, a time bomb for future generations.
Common sense tells me that to introduce such an enormous risk to the environment and the village of Majors Creek and others for no apparent gain to the economy of the nation, makes no sense at all.
Social Consequences
I have been a resident of Majors Creek for 40 years and have seen it grow into a diverse and dynamic community. Our current school bus was once a Holden station wagon, there have been 12 new houses in my street alone in the last 8 years.
Even though the mine has not commenced yet, the effects on the community are already noticeable. Development has slowed dramatically, people are concerned about their sizeable investments in land and homes. Their has been constant anxiety about ground water levels as well as contamination. Noise generated by the mine has been another worry. Science tells us we won't hear it ,but science
is often wrong, we just have to wait and see.The health of the environment especially the water ways is a constant, along with many concerns too numerous to mention, For some of us these things have caused anxiety for the last 6 years. The potential modifications have made it much worse.
Already the community has been polarised, long term friendships have been strained, a few families have had to leave early, and some that intended to settle in Majors Creek have gone elsewhere.
Surely with the addition of a cyanide plant and the associated toxin tailings, things will get worse.
We have just lost a million dollar + peach industry in Araluen. Wisbey's orchards have just dozed out 25,000 trees After 70 years of operation, along with the tress goes the jobs, and the substantial tourist traffic it generated. The decision to close down was partly due to the insecurity of investment, having a toxic gold mine upstream.
At the moment there is a new fear. Will modifications ever end? The miner states that there are approximately another 2220.000 ozs of alluvial gold around the mine site, which they will pursue robustly. Could that mean open cut mining.? Could the next amendment be to bring in concentrate from other area and turn a good profit processing it? These are genuine concerns under the current system.
Remember the mine will only operate for five years,but the toxic tailings are there forever.We on the other hand are here for a lifetime.
If possible please lobby on our behalf or consider our position in your deliberations,
Thank you,
Warren Harrison

PS. Since completing this submission I have become aware of the catastrophic tailings dam failure at the King Gold mine in Colorado this week, which was decommissioned in 1923. One million gallons of toxic waste including cyanide, lead and other heavy metals and toxins. An example of the ticking time bomb.

Support for experienced company/management with great track record.

I am a vegetable grower in the Eurobodalla Shire and farm on 2 properties one here at home in Turlinjah and another in town on the prime river flats along the Moruya River, I am also involved in the Farmers Markets held in Moruya each Tuesday at 3 pm. At those markets are other growers whose livelihood and quality of life depend upon a pristine waterway such as exists. Having worked in the past in logistics and co-ordination for Turnaround and Inspections of high hazard facilities mostly petrochemical plants I am well aware that even in these high risk process plants where the consequence of a mistake can be fatal, mistakes are indeed made and no-one can say the chance of mistake is zero. I object to the 3rd modification of the Dargues Reef Gold Mine Development Application on the grounds there is a pollution risk to a river that provides water for food production, drinking water for almost 40,000 residents, runs into an estuary and ocean that is used for recreational and commercial fishing and oyster production and in flood that water runs over and covers prime agricultural land that should this modification be approved, could contaminate soils that grow our food. That risk however low ( according to the EPA there is a significant increase of risk of harm to the environment) is completely unacceptable especially seeing as its not required. Unity has admitted to its shareholders that the mine remains viable should the modification be approved or not. If this is the case then it should not be approved. To significantly increase risk to drinking water, irrigation supply and food production to save a few bucks is not in the public interest. A small increase in share price is not worth risking the livelihoods of those that depend on a clean river for farming, aquaculture, tourism, and recreation. One accident, one rainfall event. Unity have been at court and prosecuted for 3 pollution incidents. There is no confidence at all that there will not be another.

Cyanide processing and a tailings dam with a high heavy metal content is unsuitable for a steep site above a major water system threatening people, so many critically endangered species and forest types, and businesses below.



In 2013 Unity publicly and repeatedly denied their responsibility for three major pollution events until prosecuted in the Land and Environment Court. This company cannot be trusted to follow best practice nor to admit when accidents happen.



In2013 unity refused to contact downstream users to quarantine their water supply when the EPA asked them to do, forcing the EPA to advertise and contact users directly. This company cannot be trusted with the dangers of cyanide and heavy metal on such a vulnerable site.



Unity is still not able to manage the water in their sediment dams, regularly pumping and using flocculent without a license. How can they be trusted with a much larger and dangerous tailings dam to manage?



There has been no cost benefit analysis to see how many people are at risk immediately downstream, nor what the economic damage may be from a series of small nor a major spill. The bond will only cover repairing damage on the site.. Millions of dollars of property and business income is at risk below the site, but there has been no survey of this by the company nor the department.





The company proposed to pump any leakage back into the tailings dam. But if the company goes broke, or if, as in 2013, there are no trained personnel on site when leakage happens, the heavy metals or cyanide spillage will go directly into Spring Creek, then Majors Creek and the Deua Moruya a Rivers .



In times of heavy rain it takes a flash flood ten minutes to enter the water systems of residents and farms below the site. The company states that this would only happen when high rainfall would dilute the pollution, but hail and heavy storms frequently flood the Spring Creek ridge when no rain falls elsewhere.

One major spill may mean the death of dozens of people, or hundreds on a local Open Day



The EPA has stated that the tailings dam should be moved to a safer location. The company has refused. If this project is commercially viable they should be able to afford a safer site.



Many small spills of heavy metal from the ore may pollute the Deua and Moruya river systems for generations. Do not risk our farm health and children's health with a dangerous proposal.

I support creating Australian jobs

CREATES MORE JOBS!

This country currently has some 30,000 miners out of work. We must be encouraging as many businesses as possible to invest in the mining indusrty. Without that investment the industry and our wonderful countries prosperity will continue to decline. Unity Mining has a track record of operating in sensitive invironments including within a national park in the Tasmanian wilderness. They have a strong management team with many years of experience who want to contribute to the local community and provide jobs for miners. We cannot allow process to stifle this oportunity and I urge this application be approved without delay.

As a community organisation in Eurobodalla we 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.
We are 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.
For the reasons below it is clear to us 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.

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.

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,

If this plant (enlarged tailing facility) 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.

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." You are even more 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.
We are 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.

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. Thus a spillage is likely.
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.

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.

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, bad work practice at the mine or human error to destroy this water supply.
There has been no study of the number of people and wildlife 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?
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 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 totalling $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 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.

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.

It makes no sense to you to risk irreversible damage to unique and precious environments, communities and economies of the Moruya River Catchment for the sake of a little more gold.
Unity claims that this modification can be constructed and operated in a manner that would satisfy reasonable community expectations.
Using this logic the modification should be rejected because it is a perfectly reasonable community expectation that the water supply for home and business use will not be subjected to the risk of dangerous and permanent contamination.
There can be no guarantee that accidents will not occur. Neither the Department nor the EPA can constantly monitor the operations to ensure the continued safety of those downstream.

Submission on:
ENVIRONMENTAL ASSESSMENT FOR THE DARGUES REEF GOLD MINE
MODIFICATION 3 MP_10 0054 July 2015
William A Douglas MSc 12/8/2015
I write in the strongest possible terms of my objection to the proposal to process gold-bearing ores onsite at Dargues Reef and to use cyanide to do so. The site is entirely unsuitable for the purposes of storing tailings from the dam in any case, let alone the heavy metals that may be liberated in the tailings by the cyanide extraction process.
Unity's record, over a very short period of time, has been appalling in regard to unforeseen, uncontrolled contamination events into waterways. I have no faith in Unity's ability to manage the use of seriously contaminating chemicals either in the short term during the life of the mine, or longer term in the management of the tailings dam in the post-mine period.
Given the above, the risk to the water supplies and in many cases livelihoods of downstream residents from contamination preclude there being any safe threshold for onsite processing of gold ores at Dargues Reef. Almost 40,000 residents in the Eurobodalla wholly or partly rely on stream flows in the Moruya/Deua River catchment for their water supplies. A considerable number draw water directly from the river for both farming and domestic water supplies. Any risk to this invaluable and irreplaceable resource is too great. Only a 100% guarantee that contamination will not occur, ever, even under the most extreme weather conditions, will suffice. Since this is clearly impossible to provide, the bar is too high for Unity to meet. The proposal must fall at the first hurdle.
Rest assured that community sentiment is such in Majors Creek, the Araluen Valley and in the Eurobodalla generally, that irrespective of what conditions might be applied to any approval, there will be significant and intractable opposition that will prevent the processing of ore onsite. The philosophies and techniques of Non-Violent Direct Action are well known in the Eurobodalla, following community opposition to a charcoal factory at Mogo only 15 or so years ago. It will take but a modicum of effort to dust off the training programs and start to train enough local, honest law-abiding, voting citizens to blockade the mine and prevent this travesty from proceeding. You have no idea what uprising will be consequent upon any approval for the processing of ore at Majors Creek using cyanide.
The original conditional approval for mining the gold ore body at Dargues Reef was bad enough, but just gained, by the smallest of margins, a social licence to proceed. This amendment, however, is entirely a bridge too far, and will not proceed. It must not be approved.

Yours faithfully,
William A Douglas
Science teacher, parent, farmer, citizen, NVDA trainer (coming out of retirement).

The Dargues Reef mine is a ridiculous proposal. The commodities will run out and the company will leave, leaving the people to deal with the toxic waste leaching out of the tailings dam.

I do not agree with the mine.