Mod 3 - Processing & Tailings Storage

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

I object to these modifications based on the fact that I have been a landowner and ratepayer on the Deua River downstream from Araluen since 1974. My family have looked after and out for this river always. We have been careful stewards of our property and have spent years replanting native vegetation along the river, recording wildlife and monitoring river quality. As a farmer I have relied on the cleanliness of the river and the soil to produce organic garlic.

I have two major objections to the proposed modifications, and they are related.

1. I am not confident of the safety of a tailings dam not to fail and pollute the river and its soil.
2. I am not confident of the economic viability of the mine to make enough money for the owners to rectify any pollution and compensate landowners like myself for loss of livelihood.

The demand for gold and the price of gold is at its lowest for several years. All major Australian gold companies have suspended exploration, laid off staff and seen their share price plummet. If the big companies cannot make a go of it in the current economic climate, it follows that small companies like "Unity Mining" would be unviable. There have always been small companies which buy up unused or distressed gold mines, tidy up the bookwork and sell them again. Sometimes the company may even process the ore but usually for a limited time. These companies walk away from the mine after 4-5 years, declare themselves bankrupt and the community and its officials are left to do the remediation.

I fear that "Unity Mining" falls into this category.

Dargues Reef has a long history of failure.
I include this report from the Evening News (Sydney NSW) Monday 16 March 1891 (page 7). "Dargue's Reef at Majors Creek ... is one of those mining properties which everyone says, and has said for the last 20 years, would pay if only it were worked properly. It has quite a history. All sorts of trials have been attempted to make it pay during the last 25 years."

Margaret Summerhayes
2663 Araluen Rd, MORUYA NSW 2537

I wish to make a submission against the proposed Dargues Reef gold mine on the following grounds:
* This reef will sit at the top of the Araluen Valley which contains the headwaters and is the main catchment area for the Moruya River, which is the main source of water for the Eurobodalla Shire.
* In times of climate change and growing pressure on water resources this mine will be taking a huge amount of water out of the system in the interests of making more money.
* Possible contamination of this water source will render the whole of the Eurobodalla without water.
* The use of cyanide in the processing of the gold presents a huge threat to the area and should not be accepted at any level.
* This area of the south coast is known for its food production and this contributes to the strong economic sustainability of the region. With this mine at the headwaters of our river the food farming industry will be under constant threat and our clean water image will be ruined. No mine should ever have that ability.

Finally, I would draw your attention to a comment by one of the mine people who was present at an information night in Moruya. When asked why the mine couldn't be put on the Sydney side of the mountain the reply was, 'We couldn't do that, it would threaten the Sydney water catchment'. It would appear that the people living in Sydney are far more important than those living in the Eurobodalla. How did that happen?

As investors in a number of Australian resource companies and as NSW residents with a knowledge of the relevant area, we are concerned to see the Dargues Reef project proceed as efficiently as possible with minimal environmental footprint, while maximising stakeholder returns and local employment. The proposal involves well known mining practices that are widely and safely used in many sites that are very much more environmentally sensitive than the subject area and the logic of consolidating production from the project to the mine site itself is compelling. The resources sector is in a serious depression currently with capital and finance very hard to raise. Dargues Reef being brought into production efficiently and with planning support for a reasonable modification will provide a strong signal that the sector has a future in NSW and encourage new investment.

To whom it may concern. The company behind this mine has a proven track record of failing to keep its environmental commitments. Its own annual reports show that it does not have a 100% success rate, and has thus been fined already. When I asked at their open meeting about their poor record with polluting water, the MD said, and I quote 'Yeah, we got caught with our pants down'. Now, even if the MD of the company had a better attitude toward environmental compliance the company has a proven track record of failure. therefore this should not go ahead, when the potential poisoning of 160,000 people is not just possible, but from the companies own records highly likely.



Now we all know jobs are important, but let us compare the number of proposed jobs, with the number of farmers and tourist related jobs that exist, that could be destroyed by any pollution.



Let us also consider what this region is quickly becoming Australia wide, and also internationally know for... Its food, its food commerce, its organic produce and Moruya has won best farmers market in Australia 2 years in a row. This good news has reached the UK press and its a huge benefit to our region. This region is already a place for local, seasonal and organic food, this movement and commerce should be supported by the local and federal government and encouraged, for all the right reasons. But should there be any pollution from this mine, it will kill this industry, and you will loose far more livelihoods than will have been created.



this should no go ahead.

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

As a resident and business owner within Eurobodalla and a concerned Australian citizen, I object to this third modification
to the Dargues Reef Gold Mine Development Application.

The main danger with this project is for those living in the Moruya River Catchment and the applicants assumption that
there will never be failures in the design or running of the proposed processing plant.

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.

INAPPROPRIATE SITE

It is my understanding that 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.

ENLARGED TAILINGS STORAGE FACILITY (TSF)

It is my understanding that 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 such as mine below.

Recent studies show that cyanide trapped in gold-mine tailings causes persistent release of dangerous metals 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.

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.

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.
The 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 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.

ECONOMIC CONSIDERATIONS

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.

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.

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.

POOR RECORD OF THE COMPANY

The company's operational record does not inspire confidence. 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.

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. Additionally, Unity's Bendigo mine site has been left under care and maintenance rather than being properly closed down and remediated.

Closing statement

It makes no sense to me 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.

As a resident, a business owner and a concerned citizen, I strongly object to this submission.

I am concernerd as to the impact any spill or
environmental non compliance could have on the surrounding waterways. Any
pollution of cyanide into ground and/or drinking water could have a massive
inpact on the heath of individuals in this region as well as the livelihoods
of many hundreds of small businesses in this area, in particular the farming
and primary production.
I have moved to the area from the UK and I have been
amazed by the number of small business in the area and the access to healthy
local fresh food, it is fantastic that Moruya has the best farmers market in
Australia. I grew up in the North of England, I understand the necessity and
the benefit of mining and large industries, but I have also have seen all too
well the damage on the landscape and the heath of the local population.
The
growth of the food production revolution in the Eurobodalla is providing jobs
in this region. Currently the Unity Mine employs two local people. Not if,
but when there is a spill, I wonder how many small businesses will put out of business, this mine has no positive impact for our local region.
I was looking at Unity mining's own sustainability report for 2014,
http://www.unitymining.com.au/sustainability-reports-2/
If you look at their own reporting on page 11, their groundwater monitoring
%Conformance is only 95%, and then further below they state they have had
two environmental non compliances last year. This surely demonstrates that
they cannot guarantee that there will not be a spill or any environmental
damage as their track record proves there will be.

This should not go ahead.

Australia's gold sector is very much in need of new mine developments in order to remain globally significant and competitive. The Dargues Reef gold mine is one such potential new development, one of very few in the country. I have every confidence that the Dargues Reef project can stand out as representing Australia's mining sector at its very best in terms of technical excellence in mining but also critically in terms of maintaining social licence to operate and upholding environmental best practices. The mine development will be a source of significant employment opportunity and economic benefit. Unfortunately NSW has a generally poor reputation as a destination for mining investment in comparison to other states - approving this mine development is one way for NSW to fight back in terms of competitiveness.

I am a resident of the Eurobodalla and I am deeply concerned about the third modification by Unity Mining of the Dargues Creek mine development application and the Dargues Creek gold mine in general.

I am horrified, and concerned for the future, that Unity Mining has, from the original development application to the third modification neglected a vital aspect of this project - reference to and assessment of risks to the drinking water supply for almost 40,000 thousand people in the Eurobodalla who depend on the Deua River system.

It is clear to me that Unity Mining's proposed modification to use cyanide in processing the gold poses an unacceptable risk to residents along the entire Moruya River catchment.

There are many reasons why I oppose the Dargues Creek mine including -

a) the proximity of cyanide leaching and a tailing storage facility for waste and permanent high heavy metal waste to domestic water supplies, orchards and market gardens that supply people of the Eurobodalla and further.

b) the EPA acknowledges that the risk of environmental harm would be significantly increased with the use of cyanide in gold processing.

c) Conservation Reserves and National Parks, homes to highly sensitive NSW biodiversity including Batemans Marine Park, could be at risk of toxic pollution.

d) Unity Mining's poor record does not inspire confidence. They have been fined for three pollution incidents out of five in six months of operation by the Land and Environment Court. Downstream residents had pumps damaged by grit and had to quarantine their water supply.

e) Seepage from Unity Mining's proposed enlarged tailings storage facility that will risk heavy metals ie lead, zinc, uranium, arsenic and copper, permanently polluting Majors Creek, Araluen Creek, Deua River and Moruya River.

f) Unity's Mining's poor environmental record, ignorance of proper assessment of risks to water, disregard for and disinterest in what the community and businesses are saying.

g) Unity Mining's priorities - cheaper gold processing and shareholder profits.

As a resident of the Eurobodalla, I say in the strongest terms, that community health and well being should not be sacrificed so Unity Mining's ASX statement, that on site processing would add to the 'economic robustness' of the project, can be realised.

The future of community health, business concerns and local food production is more important than Unity Mining saving money by processing on site for a small increase in shareholder profits.

21 August 2015


*Planning Services*

*Department of Planning & Environment*

*GPO Box 39, Sydney NSW 2001*

*Attention: Executive Director - Resource Assessments and Business Systems*

*RE: PROJECT APPLICATION 10 0054 MOD 3*

As a resident of Eurobodalla I strongly object to the application in the third modification of the Dargue Reef Gold Mine.

I believe this will create unacceptable risks to health, business, farming, wildlife and tourism.

I also believe that Unity Mining has not demonstrated adequate and transparent measures to ensure the safety of the proposed activities.

Any level of risk of a possible cyanide spill or leakage into our waterways with the poisoning of our water, endangering of extensive local farming and danger to wildlife is an unacceptable risk. Unity mining company has had
spills from this site in the past.

*Dargue Reef Mine location*

The Environmental Protection Authority agrees that the use of cyanide and gold onsite has *significantly increased risk of environmental harm.

The environmental assessment shows this mine to be on a hill above a village. Heavy metals including cyanide would be present in the tailings dam for years after the gold extraction is exhausted and Unity had left the site.

Australia is not a third world country and should not accept third world practices in mining.

Unity Mining past performance and Unity Mining communications

Unity have claimed that their proposed modifications can *'satisfy reasonable community expectations'*.

There is no indication these assurances will be adequately transparent or monitored by a sufficiently independent agency.

The company has minimised their estimates of possible risks due to excess stormwater. Their methodology for arriving at these estimates is not transparent.

Furthermore with climate change we are entering ever more unstable weather systems and therefore predictions of likely heavy rainfall and associated spills cannot be accurately based on past extreme weather events.

Climate change will also bring greater need to protect food production areas.

Unity mining are claiming their incident free mine at Henty in Tasmania as an example of their being responsible operators. However even if the Unity mine at Henty were incident free (and they have been fined at Henty for a
spillage) it should be noted that the site of the Dargue Reef* mine is a very different situation. As mentioned above already there have been spillages at the Dargue Reef site.

Unity mining have informed their shareholders that the Dargue Reef project is still financially viable if the modification is disallowed. The EPA has confirmed that the application to use cyanide *is* a cost saving measure.

If the modification to allow cyanide processing onsite is allowed it would be a financial gain for Unity and their shareholders. Into the future it might come to be a very large cost to residents, business, food growing,
wildlife. As usual in the case of many such environmentally challenging projects these costs are not factored in.

In addition, according to a statement made by the chairman at Unity's 2014 AGM, If approved, this application would enable Unity to process gold from elsewhere at the Dargue Reef site. Community concerns are magnified by this
possibility of an opening wedge to further endangerment at the site.

*In summary*

I believe it is reasonable to expect that our drinking water is kept safe and not so threatened; it is reasonable that food growing in the area below the mine be kept safe; and reasonable to protect the health and livelihoods of local people. We advocate putting these well beings above additional profits for the mine.

Projects such as this mine when willing to undertake practices that risk damage to others need to be held accountable for 'unseen' costs to health and wellbeing.

In the possible case of covering the costs of an unforeseen spillage it would not be seen as a cost saving approach to use cyanide to process the gold extracted.

As rate payer and local resident of Eurobodalla I call on you NOT to approve modification 3 to allow Unity mining to use cyanide in processing gold at Dargue Reef.

Signed
Dr Karin Geiselhart

RE: DARGUES REEF MINE - Yuin Aboriginal sites
21/8/15
SUBMISSION
I am writing to you about the protection of the Deua River near Moruya NSW. The Dargues Reef gold mine near Majors Creek when reopened will have pools of dangerous chemicals such as cyanide to treat the gold. These pools are supposed to be safe but let us look at the recent poisoning on the Colarado River in USA due to mining problems. The chemicals will have to be transported by truck through towns such as Braidwood and this will be a danger to residents. The costings for the protective pools have not been made public. Where in the budget for the mine are these figures for public perusal?
ABORIGINAL SITES: The Deua National Park runs alongside the beautiful pristine Deua River, it is a magnificent national park with Aboriginal Yuin rock engravings that are sacred to the local Aboriginal descendants. The Deua river near Stewarts Crossing, has several deep water holes that are sacred women's sites for the Yuin Brinja and Murramurang people. These sites have been recorded from elders and held in documents at the Moruya library. There are axe grinding grooves along the river.
Today, some people identify the Deua/ Moruya river area as being associated with Dhurga [Thoorga / Durga] language, whilst others identify the area as being Walbanja, a tribal area recorded by Tindale in 1974. Also recorded during the early contact period was the Aboriginal group named Kiyora [Flanagan 1833] or Kiora [Oldrey 1842] who occupied territory to the west of Moruya [today = Kiora]; the Aboriginal group named Gundaree [Oldrey 1842] who occupied territory on the south side of the Moruya River [today =Gundary]. All of these Yuin Aboriginal groups lay claim of custodianship over the Deua and Moruya river.
Therefore the Aboriginal community of Moruya are very concerned about the Dargues Reef Mine and its potential to destroy sacred sites, natural wildlife and the drinking water quality.
For 40 years, I have co-owned a 1878 shack near the river at Stewarts Crossing Moruya. I have often seen platypi, water dragons, freshwater Bass, diamond pythons, azure kingfishers, Eastern grey kangaroos, black rock wallabies, pretty faced wallabies, wombats, king parrots, black cockatoos, rainbow lorikeets, echidnas etc. This area is a wildlife haven. It needs to be protected.
The water from the Deua is the water supply for surrounding towns including Moruya and Batemans Bay. The water is so clean we can drink it when we swim. It is so precious and rare.
Please reconsider the permissions to open this mine.

I object to the Dargues Reef Gold project and its mine reopening, it has the capacity to destroy environmental and Aboriginal sites along the Deua and Moruya rivers and catchment area. The river is the water supply for Batemans Bay and Moruya. We drink this water. The risk to us from pollution of the river is enormous. Cyanide will be used to treat the gold at the mine and it could leak into the river. An environmental disaster would be possible. There are countless Aboriginal sites along the river including women's sites on the Deua River used by Kyora Yuin people before they were hounded form their land to make way for European colonisation. The wildlife of the Deua National Park has huge heritage value. Rare species of plants and animals are in this area. They are protected under NSW Government legislation, eg the platypus. The risk to these species is too much to allow. A gold mine that benefits a handful of shareholders is not a reason to reopen the mine. Chinese investors that have some a minor shareholding in Dargues Reef and it is possible that they could easily take over the mine and even less environmental protection might happen.

I wish to object to the Dargues Reef Gold Mine on the basis of environmental spillage and contamination issues.

No mine !!!!!

21 August 2015

Submission to the NSW Department of Planning and Environments
On the Duarges Creek Mine Modification
Project Application Number 10_0054 MOD 3

As a resident of Palerang Shire, familiar with Majors and the Araluan Valley as well as being a property holder in the Eurobadalla Shire and very familiar with Moruya, I make this submission based on environmental concern.

1. Continuing modifications to the proposal demonstrates a lack of adequate research on the mine workings and associated environmental issues. Our region was subject to contamination by the Captains Flat mine acid drainage along with unstable tailings dumps resulting in serious pollution and contaminating the Molonglo River and Lake Burley Griffin that persisted for several decades.

2. Modification 3 is a significant change from the original approved project and environmental assessment. The mining proposal now with the Tailings Storage Facility and the cyanide leaching process is not acceptable. The GHD draft report commissioned by the Eurobadalla Shire notes:

'The proposed modification would significantly increase the use of toxic chemicals in operations on the site and result in potential long term risks due to retention of toxic substances in the TSF that would pose a long term risk to human health due to long term leaching or catastrophic failure.'

3. Modification 3 is likely to be an environmental hazard for farmers in the Deua Valley region, the Eurobodalla water supply and the Moruya River recreation. The GHD report demonstrates that there is no security that the tailings storage facility can contain leakage of environmentally damaging contaminants. Furthermore the cost of monitoring and managing contamination long after the mine has closed is a massive expense that would overtake any local economic benefits.

Given the mining legacy of Captains Flat of a toxic landscape, a damaged river and remedial work that cost the government millions of dollars, the environmental and economic risk of proceeding with Modifcation 3 is too great.

Juliet Ramsay

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

As a resident of Palerang shire, 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. Failures and accidents can and do and have already occurred at the site. 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. For the reasons below it is clear to you 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.

Further, I would add that my family have been residents in the area for over six generations. My hope is that my farm will be as safe and healthy as it has been in the past for all of the future generations to come. My family and I have always strongly objected to the development of this mine in Majors Creek, and will never support its development.

INAPPROPRIATE SITE
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 forever. 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, bio-diverse 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. Further, 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.

MODIFICATION 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 I 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." I am 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.
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 mine 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 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. 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?
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.

DUBIOUS RECORD OF THE COMPANY
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. 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.

FURTHER MODIFICATIONS LIKELY
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.

Closing statement
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 EA FOR THE DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054 July 2015

As a resident of Palerang shire, 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. Failures and accidents can and do and have already occurred at the site. 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. For the reasons below it is clear to you 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.

Further, I would add that my family have been residents in the area for over six generations. My hope is that my farm will be as safe and healthy as it has been in the past for all of the future generations to come. My family and I have always strongly objected to the development of this mine in Majors Creek, and will never support its development.

INAPPROPRIATE SITE
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 forever. 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, bio-diverse 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. Further, 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.

MODIFICATION 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 I 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." I am 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.
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 mine 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 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. 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?
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.

DUBIOUS RECORD OF THE COMPANY
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. 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.

FURTHER MODIFICATIONS LIKELY
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.

Closing statement
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.

19 August 2015
RE: PROJECT APPLICATION 10 0054 MOD 3
As a resident of Eurobodalla I strongly object to the application in the third modification of the Dargues Reef Gold Mine because of the potential devastating impacts on this beautiful area.
Risks to health, business, farming, wildlife and tourism
Any level of risk of a possible cyanide spill or leakage into our waterways with the poisoning of our water, endangering of extensive local farming and danger to wildlife is an unacceptable risk. Unity mining company has had spills from this site in the past.
Dargue Reef Mine location
The Environmental Protection Authority (EPA) agrees that the use of cyanide and full processing of gold onsite has significantly increased risk of environmental harm.
The environmental assessment shows this mine to be on a hill above a village. Heavy metals including cyanide would be present in the tailings dam for years after the gold extraction is exhausted and Unity had left the site.
Unity Mining past performance and Unity Mining communications
Unity have claimed that their proposed modifications can 'satisfy reasonable community expectations'. I would like to point out the difficulties with being able to rely on this assurance.
The company have minimised their estimates of possible risks due to excess stormwater. This is not transparent.
In addition with climate change we are entering ever more unstable weather systems and therefore predictions of likely heavy rainfall and associated spills cannot be accurately based on past extreme weather events.
Unity mining are claiming their incident free mine at Henty in Tasmania as an example of their being responsible operators. However even if the Unity mine at Henty were incident free (and they have been fined at Henty for a spillage) it should be noted that the site of the Dargues Reef mine is a very different situation. As mentioned above already there have been spillages at the Dargues Reef site.
Unity mining have informed their shareholders that the Dargues Reef project is still financially viable if the modification is disallowed. The EPA has confirmed that the application to use cyanide is a cost saving measure.
If the modification to allow cyanide processing onsite is allowed it would be a financial gain for Unity and their shareholders. Into the future it might come to be a very large cost to residents, business, food growing, wildlife. As usual in the case of many such environmentally challenging projects these costs are not factored in.
In addition, according to a statement made by the chairman at Unity's 2014 AGM, If approved, this application would enable Unity to process gold from elsewhere at the Dargues Reef site. Community concerns are magnified by this possibility of an opening wedge to further endangerment at the site.
In summary
I believe it is reasonable to expect that our drinking water is kept safe and not so threatened; it is reasonable that food growing in the area below the mine be kept safe; and reasonable to protect the health and livelihoods of local people. I advocate putting these well beings above additional profits for the mine.
Projects such as this mine when willing to undertake practices that risk damage to others need to be held accountable for possible 'unseen' costs to health and wellbeing. In the possible case of covering the costs of an unforeseen spillage it would not be seen as a cost saving approach to use cyanide to process the gold extracted.
As a resident and rate payer in Eurobodalla I call on you NOT to approve modification 3 to allow Unity mining to use cyanide in processing gold at Dargues Reef.

Signed
Allan Rigby

Submission from Karis Muller to the NSW Department of Planning
on Modification 3 of Big Island Mining at Dargues Reef, Majors Creek. Project no. 10_0054 MOD3.
August 2015.

Useful site: Guidebook for evaluating mining projects, esp. ch.1, at https://www.elaw.org/files/mining-eia-guidebook/chapter1.pdf

My concerns about the proposed plan to transform a large area near my village into a noisy, polluting, local and possibly regional industrial mining centre include its absence of costings in Modification 3, and claims that no details of procedures can be provided until approval is granted. This seems to amount to carte blanche for the proponent until approval is granted, and does not reassure us about eg emergency plans. Since Unity sees itself as an experienced miner one wonders why they cannot at little expense and time use previous similar statements. It would be useful for example to know whether among the equipment Unity purchased with its lease at Bendigo and may transfer to Dargues will be its reverse osmosis plant; this seems not to have been used there, and will not be used here either. Why not?

My submission responds to certain questionable statements by Cortona/Unity and locals. Though the Majors Creek Progress Association is supposed to be a forum for us all, discussion of the mine has never been permitted. Progress therefore cannot represent the village. The Landcare affiliated group Majors Creek Catchment Guardians Inc was founded to address community concerns.

My comments on the 3rd modification, listed below, include earlier observations that the community is not informed, thus undermining the proponent's claims to have social licence to operate:

1 There have been no tailings accidents in NSW. There have been many, e.g. Captains Flat nearby, whose poisons still enter the Molonglo river and Lake Burley Griffin, (Identifying acid mine-drainage pollution at Captains Flat, NSW... Bierwith PN and Pfitznerks, 2001, at ieeexplore.ieee.org; Mine waste: those hills of gold at Captains Flat may have provided a fortune for some, but an unfortunate legacy for others, interview... Stateline, ABC, 13 Feb. 2004), as well as Peak Gold Mines, Mineral Hill, and Hillgrove before Bracken took it over. In addition Tarago Woodlawn is to be re-opened as a mine, further perhaps endangering the Sydney water supply and the Murrimbidgee river.

2 Because Knight Piesold designed the Dargues dam there are no risks of failure or over-topping.
Even at KP dams, pipes leak, rain falls, linings crack, bunds collapse. After the 2014 dam disaster at the Mount Polley gold mine in British Columbia designed by Knight Piesold, that company denied responsibility because the dam bund was later raised. BC has consequently banned wet tailings dams unless no alternative is available, cf New mines must consider tailings pond alternatives, at https://www.biv.com/article/2015/3/. Such disasters in NSW and elsewhere are easy to find on the web; new ones emerge regularly. However Unity has never investigated.

3 Cyanide non use here was an 'environmentally friendly' choice. This was never true, since it was intended that Bendigo or Parkes would have to serve instead. We were relieved that Cortona and then Unity had promised not to use it here. Now however cyanide use, which is highly toxic and requires trained handling, is for some reason environmentally friendly and thus a bonus on site, right near the village. If as stated there is a cyanide destruction circuit, which seems plausible given that Australian gold mines use between 40 and 60 tonnes of sodium cyanide (NaCN) each year, to recycle it instead seems contradictory, and is not explained. If the aim is only to maximize efficiency and save costs, why was off site cyanidation the answer before, but not now?

4 The proponent rightly says that local rocks often contain arsenopyrites and are harmless, but fails to add that these generate corrosive compounds due to crushing followed by chemical and bacterial action when exposed to air and water in the TSF (tailings.). Microbial or chemical reactions may cause sodium cyanide or NaCN to generate HCN, especially after mine suspension/ closure, ie the cessation of liming in tailings. HCN was a mass murder weapon last century, and is used in some US states to execute criminals; NaCN pellets are dropped into a basin of sulphuric acid under the execution chair, which then generates mortal HCN. To refer to peach kernels as evidence of the harmless nature of 'cyanide', as Unity employees previously alleged, is as irrelevant as saying that the sodium chloride is akin to chlorine gas, used in WW1.

Appendix 8 by Knight Piesold in the 700 p. text describes tests it did on tailings (TSF) at Victoria Parkes TSF. Levels of several toxic substances found greatly exceed permitted levels. See also Are you living in an area with mine tailings? At http://docs2.health.vic.gov.au; Management of tailings and waste rock in mining activities, 4 Apr. 2010, at eippcb.jrc.ec.europa; Mine tailings are a significant health risk to nearby populations, at www.superfund.pharmacy.arizona.edu

The foreshadowed levels of various contaminants in the more than double the approved size , 13 h. Dargues TSF are likely to be similar eventually to those at Parkes.
As well as disposing of ore and water mixed with waste metals and NaCN in the TSF Unity will send cement - mixed with this toxic slurry down mined out shafts, which will crack due to temperature extremes within a decade at most, poisoning what is left of our ground water.

5 Unity will rehabilitate the site. The mine will close or be put on indefinite hold in 2018, 2022 or more likely years after that, since Unity repeats that there are 'excellent opportunities' to mine gold over its seven other sites, enough to keep it busy for years, 'modifying' its project accordingly. Its stated intention not to mine beyond Dargues 'in this modification' means just that. There is no end in sight, while our village turns into a busy regional processing centre crushing and smelting thousands of tons of sulphidic ore trucked in from afar. Heritage town Braidwood will see not only trucks of sodium cyanide canisters trundling through Wallace Street, but also truckfulls of ore to crush and smelt at Dargues. There is no other processing centre anywhere around. When asked about all this the company is vague.

The bond cannot rehabilitate the site. How much will it cost to cover 13 hectares of sludge? If the towering TSF is ever covered over, (which Bendigo is still pursuing for its own), ratepayers will pay, as usual. Unity further plans to close the box cut entrance but not dismantle it; i.e. Dargues is to be on care and maintenance, as are Bendigo and Henty, soon. This indicates minimal rehab. and no closure, perhaps ever. As staff leave there will be no more monitoring of the dam. Why is a mine allowed to start elsewhere if the previous one is still a mess? Although Bendigo is not uniquely Unity's fault, as in most cases mines change owners several times, responsibility is evaded.

6 Unity shows a photo of a platypus in the Henty River. But have the wombats been relocated around here? How will the deaths of hundreds of birds, reptiles and marsupials that drink or bathe in the dam be prevented? Usually mines self report (usually under report) animal deaths - their minimal announced toll is never verified. Will anyone visit the site unannounced to check fauna deaths? Dead animals can be cleared away daily, anyway.

7 Mine jobs locally will bring much needed economic benefits. The mine promises to employ mostly locals. 1 500 have applied for jobs at the mine, so competition for the 120 jobs available will be fierce. How many skilled engineers or miners live round Braidwood? Dangerous jobs such as working with PAX or NaCN require five years' training. Do we want unskilled local youths to risk their lives and ours? Unity's CEO says both that locals will be hired and that these will need five years' training. So what happens in the meantime? Unity is hardly in the game of training people; it is cheaper and safer if trained staff move into the area. In addition, previously secure jobs could go on account of the mine: e.g. organic gardening and agriculture, or tourism. One orchard has laid off over 30 workers already. Local food growers will need to buy in soil, (cf warnings of Victorian health authorities), as their own soil will require regular testing at their expense.

8 People near to and downstream from the proposed gold mine are mostly unperturbed by the mine's ever increasing footprint. Many moved to the area over the years because of its peace and beauty, its animals and birds, and they contribute their savings or income to the community too. Few would have moved here had they known of the arrival of a noisy, dirty industrial project nearby. They would not have contributed their income to hire locals to help build their homes or create their gardens. Some residents have now left because of the mine, while others planning to settle have decided otherwise. A medical professional for example in Braidwood is determined to leave if this modification goes ahead...

In conclusion, Majors Creek was not and is not 'struggling' without this mine. During the mine-free decades people started local businesses or commuted. Many have done well, employed by both established locals and the many who moved because they loved this small, friendly community, its eagles and owls, its snakes and goannas, its kangaroos, and above all the irreplaceable wonders of a clear, silent night sky, the at present clean mists rolling over our houses, the green orchids and the native violets.

They know that mining of any kind seriously depletes ground water and taints what is left. Bores will dry up and rain tanks will collect contaminants. The 2015 Modification application admits that the mine's water needs will outstrip supply; Spring Creek will reduce by over half at end of mining, Majors Creek by some 40%, while the paste fill that is to be poured down the voids 'will later enter creeks' (Annexe of Modification 3). The water table will take at least 50 years to recover its pre-mining level. And now cyanide compounds are to be added to the arsenic, uranium, antimony and the rest.

Public relations donations to local causes, although well-intentioned, should take second place. They are no substitute for respect and proper care of the health of residents, of our precious wild life, native flowers and trees, and above all of the water essential to life.

Please do not allow this modification.

************

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

I am a concerned resident of Eurobodalla shire. Friends and business acquaintances of mine live on the Duea river downstream from the the Dargues Reef Mine. I strongly object to this third modification to the Dargues reef Gold mine Development Application.

The proposed modification, in particular the 2 points, Construction of an enlarged Tailings Storage Facility and final processing of gold concentrate on site to produce gold ore or unrefined gold bars using a conventional carbon-in-leach processing plant is unnecessary and potentially very dangerous.

It is this processing with such a hazardous substance, on an unsuitable site, that risk the health of the people and land of the Moruya Catchment Area. 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. We are talking about a mine site located above a drinking water supply for over 35000 residents.

Land along the Duea River is used for agricultural purposes, more specifically food production. This food production is crucial to, not only the local community as a food source, but also an income for producers and small businesses. If there is any chance of water quality being jeopardised by upstream tailings storage, or cyanide processing one must consider which industry is held in higher regard.
Local food production is a vital part of our community economics, health and tourism. It is a growing industry in the Eurobodalla and should be given utmost consideration in this process.

The EA confirms that the decision to process ore on
site at Dargues Reef is a cost-saving measure, which demonstrates the question-ability of the priorities of Unity Mining.


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.

Earlier this month saw a devastating spill at the Mt Polley Mine, near the town of Likely, in the Cariboo region of British Columbia. A dam at a waste pond on the site of the Imperial metals open-pit mine had burst, releasing 10m cubic meters of water and 4.5m cubic meters of potentially toxic slurry into virtually untouched forest, lakes and rivers into an area of Canada populated mostly by the indigenous First Nations peoples. The full repercussions of this disaster will not be known for many years, even decades.

It will only take one accident, fault, oversight, breach, flaw or significant weather event to threaten such a pristine and fragile environment. An environment that is home to clean harvested water, wildlife, and aquaculture. There is a commercial stone fruit orchard just 8km away from the proposed tailings dam, and many other agricultural properties further downstream. 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.

I am dismayed to learn it is being considered to risk irreversible damage to this unique environment, our community and local economy, for the sake of some extra profit for a mining company.

Dargues Reef Mine Modification 3

Mining Modification 3A Application No 10-0054 MOD 3
Address of mine: Majors Creek Rd. Majors Creek NSW 2622
I am making a personal submission
Name: Rebekah Howard
Address: 608 Hadlow Dr Via Bungendore NSW 2621
E-mail address: [email protected]

I object to this application
I submit the following information in support of my objection to this application to modify the development already approved to mine gold from Dargues Reef.
My family have lived in Majors Creek for 38 years and have enjoyed the peace and serenity of a simple lifestyle and a safe place to raise children.
The approval given to mine granted to Cortona Mines caused significant stress in the village, as much discussion and debate with the miner was necessary to ensure the safety and lifestyle of residents could be maintained, especially problems with continued domestic water supply and assurances that the environment would not be destroyed and soil and water would remain uncontaminated by toxic material. A big part of this was to ensure that no cyanide processing of the gold would ever be undertaken in Majors Creek. This was agreed to by the miner, considering that placing such a processing plant IN A VILLAGE, ABOVE A WATER COURSE supplying water for domestic, farming, agriculture and business from there to the coast, and water for domestic use in coastal towns was totally inappropriate.
My Parents have a house in Batemans Bay which we frequent often with my children and I am concerned at the possibility of contamination of Their water should this modification be approved.
Under present arrangements I understand that the mine approved involves all the toxic heavy metals and sulphides being removed from Majors Creek with the gold, to be taken to Parkes for final processing . This is relatively safe for Majors Creek and would not be likely to contaminate The water supply since the tailings dam remaining would be very much less toxic and no cyanide would be involved.
Introducing cyanide processing turns this mine into a HAZARDOUS mine placing many people and the environment in danger with the transporting over hundreds of miles, the storage and use of cyanide in Majors Creek all causing potential danger. In addition the toxic heavy metals and sulphides released by the processing remain dangerous forever and must be contained in a tailings dam. This dam must last forever if the water and environment are to be safe, but the dam will not last forever, posing a continuous threat. If this processor was placed on the other side of the hill it would be in the Sydney water catchment area and not be allowed. Why is The water supply of all who live in Majors Creek and along the river system of any less concern?
When Unity Mining bought the gold mine they publicly announced that they would also NEVER use cyanide or undertake full processing of the gold in Majors Creek but would adhere to the conditions already in place in the development and the conditions placed upon it by the Land and Environment Court. However, they suddenly changed their mind and without any consultation with residents decided to apply for modifications to do precisely this.
Unity Mining have lied to the community and can no longer be trusted or believed as they have no credibility. I believe that they do not, therefore, fulfill the requirements of social licence to operate. There is no compelling reason to fully process the gold in Majors Creek in such a treacherous situation, with contaminated water able to reach residences in Araluen in less than 10 minutes, because of the steep incline and the waterfall. In the event of an accident there would be no time to alleviate the problem and the release could easily cause death to a child playing in the creek below, let alone the damage to animals and the environment And fruit businesses.
I urge you strongly to consider the terrible dangers inherent in this proposal and ask you to refuse this application.


Rebekah Howard
22/08/15