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SSD Modifications

Determination

Mod 3 - Processing & Tailings Storage

Queanbeyan-Palerang Regional

Current Status: Determination

Interact with the stages for their names

  1. SEARs
  2. Prepare Mod Report
  3. Exhibition
  4. Collate Submissions
  5. Assessment
  6. Recommendation
  7. Determination

Attachments & Resources

Application (3)

EA (24)

Submissions (10)

Response to Submissions (10)

Recommendation (4)

Determination (3)

Submissions

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Showing 121 - 140 of 449 submissions
Name Withheld
Object
Braidwood , New South Wales
Message
Re 3A Modifications Dargues Reef Gold Mine
Project no.10 0054 MOD3 Majors Creek

I am making this submission to voice my objection to the above Modification on Unity Mining's Dargues Reef gold mine.
When the initial development application for opening a gold mine at Major's Creek was made by Cortona Resources it was approved after extensive community consultation. It was approved as a relatively low toxicity mine with adequate risk management and no processing on site.

The new owners of this mine, Unity Mining, have destroyed all trust by the local community in applying for this Modification to include on site processing using cyanide.

The commissioned report by Dr Peter Beck of GHD Pty Ltd has confirmed my fears as to the significant environmental risks associated with this proposal for on site processing. Unity Mining has failed to provide adequate risk assessments for almost every part of the process from the transport of cyanide to the site, storage and handling on site and long term storage of toxic tailings. These inadequacies are evidence of the incompetence of this company in managing a highly consequential and risky mining development.

The tailings dam located at the top of a large catchment, must last forever, not just the operational life of the mine which appears to be the only concern for Unity Mining. The toxic heavy metals and cyanide stored in the tailings dam pose a real and significant danger for local residents and many thousands of people living and working downstream. I cannot see the benefit of a hundred or so jobs over only 7 years of the proposed life of the mine to the risk of destroying the downstream catchment aquatic and terrestrial eco-system, human health and the jobs in agriculture, fisheries and tourism that have existed in this catchment for generation past, present and into the future. The $3 million bond provided by Unity is totally inadequate and it will fall to tax payers and future generations to take responsibility and have to live with any toxic leakage. Unity Mining will be long gone by then.

There are other examples around the world of huge environmental catastrophes involving failure of gold mining tailings dams. The recent disastrous Colorado River pollution in the USA and the enormous explosion of a storage facility involving cyanide in China are just two recent incidents.

The escalation of this development incrementally over a number of years looks like a deceptive and underhand strategy to increase the scale of this project slowly. If this Modification is approved I fear and suspect that the processing plant at Majors Creek will not only operate for the life of this mine but will become the only processing plant in eastern NSW and will continue to operate well into the future taking gold ore from many prospective gold mines in NSW. So, once again the local community will be deceived as to the scale of this project and have to live with the risks for many years to come. It is not just my generation but our children's and their children's into the future that will be affected. I understand that it is not a case of if the tailings dam will fail but when it will fail. Plastic liners cannot last forever! Short term profit at such a cost to the environment and to the people who live here.

I urge the Department not to approve this Modification as Unity Mining has failed to achieve any degree of Social Licence to operate in this community.
Name Withheld
Object
Braidwood , New South Wales
Message
Re 3A Modifications Dargues Reef Gold Mine
Project no.10 0054 MOD3 Majors Creek

I would urge the Department of Planning and Environment to reject this modification on the basis that it is environmentally unsound.
I would refer you to the commissioned report by Dr Peter Beck of GHD Pty Ltd where it states that the use of Carbon in Leach process using Cyanide as the primary leach agent to extract gold from the ore "significantly increases the risk profile with respect to short, medium and long term risk to human health and the environment".
I would also conclude from the environmental assessment report provided by Unity Mining that there is not sufficient information to assess the adequacy of proposed processing and environmental controls given that detailed management, monitoring, response and mitigation plans would only be provided after approval for modification 3 was granted.
The marginal increase in profit that modification 3 provides does not in my view warrant the increased risk downstream communities would bear long term.

Yours sincerely,
Murray McCracken230

Antony Davies
Object
Jembaicumbene , New South Wales
Message
I have lived in the Braidwood area for over 15 years and was attracted by the pristine rivers and landscape, and the vibrant community of modestly scaled but highly productive farms producing fine and internationally recognised produce. Our own historic 200 acre farm is adjacent to the Dargues Mine and we have spent nearly a decade and all of our savings and significant loans creating a world class heritage destination which has fine early 19th century buildings, organic produce, fine alpaca wool and a very large arboretum and truffle forest currently in establishment. We are also caring for and rehabilitating the extensive middle Jembaicumbene wetland, part of our property, and itself only just recovering from the major 1860s alluvial gold extraction which completely destroyed it leaving nothing but 100 acres of gravel pits and mullock heaps for over a century. The wetland is now home to platypus, black swans and a tremendous variety of birds and wildlife. Our property will shortly become a major tourist attraction, and already attracts visitors from all over the world. All of this relies on clean water - our animals and ourselves drink the fresh springwater from our wells, and the pristine brooks which traverse our property water our trees and the wildlife. A single chemical accident at Dargues Reef Mine puts all of this, including our own lives and those of all our alpacas, horses, goats, sheep, llamas, and all the wombats, kangaroos, possums, birds and everything else that grazes in the fields and drinks from the ponds and brooks, at risk of a quick and horrible death, and potentially destroys our farm and everything on it for decades and possibly centuries to come. The owners of that mine sat in our own house eight years ago and told us categorically that there would NEVER be cyanide or any processing on site at all. They also greatly underestimated for our benefit the appalling disruption of 4,000 heavy truck movements a year on our small country road, the effects of blasting on our significant historic buildings, and the dreadful noise pollution of 24 hour mine operations. They are liars, deceitful to the core and have misled us and our community in a most disgusting way. We are fed up and want nothing to do with them, but in particular we do NOT want cyanide and heavy processing on site at the fragile mine site, so precariously close to the pristine valleys and both groundwater and run-off water which we rely upon entirely. PLEASE do not allow this modification, and take steps to ensure that this mine is operated safely and within the agreements that we and our community reluctantly agreed to when the original permit was granted.
Name Withheld
Object
Congo , New South Wales
Message
I (and my family) am greatly concerned about significant risks associated with the use and storage of cyanide to process gold at this mine site. The water supply for the major part of Eurobodalla will be put at risk if this application goes ahead, and the potential for cyanide and other toxic compounds to be released into the water supply in the event of a storage failure is very frightening. From what I have researched, the tailings storage proposed are inadequate. A water supply catchment area is NOT a suitable site for such ventures. Who will take responsibility for an accident, will Eurobodalla Council or the NSW state government? Protect our water supply and the local environment.
virginia wallaace-crabbe
Object
Braidwood , New South Wales
Message
I am writing this submission to argue against the use of cyanide at the Dargues Reef Mine at Majors Creek.
The previous proposal was to use mostly benign substances which had very little risk to environmental health.
The proposed modification to use cyanide would greatly increase short and long term risks due to the retention of toxic substances in the TSF. While cyanide has a relatively short term life , other toxic substances including arsenic, cadmium, chromium, aluminium, lead, mercury and selenium can remain for decades, even centuries causing untold damage..
Also, accidental releases of cyanide at gold mines have occurred at all stages of its uses at a number of sites all round the world in recent years, leading to mass environmental destruction. Clearly then, the downstream communities
in Araluen and the Moruya catchment area would be at great risk from such an event.
Additionally, the Majors Creek area has a history of sudden, high rainfall events which can break previous records and the positioning of the TSF makes it vulnerable to flood rain....in fact, one engineer has said that the TSF was in the worst possible place it could be if such a rainfall event were to occur.
Please do not allow this proposal to use cyanide to go ahead,
Yours sincerely,
Virginia Wallace-Crabbe
Michael Davidson
Object
jembaicumbene via braidwood , New South Wales
Message
I strongly disagree with modification 3 as i have lost confidence with the mine operators. They cannot be trusted, as no guarantee has been given that a major or minor spill won't occur at some time during or after the mine has closed. the fact is a 100 percent guarantee failure will occur from the tailings dam
Name Withheld
Support
West Pymble , New South Wales
Message
I support the Dargues mine as I believe it will provide much needed jobs and opportunities for local business in the Braidwood Area.
Peg Job
Object
Braidwood , New South Wales
Message
I strongly object to the Part 3AMOD proposed by Unity Mining for their Dargues Reef gold mine at Majors Creek.

The potential dangers of toxic cyanide, used in processing gold, leaking into water, land and air downstream of the mine is serious. Unity has proven itself unreliable in caring for environmental concerns, and already paid a price for this carelessness.

Moreover, as a company which in its Annual Report of 2014 appeared to be extremely short of money, it is likely to cut expenditure as close to the bone as possible, and we cannot have confidence that safeguards will be adequate. The Company has mines in Africa in some of the poorest countries in the world, which are also the least likely to have rigorous legal safeguards for foreign companies operating in their purview. It may be advisable for the Dept to investigate the practices of the Company in its African mines before accepting its claims to due care at Majors Creek.

My particular concern is that one of the first properties downstream from the proposed mining operations is that of Jackie French. Jackie is one of our most esteemed Australian writers, a pioneer of organic farming in this country, and a champion of wombats and the threatened or endangered native species in her area (they are - so far - protected on her own property). Her land, where she has lived for many decades is the inspiration for many of her books, for children and adults, and she 'belongs' to the land itself in a similar way to that of our Aboriginal ancestors.

Her contributions to Australia have been honoured by both our government as Senior Australian of the Year 2015 and by her peers in the cultural life of Australia as Children's Laureate 2015-2016. It is incomprehensible to me that not only her water and land, but her very life and that of her family should be under such a threat as Unity Mining's gold operation at Majors Ck could pose.

I read a few months ago that CSIRO had found another non-toxic alternative to cyanide for processing gold. If this is indeed the case, why is it still being proposed for use at all?
John Spring
Object
NSW , New South Wales
Message
In reference to "visual amenity", 4.11 page 140 of the Environmental Assessment Modification 3, 2.10.4 on page 85 states that two alternative locations for the proposed waste rock emplacement were rejected as they "are in direct line of sight of the village of Majors Creek" and they "would result in adverse visual amenity".
Our home is residence R108, figure 20, page 141. It is one of the closest houses to the proposed mine site. The proposed eastern rock emplacement and larger tailings dam will be clearly visible from our house. However, no sight lines from our house have been included in figure 20, nor any mention made of adverse visual impacts on us by the proposal.
The statement in 4.11.3 that "the additional impacts would be negligible, if indeed they can be viewed at all" is totally incorrect.
Verbal agreement by Unity Mining to supply trees to us to screen the site indicates tacit agreement that the proposed modifications will have an adverse effect on us.
The proposed larger tailings storage facility and the use of cyanide for final processing are much more significant issues than just the visual amenity I refer to.
I think that the entire contents of modification 3 should be thrown out and Unity Mining should comply with the original commitments agreed to ie. NO CYANIDE.
Roger Gribble
Object
Broulee , New South Wales
Message
Dear Sirs, I am writing to express my strong rejection,to any proposal that sees further development or any continuation of mining at Majors Creek.
The basis for my objection is the obvious potential for damage to the pristine waters of the Deua, and all of the associated environment and social elements that are part of the due valley.
throughout my business career of 40 years, may of which have been linked to the mining industry, I have witnessed time and time again, the adverse impact of tailings dams and associated to mining operations. so of these operations, some of the biggest in the world, who at the time of mine opening, guaranteed that no enviromenatal damage would ever emit from their operations. without fail every single mine has betrayed the local community. examples in the Hunter Valley are well documented, the people of Bougainville and Ok Tedi will never regain their river. Large operations and large rivers are equal in their damage to small operations in small rivers.
There is no space for development at Majors Creek. I reiterate my objection to this frightening development.
Thank you for listening. Rgds Roger Gribble 0402230977
Catherine Bell
Object
Bombay , New South Wales
Message
In November 2014 I attended a public meeting hosted by UNITY.
I was not reassured by the various experts. I found them to be very dismissive and even rude to those asking questions or pointing out concerns.

Repeatedly, and by their own admission, the mine representatives have not been truthful. The original (and approved) proposal was supported generally based on the "NEVER" assurance that a cyanide processing plant would be part of operations.

And here we are, with 'modification three', which comes in the wake of several breeches and brings with it the taste if distrust.

This modification is really a new application, and I would urge you to see it as such. It is contrary to the original agreement and the community concerns are great.

At the August 2015 extraordinary council meeting in Braidwood, about 30 people stood to voice there concerns and opposition. These voices were echoed by the support in the theatre from other locals. The community does not want this modification.

Concerns include:
- continued untrustworthiness from the mine representatives. What modification will come next? open cut mining? bringing in ore from other sites for processing?
- changes to the community once the mine is operational. Including increased violence, injuries, the strain on our local hospital and health services
- the tailings dam life. Once mining operations cease, what protects us from this dam. What protects our children, our grandchildren?
- the what if there is a breech of the dam. It has happened in other locations. It is not outside reality. Who would buy the land downstream? property values will decrease, and those living there will do so in constant unease. This concern is very real, and not irrational.
- the economic value of the area as a food bowl, recreational area and tourism opportunities could be impacted. In fact several residence said they were already being impacted.

This modification is far too great a change to be considered a 'modification'. The community says NO.
Virginia & M Barry Hooker
Object
Durran Durra, Braidwood , New South Wales
Message

It is disappointing indeed that the Planning Dept, the Eurobodalla and Palerang Councils and concerned residents of the Braidwood, Major's Creek, Deua catchment, Araluen Valley and the nearby south-eastern coastal regions of NSW have to consider Unity's application to modify their existing planning permission.

The original plan for this mine submitted some years ago by Cortona (now Unity) went through a long process of public scrutiny, changes, and public consultations, with the result that a number of safeguards were added to the original proposal before approval was granted.
During all stages of that process, Cortona/Unity reiterated that on-site processing using cyanide was NEVER under consideration.

The Modification now submitted by Unity, requesting permission to use cyanide for on-site processing, has resulted in the complete loss of community trust in the Company.

At an Extraordinary Council Meeting of the Palerang Council on 20 August 2015, which we attended, NONE of the 31 members of the Shire who presented oral submissions to the Council members, supported the Modification proposed by Unity.

In making this submission, we will draw on the points made by those 31 speakers and list them briefly below for two reasons: 1. To prove the strength of community feeling AGAINST the modification and 2. To show how carefully members of the community, old and young, have considered the situation and drawn their own conclusions that Unity's modification must be rejected.

* The concentrated waste from cyanide processing to be held in a tailings dam will degrade into toxic heavy metals that will not degrade. Unity has already had three spillage events from the existing dam, resulting in toxic sludge flowing into the Deua catchment. Unity was fined for those breaches, but, even with a far larger tailings dam (as is proposed in the Modification), it is impossible to guarantee there will not be spillages. On the contrary, the independent report prepared for Eurabodalla and Palerang Councils by Dr Beck emphasises that spillage is highly possible.
* The lining of the tailings dam has a durability of 25-350 years. Even at the higher end of 350 years, toxic heavy metals will still be toxic. They need to be held for longer than 350 years.
* Unity estimates the water table will drop as a result of processing procedures and will take 50 years to return to its current level. This is unacceptable when existing below-ground water is already under threat because of global warming.
* Unity has a record of misleading at best and lying at worst about its practices. Toxic waste chemicals resulting from drilling through rock, in work already completed at the mine-site, have been illegally dumped at the Braidwood tip.
* Unity claims it has a bond of A$3 million deposited in the Braidwood Branch of the Bendigo Bank to cover rehabilitation or damage. A check with the NSW Dept of Planning found that a bond of less than A$800,000 is currently listed against Unity's Dargue's reef mine. Several speakers were very concerned that the bond was far from sufficient to restore environmental and other damage.
* Many speakers were concerned about Unity's safety record, starting with the local spillages at Dargues Reef and including the Bendigo Flat Mine where there has been flooding of mine shafts.
* A Major's Creek resident who had served as liaison officer between Cortona/Unity and local residents between 2004 and 2012, reported that the local community had objected to the use of xanthates in the original proposal but had to accept it when the mine was approved. They are now extremely worried about the effects of cyanide and heavy metal residues.
* Other residents were very concerned about the risks of accidents when trucks carrying cyanide to the site went through Braidwood (either through the main street, or past the Braidwood Central School) as it is the only route to the mine.
* Many landholders in the vicinity of the mine reported that the value of their properties had already dropped. One landholder said the mine ran along two of his boundaries and no-one would want to buy his land once this was known.
* Many speakers said their `clean, green' image as farmers and horticulturalists was threatened by the proximity to cyanide processing. They said this was a very real threat to the viability of their small businesses that they had worked hard to establish and publicise. Quality garlic and truffles are just two of the products for which Braidwood has recently established a national reputation (both being featured, for example, at a gourmet dinner in July at Government House, Yarraluma).
* A speaker who had lived in Stawell, Victoria, noted the adverse effects that came with the money made by those associated with a mine there. Alcohol and drug dependence increased markedly without the necessary infrastructure (police, medical services) to handle the problem.
* Long-term residents said that extremely heavy rain-events, for example 10.5 inches in 10 hours, were not unusual and that it was such events which had caused the 3 spillages which had already occurred at the mine site. There was grave concern that the modification would not contain the water resulting from severe weather events.
* About one quarter of the speakers emphasised that the effects of the modification, if approved, went beyond economic impacts. Both older and younger speakers were emotional when they described how they had deliberately moved to Major's Creek and the Braidwood area, to live in retirement or raise families. They said that the economic benefits of the mine were short term and that every mine has an impact on the surrounding environment as well as on the community.
* One speaker said that the anxiety about the proposed use of cyanide was causing health problems for those closest to the mine and for those living near the rivers which had already been affected by spillages. There was very real concern about the much worse threat posed by spillages of heavy metals.
* One speaker stated firmly that Unity does not have the social licence to proceed with the modification.
* One of the last speakers is expecting a baby in the near future and pondered on the fate of that child's children in 50 years and more in the future. That was the timeframe in which longer-term effects of the use of cyanide and the effects of heavy metals would be evident. It was highly unlikely that they could be remediated by Unity or its successors leaving the community in this region to handle the effects as best they could.
Thank you for your consideration of the points made in this submission.

We request that based on the scientific evidence from Dr Beck's and other objective reports, as well as the strong community reaction AGAINST Unity's Modification, Unity's application for a Modification NOT be approved.

M Barry Hooker and Virginia Hooker
10038 Nerriga Rd
Durran Durra, Braidwood, NSW 2622
Phone 02 48422311 Email: [email protected]

Maryanne Large
Object
West Pymble , New South Wales
Message
I am a physicist with a strong interest in ecology. I am also the Chair of the wildlife rescue group, Sydney Wildlife. I visited the proposed area early this year, in the context of my wildlife work. It is an area of outstanding ecological significance, with an active farming community.

I was shocked to discover the proposal for cyanide processing and a tailings dam in the area. It is extraordinary to me that there is consideration of this on such a steep site in the headwaters of a water catchment for over 100,000 people, not to mention critically endangered species and forest types.

I am aware that the mine operator has a poor record in management and has previously repeatedly denied their responsibility for three major pollution events until prosecuted in the Land and Environment Court. This does not give me confidence that they will handle the risks appropriately.


The EA describes the land below their site as `degraded farmland.' This is incorrect. It consists of two Conservation Areas, containing one of NSW most important migratory bird corridors, more than 23 rare, endangered, critically endangered and vulnerable animal and plant species, including the only local habitat of the brush tailed rock wallaby. The creek in those Conservation areas was described as `pristine' and of the highest conservation value by the NSW Department of Environment in 2013.

In 2013 Unity refused to contact downstream users to quarantine their water supply when the EPA asked them to do, forcing the EPA to advertise and contact users directly.

The company has continued to refused other EPA requests. This company cannot be trusted with the dangers of cyanide and heavy metal on such a vulnerable site.

There has been no cost benefit analysis to see how many people are at risk immediately downstream, nor what the economic damage may be from a series of small nor a major spill. The bond will only cover repairing damage on the site.. Millions of dollars of property and business income is at risk below the site, but there has been no survey of this by the company nor the department.


There has been no risk assessment of leakage of heavy metals from the tailings dam on the grounds that there will be no leakage. This presumes there will be no mistakes in construction, nor tearing of the lining. Given the company's record the risk of leakage is too great.

The company proposed to pump any leakage back into the tailings dam. But if the company goes broke, or if, as in 2013, there are no trained personnel on site when leakage happens, the heavy metals or cyanide spillage will go directly into Spring Creek, then Majors Creek and the Deua Moruya a Rivers . The consequences could be deadly.


Continued refusal to comply with inconvenient or expensive of the Conditions of Approval by the NSWL and and Environment Court, PAC and Federal authorities.

The company states it will comply with all Clean Air provisions but it does not state how it will do so.

The neglect to estimate the cumulative effect of a build up of cyanide affected heavy metal pollutants in adjacent soil, water, and deep pools of many small breaches in emissions standards, as occurs at Unity's Henty Plant. There, however, the exceedingly high rainfall dilutes it. This is not the case at the Dargues site.

The EPA has stated that the tailings dam should be moved to a safer location. The company has refused. If this project is commercially viable they should be able to afford a safer site.


Many small spills of heavy metal from the ore may pollute the Deua and Moruya river systems for generations.

In short, the proposal describes a risky project in an ecologically sensitive area, potentially affecting 10,000 people, and run by a company with a poor record in both management and compliance.

It would be highly inappropriate to grant approval.
Anna Jarrett
Object
Long Beach , New South Wales
Message
I am writing to express my extreme concern about the proposal to process gold mining at Darges reef, using a known deadly poison, cyanide. The Moruya/Deua River is one of NSW's most pristine and wild rivers. It deserves our respect and care, and future generations deserve to have a clean, healthy river. Using cyanide as part of the mining process, is not acceptable on any level. I ask that Unity Mining take a more responsible long term approach to their mining operation, and look at ways to run their business with more environmental responsilbility. The river is the life source of the communities along it. It is a home for many species., including the spawn which eventually make their way to the sea. A river polluted with cyanide means death at every level of the web of life along the river. There is no such thing as no risk when it comes to processing with cyanide and low risk is not a responsible option.
I urge the government to work with Unity Mining to set a higher standard for environmental responsibility and care.
Many thanks,
Anna Jarrett
Long Beach Batemans Bay NSW
judy Knowles
Object
Bendoura , New South Wales
Message
I am objecting to modification 3 for the following reasons:

COMMUNITY IMPACTS

1. The site is inappropriate due to its close proximity to the village of Majors Creek. Visiting the site made me realise how the noise of the operation and airborne pollution is likely to impact people living just down the slope a few kilometres away. I wouldn't expect there to be any other mining operations in Australia that have been allowed to be constructed, within such a close range of an existing residential area.
2. The residents will be surrounded by constant noise of the crushing machinery during daylight hours, as mentioned to me by the CEO of UML during my tour of the site last week. In summer this is approximately 5:30am to 8:30pm. There are other noise considerations such as the constant humming of machinery, reversing trucks and blasting. Every resident of Majors Creek is going to be impacted by the noise pollution from this development.
3. What was initially approved as a relatively low impact operation with a minimal environmental footprint and minimal threat to the surrounding environment and where the community felt accepting of the conditions imposed on the mine that would minimise the impact to Majors Creek residents, we now have a totally different scenario that is vastly different from the original one.
4. I am concerned that there will be a huge social change to both the village of Majors Creek and the entire surrounds including Braidwood. This is currently an area with modest income levels and simple rural lifestyles. The influx of higher income residents will inflate rents and house prices, creating a shortage of accommodation. Those living at Majors Creek itself may have a decrease in value to property given the proximity to the mine.
5. The Majors Creek community has been socially impacted by the ongoing debate between residents who either support or oppose the mine and or the proposed use of cyanide onsite. Friendships have been lost or strained. An on- going graffiti war is visible on the road that we travel on to town.
6. There is a level of anxiety not experienced before, both in my own family and also the broader community that comes directly from issues arising from this new proposal. I have felt intimidated and worried that my involvement in protesting publicly about the proposal, will at some point impact my family in some negative way.
7. Apart from potential employment at the mine, I see no other benefits for the community. Funding to upgrade amenities in the area, while helpful in the short term, will not out-weigh the potential negative effects of living in close proximity to a large mine and processing centre for the residents living either nearby or downstream.
8. My children have made numerous comments about their concerns regarding the potential for death to animals living downstream of the mine, should there be any contamination to the environment. They have addressed both Palerang and Eurobodalla councils to convey their concerns and produced a short film for a school assignment that allowed them to explore the potential risks to the environment they live in, and to think in an empathetic way towards those who are living downstream.
9. While we don't use social media, we are aware of ongoing confrontational posts between residents who are supporters or opponents to the proposed cyanide processing plans.
10. We are also concerned that birds will use the TSF for drinking and searching for food/prey. We sighted a sea eagle, at Jembaicumbene Bridge, just a couple of kms north of the site in 2014.


ROAD SAFTEY

1. While I am concerned about sharing the road with trucks transporting material out of the mine for processing, as is currently the alternative, I am equally nervous about the increase to traffic that will be involved with 120 employees, commuting for their 10.5 to 12 hr shift. The Majors Creek Rd is narrow, winding, poorly surfaced with only a few overtaking sections and 2 narrow bridge crossings.

2. I am also concerned that should Mod 3 be approved that the future potential for material from other mining operations to be trucked in would be greatly increased, thus creating a further and possibly greater and ongoing issue of heavy vehicle traffic.

THREATS TO AGRICULTURE AND TOURISM

1. I believe that the potential for an event, where the TSF fails and allows contamination of the water down-stream, is far too likely allow this approval to go ahead. This tailings dam will be sitting at the headwaters to the Araluen, Deua and Moruya catchments for the rest of eternity. I believe it is socially, environmentally and economically suicidal to allow this to happen. At some point in the future, whether it is in 6months or 600years, this facility will fail.

2. Anyone trying to operate an agricultural enterprise, either in the surrounding areas or down-stream, will be hard pressed to market their produce in the event of a contamination event to surrounding soil or water.

3. As the cyanide is not the responsibility of the mining company until it is onsite, the potential for the cost of cleaning up a spill in transit will be left for others to deal with and pay for.





CONCLUSION

I strongly believe that modification 3 should not be approved on the basis that it poses a very direct and real threat to the life and wellbeing of the majority of residents in Majors Creek and its surrounding communities, both now and for future generations.
I believe also that the majority of residents living in the Majors Creek area feel that this development is going to be forced upon them, regardless of their concerns and raised voices of objection.
Region X Pty Ltd
Object
Surfside , New South Wales
Message
I think your overlooking the future economic potential of the waterway and valley. The potential for a spill to devastate the area would end any tourism potential the market farmers and future potential for river tourism. The risk is too great.
In a region where employment rates are low, the future potential for farm gate tourism is huge, especially given food has become a major motivational factor for travel.
The farms could easily adapt to cater for travelling foodies.
The river also has future potential for tourism use, floating fly fishing trips, river floats and multisport activities to name a few.
Eurobodalla Greens
Object
Moruya , New South Wales
Message



THE EUROBODALLA GREENS
PO Box 295
Moruya 2537
23 August 2015

SUBMISSION ON EA FOR THE DARGUES REEF GOLD MINE
MODIFICATION 3 MP_10 0054 July 2015
Members of the Eurobodalla Greens object strongly to this third modification to the Dargues Reef Gold Mine Development Consent. Submission of the modification to allow onsite processing of the ore using cyanide as a leaching agent breaks the previous commitment given to the Eurobodalla community during settlement of a court action that led to original approval for development of the mine.
This process is controversial and its use is banned in a range of countries. The Environment Protection Authority (EPA) confirms that use of this process will significantly increase the risk of environmental harm.
The following details clearly demonstrate why Eurobodalla Greens have concluded that this proposal creates a pollution risk that is completely unacceptable to residents along the entire Moruya River Catchment from Majors Creek to coastal Eurobodalla. We are appalled that, as with the original development application for the mine, there is no reference to or assessment of the risks posed to 85% of the drinking water supply for the 38 000 residents of Eurobodalla Shire who rely primarily on water drawn from the Majors Creek and Deua River catchments.

Accidents do and will happen no matter how good the design or management of this proposed processing plant. Either an accident or poor work practices could have disastrous results for the environment, residents and agriculture in the Moruya River Catchment.


Modification not necessary for operation of mine
Unity Mining has stated to shareholders and the ASX that the Dargues project is still viable even 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 value of Unity Mining shares could come at a large cost to residents, businesses, agriculture and endangered species from the inevitable pollution that will follow construction of this processing plant.

Inappropriate site for Tailings Storage Facility (TSF)

1 The site is inappropriate for a TSF containing waste with a high heavy metal content that will remain for centuries. The EA maps show it to be on a hill above a village, on the edge of a steep escarpment and at the headwaters of an important river system. Spring Creek, Majors Creek, Araluen Creek, and Deua River are all used for domestic water supplies and agricultural purposes across this Moruya River Catchment.

2. The EPA has called for a risk assessment that would establish the most appropriate location of the TSF within the mine site, including outside the headwaters of this important river system. Disturbingly, in response the Proponent admitted that "Construction of the TSF in the 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."
The residents of the Deua/Moruya River catchment have been regarded by the Proponent as second class citizens less worthy of equal protection of their water supply.
Clearly the proponent is insisting on the site described in the EA for ease of approval and commercial convenience.


Risks associated with proposed TSF

1. The TSF represents the most significant risk to human health and the environment of our catchment in the short, medium and long term. In addition to residual cyanide, the concentrated waste tailings stored here will contain a range of other contaminants and toxic compounds that need to be considered; Aluminium, Arsenic, Cadmium, Chromium, Lead, Mercury, Salinity, Selenium, Sulphur.

2. The Proponent in the Environmental Assessment admits that this TSF will leak no matter how well built and maintained it is.
Cyanide trapped in gold-mine tailings will cause persistent release of dangerous heavy metals into the groundwater and surface water. The 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. We believe our water supply could be permanently polluted and the livelihoods of the residents threatened across the entire catchment from Majors Creek down to and including Batemans Marine Park.

3. The liner thickness is not adequate for a TSF situated within a drinking water catchment situation.
In addition, the chosen liner is known to be effective for a minimum of only 30 years to a maximum of 300 years. Once it disintegrates the toxic heavy metals in the TSF, which do not degrade over time, will be released into the environment.

4. The Proponent has also acknowledged that the TSF may fail as a result of poor construction, or seismic activity in excess of design criteria, or erosion due to failure of the emergency spillway. Despite this the Proponent did not assess the risk of heavy metal contamination in Majors Creek, Deua River and Moruya River water systems.
Eurobodalla Greens maintain that absence of such an assessment renders invalid
the Proponent's dismissal of possible impacts at some distance downstream of the mine.
5. Risk assessment for leakage from the TSF in the EA focusses solely on the operational stage of the mine which is planned to last for only eight years. Polluted leakage is to be pumped back into the TSF during this stage. However, this option will not be available even in the short term if the company ceases to be a commercial entity or becomes bankrupt and it will certainly not operate once the mine is closed down and rehabilitated.
The toxic heavy metals will be in the TSF for centuries when maintenance will be non-existent. Both in Australia and other countries records have shown that it is at this post-operational stage that catastrophic failure such as a breach in the walls occur.
Again we maintain that this situation renders invalid the Proponent's dismissal of the long term impacts of this plant on our water supply. There simply is no consideration of the long term liability to the local and regional community.



Spillage from the TSF

1.The EA allows for one to two spills per year but this is based on data that severely underestimates actual rainfall at the site.
The ridge on which the mine sits is frequently subjected to heavy rainfall that does not fall elsewhere. Long term rainfall records for properties surrounding the site reveal that the Proponent's estimates of the magnitude of stormwater levels are too low.
Since there is no mechanism to divert the spill water from the TSF it would flow into Spring Creek and the Majors Creek system. This is not acceptable.

2 It is also acknowledged that spillages could 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 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.


Inadequate economic consideration

1.The proposed changes to the existing development approval threaten far more jobs and income than the 120 residential jobs and six to ten million dollars per year that the Proponent predicts will be added to the local and regional economy.
These are trifling figures when weighed against Eurobodalla's largest industry-tourism - which swells the population to 100 000 during peak times. The visitor economy is worth in excess of $340 million per year and supports around 3500 jobs which represents 25% of the workforce.

2. 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.

3. 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 of the mine, nor what the economic damage may be either from a series of small spills or from one major spill. Property and businesses worth millions of dollars are at risk. Who will pay for any damage?
The potential financial burden on the people of NSW and the full lifecycle cost of the project is enormous.


Dubious record of the company
1.The Proponent's operational record does not inspire confidence and there is no reason to think it will improve. The company has already shown itself to be prone to accidents on the Dargues Reef steep site, even though it has not yet begun to mine.
There were five pollution incidents in the six months it was in operation. Prosecution in the NSW Land and Environment Court resulted in 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.

2. The Proponent highlights the good record of the Henty Mine operation as evidence that the company can construct and operate the Dargues mine safely. The Henty site however was constructed as a showpiece by a different company. The Dargues Reef proposal is the first real test of the Proponent's ability to develop a mine.
It should also be noted that in 2014 Unity was fined by the EPA in Tasmania for a spillage at Henty. There had been no contingency planning for spillages and they are not evident for Dargues Reef mine either.


Further modifications likely

1.The Proponent has repeatedly told news outlets and the community that it is not contemplating using the proposed plant to process gold from anywhere but Dargues Reef.
However, the Chairman's Address to the Annual General Meeting in 2014 contradicts this saying that it would be irrational for the company to restrict use of the proposed plant to just one mine site.

2. Other gold prospecting licenses are active across the region. It would only need one more modification application to extend the Dargues Reef processing plant to accommodate any such new mines.
Conclusion

It makes no sense to the Eurobodalla Greens to risk irreversible damage to the unique and precious environments, communities and economies of the Moruya River Catchment

There can be no guarantee that accidents can be prevented. Neither the Department nor the EPA can constantly monitor operations to ensure the continued safety of those downstream.
For all the reasons set out in this submission we recommend rejection of this modification.


Sheila Monahan
Secretary
The Eurobodalla Greens


Karuna Bajracharya
Object
Braidwood , New South Wales
Message
As a share holder in Unity mining company, I feel deceived that the request to process onsite in Majors Creek has been put forward in MOD 3. I never would have supported this had I known, and it seems an intentional tactic used by the company to blackmail us into supporting this modification. As you know the shares have already more than halved in value. Our community is largely opposed cyanide processing onsite, I am will to forfeit my investment in this company if it comes to that. I will still support the mine, as long as no further modifications are sought. Best regards, Karuna Bajracharya.
Beth Brunskill
Object
Moruya Heads , New South Wales
Message




Beth Brunskill
15 Hazel Road
Moruya Heads, NSW, 2537



Executive Director - Resource Assessments and Business Systems
Planning Services
Department of Planning and Environment
GPO Box 39, Sydney NSW 2001



24 August 2015

RE: PROJECT APPLICATION 10 0054 MOD 3

As a resident of Eurobodalla I strongly object to the application in the third modification of the Dargues Reef Gold Mine because of the potential devastating impacts on this beautiful area.

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'. I 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.

In addition 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 Dargues Reef mine is a very different situation. As mentioned above already there have been spillages at the Dargues Reef site.

Unity mining have informed their shareholders that the Dargues 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 Dargues 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 resident and rate payer in Eurobodalla I call on you NOT to approve modification 3 to allow Unity mining to use cyanide in processing gold at Dargues Reef.


Signed, Beth Brunskill
Kristy Moyle
Object
BRAIDWOOD , New South Wales
Message
The original approval for the mine was the result of extensive community consultation. Communities contributed countless collaborative hours with the proponents and eventually a course of action was prescribed. The communities involved were given assurances that cyanide would NOT be used onsite to extract gold, and the approval and subsequent community acceptance of the mine was contingent upon this.

The reality is, a tailings storage facility at the top of this catchment is already an exercise that puts future generations at risk from spill hazards that are unknowable in the future. Adding cyanide to the list of hazardous substances to be stored in perpetuity at the site pushes both acceptable, perceived and even estimable levels of risk beyond any that this community will accept.

The proposed modification is intended to increase the profitability of the mine and benefit shareholders, whilst placing countless individuals and communities at risk now, and infinitely into the future. This not only completely disregards the 'precautionary principle', it violates community trust and relinquishes the social license of the mine to operate.

Pagination

Project Details

Application Number
MP10_0054-Mod-3
Main Project
MP10_0054
Assessment Type
SSD Modifications
Development Type
Minerals Mining
Local Government Areas
Queanbeyan-Palerang Regional
Decision
Approved
Determination Date
Decider
IPC-N

Contact Planner

Name
Phillipa Duncan