Mod 3 - Processing & Tailings Storage

Dear Sir/Madam

In reference to Project Application Number 10 0054 MOD 3 I wish to express my concerns and serious misgivings.

The area to be affected is pristine and not only will our native flora and fauna be endangered but, far more importantly, allowing this project to proceed will have serious ramifications on the people living in the area.

Heavy metal poisoning is a real threat. Heavy metal poisoning is something that can and does occur. I personally am a witness to that.

My son has suffered years of debilitating illness as a result of heavy metal poisoning. We have no idea where and how he was exposed to this.

I would like to express my extreme concern about any possibility of this ever happening to another person, let alone many people being exposed to potential poisoning through water, soil or agriculture. I have no doubt that the people living in this area and being well- informed, will not hesitate to seek legal aid and compensation, should this project go ahead and they themselves and their families be affected.

My question is: is it worth the risk? Is it worth endangering any human being for the gain this mine would bring? Is it worth taking the chance, and it is very real, that people down the track will sue for damages and you be held responsible?

I don't live in your beautiful state. I could all to easily turn my eyes away and say " It's not my problem and it doesn't affect me or my family."

But after witnessing the sickness and despair my son has suffered, I could never wish even a portion of that on anyone or their children.

Knowing the previous mishaps that have occurred with this particular company, I am extremely concerned. It's not a matter of if, it's a matter of when.

Please, please take my concerns and those of countless others, seriously.

You would not expose yourself, your children or your children's children to any risk of heavy metal poisoning. Why would anyone else's children be of any less value?

Please put a stop to this whole application process and allow the area to remain as it is. Put the safety of numerous families before that of some financial gain. Please look at the long term effects and see that it is truly not worth the risk, both in terms of health and the risk of damages and legal ramifications.

If you wish to see any medical evidence of my son's heavy metal poisoning, I will be more than happy to scan his reports and forward them to you. Rest assured that this is no nebulous danger. It is very real and very destructive.

Thank you for taking the time to read my letter and I urge you to seriously consider the issues I have raised.

Your sincerely

Ruth Bird

1406 Rowley Rd
Wungong, WA 6112
24/8/2015

As a currently unemployed Aircraft Maintenance Engineer, I fully support this application, as the mining industry is one of the few industries who recognise people with aviation qualifications as being safety oriented and possessing high standards of workmanship. The opening of a mine at this location will provide employment opportunities in one of the highest unemployment areas in the country, the NSW South Coast. I have already submitted my resume, and eagerly await the opportunity for an interview.

I object to the proposed Dargues Reef Mine.

The potential environmental, agricultural and residential impact of this project has not been sufficiently determined. Downstream effects in the Araluen Valley and Deua River are undetermined, with surveys reaching only approximately 2 km from the site. The mine will likely impact areas much further downstream than this, affecting fragile ecosystems, agricultural sites and water supply for local residents. Long term independent critical assessment of these possible effects is necessary before any further activity in developing this site.

On a personal note - this area is where I grew up, and is the place I consider home. Just having seen the devastation caused by drought and bush fires in the Deua River area, it would be heartbreaking to see this sort of impact stem from something so directly caused by ill-informed and ignorant human activity.

Anthea Rote

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

25/8/2015

Dear Sir/Madam,

As a resident and rate-payer 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. Any use of cyanide should be considered unacceptable because no matter how small the risk of spillage, consequences of such a spill are devastating and not reversible. This is because the mine is upstream of a water supply and a fertile food bowl which is growing in reputation. The pristine environment in this area is the major draw-card for visitors, something which is vital to the local economy.

It is reasonable to expect that our drinking water is kept safe and not threatened; it is reasonable that food growing in the area downstream of the mine be kept safe; it is reasonable to expect that the tourism trade here be protected by preserving an exemplary Australian native environment and exemplary clean food production; it is of course reasonable to protect the health and livelihoods of local people.

This mine needs to be held accountable for possible 'unseen' costs to health, wellbeing, the environment and lost revenue through spoiling of the areas reputation for natural food and leisure within nature. If risks and costs of remediation in the event of a disaster were properly factored in there would be no benefit through using cyanide to process the gold extracted.

I call on you to refuse approve modification 3 to allow Unity mining to use cyanide in processing gold at Dargues Reef based on it being too significant a change to be considered a Â`modificationÂ'.

Yours sincerely

Joanna Evans

This project is a good one for the welfare of the region

Submission on
EA FOR THE DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054
July 2015
Written and prepared by Michelle Tribolet
2/4 Hawkins Rd, Tuross Head, 2537
Email: [email protected]












Introduction

I am a resident of the Eurobodalla Shire. I have lived here for more than 22 years. I strongly object to Unity Mining's proposed modification of the Dargues Reef Goldmine to include a gold processing plant on the Dargues Reef site.
The site is inappropriate
Unity Minings Dargues Reef site is situated above the Majors Creek village, as well at the headwaters of several creeks which flow into the Deua and on into the Moruya river. Spring Creek, Majors Creek and Araluen Creek are vital catchment for the Deua River which supplies most of the fresh drinking water to the Eurobodalla community. These creeks and rivers also provide a livelihood to many established orchards and market gardens from Majors Creek to Moruya Township.
I believe it is a very inappropriate location for a gold processing plant due to the dangerous chemicals used in the process and the real risks of soil and water contamination.

Enlarged Tailings Storage Facility (TSF)

Recent studies show that cyanide trapped in goldmine tailings causes persistent release of dangerous metals into the groundwater and surface water. The proposed TSF is located in a drainage line where a breach would lead to contaminated water draining into the Majors Creek, Araluen Creek, Deua and Moruya River water systems. The risk of build up of these serious toxins in our water and soil is unacceptable.

I believe an assessment must be made of the impacts and consequences of small or large spills of waste containing heavy metal downstream of the site. The tailings dam will remain on the site forever!

I believe that there needs to be further assessment of the tailings dam liner and the susceptibility to slow leaching of the contents of the TSF over the short term and the long term.

I am appalled that there is no assessment of the risk of heavy metals getting into the Majors Creek, Deua River and Moruya River water systems. I strongly believe that it is essential that an assessment of this risk is carried out.

The ridge on which the mine sits is subject to particularly heavy rainfall that does not always occur further downstream. Long term rainfall records for properties surrounding the site reveal that Unity Mining's estimates of magnitude and frequency of stormwater levels are way too low. There is also much evidence of increasing frequency of irregular heavy rainfall events in our region. A higher than average rainfall event could cause a catastrophic breach of the tailings dam, releasing highly toxic chemicals into the waterway and this risk is unacceptable.

The EA seems to allow for one to two spills per year. I find this in itself is unacceptable as it poses a real risk of build up of toxic levels of heavy metals and other chemicals in the surrounding soil and water ways. Worse still the data that this is based on is inadequate as the EA severely underestimates the actual rainfall which could occur at the Dargues Reef site!

Unity acknowledges that spillages can contain copper and mercury that exceed safe levels. In the event of a 72 hour rainfall event the risk of copper and mercury contamination is too high. There is an unacceptable risk of dangerous levels of copper and mercury building up in the soil. There is also a risk of dangerous soil contamination downstream from the processing facility from so-called `acceptable minor spillages'. Considering the dangerous toxicity of these chemicals, no spill is acceptable, no matter how `minor'.

It is noted that Construction of TSF in Greater Shoalhaven River Catchment was not considered in the original DA because this catchment forms a component of the Sydney drinking water supply - a proposal of a similar nature there would have imposed "additional regulatory requirements." I am outraged the people of the Eurobodalla Shire are not given the same consideration regarding our drinking water. It is incomprehensible that the drinking water of the residents and tourist of The Eurobodalla Shire is not governed with the same consideration and stringency as the drinking water of the Sydney region. I find this completely unacceptable.

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. These possibilities have not been included in the risk assessment done by the company. Unity proposed a six to ten year lifespan of its mining facility but admits that the tailings dam and its toxic contents will remain at the site "forever". It is unacceptable that the people who currently rely on the waterway and those generations who will rely on the waterway in the future should bear the burden of this threat long after Unity and its shareholders have moved on.

A model of what could happen in a TSF failure needs to be included in the EA. The claim by the Unity CEO that structures built in Australia do not fail because they are well built is not acceptable. There are so many variables that cannot be predicted accurately on which to base such a claim. There are many examples of unacceptable TSF spillage in Australia and many more globally even though mining companies had given assurances of negligible risk.

There is no way that Unity can guarantee that this TSF will never fail and it is unacceptable that our entire community should forever live under the threat of it happening. It is doubly unacceptable that we should bear the devastating consequences of such a failing in the event that it does occur. What is now considered state of the art technology will soon be regarded as old and outmoded. What is Unity's responsibility to its downstream stakeholders and how can this be enforced if Unity no longer occupies the site or has sold its mine on to new owners. We have already heard excuses from Unity blaming the original owners of the mine, Cortona, for the initial three accidents. Is this passing of the buck what we can expect in the case of a disaster?


Unity Mining need to issue a clear and binding model of the action it would take to aid our community in the event of a catastrophic disaster affecting the Dargues Reef Mine and all the downstream stakeholders - the entire Eurobodalla Shire. The risk that the company would be long gone in the event of a disaster is too high!

Future generations in our area will rely on these waterways and it is unacceptable that they inherit the toxic risk long after the mine is in use.

Health and safety
The proposed modification to the TSF poses an unacceptable risk to the quality of our drinking water supply and the health of our population..
The chemicals used in the processing of the gold could contaminate the main source of our Shire's drinking water with dangerous heavy metals. It is unacceptable to threaten these communities whose lives and health depend on these vital waterways.
Eurobodalla Shire economy
There are many agricultural industries whose livelihoods are dependent on the cleanliness and health of the creek and river catchment. It is unacceptable that the viability of these industries would be under a permanent threat due to a toxic TSF situated at the head of the water catchment.
Tourism is the biggest industry in the Eurobodalla Shire providing 90% of our income and employment opportunities. During the summer we have hundreds of thousands of visitors who come to enjoy our local organic produce and uncontaminated natural camping, swimming and fishing. This would be destroyed by a spillage of toxic waste into the head of our water catchment. To risk the long term viability of our economy for the short term economic advantage of Unity Mining is unacceptable.

The proposed modification is not necessary for the mine to continue its extraction of ore.

Unity Mining has stated that it's mine will still be viable if it does not process the ore on the Dargues Reef Site. It is unacceptable to place this unnecessary risk on the people and on the industries that are completely reliant on the quality of the water downstream of the mine.

The Dargues Reef Goldmine has already had three accidents since it began construction and mining operations three years ago. They have been fined three times already by the EPA and ordered to improve their standards. I have no confidence that this company will not continue to have accidents and that these accidents will be all the more disastrous if they involve the chemicals required for the gold processing plant.


Consideration for the natural environment

The Deua National Park is located downstream of the Dargues Reef Mine facility. It is home to a great diversity of native flora and fauna. Many of these species are listed as threatened and endangered. It is unacceptable that these rare and endangered species be placed under further threat. The very land and water that they depend on for survival could become irreparably poisoned. The EA needs to acknowledge and take into consideration this highly important factor.

Conclusion

When the Dargues Reef goldmine was originally approved, it was under some very strict environmental conditions. As a concession to the strong community concern of the time, the agreement that was made, that there would never be a gold processing facility on the site.

I am outraged that Unity Mines would so readily try to renege on the specific conditions that came with the goldmine when it was purchased from Cortona.

I have no confidence in Unity Mining's sense of responsibility to the people or the environment surrounding the mine. Unity spokespeople have so far been dismissive and shown disregard and even contempt for the concerns that local residents have brought to their attention. Unity Mining has been shown to be unreliable regarding previous public consultations in giving a minimum of notification as to when these opportunities would be available.

I am very concerned about this proposed `modification' and I strongly urge you to reject this dangerous and threatening proposal. The original conditions and assurances of no gold processing on the site should be upheld. The long term future of our water supply, economy and environment is at risk. The economic viability of our agricultural industries is at risk. The economic viability of the Eurobodalla's tourism is at risk. The proposal to risk these long term livelihoods for the sake of an economic advantage for a short term mining venture is totally and completely unacceptable.

I DO NOT agree with the proposed modifications to use cyanide possessing onsite at Majors Creek. Unity mining, from past experience, is distrustful and here in our beautiful town to make short term profit which dos not benefit our community. I have grown up in the Braidwood area and if this modification is approved I no longer wish to continue my life in this region with the threat of powerful greedy companies and poisoned air, water and soil.

'I am writing to wholeheartedly object to Project Application number 10 0054 MOD 3
Over the last 36 years (my entire life) I have spent numerous periods living and holidaying in the Eurobodalla area. Currently, both my brother and parents, live in the area (one with a property on the Deua river) and have been for the last five years. The former is a market farmer growing organic produce for the local markets and is a passionate committee member of SAGE, which has recently won "Outstanding Farmers Market in Australia" for the second year in a row. The latter has worked with the Eurobodalla Council voluntarily in the past.

We are all exceptionally proud of the south coast and particularly the Eurobodalla area which we have been lucky to inhabit and enjoy along with many of our friends and family over the years. We have always been active members of the community and involved with numerous initiatives to improve the Shire in general and give back to an area which has provided such an outstanding quality of life for the majority of its people.

In particular, we love its pristine outdoors from the rich estuaries, rivers and ocean to the mountains, fields and bushland.

Obviously, my brother and his diverse clientele, rely on these growing conditions, water supply and general environment for their food, overall health and in my brother's case income. Aside from the financial impact, my brother is immensely proud, as am I, of the incredible quality of his produce and the sustainable manner in which it is grown. In addition, he uses his dynamic farm to educate local children, university students and interested individuals on sustainable farming, agriculture and nutrition.

Although the benefit of these initiatives may be hard to economically quantify, the overall impact on society is clearly significant.

Outside this group tens of thousands of individuals rely on the critical water supply and surrounding nature for day-to-day life.

With all these facts in mind, it baffles me that such a modification could even be tabled. Surely, the outlined risks of cyanide use make it fundamentally wrong to approve these changes. It is therefore critical that these modifications are wholeheartedly rejected.

Concerned Local!'

EA for the Dargues Reef Gold Mine Modification 3 MP_10 0054

Objection

I feel that insufficient consideration has been given to addressing possible contamination of water and soils downstream of the proposed cyanide processing plant, (the plant). Such contamination could arise through inappropriate location/design/construction/operation, or through accidents arising from human error or Act of God.
I have concerns about:-
1) Following an event causing contamination
1.1 our household health and safety
* we drink water sourced from the Deua
* we consume fruit, vegetables, meat and fish grown in the valleys of the Deua and Moruya
* even in the absence of an event, we will feel constant chronic anxiety about the possibility of such an event, which will increase during extraordinary events such as catastrophic fire danger and extreme rainfall, so adding to what would be already highly elevated stress levels.
1.2 our household budget
* we will be required to share a part of any public costs that may be required to fund activities needed to deal with the consequences.
* we shall be materially affected by any downturn in the local economy resulting from the event.

2) further developments on the site.
* from comments made by the proponent it seems certain that the plant, if constructed would be preliminary to further expansion to what would effectively become a regional processing centre operating far into the future.
* therefore I suggest that more suitable sites should be sought with regard to terrain, vehicular access, provision of utility services and infrastructure, isolation from sensitive and vulnerable natural assets, and habitation.

3) the proponents application.
* which lacks detail with regard to the design, engineering and construction specifications of the plant.
* which omits addressing the likely risks, probabilities of contamination occurring and enumeration of the affects in time, place and magnitude resulting from failures at each and any of the several process stages of the plant.

4) the proponents failure to consider safer alternatives.
* there are less risky/more benign methods of gold extraction available.
* there are far more intrinsically certain engineering designs in common usage.

In summary, it is clear to me that this plant should be constructed at a more suitable site, employing different engineering principles of greater integrity.

Chris Jones,

Tuross Head 2537

Please don't go ahead with the Dargues Reef Mine modifications.

SUBMISSION

ON THE ENVIRONMENTAL ASSESSMENT FOR

THE DARGUES REEF GOLD MINE MODIFICATION

3 MP_10 0054


July 2015


Submission written and prepared by:-

Nicholas Summers NMAS
4 Hawkins Road
Tuross Head
NSW 2537
[email protected]


Introduction

I object to the proposed modification to the Dargues Reef Gold Mine for several reasons. I am a long term resident of the Eurobodalla Shire and work in the Moruya River water catchment which will be directly affected by this proposed modification.

I am not convinced that there will never be spills, accidents or failures of design and operation of the proposed processing plant. History shows that accidents can and do happen.

I am deeply concerned that there is no consideration of the very real risks to the main Eurobodalla water supply. Unity Mining is ignoring the concerns of the community by not adequately addressing the issue of water catchment contamination and the effects an accident could have.

It is very clear to me that the proposed modification presents a pollution risk that is unacceptable and, if approved, will entrench a long term threat to the physical and psychological wellbeing of our community.

In the following sections, I submit detailed concerns for your consideration.


The Proposed Site Is Inappropriate

The proposed site is totally unsuitable for the construction and operation of a gold processing facility using cyanide as a leaching agent. To cite the `safe' example of the Unity mine at Henty, in Tasmania, is misleading as the site there is very different.

The proposed tailings storage facility which will contain waste with a very high heavy metal concentration cannot be guaranteed to last forever which is the proposed life of this facility. Historically worldwide, there have been thousands of failures of tailings ponds. These failures in the past have triggered major pollution events contaminating soil and water and endangering human and animal health.

The EA maps show that the site is on a hill, above a village, on the edge of the escarpment and at the headwaters of the catchment system that provides the drinking water for more than 40,000 permanent residents and several hundred thousand annual visitors.

Toxic contamination of any of the headwaters would be disastrous for the users of this water. Pollution of these waterways would threaten the market gardens, orchards and other agricultural producers that rely on clean water to continue to operate. The main income generator of this region, tourism, would also be severely impacted if even a minor pollution event were to occur.

The proposed site is located in a highly sensitive and important ecological area of NSW and threatens the health and viability of the Conservation Reserves and National Parks that these waters flow through. Rare and endangered wildlife depend upon clean water to survive in their specialist habitats and any pollution event could have irreparable and disastrous results.
There is the real danger that heavy metal pollution could even be carried into the Batemans Marine Park by the Moruya River.

Full consideration must be given to the finding by the Environmental Protection Agency (EPA) that the use of cyanide and the processing of gold on this site will `significantly' increase the risk of environmental harm and damage.

No cyanide processing should be allowed on this site! The modification should be rejected outright.


The Proposed Modification is Inappropriate and Unnecessary

The proponents, Unity Mining, have stated to their shareholders and to the Australian Stock Exchange that the Dargues Reef project will still go ahead if this modification is refused.

They also state in the EA that the decision to process ore on site is a `cost saving' measure. The small rise in Unity Mining's share price is not a good enough reason to risk the health, wellbeing and peace of mind of Eurobodalla residents and their visitors.

The steep and unstable Dargues Reef site is utterly inappropriate for such a high risk construction and processing operation. There are less dangerous, viable alternatives to this proposed modification. The proponents should be encouraged to consider these alternative options and the current proposal should be rejected.


The Tailings Storage Facility (TSF)

The modification, if approved, will allow the storage of dangerous heavy metals and cyanide residues in a 16 hectare TSF, (tailings pond), forever. I repeat, forever. No-one can guarantee that this facility will not fail at some time in the future. This reason alone is enough to reject this proposal outright.

Cyanide trapped in gold mine tailings cause the continuing release of dangerous heavy metal pollutants into ground and surface water. Downstream water used for drinking, agriculture and for environmental uses could become contaminated.

The TSF will be built on steep ground above a village and above a vital water catchment, threatening people, wildlife and industries below. The TSF is located on a drainage line where any breach will likely lead to contaminants draining into the Major's Creek, Araluen Creek, Deua River and Moruya River water systems.

A true and complete risk assessment needs to address all of the environmental risks associated with this `modification'. The introduction of cyanide processing makes the chemical composition of the tailings vastly more toxic than the tailings currently approved.

The EA focuses on cyanide risks but fails to include other chemicals used in gold recovery. Details of the discharge concentrations of all these chemicals and other important information about the likely chemical composition of the tailings need to be provided by Unity, so that a true and adequate assessment of the risks and impacts to the ground and surface waters can be made.
The EA is inadequate as there is no assessment of the risks of heavy metal and/or cyanide contamination in the Major's Creek, Deua River and Moruya River systems. Assessment has not been made of the likely consequences of small and/or large spillages of this toxic waste material downstream of the site.

The risks and consequences of major cyanide or other toxic material spills on the site, but outside the bunded area, also needs to be considered. The inadequacies and omissions of the risk assessment are enough to reject the modification in its entirety.


TSF Failure

There is a wealth of evidence that similar TSF's around the world can and do occasionally fail catastrophically. Unity Mining has acknowledged this risk, (through erosion, design faults or seismic activity), yet has not included these possibilities in its own risk assessment, other than to label the consequence as `significant'! The potential impacts on human and environmental health downstream, should a catastrophic failure of the TSF occur, have not been adequately addressed.

Independent modelling of the likely consequences of TSF failure needs to be included in the risk assessment. I assert that any risk to the future of the region's water supply, however small and unlikely, is a risk too great.


Spills and Seepage

I am not confident that mine owners can ensure safety at all times. There have been at least three sediment spills at this site already. The EPA has stated that sediment and erosion control measures are inadequate. This is another example of Unity not being up to the job.

Unity Mining has significantly underestimated the actual rainfall for the site. Local rain effects have not been taken into account and stormwater levels for this site have been estimated well below actual levels. More accurate modelling has been called for by the EPA and others. Basic mistakes like this by Unity do not engender confidence in their management or operations.

There is minimal allowance for the safe diversion of spill water from the TSF. Spills will flow directly into Spring Creek and into the Major's Creek system. Surely, this is unacceptable. Even occasional minor spills could harm our agriculture and our ecosystem with the slow cumulative build up of toxic materials like copper, lead, mercury and arsenic.

Unity proposes to pump any polluted leakages back into the TSF. This is a short term fix not a long term strategy. Long after the company has gone who will provide the monitoring and management of the TSF, especially if it shows signs of damage or deterioration? This, inevitably, will be a burden to the people of NSW.

Additionally, Unity Mining has not provided adequate information about potential seepage through the TSF liner and the impacts that may occur.

It is impossible to provide a long term plan for the funding and management of the toxic TSF site for hundreds of years. For this reason alone the modification should be rejected.


Economic Considerations

The significant risk to the economy of the entire region far outweighs the few million dollars that Unity Mining promises. Residents across the entire Moruya River catchment depend on the health of their river system for drinking water, food production and for their jobs in tourism, farming and conservation.

The productive Araluen to Moruya corridor totally relies on the health of the river. The livelihoods of thousands are at threat, yet there has been no study of the economic implications, if there is a series of small or one big accident. It would take only one accident or dubious work practice to compromise the region's water supply and the economic consequences of that would be catastrophic.

There is no plan or budget for the monitoring and management of the facility over the long term. There is no guarantee of compensation if, in the future, there is an accident. There is no guarantee that the current proponents will take responsibility if they get their numbers wrong and in twenty years the TSF wall is breached with the obviously disastrous results.

In addition, there are doubts as to Unity Mining's financial credibility and ability to continue as a going concern and therefore be unable to `realise their assets and discharge their liabilities'. Unity Mining is not financially or operationally reliable.

This foolish proposal should be rejected outright on economic grounds.


Unacceptable Company Record

Unity Mining has no real experience of gold mine development. Unity is a very inexperienced player to be managing mining and processing operations of this complexity.

Unity Mining has a poor record of site operations so far, even though it hasn't started mining. There were five separate pollution incidents in six months of operation. Unity Mining was prosecuted in the Land and Environment Court for these breaches and ordered to pay $200,000 in fines and costs. Unity has already caused a great deal of inconvenience to its downstream neighbours and this is before they have started the really hazardous processing operations.

Unity's other operations in Bendigo, Victoria and Henty in Tasmania do not exactly inspire confidence in their ability to safely manage such dangerous operations. In 2014, Unity was fined by the EPA for a spillage at Henty in Tasmania. The Bendigo mine site has stalled at care and maintenance. The promised shut down and remediation is, as yet, undelivered.

With the appalling track record of Unity Mining to date, I have no confidence that Unity will improve its practices. Unity cannot guarantee that this site will be free of spills, mistakes and accidents.


Future Modifications

The original DA allowed the mine to proceed only under strict environmental conditions that included no allowance for the processing of the ore. The proposed `modification' is a fundamentally new and different proposal in its own right and as such Unity should be obliged to put in a new, complete and comprehensive DA.

This proposed modification is an attempt to sneak past public scrutiny by bamboozling with pages of documents and diagrams, snappy press releases and slick presentation with little content concerning the risks to the community or alternative proposals.

To allow the proposed modification could invite further applications at this site to extend processing to ore from other mines, enlarge the TSF or make other risky changes. It may be economically advantageous to Unity to further extend its operations at the site,however, it would not be to the advantage of the community to increase the risks that these potential modifications pose.

Unity Mining and the mining industry in general need to be sent a strong message that `back door' modifications, such as the one currently proposed, will be rejected.


Conclusion

It is unacceptable to risk irreversible and catastrophic damage to our unique and precious environment for the sake of a few bars of gold. Damage to our river systems would be catastrophic to our community and economy.

`Reasonable' community expectations would be that no company would propose to risk our livelihoods and our environment for the profits of the greedy few. It is not reasonable to expose our water supply to long term risks and dangerous unknowns.

There is no guarantee that accidents and spills will not occur. No guarantee that the site will even have the same owners in six months. No responsibility for potential disasters, no long term monitoring to ensure the safety of those downstream, no compensation in the event of a major spill. No proper assessment of risks to the downstream communities and industry.

The only sensible response to the proposed modification is to reject it outright!


Submitted by
Nicholas Summers NMAS

With reference to Project Application number 10 0054 MOD 3 I would like to strongly object. I was alarmed to hear of the proposed modification at the Dargues Reef Mine project given the findings in the GHD review commissioned by the Eurobodulla Shire Council. The risk of a significant environmental impact that will affect surrounding land and water and all living things that rely on them, is surely cause for concern and sufficient justification to block the proposed modification. This is an area of great natural beauty and one that provides for both the local community and the significant number of tourists that visit each year. The knock on effects of the potential damage caused by this proposal, were it to be approved, would be detrimental to the social and economic fabric of the area as well as well as posing a worrying risk to human and wildlife health.

Unless the people of NSW and its Government want to close down all mining, they desperately need to demonstrate their desire for mining companies to continue to operate. The current political climate is certainly not supporting the Industry, over regulation and onerous conditions have made it impossible to raise finance for projects. My own investors have recently made a considered judgment to no longer invest in any NSW based projects until the climate improves, Sad because we have now walked away from two certain developments that would have generated several hundred jobs and ~ $300M in revenue.

I think it's too risky to allow this company to use cyanide to extract gold at Majors Creek. We don't want even the slightest chance of having our precious rivers poluted.

I disagree with the gold mine development due to the existing evidence regarding the use of sodium cyanide as contamination of waterways cannot be guaranteed.
the resuling heavy metals is also a contaninate that can polute the surrounding land and waterways.

I am a resident of Moruya, downstream from the Dargues Reef Gold Mine. Like most residents of Eurobodalla, I rely on the Deua River for my drinking water and I also use the river to swim and canoe. The proposal to use cyanide in the processing of gold and the resultant heavy metals tailings stored indefinitely on site pose unnecessary risks to the river water quality.
This is not a suitable site for processing ore using such chemicals. Any pollution from the mine threatens recreational users of the river, the farmers who have orchards or market gardens along the Deua and people who eat that produce or rely on the river for drinking water.
The river passes through the Deua National Park which is a sensitive environmental area, where wildlife should be protected from industrial pollution.
I object to the increased risk from this proposal as the original approval forbade the use of cyanide or mercury for processing the ore. There is no necessity for ore to be processed on site and the original approved application was for off site processing away from this sensitive area.
The steep site of the tailings storage is a problem given the heavy rainfall which can occur in this area. This is not a suitable location for permanent storage of dangerous wastes.
I am concerned that Unity Mining has objected to siting the processing facility in the nearby Shoalhaven River catchment as that is within the Sydney drinking water catchment and they would be subject to additional regulatory requirements. The facility should not be within any drinking water catchment, whether for Sydney or Eurobodalla.
The Environmental Protection Authority has stated that the use of cyanide and the full processing of gold at the Dargues Creek mine site has increased the risk of environmental harm.
Heavy metal pollution from the mine could harm the Deua River and the Moruya River all the way to the Batemans Bay marine Park.
Unity Mining has not so far operated the mine without accidents. There have been five pollution incidents during their six months of operation. The Land and Environment court which fined them over $200,000 held that the pollution was preventable had adequate precautions been taken. I have no confidence that Unity is able to handle much more dangerous materials if they are allowed to operate using cyanide.
Should Unity be granted approval to process gold on site using cyanide, it is likely that a further application will come to process gold from other mines at this environmentally sensitive site.
I object to the proposal and ask that it be refused.

Use of cyanide to complex Au, making it soluble, is banned in many countries. Australia should do the same. Due to its toxicity, sodium cyanide present in waterways will kill all life present.

As well, CN ions in tailings will complex with other metals which have been brought to the surface in finely crushed ore. These will contain heavy metals such as mercury. There seems to be little in the EIS to control levels of these toxins.

Removing CN from tailings completely is impossible. There will be at least 50mg/L remaining. This is sufficient concentration to cause problems downstream.

Water use is another problem, local streams will dry up as they have around the Cadia gold mine n ear Orange, NSW, even though the mine EIS stated that this would not happen.

I have worked in the mining and energy areas of the Departments of Resources and Energy, Trade and Resources and Primary Industry and Energy over a 40 year period. Those areas covered foreign investment, industrial relations, infrastructure, environment, heritage, taxation, export approvals and the like.

Over that period of time I have seen many examples where mining practices have resulted in environmental degradation, whether through deliberate action or by accident.

With climate change the chances of an environmental accident have increased markedly and we have already seen a number of breaches by the company running the Dargues Reef operation. I have little faith that the company would be able to handle any major problems with climate change, that it might take short cuts in the production process and that it reinstate any damage caused to the environment should the economics of its operation change with, say, changes to the gold price which is outside its ability to control. Larger enterprises, such as Orica, have on numbers of occasions breached their environmental conditions. The same goes for some Western Australian gold mining enterprises where the original proposer for the mine originated.

The Araluen Valley is too important to take risks with and the supporters of the mine seem to base their support on money and employment grounds alone. As far as I am concerned this is a short-sighted approach which could result in disaster for the local community.

I suggest that those examining the proposal research thoroughly other mining operators (not just gold miners) to see what kind of difficulties they faced and whether they succeeded in meeting the terms of their license especially in relation to the environment and the reinstatement of the mine site after production had ceased.

Perhaps one could also examine the most recent mining related problem suffered by OK Tedi Mining in PNG as a result of a wall collapse. In my experience these kind of things happen regularly and I would hate to think what an accidental discharge of arsenic or any other chemical or pollutant would do to the local community and the good folks of Braidwood and surrounds.

Ric Hingee

Submission on EA for the Dargues Reef Gold Mine Modification 3 MP_10 0054 MOD 3 July 2015

Background for submission

My Araluen Road property has river frontage along the Deua River. I own and lease out two holiday rental cottages, Bakers Flat Cottages, at this location. The holiday accommodation is successful due to its location on the river, offering amenity to guests. Guests use the river for swimming, boating and fishing, and enjoy the wildlife and flora associated with its location. Water is also pumped from the river and used for drinking water on the property. It is the riverfront location that attracts customers to my property for their holidays. I am also intending to become resident at this property in my retirement.

As such, any risk to the quality of the water supply to my accommodation business and the environmental amenity of my property is unacceptable to me.

I am also deeply concerned about the long term affect on the environment, and on farmers, businesses and residents in the downstream catchment. I feel it is unacceptable to leave such an enormous amount of cyanide processed waste, contaminated with toxic chemicals and heavy metals at the processing location forever. Should there be a catastrophic failure of the TSF, it poses an unacceptable risk for many generations to come, in return for short term financial gain for Unity and for the townships of Majors Creek and Braidwood.

I object to the Dargues Reef Gold Mine Modification 3 on the following grounds:

Unreliable history of Big Island Mining PL regarding Dargues and Henty mines

* Big Island Mining PL failed to secure an ore processing facility in advance of seeking original approval for Dargues gold mine, exposing the fact that they had not properly researched their proposal. The mine has since been unable to secure ore processing at two separate localities, because the communities in both of these localities rejected CIL processing using cyanide. These communities, like ours, are not prepared to accept the legacy of the toxic waste which would be left in their environment forever.
* As stated in the EA by Corkery and Co. July 2015, inadequate erosion and sediment works in the initial bulk earthworks phase of the project resulted in a failure in 2013, polluting Spring and Majors Creeks three times. Unity was fined a meagre $200,000 by the EPA for its breaches. Enforcement and penalties do not provide enough deterrent to change the mining culture of it being cheaper and easier to breach and pay the fine than to spend money installing failsafe infrastructure.
* One of the key commitments of Cortona when granted original approval for gold mining at Dargues was that no on site processing of gold ore would ever occur on site. They have broken this agreement showing that they are a deceitful company that will continue to seek to break commitments whenever necessary to increase mine revenue.
* Unity uses the Henty mine as its flagship model, however Henty was not constructed by Unity. Since Unity took over operation of Henty, Unity was fined for a spillage and had no contingency plan to deal with this environmental breach.
* As such the environmental record of this mine is considerably tarnished, resulting in a lack of faith in Unity by myself and the Deua River community, and we continue to be at risk of environmental breaches regardless of promises made by this company.

Ore processing at Dargues Gold Mine poses unacceptable environmental risk forever

* Carbon-in-leach (CIL) processing using cyanide is environmentally hazardous from the moment the cyanide is brought onto the mine site. CIL processing using cyanide means the mine site will pose a risk to the surrounding environment and community should there be any accidents or extreme weather events causing toxic chemicals and waste to be released into the surrounding environment.
* No community wants a toxic processing facility in their locality, let alone a processing facility being located at the headwaters of an important water resource catchment.
* If CIL processing using cyanide approval is granted, then it stands to reason that other gold mining companies will seek to transport their ore to Dargues for processing. In the Chairman's Address to the AGM in 2014, it was clearly stated that it would be irrational for Unity to restrict the use of its proposed processing plant to just one mine.
* This will mean increased truck movements in and out of the facility, negating Unity's statement that processing on site decreases the environmental impact on the area by stopping truck movements taking ore off site for processing.
* Once the site is mined and rehabilitated, I have little faith the site will be properly monitored so that there are no environmental breaches affecting generations to come.

The application for the Tailings Storage Facility (TSF) should be a new DA

* The GHD report engaged by ESC has shown that the proposed TSF in Mod 3 is in fact an entirely different type of tailings dam and liner to the one originally approved, presenting significantly higher hazard over a longer period of time. It is essentially a new piece of infrastructure.
* As such a new DA should be required for this part of the modification application, so the modification application should be declined on this basis.


The new TSF is an unreliable storage facility

* CIL processing using cyanide also uses other chemicals, and mobilises heavy metals from the ore. This processing method would significantly increase the toxic content of the resultant waste which will remain in the TSF forever. This toxic waste dump poses unacceptably increased risk to the environment in the event of any type of breach of this facility in the foreseeable future.
* The storage of these toxic waste materials in the TSF becomes a generational problem. There appears to be a lack of understanding by Unity of the long term risks associated with this TSF. Research conducted by Dr Peter Beck of GHD shows that the engineering of the TSF may not be adequate to contain the waste for the 100 to 200 years that it will take before the risk of contaminants dissipates.
* Extreme weather events are becoming more common and unpredictable worldwide. Whilst the construction of a significantly larger TSF than in the original mine proposal is in part to accommodate extreme rainfall events, these will still potentially cause a breach of the TSF. This will result in toxic runoff into our important catchment of river systems used for agriculture, tourism and drinking water.
* Corkery and Co. have acknowledged in their 2015 EA that leakage of leachate from the TSF will occur. The research into the effects of this toxic leachate on the environment when the seepage collection systems are no longer operational is inadequate, and poses unacceptable risk of groundwater contamination.
* I am not satisfied after reading the Corkery and Co EA that the TSF liner is sufficient to withstand soil movement without serious breach of the membrane, or that the clay liner barrier will not erode. This exposes unacceptable risk of toxic leachate moving into subsoil and into the groundwater. The question then becomes where this contaminated groundwater will end up.
* As stated in the EA by Corkery and Co. July 2015, The Deua River has a high level of amphibian diversity, and also terrestrial diversity of reptiles. I believe this diversity would be reduced in the case of a major failing of the TSF, and possibly through constant short, medium and long term leaching of toxic materials into the subsoil and groundwater.
* I don't believe that in the case of catastrophic failure of the TSF, that the catchment waters would ever fully recover its diversity of aquatic life over time.
* Catastrophic failure of the TSF has not even been considered in the Corkery and Co. July 2015 EA. This is an appalling omission considering the potential impact of such a failure, and shows the company is not serious about its responsibility for environmental protection.

Summary

Big Island Mining Pty Ltd has failed the community by inadequately investigating their proposal for processing ore at Dargues gold Mine.

This modification should be refused for many reasons, primarily the following:

* Locating a large a tailings dam which will hold toxic waste forever, at the top of an important water resource catchment, poses unacceptable risk through leakage, breach and failure to the catchments human, floral and faunal communities.
* Unity has failed to undertake any risk assessment into a catastrophic failure of the TSF. This is a gross failing of Unity, considering the devastating effects on the downstream communities, including poisoning 60% of the water supply to the Eurobodalla Shire. This fact alone should be reason enough to dismiss this application out of hand immediately.
* The new TSF is not a `modification' to the original DA. It bears little similarity to the original approved TSF except location.
* Should the Unity Mining modification for gold processing on site be approved, Unity has stated that they would be open to processing ore from other mines. My fear is that this would lead to many more mines re-opening in the area, and ore being bought to Dargues from other mines, resulting in further modifications sought for expansion of processing facilities at Dargues. This would further increase risk of hazard to our environment.
* Unity has not conducted sound risk analysis for their TSF, and in particular have shown a lack of understanding of the long term risks of failure of contaminant storage facilities on site.
* Unity Mining has stated that the mine is still economically viable without approval of this modification. As such the increased risk of catchment contamination for hundreds of years does not justify the cost benefit to the company and surrounding towns.

The government must take responsibility for water security and environmental integrity in the catchment downstream from Dargues, by not approving gold processing on this site. To grant approval for this modification would be a dramatic failure of due process. Long term detrimental effects of environmental breaches before, during and after CIL processing using cyanide have not been properly researched in this application and pose unacceptable risk to our community and environment.

Thank you for the opportunity to comment on the changes proposed to the Dargues Reef Mine development. I am making a personal submission in objection to these changes.

I was born and raised in Majors Creek. My parents have lived there, on the same property `Yooralla' for 38 years. I was raised as an only child and have often said that Yooralla is itself like a family member. I was recently married at Yooralla with wedding rings made out of a tree that grew on the ceremony site. I visit regularly. Suffice to say my connection to Majors Creek is deep and enduring.

As I understand it the existing approved development involves all the toxic heavy metals and sulphides being removed from Majors Creek with the gold, to be taken to Parkes for final processing . This is relatively safe for Majors Creek and would not be likely to contaminate the water supply since the tailings dam remaining would be very much less toxic and no cyanide would be involved.

Introducing cyanide processing turns this mine into a HAZARDOUS mine placing many people and the environment in danger with the transportation, storage and use of cyanide in Majors Creek all causing potential danger. In addition the toxic heavy metals and sulphides released by the processing remain dangerous forever and must be contained in a tailings dam. This dam must last forever if the water and environment are to be safe, but the dam will not last forever, posing a continuous threat. If this processor was placed on the other side of the hill it would be in the Sydney water catchment area and not be allowed. Why is the water supply and that of all who live in Majors Creek and along the river system of any less concern?

When Unity Mining bought the gold mine they publicly announced that they would also NEVER use cyanide or undertake full processing of the gold in Majors Creek but would adhere to the conditions already in place in the development and the conditions placed upon it by the Land and Environment Court. However, they suddenly changed their mind and without any consultation with residents decided to apply for modifications to do precisely this.

It surprised me that it was even legal for them to do this. The prior agreement that was painstakingly negotiated appears to mean nothing. Unity Mining cannot expect people to trust them after this kind of maneuver. I believe that Unity Mining do not, therefore, fulfill the requirements of social license to operate. There is no compelling reason to fully process the gold in Majors Creek in such a treacherous situation, with contaminated water able to reach residences in Araluen in less than 10 minutes, because of the steep incline and the waterfall. In the event of an accident there would be no time to alleviate the problem and the release could easily cause death to a child playing in the creek below, let alone the damage to animals and the environment.

I happen to believe that these kinds of risks are not worth any number of jobs. However, as "jobs" appear to be the only argument Unity Mining puts forward in favor of the changes I feel compelled to comment. I understand that the difference between the development as it stands, and the development with the proposed changes is 20 jobs. This is a small mine. How long will those jobs even be there? The cyanide will be there forever (well until the damn inevitably breaks). How many future jobs and business will not exist if these changes go ahead? Who will want to invest in agriculture along a watercourse with a toxic tailings dam up stream? Who will want to invest in any kind of enterprise that relies on the health of the water? These jobs will come at the cost of jobs that are longer term, sustainable, and will contribute over time to the economic health of the areas concerned.

My partner and I have long term plans to make the most of what we love about Yooralla and Majors Creek, to share it with more people and change lives. We hope to one day live there ourselves and run a small NFP recovery service and social enterprise. We would certainly not be prepared to undertake such a venture under the shadow of a cyanide tailings damn and the associated risks. I love Majors Creek and as such I was to see it thrive- social, economically and environmentally. Unity Mining has no such interests. We are not stupid.

I urge you strongly to consider the terrible dangers and idiocy inherent in this proposal and ask you to refuse this application.

Yours Faithfully,
Bess Harrison