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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 161 - 180 of 449 submissions
John Mckellar
Support
Tallong , New South Wales
Message
Dear Sir / Madam
I would like to make it known that I fully support the Dargues Reef Gold Mine . I believe the economic benefits to the region are substantial and job creation needs to be encouraged.
I have no reservations at all concerning the operation of a processing plant onsite and have complete faith in Unity Minings ability to conduct operations safely for both people and the environment. I live on the edge of the Morton National Park which is and will always be pristine wilderness. There is also a very large open cut mine nearby and the benefits it provides to the local region are tremendous . If such a large mine can coexist with a National Park then I can see no reason why a much smaller operation in what is historically a Gold mining area cannot be approved.
Yours Sincerely
John Mckellar
Lisette Dwyer
Object
Deua River Valley , New South Wales
Message
I object to:
- extending the approved mine life by 4 years, from the 21st August 2018 to the 31st August 2022.
- increasing the approved maximise ore extraction
- final processing of gold concentrate on site using a cyanide leaching process in a conventional carbon-in-leach processing plant
- construction of an enlarged tailings dam to permit storage of additional tailings
- construction & use of a waste rock emplacement area
Name Withheld
Object
Warri , New South Wales
Message
I object to Modification 3 because I've worked in a gold mine with a tailings dam in Stawell and I know these are a permanent impact on any environment and have no doubt that when something goes wrong - especially in Majors Creek - no matter how small, will be an environmental disaster. Majors Creek and the Araluen Valley, the Deua River and the Moruya River are clean environments that support many communities recreationally and for food, not to mention the animals and wildlife that n matter how much money is thrown into the "repairs" of a tailings dam accident, will never recover.
I've seen for myself the dead birds crashed on the ground next to a properly contained tailings dam, so even without a spill, the bird population around the Majors Creek mine will be doomed.
I also have concerns about the Braidwood districts resources, including ambulance, fire and police and how an addition of more staff and workload at the mine will impact the town.
Name Withheld
Support
Cobar , New South Wales
Message
I have acknowledged the modifications to the Dargues Gold Mine project and welcome the changes as a common sense approach and believe that the experience Unity has from its Henty and Bendigo projects will result in a safe and environmentally compliant operation. The water management plan is thorough and provides the NSW Department of Primary Industries with a blue print for control and inspection of the operation when under construction as does the details of the processing and paste fill plants. Furthermore the adherence to the Cyanide Code is the highest governance for the safe handling, use and measurement of cyanide products. Mining as an industry cannot afford to be complacent where the environment is concerned and I think Unity Mining has shown that in this case they are diligent and up front with their planning and ideas.
Andrew Gow
Object
Jembaicumbene , New South Wales
Message
I would like to express my strong objection to the Dargues Reef Mine - Modification 3. My objection is based on the following:

- Safety: the proponent cannot guarantee against environmental contamination from a release of cyanide, with the associated disastrous consequences for the humans, animals and broader environment within the region;

- Proximity: as someone whose home, family and livelihood is within walking distance of this toxic proposal, I have deep and personal concern for our health and wellbeing. We rely on groundwater for our own consumption as well as for our stock and naturally enough we rely on an uncontaminated air supply.

- Traffic: while the proponent claims that onsite cyanide processing will reduce truck movements as ore is shipped elsewhere for processing, I am deeply suspicious that the proponent intends to ship ore from elsewhere to Majors Creek for processing. Local residents will end up with the worst of both worlds: toxic chemicals and increased traffic.

- Track record: the proponent already has a history of dam breaches and fines by the EPA at this very location. I have no confidence in their ability to contain the toxic waste within the confines of their property.

- Trust: the proponent has breached any trust held with the local community, by firstly promising that there would never ever be onsite cyanide processing and then immediately lodging a modification to commence cyanide processing. The proponent's promise is a matter of public record. Local residents can clearly have no faith in any promise or undertaking made by the proponent, so the guarantees of safety, reduced traffic and local benefit must be disregarded.

It is disgusting that rural residents of this state are constantly required to fight against the toxic impact of mining. This is not something that city residents are ever expected to face and it perpetuates the poorer health and wellbeing outcomes experienced by rural people. I trust that the Department of Planning will put the health and wellbeing of local residents ahead of the additional profit that the proponent wishes to extract from the Dargues Reef Mine and associated ventures.
Victoria Clutterbuck
Object
JEMBAICUMBENE , New South Wales
Message
I am very much against the application by Unity Mines to use cyanide in the processing of ore in its Dargues reef Mine at Majors Creek. I believe the process to be toxic, creating potential if not inevitable, pollution. If/when the toxic sludge is released it will be catastrophic for Majors Creek, the Araluen Valley, the Deua River and Moruya. Not only people but the entire ecosystem will suffer.
We must think not only of money. The environment is more important than a few gold bars.

Gilles Bonin
Object
Jembaicumbene , New South Wales
Message
I want to inform you of my objection to Unity Mine's application to extend the Dargues Reef mine at Majors Creek and to use cyanide in processing on site. The toxic sludge held in a precariously placed tailings damn represents an accident waiting to happen. We have seen what happened in Colorado and in Romania when toxic waste from mines has been released into the environment. I am concerned not only for myself but for future generations and the beautiful natural environment.

Please do not give permission for this proposal.
Richard Khouzame
Object
araluen , New South Wales
Message
I am very concerned about these proposed modifications (#3). The onsite cyanide processing, the dam wall that is to be built over the majors creek fault line that will stand 30 m high,the inevitable risks to our water supply, and heritage listed site. The effects of hi levels of heavy metals and cyanide in our immediate communities, our childrens environments and living space.No No No No No. Please say no to these modifications. Would you deem such an environment safe to raise your children and them theirs?
Name Withheld
Object
Petersham , New South Wales
Message
I object to:
the construction of an enlarged Tailings Storage Facility
&
to final processing of gold concentrate on site to produce gold ore or unrefined gold bars using a conventional carbon-in-leach processing plant.
Name Withheld
Object
Parklands , Tasmania
Message
Three years ago Coastwatchers and SERCA won stringent conditions for a proposed gold mine to operate above our valley home. We thought we should be safe.
But the sediment dams failed in the first three day rainfall. In the six months before work halted in 2013, large drifts of sediment filled the deep holes of the gorge to about a third of their depth. Much is still there. The company was convicted in the Land and Environment Court for three pollution events.
Now the company wish to change the Conditions of approval of that mining venture by Modification to allow them to process the gold ore on site, using cyanide. Instead of the heavy metals lead, zinc, cadmium, uranium and other potentially deadly heavy metals being trucked, these heavy metals will sit in a tailings dam on the steep site at the top of the Major's Creek/Deua/Morura catchment, above Eurobodalla's water supply, and farms and businesses and households.
If --or when- there is an overflow, this tailings dam is only ten minutes away from us as the water rushes down the slope below the mine site and over the escarpment.
One major cyanide spill could be deadly to us, to our near neighbours and to the endangered wildlife of the valley. An accumulation of small spills will be deadly too, as the heavy metals gradually build up in the soil t of the riverside farms and orchards, to harm today's children and children as yet unborn.
Unity Mining does not pretend there will be no spills. It admits there will be, but says that they will be diluted by rain. This is unproven and even if it were to be the case it presumes the spills will occur when it is raining- a rash assumption in this area. The company ignores the fact that as they refused to test the creek on our property during and after the previous the pollution events they did not see that as the water slows and reaches the pools, the pollution can be even worse than on the steep land immediately below the mine site as the water slows and the heavy material settles or fills the pools.
Nor have the company seen how thunder storms break above their site, sending flash floods far greater than their estimate of 1 in 1,000 year events crashing down a dry watercourse.
Given the history of work on the site in 2013, a major failure or series of small failures seems inevitable. So called `world's best practice conditions' failed in 2013. Why will it be different now?
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 ... including the production of my books ... 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.
Name Withheld
Object
Burnie , Tasmania
Message
Three years ago Coastwatchers and SERCA won stringent conditions for a proposed gold mine to operate above our valley home. We thought we should be safe.
But the sediment dams failed in the first three day rainfall. In the six months before work halted in 2013, large drifts of sediment filled the deep holes of the gorge to about a third of their depth. Much is still there. The company was convicted in the Land and Environment Court for three pollution events.
Now the company wish to change the Conditions of approval of that mining venture by Modification to allow them to process the gold ore on site, using cyanide. Instead of the heavy metals lead, zinc, cadmium, uranium and other potentially deadly heavy metals being trucked, these heavy metals will sit in a tailings dam on the steep site at the top of the Major's Creek/Deua/Morura catchment, above Eurobodalla's water supply, and farms and businesses and households.
If --or when- there is an overflow, this tailings dam is only ten minutes away from us as the water rushes down the slope below the mine site and over the escarpment.
One major cyanide spill could be deadly to us, to our near neighbours and to the endangered wildlife of the valley. An accumulation of small spills will be deadly too, as the heavy metals gradually build up in the soil t of the riverside farms and orchards, to harm today's children and children as yet unborn.
Unity Mining does not pretend there will be no spills. It admits there will be, but says that they will be diluted by rain. This is unproven and even if it were to be the case it presumes the spills will occur when it is raining- a rash assumption in this area. The company ignores the fact that as they refused to test the creek on our property during and after the previous the pollution events they did not see that as the water slows and reaches the pools, the pollution can be even worse than on the steep land immediately below the mine site as the water slows and the heavy material settles or fills the pools.
Nor have the company seen how thunder storms break above their site, sending flash floods far greater than their estimate of 1 in 1,000 year events crashing down a dry watercourse.
Given the history of work on the site in 2013, a major failure or series of small failures seems inevitable. So called `world's best practice conditions' failed in 2013. Why will it be different now?
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 ... including the production of my books ... 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.
Name Withheld
Object
Potato Point , New South Wales
Message
As a resident of the Eurobodalla shire, with friends and business acquaintances living on the Duea river downstream from the the Dargues Reef Mine, I am deeply concerned about the proposal to the third modification to the Darques reef Gold Mine Development Application. I strongly object to the above mentioned Development Application.

In particular I am concerned with two points; the construction of an enlarged Tailings Storage Facility and the final processing of gold concentrate on site to produce gold ore or unrefined gold bars using a conventional carbon-in-leach processing plant. This is unnecessary and potentially very dangerous.

The processing that is proposed, with such a hazardous substance, on an unsuitable site, severely risks the health of the people and the land of the Moruya Catchment Area. 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.
The proposed mine site is a site that is located above a drinking water supply for over 35,000 residents!! Not to mention the agricultural land that is used as a food source and a means for income for the local residents.

Much of the land along the Duea River is used for agricultural purposes, specifically food production. This food production is crucial to, not only the local community as a food source, but also an income for producers and small local businesses. If there is any chance of water quality being jepoardised by the upstream tailings storage, or cyanide processing this proposal must be stopped!

Local food production is a vital part of our community economics, health and tourism. It is a growing industry in the Eurobodalla and should be given utmost consideration and priority in the decision process.

The EA confirms that the decision to process ore on
site at Dargues Reef is a cost-saving measure. This demonstrates the question-ability of the priorities of Unity Mining. Cost saving, and therefore for further profit for one party, one company at the potential expense of the health and livelihood of thousands of residents is an unquestionable crime.


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.
Please consider the seriousness of cyanide as a poison that is seriously harmful to humans, and can cause death.

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.

Earlier this month saw a devastating spill at the Mt Polley Mine, near the town of Likely, in the Cariboo region of British Columbia. A dam at a waste pond on the site of the Imperial metals open-pit mine had burst, releasing 10m cubic meters of water and 4.5m cubic meters of potentially toxic slurry into virtually untouched forest, lakes and rivers into an area of Canada populated mostly by the indigenous First Nations peoples. The full repercussions of this disaster will not be know for many years, even decades.

It will only take ONE accident, fault, oversight, breach, flaw or significant weather event to threaten such a pristine and fragile environment - some of which are within human control and others, such as weather patterns, ARE NOT WITHIN HUMAN CONTROL.
This is an environment that is home to clean harvested water, wildlife, and aquaculture. There is a commercial stone fruit orchard just 8km away from the proposed tailings dam, and many other agricultural properties further downstream.
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.

I am dismayed to learn that it is being considered to risk irreversible damage to this unique environment, our community, the people and the local economy, for the sake of some extra profit for a mining company.
Name Withheld
Object
Cronulla , New South Wales
Message
* As a regular visitor to a property in Eurobodalla, I object to this third modification to the Dargues Reef Gold Mine Development Application. I visit a beautiful property owned by family and friends of over 100 acres near the junction of the Deua River and Araluen Creek. The property is used for holiday activities including camping, swimming, walking and just simple relaxation. The river water is the source of drinking water.
* The main danger with this project is the assumption that there will never be failures in the proposed processing plant. Accidents have happened with this company several times.
* 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.
* For the reasons below it is clear that the proposed modification creates a pollution risk that is unacceptable to residents and holiday makers along the entire Moruya River catchment. The potential cost to the local community is too great and Unity is ignoring the threat to our wellbeing.
* Given the risk to the environment and potential pollution of the waterways, visitors will no longer see the Araluen Valley as a tourist destination.

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 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.
THE MODIFICATION IS 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 property owners, 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 concur 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." As well, 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 explanation 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."
* Negligible consideration 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 proposed changes to the existing development approval threaten far more jobs and income than the six to ten million dollars per year that Unity predicts will be added to the local and regional economy. These are trifling figures when weighed against the worth of clean water catchments and food production downstream.
* 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.
* Property and businesses worth millions of dollars is at risk. Who will pay for any damage?
* 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 totalling $200,000.
* Anyone 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.


* It makes no sense 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.
* 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.
Steven Hockey
Support
Braidwood , New South Wales
Message
Ever since Tallaganda shire became Palerang Council employment for the young has gone out the window, there was two saw mills working in the area 20 odd years ago which one had two buses picking up workers in and around the Braidwood area every day to go to work.
The Dargues Reef Gold project would be great for the Braidwood area as to bring money and employment, I have been to the mine site as I have a very small business of supplying drinking water which I have done about ten times over the time workers have been on site.
I urge the decision makers to think about the Braidwood district and the people who work away as there is no work here.
I fully support the Mine.

Regards
Steven Hockey
Pei-Shan Wu
Object
Moruya , New South Wales
Message
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. Accidents do happen and when they do, it poses a great risk to us who rely on this river system for our drinking water. Not to mention the pollution threatening the local orchards, gardens and wildlife. The record of Unity (5 pollution incidents in 6 months plus poor management of their other mining sites) does not inspire confidence.
Leonard Tompkins
Object
Batehaven , New South Wales
Message
I am most concerned about possible failure of the tailings dam associated with this project which could lead to toxic chemicals and heavy metals entering the water supply for Batemans Bay. Having been associated with the failure of the tailings dam at the Ranger uranium mine in the NT some years ago I am well aware of the factors that can lead to poor or inadequate inspection and maintenance of tailings dam years after they are constructed. I implore the NSW Government to reject the mining company's proposal for the use of cyanide in this location.
Philip Jasprizza
Object
Deua River Valley , New South Wales
Message
Resident of Deua River Valley 35 yrs.- involved in Civil Construction 46 yrs. including major project management. Proposed modification poses unacceptable threat to ecosystems & agriculture from Majors Ck to Batemans Marine Park with possible contamination of drinking water for Eurobodalla's Nature Coast. Design and situation of Tailings dam threatens streams & groundwater systems. Unity has not shown commitment to best practice to safeguard our vital resource, & has lied on several occasions. It has shown contempt for downstream users & EPA. All risks have not been addressed.
Name Withheld
Support
Braidwood , New South Wales
Message
As a small rural town with limited employment opportunities, this mine would benefit the area financially.
The flow on effect to our schools, shops etc would create a ripple effect that would exponentially increase the boost to his small rural economy.
I am confident that all the potential environmental impacts have been addressed and the risk to the area is insignificant.
Name Withheld
Object
Braidwood , New South Wales
Message
Approval of the mine poses an unacceptable risk for people, clean food and water in the region, with severe potential risks on downriver communities and the environment.

The economic value of gold processing on site is marginal at best. If the true environmental and social costs both now and in the future were properly costed into the equation, the mine would be a non-viable proposition.

The expert report commissioned by the Council indicates not if, but when a spill happens it will be devastating to the local and downstream communities. The company's bond only covers reparations on site, and any damage to air quality, downstream pollution to crops and water, or accidents on the roads with trucks carrying cyanide will all require litigation of a company which could phoenix itself to avoid penalty. The cost of remediation would be far in excess of the bond currently being requested of Unity and at a point in the future the cost will be borne by the State and future taxpayers.

There is a significant risk that if a gold processing plant is established that ore from other gold mines would be trucked into the area for processing. There are few if any options available for processing gold in NSW. The establishment of the infrastructure economically compels its continued use and I do not have faith in the company or government not to sacrifice the local area for the sake of a few extra dollars.

The site of the proposed tailings dam is unsafe and any breach would lead to contaminated water draining into Major's Creek, Araluen Creek, and the Deua and Moruya river systems. The topography and rainfall at the site pose a significant threat of breaches, overtopping and leaks. The rainfall data in my view underestimate the particular climatic conditions at Major's Creek where there have been high rainfall events in short periods in recent years.

Unity has a history of repeated and defiant non-compliance with EPA directives and conditions of approval. I do not believe that the EPA are sufficiently resourced to oversight this project and monitoring at best is an "after event" alarm, rather than a mechanism to prevent accidents. In reality it will be the communities or individuals raising the distress beacon, and it may be too late then to remedy damage done to our air, quality, crops, water etc. and ultimately our health and welfare and the well-being of our environment.
Glenda Jones
Object
Araluen , New South Wales
Message
Dear Minister John Barilaro
I am a resident of Araluen and feel my my future enjoyment of the organic nature of this area and my family's good health will be adversely affected if the NSW Department of Planning allows this mining development.
Project Application number 10 0054 MOD 3

This mining company is treating the local community with contempt. Based on a proposed production life of seven years it is prepared to risk the health and well-being of the people who live in the valleys below
This risk is unacceptable and people, clean food and water must come before gold processing and the very dubious rational of marginal economic gain. The approval for the mine without modification 3 (gold processing on site) remains valid.* There will be a Tailings dam 700m long, 400 metres wide and 32 metres deep at its deepest point in Majors Creek if Mod 3 gets approved.

* This site preferred by Unity is not safe.
* A TSF of 16hectares poses significant risk of breaches, overtoppings and leaks. The elevation surely means there is only one way and that is down via streams through groundwater with all of the consequences for the whole area.
* The EA acknowledges that spillages can contain copper and mercury that exceed safe levels by two to five times in a 1-200 year, 72 hour rainfall event. This is very concerning given the rainfall data is inaccurate and that the particular climatic conditions at Major's Creek remain underestimated, misunderstood and denied.

Unity Mining's History

* This company has a history of repeated and defiant non compliance with EPA directive and Conditions of approval. Can this company be trusted?

* There is no capacity except through the taxpayer to remedy downstream damage. The company's Bond only covers reparations on site. Thus reparations for damage done which could be air quality, downstream pollution to crops and water, truck carrying cyanide accident etc will all require the company to be sued.

Economic Issues

* There has been no economic study even a poor one of the numbers of people and livelihoods they may be affected, no study of what may happen with one big spill or many smaller leaks. Could this be because Unity would not see that as a risk as their bond only covers on site issues?

Community Issues

* A cost saving measure or a bid to increase profits by this mine plus others in the area puts at risk the catchment from Major's Creek to the sea at Moruya. To try and develop such a processing plant here at the headwaters of a major river, agricultural system and coastal residential areas has every community along the way objecting in the strongest terms.

Environmental Issues

* All the following are at immediate risk. The Majors Creek National Park Reserve, the Majors Creek gorge, and the Araluen Scarp Grassy Forest, and the Neverbreak Hills Voluntary Conservation Area, proclaimed in 2013 and adjacent to the Major's Creek Conservation Area are areas of considerable biological richness, in both numbers of species and habitats. The Neverbreak Hills Voluntary Conservation Area was assessed and proclaimed in 2013.
* The survival of the extraordinary number of species directly below the mine site is due to the steepness and roughness of the terrain, which has meant that it has not been logged or affected by earlier mining. It is possibly the only remnant of the original ecology present before the disturbances of farming and gold mining.

* Specific species listed in NSW as rare and endangered species in the area likely to be affected by the mine include:
* Petrogale penicillata (Brush-tailed Rock Wallaby) This rare an endangered species exists in the limited protected conservation sites below the mine, relying directly on water that may become contaminated by heavy.
* Powerful Owl (Ninox strenua): these regularly nest within one to two kilometres of the mine. Status: vulnerable
* Barking Owl (Ninox connivens). Status: vulnerable.
* Araluen Zieria adenophera: the only wild specimens of these are within five kilometres of the proposed mine. Status: critically endangered.
* -Majors Creek Leek Orchid: Prasophyllum sp. Majors Creek: status, endangered
* New Holland mouse (Pseudomys novaehollandiae): vulnerable
* Zieria adenophera- Araluen Zieria: endangered
* -Button Wrinklewort
* Rutidosis leptorrhynchoides- endangered
* -Grey Deua Pomaderris
* Pomaderris gilmourii var. cana
* The failings in the design of the Dargues Reef tailings dam and processing site, however, make it probable that within a five-year period there will be a major rainfall event that the dam, or even the storage site, is unable to cope with, leading to pollution of the flood plain and waterholes downstream.

Yours sincerely
Glenda Jones

Lot 16 Naughtons Close
Araluen
NSW

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