Mod 3 - Processing & Tailings Storage

This project looks very promising for the future of the surrounding communities creating employment and growth and into the future trades, recognition that mining and communities can work together and both prosper from each other.

Surely it would be close to a criminal act to deliberately use a toxic substance on an elevated site, poised above food producing pastures, orchards and human habitation. The criminality is knowing that the holding containers for any future toxic materials have once already allowed the contents of mud and silt to overflow and sweep downstream. (Imagine the risks posed to the health of humans and animals and crops and fruit orchards if the overflow was during production, with toxic waste material in the holding containers). The overflow of mud etc was a mistake which forced the company to admit liability and pay a fine. This admission of awareness of the dangers involved with using toxic substances, coupled with the Company's full knowledge of this area's volatile and predictably violent rainstorms would make it a lot easier to bring a class action against this company.



Araluen

What is the annual rainfall of Araluen?

The annual rainfall of Araluen is about 720 mm.

What is the most rain Araluen has ever received in a day?

The most rain received by Araluen in a day was 200 mm.



For example:- As long ago as February 1860 unpredictably heavy rainfall fell in the Araluen and Braidwood regions. Consequently severe floods caused major destruction and resulted in a flash flood killing 24 people.

In 2010 there was a road collapse on Araluen Road, about 18km from Moruya as a result of extremely heavy rain such as 110 millimetres in 45 minutes.

In 2012 a four-wheel-drive became stuck when it attempted to cross Araluen Creek after three days of torrential rainand the three men attempted to exit the vehicle, before they were washed downstream in the floodwaters.

One of the men was rescued from a tree and another was located downstream while the third mans body was recovered downstream.

In 2014 heavy rain brought drenching rain in eastern Victoria and southeastern New South Wales in 24 hours

A broad low pressure trough fed by a very humid northeasterly flow and was aided by an upper level low lying over southwestern NSW. This generated significant instability, producing widespread heavy rain and thunderstorms across the region. "Several places cracked the 100mm mark, including Araluen which collected 147mm to 9am, its heaviest rain since 1992."



How can this record of deluging, spilling, flooding and unpredictable rainfall be ignored by a company whose activities rely on maintaining the absolute opposite?

It doesn't sound safe and it isn't.

I am writing to object to the EA FOR THE DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054.

I made a submission when the mine was originally proposed, because I did not think it was in a suitable location. In the end the mine was approved without an associated gold processing plant using cyanide. This was very important to the approval of the proposal.

Now the proponent is suggesting that the consent be modified to allow a gold processing plant using cyanide, on the grounds that there will be financial benefit to the proponent.

There was no case for the gold processing plant before, and there is none now. The risk to water, bushland and farmland is too high. The site is located on a hill above a village, so if there's any spill from the tailings storage facility, it will have potentially a severe social, environmental and economic impact.

I don't think the modification should be approved.

The proponent has stated that

I AM IN SUPPORT OF THIS APPLICATION GOING AHEAD FOR EMPLOYMENT AT MAJORS CREEK MINE

The project will provided great employment oportuinties.

I earnestly and respectfully urge a halt to any mining and related processes using cyanide and other environmentally risky processes at the Dagues Creek mine
I urge a maintains fe of existing arrangements
Yours sincerely
Meg Selman

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

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'. We 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.

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.

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. 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 member of the local community in Eurobodalla I call on you NOT to approve modification 3 to allow Unity mining to use cyanide in processing gold at Dargue Reef.


Signed

Sandy Wilder
Moruya Heads

POINTS FOR SUBMISSION ON DARGUES REEF GOLDMINE Environmental Assessment
Submission on EA FOR THE DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054 July 2015

As a landholder in Eurobodalla I object to this third modification to the Dargues Reef Gold Mine Development Application. I acknowledge that these points have been taken from a document prepared by an action group set up to oppose the modification and are not my own work. However, I agree with all the points and I use them simply because I cannot express the concerns I have any better than is done here.

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

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.

The proposed modification creates a pollution risk that is unacceptable to residents along the entire Moruya River catchment.


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 for ever.
* The EA maps show it is on a hill above a village, on the edge of steep escarpment and at the headwaters of an important river system. Spring Creek, Majors Creek, Araluen Creek, and Deua/Moruya River are all used for domestic water supplies and agricultural purposes
* Pollution in these waterways would threaten the orchards and market gardens of the Araluen Valley and the water supply to Eurobodalla Shire.
* The Environment Protection Authority (EPA) agrees that the use of cyanide and full processing of gold on the mine site has significantly increased the risk of environmental harm.
* It is also located in a highly sensitive, biodiverse area of NSW, and threatens wildlife drinking the water in Conservation Reserves and National Parks. Heavy metal pollution could also be carried into Batemans Marine Park by the Moruya River.
* This mine is on a completely different kind of site to the Unity mine at Henty in Tasmania which should not be quoted as proof that this kind of processing plant at Dargues Reef will be safe.

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 you agree with the EPA that a full risk assessment needs to be done which addresses all environmental risks associated with the TSF. This should include consideration of moving the TSF to a more appropriate part of the site which happens to lie in the Shoalhaven River catchment.
* Correspondence obtained through GIPAA reveals the unsatisfactory response from Unity that this is not justified as the company is "merely seeking to modify an already approved TSF layout." 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.
* The "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 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.
* 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 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.
* 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 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.
* 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.

Summary
* It makes no sense tto 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.

Letter of Opposition to On-Site Processing by Darques Gold Mine at Major's Creek

10th January 2015

Dear Sir/Madam

I am writing to voice my opposition to the proposed changes to permit on-site processing at the Darques Gold Mine in Major's Creek.

Before Xmas I attended the meeting arranged by Unity Mining representatives to inform our community regarding the mooted changes.I listened on in amazement at the flagrant obfuscation and down-playing of the risks to our communities water supply and environment of the proposed cyanide leaching of gold deposits and installation of a heavy
metals tailings dam in the headwaters of the Eurobodalla water supply.

My reasons for concern are as follows:

In the first 6 months of operation, Unity Mining had five environmental breaches, three ofwhich resulted inthem being prosecuted and fined. Big Island Mining Pty Ltd was convicted after pleading guilty to three water pollution offences which occurred at the Dargues Gold Mine at Majors Creek in February and March 2013, and was fined almost $200,000.

The Land and Environment Court found that while the environmental harm caused by the incidents was low, practical measures were available to minimise that harm and there appeared to have been a substantial failure to implement these measures. The Court found that the harm was foreseeable and the mine shared culpability with e specialist contractor for the pollution. With such an abysmal track
record to date, before any processing is to commence, how can we allow such a company to interfere with our water supply and environment? The Eurobodalla has approx 40,000 residents, which swells to over 120,000 in the tourist season.

Rehabilitation works at another site, Woodvale Ponds, run by the same Mining Company-in one of it's other guises- is still awaiting commencement more than after 2 years after cessation of mining. Pond 6 at this site has an associated toxic groundwater plume which extends to within 200m of the local waterway Myers Creek. Three members of the environmental review committee have estimated that the company's bond has been underestimated in the order of $12-15 million. The heavy metals tailings dam is there for all time.

The Araluen valley has a thriving peach industry, cattle farming and environmental tourism. If the cyanide and tailings dam were to ever threaten these endeavours it would spell the closure of all these businesses & jobs.

I believe this Company is going to set up this mine with the sole purpose of on-selling and profit gouging with no concern for local issues of water supply, environment, or long-term and sustainable employment.

I strongly urge you to insist on an entirely new development application and environmental assessment.

Yours sincerely

Ms Stephanie Birk

4 Gundary St

Moruya 2537

Mob: 0403925209

Ph; 02 44742120

Cyanide processing or ore rich in heavy metals should not happen next to a village above a major farming and tourism area..

A cost-benefit analysis should be done to see what would be gained in exchange for running these risks. One insignificant cyanide processing plant threatens businesses that bring in far more money to NSW and Australia than would be returned to the public coffers by mining royalties or job creation.

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

This is a decision that is not made in the communities best interest. It needs to be re-evaluated.

On behalf of my family I wish to object to this submission on the grounds of risk to the agriculture industry including the reputation of local produce and the risk to health both human and environment. I believe the risk to safety and wellbeing of our community far outweighs the profits of one organisation. Technical data and government reports support these risks are very real and have to potential to devastate our community. https://savemoruyariver.wordpress.com/reports-and-technical-data/

Unity Mining has a good track record in operating underground gold mines in Australia. Unity has demonstrated that they can operate the Dargues Goldmine with little or no impact on the surrounding environment as they have done with their mines within the Bendigo city limits and in the Tasmanian wilderness at Henty.

In addition, the Dargues Goldmine will bring employment and income to the Braidwood area.

Given the pollution incidents already associated with this mine the operators have demonstrated an ineffective commitment to the original environmental controls applied for the mine.

It would be comprehensively irresponsible to allow the use of cyanide on site as part of the mine operations.

The 'approval creep' process that seems to be in play has the potential to discredit the NSW planning approval process and the reputation of the approval authorities involved.

The mine operators may not be confidently trusted to protect the beautiful Deua River.

My family own over 1,000 acres of land on the Deua River across Palerang & Eurobodalla Shires. This land has been in the family for over 50 years. It is used for holidaying and recreational purposes. As such the land (and the river) is pristine. I have been watching the Dargues Reef Goldmine Development application with concern for some time now and I am very alarmed with the proposed use of cyanide in the processing plant and the location of the tailing storage facility on steep land above some of the river's key tributaries. I majored in Geomorphology at University and I clearly understand that extreme weather events can have unexpected impacts upon natural and man made structures in any landscape. As such, it is critical that structures built to contain pollutants such as heavy metals and cyanide must be located extremely carefully. I believe that Unity Mining are taking environmental risks to improve the economic viability of the mine. I do not believe the processing plant and tailings storage facility can operate safely given the selected location. Given the importance of the river, not only to me and my family but to the broader community, this application should be rejected.

Submission on EA FOR THE DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054 July 2015
As a resident of Eurobodalla 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, as history gas shown accidents do and will happen. I am concerned that in 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 that the proposed modification creates a pollution risk that is unacceptable to residents along the entire Moruya River catchment. The potential cost to our community is too great and Unity is ignoring the threat to our well-being.
* The site is unsuitable for the construction and operation of a gold processing plant using cyanide as a leaching agent and a tailings storage facility for waste with a high heavy metal content that will remain for ever.
* The EA maps show it is on a hill above a village, on the edge of steep escarpment and at the headwaters of an important river system. Spring Creek, Majors Creek, Araluen Creek, and Deua/Moruya River are all used for domestic water supplies and agricultural purposes
* 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.
* 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.
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 us, the residents of the Moruya River catchment as second class citizens and less worthy of protection.
I also feel that the points below need consideration:
* 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?

The proposal has overlooked many factors and risks that are real for all of the residents and the environment downstream from the site. I strongly feel that this proposal is not considered enough to be passed and is lacking in many details and considerations. It is virtually impossible for any company to ensure the safety of the operation and the future containment of any pollution from the site. I urge you to not approve this ill considered and risky proposal.

Submission on EA FOR THE DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054 July 2015
I am writing to express my objection to the modification to the Dargues Reef Mine Development Application.

I am a resident and small scale organic farmer living and working on The Deua River within Eurobodalla Shire.
I am concerned about the impact that any accidental damage caused by a failure of the mine could cause if this proposal came in to operation, short term and in the long term future.
As a resident I have concerns about the water quality in this natural and pristine environ of the Deua River, the National park and the waterways downstream.
Many of us also rely on the clean water of the Deua River for wellbeing and livelihood.

I have specific concerns about the tailings dam and the fact that a failure of the proposed system would see real damage to such a clean waterway, not to mention the damage to drinking water supply to Moruya and beyond. Other such dams have failed despite companies claiming to have designed a fail safe solution. I am concerned that there is an assumption that the design will not fail, or that operators of the site may not fail in some way.
If something were to go wrong with the designed system the cost of recovery would be massive, not to mention the loss of water supply, income and loss nature and quality of life for all of us downstream from the site.
The pollution risk is unacceptable to all who live on the catchment and this proposal does not consider the massive losses that the project would expose all of those in the catchment to.
The site and it's surrounds are not suitable to this high risk construction project;
Unity have shown that they are not happy to just mine the site for gold, and future expansion and increased use of the site and it's facilities would only increase these risks.

The irreversible damage that could occur from this mine is not acceptable to this community and the risk is just too high. The ongoing legacy would be horrific for the future of the region and it's people for some shorter term gain to Unity.

This submission is to object socially and environmentally to the processing plant using cyanide at the Dargues Reef gold mine. All the promises made that the cyanide at the mine is no risk is absolute baloney. There is no concrete evidence that the cyanide used to process the gold will be contained. The high risk of the tailings dam failing is definite. The lethal risk to the creek and waterways into the Araluen Valley and onto Moruya is inevitable. Every tailings dam has eventually failed destroying farmland and contaminating everything in its path. \

Excessive rainfall and bushfire are both recipes for disaster. Once the cyanide is released in any way there is no going back to rectify the devastation to humans and wildlife.

Putting the processing plant at Dargues is dicing with death for all from Majors Creek to Moruya.

Creating people's wealth is being put above peoples lives.

It would be a disgrace to go ahead with this proposed disaster.

Spin doctors will spin for their own gain, tell people what they want to hear and are notorious for not being transparent to the people asking the important questions. No more spin. No guarantees can be made that the poisonous cyanide and cyanide gas will not eventually affect the people and wildlife of this area. If you have a conscious this will be put to a stop before it begins and feeble excuses have to be made after the irreparable damage is done.

I am against the Modification 3 of the Unity Gold Mine for several reasons.
For the health of the environment and for the community downstream of the gold mine, I do not want cyanide and other hazardous chemicals to be used at the mine. In a perfect world there would never be dams with cyanide and other chemicals overspilling into waterways, however, why should our community and around 100,000 people downstream suffer the consequences of an accident that could be avoided. No amount of money will repair the long term damage that such accidents create. When the gold mine was first proposed, the local community were told, in writing, that cyanide would not be used in the processing of the gold. Now, several years later that promise has been disregarded and our community has become divided.
My concern regards the proposed use of cyanide at the mine and the safety and number of trucks carrying cyanide and other hazardous chemicals through our heritage town, not to mention the route before Braidwood and onto Majors Creek.
The Modification 3 report states in the event of fauna deaths in the vicinity of the dam:
"Implement a procedure to monitor fauna, rescue (if needed), record and investigate any fauna deaths on or immediately surrounding the Project Site and determine the cause of death where the cause of death is not obvious"
However, at a meeting on the 4th August 2015, DRCCC asked Unity Mining a question regarding whether testing to determine the reasons for an animal found dead would be carried out, Unity Mining stated:
" It is likely that individual animal deaths would not be tested. If there was a mass fatality event this could trigger further investigations, such as blood testing for oxygen concentration".
This response from Unity Mining contradicts their statement in the Modification 3.
I also ask, what constitutes "a mass fatality event"? Even so, it's a `could' not a `would' response from Unity Mining and what guarantees are there that these daily tests will be performed and properly reported?

I am also concerned that the Dargues Reef Gold Mine could become a major gold processing plant with the associated increases of toxic chemical use and transport through the area.

Object to Dargues Reef Mine modification 3 to the flawed
Major Project 10_0054

I object to Modification 3 because using Cyanide and heavy metals are totally in appropriate for this area just above Majors Creek which runs into Eurobodalla's drinking water. The size of the tailings dam is a disaster waiting to happen - both in the building of it and for the future.
Majors Creek has a unique climate with the sea breeze blowing in from the east most evenings. So ANY vapours from CYANIDE or it's Heavy Metals in our village is unacceptable.