MOD 11 - water management during MPPS outages

I oppose the proposal to release toxic mine wastewater into our drinking water catchment. The impact on our water quality, the national park and the wildlife are unacceptable. Centennial should be made to fully treat the wastewater to remove contaminants prior to any discharge, to preserve Sydney's drinking water and the ecosystems that rely on the water system.

Thank you for your consideration.

I oppose Centennial’s toxic mine wastewater plans. Centennial MUST be required to properly treat mine wastewater to ensure that any discharge fully removes all contaminants such as elevated levels of salinity, arsenic, zinc, selenium, ammonia, fluoride, and brine and deliver the zero-release system they proposed when the water treatment plant was first approved. That was the original plan, and approval was given on this basis.

I find it completely irresponsible for Centennial to want to absolve themselves of the responsibilities that they had agreed to at the beginning of the water treatment plant and that they think it is fine to release these contaminants with an additional 42 million litres per day of mine wastewater to Thompsons Creek Reservoir (for up to 111 days at a time) to cover Mount Piper outage periods.

If their proposal goes ahead, it will consist of up to 18 million litres per day of water through the water treatment plant and 24 million litres a day of untreated water where only sediment is removed, meaning that untreated contaminated water would be released into the waterways free to contaminate Sydney's water supply at Warragamba Dam.

Currently, it is my understanding that Thompsons Creek Reservoir discharges water via tributaries of the Coxs River which flows through a World Heritage listed national park, the Blue Mountains which ends up at Warragamba Dam.

The company's modification report said it needed to discharge the additional water, bypassing its water treatment plant, as the plant was operating at capacity. The company must maintain their responsibilities and made to be accountable in the form of taking on guardianship of the pristine surrounds and to avoid at all costs any consequential potential environmental disaster.

Centennial must instead, build or extend the capacity of the water treatment plant prior to discharging any additional water to ensure thorough treatment of the water and to NOT discharge contaminates into waterways in a Conservation Area and World heritage listed site.

Discharging contaminated water will erode the environmental values of the World Heritage listed site (Blue Mountains) and a conservation area (Gardens of Stone). It will damage native wildlife habitat, swamps, waterways and streams particularly affecting the endangered platypus whose habitat requires clean waterways and streams.

Adding contaminates to waterways connected to Warragamba Dam will pollute Sydney’s drinking water and risk people’s health.

The EPA and the NSW government will have failed to protect flora, fauna and people if this water management proposal is approved.

Centennial has a terrible track record having breached its environmental licence, numerous times. They cannot be trusted to deliver accurate environmental assessments. To date, they usually understate their negative impact on the environment and they continually breach protections in place which attracts fines that then have taxpayers paying off Centennial's litigation costs!

The above statement is supported by the following two examples.

1. In 2010, Centennial was ordered to pay $1.5 million for causing irreparable damage to delicate waterways on the Newnes Plateau.

2. In 2017, this mining company was fined more than $1 million by the Land and Environment Court for spilling toxic coal sludge into the beautiful Wollangambe River.

The likely significant impacts of these projects on water quality and the fact that they are integral to the expansion of Angus Place Coal mine, demonstrates the need to refer this proposal for assessment under our national federal environment laws and to be assessed under the water trigger test. The NSW government must insist that Centennial be assessed under this set of criteria.

Because of the destructive implications for nature and communities, there is an urgent need for the NSW government to commission a public inquiry into mine wastewater produced by Centennial’s underground coal mines in the Gardens of Stone region.

The NSW government has a duty of care to protect human health, native wildlife, their habitats and the environment in this Conservation and World Heritage listed area.

I strongly oppose Centennial’s proposal of dumping contaminated water in our waterways.

Centennial has a history of environmental damage and breaches with significant fines attached. Because Mount Piper power station will be offline for maintenance, they want to release into Thompsons Creek Reservoir (for up to 111 days at a time) up to 18 million litres per day of water through the water treatment plant and 24 million litres a day of untreated water that is highly contaminated water into this reservoir. Thompsons Creek Reservoir discharges via tributaries of the Coxs River that flows through a World Heritage listed national park and a conservation area the Gardens of Stone- that ultimately flows to Warragamba Dam and provides Sydney’s drinking water. These pollutants are above Australian standards and will likely cause ‘environmental harm.’ They will further degrade swamps and wetlands in the area, rivers and streams. The threatened Platypus and other native wildlife will be severely affected. Water standards in Warragamba Dam could drop and severely affect people's health. Centennial needs to stop operation and build another water treatment plant to discharge this highly contaminated water in the proper way according to what was agreed in the original proposal. That is to deliver the zero- release system they proposed when the water treatment plant was initially approved. Anything less is not acceptable to the health of our fragile ecosystems, native wildlife and their habitat and people's health. Their proposal should also be assessed under national federal environmental law applying the water trigger criteria to assess the environmental impacts of this contaminated water discharge.

Sydney's drinking water is precious and all efforts must be made to avoid contamination. The Centennial proposal to release contaminated mine waste water into a water system which feeds into Warragamba dam puts at risk Sydney's main source of drinking water. This risk is entirely unacceptable.
Centennial’s underground coal mining right next to a national park has already damaged the aquifers under the Gardens of Stone. How could the public possibly rely on any assertions by Centennial's engineers that this release of the huge volume of 42 millions of litres a day of waste water (treated and untreated) won't pollute the drinking water of millions of Sydneysiders with heavy metals, salt and low oxygen levels? This proposed wastewater release would also contaminate the waterways of the Greater Blue Mountains World Heritage Area, with likely damage to its fragile ecosystems, wildlife and plants.
The proposal that this wastewater could be discharged for up to a third of the year for up to 15 years is an absolutely unconscionable risk to take. We are likely to experience a couple of extended droughts over this period, in which water levels will fall in natural waterways and Warragamba dam: in these periods, coal mine waste water is likely to be even more toxic.
Centennial is also entirely irresponsible in not offering an alternative solution should mine waste water exceed approved salinity levels.
Australia has no need of further coal, and we certainly don't need the carbon emissions from burning more coal, wherever in the world this occurs. We must protect the drinking water of Australia's largest city and precious Blue Mountains national park region. The Springvale mine is clearly an unsustainable operation and the solution is obvious. Close the Centennial Springvale mine.

To whom it may concern,
I wish to make some concerns known about the history of Centennial coal and their previous infractions that have led to environmental damage and fines in the past. This most recent proposal would compromise the health of Sydney's drinking water and the health of the local Heritage area in the Blue Mountains.
Drinking and washing water, at least where I live, is already laced with heavy metals which forces me to use a combination of kettles and filters to make drinkable water. This proposal would only make the issue worse.
As for Centennial, they have already been denied similar discharge proposals twice, as far as I know; I do not see a reason for this to be any different.
If this proposal is approved it could lead to further problems down the line as Centennial will go further and further with its requests. Unless they can treat their water before discharging it, I am against this proposal. If they can't treat their water, the Springvale Mine should be closed and alternative fuel/supplies (whether renewable or otherwise) should be sought.
Centennial Coal has also breached its environmental licence across 7 mines over a thousand times, so they should no longer be in a position to self-report or police their own reporting.
Finally, the NSW government should commission a public inquiry into mine wastewater from Centennial Coal's mines in the Gardens of Stone area.

Thank you for your time,
Matthew Hasemore

I wish to put forward reasons behind my objection to the proposal by Centennial Coal, to discharge toxic wastewater into the headwaters of Sydney’s drinking water supply. This is a horrifying thought, that the quality of drinking water & the ecology of the Greater Blue Mountains World Heritage area be compromised, by a company who has an appalling track record of environmental licence breaches.
Water experts have previously suggested that this approach, the blending of dirty water with treated water will exacerbate the pollution of Sydney’s drinking water catchment.
Species such as the platypus will be negatively affected by raised salinity, which may affect their ability to source food.
The only safe solution here is to ensure that Centennial treat mine water & remove all heavy metals, salt & brine.
They also need to deliver on the ‘Zero release system’.
We are failing our environment & all that depends on it if this proposal is granted.
Thank you, Meg Bray

See attached document

Dear Reader
I oppose this proposal due to my concern that the health of Sydney’s drinking water and the ecological value of the Greater Blue Mountains World Heritage Area and wildlife such as the platypus will be compromised should this proposal be approved.
Water experts have previously warned that blending or dilution of dirty water with treated water will exacerbate, rather than address, pollution of the Sydney drinking water catchment as overall load of pollutants will drastically rise[1].
Two previous applications from Centennial seeking to discharge megalitres of mine waste into Wangcol Creek were withdrawn, and this ‘dilute and discharge’ approach would be far worse as it involves far more polluted water.
If this first proposal is approved, it would result in a huge increase in pollution, heavy metal and salinity load into the receiving environment. Higher salinity means lower oxygen, which reduces food for platypus. Elecro-receptors on their bill locate prey, however salinity disrupts these, they can’t find food and starve to death.
As Mount Piper power station may remain open until the early 2040s, Centennial is seeking permission to dilute and discharge water from Thompsons Creek Reservoir during scheduled offline maintenance periods for the lifetime of the water treatment plant. This could mean up to or around 15 years of huge volumes of dirty water discharge for up to 111 days at a time.
Centennial should be required to treat mine water to ensure that any discharge fully removes contaminants like heavy metals, salt and brine and deliver the zero release system they proposed when the water treatment plant was approved. Anything less threatens the safety of Sydney’s drinking water supply and water dependent ecosystems, including endangered and threatened species.
If Centennial is unable to do this, Springvale mine must be closed and alternative coal supplies found for Mount Piper power station.
It is not good enough for Centennial to self-monitor the level of contaminants as they have proposed. Centennial has been found to have breached its environmental licence more than 1400 times across 7 coal mine sites in the Greater Blue Mountains region[2].
There is no ‘plan B’ to divert mine water if monitoring reveals higher than expected salinity levels.
The planning department must require Centennial to significantly reduce the mining intensity at its underground coal mines to protect the natural environment and to reduce the volume of wastewater sent to Mount Piper power station.
The government should commission a public inquiry into mine wastewater produced by Centennial’s underground coal mines in the Gardens of Stone region.
[1] Centennial Coal plan to release more water into Sydney catchment will make pollution worse, expert says - ABC News

[2] https://apps.epa.nsw.gov.au/prpoeoapp/

Please do not allow this Submission by Centennial Coal to be approved.


Sincerely

J Reid

I am writing to express my strong opposition to this proposal which puts at risk the quality of Sydney's drinking water. This will directly adversely affect the health of my children and grandchildren and should be of major concern to the entire water drinking population of this huge city. Additionally, the ecological value of the Greater Blue Mountains World Heritage Area and wildlife such as the platypus will be compromised should this proposal be approved.
Water experts have previously warned that blending or dilution of dirty water with treated water will exacerbate, rather than address, pollution of the Sydney drinking water catchment as overall load of pollutants will drastically rise.
Two previous applications from Centennial seeking to discharge megalitres of mine waste into Wangcol Creek were withdrawn, and this ‘dilute and discharge’ approach would be far worse as it involves far more polluted water.
If this first proposal is approved, it would result in a huge increase in pollution, heavy metal and salinity load into the receiving environment. Higher salinity means lower oxygen, which reduces food for platypus. Elecro-receptors on their bill locate prey, however salinity disrupts these, they can’t find food and starve to death.
As Mount Piper power station may remain open until the early 2040s, Centennial is seeking permission to dilute and discharge water from Thompsons Creek Reservoir during scheduled offline maintenance periods for the lifetime of the water treatment plant. This could mean up to or around 15 years of huge volumes of dirty water discharge for up to 111 days at a time.
Centennial should be required to treat mine water to ensure that any discharge fully removes contaminants like heavy metals, salt and brine and deliver the zero release system they proposed when the water treatment plant was approved. Anything less threatens the safety of Sydney’s drinking water supply and water dependent ecosystems, including endangered and threatened species.
If Centennial or any other mine operator cannot remove contaminants from their mine water before releasing it into Sydney's drinking water supply then their operations cannot be tolerated and must cease.
The risk to health is too great and that is why I strongly object to this proposal.

Energy supply to NSW depends on the continuation of mining and generation operations in the Lithgow area.
These operations contribute to the wellbeing of the local area by providing employment and economic opportunities, the cessation of which would be devastating to the local communities.
The proponents have, over many years, shown a significant commitment to improving water quality outcomes for the catchment and I fully support approval of Mod 11.

I attach my document indicating the reasons why Centennial’s toxic mine waste plans are opposed. Centennial MUST be required to properly treat mine wastewater to ensure that any discharge fully removes contaminants like elevated levels of salinity, arsenic, zinc, selenium, ammonia and fluoride, and brine and deliver the zero-release system they proposed when the water treatment plant was first approved.
Centennial now wants to release these contaminants with an additional 42 million litres per day of mine wastewater to Thompsons Creek Reservoir (for up to 111 days at a time) to cover Mount Piper outage periods. This will consist of up to 18 million litres per day of water through the water treatment plant and 24 million litres a day of untreated water (only sediment will be removed). This refers to untreated contaminated water!
Thompsons Creek Reservoir discharges via tributaries of the Coxs River that flows through a World Heritage listed national park and ultimately to Warragamba Dam. The company's modification report said it needed to discharge the additional water, bypassing its water treatment plant, as the plant was operating at capacity.
Discharging contaminated water will erode the environmental values of the Greater Blue Mountains, a World Heritage listed site and a conservation area (Gardens of Stone). It will damage native wildlife habitat, swamps and waterways and streams particularly affecting the endangered platypus. Adding contaminates to waterways connected to Warragamba Dam will pollute Sydney’s drinking water and risk people’s health. The EPA and the NSW government has failed to protect nature and people if this water management proposal is approved.
The likely significant impacts of these projects on water quality and the fact that they’re integral to the expansion of Angus Place coalmine, needs to be referred for assessment under our national environment laws and assessed under the water trigger test. The NSW government must insist that Centennial be assessed under these criteria.
Furthermore, because the implications for nature and communities are so dire, the NSW government should commission a public inquiry into mine wastewater produced by Centennial’s underground coal mines in the Gardens of Stone region. The NSW government has a duty of care to protect people's health, native wildlife, their environment and habitat and a Conservation Area and a World Heritage listed area.

I object to the release of toxic waste at any time into the Cox's River. The river itself cannot clean the toxins from the water, the toxins must be removed and dealt with sustainably by Centennial Coal before the water enters the river. We are loosing our viable river systems and with it the biodiversity that maintains life on this continent through the lazy self interest of destructive industries.
The water does end up in Warragamba Dam where the State Government and NSW taxpayers will have to clean up Cenntenial's mess, with Centennial laughing all the way to the bank.
Stopping the contamination at the source is non negotiable and must be closely monitored to stop the environmental vandalism Centennial will be continually attempting.

Centennial Coal has magnified the need to protect against dumping of toxic spent water into our drinking water catchment. This is almost too absurd to contemplate, but it's a real threat, and I stand with all those people on country and throughout Australia to represent nature and health conservation. Our first people will be horrified that Centennial Coal are even suggesting this lunacy! Where's the EPA, the environment Minister and locals, whose voices are drowned out by the dollars this proposal represents. Please do the right thing and not allow this environmental vandalism to occur.
Yours faithfully,
Colleen Roche

It disturbs me that water used in the processing of coal would be redirected into the drinking water catchment, for reasons of both public and ecological health.

I am totally opposed to Centennial mining operations and water discharge due to the damage and pollution to the Coxs River and catchment. The area is adjacent to the Gardens of Stone State Conservation Area and the World Heritage Area of the Blue Mountains. This is a stunning nature wonderland with more than 80 rare and threatened species and 16 threatened ecological communities and Aboriginal sites many thousands of years old.

Centennial Coal has already damaged aquifers, draining irreplaceable peat swamps, destroying them forever. The mining operations at Angus Place and the water discharge are continuously damaging the environment. I am totally opposed to the release of mining waste water and associated damage to the environment.

Kind Regards

EnergyAustralia supports the Modification Application and Report and is pleased to provide comment as per the attached document.

I’m very concerned about the health of Sydney’s drinking water, the impact on wildlife such as the platypus
Centennial Mining operations are adjacent to the Gardens of Stone State Conservation Area with rare and threatened species
Intensive mining methods have destroyed acquirers and Centennial removes more than 20million litres of groundwater annually and stores 5 billion litres of mine wastewater underground and proposes to discharge this waste water into Sydney’s catchment of 42 million litres per day
We already have recognised high pollutants in Sydney drinking water

Do I and the rest of the people in Sydney want to drink polluted water? NO
Do I and the rest of the people in Sydney want to see the ENVIRONMENT destroyed because of corporate greed? NO
So Centennial wants to release an additional 42 million litres per day of mine waste water to Thompsons Creek Reservoir (for up to 111 days at a time) to cover Mount Piper outage periods. This will consist of up to 18 million litres per day of water through the water treatment plant and 24 million litres a day of untreated water (only sediment will be removed). Thompsons Creek Reservoir discharges via tributaries of the Coxs River that flows through a World Heritage listed national park and ultimately to Warragamba Dam. And this could continue for 15 years?

They are also proposing to apply to release up to 26.5 million litres per day into Wangcol Creek consisting of 16.5 million litres per day treated water via the water treatment plant and 10 million litres per day untreated water (only sediment will be removed) for up to 4 years.

The Major points for my submission are
• I clearly oppose this proposal and am especially concerned that the health of Sydney’s drinking water and the ecological value of the Greater Blue Mountains World Heritage Area and wildlife such as the platypus will be compromised should this proposal be approved.
• Water experts have previously warned that blending or dilution of dirty water with treated water will exacerbate, rather than address, pollution of the Sydney drinking water catchment as overall load of pollutants will drastically rise[1].
• Two previous applications from Centennial seeking to discharge megalitres of mine waste into Wangcol Creek were withdrawn, and this ‘dilute and discharge’ approach would be far worse as it involves far more polluted water.
• If this first proposal is approved, it would result in a huge increase in pollution, heavy metal and salinity load into the receiving environment. Higher salinity means lower oxygen, which reduces food for platypus. Elecro-receptors on their bill locate prey, however salinity disrupts these, they can’t find food and starve to death.
• As Mount Piper power station may remain open until the early 2040s, Centennial is seeking permission to dilute and discharge water from Thompsons Creek Reservoir during scheduled offline maintenance periods for the lifetime of the water treatment plant. This could mean up to or around 15 years of huge volumes of dirty water discharge for up to 111 days at a time.
• Centennial should be required to treat mine water to ensure that any discharge fully removes contaminants like heavy metals, salt and brine and deliver the zero release system they proposed when the water treatment plant was approved. Anything less threatens the safety of Sydney’s drinking water supply and water dependent ecosystems, including endangered and threatened species.
• If Centennial is unable to do this, Springvale mine must be closed and alternative coal supplies found for Mount Piper power station.
• It is a sick joke and It is not good enough for Centennial to self-monitor the level of contaminants as they have proposed. Centennial has been found to have breached its environmental licence more than 1400 times across 7 coal mine sites in the Greater Blue Mountains region.
• There is no ‘plan B’ to divert mine water if monitoring reveals higher than expected salinity levels.
• The planning department must require Centennial to significantly reduce the mining intensity at its underground coal mines to protect the natural environment and to reduce the volume of wastewater sent to Mount Piper power station.
• The government should commission a public inquiry into mine wastewater produced by Centennial’s underground coal mines in the Gardens of Stone region.

Releasing toxic wastewater into a reservoir that then discharges into the headwaters of Sydney’s drinking water supply? Are you serious? How is this even being considered? Have we not learnt this lesson many times before? Have these mining companies not already poisoned and/or killed enough? Not to mention the permanent destruction to the land and waterways.
Even IF they can filter the wastewater, why would you even take the chance? Hell no!

I object to this proposal as the risk to the environment and the water catchment area is to great.
This company have previously damaged the environment.