Mod 3 - Processing & Tailings Storage

I object to the modification of Dargues Reef gold mine which allows cyanide to be used to process the ore.

Reasons:
Cyanide permanently releases heavy metals into the tailings slurry.
The mine has already proved that it cannot keep its waste material safely on site.
Scientific consensus predicts climate change will lead to even more intense rainfall events in our region.
Nearly all the Shire's water supply comes from the Deua River which would be severely impacted by a spill from the tailings dam.
Pollution of the water supply would have a huge effect on the health of the population that may be on going as heavy metals would remain in the sediment of the river.
Heavy metal contamination of the estuary sediments would also impact the fish and other marine life.
Recreational and commercial fishing and oyster production could also be impacted by heavy metals in the estuary water and sediments.

I would like to object most strongly to the proposal by Unity Mining to expand the operation of Dargue Reef gold mine to process on site, using cyanide. This will put the Moruya River catchment under threat, no matter what environmental controls are placed on the development. It is not acceptable to undertake activities which have the potential to damage the water supplies of the productive Araluen Valley and tens of thousands of residents of Eurobodalla Shire.

To whom it may concern.
I have been a land owner on the Deua River for just over 25 years. I have always felt so honoured to experience one of the very few pristine rivers in this country. I have recently been able to capitalize on my property by growing composting worms and organic strawberries. I have held on to this property for the sake of my grandchildren and their experience of swimming in a pristine river.
The Dargues Reef Mine project is putting my agricultural business and the health of river and the people who honour it AT A HAZARDOUS RISK. Do we now have to test our waters before we use it for agriculture, before we swim in it, before we bath in it. And how can we even consider risking the drinking water of the people. It is a water catchment and can not afford any risk of toxic accidents, unforseen toxic runoff and even forseen toxic runoff. This water is the life force of all that depend on it. This is risking life. The life of the Deua River. Please put a stop to this mine expanding and using further toxic chemicals.
Please consider for the rights of the people the river and not greedy companies looking for easy ways out.

To whom it concerns,

I object strenuously to the suggestion by Unity Mining Limited that they be allowed to conduct on site extraction of gold from gold ore by using cyanide processing at the Dargues Reef Mine, even though the original granting of the right to mine in this area was granted only due to the condition that all ore be processed offsite. It is also my understanding that they wish to have this allowed without submitting a revised Environmental Impact Statement.

I have grave concerns about allowing this kind of extractive processes in the catchment of such a beautiful and healthy river system as the Deua/ Moruya. As a fisherman and kayaker/ canoeist I have spent many days on this river and the thought that a sudden flood could result in huge fish kills and siltation of its crystal clear waters is incredibly distressing. Apart from the fish and the ecosystem as a whole, many local residents and farmers rely on the river for water (for both humans and stock).

In addition to this the potential impacts on the tourism industry in Moruya downstream of a spill over of the proposed tailings dam could be catastrophic if it results in fish kills and pollution of the waterway. The town of Moruya relies a great deal on the influx of summer tourists who come to fish, swim and paddle in the river and the customers that this brings to local businesses. To put this industry at risk in the long term simply to allow a mining company to save a few dollars and provide a small number of temporary jobs is short sighted in the extreme.

The health of this river has been previously affected by gold mining and its impacts in the past (in the 1800's), and caused its once deep and crystal clear flow to become silted and sand slugged to the point that the 60 tonne ships that used to be able to dock at Moruya township were unable to make their way up the river at all. This damage which stopped in the 1870's with the cessation of large scale sluicing for gold can still be seen today (in the siltation of the river at Moruya township as you pass over the bridge) and this will likely take thousands of years more to be cleared by natural processes. In the intervening 145 odd years since these events, the river has been able to recover, in parts, to a semblance of what it must once have been before these practices were begun and support a beautiful native fish assemblage and ecosystem (despite the damage).

In this vein I would urge the NSW government to consider the potential social, economic and environmental impacts that a spill over of the tailings dam proposed could cause to the river and weigh this against the very limited benefits to the local area that allowing on site processing at the Dargues Reef Mine would provide.

Sincerely,

Alex Blanden, Canberra, ACT.

I am incredibly concerned about what the impact of processing cyanide and heavy metals on site will have on the environment and the water quality in the catchment area of the Araluen creek and Deua River Valley. I grew up in this pristine area and This is the water we DRINK, not just the people who live here but the whole shire, how can this have ever been thought of as a good idea, are people Insane!!!! NO CYANIDE!!!!!!!!!!

This idea is a disgrace. To build a gold mine in the upper reaches of a catchment area is stupid enough, but to process the gold on-site using Cyanide and just build a dam to store the waste? Are you kidding?! What happens in 100 years?

According to a govt. report "while much of the cyanide used at mining sites does break down fairly readily, either as a result of natural degradation or the various treatment processes sometimes employed, significant amounts of
the original cyanide form potentially toxic compounds that remain unaccounted for in the monitoring of mining operations." (http://www.esc.nsw.gov.au/council-services/water-waste-recycling/water/watersupplygeneralinformation.pdf)

So what are they going to do about that?

Why did they not include this request in their original application???

This is completely irresponsible, not to mention incredibly dodgy. The Deua river is a fragile ecosystem and it feeds the Eurobodalla shire water supply.

With water resources the world over the way they are, why on earth would you chance ruining an amazing supply that has been bountiful for time immemorial?!!

That is just stupid.

Please, please do not allow this.

The only reason the mining co. would want this, is to cut costs, and I am quite sure a mining co. such as unity would be able to afford to take it elsewhere for treatment, somewhere that is NOT in a catchment area, perhaps?

I DO NOT SUPPORT PLANS FOR A GOLD PROCESSING PLANT USING CYANIDE AT DARGUES REEF MINE

I live near the Moruya River and along with many others from along the headwaters to the estuary I am very concerned about the serious pollution risks from this plant.

I consider this site is totally inappropriate for a gold processing plant using cyanide. Fines for pollution have already revealed a lack of competence by Unity Mining and the potential cost to community is too great.

Pollution risks to Moruya River catchment are potentially catastrophic and it is not logical to make the assumption that there will never be any failures in the design or working practices of this mine.

As a resident of Eurobodalla Shire, a past bushwalker and now tourist of the Majors Creek, Araluen and Duea River areas I fee the proposed cyanide extraction plant in the headwaters of the above creek/ river systems just poses an unacceptable risk. I have read the company's environmental application and sure, on paper it looks good but in my experience companies go into receivership and the new owner , while trying to recoup value for proponents can fail to carry out all the controls originally agreed upon.
If there was no risk five times a day monitoring would be unnecessary and if on investigation of unexplained fauna death cyanide was found to be involved it would be too late.
These potentially affected waterways are the headwaters of Eurobodalla's drinking water, the source of water for the Araluen agricultural enterprises and the waterway in one of the most unspoilt areas of the State.
The reason for the proposed cyanide extraction plant is to make the mine more profitable for the company. I feel that the potential profit of the company does not balance any risk, even if very slight to the environment, and lifestyle of the residents of Major's Creek, Araluen Valley, Duea River Valley and ultimately Eurobodalla Shire.

The employment and training opportunities that would be available if this mine goes ahead, would benefit the whole community. Currently Braidwood" exports" the majority of its young people due to the lack of employment opportunities in the district.
There is a financial benefit for the local businesses, this was seen in past years with the exploration drilling teams, and the road and Portal construction project. Rental properties, the local supermarket, petrol station, mechanics, cafe's and the school all benefited from the extra work and income they were receiving.
The company in the past has shown a willingness to conform with regulations and they have shown care and respect for the local environment and community. They have for many years, and Cortona before them, built up a base line for sound, and dust levels and water levels in the local creek that occur now in the area, they will have this to refer to once they begin mining operations..
The modification for processing on site, has the benefit of taking heavy truck movements off the Majors Creek road. Even though these truck movements were not going to be great and there was agreement of times when the road would be left clear for school buses etc. it is still better that they do not occur.
The panic about Cyanide from some sectors, seems extreme. Possibly it is from misinformation or scare tactics employed by those who do not want this mine to go ahead, no matter what, and will use any tactic to stop it. It seems the loudest protests come from those not living in the district or retired or self funded people, who have no need of a job for themselves or their children. Unity has agreed to all the strict handling controls, and indeed it is their interest to meet these.

If you look at their operation at Henty in Tasmania in the middle of a wilderness area, it is still operating. If they were a careless company with no regard to environment they would have been closed down years ago.

In the past there has been a willingness to provide financial support within the community, sponsorship of local sport clubs, restoration and donation of the old Gold Coach to the Braidwood Museum, donation to a local community group to assist with building a children's playground and restoring the tennis courts. The company has shown a real spirit of community and I am sure this will continue if the mine can go ahead.

At the community meeting where the processing on site was announced, the company presented all the information that we needed as a community to asses the proposal. It was a pity that the presentation was interrupted so many times by the same few people asking the same questions, so that the meeting become protracted and a lot of people left before all the information was presented. This would indicate to me though , that the people who left were happy with what they had heard and did not feel they needed to stay.

I totally support the mine and its current proposal for processing on site

My family are in support of this mine. The benefits to our community are enormous. The development application and modification application prove how safe this operation will be. This mine should be allowed to continue.

Im in full support of Unity Mining to develop and mine the Dargues reef ore body. Unity have proven they can mine in a a safe and environmentally sensitive way at Henty. The project will provide great employment opportunities for the people of the region and could lead to further discoveries of gold and or base metals.

I make this submission as a resident and landowner of Braidwood. Whilst I have in the past expressed interest in employment with the mine (and would certainly consider that option should the opportunity arise again), I have no particular affiliation with the mine or any contract for services which may realise from the mine moving into production.

I support the development of the mine as I see it as an incredibly important driver of growth for Braidwood and district. In a town lacking any one major employer, the mine would drastically improve the local employment landscape by both providing opportunities for the many locals who commute to Canberra for work to instead work locally and the introduction of 'new' workers into town stimulating population growth. Despite early challenges with environmental issues, I have every confidence that Unity appears to demonstrate the ability to operate the mine in a responsible and sustainable manner.

Over a period of 3 years I have watched with interest of how Unity Mining evaluates the Dargues Gold Mine in Southern NSW. Their approach has been systematic and thorough and with all projects of this size it has come with some huge hurdles
As with all mining operations in Australia there are some very stringent guidelines that come with operating such assets, and Unity has proven that they are able to successfully operate these assets within the regulatory guidelines at all of its current operations.
Safety, community conciliation, environmental impact, employee relations, budgetary constraints, and delivering on what they say, are key to any successful business and Unity Mining continuously delivers. When evaluating whether I would like to work for such a company, Unity ticks all the boxes in this regard.
I have no doubt that if Dargues Gold Mine is given approval modification 3, Unity Mining will operate a very successful mine operation.

I am writing to express my concern about the possible downstream impact of any failure/leakage of the proposed tailings dam at the mine.
Many people will have forgotten about the amount of rehabilitation work that was required in the 1970s to ameliorate the impact of heavy metals in runoff and leakage from past Captains Flat mining downstream on the Molonglo River and Lake Burley Griffin in the ACT. No system is ever foolproof and any failure of the tailings dam at Dargues Creek Mine will have a serious impact on downstream water quality and the aquatic environment.
The Deua River Rivercare Group has been working over the last 10 years to improve water quality and the aquatic environment of the Deua River. The work has been carried out on a voluntary basis using funds raised by the group. The work has been supported by Eurobodalla Shire Council because of the positive impacts on the riparian environment.
Repair of the river has seen an increase in aquatic and adjacent terrestrial diversity as well as protecting water quality. The river water is used to provide part of the Shire water supply.
Heavy metal contamination has a long term impact on human health and to risk any pollution of a municipal water supply is foolhardy.

I have lived on the Deua River, downstream of the proposed development, for the past sixteen years. The Deua River is one of the few rivers in NSW which is in reasonably good health from an environmental point of view, however it continues to be exposed to threats which are either expensive or impossible to remediate. The Dargues Reef project is one of these threats.
I am an active member of Deua Rivercare. We spend a lot of volunteer time, and a significant amount of taxpayers dollars, on remediating the mistakes of the past. Surely we must learn the lesson soon that waterways are a precious resource, and must not be compromised for short term profit.
I have both general and specific concerns about the Dargues project.
General concerns include;
the prioritising of extractive over productive industries.(mining versus agriculture)
the lack of application of the precautionary principle with reference to difficult to quantify effects on aquifers and catchments
the destructive effects on small communities of boom and bust style development
prioritising of short term private rather than long term public gain.
My specific concerns relate both to Unity Mining itself, and to this application.
Unity mining has a history of breaching both trust and consent conditions on this project. The CEO is on record saying there would never be cyanide processing on site. This was obviously a politician's use of never, rather than the way most of us use the term. He is now on record saying there will never be processing of ore from offsite at the Dargues facility - I don't believe him.
The company breached environmental conditions when they first started work on the site - no matter how tight the consent conditions, if they are breached they are worthless. I am concerned that the company does not have the capacity to adhere to consent conditions, and that the consequences of failures range from problematic locally to catastrophic regionally.
The company appears to be insolvent. The share price is very low. There appears to be no discussion in the application of what will happen if they are unable to raise the capital to complete the project. Will we be left with another unfinished, unremediated industrial site? Or will the project be sold to the highest bidder and another round of development proposals begin?
Concerns specific to the application are limited by my lack of technical expertise in the field, however from what I can make out;
the funding round the cyanide processing area appears under done. It is 110% of the largest tank rather than 110% of the capacity of all eight tanks.
There appears to be inadequate detail about how the issue of acid leachate from the tailings dam will be managed. This has substantial long term impact on the catchment health.
There appear to be no specifications as to the expected lifespan of the plastic, partial dam liner, and of the plastic material they plan to use to contain the tailings and waste during post production site remediation.
there is discussion of possible exploration of reefs nearby, I presume if these prove to be exploitable they will process on the proposed Dargues site. There is no discussion of the implications of more tailings, or an extension of the tailings facility.
I am concerned that this project, if allowed to go ahead, will continue to grow, modification by modification, and impact on our ecosystem and community in ways which are impossible to quantify.
I hope the substantial community opposition will inform the decision on this project

I am extremely concerned about the impact that the proposed modification will have on the environment. However many precautions are taken there is always the risk of a spill and if cyanide escapes into the water system it could have disastrous consequences.Unity Mining has a bad record in regard to mining at the site. It has pleaded guilty to three counts of discharging silt-laden water at the site.
The proponent's history of remediation at its Kangaroo Flat mine at Bendigo does not fill one with confidence.A news item posted by ABC radio on 11th November, 2013 states that Bendigo residents wanted the land where the mine is situated remediated. They were also concerned that the plant would be reopened to process gold trucked in from interstate.
A news item published in the Bendigo Weekly on 15th November 2014 stated that groundwater previously pumped out of the Kangaroo Flat mine was rising in the city's abandoned mineshafts The water had high levels of arsenic and salt in it as well as sulphur and metals such as manganese.
Given the proponent's previous history, and the possible environmental consequences, the approval authority should be extremely wary about granting the proposed modification.

I support it because lots of people would benefit on this project.

Dear Madam/Sir,

I think that 'Environmental Assessment - Modification 3' demonstrates competence and good intent of Unity Mining company managers to develop Dargues Gold Mine according to the world's best practice, which should alleviate reasonable concerns of the community for the natural environment of this beautiful region.

I also believe that this project will significantly advance the local economy and therefore sincerely hope that Unity's application will meet with your approval.

Yours truly,

Drazen Vukovic
(Consultant Geologist, based in Canberra)

Do not allow Unity Mining to use cyanid processing anywhere in the Deua/Moruya River catchments under any circumstances or at any stage. Already Unity Mining have had environmental breeches in their construction phase, which have contravened the NSW Government Environment Protection Legislation and the small fine of little consequence to Unity Mining.
With Unity Minings current track record it is not an 'if there is a breech with the cyanid processing' it will be when there is a breech. When there is it will kill all animals life that uses the waterways or feeds within them. This would be an environmental catastrophe of enormous consequences. It would put the human drinking water for Eurobodalla Council Area, wetlands in the tidal zone of Moruya River and the Batemans Bay Marine Park at extreme risk of irreparable long term damage. No fine would be enough to fix such damage.
Further, it would be left for future generations, not Unity Mining, to be the police force/guardians to stop the catchment being used by any primary producers directly or indirectly, or drinking water supplied to residents of the Eurobodalla Council Area, once they have been contaminated.
This is an extraordinary unacceptable long term risk, please make sure Unity Mining is not given an extension to their current lease but instead go through a new Development application to stop this madness.

I am keen to be part of this exciting project going forward.