Mod 3 - Processing & Tailings Storage

I support this application because the Braidwood district, New South Wales and Australia in general require more mining operations to commence for the economic benefit of the community. Based on the track record of Unity Mining then this gold project will be well managed, economically sustainable and environmentally neutral.

I am extremely concerned about possible use of cyanide for gold processing in the Deua River catchment. The people of the Majors Creek end as well as the Eurobodalla end of this major river system do not want cyanide in their water.

The Dargues Reef Mine proponents were allowed the original proposal on the basis that there would be no cyanide usage. and it is completely inappropriate to allow this modification due to the high risk to the environmental quality of the river system.

This river provides unpolluted high quality human drinking water for Eurobodalla Shire, as well as for horticultural and agricultural uses in the rich fertile river valley. The river and its clean water are also extremely important for fishing, tourism and nature conservation.

These are the big draw cards and economic bases of this undeveloped south coast region and it is not acceptable to allow the introduction of cyanide processing into this healthy natural system.

The "National Pollution Inventory: emissions estimation technique manual for gold ore processing. December 2006", emphasised that more research was needed as cyanide release and effects had not yet been accurately modelled, and that the behaviour of cyanide within Tailings Storage Facilities (TSFs) was extremely complex and also had not been accurately modelled.

It also noted that when used in gold processing cyanide may:
- be carried through the system in a dissolved form
- seep from TSFs as a ground emission
- convert to various degradation products
- decompose to form ammonia and bicarbonate, and
- be released in gaseous form as hydrogen cyanide.

The Australian Government document "Leading Practice Sustainable Development Program For The Mining Industry Cyanide Management May 2008" details the difficulties of reducing risks when using cyanide to process gold.

It states that managing cyanide to minimise risks to human and environmental health represents one of the key challenges that continues to face the mining industry.

Wee are not willing to accept this risk in our water catchment.

I wish to support the application as it the mine's development is environmentally safe and is a sensible use of our nations natural resources. Our society relies on development. We are desperate for work but not at the expense of environmental damage. This development demonstrates exactly that. Scaremongering and personal , ill informed opinions should not get in the way of such a development. The firm I lead undertakes work for companies such as unity mining. We do so in the safest and most most professional manner. The same cannot be said for the detractors of the project. Please approve this mining operation.

I have worked on the West coast of Tasmania for ten years and am well aware of Unity Mining's exemplary environmental record at the Henty Mine site situated within the button grass plains and mountains of the west coast. I believe they will bring this knowledge and more with them to ensure that the Dargues Reef Gold Project is undertaken to the highest standards.

I am a mining industry professional (geotechnical engineer) with over 26 years of experience.
I have read the sumission, and in my opinion, the environmental assessment is of a high standard and is along the lines of what would be typically deemed to be acceptable. The Proponent has given appropriate consideration to impacts on surface water, groundwater, flora, fauna, and cultural sites, and the impacts are expected to be minimal.
The benefits of this project include employment opportunities for locals and broader industry professionals, economic benefits for the local community, shareholders and the nation as a whole, and on the balance of minimal impacts vs. substantial benefits, it should be allowed to proceed.

I support the Dargues Reef Gold Project

I've read the submission and support the project.
My main points in support are:
- Unity have a track record of responsible mining activity that I have witnessed in Victoria and Tasmania.
- The economic benefits of having the mine running will be felt Australia wide. I live in the Melbourne northern suburbs but rely on projects such as the Dargues project for employment in specialty engineering services.
- Unity look after their employees, and have done a credible job this year at the Henty Mine in Tasmania.
- Unity management have been around and are experienced. They know how to do things the right way, responsibly and complying with "worlds best practice" in terms of company management, mining techniques and safety, community relations and environment management.

19/08/2015 Mr Glen A Rothwell 489 Wallaces Gap Road Majors Creek 2262 N.S.W. to The Planner N.S.W Planning & Environment. RE-Application 10-0054 mod 3 Dargues reef gold mine, I am concerned about road safety on the Braidwood to Majors creek road, some upgrading and widening work has been done but many parts of the road are narrow and in poor condition and an increase in traffic of large trucks mining equipment employees & support services will increase the risk of accident, The road cannot support this type of traffic increase safely, I had the disturbing experience of nearly being run of the road by two mine associated vehicles in the past, I am extremely distressed at the thought of anyone, especially a local community member being killed or injured because of inadequate and poorly considered infrastructure.

i believe this is a quality project, that has substantial benefits for the community.

I have only recently been made aware of the Dargues Reefs Mine's proposal for onsite processing of gold using toxic chemicals.
It has filled me with concern and an overwhelming feeling of dread.
I fell in love with the Araluen Valley as a teenager and have spent the last 10 years of my life working and saving to be able to create myself a life in this magical place.
I have purchased my land and spent a great deal of money putting in my Orchard, Nut and Truffle trees. It has been my dream to create for myself and my growing family a somewhat self sustainable farm life and to hear that it could all now be at risk has me feeling extremely panicked.
It is clear to myself and many others that the risk that this proposed processing facility puts on the health environment and families are simply not worth it.
There is no compensation/fine that could ever cover what could be lost by way of contamination of the toxic chemicals and Cyanide that would be used in the processing facility.
We want to live happily in our home in the valley without all the sleepless nights that would result if this proposal was given the go a head.
Please do not approve this proposal.

When my husband and I moved to Majors Creek 10 years ago, we fell in love with the place; the abundant wildlife, the friendly locals, the clean fresh air, the amazing stars we'd watch from our veranda at night. They were all small things that added up to one big thing: we'd found a place we wanted to raise our family and call home forever.

All that has changed since the Dargues Reef gold mine and cyanide processing plant has been on the radar and it threatens the very things that make Majors Creek so special to us.

Neighbours now don't speak to each other, families are packing up and moving out, already there have been environmental breaches that have polluted our precious waterways and even if we wanted to move, we can't afford to as house prices in Majors Creek are not keeping pace with surrounding areas. For the past eight years we have put off renovating our home to "wait and see" what happens with the mine ... And we're still waiting, still in limbo.

It just seems incredibly unfair that a company's greed for a precious metal is over-riding our ability to live the life we want. Why does a company's bottom line mean more than my family's right to a peaceful existence?

My main concerns about the Dargues Reef mine are:

* The use of cyanide and other heavy metals is not without risk. They can make their way into the air, water and soil, risking the health of my family. It might not be common, but it happens.

* The noise. Drilling, crushing ore and big machinery will pollute the silence and drown out the birdsong we love so much.

* Water: The mine needs a HUGE amount of water to operate and will be using OUR underground water table for its processes.

* Dust. We have such amazing clean air - why should we let a company come in and foul it up?

* The blight on the landscape: Where once there was farmland, there will be a major plant with buildings, a 16-hectare tailings dam and heavy machinery.

* The community rift: There are two definite camps of those who support and those who oppose the mine. To us, this is one of the most upsetting aspects of this whole proposal.

* The increased traffic: More heavy machinery and trucks on our country roads equals more danger.

* Light pollution: I don't want to see any lights other than stars at night.

* The possibility of the mine processing ore from other mines. On Wednesday August 19, during a visit to the site, Andrew McIlwain said he would "Never say never about anything" when I asked him if this was a possibility.

Not all of us who oppose the mine are gung-ho greenies or even vocal about our beliefs but Unity's insistence on constantly changing the goal posts to suit its own financial agenda is disgusting - and insulting - to a community who has had this hanging over its head for nine years now.

And when all the gold is gone and the miners pack up, we will be left behind with the toxic legacy of a company that retreats to count its profits.

"Unfair" just doesn't describe how that feels.


Yours sincerely,


Ben, Narelle, Tate (aged 7), Frances (aged 6) and Harvey (aged 3) Doherty



PS: I understand not all my points relate specifically to Modification 3 but I think they are all linked in one way or another.

I wish it be known that I would like to support a well run, professional mining operation.

A well run mine provides jobs directly and cash flow to the community and businesses. The value adding of mining is very evident given the recent drop of the $AUD due to reduced mining in Australia.

Mining is more responsible and less destructive to the environment than farming.

The fact that any Government or council would consider allowing any mining to use cyanide in processing with even a remote chance of it getting into our water is just unbelievable.

Objection to the change of approval for the Dargues Reef mine at Majors creek.

I am contacting you to voice my concern over Unity Mining's application to allow on site cyanide processing at the Dargues Reef Mine near Majors Creek. As I am sure you are aware the Dargues Reef mine is in the headwaters of our water supply via the Deua River. The mine had approval to go-ahead provided there was no cyanide processing within the water supply catchment. As everyone agreed having cyanide processing and a tailings dump with all the toxic pollutants remaining for all time within a water catchment would be unacceptable to all informed water users.

There are many problems with this proposal for insistence

· The processing plant is not roofed relying on pumps during a rain event to ensure the bunding is not overtopped. Pumps can never be relied upon as a line of last resort.
· The rain intensities used for the flood calculations have been exceeded in the past. During the late 1970s we had a rainfall event where we received over 600mm of rain in a 24 hour period. This rainfall would exceeded the design.
· A similar tailings dam has failed in Mount Polley Canada. Coincidently I have been told this failed tailings dam was designed by engineers with involvement in the Dargues project. The risk of a similar disaster happening here however small is surly too great a risk for all water users to take with their water supply.

The planning and certification authorities did a great job during the original approval process to ensure there was no on-site processing and a proposal acceptable to all parties was agreed upon.

The mining company's agreement to this acceptable proposal is now in question. The new proposal is not best practice. It is the cheapest most profitable option to only one party, Unity Mining. All other parties will end up holding all the risk for no gain. Unity Mining has not shown itself to be a capable operator, they have already had numerous pollution failures. They should at least prove they could operate the mine safely without pollution before considering on-site cyanide processing.

I urge the Department of Planning and Environment given the importance of this water source to oppose wherever possible this new proposal.

Thank you for your consideration of this issue.

Regards

Len Ryan

I support this mine proceeding as it is a small mine but will greatly benefit the nearby communities.
The project is proposing standard mining and processing practices and by using paste fill is minimising the surface disturbance.
Unity Mining have shown they can successfully operate mines without harming the environment.

Submission on
EA FOR THE DARGUES REEF GOLD MINE MODIFICATION
3 MP_10 0054 July 2015
As a resident of Eurobodalla, I wish to strongly object to this third modification to the Dargues Reef Gold Mine Development Application.
My primary concern is the assumption that there will never be failures in the design or running of the proposed processing plant. Accidents can happen, and the implications of some may well be catastrophic. There seems to be insufficient data available to fully assess the magnitude of the risk at this time. Nevertheless, the potential risk seems so great as to make this modification untenable.
I am dismayed that there has been no thorough assessment of the risks posed to the drinking water supply for 40 000 residents of Eurobodalla Shire who rely on water drawn from the Deua River system. Any pollution in these waterways would also endanger the orchards and market gardens of the Araluen Valley. 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.
If this plant is approved, dangerous heavy metals and cyanide residues left after the gold is extracted, would be stored "forever" as waste in a 16 hectare (40 acres) tailings storage facility(TSF). 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 . However,these possibilities have not been included in the risk assessment done by the company.
These risks are real. In Australia, the Ranger's uranium mine tailings dam has spilled into the Magellan Creek wetlands more than once, and there are many overseas examples of what can go wrong. Much more information on seepage from the TSF through the liner is needed before Unity can dismiss either long term impacts from cyanide use or possible impacts at some distance downstream of the mine.
The addition of a processing plant would fundamentally change the economics of mining in this area. Other gold prospecting licenses are active across the region, and it would only need one more modification application to extend the Dargues processing plant to accommodate any such new mines. All the more reason to require a thorough examination of the risks associated with seepage from the TSF.
Unity has 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.
Unity's operational record does not inspire confidence. There have been significant accidents on the Dargues Reef steep site, even before the mine commences operation .
Taken altogether, I have concluded that this modification does not stack up, in terms of pros and cons. Any benefits that might accrue would come at an unacceptable risk to residents of Eurobodalla who rely on the Deua for their drinking water. Accordingly I urge that the Modification be rejected.
Yours faithfully


James Beattie Monahan
2 Evans Road
TUROSS HEAD
NSW 2537

E-Mail [email protected]

Letter of Opposition to On-Site Processing by Darques Gold Mine at Major's Creek.
Project Application No. 10 0054 MOD3

14.8.15

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 of which resulted in them 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

Having travelled through W.A. recently we realized many of the benefits of mining in an area. This includes jobs in mining, and the local shops, motels food stores , hardware & engineering etc. If we continue to say no to a business wanting to "start up" in an area it is then detrimental to providing jobs for our young people.

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

I am a resident of the Eurobodalla Shire and live in Moruya. We also have a small farm on the Deua River at 2663 Araluen Road where we grow organic vegetables for sale. I strongly object to this THIRD modification to the Dargues Reef Gold Mine Development Application, and find this incremental approach to seeking approval disturbing and dishonest

I am very concerned with the assumption that any design and construction of mining infastructure is foolproof and that there will never be failures. Witness the collapse of the Captains Flat tailings into the Molonglo River in the 50's which effectively poisoned the Molonglo downstream, from which it has never recovered. Unity Mining has already had three failures of its systems under current guidelines, and they should not be trusted to avoid accidents in the future.

The risks to Downstream users of polluted water supplies cannot be underestimated. The Mine has a limited shelf life, yet the risk to users exists for generations at least. We are still dealing with the increased sediment load in the Deua River from the disturbances of the Araluen and Jembaicumbene Goldfields in the 1860s. We do not want to have to contend with additional problems of contaminated water entering the river system from overflows of the tailings dam.

We have lived on the river for 40 years, and during that time flows have varied enormously, depending on rainfall history. We are capable of receiving massive, intense falls of rain which will put any impoundment under pressure. 475 mm of rain(19 inches) has been recorded on the top of the Clyde Mountain in 24 hours, and the Majors Creek area is not that far away. The risk to the waterway is just too great to assume that these falls will not be repeated or even exceeded in the future. Unity Mining is obviously more interested in their bottom line than the long term welfare of the users of the river.




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. Unity Mining is obviously concerned that they may be left with a stranded asset in these days of low and falling gold prices, and so it is in their interest to cost save, to both improve their share price and the potential to on sell their project. Any agreement reached with Unity Mining may be disputed by any future owner, and the incremental approval process would be ongoing. The risk of this happening is just too great.


* 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. There is nothing to say that Unity Mining will see out the long term storage of these tailings, and we are likely to find in the future that the current proposers move on or become bankrupt or just cease as a mining entity. What happens then? Does the government take over the long term storage responsibility? Who is responsible for compensation in the event of a collapse?

* 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
My primary concern with this proposal is the long term storage and management of the tailings facility, and the long term risk to our water supply and environment of this proposal.

* I agree with the EPA that a full risk assessment needs to be done which addresses all environmental risks associated with the TSF. This should include consideration of moving the TSF to a more appropriate part of the site which happens to lie in the Shoalhaven River catchment. Although this only shifts the problem

* Clearly Unity is insisting on this site for commercial convenience. I am appalled at the excuse that "Construction of TSF in Greater Shoalhaven River
Catchment was not considered in the original DA because this catchment forms a component of Sydney drinking water catchment and any proposal there would have imposed additional regulatory requirements." This treats the residents of the Moruya River catchment as second class citizens and less worthy of protection.

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 as any risk of a breach could be catastrophic.

* 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.

ECONOMIC CONSIDERATIONS
* As residents in the catchment, our livelihoods are dependent upon the health of our 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 I note that much of the orcharding in the Araluen Valley is currently being discontinued due to fears of long term damage from this mine..
* 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?

Closing statement
* It makes no sense to me to risk irreversible damage to unique and precious environments, communities and economies of the Moruya River Catchment for the sake of a little more gold. All the gold that has ever been mined is still in existence, we hardly have a need for more.

*Unity claims that this modification can be constructed and operated in a manner that would satisfy reasonable community expectations.

* This 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. THE RISK IS TOO GREAT.


Greg Summerhayes
Resident of Moruya and the Deua River

I have just read the draft GHD report to ESC and concur with its findings. Given the change to onsite processing with cyanide in a CIL plant, remnant cyanide will be discharged in the tailings and this will assist in the persistent release of toxic metals in the tailing into the groundwater and surface drainage systems as the TSF gradually deteriorates and perhaps fails. This is an unacceptable risk in the headwaters of the drinking water catchment of the ES.
I was an Assoc. Prof. in Environmental Scientist at UPNG and worked on the EISs of numerous goldmines in PNG in the 1980s. Subsequently I was Manager, Environmental Studies in a large consulting firm in Australian competing with GHD