MOD 8 - Mobile Coal Sizing and Waste Tyre Disposal

I strongly object to further polluting this area by burying many old, very large, rubber tyres underground, in areas where you have already caused environmental destruction by clearing the bush and the habitats of the animals that live in this area.

I strongly believe the company, which is working in this area, needs to take their rubbish away from this wilderness area and dispose of the tyres in an area that is already devoid of native bush and does not have native animals living in it.

We are destroying our wilderness areas. It has to stop.

Reg : Maules Creek mine - tyre burial and groundwater wastage.
Groundwater is precious. After mining the “sinks” let this water evaporate after is seems into the spaces left by mining.
The practise of Tyre Burial leaches toxicity into the groundwater and surrounding land.
These are dangerous for future land and water - please act to stop this.

Coal is killing us and dooming our future. No expansions, no new mines.

Please refer to attached comments.

This modification should be withdrawn.

Underground tyre fires are particularly problematic as they can be so difficult to control. A UK
Environment Agency Report (1998, Section 4.2 & 4.7) indicated that a tyre fire in a tip containing 10
million buried tyres burned for more than 10 years underground. Tyre fires in landfills threaten the ongoing operation of the facility and can release pollutants into the soil and groundwater.
In addition, tyre fires have the potential to impact on human and animal health as a result of the air quality
and pollution created from the toxic smoke created. Many chemicals carried in the smoke, some of which
are mutagens and carcinogens, have been identified in the emissions from both the controlled and
uncontrolled burning of rubber tires (CIWMB 1996). The smoke contains many tiny particles (smaller
than 10 µm) small enough to the inhaled into the deep lung (CIWMB 2002). The major carcinogens of
concern are polycyclic aromatic hydrocarbons (PAH’s) as well as heavy metals contamination of zinc and
lead (CIWMB 1998). These can cause acute health effects including eye, nose and throat irritation and
exacerbate asthma and repertory conditions and the potential to exacerbate pre-existing heart conditions,
confirming that the most significant public health risks appear to be people with asthma, heart and lung
diseases (CIWMB 2002).
https://www.accc.gov.au/system/files/public-registers/documents/D12%2B149381.pdf

My reasons for objecting to this project are:
- the environmental impacts have not been assessed. Such an assessment should be done taking into account the cumulative impacts of the many thousands of off road tyres the company has already buried in their mines across the region.
- The addition of many thousands of tonnes of unstable waste to what we will be left with after Whitehaven has gone needs to be known - it is not acceptable for the Department to accept the company's word on this or anything - they have a long record of breaking environmental laws and this project is an indicator that they don't plan to change that. If they wanted to mend their reputation for top shelf environmental destruction they would partner with the tyre companies in the Tyre Stewardship Scheme.
- Rejecting this modification is an opportunity for the NSW government to demonstrate to the community that it means what it says about resource recovery and recycling. A rejection would contribute significantly to the government meeting its targets, and at the same time run up a flag for a wide range of industries engaged in unnecessary waste creation and waste dumping.

See attached letter

Dumping tyres in the bush is not a valid solution for waste. Whitehaven should go with the re-use initiatives provided by tyre companies. Dumping is environmental vandalism.

http://www.planningportal.nsw.gov.au/major-projects/project/42841

To whom it may concern.

I object to using tyres as infill at the Whitehaven coal site.
Tyres are one of the most dangerous and toxic accumulated waste products.
Previously I was on the NSW State Waste Advisory Council when NSW was intending to reduce waste by 60% by the year 2000.
I discovered that the reason for myriads of tyres being stockpiled and dumped is firstly, the tyre companies want to sell more new tyres, and they pay the tyre retailers to slash tyres so that they cannot be retreads.
Another reason is the lack of legislation to limit the number of tyre sizes and requirement for standardised limited tyre sizes. Tyre shops do not have the range of suitable machinery to retread tyres.
All tyres of smaller vehicles or mining trucks must be dealt with sustainably by the manufacturers.
They must not be dumped, buried or burned because the toxic chemicals of the tyres find their way into the surrounding environment and groundwater or create toxic emissions and ash whether burned intentionally or ‘accidentally’.

Whitehaven is once again demanding to be permitted to further trash our planet.
Please do not allow Whitehaven to go ahead with this one more dangerous and unreasonable demand.

Yours faithfully
Keelah Lam
36 Lauderdale Avenue
Fairlight 2094
Ph: 0479090240

Wando Conservation and Cultural Centre Inc is based at Maules Creek approx. 70 kms from Gunnedah; Wando engages in research and monitoring to protect the environment and the communities in the area.
Wando opposes the application (Mod 8) on the part of Whitehaven Mines on a number of grounds:
a) Inappropriate and inadequate process
b) Failure to meet regulatory requirements
c) Groundwater concerns
d) Failure to consider new processes for dealing with end-of-life of mining tyres
e) Increased noise and dust from mobile crushers
f) Greenhouse gas assessment
Wando is firmly of the opinion that the modification must be rejected.
See elaboration in attachment

PA 10_0138, Modification 8
MAULES CREEK COAL MINE ‐ MOBILE COAL SIZING AND WASTE TYRE DISPOSAL We reject this modification
As an advocate for a local resident affected by the mine I oppose the application (Mod 8) on the part of Whitehaven Mines.
Some of our reasons to deny the application-
There is only an exhibition period limited to 14 days which is not sufficient to consider the modification and reply for the average farmer.
The precautionary principal has not been applied. Whitehaven have broken the law burying tyres, this is not acknowledged publicly.
This is not a minor modification but requires a new environmental assessment.
Groundwater contamination is a serious risk from the coal mines. This cannot be repaired after contamination, and all steps must be taken to prevent groundwater contamination from coal mining, particularly from burying tyres and other rubbish.
Whitehaven Mine at Maules Creek should be encouraged to engage fully with the Tyre Stewardship of Australia and other stake-holders to develop an efficient recycling option for dealing with end-of-life mining tyres in NSW. The Tyre Stewardship Council of Australia’s extended producer responsibility scheme will commence in January 2022
The modification, which would see the dumping and burial of at least 300 tyres per annum, a practice which has been occurring since 2012, is totally unacceptable.

As a advocate for Maules Creek resident, Cliff Wallace it is unacceptable to allow increase o any noise or dust in Maules Creek
.
Cliff frequently has trouble sleeping with the constant hum of mining machinery. Any relaxation of regulations that will increase impacts on neighbouring people cannot happen. There should be no modification that reduces the rights of the neighbours of the mine. No variation on light, waste, noise, dust or water modifications can be considered.
Most variation must be denied

As a advocate for Maules Creek resident Cliff Wallace these variations are not acceptable. On discussion with Cliff Wallace He does not supports PA 10_0138, Modification 8
Yours
Pat Schultz

It is not within my, nor would I suggest the broader community’s expectation that Whitehaven Coal should be granted exemption from recycling tyres.
Farmers in the district can’t bury tyres and in fact we pay for disposing of these products with the intention of them being recycled. I’m not sure of any exemption anyone else gets, and the mining industry located within our agricultural precinct should do the same and recycle these recyclable items.
Any claim by Whitehaven that this is too costly to recycle these recyclable items is opportunist at best. Whitehaven have stockpiled these onsite now for many years. In recent 2021 media articles I note the following points made and quotes from Whitehaven Coal CEO Paul Flynn.
“The head of Australian miner Whitehaven Coal, Paul Flynn, is expecting a strong start to 2021 as coal prices begin to rebound”
“Whitehaven reported a $94.5 million loss for the six months to December 31 (2020), down from the $27 million profit it posted a year earlier”
“With future savings targets identified and coal markets rebalancing in response to demand signals we are optimistic about achieving stronger outcomes through the second half,” Paul Flynn Feb 17, 2021
Burying of these recyclable items onsite when they can be recycled - but dismissed outright on economy aspects alone - should be called out for the demonstrably nonsense that it is. These items will remain legacy issues onsite, and they should be returned to raw materials or reusable products in the very least.
Whitehaven has made its own problem of this product on this site and other North-West NSW mining sites - over multiple years of profit, dividends for the investors and bonuses for executives - and only now in 2021 scope the cheapest option of burying many years’ worth of stockpiled tyres.
Our community - and this site that is anticipated to be returned to Agricultural use in due course, shouldn’t be seen as potential “savings targets” for Whitehaven Coal in regard to this issue.
It is obvious that for the length of time that this current mining project has been in operation, that tyre disposal should have been an issue by this time, and it begs the question – why Whitehaven are now seeking permission via official “modification” channels with years of stockpiled recyclable tyres onsite. What occurred prior to this stockpile developing? Is it easier to seek permission than forgiveness?
Whitehaven Coals ability to plan is appalling. Community expectation is set on day one of approval of the original project scope, and then dashed time and time again modification after modification, to a project totally out of scope of its original plans and approval.
Do the community a favour and reject this modification that will leave considerable legacy issues for future generations to deal with.
https://www.smh.com.au/business/companies/whitehaven-coal-points-to-green-shoots-despite-price slump-20210217-p573du.html

Dumping types into coal mines is against every advice on rehabilitation and will create a dangerous toxic site

This is dangerous to public health and biodiversity

Attached

I am very concerned about the ongoing and long-term impacts on human health from dust particulates, chemicals in the dust and mining noise. Three relocatable crushers, including one moving around on top of the Northern overburden, will generate a lot of noise (and dust) to our local residences. It will be impossible for the EPA to manage.
I object to the tyre burial. It will create ongoing, long term pollution of our water sources as the tyres break down over a 500 year period and leach toxic chemicals into our water source forever really. There is an intergenerational equity issue for our children. They need water, clean water and this region is the recharge area for the Maules Creek water source. The pollution will continue long after the mine is gone. 'Monitoring' is not a fresh water system to filter all the water that leaves the site both surface and groundwater. I object to the destruction of the forest by burying tyres in it and making rehabilitation even less likely to succeed. The resource recovery solutions exist. There is no need for this pollution inflicted into our community. I have a particular concern over the signals sent to a mining company that the EPA has found has illegally buried tyres at multiple site across the North West being given permission to do this after years of not complying with its pollution licence or project approval. Right now is the time for recycling and recovery of the tyre resources.
Finally, there is also an increase in greenhouse gas pollution from burning more diesel for trucks to crushers. Any fraction of an increase in greenhouse gases matters. An annual increase of 3,686 T C02--e - kilotonnes of carbon dioxide equivalence-,is relevant to the global climate crisis. Particularly as it is added to the 30,028,092 T C02--e on average of GHG emissions from the MCCM operations. Modifications should be about decreasing emissions and environmental and community impacts. This modification does the opposite. I ask the Department to reject this modification. There are many sensible ways forward. The options to recover the resource are available through Tyre Stewardship Australia and the crusher aspect must do more than save the company money by polluting the environment and community. Thank you.

letter attached

I strongly object to Modification 8.
It goes against the EPA waste Hierarchy and their Guideline Policy to bury tyres and the local Maules Creek community do not want the Leard State Forest to be a ‘landfill’ of waste rubber tyres that will cause environmental issues for future generations to deal with.
MCCM have not been good neighbours to our community or the Gomeroi and to inflict more toxic dust, noise and environmental pollution in the Leard State Forest and surrounding Maules Creek district is offensive and will have long-term consequences. Compliance of this modification alone will be impossible to police.