Mod 3 - Processing & Tailings Storage

The use of Cyanide is a proven technology and has been safely handled within the Australian mining industry for years. Provided the correct procedures are developed and followed (the purpose of safe work procedures and environmental impact studies). It will pose no danger to the down stream water supply. As a down stream resident I hold no fears for its use at the mine and welcome the future job prospects for the area as well as the continuation of the gold mining history of Majors Creek that started in 1851.

I am writing to express my great concern regards the proposal by Unity Mining to incorporate cyanide processing on site at the Majors Creek (aka. Dargues Reef) gold mine, in contravention of its prior conditions of approval.

I hope that your foremost priority is to do the utmost to protect the short-and-long-term health of the environment, our water supplies as well as the residents and local businesses who are threatened by this proposed development.

I have read reports such as:

- Canberra Times, August 19, 2015: "Cyanide at Majors Creek gold mine poses health risk for coast: report... Four tonnes of cyanide waste from a gold mine would accumulate long term in a tailings dam above a South Coast water catchment, and it was not a matter of if the tailings dam would leak but when, says an environmental scientist... The catchment provides drinking water for 40,000 permanent residents, and up to 100,000 people during the summer holidays..." http://m.canberratimes.com.au/act-news/cyanide-at-majors-creek-gold-mine-poses-health-risk-for-coast-report-20150819-gj2dkd.html

- ABC News, August 3, 2015: "Majors Creek gold mine: Historic orchard uprooted amid fears of toxic mine runoff... Melbourne-based Unity Mining has New South Wales planning approval to operate a 450-metre deep gold mine at the Majors Creek site, in an area renowned since the 1860s for its rich gold reserves. It planned to transport the ore to a second facility for processing - however the company now wants to incorporate cyanide processing on site, in contravention of its conditions of approval..." http://www.abc.net.au/news/2015-08-02/dargues-reef-gold-mine-fears-over-toxic-mine-runoff/6654480

- "Unity Mine cyanide proposal threatens Araluen Valley..."- http://24h.net.au/top-stories/unity-mine-cyanide-proposal-threatens-araluen-valley-says-author-jackie-french/

- "Draft report raises major concerns about proposal to use cyanide at south east mine..." - http://mobile.abc.net.au/news/2015-08-21/mine-report/6713182

- ABC News August 24, 2015: "Palerang Council vows to fight plans for proposed gold mine amid fears of cyanide contamination..." - http://mobile.abc.net.au/news/2015-08-24/palerang-council-vows-to-fight-dargues-reef-gold-miners/6721276

Yours Sincerely,

Robert Ryan

I strongly object to Dargues Reef Gold Mine project modification.
When approval was first granted for the mine the Company categorically assured the community that no processing would occur onsite. This proposal destroys that assurance and community trust.
No environmental assessment of the effect of a failure of the tailings dam has been made to the Deua River catchment which provides fresh drinking water to Eurobodalla Shire. It is a basic right for the community to have fresh, reliable water, now and for future generations. The Deua River is part of the Deua National Park, and flows to the ocean into Batemans Marine Park, and needs to be safeguarded.
Tailings dams have a history of accidents around the world, and spill a toxic cocktail of sludge and heavy metals with devastating effect to the environment of rivers downstream from such dams.
This modification should have the requirement of a new DA and EIS, not a limited EA.
I therefore urge the Minister for planning to reject this modification proposal.

I have owned a property on the Deua River for more than 30 years. Although not living on the property permanently my family have enjoyed the pleasures of the pristine Deua during this period. The water is crystal clear & unpolluted. This valuable natural resource needs to be protected from the contaminates that will eventually find its way into the Deua. The mining company has shown that it cannot be trusted & admits that they have no "Plan B'" should there be an unexpected accident to the holding dam eg. flooding, earthquake.
I therefore urge you to deny Unity the right to use cyanide at their mine.

N.S.W. DEPARTMENT OF PLANNING

Submission on Project Number 10-0054 MOD 3.

Modification 3 of Big Island Mining at Dargues Reef, Majors Creek

I thank the Department for the patience and persistence evident in its professional consideration of plans and modifications put forward by successive proponents of this long standing project.

My comments on some aspects of Modification Nr. 3 concern the administrative process and some technical aspects, The latter draw chiefly on the excellent recent report by Dr P. Beck of GHD Pty Ltd, which is free of commercial obfuscation and ambiguity, as well as my own experience over sixteen years in research project management in the U.K. With R.T.Z. / Borax as then was.

Background - Promises and Social Licence
I do not support the proposed modification , which includes the use of cyanide in whatever form to process gold at Majors Creek. As the Report by Dr Beck points out, processing with cyanide would lead to hazards including the dissolution of heavy metals such as lead, arsenic, antimony, and others present in the sulphide ore. The proponent had used cyanide at its Kangaroo Flat operation in Bendigo, which had been polluted through cyanide use by others over many years previously, and requires sustained pumping of effluent to avoid flooding . The proponent was also unable to exercise an alternative processing option, which was to use the cyanide leach facility at Victoria Parkes, owing to a legal challenge there.

For its hearing in 2011 to consider Cortona's operation the PAC had been told that Cortona would not use cyanide at the Creek because of community concerns about likely leaking from the dam. In fact these concerns were not limited to leakage alone. Subsequently, Unity announced to the Majors Creek community on 11 November 2014 that it would not honour the assurances given by it and Cortona that cyanide would not be used at Majors Creek. In so doing it forfeited its social licence.

Approvals Process - Hostage to the Past
As is known, a site for mining requires a significant financial bond for safety and related remedial work when no longer economically viable; as well as increasing over time through sustained deterioration and degradation both physical and chemical, such work may be constrained by the prospect of the mine re-opening as ore discoveries or prices grow. Since the interest cost of the bond and of any urgent remediation could be more favourable as a tax deduction when the owner works elsewhere there is effectively a potential for a subsequent mine approval to be granted to encourage work at a former site. The approvals process is then in effect held "hostage" to the past or, as less tactfully described by other commentators, is a "Ponzi Scheme."

PAC and Proponent's Budget
In its recommendation on the extension of the Bulga Middlebrook coal mine operated by Rio Tinto the PAC recommended moving the village, which is obviously costly and unusual. But maybe within the budget of major multinational. This is perhaps of concern to the extent that this and other PAC recommendations may reflect the liquidity of the proponent, and especially more so in a converse situation where the proponent may have limited resources.

Noise and vibration impacts
In documents prepared for the proponent on this subject previously, surface noise measurements were overlaid on old maps of the Creek that showed the original 'paper roads', and therefore gave a potentially misleading representation of where mine noise would be of most nuisance. It must also be emphasised that the transmission of noise and vibration through sub surface strata of varying density and elasticity is complex and difficult to predict. For this reason it is no coincidence that several residents on the line of major former mine workings have experienced noise and vibration nuisance despite their distance from the mine site, which has not adequately been acknowledged. It is also important to recognise that noise nuisance has a subjective component, evidenced by the irritation caused by a dripping tap at night. In this context acceptable urban noise levels should not be applied at the Creek, where at night in particular there is extremely low noise background. This observation is not novel, and is recognised in basic acoustics work. In relation to the crusher there has I believe been work on active silencing, which is particularly suitable where noise signatures are relatively constant.

Effluent Dam - Tailings Storage Facility (T. S.F.)
Visitors to the mine site have been told that the presently designed TSF will meet design criteria including withstanding ingress by a crashed medium sized aircraft. More realistically leakage through, rather than over the wall, from e.g. burrowing by wildlife could eventuate, leading to failure. Although the present design and location approach the ludicrous, it may be that the T.S.F as presently proposed in a location at at the head of a gulley, above a crucial water catchment, with a wall in large extent approaching 35 metres, and linings of questionable physical and chemical durability has been put forward as a basis for further improvement. This would be a charitable interpretation, recognising the proponent's primary fiduciary responsibility to shareholders. Failure of TSF dams from gold winning and containing inter alia cyanide residues has occurred worldwide with very serious consequences, especially after ad. hoc. modifications to increase the capacity of an otherwise professionally guaranteed design. Tailings contain a mixture of chemicals which make it difficult to predict the action of them or their reaction products. In particular it may be critical if there is embrittlement of the plastic liner by leaching or reaction of the plasticisers in it.

Majors Creek Climate, Tailings, dust suppressants, and smelter dust
Majors Creek frequently has heavy, pervasive and long lasting mists. At the mine site they both reduce visibility and blanket dams including the tailings . There is therefore I believe valid concern over the possibility of particulates and dissolved solids being carried form the tailings in a smog or other colloidal dispersion and subsequently deposited on roofs collecting rainwater. Mention has also been made of dust suppressants, in the context of mine dust settling on roofs. Since these are typically quaternary amines and related organo-nitrogen compounds they too present a risk, although some have been tested for carcinogenicity. For the safety of water supplies in Majors Creek and the locality it is imperative that efficient dust settling is effected and monitored.

Treating the Tailings
Unity has advised that it is unlikely to re-commission the reverse osmosis equipment that was included in its Bendigo acquisition. There are however many other established methods likely to decrease the level of contaminants in tailings water including ultra-filtration/reverse osmosis, and also perhaps, electro-dialysis and possibly solvent extraction with a centrifugal [ Podbielniak ] unit. Amongst gold producers Bracken Resources in NSW has used reverse osmosis / ultra filtration to substantially clean their effluent at Hillgrove.

Foreign investment and the uncertain risks of tighter regulations.
Were Unity to seek overseas investment for the mine it will be crucial for regulations to be set initially at a level that need not be increased later. If Australia became party to The Trans Pacific Partnership (T.P.P.) trade agreement, its present provision for Investor State Dispute Settlement ( I.S.D.S.) could allow an overseas investor to seek damages if, having invested, new or increased regulations could be proven to have reduced the profitability of its investment.

Representation
Sadly, Majors Creek Progress Association (P.A.) has not permitted discussion of the mine at its meetings. For this reason our P.A. should not be taken to speak on the mine as representative of the residents of Majors Creek and nearby.

In conclusion.
Most of the concerns raised here, as well as by others, and in the Report by Dr Beck are especially evident in the post-remedial status and effects of the Captains Flat mine and its dam, which has been capped similarly to plans for Dargues, and from which the leaking contents have made grass unsuitable for grazing locally, and are still passing into Lake Burley Griffin via the Molonglo River.

The RRR Garlic of Majors Creek, is part of a rapidly expanding new Garlic growing arigcultual industry of Braidwood. This is our fifth year in production, developing our business plan to export to mainland China.

In the GHD report at point 6.1.1 headed, advice of risks associated with cyanide operation at the site, and I quote in part

"The most significant consequences of a small scale cyanide release would probably be community concerns AND REPUTATIONAL DAMAGE DUE TO PERCEPTION."

MY organically grown garlic already has a reputation of being Green and Clean organically grown, superior garlic. My major customers are Hong Kong, Chinese.

These clients are already, after mainetream media exposure, asking if my garlic is safe! And the Dargues Reef site has not started production!

Australian Grown Garlic is hard to purchase, we cannot keep up with demand in Australia and our export plans will be under threat if Unities Modifications to process on site are allowed to proceed.

Where do you want your food grown? Who is going to compensate me for the loss of my business reputation. Or will I be forced out of the garlic growing business.

I have not gone into detail about Unities constant lies, manipulation, misinformation to shareholders, media and community, this is well documented. I just ask the authorities not to be made fools of and rubber stamp a submission that is dangerously flawed on every level. Consider, the companies balance sheet, Unity does not even, now, have the funds to remediate the land they have already worked on.

I'm writing to voice my objections to the proposed modifications at Dargues Reef mine. Even if we weren't to acknowledge the recent slip up at this site and the environmental damage caused, the risk of building a cyanide based processing plant adjacent to a water source which is vital to the survival of the Braidwood residents, Canberrans and the habitat of local wild life is too high.
My family, many friends and I have crops which rely on this water to be drinkable because we eat and sell food grown on this land. Safety measures around managing toxic substances are certainly less wise than not using them at all.
A fine for a spill is a short term hurt for shareholders in a corporation. A cyanide spill is a lasting and devastating disaster for the local environment. Let's push towards innovation for cleaner solutions to extraction.
I hope you will consider the long term impacts and find the continued viability of healthy land to be more important than short term fiscal profits.

Warmest Regards,

Ali Goward.

I have serious concerns regarding water safety and impacts on local populations and the environment. I urge you to disallow this expansion.

Proposed Dargues Reef Gold Mine - Modification
I am a landowner in the Deua River Valley.I am terrified of the ramifications of a failure of the tailings dam on our water supply,agriculture etc.There is mention of a spillway construction to safely convey "water" from the facility to Spring Creek in the event of uncontrolled discharge.Spring Creek is part of the Deua River Catchment.A matter of concern to me is also what happens with the dam after mining has ceased,who will monitor toxicity levels and any contamination in the following years.

I am writing to express my objection to the proposed modification, on the grounds that cyanide processing is not suitable for the site, and the establishment of a cyanide processing plant may be the first step in a series of developments that will dramatically increase the impact that the mine has on the Majors Creek Community.

My submission is in support of the Dargues Creek Mine. The Braidwood District is in dire need of employment opportunities for people from all skill levels. Instead of people and shires taking the "not in my back yard"principle to any development how about supporting employment, better roads, better wages, vibrant town including new shops. Mines bring new life to existing industries, fuel suppliers, hydraulic hose repairers, vehicle repairers just to mention a few. I have had a first hand site inspection of the Dargues facility which I urge all to take. This will allay many of the fears people may have about spillages. Future is bright for this facility with support.

I submit the following information in support of my objection to these modifications being approved. I am particularly concerned about the use of cyanide in Majors Creek above a watercourse that supplies water for domestic and agricultural use all the way to the coast. I cannot conceive of any argument that would deem this to be an acceptable risk. I have friends and family members who live and farm in this area.

It is my understanding that when Cortona Mines proposed to mine Dargues Reef, it was established that no cyanide mining would ever happen here, and nor would any open-cut mining ever be undertaken. On this understanding and with some misgivings the members of the community were generally prepared to accept the proposal, aware of the fact that almost all of the toxic heavy metals and sulphides would be removed with the gold to an existing cyanide processing plant in Parkes or elsewhere and assurance that our tailings dam would be relatively inert, and therefore safe.

It is therefore surprising and disappointing that these modifications have been proposed and it is my hope that they will be rejected.

Submission on EA for the
DARGUES REEF GOLD MINE MODIFICATION 3 MP_10 0054 - July 2915


I object to this modification of the Dargues Reef Gold Mine DA

The proposed modification creates an unacceptable risk of environmental pollution leading to loss of plant and animal life and pollution of the water ways and water supply. This risk will be both immediate and very long lasting, and will most likely increase over time.

The site and its position in the water catchment is completely inappropriate for a processing plant that uses toxic materials.
The site is on an escarpment which, like all escarpments, is subject to continuous erosion. Basic geography teaches us that higher ground is eroded by water which carries the materials down hill via creeks and rivers. The erosion might be slow under normal conditions but it is unstoppable, and eventually the mine site will be effected. By then the mine might not be operating, but its legacy of gold processing will still be there.
In addition, the site is subject to heavy rainfall events which, at any time, could flood the ponds and cause them to overflow and carry toxic materials downstream.

The public interest
Section 79C (e) of the EP&A Act requires consideration of the public interest, that is, the weighing up of the benefits and detriments to the public of the proposed development. In such an assessment the private benefits and detriments are excluded from consideration.

The public benefits of the proposed development are minor. They include some jobs, some economic growth, and perhaps an enhanced balance of payments.

The public detriments of the proposed development are significant. They include the risk of widespread environment damage via waterways from the escarpment to the coast and beyond; loss of livelihood to farmers, agriculturists and other using the waterways; decline in tourism and the livelihood of those dependent on tourism. The loss of public confidence in the safety of drinking water after each major rain event will also damage the mental health of the community.

Conclusion
This proposal constitutes an unacceptable risk to the public and in not in the public interest.

I STRONGLY OBJECT TO THE CYANIDE PROCESSING AS PROPOSED. THE POTENTIAL LONG TERM RISK TO THE COMMUNITY AND ENVIRONMENT DO NOT BALANCE THE SHORT AND MEDIUM TERM (THERE ARE NO LONG TERM) ECONOMIC BENEFIT TO THE COMMUNITY.

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I regularly visit the Deua River and Moruya. I have family there so although I'm not resident in the area I have been in the past and may again in the future.

I strongly object to processing the ore on-site. To do so would add unacceptable risk with huge consequences from a toxic leak for many generations. This is reflected in the GHD report recently presented to the local councils. So many people downstream rely on that water, not to mention the environmental and recreational value of that river.

The liberation of further toxic heavy metals in the processing further extend the risks. The transportation of dangerous chemicals and possible transport of off-site ores to be processed on this site also add risk to the local communities.

I struggle to believe that such a risky development could be approved. If it is, the requirements, safeguards and standards must be so stringent that the risk is absolutely minimal. To a layman, from what I have seen this is not possible, there are too many single points of failure and the risk has to be managed well beyond the mine has passed it use or the company gone broke.

This company also appears to act as many do; with a foot in the door (the mine approved based on processing off-site and heavy compliance) the conversation changes to onsite processing and in the application, diluted compliance on the original application. As a company it has to try to make money for its shareholders, and minimising compliance costs is part of that.

Watching this issue over the years I expected the Braidwood community to be divided but from the recent council meeting it seems there are few willing to speak for this development. Of course downstream there are no benefits and only risks from the mine and its expansion into on-site processing. There is real potential for significant drops in real estate value downstream if this application is approved. Some may just sell to move to a location where they can farm and enjoy their place without the worry of what may be in the water or what may happen after an incident upstream.

As a society we have a responsibility to preserve and protect as much of our environment as we reasonably can, to approve on-site processing poses such a risk to so many and to such a pristine water course it is difficult to believe it could be considered.

One day such approvals could be given as examples of where we lost what was once one of NSW's cleanest rivers.

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

I am appalled and outraged that, 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. Water is far more important than gold
It is clear that the proposed modification creates a pollution risk that is unacceptable to residents along the entire Moruya River catchment. The potential cost to the community and visitors is too great and Unity is ignoring the threat to our well-being.
The EA maps show it is on a hill above a village, on the edge of steep escarpment and at the
headwaters of an important river system. Spring Creek, Majors Creek, Araluen Creek, and Deua/Moruya
River are all used for domestic water supplies and agricultural purposes
Pollution in these waterways would threaten the orchards and market gardens of the Araluen Valley and
the water supply to Eurobodalla Shire.
The Environment Protection Authority (EPA) agrees that the use of cyanide and full processing of gold
on the mine site has significantly increased the risk of environmental harm.
It is also located in a highly sensitive, biodiverse area of NSW, and threatens wildlife drinking the water
in Conservation Reserves and National Parks. Heavy metal pollution could also be carried into
Batemans Marine Park by the Moruya River.
It is totally unacceptable , please show common sense
Jane Anderson

August 26, 2015

SUBMISSION OF OBJECTION TO THE NSW DEPARTMENT OF PLANNING AND ENVIRONMENT
Dargues Reef Gold Project (10_0054).
The proposed modifications are known as Dargues Reef Mine Modification 3 (Mod 3)

I, Mark Katte object to the proposed Modification 3 at the Dargues Reef Gold Project as submitted by Unity Mining Ltd and its subsidiary Big Island Mining Ltd.
As a long term (10+ years) land owner in Majors Creek I have great concerns with this proposed modification, both for my own health and safety and that of the effects on the greater community. The applicant has a track record of multiple environmental failures and has been fined numerous times for breaches of their current operations. Just saying that what is proposed will be done to the guidelines is not enough.
The Majors Creek Catchment Guardians, of which I am a member and the local communities from Majors Creek through Araluen and down to Moruya are extremely worried that in the use of cyanide, there are no second chances.
What is of major importance is that the "life of the mine" being proposed until 2022 is not the same as the ongoing risk long into the future. The greatest risk will in fact be after the mine has ceased operations and how the site be managed and monitored then .With a life expectancy of the Tailings Storage Facility between 30 and 300 years, at some time between 2045 and 2315 there is 100% chance the Tailings Storage Facility will fail and a catastrophic disaster will ensue. Once the damage is done we cannot go back.
We all have a social responsibility to the community,to not cause any harm, to the area in which we live, work and socialize.This proposed modification will create noise and air pollution,as well as damage to the environment,including poisoning of waterways affect native animals, people,livestock and peoples livelyhoods. If it is approve to operate 24 hours a day there will be no respite for anyone who lives in the valley that is a large part of Majors Creek.
As a resident of Majors Creek, I am deeply concerned about the validity of this project. In my opinion the proposals present an increased environmental risks associated with transportation of hazardous substance, on site storage of these substances and also the proposed TSF that will now house concentrated toxic tailings containing heavy metals. The proposal is contrary to the objectives of the original approval and as such should require a new Development Application.
In closing I feel this application should be wholly rejected base on the fact that UML has shown no regard for the community or environment in the past, so clearly cannot be taken on their word to do the right thing into the future. Who will pay the real price if and when (based on the history of UML at this site) there is any type of failure, be it now or long after operations have ceased? How can we be certain that our water is safe to drink or use to water our vegetables? Our air is safe? Not just today but for future generations.

Mark Katte

Majors Creek resident

I do not support the Modification 3 proposal, because it enhances the possibility of negative impact to the local environment, including the rivers, the land and the local farms. I don't think the risk is worth the reward for the company. If businesses can't maintain their integrity then what hope do they have of maintaining the level of risk to the environment.

Its time that the decision makers took a look at what is best for the greater communities and put themselves in the locals shoes. Would you want toxic particles landing on your roof to wash into your only water supply. Would you want an arsenic filled dam to leach into the environment and poison the land and water. Would you want 24hr background noise going while you try to sleep a couple of kilometers away. I know I wouldn't.

I do not support the Modification 3 proposal, because it enhances the possibility of negative impact to the local environment, including the rivers, the land and the local farms.